Action Alert: Tell Brighton & Hove City Council to stop promoting police crackdowns against sex workers

UPDATE: Survey deadline has been extended to Thursday 31 May. If you live, work or travel to Brighton & Hove, please urgently respond to this action alert and share with your networks.:


Note: Many of the consultation survey questions are multiple choice, but please raise the points below where possible. Information not submitted through this format will not be taken in to consideration by the Community Safety Partnership at this point.




Brighton & Hove Community Safety Partnership is reviewing its local Violence Against Women and Girls (VAWG) Strategy. The current policy is very problematic. It labels prostitution as a form of violence and exploitation, promotes the closure of premises where sex workers are working together, and promotes the criminalisation of clients.

Labelling prostitution as violence invites a police crackdown on sex workers in the name of tackling violence against women. Crackdowns mean sex workers are running from the police and can’t work together in premises without falling foul of the brothel-keeping law. Fear of arrest deters sex workers from reporting rape and other violence. The ECP objected to the Brighton & Hove 2012-2017 policy including because it is committed to: “taking action to close sex-industry establishments and prosecuting brothel owners or managers”. Even senior police officers have voiced concerns that “operations to tackle the trade are ‘counterproductive’ and likely to put the lives of women at risk.”

Brighton and Hove City Council’s VAWG Strategic Commissioner claimed that they are constrained in what they can recommend because prostitution is illegal. But they have no qualms about promoting the criminalisation of clients[1] ignoring evidence that this would increase stigma and discrimination against sex workers.[2] In any case a Violence Against Women and Girls strategy can and should document and challenge the injustice and increased vulnerability to women caused by the current laws (which force sex workers of all genders to work in isolation and deter us from reporting violence for fear of arrest). Other councils, such as Edinburgh and Leeds have.

This is a chance to make your views known and determine what happens in your local area about prostitution. Please tell Brighton & Hove to change its VAWG policy so that a) prostitution isn’t conflated with violence, b) it doesn’t promote police crackdowns against sex workers, c) it documents the harm and increased risk of violence caused to sex workers by the prostitution laws. If we can change the Brighton & Hove VAWG policy it sets a precedent for other local councils to follow suit.

Please fill in the consultation survey here


  • Any reference to prostitution as a form of sexual exploitation and violence[3] must be removed from the policy. All other measures are discredited and distorted by defining prostitution in this way. Exploitation should be defined and tackled in the same way as it is in other industries. The Crown Prosecution Service (CPS) policy also defines prostitution as violence; no distinction is made in prosecution priorities between small collectives, where women work co-operatively, keep their own money and set their own hours and establishments run by coercive bosses.
  • There must be recognition in the VAWG policy that criminalisation undermines sex workers’ safety on the street and indoors by forcing people to work in isolation and deterring sex workers from reporting violence for fear of arrest.
  • References to promoting crackdowns and brothel closures[4] must be deleted as these put sex workers at greater risk of attack.[5]Women Against Rape has highlighted the appalling 6.5% conviction rate for reported rape. The rate in Sussex is comparable. Tackling reported rape must be the priority of Sussex Police and the CPS.
  • The criminalisation of clients must not be promoted in the policy. Evidence from Sweden where a law criminalising clients was introduced in 1999, shows that it has had a devastating effect on the rights, health and safety of sex workers.[6]
  • The strategy should include measures to tackle the impact of austerity cuts, which have disproportionately fallen on women,[7] and which in other areas are directly related to an increase in prostitution.[8] Concerns expressed in the Strategy[9] about the number of women in sex work through lack of choice would be better addressed by measures to reduce poverty,[10] homelessness[11] high rents and low wages[12] in Brighton & Hove.
  • References to a zero tolerance to lap dancing clubs should be removed.[13] See East London Strippers Collective article for more information.
  • There should be a commitment to looking at the success of decriminalisation in New Zealand.
  • Yes, we want more services, but not those that collaborate with the criminal justice system. For those of us who want to get out of prostitution we need money and resources and not punitive rehabilitation programs.
  • Since the last Brighton policy was published, the Home Affairs Committee has recommended a change in the lawso that soliciting is no longer an offence” and so that “brothel-keeping provisions allow sex workers to share premises”. Crucially the Committee also called for a law to delete “previous convictions and cautions for prostitution from the record of sex workers”, and rejected proposals to recommend the criminalisation of clients, saying that such legislation “makes no attempt to discriminate between prostitution which occurs between two consenting adults, and that which involves exploitation” and “can be misused to harass and victimise sex workers.”


The survey can be completed entirely anonymously. There is the option to leave contact details at the end if the person would like to participate in a follow-up focus group (for victims/survivors) or would like to be kept up to date with how the strategy is progressing.

Alternatively, contact details can be emailed separately to to ensure the person’s survey answers are kept anonymous. The only person to view the survey answers will be a researcher at AVA. All answers will be stored on a password-protected computer and will be deleted once the final consultation report has been produced.


The ECP met with the VAWG Strategic Commissioner in January 2016 and gave input into the VAWG 2012 – 2017 strategy, specifically on the issue of sex work. We objected to prostitution being defined as violence and suggested some changes along the lines of the points mentioned above.

Brighton & Hove City Council have since conducted a Public Health Rapid Needs Assessment and Action Plan on Sex Work in Brighton & Hove (with no direct consultation with sex workers) looking at “the size and nature of the sex industry; the risks and needs of people involved; the impact on the city and what helps and hinders support to those engaged in the sex industry”.

ECP did not participate directly in the consultation but did provide feedback and evidence that criminalisation and crackdowns prevent sex workers reporting violence.

Information came from local service providers who say they work with sex workers or was drawn from earlier research projects. The illegality of sex work means that most sex workers won’t compromise their anonymity to report their existence, experience and needs to the Community Safety team, local organisations or anyone else in authority. The report is lacking as a result and that should be a major concern. Additionally, for sex workers, these documents and process have little validity whilst the VAWG strategy on which they are founded is flawed, discriminatory and misrepresents our situation and demands.

Brighton and Hove City Council’s Community Safety Partnership have now commissioned a national charity, AVA, to conduct an independent consultation to gather the views of those who live, work or travel to Brighton & Hove and East Sussex on domestic violence and abuse and sexual violence against women and children in view of updating the VAWG strategy.



[1] Brighton & Hove has made a commitment to: Increase protection of women and girls individually, and collectively as a group, which also involves challenging and minimising the demand produced by men who buy sex which increases the market for commercial sexual exploitation and trafficking, harms women and girls as a group and inhibits progress towards gender equality” p38
[2] English Collective of Prostitutes. (2015). Decriminalisation of Prostitution: the Evidence. p5
[3] [“The term “violence against women and girls” (VAWG) used in this strategy is therefore taken to refer to the range of crime types which are predominantly, but not exclusively, experienced by women and girls which include: … Sexual exploitation, including commercially through prostitution and the sex industry” page 5]
[4] Work with colleagues in Licensing in relation to the new legislative powers available to Local Authorities that surround the licensing of Sexual Entertainment Venues in the city, such as lap-dancing clubs, in order to limit the numbers, and work towards a zero tolerance, of sexual entertainment and sex-industry establishments” p38
[5] Evidence from National Ugly Mugs shows that where arrests of sex workers and clients were high, only 5% of sex workers who were a victim of a crime reported it. This compared to 46% of victims in areas where police adopted a harm reduction approach.
[6] English Collective of Prostitutes. (2015). Decriminalisation of Prostitution: the Evidence. p5
[7] The Guardian, 9 March 2017.
[8] Doncaster reports a 60% increase (The Star, 19 March 2014), Sheffield 166% (The Star, 1 June 2014), while charity workers in Hull report: “ . . . women who are literally starving and they are out there to feed themselves.”
[9] The strategy states that sex work is “necessitated by a lack of choices and opportunities”. p9
[10] One of the busiest food banks in the city has seen a 62 per cent increase in the number of people referred to it for emergency food supplies between April and September 2017 – that is an additional 246 three-day emergency food supplies provided to local people in crisis –compared with the same period in the previous year. The figure has been put down to continued issues with benefits payments, with nearly 60 per cent of the reasons given for referral relating to benefit changes or delays in receiving money. The Argus, 8 November 2017.
[11] National homeless charity Shelter released a list putting Brighton and Hove in second place for the local authority with the highest rates of people recorded as homeless. It says 4, 218 people are recorded as rough sleeping or living in temporary accommodation – that is one in 69 people. Ibid.
[12] Rent and house prices have soured whilst wages have stayed low. The average one-bedroom flat costs nearly nine times the median household annual income and a three-bed house costs 16 times the median household annual income. Brighton & Hove Green Party. (2018).
[13] “Work with colleagues in Licensing in relation to the new legislative powers available to Local Authorities that surround the licensing of Sexual Entertainment Venues in the city, such as lap-dancing clubs, in order to limit the numbers, and work towards a zero tolerance, of sexual
entertainment and sex-industry establishments.” p38