Submission to the Executive Office’s Consultation on the Ending Violence Against Women and Girls Strategic Framework
Date produced: October 2023.
Below is a summary of our recommendations and messages.
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2.16 The NIHRC recommends that the Executive Office includes in the draft Strategic Framework a full and comprehensive list of relevant human rights standards with corresponding links.
3.7 The NIHRC recommends that the Executive Office makes explicit provision in the draft Strategic Framework for women and girls who are at an increased risk of violence or who face additional barriers to accessing justice, service provision and specialised support, including legal support. This should include ensuring that specialised services are consistently available and fully accessible.
3.13 The NIHRC recommends that the Executive Office makes clear in the draft Strategic Framework that support is available, regardless of immigration status, and that sufficient refuge places are available in NI according to need, in compliance with international human rights law.
3.14 The NIHRC recommends that the Executive Office ensures that the draft Strategic Framework ensures that refugee women and women seeking asylum are provided with information on their rights under domestic law in NI pertaining to violence against women and girls.
3.19 The NIHRC recommends that the Executive Office considers how the draft Strategic Framework can complement and enhance other government strategies which take a gender-neutral approach to issues which have a gendered effect.
3.23 The NIHRC recommends that the Executive Office, in partnership with other relevant NI departments, ensures that the draft Strategic Framework includes measures to address the effect of poverty in exacerbating violence against women and girls. This should include ensuring that specialised services are accessible and securely funded.
4.5 The NIHRC recommends that the Executive Office ensures that the draft Strategic Framework includes specific measures aimed at child victims of abuse, especially girls, and specifies how it will complement other strategies aimed at tackling abuse of children and young people.
4.6 The NIHRC recommends that the Executive Office ensures that the draft Strategic Framework is reflective of the Barnahus Model, and that this approach is incorporated across the criminal justice system when dealing with child victims.
5.7 The NIHRC recommends that the Executive Office ensures that the draft Strategic Framework provides for data collection that is disaggregated, regular, comprehensive and comparable.
5.8 The NIHRC recommends that the Executive Office ensures that the draft Strategic Framework provides for disaggregated data collection on violence against women and girls that is reflective and representative of NI society.
6.5 The NIHRC recommends that the Executive Office secures ring-fenced long-term funding that extends across the seven-year span of the draft Strategic Framework and that includes a contingency plan in the latter years of the draft Strategic Framework to ensure long-term initiatives can continue effectively without resource constraints.
7.7 The NIHRC recommends that the Executive Office considers Windsor Framework Article 2 within its current impact assessment framework, including Human Rights Impact Assessments to ensure continuity of human rights and equality protections.
7.8 The NIHRC recommends that, when assessing the impact of policy and legislation on Windsor Framework Article 2, the Executive Office and NI Departments should consider all EU law which underpins relevant ECHR rights and ensure there is no diminution of standards set out in the relevant EU law.
7.9 The NIHRC recommends that the Executive Office develops and implements training and guidance for departmental officials on Windsor Framework Article 2, including Impact Assessments, to embed consideration of Article 2 throughout legislative and policy processes.
7.13 The NIHRC recommends that the Executive Office’s draft Windsor Framework Impact Assessment identifies the relevance of the EU Recast Equal Treatment (Employment) Directive and the EU Equal Treatment (Self-Employment) Directive to the draft Strategic Framework and acknowledges the need to keep a watching brief on these Directives and relevant CJEU jurisprudence in relation to the draft Strategic Framework.
7.14 The NIHRC recommends that the Executive Office includes reference to the EU Recast Equal Treatment (Employment) Directive and the EU Equal Treatment (Self-Employment) Directive under its Human Rights Framework in the draft Strategic Framework.
7.16 The NIHRC recommends that Windsor Framework Impact Assessments consider all relevant provisions of EU law engaged under the Windsor Framework Article 2 commitment in relation to the legislation or policy being assessed, as well as screening for breaches of the commitment.
7.26 The NIHRC recommends that the Executive Office embeds consideration of the EU Victims’ Directive in its draft Strategic Framework.
7.27 The NIHRC recommends that the Executive Office define, in future Windsor Framework Impact Assessments, victims’ rights under the Belfast (Good Friday) Agreement to include all victims of crime and considers relevant provisions of the EU Victims’ Directive in future legislation and policy relating to victims of crime.
7.34 The NIHRC recommends that the Executive Office considers the EU Trafficking Directive and the EU Child Sexual Exploitation Directive in its Windsor Framework Impact Assessment and embeds these provisions within the draft Strategic Framework.
7.40 The NIHRC recommends that the Executive Office keep under review the proposed EU VAWG Directive and ensure that any potential updates to the EU Equality Directives are reflected in NI law in compliance with Windsor Framework Article 2.
7.41 The NIHRC recommends that, in addition to what is required by the keep pace obligation under the Windsor Framework and as a matter of good practice, the Executive Office should ensure NI law aligns, on a voluntary basis, with any enhancement to equality and human rights pursuant to the EU VAWG Directive.
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