Female genital mutilation: the case for a national action plan - Home Affairs Committee Contents

3  Safeguarding at-risk girls

38. Although prosecutions have an important role to play in deterring FGM, each instance represents a child or woman that the state has failed to protect. The NSPCC, for example, told us the main focus should be on prevention and intervention with each child that is at risk.[59] The key to achieving this is to treat FGM as a child protection matter, mainstreaming it as part of the existing safeguarding framework. In this Chapter we consider the guidance available to frontline practitioners, and examine the roles and responsibilities of each group in protecting children from FGM.

Training and the multi-agency practice guidelines

39. One of the main barriers to identification and intervention is a lack of understanding among health, education, social care and other professionals of the risk factors, signs, and how to respond.[60] FGM differs from other forms of child abuse in that it is a one-off event in the child's life that usually takes place in an otherwise loving and caring environment. As such it is not usually accompanied by a pattern of behaviour and indicators that would normally alert the authorities that a child was at risk. Several witnesses raised concern at the current level of awareness of FGM by practitioners. The Police and Crime Commissioner for Avon and Somerset, for example, told us she was still meeting frontline professionals who did not know what FGM stood for.[61] A recent NSPCC survey of 1,000 teachers in England found that one in six did not know FGM was illegal in the UK, and that there was a legal duty on them to take action to safeguard children at risk.[62] Another survey conducted in Wales showed that whilst a large proportion of frontline professionals were aware of FGM, more than half were unsure who was at risk and had never received any formal training. Inevitably, this results in situations where the first time professionals have to deal with a case involving FGM is in a crisis intervention.[63] The Intercollegiate Group told us this was a particular problem in the NHS outside London. Women presenting at hospitals with FGM have reported experiencing reactions of shock, revulsion and confusion shown to them by NHS staff.[64]

40. A number of witnesses argued that mandatory and high-quality training was the only way to ensure all practitioners were capable of recognising the risks of FGM, or understanding when it has taken place, and how to respond.[65] The Tackling FGM Initiative and the Equality and Human Rights Commission told us it needed to be included as part of statutory child protection training, highlighting the legal duties on relevant professionals to report any suspicion that a child might be or has been subjected to FGM.[66] Juliet Albert, a specialist FGM midwife, told us this should include midwives, health visitors, GPs, practice nurses, teachers, obstetricians and gynaecologists, social workers, nurses, and teaching assistants.[67] The Intercollegiate Group called for the incorporation of FGM at all levels—pre-registration education, undergraduate medical education, and postgraduate speciality education, as well as continued professional development for health professionals, teachers and social workers.[68] The Bar Human Rights Committee recommended introducing a legal requirement to make training mandatory.[69]

41. An introduction to the Multi-Agency Practice Guidelines on FGM should form a key part of the provision of training for practitioners. The Government published these in 2011 to help promote a joined-up approach across frontline agencies. They provide guidance on identifying girls and young women at risk of FGM, or who have been subjected to it, and the steps that can be taken to prevent the practice. The Guidelines state clearly that "FGM is a form of child abuse and violence against women and girls, and therefore should be dealt with as part of the existing child and adult protections structures, policies and procedures". They are designed for all frontline professionals and volunteers within agencies that have a responsibility to safeguard children and young people from abuse.

42. The Guidelines are highly regarded by practitioners, although the National Association of Head Teachers and ACPO told us they needed updating to reflect current reforms to the National Curriculum and to include the role of education authorities.[70] However, there is limited awareness that they exist. FORWARD told us that through their training provision for professionals, generally between only five and 10 per cent of the people attending had previously heard of the Guidelines.[71] As Leyla Hussein put it, the guidance "would only be effective if someone actually picks it up and reads it".[72]

43. The Daughters of Eve and a number of other witnesses, including the Mayor of London's Harmful Practices Taskforce, the Agency for Culture and Change Management, FORWARD and ACPO, called for the Guidelines to be given a statutory basis to ensure their use.[73] Indeed, ACPO noted that this would give the Guidelines a similar footing to the Government's Multi-Agency Practice Guidelines for handling cases of forced marriage. Section 63Q of the Forced Marriage (Civil Protection) Act 2007 states that: "A person exercising public functions to whom guidance is given under this section must have regard to it in the exercise of those functions". The Government, however, told us the Guidelines were not statutory because it believed the policies and procedures necessary to tackle FGM already existed through the child protection system—a view shared by the Royal College of General Practitioners.[74]

44. It is deeply concerning that so many frontline practitioners do not recognise the indicators of when a girl or young woman is at risk, or has undergone FGM, and, even when they do recognise the signs, they do not know how to respond. It is unacceptable that those in a position with the most access to evidence of these crimes do nothing to help the victims and those at risk. The record of referrals by healthcare practitioners and others is extremely poor and a lack of training, awareness or ethical concerns can no longer prevent positive action being taken. To remove one of the obstacles to referring, high-quality training for all professionals, including midwives, GPs, health visitors, practice nurses, teachers, obstetricians and gynaecologists, social workers and teaching assistants, is therefore vital both during education and through continued professional development. This should form an essential part of all child protection training. Furthermore, we welcome and support the recommendations of the Intercollegiate Group, though we believe that this work could be better communicated. We note with disappointment that the Royal College of General Practitioners is not a signatory to the report. GPs have a vital role in responding to FGM, and we hope that the Royal College will now work with the Intercollegiate Group to implement its recommendations.

45. The Multi-Agency Practice Guidelines on FGM have a valuable role to play as a tool for all practitioners. However, they will only ever be useful if they are read, and that is more likely to happen if they are mandatory. We recommend the Government update the Guidelines and place them on a statutory footing, giving them parity with guidelines for handling cases of forced marriage. We believe this will provide a much stronger incentive for agencies responsible for training to ensure the inclusion of FGM. To support this, the Department of Health should improve the accessibility of the Guidelines, rather than simply publishing them online, and provide funding for the development of e-learning materials for practitioners. The Department of Health and Department for Education should also ensure arrangements are in place to monitor compliance and hold to account bodies who are responsible for training provision.

Overcoming cultural sensitivities

46. One of the primary reasons why there has traditionally been a reluctance for practitioners to report FGM cases, or discuss it with pupils or patients, is a fear of being accused of racism. The Home Office identified this as a barrier to reporting 10 years ago.[75] School head teachers, for example may be fearful of undermining good relations they have established with practising communities. Elsewhere, the Tackling FGM Initiative told us women who have undergone Type 3 FGM regularly report that they are never asked about what has happened to them during medical checks.[76] However, the Government told us it was clear that "political and cultural sensitivities must not get in the way of preventing and uncovering this terrible form of child abuse".[77] The Royal College of General Practitioners has clear guidance that misplaced concerns around cultural sensitivity should not prevent reporting where it is suspected that FGM has taken place, or that a girl is at risk.[78] Leyla Hussein put it more starkly:

    For me, you are being racist if you stay silent because you are saying, "A girl who is a brown colour is allowed to go through this, but for a girl who is white, blonde and blue-eyed, it would be an outrage".[79]

Linda Weil-Curiel made a similar point:

    People talk of culture and tradition, but children have a fundamental human right not to be mutilated. It is racist to think otherwise.[80]

47. Misplaced concern for cultural sensitivities over the rights of the child is one of the main reasons why the UK has failed to tackle FGM to date. A key objective for a national action plan on FGM must be to overcome practitioners' own reluctance to address FGM so that they respond to it in the same way as other forms of child abuse. Practitioners must be given the confidence to know that they will not suffer any detriment as a result of raising legitimate concerns about FGM. Again, training is important for practitioners to have the confidence to talk about FGM. But it is also about making such conversations routine so that professionals overcome any awkwardness about having them.

The role of health professionals

48. Health professionals have a vital part to play in identifying both at-risk girls and women and girls who have already been subjected to FGM. However, witnesses told us many practitioners often failed to identify these groups, and when they did the information was not always passed on to those agencies who were best-placed to respond. The royal medical colleges in the Intercollegiate Group advocate a 'life-course' model to monitoring at-risk children.[81] This operates on the basis of early identification and protection, with a shared responsibility for child safeguarding between the NHS, social services, and others.

49. A key starting point is when women contact their GP, local maternity unit or midwifery clinic during the early stages of pregnancy. For many women from migrant communities this may be their first contact with the NHS. If the future mother is identified as having undergone FGM or is from a practising country, it is likely that if they give birth to a girl, that child will in the future be at risk unless preventative steps are taken. An early opportunity to raise the issue with prospective mothers, therefore, is during the antenatal booking interview, which usually takes place with a midwife around 10 weeks into pregnancy. This interview already collects a range of information on the patient's lifestyle, such as smoking and alcohol consumption, as well as family history, breastfeeding intentions, etc. However, there is no requirement to ask about FGM. Not only does this pose potential risks for the mother later on in terms of managing her pregnancy and birth, but it also misses an opportunity to flag the future child as being at-risk if they are a girl.[82] The Intercollegiate Group's view is that "every woman from, or partner to someone from, an FGM-practising community who attends antenatal appointments should be asked about FGM as early on in pregnancy as possible, and the outcome of that discussion accurately recorded".[83]

50. If the FGM status of the mother has not been picked up and discussed during pregnancy, there is still an opportunity at the point the child is born. Again, the midwife has a key role by passing on the information to other agencies, such as children's social care, the police, health visitors, and GPs so that the risk to the child can be monitored and managed over time. One way of doing this is to refer the case to children's social care, or where they exist, the local multi-agency safeguarding hub (MASH), which many local authorities have established in the last couple of years. The MASH co-locates a multi-disciplinary team from children's social care, the police, health, education, housing and probation services to respond where someone is concerned about the safety or well-being of a child. It assesses the level of risk and determines what action to take, such as a children's social care assessment, a home visit by the health visitor, or intervention by another agency.

51. The Intercollegiate Group has recommended a policy of automatic referral to children's social care for girls born to mothers who have undergone FGM, so that an action plan can be put into place.[84] At present across the NHS only a handful of women are referred at this stage, although there are pockets of good practice.[85] For example, the London Borough of Newham told us maternity units are required to make a referral for child safeguarding when it is know that the mother has undergone FGM. They are also invited to access the FGM Prevention Service, which is designed to help them to understand the negative consequences of FGM and not allow FGM for their daughters.[86] The Police and Crime Commissioner for Northumbria highlighted a similar practice of systematic referrals by midwives to social services in one part of the county.[87]

52. This summer, a two-year pilot will launch in six London boroughs where midwives will provide information to social workers on new mothers who have undergone FGM. It will be managed by the charity Children and Families Across Borders, alongside the Mayor's Office for Policing and Crime, the Metropolitan Police Service, the Royal College of Midwives, NHS England, and others. As part of the pilot, social workers and health staff will undertake a risk assessment of potential victims. All families will receive literature on the long-term health effects of FGM, and will be clearly told the law on FGM and the potential penalties for allowing or enabling a child to undergo the procedure. For children identified as most at risk, social workers will work directly with the family, but will also escalate the matter if they believe FGM is likely to occur or has occurred. At this point the police will become involved. If it is thought FGM has occurred a child protection medical may be requested. If it is believed the child will be taken out of the UK to undergo FGM the family will be flagged with the border authorities to prevent the child from travelling.

53. Another way in which the FGM risk to the child can be passed on to other agencies is through the Personal Child Health Record, known as the "Red Book". This is given to all parents and carers at a child's birth, and is the main record of their health and development. The parent or carer retains the Red Book, which is updated by health professionals each time the child is seen. An electronic version of the Red Book is currently being developed and piloted. The evidence we received called for a specific reference to FGM in the Red Book.[88] This would enable all those in healthcare settings who come into contact with the child to monitor on an ongoing basis the level of risk, raise the issue with the mother, and if necessary refer the child again to social care or the police. Leyla Hussein told us:

    The moment a girl is born, it should be alerted on her red book. The red book will go to the health visitor. The health visitor should pass that on to the nursery. The nursery should pass that on the primary school teacher. Without even physically examining them, the parent knows that these children are being monitored.[89]

Muna Hasan from Integrate Bristol told us about her mother's experience in Sweden:

    Her midwife brought up the subject the day she found out she was pregnant. Even though they did not know the sex of the child they still brought up FGM and said, "Do you know the laws in this country?" They followed that up all the way till I was in nursery and so on.[90]

54. There are various ways in which girls may continue to come into contact with the NHS throughout their childhood, and at which point the health professional should consider discussing FGM with the parent. In Sheffield, for example, safeguarding intervention has taken place after families sought vaccinations at GPs' surgeries for girls travelling to FGM-practising countries.[91] Girls or women at any age may seek medical attention as a result of complications arising from having undergone FGM. Elsewhere, instances where a patient from a practising community refuses a smear test or experiences pain or distress during the test, may indicate that they have undergone FGM.[92] School nurses may be approached by children who have either returned from or are due to take an extended holiday in their home country. The Intercollegiate Group has also recommended including questions on country of origin when registering for the first time at GP practices to determine whether the patient and their family are from an FGM-practising country.[93] Indeed, from June this year GPs will have specific codes to record FGM on their patient files.[94] All of these situations present an opportunity to raise the issue sensitively with the patient, record the outcome, refer on to social care or the police if appropriate, or refer them to support services. As one of the royal colleges told us: "the most important thing is having that conversation and safeguarding the child".[95]

55. The Royal College of General Practitioners raised concern that often it was difficult to ask questions about FGM sensitively, but directly.[96] However, Dr Kerry Robinson, a consultant paediatrician, told us such conversations became much easier once they were conducted as a matter of routine.[97] The Royal College also noted that a desire to maintain patient confidentiality was often a factor in GPs' reluctance to refer patients. A wider concern raised by witnesses was a lack of certainty among health professionals about when and how to refer cases to social children's care or the police.[98] FORWARD told us: "people don't feel able to refer or are not sure who to refer to, so there needs to be more clarity around the referral pathways: do you go to social services or the police".[99] Dr Comfort Momoh, a midwife who specialises in the treatment of FGM, told us that, in her experience, over half of health professionals were not aware of how to refer cases on to social care, noting: "we all need to know what our roles and responsibilities are".[100]

56. Healthcare professionals have a vital role in breaking the generational cycle of FGM. When a woman is identified as having undergone FGM or being from a country where FGM is practised, then her daughters, future children, younger sisters and other younger female family members should be considered at risk, and preventative measures put in place. But at present there is no consistent approach for identifying at-risk girls and monitoring them throughout their childhood. This process should start before the child is even born. We recommend that the FGM status of the mother and her intentions for the child if it is a girl be made a compulsory question at the antenatal booking interview. This would provide an opportunity to discuss the issue frankly, but sensitively. It would enable better preparation for the delivery, and where the question is not relevant to the mother, it will serve to raise awareness of the issue.

57. Where a girl is born to a mother who has undergone FGM, or where there is perceived to be a risk to the child, we believe the NHS should, as a matter of policy, make a referral to children's social care, or the local multi-agency safeguarding hub, so that an action plan for the safeguarding of that child can be developed and implemented. We welcome the pilot in London to implement such an approach, and hope that it will inform a national roll-out as soon as possible. Furthermore, we recommend the Royal College of Paediatrics and Child Health amend the Personal Child Health Record, or Red Book, to include a specific reference to the risk of FGM to the child, and any safeguarding steps that have been taken. FGM should also form part of the standard questioning for women registering for the first time at GP practices. To support these recommendations, the NHS in conjunction with social care agencies must establish clear referral pathways, which are understood by health professionals so that they feel confident using them. We do not accept that patient confidentiality should prevent practitioners from making a referral where a child is at risk: as with any other form of child abuse, the law allows for disclosure where it is in the best interests of the child.

The role of schools

58. Schools potentially have an important dual role in tackling FGM—first by identifying potential or actual victims, and second by raising awareness about the practice among pupils. In respect of the former, teachers, particularly in primary schools, may be the first to become aware that a girl who is from an FGM-practising country is due to take an extended holiday to her home country. They may also be the first person with safeguarding responsibilities to become aware that a girl has taken an extended break from school, or may be displaying behaviour that indicates they are in pain or discomfort. In these situations it should be the school's duty to make a referral to children's social care and the police, in the same way as would happen for other forms of child abuse. However, as noted above, many teachers do not know how to respond in these situations. For example, a YouGov survey of 1,000 teachers in 2013 found that four out of five had not had FGM child protection training on identifying at-risk girls, and seven out of 10 were not aware that there was Government guidance on how they should respond.[101] Muna Hasan from Integrate Bristol summed up the implications of this lack of awareness:

    Teachers […] will be the first point of contact. A child might go to them and be like, "I am scared of having FGM", or "I know someone who will have FGM". If your teacher does not even know what it is, how are they supposed to protect you?[102]

59. The key role of schools in responding to FGM was the subject of an e-petition in 2014, which gathered more than 234,000 signatures. Launched by the Fahma Mohamed, a student in Bristol, it called on the Secretary of State for Education to write to headteachers before the summer holidays to take all steps to protect children in their schools from the risk of FGM.[103] In response, the Department wrote to all headteachers on 3 April, launching Keeping Children Safe in Education, the Department's updated safeguarding guidance for schools, which for the first time contains explicit reference to FGM. Between 3 and 29 April, the web page hosting the guidance received 65,729 page views, but we were disappointed to learn that as of 30 April, only 43 per cent of recipients had opened the email, and that only 30.5 per cent of recipients had clicked through to the guidance itself.[104]

60. A number of witnesses told us teachers needed to be fully trained to have an awareness and understanding of FGM as part of their safeguarding responsibilities.[105] However, the National Association of Head Teachers told us it believed many schools were ignorant about FGM.[106] In 2013 Ofsted wrote to all head teachers to highlight that it had updated its supplementary guidance on inspecting safeguarding to include forced marriage and FGM. For example, inspectors are now encouraged, where appropriate, to ask whether designated senior staff for child protection are aware of the issue and have ensured that staff in the school are aware of the potential risks. However, it is not clear to what extent Ofsted inspectors have asked questions on these issues in school inspections to date.[107]

61. The second role for schools in tackling FGM is by talking about the subject with pupils. At present, discussion of FGM in schools varies considerably across England, with pockets of good practice in areas such as Bristol, for example, thanks to the work of the charity Integrate Bristol. But many schools do not address the issue at all. One respondent to Fahma Mohamed's e-petition said: "My school has a large Somali majority. We know FGM is a big issue, but we never mention it". Another said: "I am very aware of the trauma this causes girls I have taught. It is something they can't talk about because there is no 'box' for it in Personal, Social and Health Education (PSHE) or in pastoral programmes with form tutors".[108]

62. Many of our witnesses told us FGM should form a compulsory part of personal, social and health education provision, that it should be taught within the wider context of violence against women, and that it should include both girls and boys.[109] The NSPCC, for example, said it was perhaps the most important aspect of preventative work that could be done with young women because educating the current generation to question the practice has the potential to break the inter-generational cycle of FGM.[110] Leyla Hussein and Muna Hasan told us this already happened in countries such as the Netherlands and Sweden, where FGM is discussed openly among pupils within the context of tackling violence against women and girls.[111] The Metropolitan Police also noted that encouraging greater discussion around FGM in schools was likely to increase the level of reporting. Assistant Commissioner Rowley told us, "it is education that changes it from being socially acceptable […] to socially unacceptable, which generates more witnesses and victims coming forward and would help achieve more prosecutions".[112]

63. At present PSHE is a non-statutory subject. The Government's policy is to allow teachers flexibility to develop a PSHE programme that meets the needs of their pupils, rather than to set a standardised curriculum. The PSHE Association provides learning tools to help teachers who wish to give lessons on FGM, but schools are not under an obligation to include FGM in the curriculum. Christine Townsend from Integrate Bristol, for example, told us how she had to battle every year to ensure timetable space was available for the issue.[113] However, the Children and Families Minister told us that "there are many who feel that if all those aspects that are not compulsory were made compulsory, that would skew the balance too much away from the parental responsibility that still exists where it comes to children's education".[114] However, the Parliamentary Under-Secretary of State for International Development announced in the Chamber that education on FGM "needs to be a required part of the curriculum here in high-prevalence areas".[115] The Deputy Prime Minister said: "We want to guarantee that young men and women learn about FGM at school. We want to ensure these young people can speak out if they, their sisters, cousins or friends are in danger and that they know where to go if they need help".[116]

64. Professionals in schools, including teachers and school nurses, have the most regular and ongoing interaction with young people outside of their homes. They are in the best position to detect the warning signs that a girl may be at risk of FGM, or has already undergone the procedure. It is vital that school staff have an awareness of these indicators, and know when to refer the matter to children's social care and the police.

65. We commend the Secretary of State for Education's decision to write to every school to highlight his Department's revised safeguarding guidance, which for the first time raises FGM. However, it is deeply disappointing that almost 70 per cent of the recipients of the guidance did not even look at it in the month after its publication. We recommend that the Secretary of State for Education resend the guidance to all head teachers and child protection officers. To ensure that the guidance has been looked at, the Department for Education should link the receipt of a proportion of school funding that relates to social education and child protection to the electronic notification that the guidance has been viewed.

66. We further recommend that head teachers and child protection officers, where they have not already done so, undergo compulsory safeguarding training which specifically deals with FGM. This training should be disseminated to all teaching staff through schools dedicating time during the remaining in-service training days in 2014 to provide guidance on child safeguarding in respect of FGM and forced marriage. In addition, we recommend that Ofsted publish a progress report setting out the number and proportion of its inspections to date that have explicitly asked about safeguarding against FGM, and the outcome of those inspections.

67. We note that the large majority of our witnesses felt that Personal, Social and Health Education (PSHE) should be made compulsory, with FGM included as part of a wider curriculum on tackling violence against women and girls. It is important that teachers and pupils have an opportunity to discuss issues such as FGM, especially where a proportion of the school population may come from a practising community. We recommend that, where Ofsted assesses PSHE provision in schools, it explicitly examines the school's approach to education on FGM and violence against women. Empowering children to discuss the issue openly will increase the likelihood of breaking the inter-generational cycle of FGM, and will also increase the level of reporting, in so doing helping to ensure the safeguarding of at-risk girls. We recommend that PSHE be made compulsory, including teaching children about FGM in high-prevalence areas.

The role of children's social care

68. It is the duty of social care professionals to co-ordinate the most appropriate response when it receives a referral for a child from either health or education practitioners. Where the referral is for a girl who is seen to be at risk, children's social care should draw up an action plan in collaboration with, for example, health visitors, school nurses and FGM voluntary organisations, to follow the matter up with the parents through ongoing education and by monitoring the girl throughout her childhood.[117] Where the girl has already undergone FGM or is seen as being at immediate risk, the response should include the police. If FGM has taken place, as well as providing counselling and medical support for the child, social care should also look at whether there are other girls at-risk within the family, and draw up an action plan for their protection.

69. Several witnesses raised concern that when health and education professionals do make a referral to children's social care, it is either ignored, or they are told that the case does not meet their risk threshold for intervention.[118] The Royal College of General Practitioners told us, for example, it would like to see referral thresholds clarified and developed both nationally and at the level of local safeguarding children boards.[119] The Metropolitan Police Service also raised concern that social services in London did not always inform the police when an FGM-related referral had been made.[120] It pointed to the London Safeguarding Children Board's Safeguarding children at risk of female genital mutilation guidance, which states that: "A girl who has undergone FGM should not normally be subject to a child protection conference or registered unless additional child protection concerns exist. However, she should be offered counselling and medical help". The MPS argued that if it did not receive such information where a crime had been committed, this made its efforts to prosecute for FGM more difficult. However, the London Safeguarding Children's Board told us the guidance stated clearly elsewhere that the police should automatically be included in any strategy meeting arising from an FGM-related referral.[121]

70. When social services consider a referral it is important that it results in an appropriate response. However, witnesses also expressed concern in this regard. Dr Comfort Momoh told us her efforts to work with social services in two south London boroughs had been hampered because they were not aware of what their roles and responsibilities were. She said: "Each time they say, 'Even if you refer cases to us, what are we going to? We don't have the capacity and we don't know what to do'".[122] In other cases social workers who were unsure about how to respond to information about girls at risk had simply passed the responsibility for their protection on to community organisations. At the other end of the spectrum social services have also been criticised for overreacting because they have not known how to assess the risk. The Tackling FGM Initiative told there had been a number of cases where social services had removed children from their families following reported concerns, without conducting any investigations or assessments.[123] However, there have also been examples of good practice, especially where social services have worked closely with community groups to visit families together. The practice of signing agreements to not perform FGM with families at risk has also proven effective.[124]

71. Children's social care has an essential role in responding to referrals made by healthcare and education professionals, and others, and in developing an appropriate response that safeguards the child. It is concerning that many of those who make FGM-related referrals believe that the threshold for social care intervention is often too high. We recommend that the Department for Education investigate this issue with local safeguarding children boards. We are also concerned that some children's social care services fail to respond to referrals effectively either by not responding at all, or by overreacting. All local safeguarding children boards need to develop clear and consistent risk assessment protocols so that an appropriate action plan is put in place for every child referred to social services. This is particularly the case if efforts to increase the number of referrals from the health and education sectors are to be successful.

The role of the police

72. Whilst the overall responsibility for leading any response for at-risk children lies with the local authority through social services, the police will usually assist with their safeguarding duties, particularly where the child is at immediate risk, or is believed to have already undergone FGM. ACPO told us that in the last five years the police had dealt with over 200 FGM-related cases nationally, though mostly in London and the West Midlands, of which 11 had been referred on to the Crown Prosecution Service for consideration.[125]

73. Most police activity on FGM involves child safeguarding rather than investigating a crime allegation. For example, of the 69 referrals made to the Metropolitan Police Service in 2013, only 10 were recorded as an FGM offence. The circumstances of the 59 other referrals included instances where a referral had been made by a third party about a perceived risk; where a child had come to the attention of the authorities as having had FGM abroad prior to coming to the UK; and where a mother has had FGM and a risk assessment has been undertaken on the family as to whether the newborn is at risk. In all these cases the MPS told us it undertook a review and safeguarding activity alongside other agencies. Indeed, the Met noted that "Safeguarding is the optimal outcome as it prevents harm, but this does not form part of current debates on the policing response to FGM".[126] Elsewhere, Avon and Somerset Constabulary told us its officers consider visiting every family relating to an FGM referral irrespective of whether there is evidence of a crime, partly to collect better intelligence, but also to reinforce the message about the law and to signpost for advice.[127]

74. The low level of reporting means that responding police officers often do not have the experience or competence required to feel confident in the investigation of FGM cases.[128] Although the Police and Crime Commissioner for Northumbria told us training in honour-based violence and FGM was provided to all new police recruits, community support officers, call handlers and investigators, the PCC for Greater Manchester told us: "There is little awareness of the issue within current policing procedures and practices, and minimal training".[129] Avon and Somerset Constabulary also noted that the low level of reporting made it difficult to bid for further investment in the police's work against other policing priorities.[130]

75. In response to the low level of reporting to the police, some forces have sought to take a more proactive and intelligence-led approach. For example, this year eight police forces will be working together at five airports on airport-side operations during a period when it is most likely that girls will be taken out of the country.[131] These kinds of operations have been successful in the past when undertaken in partnership with community organisations. For the last few years under the banner of Project Azure, the Metropolitan Police has taken a more proactive approach through a range of initiatives. For example, it leads the FGM Strategy Group, which led to the creation of an information sharing protocol between the police and the NHS, as well as intelligence development and greater engagement with schools and the third sector. It also provides training to child abuse investigation teams who undertake all FGM-related investigations. In addition, it implemented Operation Limelight—an awareness and intervention campaign targeted at people travelling to and from high-risk countries.[132] However, a former consultant to the MPS told us that, despite these activities, the Metropolitan Police had still not succeeded in securing a conviction for FGM, and that this was due in part to the fact that the level of resource provided to Project Azure had not reflected the scale of the problem in London.[133]

76. The police have an important dual role to play in tackling FGM, both by working with children's social care and other agencies to safeguard at-risk children, and in investigating where a crime may have taken place. Given the low level of referrals to the police to date, we welcome the more proactive approach recently taken by forces such as the Metropolitan Police Service, particularly its recent operations in airports. We believe forces need to ensure that officers receive training to respond appropriately to referrals, and are able to work effectively with grass-roots organisations to break down barriers with affected communities. We were extremely disappointed in the role of ACPO and its lead, who appear to have made little effort to tackle the problem faced, and have shown a distinct lack of leadership in this matter.

The role of the third sector

77. Third sector organisations such as FORWARD, Daughters of Eve, Orchid Project, 28 Too Many, Bawso, the Tackling FGM Initiative, the Hawa Trust, Integrate Bristol and others have arguably been responsible for raising FGM up the political agenda in recent years and shaping Government policy. Despite very little funding, such groups have worked in a variety of ways to raise awareness of FGM and tackle the practice. For example, some groups have been responsible for developing awareness-raising programmes within communities in partnership with health, education and safeguarding professionals. The Tackling FGM Initiative told us grass-roots organisations were often best-placed to carry out this type of work because they were more likely to be trusted by the communities they worked within.[134] For the same reason, such groups have also been effective at working with social services to conduct family visits where there are at-risk children in order to inform them about the law, and also by taking part in safeguarding case conferences. In addition, third sector organisations have been at the forefront in providing training for frontline practitioners on their responsibilities, and how to raise FGM sensitively. FORWARD, for example, trained more than 1,500 professionals in 2013.[135] Elsewhere, the teacher and youth worker-run Integrate Bristol organisation has been carrying out pioneering work in recent years, empowering pupils to talk openly about FGM and challenge the practice within their communities.[136] Overall, the National Association of Head Teachers told us the voluntary sector was leading the way, and that: "The depth of knowledge and expertise possessed by these and other bodies is a rich resource".[137]

78. The NSPCC has also done a considerable amount of work on FGM in recent years. In June 2013 it established a specialist FGM hotline, in conjunction with the MPS and the Home Office. The hotline exists for anyone who is concerned that a child's welfare is at risk. Although callers' details can remain anonymous, any information that could protect a child is referred to the police or social services.[138] As of 31 March 2014 the line had received 198 calls and emails, resulting in 87 referrals to the police.[139] However, the NSPCC described this as "just the tip of the iceberg", noting that more people were coming forward to report concerns in recent months because of the increased level of awareness and debate around the issue.[140] The charity also received 20 FGM-related calls to its ChildLine between 1 April 2013 and the end of the year—17 from children contacting about a personal concern, and the remainder from children with concerns for another child.

79. The importance of third sector organisations in working with other agencies to safeguard at-risk girls cannot be understated. Their role in raising awareness, training professionals, and working with affected communities is vital to tackling FGM in the UK. To date they have achieved this with very little financial support. The Government must provide additional funding to increase significantly the capacity of grass-roots groups, and to encourage the roll-out of best practice from groups such as Integrate Bristol. We support the NSPCC's FGM helpline, which has significantly increased the number of police referrals, though the charity itself believes this is the tip of the iceberg. The Government therefore needs to do much more to promote awareness of the helpline's existence among frontline practitioners and practising communities.

80. Overall, the safeguarding of girls and young women at risk of FGM requires the development of a multi-agency approach with co-operation between all those who come into contact with children—health, education, social care, the police and others. FGM is child abuse and needs to be treated accordingly through existing child protection and safeguarding system. This requires a much greater emphasis on the collection and sharing of information, and the development of clear referral pathways that are well-understood and used by frontline practitioners.

Raising awareness

81. A consistent message from our evidence was the importance of the Government's role in raising awareness of FGM. At present there is a lack of awareness of the legislation on FGM, of how to make a referral, and of the services available for survivors. To date, however, support for awareness-raising has been poorly funded, piecemeal, and largely left to grass-roots organisations and campaigns in the national media. In November 2013 the Government received an award of €300,000 from the European Union to fund a communications campaign on FGM. It has also supported initiatives such as the International Day of Zero Tolerance to FGM, on which this year the Government published a declaration setting out the programme of work it had underway to tackle FGM.

82. One Government initiative has been the 'Statement Opposing Female Genital Mutilation' leaflet, which it launched in October 2012. This is a pocket-sized document, which explains the law and potential penalties that can be used against those who commit, or assist someone else to commit, FGM.[141] It is designed to be carried in a purse or the back of a passport, and is for families who have recently entered the UK, who do not wish their children to undergo FGM, but are subject to social pressure to do so when visiting their families abroad. It is based on the 'Health Passport', introduced in 2011 in the Netherlands, where an estimated 21,000 women have undergone FGM.[142] The UK Government has distributed over 41,000 statements to date. The Tackling FGM Initiative told us they had been well-received, though it was not clear to what extent girls were taking them abroad. Other concerns raised about the statements included the fact that use of the term 'female genital mutilation' risked alienating their target audience; that the language in the statement could be simpler and less legalistic; that the statement could also explain better the health consequences of FGM; and that there had been a lack of publicity and promotion for the statement.[143] It was also noted that the statement should be integrated as part of a much wider range of initiatives with communities.[144]

83. Many of our witnesses, including the Intercollegiate Group, 28 Too Many, the Tackling FGM Initiative, FORWARD, and ACPO, emphasised the need for a comprehensive and ongoing national awareness campaign.[145] They told us it should be multifaceted—separately targeting health, education, social care and other frontline professionals, practising communities, and the wider general public. For example, ACPO told us: "it is essential that there is a unified communication strategy at a national level".[146] Such a campaign would need to operate at different levels and use a range of media. This should include the use of leaflets and posters in GPs' practices, A&E, nurseries, schools, community centres, youth clubs, churches, mosques etc.[147] It should also make use of community media, as well as the wider media. It could also take the form of information provided routinely to new arrivals to the UK from FGM-practising countries. Witnesses suggested that the content of such a campaign should seek to raise awareness of the illegality of FGM and the health risks associated with it, as well as providing information to practitioners seeking advice on making a referral, and signposting women who have undergone FGM to the services that are available to them.

84. There is a clear case for a national FGM awareness campaign, on the same scale as historic public health campaigns on domestic violence and HIV/AIDS. For too long it has been left to grass-roots campaigners and the national media to do this work. And whilst we welcome the €300,000 of EU funding for awareness-raising, it is not sufficient. We recommend the Government provide funding to implement a national campaign that targets frontline professionals, practising communities, including at-risk girls, as well as the wider general public. The campaign should carry the unambiguous message that FGM is a serious crime and child abuse. It should also signpost practitioners who are unsure as to how to make a referral, and women who have undergone FGM and are seeking support.

59   FGM 0004 (NSPCC), para 1 Back

60   FGM 0010 (28 Too Many), para 3.3.2, FGM 0022 (Intercollegiate Group on tackling FGM), para 11, FGM 0026 (Tackling FGM Initiative), para 3, and FGM 0030 (Bawso), para 4.4 Back

61   FGM 0019 (Avon and Somerset Constabulary), para 25 Back

62   FGM 0004 (NSPCC), para 16-17 Back

63   FGM 0010 (28 Too Many), para 3.3.2 Back

64   FGM 0022 (Intercollegiate Group on tackling FGM), para 22 Back

65   FGM 0011 (International Association of Women Police), para 21, FGM 0023 (Juliet Albert), para 3, FGM 0030 (Bawso), para 8.1-8.2, and FGM 0047 (FORWARD), para 37 Back

66   FGM 0026 (Tackling FGM Initiative), para 3, and FGM 0048 (Equality and Human Rights Commission), para 28) Back

67   FGM 0023 (Juliet Albert), para 3 Back

68   FGM 0022 (Intercollegiate Group on tackling FGM), para 29 Back

69   FGM 0008 (Bar Human Rights Committee), para 4 Back

70   FGM 0029 (Government), para 20, FGM 0036 (National Association of Head Teachers), para 3.1, and FGM 0046 (Association of Chief Police Officers), para 73; Q24 (Leyla Hussein) and Q339 (Royal College of General Practitioners) Back

71   Q240 (FORWARD) Back

72   Q24 (Leyla Hussein) Back

73   FGM 0018 (Agency for Culture and Change Management), FGM 0045 (Mayor of London's Harmful Practices Taskforce), FGM 0046 (Association of Chief Police Officers), and FGM 0047 (FORWARD), para 28 Back

74   FGM 0029 (Government), para 19; Q340 (Royal College of General Practitioners) Back

75   FGM 0011 (International Association of Women Police), para 7 Back

76   FGM 0026 (Tackling FGM Initiative), para 26 Back

77   FGM 0029 (Government), para 2 Back

78   Q321 (Royal College of General Practitioners) Back

79   Q33 (Leyla Hussein, Daughters of Eve) Back

80   Q419 (Linda Weil-Curiel, Lawyer at the Paris Bar) Back

81   FGM 0018 (Intercollegiate Group), para 20 Back

82   FGM 0041 (Dr Comfort Momoh, African Well Women's Clinic, Guy's and St Thomas' Hospitals)  Back

83   FGM 0022 (Intercollegiate Group on tackling FGM) Back

84   FGM 0022 (Intercollegiate Group on tackling FGM) Back

85   FGM 0051 (Yana Richens OBE and Sarah Creighton), para 4 Back

86   FGM 0037 (London Borough of Newham), para 4.1 Back

87   FGM 0016 (Police and Crime Commissioner for Northumbria) Back

88   FGM 0022 (Intercollegiate Group on tackling FGM) and FGM 0023 (Juliet Albert), para 1 Back

89   Q46 (Leyla Hussein, Daughters of Eve) Back

90   Q55 (Muna Hasan, Integrate Bristol) Back

91   FGM 0018 (Agency for Culture and Change Management) Back

92   FGM 0052 (Royal College of General Practitioners) Back

93   FGM 0022 (Intercollegiate Group of tackling FGM) Back

94   Q348 (Royal College of General Practitioners) Back

95   Q407 (Dr Robinson, Royal College of Paediatrics and Child Health) Back

96   FGM 0052 (Royal College of General Practitioners) Back

97   Q408 (Dr Kerry Robinson, Consultant Paediatrician, Whittington Health) Back

98   FGM 0012 (Professor Lisa Avalos), FGM 0022 (Intercollegiate Group on tackling FGM), FGM 0026 (Tackling FGM Initiative), FGM 0041 (Dr Comfort Momoh), and FGM 0052 (Royal College of General Practitioners) Back

99   Q231 (FORWARD) Back

100   Q379 (Dr Comfort Momoh, African Well Women's Clinic, Guy's and St Thomas' Hospitals) Back

101   FGM 0004 (NSPCC), para 13 Back

102   Q68 (Muna Hasan, Integrate Bristol) Back

103   FGM 0033 (Fahma Mohamed) and FGM 0039 (Guardian News Media) Back

104   Official Report, 6 May 2014, column 61W, pupils: safety Back

105   FGM 0012 (Professor Lisa Avalos), FGM 0019 (Avon and Somerset Constabulary), FGM 0022 (Intercollegiate Group on tackling FGM), and FGM 0041 (Dr Comfort Momoh, African Well Women's Clinic, Guy's and St Thomas' Hospitals); Q68 (Muna Hasan, Integrate Bristol) Back

106   FGM 0036 (National Association of Head Teachers), para 2.3 Back

107   FGM 0039 (Guardian News and Media), para 6 Back

108   FGM 0033 (Fahma Mohamed) Back

109   FGM 0008 (Bar Human Rights Committee), para 9, FGM 0010 (28 Too Many), FGM 0019 (Avon and Somerset Constabulary), para 30, FGM 0022 (Intercollegiate Group on tackling FGM), FGM 0033 (Fahma Mohamed), para 4, FGM 0041 (Dr Comfort Momoh, African Well Women's Clinic, Guy's and St Thomas' Hospitals), FGM 0045 (Mayor of London's Harmful Practices Taskforce), and FGM 0048 (Equality and Human Rights Commission), para 26; Q21 (Leyla Hussein, Daughters of Eve), Q56 (Muna Hasan and Christine Townsend, Integrate Bristol), Q207 (Metropolitan Police Service), and Q244 (NSPCC and FORWARD) Back

110   Q244 (NSPCC) Back

111   Q30 (Leyla Hussein, Daughters of Eve) and Q50 (Muna Hasan, Integrate Bristol) Back

112   Q216 (Metropolitan Police Service) Back

113   Q55 (Christine Townsend, Integrate Bristol) Back

114   Q277 (Parliamentary Under Secretary of State for Children and Families) Back

115   House of Commons Official Report, 18 June 2014, column 1101 Back

116   Speech given on 28 May 2014 by the Deputy Prime Minister Back

117   FGM 0022 (Intercollegiate Group on tackling FGM) Back

118   FGM 0018 (Agency for Culture and Change Management), FGM 0022 (Intercollegiate Group on tackling FGM), para 16, and FGM 0026 (Tackling FGM Initiative), para 1; Q311 (Royal College of Midwives) Back

119   FGM 0052 (Royal College of General Practitioners), para 52 Back

120   FGM 0025 (Metropolitan Police Service), para 20-21 Back

121   FGM 0057 (London Safeguarding Children Board) Back

122   Q379 (Dr Comfort Momoh, African Well Women's Clinic, Guy's and St Thomas' Hospitals) Back

123   FGM 0026 (Tackling FGM Initiative), para 1 Back

124   Ibid. Back

125   Q135 and Q136 (Association of Chief Police Officers) Back

126   FGM 0025 (Metropolitan Police Service), para 25, 26 and 29 Back

127   FGM 0019 (Avon and Somerset Constabulary), para 27 Back

128   FGM 0019 (Avon and Somerset Constabulary), para 16 Back

129   FGM 0016 (Police and Crime Commissioner for Northumbria) and FGM 0040 (Police and Crime Commissioner for Greater Manchester) Back

130   FGM 0019 (Avon and Somerset Constabulary), para 15 Back

131   Q147 (Association of Chief Police Officers) Back

132   FGM 0025 (Metropolitan Police Service), para 9 Back

133   FGM 0021 (Ralph Tilby) Back

134   FGM 0026 (Tackling FGM Initiative) Back

135   FGM 0047 (FORWARD), para 34 Back

136   Q47 (Christine Townsend, Integrate Bristol) and Q48 (Muna Hasan, Integrate Bristol) Back

137   FGM 0036 (National Association of Head Teachers), para 3.4 Back

138   FGM 0004 (NSPCC), para 8 Back

139   FGM 0056 (NSPCC) Back

140   Q235 (NSPCC) Back

141   FGM 0029 (Government), para 31 Back

142   Marja Exterkate, Female Genital Mutilation in the Netherlands: Prevalence, Incidence and Determinants, January 2013 Back

143   FGM 0010 (28 Too Many), para 3.5.2, and FGM 0012 (Professor Lisa Avalos) Back

144   FGM 0012 (Professor Lisa Avalos) Back

145   FGM 0008 (Bar Human Rights Committee), para 8, FGM 0010 (28 Too Many), para 3.5.3, FGM 0011 (International Association of Women Police), FGM 0019 (Avon and Somerset Constabulary), para 40, FGM 0022 (Intercollegiate Group on tackling FGM), para 25, FGM 0023 (Juliet Albert), FGM 0026 (Tackling FGM Initiative), FGM 0040 (Police and Crime Commissioner for Greater Manchester), FGM 0043 (Dr Deborah Hodes), FGM 0046 (Association of Chief Police Officers), and FGM 0047 (FORWARD), para 46; Q371 (Royal College of Midwives), Q387 (Dr Kerry Robinson, Consultant Paediatrician, Whittington Health), and Q394 (Dr Comfort Momoh, Guys' and St Thomas' African Well Women's Clinic, and the Community Practitioners and Health Visitors Association) Back

146   FGM 0046 (Association of Chief Police Officers), para 84 Back

147   FGM 0022 (Intercollegiate Group on tackling FGM), para 25 and FGM 0043 (Dr Deborah Hodes) Back

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Prepared 3 July 2014