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A letter to the PSNI and The Department of Justice for Northern Ireland

Chief Constable Matt Baggottdownload (1)
Police Service of Northern Ireland
Police Headquarters
65 Knock Road


CC The Department of Justice for Northern Ireland

17 February 2014

Policing of Indoor Adult Sex Work in Northern Ireland

Dear Mr Baggott,

We are writing to you regards the policing of indoor adult sex work in Northern Ireland.

Sex work has traditionally been a low priority for UK police forces, especially so in regions like Northern Ireland, where there is little if any outdoor sex work taking place, rather almost all sex work is indoor sex work, carried on discreetly, away from public view.

However in recent years there has been an extremely high level of public concern about sex trafficking into prostitution in Northern Ireland and this has led to increased police attention on indoor sex work.

The PSNI’s recent submission to the Justice Committee examining the Human Trafficking and Exploitation (Further Provisions and Support for Victims) Bill acknowledged that the majority of persons selling sex are independent and not trafficked or controlled by organised crime groups. We agree with this assessment.

With regard to persons being trafficked into or exploited in sex work, to quote UNAIDS Guidance Note on HIV and Sex Work (2012), which we believe applies well to the current Northern Irish situation, “Sex workers themselves are often best placed to know who is being trafficked into commercial sex and by whom, and are particularly motivated to work to stop such odious practices.” We’d like to see sex workers more included in anti-trafficking efforts. Currently, whilst major resources are being directed at anti-trafficking work, and there are campaigns to include a wide range of people in this work, sex workers are largely being overlooked here. We believe sex workers could greatly assist the PSNI in combatting sex trafficking into prostitution.

At present, not all sex workers feel able to engage with police, many have valid concerns about doing so. But we believe the PSNI could create an environment where sex workers don’t have to fear engaging with police.

We are also concerned that the current anti-trafficking agenda is increasing discrimination against sex workers, and putting sex workers, who are already at risk of violence and abuse, at even greater risk.

We would like the PSNI to adopt a new strategy for policing indoor sex work, which encompasses prioritising sex worker safety and building good relations with the sex work community, so as together we can work against trafficking and exploitation, sex workers can conduct their work as safely as possible, and abusive persons who pose a risk to sex workers and the wider community can be more effectively dealt with.

Our recommendations for improved and consistent policing of indoor sex work in Northern Ireland are attached with this letter as Proposed PSNI Indoor Adult Sex Work Policing Guidelines.

We would appreciate it if the PSNI would consider our recommendations in regard to the policing of indoor adult sex work in Northern Ireland. We note that the 2011 Department of Justice, Research paper investigating the issues for women in Northern Ireland involved in prostitution and exploring best practice elsewhere, stated that at that time the PSNI were developing policies to ensure a consistent police response to prostitution and human trafficking in Northern Ireland, but we are unsure of the status of this work and the content of any existing PSNI policies on sex work and sex trafficking.

Yours sincerely,

Lucy Smith, UglyMugs.ie (Safe IQ Ltd.)
Laura Lee, International Union of Sex Workers (IUSW)

These proposals were drawn up in consultation with sex workers who are resident in Northern Ireland or regularly visit Northern Ireland, several of whom wish to co-sign this letter: Kate, Amy, Kelly, Sophie, Alyssa, Stella, Ms Smith, Ana and Rachel.

The proposals are also supported by:
Nine (Former UK sex work project worker)
Ruth Jacobs, Writer, Broadcaster & Campaigner
Wendy Lyon, Feminist Ire

Proposed PSNI Indoor Adult Sex Work Policing Guidelines

In these recommendations we frequently cite the latest Home Office and Association of Chief Police Officers of England, Wales and Northern Ireland (ACPO) good practice guidelines. These are contained in the Home Office’s A Review of Effective Practice in Responding to Prostitution (2011) and ACPO’s ACPO Strategy & Supporting Operational Guidance for Policing Prostitution and Sexual Exploitation (2011).

Prioritise Sex Worker Safety

Police forces have considerable discretion in deciding when and how to enforce laws. Home Office guidance is clear, police forces should recognise that persons involved in prostitution are vulnerable to harm, and take this into account when determining how they apply prostitution legislation. The Home Office is also clear, “The police’s responsibility for public protection means that stopping attacks on those involved in prostitution, and catching and convicting those responsible, is a core part of reducing harm from prostitution.” We would like the PSNI to make the safety of people selling sex a priority in sex work policing.

Public Message on Crime Against Sex Workers

We recommend the PSNI send out a strong public message that crimes against sex workers will not be tolerated. Currently some offenders target sex workers, because they believe there will not be consequences to their offending if the victim is a sex worker. In recent years it has increasingly become the case that such beliefs are held, due to the framing in the media of all sex work as rape, and of sex workers as persons who have no choices or rights or capacity to consent. A clear message from the PSNI that crimes against sex workers are unacceptable and will be treated extremely seriously would discourage crime against sex workers. Without this message offenders are more likely to think they can get away with crimes against sex workers, leading to further targeting of sex workers. Sending out this message reduces the risk of sex workers being the victims of crime. This message would also assure sex workers that the PSNI do take crimes against them seriously, which helps encouraging reporting of crime by sex worker victims.

Taking Crime Against Sex Workers Seriously / Hate Crime

Since September 2009 UglyMugs.ie has recorded 472 Northern Irish incidents, 173 of which would be crimes. This breaks down as 79 threatening or abusive communications, 62 incidents of in-person threatening or abusive behaviour, 15 of assault, 9 of sexual assault, 17 of robbery, 6 of impersonating police, 3 of stalking, 9 of exploitation, 4 of blackmail, 14 of fraud and 10 of criminal damage (Those figures don’t add up to a total of 173, as some incidents would involve multiple categories of crime.) Of these 173 crimes, in only 8 (4.6%) cases did the sex worker indicate he/she had or was planning to report the crime to the PSNI.

This clearly shows that crime against sex workers is under-reported in Northern Ireland. It is a hidden problem where victims do not receive adequate support and perpetrators can continue to commit crimes without coming to police attention. It is recommended that the PSNI encourages the reporting of crimes by sex workers and ensures such crimes are taken seriously by officers and that sex workers receive the support they need as victims. We know, from talking to sex workers who have reported crimes to the PSNI, experiences of reporting crime to the PSNI are already generally positive, but we want to ensure good practice is standard, that sex workers are not sometimes faced with poor and outdated attitudes from officers, like perceiving crime as an ‘occupational hazard’ for sex workers or equating rape to not being paid.

In 2006, Merseyside Police designated crimes against sex workers as hate crimes. We would recommend this as the optimal means of ensuring the PSNI response to crimes against sex workers is best practice. This strategy, now known as the ‘Merseyside Model’, was formed under the leadership of Bernard Hogan-Howe, now Metropolitan Police Commissioner. Implementation of it led to unprecedented increases in the reporting of crimes by sex workers and the number of criminals being convicted. In 2010 the overall conviction rate in Merseyside for crimes against sex workers was 84%, with a 67% conviction rate for rape (the national average conviction rate for rape is 6.5%).

ACPO defines hate crimes and incidents as any crime or incident where the perpetrator’s prejudice against an identifiable group of people is a factor in determining who is victimised. All hate crimes are hate incidents, but some hate incidents may not constitute a criminal offence and are therefore recorded as a hate incident only. The PSNI currently records 6 types of hate crime and incidents, the 5 categories recorded by all UK forces – disability related, homophobic, racist, religious and transphobic – plus sectarian. It is an option for any police service to add additional categories, as the PSNI has done in the case of sectarian.

Treating crimes against sex workers as hate crimes acknowledges that sex workers are a minority who are disproportionately targeted by criminals and as a group their victimisation fits within a number of the established definitions of hate crime.

Merseyside is now widely considered to be the lead nationally in terms of addressing violence against sex workers. Adoption of the Merseyside Model is recommended by ACPO. It is also recommended in the 2012 Silence on Violence report commissioned by the Mayor of London and undertaken by Andrew Boff AM, and the 2013 report Violence Faced by Sex Workers in Westminster by the Westminster Sex Worker Task Group.

It is clear from UglyMugs.ie reports that sex workers are a stigmatised and socially marginalised group who face abuse from perpetrators motivated by prejudice and hostility towards sex workers and targeting by criminals who view sex workers as ‘easy targets’, unlikely to report crimes committed against them or be believed by police if they did. In some UglyMugs.ie reports sex workers describe offenders who have directly made statements like “You can’t report me to the police! You’re a whore!”

Adding sex worker targeted hate crime to the types of hate crime recorded by the PSNI would bring this crime into the existing PSNI hate crime structure, where various procedures have to be adhered to, and victims could be assured of the professional and supportive response that they need. It would also mean sex worker targeted hate crimes and incidents would be recorded for the first time, this data would be publicly available, and potentially a thematic review could be conducted by the Northern Ireland Policing Board.

The Merseyside Model is widely supported, not only by sex workers and sex worker organisations, but also by many anti sex work and anti sex trafficking organisations, who also believe persons selling sex need the hate crime police approach to crimes committed against them as part of a victim centred police response.

Offence Prioritisation

Although working as a sex worker is not illegal, some activities related to sex work are criminalised. Notably indoor sex workers must work alone in order to work legally. If two or more sex workers work together, both or all sex workers can be considered to be brothel keeping, which is illegal. The English Collective of Prostitutes (ECP) has frequently highlighted that sometimes when sex workers report crimes, police focus their attention on the sex worker(s) and any crimes related to sex work they may be committing, such as not working alone, rather than the original crime against the sex worker(s) that the sex worker(s) reported. As a result of this situation sex workers often feel that they cannot report crime to the police.

Police officers may feel they are in an impossible position here, that if a sex worker reports a crime, and in doing so reveals criminality, the police are compelled by the law to act on this.

However police are allowed, in certain situations, to use discretion on what to prioritise when witnessing multiple crimes simultaneously.

Most forces have policies in place for prioritising victims of serious crime above the victim’s own more minor misdemeanours in certain situations, for example in rape cases. It is this prioritisation that needs to occur in regard to crimes against sex workers, to remove the barrier to reporting for sex workers that is fear that the police may seek to prosecute them for an offence. This has been done successfully in Merseyside.

If sex workers felt more able to report crime to the PSNI, this would improve the PSNI’s ability to identify and prosecute perpetrators of abuse against sex workers.

Liaison Officers

Some police forces have sex work liaison officers.

It is generally the case that victims of hate crime have access to a liaison officer. In Merseyside, where sex worker targeted hate crime is recognised by police, they have two police sex work liaison officers who have this role as part of their wider duties, and these officers work closely with the sex work community to encourage sex workers to report crimes and act as a link between the sex work community and police.

The provision of sex work liaison officers within the PSNI is considered essential, regardless of whether the PSNI formally includes sex worker targeted hate crime within the existing PSNI hate crime structure.

Currently persons selling sex have no contact point within the PSNI to turn to for help. Their only option is to walk into a police station or phone general police numbers, something which most people selling sex find an intimidating prospect, to the point that many will not do it in any circumstances, and those who are prepared to do it often find they do not get the help they need anyway, as the problem they are reporting is not understood by the officers they speak to, who lack experience of sex work policing.

In order for the PSNI to effectively tackle crime against sex workers and sex trafficking into prostitution, people selling sex must have easy access to a liaison officer who is friendly, approachable, understands their situations and can provide advice and support to them.

At the moment all victims of hate crime in Northern Ireland have access to a PSNI Hate Incident Minority Liaison Officer (HIMLO) and liaison officers are also appointed in regard to other communities or issues that are not hate crime related. The PSNI should create sex work liaison officers. This could be an additional role for selected officers, alongside the officer’s wider duties. It is however important that sex work liaison officers do not also have an enforcement role in this specific area.

PSNI sex work liaison officers would increase contact between sex workers and the police, improve safety and reduce abuse of sex workers, and create and maintain the relationships of trust between the PSNI and sex workers which are essential for receiving intelligence regarding sex trafficking and other serious crimes.

Ugly Mug Schemes

Ugly mug schemes aim to improve the safety of sex workers and reduce crimes committed against them, by bringing sex workers together to share information with each other about potential dangers.

Two ugly mug schemes cover Northern Ireland, UglyMugs.ie and the UKNSWP National Ugly Mugs (NUM).

UglyMugs.ie does not routinely share information with the PSNI, but does so sometimes on an individual case basis. If the reporting sex worker agrees, NUM automatically shares details of offenders with the Serious Crime Analysis Section (SCAS) and the North West Regional Intelligence Unit (NWRIU) who then disseminate the information to intelligence contacts in police services in England and Wales.

It is recommended the PSNI provides a means for ugly mug schemes to share information with the PSNI. Currently Northern Irish sex workers reporting crime to ugly mug schemes do not have the ability to anonymously share intelligence with the PSNI about violent offenders, exploitative abusers and other dangers they encounter in the course of their work. The PSNI should want to be aware of ugly mug incidents in order to help them effectively police abuse of sex workers and sex trafficking.

Home Office guidance outlines how local ugly mug schemes supported by police are a valuable intelligence source, and the effective use of local ugly mugs schemes can therefore be an effective part of policing prostitution. Further, ugly mug schemes can act as an intermediary between police and sex workers and encourage formal reporting of crimes to the police. Police can also use ugly mug schemes to communicate to sex workers both general messages to encourage police engagement, like that crimes committed against sex workers will be taken seriously, and specific messages about potential dangers the PSNI may be aware of.

Anonymity for Witnesses

Lack of anonymity for sex worker witnesses is a major deterrent to sex workers engaging with the criminal justice system. All victims of certain sexual offences, including rape, are entitled to anonymity. But there is no entitlement to anonymity for sex workers who are the victims of non-sexual offences or witnesses in criminal cases. Many sex workers greatly fear being ‘outed’ as a prostitute in the media and to family, friends and the wider public. If the PSNI could recognise that being publicly named as a prostitute can be uniquely damaging, and apply for special measures for sex worker witnesses, to prevent them being publicly named as a prostitute, this would make it easier for sex workers to engage with the criminal justice system.


Police searches – unannounced forced entry visits – are a frightening experience for sex workers. A large group of police officers breaking down your door and coming into your home/workplace shouting would likely be a frightening experience for anyone. Many sex workers are migrants or have experience of working in different countries. They may have had previous bad experiences with police or authorities. They may have been a victim of crime in the past. It is not uncommon for criminals who target sex workers to pose as police. Factors such as these can make searches especially frightening for sex workers.

Whilst there are circumstances where searches are necessary, it is recommended the PSNI recognises that searches are frightening for sex workers and discourage sex workers from engaging with police. Unnecessary searches should be avoided. Necessary searches should be as unintrusive as possible and all reasonable steps should be taken to show respect for the sex workers involved and try to minimise the distress caused.

Sex workers should be shown the same respect as would be shown to any other person in respect of their bodily privacy. Sometimes police may arrive upon sex workers in a state of undress. It is good practice for police to bring blankets with them, which they can supply sex workers, to wrap themselves in, while in police presence, and sex workers should be given adequate opportunity to dress as soon as possible. Whilst we are not aware of any recent complaints from sex workers in Northern Ireland regards respect of their bodily privacy by police, sex workers in other areas of the UK, like Scotland, have reported experiencing disrespect for their bodily privacy from police recently.

The media should never be invited along on searches, to photograph sex workers and/or potential sex trafficking victims. This practice is universally detested by persons selling sex. Faces being blurred does not mean persons are not identifiable or make the practice acceptable. It is frightening enough to be caught up in a police search without then being subjected to the violation of journalists photographing your distress against your will.

There is a very poor relationship between people selling sex and elements of the media who regularly seek to ‘expose’ them. Being identified in the media as a sex worker can devastate a person’s life. Many sex workers live in fear of the media. The PSNI should not be providing the media with opportunities to photograph sex workers and/or potential victims of sex trafficking. Regards the latter, a precedent here is that since 1976 victims of sexual offences have been automatically entitled to lifelong anonymity with it being a criminal offence for the media to reveal their identity.

It should also be noted that the media often continue to use photos long after the events a series of photos may relate to, to illustrate various general prostitution or sex trafficking related stories.


Due to discrimination sex workers frequently face great difficulties with accommodation. Landlords and/or hotel staff exploiting sex workers is not uncommon. All sorts of people exploiting sex workers, under threat that they will get them evicted via reporting them to the police or their landlord/hotel, is not uncommon.

Sex worker evictions undermine sex worker safety. In the short-term sex workers can find themselves in the dangerous situation of being suddenly homeless. Moreover, sex workers find themselves pushed out of places they feel safe working in, into less safe working environments, making them more vulnerable.

Sex worker evictions are often the result of police actions. Northern Irish sex workers report that police sometimes contact hotels and letting agents / landlords to inform them that a sex worker or sex workers are staying in their accommodation. This invariably results in eviction for the sex worker(s). Police searches of premises can lead to sex worker evictions. Even ‘friendly’ police visits, where the police have in no way sought to cause any issues, can lead to sex worker evictions.

The police do have a responsibility to investigate complaints about anti-social behaviour related to an indoor sex work venue, but Home Office and ACPO guidance is repeatedly clear that police must prioritise the safety of sex workers when handling sex work related issues, and evictions clearly undermine sex worker safety.

Therefore the PSNI should view sex workers evictions as undesirable and adopt a policy of not seeking or contributing to sex worker evictions unnecessarily. Many police forces have brothel closure guidelines and policies. ACPO recommends a risk assessment is conducted before police seek to ‘close down’ any sex work establishment. Where sex workers are evicted, police have to consider the safety of the sex workers, who may have nowhere else to go and find themselves in a dangerous situation as a result of the eviction.

Arrests / Prosecutions

Arrests and prosecutions of sex workers have increased in recent years. A recent FOI request (PSNI Request Number F-2014-00002) shows that in 2012 arrests for prostitution offences were up 238% from 2007 figures, similarly prosecutions for prostitution related offences were up 188%, and 11 persons (all women) were convicted of prostitution related offences (compared to none in 2007).

Working indoors as a sex worker is legal provided the sex worker works alone. But indoor sex workers that do not work alone are criminalised under brothel laws.

That sex workers who work together for safety are criminalised is a problematic situation for police.

Enforcement action against sex workers for not working alone clearly undermines sex worker safety.

A number of Canada’s prostitution laws have recently been struck down by their Supreme Court for infringing the constitutional right of sex workers to security. The criminalisation of sex workers not working alone under UK law arguably violates their security rights under the European Convention on Human Rights (ECHR). The PSNI is required by the Human Rights Act 1998 to uphold and protect the fundamental rights and freedoms of individuals that are enshrined in the ECHR and the Northern Ireland Policing Board has a statutory duty, under the Police (Northern Ireland) Act 2000, to monitor the performance of the PSNI in complying with the Human Rights Acts.

Arrests and prosecutions of sex workers for not working alone occur in an inconsistent manner across the UK.

Many UK police forces state at different times that they have differing policies regarding the policing of sex work. Writing in Silence on Violence (2012), Andrew Boff AM said that in London the Metropolitan Police unit responsible for policing sex work and sex trafficking, SCD9, has stated they focus on forced prostitution only and do not intentionally target brothels that do not involve trafficked persons, further they focus specifically on those trafficked according to the International Labour Organisation (ILO) indicators or trafficking clearly linked to an organised criminal network, rather than targeting trafficking under the much broader UK legal definition of sex trafficking, which does not require force, coercion or deception. However there are sex workers in London who would argue this is not the case, the Metropolitan Police are not in reality restricting policing of sex work to only focusing on sex trafficking into prostitution.

Changes in public attitudes and community complaints often have an impact on how sex work is policed. Frequently there is not clarity in the way the law is applied.

We would recommend in regard to brothel laws that the PSNI adopts a policy of distinguishing between those involved in the management of brothels and sex workers working in brothels, and the latter should not be arrested or prosecuted, because to do so undermines sex worker safety and decreases the likelihood of sex workers reaching out to police when a victim of crime or if they are aware of serious criminality.

For sex workers arrest and prosecution can lead to consequences such as a criminal record, a jail sentence, being publicly labelled as a prostitute, losing custody of children and/or deportation. It is questionable whether there is any public appetite remaining in Northern Ireland for such harsh treatment of persons selling sex, given that even most of those who want further criminalisation of sex work, only want criminalisation of buyers of sex and argue that those who sell sex should not be law enforcement targets.

Police Misconduct

Sex workers in Northern Ireland do sometimes report to UglyMugs.ie that they have experienced poor police behaviour, for example offensive and insulting language used to address them. Historically and globally sex workers have frequently been subjected to a wide range of abuses from corrupt and criminal police officers, for example extortion of sexual acts in exchange for avoiding arrest.

A code of conduct for officers of all ranks dealing with sex workers would be useful. Sex workers, like everyone else, should receive good service from the PSNI. Officers who do not treat sex workers professionally should face disciplinary action and criminal proceedings in cases where criminal abuse has taken place. The PSNI should be committed to treating sex workers professionally. Details of how sex workers can complain, if officers behave unprofessionally, should be easily available.

Serious Crime

Serious crime related to sex work should be policed rigorously. The majority of sex workers want the police to do this. In fact a common sex worker complaint about policing of sex work at times is that the police are not taking action against serious crime related to sex work. Improved relations between sex workers and police would result in sex workers being more able to talk to police when they are aware of serious crime.


Trafficking is presumed to be a current PSNI policing priority.

One of the clear advantages of the PSNI prioritising the safety of sex workers is that sex workers are far more likely to alert the police when they are aware of trafficking, because they will not fear personal repercussions for doing so as a result of the trust and understanding built up with the police.

Clearly if people are being sex trafficked into prostitution, then sex workers are uniquely well placed to have the most useful knowledge of that activity.

The PSNI should actively encourage sex workers to report trafficking.

Home Office guidance provides a case study of the Greater Manchester Police Sexual Crime Unit, a police unit which focusses on the welfare of sex workers, and has found this has aided them in combatting sex trafficking. They say the assistance of people involved in prostitution has been vitally important in bringing trafficking prosecutions and the unit has found that many sex workers genuinely care about the welfare of trafficked persons and are quite willing to give statements or intelligence if they feel it will help the victim.

A change of priority from enforcement to protection in regard to sex workers also means sex trafficking victims are less likely to be treated as criminals. Victims of sex trafficking are also more likely to be identified.

People generally understand sex trafficking as involving force, deception or coercion, as per the Palermo Protocol definition. However the UK legal definition of sex trafficking does not require force, deception or coercion and therefore includes the movement of all sex workers, including willing sex workers.

Rather than persons who have been tricked into being a sex worker against their will, it is more likely that victims of sex trafficking under the UK legal definition are persons who choose to be sex workers. Their conditions of work may be exploitative, but they may only comprehend this gradually. Such persons are however unlikely to ever seek help from police or provide police with intelligence about trafficking if there is a hostile relationship between police and sex workers.

Friendly policing towards sex workers is therefore a vital component of policing sex trafficking. A person who has had a negative experience of the PSNI, like being caught up in a police search, is unlikely to go on to engage with the PSNI, whereas a person who received a friendly visit from the PSNI and was advised they could contact the PSNI if they ever needed help is far more likely to go on to engage with the PSNI in the future.

Specialist Unit

Some UK police forces have specialist sex work units. For example, in London, SCD9, Human Exploitation and Organised Crime, is a central unit of the Metropolitan Police that has overall responsibility for the policing of on and off street prostitution within its remit, although it also has other responsibilities.

The PSNI should consider whether it would be better if policing in relation to sex work was the responsibility of a specialist unit. With the current approach of no specialist unit, there is inconsistency in how sex work is policed, and many officers dealing with sex workers have little understanding or knowledge of sex work.

Belfast Harbour Police

The Belfast Harbour Police come in contact with sex workers as the small Port of Belfast area they are responsible for policing is an area where a number of indoor sex workers are based. Several sex workers have expressed to UglyMugs.ie that they’ve had an interaction with the Belfast Harbour Police where they would consider their treatment to have been poor. It would appear that the Belfast Harbour Police approach sex work somewhat differently to the PSNI and there is an inconsistency in the policing of sex work in Belfast as a result of this.

Various crimes or incidents that occur within the Belfast Harbour Police area are designated the responsibility of the PSNI. It is recommended that the PSNI and Belfast Harbour Police consider whether policing in relation to sex work being the responsibility of the PSNI would be a better arrangement, and if that arrangement is not suitable, look at how the Belfast Harbour Police can effectively police sex work alongside the PSNI in a consistent manner.


In recent years condoms have been used by the PSNI as evidence to support prostitution-related charges. Confiscating condoms from sex workers or using condoms as evidence against sex workers is not recommended as it directly undermines HIV prevention and public health interventions. The negative consequences of condoms being used as evidence of prostitution by police, and why such practices should be discontinued in areas where they are still ongoing, has been covered by a number of major International reports in recent years, including Human Rights Watch’s Sex Workers at Risk, Condoms as Evidence of Prostitution in Four US Cities, 2012.

Strategic Lead

A strategic lead for sex work should be appointed within the PSNI to oversee the policing of sex work.

ACPO Working Group

The PSNI should join the ACPO National Police Working Group on Prostitution, Chaired by the National Police Lead on Prostitution, ACC Chris Armitt, in order to keep up to date with national best practice in this area.

Community Engagement

Good policing of sex work requires effective partnerships between the police and others, including the sex work community. Sex workers are one of the few groups in society that are still often excluded from involvement on policies relating to them, yet sex workers are the experts on their own lives. In Manchester the Manchester Prostitution Forum including all they key agencies such as the police, health service, city council and voluntary sector organisations meets every six months and its purpose is to develop and maintain effective partnership working. In Northern Ireland the Department of Justice has an NGO Engagement Group to tackle human trafficking, but no sex work group, and further, sex work related groups or individuals are not included in trafficking group. It is recommended that there be a group focused on sex work and that the sex work community is included in that group.

Support Services for Sex Workers

There is a lack of support services for sex workers in Northern Ireland, which is a clearly undesirable situation. Sex workers don’t have easy access to advice and support or dedicated health services.

Security concerns appear to have been one factor that has held back development of services. It is noted that the small Belfast Commercial Sex Workers Service operates very discreetly to the point no contact details are publicly available. The 2011 Department of Justice, Research paper investigating the issues for women in Northern Ireland involved in prostitution and exploring best practice elsewhere, states that previous attempts by one organisation to provide outreach support to sex workers were abandoned following the PSNI advising it would not be safe for their workers to engage in outreach work with sex workers.

The lack of support services for sex workers in Northern Ireland directly negatively impacts on the PSNI’s ability to police sex work effectively. It is recommended the PSNI reassesses the security situation regards service provision to sex workers and encourages the development of such services in future if possible.


It is important that all officers who deal with sex workers receive adequate training. Officers should always be professional and respectful in their policing of sex work and the safety of persons selling sex should always be prioritised, regardless of any personal views the officer may have on prostitution.

As well as an understanding of how sex workers can be vulnerable to abuse and why abuse of persons selling sex needs to be taken seriously, officers should also understand the reasons why sex workers are often reluctant to engage with police, some of which are unique to sex workers, such as:
Worry about being judged by police for being a sex worker
Worry about not being believed by police because of being a sex worker
Fear of being investigated by police for sex work related offences
Fear of losing accommodation
Fear of being exposed as a sex worker
Fear of immigration problems
Fear of police and/or previous bad experience of the police
Feeling police will not been interested / do not care about sex workers
Acceptance of abuse as a ‘normal’ part of sex work

Knowledge of the law is important. Encountering police who are not aware of the law is a common problem for sex workers. Sex workers frequently report being ‘investigated’ and sometimes being evicted as a result of officers who appear to erroneously believe all sex work is criminal and thus they are acting correctly in seeking to obstruct sex workers from conducting their business.

Recognise that sex workers are stigmatised and face discrimination. Many sex workers are also migrants and may also experience racism and discrimination as a result of this. Sex workers can also be male or trans* and some sex workers also face discrimination on the basis of their sexual orientation or gender identity.

People selling sex are a diverse group of people, who come from a wide range of backgrounds and are in sex work for a wide range of reasons. Sex workers are not all the same. Whilst most persons selling sex are doing so as a matter of choice, police could encounter victims of sex trafficking in prostitution.

People selling sex deserve to be treated with the same respect and kindness as any other person. Officers should be caring, compassionate and understanding towards people selling sex and especially try not to come across as aggressive, as sex workers may feel intimidated by police.

As individuals sex workers have the right to make their own informed decisions about their own lives. The autonomy of sex workers must be respected. Police cannot forcibly ‘rescue’ sex workers.

Most sex workers do not want to be identified as sex workers because of the stigma attached to sex work. Often their families, friends and even partners do not know that they do sex work and they fear being found out. They may have a second job and that employer does not know about their sex work. Their landlord may not know they are a sex worker. It is very important the PSNI are very discreet when dealing with sex workers, in recognition of the discrimination sex workers face and their resulting privacy needs.

Many sex workers regard the term ‘prostitute’ as offensive. Numerous other terms sometimes used to describe sex workers are clearly offensive, including prossie, whore, hooker, ho. As a general rule the PSNI should note how people in sex work describe themselves, e.g. escort, and reflect their choice of language.


The public’s views on sex work and sex trafficking are very heavily dependent on the information they receive via the media. ACPO recommends police forces develop evidence based sex work policing policies and scope their own ‘problem’ using factual information and statistics gathered locally. Historically police forces in the UK have periodically engaged in ‘crackdowns’ on sex work, especially on-street sex work, to appease public moral discontent, but such operations are not helpful, at best they only result in displacement of sex workers to other areas, which is not a solution and at worst, they have resulted in the murder of sex workers. Hostile media portrayal of people in sex work increases the risks to those in sex work. It is recommended the PSNI is careful not to contribute to or react to inaccurate and/or sensationalist media on sex work.

Supporting Policymakers

The PSNI should engage in public debate on sex work and support policymakers in creating laws and policies which make it easier to investigate and successfully prosecute those who abuse persons in prostitution. ACPO also takes a role in supporting national policymakers and lawmakers in creating prostitution policies and laws and regularly speaks to the media about prostitution legislation.

Published Sex Worker Contact Policy

Traditionally, many sex workers have never have occasion to interact with the PSNI, as they have not required police assistance and have not come to police attention due to the discreet nature of their work. However with increased public concern about sex trafficking into prostitution, all indoor sex workers can now expect to come in contact with police at times.

Most sex workers do not object to the PSNI making ‘friendly’ visits or ‘welfare checks’. This type of contact is much preferable to more intrusive and formal actions which can threaten the safety of sex workers. However there is a lack of information about what sex workers can expect when contacted by the PSNI. Also PSNI policies in contacting sex workers appear to differ in places from the policies of other forces sex workers may be familiar with, for example sex workers frequently report that police officers in Northern Ireland come alone when visiting and do not always provide a card with their details. Further to this sex workers do sometimes experience problems with criminals impersonating police.

At the moment sex workers being contacted by ‘police’ by phone, SMS, email or in person visits are frequently unsure if the persons presenting themselves are even really police are not. There is an information vacuum here that is causing distress to sex workers at times. It is recommended this situation is resolved by the PSNI publishing clear guidance for sex workers as to what they can expect if contacted by police, including how to identify police from others who may impersonate police.

Police Records

Sex workers have reported than any contact with police can result in a note being added to police records, stating that they are a sex worker. The practice of recording that persons are sex workers on police records, if ongoing, should be discontinued. Further, sex workers should be able to have such notes removed, if already added to their police record. Being identified as a sex worker on police records can prevent sex workers exiting sex work, as such notes can show up on Criminal Records Bureau (CRB) checks carried out by employers in connection with job applications. It is also clearly a disincentive to sex workers to engage with police at all, if doing so may result in their being recorded on police records as a sex worker.

Reporting to Social Services

Many sex workers are parents or guardians. Sex workers are not unfit parents or guardians. The PSNI should not report sex workers who are the parents or guardians of children to social services on the basis of their being sex workers. On 14 February 2014 the BBC published an article about compensation awarded to a Northern Irish woman whose photos were published on a sex work website without her consent. The article reported that this woman, who was not a sex worker, contacted police seeking assistance in getting her photos removed from the sex work website. Police were unable to help, but did report her to social services, who then carried out an investigation.

Outdoor Sex Work

There is reportedly very little outdoor sex work in Northern Ireland. Due to an administrative error soliciting offences were not recorded in Northern Ireland until 2011. No prosecutions for soliciting have been brought since this date to our knowledge. We have not covered outdoor sex work in these proposals, due to lack of experience of the issues involved in outdoor sex work, but we would recommend that any review of sex work policing should be for all sex workers, including outdoor sex workers. ACPO and the Home Office provide guidance on the policing of outdoor sex work. Also the Belfast Commercial Sex Workers Service has experience in this area and could identify additional recommendations for the benefit of outdoor sex workers.

One comment on “A letter to the PSNI and The Department of Justice for Northern Ireland

  1. Pingback: A letter to the PSNI and The Department of Justice for Northern Ireland - TRPWL : TRPWL

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This entry was posted on 17 February, 2014 by in Campaigns and Groups, sex worker politics.
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