By providing a collective response to decision makers, Clinks strengthens the voice of the Sector, and ensures its voice includes a wide range of organisations – in particular those that might not have the capacity to write their own response.
Clinks produces written responses to proposals from policy makers and legislatures on issues which affect the Voluntary and Community Sector and its service users.
Read our responses here:
Clinks has responded to the Ministry of Justice’s draft guidance on applying to open secure schools and have focused our response on the draft quality indicators included in the guidance that will form part of the monitoring and accountability structures. We make a series of recommendations, including: national training standards to be introduced, rooted in an understanding of children’s psychosocial development and the importance of relationships; the quality indicators draw upon HM Inspectorate of Prisons indicators for adult male prisons, particularly Expectation 80 states that “prisoners’ needs are met by coordinated rehabilitation services”; and an additional quality indicator is introduced around meeting the needs of specific groups of children and young people.
Clinks has responded to HM Government’s consultation on transforming the response to domestic abuse. We welcome the recognition that domestic abuse is often a key factor in women’s involvement in the criminal justice system (CJS) and stress the need for a shared approach across government to responding to victims of domestic abuse. Our response focuses on the importance of early intervention and prevention, as well as diversion from the CJS.
Clinks response to the All Party Parliamentary Group on women in the penal system (June 2018)
Clinks has responded to the All Party Parliamentary Group on women in the penal system’s inquiry into the sentencing of women. Our response highlights the need for sustained investment in women’s centres, information for sentencers about the availability of gender specific services available to them and the provision of gender specific community sentencing options. Our response was informed by consultation with our members during our women’s networking forum meeting on 8th May, complimented with our existing knowledge.
Clinks and the Young Review worked together to submit a response to the Criminal Justice Joint Inspection Business Plan 2018/19 Consultation. We have focused specifically on the proposal to undertake a scoping and feasibility study on ethnic disproportionality in the criminal justice system. We draw on our own and others’ previous work on race and the criminal justice system including the Young Review’s final report, David Lammy’s independent review into the treatment of, and outcomes for, black, Asian and minority ethnic individuals (BAME) in the criminal justice system, and Clinks’ recent response HMI Probation’s consultation on its inspection framework and programme. Our response outlines some of the key considerations we believe the Criminal Justice Joint Inspection will need to take into account when developing its proposed scoping and feasibility study into ethnic disproportionality in the criminal justice system and the potential for future thematic activity in this area.
Clinks submitted evidence to the Health and Social Care Committee inquiry into prison healthcare. We drew on evidence gathered through our work in the VCSE Health and Wellbeing Alliance, and from our members working with people in prison. Our response focusses on the challenges prisons and prison healthcare services face in providing care which is equivalent to that offered in the community; and the role the voluntary sector can play in meeting the health and care needs of people in prison and improving continuity of care.
Clinks has responded to HM Inspectorate of Probation’s 2018 consultation on its inspection framework and programmes. Our response draws on evidence from our ongoing policy work and consultation with members. The consultation focused on the inspection of youth offending teams, potential topics for thematic review, the balance of inspection work and potential research projects. Our response highlights the importance of gaining a better understanding of partnership work with the voluntary sector in probation services and youth offending teams. It makes a number of recommendations about topics for thematic review or further research, including outcomes for black, Asian and minority ethnic people, service user involvement and the effective use of community sentences.
The National Institute for Health and Care Excellence (NICE) has created draft guidance on preventing suicide in community and custodial or detention settings. In our response to NICE’s consultation we strongly support the inclusion of voluntary organisations in all suicide prevention partnerships and encourage better data sharing between organisations. Our response is informed by previous work by the Reducing Reoffending Third Sector Advisory Group to the Ministry of Justice on effective care and support for people at risk of suicide and self-harm in prison.
Clinks responded to the NHS England consultation on conditions for which over the counter items should not routinely be prescribed in primary care. The consultation set out proposals for national guidance for Clinical Commissioning Groups on the prescribing of ‘over the counter products’ for 35 minor and/or self-limiting conditions. Our response to this consultation focused on the potential impact of the proposed changes on people in contact with the criminal justice system and their families, informed by feedback collected from Clinks members.
The government plans to change the existing organ donation system to an 'opt-out' system. Under the current system people, who want to donate their organs ‘opt in’ or agree to donate after their death by signing up as a donor on the NHS Organ Donor Register and telling their family their decision. The proposed new system would be an ‘opt out’ system, meaning unless people had registered to opt out of donating their organs, they will be assumed to have consented. The aim of the consultation was to establish what more could be done in England to ensure that public support for organ donation is supported both within the legal system and in the NHS and that a person’s decision to donate is supported whenever possible. Our response to this consultation focuses on the potential impact of the proposed changes to consent for organ and tissue donation on people in the CJS and their families, and has been informed by feedback collected from Clinks members.
Clinks and the Young Review worked together to submit a response to the Women and Equalities Committee inquiry into the race disparity audit. Our response draws on our own and others’ previous work on race and the criminal justice system including information from consultation events, which Clinks has previously held, to inform our submissions to the Lammy Review and to the committee’s previous inquiry into improving outcomes for people from Gypsy, Traveller and Roma communities. The response is structured around the questions posed by the committee’s inquiry, which cover what the race disparity audit reveals, how the government should respond to the audit, and what the audit tells us are the most pressing policy issues. In providing answers to the inquiry’s questions we have focused on the criminal justice data collated by the audit.
Clinks has submitted evidence to the Justice Committee inquiry into the prison population. We welcomed this inquiry, and used our extensive prison focused work and evidence gathered from our members to respond. Our response focuses on the impact that the make up and size of the prison population has on safe and effectively managed prisons, with a particular emphasis on the implications for voluntary sector organisations working in prisons and their ability to deliver effective rehabilitation and resettlement services.
Clinks has responded to the Department for Communities and Local Governments’ consultation on the homeless code of guidance for local authorities. Overall, we recommend that the role of housing authorities in relation public, private and voluntary organisations working with people in contact with the criminal justice system is made explicitly clear. This should help ensure there is no duplication in activity and that people in contact with the criminal justice system do not fall through gaps in provision. Our response also highlights the need for housing authorities to work with voluntary organisations and their service users as key strategic and delivery partners and that the wording relating to spent convictions is made explicitly clear to avoid confusion.
Clinks submitted a response to Crisis’ call for evidence to inform their campaign to end homelessness. Our response highlights the importance of addressing people’s accommodation needs during their first contact with the criminal justice system; the need for timely resettlement support before people leave prison; and the challenges that remain with recording accurate accommodation outcomes. Our main recommendation is for the Ministry of Justice to develop a cross-departmental accommodation strategy in partnership with the Department for Communities and Local Government and Department of Work and Pensions to ensure people in contact with the criminal justice system are able to secure appropriate, safe accommodation.
London Voluntary Sector Council and Clinks responded to the London Assembly Police and Crime Committee investigation on women offenders. It discusses the main barriers to supporting women in contact with the criminal justice system in London and the difficulties faced by women-centred services providing this support. It puts forward a number of key principles to guide the new Female Offender Service set up by the Mayor’s Office for Policing and Crime. These include supporting the desistance process, focusing on diversion and early intervention and addressing the needs of black, Asian and minority ethnic women. The response also provides case studies, outlining good practice in other areas of England and Wales that could be replicated in London.
In order to respond to HM Inspectorate of Probation’s consultation questions we have drawn on evidence from our ongoing policy work and consultation with members. In our submission we have focused on the three key areas which we feel our knowledge and expertise best places us to provide feedback on. These are: HM Inspectorate of Probation’s engagement with voluntary sector organisations;Probation providers’ engagement with voluntary sector organisations; and prioritising equalities in HM Inspectorate of Probation’s framework and programmes.Throughout our response we have made a number of recommendations and suggestions for HM Inspectorate of Probation to consider as well as offers of support that Clinks could provide to the HM Inspectorate of Probation.
In November 2016, the Women and Equalities Committee launched an inquiry into inequalities faced by Gypsy, Roma and Traveller communities. The inquiry looked at the 28 commitments for tackling inequalities faced by Gypsies and Travellers published by a ministerial working group in 2012, asking what progress has been made in achieving them, how effective policy-making and implementation is for these groups more generally, and how the Government can tackle such continuing inequalities. Clinks’ response examines the specific inequalities faced by Gypsy, Roma and Traveller (GRT) people in the criminal justice system. It highlights in particular the lack of monitoring around outcomes for GRT people, low levels of awareness of the needs of GRT people among prison and probation staff and educational barriers for GRT people. The response makes a number of recommendations based on consultation with voluntary sector organisations with expertise in supporting GRT people in the criminal justice system.
Clinks responded to the Lords Select Committee on Charities’ call for evidence on the sustainability of the charity sector. Our response reflects direct consultation with our members and various surveys, primarily Clinks’ State of the sector reports and our in depth work on the impact of recent changes to probation. Clinks made nine recommendations to the Committee, shining a light on the diverse voluntary sector, valuing volunteering, better strategic involvement of organisations, support for grants and a different approach to commissioning. We advocate for the sector’s role in supporting people with multiple needs and providing people with lived experience with a voice in shaping services and policy. We also call for a commitment to involve voluntary organisations in both local and central government.
London Voluntary Service Council (LVSC) and Clinks have submitted this joint response the Mayor’s Office for Policing and Crime’s (MOPAC) consultation on their Police and Crime Plan 2017-18. The response outlines the issues highlighted by voluntary sector organisations during LVSC’s consultation with their Safer Future Communities network, focusing on engagement of the voluntary sector, tackling inequalities and meeting the needs of vulnerable people. The recommendations include that the Metropolitan Police Service should seek to build positive communication links with refugee and migrant communities, that MOPAC should develop and publish a strategic plan for tackling inequalities for BAME people within the CJS in London and MOPAC should utilise the learning from the Making Every Adult Matter coalition in order to inform its approach to devolution.
Her Majesty’s Inspectorate of Prisons (HMIP) last revised the Expectations for adult male prisons in January 2012. In light of the new prison reform agenda and evolving human rights standards, HMIP decided in 2016 to review this set of Expectations. In January 2017 HMIP published its draft revised Expectations and launched a public consultation, with feedback requested by 17 February 2017. In order to ensure the active involvement of voluntary organisations in this process and to inform a comprehensive response to the review, Clinks was delighted to work with HMIP to hold three consultation events on the revised Expectations. We also invited voluntary organisations to share their own written responses with us. This response collates and summarises the key feedback – the main points of consensus among voluntary sector participants during structured, noted discussions – from all the consultation events, together with the written material that we received.
In September 2015 Charlie Taylor was asked to lead a departmental review of the youth justice system for the Ministry of Justice – the Taylor Review. Taylor’s final report was published in December 2016, together with the Government’s response. Clinks has now published a response to both reports, in partnership with Nacro and Peer Power. Our response evaluates both sets of proposals against the issues highlighted in the original submission that we made to the Taylor Review in April 2016, in order to identify what is welcomed as well as a number of areas that we believe continue to require attention.
As many people who have a conviction rely on supported housing, Clinks has responded to the Department for Communities and Local Government and Department for Work and Pensions funding for supported housing consultation. It is essential that the funding mechanism for supported housing enables providers to continue to deliver their services and meet the needs of their clients. Our key recommendations include: that the Ministry of Justice develop a cross-departmental accommodation strategy to support positive accommodation outcomes for people in contact with the criminal justice system; that people with a conviction are defined as a vulnerable group by the Department for Communities and Local Government, with guidelines circulated to local authorities; and that there is a statutory duty on all local authorities to assess the supported housing needs of their population. Clinks also responded to the Work and Pensions Committee and the Communities and Local Government Committee joint inquiry into the government’s funding reform for supported housing, stressing the importance of the need for a cross-departmental accommodation strategy led by the Ministry of Justice.
Clinks has submitted additional written evidence to the Justice Committee’s sub-inquiry on governor empowerment and prison performance in response to some of the supplementary questions posed. Our submission takes account of the publication by the Ministry of Justice of the Prison Safety and Reform white paper in November 2016 and Clinks’ response to it. While welcoming many of the commitments made in the white paper, Clinks' evidence highlights the need for the Ministry of Justice and National Offender Management Service to disseminate timely information to the voluntary sector about governors’ new budgetary and commissioning responsibilities and ensure that existing providers, including voluntary organisations, are fully consulted and engaged with those plans at the earliest possible date.
Following publication in November of the Government's Prison Safety and Reform white paper, Clinks has taken the opportunity to respond to the proposals contained within it, drawing on all our work to build the sector's effective engagement with the prison reform programme throughout 2016. The response is not intended as a detailed briefing on the white paper's content, but rather presents an analysis of its proposals in terms of what is welcomed, what areas still require more detailed development, and in particular what offers Clinks and our members can make to MoJ, NOMS and prison governors to support this important work as it progresses.
Clinks submitted evidence in September 2016 to the Justice Committee’s inquiry on prison reform. Clinks' submission, which pre-dated the Government's publication in November of the Prison Safety and Reform white paper, highlighted that voluntary organisations have a key role to play as strategic and delivery partners in the prison reform programme, helping prisons to become more community-facing institutions and enabling in-reach by volunteers and non criminal justice agencies to undertake a range of activities known to support desistance. It therefore urged the Ministry of Justice and National Offender Management Service to actively consult with the voluntary sector throughout the design and implementation of the reform programme. For more information about the inquiry visit the Justice Committee's webpage here.
Clinks submitted a response to the House of Lords Financial Exclusion Committee highlighting that having contact with the Criminal Justice System exacerbates and contributes to peoples’ experiences of debt, poverty and financial exclusion. The respose makes the following recommendations: the finance gap experienced by many prisoners on release is bridged; there is tailored support for families of people in contact with the CJS; and resettlement services are delivered at the earliest opportunity.
Clinks submitted this response to a consultation by the London Health in the Justice System and Other Vulnerable Adults Strategic Clinical Network on their draft strategy for improving health outcomes for women in contact with the Criminal Justice System in London. The response welcomes the overall direction of the strategy, which acknowledges the need for greater collaboration across the whole system to enable continuity of care; the need for a gender sensitive response to vulnerable women; and a focus on building women's resilience, self-confidence and ability to manage their own health. Clinks also highlights the importance of including voluntary sector organisations as key partners in order to achieve the ambitions set out in the strategy.
A summary of Clinks’ response to the Department of Health consultation on the Carers Strategy (September 2016)
Clinks submitted a response to the Department of Health consultation on the Carers strategy. Although the survey was primarily aimed at carers, it also offered an opportunity for other organisations to contribute information. We believe it is of the utmost importance that there is better identification of carers, including among those in prison and their families, and that they are able to access relevant information and advice. We need to improve services and other formal support for carers affected by the Criminal Justice System, ensuring that carers are fully involved in the design of those services.
Clinks' submission to the Charity Commission’s consultation on the power to disqualify from acting as a trustee (August 2016)
Clinks has worked alongside partners, such as Unlock and the Prison Reform Trust, to raise concerns on behalf of the voluntary sector about new powers granted to the Charity Commission under the Charities (Protection and Social Investment) Act 2016 to disqualify people with certain convictions or cautions from acting as trustees or being employed as senior managers in charities. This law is due to come into force in April 2017. Clinks is committed to removing any unnecessary barriers that stop people with lived experience of the Criminal Justice System from leading and shaping the voluntary sector.
Clinks' submission to the Government’s consultation on new policy directions for the Big Lottery Fund (August 2016)
Clinks has submitted this response to the Government’s proposed new policy directions for the allocation of Big Lottery Funds in England, the Isle of Man and UK-wide funding programmes. The Big Lottery Fund is the UK’s largest single distributor of National Lottery money, responsible for distributing 40% of all funds the National Lottery raises for good causes. It is the single largest funder of the voluntary sector across the UK. Clinks is committed to seeing a proportion of these funds spent on vital rehabilitation and resettlement services in the Criminal Justice System.
Clinks has responded to the Sentencing Council consultation on the sentencing of youths, drawing on the views and evidence gathered in consultation with Clinks’ members to respond to the government’s reviews of the youth justice system and of racial bias and disproportionality in the Criminal Justice System. The response emphasises the importance of placing a model of desistance at the heart of the sentencing guidelines, and ensuring that sentences for children are always aimed at reducing re-offending and safeguarding the welfare of the child.
Young Review submission to the Lammy Review (July 2016)
One of Clinks' partners, the Young Review, has responded to the government's review of black, Asian and minority ethnic (BAME) representation in the Criminal Justice System. The Young Review was set up in partnership with Clinks in 2012 to focus on improving outcomes for young black and Muslim men in the Criminal Justice System, successfully concluding in 2014 with the Young Review report. Clinks is now a member of the Young Review Independent Advisory Group to the Ministry of Justice and the National Offender Management Service. This submission makes a number of recommendations, some of which were originally put forward in the Young Review report, including reviewing the process for downgrading a prisoner's status, further developing service user involvement, and improving the ethnic representation of staff in the Criminal Justice System.
Clinks, NCVO and Third Sector Research Centre have responded to the Public Accounts Committee inquiry into Transforming Rehabilitation. We have extensive up-to-date evidence from the voluntary sector about their engagement in and experiences of Transforming Rehabilitation through our TrackTR project. This has captured unique evidence from two surveys, a consultation event, and in depth conversations with providers and policy makers including Community Rehabilitation Companies, the National Probation Service and relevant government departments and agencies. Furthermore Clinks has continued to talk to voluntary sector organisations throughout England and Wales to inform our submission. Throughout this submission we highlight key findings from our research and make a series of recommendations.
We have worked with a number of national and local voluntary sector partners concerned with achieving positive outcomes for Black, Asian, and minority ethnic people (BAME) in the Criminal Justice System (CJS) to formulate this submission, not only in response to the questions posed by the formal consultation, but also to address the broader themes encompassed by the review. The response makes a number of recommendations on themes which include: developing and implementing an action plan for BAME equality in the CJS, effective engagement and partnership with the voluntary sector, involving service users, staff training and recruitment, and working with other review teams.
Since early 2016 Clinks has been working with a number of national and local voluntary sector partners concerned with children, young people and youth justice to formulate our submission to the Taylor Review of the youth justice system, not only in response to the interim report published in February 2016 but also to address the broader themes encompassed by the review. The submission draws on feedback from five consultation events with voluntary sector organisations across England and Wales, including one with organisations supporting Black, Asian and minority ethnic people convened by BTEG and POPS. Two special consultation events were also held with Nacro and Peer Power, to hear the views of young people with experience of the youth justice system.
Clinks, in partnership with Homeless Link has submitted evidence to the Work and Pensions Committee Inquiry into housing and employment support for people on their release from prison. In our submission we highlight the need for resettlement support to be offered to prisoners at the earliest opportunity, increased transparency of services commissioned by Community Rehabilitation Companies and the National Probation Service and the need for continued investment in supported housing.
Clinks has submitted evidence to the Ministry of Justice review into the care and management of transgender offenders. The review will develop recommendations for revised guidelines which cover the future shape of prison and probation services for transgender people in the Criminal Justice System. As well as submitting this written response, we have given oral evidence through attending two roundtable discussions hosted by the review team.
The Charities (Protection and Social Investment) Bill is currently passing through parliament and is due it's second reading in the House of Commons on 3rd December 2015. Clinks has supported a briefing written by Unlock which outlines concerns about proposals in the Bill which extend the disqualification framework for people with criminal convictions acting as trustees or in senior posts in voluntary sector organisations. The briefing is also supported by a number of other criminal justice charities including the Prison Reform Trust, User Voice, The Howard League for Penal Reform, Transform Justice, Centre for Crime and Justice Studies, and the Criminal Justice Alliance.
Clinks submission to the review of prison education (November 2015)
Earlier in the year the Secretary of State for Justice announced a review of prison education in England and Wales to examine how it supports effective rehabilitation of different segments of prison learners. The Coates Review has since issued a call for evidence and this is Clinks' response. In our submission we highlight the importantance of a wide ranging curriculum including through the arts, sport and the involvement of families; and the role the voluntary sector can play in the provision of these.
Clinks response to the Department of Health VCSE Review (November 2015)
Clinks have responded to the VCSE Review discussion paper on the challenges and solutions to better investment and partnership with the voluntary sector. The VCSE Review was initiated by the Department of Health, NHS England and Public Health England, to review the role of the voluntary sector in improving health, wellbeing and care outcomes. The review aims to make recommendations on how the sector can maximise and demonstrate its impact; build sustainability and capacity; and promote equality and address health inequalities. Clinks' response draws extensively on input and examples for our members and on our ongoing research with the voluntary sector working with offenders and their families.
Clinks has submitted evidence to the Justice Select Committee’s inquiry into young adult offenders. The inquiry aims to assess the implications of the findings of the Harris Review and selected recommendations for current policy and practice; examine the evidence on what might constitute more effective or appropriate treatment of young adults throughout the criminal justice process; and review the impact of guidance to sentencers and prosecutors which advises that they consider the maturity of the offender in their decisions. Our evidence supports the Transition to Adulthood Alliance submission and particularly highlights the role the voluntary sector has played in pioneering approaches for young adults as well highlighting a range of equalities issues that need to be considered with regards to this age group. Our submission along with all the other submissions of evidence, as well as the inquiry's full terms of reference and up to date news can be found on the Justice Select Committee's webpage.
Clinks Response - to the HM Inspectorate thematic inspection (September 2015)
Clinks has submitted evidence to the HM Inspectorate of Probation thematic inspection of work with women offenders. The Inspectorate are interested in establishing the current landscape for and the provision and gaps in services for women who offend. In our evidence we have highlighted key points in relation to the location, leadership and funding of women centres; barriers to gender-specific work; changes in the needs of female service users over the last two years and examples of good practice from the voluntary sector.
Clinks response to the Spending Review 2015 (September 2015)
‘A country that lives within its means’ outlines the government’s priorities for Spending Review 2015 and the principles that will guide its decisions. Clinks’ representation to the Spending Review 2015 focuses primarily on the review’s priorities around criminal justice and some of the other priority areas outlined which may impact on the Criminal Justice System (CJS) and the cost of providing services to those in contact with it. We concentrate on key issues for the CJS which may impact on costs and which we believe the Treasury and the Ministry of Justice should consider when assessing or developing policy proposals within the context of this Spending Review.
Clinks response to the Care Quality Commission's consultation on regulating and inspecting health and social care in prisons and young offender institutions, and healthcare in immigration removal centres (May 2015)
The Care Quality Commision (CQC) and HM Inspectorate of Prisons (HMIP) have developed a joint inspection framework which intends to support CQC and HMIP to develop a holistic and coherent view of health within secure settings. It aims to hold providers to account but also work with them to identify wider health issues. Clinks' response and recommendations to the CQC are based on discussion with Clinks members at two workshops which we held in London and Leeds.
Clinks responded to the Ministry of Justice consultation on the Secure College rules with a letter supporting the Prisoner Learning Alliance's response and also highlighting some additional points. The purpose of the rules will be to set out the core parameters within which Secure Colleges will be required to operate to ensure that young people are detained safely and securely, and that their educational and rehabilitative needs are addressed.
You can read Clinks response to the orginal consultation, Transforming Youth Custody, in which secure colleges were proposed below.
We have contributed to NCVO's response to the government's consultation on the UK transposition of new EU procurement directives. The response says that many of the problems associated with commissioning and procurement relate to poor decision-making, misplaced organisational priorities and risk averse behaviour.
Clinks has submitted a brief response to the Home Office’s consultation entitled ‘strengthening the law on domestic abuse’ and would support a change in the law that would help ensure all cases of domestic abuse are recognised and addressed. The response highlights that women's offending is often one of the longer-term potential consequences of coercive control in intimate relationships and have urged the Home Office to recognise this. We have also outlined the essential need for gender-specific services to be in place to provide support to women in the Criminal Justice System who are experiencing or have experienced coercive control.
Clinks has responded to the Labour’s party’s wide-ranging consultation, 'Renewing our bond with the third sector'. We work with all political parties to ensure that the experiences of our members inform policy decisions. In particular, it is essential that the Labour party and any incoming Labour government understand that the voluntary sector is in need of stable and committed support for the vital contribution it makes to rehabilitation and community safety, both as providers of services, as an essential strategic partner and an advocate for better services and policies. Labour should have a clearer vision for how it intends to support this work, and a more explicit recognition, in its policy messaging around criminal justice, of the contribution the sector makes. We make specific points on funding and good commissioning, the value of infrastructure, the role of ex-offenders as staff and volunteers, and the vital importance of the sector’s independent voice.
Clinks’ response to the Care Act (2014) consultation (August 2014)
Clinks have focused this short response to the Sentencing Council on female offenders as the sentencing guidelines for theft offences are disproportionately likely to affect them. The response makes a series of recommendations relating to culpability, as well we aggravating and mitigating factors for these offences.
Clinks’ interest in the Industry Standard Partnering Agreement (ISPA) stems from our role in supporting and representing the wider VCSE sector; we are not a potential provider of services under Transforming Rehabilitation (TR). The ISPA is the key practical document for voluntary organisations who are considering entering the new supply chains. Although it is designed to govern subcontracting arrangements in any future Ministry of Justice (MoJ) contracts, it has been keenly awaited with specific reference to TR since the start of the competition.
Clinks has therefore taken a keen interest in the ISPA and its role in ensuring that the VCSE sector is able to participate to its full potential in the new rehabilitation landscape, in line with the Government’s original vision of “opening up the market to a diverse range of new rehabilitation providers, so that we get the best out of the public, voluntary and private sectors, at the local as well as national level”.
Clinks has submitted evidence to the Ministry of Justice’s Triennial Review of the Parole Board. This is part of the process that all Non-Departmental Public Bodies (NDPB) are going through, and does not indicate any specific plan to discontinue the Board or change its functions. Our response highlights the importance of the Board’s continuing role as an independent body in ensuring decisions on parole are not perceived as being influenced by political priorities. We also argue that this should remain a national and not a local function. Finally, we suggest that the Parole Board could increase its engagement with the voluntary sector in order to benefit from the sector’s expertise.
Clinks has responded to the Justice Select Committee inquiry into Crime Reduction Policies, that focused on the Transforming Rehabilitation Proposals. We highlight our concern as to the low numbers of voluntary sector organisations that have currently signed up to provide services under TR, our questions regarding how the current payment mechanism would incentivise the provision of services that prioritise intermediate outcomes and outline that we would like to see the proposals offer a fair and genuine opportunity for the sector.
Transforming Management of Young Adults in Custody (December 2013)
Clinks has responded to a Ministry of Justice consultation on proposals to change the management of young adults in custody, most notably moving them from YOIs into mixed institutions. We recommend that a comprehensive approach to young adults in the CJS, as championed by T2A, should be developed as a precursor to engagement and support for these proposals from the VCSE Sector. This should include a much stronger business case for the rehabilitative benefits and practical details of how the new arrangements would operate both within custodial institutions and in the community.
Clinks are focusing this short response on benefit fraud, owing to the links with poverty and social inequality, yet some of the issues raised, particularly in relation to culpability measures and mitigating factors, are also relevant to the other fraud offences. As the Sentencing Council has itself noted during the events that have formed part of this consultation process, the sentencing guidelines for benefit fraud are likely to disproportionately affect women offenders.
Ministry of Justice Straw Man payment mechanism (July 2013)
Clinks has submitted a response to the first version of the Ministry of Justice’s proposed ‘Straw Man’ payment mechanism for the Transforming Rehabilitation reforms. While Clinks is grateful that some of the feedback from the Work Programme appears to have incorporated into this document, it feels that potential providers still require more detail on certain aspects of the payment mechanism and more information on how it will apply to subcontracted partners.
Ministry of Justice Equalities Questionnaire (July 2013)
Following the Transforming Rehabilitation consultation, the Ministry of Justice launched an online questionnaire to engage with organisations over minority groups of offenders with protected characteristics to inform round-table discussions and/or stakeholder meetings. Clinks' response focuses on service users from Black, Asian and Minority Ethnic backgrounds, age, and disability as consultation relating to women offenders is taking place separately.
Transforming youth custody (April 2013)
Whilst we welcome the broad intentions of the consultation document, we have raised issues around tailoring education to young people in custody, meeting the wider needs of young people in custody, a focus on outcomes and in particular a binary measure for payment by results commissioning of services, and equality and diversity. Clinks would also recommend that MoJ and YJB consider carefully how Secure Colleges, and education services in the secure estate more generally, can facilitate smooth transitions from youth to adult provision. This could be achieved through dialogue with partners in the Youth to Adult Transitions Forum and VCS organisations involved in the T2A pilots.
Clinks’ response has been informed by direct submissions from our members following a call for views on the consultation document in Light Lunch, and by feedback from participants in MoJ/NOMS consultation events. Clinks also chairs the Ministry of Justice Reducing Reoffending Third Sector Advisory Group (RR3) and in that capacity sought members’ views at the most recent RR3 meeting in January 2013.
Justice Select Committee inquiry into women offenders (September 2012)
This evidence is submitted jointly by Clinks and the Reducing Reoffending Third Sector Advisory Group (RR3). Clinks is the national umbrella body supporting Voluntary and Community Sector (VCS) organisations working with offenders and their families and provides the Secretariat to the RR3. The RR3 recently responded to a request by Crispin Blunt, Minister for Prisons and Probation, to convene a time-limited Task & Finish group to produce a series of recommendations on women. The resulting paper (published May 2012) addressed the need for a distinct national approach to women at risk of offending and discussed the urgent need for clarity over where responsibility for specialist services for women will be located in the shifting commissioning environment. The final paper with a full list of contributing VCS organisations accompanies this submission.
Clinks has responded to NOMS Commissioning Intentions Discussion Document 2013-2014. This response welcomes NOMS' recognition of the value of intermediate outcomes and outlines some of the difficulties faced by small and medium VCS organisations in evidencing their outcomes. It also considers potential opportunities for greater VCS involvement in local commissioning and procurement, and what the draft commissioning intentions could mean for women, young adult and BAME offenders.
Clinks response to MoJ review of Probation (June 2012)
Clinks has responded to the Probation Review, feeding in views from our four consultation events and input from our members. The response highlights the distinctive profile of the VCS working with offenders and the economic state of the sector as well as the appropriateness of different levels of commissioning, the implications of payment by results and the nature of risk.
Clinks response to NOMS Commissioning Intentions (March 2012)
Clinks welcomes the opportunity to respond to NOMS' 'live' Commissioning Intentions Discussion Document 2012-13. Clinks' response focuses on commissioners' engagement with the VCS, areas which have considerable potential for VCS involvement (particularly Integrated Offender Management and Restorative Justice), the challenges of evidence-based commissioning, commissioning services for specific groups within the criminal justice system (CJS), and expanding the use of volunteers in the CJS.
In this paper we respond to over 30 questions set out in the Labour Party's criminal justice working group. We draw on our work with the voluntary sector over the last 12 months to provide insight and recommendations on topics including measuring effectiveness, the role of the voluntary sector, sharing good practice, and achieving effective rehabilitation.
Clinks' written evidence on the new landscape of policing (written March '11, release for publication October '11)
In April 2011, Clinks submitted written evidence to the Home Affairs Committee inquiry into the new landscape of policing. The Committee has now published its full report, The New Landscape of Policing together with the oral and written evidence that it considered. Clinks’ submission stresses the key role to be played by the new Police and Crime Commissioners in ensuring that local VCS partners are engaged at both a strategic and operational level. The paper calls for the clarification of the new local commissioning structures, and makes a number of recommendations to ensure that there is sufficient VCS representation on the new Police and Crime Panels. It is hoped that the implementation of good partnership practice between the police and the VCS will allow the latter to act as an equal and independent partner in both the commissioning and delivery of local services.
Clinks and NCVYS welcome the direction of travel set out in the Consultation on the Secure Estate. In particular we support the principle of a distinct, specialist secure estate for children and young people and the focus on improving rehabilitation. Yet any strategy for the secure estate should be seen within the wider objectives of the Ministry of Justice to reduce the use of custody for young people. There is a clear need to develop effective alternatives for those young people for whom custody is not necessary.
On June 21st 2011 the Government published its response to the consultation on the Green Paper, ‘Breaking the Cycle’, alongside the Legal Aid, Sentencing and Punishment of Offenders Bill. Clinks very much welcomes the proposals in the Bill that bring greater flexibility to community sentences and restrict the use of remand. However, the Government’s response to the Breaking the Cycle consultation appears to mark a disappointing retreat from some of the more radical proposals outlined in the Green Paper earlier this year, which our extensive consultation with members enthusiastically endorsed. We have therefore submitted the attached paper to the MoJ, which sets out in greater detail our reaction to both documents.
'Breaking the Cycle' Green Paper (March 2011)
Clinks have published our response to the ‘Breaking the Cycle’ Green Paper. We very much support the ambition to reduce the prison population by reserving custodial sentencing to those offenders that present a risk of harm to the public. There is quite clearly a significant role for the VCS in supporting the Government to achieve this aim and to effect a significant reduction in reoffending. Clinks’ response addresses most, but not all, of the questions identified in the Green Paper. It is structured around key themes of particular relevance to the VCS working in the CJS, informed by the issues prioritised by workshop participants at our various consultation events across the country.
Modern Commissioning (January 2011)
Clinks has responded to the Cabinet Office Green Paper on Modern Commissioning, highlighting barriers and opportunities to VCS involvement and making recommendations to engage with the Sector.
Submission on Payment by Results (October 2010)
Clinks has coordinated a consultation with our members and other Voluntary and Community Sector (VCS) organisations on the implications of payment by results for the Criminal Justice System (CJS). In this paper, we bring together these perspectives to contribute to the preparation of the rehabilitation Green Paper.
Submission to the Government's review of Sentencing (September 2010)
Clinks welcomes the opportunity to respond to the request for comments that could contribute to a White Paper to be published in the Autumn. The suggestions are structured around the key stages in the criminal justice process and particularly identify the potential for the enhanced role of the VCS.
Submission to the Government's proposed 'Rehabilitation Revolution' (September 2010)
Clinks welcomes this opportunity to contribute to developing proposals for the Coalition government’s Rehabilitation Revolution ahead of a White Paper in the Autumn. We identify some key issues for the voluntary sector in terms of capacity and voice, argue for the greater involvement of ex-offenders in delivering the rehabilitation revolution, and point out some of the challenges in relation to the emerging regime of payment by results.
Submission to the governments' Comprehensive Spending Review (September 2010)
Clinks is pleased to contribute to the Spending Review. We welcome and endorse the government’s commitment to assess ‘how’ public money is spent rather than ‘how much’ is spent on public services, especially in the Criminal Justice System. As the organisation that supports VCS organisations that work with offenders and their families, we are encouraged that the future focus will be on radical and innovative ways to deliver services more effectively. The VCS has a track record in pioneering approaches to tackle difficult social problems in new ways.
The sector is defined by its innovative, flexiClble and user-focussed approach to service delivery; often achieving longer lasting outcomes for offenders. If the sector is to continue offering real choice to offenders, there must be a greater degree of inter-agency co-operation between organisations in the sector, driven by an increase in organisational capacity and skills.
We also endorse the strong statements supporting the role of the third sector in delivering services to offenders and contributing to reducing re-offending. In our response we will address specifically the questions identified in the document and then add some additional comments relating to two specific issues.
Clinks' Response to the Titan Prisons Consultation [August 2008]
The joint Clinks & Action for Prisoners Families response to the Ministry of Justice's Titan Prisons Consultation shows over 70% of our members thought Titans would present problems with their service delivery; almost 80% believed the size of Titan prisons would be an obstacle; 95% believed that Titans would not enhance the quality of family contact for prisoners; and 100% of respondents felt that the resources for Titan prisons should be re-directed to community-based provision for offenders.
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Clinks' Response to the NOMS Draft Action Plan [April 2008]
The NOMS Voluntary Sector Team recruited Clinks to undertake a number of consultation events to facilitate responses to the draft plan. The overall response to the draft Action Plan is informed by the aggregated responses from the workshops. We will now be looking forward to the final published version of the Action Plan with identified milestones and key actions for government departments.
Effective Sentencing - Clinks' Response to the Home Affairs Select Committee Inquiry [March 2007)]
The intention to use custodial sentencing for serious and violent offenders and to promote the use of community sentences for non-violent offenders is welcome. Clinks believes that there is very little merit in short prison sentences for non-violent offenders. This document details Clinks' response to the Home Affairs Select Committee Inquiry into 'Effective Sentencing' and how we believe this can be achieved.
Clinks' Response to Offender Management Bill [November 2006]
Clinks' circulation to members, expressing our stance on the Offender Management Bill, due for its Third Reading in the House of Commons in February 2007.
Response to 'Restructuring Probation to Reduce Re-offending' [December 2005]
Response to Home Office proposals that clearly have significant implications for both the Voluntary and Community Sector that currently delivers services to offenders and organisations who might be interested in doing so in the future.
Response to the National Action Plan for Reducing Re-Offending [September 2005]
Clinks commends the production of the National Action Plan and the commitment it gives across a range of government departments to tackle the issues impacting on reducing re-offending.
Response to draft NOMS Strategy on the role of the VCS [April 2005]
This response generally welcomes the acknowledgement of the significant and central contribution which the sector has already made to the work of the correctional agencies.
Response to the NOMS Community & Civil Renewal Strategy [September 2004]
Clinks particularly welcomes the opportunity to respond to the Communities and Civil Renewal Strategy as it promotes and encourages the contribution that a local, community-based approach can make to reducing re-offending.