Reflections on the Domestic Abuse Commissioner’s response to the Serious Violence Duty Consultation

The response from the office of the Domestic Abuse Commissioner for England and Wales, Nicole Jacobs, to the Government consultation on the Statutory Guidance on the Serious Violence Duty is very much worth reading (Link here). It makes a clear case for the inclusion of domestic abuse in the definition of serious violence for duty holders and an expectation that domestic abuse should be part of local strategy actions.

It highlights the emerging data on the high prevalence of child survivors of domestic abuse in Violence Reduction Units (VRUs). One has found that “42% of children involved in public space serious violence experienced domestic abuse in the home (19% more than once)”. In fact, figures I recently received from a Serious Youth Violence project in Essex supported 157 children in their first 18 months and found that 92% had experienced domestic abuse. Another support organisation for young people on-road, ‘Action Isleworth Mothers’ found 90% of children on their caseload had experienced DVA. In my work on this topic I have heard time and again that the co-prevalence rates are very high, when data is collected. As I have written about in my research- I think we need to consider this co-prevalence as more than just ‘ACEs’ on a risk assessment, but consider deeply what this means for young people’s sense of themselves. It was great so see an endorsement of my book in the consultation;

“I would direct the Home Office towards Dr Jade Levell’s recently published book which provides important insights into how boys in this context navigate their journey to manhood with the constant presence of violence in their lives, in addition to poverty and racial marginalisation.”

Government consultation on the Statutory Guidance on the Serious
Violence Duty: Written submission from the Domestic Abuse
Commissioner for England and Wales. (2022) Page 2.

My book is split into three distinct sections. Part 1 outlines the theoretical and methodological background to my research. Part 2 is life stories of men who engaged in music elicitation interviews. Part 3 is focused on ‘joining the dots’ in practice and includes my analysis of, ‘Policy Links: Why is ‘Domestic Abuse’ Not ‘Serious Violence’? A False Dichotomy’, and ‘Gender Blind? The Public Health Approach to violence’. Building on the life story interviews I conducted as well as analysis of all serious case reviews where children have died who have experienced childhood DVA and involvement in youth offending on-road, I make a case that DVA should be an integral part of safeguarding, youth, and social work, for young people on-road. However as the DVA and SYV sectors have worked in silos I found a lack of awareness of the dynamics of DVA in the SCR’s which focused much more on the criminality of young people and the need for surveillance. So I am also pleased to see in the DA Commissioners response highlighting the need for effective training and upskilling on domestic abuse in the SYV sector;

“I would strongly recommend that there is substantial domestic abuse content – covering support and provision – through all the proposed options, including seminars, peer support and national facilitators. This could include sessions from Violence Reduction Units on their role in wider domestic abuse structures; training from the domestic abuse sector; and academic sessions from leading researchers on the relationship between domestic abuse and public space serious violence, like that of Dr Jade Levell mentioned in Question 2.”

Government consultation on the Statutory Guidance on the Serious
Violence Duty: Written submission from the Domestic Abuse
Commissioner for England and Wales. (2022) Page 6.

It is also really notable that the response was explicitly critical of the way the former ‘Gangs Matrix’ misused personal data from young people who were considered a risk to others in a way that further marginalised them. The matrix was very widely criticised, including by Amnesty International, who found it to be, ‘the wrong tool for the wrong problem: a racially discriminatory system that stigmatises young black men for the music they listen to or their behaviour on social media’ (Access their report here). Most notably, AI found that on the matrix, ‘72% of those identified as responsible for ‘gang flagged violence’ are Black, whereas in reality 27% of those responsible for youth violence are Black.’

“it is important to highlight good and bad practice in the guidance to ensure duty holders do not mishandle data. For example, the Metropolitan Police’s handling of data in implementing the gang matrix was found to be in serious breach of data laws in 2018 by the Information Commissioner’s Office (ICO)… Such breaches and poor practice cannot happen again. Doing so would undermine the value of the duty and further erode the confidence in our criminal justice system, as well as having the potential to further marginalise individuals who may be rightly wary of statutory agencies and risk exacerbating the concerns of over policing black and minoritized communities”

Government consultation on the Statutory Guidance on the Serious
Violence Duty: Written submission from the Domestic Abuse
Commissioner for England and Wales. (2022) Page 6-7.


I think it is really excellent that the office for the DA Commissioner is also highlighting the risks of racial marginalisation in the information systems used under the Serious Violence Duty. As I have written about in my book, the marginalisation of boy child survivors of DVA are exacerbated by other co-existing forms of marginalisation, including of race, class, poverty, as well as criminal history. Children who are offending and engaging in youth violence are already less likely to be seen as victims in their own right, a case which is more pertinent for Black boys who can be further ‘adultified’ and seen as less vulnerable.

The last point to highlight is the lack of a coordinated community response within and around VRUs. They note;

As I have raised in Question 2 from my engagement with Violence Reduction Units, it has become clear that there often is an absence of a structure that promotes and embeds a coordinated community response. It is important that any structures designed for the duty, lead on, or fit into, wider domestic abuse
systems, such as the domestic abuse, sexual violence, and VAWG strategic and operational groups that have developed alongside, and sometimes as part of, safeguarding boards. The multi-agency structure should also engage and develop relationships with the domestic abuse and sexual violence sector. This is in order to ensure collaboration and prevent duplication which could occur with the new duty. This is also whilst driving forward a co-ordinated approach and ensuring that there is an effective, co-ordinated, and cobeneficial response to public space serious violence and domestic abuse, of
which we know there is much overlap.
This must be reflected in the expectations of the governance.

Government consultation on the Statutory Guidance on the Serious
Violence Duty: Written submission from the Domestic Abuse
Commissioner for England and Wales. (2022) Page 12.

The lack of the CCR model in areas outside of London and larger cities has been on my mind a lot recently. As part of another project I am part of, ‘The Other Side of the Story: Perpetrators in Change’ (OSSPC) which is a European Commission funded project looking a capacity building in early intervention DVA perpetrator work, we have been talking a lot about the CCR model. Recently we delivered training to 80 professionals from across the South-West of England. As part of this we discussed the Istanbul Convention and the Coordinated Community Response (CCR) model. I was shocked to see that prior to the training only 46% were previously aware of the Istanbul Convention (rising to 100% post training). The CCR model is at the heart of the Istanbul Convention, and we also found that only a minority knew about the CCR. Instead work was very localised and had varying amounts of coordination, mostly through the MARAC, which means that the coordination is focused only on high risk cases which are known to services. Children are therefore falling through the gaps.

Serious youth violence/public space violence cannot be effectively dealt with unless we recognise many young people involved are child survivors of domestic abuse. At present we are failing child survivors of DVA by not offering them early and effective support. But this response from the DA Commissioner gives me real hope for change- and I am proud to be a small part of it.

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