Women in Prison. A response to the London Assembly Police and Crime Committee investigation into Women Offenders

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1 Women in Prison A response to the London Assembly Police and Crime Committee investigation into Women Offenders 20 th October 2017 About Women in Prison Founded in 1983, Women in Prison (WIP) aims to reduce the number of women in prison and prevent the damage done to women and their families by imprisonment. Women in Prison s proposals are based on experience of delivering gender-specialist support services in prison and the community for women affected by the criminal justice system. For more information see 1

2 Introduction: About Women in Prison (WIP): Women in Prison (WIP) is a women-only organisation that provides holistic genderspecialist support to women affected by the criminal justice system. We work in prisons, in the community and through the gate, supporting women leaving prison. We run three women s centres (in Manchester, Woking and Lambeth, London) including liaison and diversion schemes for women involved in the criminal justice system. Our combined services provide women with support around advocacy, complex needs, domestic and sexual violence, education, training and employment, mental health, parenting and substance misuse. We advocate for a significant reduction in prison sentences and for strengthened community support services. Our policy and campaigns work is informed by our frontline support services for women, delivered at every stage of a woman s journey through the criminal justice system. The experience and knowledge of staff working directly with women affected by the criminal justice system enable us to see first-hand how well policy is implemented in practice. About this consultation response: Our response to this consultation is concerned specifically with women involved in the criminal justice system. 2

3 Introduction We value the opportunity to contribute to this investigation into women offenders in London and we appreciate the recognition that women offenders are a distinct group that often have very specific needs in relation to preventing offending and rehabilitation. We are pleased that the Mayor s Police and Crime Plan places specific focus on women as a target group for reducing reoffending and makes commitments to divert low-risk women from the formal criminal justice processes through the pilot of a police-led triage service that will direct women into specialist support services push for additional investment to expand access to specialist women s centres develop a new Female Offender Service, which will reach 950 female offenders across London We welcome this investigation examining the provision of specialist support services for women across London, in particular the focus on women s centres and their impact on offending and reoffending, and the question whether the closure of HMP Holloway has affected the rehabilitation of London s women in prison. Women in the criminal justice system is a small cohort, making up 5% of the prison population and 15% of the probation caseload. This presents an excellent opportunity for a range of pilot schemes in tackling offending and reoffending. In Women in Prison we believe that it is possible to reduce the number of women in prison from 4,000 to 2,020 by This could be a precursor to radical reductions in the number of men in prison. We are supported by MPs across political parties, prison governors, charities and others in this ambition and it is now widely accepted that there is a crisis in our criminal justice system which makes change a necessity. The answer to reducing women s (re)offending lies in investment in community support services and housing for women as well as an investment in diversionary schemes to act as an alternative to needless and counter-productive custodial sentencing. The answer does not lie in prisons or in tweaks to the criminal justice response. The Transforming Rehabilitation (TR) reforms sought a criminal justice solution to a social and community problem that of high reoffending rates among our most vulnerable citizens. This approach has absolutely failed. This was our view from several years ago, which is one of the reasons why WIP withdrew from delivering services in the TR contracts. Now this is a view broadly accepted across independent inspectorates, local councils, prison and probation staff and charities, both in and outside the TR reforms. In the case of women, we are in the fortunate position that in London there are still quality services remaining, albeit much reduced and under strain. This response is mainly about how we build on this and ensure London is a beacon of good practice leading the way in reducing the women s prison population. 3

4 Questions: 1. What are the specific needs of women offenders in London? As a group, women prisoners have disproportionate levels of experiences of trauma, with many having experienced childhood abuse. A third of women in prison grew up in the care system. A majority of women affected by the the criminal justice system also go on to experience abuse and violence in adult relationships and a disproportionate number have experienced sexual violence and involvement in prostitution. There is a strong link between women s experiences of trauma and mental ill health, including depression, anxiety and post-traumatic stress disorder. Official figures show that 49% of women prisoners are assessed as suffering from depression and anxiety, compared to the rate of 19% in the general population 1. In one study 25% of women in prison reported symptoms indicative of psychosis, compared to the overall rate of 4% among the general public 2 and 30% of women have had a previous psychiatric admission before they entered prison 3. A large proportion of women in the criminal justice system also have personality disorders with 57% of sentenced women having a diagnosis 4. A majority of women involved in the criminal justice system are affected by substance misuse and there is a strong link between women s mental health issues and substance misuse issues. The relationship between addiction and mental health is complex with conflicting theories around whether dual diagnosis is the most appropriate response or whether substance misuse is a consequence of mental health which can be reduced when addressing the root causes of mental health issues. We know from working with women that many self-medicate using illicit substances as a coping mechanism to deal with previous and/or current trauma. This substance misuse, in turn, has a significant negative effect on reoffending, with many women committing crimes such as theft, handling, burglary or robbery to finance their addiction. Women who have committed crimes are disproportionately also victims of crime, and many women commit crimes as a result of the coercion and control they are subjected to in abusive relationships, including those involving sexual exploitation and prostitution. There are clear links between mental ill health and self-harm and suicide that apply to women affected by the criminal justice system throughout their lives. 46% of women prisoners report having attempted suicide at some point in their lives, compared to 6% of the general UK population. 5 As a group, women affected by the criminal justice system in London also face severe housing needs. The current housing crisis means a lack of housing for many people and women in the criminal justice system face a housing crisis in every possible respect: There is an inadequate supply of refuges for women fleeing domestic violence, of supported housing services for women with complex needs, of hostels for women on release from prison and of council accommodation for longer term housing needs. Women in the criminal justice system often find it impossible to access private rental accommodation for a number of reasons. For more information about housing and women in the criminal justice system, please see the briefing Home Truths produced by Prison Reform Trust in partnership with Women in Prison. 4

5 An overwhelming majority of women affected by the criminal justice system face housing issues, with housing often being a significant cause and effect of prison. An estimated 60% of women leave prison homeless and homelessness often plays a part in many women ending up back in prison. Homelessness and inappropriate housing play a fundamental role in women s (re)offending, with prison sometimes being the only housing option available to a woman, with a huge financial and human cost to society and individuals. Black, Asian and Minority Ethnic (BAME) women face particular barriers and are disproportionately affected by the criminal justice system. This has been outlined in the recent Lammy Review 6, to which WIP contributed through our report Double Disadvantage, produced in partnership with Agenda. Ministry of Justice analysis shows that black women are about 25% more likely than white women to be sentenced to custody at crown court. Disproportionate outcomes are particularly noticeable for certain offences. For every 100 white women sentenced to custody at crown courts for drug offences, for example, 227 black women received custodial sentences. 7 As outlined in the Corston report, BAME women face the same barriers in accessing services on release from prison as white women but they are further disadvantaged by racial discrimination, stigma, isolation, cultural differences, language barriers and lack of employment skills. Women in the criminal justice system hence have very complex needs and face multiple, overlapping disadvantages. They often lead chaotic lives and this lack of stability is reinforced by being caught up in a cycle of reoffending and a revolving door of short sentencing. Prison sentences uproot women who may be on a path towards greater stability and result in loss of children, homes and employment opportunities. Prison sentences also greatly exacerbate the difficulties to integrating into society due to disjointed and insufficient resettlement, rehabilitation, support services and housing provision post-release. Having been to prison is a stigma that is often carried for life, however minor the crime or short the sentence. 2. How are London s voluntary sector organisations working with women offenders, particularly those placed in prison outside London? Challenges: Closure of HMP Holloway The closure of HMP Holloway means London no longer has a women s prison. As a result, many women are now serving prison sentences further away from their families and children. While we do not advocate the use of prison for women, unfortunately the desperate lack of housing and support services in the community means that sometimes people are accessing these services while in prison. HMP Holloway provided a strong hub for services and for funding for these (including from charitable sources). The closure of HMP Holloway has thus removed support and housing in London for some of the most vulnerable women in our communities. 5

6 The closure of HMP Holloway has had a significant negative impact on support services that work with women in the criminal justice system, including ours. Women in Prison (WIP) was founded in 1983 by a former HMP Holloway prisoner and we worked in and with HMP Holloway until its closure in Throughout the many years we were in HMP Holloway, we built strong working relationships with the Community Mental Health In-reach Teams and Psychological Therapies Teams within the prison. We also got to know other voluntary sector agencies providing support services within the prison and worked alongside one another to provide the widest possible range of support for the women in HMP Holloway. We continue to work with women who resided in HMP Holloway and women who are now residing in other Southern prisons such as HMP Downview and HMP Bronzefield as well as further afield. However, Holloway s closure has had an impact on us as an organisation as we have been forced to relocate services to follow the women further away from our base, costing us much more to deliver the same service, both in travel time for staff and travel cost. This cost is significant for any small charity and many other support services that provided in-reach services in HMP Holloway were simply not able to adapt, resulting in an overall reduction of support services for women. During the period of HMP Holloway s closure there was dramatic impact on the ability to deliver services and meet targets especially due to the referral pathways which were completely destabilised by the Transforming Rehabilitation reforms. Whilst some London-based funders were supportive during this period, others did not make allowances for the serious impact of the prison s closure. We know of cases where not meeting targets agreed before the closure decision led to severe financial penalties despite the fact that the circumstances were beyond the control of any charity working in this sector. In addition to the significant financial burden, voluntary sector organisations cannot simply assume being granted access to prisons for service delivery. Prisons, by their very nature, are closed, high-security institutions, cautious about letting outside agencies in. Setting up a Service Level Agreement with a prison for service delivery is a very time-consuming and complex process and one that is subject to staff and governance decisions. As a result the services in the re-opened HMP Downview took many months to become established meaning that for a long period services were unable to deliver a full and effective service to London women in prison and those leaving. This was on top of the severe logistical challenges of serving a prison a long distance from central London. Our staff could walk to HMP Holloway from our Islington office. The change meant at least 2 trains and a bus ride and sometimes a 5 hour roundtrip to deliver a service to a single woman. It is vital that this investigation recognises that as soon as the sudden decision to close HMP Holloway was made in November 2015 a negative impact on women and on services began. The disruption in the prison and the grief of staff and women was plain to see for the duration of its transition to closure in July It is a sad reality of our system that for a small number of vulnerable women repeatedly returned to Holloway it had become a familiar place akin to a home. In practical terms, staff working in the sector became unsure of the stability of their employment. Within weeks of the announcement of closure referrals had started to slow to projects run 6

7 by charities. This has many implications but one is that it became difficult (and later impossible) to meet targets set by funders such as London Councils and others. This has had serious financial consequences for us and for other service providers in London. Funding climate for voluntary sector organisations In terms of working with women, whether placed in prisons outside of London or not, WIP and our voluntary sector partners can only deliver services we are funded to deliver. The Reserves position of the vast majority of women s and criminal justice agencies gives little room for flexibility and to carry gaps in funding. The entire voluntary sector, and particularly the women s sector, face significant funding challenges coupled with an ever-increasing need and demand on services. The result for the sector as a whole is over-stretched services and a patchy service delivery with voluntary sector organisations competing for limited funding and women facing a lack of services. Due to restricted funding criteria, many women fail eligibility criteria for support services, despite being in need of support. It is also the case that some funding and commissioning arrangements are making it even harder to deliver services. A good example of this is Payment by Results (PbR) and spot purchasing arrangements. Charities are expected to either gamble on being able to achieve specific outcomes before receiving payment or to have staff on hand just in case they are needed. The numbers of men affected by the criminal justice system means that economies of scale can help charities survive these kind of arrangements. However, the fact that women make up a group relatively small in number (albeit with highly complex needs) means economies of scale are not possible. Women in Prison have been in the position of stepping aside from work we knew we could deliver well because we were simply not able to take the risk to our Reserves that some of the new style public sector commissioning entails. We know we are not alone in this and it is happening more and more as charity trustees assess the risks to their charity s finances when such gambles do not pay off. CRCs and TR The introduction of the Community Rehabilitation Companies (CRCs) under Transforming Rehabilitation (TR) has added enormous additional strain to the funding difficulties of the women s sector serving women in the criminal justice system. Voluntary sector agencies compete with CRCs for funding and there are many misperceptions about the remit of CRCs and inaccurate assumptions about the level of support that CRCs are able to provide. The support offered by the CRC in custody is limited to 12 weeks pre-release. This inevitably leaves women on longer sentences with little support during their sentence, meaning a lost opportunity to address issues over the long term in preparation for release. Despite the limited remit of the CRC, in many cases prisons provide no additional support services to women outside of the 12 weeks leading up to release. For example, the availability of Domestic Violence (DV) support service provision in women s prisons is very limited, despite being a key factor in women s offending. The same is true of housing support. 7

8 The reality of the Payment by Results (PbR) element of TR is a sector forced to focus on meeting contract targets rather than undertaking in-depth work responding to real need. The result is a culture of CRCs merely sign-posting clients, often to services that in turn replicate this sign-posting, with no services left to do the actual work that is needed and women pushed between services. Often organisations trying to deliver services under PbR are financially penalised for not meeting targets, even where these are beyond their control due to systemic issues such as a shortage of housing or other agencies not able to deliver their part in the system. We appreciate that between 2015 and 2017 MOPAC has been working closely with the CRC in relation to delivery of services for women offenders. Given how the TR reforms have unfolded, it is vital now that in London we look beyond the CRC and the criminal justice system to the answers to the crisis facing women affected by the criminal justice system. Opportunities: Women s centres Due to the multiple and complex needs faced by women in the criminal justice system, women tend to require support around various issues such as benefits and debt, housing, domestic violence, parenting, substance misuse or health. Women may also need encouragement to attend appointments or advocacy in professionals meetings. In addition to practical advice and support, many women benefit from emotional support and the simple knowledge that there is a professional available to them if they need to reach out for help. One-stop-shop women s centres are able to provide such holistic services to women in a women-only, safe environment. WIP runs three such women s centres, including the Beth Centre in Lambeth, and we strongly urge that this model is extended across London. However, it is vital that funding for any such support services is increased, made long-term and stable as otherwise increased expectations cannot be met by women s centres and other voluntary support services who are already struggling to meet demand from service users. Each women's centre is different and tailored to suit local needs, but women's centres can be used as important resources for court and police diversion schemes, as part of a package of measures for community sentences and for the delivery of probation and other programmes. There have been some positive developments in recent years, with women s centres being used for liaison and diversion schemes. Examples of these include schemes run by Women in Prison in partnership with other criminal justice agencies in Surrey, Lambeth and Manchester. Women s centres also focus on early intervention and other forms of diversion from custody. Another type of services women s centres can provide is early intervention for women at risk of offending including younger women and those at risk of sexual exploitation. The most fundamental way the Mayor can work with the women s sector to increase the resilience of women s centres is through direct sustainable funding (as opposed 8

9 to funding routed through the CRC or other contract managing organisations). Ringfenced, long-term, stable and adequate funding for women s centres is crucial if women s centres are to not only survive, but become serious solutions to the criminal justice and social crisis of those with complex needs caught in a cycle of reoffending. This should not be seen as an additional cost but as an investment that will have significant benefits for public safety, life chances and investment in human capital. It should also be seen as a cost-effective way of managing public spending as government commissioned analysis has confirmed through Justice Data Lab data on women s centres 8. Women s centre services differ depending on sources and levels of funding and location but all share the ability to provide services that are significantly less costly than prison and more effective. A women s centre in a London Borough can be run on an annual budget of 300, ,000. This enables support at that centre for between women per year. The average annual cost for services at such a centre thus equates to approximately 1,000 per woman, compared to 42,766 per woman in prison. 9 But the cost of providing in depth services to meet needs in a sustainable way is much more than this and there needs to be a clear understanding by commissioners of how women s centres bring in services to supplement their basic offer. We find that frequently there is an unrealistic expectation of what charities can provide for particular sums of money. Commissioners need to understand that this area involves high pressure skilled work and need to allow for sufficient clinical supervision for staff and the reality of sickness levels in the sector. The fact is that the vast majority of charities in the criminal sector have no room for flexibility in carrying services and have depleting reserves (approximately 1.7 months reserves on average remaining according to a recent research report by Clinks). 3. Which parts of London are currently lacking specialist support services, such as women s centres? There are a number of organisations providing support pan-london, across a range of different support areas and support is offered through outreach work, drop-in services or floating support. However, not only is there a far greater demand than supply for support services across the board but not all services are genderspecialist or criminal justice-specialist. For example, mental health services for women tend to be aimed at new mothers suffering from post-natal depression rather than women suffering from any other mental health condition 10 and most criminal justice specialist support tends to be offered to both men and women, resulting in women s unique issues being ignored. Women s centres provide excellent services where they exist and have a proven impact on reoffending rates 11 but there is still far too little provision across London, with many women unable to access services in their local area. Local services are often restricted in funding criteria to work only with those having a local connection, resulting in a postcode lottery. There are currently only two women s centres in London delivering holistic services to women affected by the criminal justice system 9

10 according to the one-stop-shop model advocated by Baroness Corston: the Beth Centre in Lambeth and Advance Minerva in Hammersmith. Many London boroughs have services that offer gender-specific tailored support to women from specific cultural backgrounds or support focused on specific areas such as FGM or counselling. Some of these services are referred to as women s centres. However, though these services provide excellent and much need support there is still a need for a proliferation of the holistic women s centres outlined above. Across the board, funding is unstable and services do not form part of a cohesive network but tend to be stand-alone. This is something MOPAC can address directly and with immediate effect. 4. What impact could MOPAC s new Female Offender Service have on women s offending and reoffending? We understand that the new Female Offender Service, funded by the Mayor s Office for Policing And Crime (MOPAC) and the London Community Rehabilitation Company (London CRC), plans to expand and improve current services and bring different agencies together to tackle women s reoffending across the capital, building on the work of the Minerva project which works with women who are either leaving custody or serving their sentence in the community. We understand the new service plans to reach 950 female offenders across London with MOPAC s funding enhancing support services in 10 London boroughs, including specialist care in the areas of domestic and sexual abuse, trauma counselling, employment support, parenting and housing. We support any move to expand services, based on previous models of successful service delivery. However, we are concerned about the way that resources have flowed direct to the CRC and we do not believe this has resulted in building on the strengths across the women s sector in London. This is an opportunity to ensure funding is directed most effectively across the women s sector. We work closely with CRCs and the National Probation Service across London, including in the Beth Centre. The same is true in our centres in Woking and Manchester. Our experience shows that provision is strongest when CRC/Probation are a partner in service delivery rather than a route to funding; CRCs have enough of a challenge meeting their contractual requirements to HMPPS without being required to deliver on a broader set of outcomes including prevention and engagement of women on diversion schemes. Below are a few points of particular importance that we would like to see given consideration as commissioning arrangements are decided for the future. Early intervention - girls and women at risk of offending We would advise that support to women in the criminal justice system is, as much as possible, free of restrictions and open to all women who might benefit. One problem with the CRC model of delivery is that services are only available to women serving, 10

11 or having served, a custodial sentence. Unfortunately this excludes all girls and women at risk of offending for whom early intervention would be beneficial. Early intervention is key, not just to divert women when they first come into contact with the criminal justice system but also to prevent women from entering the criminal justice system in the first place. The majority of women s offending is related to lived experiences of poverty, insecure housing, mental ill health, abuse (domestic, sexual and child abuse) and addiction. Community support for disadvantaged girls, young women and women are therefore crucial in order to prevent a slippage into the criminal justice system, especially as once entered it is very difficult to get out. Women s centres can and do provide this support, but only where funded to do so. Current service provision under TR is aimed exclusively at Post Sentence Supervision (PSS), meaning that providers under these contracts are not funded to work with all women on community orders or at risk of offending. This is a missed opportunity to reach an at-risk group at a crucial time that could be addressed nationally by women s centres with adequate funding. But this funding needs to be separate to and complimentary of that provided to CRCs under TR. Where services are stronger there are established whole system responses led by women s services and with strong support (including with funding) from Local Authorities, Police forces and PCCs. CRCs are a partner in this, but with a similar role to that of the other statutory services. Given all the problems with CRCs outlined above, it is vital that MOPAC directly funds women s centres and other services that are not part of the CRC as the CRC model cannot, by its very nature, reach all women who might benefit from support. Diversion and out of court disposals In recent years, there have been several examples of problem-solving justice initiatives for women such as police-based triage, Integrated Offender Management (IOM), restorative justice and liaison and diversion schemes. We strongly recommend these are extended across London and become the norm for women in contact with the criminal justice system. There have been some very positive developments in recent years, with women s centres being used for liaison and diversion schemes. Examples of these include schemes run by Women in Prison in partnership with other criminal justice agencies in Surrey, Lambeth and Manchester. We would recommend that the Mayor looks to the number of past and existing successful pilot schemes in order to determine how to best roll out and extend these schemes. One such example is the Beth Centre in Lambeth which has recently run a successful pilot scheme 12. A focus on diversion needs to be a crucial part of MOPAC s new Female Offender Service. However, a crucial point here is that for problem-solving justice interventions such as diversionary schemes to work, women not only need to be diverted away from custody but also need diverting toward support in the community. More investment in and funding for women s centres and other services is therefore vital if diversion and other community options are to become serious criminal and social justice solutions. 11

12 Mental Health Diversion A greater focus on mental health support for women is also needed in order to reduce reoffending for women. Such diversion from custody into community mental health support for the majority of women with mental health needs is in line with Lord Bradley s recommendations 13. There are several examples of mental health liaison and diversion schemes being successfully rolled out across the country that can be built on. One example is the work undertaken by Together for Mental Health and their work in courts, which includes gender-specific work with women. Housing As outlined above, it is absolutely vital that women have access to appropriate housing due to the strong correlation between homelessness and offending. Given the current housing crisis, it is sadly not sufficient to simply increase funding for housing advice and support services but the actual availability of housing stock itself also needs to also increase. The housing situation in London is increasingly dire and has been getting steadily worse over the last ten years, with many women knowing they will be released to street homelessness, prostitution or domestic abuse. Homelessness is a major driver of women s offending as well as a devastating consequence of imprisonment. The link between homelessness and offending has, to date, not been given sufficient attention by policy makers who often look at the two issues in isolation. However, without an increase in available housing for vulnerable women involved in the criminal justice system, no amount of housing support from voluntary sector organisations can help solve the problem of women ending up in the criminal justice system as a direct result of lack of housing. Housing is a major barrier to desistance for women and needs to be a cornerstone of any criminal justice strategy. Provision of housing is an extremely important factor in preventing offending for women. Many women affected by the criminal justice system lead chaotic lives and do not have a home to go back to on release from prison or can end up in prison partially as a result of a lack of housing. Likewise, many women caught up in the criminal justice system lack support networks. In the event of homelessness, many women with substance misuse issues (and often associated mental health issues) are forced to stay with peers involved in substance misuse, hence seriously running the risk of relapsing if they have previously been detoxed. Some women have to choose between the least bad option, which may involve facing a choice between sexual exploitation and street homelessness. Similarly, many women who are in abusive relationships face choosing between homelessness and staying with abusive partners. Lack of appropriate housing therefore has a tragic direct effect on women s mental health. Given the above, safe and suitable housing is also a fundamental prerequisite for the success of community sentencing. 12

13 As an organisation we recognise that local councils are under immense pressure to provide housing for vulnerable people due to a lack of housing stock. Individual housing officers working for housing departments within local councils are sometimes simply unable to provide the housing needed for applicants on a day-today basis and are not personally responsible for the lack of provision within their boroughs. There is no doubt that national housing policy has to change in order to provide the social housing that is desperately needed in order for councils to carry out their duties. There can be no improvement to today s dire housing situation without a significant increase in housing allocation. This has to be a conscious national decision that will have to filter down to local councils in the form of increased housing stock. In London it requires innovation and focusing attention to existing initiatives (some of which are listed below). Not only do councils struggle to provide long-term, stable housing for those in need but the lack of long-term social housing also has a knock-on effect on temporary accommodation. Due to the lack of move-on accommodation, many people are stuck in short-term temporary accommodation for long periods of time, often years. This is clearly not a suitable solution for these particular tenants and is a cause of depression and other mental health issues. It also means that there is a strain on temporary accommodation for others in desperate need of emergency accommodation who are instantly turned away at the point of enquiry and hence forced to remain in a state of crisis. Women affected by the criminal justice system are relying on supported housing more than ever. Many women are incredibly vulnerable and need support but are still not deemed vulnerable enough by their local council to be eligible for housing. Supported housing provides a housing option for these women and it is vital that this provision is extended. We would urge the Mayor to cement statutory duties for women with complex needs in the criminal justice system and ensure supported housing provision and funding is extended for this group. This could be linked to provision for those leaving other state institutions such as the care system so that as well as permanent housing solutions there are stepped supported housing solutions on offer. There are several excellent supported housing providers in London on which increased support housing can be modelled. Reunite is an example of a supported housing project run by Commonweal, Housing for Women and Women s Breakout that focuses on the needs of women leaving prison who cannot not be reunited with their children until they have a home but cannot access appropriate housing until they have their children in their care 14. For women with substance misuse issues, Treasures 15 provides an opportunity for women to resettle on release from prison. We also believe that housing advocacy support can make a huge difference to women leaving prison to access provision that is available. We have many examples where tenacious and knowledgeable advocates have done this. We did have an excellent London Councils funded project running to do this until March Sadly the project was not re-funded by London Councils and an application to the Treasury Tampon Tax was also unsuccessful. This was yet another casualty of HMP Holloway s closure and of the TR reforms. There are still many who believe that 13

14 CRCs are responsible for housing for women leaving prison, and that funding specialist support such as we provided could end up subsidising private sector profits. This one example is an illustration of the desperate need for systems change in London so that we can begin to fill these gaps including accessing central government resources and money from independent Trusts and Foundations. HMP Holloway site We form part of the network of community organisations calling for the Mayor of London to buy the Holloway prison site to protect it for affordable homes and community facilities. We feel this site presents an excellent opportunity for the Mayor to implement his recently launched draft housing strategy, with 250m earmarked for the purchase of land specifically for affordable homes. Not only would this have deep and lasting impact on the lives of Islington residents but it would also have broader implications for public policy in setting a benchmark for the disposal of prison sites and public land in London and across the country. We also call for the establishment of a women s building on the site of HMP Holloway to provide a hub of support services to women, including women affected by the criminal justice system. We recently undertook a consultation exercise with women affected by the criminal justice system, many of whom had resided in HMP Holloway. As well as consulting women about how the closure of the prison affected them, we asked for their vision and ideas for the future development of the site. An overwhelming majority of respondents cited housing as their main priority for site development, whether council housing, supported housing or domestic violence refuge provision. The respondents would also like to see a women s building and/or centre with associated support services around mental health and domestic violence. Our consultation exercise with our service users echoes a larger survey undertaken by Community Plan for Holloway which also reached out to local residents and community organisations 16. Our vision for the Holloway site is supported by Islington Council whose draft Supplementary Planning Document outlines a number of objectives for the site, including 50% affordable homes and a women s building. Further Information This consultation response was prepared by Sofia Gullberg, Policy and Information Coordinator at Women in Prison. For further information please contact sofia@womeninprison.org.uk Women in Prison Ltd. 14

15 2 nd Floor, Elmfield House, 5 Stockwell Mews, London, SW9 9GX t: Charity number: Company number: Ministry of Justice (2013) Gender differences in substance misuse and mental health amongst prisoners, London: Ministry of Justice 2 Ministry of Justice (2013) Gender differences in substance misuse and mental health amongst prisoners, London: Ministry of Justice ibid The Lammy Review: An independent review into the treatment of, and outcomes for, Black, Asian and Minority Ethnic individuals in the Criminal Justice System, Ministry of Justice, Black, Asian and Minority Ethnic disproportionality in the Criminal Justice System in England and Wales, ality-in-the-cjs.pdf 8 Ministry of Justice, Justice Data Lab Re-offending analysis: Women s Centres throughout England, Ministry of Justice, Cost per place and cost per prisoner by individual prison, NOMS annual report and accounts , management information addendum 10 See Holly, J. (2017). Mapping the Maze: Services for women experiencing multiple disadvantage in England and Wales. London: Agenda & AVA 11 Ministry of Justice (2015) Justice Data Lab Re-offending Analysis: Women s Centres throughout England 12 See Metropolitan Police Total Policing Women s Diversionary Project Review May The Bradley Report (2009) Lord Bradley s review of people with mental health problems or learning disabilities in the criminal justice system

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