We support the Government’s ambition to improve the service and support that victims receive, and hope that the Victims and Prisoners Bill and related non-legislative measures will help to improve victims’ confidence to report crimes and seek justice, as well as to rebuild their lives.
- We support the Government’s ambition to improve the service and support that victims receive, and hope that the Victims and Prisoners Bill and related non-legislative measures will help to improve victims’ confidence to report crimes and seek justice, as well as to rebuild their lives.
- The Bill proposes that Police and Crime Commissioners (PCCs), health bodies and local authorities will be required to work together when commissioning support services for victims of domestic abuse, serious violence and sexual violence, to deliver a more joined-up support offer. While laudable in its objective, introducing new legislative duties does not automatically improve collaboration or partnership-working. This is particularly the case if the duty is not accompanied by funding for support services themselves, but just funding for the mechanics of the duty. We note that a recent report by the Domestic Abuse Commissioner recognised ‘insecure and insufficient’ funding being a key driver for services struggling to meet demand.
- A sustainably funded, locally-led approach, which provides areas with the flexibility and resources to identify local priorities and take action on them, will be the most effective way to improve collaboration and deliver on the priorities of the Bill. Alongside that, the Government should focus on preventing crimes occurring in the first place by investing in vital early intervention and prevention services, many of which are provided by local authorities.
- It is important to ensure that the implementation of the Bill aligns with other recent, new duties relating to these crimes (notably the serious violence duty and duty for councils to provide accommodation-based support for domestic abuse victims), which also mandate partnership working, needs assessments and strategy development. Local areas should have the flexibility to implement these duties in a way that makes sense locally, rather than being required to set up separate structures or processes for specific individual duties.
- More generally it would be helpful for Government to provide clarity, through the current Community Safety Partnership (CSP) review, on how it sees the operation of the complex community safety landscape, while allowing local partnerships to identify local delivery structures that encourage collaboration and avoid duplication of work or leaving gaps.
- It will be important to understand how the new Victims Funding Strategy will align with the proposals in the Victims and Prisoners Bill, and to have an accurate sense of the total amount required to fund community-based services. A commitment from Government to streamline funding, rather than providing multiple pots with differing criteria, would be welcome.
- Further clarity is needed on how the enhanced role of the PCCs to review compliance with the Victims’ Code will operate. We urge both PCCs and the Secretary of State to take a proportionate approach that minimises the burdens on youth offending teams and other local criminal justice bodies.
The Government has noted that many victims lack confidence, or feel unable to report a crime. Therefore, it is hugely important that victims are supported after they come forward to access help. Victims should be matched with adequate early-interventions and preventative services to help them escape their situation and give them the confidence to come forward.
However, our ultimate ambition should be to prevent these crimes from occurring in the first place. The Victims and Prisoners Bill should therefore be accompanied by a wider commitment to prevent crime and invest in early intervention and prevention services. This must be a cross-Government approach, rather than a solely criminal justice-led issue.
Collaboration between partners
We believe that a sector-led approach, which provides local areas with the flexibility and resources to identify local priorities and take action, is one of the best ways to improve collaboration: this will not automatically be achieved simply by creating a legislative duty. For example, we support the voluntary approach of Violence Reduction Units (VRUs), which bring together different organisations, including the police, local government, health, community leaders and other key partners to tackle violent crime by understanding its root causes. The recent VRU evaluation concluded that the VRU model continues to make progress in implementing, and delivering on the aims of, a whole-system approach to violence reduction, while driving particular improvements in multi-agency working and data sharing.
As part of a collaborative approach, there is a need for clarity on how PCCs, CSPs and VRUs are expected to work together overall, and with health, given the overlapping, but diverse range of community safety issues they cover, their related roles and the varied funding streams available to different partners. In addition to the Bill, there is a need for guidance to support better alignment by VRUs with existing statutory functions and partnerships (as highlighted in the Home Office’s evaluation of VRUs) and the role of CSPs, which the Government is currently reviewing. It will be important for PCCs and relevant partnerships to have clearly defined roles and ways of working. There should be an emphasis on strong partnership working and joint decision-making as the default position, including in relation to funding bids.
Adequate funding is also important to strengthening collaboration, both in terms of supporting partnership working and, in this context, funding support services themselves. The impact assessment for the Bill identifies funding for the duty to collaborate, however it does not consider the funding that will be needed to sustain and expand victim support services. For the Bill to achieve its ambitions, there needs to be long-term, streamlined Government funding for victim services and interventions.
We are concerned that in areas such as domestic abuse, there is a mismatch between the statutory responsibilities which are placed on councils and the fact that funding to support domestic abuse victim support services is typically routed through PCCs. The introduction of VRUs in some areas has created an additional vehicle for commissioning services that can sometimes be wholly separate to the work of local CSPs. It would be helpful for Government to allow local partnerships to re-design the structures for delivering their range of duties at the local level, to encourage collaboration and avoid duplication of work or leaving gaps.
With regards to commissioning, it is vital that there is greater investment in community-based support, including early intervention and prevention services, as well as investment and research into perpetrator programmes. The Violence Reduction Unit model should also be expanded to all police forces areas, backed by long-term and sustainable funding.
The Domestic Abuse Commissioner’s office has outlined that the scale and prevalence of domestic abuse, as well as the impact of the pandemic means that the demand for services still far outstrips provision, particularly of the most tailored, holistic forms of support to victims and survivors. A failure to invest in these services will lead to further long-term costs for the Government.
Alignment with other legislation
It is crucial that the Government ensures its various recent and forthcoming strategies, guidance, and legislation in this space work cohesively with the Victims and Prisoners Bill.
This should include the Part 4 statutory duty to deliver domestic abuse accommodation-based services outlined in the Domestic Abuse Act 2021; the serious violence duty outlined in the Police, Crime, Sentencing and Courts Act 2022, and the Community Safety Partnership Review led by the Home Office, referenced above.
The community safety reforms outlined by current and forthcoming legislation are taking place at different times, with different commencement schedules, but create similar duties around partnership working, needs assessment and strategy development. There is a risk of this legislation simply adding new duties to an already crowded landscape. The Government should provide clarity on how this complex, overlapping pictures fits together, while also allowing local partnerships flexibility to deliver the duties in a way that makes sense locally, using established partnership mechanisms as appropriate, rather than being required to establish specific structures for individual duties.
Scope of the Victims and Prisoners Bill
The Bill identifies domestic abuse, sexual violence and serious violence, but councils and their partners may commission services that work across all these crime types and more. The Bill must ensure that other victims do not feel like their cases of antisocial behaviour or similar crimes are treated as “low-level” or less important than serious violent crime or wider criminal offences. For many councils, the main form of serious violence locally will be domestic abuse, meaning there will need to be flexibility in how councils approach the categorisation of support services, which will need to be reflected in the statutory guidance. The definitions of serious violent crime will need to also work cohesively with wider legislation and duties, to prevent duplication or multiple partnership arrangements commissioning the same services, and a cohesive approach will be required alongside councils’ current statutory duty to deliver accommodation-based support and services under the Domestic Abuse Act.
Victims’ Code oversight by PCCs
We await further clarity on the transfer to PCCs of the function of reviewing the operation of/compliance with the Victims’ Code, and what this will mean in practice for regard to youth offending teams. Any proposed new data collections need to be developed in consultation with Youth Offending Teams (YOTs) and wider partners to ensure that these are proportionate and genuinely contribute to improving outcomes.