Social Work Scotland response to UK Government’s call for evidence on Identification of Modern Day Slavery
October 2025
Introduction
Social Work Scotland is the professional body for social work leaders, working closely with our partners to shape policy and practice, and improve the quality and experience of social services. We welcome the opportunity to provide a response to the call for evidence on the Identification of Victims of Modern Slavery.
Background
The Call for Evidence on the Identification of Victims of Modern Slavery aims to gather information from various groups to improve the UK’s system for identifying victims of modern slavery. There is a focus on enhancing the National Referral Mechanism (NRM), the current framework for formal identification and support.
The Call for Evidence seeks insights on victim definitions, the effectiveness of initial identification practices by First Responder Organisations, and how formal identification processes can be made more victim-focused, accurate, efficient, streamlined, and future-proofed.
The views expressed by Social Work Scotland’s members in response to the Call for Evidence reflect a nuanced and practice-informed critique of the current systems and terminology surrounding the identification of victims of modern slavery. Member responses reveal a consistent concern with the accessibility, relevance, and effectiveness of existing frameworks, particularly the National Referral Mechanism (NRM) and associated statutory guidance.
Members question the utility of the term “modern slavery,” arguing that while it carries legal and policy weight, it often fails to resonate with victims and practitioners alike. The term is seen as alienating, evoking historical connotations that obscure the lived realities of contemporary exploitation. Young people may not identify with the label, especially when their experiences involve coercion masked as choice. Consequently, the term may hinder both self-identification and professional recognition of exploitation. “Exploitation” is proposed as a more relatable and practical alternative, better suited to multidisciplinary safeguarding contexts.
The statutory indicators used to identify victims are similarly critiqued. While they offer a foundational framework, they are not widely relied upon by practitioners, who favour locally developed resources and guidance from organisations such as Action for Children and the Centre for Youth and Criminal Justice (CYCJ). These alternative materials are praised for their clarity, specificity, and grounding in real-life scenarios. Members argue that the statutory guidance lacks the nuance required to detect subtle forms of coercion and control, particularly in cases involving criminal and sexual exploitation of young people.
Training and multi-agency collaboration emerge as central themes throughout the Call for Evidence. Members stress that effective identification of victims depends not only on written guidance but also on dynamic, practice-led learning environments. Peer-to-peer training, lived experience narratives, and shared casework are highlighted as powerful tools for deepening understanding and fostering cross-sector cooperation. There is a strong preference for holistic approaches that consider exploitation in its various forms (sexual, criminal, labour, and beyond) rather than siloed categories.
Concerns are also raised about the limitations of the current legal definitions under the Slavery and Human Trafficking (Definition of Victim) Regulations 2022. Members identify significant gaps, particularly in relation to child criminal exploitation and online abuse, which are not adequately captured by existing frameworks. The lack of a statutory definition for child criminal exploitation is seen as a barrier to justice, often resulting in the prosecution of victims rather than perpetrators.
The consultation also explores the effectiveness of centralised versus devolved decision-making models. Members overwhelmingly favour devolved systems, citing Glasgow’s pilot model as an example of good practice. Local decision-making is credited with enabling faster, trauma-informed responses, reducing the risk of criminalising victims, and strengthening multi-agency partnerships. However, concerns about consistency and capacity across different regions are acknowledged, with calls for national oversight to prevent disparities in victim support.
Finally, the importance of creating safe and supportive environments for initial victim interactions is underscored. Trauma-informed practice, professional confidence, and appropriate settings are deemed essential for encouraging disclosure and engagement. Members advocate for training that equips frontline professionals with the skills to recognise subtle indicators and respond sensitively.
In sum, Social Work Scotland’s members advocate for a more flexible, locally responsive, and trauma-informed approach to identifying and supporting victims of modern slavery. Their views reflect a deep commitment to safeguarding and a desire to reform systems that, in their current form, often fall short of meeting the complex needs of those affected by exploitation.
This response to the Call for Evidence presents the key questions posed, and the feedback received from our members.
