This report reviews definitions of extremism used by governments in countries other than Scotland. This section provides an overview of the background to this review and outlines the research aims and questions.
1.1. Background and aims
The purpose of Prevent is to 'stop people becoming terrorists or supporting terrorism' (Home Office, 2018). While counter-terrorism (and therefore Prevent) is a reserved matter and the responsibility of the UK Government, the Counter-Terrorism and Security Act (2015) places a duty on sectors that are devolved from Westminster to the Scottish Government (including local authorities, health and social care, education, prisons, and the police) to pay 'due regard to the need to prevent people from being drawn into terrorism'. This is known as the Prevent duty.
The Prevent duty guidance for Scotland (Home Office, 2021a) outlines how specified authorities are expected to comply with this duty. There is sector-specific guidance for further education institutions (Home Office, 2021b) and higher education institutions (Home Office, 2021c).
The Scottish Government supports the specified sectors to fulfil their obligations under the Prevent duty (Home Office, 2021a), and ensures that mechanisms are in place for safeguarding and supporting individuals who may be susceptible to being drawn into terrorism as outlined in the Prevent Multi-Agency Panel (PMAP) Duty Guidance (Home Office, 2021d).
In Scotland, the approach taken to Prevent is tailored to the Scottish context and the specific challenges faced by Scottish communities. Emphasis is placed on early intervention, safeguarding, and the prevention of people from becoming alienated or isolated, with the aim of reducing vulnerability and increasing resilience to extremist narratives.
The UK Government currently adopts the following definition of extremism:
'vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas'. (Home Office, 2011: 107)
This definition was used in the UK Government's Counter-Extremism Strategy (Home Office, 2015), which set out the UK Government's approach to countering 'both violent and non-violent' extremism. However, as counter-extremism is a devolved matter, the Counter-Extremism Strategy, and UK Government definition of extremism, were not adopted in Scotland.
At present, therefore, the Scottish Government does not have an official definition of extremism. An evidence review carried out by Scottish Government researchers highlighted challenges with defining extremism (Scottish Government, 2023). For example, key difficulties include that:
- Various factors, such as the prevailing political culture, value systems and personal characteristics and experiences, influence how the term is understood, meaning it is an inherently relative and ambiguous term (Sotlar, 2004).
- Extremism is often conceptualised as a continuum of beliefs and behaviours, which makes it difficult to capture in a definition (Wilkinson and van Rij, 2019).
- Defining extremism too broadly can risk impeding rights to free speech and protest, while defining it too narrowly can lead to potentially extremist behaviours being overlooked (Redgrave et al., 2020).
Challenges such as these have meant that while a range of definitions of extremism have been proposed, there is a general lack of consensus on how the term should be defined in the literature (Bötticher, 2017; Lowe, 2017; Nasser-Eddine et al., 2013; Redgrave et al., 2020; Saija et al., 2021; Schmid, 2013).
A key recommendation from the evidence review was that the Scottish Government should review how governments in other countries define extremism, which is the aim of this report.
1.2. Research questions
The review sought to answer the following questions:
1. How is 'extremism' defined by governments in other countries, and what can be learnt from these definitions?
2. What terminology is used by governments in other countries to describe particular types of extremism, and what can be learnt from these approaches?
To address these questions, a review of approaches to defining extremism which are used by governments in other countries was undertaken. To ensure that the definitions chosen were relevant and informative, a decision was made to focus on countries with:
- an official definition of extremism;
- a definition of extremism which is publicly available;
- a definition of extremism available in English;
- a comparable level of socioeconomic development to Scotland and the wider UK;
- a tradition of democratic governance.
These criteria led to the identification of the following 13 countries for inclusion in the review:
- Czech Republic
- New Zealand
- The United Kingdom
- The United States
The review process involved identifying, collating and summarising publicly available material about the definitions used by the governments in each of these countries. Key sources typically included government websites, legislation, and policy documents and strategies, particularly those related to the prevention of extremism and terrorism.
Notably, while this report covers a range of definitions of extremism, it should not be regarded as a comprehensive or definitive account of all definitions that exist or which are adopted outside of Scotland; rather, it constitutes a summary of the definitions used by governments in the countries which met the above inclusion criteria. The definitions covered were used by the governments when this report was written (in 2022), but it is possible that they may have been amended or updated since this time.
1.4. Report structure
The next section describes how extremism is defined by the governments in each of the above countries in turn. This is followed by a discussion of the key findings of the review and recommendations.
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