My Lords, we dealt in the previous group of amendments with the distinction, or lack of it, between “reason to believe” and “reasonable grounds to believe”, and to which the noble Lord, Lord McColl,
referred. Here, just as on that issue, the guidance will be important in making clear the position. That is because the first few days are so critical, as the noble Lord and others have said.
Guidance will also be important as regards our international obligations, to which the noble Baroness, Lady Grey-Thompson, referred. Looking at Amendment 78, I have been wondering whether it is necessary to detail what are already obligations, or whether one should have simply the general umbrella description, so that we are not stuck on any particular points. It might be necessary because we are, we hope, making quite a step change. It might also be necessary because having them spelt out in primary legislation will be an easier route to a remedy through the courts; but I raise the point because, if the amendment is not accepted, the guidance will be important in that regard.
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I want to mention health provision in particular. On 6 April, regulations about charges to overseas visitors will come into force, and victims of trafficking will be exempt from certain charges. They are referred to as “victims of trafficking”, not as “victims of slavery and exploitation”; that may be because, by definition, we are talking about people who come from overseas, so they will be regarded as trafficked. I am not quite convinced about that, but there we go. It is not quite the thrust of my point this afternoon.
As I read the regulations, the exemption depends on a reasonable grounds decision. My wider point is that it might be important to refer a victim to a GP straightaway, not for one of the relevant conditions as spelt out in the regulations, but for a condition that would be less urgent in the case of another patient, but is particularly important here because a victim of trafficking needs quick attention and care. I do not discount the points that the noble Baroness, Lady Howarth, has just been making.
To come to the particular point for today, I wonder whether the noble Earl, Lord Howe, could consider including healthcare and perhaps other care in the pilots that are to be undertaken. Might there be a mechanism piloted as part of the new NRM to test turnaround times, for instance? There might be ways of recording the reasonable grounds assessment that could be quicker than the sort of bureaucracy that, all too often, gets in the way, involving, for example, telephones, emails and so on. My request to the Minister is that there be an imaginative and extensive use of pilot testing in the case of some of the items of care and support that are so important.