Domestic Abuse Bill

Written evidence submitted by AVA (Against Violence and Abuse) (DAB38)

Public Bill Committee on the Draft Domestic Abuse Bill (2019-21)

Executive Summary

1. AVA believes that we achieve more together than we do alone. As a result, we are a signatory to the second joint submission from several VAWG charities, submitted on our behalf by Women’s Aid. We are also signatories to submissions from the Inter-Collegiate and Agency Domestic Violence Abuse Forum (INCADVA), the Violence, Abuse and Mental Health Network (VAMHN), and the joint submissions from the children’s and VAWG sectors led by Action for Children.

2. We welcome the amendments made to the Bill in light of the Joint Committee’s recommendations but feel there are still serious gaps in the provisions laid out in the current Bill. This Bill can and must do more.

3. Women experiencing domestic abuse, particularly where they also experience other forms of multiple disadvantage, need access to trauma and gender informed services that can meet their needs holistically. This must be available in both domestic abuse services, and other specialist services to which women experiencing abuse otherwise present, in particular, substance use, homelessness and mental health services.

4. Children who have seen, heard or experienced domestic abuse must be provided with adequate long-term support.

5. The fear of child removal is one of the biggest barriers to disclosure for mothers experiencing domestic abuse. There needs to be better informal and non-judgmental community-based support for mothers experiencing domestic abuse that enables them to seek help before crisis-point.

6. The Government should prioritise work to develop alternatives to permanent child removal that protect the child from short-term risks, whilst also recognising the long-term risks to both mother and child in the event of permanent removal into care.

7. Women survivors of domestic abuse whose children have been permanently removed into care need more support, including support to establish contact with children and around care proceedings.

8. Step-down support for women and children when children are returned to families or no longer deemed in need must be long-term and adopt a strengths-based approach.

About AVA

9. AVA (Against Violence & Abuse) is a feminist charity committed to creating a world

without gender-based violence and abuse. Our mission involves ‘working with survivors to end gender-based violence by championing evidence-based change’. We are an expert, independent and groundbreaking national charity, particularly recognized for our specialist expertise in multiple disadvantage and children & young people’s work. Our core work includes training, policy, research and consultancy.

Our approach to the Draft Domestic Abuse Bill

10. In the spirit of cross-sector solidarity, we are a signatory to a number of submissions from the VAWG sector and beyond. The submissions we support are briefly summarised below:

The second joint submission from a number of VAWG charities submitted on our behalf by Women’s Aid presents numerous recommendations including, but not limited to: the need for a gendered definition of domestic abuse, greater protection for migrant women, accessible provision for survivors living with disability and LGBT+ survivors, and necessary changes across the family court and criminal justice systems, social security, housing provision and health services.

The joint submissions from the children’s and VAWG sectors led by Action for Children present the need for greater protection and support for children experiencing abuse. This includes the need for the definition of domestic abuse to be extended to recognise children as victims in their own right.

The Inter-Collegiate and Agency Domestic Violence Abuse (INCADVA) forum’s submission presents the importance of an integrated health care response to enable early intervention when responding to domestic abuse. This includes the need for all health services to provide a strategic commitment to responding to domestic abuse, sustainable funding for specialist training and implementation of best practice, and prioritisation of the mental health needs of survivors.

The Violence, Abuse and Mental Health Network’s (VAMHN) submission presents the need for clearer recognition of the mental health impacts of domestic abuse and the role of mental health services in identifying and responding to abuse, as well as the need for action to address the under-provision of adult and child victims and perpetrators of domestic abuse.

11. We also support a number of additional priorities and campaigns.

The Step Up! Migrant Women Coalition, led by the Latin American Women’s Rights Service;

Southall Black Sister’s #ProtectionForAll campaign, including a comprehensive strategy on violence against and abuse of migrant women.

Rights of Women’s campaign to improve victims’ and survivors’ access to legal aid.

Imkaan’s ‘Alternative Bill’, which outlines a response to VAWG that is gendered and intersectional.

Surviving Economic Abuse’s call to extend the offence of controlling or coercive behaviour in the Serious Crime Act to post-separation abuse.

DRIVE’s call for the government to publish and fund a new Domestic Abuse Perpetrator Strategy.

Prison Reform Trust’s call for an introduction of a statutory defence for domestic abuse victims compelled to offend by their abusers.

Stay Safe East’s briefing and recommendations for disabled survivors.

Agenda’s Ask and Take Action campaign.

Further considerations and recommendations

In addition to confirming our support for these submissions to the Committee, we would like to make the committee aware of some further considerations. Of particular relevance are recommendations arising from our policy and consultancy work on multiple disadvantage (See: ‘Breaking down the Barriers’ [1] , ‘Mapping the Maze’ [2] and ‘Complicated Matters’ [3] ) and children and young people (See, for example: The Community Group Programme for Children and Young People [4] ).

12. Service Design and Pathways

Women experiencing multiple disadvantage do not typically present at specialist domestic and sexual violence services [5] . There must be a responsibility placed on all public services to enquire about abuse and ensure thresholds for support do not disproportionately exclude women facing multiple disadvantage.

Enquiry into current and historic domestic abuse should be standard practice across publicly funded services. There must be appropriate trauma and gender informed, support and pathways into care where abuse is identified.

Training around domestic abuse and multiple disadvantage must be standard practice across all publicly funded services. This must include insight into the interconnection between domestic and sexual violence, substance misuse and mental ill health [6] , trauma, and intersectionality.

All women experiencing multiple disadvantage who have experienced abuse should be able to access appropriate women specific trauma informed services as a priority [7] .

Thresholds and inclusion criteria for support should be reviewed by all services to ensure that women experiencing domestic and sexual violence and multiple disadvantage are not disproportionately excluded from the support they need and deserve.

Services should work collaboratively [8] and seek to break down service siloes and offer person centred, holistic and flexible support. For example, our work around best practice models [9] has shown the following to be particularly effective: mental health and substance use services being jointly led at a strategic level, one lead specialist to help women navigate other services, multi-agency services, assertive outreach, peer support.

13. Workforce

There should be a public duty on services to ensure their staff are appropriately trained to enquire about domestic and sexual abuse, and respond appropriately to disclosures [10] , including having clear referral pathways which reflect women's diverse needs and experiences.

Services must encourage and work towards diversity (of age, ethnicity, experience, ability, religion, sexuality etc.) in staff teams so that appropriate support is available to all women who have experienced violence [11] .

Women with lived experience need to be valued and prioritised as a positive, transformational part of the paid workforce.

14. Gender and Trauma informed practice

Government, led by the Department of Health and Social Care, should lead an evidence review on the value and impact of trauma informed approaches in public service settings. This should build on the evidence base [12] and develop national guidelines on what quality gender and trauma informed services mean in practice.

15. Poverty

The DWP, with the support of the women’s sector and women with lived experience, should produce a revised, updated and comprehensive Equality Impact Assessment for the continued roll out of Universal Credit, and for all future policy and decision making around welfare reform [13] .

16. Children

There must be adequately funded specialist domestic-abuse related therapeutic options of support for children (including young people experiencing abuse in their own intimate relationships).

All relevant staff members in publicly funded services [14] must have access to suitable training and resources around the impact living with domestic abuse has on children and how to handle disclosures and provide support. [15]

Relationships and Sex Education needs to be provided to all children and young people [16] from early years onwards. It should take place in all educational settings and needs to support children and young people to recognise abuse and understand where to get help, as well as promoting healthy relationships. It also needs to reflect the gendered nature of this abuse. This education should be supported by a Whole School Approach [17] to tackling abuse [18] .

The Government must produce separate statutory guidance on teenage relationship abuse. This should cover intervention, prevention and specialist support tailored to their needs.

The definition must be extended to recognise children as victims in their own right as set out in the joint submission from the children’s and VAWG sectors.

17. Child removal

Fear of child removal is one of the greatest barriers to disclosure of abuse, especially for those living with multiple disadvantage. The notion of ‘failure to protect’ places the burden of responsibility onto the victim.

The Department of Education should prioritise work to develop alternatives to permanent child removal that protect the child from short term risk whilst recognizing the long-term risks to both mother and child of permanent child removal into care.

Further investment is needed in Family Drug and Alcohol courts which are proven to be effective [19] .

Particular attention should be paid to alternative models (in the UK [20] and abroad) such as the social models in Germany, that have a greater emphasis on supporting parenting combined with temporary rather than permanent removal.

Children’s services should apply strengths-based approaches that enable women to draw on their strengths, make safe plans for their children, and allow decision making about a child’s welfare based on proper understanding of the family context.

A full understanding of the experiences of survivors facing multiple disadvantage must be embedded in all children and family social work training and development in England and Wales [21] . Multi-disciplinary teams should be in place in all local areas, drawing on the skills of substance misuse, mental health and domestic abuse practitioners to work alongside children and adult social workers.

More gender and trauma informed step-down and long-term support is needed to support mothers and children who would face both permanent and temporary separation.

In their current form, written agreements, which require victims to sign contracts with terms around their contact with the perpetrator, are highly problematic and should not be used.

18. Child to Parent Violence (CPV)

The bill needs to more adequately respond to the complexities of CPV. The bill currently refers to adolescent to parent violence but this needs to be amended to include children of all ages. In our work, we often get asked about children as young as four, as well as adult children abusing elderly parents.

Any work on CPV must take account of any trauma that many of these children will have experienced at a young age and how that manifests in behaviour as a protective pattern, so that practitioners are able to properly identify and respond. AVA and many other organisations are concerned about trauma being misdiagnosed as ADHD and conduct disorder among other labels.

The government should undertake a national prevalence study to ascertain the full scale and impact of CPV. Furthermore, social workers and other key frontline staff should be trained on a trauma informed approach to CPV.

The domestic abuse commissioner should work closely with the children’s commissioner to ensure appropriate support across sectors.

Funding must be provided to enable parents/carers to develop understanding and tools to support children and for children to learn healthy and safe ways to heal from trauma.

In recognition that adoptive families are disproportionately affected by CPV, we support Adoption UK’s submission to the bill committee.

19. Commissioning and Funding

As a matter of urgency, local commissioners must address gaps for women facing multiple disadvantage.

Commissioners should build incentives into contracts to encourage mainstream services to work collaboratively and ensure that specialist expertise, including that provided by the specialist women’s voluntary sector, is prioritised.

There must be a shift towards long-term commissioning. Outreach and support projects for women experiencing multiple disadvantage need sufficient time to engage with women who have otherwise lost trust in services. Short term projects risk being counterproductive and facilitating further distrust in services when women build trusting relationships which end abruptly.

Commissioners should ensure that services provide data on who is being turned away to allow data collection on service thresholds and provide clarity on local need.

The Cabinet Office should promote the take up of the Public Services (Social Value) Act 2012, which has a positive impact where used, to support local authorities to meet the needs of marginalized women in their area

Police and Crime Commissioners local plans should have a gendered lens that understands the connections between women’s offending and their experiences of domestic abuse, and enables more holistic commissioning that addresses the risks that cause women to become involved in the criminal justice system

Commissioning processes must involve genuine and meaningful co-production with women with lived experience at all stages. Beneficiaries should be supported with remuneration and/or through accredited skills and training

20. Local and National Strategy

A Secretary of State for Equalities should be appointed, with their brief including responsibility for driving cross departmental approaches to improving the national response in England and Wales to women experiencing and living with the legacy of domestic and sexual violence, abuse and multiple disadvantage.

A central government funding pot should be developed to invest in service redesign and incentivize local bodies to collaborate to break down silos and build better infrastructure to meet women’s needs in the long-term.

The Domestic Abuse Commissioner and the Welsh Advisors for Violence against Women, Gender Based violence, Domestic Abuse and Sexual Violence respectively must prioritise survivors facing multiple disadvantage. This needs to be done in partnership with both the Children’s Commissioner and the Victims Commissioner.

Local and national government departments must commit to robust research and gender disaggregated data collection that allows for an intersectional analysis across equality characteristics.

21. Survivor’s voices

The Government must commit to meaningfully engaging with survivors as experts by experience in any future review of the Bill and non-legislative guidance.


This Bill is an opportunity to transform the response to domestic abuse. This Bill can and must do more. This will remain a lost opportunity unless it reflects the support that women and children need. The focus of this Bill must move away from the limited attention on the criminal justice system, and instead focus on opportunities to make domestic abuse everyone’s business.

AVA (Against Violence and Abuse)

June 2020

[1] AVA, Agenda. "Breaking down the barriers". London. 2019

[2] AVA. Mapping the Maze. 2017. London.

[3] AVA. Complicated Matters – A Toolkit Addressing Domestic and Sexual Violence, Substance Use and Mental Ill-health. 2013. London.

[4] See:

[5] They are more likely to present at addiction treatment, criminal justice, health and homelessness services.

[6] See:

[7] Our work Mapping the Maze illustrates the stark gap in service provision for this group of women.

[8] See, for example: The MEAM approach:

[9] See, for example: Sharpen, J. (2018) Jumping through hoops: How are coordinated responses to multiple disadvantage meeting the needs of women? London: AVA, MEAM, Agenda and St Mungo’s.

[10] See:

[11] For example, evidence from the Survivor Consultations (insight into the experiences of survivors in the healthcare system as part of the Pathfinder Consortium) illustrated the need for diverse staff teams in the health system to appropriately support BME women and Deaf women who currently face considerable barriers to access and tailored support. See:

[12] See: Ava, Agenda. The core components of a gender sensitive service for women experiencing multiple disadvantage. 2017. London.

[13] For more on making social security work for survivors see: WBG, EVAW, Surviving Economic Abuse. Benefits or Barriers. 2019. London.

[14] Local authority, health workers, youth workers, teachers.

[15] For further considerations see: VAMHN, Survivor’s Voices, UKRI, McPin. Supporting ‘off-radar’ children and young people who are at risk of violence/abuse in their household. 2020. London.

[16] In particular, young people living in residential or foster care who are repeatedly shown to have limited access to RSE through multiple placement moves and disjointed schooling.

[17] See, for example,

[18] Our free award winning platform sets out this model for schools to follow to enable them to identify and respond to domestic and sexual abuse and will help them to provide high quality RSE.

[19] See: Harwin, J., Bachar, A., Ryan, M. & Tunnard, J. (2014) Changing Lifestyles, Keeping Children Safe: an evaluation of the first Family Drug and Alcohol Court (FDAC) in care proceedings. London: Nuffield

[20] Programmes such as Positive Choices (Suffolk Children’s Services) and Pause are notable here.

[21] The work of the Centre for Child and Family Justice and Lancaster University on recurrent care proceedings demonstrates the need for such an understanding. See:



Prepared 11th June 2020