Child Protection Improvement Programme

Child Protection Improvement Programme Update #14

March 16, 2020 by No Comments | Category Uncategorized

The National Child Protection Leadership Group

The National Child Protection Leadership Group last met on 7 January 2020. The group received an update on the development and implementation of the Minimum Dataset for Child Protection Committees, Joint Investigative Interviews and Barnahus work. The group also received an update on children, young people and families participation and engagement. Members had an in depth discussion on the revision of the National Guidance for Child Protection in Scotland. This provided members with an opportunity to discuss the draft guidance, key changes to the 2014 version, and plans for consultation and engagement.

Revision of the National Child Protection Guidance

The Steering Group met in December and February and will meet again in March.The Group will review the full draft of the guidance and the consultation questions. . There continue to be ongoing discussions with a variety of stakeholders who are providing recommendations, suggestions and draft text. The revised guidance will go to Scottish Government consultation in April and engagement events are being planned.

Case Review Oversight Group – (Significant Case Reviews)

The Case Review Oversight Group was established in May 2019. This Group is chaired by Alan Small and will co-ordinate CPIP/System Review recommendations relating to Significant Case Reviews and consider the purpose, criteria and governance of such reviews. This Group will make recommendations to the Child Protection Leadership Group on a proportionate and timely approach to reviews that supports a learning culture and also the successful implementation of findings to support improvement in child protection practice.

Expert Group on Preventing Sexual Offending involving children and young people

The final report of the Expert Group on Preventing Sexual Offending involving Children and Young People was published in January 2020:

The report sets out proposals to improve prevention and early intervention in response to harmful sexual behaviour involving children and young people. The proposals are currently under consideration but initial action is being taken forward by establishing a multi-agency group to oversee the next phase of work. This group will draw on expertise across sectors to embed implementation within existing work to tackle gender-based violence and all forms of child abuse. The key areas of focus are:

  • Expanding preventive programmes and interventions to ensure more effective engagement with boys and young men;
  • Investing in Scotland-specific guidance to support parents, carers and practitioners to better identify and intervene at the earliest stage; and
  • Development of clear referral pathways and training frameworks to ensure all professionals have the right skills and access to services and support.

Implementing the Children’s aspects of the Human Trafficking and Exploitation (Scotland) Act 2015

Child Trafficking Strategy Group (CTSG) are currently focusing on developing awareness raising workshops for practitioners on trafficking and exploitation which plan to be delivered in four locations across Scotland starting in Spring 2020.

Scottish Government is working with COSLA and other partners to deliver age assessment guidance training for first line-managers in Scotland. Sessions will be held in four different localities across Scotland with the first session taking place in March 2020.

The research on child trafficking by University of Strathclyde which was commissioned by Scottish Government to get a better understanding of the routes into and out of trafficking for children in Scotland will be published shortly.

For awareness – CPC Scotland are represented on the Child Trafficking Strategy Group

The Human Trafficking and Exploitation (Scotland) Act 2015, which required Scottish ministers to produce the Trafficking and Exploitation Strategy, also requires us to review the Strategy every three years, to produce a report on to what extent it has been complied with, and if necessary to publish a new Strategy. The Strategy was published in May 2017, so we have a deadline of May this year to comply.

We are continuing with an extensive programme of engagement to inform the review. Following on from the Stakeholder Forum that brought together 100 attendees to launch the Strategy review on Anti-Slavery Day 2019, an online public survey seeking opinions on the review was open from 18 October to 31 December. The survey received 246 responses and work is underway to analyse the views provided.

Detailed one-to-one meetings are being held with key partners and a full day event with all Action Area chairs and members took place on 6 December.

Engaging with survivors of human trafficking and exploitation remains a key priority and we are working to create a number of settings in which this can take place over the next month or two, including in partnership with Aberlour Child Care Trust and the Scottish Guardianship Service.

The review is a great opportunity to reflect on what we’ve collectively achieved and what more we could have done, and to consider what our priorities should be for the next three years.

Unaccompanied Children in Scotland

The Scottish Government consultation on the Independent Child Trafficking Guardian (ICTG) closed on 17 November 2019. The consultation sought views that will inform the development of the roles and responsibilities of Independent Child Trafficking Guardians and a new service. There was a total of 40 responses to the consultation and the published responses can be found here. These included responses from 19 organisations, 18 Individuals and 3 who wished to remain anonymous.

The responses are currently being analysed and a final report will be published in due course.

Online Safety for Children and Young People

UKCIS working group for vulnerable users in the digital world

Through the National Action Plan on Internet Safety for Children and Young People, the Scottish Government continues to participate as an executive board member of UKCIS (UK Council for Internet Safety), to ensure that Scotland’s interests are appropriately represented. UKCIS is a collaborative forum through which government, the tech community and the third sector work together to ensure the UK is the safest place in the world to be online. Internet Matters is also a UKCIS member and chairs a UKCIS working group looking at how to better to support vulnerable users in the digital world.

As part of this Working Group, Internet Matters is undertaking a mapping exercise to determine existing resources and materials already developed and available to support vulnerable users online, as well as determining where the gaps are and what action is needed. An invitation to participate in this mapping exercise has been extended to CPC lead officers, as well as a range of stakeholders through various national groups.

Online Harms regulatory proposals

In 2019 the UK Government set out their plans for a world-leading package of measures to keep UK users safe online, comprising legislative and non-legislative measures which will make companies more responsible for their users’ safety online, especially children and other vulnerable groups. It proposes to establish in law a new duty of care towards users, which will be overseen by an independent regulator.

The UK Government published their initial consultation response on 12 February 2020, primarily covering businesses in scope, freedom of expression, transparency, and the expansion of Ofcom’s remit to include regulation of the internet. The response can be accessed online at

Scottish Online Safety Education Group

The Scottish Government has since the publication of its Internet Safety Action Plan in 2017, continually engaged with the National Crime Agency’s Child Exploitation and Online Protection Command (NCA-CEOP). In 2019 the Scottish Online Safety Education Group was formalised, its members representing Scottish Government Leaning Directorate and Child Protection, Police Scotland Safer Communities Harm Prevention, NCA-CEOP, Education Scotland and Young Scot.

The Group aims to share focused and relevant updates on current projects related to online safety education and identify gaps in online safety education provision, including safeguarding, and if necessary produce relevant, evidence-based support, guidance and / or events. The Group meets quarterly.

Online RSHP teaching resource (

Relationships, sexual health and parenthood (RSHP) education is a key component of the health and wellbeing area of school curriculum in Scotland. The aim of RSHP education is for every child and young person to have a happy and healthy life and to have confidence in building positive relationships and making well-informed choices as they move into adulthood.

To support delivery of relevant and engaging learning, an online RSHP teaching resource was launched in September 2019. This resource provides teachers with factual resources and guidance to support pupil’s understanding of healthy relationships and how to stay safe online. These resources, where appropriate, echo the messages contained in the resource on Key Messages for Young People on Healthy Relationships and Consent.

Key messages for young people on Healthy Relationships and Consent

In May 2019 the Scottish Government published the Key Messages for Young People on Healthy Relationships and Consent resource aimed at professionals to help them support young people in their understanding of safe, happy and mutually respectful relationships. It is part of the Scottish Government’s work on supporting positive relationships and sexual wellbeing in young people.

Work is currently underway on an age and stage appropriate key messages resource for professionals working with younger children from early years to primary school age.

National Action Plan on Internet Safety for Children and Young People

Work continues to implement the actions of the National Action Plan on Internet Safety for Children and Young People.

Tackling Child Sexual Exploitation

A progress report is currently in preparation to reflect the wealth of work delivered in Scotland through the National Action Plan to Prevent and Tackle Child Sexual Exploitation over the last three years. It is due for publication by March 2020.

Amending Section 12 (“cruelty to persons under 16”) of the Children and Young Persons (Scotland) Act 1937

A public consultation on proposed changes to section 12 (“cruelty to children”) of the Children and Young Persons (Scotland) Act 2019 was carried out in late 2018. The Scottish Government published an Analysis Report of consultation responses on 30th September 2019.

We are currently considering how best to amend criminal legislation to reflect our modern understanding of the nature and impact of neglect in a way which does not unfairly criminalise vulnerable groups of parents in light of analysis of these responses and further engagement with key stakeholders.


The Scottish Government is exploring the application of the Barnahus concept for immediate trauma informed support for child victims of serious and traumatic crimes within the context of Scotland’s healthcare, child protection and criminal justice systems and to explore how Barnahus could work in our adversarial system, which includes cross-examination. Barnahus provides Scotland with an opportunity to design a genuinely child-centred approach to delivering justice, care and recovery for children who have experienced trauma, including, but not only, child sexual abuse.

HIS and the Care Inspectorate have been commissioned by the Scottish Government to develop Scotland-specific standards for Barnahus based on the European PROMISE Quality Standards which are based on best practice from the Nordic countries.

Age of Criminal Responsibility (Scotland) Act 2019

We are working closely with key partners to ensure that implementation of the Age of Criminal Responsibility (Scotland) Act can take place as quickly and as safely as possible. Professional social workers and the Age of Criminal Responsibility project team in Police Scotland are closely involved in developing statutory guidance for investigating serious harmful behaviour by children under 12 years of age. SG officials are in early discussion with partners in relation to developing the list of places of safety required under the Act. The police power to remove a child to a place of safety is designed only to respond to the immediate risk of significant harm and use of this power will be closely monitored.

The next set of regulations which provide for a fairer and more proportionate approach to the disclosure of information is scheduled to commence in June this year. Information about behaviour that occurred while a person was under 12 may still be retained by the police and other relevant bodies for their purposes. This information may be disclosed by the chief constable as “Other Relevant Information” (ORI). This will only happen if the chief constable considers that the ORI is relevant to the purpose of the disclosure and that it ought to be disclosed, and, following a review of the information, an independent reviewer agrees. Disclosure will only be possible on an enhanced disclosure or PVG scheme record. State disclosure by Disclosure Scotland will only occur in rare instances after very careful consideration by the independent reviewer of all information available at the time.

The Advisory Group has been established, which will review the operation of the Act and consider whether the age should be increased further. This Group has now met twice. At its most recent meeting (9 January) the Group commissioned SCRA with undertaking an in-depth analysis of offences referred to the Children’s Reporter as well offences jointly reported for the 12-15 age group. This research will provide the Group with a solid evidence base in which to undertake a full evaluation of the age of criminal responsibility.

Children’s Hearings System:

Children 1st have been successful in their bid for the National Safeguarder Management contract. This will offer continuity and bring opportunities for further development of the role of Safeguarders in the Children’s Hearings System. The two year contract will begin on 1 July 2020.

The Supreme Court has heard arguments that siblings views should be considered at all stages when a child is referred to a children’s hearing, with social work assessments of key family relationships being the starting point. The decision of the court is expected soon.

16/17 year olds within the Children’s Hearings System

The Scottish Government are committed to delivering on the rights of the child.  A multi-agency partnership short life working group was set up in 2017 to consider what changes would be required in order to allow those 16/17 year olds not on a compulsory supervision order, to also be considered by the Children’s reporter through joint reporting.  The group reported to the Children’s Hearings Improvement Partnership in 2018.  Discussions with partners and stakeholders (both internal and external) are currently underway and we plan to have a public consultation in the coming weeks.

National Review of Care Allowances

The National Review of Care Allowances reported in September 2018 and published 12 recommendations for improvement. The report can be read here:

The Scottish Government is continuing to work with COSLA to agree how best to take forward the recommendations of the Review, with a view to implementation from April 2020. This will improve consistency and transparency for looked‑after children, their families and their carers across Scotland.

Independent Review of Care

The Independent Care Review published its final report and conclusions on 5 February 2020. They have produced six outputs in total:

  • The PROMISE – the final report setting out what the high level vision for future care and containing between 60 and 70 conclusions;
  • The PINKY PROMISE – child friendly version of The Promise;
  • The PLAN – sets out the implementation approach the Review considers necessary to deliver the vision;
  • The MONEY – narrative on how Scotland must invest better setting out the human impact
  • FOLLOW THE MONEY – sets out the methodology, process, data collection and analysis which underpinned the human and economic cost modelling undertaken;
  • The RULES – the legislative frame demonstrating the complexity of legislation involved in delivering care and support.

The five key areas through which the report is structured are:

  • VOICE: All those involved in the care and decision making about children and young people must listen to and respond to what they want and need, and be well informed of their circumstances.
  • FAMILY: Where there is sufficient experience of love and care for children and young people that they value, they must stay with their family and their families must be given intensive support together, to nurture that love and overcome the difficulties that get in the way.
  • CARE: Where staying with their family is not possible, children and young people must have relationships that are like family for as long as they need and want: love must feel normal, enabled and lasting.
  • PEOPLE: Children and young people must be actively supported to develop relationships with people in the workforce and wider community. The workforce must share common values and language, and be supported and nurtured to care, able to bring their whole selves to work, so that their interaction with children and young people is natural and relational.
  • SCAFFOLDING: Children, families and the workforce must be supported by an infrastructure that us there when it is needed, This will be enabling, supportive and accountable with Scotland’s services designed to meet the needs of those they serve and not the needs of the system

Implementation of these conclusions will require a transformational and cultural change by everyone involved in the lives of these children and young people. The Scottish Government is determined to have people with care experience at the heart of driving the necessary change forward. The Scottish Government will work with all of its energy and focus, along with local authorities, care providers and all relevant stakeholders, to make the changes to the system that the review considers necessary and to deliver that change as quickly and as safely as possible.

Children (Equal Protection from Assault) (Scotland) Act 2019

John Finnie MSP introduced the Children (Equal Protection from Assault) (Scotland) Bill into the Scottish Parliament on 6 September 2018:

On 7 November 2019, the Bill received Royal Assent.

The Act will abolish the common law defence of reasonable chastisement currently available to parents (or others caring for or in charge of children) charged with assaulting a child in their care. This will come into force on 7 November 2020.

The Act also places an obligation on the Scottish Ministers to raise awareness about the removal of the reasonable chastisement defence.

The Scottish Government has established an Implementation Group which has already begun to consider what will be required to implement the Bill, including awareness raising. Information about the work of this group is available at

Children (Scotland) Bill

The Children (Scotland) Bill was introduced into the Scottish Parliament on 2 September 2019. The Bill was referred to the Justice Committee for Stage 1 scrutiny and is currently under consideration.

The Bill has been informed by the outcome of a consultation on the Review of Part 1 of the Children (Scotland) Act 1995 (the 1995 Act). Part 1 of the 1995 Act covers parental responsibilities and rights and contact and residence cases relating to children when parents are no longer together.

The key policy aims of the Bill are to:

  • Ensure that the child’s best interests are at the centre of any contact and residence case or Children’s Hearing;
  • Ensure that the views of the child are heard;
  • Ensure further compliance with the principles of the United Nations Convention on the Rights of the Child; and
  • Further protect victims of domestic abuse and their children in family court proceedings.

The Bill covers a range of areas. The key areas of the Bill are:

  • Establishing a register of Child Welfare Reporters and curators ad litem;
  • Regulating child contact centres;
  • Encouraging the views of younger children to be heard by decision makers in some circumstances;
  • Protecting victims of domestic abuse by prohibiting personal contact of a case in certain circumstances and authorising special measures to be used in family court cases; and
  • Promoting of contact between looked after children and siblings.

We recognise that primary legislation is only part of the action necessary to improve the operation of family justice. A Family Justice Modernisation Strategy was published on 3 September 2019. This sets out work that is ongoing by Scottish Government and others; work that can be done via secondary legislation or by improved guidance; areas covered by the Bill; and areas that are for longer term work. It includes the PFG commitment to keep siblings together where it is in their best interests.

UNCRC Incorporation Bill

The Scottish Government is committed to incorporating the United Nations Convention on the Rights of the Child into Scots law by the end of this Parliamentary session.

The Bill will seek to incorporate the Convention in full and directly – using the language of the Convention – in every case possible. The only limitation will be the limit of the powers of the Scottish Parliament. We expect that we can incorporate the vast majority of the UNCRC’s provisions. The Bill will also make provision to allow incorporation of those parts of the Convention currently beyond the powers of the Scottish Parliament into domestic law if – and when – the powers of the Parliament change in the future.

Every devolved body, health board and council, as well as the Scottish Government itself, will be legally obliged to respect children’s rights; if they do not, children and young people will be able to use the courts to enforce their rights.

The bill will aim to ensure that there is a proactive culture of everyday accountability for children’s rights across public services in Scotland. That will mean that children, young people and their families will experience public bodies consistently acting to uphold the rights of all children in Scotland.

Children’s Rights and Participation

The 31st March 2020 will see the end of the initial reporting period for the duties placed on public authorities under Part 1 (section 2) of the Children and Young People (Scotland) Act 2014. The duty states that those public authorities, listed under Schedule 1, should report, “as soon as practicable” after the end of each 3 year period, on the steps they have taken to secure better or further effect within its areas of responsibility of the United Nations Convention on the Rights of the Child (UNCRC) requirements.

On 20th November 2019 we published our progress report on our Action Plan on Progressing the Human Rights of Children in Scotland 2018-21. One of the 4 high level strategic actions in our action plan is the development of a strategic approach to children and young people’s participation. As part of this work we launched a children and young people’s participation webpage on the Scottish Government website in early March. It provides information, guidance and support on children and young people’s participation in decision-making.

At our annual Cabinet meeting with children and young people, members of the Children’s Parliament, the Scottish Youth Parliament and Cabinet Ministers discuss the most important issues affecting children and young people in Scotland. On 24th January 2020 we published the progress report on agreed actions from 2019 Cabinet meeting. The 2020 Cabinet meeting took place on 3rd March.

Equally Safe

The Equally Safe Joint Strategic Board is co-chaired by the Minister for Older People and Equalities and CoSLA Community Wellbeing Spokesperson, Cllr Kelly Parry. The most recent meeting of the Board was on 29 October 2019, and the next is scheduled to take place sometime in April..

We have now published the Equally Safe Year Two Report which was produced jointly with COSLA and the Improvement Service. The report can be viewed here.

Membership of the Equally Safe K-Hub group has grown steadily, and we continue to use the space to share resources and papers. Those with an interest are encouraged to join and share within your networks.

Female Genital Mutilation (FGM)

The new Female Genital Mutilation (Protection and Guidance) (Scotland) Bill was introduced to the Scottish Parliament on the 29th of May 2019. The Bill completed stage 2 on the 23rd of January, and stage 3 is due to take place in mid-March. The Bill includes provisions for FGM Protection Orders, and statutory guidance.

You can read the Equalities and Human Rights Committee’s Stage 1 Report on the Bill here.

Meanwhile, we continue to implement Scotland’s national action plan to prevent and eradicate FGM, which was published in 2016. We published a Year 3 Progress Report on the Action Plan on the 8th of November 2019. You can view the report here.

The FGM stakeholder summit was held in July 2019, at which officials gathered views on the new legislation, and on the National Action Plan more generally. The Minister for Older People and Equalities opened the event, and re-confirmed the Scottish Government’s commitment to protecting women and girls from the practice of FGM.

Supporting Disabled Children, Young People and their Families Information website

The Scottish Government committed to developing a resource to Support Disabled Children, Young People and their Families. This stems from SNP 2016 manifesto commitments to ensure disabled children have the best start in life.  The website launched on the Scottish Government website on 24 April 2019 –

The site is rights based and was developed through a process of co-design and co-production.  It aims to provide clear, accessible information on national policies, entitlements, rights and the provision of various forms of support which may bet available to disabled children, young people and their families.  The guides to policies, legislation and service provision are interspersed with examples of real life stories to showcase best practice.

This action is now complete , although the resources and information within may be subject to periodic updates provided by the content owners. The website analytics will continue to be gathered to ensure there is still interest and visitors to the site.

Getting it right for every child Policy and Practice Guidance Update

The Scottish Government is updating Policy and Practice Guidance on Getting it right for every child (GIRFEC) to promote and support GIRFEC good practice and . to provide organisations and practitioners with confidence, clarity and practical support to deliver GIRFEC, underpinned by necessary, relevant and proportionate information sharing.  We will also develop information and guidance for children, young people, and parents.

This guidance will be developed in partnership with delivery partners and stakeholders including children, young people and parents.  Work has already commenced including engagement with key networks and organisations.  We aim to publish refreshed guidance by the end of 2020.

Getting it right for every child Leadership Project

Delivery of GIRFEC requires the services that support children to work collaboratively together to improve outcomes for the children and families that they are working with.

In order to improve collaborative children’s services, we have undertaken a project exploring a Collective leadership offer aligned to the delivery of GIRFEC. This will encourage leaders of organisations who work with children to collaborate on managing an integrated child services system. It is designed to test the theory that the application of collective leadership to the implementation of GIRFEC (with a particular focus on the 10 core components) will lead to improved implementation of GIRFEC.

The GIRFEC Leadership Programme aims to increase capability and capacity around collective leadership in partnerships to drive forward integration and fully embed GIRFEC at the local level. A trial of the Programme is running in 2 partnerships (Argyll & Bute, and Fife) until Sept 2020.

Alongside this the SG are working with local partnerships across Scotland to deliver a series of regional leadership seminars to address common challenges with a particular focus on collective leadership, integrated practice and GIRFEC.

Preventing Child Deaths

A National Hub for the prevention of child deaths was launched on 28 March 2019 at an engagement event for a range of stakeholders. Its focus is to use evidence to inform practice in reducing child deaths in Scotland. Initial work includes the preparation for the full rollout of Child Death Reviews in Scotland. The Hub will be hosted by Healthcare Improvement Scotland in partnership with the Care Inspectorate and Scottish Government.

Child Death Reviews will be carried out for the death of every child in Scotland (all live born children up to their 18th birthday), and up to 26th birthday for those in receipt of aftercare or continuing care at the time of their death, as recommended by the Child Death Reviews Steering Group which reported in 2016.

The Hub will take a multidisciplinary approach, focused on using evidence to deliver change, and will seek to ensure every child who dies within Scotland receives a review of their death. In the first year, the Hub will establish a plan for national Child Death Reviews. This work will include looking at where Scotland sits in relation to child deaths and identifying areas of good practice in the process of Child Death Reviews and prevention, from the rest of the UK and internationally.

Links will be made with existing programmes such as Duty of Candour legislation, Learning from Adverse Events and Mother and Child Quality Improvement Collaborative (MCQIC). The process will also use evidence from other reviews and data sources to look at how to improve shared learning, and investigate learning from existing reviews, such as Significant Case Reviews and Fatal Accident Inquiries.

Pilot work is currently being carried out in three areas across Scotland to inform the development of the system and consideration is being given to extending the pilot work.

Comments from CPC members about the ongoing work would be welcome.

Scottish Child Abuse Inquiry

In summer 2019, Phase 4 of hearings commenced with evidence relating to investigations into residential child care establishments run by male religious orders with a particular focus on:

  • Residential establishments run by the Congregation of Christian Brothers with a particular focus on their provision at St Ninian’s in Falkland, Fife.
  • The Order of Benedictines and their provision at Carlekemp in North Berwick and the Fort Augustus Abbey School.
  • In September 2019 a case study began into the Marist Brothers and their provision at St Joseph’s College, Dumfries and St Columba’s College in Largs.

The Inquiry has also published two case study findings to date on Daughters of Charity (October 2018) and Sisters of Nazareth (May 2019) with further case study findings to published in due course.

On 3 December 2019 Phase 4 of hearing began into the Child Migration case study. This phase relates to investigations into the abuse of children whose departure from Scotland to countries such as Canada, Australia and New Zealand was part of the child migration programmes.

A case study investigating abuse at residential boarding schools throughout Scotland is planned for later in 2020. Details of which schools will fall within the case study will be announced in due course. In 2019 Lady Smith announced that a case study will be held into foster care. This will include children who were boarded out as well as children who were placed in foster care. The Inquiry is recovering evidence from all 32 Scottish local authorities and is gathering evidence from applicants whose care was arranged by any Scottish authority. The case study is expected to begin in 2021.

Hate Crime Bill Consultation

On 14 November 2018 the Scottish Government launched its 14 week consultation, One Scotland: Hate Has No Home Here, which sought views on the proposals for a new hate crime bill, including whether there should be a new statutory aggravation for age.

On 27 June we published the consultation analysis which we will consider as we develop our consolidated hate crime legislation to be introduced during the current parliament session.

We sought views on whether we should add a new statutory aggravation based on age hostility, following Lord Bracadale’s recommendation. He found that, although there might only be a relatively small proportion of crimes relating to hostility against a person because of their age, introducing a new statutory aggravation based on age hostility would send a clear message to society that these offences would be treated seriously and would not be tolerated. He recognised that the majority of these offences would likely be committed against elderly people, however he also noted that it could also be used to protect younger people. We also sought views on Lord Bracadale’s recommendation to consider the introduction, outwith the hate crime scheme, of a general aggravation covering exploitation and vulnerability.

Lord Bracadale also recommended that no specific legislative change was necessary in regard to online hate crime and we proposed to accept this recommendation within our consultation. We will continue to engage with both the UK Government and the Law Commission as they take forward work in this area.


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