Protocol and Guidance for Modern Slavery

What is modern slavery?

Modern slavery encompasses slavery, servitude, forced and compulsory labour and human trafficking. There is no typical victim of slavery. Victims can be men, women or children of all ages and nationalities. The following definitions are encompassed within the term 'modern slavery' for the purposes of the Modern Slavery Act 2015:  

• 'slavery' is where ownership is exercised over a person
• 'servitude' involves the obligation to provide services imposed by coercion
• 'forced or compulsory labour' involves work or service extracted from any person under the menace of a penalty and for which the person has not offered themselves voluntarily
• 'human trafficking' concerns arranging or facilitating the travel of another with a view to exploiting them. It is irrelevant whether the person consents to the travel. Both modern slavery and human trafficking are crimes

See the links to the offences: 

• section 1
• section 2
• section 3

Statutory duty to notify

Section 52 of The Modern Slavery Act 2015, places a duty on all local authorities, the police (including the British Transport Police), the National Crime Agency and Gangmasters Licensing Authority to notify the government using the National Referral Mechanism (NRM) if they believe a person may be a victim of human trafficking or slavery.

Home Office staff within UK Visas and Immigration, Border Force and Immigration Enforcement (amongst other agencies) are also required, as a matter of Home Office policy, to comply with the duty to notify.

The difference between an NRM referral and a Duty to Notify (DtN) referral relates to the consent of the adult involved.

Under the duty,  referral to the NRM is mandatory even if the victim wishes to remain anonymous and does not want to access specialist support. In this instance only mandatory fields of the online form that collects data anonymously are required, and this is referred to as the DtN.

Notification of child victims

Any child identified as at risk of being trafficked should be referred to the Dorset Children’s Advice and Duty Service (ChAD).

Children who are recognised as under 18 years old do not have the option of anonymity and should also be referred to the National Referral Mechanism (NRM) in all cases. This online NRM form should be used for a child victim. 

Any child under the age of 18, transported for exploitative reasons is considered to be a trafficking victim, whether or not they have been forced or deceived. This is partly because it is not considered possible for children in this situation to give informed consent. Even when a child understands what has happened, they may still appear to submit willingly to what they believe to be the will of their parents or accompanying adults. It is important that these children are protected.

Notification of adult victims

See guidance on the NRM process for adults.

The NRM online form should be used for any adult victim regardless of whether the adult victim provides consent or not. If the victim does not consent and wishes to remain anonymous and not receive support, the same form should be used although no personal information will be given.

 If the adult consents and is accepted for support, the support can include: 

• temporary safe accommodation
• medical treatment
• emotional Support
• interpreters / translators
• protection
• legal advice
• financial support
• outreach support 

In the case of an adult victim, any notification should be copied to the Adult Safeguarding Triage Team.

Dorset’s Local Notification Process

A step by step guide detailing the modern slavery and human trafficking local notification process is provided below. Members of staff should liaise with their organisations’ Safeguarding Slavery Leads when following the process and completing the notification forms.

Do you think the potential victim is under 18?

If the answer is yes, you should refer to the ChAD service and then complete and submit an NRM online form. Copy this NRM form to your contact in the ChAD, the Dorset Police Force Intelligence Bureau and relevant Safeguarding Slavery Lead (SSL).

Potential victim’s over 18

Is the potential victim willing to be identified and provide their personal details? 

If the answer is no, there is still a Duty to Notify and you need to complete and submit the online NRM form using only the mandatory fields  that collects data anonymously. Copy the form to Adults Safeguarding Triage, Dorset Police Force intelligence Bureau and relevant Safeguarding Slavery Lead (SSL).

If the answer is yes to providing personal details, before you complete and submit the online NRM form you need to ask if they want to receive specialist support.

If the answer is yes, complete and submit the online NRM form (and indicate on the form that support is requested). Copy the form to Adults Safeguarding Triage, Dorset Police Force Intelligence Bureau and relevant Safeguarding Slavery Lead (SSL).

To access support, contact the Salvation Army on 0800 808 3733

If the answer is no, complete and submit the online NRM form (but indicate on the form that support is not requested). Copy the form to Adults Safeguarding Triage, Dorset Police Intelligence Bureau and relevant Safeguarding Slavery Lead (SSL).

When making an NRM referral please ensure the relevant parts of the forms are properly signed by the potential victim. It is important to ensure potential victims are aware who their information will be shared with so they can give informed consent.

What happens next?

The NRM online form will be assessed by the Home Office which is the Government department that leads on modern slavery. Contact details for the Home Office are provided on each form. The Home Office will endeavour to make a reasonable grounds decision within 5 working days.

In the interim period, as long as the NRM form has been signed by the victim and submitted to the Home Office, it should be possible to access support for them through the Salvation Army. Support is available to potential victims even if they have ‘no recourse to public funds.’ 

The Salvation Army can be contacted 24/7 on 0300 303 8151.

Operations

Modern slavery and human trafficking are crimes and any immediate or urgent concerns should be reported to the Police by calling 999.

Less urgent issues can be reported to Dorset Police via their 101 number and intelligence and information shared with the Police by contacting the Force Intelligence Bureau (FIB). 

Any operation relating to modern slavery or human trafficking will be led by Dorset Police. 

In planning and executing the operation the Police may require the co-operation and support of services within partner agencies. The type of services and support will depend on the nature and scale of the operation. As a minimum, in the event of a planned operation, the Police will liaise with the Safeguarding Slavery Leads (SSLs) to ensure they are sighted, and the correct interventions and support are in place. 

A list of partners' contacts and services.  

SSLs will act as the Single Point of Contact (SPOC) within their organisation in the event of any planned operation. 

In the event of Dorset Police identifying a victim of modern slavery as a result of normal operations, the Police will follow their internal modern slavery protocol and complete the required notification form. If the Police via an unplanned modern slavery operation identify a large number of modern slavery victims Dorset Council can assist in the humanitarian response to the incident.

In these situations Dorset Council’s response can be activated via the Duty Emergency Planning Officer who is available 24/7 on:

• their pager on 07623 544346
• duty mobile on 07443 149292

The Emergency Planning team will liaise with colleagues to identify the most appropriate response, resources available are: 

• provision of temporary place of safety via a rest centre attended by social care staff
• emergency transport provision via Dorset Travel and local transport providers
• co-ordination of voluntary agency support
• duty Communications officers
• Dorset Councils SSLs N.B. Dorset Council’s SSLs are not 24/7
• Dorset Council can provide a Local Authority Liaison Officer (LALO) 24/7to attend the scene in a coordination role. Please note the LALO is not a social worker.

Please note: Dorset Council’s ability to complete notification forms out of hours is dependent on our Out of Hours adults and children’s social care providers. We may not always be able to get officers to the scene of the incident so will rely on support from Salvation Army and Police.

Safeguarding Slavery Leads (SSLs)

SSLs should act as a point of advice and information for staff from their organisation and should help them with the completion of NRM online referral forms. SSLs have a role to play in ensuring links are made to safeguarding and the Police regarding any notifications and should act as the SPOC for their organisation in the event of a planned operation.

Details of your SSL. 

Contacts and services

If there’s a crime, emergency or someone is in immediate danger call 999.

Operations relating to modern slavery or human trafficking should be led by Dorset Police. In the event of an unplanned event or operation the Police should contact Dorset Council’s Duty Emergency Planning Officer on 07623 544346.

For a planned event or operation, the Police should contact the appropriate Safeguarding Slavery Lead (SSL) in Dorset Council. 

24/7 generic contacts - to be used for any unplanned event, situation or operation

Sources of modern slavery advice and support within agencies

Contact details for people within agencies who can provide non-urgent advice and information to professionals about Modern Slavery issues

 Available services