1. Police & Crime Commissioner comments:
1.1 I welcome the findings of this report which summarises the context and challenges faced by law enforcement in tackling the online sexual abuse and exploitation of children. The following sections set out how the Force are addressing the report’s recommendations, and I will monitor progress through my Office’s existing oversight mechanisms.
1.2 I have requested the Chief Constable’s view on the report, and he has stated:
The internet provides a readily accessible platform for distribution of child sexual abuse material, and for adults to groom, coerce and blackmail children to generate indecent imagery. The challenges are an increasing volume of cases, a need for multi-agency enforcement and safeguarding, limited resourcing and delays in investigations, and inadequate information sharing.Tim De Meyer, Chief Constable for Surrey Police
The report concludes that more is needed to be done to tackle the challenges faced and improve the response to online child sexual abuse, with 17 recommendations made. Many of these recommendations are jointly made for forces and National Police Chiefs’ Council (NPCC) leads, together with national and regional law enforcement agencies including the National Crime Agency (NCA) and Regional Organised Crime Units (ROCUs).
2. Response to Recommendations
2.1 Recommendation 1
2.2 By 31 October 2023, the National Police Chiefs’ Council lead for child protection should work with chief constables and chief officers with responsibilities for regional organised crime units to introduce regional collaboration and oversight structures to support the Pursue board. This should:
- improve the link between national and local leadership and the frontline response,
- provide detailed, consistent scrutiny of performance; and
- meet chief constables’ obligations for tackling online child sexual abuse and exploitation, as set out in the Strategic Policing Requirement.
2.3 Recommendation 2
2.4 By 31 October 2023, chief constables, the director general of the National Crime Agency and chief officers with responsibilities for regional organised crime units should make sure they have effective data collection and performance management information. This is so they can understand the nature and scale of online child sexual abuse and exploitation in real time and its impact on resources, and so forces and the National Crime Agency can react quickly to provide adequate resources to meet demand.
2.5 Response to recommendations 1 and 2 is being led by the NPCC lead (Ian Critchley).
2.6 South East region law enforcement resource prioritisation and coordination on child sexual exploitation and abuse (CSEA) is currently led through a Vulnerability Strategic Governance Group, chaired by Surrey Police ACC Macpherson. This oversees tactical activity and coordination through the CSAE Thematic delivery group led by Surrey Police Chief Supt Chris Raymer. Meetings review management information data and current trends, threats or issues.
2.7 At this time Surrey Police expect that the governance structures in place and that the information collated for these meetings will align with requirements for national oversight, however this will be reviewed once this is published.
2.8 Recommendation 3
2.9 By 31 October 2023, the National Police Chiefs’ Council lead for child protection, the director general of the National Crime Agency and the chief executive of the College of Policing should jointly agree and publish interim guidance for all officers and staff dealing with online child sexual abuse and exploitation. The guidance should set out their expectations and reflect the findings of this inspection. It should be incorporated into subsequent revisions and additions to authorised professional practice.
2.10 Surrey Police await publication of said guidance, and is contributing to the development of this through sharing our internal policies and processes which currently provide an efficient and well organised response.
2.11 Recommendation 4
2.12 By 30 April 2024, the chief executive of the College of Policing, in consultation with the National Police Chiefs’ Council lead for child protection and the director general of the National Crime Agency, should design and make available sufficient training material to make sure frontline staff and specialist investigators dealing with online child sexual abuse and exploitation can receive the right training to carry out their roles.
2.13 Recommendation 5
2.14 By 30 April 2025, chief constables should make sure officers and staff dealing with online child sexual abuse and exploitation have completed the right training to carry out their roles.
2.15 Surrey Police await publication of said training and will deliver to the target audience. This is an area in need of distinct, well-defined training especially given the scale and changing nature of the threat. A single, central provision of this provides good value for money.
2.16 Surrey Police Paedophile Online Investigation Team (POLIT) is a dedicated team for investigating online child sexual abuse and exploitation. This team is well-equipped and trained for their role with structured induction, qualification and continuing professional development.
2.17 A training needs assessment is currently underway for officers outside POLIT in readiness for receipt of national training material. Every officer who is required to view and grade indecent images of children is nationally accredited to do so, with the appropriate wellbeing provisions in place.
2.18 Recommendation 6
2.19 By 31 July 2023, the National Police Chiefs’ Council lead for child protection should provide the new prioritisation tool to law enforcement bodies. It should include:
- expected timescales for action;
- clear expectations about who should use it and when; and
- who cases should be allocated to.
Then, 12 months after those bodies have implemented the tool, the National Police Chiefs’ Council lead for child protection should review its effectiveness and, if necessary, make amendments.
2.20 Surrey Police currently await delivery of the prioritisation tool. In the interim a locally developed tool is in place to assess risk and prioritise accordingly. There is a clearly defined pathway for receipt, development, and subsequent investigation of online child abuse referrals into the Force.
2.21 Recommendation 7
2.22 By 31 October 2023, the Home Office and relevant National Police Chiefs’ Council leads should consider the scope of the Transforming Forensics Rape Response Project to assess the feasibility of including online child sexual abuse and exploitation cases in it.
2.23 Surrey Police currently await direction from the Home Office and NPCC leads.
2.24 Recommendation 8
2.25 By 31 July 2023, chief constables should satisfy themselves that they are correctly sharing information and making referrals to their statutory safeguarding partners in cases of online child sexual abuse and exploitation. This is to make sure they are fulfilling their statutory obligations, placing the protection of children at the centre of their approach, and agreeing joint plans to better protect children who are at risk.
2.26 In 2021 Surrey Police agreed a process for information sharing with Surrey Children’s Services at the earliest possible stage after risk to children was identified. We also use the Local Authority Designated Officers (LADO) referral pathway. Both are well-embedded and subject to periodic regulatory scrutiny.
2.27 Recommendation 9
2.28 By 31 October 2023, chief constables and police and crime commissioners should make sure their commissioned services for children, and the process for referring them for support or therapeutic services, are available for children affected by online sexual abuse and exploitation.
2.29 For Surrey resident child victims, commissioned services are accessed through The Solace Centre, (Sexual Assault Referral Centre – SARC). The referral policy is currently being reviewed and rewritten for clarity. This is expected to be complete by July 2023. The PCC commissions Surrey and Borders NHS Trust to provide STARS (Sexual Trauma Assessment Recovery Service, which specialises in supporting and providing therapeutic interventions to children and young people who have suffered sexual trauma in Surrey. The service supports children and young people up to age 18 years who have been impacted by sexual violence. Funding has been provided to enable the service to be extended to support young people up to age 25 years who live in Surrey. This closes an identified gap for young people coming into the service at age 17+ who then had to be discharged from the service at 18 years regardless of whether their treatment was complete. There is no equivalent service in Adult Mental Health Services.
2.30 Surrey OPCC has also commissioned the YMCA WiSE (What is Sexual Exploitation) project to work in Surrey. Three WiSE workers are aligned to Child Exploitation and Missing Units and work in partnership with police and other agencies to support children at risk of, or experiencing, physical or online child sexual exploitation. Workers take a trauma informed approach and use a holistic support model to build safe and stable environments for children and young people, completing meaningful psycho-educational work to reduce and/or prevent the risk of sexual exploitation as well as other key risks.
2.31 STARS and WiSE are part of a network of support services commissioned by the PCC – which also includes, the Victim and Witness Care Unit and Child Independent Sexual Violence Advisors. These services support children with all their needs when going through the justice system. This involves complex multi-agency work for wrap-around care during this period e.g. working with child’s school and children’s services.
2.32 For child victims of crimes who live outside the County, referral is via Surrey Police Single Point of Access, for submission to their home force area Multi-Agency Safeguarding Hub (MASH). Force policy sets out the submission criteria.
2.33 Recommendation 10
2.34 The Home Office and the Department for Science, Innovation and Technology should continue working together to make sure online safety legislation requires the relevant companies to develop and use effective and accurate tools and technologies to identify child sexual abuse material, whether or not it was previously known. These tools and technologies should prevent that material being uploaded or shared, including in end-to-end encrypted services. Companies should also be required to locate, remove and report the presence of that material to the designated body.
2.35 This recommendation is led by Home Office colleagues and DSIT.
2.36 Recommendation 11
2.37 By 31 July 2023, chief constables and police and crime commissioners should review the advice they publish, and, if necessary, revise it, to make sure it is consistent with the National Crime Agency’s ThinkUKnow (Child Exploitation and Online Protection) material.
2.38 Surrey Police complies with this recommendation. Surrey Police references and signposts to ThinkUKnow. Content is managed through a media single point of contact in the Surrey Police Corporate Communications Team and is either national campaign material or locally produced via our POLIT unit. Both sources are compatible with the ThinkUKnow material.
2.39 Recommendation 12
2.40 By 31 October 2023, chief constables in England should satisfy themselves that their forces’ work with schools is consistent with the national curriculum and National Crime Agency educational products on online child sexual abuse and exploitation. They should also make sure this work is targeted based on joint analysis with their safeguarding partners.
2.41 Surrey Police complies with this recommendation. The POLIT prevent officer is a qualified Child Exploitation and Online Protection (CEOP) Education Ambassador and delivers CEOP ThinkUKnow curriculum material to partners, children and to the force’s Youth Engagement Officers to engage with schools on a more regular basis. A process is in place to identify hotspot areas of need to deliver bespoke targeted prevention advice using CEOP material, as well as creation of a joint partnership review process. This will progress to develop advice and guidance for response officers and child abuse teams, using CEOP material in the same way.
2.42 Recommendation 13
2.43 With immediate effect, chief constables should satisfy themselves that their crime allocation policies make sure online child sexual abuse and exploitation cases are allocated to those with the necessary skills and training to investigate them.
2.44 Surrey Police complies with this recommendation. There is an overarching force crime allocation policy for online child sexual abuse allocation. Depending on the route into force this directs crimes directly to POLIT or to the Child Abuse Teams on each Division.
2.45 Recommendation 14
2.46 With immediate effect, chief constables should make sure their force meets any existing recommended timescales for activity targeting online child sexual abuse and exploitation, and arrange their resources to meet those timescales. Then, six months after the new prioritisation tool is implemented, they should carry out a similar review.
2.47 Surrey Police meets the timescales set out in force policy for intervention timeframes after risk assessment completion. This internal policy broadly mirrors the KIRAT (Kent Internet Risk Assessment Tool) but extends the applicable timescales for Medium and Low risk cases, to reflect the criteria, availability and timescales set and offered for non-urgent warrant applications by Surrey His Majesty’s Courts and Tribunals Service (HMCTS). To mitigate the extended timeframes, the policy directs regular review periods to reassess risk and escalate if necessary.
2.48 Recommendation 15
2.49 By 31 October 2023, the National Police Chiefs’ Council lead for child protection, chief officers with responsibilities for regional organised crime units and the director general of the National Crime Agency (NCA) should review the process for allocating online child sexual abuse and exploitation investigations, so they are investigated by the most appropriate resource. This should include a prompt way of returning cases to the NCA when forces establish that the case needs NCA capabilities to investigate it.
2.50 This recommendation is led by NPCC and NCA.
2.51 Recommendation 16
2.52 By 31 October 2023, chief constables should work with their local criminal justice boards to review and, if necessary, amend the arrangements for applying for search warrants. This is to make sure the police can secure warrants quickly when children are at risk. This review should include the feasibility of remote communication.
2.53 Surrey Police meets this recommendation. All warrants are applied for and obtained using an online booking system with a published calendar accessible to investigators. An out of hours process is in place for urgent warrant applications, via the Clark of the Court who will provide details of an on-call Magistrate. In cases where increased risk has been identified but the case does not meet the threshold for an urgent warrant application, greater use of PACE powers has been implemented to ensure early arrest and searches of premises.
2.54 Recommendation 17
2.55 By 31 July 2023, the National Police Chiefs’ Council lead for child protection, the director general of the National Crime Agency and the chief executive of the College of Policing should review and, if necessary, amend the information packs given to families of suspects to make sure they are consistent nationally (notwithstanding local services) and that they include information that is age-appropriate for children in the household.
2.56 This recommendation is led by NPCC, NCA and the College of Policing.
2.57 In the interim Surrey Police use the Lucy Faithfull Foundation suspect and family packs, providing these to every offender and their families. Suspect packs also include material on investigative processes and signpost welfare support provision.
Police and Crime Commissioner for Surrey