Home Affairs Committee

Oral evidence: Violence Against Women and Girls strategy update, HC 731

Tuesday 27 October 2026

Ordered by the House of Commons to be published on 27 October 2026.

Watch the meeting

Members present: Dame Karen Bradley (Chair); Matt Bishop; Preet Kaur Gill; Mr Paul Kohler; Robbie Moore; Margaret Mullane; Dr Peter Prinsley; and Bell Ribeiro-Addy.

Justice Committee member present: Catherine Atkinson (Chair).

Public Accounts Committee member present: Anna Dixon.

Women and Equalities Committee member present: Alex Brewer.

Joint Committee on Human Rights member present: Peter Swallow.

Questions 1 to 60

Witnesses

I: Dame Nicole Jacobs, Domestic Abuse Commissioner, Office of the Domestic Abuse Commissioner; and Eleanor Lyons, Independent Anti-Slavery Commissioner, Office of the Independent Anti-Slavery Commissioner.

Examination of witnesses

Witnesses: Dame Nicole Jacobs and Eleanor Lyons.

Q1             Chair: I welcome our witnesses to this one-off session that the Home Affairs Committee is holding on the progress being made on the new violence against women and girls strategy, which was released in December last year.

We are delighted to be joined by guests including the new Chair of the Justice Committee, Catherine Atkinson; Anna Dixon from the Public Accounts Committee; Alex Brewer from the Women and Equalities Committee; and Peter Swallow from the Joint Committee on Human Rights, who will join us later. That demonstrates that this is a very cross-cutting, cross-Government piece of work, and that while it may be led from the Home Office, it is very much not being delivered entirely by it. Can I ask our witnesses to introduce themselves and then we will get into questions?

Dame Nicole Jacobs: Hi, I am Nicole Jacobs, the Domestic Abuse Commissioner for England and Wales.

Eleanor Lyons: It is lovely to be here. I am Eleanor Lyons, and I am the independent anti-slavery commissioner for the UK.

Q2             Dr Prinsley: Good afternoon. I am Peter Prinsley, MP for Bury St Edmunds and Stowmarket. You look very far away—we normally have a slightly smaller room. I hope you can hear us.

It says here that one woman is murdered every three days in this country, there are more than 100,000 rapes a year and about one in 20 of the population are said to be perpetrators of violence against women and girls. What impact has “Freedom from Violence and Abuse”—the VAWG strategy—had so far, and how does that compare with the impact of previous strategies?

Dame Nicole Jacobs: That question is really timely because it was just last week that our National Centre for VAWG and Public Protection set out the strategic threat assessment for violence against women and girls, and it was staggering. We also had some of our crime survey for England and Wales statistics last week showing an increase in domestic abuse over the last year. It is true that, in general, Government and society are starting to understand both the prevalence and harm of domestic abuse, and more widely, violence against women and girls. The Domestic Abuse Act has really helped to elevate things.

We are coming up to a year since the strategy you asked about was published. It was long awaited; we waited a year for it, with the new Government. One thing that was really positive was that it set quite a good context for the drivers of violence against women and girls. It certainly did not shy away from the idea that there are male victims, but it definitely took a gendered nature and understood and explained the gendered nature of these crimes, while, at the same time, not undermining boys and men who are victims. I thought that was very positive. It had a lot of language in it about misogyny, for example.

It took a cross-Government approach. Very often in years past, we have criticised strategies like these for being too criminal justice-focused. This was very much not only criminal justice-focused; you could see a real concerted effort across all Government Departments. Ellie and I are both hosted at the Home Office, but certainly in my role in domestic abuse I meet across all Departments—on housing, health and with the MOJ—and I can see how the strategy has influenced each and every Department to put their best foot forward. In particular, health is a very good example—probably the strongest example from my perspective in the whole of the strategy.

I have been in this role for seven years, so I have seen many variations of leaders and Ministers over the years. It was difficult for me to get a foot into the Department of Health and Social Care in the past, or what I would call a meaningful one. This strategy did create a commitment from that Department that is fairly substantial and I can also say is being implemented—creating a GP pathway called “steps to safety”.

The first 12 integrated care boards have just been commissioned. Fairly substantial funding has been put alongside that £34 million, which is actually not cited as a figure in the strategy that has subsequently transpired. Jess Asato MP has been given a role in the DHSC. I am sure we will go back to some of the positives. It is also positive in that it creates a view of a public health approach to these things, weighing much more towards prevention—early intervention not so much. We have often lurched in the past to crisis.

Frankly, my overarching worry about the strategy is that we do not have a grip on it, on some of the best parts of it. We are not transparent enough about where we are in terms of the actions. There is an entire document that lists all the actions in the strategy, and there is not enough understanding of the governance and accountability of the strategy in general. It has a lot of good ideas in it, but there are many, many actions where I cannot actually explain to you where we are right now, who is taking responsibility in Government for those actions, and how much funding and resource planning is attached to those actions. That is my overarching concern.

I highly question whether such a cross-cutting strategy should be led at the Home Office. I think we have to consider quite strongly our Prime Minister driving from the centre all sorts of things like rough sleeping—I was at the rough sleeping summit yesterday—and whether this strategy would be better governed from the Cabinet Office or No. 10. My last word on it is that we do not really have time to waste. This is a good strategy, but it has not got a grip and accountability on it. We are losing a lot of ground that we could be gaining if we were implementing the actions in it.

Q3             Dr Prinsley: Eleanor, would you like to say something about that?

Eleanor Lyons: Just to add to what Nicole said, I welcome that the strategy is cross-Government. I think it is ambitious. It is right that it is tackling the underlying issues that are driving the increase in violence against women and girls.

But from my position, I see the strategy as a huge missed opportunity to protect the women and girls who come and tell me about the harms they have suffered. Modern slavery is not mentioned in this strategy, and it was in previous VAWG strategies that we saw. In terms of the underlying metrics, we have that the Government are trying to halve domestic abuse, sexual violence and stalking—they are all very important things that we need to address—but we are not including in those metrics any national referral mechanism statistics or anything that outlines some of the harms that are happening when it comes to sexual exploitation and trafficking.

The consequence of that a year in is becoming really clear. The survivors I speak to do not feel that they have heard about the strategy or that it impacts them, and I think that is how we should judge success. They do not feel like they are being listened to in the delivery of the strategy, and the political will, attention and focus are going on areas that are explicitly outlined. So while I welcome the strategy—I think it is doing an awful lot of good beyond just transparency, accountability and ownership—I do not think it is truly recognising all the forms of VAWG. I would like to see sexual exploitation and modern slavery more clearly referenced in the strategy moving forward, and in the accompanying actions underneath it.

Q4             Dr Prinsley: Thank you for that. That was some stuff about the additional things you would like to see, but there is the question about the impact of what we have done so far. Can that perhaps be measured? There is a metric to halve violence against women and girls, and we have been at it for a little while now. Do you have any sense of whether we are going backwards or forwards at the moment?

Eleanor Lyons: When it comes to sexual exploitation, if we look just over the last year, for British women and girls, that has risen by 23%. That is not a metric that is underlying the strategy and what the Government are trying to achieve, but I still think it is meaningful. Sadly, it actually shows that, for some of the most vulnerable women, who often have overlapping needs—they may have been victims of domestic abuse or child abuse and are now victims of sexual exploitation—we are not managing to decrease that number. This is a moment, a year in, when we need to ask ourselves the question: what needs to change to be able to help that group?

Dr Prinsley: I agree; thank you for that answer.

Dame Nicole Jacobs: The strategy was published with metrics that were quite ambitious. When I first saw the metrics, I thought that it was a bold approach. The headline metric is quite pure; it is about the prevalence of women and girls among people aged 16 and over who are victims of domestic abuse, sexual assault and stalking. I think that plays straight into what Eleanor just pointed out, in that those are just three of the strands but not all of them. Some of the supporting metrics include female homicide, repeat domestic abuse and prevalence of sexual harassment, and there a number of sub-metrics as well.

My point is that, in general, we are almost a year in, and I do not know how these metrics are going to be measured—other than the headline metrics, which I believe is the crime survey for England and Wales. I have never seen or heard of a document—maybe there is one behind the scenes that I am not aware of—that shows me exactly how these metrics are going to be measured, and where we are right now. That is what I mean by the lack of grip and lack of transparency.

Q5             Dr Prinsley: What we are seeing is a fall in crime nationally, and all sorts of crimes are less, including burglary, assault in the street, car theft or radios being nicked, but what I do not think we are seeing—at least I have not seen any evidence—is a fall in violence against women girls or domestic violence. If anything, what you describe is an increase, which is very worrying.

Dame Nicole Jacobs: It is worrying. You would expect that the more you do, the more you would naturally see increases, because you may be helping people earlier, and people will be coming forward feeling more confident in systems. However, what lies behind the metrics? How are things being measured? What do we make of that analysis? A lot of that is not something that is being discussed openly and transparently.

I think we could accept some increases. For example, when you open up a GP pathway, you will absolutely see people coming forward to health early, as it is a trusted environment. If anything, you would naturally expect GPs to show more, and that would not be an increase, but it would appear as one. There is something about making sense of what the metrics are, but we can do that only if we are having a transparent conversation, and we know exactly how things are being measured, but that is not happening. It may be happening behind closed doors with Ministers—I can accept that that might be entirely true, but I am not aware of that.

Chair: It is very interesting. One of the points we made when were first talking about these metrics was that, if the focus is put on these things, you can have more people coming forward, and you will therefore have an increase in numbers. That is not actually an increase in prevalence, but it is an increase in reporting, and that is something to be careful of.

Q6             Mr Kohler: Thank you for joining us. The previous VAWG strategy focused a lot on pursuing perpetrators through the criminal justice system; that clearly has a huge a role to play, but it is not enough on its own. Dame Nicole, you mentioned the strategic threat risk assessment from the national centre published last week, which identified repeat perpetrators as a critical issue. Do you think enough is being done to pay attention to that to actually break the cycle of abuse?

That was my general question, and I also have a specific question. I am aware of the Drive Project at the Home Office, which I understand Cambridgeshire police are implementing. What is your view on that, and is there uptake from other police forces?

Dame Nicole Jacobs: There is still a lot in the strategy that has to do with criminal justice, and that is right. I know from victims and survivors of domestic abuse that the police will be one of the first ports of call. It is not a criticism to say that in the past we have focused on criminal justice; it was a natural place, but it is not the only place, and I think we have moved on from that. As you say, there are plenty of actions that the Home Office should be and is driving that are incredibly important, but if we look at what is in the strategy, in terms of early intervention and prevention, it is there, but it could be so much more robust.

It is also fairly underdeveloped, a year in. For example, there are commitments in the strategy that relate to schools. One of the things shown by the gathering of evidence prior to the strategy, which Government analysts conducted, was that schools-based work is well evidenced as effective, yet for the scale of the problem, we still have modest commitments from the Department of Education. At least they are there—that is better than before—but as an example, there is a fairly modest commitment on bringing together the right tools and information for teacher training or schools training. Again, I do not know fully how well under way that is, because we do not have a structure and a transparent way of knowing how and when the actions are taking effect.

There are some commitments about building the evidence base through the Youth Endowment Fund; that is definitely up and running. This is devolved to Wales, but from my travels in England particularly, there is a lot of activity in schools. There are lots of individual charities and initiatives, and some of them are very good, but we do not have enough of a community of practice or a coherent understanding of what good absolutely looks like and must be in each and every school. What is the whole-school approach?

So there is a lot missing and there is a lot half-implemented in that prevention strand, and I would say the same for the early intervention. It is a real mixed picture, and this is why I feel this sense of urgency: we do not have a lot of time, so let’s get on with seeing what those commitments are fully. When this strategy was published, we were told that it was the first version, that there would be other iterations and that it would build over the years. That is one area that needs quite a lot of building and a lot of emphasis that we do not have.

There is quite a bit on the online space, which I think we will come to. Drive is commissioned by the Home Office for a roll-out across the whole of England and Wales. It is one of many things that helps centre more focus on the perpetrator. Having a way of working for the police and partners that actually allocates a focus on the offender is really welcome. Some areas have taken to that better than others.

You will think that I am very repetitive, but again, if you said to me, “Domestic Abuse Commissioner, how many areas have rolled out Drive?”, I would say, “I don’t know, because I don’t have anything that is reported on in front of me.” I know anecdotally the places that I have talked to that are implementing Drive and how it is going. However, I do not know where we are in that roll-out. That is where we need much more grip and transparency so we can all get behind it.

There are lots of areas that would welcome getting behind some of this activity, but they have to know when they can depend on it coming, who is planning it and where they are looking to. I was in Wiltshire on Friday at an amazing event. People there needed to know from this strategy what is coming down the line that will help them get done what they would like to get done. We are all being held back by not having enough transparency here.

Q7             Mr Kohler: Repeat offenders are such a huge issue: a quarter of all suspects have committed three or more VAWG offences. Is Drive working or is it too early to tell? Is enough resource being put into dealing with this chronic issue of persistent repeat offenders?

Dame Nicole Jacobs: I do not think that Drive would answer all those questions. Drive is a good structure, and it helps create a positive structure of working, but it is not the only way to achieve this. My own strategy, separate from the VAWG strategy, very much focuses on the point of first contact with the police.

I believe that victims and survivors need and deserve an excellent first response so that we do not have a continual situation where there is no further action, where we are asking how many times that needs to happen, and where maybe the algorithms and some of the tactical policing methods are starting to kick in.

We need a much better quality first response from the police. That can, and should, be planned into police reform. We have that great opportunity in front of us. I hope that will happen, but again, that kind of thing is not necessarily written into the strategy. I felt that was an omission.

Q8             Mr Kohler: Eleanor, do you have any thoughts on that?

Eleanor Lyons: When it comes to modern slavery and human trafficking, the police have two roles. One is to help us identify potential victims and refer them into the national referral mechanism, and the other is to hold perpetrators to account when it gets to that stage. Looking across the numbers, they speak for themselves. There have been only 70 people prosecuted in England and Wales for modern slavery offences in the last year, against a backdrop of over 23,000 victims. There is clearly a big disparity there.

We know what works in terms of supporting victims through the criminal justice system with things such as victim navigators. However, taking a step back from the VAWG strategy, the Government have cut funding for dedicated modern slavery and human trafficking teams in police forces. In order for us to say that this should not be a high-reward, low-risk crime, we need that to be matched by Government funding, messaging and rhetoric beyond just the strategy. At the moment that is missing.

Sadly, when I speak to frontline services and survivors of sexual exploitation, they do not feel like their perpetrators are being held to account. That is compounded by them having to navigate a system that lasts for years. They are having to hold that trauma and live with that uncertainty. I know that we will come on to talk about the early release scheme, but they are also beginning to question whether it is really worth them navigating that long system to maybe not even end up with offences in place at the end or for their perpetrator to be released quite quickly.

When talking about the cross-Government nature of the strategy, we need to look at Government as a whole and the entire message that they are giving to female survivors. I do not feel like we are doing enough to prevent that harm when it comes to modern slavery.

Q9             Chair: I want to ask about data. It has always been the case that it is nigh on impossible to get data. Police forces record things differently, and things are also recorded differently in the criminal justice system. It is very difficult to get that information. We met a group of Romanian MPs last week and they have just passed a femicide law. It does not actually change the offences, but it makes femicide something that has to be recorded and properly identified. Do you have any thoughts on that?

Dame Nicole Jacobs: That sounds really positive. One of the things that has happened—I think it was a positive action in the strategy—is the notion of the DA-flagged offence. That sounds very simple but it creates a judicial finding so that, at the time of sentencing, it is very clear what is a domestic abuse-related offence. That then helps when we need to understand the data later, and very practically from the standpoint of probation—overseeing offenders upon release, and that kind of thing—it means that they actually know what the domestic abuse-related offences are.

We have not known that, believe it or not—I think that the Committee know that, but most people would not appreciate that that information is hard to find. We have to do much more to make changes such as what you said to make sure that the data is really clear. On domestic abuse homicide and suicide, we have made some progress in coming to terms with those tragedies and trying to learn from them, but there is a whole range of other femicide-related crimes for which we need to do the same. I think you are right, Chair.

Chair: We will move on to Government leadership of the strategy.

Q10        Alex Brewer: I want to dig into some of the things you said already without necessarily going over the same ground. The Government had a well-publicised and ambitious aim to halve violence against women and girls in a decade. Is it clear to either of you when that decade started?

Dame Nicole Jacobs: I consider that it started from the point of the strategy last year. A very important milestone is coming in December, when we will be a year into that strategy.

Eleanor Lyons: I interpreted it in the same way.

Alex Brewer: Okay. Thank you. It was not very clear to me whether it was immediately after the election or when the strategy was launched, or whether it had not even started yet.

Dame Nicole Jacobs: I mean, we could be wrong. It is possible. When did the metric start? I think you are making your point there.

Q11        Alex Brewer: Dame Nicole, ministerial responsibility for VAWG has changed recently. Has that affected the engagement with the Government that you talked about?

Dame Nicole Jacobs: Yes, it always does. As you will all know, any time there is a shuffling of key ministerial posts that creates disruption. For this strategy it feels very much that the day-to-day responsibility sits between the Home Office and the MOJ, with the Safeguarding Minister and the Minister for Victims. We are on our third Home Office Safeguarding Minister and our second holder of the MOJ post; some of the same people have also come back.

The larger point is that although those exceptional leaders help to drive the work day to day, the issue needs much more serious elevation to and attention from our Secretaries of State. I have seen the difference over time when that happens, and what happens as a result. It may be that Secretaries of State attend interministerial groups on the strategy; they may include the strategy in some of their discussions. I am not fully aware of those, if they are happening, but we need to see much more of the heft of Government.

I was delighted when I saw our Secretary of State for Health and Social Care speak in her conference speech about a public health approach to domestic abuse. That is what we need. That really helps people like Ellie and me, when we are interacting within Government, to push things ahead and drive accountability. There needs to be some kind of elevation.

Having yesterday seen the Prime Minister talk so clearly about rough sleeping, I want to see some equivalent leadership on this strategy. There are obvious ties to homelessness and between this strategy and other strategies in Government. I understand that in the new year the Prime Minister will be publishing and sharing with us a 10-year plan for Britain. Violence against women and girls absolutely must—not should, but really must—be in it. We need elevation.

Q12        Alex Brewer: Are you both confident that this is still a Government priority and is being taken seriously across the different Departments by Ministers and officials?

Dame Nicole Jacobs: I do not believe that, to date, this strategy has been implemented in a way that shows that it is at the top of the priority list, in terms of resource and all those things. I really feel that we can do much, much better to realise the ambition of the strategy.

Eleanor Lyons: I would broadly echo what Nicole has said. With the previous Prime Minister, when the strategy was launched, it was very clearly part of the Government’s mission. I think there was a lot of attention, excitement and hope for what the strategy would achieve.

It is hard to see a similar level reflected at the moment, but I think there is a new opportunity with the new Prime Minister to outline that we can and should be doing this and to start looking more broadly at how we measure it, who is accountable and where it should be owned—and make sure that it is reflecting all the vulnerable groups of women as well.

I have had positive engagement with the new Ministers, but I think that Nicole is right to say that when we get new Ministers, they understandably have a whole new brief and area to commit to. There is a chance or moment where we can hopefully see what that will look like in the new Administration.

Q13        Alex Brewer: Is the VAWG strategy advisory board a useful forum for influencing Government activity and ensuring that it is informed by lived experience?

Dame Nicole Jacobs: I stood on that advisory board, and it is useful in that many of the right people are sitting around the table. But there are limitations in that, with such a broad strategy, how could you imagine having over 200 actions without having more metrics and transparency in front of you?

I appreciate that it is not a governing board; it is very much set up with the terms of reference to advise and have some element of accountability because of the expertise in the room. But it is very hard to do that if you do not have information. For example, the papers are sent out a week in advance. A lot of the broad discussions can be about one subject at a time, but you are only meeting once a quarter, so you are not covering them all.

This is such an ambitious strategy that it requires, I would say, more sub-groups and clarity for each Government Department that is leading on particular actions with their own way of governing their actions. You can have an amazing, expert domestic abuse service, for example, and it may not be expert in all areas but it could be very useful in some areas of the strategy. There needs to be a broadening of what that good governance looks like, and I would say that that can be improved.

Again, one of my frustrations has been feeling that we could be going so much further, faster if we had some governance that we could lean on. Then I could understand who is leading, where the activity is and who I am getting in touch with in each and every Department. Helping to signpost would very importantly get survivor voice into the planning of those actions. But that is just not what I see.

Q14        Alex Brewer: Are you saying that that survivor voice is not being heard and fed through enough at the moment?

Dame Nicole Jacobs: In some cases, yes. In some of the things in the strategy, which will ultimately result in frontline service delivery by charities, they will likely have quite a lot of survivor input and may be led or run by survivors. We have something called “Our voices matter” at the Domestic Abuse Commissioner’s office, where we have over 1,000 people who we communicate with and engage with. We have brought some of those voices into Government as much as we can, but we have very limited resource for that—we have one full-time equivalent worker who is able to help us with that, primarily. Again, further investment in that is needed.

Eleanor Lyons: When it comes to the advisory board, I think it is a really good idea that they should bring together some kind of accountability mechanism for the strategy. But when it comes to the modern slavery sector being represented on that board and my office being represented on that board, so far we have not been. The consequence of that is twofold. There is a whole voiceless section of women who are affected by sexual exploitation that is not being heard at that advisory board. It also means that when policy could be co-created, collaborated on and better as a result of that, we are missing those opportunities.

I have pushed the Home Office a lot on this point. They assure me that the advisory board will have a rotating membership, and everyone will be heard on it eventually, but I am really struggling with the transparency around it, how that will happen and in what order they are going to discuss topics that are really important. I see that as quite a basic ask and a fundamental thing that we need to understand—who is being heard in this VAWG strategy, and what are we achieving against the things that are laid out in it? The advisory board will hopefully be expanded, but at the moment it is not working in a way that really represents the survivors of modern slavery.

Q15        Alex Brewer: It seems to me from what you are saying that neither the big picture horizon-scanning piece nor the detailed work of objective setting and meeting those objectives is quite hitting the spot. Have I got that right?

Dame Nicole Jacobs: Yes. Looking at the diversity and range of work in this strategy as it is laid out, if you want Government and civil servants to be getting the best advice and information, you would immediately recognise that you could never achieve that in one quarterly meeting.

You would have to have some kind of structure across Departments where you could really understand where you are gaining that expertise. You mentioned Drive and DAPOs. There are working groups—I am not saying that there are not—but they are fairly disparate, and I am not sure they are feeding into decision makers how well we are achieving these parts of the strategy. There is room for improvement there.

Q16        Alex Brewer: I have one final question. This is obviously a huge cross-departmental thing, as indicated by how many people we have here. Which Departments are really prioritising the actions needed for this Government’s ambition, and are there any Departments that could be doing more?

Dame Nicole Jacobs: I have already given a very clear indication that I have been very pleased in terms of understanding the Department of Health and Social Care’s commitments, where they are on them, how much money they are investing, and the kinds of things they are doing above and beyond what is in the strategy already. That is a really good example.

In terms of the Department for Education, if you put aside the schools work we have already talked about, their answer in the strategy to the kinds of services that children who are victims of domestic abuse—who we have defined as victims in their own right—will get is, “Look at Families First, broadly. Look at the £1 billion-plus of funding that we are putting in, which is essentially how we will redesign and implement children’s social care.” That is not answering the question very specifically. To me, there is much more that the Department for Education could be doing to step up and be clear about what that is achieving. That is a huge priority for children who are victims of domestic abuse, given the prevalence.

I would put the Home Office in the category of “well under way” in terms of, broadly, some of their commitments. But, again, there are some real hiccups along the way with regard to the protection order roll-out and some of the key strands there.

I am sure we will come to MOJ, but I feel that with early release and some of the pressures on our system, some of their commitments are getting overshadowed and not being implemented. It is the same with DWP. That is what I mean about looking at something whereby we could say, “What’s the accountability on these actions? Who’s making sure that they are getting done?” That is the sense of urgency that I feel. It is a question of having to face up to that.

Another huge one that I am sure we will come to is DCMS and all of the online space and harms. There are many question marks and underdeveloped areas, but there is some progress. It is a mixed picture.

Eleanor Lyons: I would echo that. Nicole has outlined some of the Departments that we have had very good engagement with. Jess Asato, leading the VAWG health work, has been hugely helpful. She is very inclusive in terms of understanding all the forms of violence against women and girls and implementing change. In the online harm space, we have had good engagement with DSIT and with MOJ. I always find them very collaborative and wanting to listen to victims.

I would say, taking a step back, that the Home Office is presenting quite a challenging message to survivors of sexual exploitation at the moment, because on one hand they have the VAWG strategy, which is of course saying, “We’re here to identify and protect you,” and on the other hand they are introducing credibility assessments for survivors of sexual exploitation in the Immigration and Asylum Bill.

If survivors have similar accounts to any other survivors, if they have taken too long to come forward or if there are inconsistencies in their accounts, which we know can happen because of trauma, their credibility must be questioned under the new law changes. The reality, when I speak to frontline services and survivors, is that that is the main thing that is impacting on them at the moment. While the Government may be doing really good work across Government to try to identify and protect them, we are sending a message to survivors of sexual exploitation that, actually, their credibility is going to be questioned.

For this cohort, that is undermining the trust in the overall strategy and in the hope that Government are there to protect and help them. So while I am having positive interactions across Government, I don’t think I can overlook this harm that is being done in legislation at the moment.

Chair: That is interesting because we fought for so long for victims to be listened to and believed. Training through the College of Policing and everything else has all been about victims being believed in order to have the confidence to come forward, so what you say is worrying. Nicole, you make very powerful arguments for, perhaps, ownership of this to be at a different Department from the Home Office—in the Cabinet Office or No. 10 maybe.

We are going to move on, and Anna Dixon is going to continue on the financial side of things and Government leadership.

Q17        Anna Dixon: I have just one quick follow-up question on cross-departmental working. And thank you, Chair, for inviting me to guest from the Public Accounts Committee. We looked at the last Government’s VAWG strategy, and one of our conclusions was that “the Home Office failed to secure the full support of other government departments.” Are we at risk of history repeating itself, Dame Nicole?

Dame Nicole Jacobs: Yes, we are. Again, it’s somewhat of a mixed picture. I will lead with a good example. This strategy didn’t say how much the Department of Health would commit to Steps to Safety, and they committed far more than I thought they would when I read the strategy a year ago, so that’s positive.

I didn’t mention MHCLG a moment ago, and that was a huge oversight, because of part 4 of the Domestic Abuse Act. There is some serious resource and commitment to accommodation-based duties. There has been a real willingness in that Department to see the intersections between domestic abuse and homelessness. So I should have said that earlier.

But you are exactly right. If you look at these actions and ask yourself, for any that would require resource, “Well, what’s the resource?”, you wouldn’t know, and I still wouldn’t know. That is the case for most of the actions—except for that health report or work. We absolutely need to see it. If you look at the actual financial picture and at funding for specialist services, which traditionally comes from pots of money but mainly through MOJ, through police and crime commissioners, the fact that they are being abolished creates a lot of uncertainty. Devolution, which we may come to, presents a huge amount of possibility, but also some uncertainty and difficulty if it is not done in the right way to wire in the aspects of domestic abuse and VAWG services. There are real uncertainties there.

A stable part of that picture is the duty created in the Domestic Abuse Act for accommodation-based services at MHCLG. But it is still absolutely the case that, on the frontline, those timescales of funding are very short—the trajectories are short. I am not clear what each Government Department is contributing financially, and I have asked for that—I have absolutely asked for that—because, at the very least, we should understand what we are achieving for VAWG and domestic abuse within, for example, Families First, Changing Lives or all sorts of Government funds. Again, I do not have the answer to that, and we should be able to have the answer.

Q18        Anna Dixon: One of the things the Home Office committed to in their Treasury minute to us was, first, to establish a cross-Whitehall team to monitor delivery of the VAWG commitments. It seems that if that team were meeting and at least reporting publicly, either to Parliament or to the VAWG strategy advisory board, that would go some way to meeting your desire to know whether the 200-plus actions are indeed being actioned. If they were doing that and reporting on it, would that go some way towards the transparency you are looking for?

Dame Nicole Jacobs: There may be something that Ministers are sharing with each other and seeing that I do not see; I concede that that could very well be the case. But the point is that that needs to be much more transparent, first, because that helps us understand where we are. It is also really important for local areas that are trying to get this right. They must understand what is being done that will ultimately contribute to what they are trying to achieve on the ground.

You can look at those examples and some of those commitments and think, “When is that going to happen? Is there funding attached to it?” If the answer is, “I do not know,” it is not helping the planning or sharing of that ambition with the rest of the world.

Q19        Anna Dixon: One of the other things we called for was a joint spending review bid. I do not think that that actually happened, so one of the challenges is understanding how much is being spent to deliver the VAWG strategy. Eleanor, have you seen any increase in Government funding for services related to modern slavery? Has there been any increased certainty? My understanding was we were moving towards three-year commissioning for some of the brilliant voluntary and community sector organisations that support victims and survivors. Is that coming through at all?

Eleanor Lyons: The modern slavery victim care contract is being re-tendered at the moment, and I think the Government will soon announce who will receive that. That is welcome.

We have seen a big increase in the number of victims of modern slavery, which does put extra pressure on that service. Women and girls are moving through it more quickly, and when I am on the frontline with services, I often find that it is charitably funded safe houses, which we do not see as the Government or in the official statistics, that are looking after women and girls long term and providing that specialist care and support. So while I welcome the modern slavery victim care contract continuing, I do not think we are fully understanding the need and the prevalence of harm out there.

As I mentioned earlier, when we have cut police funding to dedicated modern slavery and human trafficking teams, on the one hand we are continuing to support women once the harm has happened, but on the other hand we are not doing enough to prevent harm from happening or to hold the perpetrators to account. So I do not think we are seeing the whole, and that loss of specialist teams is very detrimental to these women.

Q20        Anna Dixon: What about spending for domestic abuse, both on prevention and support?

Dame Nicole Jacobs: There are some parts of the strategy that outline increases—for example, on safe accommodation, which had roughly an additional £19 million from previous years, and that is because it is a statutory duty.

Through MOJ, there was a 2% increase for police and crime commissioners for the funding for victims. That was outlined as a little over £1 billion in the strategy, but that was for all victims of crime, not just all violence against women and girls—there are obviously other victims of crime who need support—and it was over three years. If you factor in all the kinds of real-time increases, it was not really an increase as such, although it was set out as a 2% increase. There is also helpline funding out of the Home Office and the Drive funding that was mentioned earlier.

There are some things that we know of, but I have wanted to try to get to the bottom of the larger pots of funding, like Families First or other funds within Government. They are named in the strategy, but it is not very clear what they are achieving and how they are achieving it for violence against women and girls, and that really needs looking at. I have asked for that detailed breakdown, and we should be able to see that. It helps trusts and foundations, and it helps all sorts of ways that people can collaborate and play their part in achieving these aims. We need to see that.

Anna Dixon: Unfortunately, it seems that we count public accounts by Department, so we look at all the departmental accounts, but with a cross-Government strategy, it is very hard to follow the money and find out what has been spent on these items. That is something that perhaps we need to push a bit harder for.

Q21        Catherine Atkinson: I have one short follow-up. Having multi-year settlements is so important for organisations to be able to plan for their future and ensure that they are able to have clear strategies. With the uncertainty about what things will look like post police and crime commissioners, are you concerned that the impact on the ability to plan into the future means that organisations face the same uncertainty they faced when it was constantly just funding year by year?

Dame Nicole Jacobs: I was at first slightly panicked about that, but I understand that there is clarity within Government that that transition needs to include very careful planning for the victims’ services. I do not think that that is something the Government are unaware of or that people are not planning for, but I still think that it is inevitably going to create difficulty, because we were looking forward to the idea of more multi-year settlements.

I am kind of agnostic about the decision about police and crime commissioners, but the point is that it now creates disruption until we know some of the really key decisions in relation to police reform and how the Government may or may not implement a duty to collaborate for the funding of domestic abuse and sexual violence services, which stemmed from the Victims and Prisoners Act, which has still not been implemented. Partly because of all those changes, until we know a bit more about the devolution planning, it is still very up in the air.

I feel that there is a lot to gain in some of these plans, but we have to be very careful about the safeguards around how victim services are planned for in these transitions and who is responsible as more of these decisions are being taken locally. There are some really great mayoral authorities and other local authorities, and there is some really good practice out there that really speaks to your last inquiry in 2025 about buy-in for provision and transparency of how money is being spent at the local level. There are good things to hold on to, but they have to be planned into devolution, they have to be planned for in some of these transitions, and they have to be very explicit for that to happen, I am afraid. Safeguards are needed.

Chair: We will come on to devolution in a moment; I will bring in Matt Bishop first, and then we will go to Bell Ribeiro-Addy on devolution.

Q22        Matt Bishop: Thank you both for coming in and spending the afternoon with us today. Prior to my appointment to this Select Committee, I sat on the Justice Committee. I am acutely aware, from both sides, that concerns have been raised about funding being primarily used and allocated for criminal justice responses, rather than to maybe achieve the structural changes that we believe are needed to tackle the causes of VAWG. Do you both agree?

Eleanor Lyons: It is hard to tell where the funding and attention are going across those areas. I do not think that we should underestimate the scale of the structural change that we are trying to make, though. When I look at the research that we are seeing on rising sexual exploitation in the UK, there are freely accessible websites that have punters talking about how a girl was clearly trafficked, drugged and exploited, and they still chose to rape her and not report that harm to the police. So I do welcome the level of ambition in the VAWG strategy, but I am nervous, still, that it will not actually get to what we are trying to challenge and what we are really trying to stop occurring.

From my side of things, it does not feel like we are truly managing to tackle the criminal justice system and the response there, and there are still big challenges. When it comes to the action plan underpinning the strategy, I look at how it is going to help the survivors I hear from every day. While some progress has been made, particularly for children, I am not sure it is actually going as far as I would like, as quickly as I would like, on challenging some of the harms happening to adult victims of sexual exploitation.

Dame Nicole Jacobs: I genuinely believe that it has to be both things. We have to have a rigorous criminal justice response that we are confident in. I also think that victims can really benefit, in that first contact with the police—no matter what happens with the criminal justice response—from the ability of the police to give a good, believing response and to help signpost and connect victims very early on to people in their community who can help them. That is one element of early intervention.

There is so much about the criminal justice system that requires improvement. But, again, if you think of the key elements in this strategy in terms of where people go for contact at the start—for children, it would be schools, youth clubs and online spaces—it is a very mixed picture in terms of how well we are progressing. Presumably, these are the kinds of things that you would really like to see much more emphasis on.

On health, again, we could do much more beyond GP pathways; we could do much more in mental health spaces. There is so much. When I say that this strategy is comprehensive, I do not mean it is comprehensive as in it has absolutely everything in it; it is a good start in terms of some serious effort in the prevention and early intervention space, but it is certainly not getting us as far as we need to be. I hope that answers your question; I am not quite sure whether it did.

Q23        Matt Bishop: It does, thank you. What would you both do to bring victims’ voices, or survivors’ voices, to Government, to help make decisions on how to allocate funding in this area? What would you suggest, or what do you do, with Government?

Dame Nicole Jacobs: We have a network, so every single report that we publish would be fully informed by lived experience through that network, or through seeking views from all sorts of local networks that already exist.

We bring people to Government at roundtables. We did a survivor summit that included all Government Departments, and civil servants in those Departments as well as Ministers, to give them more exposure to very particular topics. In all our consultation responses, a lot of the day-to-day work—the fabric of the organisation—is about doing that. I try not to think of myself as the only voice, but as a bit of a conduit to quite a diverse range of people who want to speak to decision makers.

Early release is a great recent example. I have been talking individually to many victims about what they are hearing from probation, for example, and then bringing those conversations directly into my discussions with Ministers and civil servants. It is a pretty diverse range of methods and ways, but you never feel that you are doing that enough.

Eleanor Lyons: Similarly, I host a summit bringing together 15 lived experience advisory panels from across the UK. I say to survivors, “What do you feel about the strategy? What do you feel about the Government? What do you feel about the legislation at the moment?” I do my very best to amplify their voices and take that to Ministers and officials, but I am deeply conscious of the fact that the main value comes from policymakers hearing directly from survivors, not with me in the middle.

I have asked the Government and Ministers to attend the summits themselves and hear directly from survivors about their experiences. Back to your point about criminal justice outcomes, it is in those meetings and convening points that you hear from survivors that police still treated them like they were criminals rather than victims in some cases, and that they were treated as though they had made bad choices, not as women being sexually exploited and held against their will.

There is a lot we need to do to improve survivor engagement. I hope the survivor panel will be convened by the Government and Ministers so they can hear directly from those women.

Q24        Matt Bishop: That is really important. What has the response been from Ministers when you have invited them?

Eleanor Lyons: It has been mixed. No Minister has yet turned up at the summit, but I have invited the most recent Safeguarding Minister, and I very much hope she attends the next one.

Dame Nicole Jacobs: We have had fairly decent engagement with Ministers in some of the activities I described. I do not want people to think that Ministers are not engaged. My experience is that they have been quite engaged, so there may be a bit of a mixed picture.

Q25        Matt Bishop: Moving on a little bit from those examples, do you have any examples of work from up and down the country that has perhaps been good at preventing VAWG and that you think should be adopted nationally or applied in different parts of the country?

Dame Nicole Jacobs: There are always great examples across the country and pockets of really excellent practice. A couple of years ago, we organised the festival of practice because we wanted to show local decision makers and local commissioners of services what the best responses to domestic abuse were by schools’ work, family court, health, counselling, community groups, and religious leaders. We wanted to showcase all of that.

There are good practices, but on prevention, we will all be typically thinking of schools work and work in communities. Yes, there are great examples, but very often they do not get the elevation and roll-out that I might expect. That is partly because there will be questions like, “Have they been fully evaluated and have they had some threshold of evaluation?”, which is probably really unrealistic for a small, regional or local initiative. We get a lot of holding back on the basis of that type of argument.

On the flip side of that, a lot of Government funding will eventually be spent on some of those things at the local level. The Department for Education is a great example of where we need a much more rigorous community of practice about those kinds of initiatives because they are so varied and dispersed in so many places.

We do a lot of recreating the wheel without giving clear inspiration and guidance from some of what we know. A lot of what the Government hear about is from second-tier organisations; they are not hearing those examples, so both of us bring them into the room as much as we possibly can or put them into our reports as case studies and evidence.

Eleanor Lyons: I am lucky enough to be UK-wide, so I get the opportunity to speak to the devolved Administrations, and there are cases there when they are really focused on prevention. In Scotland’s VAWG strategy, they explicitly mention the harm that sexual exploitation and modern slavery does, because they have named the harm and acknowledged that it is there.

You see a lot of good programmes coming from the Government, such as Routes Out, where they try to prevent sexual exploitation from happening on the streets of Scotland before it occurs, which is really positive. There is a lesson there about acknowledging what is going on and then acting to prevent it.

I work with an APG in Northern Ireland, and they are really good at acknowledging how the online world is facilitating some of this harm. In that way, they are sometimes far more forward-thinking than we are collectively out of Westminster because they notice the harm happening online, acknowledge the trafficking and then look at what they can do about it.

From my visits to Wales and going into meetings with them, they have truly embraced the public health response we have seen in this VAWG strategy. They obviously have some advantages in having fewer things to deal with across the board, but there is a real lesson there in how well they join up services. They get together and convene modern slavery conferences, and the Minister is at it; it is a clear focus. It is not perfect, but when I work with the devolved Administrations, I find that there are some good examples we can learn from.

Q26        Matt Bishop: I want to come back to Dame Nicole’s comment about the Government perhaps not looking at this as quickly and robustly as they should until we get further down the line. I am sure that I know the answer, but you can just give a yes or a no: when I was a police officer, I used to say that prevention is better than detection, and I assume that you both agree that that is the case in VAWG, or in any case.

Dame Nicole Jacobs: Absolutely. The earliest effective intervention is the better one. Wales has Ask and Act, which gives the sense that everyone has a responsibility to ask and act in whatever service they are in or whatever response they give. They do a lot of work with the police on early help and with young people who you would not feel comfortable calling perpetrators of abuse but are showing early signs. They really have a joined-up approach in relation to that, and they do much more clear and comprehensive schools work.

In your report in 2025, you talked about buy-in for services. In Wales, they have a provision for supporting buy-in for services across Wales. Now that Eleanor is mentioning Wales, there are really good examples of that joined-up, preventative approach there.

Eleanor Lyons: I would say that prevention is the key when it comes to this. A lot of the women and survivors of sexual exploitation I meet—I know that we are talking about things in silo and you have Nicole and me here—have experienced multiple forms of harm and abuse over their lifetimes, as you will know. They have very complex needs.

It is hard because, once someone has suffered from child abuse and then domestic abuse, they can often end up being sexually exploited. Ideally, we want to stop any of those things happening, because the recovery journey is so challenging for those women. When we speak to them, what they have gone through is absolutely horrific.

Q27        Bell Ribeiro-Addy: I want to come to you first, Eleanor, and ask about the Prime Minister’s vision for devolution. How would you expect it to affect the Government’s approach to tackling violence against women and girls overall?

Eleanor Lyons: Care for victims of modern slavery is delivered at the moment by the Salvation Army. They provide the support structure, which is very welcome. I would like to see a drive to make sure that victims of modern slavery are not forgotten in devolution. Far too often, when I go to visit fantastic services or safe houses, or even local police forces, I meet people who happen to be hugely passionate about stopping this harm and holding the perpetrators to account. If they move on, the whole system in that local area can dissipate and disappear.

I do not think our response at the moment is systemically embedded in local areas enough. With devolution, I would very much like that to change and for us to be far clearer about how systems wrap care around survivors. I see great examples of multi-agency working in Nottingham or when I visit Wales, but we should look at that across the board. How do we embed that in the changes coming with devolution?

Back to the data point, I would like there to continue to be some kind of national join-up, so that we understand the scale of harm that is going on, rather than local areas—this does happen at the moment—having their own response and keeping their own data, that then does not feed back up to us understanding what is happening across the country.

Q28        Bell Ribeiro-Addy: Are there areas where greater devolution would not work?

Eleanor Lyons: When it comes to children, we have seen the devolved decision-making pilots being rolled out by the Government. That does work, where you see local safeguarding teams wrap care around that child and assess whether they are a victim of exploitation. That is done by professionals who know them best, and that completely makes sense for us on that side of things.

I am less clear about how that would work for adult survivors of exploitation, in terms of the national referral mechanism. I do not know if we can devolve that decision to local areas. I do not think the thinking or the policy thought has gone into it yet to see how that would end up working in practice.

Where local areas take the lead and wrap care around survivors in the way that they know best, it works fantastically well, but for me, it is still too reliant on people who happen to be hugely committed to this area, rather than us asking every local authority to have a modern slavery co-ordinator or every police force to have a specialised individual who knows their first responder organisation, how to act in a trauma-informed way, and what they can do with the CPS to take forward the criminal justice process.

It is too much of a mixed bag at the moment, depending on where you are in England. If the devolution process helps to improve that, that is welcome, but I would not want it to add any more complexity to the system.

Q29        Bell Ribeiro-Addy: What things could they do to avoid a postcode lottery?

Eleanor Lyons: With victims of modern slavery, it is slightly different from what I think Nicole will go on to say. The Salvation Army works across the country and provides care for individuals. The Home Office already has quite a good idea of what the safehouses are doing on that side of things and how many survivors are entering them. For me, it is about better join-up at a local area.

We will touch upon the duty to collaborate, but where multi-agency partnerships are happening, that is when we are doing the best work on prevention. When we have charities embedded in local police forces, going to visit brothels and making sure that women in them are truly consenting and not being sexually exploited, I see the best practice happening. It is very much that encouragement of people coming together from different safeguarding professions and understanding what is happening in those communities where I see the best outcome for survivors.

Q30        Bell Ribeiro-Addy: Dame Nicole, how do you think we can go about avoiding the postcode lottery of strong commissioning in some areas sitting alongside weak provision in others?

Dame Nicole Jacobs: It is so important for your Committee to consider the impacts of devolution, partly because there are some real possibilities for improvement, such as the concept of pooling budgets and bringing together services, local leadership and shared objectives. All of that is really important, but there are some simple yet highly relevant points to consider.

Domestic abuse services sit at the intersection between health, housing, criminal justice, community work and children’s social care, but they are not themselves sitting in core budgets. The domestic abuse services are not statutory requirements unless you are talking about housing; an accommodation-based duty was established in the Domestic Abuse Act. I would say that domestic abuse and a lot of these issues are a real test of devolution, and therefore they have to be understood and wired in from the start. They cannot be an afterthought—how will we figure out how to do this after?—they have to be a good test for us about that. 

We have spent quite a lot of the summer on this, and in fact I published a discussion paper on devolution and domestic abuse for this very reason. It is really interesting to go to more mature mayoral combined authorities and some emerging ones and really get your head around it, as I have been trying to do—I think that is all very natural to you.

The combined authorities are a real opportunity for some of what you talked about in your report in 2025—how you plan for by-and-for services, how you have that strategic oversight of an area and ways to structurally raise the early-intervention prevention work you would want to see in every area.

What I am more concerned about is the local authority area and, unless this is planned for, where the actual commissioning of the frontline service provision for local authority housing and children’s social care will happen. That needs much more planning and thought in devolution, so in my discussion paper we talk about national safeguards being needed and making sure there is some strong clarity role in national Government in some of that delivery.

What are the objectives that have to be met when that devolution takes place? What are the strings that will be attached to some of that devolved decision making? Those things are really important. If the legislative hooks that we might need, such as the duty to collaborate, have these challenges in implementation in mind, that could help us quite a lot.

Q31        Bell Ribeiro-Addy: I was going to ask about that, actually. It has not been enacted yet, but what impact do you think it has had with services actually collaborating? Both of you have touched a lot in most of your answers how important it is when they are.

Dame Nicole Jacobs: At the start, I think areas really were focused on it because they knew it was coming. The duty holders are the local authority, the police and crime commissioner and the integrated care board. Of course, there has been a lot of disruption. As you know, police and crime commissioners are not continuing past 2028, so that is one major disruption. How does that work? Who will inherit that duty and how?

Bell Ribeiro-Addy: That is one of my questions.

Dame Nicole Jacobs: It is still to be decided. I think that is part of the wiring in that we are discussing with devolution—making sure this is all coherent. The integrated care boards, while in most areas they want to be a player and contribute, they often are quite absent because they have halved in size in recent years. Often people who were leading on some things that relate to these issues and ICBs are not are not in post anymore, or people do not really know.

Most areas I have been to recently will say, “Yes, our ICB is looking forward to contributing, but they are just settling down now after all this change.” When I ask, “Would you still want this duty? How do you want it?”, areas do say back to me “Yes, we do. I think it will help us. But a duty is only going to be as good as the planned provision of funding, and we can only do what we can do with what we have got.”

At that local authority area, the combined authority will be able to help in those areas where that will be the way things are constructed—though I know not all areas will be. But I guess that is the whole point. Devolution needs to answer this question: at what level will the strategic planning be happening; at what level will the decisions be made; and how will decisions be made about the pooling of budgets for these types of services?

The big prize is something I heard the Prime Minister speak about yesterday: the strength of the community-based services and the third sector charities who are providing services. That is what I mean when I say the domestic abuse sector, primarily. We need to ensure that they can stay independent but are treated and stabilised in the way that you would see statutory sector partners. That is what we have to square in devolution and in that duty, and that is not all set out yet.

Q32        Bell Ribeiro-Addy: That makes it a little bit more difficult, but given that you do not have the answer to this, who do you think would be best placed to scrutinise the performance of violence against women and girls services locally once police and crime commissioners go? Would there be—or should there be—a role for survivors and specialist organisations in that?

Dame Nicole Jacobs: Some of the paper I published sets out some of the safeguards and flexibility needed, because every area is a bit different, as well as the community participation or accountability mechanisms. One absolutely must be how survivors themselves—the people these services are set up for—will contribute locally, through devolution, and influence that change. There are some really nice examples of that in some areas but, again, it has to be designed in. We cannot just hope that it will happen in all areas, because, genuinely, if we do not design it in now, we will move more towards a postcode lottery instead of the opposite.

That is why we really want No. 10 North’s attention on this in terms of the test for devolution, so that they can see how this will play out and how they can gain more ground on both flexibility at local level in decision making and accountability for making sure that services are there and that they are more consistent. If that is what this pooling of budgets and resources, and localised decision making, is meant to achieve, that must be what they achieve.

Q33        Bell Ribeiro-Addy: Have you had any indication that you will have powers, alongside the Victims’ Commissioner, to examine and challenge local delivery under whatever new arrangements are going to be made?

Dame Nicole Jacobs: Not that we have discussed. Maybe the Victims’ Commissioner has discussed that—I don’t know—but I have not had that discussion. It is something that I feel we really urgently have to make sure is wired in, in understanding how those accountability measures will happen. I am very willing to have that discussion. I think there are other ways too. I will publish another paper. We are doing roundtables with mayoral authorities right now, and we will publish a little more detail from our first paper about how we think that could work. I will make sure to send that to the Committee.

Q34        Bell Ribeiro-Addy: How good do you think the PCCs have been at allocating funding for services? Are you concerned about how that commissioning is going to be done once they are gone?

Dame Nicole Jacobs: Some are better than others, frankly, but very often they have done quite well. Right now, if you are trying to keep services going—whether for trafficking, modern slavery or any of these VAWG strands—no one person at the local level holds all the funding cards. The local authority, the PCC, the county council and more regional authorities each have some. Charities have some, too; keep in mind that they bring a lot of added value to their areas through trusts and foundations and their own fundraising.

Some police and crime commissioners have been really strategic about establishing a shared vision, really understanding who is bringing what and when, and making the most of that, and some have not. That is why we are where we are. In some ways, I feel that devolution is quite an opportunity if it is done well, and that is the emphasis we are trying to bring to it right now: making sure that, where we are headed, we resolve some of these long-standing issues.

I know this Committee has been really dedicated to by-and-for provision, and I am very dedicated to community-based by-and-for provision, because I think that is where people, particularly those who are not so trusting of other services—so really vulnerable people—really go for help. That is where you have a really good opportunity with the strategic authority or combined authority in any area to help plan for that provision. It is hard to do when it is more local; it is better to think about it in a place-based, regional way. There are some real gains there.

Chair: I am conscious that we have kept you for a while and we still have some meaty issues to get through. Are you okay for time?

Dame Nicole Jacobs: Sure.

Chair: Great, thank you. We are going to move on to early release.

Q35        Preet Kaur Gill: Dame Nicole, earlier this month we had about 1,400 offenders released. How carefully do you think the impacts on victims/survivors of domestic abuse were considered before the policy was announced?

Dame Nicole Jacobs: I genuinely think that victims of domestic abuse were considered, but the trouble is that there was a feeling of being between a rock and a hard place. You are trying to achieve prison spaces, but you also know the prevalence of domestic abuse. Again, we have some trouble with the data, but we know from probation, for example, that 30% of the people it supervises are domestic abuse offenders, whether they were in prison for that or not, so there was a consideration.

Of course, in the early SDS40 scheme there were some carve-outs that related to domestic abuse offences, and a choice was made not to do that. I believe—but I do not know—that the decision was made because of the need to achieve clarity on what releases would happen and when, and how much they would alleviate prison spaces. As I have said many times, I am afraid that we have sadly been achieving that on the back of victims, who are really paying the price for a lack of planning over many, many years.

Q36        Preet Kaur Gill: What information have you received about the tagging of offenders? Do you think the process is working as intended?

Dame Nicole Jacobs: Again, with the data on tagging, do we know for sure? The answer is no. We know from the probation inspectorate that there have been chronic problems with tagging just in getting them on and making sure that everyone knows they are on, let alone what happens when there are breaches. If we are releasing prisoners early to continue their sentence in the community, these things must be airtight.

The problems that we have had need to be worked through, and we have to face up to them. We have asked the Government to publish data on tagging and how it is being implemented, and until that happens, I do not believe that victims will feel very confident in the process.

To give you an example, I talk to multiple victims every week who say things like, “I’ve been told that the release date will be some time in the month of X, but I’ve been told that I won’t know the date until closer to the time, and I’ve been told that I won’t know the licence conditions until very close to the time.” I have had people tell me that they have been told by probation that they will not know until just before, or in the days before. That does not give victims a lot of assurances on what is happening and when, and on whether things are definitely going to happen. These are the system-induced risks that are not being tightened up, and that is what really concerns me.

Q37        Preet Kaur Gill: What would you recommend the Government do to make sure that victims are safe? Do you feel that victims have somewhere to go and ask questions once they have been told the information, or are they just left to wait for the next contact?

Dame Nicole Jacobs: There are lots of things in place, but I believe they could be much more robust. For example, one of the things that victims should expect is that, prior to release, there is a really clear risk assessment.

The Probation Service will have a pre-release team. They will have multi-agency work that is done primarily by reaching out to the police, but also to children’s social care, to gather information about risks for the release. They will also look at housing and where the person is going to live, and those kinds of things. I have heard excellent examples in some areas of how that risk assessment is taking place. I have heard about re-referrals to the MARAC, for example. It is about making sure the victim and the community are aware of the release, and that kind of thing. I do not believe that is as uniform and clear in all probation areas as it should be.

On victim contact, if there has been a sentence of a year or more, most victims have been able to liaise with a victim liaison officer who works at probation. A lot of sentences for these releases are under a year, so we have to proactively reach out to victims that probation traditionally has not been reaching out to.

There are lots of gaps. Is that contact happening, and when it is, is the information clear? There is sometimes a difference between what I hear is happening and what is happening. Maybe I hear that attempts to contact are 100%, but when I ask probation locally, very often they will be honest with me and say, “We have trouble contacting all victims. In fact, we have quite a lot of trouble contacting some victims because we never knew how to contact them in the first place, or they have moved or the information we had was incorrect.” There is a reality check about how it happens.

The Government have set up a helpline that is run by Victim Support. They were supposed to have set up, by October, a helpline run by probation, which would give them the ability to have all the information at their fingertips. That has not been stood up yet. I am told it should be stood up towards the start of the calendar year.

Beyond the contact, we are on to tagging and exclusion zones. A lot of that boils down to the implementation gap: is it really going to happen as expected? There is a lot to look at for victims—and a lot to be unsure about, I am afraid.

Q38        Preet Kaur Gill: There were a lot of really good points in there. Finally, do you feel that children’s social care could do more? Often, a victim does not want to have contact with her perpetrator, but the perpetrator will make contact with her, and she is accused of not being able to protect herself or her children as a consequence, and therefore you have child protection plans and so on. Now that we have children in the definition of victims of domestic abuse, what do you see happening in that scenario and where do you think the responsibility lies? What more should children’s social care do in that space?

Dame Nicole Jacobs: That is a great question. In fact, to give credit where it is due, colleagues at the Department for Education recently told me that, in the light of some of the changes that were brought in following the review of child sexual abuse—the duty to share information that has been enacted, for example—the Department has proactively reminded leads within children’s social care that with these early releases, they must be proactively sharing information if they have concerns, and that that extends to the adult who is caring for the child.

You are exactly right. The risk assessment process that I was describing is really important to make sure that probation is equipped with all the information that is known, and children’s social care often has information that needs to be understood through that.

Chair: I told you these issues would be quite meaty. We have the Chair of the Justice Committee, Catherine Atkinson, as well as Margaret Mullane and Matt Bishop to come in on this topic.

Q39        Catherine Atkinson: I want to ask you about whether victims and survivors feel they are adequately consulted on tagging and licensing conditions, in early release but also more broadly. You have pointed to quite an inconsistent picture. What do you think needs to happen so that what is intended is actually being done on the ground?

Dame Nicole Jacobs: I genuinely believe that we need clearer communication between the parts of probation that run the victim liaison work and Government about what they are hearing from victims and the concerns, and what advice they are actually giving. I hear a lot of variation in advice: one person I talk to might say that they will be told about some of those provisions earlier, and that they are clearer, and the very next person I talk to will say, “I’ve been told I can’t know until the day or the week before.” There has to be some kind of reckoning.

The Government says to me, “If you break these releases down over every area, it’s actually not that many in every probation area.” If that is the case, we should be asking for some clarity: “What is the exact advice you are giving? How many tags? How many exclusion zones? Give us the granular detail.” We cannot have it both ways, where they say, “Well, it’s hard to tell you that, but the releases in each probation area are only so many.” I do believe we could get to that point and have a greater grip on that.

I was at an event last week where someone from probation said in front of the audience, “We are really struggling. We feel great responsibility about this.” I do think there is also something about finding ways for the charities in an area, for example—the resources that could be helping probation—to step up and make sure that these links are being made. I feel like it is very operational. There is one thing about setting a policy and saying, “We will do this,” and there is something within MOJ about digging much deeper and asking: “Where are the problems operationally?

How do we make those clear and bring them to the fore?” For example, my first thought when it comes to the helplines being run by Victim Support is that, surely, we want to know the questions that are being asked—we want to know what victims are phoning up and asking about, and where they are not finding their way to the right information. We need to respond to those things very quickly.

Q40        Catherine Atkinson: You mentioned exclusion zones, where offenders are banned from specific areas. I want to ask about restriction zones, where they are confined to specific areas. At the moment, those are only going to be used for high-risk sexual and violent offenders. Do you think they should be used more broadly for domestic abuse perpetrators?

Dame Nicole Jacobs: Yes, I do think they should be used more broadly. The reason that has been set out in the way that it has could be just about operationalising it with policing and others, and how you implement it so you are not exceeding people’s expectations of what really will happen. But surely, if we want to set that out as an option, we want to know—and this is some of the data we have been asking MOJ and the Government for—the number of tags, and the number of restriction zones and exclusion zones. We are saying, “Please let us know,” which would be a way to reassure people that these options are being used and implemented.

The Government have said that they expect this to extend to other categories, but it seems really obvious. The things that the victims I speak to are doing to sort out this change in the timeline—moving house, changing jobs, not finishing a course—should shock us all. It is a huge price for them to pay, not having seen it coming and being quite taken aback and surprised by it. At the very least, we have to get the measures right and make sure there is a lot of transparency about them.

Q41        Catherine Atkinson: Finally, can I ask you about domestic abuse protection orders, which are supposed to be rolled out across criminal, civil and family courts from next month? How do you feel they are going? Are they making it possible to use positive requirements and make offenders fulfil certain criteria? Are they doing all they could be doing?

Dame Nicole Jacobs: The DAPOs are not using positive requirements very much right now, if at all. The ability to apply from the family court is not being utilised. The way that was set out in the Domestic Abuse Act, and the ambition of that, has not been fully realised. I have not seen the final evaluation for the DAPO pilot; I think that is meant to be published fairly soon.

The Home Office is rolling out DAPOs, and I am told that most areas are gearing up to be able to apply and achieve a DAPO. But we have to remember that they are somewhat limited in what they set out to do. It is a mixed picture and has not been done in a way that has achieved the full ambition.

Some legislative changes have been needed, which I think people did not foresee, about offenders not having to give their agreement to some of those positive requirements and about age limits. I understand that that is the whole point—it is a new thing and it is needed, and we probably envisioned that we would have to make some changes. One area that has implemented them is Greater Manchester; I have spoken to that team specifically and they are very positive about what they have achieved so far.

I think this is the point: we have to know where we are in the journey. It is not a full roll-out as it was set out in the Domestic Abuse Act. I would question whether we have invested enough in the positive requirements and how you build that scaffolding around the DAPOs. I think that that has been under-resourced. Are they probably able to apply in most areas? Yes, but I think we are not nearly there yet.

Q42        Margaret Mullane: What you said about the victims having to think about leaving home or changing their career was very moving. On the Probation Service and tags, there was a figure of 5,000 people being without any tags at all.

Would you agree that the Government are in a quandary, where you have to have the victims’ faith in what you are trying to do but you are also trying to carry the public with you in the decision on prison releases? We all know how much the Probation Service is under pressure, but do you agree that not setting up that phone line is unacceptable?

Dame Nicole Jacobs: I do. I find that the Probation Service are really honest, willing and open, and full of people who want to do the right thing, but this has put them in a very difficult position in terms of change. Since the Sentencing Act, this had been very clear—the Government said, “We’ll stand up this line, and we’ll make sure we have the risk assessment in place and other issues sorted out”—but as we got closer, it became clear that that was not going to happen. That is a combination of probation and MOJ, and it has exposed cracks that were already in the system around release. It was already inadequate on release, full stop.

I would say that the Government have a real opportunity now to sort that out permanently once and for all. Those issues have been there for a long time, and we cannot just pretend that things will be perfect. We have to be rigorous about it, and the impact on the victim must be built in. I have had people say to me, “Nicole, people will always be released,” but it was never safely planned. You cannot then layer on an early release and more uncertainty and expect that to work without quite serious effort, attention and grip. I think we are getting slightly closer to that, but we are not quite there yet. And yet we are doing it—the releases are happening.

Q43        Matt Bishop: I have a couple of quick questions. As I am sure you will both agree, it takes immense strength for victims and survivors to report crimes of domestic abuse, controlling or coercive behaviour or sexual assaults. We know that; that is fact. Do you think that the impact of the early release scheme will mean that victims are less inclined to report? Will they think, “Well, what’s the point, if they’re going to be out after whatever sentence they may end up with?”?

Dame Nicole Jacobs: I do worry about that. I worry about my own responsibility and speaking to the media so openly about these concerns, because of course you are balancing people’s confidence in systems. I want people to know—you were a police officer, so you will know—that there are lots of people who are willing to help, who are going the extra mile and all those things, but you cannot deny how the people who I have spoken to and who have spoken to the media have felt and how they have been let down.

It is a balancing act. On the whole, I obviously want people to reach out for help and support; it should be there, and it will be there in lots of cases. Over the years, it will not have been the only thing, but there have been quite a few things that have eroded the trust of victims in the criminal justice system.

Eleanor Lyons: I agree. For the survivors I speak to, it has eroded their trust that it is worth their while explaining what has happened to them when they have been met with constant challenges, whether that be not being believed or listened to at first, or the years that it takes to navigate the system. When you add early release on top, it is just another thing that means that they think, “Actually, why is it worth me coming forward?”.

I would add one small thing on the protection orders, which comes back to the join-up that we were talking about at the start in terms of cross-Government work. When it comes to slavery and trafficking risk orders and prevention orders, there are lessons to be learned for the Government, about the police and the Crown Prosecution Service having the awareness, about monitoring and about local forces not being able to apply for orders in their patch, which the Government are addressing with the changes they are making at the moment. The women we are trying to help with this strategy can face overlapping harms, and there are lessons to be learned from things we have tried to do in the modern slavery space that may not have worked as well as we would have liked for survivors of domestic abuse.

Q44        Matt Bishop: Following up on that, we heard in evidence to the Government before these early release decisions were made that any perpetrator of any crime being sentenced to prison time is a deterrent, no matter how long the sentence. I disagree; I think the longer the sentence, the more chance you have of thinking twice before you go and commit a crime.

Do you agree with that sentiment, or do you think that perpetrators of domestic abuse think, “Well, I’m going to get even more time off”? How much of an impact does that have on their decision making or if they are second-guessing themselves? What are your thoughts?

Dame Nicole Jacobs: I do. I have heard from a lot of victims recently who, once they have got their head around what is happening about how long you would stay in custody, how long you serve your sentence in the community and how that has changed, will say things like, “I wish I had said all of what he had ever done.” In other words, “I wish I could have built the picture so that it was clearer that what he was being sentenced for was really commensurate with what happened”—he or she, depending. I understand that; I suppose the flipside is that in the Sentencing Act we have a move, or a drive, to community-based sentences and a presumption of a community-based sentence.

My immediate question is what that looks like. What is an adequate community-based sentence for someone who is a perpetrator of domestic abuse, given all those risks? We have not been able to talk enough and work enough in Government on that, because of early release overshadowing so much, but in actuality it has already started. The Sentencing Act has ensured that that will happen for some of those sentences, and that will be an emerging concern.

Eleanor Lyons: I often see—I am sure you do, too—the Sexual Offences Act being used to hold perpetrators of modern slavery to account. In a way, I agree with that approach, in terms of it disrupting crime taking place, but there is a reason why there is a lifetime sentence in the Modern Slavery Act. It recognises the level of horrific action that is going on behind controlling someone: trafficking, exploitation and women being raped multiple times a day.

I sit through cases that are used as best practice, when the police have done a fantastic job of identifying perpetrators and taking the victim through the criminal justice system and supporting them. I get to the end of those presentations, and when they say that the person was held to account with two years in jail, and then you add the early release scheme on top, I am shocked. It leads to survivors really questioning what justice looks like for them. That is something I hear time and time again from them. I have serious concerns about whether we are using the powers under the Modern Slavery Act—I do not think we are—and what this additional move is doing to survivors.

Q45        Matt Bishop: As we all know, when we talk about things like controlling and coercive behaviour, it can mean many things. It could mean a one-off incident or a series of incidents. I welcome the Government’s recent changes to the early release scheme, but do you think that all domestic abuse cases, regardless of the levels and regardless of whether they involve controlling and coercive behaviour or domestic rape, should be exempt from early release?

Dame Nicole Jacobs: I have tried to make that case. I tried to make that case as an amendment to the Sentencing Act, to say that particular offences should be excluded. It is a little bit difficult to say that all domestic abuse perpetrators are offenders, because of some of the ways we track those cases, but I believe that they should have been excluded.

It is not for me to answer whether that is realistic for the Government, given what they knew. I do not know all the information they had in front of them about prison spaces. That is not for me to answer; it is for them to make that decision.

I definitely wanted domestic abuse-related offenders to be excluded, because of the respite alone, but that has not happened. Victims will understandably have not followed the Sentencing Act and all these changes, and they are quite shocked. They are genuinely quite shocked by this change and feel that it has come out of the blue. I have had victims say to me, “How can people in Government change what the judge said and ordered?” It just does not make sense to them, and I can see why that would be the case.

Matt Bishop: Presumably, Eleanor, you agree with those comments.

Eleanor Lyons indicated assent.

Chair: Can I take Catherine Atkinson and Preet Kaur Gill’s questions together, just so we can move on?

Q46        Catherine Atkinson: I want to go back to preventive orders—something I used to do a lot when I was a barrister. I am conscious that you have so many different types of orders, including non-molestation orders, sexual harm prevention orders, stalking orders or injunctions against harassment. Moving to having a universal order with domestic abuse prevention orders seems like a really positive step.

Do you think that there should be a simplification of all the orders? Do you think that more needs to be done for consistency across police forces? Should minds be applied again when there is early release, to see whether or not those kinds of preventive orders are needed for those offenders?

Preet Kaur Gill: In respect of domestic abuse perpetrators, do you think that Drive or a perpetrator programme should have been part of the release conditions? How robust is it that markers are being put on properties, and that there is an expectation of what the police response to a call-out from that number should be to support victims further?

Dame Nicole Jacobs: I think the original thinking was that the more the DAPO was developed and rolled out, the more it would almost be a natural progression to use those as opposed to other orders. It would not be for all orders, though; we are far from that. In many areas, I have had people say to me, “We are likely to continue using some of these other orders until we straighten out the issues with the DAPOs.”

It is another thing to know they exist. In police reform, we have to achieve some way for police forces to know and have at their fingertips all the right information. It does such a disservice to victims, and also to the safety of those in frontline response, if they show up to an incident at a residence or a location where they do not have all the information in front of them.

What worries me a little is that some of the improvements that we need to look at urgently will start to get kicked into the long grass—not necessarily intentionally, but because we will be so focused on police reform. What about the here and now? Some of these problems, as you say, are very chronic. There are some pilots and initiatives about ways to share information manually about various orders. None of that is really good enough. A lot of it comes down to the technology being used, the different methods in different forces and the lack of a uniform way of sharing those orders. That leaves it up to the victim to explain the order, to have it with them and to talk about it. That is just not good enough.

In relation to early release, you are right about being clear on what the role of the police is in breaches. Most people and most victims think a tag goes off if there is a breach and that somehow that activates a kind of overarching response. That is not the case, actually; the probation officer will know about it eventually, within a time period, but a predictable action will not necessarily be taken. That needs much more clarity.

You are right that Drive is something that the Government have got behind and rolled out. That is about knowing much more about the perpetrator and offender. Surely there is much more scope to draw that a bit closer to problem-solving for some of these issues with early release. Yes, I think you are on to all the right issues and ideas there.

Chair: We are going to move on to online harms. I will bring Robbie Moore in.

Q47        Robbie Moore: Just before we move on to online harms, I want to ask a further question on the early prisoner release scheme.

Chair: I told you it was a big topic.

Robbie Moore: It has to do with understanding your perception of the erosion of trust among victims and survivors in coming forward to the national grooming gangs inquiry that we now finally have in place. It has been put to me that while there was a roll-back by the Government and those perpetrators of very serious sexual crimes, including rape, will now not be released at serving 33% of their sentence, there is still this challenge of trust being eroded. Do you feel that there may be victims and survivors who are less reluctant to come forward to provide evidence as part of that inquiry? It has certainly been put to me that that is an area of concern.

Dame Nicole Jacobs: Gosh. I am not trying to cop out, but that is a bit out of my scope, given the kinds of experiences I have talking to victims, whose experience will traditionally be domestic abuse-related. There is a real overlap there, but I do not know that I have heard specifically about the grooming gangs. I wish I could tell you more. I will try to find out a bit more and maybe bring that back to you, but I cannot recollect hearing specifically—

Robbie Moore: I only asked that as a bolt-on, because I know that domestic abuse and child sexual exploitation have been heavily linked.

Dame Nicole Jacobs: Yes, heavily linked.

Eleanor Lyons: Some of the survivors of sexual exploitation who I work with are survivors from the grooming gangs, and the thing that they brought up is the criminalisation aspect of their exploitation, which you will know about. However, they are also consistently speaking about this credibility requirement, which I know is slightly different to the early release scheme.

I cannot stress enough how harmful it is to have, on the one side, our hopefully making progress when it comes to domestic abuse and saying, “We understand it takes time to come forward and that it is difficult, and that we should be listening to and believing you as the premise”, but then to have a different rule for survivors of sexual exploitation and saying to them, “We don’t believe you, we must question your credibility”, taking place in legislation. That is something that I am hearing consistently from those survivors. When you have multiple overlapping harms taking place, I think that will lead to long-term harm, in terms of people feeling confident about coming forward.

Chair: I am sorry to interrupt, but given that Peter has specific questions on that topic, can I go to him now? Then we will come back to you, Robbie, for online harms.

Q48        Peter Swallow: I was going to start by asking about changes to credibility under the proposed Immigration and Asylum Bill, but I think we have covered that quite extensively. So I will move past that to ask about other changes proposed in that Bill and how they interact with action on violence against women and girls.

First, on reforms to the national referral mechanism, do you feel, Eleanor, that they will be helpful in identifying potential victims? How well do you think the Home Office is currently able to identify the victims of modern slavery in the asylum system and outwith it?

Eleanor Lyons: There are some commitments in the action plan underpinning the VAWG strategy where I think good progress has been made in terms of the national referral mechanism. That is largely around better advocacy for child victims of exploitation and devolved decision-making pilots.

However, looking at national referral mechanism reform as a whole, I see that as harmful steps taking us backwards in our ability to identify victims of exploitation. The credibility requirements, as we have touched on, cause incredible concern among survivors. But there is also something bigger here. We rely on victims of modern slavery not being able to come forward and self-identify but being identified by a first-responder organisation. When we are cutting funding for dedicated police teams and we are not recognising the role that is going on across non-statutory responders, we are reducing our ability to identify survivors.

That does not apply across all police forces; some forces are really aware of their roles and responsibility, as are some local authorities. But increasingly in my time as commissioner, I am hearing survivors say, “I was told by a police force that I wasn’t able to be referred into the national referral mechanism”, or, “This didn’t apply to me”, only for them to find out that that was the wrong information.

I am concerned about our overall overarching approach to identifying victims of modern slavery at the moment. We see from the rising numbers that we are still identifying them in huge numbers, but I do not think that we are reaching everyone who needs our help and support.

Q49        Peter Swallow: You said you had specific concerns about the proposed changes in the Bill to the NRM. What are those concerns?

Eleanor Lyons: My main concerns are that the Home Office is saying that national referral mechanism reform is being delivered through the credibility requirement—clause 36 of the Immigration and Asylum Bill, part 5. They say that will make it easier to identify victims of modern slavery. I completely disagree with that premise; I do not think that it is making it easier for us to identify them. It is creating a culture of fear among survivors that they will not be believed and it is introducing a very strange precedent for this group of survivors that we are questioning their credibility and their stories when they come forward. I think that is universally doing harm at the moment.

When you say as a Government, “We are passing this law”, and it feels detached from survivors, that is not what I find when I speak to them. They are deeply concerned. I have had al-Fayed survivors get in touch with me and say, “This will actually stop women like us being recognised”, and they are already struggling to get the support they need. However, they are also coming forward to me because they are nervous about what it will mean to other women and girls being exploited at the moment.

Q50        Peter Swallow: The claim is consistently made—not by me; I am just reporting on it—that asylum seekers at risk of their asylum claim being turned down are belatedly turning to claims about modern slavery, in order either to have another go at claiming asylum or to delay any attempts to remove them from the country. Is that a legitimate complaint? Is it something that you have seen? If it is, does that undermine the position of very real victims of modern slavery in the asylum system? If that is a concern, does it need to be addressed so that we can better protect genuine victims of modern slavery?

Eleanor Lyons: If you are confirmed to be a victim of modern slavery by the Home Office, that does not give you any automatic right to remain in the UK. I really struggle to understand that assertion being put forward by the Government. Also, when I question the Home Office on the data behind those claims, they really struggle to provide any meaningful statistics.

The best ones they have managed are how many high-risk deportation flights are delayed after 3 pm on that day from a claim. It is a tiny percentage of those victims of the modern slavery system; I think it is less than 1% or 2% of those victims. I do not see any evidence from the Home Office to assert that claim.

The Home Affairs Committee, chaired by Dame Diana Johnson before Dame Karen Bradley, questioned the Home Office extensively on that claim. It found that there was no misuse of the system when it comes to it. The largest nationality of survivors of modern slavery are UK nationals.

Making the knee-jerk reaction across all survivors of exploitation that we “must”—which is the wording of the legislation—question their credibility if they have been exploited is going to affect all victims and their ability to come forward and speak freely about what is happening to them. Even if the Home Office was trying to address an issue, as I have outlined, the numbers are incredibly small on the evidence that we have seen. I am concerned about that part of the legislation.

Q51        Peter Swallow: I am only a guest from the Joint Committee on Human Rights, and I know that you are coming before us—perhaps this can be a taster of that session—so very briefly, do you just have a one-line response on changes to transparency and supply chain statements? That is also connected to this wider piece around protecting particularly vulnerable women.

Eleanor Lyons: Yes. I think the parts in the Bill are steps forward, but we need to be asking businesses to actively prevent the harm and forced labour happening in their supply chains across the world, not just report on it. The UK is hugely behind compared with our international partners in this space. That means that we are not doing enough to protect survivors at the moment.

Q52        Peter Swallow: Dame Nicole, this is obviously Eleanor’s bailiwick, but did you have anything briefly to add?

Dame Nicole Jacobs: No. I thought that was very comprehensive.

Q53        Robbie Moore: Focusing on online harms, as an overview do you believe that the online platforms have effective measures in place to protect violence against women and girls? We have quite rightly heard criticism of them from the previous Safeguarding Minister.

Dame Nicole Jacobs: Again, with this strategy there were some commitments in here about specific offences. It is really positive to see those steps forward. On the one hand this space is really busy, and on the other it is less clear in terms of where we are and exactly where we are headed. There are a lot of actions and statements of intent in this action plan.

Again, it is unclear at DCMS now that DSIT has been decommissioned and the portfolio has been transferred to DCMS. I would like to see a much greater bringing together of the VAWG sector service providers to give regular on-the-ground, quick input and expertise to DCMS and Ofcom about some of the things they are seeing in the here and now—the helplines, the first ports of call.

In some ways, the strategy does point to all sorts of ways in which we strengthen prevention, such as education about digital spaces, accountability and take-down measures. The kinds of things I believe need to happen are all there in lots of ways, but we do not have clarity about who, when and how.

One thing that is genuinely missing is tuning into the helplines and services that are real ports of call. For domestic abuse in particular, where this gets difficult is around coercive and controlling behaviour. Sometimes online harm will be very obvious to some of us, but with domestic abuse it is not always so obvious because you would have to know the context of the domestic abuse and what the threats or presence online looks like. We lack a full understanding about that.

There is also a disconnect between what we expect of the police in terms of these issues and what is recorded, what really happens and what is dealt with. Frankly, that is partly because of the barriers about what they feel is achievable that are put in place for them. If you are a victim of domestic abuse and you approach the police over criminal damage, online abuse or non-fatal strangulation, some of those things will be more obvious for the police to pursue and account for. I am afraid we are missing a huge amount of online harm because it falls into the “too hard to address” category. The immediate advice to victims is “You stand down. You hide away. You get off the platform.” There is so much more to do.

A great step forward would be understanding where we have got to so far with the commitments that we do have and understanding who is taking responsibility for those actions within DCMS and when.

Q54        Robbie Moore: Do you think that the Online Safety Act has had the benefits that everyone was expecting when it comes to dealing with modern slavery and domestic abuse?

Dame Nicole Jacobs: Not particularly in those areas, partly because of some of the dynamic I described. There needs to be much firmer clarity about the role of Ofcom in regard to some of these crimes and some of these areas.

I know we talk about specialist services provision, but if Ofcom says it wants to be an evidence-led regulator, we have to invest in the evidence base. Where will you get the evidence base? You get it from the places that are directly supporting victims. Those charities and services are not funded to the extent that they can provide research to Ofcom. They are providing support to people who are calling.

If we want that to happen, we have to construct that and make sure we are supporting those services well enough so that we can understand what they are hearing and add to the evidence base. Engineering that will require a much more assertive role from the Government.

Q55        Robbie Moore: Eleanor, did you have anything to add?

Eleanor Lyons: I will briefly add that when it comes to sexual exploitation, perpetrators are now using the internet—they have amazing ability with AI speed reach—to groom their victims online. Even in my time as commissioner, I have seen a huge increase in sexual exploitation facilitated through platforms. I do not think they are doing enough.

When I looked at adult service websites there were signs of trafficking in 60% of those ads. The adverts were not being taken down, there was nowhere for those women who were being exploited to report the harm, and there was no age verification on those websites. Survivors told me that children were contacting them online.

When I look at the third-party management on OnlyFans, there are clear conversations about trafficking, exploitation, violence and control taking place on those platforms. I do not think we or the platforms are doing enough. I have had good engagement with Ofcom; I work closely with them and welcome their collaboration, but the difficulty is that perpetrators are using the internet at far greater speed than we ever thought they would when we passed the Online Safety Act.

If we are trying to prevent harm and prevent individuals from being groomed, we need to be as forward-facing as the perpetrators. We need to understand how they are using tech to reach across society and to reach new groups of vulnerable girls. They tell me that they are being targeted while sitting in English class, whereas before—even five years ago—that was not what we were seeing.

It also means that the women I used to see being sexually exploited, who were far more visible to charities and safeguarding professionals, on the street or in certain areas or communities, are now being controlled online and are appearing in pop-up Airbnbs and brothels. That makes it harder for us to identify and reach them. I welcome the BIPs about online harms in the action plan, but they are not truly looking to the future enough to understand how this landscape has changed, even in one year.

Q56        Robbie Moore: Do you feel that additional legislation is needed to address the concerns that you have raised, or is current legislation sitting there and just not being acted on?

Eleanor Lyons: First of all, the Online Safety Act needs to be fully applied. I welcome Ofcom’s approach in focusing primarily on children to begin with, but we now need to look more broadly to protect all individuals online. We need to leave that door open for new legislation to understand where AI is being used in an incredibly harmful way to recruit and control very vulnerable victims. We need to have that conversation in policy making.

Q57        Anna Dixon: On online harms, the Public Accounts Committee was concerned that the Government, whether through legislation or Departments, are not able to have the agility to respond to the rapidity at which that is being perpetrated and is moving.

You mentioned Ofcom, but also the platforms. Given that perpetrators are likely to outwit new legislation as quickly as we can pass it, what should either Ofcom or the platforms themselves do to cut down this explosion of sexual exploitation, including of children, which you described and which is also vividly described in the recent threat risk assessment by the national centre for violence against women and girls and public protection?

Chair: We will take Peter’s question now as well.

Q58        Peter Swallow: Very briefly, the Human Rights Committee recently looked at AI. A lot of these questions presuppose that there is an offender somewhere, even if they are behind a keyboard, but one of the risks with AI is that the black-box nature of the process means that harms can be generated without accountability necessarily landing with any one human. As we think about protecting ourselves from AI, what would be your priority for making sure that we build systems that are inherently safe for women? Sorry; I appreciate that I am asking for a brief response to a very big question.

Eleanor Lyons: I will try to be brief. Over the last year, we looked at the future and evolving threats, and one of the key things that came up was how perpetrators are using AI—whether it is to generate CSAM, or to target a huge range of individuals online by using fake ads or profiles to start conversations with them and then either grooming, controlling or blackmailing them. It is difficult for policymakers to understand how to respond to it when perpetrators are moving more quickly than was outlined in the strategy, but platforms need to take far greater accountability for this. The Online Safety Act is welcome, but ideally, you would not actually need this legislation.

Platforms know about a lot of the harm taking place. I have questioned them on why when there is a clear sign of a woman with no age verification—sometimes it is even listed that they are a teen—being sexually exploited, there is not somewhere for that to be reported. Is it okay that their take-down process seems to take an absolute age, when I think it should be immediate? In my mind, it is not.

This comes back to the whole-society approach in the strategy: we need everyone to play their part to stop violence against women and girls. If we look at the rising numbers of younger UK girls we are seeing being sexually exploited, part of that is being driven by the explosion of things happening online at the moment.

Dame Nicole Jacobs: I am not saying that the strategy answers everything, but it does provide some clarity about the infrastructure that Government should be putting in place or intended a year ago to put in place. When I was looking at those particular sections before coming here today, I was thinking, “I don’t really know if these things are happening or not,” so how would I then know about the nimble reaction that is required?

I believe there needs to be much more time, attention and energy, so that it is clear for service providers that are seeing these trends—they will be the ones who spot the emerging trends—where that activity is sitting and how you would engage with it, because I feel it is not clear to most people. That would be a good first step.

A good recent example of progress is the National Centre for Violence Against Women and Girls and Public Protection, which was a commitment in the strategy. It is up and running and is going from strength to strength. It is equipping police forces with some of this information at much greater pace, and that needs to be built upon.

Where perpetrators have been learning in online spaces about how to carry out drug-facilitated sexual assaults, the national centre has been working with the National Crime Agency, and there has been much more join-up and clarity. Those who care and want to see change need to know what their vehicles are for making that change. That is a good example, but we need to see so much more of these commitments built on, and it must be clear for us how to address those.

In terms of the platforms themselves, I hope Ofcom can help make it clear to us, as users, which platforms we should feel confident in and which we should not. I hope the public will increasingly vote with their feet or their fingers.

Chair: Thank you. I refer you to the valedictory speech that Jonathan Hall made last week in this building, in which he talked about quite a lot of this, so I think we have a lot of people on our side.

We have kept you a long time because we have extra Committee members here, but we have a few final questions from Matt Bishop about information sharing with immigration services.

Q59        Matt Bishop: The VAWG strategy committed to requiring the police to seek a domestic abuse victim’s consent before sharing their information with immigration enforcement. Do you know whether that is happening? If it is, how is it working?

Dame Nicole Jacobs: It is not happening, as far as I understand. It was a really celebrated notion. In shorthand, we call it the firewall—the idea that information about you would not be passed along to immigration services. It is absolutely clear: many police leaders have talked to me about this, and they would like to see it.

I have asked the Home Office about how often information is aiding any kind of immigration enforcement when it is passed along, and it is not often. All it is doing is protecting perpetrators, because it means that migrant survivors are very worried to come forward. They are told a lot of misinformation, and they obviously have huge support needs. It plays straight into the hands of the perpetrator, as you know.

The disappointment in the language of that commitment was this idea of asking for consent. Picture yourself in that situation—you can quite easily, as a former police officer. If you ask in a certain way, “Are you sure you’ve had consent?” maybe the victim will feel they have to give consent for information to be passed along. That needs clarity.

Again, we are about a year on, and I do not think we have achieved what that commitment set out to do, which is for everyone to understand how that consent would be obtained and operationalising that. It is, frankly, a great frustration for many, many people that that commitment has not been acted upon yet.

Matt Bishop: Do you have anything to add, Eleanor?

Eleanor Lyons: I completely agree with Nicole on this area. We have pushed in many bits of legislation and not managed to get it passed, but it is something that I think stops us identifying very vulnerable women.

Q60        Matt Bishop: My last question is, are there any other areas where immigration policy is not aligned with the VAWG strategy?

Eleanor Lyons: I think, unfortunately, there are. When you speak to survivors, they tell you that perpetrators who are controlling and exploiting them use immigration policy as a means to stop them coming forward. They say, “If you come forward, you’re not going to be believed. You’re going to be deported. You’re going to be held to account by the Government.” Sadly, when we have rhetoric coming from Government and policymakers that echoes that threat, I think it leads to real harm and stops us being able to identify victims who really do need our support.

Chair: That is something I hear day in, day out. We have kept you longer than even we were expecting, but I think you can see the level of interest in this area across many Committees. Certainly for the Home Affairs Committee, there is much more we want to do on this, and there are questions that we need to put to the Prime Minister and the Home Secretary in due course. Thank you once again to our witnesses. This is something that we will be working on and taking forward.