Our guide to responding to the Home Office ‘New Plan for Immigration’ consultation
On 24th March, the UK Home Office launched a six-week consultation about its ‘New Plan for Immigration’, which also contained proposals to significantly change the existing system for the identification and support of victims of modern slavery (called the National Referral Mechanism).
Hope for Justice responded to this announcement at the time with a statement, and to the concerning way the story was presented in the media and the quotes from ministers, who focused on alleged abuse of the existing system by criminals and implied a widespread problem of people falsely claiming to be victims of modern slavery to avoid justice or immigration enforcement. We do not believe this to be an evidence-based claim, and the Independent Anti-Slavery Commissioner produced a report looking at the facts.
Our view on the consultation:
Hope for Justice was surprised at the extent of changes to modern slavery support policy in this consultation, since the provision of support to victims of modern slavery is not an immigration decision and a significant proportion of victims entering the system are UK nationals. We are concerned that modern slavery has been included within this plan.
Overall the consultation itself is not fit-for-purpose for consulting on such widespread changes. In particular, the format of the consultation and the evidence provided to support changes is complex and confusing.
Hope for Justice believes that the proposed changes would significantly impact on the government’s international reputation of being world-leading in the fight against modern slavery. We welcome any improvements to victim care and any update to the modern slavery strategy; however, a significant proportion of the changes outlined in the plan will negatively impact vulnerable men, women and children. The proposed would increase the risk of exploitation and reduce the ability of victims to be identified, to access safeguarding and support, and ultimately reduce the chances of them being able to engage with criminal justice processes and ensure perpetrators are held accountable for their crimes.
In fact, our experts believe that if these rules were in place 5 years ago, the Operation Fort investigation – where Hope for Justice helped police bring down the gang behind the biggest trafficking case in European history and supported scores of survivors – would likely never have happened.
The traffickers would still be active, instead of in jail where they are now (graphic shows a collage of media coverage at the time).
Despite the consultation not being fit-for-purpose, it is still important for organisations, individual practitioners in the field and members of the public to take part in the consultation given the significance of the changes outlined.
We are therefore urging our supporters to take part in the consultation and have provided some guidance in terms of the topic and Hope for Justice’s response to this. Hope for Justice is only answering questions that relate specifically to the concerns around modern slavery.
How to sign up and take part in the consultation:
-After sign up you should receive an email confirmation from Britain Thinks, which is running the consultation on behalf of the Home Office. In the email click on Go to the platform. This takes you to the website where you can take part in the consultation.
-The platform has a number of documents including the Plan for Immigration and two separate online surveys: one is entitled the New Plan for Immigration: Main questionnaire and the other is called Further details questions on the New Plan for Immigration.
-For each of the survey click on the relevant “Take the Survey” link or select the relevant link from the drop down options available in Projects at the top of the page. Note the survey that you are looking for is as a member of the public as the question numbers are different for professionals.
-If you are short of time we have suggested that you focus on responses to chapter 1 and chapter 5 and 6.
You do not need to answer every question – you can decline to answer the question and move onto the next. DEADLINE: Responses to the consultation must be submitted by 11.45pm on 6th May.
Our responses and suggestions:
For speed and your convenience, we have summarised our answers to each question in bold red text in this briefing document. You may wish to use these as model answers for your own responses (we think this should only take about 10 minutes) or write your own.