PLVAW 01
Ymchwiliad ôl-ddeddfwriaethol i Ddeddf Trais yn erbyn Menywod,
Cam-drin Domestig a Thrais Rhywiol (Cymru) 2015
Post legislative inquiry into the Violence against Women,
Domestic Abuse and Sexual Violence (Wales) Act 2015
Ymateb gan: Partneriaeth Diogelwch Cymunedol Gwynedd ac Ynys Môn
Response from: Gwynedd and Anglesey Community Safety Partnership
I can only speak on behalf of the Local Authorities with whom I am actively engaged, however I can state that as a result of this legislation, I have witnessed some substantial cultural shifts within one of the Local Authorities in particular, with whom I am engaged.
Another accepts the duties and obligations that will arise as a result of this legislation, especially pertaining to section 5 (duty to prepare a local strategy) and statutory guidance under section 15 (National Training Framework), however owing to the duties and obligations arising from the Wellbeing of Future Generations Act, the Housing (Wales) Act and the Social Services and Wellbeing Act simultaneously, are far more pragmatic in their approach. Despite the differing approaches taken, every effort has been made within the past twelve months to raise awareness with Chief Executive Officers, Service Leaders and Managers, of the National Training Framework and the obligations that lie ahead.
However, what I will say is apart from the culture shift seen within one organisation whom I am working closely with, as a result of awareness raising of this Act, I cannot say whether the legislation itself is having any impact on organisations.
The reasons that I believe for this are due to poor communication, technical difficulties and substantial lack of any form of clarity or direction from Welsh Government.
In reference to the National Training Framework on Violence against Women, Domestic Abuse and Sexual Violence, no member of staff I have been working with has been able to gain access to the Level 1 e-learning module, due to the technical issues that appear to have arisen as a result of the transfer of the license for hosting e-learning from the All Wales Academy to the NHS E-learning site.
This technical issue has been ongoing for a period of over eight months and is causing a great deal of consternation and frustration. It appears that neither Gwynedd nor Anglesey will achieve the 50% completion rate target by 31st March 2017 as a result.
Furthermore, similar problems have arisen with regard to Levels 2 and 3 of the National Training Framework, where Local Authorities are expected to develop Ask and Act policies, appoint Ask and Act Leads and contact officers, appoint individuals to form part of a Regional Training Consortia to deliver training, and arrange for designated members of staff to receive the said training either as a stand-alone training package or as an integrated package with safeguarding training.
Again, Local Authorities are expected to have outlined how this training will look like within their organisations in a regional training plan to be submitted to Welsh Government by 31st March 2017, and yet despite this timescale, there has been no communication, direction or clarification from Welsh Government as to how they envisage this training to be developed, ie. will it be developed by Welsh Government or is there an expectations that Local Authorities devise their own Ask and Act via a Regional Workforce Development Group for instance?
The lack of communication and progress on the issue is disheartening.
Despite obtaining the commitment of several service departments to trial and initiate the e-learning and Ask and Act, progress cannot be achieved due to technical difficulties and lack of communication as to Welsh Government’s intentions in respect of the Ask and Act. As a result, this is not only hampering progress but momentum.
I am not sure as to the most effective methods of capturing service user experience. I would suggest that in order to make the best possible use of service-user feedback in order to develop ideas as to how to improve services, a regional or national network be developed, comprising of individuals who are engaging with services but who have surpassed crisis intervention and are no longer considered high risk.
3. Whether survivors of abuse are beginning to experience better responses from public authorities as a result of the Act, particularly those needing specialist services?
Due to the fact that my core work is strategic and owing to the problems that have arisen with regard to sections 5 and 15 of the National Training Framework (which would offer opportunities to increase disclosure rates), I feel it is too early to speculate as to whether the Act has had a noticeably beneficial impact on service users requiring specialist assistance from public authorities. However, I can say with certainty that awareness around Violence against women, domestic abuse and sexual violence within the two authorities whom I am engaged with has increased dramatically over the past twelve months, as a result of raising awareness of the Act.
I would add however that some non-frontline service departments have demonstrated little awareness of the Act, in contrast to the Wellbeing of Future Generations Act and the Social Services and Wellbeing Act therefore I suggest perhaps that some consideration be given to the development of promotional material that might highlight this piece of legislation.
Again, I feel it is rather early to speculate as to whether the National Adviser has sufficient power and independence from the Welsh Government to ensure implementation of the Act, in practice.
In principle, I would agree that the National Adviser is sufficiently independent from Welsh Government as to make informed, impartial and sound evidence-based judgements and recommendations, free of influence, and early indications thus far, would appear to support that assessment.
Furthermore, the National Adviser has thus far demonstrated a strong commitment to the inclusion of service user engagement in the improvement of services and has also shown a willingness to listen to the concerns of service providers and strategic leaders in this area.
The National Adviser will be supporting the transition to regional strategic leadership, by becoming a member of a regional group that will oversee the development of a Regional Training Plan, Regional Training Consortia and the appointment of a Regional Advisor in North Wales. The National Adviser’s involvement will be considered welcome and crucial to ensuring that the transitional process is as transparent and as accountable as possible.
As my core work is strategic, I can only evidence this assessment with data and information fed-back to me via service providers involved in the delivery of this work.
However, I can state with clarity that qualitative and quantitative data has consistently shown that schools-based intervention on healthy relationships has had a marked positive effect on children and young people, with one such regionally-commissioned programme once having contributed to a Police disclosure, later followed by a successful prosecution.
Statistics consistently show that such intervention programmes are crucial in educating children and young people about issues relating to domestic abuse, sexual offences, child sexual exploitation and consent.
While I certainly agree that these programmes are fundamental to changing attitudes and have consistently shown a positive effect on young people, I feel it is too early to speculate whether the formulation of the Act and the whole school approach has improved attitudes further.
I would however expect in the coming years for the whole schools approach to considerably strengthen and improve schools-based intervention programmes further as the ethos becomes embedded within current educational practices and culture.
I would add however that in the same vein, it is also crucial to develop age-appropriate programmes for younger children of primary school age, who may be experiencing domestic abuse at home, as this constitutes a child protection issue. Whether this takes the form of programmes designed to encourage young children to speak out to appropriate adults, such as teachers about abuse taking place at home; or whether the programme should consist of training to identify signs and symptoms within children and strictly following the Child Protection procedures as a result, I feel some age-appropriate intervention for teachers, and/ or primary school age children should be considered, as many Child Practice reviews, statistics and data has shown a link with child abuse and domestic abuse.
For these reasons, I feel it is crucial to target children as well as young people as to how they can obtain support and protection.