Commissioner’s Response to the Home Office Consultation – FGM
5th December 2014
Vera Baird QC response to the Home Office Consultation about Female Genital Mutilation – December 2014
Q1. Do you agree that the draft statutory guidance provides frontline professionals with the information they need on the prevalence of FGM and the issues around it? If not, where and how could the guidance be changed?
The draft statutory guidance for frontline staff is comprehensive in terms of instruction and safeguarding mechanisms. However, a key area of sensitivity around understanding and implementing the guidance is the direct work with Black and Minority Ethnic communities and victims of FGM. There needs to be a considerable amount of training and support put in place, work with community organisations and specialists BME women’s groups to ensure that professionals can engage with guidelines effectively alongside a sensitive, informed and safe approach to working with victims from diverse communities.
Q2. Do you agree that the draft statutory guidance provides service delivery organisations with the information they need on the prevalence of FGM and the issues around it? If not, where and how could the guidance be changed?
The guidance draws attention to this without an overload of information, which can sometimes desensitize the audience. Links to other organisations who have more detailed information such as Forward, is also a positive step.
Q3. Do you agree that the draft statutory guidance adequately captures FGM risk factors?
There could be a better understanding of FGM within a wider context of violence against women and girls, with more attention paid to the FGM as part of a spectrum of violence rather than as a ‘cultural’ practice alone.
Q4. Do you agree that the draft statutory guidance captures the full range of legal tools and interventions to enable professionals and public sector organisations to safeguard and protect women and girls at risk of FGM?
As above, it is important to highlight that the amount of support and work around awareness raising must go hand in hand with these tools and interventions. A multi-agency approach is always positive but is only as good as relevant agencies have trained and competent staff who can deal with the issues relating to FGM effectively.
Q5. Do you agree that the draft statutory guidance promotes an individual-centred approach, ensuring that a woman or girl’s individual circumstances drive the decision making process at all times? If not, what additions do you consider could be made to the guidance?
The guidance promotes an individual centred approach but it is important to highlight that for this to be carried through, there needs to be additional in-house training with professionals, providing them with the tools to holistically contextualise each individual’s needs, for instance, the additional struggles and potential violence/pressure from the family for women without recourse to funds. This brings to the fore a need to interconnect the facts, figures and processes with the practice and experience of working with BME victims in a way that identifies any additional needs or risks and affects the way that individual is supported.
Q6. Do you agree that the draft statutory guidance provides sufficient – and clear information for a) health care providers b) police c) children’s social care and d) schools and colleges?
The guidelines provides sufficient and clear information for the statutory agencies listed above – these agencies should be taking responsibility for auditing and checking the cultural competence and knowledge of FGM of its workforce. There should also be an additional caveat that these organisations should examine local and regional demographics to better understand how they can work with specialist organisations, for instance, those working with BME women to improve longer-term outcomes and engagement.
Q7. Do you agree that the draft statutory guidance captures how professionals and public sector organisations can work with communities to prevent FGM?
The guidance on partnership working between professionals, public sector organisations and communities is useful but it also needs to make reference to specialist organisations working with BME women. These organisations have worked hard to build trust with victims of domestic abuse and sexual violence and are more likely to be approached for help and support. The public sector organisations rely on the expertise of these organisations and recognising the roles played by statutory agencies in tackling FGM, it is vital that all of these key stakeholders collaborate to provide holistic support to victims. Specialist organisations have a good level of understanding of the issues relating to FGM so joint training programmes with the public sector organisations will also be extremely beneficial.
Q8. Do you agree that the draft statutory guidance describes a multi-disciplinary approach, which will allow for the voice of the child to be heard and respected whilst working to protect and support her? If not, where and how could it be improved?
The guidance describes the importance of a multi-disciplinary approach and it is vital for key stakeholders to work together to ensure that voices of BME women and children are represented. Again the effectiveness of the partnership working is dependent upon the culture or the knowledge base of the statutory sector, collaborating with voluntary and community organisations. The cuts to children’s services and youth projects in local authorities have left many children and young people at risk, as they are not being supported outside of mainstream schooling. Specialist organisations working with women have been funded by the Police and Crime Commissioner, Northumbria to support girls and young women and raise awareness of FGM in communities. Schools should be better supported to tackle FGM and raise awareness of this subject in their institutions.
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