Appendix 1a
ALG Response to the
Consultation on the second London Domestic Violence
Strategy
Introduction
1. The Association of London Government (ALG) represents all 32
London boroughs, the Corporation of London, the Metropolitan
Police Authority and the London Fire & Emergency Planning
Authority.
The ALG lobbies for proper resources for the
capital, leads the debate on key issues affecting London, runs
a range of services designed to make life better for
Londoners, and helps its 33 member councils provide the best
possible services in their own areas.
2. Through both the services that they provide and their
leadership role in crime reduction boroughs have a major role
to play in tackling domestic violence, particularly at a local
level. The ALG works with the boroughs to develop and improve
services to those affected by domestic violence and to
integrate domestic violence into their crime and disorder
strategies. On behalf of the boroughs, the ALG funds a number
of voluntary organisations providing services and
interventions relating to domestic violence through the ALG
grants programme. These projects include refuges, advocacy
services and a London-wide school’s domestic violence
prevention project.
3. The ALG has contributed to the delivery of the first strategy
and looks forward to continuing to work with the boroughs, GLA
and other partners on improving responses to domestic violence
through the second strategy. The ALG’s response to the
consultation on the second London Domestic Violence Strategy
(LDVS2) is set out below, following the structure set out in
the consultation document.
The response is based on
discussions with boroughs at both officer and elected member
levels.
The Strategy Framework
Consultation question: Do you agree with these priority areas for
service development and improvement? Are there any significant
gaps? Is your agency able to fulfill its role in these plans?
Aims
4. The ALG supports the proposal to retain the four aims of the
original LDVS in the second strategy, namely: increasing
safety, holding abusers accountable, reducing social tolerance
and educating children and young people. However, the ALG
would like to see a fifth aim added which focuses on
‘supporting women and children to rebuild their lives after
domestic violence’. Domestic violence has devastating
consequences for women and children affected by it. It can be
profoundly traumatic, affecting the mental and physical health
of those being abused and can lead to drug/alcohol
dependence1. Many of these effects persist after the end of
the violent relationship and the four proposed aims do not
adequately reflect the need to support women and children to
recover from the trauma that they have experienced.
Key Priorities – service provision
5. The ALG supports the priorities for service provision but in
line with our request for a fifth aim, believes that support
to recover from the consequences of domestic violence needs to
be integrated into most of these priorities. For example
improving the health sector’s response to domestic violence
should include improving access to counselling and therapy for
those affected by domestic violence and integrating domestic
violence screening into the provision of mental health
services. Services such as counselling and therapy can help
individuals to address the emotional impact of domestic
violence and thereby enable them to make personal decisions
which can allow them to move on with their lives. The ALG
welcomes the reference to the Department of Health’s Violence
and Abuse programme within the strategy.
6. The ALG believes that it is essential that the GLA consult
with the boroughs, ALG and other stakeholders on the most
appropriate models for implementation of the key services
detailed in the strategy, such as independent domestic
violence advocacy services, to ensure the best use of
resources and provision of accessible, sustainable, high
quality services across London. For example the proposed
independent advocacy services could be delivered by 33
independently managed services but the potential of a panLondon and/or sub-regional approach to the management of
locally based advocates should also be explored. Whether
managed on a pan-London, sub-regional or local basis, it is
essential that the advocacy services develop strong links with
local authorities and with partner agencies in each borough
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Women and Equality Unit, DTI, The Cost of Domestic Violence, 2004
2
and that advocates are available and accessible to those who
need them wherever they live in London. It is also essential
that the GLA identify adequate resources for developing
advocacy services.
7. The ALG welcomes the increased focus on development of
services in the health sector.
8. The ALG would welcome clarification of all the components
expected in the suggested Sanctuary Schemes to enable women
to stay safely in their own homes, as a number of different
models have been implemented across London.
9. The ALG supports further work to improve accessibility to and
appropriateness of services for abused women with a range of
additional needs, and the proposed research to support this
development. However the ALG would like this work extended to
include young people who are experiencing domestic violence
within their own relationships. According to the British Crime
Survey, 7.2% of 16-19 year old women had experienced domestic
violence in the previous year with only 20-24 year olds being
more at risk.2 The ALG believes that it is important that
services are available to this particular group. Work on
developing services for young women should include the
potential role of partner rape as a cause of teenage
pregnancy.
10. The ALG believes that both the voluntary and statutory sectors
should be involved in work to deliver relevant services for
women with additional needs.
11. The ALG recognises the value of services such as that provided
by LB Sutton for children exposed to domestic violence. The
ALG will work with boroughs on approaches to better
identification of children affected by domestic violence and
on potential models for delivering improved services to such
children.
12. The ALG supports increased interventions with domestic
violence perpetrators but is concerned that any interventions
outside of the criminal justice system should not be an
alternative to prosecution. Instead they should be a route to
services for those not being picked up through the criminal
justice system.
Home Office, Domestic Violence, Sexual Assault and Stalking: Findings from
the British Crime Survey, March 2004
2
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13. The ALG supports the proposal to increase public awareness and
understanding of domestic violence. The ALG welcomes the
acknowledgement of the success of the Westminster domestic
violence forum led work on integrating domestic violence
prevention into schools across London, which is funded by the
ALG. The ALG will consider how it can best support further
work in schools and with children who have experienced or
witnessed domestic violence.
Key priorities- process and structural issues
14. Although the ALG supports a number of these proposals, it is
concerned by others. The ALG believes that the process and
structural issues require further development in consultation
with other agencies across London.
15. The ALG welcomes the proposal to improve service user
involvement.
16. The ALG supports the development of standardised domestic
violence protocols and guidance but is concerned by the lack
of clarity in relation to which agency is supposed to lead on
specific actions. The reference to ‘we’ in this section of the
strategy needs to identify specifically which agencies would
develop which protocols. The ALG, in conjunction with the
London Child Protection Committee (LCPC), is already leading
on work to develop risk assessment tools for social workers
and believes that the ALG and LCPC should remain the lead
agencies within this work.
17. The ALG is concerned that the proposal for “every borough” to
adopt a ‘core’ version of domestic violence protocols is
confusing, implying that such protocols are only for local
authorities. Local authorities are only part of the response
to domestic violence and the strategy needs to be clear about
when it is referring specifically to the local authority, and
when it is referring to a wider set of agencies operating
within the geographical area of a borough’s boundaries. The
ALG suggests that it should be for every agency to adopt the
‘core’ version, not just local authorities.
18. Local authorities need to be properly involved in the
development of any guidance and protocols relating to their
areas of responsibility with adequate time for consultation
before guidance is finalised.
19. The ALG does not support the proposals for monitoring and
compliance. The ALG believes that there should be a greater
emphasis on the impact of the second strategy focusing on
outcomes rather than processes. Although the review of the
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first strategy highlights a number of strengths, it is not
clear about to what degree the four aims have been achieved:
 are women and children safer than they were four years ago?
 are perpetrators held accountable for their behaviour and
less likely to re-offend?
 has social tolerance of domestic violence been reduced?
 are the next generation less likely to use domestic violence
to impose power and control in intimate relationships?
20. The ALG believes that, in consultation with other partners,
the Mayor should set key outcomes for the second strategy such
as fewer domestic violence related deaths and serious
injuries; an increase in the number of women able to stay
safely in their own home; an increase in the proportion of
arrests, prosecutions and convictions; a greater understanding
of domestic violence among young people; improved
health/mental health of survivors. The ALG funds voluntary
organisations on the basis of outcomes and would be willing to
assist in the development of potential outcomes and associated
indicators.
21. The ALG is concerned at the proposal to conduct annual audits
of local Crime and Disorder Reduction Partnerships (CDRPs) and
seeks clarification of which agency would conduct such audits
as it is unclear from the ‘we’ referred to in the Strategy.
There is a need to simplify targets and management of the
CDRPs not further complicate them. The audit would create an
additional burden for local authorities and their CDRP
partners. The Government Office for London (GOL) already
audits the performance of CDRPs. We believe it would be more
appropriate for Government Office for London (GOL) to
integrate a greater focus on domestic violence within their
existing processes with CDRPs rather than have an additional,
potentially duplicating, process added on. In order to make
this effective, we believe that there is a need to include GOL
as one of the key agencies involved in delivering the key aims
of the second London Domestic Violence Strategy. The ALG also
believes that the levels proposed within the audit are overlymechanistic and are not supported by a clear evidence base and
would support a focus on outcomes instead.
22. The ALG welcomes the proposal to develop a domestic violence
resource centre but would like further details on:
 How the centre will be resourced;
 How it will be accountable to the range of agencies it
serves and to survivors of domestic violence;
 How it will be accessed;
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
What form it will take.
23. With regards to high quality domestic violence training, the
ALG would like this to incorporate training on the strong
links between domestic violence and child protection. There is
a need for both single agency and multi-agency training. The
ALG would welcome further information on the development of a
pan-London domestic violence training unit and how this would
identify and meet the training needs of different agencies and
relate to existing training programmes, such as on child
protection.
24. The ALG notes the absence of a link in the Strategy with the
London Crime Reduction Delivery Board. In particular the ALG
believes that a structural relationship between the London
Domestic Violence Forum Steering Group and the London Crime
Reduction Delivery Board is essential to ensure that domestic
violence issues are prioritised within the overall crime
reduction response in London.
Implementation
Consultation question:
implementation?
Do you agree with the mechanisms for
25. The ALG supports the restructuring of the London Domestic
Violence Forum and the creation of a steering group. The ALG
would welcome the opportunity to contribute to the Steering
Group. As mentioned above (paragraph 24), the ALG believes it
is essential that there is a structural link between the
Steering Group and the London Crime Reduction Delivery Board.
26. The ALG welcomes the proposal to incorporate the work of
Project Umbra – one of the key MPS programmes to tackle
domestic violence in London – into the Strategy. However, we
would welcome further information on the relationship between
the Project Umbra Board and the Steering Group and how panLondon work will link with local domestic violence
initiatives.
27. The ALG would welcome further information on how the Mayor
will oversee the day-to-day progress on the strategy. The ALG
believes that the strategy also needs to set out clearly the
relationship between the Greater London Authority and the
Greater London Domestic Violence Project (GLDVP) and the
Steering Group. Specifically, the ALG would like further
information on how the London Domestic Violence Forum Steering
Group members will contribute to the monitoring and evaluation
of GLDVP in delivering the strategy.
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28. A number of the lobbying issues suggested in the strategy,
such as the common assessment framework and resources to
address domestic violence are of interest to the boroughs and
ALG. The ALG would welcome the opportunity to undertake joint
lobbying with the Mayor. The ALG would welcome the Mayor’s
support for the replacement of ‘allowing a child to witness
domestic violence’ with ‘perpetrating violence in the presence
of a child’ as a risk indicator in the Common Assessment
Framework guidance.
29. As mentioned above, the Strategy refers on a number of
occasions to ‘we’ but it is often not clear who the ‘we’
refers to. For the sake of transparency and accountability the
ALG believes that the strategy should be clear about which
agencies are responsible for which actions. The Strategy also
refers to ‘boroughs’ on a number of occasions in a context
which appears to apply to a range of agencies within a borough
boundary rather than the local authority. The ALG believes it
is essential that there is clarity within the strategy about
when the term ‘borough’ refers to the local authority and when
it refers to a wider range of agencies within borough
boundaries.
Assessment Framework
Consultation question: Do you agree with this assessment
framework?
Are there any gaps?
30. The ALG welcomes the simplified minimum standards for all
agencies but believes that a greater focus on outcomes should
be introduced. For example, one standard specifies that
domestic violence information should be provided in at least
three languages. In a number of boroughs there are many
different first languages spoken and the choice of three
community languages seems arbitrary. There are varying levels
of literacy in different communities, particularly for women,
and providing translated leaflets is a ‘tick box’ approach
that does not guarantee improved access. There needs to be
flexibility about how to make services accessible to
communities whose first language is not English. The standard
could be framed in terms of ensuring that services are
available to those whose first language is not English or who
have visual disabilities. A range of possible actions to
achieve this access could be suggested such as translated
leaflets but also outreach and community-language based
services, language line back-up etc. Focussing on the outcome
of improved access would allow agencies flexibility to tailor
their responses.
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31. As mentioned above (paragraph 21), the ALG is opposed to the
introduction of an additional auditing process for CDRPs.
CDRPs are currently subject to a performance management
framework by the Government Office for London; the proposal
for the second London Domestic Violence Strategy to create
another set of targets for local CDRPs may lead to duplication
and in our view, fails to meet the current demands to simplify
targets and management of the CDRPs. As mentioned above, the
ALG also believes that the levels proposed within the audit
are overly-mechanistic and are not supported by a clear
evidence base and would support a focus on outcomes instead.
32. As mentioned previously (paragraphs 19-20), the ALG believes
that the assessment framework should include ‘high-level’
indicators for measuring the success of the second Strategy.
This was absent from the first Strategy and it is not clear to
what degree its four aims have been achieved. The ALG would
like to see a range of outcomes which would enable the impact
of the second Strategy to be measured over time against the
key aims set for it. The ALG funds the voluntary sector on the
basis of outcomes and would be willing to work with the GLA on
developing potential outcomes but believes that these should
only be finalised after consultation with other agencies.
The Strategy Recommendations
33. The ALG welcomes the use of the existing BVPI 225 on domestic
violence as the basis of recommendations for local
authorities. However, the issue of working with other
providers, particularly with regards to housing provision,
needs to be reflected in how these indicators are met. The
ALG also supports the additional criteria which many local
authorities are already working to implement.
34. The recommendations outlined for the ALG are welcome but the
ALG would like to modify two of them as set out below:
 Ensure issues arising from the Domestic Violence Coordinators
Network meetings, facilitated by the ALG, are raised with
borough Community Safety Managers.
 Consult on the development and support of domestic violence
services, including pan-London domestic violence education
initiatives, within the consultation process on future
funding priorities within the ALG grants programme.
35. The ALG believes that the GLDVP’s proposed work on integrating
domestic violence into children’s trusts and extended schools
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would be more effectively carried in partnership with the ALG
and GOL who have already established relationships with the
lead members and officers developing children’s services. We
would therefore an additional recommendation for the ALG to be
included:
 Work in partnership with the GLDVP, GOL and Children’s
Trusts to integrate domestic violence into Children’s
Trusts, extended schools and the work of the Directors of
Children’s Services.
36. The recommendation for GLDVP relating to this area of work
should be modified to reflect this proposal.
Association of London Government
October 2005
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