Modern Slavery Toolkit

Referral Process and Safeguarding

First Responders

First Responders are responsible for identifying, interviewing, and referring victims, and keeping the Single Competent Authority (SCA) up to date with any new information after a referral.

Bexley’s First Responders include the following:

Police

  • In an emergency, always call 999
  • In a non-emergency, call 101 or visit your local police station

Adult Social Care

  • For adult concerns call the 020 8303 7777 and ask for 'Screeners' or email screeners@bexley.gov.uk

Multi-Agency Safeguarding Hub (MASH)

  • For children concerns call 020 3045 5440 or email childrensmashteam@bexley.gov.uk 

Community Safety Services

  • If unsure or for more information, call 020 8303 7777 and ask for 'Community Safety' or email community.safety@bexley.gov.uk

Modern Slavery Helpline

  • For more information or professional advice, call 0800 0121 700 or visit the Modern Slavery Helpline website - Visit wwww.modernslaveryhelpline.org

First Responders are not just form fillers; our duties include not only making a referral or notification into the NRM, but also providing support and safeguarding the potential victim. This is why a multi-agency approach is essential to build a full picture, including of the person’s vulnerabilities and needs, and obtaining additional evidence. Within this, First Responders should work with non-First Responder’s to identify concerns, share information, and take prompt action.

If you are not a First Responder, you should report any concerns to one of the above for further action.

The National Referral Mechanism (NRM)

The National Referral Mechanism (NRM) is the current process in place in the UK for victim identification and support to a potential victim (PV). This came into effect in the UK on 1st April 2009 for victims of trafficking and was extended to cover all victims of all forms of modern slavery following the Modern Slavery Act in 2015. It is also the mechanism through which the National Crime Agency collects information about victims to build a clearer picture on human trafficking and slavery in the UK. It was introduced to allow the UK to meet its obligations under the Council of European Convention on Action against Trafficking in Human Beings.

The NRM process works as follows:

Online NRM referral by First Responder for child or consenting adult

  • If no adult consent, Duty to Notify completed via online form by First Responder
  • If child, make a referral to the ICTG service
  • Notify Community Safety nrm@bexley.gov.uk

Decision-maker consider and make Reasonable Grounds Decision within 5 working days ("reasonable grounds to believe")

Positive Reasonable Grounds Decision

  • Multi-agency planning / Support commences
  • Investigation Commences / partners share new info with SCA by email to nrm@modernslavery.gov.uk

Negative Reasonable Grounds Decision

  • A reconsideration request may be made
  • A new referral may be made
     

Decision-maker investigate and make a Conclusive Grounds Decision no earlier than 30 calendar days ("on the balance of probabilities")

Positive Conclusive Grounds Decision

  • Multi-agency support Continues
  • Move on / Reach-in support
  • New referral may be made

Negative Conclusive Grounds Decision

  • MAAP review decision
  • Exit NRM within 9 days
  • Reconsideration request or new referral may be made

Post -NRM

  • A new referral may be made

Making a Referral

Whether you are making a NRM referral or a DtN, the same online form is used. A DtN will ask for redacted information, not identifying the victim.

Make a referral

While you do not need to have proof to make a referral, some objective intelligence which has led to your professional concern must be present to make a referral. You should be specific and as detailed as possible. Detail must be neutral and evidence-based, explaining only the known facts. The language used and level of evidence provided can affect the decision-making process.

There are questions on the NRM referral form which represent the key information and intelligence to be shared, and this information, if not already known, should be sought from relevant partners before making a referral to ensure that the NRM referral is effective. As further evidence comes to your attention, or if you are asked for further evidence to be provided by the decision-maker, you should submit this to the decision-making body as soon as possible and within the deadline provided.

There are slightly different referral routes, depending on whether the victim is an adult or a child. If unsure, assume they are a child.

The referral route for children

1. Notify MASH

You must notify the Multi-Agency Safeguarding Hub (MASH) (020 3045 5440). MASH will make enquiries and gather more information to understand the risk relating to the child with the guidance of Modern Slavery indicators.

If it is clear that the child may be at risk of significant harm, the MASH will immediately make a referral to the Children’s Social Care Assessment service for a Child Protection Strategy Meeting (s.47 Children’s Act 1989) to consider the need for a child protection enquiry.

2. NRM Referral

If the suspected victim already has an allocated social worker, the referral will be sent directly by the MASH to their social worker, who will be responsible for making appropriate referrals into the NRM. Otherwise, the case will be referred to the Referral and Assessment Team for consideration and NRM referral.

You should always make a referral if you suspect a child is a victim of modern slavery. Consent is not required, but the NRM should be explained to them.

View the Statutory guidance Modern slavery: how to identify and support victims on the GOV.UK website.

All referral receipts made by the Local Authority should be emailed to nrm@bexley.gov.uk for tracking, and the community safety email should be noted as a second point of contact in the NRM referral form to ensure responses are received despite any turnover of staff.

3. Independent Child Trafficking Guardians (ICTG) Referral

You also should refer the child or young person to an ICTG by completing this online referral form. This is in addition to usual safeguarding routes and NRM referrals (below) and can enable them to provide either direct support to unaccompanied minors or professional support to those with a parent/guardian.

Make a ICTG service referral

4. Information Share and Multi-Agency Safeguarding (MACE referral)

If the child is known to the local authority or another service, they should be informed of the referral to ensure they are able to contribute to the process, i.e., by providing supporting evidence.

Cases suspected to concern exploitation should always be referred to and updated at MACE, the main partnership forum to discuss and agree multi-agency actions to intervene, disrupt and safeguard that child or young person.

The referral route for adults

The referral route for adults is as follows:

1. Notify Screeners

You should notify the adult contact centre where screeners will assess and send to triage via 020 8303 7777 or screeners@bexley.gov.uk.

2. NRM Referral

You can only make a referral for an adult you suspect to be a victim of modern slavery if they consent – you should discuss the type of information they could share and the support they would receive if they did want to come forward.

View the Statutory guidance Modern slavery: how to identify and support victims on the GOV.UK website.

All referral receipts made by the Local Authority should be copied to nrm@bexley.gov.uk for tracking, and the community safety email should be noted as a second point of contact in the NRM referral form to ensure responses are received despite any turnover of staff.

3. Duty to Notify

If the adult does not consent, or if you are not able to contact the potential victim and do not know their personal details, you then have a duty to notify (DTN). This is via the same online form but with restricted personal information. All notification receipts made by the Local Authority should be copied to nrm@bexley.gov.uk for tracking, with non-identifiable information.

4. Information Share and Multi-Agency Safeguarding

Modern Slavery is a category of Safeguarding under the Care Act 2014 and therefore all information must be share in a multi-agency way to safeguard adults at risk. If the adult is known to the local authority or another service, they should be informed of the referral to ensure they are able to contribute to the process, i.e., by providing supporting evidence.

Cases can be referred to Community Risk MARAC or otherwise an ad hoc professionals meeting called to consider risk and needs of the potential victim, and to create and carry out an action plan for safeguarding.