Consultation on the Proposed Changes to Guidance for Local VAWDASV Strategies
Improving responses to older people’s experiences of abuse is one of my key priorities. I therefore welcome the opportunity to comment on several of the proposals that may affect older people with lived experience of VAWDASV. Please accept this letter as my response to the consultation.
I welcome the proposal to issue the guidance on a statutory basis; this will help strengthen compliance across public bodies and will address inconsistencies within current levels of engagement. The fact that these statutory duties will now apply to a wider group of organisations than previously, including those with whom older people most often interact, will help raise the ‘profile’ of older victim survivors of VAWDASV. Engagement with bodies such as adult social care, health and housing, will ensure that the voices of older people are heard in the development of strategic plans and service provision.
Integrating data from these wider public bodies into needs assessments also has the potential to improve the visibility of older people’s experiences of VAWDASV at a strategic level. This, in turn, will help shape age-inclusive commissioning processes and service responses. Older people are often under-represented in criminal justice data and data from specialist services, and so are disadvantaged where strategic planning and commissioning is solely reliant upon such data. It is, of course, critically important that older people themselves are provided with opportunities for engagement and comment as the development of the guidance is progressed.
The guidance provides an important means of raising awareness of older people’s experiences of VAWDASV, making explicit that older, as well as younger people, are at risk of and experience
gender-based violence. When violence and abuse is perpetrated against older people, there can be a tendency to understand it ‘differently’. Older people are often seen as an inherently
‘vulnerable’ group, solely in need of ‘safeguarding’ and protection in situations of VAWDASV. It is important that strategic responses pay attention to the autonomy, dignity and choice of older people.
The focus upon outcomes is to be welcomed, since it prioritises understanding the impacts of interventions and services from the perspectives of those with lived experience of VAWDASV. Critically, however, outcomes must be age disaggregated, including age breakdowns amongst the older population, ideally in five-year age bands. This will highlight differences in access to
specialist services and will help to determine the effectiveness of models of service delivery.
Finally, I note that the guidance refers to other related policies; those which overlap with and include duties connected to the implementation of VAWDASV. It is important that reference is
specifically made to the Welsh Government’s National Action Plan to Prevent the Abuse of Older People in Wales. The plan focuses upon the actions needed to prevent and respond to older
people’s experiences of VAWDASV.
If you would like to explore any of the points above in more depth, please contact my Safeguarding Lead, Andrea Cooper (andrea.cooper@olderpeople.wales).
Yours sincerely,
