Written evidence submitted by the Latin American Women’s Rights Service (POP0013)


About Latin American Women’s Rights Service (LAWRS)

1. LAWRS is a human rights, feminist organisation ‘by and for’[1] Latin American migrant women living in the UK. We support 2,000 women every year who are exposed to violations of their fundamental human rights, facing violence against women and girls, exploitation in low-paid sectors, trafficking, or enduring severe poverty and deprivation.

2. Our direct support includes casework for women experiencing gender-based abuse, counselling and emotional support, advice and casework on employment rights and exploitation, family law and immigration, among others.

3. We also actively advocate for women’s rights, migrant’s rights and the rights of ethnic minorities, working with sister organisations in the ending violence against women and girls (VAWG), migrant and anti-slavery and anti-trafficking sectors.



4. LAWRS welcomes the opportunity to submit evidence to the Home Affairs Committee on policing priorities. LAWRS and the Step Up Migrant Women campaign have for many years been campaigning and engaging with police and other relevant stakeholders to improve the experiences of migrant victims of crime approaching the police.

5. Migrants living in the UK face increased vulnerability and often experience multiple crimes exerted by multiple perpetrators. At the same time, we are witness to the lack of trust that migrant victims have towards the police and other law enforcement bodies. Over a decade of hostile environment policies have led vulnerable migrant victims to be fearful of the authorities that are meant to protect them. This fear prevents them from reporting crimes and receiving support from the police. Thus, increased collaboration between the police and Immigration Enforcement has led migrant victims to endure abuse and exploitation for more extended periods.[2]

6. Currently, migrants are at real risk of having their data shared for immigration control purposes when trying to report a crime.[3] This, tied to the fact that migrant communities tend to be very close-knit, often results in this information quickly spreading among them through word of mouth, damaging trust further. It is imperative that a modern police considers how to repair this broken relationship with migrant communities in order to really build trust.

7. Unfortunately, subsequent governments have ignored the evidence from the third sector regarding migrant victims’ experiences with the police, and an Immigration Enforcement Migrant Victims Protocol is currently being developed to institutionalise data-sharing practices between the police and Immigration Enforcement. Far from protecting vulnerable victims, this Protocol will further foster fear of approaching the police among migrant communities and prevent the police from accessing valuable intelligence to tackle and prevent crime and bring perpetrators to justice.


Question 1: What a modern police service, fit for the 2020s and beyond, looks like

8. A modern police service for the 2020s would:

be a force that protects people’s human rights and focuses their operations in tackling and preventing crime under a framework of accountability with a victim-centred approach that considers the intersectional inequalities of victims;

have a better understanding of both VAWG and exploitation to improve identification of victims and support those who seek access to police and other services. This includes improving the understanding and addressing of the particular experiences and needs of victims with protected characteristics;

understand the crucial role of working efficiently in collaboration with other public bodies, specialist organisations and other victims’ representatives to tackle crime and provide trauma-informed support tailored to the needs of different groups of victims. Currently, LAWRS finds that this collaboration varies greatly and subjects victims to a postcode lottery, where often migrant and Black and minoritised women receive inconsistent and often incorrect information regarding crime, support available, and the progress of their cases, amongst others and

fulfil their commitment to treat all victims of crime as victims first and foremost irrespective of their immigration status. Relieving the police from collaborating with Immigration Enforcement is a key step in the right direction.


Question 3: The roles that police forces should prioritise

  1. Protecting all victims: the importance of safe reporting mechanisms

9. Migrant victims and witnesses of crime are currently afraid to approach the police for fear of facing negative consequences related to their immigration status. Under the hostile environment, police have had inconsistent responses to victims,[4] in many cases prioritising immigration control over their safeguarding. As a result, migrant communities perceive the police as a threat, even when they are at risk and in need of protection.

10. Research by the Step Up Migrant Women Campaign shows that one in two migrant victims of VAWG with insecure immigration status do not report domestic abuse to the police for fear of disbelief, destitution, detention and deportation. Perpetrators often exploit women’s insecure status, telling them that if they approach the police they will not be believed and  supported, and will instead be at risk of detention or removal because of their legal status. Evidence shows that 62% of migrant women had specifically been threatened in this manner by their abusers.[5]

11. Similarly, victims of exploitation supported by LAWRS do not generally consent to a referral to the National Referral Mechanism (NRM) unless they have regular status. In spite of a desperate need for support by those who are undocumented, they are forced to remain underground, being more afraid of  Immigration Enforcement than of their exploiters.

12. Furthermore, it is our experience that often migrant victims of crime become undocumented as a result of the abuse and exploitation experienced. This can happen, for instance, when a perpetrator or exploiter gives false information to the victim regarding their immigration status or their right to work and settle, or promises to apply for the appropriate visa when it is time to do so, only to allow deadlines to pass in order to increase their control over the victim.

13. In line with our experience from the frontline, the government recognises immigration status as a risk factor to becoming a victim of serious crime, including gender-based abuse and exploitation.[6] Immigration status is used both by perpetrators of domestic abuse and by exploiters and traffickers as a means of control.[7] When the police share information with the Home Office, they are giving perpetrators and exploiters a weapon to abuse with impunity and removing the possibility of protection for victims.

14. In order to ensure equal access to justice and support for all victims, it is essential that the police guarantee that victims with insecure immigration status can report crime and access support safely. This will only be achieved by establishing a complete firewall between the police and Immigration Enforcement, which would restrict the police’s ability to automatically share a victim’s personal data with Immigration Enforcement when reporting a crime or requesting support. This would ensure that personal data of a victim or witness of crime in the UK that is processed when they are trying to report or seeking support related to crime is not used for any immigration control purposes.

15. This measure is likely to improve reporting rates amongst victims and witnesses with insecure immigration status, as well as those with secure status who would currently choose not to report for fear of endangering others, or due to misunderstanding their own status. Evidence shows that a firewall can make victims and witnesses feel confident in approaching the police to report crimes and more likely to engage in criminal proceedings which will in turn allow the police to hold perpetrators to account and prevent crime.[8] In contrast, by having to focus on people’s immigration status, the police are placed in a difficult position having to undertake tasks that jeopardise their ability to access valuable intelligence needed to prevent and address abuse and exploitation, whilst missing an opportunity to increase people’s trust.

16. A firewall between the police and Immigration Enforcement is not only possible, but already in practice successfully in other cities around the world, such as Amsterdam and New York.[9] Some local police forces in the UK are currently reviewing their practices with a view to stop data-sharing and protect victims, as officers and detectives on the frontline often understand that collaboration with migrant communities is key to fight crime and protect vulnerable victims.

17. Recently, the Justice Select Committee scrutinising the draft of the forthcoming Victims Bill published its report, which included the recommendation to end victims' data-sharing between the police and the Home Office and introduce a firewall.[10] In the context of the Victims Bill, the London’s Victims Commissioner and the Domestic Abuse Commissioner have also highlighted the importance of a firewall to ensure safe reporting mechanisms for migrant victims.[11]

Immigration Enforcement Migrant Victims Protocol

18. In December 2020, the findings of the first super-complaint investigation led by three independent police watchdogs concluded that arrangements on victims’ data-sharing are significantly harming victims of crime and the public interest, as crimes are not reported and therefore remain unpunished.[12] Among other recommendations, the three police bodies called for immediate action to stop domestic abuse victims’ data from being shared with Immigration Enforcement and instructed the Home Office to conduct a review on the data-sharing policy and legal frameworks.

19. After conducting this review, the government dismissed the evidence and rejected the introduction of a firewall, arguing that data-sharing with Immigration Enforcement is essential to protect victims. Instead, they proposed an Immigration Enforcement Migrant Victims Protocol. Based on our experience supporting migrant victims, we disagree with the government’s response[13] and argue that there is a concerning conflict of interest with Immigration Enforcement safeguarding victims whilst carrying out their main responsibility of enforcing immigration rules. As a community-based ‘by and for’ migrant women's organisation, we reject the  protocol as we know that this approach will not increase victims' confidence in reporting crime and in the police. On the contrary, by institutionalising the role of Immigration Enforcement in reporting a crime, vulnerable victims will be further prevented from coming forward to the police and will be exposed to further harm.

20. A police force that seeks to build trust with the community should reject the Immigration Enforcement Migrant Victims Protocol and prioritise protecting victims and preventing crime over any form of immigration control.

b. Providing better support for victims

21. In line with the Equality Act and the Public Sector Equality Duty, public bodies should take steps to meet the needs of people with protected characteristics and eliminate unlawful discrimination. In this vein, migrant victims who are likely to experience communication barriers should always be offered certified interpreters. However, in practice, this is not often the case, or offered only after the involvement of a supporting organisation requesting it. At LAWRS we have supported victims who, when they try to report the perpetrator to the police, are required to bring their children or a friend/acquaintance to act as interpreter.

22. Asking a non-certified interpreter to act as such is not good practice and can have damaging effects. For instance, a child interpreting between their mother and the police could result in re-traumatisation, while at the same time, preventing the mother from fully disclosing the extent of the crime. As a result, cases can be classified as non-crime incidents due to the lack of evidence. When requesting a friend, partner or acquaintance to act as interpreter, the victim can also be put at further risk, as the acting interpreter could be the perpetrator or be abusive themselves.

23. Police should maintain a trauma-informed approach throughout all interactions with victims. Further support (immigration advice, counselling, advice on VAWG and social benefits, etc.) should be provided by specialist ‘by and for’ organisations. In order to guarantee access to specialist services, it is necessary to establish clear referral pathways with such organisations.

24. Victims should receive constant and accessible information about their reports,  investigations and progress of their case. Failing to do so puts victims at risk - for instance, when a perpetrator’s bail condition is lifted and the victim is not made aware.

25. Migrants have often met with racist and discriminatory practices when reporting crimes or approaching the police. Structural racism prevents victims from coming forward and collaborating with the police. Training on anti-racism should be ongoing. This training will improve migrants’ experiences and willingness to report and cooperate with police and identify criminals and victims. Nevertheless, training will not be effective without strong accountability mechanisms. When an officer is reported for racism, and other foms of discrimination, there must be a thorough transparent investigation. If found guilty, the serving police officer must be removed and not allowed to get away with it. 

26. Furthermore, as mentioned above , there is a need for a clear separation between police tasks and immigration control as evidence shows that heightened enforcement of immigration legislation by police forces, promotes and increases racial profiling and discriminatory police practices.[14]

c. Protecting people from being exploited or harmed

27. Certain crimes, such as exploitation and modern slavery, and some types of VAWG, can be hard to identify. This means that victims themselves often do not know that they are victims and that they have a right to receive support. Police officers should be properly trained to understand what these crimes look like for specific communities, without falling into stereotypes, to recognise them and identify victims and to understand how perpetrators of these crimes operate. This is particularly important as victims can often be encountered before they have had a chance to report (for example, during police operations). It is also relevant in crimes involving the use of people’s immigration status to coerce and trap them in abusive relationships and exploitative environments.

28. Many migrants arrive in this country with false promises from their employers and perpetrators of abuse. They come believing that they have a right to work, or that their visa has been, or will be, taken care of. Others might lose their status (for example, because they are unable to cover the fees for re-applying). The illegal working offence means that they can be committing a crime unknowingly, or simply for trying to survive and support themselves or their families. This very often leads to employers exploiting the situation to their advantage, and threatening to report workers if they complain or if they do not comply with exploitative conditions of work. Similarly, it may lead victims of domestic abuse to remain with their perpetrators and endure abuse for longer, because they are unable to work or to access public funds which also prevents them from accessing refuge accommodation.

29. In order to identify people in breach of the ‘illegal working’ offence, simultaneous operations with Immigration Enforcement are carried out by the police.[15] These operations can hinder trust and discourage workers from collaborating with the police, either because of their own immigration status, because they have been misinformed about their right to work (many European citizens, for instance, were told by employers after Brexit that they had lost all their rights in this country), or because they are scared of putting their colleagues in danger.

30. For some types of hidden work, such as domestic work, it can be very difficult to spot signs of exploitation. Targeted outreach is important so that victims can receive information and understand their rights when they are being exploited. Ongoing training for police officers on indicators of exploitation, on the National Referral Mechanism (NRM) and support available for victims -including those who do not consent to being referred into the NRM- is also essential.

31. Migrant victims of VAWG often experience coercive and controlling behaviour in the form of threats of being reported to the Home Office if fleeing, seeking support or reporting abuse to the police.[16] Our frontline expertise shows that as part of their experiences of abuse, women are misinformed and misled about their rights and entitlements and in many occasions made undocumented to increase perpetrators’ power over them. These threats contribute to fostering mistrust in the police and other law enforcement authorities. For that reason, when victims of VAWG approach the police and they focus their interventions on prioritising forms of immigration control, women’s worst fears are confirmed. Best practice involves prioritising the safety of victims and referring them to specialist ‘by and for’ organisations where women can access wrap-around holistic support to rebuild their lives, including accessing immigration advice and casework to regularise their stay.

32. We are supportive of alternatives to criminal justice outcomes for victims. This is because we understand that not all victims are keen to follow the same pathway to access justice. A modern police should support victims who choose not to engage with the Criminal Justice System (CJS), and incorporate actions to build stronger communities and increase service-based interventions,  particularly with a focus on prevention and addressing the root causes of violence and abuse.

d. Reducing and preventing abuse and exploitation

33. We believe that the police should put prevention at the centre of its strategy. Prevention, contrary to an enforcement-led approach, can provide alternatives to tackle root causes of crime. This focus is key for marginalised communities and victims, as a heavily focused CJS response might not provide alternatives for them. In contrast, prioritising steps to prevent serious crimes is essential to ensure the human rights of women and their communities are realised. Furthermore, a focus on prevention can reduce the social and economic costs of violence.[17]

34. Some migrant communities can be hard to reach. Targeted outreach within these communities (including online) and building good relationships, is essential to ensuring that messages reach them effectively. However, within migrant communities information is more generally shared through word of mouth, which is why it is important that any migrant who reports a crime is provided with the appropriate trauma-informed support.

35.Prevention of crime and violence in migrant communities also requires close collaboration with specialist community organisations that can carry out effective outreach within the community and circulate relevant information. Close collaboration with community-based services can be positive in developing joint prevention campaigns/interventions to inform victims from Black and minoritised communities about recognising abuse and being aware of available support. These organisations are generally made up of people from within the community, and can therefore help improve ties with the police and other authorities, when it is safe to do so.

Question 4: What can be done to build trust with the community

a. Tackling institutional discrimination and racism

36. In order to build trust with migrant communities, it is vital to understand the structural and institutional discrimination that they are subjected to when approaching the police and seeking to access the CJS.

37. Our frontline experience shows that migrant women are often disbelieved and blamed for the abuse they are victims of, often being accused of fabricating crimes in order to exploit the system, access support and regularise their immigration status.

38. Evidence also shows that when the victim is a migrant woman, criminal investigations and charges have fewer possibilities of going forward.[18] Furthermore, it has been our direct experience more recently that cases are often closed without the victim or supporting organisation being informed.

39. Police forces need to be consistently vigilant to fully eliminate any form of discrimination and racism from their ranks. Training should be ongoing and officers found to have displayed discriminatory and/or racist behaviour should be investigated and, when appropriate, removed, as a lack of accountability hinders trust with the community.

b. Working with community organisations

40. As mentioned above, stronger collaboration with specialist community-based organisations is a key factor to increase trust and confidence in the police, as these organisations are embedded in the community.

41. Crimes such as domestic abuse and modern slavery can present different characteristics and trends in certain communities, in some cases making them hard to identify. It is vital that the police work closely with organisations to better understand the specificities of certain crimes within each community, and how to identify, tackle and prevent them in more effective ways.

42. Community organisations can also organise outreach sessions that allow the police to understand the intersectional vulnerabilities of each community. Policies on engaging such communities should be developed and improved in line with the learnings of this process and all staff should be aware and abide by them.

43. These organisations are also the ones who can provide wrap-around, holistic support that is linguistically and culturally sensitive. Efficient referral pathways should be established and regular feedback with supporting organisations should be maintained throughout the reporting process and investigations.

c. Increased policing does not equal increased safety

44. Several reports into policing in the UK[19] have highlighted the systemic failures of the police, including, for example, police officers perpetrating VAWG and displaying misogynistic, homophobic and racist behaviour, amongst others. These reports evidence that far from being the one to protect marginalised communities, the police very often perpetrate violence and abuse. This, in particular, affects women and people from Black and minoritised communities, regular targets of sexist and racist practices by the police.

45. In this context, the current tendency to increase policing can be a frightening prospect for many. This fear is not unfounded, as traditionally marginalised communities have been vulnerable to police surveillance. Police monitoring is often fostered by presumed criminality related to people's intersectional identities. Some examples of this are the police's excessive use of stop and search powers on Black people, who are seven times more likely to be searched than white people;[20] and the revelation of ethnic disproportionality with data showing that most children (10-17 years old) strip-searched by the police between 2018 and 2020 were Black.[21]

46. Over-policing and increased surveillance can also inflict further harm to victims that justifiably mistrust the police. Organisations from the VAWG sector have stated the risks of interventions targeting ‘hotspot areas’ with increased policing in boosting racial bias to the detriment of victims of crime.[22]  


Question 5: What the Metropolitan Police must do to increase trust under its new Commissioner

47. LAWRS is a pan London service that supports migrant victims of crime engaging with the Metropolitan police. In the last years, we have been witness of several miscarriages of justice produced by systemic failings in protecting migrant victims. As mentioned above, these failures are a long-standing issue harming migrant victims’ confidence that if coming forward they will be protected and justice guaranteed.

48. As the MET has been  placed into special measures and a new Commissioner takes office, we see this as an opportunity to reevaluate police’s role in cooperating with Immigration Enforcement. Our frontline evidence shows that by doing so, the MET police neglects migrant victims’ human rights and leaves them in the vulnerable position of having to endure abuse and exploitation indefinitely.

49. Whilst we welcome the new Commissioner’s commitment to tackling some forms of gender-based violence including sexual violence, we are concerned about the harming effects that mirroring counter-terrorism policing to address VAWG[23] can have on Black and  minoritised communities who are already at the sharp end of police surveillance.[24]


Question 6: Steps to improve national conviction rates

50. As mentioned above, trust is fundamental to the effectiveness of the system and the ability to investigate and prosecute crime. Unless migrant victims can feel confident that they are not at risk due to their immigration status, this trust will never be established. Without victims coming forward, the police will miss out on accessing vital intelligence necessary to tackle and prevent crime.

51. When victims do approach the police, it is essential that every officer has an understanding of crimes which can have hidden indicators, such as domestic abuse and modern slavery. This will allow them to identify victims early and provide the appropriate support, including filing an official report should they wish to do so.

52. Believing the victim and not placing the blame on them is key in ensuring that they will remain engaged with the police throughout the process. This will also reduce the risks of re-victimisation which in many instances prevent victims from approaching the police in the first instance. It is also vital to address specific needs that each victim might have, such as access to an interpreter, to ensure that evidence is gathered correctly and thoroughly. 

53. Finally, in order to increase conviction rates, the police need to make sure that the handling of investigations improves, centering the experience of the victim. At the same time, investigations need to progress beyond taking a first statement from the victim. It is our experience that, after this step, the police consistently declare a lack of sufficient evidence to carry out further investigations. Dropping cases due to lack of evidence without an investigation being conducted seems contradictory as it is the job of the police to investigate to gather such evidence and make the case more robust to be able to follow its course in the Criminal Justice System.



October 2022




Annex 1: Case studies


Case study 1 - Laura*



Case study 2 - Sara*












Case study 3 - Carla*



* All names have been changed to protect the victims’ identities.




[1] For a detailed definition of what ‘by and for’ means, please see: https://twitter.com/Imkaan/status/1511743129094864896

[2] LAWRS. The Right to be Believed Migrant women facing Violence Against Women and Girls (VAWG) in the ‘hostile immigration environment’ in London, key findings. 2019.

[3] The New Statesman: Police report hundreds of crime victims a month to immigration service, 2022.

[4] Safe to share? Report on Liberty and Southall Black Sisters’ super-complaint on policing and immigration status, 2020.

[5] LAWRS. The Right to be Believed Migrant women facing Violence Against Women and Girls (VAWG) in the ‘hostile immigration environment’ in London, 2019.

[6]  Home Office: Modern Slavery: Statutory Guidance for England and Wales (under s49 of the Modern Slavery Act 2015) and Non-Statutory Guidance for Scotland and Northern Ireland; Home Office: Domestic Abuse Draft Statutory Guidance Framework, 2021. Para 85.

[7] Safety Before Status. Improving pathways to support for migrant victims of domestic abuse, 2021.

[8] Migrants reporting crime: building trust with the police.

[9] Examples of how a firewall can work in practice have been tried internationally. For more information please see: Preventing and Addressing Abuse and Exploitation: A Guide for Police and Labour Inspectors Working with Migrants, 2022.

[10] Pre-legislative scrutiny of the draft Victims Bill.

[11] Justice Committee: Pre-legislative scrutiny of the draft Victims Bill (14:42:46)

[12] Safe to share? Report on Liberty and Southall Black Sisters’ super-complaint on policing and immigration status, 2020.

[13] For more information, please see our Joint response to the “Home Office and Police data-sharing arrangements on

migrant victims and witnesses of crime with insecure immigration status”, 2022.

[14]  Ritchie, A., 2017. Invisible No More. Police violence against Black women and women of colour. Beacon Press.

[15] Labour Exploitation Advisory Group & Focus on Labour Exploitation: Opportunity Knocks: improving responses to labour exploitation with secure reporting, 2020.

[16]  LAWRS data shows that at least 60% of migrant women have received threats of deportation from their perpetrators: The Right to be Believed - Key Findings, 2019

[17] A public health approach to modern slavery has also been recommended by the Independent Anti-Slavery Commissioner, Public Health England and the University of Sheffield in their report: Refining a public health approach to modern slavery, 2021.

[18] Bates, L., Gangoli, G., Hester, M. and Justice Project Team (2018), Policy Evidence Summary 1: Migrant Women. University of Bristol, Bristol.

[19] Baroness Casey Review - Interim Report on Misconduct; Operation Hotton Learning report; PEEL 2021/22 – An inspection of the Metropolitan Police

[20] Stop and search: Ethnic minorities unfairly targeted by police - watchdog, 2022.

[21] Revealed: Met police strip-searched 650 children in two-year period, 2022.

[22] Joint Principles for the Home Office Safer Streets Funding, 2021.

[23] Met chief Sir Mark Rowley announces major new crackdown on sex predators, 2022.

[24] An example of how counter-terrorism policies can negatively impact racialised communities is the Prevent strategy.