Consultation on the Gender-based Violence, Domestic Abuse and Sexual Violence (Wales) Bill

The Communities, Equality and Local Government Committee have asked for organisations to consider 5 specific areas of the Bill as part of an ongoing consultation process.

The collaborative response from Domestic and Sexual Violence and Abuse co-ordinators (DSVA’s) working across South Wales area can be found below:

1) General principles of the Bill and the need for legislation to improve the Public Sector response in Wales to gender based violence, domestic abuse and sexual violence including:

· The publication of national and local strategies and

· The appointment of a Ministerial Advisor on Gender Based Violence, domestic abuse and sexual violence

National and Local Strategies

The DSVA’s welcome both the publication of both a national and local strategy however clarification surrounding target setting is still needed at both a national and local level. Sanctions for failing to realise targets are not made clear within the Bill, more information is needed. Will there be minimum standards? How will ‘success’ be measured, monitored and evaluated?

Appointment of a Ministerial Advisor

The DSVA’s welcome the appointment of a Ministerial Advisor. It would be useful to know how the Ministerial Advisor will be appointed. There is some concern over the very tight timeframe that has been stated within the Bill which suggests that an appointment will be made during Autumn 2014.

2) Any potential barriers to the implementation of these provisions and whether the Bill takes account of them

Given the recommendations in both the Williams Report and very recent Police and Crime Commissioner Report undertaken by CAADA which reviews the services available to victims of domestic abuse across South Wales it is difficult to comment on the impact this legislation will have both nationally and locally as the picture of how Wales will ‘look’ and how service provision will be reorganised is unclear.  We have however made some general comments below:

Service Provision

The launch of the Bill is likely to increase the need for service provision for victims and their families. Given the significant budget cuts that are currently taking place across many local authorities this is of concern. Raising the profile of gender-based violence is hugely positive but we must ensure that victims and their families receive a first class service, when they need it.  In addition, more statutory and voluntary interventions for perpetrators (men, women and young people) are also needed if we are to affect positive change.

Gender Based Violence

The CPS ‘Violence Against Women and Girls’ Report (2014) highlights the gendered nature of sexual violence and domestic abuse. The DSVA’s fully accept that men can also be victims and it is appropriate for this to be highlighted however there is a need to ensure that service provision (and national and local strategies) takes account of the fact that women are disproportionately affected.

The Title of the Bill

The DSVA’s believe that the original title ‘Domestic Violence and Domestic Abuse (Wales) Bill’ is clearer than the new title. 

Domestic Abuse and Sexual Violence Role

Developing effective working relationships between local providers and other relevant agencies cannot be underestimated, This is a key role of the DSVA Co-ordinator. The role of the DSVA co-ordinator is not mentioned in the proposed Bill.

3) Whether there are any unintended consequences arising from the Bill

The removal of both workplace policies and education awareness from the Bill are disappointing.

Workplace Policies

Workplace policies need to consider the victims of both domestic abuse and sexual violence. Workplace policies should include guidance on how to support victims and manage possible perpetrators. Such policies also need regular review and there is a concern that workplace policies in place may not be robust enough to manage all forms of abuse. Secondly, in order for the policy to be successful  all employees working within the statutory sector will need some level of training around Gender based violence and related issues. Guidance on how this should be approached is not yet clear.

Education Awareness

To exclude this from the Bill completely is very disappointing and there is a risk that this exclusion will serve to undermine the main purpose of the Bill. Experts in domestic and sexual violence must be consulted as part of the education review. Domestic Abuse Awareness and Sexual Violence Awareness should be compulsory in all schools.  We are aware that there has been a recent consultation in respect of the Education review.

4) The financial implications of the Bill (as set out in Part 2 of the Explanatory Memorandum)

More information is required in respect of financial implications generally. It is of concern that the Bill is to be launched during a time of financial uncertainty when budgets cuts continue to affect a number of statutory agencies

5) The appropriateness of the Bill for Welsh Ministers to make subordinate legislation (as set out in Chapter 5 Part 1 of the Explanatory Memorandum)

Given the nature of domestic abuse and sexual violence, this would seem appropriate.

South Wales Domestic Abuse and Sexual Violence Co-ordinators

Nicola Jones – Cardiff

Beth Lindsey-Gaylard – Bridgend

Louise Thomas – Rhondda Cynon Taff

Jennie Roberts – Vale

Julia Lewis – Neath & Port Talbot

Leanne Webber - Merthyr

3^rd September 2014