Protocol and Guidance for Modern Slavery

What is modern slavery?

Modern slavery is complex, and the term is used to encompass slavery, servitude, forced and compulsory labour and human trafficking. Perpetrators of modern slavery target vulnerable individuals and groups. There is no typical victim. Victims can be men, women or children of all ages and nationalities.

The Equality and Human Rights Commission provides the following definitions: 

• slavery is when someone actually owns you, like a piece of property. 
• servitude is similar to slavery – you might live on the person’s premises, work for them and be unable to leave, but they don’t own you. 
• forced labour means you are forced to do work that you have not agreed to, under the threat of punishment. 

Human Trafficking is a factor in some but not all cases of modern slavery. Human Trafficking is when a person is moved for the purpose of exploitation; this includes movement within a country, whether from one city to another or even just a few streets, as well as international movement. Exploitation can take many forms, including sexual exploitation, forced criminality, financial exploitation and debt bondage. Victims of human trafficking can be men, women and children, and a person is still a victim of human trafficking if they have not yet been exploited but have been moved in order to be exploited. 

Modern slavery is a crime. Descriptions of the offences are set out in Section 1, 2 and 3 of the Act:. 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 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 are also required, as a matter of Home Office policy, to comply with the duty to notify.

The duty to notify is mandatory even if the victim wishes to remain anonymous and does not want to access specialist support. This is to allow non-personalised data to be captured, as part of building a fuller national picture of what is happening. 

Children who are recognised as under 18 years old do not have the option of anonymity and must be referred to the National Referral Mechanism (NRM).

Adults who are considered potential victims can access specialist support and advice by being referred to the NRM. They need to give consent to a full referral, which will include their personal details. Support can include:

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

The duty to notify does not act as a safeguard to people at risk and existing safeguarding processes should be followed in tandem with any referral. In the case of a potential adult victim, any referral to the NRM should be shared with the Adult Safeguarding Triage team.

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. 

Any child identified as at risk of being trafficked should be referred to the Multi-Agency Safeguarding Hub (MASH) through the normal mechanisms. Information will be gathered and a manager will make a 24 hour decision as to how this might be progressed.

All referrals, for an adult with or without consent or a child, are made using the same online form. The form is designed to be responsive and will change depending on the information you the different options you select. If you won’t have access to a computer when you speak to a potential victim, there is an NRM prompt sheet you can download and use. This contains questions you’ll need to ask to collect the type of information that is needed.  

A flow chart detailing the modern slavery and human trafficking notification process is provided further below. Members of staff should liaise with their organisation’s Safeguarding Slavery Leads (SSLs) when following the process and completing the notification forms (contact details are provided here).

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.

If you think someone may be a victim of modern slavery, please liaise with your organisation’s Safeguarding Slavery Leads (SSLs) and follow the steps below.

Do you think the potential victim is over 18?

If the answer is no, you should notify the Family Support and Advice Line/MASH, and complete an NRM form.

Potential victim’s over 18

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

If the answer is no, complete a NRM form, selecting options not to include personal details. Inform Adults Safeguarding Triage, Dorset Police Force Intelligence Bureau and relevant Safeguarding Slavery Lead (SSL).

If the answer is yes, does the victim want to receive specialist support?

If the answer in no, complete an NRM form (but indicate on the form that support is not requested). Inform Adults Safeguarding Triage, Dorset Police Force Intelligence Bureau and relevant Safeguarding Slavery Lead (SSL).

If the answer is yes, complete an NRM form (and indicate on the form that support is requested). Inform Adults Safeguarding Triage, Dorset Police Force Intelligence Bureau and relevant Safeguarding Slavery Lead (SSL). Contact the Salvation Army to access support.

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.

Operations

Modern slavery is a crime 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) Community partnership intelligence | Dorset Police 

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 SSLs in the Council to ensure they are sighted and the correct interventions and support are in place.

A list of partners’ contacts and services are provided here.

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

In the event of an unplanned operation, the Police should contact the Council’s Duty Emergency Planning Officer who is available 24/7 via their pager - 07623 544346.

The Emergency Planning team will liaise with colleagues to:

• identify suitable reception centre premises
• activate the staffing of premises by social care staff trained in reception centre management (in conjunction with a designated Local Office Incident Manager or Post Trauma Response Coordinator)
• coordinate emergency transport provision via Dorset Travel and contact transport providers
• provide documentation at reception centres (if required) 
• co-ordinate voluntary agency support (e.g. practical and emotional support, administrative assistance, first aid, pastoral care, catering and welfare provision)

In the event of an unplanned operation, the Duty Emergency Planning Officer will be responsible for liaising with other necessary emergency response teams, with Council colleagues and relevant partner SSL.

Through operations and by responding to pieces of intelligence received by the FIB, it is possible to disrupt modern slavery activity and protect victims from further exploitation.  

Information for 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 the online NRM form. 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.

Further guidance on the role of First Responders can be found in the Modern Slavery Statutory Guidance. This guidance was last updated 30 January 2023 and SSLs should familiarise themselves of the current processes and requirements. 

All NRM forms are sent to the Single Competent Authority (SCA) who will be responsible for making both a reasonable and conclusive grounds decision regarding any case.

The SCA endeavour to make a reasonable grounds decision as soon as possible, ideally within 10 working days but it can take longer. In the interim period, as long as the online NRM form has been completed by the potential victim, 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 on 0800 808 3733.

There is a useful short video, developed by the National Crime agency (NCA), the National Police Chief’s council (NPCC) and the National network of Regional Organised Crime Units (ROCU), that explains the process of making a referral to the NRM.  There is also a video covering Section 45 of the Modern Slavery Act as a statutory defence.

Further resources, including quick reference guides, will be made available as they are identified or developed.

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 the 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