National Ugly Mugs (UKNSWP) submission of written evidence to the APPG ‘Pop-up brothels’ Inquiry December 2017
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- This response is from National Ugly Mugs in their capacity as a national, award-winning organisation, whose mission is to end violence against sex workers.
- We find the term ‘pop-up brothels’ sensationalist, misleading and problematic in the context of policy debate.
- There is no robust evidence detailing of the operation of pop-up brothels.
- We do, however, recognise that the criminalisation of brothels in England and Wales means sex workers are left to work in a variety of ways, including using short-term lets.
- To our knowledge, there is no evidence demonstrating the number of short-term lets used for sex work, or of an increase in such use. The National Police Chiefs Council (NPCC) has claimed there has been such an increase in the media, but this claim must be investigated and properly evidenced before it can be used as the basis for policy change.
- To our knowledge, there is no robust evidence about the links between organised crime and the use of short-term lets for sex work. However, if links with organised crime were evidenced, then working with sex workers to ensure their health, safety and public protection is paramount.
- There is no data that evidences the specific type of violence and exploitation that may or may not happen in the context of short-term lets used for sex work or ‘pop up brothels’.
- However, we recognise that sex workers across sectors are vulnerable to violence; and two key factors contributing to this are their criminalised status and stigma they experience, which is in turn exacerbated by their criminalisation.
- There is no specific evidence about the impact of short-term lets used for sex work on the wider community; it is likely that they could impact in the same way as any other working premises, such as through: noise, children witnessing activity, increased volumes of traffic etc.
- However, many establishments are very discreet and academic research has evidenced the various positive outcomes of legalised brothels.
- Those who experience exploitation in the context of any type of sex work should be offered non-judgemental and holistic support from organisations and practitioners who are experienced in working with sex workers.
- Although it is important to note that organised crime does not always have a consistent or common involvement with sex work, where sex workers do experience harm in the context of organised crime, groups and individuals must be supported via specialist sex work support agencies to access public protection from the police.
- The government should consider its over-all approach to regulating sex work and consider the harm that the current quasi-criminalised system causes to sex workers.
- There is a host of evidence demonstrating that decriminalisation is the model which best supports sex workers rights and needs for health, safety and well-being.
Background: National Ugly Mugs (NUM)
National Ugly Mugs (NUM) is a pioneering, national organisation, founded by the UK Network of Sex Work Projects and initially funded by the Home Office. NUM provides greater access to justice and protection for sex workers who are often targeted by dangerous individuals but are frequently reluctant to report these incidents to the police. These offenders are often serial sexual predators who pose a serious risk.
Our Mission: Ending Violence Against Sex Workers.
What we do:We take reports of incidents committed against sex workers and produce anonymised warnings which are sent directly to sex workers and support projects throughout the UK.
With consent, we share anonymous intelligence to the police.
We support sex workers in making full reports to the police so that the perpetrators can be identified, arrested and convicted.
We ensure sex workers have access to professional services when they have been a victim of crime.
We provide expert guidance and advice to police and deliver training throughout the UK.
NUM is formally supported by the National Police Chiefs Council, the Home Office, the National Crime Agency and is represented on the National Police Working Group on Prostitution. NUM has won numerous awards including the Guardian Charity Award, the Third Sector Excellence Award for “Small Charity, Big Achiever” and the “Highly Commended Charity of the Year” Award at the Charity Times Awards.
Approximately 300 frontline support organizations are members, including the majority of specialist outreach and support projects who engage with sex workers on a weekly basis throughout the UK. Projects have vast expertise and support 20,000 sex workers annually. At the time of writing NUM has over 4200 individual sex worker members. In total, an estimated 20,000 sex workers benefit from NUM. NUM deals with approximately 60 incidents of crime against sex workers per month, regularly supports police investigations, and has prevented crime and contributed to police investigations, leading to the apprehension of a number of offenders, including serial offenders.
A 2015 survey of our membership reported that 96% of members felt safer as a direct result of NUM; 90% felt more likely to report to police; 74% said they felt less likely to be targeted by offenders and 46% have avoided specific individuals because of NUM.
We are submitting evidence to this inquiry because it is our mission to end violence against sex workers.
1 . The scale and nature of the practice
How do pop-up brothels operate?
The term ‘pop-up brothel’ is sensationalist, misleading and problematic in the context of policy debate. It was a term generated by the media. Sex workers have operated in a variety of off-street spaces over time, including short-term lets. As journalist Frankie Mullin reports: ‘working from short-term lets is common… [e]ither independently or for managers, sex workers travel for work.’ In order to find out the details of their operation we suggest that the APPG engage with sex workers. As Mullin notes, the APPG have not made any links with active sex worker groups in the context of their inquiry. We recommend that they do this in order to develop an evidence-based and clear picture of the use of short-term lets for sex work and the impact they have on sex worker safety. As Mullin states: ‘Not one member of the parliamentary group will be affected by the results of this inquiry, but thousands of sex workers will. Why, yet again, are so many being excluded?’
Who is involved in the operation of pop-up brothels?
In an article in the Times newspaper the National Police Chiefs Council stated: "We have seen an increase in the set-up of pop-up brothels across a number of force areas. While this is relatively widespread, it is still an emerging issue and does not present consistently across the country". As this issue is emerging and since there is no research or data available on the operation of so-called ‘pop-up brothels’, details of their operation cannot be known.
Brothels and indoor spaces visited by outreach projects across the UK - some of which are NUM members - often constitute groups of individuals working together for safety.
London based practitioners from NUM have noted that the closure of more permanent brothel spaces can result from the landlords being forced to evict tenants by the police as it is illegal to let premises knowing that they will be used as a brothel (Release, 2017). This leaves sex workers to operate from their own homes, the street, or in short-term lets or ‘pop-up brothels’. Thus the criminalization of sex workers, and the impact of the law on working practices, means that in some contexts sex workers will operate in more precarious ways.
On what scale are pop-up brothels operating and has there been an increase?
Off-street sex work is common across the UK, especially in towns and cities. To our knowledge, there is no quantitative data in existence that can provide an accurate account of the scale and whether there has been an increase. As noted above, the NPCC has claimed that there has been an ‘increase’; it is essential for the APPG to look carefully at the data on which this claim is based. To say there has been an increase suggests comparison with some sort of baseline figure, but to our knowledge no such figure has been made publicly available.
There is currently a tender for research out with the Home Office that should provide some clarity around this. Extant evidence of the scale of prostitution is generally of questionable reliability.
2 . Links with organised crime:
What links are there between organised crime groups and pop-up brothels?
To our knowledge, there is no robust evidence about the links between organised crime and the use of short-term lets for sex work. If links with organised crime were evidenced, however, then working with sex workers to ensure their health, safety and public protection would be of paramount importance. Arresting sex workers for operating together, and closing down the premises from which they work is counter-productive and risks pushing sex workers into more risky situations. Where sex workers come forward to assist in investigations, reassurances must be provided that they will not be criminalised/deported as a result of investigations.
3 . Associated harms and exploitation:
What is the scale and impact of sexual exploitation in pop-up brothels?
Sex workers experience violence in course of their work in multiple spaces, as has been reported and documented by sex workers and NUM. There is no data that evidences the specific type of violence and exploitation that may or may not happen in the context of short-term lets used for sex work. However, sex workers across sectors are vulnerable to violence and two key factors contributing to this are their criminalised status and the stigma they experience, which is in turn exacerbated by their criminalisation.
How do pop-up brothels impact on the wider community?
Although there is no specific evidence about the impact of pop-up brothels on the wider community, it is likely that they could impact as per any other working premise. Thus there could be an impact from potential associated behaviors for example: noise, children witnessing activity, increased volumes of traffic etc. However, many establishments are – not least because of their criminalized status - very discreet, and those involved do not want to draw attention to themselves for fear of closure, police action against individuals or being outed. In addition academic research has evidenced the various positive outcomes legalised brothels can bring to community and residential spaces, including the provision of passive surveillance, contribution to local economies, feelings of safety and security, and a good relationship with other residents.
4 . Effective responses and prevention strategies:
How can individuals exploited in pop-up brothels be best provided with help and support?
Those who experience exploitation in the context of any type of sex work should be offered non-judgemental and holistic support from organisations and practitioners who are experienced in working with sex workers.
How can organised crime networks profiting from sexual exploitation be stopped?
Although it is important to note that organised crime does not always have a consistent or common involvement with sex work; where sex workers do experience harm in the context of organised crime, groups and individuals must be supported via specialist sex work support agencies to access public protection from the police.
What, if any, action should the government take in relation to pop-up brothels?
The government should consider its over-all approach to regulating sex work and consider the harm that the current quasi-criminalised system causes to sex workers. That sex workers use short-term lets to operate reflects the fact that operating together rather than alone is criminalised. In a recent study by NUM in which over 200 sex workers and more than 50 organisations took part it was found that nearly 70% of sex workers supported full decriminalisation as a regulatory model. Only 2% of sex workers supported the Swedish model and the criminalisation of clients. 96% of sex workers and 75% of organisations said that the purchase of sex should not be criminalised.
There is a host of evidence demonstrating that decriminalisation is the model which best supports the health, safety and well-being needs of sex workers. As a model of regulation, decriminalisation is favoured by the World Health Organisation, The Lancet, and Amnesty International. The landmark 2016 Home Affairs Select Committee Report on Prostitution stated the government should consider decriminalisation as a model for England and Wales. They also took the ‘strong view’ that: (i) soliciting should not be an offence; (ii) laws should enable sex workers to share premises for safety; (iii) previous convictions or cautions for prostitution should be deleted; (iv) sanctions tackling exploitation, coercion and control should be strengthened. NUM recommends that these should be the focus of any substantive government inquiry.