Justice Select Committee Call for Evidence

Pre-legislative scrutiny of the draft Victims Bill

SurvivorsUK supports boys, men, and trans non-binary survivors of sexual violence. We relentlessly work to ensure they have access to the support they need to navigate the impact of sexual violence and begin their journey of recovery.

We provide a national online helpline, individual and group counselling to those aged 13+ who have experienced sexual violence at any time in their lives. We also offer emotional support through the justice system, support for friends and families of survivors, and training for professionals and organisations.

Our vision is a society that acknowledges, supports, and advocates for boys, men and non-binary people who have been affected by rape or sexual abuse.

Earlier this year and in response to the Ministry of Justice’s Consultation titled ‘Delivering justice for victims’ we put selected, relevant questions from the Victims’ Bill consultation document to our clients and staff.

As was the case in that consultation, we have used their responses in our answers here to provide you with direct insight from the boys, men, and non-binary survivors who have suffered and been affected by these traumatic crimes. Their answers also detail their journey through the criminal justice system as a victim of sexual violence.

We thank you for taking into account our clients’ and staff’s views on this topic, and we hope it provides you with a valuable insight into an often-silenced group.

In kind,

Gary Williams, CEO of Survivors UK

Del Campbell, Groupwork Facilitator











  1. The Bill’s definition of victim.

As a charity that is working to support men, boys and those who identify as non-binary overcome the impact of sexual abuse, we are supportive of the descriptions of harm in the Bill as sexual abuse includes physical, mental and emotional harm, and in some cases, economic loss.

However, many of the male and non-binary survivors we work with experienced sexual abuse and violence many years, even decades, prior to seeking our support. We recommend this context be reflected in Clause 1, Subsection (4):

(4) In determining whether a person is a victim for the purposes of this Act by virtue of any criminal conduct, it is immaterial (a) the amount of time that has passed before a victim reports criminal conduct (b) that no person has been charged with or convicted of an offence in respect of the conduct.

  1. The Government’s proposal to put the overarching principles of the Victims’ Code in primary legislation and set out key entitlements in secondary legislation, consulting on changes to the Code once the Bill is in force.

In responding to the Ministry of Justice’s Consultation titled ‘Delivering justice for victims’, SurvivorsUK hosted a voluntary focus group of service users who are all male and non-binary survivors of sexual abuse. We also hosted a survey for those unable to attend.

We understand that putting the Victim’s Code in primary legislation with key entitlements set out in secondary legislation will improve the delivery of the code and the rights it affords to victims who are navigating the criminal justice system. There is potential for this improvement to also expand to other agencies where victims are seeking support.

It is worth noting that our responders were, overall, not aware of the Victims’ Code when reporting their crime. Neither were some made aware of it by the police, which went on to include throughout their involvement with the criminal justice system spanning multiple years. Some of our Survivors wish they had been made aware of it at the time because they may have gone on to receive better support from the police.

Another said how their experience when reporting their historic sexual abuse spans several police forces, from initial reporting to investigation. They were not aware of the Victims’ Code until relatively recently. And if they were aware before they were not aware of how it can be applied to support them. Upon learning about the Code they are concerned that how multiple police agencies means there were multiple opportunities to make them aware. This respondent told us that reporting their instance of historic sexual abuse for the first time felt like “the twilight zone”.

“Once I walked away [from the station], I just carried on with my day. I was provided with no information. I had no idea what a victims code is or what it should be. When it comes to sexual violence there needs to be a document that can be given to a victim that is sensitive to what they are reporting - especially for male victims.” - SurvivorsUK client.

This client did not receive any emotional support until three years after their case.

Agreement was found in the group around there being literature provided on the Victims Code to the survivor at the first point of contact and that this should be followed up throughout the time the agency is working with the survivor.

However, they stressed the need for a victim not to be “bombarded” with information at the point of reporting for the first time, but to still be handed all the information they may need – perhaps in a leaflet. This would help to alleviate the forgetfulness that may occur when the victim is in a heightened emotional state.

The lack of support signposting was echoed by numerous other clients, who reported their initial interactions with police feeling rushed. This indicates a need for an increase in specialised officers across all forces who can correctly signpost victims at the very start of their interactions with the justice system.

Respondents also suggested the need for information on the Victims’ Code to be more publicly known – perhaps with information on it being shown in schools, workplaces, libraries, or other community hubs. By making this information well known, clients said it may have encouraged them to report a crime earlier.

Undoubtedly, this Bill requires a whole and multi-agency approach to meet the needs of the proposed legislation. Once the Bill is in force, we strongly advocate the need for accountability in its delivery and would advise this Committee and the Government to propose a routine method to review the Bill in a timely way. Of paramount importance in this timely review are the views and experiences of victims, as well as those who are dispensing the Bill to ensure agencies are joined up, that it is meeting the tailored neds of individual victims, and to make sure that there are no gaps in dispensation geographically.

  1. The key changes the Government should consider making to the Victims’ Code, including consideration of those already proposed by the Government in its response to the consultation.

We have a number of areas of feedback from our clients and staff which are detailed in areas below:

Clause 2, Subsection (3)-(5) allows for the code to be flexible and adaptive to the needs of the victim and their family. It also makes provision for regional variations.

This is positive. In the feedback from our focus groups and surveys, males of different ages, ethnicities, backgrounds, locations, as well as their families or friends, receive very different levels of support derived from the Code.

Clause 2, Subsection (6) provides that the Code may not require anything to be done by a person acting in a judicial capacity or by a member of the Crown Prosecution Service when exercising a discretion.

Feedback from our clients shows how the handover between the police and the Crown Prosecution Service (CPS) sometimes does not consider the needs of the victim in terms of transparency, accountability and through communication. One client said that they felt “stonewalled” when trying to contact the CPS regarding question on their case, as they were told a lawyer would be in touch with them, further stripping any power they had over what happened to them.

Another victim said that their communication with the police and the CPS triggered an increase in their post-traumatic stress disorder symptoms after only receiving a letter informing them that their case had been closed due to the force being unable to identify the perpetrator. Not having a proper conversation on this meant they felt unheard and disbelieved.

And other respondents still did not know anything of the Code at the handover to the CPS, or what the next stage entails.

We would strongly advise that it is a requirement of the police, the CPS and the entire judicial system to ensure on first point of contact that the victim is aware of the code and what the next stage will require of them.

SurvivorsUK welcomes Clause 5 which will provide accountability and oversight for the compliance of the Code by the police. However, from our feedback and experience, we see some victims’ cases may range a number of police forces and agencies.

Particularly for male and non-binary victims of sexual abuse, sometimes a victim’s negative experience of navigating the system comes from the too often disjointed and fragmented justice system and associated agencies. To be truly accountable, consideration of the whole victim’s pathway needs to be a reflected.

Furthermore, in Clause 5 careful consideration needs to given to the nature and extent of the data collected and how it will be used locally and nationally. Elected officials should see outcomes in data, but not handle highly sensitive and personal information. Victims must also be given a full verbal and written account of how their data will be used with the right not to provide data and to withdraw consent at any point.

An additional area our responders are keen to convey on this question in your consultation, is the understanding that in going to the police it takes a huge amount of courage and emotional preparation with the expectation that you will be heard.

Understanding the victim’s pathway in the Code, coupled with junctures where there is communication and transparency over decision making is key to fostering a better understanding between the victim and the agency they are dealing with. Therefore, a better environment would include different junctures to get feedback from the victim and consult where necessary so that the services can manage expectations. This can be included where there are timely intervals and set initiatives.

  1. The Government’s proposals to amend the role of the Victims’ Commissioner.

Our responders welcome the changes in the Bill which is recognised to drive accountability and transparency, as well as recognition for the whole criminal justice system. We see greater opportunity in these proposals for the Victims’ Commissioner to be a more powerful representative voice.

However, questions arose whether these changes go far enough to also include health, local government, employment and education agencies.

It must also be noted that responders were shocked the changes being made were not already in place.

  1. The Government proposals to place a duty on the relevant criminal justice agencies (the police, the Crown Prosecution Service, HM Courts & Tribunals Service, Youth Offending Teams and HM Prison and Probation Service) to collect data and keep under review their delivery of the Code.

We responded to some of this point earlier in Section 3 about collection, use, input and the role of the victim, with regard to data.

And to repeat a point previously made, often a victim’s journey encompasses multiple agencies including, health, employment, education, and local government. To fully appreciate the victim and their needs, it may be that data will need to be more widely collected, should it be offered by the victim.

  1. The Government’s proposals on the role of the inspectorates, including an improved focus on victims, and a new power for the Government to direct aspects of their work.

This is welcome as it will drive accountability and transparency in the victim’s interests – key themes in the feedback we received throughout our consultation. We also understand it will give greater reassurance from the top down.

However, there is no threshold given in order for the agencies to act and there is also no understanding of what the agencies will be ‘thematically’ reviewing. This can largely be down to context and feedback given to us says that without this being set out, our survivors are sceptical as to whether agencies may be able to avoid scrutiny.

  1. Whether the legislative steps proposed by the Government will lead to an improvement in the commissioning of support services?

Even prior to being a recipient of services, our responders feel there is a barrier to accessing support. This is particularly relevant to male and non-binary survivors of sexual abuse and is also furthered by location, age, socio-economic background and other factors.

Many of our respondents note that in order to access some services, you may first have to go to the police which is not what all male and non binary survivors want to do in the first instance. But where and how to access support that is suitable and readily available without police involvement is too often not present.

While some have had good one-to-one experiences with officers providing support throughout their cases, it was noted that there was little signposting to other services. This is also the case in other agencies, such as health, education, local government and in employment.

It was also noted by the group that learning difficulties are not always supported throughout the police processes. On the whole, the feedback said that the police supporting victims is patchy and at times can be irrelevant.

We advocate that access for victims to support services is a necessary requirement when considering the commissioning of services. Support services too often fall down when they are not signposted to the victim and this is the experience of the vast majority of our responders.

Throughout the UK there are huge gaps in the provision of services for male and non-binary survivors of sexual abuse. 1 in 6 men suffer from sexual abuse at some point in their lives. Reviewing these gaps and where organisations can be supported to do more outreach along local pathways, would help to close them.

Another challenge is also having the capacity to integrate more services on the frontline. Experience in the group was also given further along the survivor’s journey where too many services operate in silence. Multi-agency meetings were highlighted to work well as they improve communication, but these need strong coordination in setting up and often get delayed.

Overall, the group agreed that to overcome these challenges, this requires proper funding from central and local governments. It was not felt that the financial implication of the Bill will go far enough to resource the huge downfalls in service provision botn in the back office, frontline or in the third sector and the figures do not reflect the multi-agency victim pathway.

The group wanted to showcase in their response how SurvivorsUK is a great model which provides support services across the UK irrespective of background, socio economic status or cultural heritage. SurvivorsUK assesses individual needs and provides support across a range of areas from mental to sexual health, therapy and counselling and through the criminal justice system.

The group feels the organisation is unlike any other, with a great degree of success, and would like the Ministry of Justice to meet with SurvivorsUK to learn about their model and how this can either be expanded or replicated.


  1. Whether the steps outlined by the Government will lead to increased awareness and effectiveness of the ISVAs and IDVAs?

We welcome proposals to issue guidance on the roles and functions of Independent Sexual Violence Advisors (ISVA). At SurvivorsUK we currently employ ISVAs to support people accessing our services who are currently experiencing dealing with the criminal justice system. We understand the Government’s proposals will bring a greater level of awareness and understanding for the critical role ISVAs play in supporting survivors.

SurvivorsUK ISVA respondents said they would both utilised more and "respected" more by defining their role. In turn, this would help cut down on ISVA burnout and vicarious trauma. Raising the profile and recognising the importance of the ISVA profession should also positively increase what funding and ensure better salaries.

However, we would advocate the guidance to be issued by the Secretary of State should consider the following feedback from our group.

Those who have used an ISVA in the group explained how they supported them through the criminal justice system. Feedback showed how ISVAs provide emotional support and have been consistently positive and encouraging. Responders feel that particularly in light of the nature of sexual abuse, that this was critical to them in their journey through the system, with one respondent describing their ISVA as “invaluable”.

Other responders in the group who have experienced going through the criminal justice system said that they were not aware ISVAs existed and wish they had known about them and where to go to receive support when they reported the crime.

The group agreed that ISVA services should be promoted early on to any victim of sexual abuse who comes to a police station to report a crime.

The group echoed sentiment regarding the challenges they have had in accessing services in general which was answered earlier in the consultation. One respondent, a male, first had to reach out to a women’s support service before being directed to SurvivorsUK.

Particular regard was given to the male experience of sexual abuse and the varying intersecting identities in relation to this, such as the Black, Asian or LGBTQ+ communities – as well as trans, non-binary, and gender-neutral people – when trying to access support.

The group agreed that the challenge in accessing advocate services comes down to advertising the support services and communicating it effectively to victims.

Another challenge is also having the capacity to integrate more services on the frontline. Experience in the group was also given further along the survivor’s journey where too many services operate in silence. Multi-agency meetings were highlighted to work well as they improve communication but these need strong coordination in setting up and often get delayed.

Overall, the group agreed that to overcome these challenges, this requires proper funding from central and local governments.

Responders felt that from their experience, ISVAs can vary in experience and ability. Feedback from the group also centred on understanding from other survivors outside of the group.

From a victim’s perspective, the group knows what training a teacher, social worker, GP has, but it is not clear what training an ISVA has and it would be reassuring to know this. Agreement was found that a standards board may improve accountability and consistency of support provided - it would be a good idea to professionalise the role further.

Staff respondents at SurvivorsUK agreed that requirement needs to be made for all ISVAs to be accredited and to take part in CPD. Suggested that the government should set the standard in consultation with training providers like Lime Culture and even ISVAs themselves.

  1. What implementation, resourcing and accountability challenges exist with respect to the Victims Bill?

Our survivors who responded often told us in detail about their journey through the entire system which involves multiple agencies across education, health, justice, local government employment and home affairs. What is clear is how their negative feedback derives from a broken pathway in accessing support. From taking a holistic approach we can see how the gaps between services are where there are more acute implementation, resourcing and accountability  challenges.

Funding for rape crisis services which would allow organisations the resources required to disseminate relevant and timely information was an aspect responders stressed was needing to be increased. This would help outreach, service user engagement, and communications.

SurvivorsUK staff respondents highlighted that increased funding for rape crisis services would help professionals manage overwhelming caseloads and perform in all aspects of their work, including staying abreast of developments such as the Code. They also highlighted that changing “guidance” to “requirements” would increase responsibility and accountability. 

The introduction of mandatory training for witness care within the police so they know of rights under the code, ensuring correct and up-to-date signposting for ISVA/ISDAs, producing and circulating a simplified document to agencies for clients on first contacted, and introducing a campaign which highlights this information were also suggested.

  1. Whether there should be any further measures included in the Bill?

Some of our responders then told us about the Victims’ Right to Review Scheme (VRR). Those who had utilised the Right to Review scheme reported a negative experience, saying that they frequently did not know of its existence until it was offered to them. This reflects the views expressed by some throughout the consultation that they feel like they are in the dark when trying to understand their rights, what the process should be and the purpose or meaning behind elements, such as the VRR. 

They said that because of this, the VRR can be confusing to some who may feel the CPS decision is final and it needs to be communicated in crystal clear language from the outset - this should be a legal requirement.

The experience of those who have been through a VRR is they felt it is a pre-determined internal routine where the outcome will not change. This is largely because the VRR looks like an ‘extra’ which is compounded by the fact it is not an open process – it’s yet again another opaque bureaucratic handled at arms distance by letter.

The way in which the CPS handles informing the victim about the VRR does not inspire confidence or a belief that they are going to be involved in reaching a conclusion or outcome that is more satisfactory to the victim’s needs. 

On functions in the system such as the VRR, the group expressed concern that not even some of the professionals supporting victims will be aware of a VRR and what it encompasses, nor will some in frontline services such as the police be able to give an idea of what a VRR might achieve for the victim.

Our responders agreed that they cannot recall of hearing about anyone who has ever been through a VRR having a positive story or outcome to tell. Because of the lack of information and awareness, victims are sceptical particularly when they have already been through a long and drawn-out process to reach the stage of a VRR, which has been painful and stressful.

“I found myself sinking psychologically when I was in the process of understanding what rights I did and what I didn’t have, and in the end I gave up because it was so detrimental to my psyche and caused so much pain,” one SurvivorsUK client said of the Right to Review scheme.

The VRR should seek empowerment of the victim. But it was agreed that after going through the criminal justice system, to reach the CPS felt isolating enough without an advocate or support through their decision process, but the VRR made this worse. Complimenting this is the general experience of the CPS being untouchable and out of reach. 

What would improve the VRR, and the indeed the CPS, is if the VRR engaged the victim better so to give them a voice, allowing them the opportunity of being able to advocate and express their views. Coupled with clear understanding of the VRR, and setting expectations, the VRR would feel less distant, opaque and pre-determined and that the system is fair, if not on the side of the victim. 

  1. Are there any relevant international examples the Committee should consider?

We do not have any relevant examples of international good practice.

  1. Whether the provisions of the Bill could have any implications for due process?

The main concern from our feedback is the use of data, which has been addressed throughout this response.