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We find it very concerning that @NicolaSturgeon didn't mention women's rights once in her comments regarding the govt's GRA proposals. Our group will soon be presenting work to the Scottish govt which will hopefully lead to the rights of women & girls finally being considered.
In the meantime we would like to highlight that the Scottish government has funded guidance for Scottish schools that has not been assessed & potentially infringes on the rights of children (see wgscotland.org.uk for our assessment); guidance that would lead to girls who >
>are recovering from abuse & who are too distressed to get undressed in front of male children (who could also be many years older) being told their feelings are based on misconceptions (& therefore invalid, which is victim blaming) & are to be reminded of 'respect'. And if they>
>are still too distressed they are meant to be separated from their peer group & their own spaces. It is the Scottish govt's job to ensure that all guidance in relation to children upholds their rights & welfare. They also changed their funding policy for survivor services in >
>Scotland, so that such services had to be trans inclusive to receive funding. However they did not assess the impact of this policy first, to see how women who need female-only support would be impacted. As such there are women who cannot get the support they need. The govt >
>also failed to carry out any impact assessment in relation to women and girls and their GRA proposals, so we need to ask why they feel they can say there is no potential impact when they have not yet assessed this & neither has anyone else? What does that say about their >
>commitment to women's rights & equality? Having a GRC makes the sex based exceptions in the Equality Act much more difficult to use. For e.g. NHS Lothian has said that it would be illegal for the NHS to prevent transwomen with GRC's from providing female-only healthcare. This >
>means that a woman or girl who books an intimate procedure & agrees with her NHS provider that she can have a female HCP, could be faced with a male HCP & with no warning. This is a serious patient welfare & consent issue. Yet the govt has not considered these kinds of issues, >
>& the general problem of the impact on the EA protections at all. Not long ago we found out that the Scottish Prison Service had failed in their legal duty to consider the impact of their transgender policies on female inmates & staff. The govt failed to address this matter at >
>all. Thankfully the SPS has now taken steps to properly assess their policies this year, & will consult with female inmates, staff & with women’s groups. The Scottish govt has also legislated for equal gender representation on public boards, however the legislation means that >
>we will no longer have any idea of the % of females on our public boards. As a response to sexism this simply makes sexism invisible, & is a statement that females no longer deserve equal representation as a class of people. We would recommend that the Scottish govt takes note >
>of the cross party committee report on the Scottish Census, where they highlight that failure to engage women’s groups has led to legislation that is ‘not fit for purpose’. The kinds of systemic failures we have highlighted here make clear how the Scottish govt urgently needs >
>to start consulting with women & properly assess policy. It should be recognised that they need to now take part in a listening exercise. And our first message is that the Scottish government needs to understand that without assessing your own policies, >
>which includes consulting affected groups, you can have no idea of their potential impact. In our view, it's only when this is understood that good policy becomes possible.
