Session 2024-25
Crime and Policing Bill
Written evidence submitted by Image Angel to the House of Commons Committee on the Crime and Policing Bill (CPB16)
Executive Summary
● Image Angel digital solution to online VAWG. We focus on safeguarding, harm prevention, and long-term wellbeing.
● We are deeply concerned about the proposed introduction of the Nordic Model and the potential criminalisation of adult services websites (ASWs), which will undermine existing harm reduction strategies and place sex workers at increased risk.
● There is clear international evidence that the Nordic Model increases violence, reduces access to justice, and worsens the conditions under which sex workers operate.
● Policies that criminalise aspects of sex work fail to prevent harm and instead intensify it, particularly for marginalised groups, including women, LGBTQ+ workers, migrants, and people of colour.
● We urge the Committee to prioritise harm reduction by rejecting these amendments and supporting full decriminalisation, alongside the development of evidence-based safety frameworks.
Introduction
1. Image Angel is a UK-based digital harm reduction solution.
2. Our work includes education, digital self-defence.
3. We believe legislative frameworks should be grounded in harm reduction and evidence, not ideology or stigma.
4. We are submitting this evidence to voice strong opposition to the introduction of the Nordic Model and the criminalisation of adult services websites, both of which are counterproductive to the goal of preventing harm.
The Importance of a Harm Reduction Framework
5. Harm prevention in sex work is best achieved when workers have the freedom and resources to take proactive steps to protect themselves.
6. Criminalisation, even when aimed at clients or third parties, undermines harm reduction by pushing work underground, increasing secrecy, and reducing access to support services.
7. When people are criminalised or forced to operate in legal grey areas, they become more vulnerable to violence, coercion, blackmail, and exploitation.
Impact of the Nordic Model on Safety
8. The Nordic Model assumes it is possible to criminalise buyers without endangering sellers. In practice, the opposite is true.
9. Evidence from countries such as France and Ireland shows that where this model has been implemented, violence against sex workers has increased and relationships with law enforcement have worsened.
○ In France, 63% of sex workers reported deterioration in their living conditions following the law’s implementation. (Médecins du Monde, 2018)
○ In Northern Ireland, researchers found the law had no impact on demand and that safety worsened (Queen’s University Belfast, 2019)
10. Criminalising clients makes them more reluctant to share identifying information or communicate clearly, reducing the effectiveness of safety screening practices.
11. Sex workers are left with fewer clients and fewer choices, increasing pressure to accept riskier work.
12. The model also increases stigma, isolates workers from community safety networks, and makes it harder to report abuse without fear of judgment or secondary policing.
Consequences of Shutting Down Adult Services Websites
13. Adult services websites (ASWs) are widely used by independent workers to advertise services, screen clients, and maintain control over their working environment.
14. These platforms support basic harm reduction practices: they allow for client verification, allow workers to decline unsafe clients, and reduce reliance on exploitative intermediaries.
15. The proposed amendments targeting those who "profit from the prostitution of others" would likely lead to the closure of these websites.
16. The consequences of similar legislation in the United States (FOSTA-SESTA) are well-documented. A study from the Hacking//Hustling collective found increased violence, loss of income, and reduced safety for sex workers after online advertising platforms were taken offline.
17. Shutting down ASWs will not reduce demand or trafficking - it will remove one of the few tools that independent workers have to operate safely.
Why Decriminalisation Supports Harm Prevention
18. Decriminalisation enables sex workers to implement harm reduction strategies without fear of arrest or surveillance.
19. It allows for cooperative working, access to legal recourse, and engagement with public health and support services.
20. It reduces the power of exploitative third parties by increasing worker independence and agency.
21. Full decriminalisation is recommended by leading global organisations, including:
○ UNAIDS
At-Risk Groups and Disproportionate Harm
22. Criminalisation disproportionately harms those who are already marginalised:
○ Women, particularly those working independently
○ LGBTQ+ sex workers, especially trans women
○ Migrants and people with insecure immigration status
○ Black and minority ethnic workers who are more frequently targeted by police
23. When safety strategies like client screening, working indoors, or using digital platforms are taken away, these groups are put at even greater risk of violence and exploitation.
24. A harm prevention strategy must centre these voices and acknowledge the unequal impact of punitive laws.
Recommendations
25. The Committee should reject the proposed amendments introducing the Nordic Model and the criminalisation of adult services websites.
26. Instead, the Government should:
○ Commission an independent review of sex work legislation grounded in harm reduction principles
○ Work in consultation with sex workers and frontline organisations
○ Support the full decriminalisation of consensual adult sex work
○ Provide long-term, trauma-informed support services and exit strategies for those who wish to transition out of the industry
○ Maintain and regulate digital platforms that enable safe, independent work
○ Consult upon the minimum safety standards required on ASW’s
Conclusion
27. Image Angel's work is built around preventing violence from happening, protecting digital privacy.
28. The proposed legislative changes would severely compromise safety efforts, particularly for those most at risk.
29. We urge the Committee to reject punitive approaches in favour of practical, evidence-based policies and preemptive solutions that promote autonomy, dignity, and harm reduction.
March 2025