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)

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