We have submitted a complaint to the Scottish Government today re the GRA reform process & what we consider to be unacceptable conduct & failures. We have summarised areas of our complaint below that we believe to be in the public interest (long thread to follow): The Scottish Government falsely claimed to us in September 2021 that the 17,058 responses to the second GRA consultation was NOT lower than the govt had anticipated, & went on to use the number of responses received as the reason why it was reneging on its commitment to publish >

We can now confirm that out of every frontline women's service in Scotland affiliated with either @rapecrisisscot or @scotwomensaid (which is nearly all of them), only one would confirm they can offer their services on a female-only basis to survivors who need that. We have evidence not only that women in Scotland need access to these services on a female-only basis, but that many are self-excluding right now & unsupported. (Please note RCS & SWA consider 'women-only' to include males; 'female-only' precludes males, hence our terminology).

THREAD: Regarding the process of drawing up the Scottish Govt's school guidance:

We can confirm that the Scottish Govt did not seek consultation with women's orgs that were not govt funded, or with working-class groups, or with any stakeholder groups which identified the LGBT > >Youth Scotland guidance as detrimental to stakeholders, or with any gender critical groups. This is despite being asked to do all of those things & having the opportunity to do so. The Govt did not consult openly with parents re the impact of its proposed guidance either, & it >

STATEMENT: We are sharing the following in response to the insinuation by @rapecrisisscot (RCS) that our organisation is responsible for preventing women from accessing support they need, due to asking rape crisis centres if they can provide their services on a female-only basis>

https://twitter.com/rapecrisisscot/status/1424767097108934662

>Some background: In 2018 we wrote to RCS to ask if they could clarify whether providers in their network offer services to women & girls on a female-only basis where required. We asked this question as it had become clear that women were self-excluding >

On 23rd July we wrote to Rape Crisis Scotland's network of providers, as @rapecrisisscot previously advised us to do, in order to ask whether they can offer their services on a female-only basis, & on 27th July we wrote to Scottish Women's Aid's network to ask the same. We wrote to these providers to let them know we have offered advocacy services to women having difficulty finding the services they need on a female-only basis, including women on their waiting lists. We told them we have not managed to help all the women who contacted us - some>

We wanted to highlight some information relating to the research we carried out on one specific aspect of the EQIA that scotgov completed in relation to the GRRB. We think it’s important to highlight this, to underpin why the concerns we women are raising over the unrestricted/ Access to apply for a self declared GRC with effectively no safeguarding & no gatekeeping, are not ‘misplaced’, ‘moral panic’ or any other dismissive term that’s been used to minimise & undermine our very reasonable objections to this bill.

So, on we march to address some further details of our guide for the GRRB consultation, continuing with Q4, points 2 & 3. And before we begin, again, much of this is from the excellent work done by @mbmpolicy 🙏🏻. Some highlights to follow which are all the more relevant tonight/ as many of the points raised are being relied upon by the EHRC Scotland in their now published GRRB consultation response equalityhumanrights.com/en/our-work-sc…

We have received a troubling clarification from the Scottish Govt re consultation responses it will not publish. The govt is now saying it will not publish responses which mention anyone convicted of a crime by name, or any person's known trans status. We will challenge this.> >We can still FOI those responses for the purposes of our group's analysis, & the govt has confirmed it *will include all responses in its own analysis*, however this essentially functions as a decision not to make public responses which present the govt with crucial counter >

We can now finally publish our guidance for the GRA consultation (!). We've provided substantive responses in the form of counter argument & evidence re Self-ID & the EQIA, & guidance re what to cover in outlining how you will be impacted by the proposals: wgscotland.org.uk Also if you have already responded but would like to include our guidance, you can retract & redo your responses without losing what you previously sent in. Also please ensure to PUBLISH your responses, which you can do anonymously. (See the intro to our Questions for full info).

Some confusion re this tweet & apologies if this was due to our wording. Just to clarify: The govt has not said it will disregard submissions (!), all responses will be in the stats, & there is no change at all in procedure. The point is the govt is consulting re the *content of>

https://twitter.com/WG_Scotland/status/1223678102095761408

>its Bill and EQIAs*, & thus *will only adapt its proposals & impact assessments based on how responses address this content*. The Cab Sec has said how people address the *content* of the Bill & the EQIAs will inform what they do. So personal testimony re impacts, & counter >

We contacted the govt today regarding its position that potentially 'offensive' responses to the GRA consultation will neither be considered nor published. Before going into what we asked, we have confirmed with the Info Commissioner that we can FOI those responses, & we will.> >We asked that the govt considers & publishes responses it finds potentially offensive, unless there are legal reasons to withhold those responses (for example if they include any of the other criteria from Chapter 1 in relation to issues like copyright etc that mean they can't >

GRA THREAD: We would firstly like to remind people our recommendation is to leave your consultation responses until the last couple of weeks, as this permits including the best available evidence. We have started work on our guidance regarding the government's GRA consultation> >& we aim to have our guidance published in early February. Please also remember it is very important that you choose to publish your response, which you can do anonymously, as this will allow your response to be included in the data analysis we will be paying for. This data>

THREAD on our initial response to the govt's EQIA re the impact of its GRA proposals on women & girls: We are *very* disappointed that the govt has not listened to women who responded to the last consultation, or to women's groups who represent women who feel the govt's Self ID > >proposals will adversely impact them. Women, including rape survivors, have been clear with the Scottish Govt in their consultation responses, & in our public survey of 2000 women (see the report on our home page) that they need female-only provision, & how their ability to >

GROUP UPDATE re Scottish Govt school guidance for trans pupils: Below is a very long thread detailing our meeting with the Support & Wellbeing Unit Head today, in order to provide an update re the govt’s school guidance. We are mostly very disappointed at what we heard from the > >Unit Head today, & have major concerns. For some background: in January our group produced a Children's Rights Impact Assessment re the LGBT Youth Scotland guidance for trans pupils that revealed the guidance breached the UNCRC/children’s human rights (& it was in response to >

In August the EHRC asked our group for feedback 'in the Scottish context' on the EHRC's draft 'Equality Act Guidance for Schools on Transitioning Pupils'. With the agreement of @EHRCScotland we have now published an edited version of our response here: wgscotland.org.uk/consultation-r… We believe that policy making should be transparent & that policy makers & organisations seeking to influence policy should be as transparent as is reasonably possible, hence why we are publishing our response (which we have also sent to the Scottish Government).

GROUP UPDATE: We will soon be meeting with Shirley-Anne Somerville to discuss our Female Only Provision Report & recommendations, & the factors our group is arguing must be considered & assessed in relation to the govt’s GRA proposals. The Govt has engaged with our report, & we > >look forward to our meeting & also to providing updates in due course. We have also been invited to meet with the Scottish Prison Service (SPS management has also engaged with our FOPR) & will update on this process too. We've also spoken with the Head of Open Govt in Scotland >

The Equality Act 2010 makes it clear that where a women's service provider takes the view that the women for whom the service is meant wouldn't access the service if it is not single sex (i.e. if it does not preclude transwomen) it can lawfully preclude transwomen on this basis>

https://twitter.com/ScottishTrans/status/1177542591191113728

>'Case by case basis’ in the EA refers to the *specific set of circumstances* in which the single sex exceptions can be applied. And in the specific circumstances where women would self-exclude from a service if it is not female only, making that service female-only can be>

Re women's services, here is a selection of some quotes from women on why they need female-only: “I was the victim of a brutal rape and battery, I didn't handle being around any male bodied person for months and I still have deep anxiety around males” “I HAVE used a women’s > >refuge. I NEEDED that space to be free from males to let my guard down and heal. My child who WITNESSED VIOLENCE needed to be in a place without male bodied people so he could relearn what safe felt like” “I am a survivor of long term violent sexual abuse at the hands of men. >

THREAD: We are thrilled that we can now share our Female Only Provision Report (found at: wgscotland.org.uk) covering a survey we carried out of 2,000 UK women to ask them re the impact of changes to female-only provision that mean they are no longer single sex. We asked > >these qns because no-one else has, & our report reveals that opening up female-only spaces, services, groups & initiatives to male people, is impacting the privacy, dignity, safety, welfare, participation & representation of women & girls, eroding our human rights & equality >

This blog by @S_A_Somerville confirms our fears re the Scottish government's complete failure to understand women's concerns re their GRA proposals, or indeed to understand the wider issues due to changes to female-only provision. It is also incredibly concerning that in respect>

https://twitter.com/ScotGovFairer/status/1118814468765515776

>to women's & trans rights, Shirley only said that we should all unite around transphobia, with no mention of misogyny at all, despite the recent misogynist attacks on MSP's & the recent violent threats made towards women & a grassroots feminist group - all from trans activists.>

James Morton from @ScottishTrans wrongly states here that access to women's services "is not determined by whether or not she has received legal gender recognition". Not only has the EHRC been clear that the "the sex discrimination exceptions in the Equality Act therefore apply > >differently to a trans person with a GRC or without a GRC", but the UK Govt Equality Office recently stated to our group, in writing, that "The fact that a trans person has legal gender recognition will form part of the service provider’s decision as to whether to provide a >