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.
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
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.
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.
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. 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.
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.
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.
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.
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.
The Intercollegiate Group called for the incorporation of FGM
at all levelspre-registration education, undergraduate
medical education, and postgraduate speciality education, as well
as continued professional development for health professionals,
teachers and social workers.
The Bar Human Rights Committee recommended introducing a legal
requirement to make training mandatory.
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
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.
As Leyla Hussein put it, the guidance "would only be effective
if someone actually picks it up and reads it".
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.
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 systema
view shared by the Royal College of General Practitioners.
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.
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.
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".
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.
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".
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.
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.
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.
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
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.
At present across the NHS only a handful of women are referred
at this stage, although there are pockets of good practice.
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.
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.
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
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.
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
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.
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.
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
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.
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.
Indeed, from June this year GPs will have specific codes to record
FGM on their patient files.
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
55. The Royal College of General Practitioners
raised concern that often it was difficult to ask questions about
FGM sensitively, but directly.
However, Dr Kerry Robinson, a consultant paediatrician, told us
such conversations became much easier once they were conducted
as a matter of routine.
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.
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".
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
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 FGMfirst 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.
Muna Hasan from Integrate Bristol summed up the implications of
this lack of awareness:
] 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?
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.
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.
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.
However, the National Association of Head Teachers told us it
believed many schools were ignorant about FGM.
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.
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".
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. 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.
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.
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".
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.
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".
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
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
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
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
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.
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.
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. 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.
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.
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'".
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
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.
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.
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".
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.
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.
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".
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.
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.
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
Limelightan awareness and intervention campaign targeted
at people travelling to and from high-risk countries.
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.
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.
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.
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.
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".
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.
As of 31 March 2014 the line had received 198 calls and emails,
resulting in 87 referrals to the police.
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.
The charity also received 20 FGM-related calls to its ChildLine
between 1 April 2013 and the end of the year17 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
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 childrenhealth, 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.
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.
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.
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.
It was also noted that the statement should be integrated as part
of a much wider range of initiatives with communities.
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.
They told us it should be multifacetedseparately 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".
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.
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
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
FGM 0019 (Avon and Somerset Constabulary), para 25 Back
FGM 0004 (NSPCC), para 16-17 Back
FGM 0010 (28 Too Many), para 3.3.2 Back
FGM 0022 (Intercollegiate Group on tackling FGM), para 22 Back
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
FGM 0026 (Tackling FGM Initiative), para 3, and FGM 0048 (Equality
and Human Rights Commission), para 28) Back
FGM 0023 (Juliet Albert), para 3 Back
FGM 0022 (Intercollegiate Group on tackling FGM), para 29 Back
FGM 0008 (Bar Human Rights Committee), para 4 Back
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
Q240 (FORWARD) Back
Q24 (Leyla Hussein) Back
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
FGM 0029 (Government), para 19; Q340 (Royal College of General
FGM 0011 (International Association of Women Police), para 7 Back
FGM 0026 (Tackling FGM Initiative), para 26 Back
FGM 0029 (Government), para 2 Back
Q321 (Royal College of General Practitioners) Back
Q33 (Leyla Hussein, Daughters of Eve) Back
Q419 (Linda Weil-Curiel, Lawyer at the Paris Bar) Back
FGM 0018 (Intercollegiate Group), para 20 Back
FGM 0041 (Dr Comfort Momoh, African Well Women's Clinic, Guy's
and St Thomas' Hospitals) Back
FGM 0022 (Intercollegiate Group on tackling FGM) Back
FGM 0022 (Intercollegiate Group on tackling FGM) Back
FGM 0051 (Yana Richens OBE and Sarah Creighton), para 4 Back
FGM 0037 (London Borough of Newham), para 4.1 Back
FGM 0016 (Police and Crime Commissioner for Northumbria) Back
FGM 0022 (Intercollegiate Group on tackling FGM) and FGM 0023
(Juliet Albert), para 1 Back
Q46 (Leyla Hussein, Daughters of Eve) Back
Q55 (Muna Hasan, Integrate Bristol) Back
FGM 0018 (Agency for Culture and Change Management) Back
FGM 0052 (Royal College of General Practitioners) Back
FGM 0022 (Intercollegiate Group of tackling FGM) Back
Q348 (Royal College of General Practitioners) Back
Q407 (Dr Robinson, Royal College of Paediatrics and Child Health) Back
FGM 0052 (Royal College of General Practitioners) Back
Q408 (Dr Kerry Robinson, Consultant Paediatrician, Whittington
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
Q231 (FORWARD) Back
Q379 (Dr Comfort Momoh, African Well Women's Clinic, Guy's and
St Thomas' Hospitals) Back
FGM 0004 (NSPCC), para 13 Back
Q68 (Muna Hasan, Integrate Bristol) Back
FGM 0033 (Fahma Mohamed) and FGM 0039 (Guardian News Media) Back
Official Report, 6 May 2014, column 61W, pupils: safety Back
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
FGM 0036 (National Association of Head Teachers), para 2.3 Back
FGM 0039 (Guardian News and Media), para 6 Back
FGM 0033 (Fahma Mohamed) Back
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
Q244 (NSPCC) Back
Q30 (Leyla Hussein, Daughters of Eve) and Q50 (Muna Hasan, Integrate
Q216 (Metropolitan Police Service) Back
Q55 (Christine Townsend, Integrate Bristol) Back
Q277 (Parliamentary Under Secretary of State for Children and
House of Commons Official Report, 18 June 2014, column 1101 Back
Speech given on 28 May 2014 by the Deputy Prime Minister Back
FGM 0022 (Intercollegiate Group on tackling FGM) Back
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
FGM 0052 (Royal College of General Practitioners), para 52 Back
FGM 0025 (Metropolitan Police Service), para 20-21 Back
FGM 0057 (London Safeguarding Children Board) Back
Q379 (Dr Comfort Momoh, African Well Women's Clinic, Guy's and
St Thomas' Hospitals) Back
FGM 0026 (Tackling FGM Initiative), para 1 Back
Q135 and Q136 (Association of Chief Police Officers) Back
FGM 0025 (Metropolitan Police Service), para 25, 26 and 29 Back
FGM 0019 (Avon and Somerset Constabulary), para 27 Back
FGM 0019 (Avon and Somerset Constabulary), para 16 Back
FGM 0016 (Police and Crime Commissioner for Northumbria) and FGM 0040
(Police and Crime Commissioner for Greater Manchester) Back
FGM 0019 (Avon and Somerset Constabulary), para 15 Back
Q147 (Association of Chief Police Officers) Back
FGM 0025 (Metropolitan Police Service), para 9 Back
FGM 0021 (Ralph Tilby) Back
FGM 0026 (Tackling FGM Initiative) Back
FGM 0047 (FORWARD), para 34 Back
Q47 (Christine Townsend, Integrate Bristol) and Q48 (Muna Hasan,
Integrate Bristol) Back
FGM 0036 (National Association of Head Teachers), para 3.4 Back
FGM 0004 (NSPCC), para 8 Back
FGM 0056 (NSPCC) Back
Q235 (NSPCC) Back
FGM 0029 (Government), para 31 Back
Marja Exterkate, Female Genital Mutilation in the Netherlands:
Prevalence, Incidence and Determinants, January 2013 Back
FGM 0010 (28 Too Many), para 3.5.2, and FGM 0012 (Professor Lisa
FGM 0012 (Professor Lisa Avalos) Back
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
FGM 0046 (Association of Chief Police Officers), para 84 Back
FGM 0022 (Intercollegiate Group on tackling FGM), para 25 and
FGM 0043 (Dr Deborah Hodes) Back