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Home Affairs CommitteeWritten evidence submitted by the Salvation Army [HT 01]

1. Introducing The Salvation Army

1.1 The Salvation Army works in 126 countries. Work to counter human trafficking is undertaken in many of these countries. In “source” countries there is an emphasis on prevention, making communities aware of the dangers of becoming a victim and also working to alleviate the poverty which so often precipitates trafficking. In “receiving” countries there is an emphasis on identifying victims and providing support, including preparation for employment, depending upon the resources available.

1.2 The Salvation Army in the UK is a Christian church and charity serving a wide range of people. Through its 700 church and community centres it offers activities and services that meet locally identified needs. Directly managed charitable services include the following:

Residential and community support for people experiencing homelessness.

Residential care for older people.

Welfare to work services for long-term unemployed people.

Family Tracing Service reuniting family members who have lost contact.

Emergency Services supporting blue light services at major incidents.

The ethos of the organisation is to provide holistic services without discrimination.

2. Introducing the Victim Support Contract

2.1 Since July 1 2011, The Salvation Army has managed the Victim Care Coordination Contract for adult victims of human trafficking in England and Wales. This Contract is jointly funded by the Ministry of Justice and Home Office and was awarded to The Salvation Army for two years with a possible 12 month extension. Under the terms of the contract, The Salvation Army coordinates the provision of support and accommodation services to meet victim entitlements under Article 12 of The Council of Europe Convention on Action against Trafficking of Human Beings (ECAT).

2.2 The specialist support programme overseen by The Salvation Army protects and cares for victims, and provides them with access to confidential client-based, tailored support services, including:

Accommodation.

Legal advice.

Counselling.

Health care.

Education and Training.

Outreach support.

A 24/7 capability to transport rescued victims.

The service now includes a network of 12 diverse service providers who collectively provide no less than 19 safe houses. The accommodation available is spread throughout England and Wales so service users can be moved away to a safe geographical location if necessary and appropriate.

The Salvation Army’s partner organisations are:

Riverside.

BCHA.

Unseen UK.

Migrant Helpline Ltd.

The Medaille Trust.

City Hearts .

Ashiana.

Sandwell Women’s Aid.

Hestia.

BAWSO.

2.3 The service is able to accommodate individual adults, couples and families with diverse support needs. Victims are accommodated with a service provider that can offer them the most suitable care, support and security depending on their situation and needs.

Scope of provision

Number of Service Providers

Female victims only

9

Men victims only

2

Both gender

5

Families

4

24 hour supported accommodation

6

24 hour on call supported accommodation

7

Provision of high level support

6

Provision of medium level support

6

Provision of low level support

3

The service is also able to provide outreach support to victims who are not being accommodated but who are still eligible to receive support.

2.4 When an individual has been referred to the National Referral Mechanism (NRM) and receives a positive reasonable grounds decision, (or in exceptional circumstances before this decision is made), they will be able to access support and accommodation if required. When an NRM form is completed by a First Responder, potential victims are asked if they consent for their information to be referred to The Salvation Army in order to access support and accommodation. The majority of individuals referred to The Salvation Army are interviewed over the phone for an “initial assessment”. Where appropriate, eg if a potential victim is in a detention centre, face to face initial assessments can be undertaken. Depending upon the outcomes of this interview, in terms of support needs, risk factors and geographical location, The Salvation Army will make a referral to the most appropriate service provider for accommodation-based or outreach support.

2.5 The Salvation Army has the capacity to act as First Responder for those agencies that identify potential victims and do not have that status. The Salvation Army is able when necessary to organise transport for victims from their current location to the safe house.

2.6 From April 2013, potential victims who have made an asylum application are referred to Asylum Support Services (ASS) immediately to be accommodated, and outreach support provided where appropriate. If an individual makes an asylum application after they have entered safe house accommodation, the service provider must ensure, following the asylum application and screening, that the individual is immediately referred via the Home Office to Asylum Support Services to assist a prompt move to accommodation provided by the ASS.

2.7 If an individual receives a positive reasonable grounds NRM decision they are entitled to a 45 day recovery and reflection period of support and accommodation. During this time potential victims will be able to access psychological and medical help, counselling, legal advice and referral to legal services, support with immigration applications, guidance on criminal injuries compensation applications, education and training and support to meet spiritual needs.

2.8 Once the service user has received a conclusive grounds decision they are required to leave the service. If the service user receives a negative conclusive grounds decision we aim to exit them from the service within 5 days. If the service user receives a positive conclusive grounds decision they are required to exit the service within 14 days or exceptionally no later than 28 days after the date of decision.

2.9 A potential victim receiving outreach support has the same support entitlements as those accommodated within the service.

2.10 The Salvation Army regularly communicates with partner organisations to respond to enquiries regarding the service and entitlements of service users. The Salvation Army hosts quarterly meetings with all sub-contractors in order to update them about changes and improvements to the service and service management and get their feedback. The Contract Officer visits sub-contractor organisations periodically to monitor service provision and performance. All safe house provision under this contract undergoes annual Safeguarding and Information Security audits.

3. Additional Work in Support of the Contract

The Salvation Army has been able to provide extra support to victims of trafficking and the anti-trafficking sector over and above the contract. We acknowledge the generosity of donors in making this possible.

3.1 An on-going issue for the service is the accessibility and suitability, of move-on accommodation for victims of trafficking after they leave the service. It has often been difficult to secure accommodation with the local authority for individuals with no “local connection” and those who are not deemed to be “priority need”.

Local authorities were identified as lacking an adequate level of provision, knowledge and support for victims of human trafficking. To engage local authorities further with this issue and to increase awareness of trafficking and support available to victims, The Salvation Army hosted the Anti-Human Trafficking 2013 Conference in April 2013. The aims of the Conference were to: increase awareness and knowledge about anti-trafficking and the support available; support the development of regional anti-trafficking coalition groups and disseminate information about the contract and The Salvation Army’s work. The Conference was a great success with over 300 delegates in attendance from local authorities, police, NGOs, trafficking support services, academics, policy makers and sub-contracted organisations.

Helen Grant MP, Victim’s Minister, delivered the key note address, and speakers included representatives from GRETA, Home Office, Salvation Army and a Police and Crime Commissioner. The Conference allowed delegates numerous opportunities for networking, best practice classes and workshops around working together to protect and support victims. Positive feedback from Conference delegates confirms the aims of the day were met.

3.2 The Salvation Army was able to secure funding of £400,000 over two years from the Garfield Weston Trust in order to provide a “Victim Care Fund” for service users. This Fund was set up to enable The Salvation Army to develop creative solutions to the increased need for further resettlement support and aftercare provision for trafficking victims. Victims are encouraged to write their own application to the Fund where this is possible.

The victim care fund is being used in a number of different ways to support the diverse needs of the client group, for example:

rent deposits for move-on accommodation;

supporting repatriation including financial support for flights home;

group work and social activities such as social outings to the cinema or swimming;

English language tutoring;

job clubs and CV writing sessions;

cookery classes;

attendance at HERA’s entrepreneurship classes; and

research to develop and improve the victim care service, male victims of human trafficking research.

4. National Referral Mechanism (NRM)

We understand the purposes of the NRM to be:

Identifying potential victims of human trafficking.

Gathering data about the nature and extent of human trafficking.

Making decisions about whether a potential victim has reasonable grounds and then conclusive grounds for being considered a victim.

Enabling victims to receive appropriate care and support.

Our witness sits on the NRM Oversight Group and therefore these comments reflect the desire on our part for effective inter-agency working.

4.1 Identifying potential victims of human trafficking

We welcome the greater number of agencies and people available to act as “first responders”. (see appendix p13). As the pool of people involved grows, so does the need for consistency of approach. More rigorous training and monitoring of first responders would add to the effectiveness of the NRM. (See Government Strategy para 3.27 p 10).

4.2 Gathering data about the nature and extent of human trafficking

UKHTC act as custodians of the NRM data. More could be learned from this data if the capture, management and analysis of the data were better resourced.

4.3 Making decisions about whether a potential victim has reasonable grounds and then conclusive grounds for being considered a victim

The targets for reaching “reasonable grounds” (5 days) and “conclusive grounds” (45 days) decisions are clearly challenging and, in the majority of the cases referred to The Salvation Army, are not met by the Home Office Competent Authority. (Average number of days for Reasonable Grounds decisions is 37 and for Conclusive Grounds decisions is 104.) Delays in decisions have direct consequences for victims whose access to support and other entitlements can be delayed. There is no right of appeal against these decisions and potential victims who request a reconsideration of their decision cannot access support services during the period of reconsideration. Judicial Review is a possibility at present.

We welcome the setting up of a centralised NRM Central Hub in Leeds by the Home Office to deal specifically with decisions relating to potential victims of human trafficking and the intention to reduce the back log of decisions. We hope this will also make it easier to separate the immigration and victim issues which potential victims often present at the same time but which are required to be considered separately.

4.4 Enabling victims to receive appropriate care and support

Greater numbers of victims are entering the NRM and so greater numbers are receiving support. We welcomed the revision of the NRM form prompting First Responders to inform victims of the support service available via The Salvation Army and how they can be accessed.

4.5 Sharing of completed NRM forms

The NRM oversight group have been asked to look at greater consistency of approach between the competent authorities. There are legal provisions which enable the police, the CPS and legal advisers to get access to the forms but the procedures for doing this are not well understood. We would also like to see a common policy on passing the NRM forms to those agencies providing care under the Victim Support Contract. The forms would enable a more rapid diagnosis of client needs and therefore a wider range of support services to be offered as appropriate.

5. The Government’s Human Trafficking Strategy

5.1 The Government’s Strategy was published in July 2011 at the same time as the Victim Care Contract commenced. We welcomed Chapter 3 which looked specifically at victim identification and care and reflected our aspirations for the Contract. The implementation of the EU Directive this April also consolidates the work of the Strategy.

5.2 The Salvation Army is represented on the Joint Strategy Group set up by the Home Office. This group is able to refer issues for consideration by the Inter-departmental Ministerial Group (IDMG) on all aspects of Human Trafficking. The Joint Strategy Group has met twice and so its work is still at initial stages. We see value in the thematic approach it is taking, identifying issues that can be worked on across central government, local authorities, and the private and voluntary sectors. The Group has on its agenda issues such as awareness raising for front-line professionals, effective data collection and prevention strategies, all of which we welcome.

5.3 We feel the Victim Support Contract has tried to meet the vision set out in paragraphs 3.33 to 3.37. We have valued the quarterly review meetings with Ministry of Justice and Home Office which have been opportunities for us to be held to account and to propose improvements to the policies and procedures that affect victims.

5.4 Many of our support providers are specialists in the field of human trafficking and so we take seriously their feedback on the workings of the Contract. The increased numbers of victims being identified and the understandable constraints in public resources mean that some aspects of the approach envisioned in the Strategy are under pressure. However, it is important to retain flexibility as that enables us to respond to the very different types and levels of needs victims present. The following issues would represent concerns coming from our support providers which we share.

If victims are to recover they need a realistic and sustainable offer of accommodation when their 45 day period has finished or their conclusive grounds decision been received. A two week period is allowed for exit. Currently the Benefit System and Local Authority Housing Services rarely match that time scale, leaving some victims at risk of homelessness.

The appropriate sharing of information on NRM forms greatly assists care planning for victims as they enter the service.

Case review and audit is vital to raising the quality of decisions and we would welcome the sharing of the findings from these exercises so all stakeholders can improve their practice.

The identification and treatment of people in the asylum system remains a concern. Minimum standards for ASS accommodation to be used by potential victims of human trafficking would be helpful. Accommodation needs to be located where outreach support can be delivered in a timely way to victims who often have fears for their personal safety.

6. Key Lessons From our Work so Far

The key lessons we take from our operation of the Contract so far fall into two categories, first, the operation of the NRM and second, the support for victims to move on once they have received their conclusive grounds decision. Whilst these lessons may seem procedural we believe they lie at the heart of sensitive and compassionate responses to victims.

6.1 Making reasonable grounds and conclusive grounds decisions in a timely way gives victims a clear timescale within which to start their recovery and plan for their future. It enables them to access appropriate services at a time when their need is at its greatest.

6.2 Maintaining a clear distinction between immigration and asylum decision-making processes and NRM decisions is crucial for sustainable outcomes for victims following on from the support they have received under the Victim Care and Coordination Contract.

6.3 The task of raising awareness of this crime is not complete and many front-line professionals in public, private and voluntary organisations are unaware of the signs of trafficking and how to make a referral.

6.4 The engagement of local authorities is crucial to enabling victims to move on. Wider recognition that victims are vulnerable adults and the responsibilities that flow from that is essential. We would like to engage with local authorities much earlier in the process of recovery and reflection. We commend those local authorities that are developing best practice. The conference we held for Local Authorities on 24 April 2013 was designed to contribute to this agenda.

6.5 For those victims from the EEA who wish to return to their country of origin, there is at present no safe, structured and resourced route by which this can happen. We realise the size of this challenge and are seeking to make our own contribution but feel that greater coordination and investment is needed.

We appreciate this opportunity to give evidence and our witness looks forward to appearing before the Committee on 4 June.

Salvation Army

May 2013

ANTI-HUMAN TRAFFICKING VICTIM CARE COODINATION AND CONTRACTING SERVICE (AHT)

UPDATE ON CLIENTS—APRIL 2013

Total

Female

Male

Total number of clients who have entered the service since 01/07/11

837

505

332

Number referred who did not enter service

267

200

67

Do not meet service criteria

(Reasons include clients who have been wrongly identified as victims of trafficking eg homeless)

140

Declined help

(Eg Choosing to receive help from another organisation)

64

No further contact

(Eg No contact details given by referrer)

63

Number exited

665

388

277

Number of clients receiving outreach

61

51

10

Number of clients accommodated

111

66

45

Number of clients receiving resettlement 1

0

0

0

TOP FIVE NATIONALITIES BY GENDER

Top Five Nationalities

Male

Female

Total

Percentage of Total Referred

Nigerian

5

155

160

14%

Polish

97

22

119

11%

Albanian

1

106

107

10%

Romanian

43

56

99

9%

Slovakian

49

31

80

7%

July 2011- April 2013

TYPES OF EXPLOITATION

Type of Exploitation

Number of victims by Exploitation type

Percentage

Domestic servitude

84

10%

Domestic servitude & Labour

4

0%

Domestic servitude and Sexual

9

1%

Labour

361

43%

Labour and Sexual

7

1%

N/A

1

0%

Not known

25

3%

Other

11

1%

Sexual

335

40%

Grand Total

837

July 2011-April 2013—Those entering the service

EXIT DESTINATIONS

Exit destination Breakdown

Total by Destination

Percentage

Voluntary Repatriation

129

19%

LA Accommodation

62

9%

Private Rented Accommodation

13

2%

Asylum Support Service

97

15%

Friends Family

30

5%

Referred to Charitable Organisation

23

3%

Resettled in Area

61

9%

Resettled Out of Area

27

4%

Absconded

21

3%

Other

22

3%

Unknown

180

27%

Total

665

July 2011-April 2013—Data as receieved from sub contractors

BREAKDOWN OF REFERRALS BY REFERRAL AGENCY

Service

Number

Percentage

City Council

3

0.27%

Detention

6

0.54%

GLA

39

3.49%

Health Services

8

0.72%

Legal Representative

67

6.00%

Local Authority

17

1.52%

Media

1

0.09%

N/k

2

0.18%

NGO

278

24.91%

NHS

19

1.70%

Other

11

0.99%

Other Government Agency

1

0.09%

Police

301

26.97%

Prison Service

8

0.72%

Probation Service

3

0.27%

Self Referral

64

5.73%

SOCA

7

0.63%

Social Services

35

3.14%

Solicitor

2

0.18%

South East

1

0.09%

Transfer

38

3.41%

Home Office (formerly UKBA)

199

17.83%

UKHTC

5

0.45

Youth Justice

1

0.09%

Total

1116

July 2011—April 2013

1 Resettlement is defined as outreach support for those exiting accommodation to support them to move on into the community These figures are a correct snapshot taken at the end of April 2013. These figures can vary on a daily basis so can not be indicative of the exact number of individuals being supported by The Salvation Army and partner organisations other than at the point in time when this snapshot was taken. Figures released by The Salvation Army are likely to vary from the overall National Referral Mechanism statistics from the UK Human Trafficking Centre, which are available on the SOCA website. The figures from the UKHTC are for the total number of individuals entered in the National Referral Mechanism. The Salvation Army does not support every person who enters the NRM, for example lone children are supported by Barnados and there are other organisations providing support to victims of trafficking in the UK. In addition some adult individuals will choose to return to their home country once identified or will be supported and accommodated by friends or family while they are in the NRM.

Prepared 11th September 2013