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The National Referral Mechanism (NRM)

What is it for?

The NRM is the government’s system to identify potential victims of modern slavery and refer them for support. There is a two step process:

Step 1: Someone who shows signs that they are a victim of modern slavery is referred into the NRM. The Competent Authority, the NRM decision maker, then decides if they think there are reasonable grounds to believe that an individual is a victim of slavery or human trafficking. (‘Reasonable Grounds’ decision stage (RG))

Step 2: If the Competent Authority says this person might be a victim of modern slavery (they have a positive RG decision), the victim has a period where they can get some support to help them with recovery and the Competent Authority has more time to assess the case. When the Competent Authority is ready, they decide if they think the person is definitely a victim of modern slavery. (‘Conclusive Grounds’ decision stage (CG))

Who are the decision makers?

Decisions about who is recognised as a victim of modern slavery are made by one of the Competent Authorities (i.e. staff in the Home Office). The Single Competent Authority (SCA) was launched in April 2019 and the Immigration Enforcement Competent Authority (IECA) was created on 8 November 2021.

The IECA is the Competent Authority responsible for making NRM decisions in respect of:

  • Individuals detained in an Immigration Removal Centre (IRC) and who are ‘Foreign National Offenders’ (not defined)
  • Individuals who have immigration cases managed by the ‘National Returns Command’ casework team (this could apply to anyone in an IRC)
  • Individuals who have immigration cases managed by Third Country Unit (TCU)/’inadmissible process’ (whether detained or not)
  • All ‘Foreign Nationals Offenders’ in prisons (whether a deportation order was made or not); and
    All ‘Foreign National Offenders’ in the community (whether a deportation order was made or not).

The SCA is responsible for all other NRM decisions.

Following a positive CG decision, the Competent Authorities will also consider whether to grant temporary permission to stay in the UK.

Who can refer a potential victim of modern slavery into this system?

There are certain organisations (statutory and non-governmental and some charities) who can refer victims into this government system if they think that someone might be a victim of modern slavery. They are called ‘First Responders’. (There are different first responder organisations in Scotland and Northern Ireland to England and Wales. The information here is about the organisations in England and Wales.) First Responder organisations are meant to:

  • Identify potential victims of modern slavery and recognise the indicators of modern slavery
    Gather information in order to understand what has happened to them
  • Refer victims into the NRM via the NRM form (in England and Wales this includes notifying the Home Office if an adult victim doesn’t consent to being referred)
  • Provide a point of contact for the government to assist with making the reasonable and conclusive grounds decisions and to request a reconsideration of a negative decision where a First Responder believes it is appropriate to do so.

The current statutory and non-statutory First Responder organisations are:

  • police forces
  • certain parts of the Home Office:
    • UK Visas and Immigration
    • Border Force
    • Immigration Enforcement
    • National Crime Agency
  • local authorities
  • Gangmasters and Labour Abuse Authority (GLAA)
  • Salvation Army
  • Migrant Help
  • Medaille Trust
  • Kalayaan
  • Barnardo’s
  • Unseen
  • NSPCC (CTAC)
  • BAWSO
  • New Pathways
  • Refugee Council

For Scotland and Northern Ireland these are:

  • police forces
  • certain parts of the Home Office:
    • UK Visas and Immigration
    • Border Force
    • Immigration Enforcement
  • Gangmasters and Labour Abuse Authority (GLAA)
  • local authorities (Scotland)
  • health and social care trusts (Northern Ireland)
  • Salvation Army (Scotland)
  • Migrant Help (Scotland)
  • Trafficking Awareness Raising Alliance (TARA) (Scotland)
  • Belfast and Lisburn Women’s Aid (Northern Ireland)
  • Independent Child Guardian Service (Barnardo’s) (Northern Ireland)
  • Youth Work Alliance (Northern Ireland)

Completing the referral

First Responders complete a form saying why they think the person they have met is a victim of modern slavery. This has to be done online for adults and children. The same form is used for an NRM referral or informing the Home Office about possible victims (the ‘Duty to Notify’). The form will be sent to the SCA. After this, the First Responder will be sent a link to download a copy.

The government says this:

‘We recognise that first responders may be unable to provide significant detail about the individual and their potential modern slavery experience on this form (e.g. where an individual is seriously traumatised). However, it is important that all information available at this stage is provided on the form to support a timely reasonable grounds decision.’

Adults will only be accepted into the NRM if the consent section of the form has been completed. The First Responder is meant to make sure that the individual they are referring understands what is happening so there is informed consent. They should cover:

  • what the NRM is
  • what support is available through it
  • what the possible outcomes are for an individual being referred.

The government also says this to First Responders (which is worth bearing in mind if there were any problems in the NRM referral form or referral process):

‘The online referral should only be completed for adults when a member of staff from a designated first responder organisation suspects someone is a victim of modern slavery (see section 8) and where the adult concerned has understood the implications of, and consented to, the referral.
It is not to be used as an interview record but as a means for the first responder organisation to provide as much information as possible to the SCA to enable a decision to be reached.
This does not prevent the first responder from approaching the potential victim to obtain further details where appropriate, while avoiding placing them under unnecessary additional stress or trauma.’

Even though the NRM form is not designed to be used as an interview record but rather a mechanism for a First Responder to provide information to the SCA, ATLEU is aware of cases where information in the NRM has been used to say that an individual is not believable or credible because of discrepancies between the information on the NRM form and information from other sources. Individuals have the right to request a copy of the NRM form and they also have the right to comment on whether it is an accurate record. Please see our section on getting documents.

This also is why it is always important to check what victims know about the NRM, their referral and if they had what was written about them (particularly in the narrative section) read back in a language they understood. Please see our sections on Informed Consent, Data Sharing in the NRM, Police and the NRM and Housing and Support, because these are all topics that should be properly explained to survivors when they decide to give informed consent to enter the NRM.

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