This article appeared in the print edition of the Evening Telegraph: 17/02/2020 
 
I discussed various potential opportunities with my careers adviser before leaving high school but becoming a spokesperson for menstruation was never on my list. However, that became my lot a few years ago when an increasing number of women and girls presented at foodbanks across Scotland in need of sanitary items. Many women, due to circumstances beyond their control, were forced to supplement the use of sanitary items with socks, toilet roll and newspaper. My awakening came like a lightning bolt when, in 2010, one young lady came to Dundee Foodbank and turned down sanitary items stating she was too malnourished due to a lack of calories.
 
From 2016, I was called upon for interviews with various media outlets to discuss what became known as “period poverty” and, in 2017, I and my colleagues submitted a detailed report to Aileen Campbell when she was the Minister for Public Health. Alongside other grassroots campaigns, this led to a pilot in Aberdeen followed by £9.2 million of Scottish Government investment to ensure sanitary provision in schools, universities, libraries and leisure facilities.  In 2018, I retreated and assumed that was the job done until a fortnight ago when Aileen Campbell, now the Cabinet Secretary for Communities, opposed the bill on the free provision of period products.
 
The architect of the bill, Scottish Labour’s Monica Lennon, has been the single most fervent champion for the universal provision of sanitary items. She and I met in Holyrood the day after the Local Government and Communities Committee voted by five to two against it, citing concerns over cost and implementation. Scottish Green MSP, Andy Wightman, highlighted that the principle of universalism is at stake and there is a need to counter the belief that you can institute rights without legislation.
 
Monica said: “The driving principle of the bill is achieving period dignity for all.” She adds: “Legislation is essential to secure rights and protect the progress made so far. Means-testing menstruation is not practical or dignified – a universal approach is progressive.” The bill has support from the Scottish Labour Party, Scottish Green Party, Scottish Liberal Democrats and, in a live interview, the new leader of the Scottish Conservative Party, Jackson Carlaw, pledged support.
 
SNP equivocation has infuriated members. Last week, I met the SNP Students National Equalities Officer, Stuart Smith, who has already secured significant support within his party including some elected members. He said: “We are the party of the baby box, universal education, free prescriptions and free personal care.” He adds: “There may be economic concerns but that is what stage two of the parliamentary process is for.”
 
Nevertheless, on Tuesday 25 February, the bill will be presented and the SNP are at least four votes shy of a majority, which means if all other parties vote for it, we could see a political earthquake and irreparable damage done to the SNP claim they are the party of gender equality.

​The ‘Proposed Sanitary Products (Free Provision) (Scotland) Bill' has been criticised at the first stage on 5 February 2020. This article discusses why the Scottish Government should consider the positive implications of the proposed Bill which could not only tackle period poverty, but also positively impact those suffering with endometriosis. 
 
“You can’t have a world class education system if students are skipping class when they have their period. They should be able to visit the toilet safe in the knowledge that sanitary products are freely available.” [i]
 
In a column penned for The Big Issue magazine in 2017, MSP Monica Lennon passionately stressed the importance of ensuring menstruation does not hinder the education of Scottish students. Lennon’s draft proposal, lodged on 11 August 2017, motivated numerous universities, schools and colleges to undertake an obligation to ensure the provision of free sanitary products in their establishments. 
 
The draft proposal (which was introduced as a Bill in the Scottish Parliament on 23 April 2019) had the potential to position Scotland as a driving force behind tackling the issues posed to women* by often expensive period products, thanks in no small part to unfair taxes imposed by an antiquated system of taxation. The campaign led by Lennon gave women in Scotland hope that they would no longer worry over the costs of sanitary products whilst living in a nation that was likely to become an innovative player in the campaign to end period poverty. 
 
It’s one of many reasons why the recent criticism of the Bill by Holyrood MSPs at its first stage has come as a huge disappointment. The key criticisms of the Bill were published on 5 February 2020, with the primary concern of the Local Government and Communities Committee being the cost. In addition, there were concerns over who would bear this cost should the Scottish Government choose not to. The criticisms have left some women in Scotland feeling deflated due to the impact that the legislation could have had, not only on period poverty, but also on relieving the financial burden of those suffering from endometriosis. 
 
Endometriosis
 
For those of you who aren’t aware, endometriosis “is a condition where tissue similar to the lining of the womb starts to grow in other places, such as the ovaries and fallopian tubes.” [ii] The condition is often excruciatingly painful, extremely debilitating and has been listed among the 20 most painful conditions to experience alongside heart attacks and arthritis. [iii] In addition to often unbearable pain, endometriosis can also cause abnormal amounts of bleeding during the menstrual cycle. The definition of ‘normal’ menses is less than 80 mL of blood being shed, [iv] therefore, someone suffering with this illness will likely lose more than 80mL during their menstrual cycle.
 
The Financial, Psychological and Educational Cost of Endometriosis 
 
Financial and Psychological 
 
As endometriosis can cause uncharacteristically heavy bleeding during the menstrual cycle, sufferers sometimes have to change their sanitary products as often as every hour (if they are able to make it that long). This is compared to guidelines that suggest sanitary products only need to be changed every 4 to 6 hours. [v] In addition, an endometriosis sufferer may also experience irregular periods which may last longer than 7 days. [vi]
 
Consequently, the number of sanitary products which are utilised by a sufferer of endometriosis will generally far outnumber the number of sanitary products which are utilised by a woman without the condition. Using the above guidelines, on a very basic comparison an endometriosis sufferer could be using 4 to 6 times the number of sanitary products that someone with a ‘normal’ period uses on any given day. The financial burden that this places on sufferers is significant. Given that the average lifetime costs of managing a menstrual cycle are somewhere between £1,000 and £1,500, [vii] the costs for a sufferer of endometriosis could be astronomical. 
 
This is where the Proposed Sanitary Products (Free Provision) (Scotland) Bill could have a huge impact on sufferers of endometriosis, and one of the many reasons why the Scottish Government should begin to seriously consider how they could practicably bear the costs in order to improve the quality of life of sufferers. The provision of free sanitary products would alleviate the financial burden of purchasing multiple sanitary products massively and allow sufferers to worry less about dedicating a large proportion of their income to sanitary products. It has already been shown that providing women free sanitary products, regardless of income or reproductive health issues, has a positive effect. During the Aberdeen pilot of the Access to Sanitary Products programme [vii] which ran between September 2017 and February 2018, 63% of those involved felt that taking part in the pilot had an impact on them. 
 
The most common response when asked specifically what kind of impact the pilot made was that those involved had “more money available to spend on other essential items” and that they were “less worried about having [their] period”. One respondent was quoted as saying free sanitary products provided in this way would be “a god send for me and 2 daughters. Between the 3 of us someone is always having a period.”
 
It’s unknown if any of the participants in the said pilot suffered from endometriosis. However, it is clear that the provision of free sanitary products has been shown to relieve both the financial pressure of purchasing sanitary products and also relieve the anxiety associated with having a period due to period products being easily accessible. 
 
The impact this could have on women with endometriosis is significant. Several studies have reported the association between endometriosis and psychological diseases, underlining that endometriosis is related to a wide range of psychiatric symptoms especially depression, anxiety, psychosocial stress and a poor quality of life. According to recent literature, depression and anxiety are the most common disorders associated with endometriosis. [viii] If the provision of free period products could help to alleviate that anxiety in some way, whilst also simultaneously reducing Scotland’s rate of poor mental health (15% of adults in Scotland have low wellbeing or a possible psychiatric disorder) [ix], then this Bill seems highly worthy of being enshrined into law and should be considered in line with the wider impacts it is likely to have. 
 
Educational
 
In addition to alleviating strain on both financial and mental wellbeing, the provision of free sanitary products to those suffering from endometriosis must be considered in order to ensure, if not further, the education of sufferers. The Access to Free Sanitary Products for those at school, college or university study carried out by Child Rights and Wellbeing Impact Assessment (CRWIA) [x] in 2017/18 found that around a quarter of respondents, 26% of which were currently in education, said they had struggled to access sanitary products in previous year. 
 
Around 6 in 10 respondents who reported struggling to access products said that this was because they didn’t have the product they needed. Tie this into anecdotal evidence from the aforementioned Aberdeen Pilot scheme that some girls are missing education in order to manage their menstruation, and we begin to see that lack of period products could have a huge impact on educational attainment. 
 
If we then consider that, according to the CRWIA study, the most common way respondents in education who had struggled to access products coped was having to ask someone else for a tampon/towel (71%) or to use an alternative e.g. toilet paper (70%), we see how unfeasible this is for someone suffering with endometriosis. It would be both impractical and uncomfortable for a sufferer of endometriosis to ask a friend or a teacher for a new tampon or sanitary towel every other hour. It would be nigh on impossible to use toilet paper due to the volume of blood that an endometriosis sufferer would lose. 
 
Should free period products not be readily available, then the affected individual would most likely have to leave school, college or university early, missing out on classes, or, knowing the stress and embarrassment that not having adequate period products can cause, simply fail to show up at all when their period is due. This would be so damaging to the education of sufferers of endometriosis, where it is not uncommon to experience heavy bleeding for over a week. 
 
It’s quite clear that the provision of free sanitary products is important to furthering the education of both women with normal periods and endometriosis sufferers alike. Given the potential for academic attainment to fall drastically in the wake of a period without the proper sanitary protection, the Scottish Government should perhaps consider how it might commit a portion of its education budget in order to bear the cost of such products in order for them to be made available to all even where some educational establishments are unable to bear the cost of providing free sanitary products.
 
Conclusion
 
A very small selection of the benefits of the aforementioned Bill have been discussed here, and whilst they have been framed from the point of view of an endometriosis sufferer, the analyses given can apply to women from all walks of life. A number of women are facing a poorer quality of life due to the financial and psychological burden placed on them due to being unable to source adequate sanitary products, or having to pay through the nose when they are able to find them. 
 
Enshrining the provision of free sanitary products into law will help to ensure no woman has to miss out on employment or education due to being unable to prepare for a natural process so out of their control. It will ensure that no woman feels anxiety over deciding whether they can afford to buy meals for the week, or packets of overpriced sanitary products. It will ensure that a teenage girl already battling the difficulties of hormones, puberty and becoming a woman won’t have to run home red faced and in a panic when she’s caught short. The positive implications of Monica Lennon’s campaign and subsequent Bill go right to the heart of the issue, and could go a long way in ensuring that Scotland is a pioneer of menstrual equity. 
 
*It should be noted that reference to ‘woman’, ‘women’, ‘female(s)’ or 'girl(s)' throughout this article is inclusive of those individuals who may no longer identify as female but are biologically still able to have a menstrual cycle and so are directly impacted by the issues raised.
 
[i] https://www.bigissue.com/opinion/monica-lennon-ill-make-period-poverty-history/ 
 
[ii] https://www.nhs.uk/conditions/endometriosis/
 
[iii] https://metro.co.uk/2018/10/30/these-are-the-20-most-painful-illnesses-according-to-the-nhs-8088456/
 
[iv] https://www.uptodate.com/contents/approach-to-abnormal-uterine-bleeding-in-nonpregnant-reproductive-age-women
 
[v] https://tampax.co.uk/en-gb/tampax-articles/my-first-tampon/how-often-should-you-change-your-tampon
 
[vi] https://www.endofound.org/endometriosis-symptoms
 
[vii] https://www.gov.scot/binaries/content/documents/govscot/publications/research-publication/2018/05/access-sanitary-products-aberdeen-pilot-evaluation-report/documents/00535768-pdf/00535768-pdf/govscot%3Adocument 
edit.

The last couple of years has seen a growing public interest in period poverty, revealing particular gendered patterns of poverty. A 2018 poll suggested that nearly 20% of girls and women in Scotland are unable to afford period products such as pads and tampons[1]. Much of this attention has been on girls and women who are in the education system or who are using foodbanks. Also in 2018, the Scottish Government launched a scheme to ensure all schools, colleges and universities provide free period products for those who require them[2]. Similar efforts are in place to help homeless women access the period products they require[3]. These are significant steps toward making Scotland a global leader in challenging period poverty. However, a focus on education or on those who are not in employment or who are using foodbanks neglects the experiences of women, trans and non-binary people in employment who may also experience period poverty. 

Our research conducted between 2017 to 2019 has revealed that many women, trans and non-binary people struggle to manage their period while they are at work. This can be worse for those living with conditions such as endometriosis which can cause heavy menstrual bleeding and considerable pain. Our data suggests that women may be absent from work due to severe menstrual symptoms, but are unlikely to report the true reason for their absence due to embarrassment.

In the summer of 2018 Danielle Rowley, the then MP for Midlothian shared her experiences of the costs of menstruation[4]. Her story of stained trousers attracted considerable media attention and highlighted that broader costs of menstruation, particularly heavy periods.  Our research also suggests that some people, even in highly skilled careers such as education, are unable to afford not only menstrual products, but also over the counter medications, clothing and other required items. Women, trans and non-binary participants in the research shared distressing accounts of attempting to manage their periods and gynaecological health conditions when unable to afford appropriate products. While the focus on period poverty remains on those accessing education and those experiencing extreme hardship, we are missing the realities of those who are stuck in cycles of precarious work and low pay.

​A radical approach is needed and universal access to menstrual products would ensure that no one missed school, work or social activities because they can’t access towels, tampons or cups. A universal approach would prevent anyone from falling through the cracks of policies which target specific groups.  Period poverty can be experienced by anyone and is a workplace issue. When we go to work we don’t expect to bring our own toilet paper or handwash with us! It’s time for period products to be recognised as the essential item that they are and to be accessible to all.


[1] https://www.theguardian.com/society/2018/feb/05/period-poverty-scotland-poll-shows-women-go-to-desperate-lengths
[2] https://www.bbc.co.uk/news/uk-scotland-45295743
[3] https://www.scotsman.com/regions/glasgow-strathclyde/glasgow-s-homeless-women-to-be-given-free-sanitary-towels-1-4540168
[4] https://www.glamourmagazine.co.uk/article/danielle-rowley-interview

My period is not a luxury. Just ask anyone who menstruates, and they will tell you the same.
 
At best, our monthly cycle is an inconvenience –  an au natural reminder that today really wasn’t the day to wear those good knickers. At worst, our period can serve as a devastating and painful reminder that our body maybe isn’t working the way it should be.
 
My name is Katy Johnston, I’m 23-years-old and following surgery in April of 2018 I was officially diagnosed with stage 4 endometriosis: a gynaecological condition that affects 1 in 10 women in Scotland and makes my period the worst time of the month.
 
Endometriosis is the second most common gynaecological condition in the UK – it occurs when cells that replicate those lining the uterus grow elsewhere in the body – fusing themselves to organs and creating sticky cysts and painful clots. Each month, these cells break down and bleed out, but, unlike a normal period, the blood has nowhere to go. Instead, it stays inside, snowballing, and brings with it extreme cramps, nausea, pain during sex, heavy menstrual bleeding and potential infertility.
 
So yeah, my period is more than a monthly inconvenience. It’s a lingering headache, a persistent nightmare. It’s constant and unrelenting and it went undiagnosed for years, because, after all, ‘it’s just a period’.
 
For me, and I’d hazard, most the 190 million individuals with endometriosis across the universe, access to sanitary products is no luxury, but a daily essential.
 
And, as MSP and shadow cabinet secretary for health and sport, Monica Lennon put it: “No one should face the indignity of being unable to access these essential products to manage their period.”
 
I’ve gotten pretty used to carting around a small medical cabinet worth of painkillers, heat packs, tens machines, and sanitary items with me, always. Frankly, these are the essential items I rely on to get through the day. Anyone who might call them ‘luxury’ or ‘non-essential’, clearly doesn’t have a gynaecological condition like endometriosis.
 
This condition isn’t cheap, according to leading charity Endometriosis UK, endometriosis costs the UK economy £8.2bn a year in treatment, loss of work and healthcare costs.
 
Recently, lugging about my stash of medical supplies, I’ve become increasingly aware of my relative privilege.
 
My period is costly.  My bleeding is daily (although I’m also menopausal thanks to endo – long story) and I’m constantly forking out for the latest pain relief gadgets, essential oils, ointments, over the counter remedies in search of a cure (There is no cure by the way).
 
I’m a student. I work part-time. I depend on freelance work and my loan to fund both my life, pay the bills and contribute towards the management of my condition. I am not well off but, the difference is, I can afford to bleed through my knickers when a lot of people can’t.
 
According to the homelessness charity Shelter, in 2018 34,972 homeless applications were made in Scotland. If half of those people are women and one in ten of those women have endometriosis, we’ve got a problem and it’s not going anywhere.
 
I am so grateful to the NHS: for my weekly prescription, which, no doubt, I could not afford without it. For the treatment I have received from MRI’s to ultrasounds in the early stages through to surgery, which I will need again and for my many regular GP appointments and consultations.
 
But we’ve got a long way to go. I was delighted when I saw the issue of free sanitary provisions in hospitals flash up on Sky news last week. How is it that my student library freely stockpiles tampons in their loos, but countless NHS hospital would think twice before supplying period provisions? Even on the gynaecology ward, after my first operation, I was forced to borrow sanitary items from a fellow patient as I had soaked through my pyjamas and the ward sisters had nothing to offer me but paper knickers.
 
Endometriosis isn’t cheap, but we didn’t ask for it. This health condition shouldn’t be forced into the shadows because it’s about periods and that makes us uncomfortable. Regardless of whether it’s endo, PCOS, menorrhagia or just a regular period, no one should feel caught short in public spaces.
 
Schools, public bathrooms, libraries, galleries, football stadiums, concert venues, shopping centres, hospitals should all cater for people who bleed.
 
Because there’s a lot of us, and silencing us doesn’t stop us bleeding, it just creates a culture where women grow up ashamed of what is natural and embarrassed about something over which they have no control. 

I didn’t really think about period poverty until colleagues who volunteered at a Dundee foodbank told me about young women and girls who were asking about sanitary products and telling their stories about the impact on their lives of not being able to afford them.

Some were unable to go to school, some were subjected to bullying, all were unhappy and all embarrassed or ashamed.  It’s hard enough being a teenager without having to go through that. When I was that age, I had very heavy and long periods. I can still remember worrying about leakages, and being caught out when it started unexpectedly.  Running the gauntlet of the school bus with stained clothes was hideous, and that’s without social media to spread the teasing. But I knew that I wouldn’t have to go without sanitary protection for longer than it took to reach a public toilet or get home. Those girls my colleagues met in Dundee didn’t have that comfort.

So we started collecting sanitary products in the staff break out area to donate to the foodbank. I thought people might find it too embarrassing, or the novelty would wear off or might even complain. But they didn’t – they collected so much we had to have two boxes on the go at a time. And it wasn’t just the women, the men bought them too.

What still surprises me is that people were so reluctant to speak about it. Women swap stories about birth, about all sorts of ailments, about their sex lives, but periods have remained strangely taboo particularly in mixed company.

That’s why I’m so pleased that women like Monica Lennon have spoken out tirelessly and the government and wider society have responded positively. There is a strong message about visible, free sanitary towels and tampons which says it’s normal and here’s what you need as well as the most important aspect – making sure all women and girls have the protection they need.

You could argue that providing free products in offices and public spaces is simply subsidising people who can already afford them. However, I think universal availability is part of destigmatising. All women go through this and it’s important for young girls in particular to feel “normal”.

No one should ever feel ashamed of such a natural human function, nor should they be bullied, teased or excluded because of it. Sanitary protection is a basic human right and I am very pleased to be supporting this campaign.

It is no secret that the debate around period poverty is more prominent than ever before. I have admired the work done by Labour’s Monica Lennon MSP on tackling period poverty from afar, and it’s been great to see college’s, universities and other public spaces providing sanitary items for free. A pilot scheme has been introduced in my university for sanitary product provision and I was chuffed to bits when I seen it. “We’re making progress – yass!”
 
But the fight is not over! I am a season ticket holder for Celtic Football Club, and with my universities moves towards accessible sanitary products in mind, it got me thinking about why a similar scheme couldn’t be introduced in football grounds – or any sporting venues for that matter! However, focusing on football, its no secret that it has historically been a male-dominated sport. Whilst the number of women attending football fixtures has most definitely increased, we’re still the in the minority. It is important that we are visible and our needs are recognised. I shared a poll on Twitter asking about people’s experiences with accessibility to sanitary products at football grounds and a common answer was that they “couldn’t remember” if there was a sanitary items dispenser in the toilets that they used. This isn’t good enough. Women should leave sporting events knowing that their needs were well catered for, and I think this is something that access to free sanitary items would provide. The principle of being recognised and paid attention to  is important – in addition to removing the financial obstacles to buying sanitary items.
 
It cannot be ignored that at the heart of this move is the knowledge that, as the price of sanitary products increase, not all self-identifying women and girls can afford them. It would be ignorant to assume that everyone can afford a sanitary towel or a tampon, especially when you’re using multiple a day for generally up to a week. We can’t have people compromising their health and hygiene by going without sanitary items because they can’t afford them whilst others can. So, yes, of course this is about making sure the products are easily accessible for everyone, but it’s not the sole aim of our campaign. A few other female season ticket holders and myself have put this campaign in place to promote women’s presence at the football, to make our needs visible and our voices heard. We also know in practice that sanitary hygiene in football grounds is harder than it may seem. We have heard from girls who said there was not a sanitary items dispenser in the toilet closest to them, or that there’s no access to sanitary bins. We hope that through this campaign and opening communications with the Club that we may be able to introduce a system where sanitary items are free to access and the comfort of the matchday experience can be optimised for female support.
 
This problem is not just specific to Celtic, to football, or to sport. It’s nation-wide and its roots can be found in the unequal gender balance upon which our society is built. Social attitudes mean that we are encouraged not to speak about menstruation or sanitary items, hence why little progress has been made in sanitary provision for women and girls. We believe that these products are just as necessary as toilet roll, which we don’t have to pay for. We want to break the stigma of talking about women’s reproductive health in public and we hope that through our campaign we will no longer see women and girls struggling to access sanitary products - we want a more comfortable match day experience for all who menstruate. 

The EIS, Scotland’s largest teaching union[1], has a long-standing interest in highlighting the damaging impact of low-income poverty on education. Last year we held special screenings of Kev Loach’s powerful film ’I, Daniel Blake’, to help our members become more aware of the changes to the social security system which are driving many into poverty and despair.
​
One scene which profoundly moved our members showed Katie, a struggling single mum, experiencing deep shame after being caught shoplifting sanitary products. Those working in food banks are increasingly encountering women and girls who are suffering the indignity of being unable to afford to buy sanitary products when experiencing their period. The Project Manager of one food bank in Nottingham says, “It’s quite something when you give somebody a box of tampons and they break down in tears” [2]. A spokesperson for the leading food bank network in Scotland, interviewed in July 2017, said, “We've taken evidence across the country of women who supplement that [period products] by the use of socks, they would use toilet paper and in some of the worst circumstances…by the use of newspaper."[3]

Women and girls deserve so much better than this. That’s why the EIS strongly supports Monica Lennon’s proposal to bring forward a Bill to end period poverty and oblige schools, colleges and universities to distribute items as needed, free of charge.

We believe that free and easy access to period products is fundamental to the health and wellbeing of women and girls. We know that health and wellbeing (one of the three pillars of the Curriculum for Excellence) impact on educational outcomes. We also believe that universal free provision of period products will enhance learners’ attendance and attainment.

It is common sense to suggest that girls are more likely to attend school/college, and be able to focus on their learning, if they know they can manage their period without stress or shame. However, this is also an evidence-based position. Research commissioned by ActionAid in 2016 found that more than 3.5 million girls and women in the UK had missed school or work because of their period.[4]

A universal provision scheme as proposed by Ms. Lennon would also help to mitigate the impact of poverty on education, and should form part of the overall approach to ensuring ‘equity’ in educational provision, a stated Scottish Government priority.

Furthermore, it would promote equality - in line with the Public Sector Equality Duty. And, crucially, it would contribute to tackling the stigma associated with periods. Periods are not a medical emergency or a secret shame – they are a normal and natural part of life for women and girls. They deserve to be part of public policy in the same way as any other health issue.

In the EIS, we know only too well that the current climate of austerity, with one in five children in Scotland living in poverty[5], is damaging to our learners. We know children and young people are coming to school hungry and cold. We know families are choosing between eating and heating. We know that women and girls are stressed and distressed if they have no money to buy period products and are too embarrassed or ashamed to ask for an emergency supply. It is disgraceful that, in this day and age, many women and girls struggle to access basic sanitary products, which can have a significant impact on their health and wellbeing. This is a matter of basic human dignity, to which we should all be entitled, regardless of income. It’s time to end period poverty for good.


[1] http://www.eis.org.uk/
 

[2] https://www.theguardian.com/society/2016/dec/12/period-poverty-call-to-tackle-the-hidden-side-of-inequality
 

[3] http://www.bbc.co.uk/news/uk-scotland-40566524
 

[4] https://www.actionaid.org.uk/about-us/periods-and-menstrual-hygiene

[5] http://www.gov.scot/Publications/2017/11/9758