Northern Territory Council of Social Service

NTCOSS submission to the Review of the Legislation and the Justice Response to Domestic Violence in the Northern Territory

NTCOSS response to the Review of the Legislation and the Justice Response to Domestic Violence in the Northern Territory
The Northern Territory Council of Social Service (NTCOSS) is the peak body for the Northern Territory (NT) Community and Social Services Sector and is a voice for people affected by social and economic disadvantage and inequality. NTCOSS membership is made up of community managed, non-government, not for profit organisations, which work in social and community service delivery, sector development and advocacy. The community sector plays a vital role in creating social wellbeing for all Territorians and in building safe and healthy communities by providing services that enable people to access and participate in health services, education, employment, economic development, and family and community life.


All people have the right to live a life free from violence, and NTCOSS is a strong advocate for putting an end to all forms of domestic, family and sexual violence (DFSV) in our communities and working to address the related social harms. NTCOSS advocates for and with the specialist DFSV service sector in the NT to improve safety, wellbeing, economic and social justice outcomes for individuals and communities impacted by DFSV.


NTCOSS welcomes the opportunity to provide a submission in response to Review of the Legislation and the Justice Response to Domestic Violence in the Northern Territory (the Review). This submission will establish several key points in response to the review document relating to systemic reform across the Territory, along with direct responses to specific suggested reforms. Coercive control and the legislative review component will be addressed in a second submission to the Department on 9 November 2022.


NTCOSS represents a varied service sector, with members bringing different experiences and perspectives relating to DFSV from across the region. NTCOSS acknowledges that a number of member organisations with specific expertise in this area have also provided submissions. In particular, NTCOSS supports submissions by Aboriginal community-controlled member organisations (ACCOs), including the Family Violence Legal Prevention Services’ of the Northern Territory (North Australian Aboriginal Family Legal Service and Central Australian Aboriginal Family Legal Unit) and North Australian Aboriginal Justice Agency (NAAJA) , networks representative of DFSV member organisations across the Territory, and members that provide specialist DFSV services and legal services (noting the submission provided by the NT Women’s Legal Services)1. NTCOSS acknowledges the endorsement of the below submission by the Women’s Safety Services of Central Australia and the Central Australia Family Violence and Sexual Assault Network. NTCOSS acknowledges the feedback and contributions by the NTCOSS DFSV Group to this submission.

Background
The Review is ambitious and explores a range of avenues for systemic and legislative reform, noting the parameters to:

  1. improve the responsiveness of the justice system to victim-survivors and people who commit DFV;
  2. prioritise the safety and well-being of DFV victim-survivors, including children who are exposed to, and impacted by, DFV;
  3. increase the accountability of offenders for their conduct, and increase opportunities and motivation for them to change their behaviour;
  4. take into account the high percentage of Aboriginal families affected by DFV in the NT and ensure responses are culturally safe and appropriate and informed by the principles in the Aboriginal Justice Agreement (AJA); and
  5. consider whether criminalising coercive control is likely to contribute to improved responses to DFV in the NT.
    This submission will provide general advice regarding the implementation of any such Systemic Reforms (SR), while then providing specific advice on SR recommendations as put forward in the Review paper.
    Noting the policy context and methodology of the Review, previous recommendations provided to Government throughout the various consultations processes undertaken over the last term of government pertaining to DFSV reform, informed by broader engagement with the community sector and the specialist DFSV sector, will be drawn on to inform this response.
    In 2021 NTCOSS carried out a series of consultations across the Territory relating to the development of Action Plan 2 under the Northern Territory’s Domestic, Family and Sexual Violence Reduction Framework 2018-2028: Safe, Respected and Free of Violence (the Reduction Framework). While noting that the work around the implementation of Action Plan 2 has progressed through the development of the DFSV- Interagency Coordination Reform Office (DFSV-ICRO), many of the key points of these consultations are still relevant today and to the suggested systemic changes as part of the Review. This submission is available at Attachment A.
    Summary points from this include;
  • Ensure that organisations and communities with specialist expertise and knowledge are central to any approach
  • Increase cultural diversity and lived experience in regard to forums that influence government policy
  • Evaluation and monitoring must be central to any future implementation; and
  • Reforms must be fully costed before implementation and all reforms must be adequately resourced and prioritised in their delivery

NTCOSS’ submission on the draft National Plan to End Violence Against Women and Children 2022-2032 has also been included, and can be viewed at Attachment B.
NTCOSS notes the Review’s position that ‘sexual violence is a form of DFV if the victim-survivor and the offender are in a domestic relationship, including a sexual offence committed by a partner, ex partner or family member… legislative reform in relation to sexual offences is being considered by the Government separately, and is not included in this review’. While acknowledging this, NTCOSS has chosen to use the term DFSV throughout this paper to reflect the work being carried out across Government as part of the DFSV-ICRO and the terminology used in the Reduction Framework, the cornerstone of DFSV reform in the Territory. In addition to this, it is important that any recommendations adopted as part of the Review relating to SR include DFSV, not just DFV.
Where a specific response has not been provided relating to a SR, this can be taken as support for this recommendation.

General overview

  • Over the last term of the current government, there has been a progressive reform agenda relating to DFSV and other government initiatives (such as the Aboriginal Justice Agreement). Many community sector organisations, community members and government agencies participated in this reform work, attending consultations, providing submissions, feedback and engaging with the implementation of the various frameworks. Noting the resourcing already provided in this space, it is critical that any implementation of the SR recommendations are reflective of this.
  • NTCOSS notes feedback from members regarding the need for victim-survivor safety to be the priority for all responses and programs and to be a cornerstone of reform across the Review, not just under specific SR areas.
  • As the DFSV-ICRO is the current mechanism in place to coordinate the NT Government’s (NTG) reform agenda pertaining to DFSV, and therefore responsible for leading many of the suggested outcomes of the Review, it is critical that the NTG consults with the sector and agencies on any mechanism to proceed the DFSV-ICRO following the 12-month period it has been stood up for. While such a mechanism is alluded to in the Review, there is nothing yet committed to by Government to ensure the continuation of this work.
  • NTCOSS notes member feedback regarding the lack of mention of women who are both users and victim-survivors of DFSV across the scope of the SR. This is of particular concern noting the perceived, ongoing injustice in the gendered difference in the sentencing of men and women for violent crimes.2 While NTCOSS will expand on this in the response to the legislative review component, it is important it is kept in view across SR.
  • Further to the above, while NTCOSS recognises that the Review is an outstanding action from Action Plan 1 (2018-2021) under the Reduction Framework contributing to Outcome 5,3 the postponed released of Action Plan 2, with consultations, recommendations and reform areas put forward as part of this work reflecting the outstanding actions from Action Plan 1, must be noted. Some work has progressed past Action Plan 1, such as through the current DFSV Theory of Change development for the Reduction Framework, and through the progression of the Safe, Respected and Free from Violence Grants and Partnership Grants. This work must be acknowledged through this process.

COERCIVE CONTROL
NTCOSS has received member feedback relating to coercive control and notes that there is a lack of consensus relating to this issue. Despite this, the majority of members support Option 1 as defined within the review paper to ‘not criminalise coercive control but immediately prioritise a raft of other legislative and systemic reforms (over four years) to improve the justice response to DFV and coercive control (as set out above). This option provides an opportunity to evaluate how effective these reforms have been, and for any future decisions about whether coercive control should be criminalised in the NT to be informed by that evaluation, along with the experience in other jurisdictions’. NTCOSS will further expand on this position when responding to legislative reforms. Please refer to the supplementary submission upon release.
PROPOSAL SR 1
It is proposed that the systems reforms identified in this review are integrated into the DFSV-ICRO reform agenda.
NTCOSS supports all DFSV reforms being integrated into the work of the DFSV-ICRO over the prescribed time the DFSV-ICRO is stood up, noting the DFSV-ICRO’s remit to establish a whole of government reform agenda for DFSV. Ensuring that DFSV reforms are aligned across Government with appropriate evaluation and monitoring embedded within the reform agenda, and adequately funded across agencies, is critical to success.

PROPOSAL SR 2
It is proposed that DFV reforms and AJA reforms are aligned to ensure that:
a. the views and experiences of Aboriginal people inform DFV reforms;
b. DFV responses and programs are culturally safe and competent;
c. victim-survivor safety is the first priority of all responses and programs;
d. offenders are supported to take responsibility for their behaviour and to change their behaviour in order to reduce DFV offending and reoffending;
e. in addition to behaviour change objectives, there are culturally appropriate supports in place to ensure that Aboriginal women, Aboriginal men, and Aboriginal children are supported to heal from inter-generational trauma and recent trauma.


NTCOSS supports the recommendations under SR2. Noting that the NTG is signatory to the Aboriginal Peaks of the Northern Territory (APONT) Partnership Principals4 and to Closing the Gap, priorities pertaining to centring Aboriginal voices, experiences and cultural safety should already be embedded across the NTG’s reform agenda in all social areas.
NTCOSS notes member feedback that stronger alignment with Priority Reform 1 under Closing the Gap,5 means all parties to the Agreement should recognise that adequate resourcing is needed to support the ACCO sector, including specialist DFSV services in this space, to partner with relevant. governments on matters that impact their communities. Further, members have raised the need that for the NTG to align with Priority Reform 2
6 under the Agreement, funding prioritisation policies which preference ACCOs with relevant and appropriate expertise to deliver services relating to specific outcomes for Aboriginal people should be prioritised.
NTCOSS recommends the introduction of an integrated assessment tool (ongoing and not just bound to the Review) that demonstrates how the reform agenda and alignment of various frameworks is adhered to across agencies and the community sector to align with these principles and reform areas.
NTCOSS notes member support for the development of minimum standards relating to cultural safety within organisations and agencies to inform best practice in the development and implementation of programs.

PROPOSAL SR 3
It is proposed that reforms to community-based sentencing options and the expansion of programs:
a. are informed by specialist expertise on DFV, and
b. include safeguards to monitor and prioritise the safety of victim-survivors while DFV offenders are on community-based orders and participating in community-based programs.
NTCOSS notes support for the proposed changes to Mandatory Sentencing and Reform of Community Based Sentencing Options, however acknowledges feedback and concern from members regarding the consultation process taken regarding reform in this space. NTCOSS provided feedback at the time directly to the Department of the Attorney-General and Justice regarding these concerns, specifically the need to ensure adequate consultation, resourcing and time provided for the sector to participate in the ongoing reform process, and for the reform to be embedded within the DFSV-ICRO’s work where intersections exist with DFSV responses
NTCOSS notes feedback from members concerning the current resourcing level of community-based programs (of note, men’s behaviour change programs inclusive of partner support work). NTCOSS expands on feedback on such programs at SR10 and SR22.

PROPOSAL SR 5
It is proposed that collaboration between stakeholders occur to agree on shared expectations of the justice response, with the above expectations as a starting point for discussion.
NTCOSS supports collaboration between stakeholders to inform justice responses and meet shared expectations, using findings from previous consultations and work carried out. This echoes sentiment from the Action Plan 2 consultations, which called for a more integrated and collaborative approach to service systems. While NTCOSS supports SR5, processes must be determined regarding what constitutes effective collaboration to define this moving forward (noting comment under SR3 regarding concern from members). NTCOSS also notes member feedback assessing the need for trauma informed and culturally appropriate responses as part of these shared expectations of the justice response.

PROPOSAL SR 7
It is proposed that the DFSV-ICRO reform agenda include consideration of funding for TFHC to implement an extensive program of community awareness raising about coercive control and DFV. The project will empower Aboriginal families and communities to identify, prevent and respond to coercive control through culturally safe and appropriate community-level engagement. The project aims to initiate greater community action on DFV and coercive control on an ongoing basis, through a range of non-government agencies and through involvement of the Law and Justice Groups, established under the AJA.
While NTCOSS supports SR7 and the establishment of campaigns to increase community awareness relating to coercive control and DFSV, emphasis needs to be placed on integrating any such work within the current commitments being sought under Action Plan 2 and determined throughout this previous consultation process, particularly relating to evaluating and monitoring programs that are currently underway to inform success and adequate resourcing for primary prevention and early intervention responses. Along with this, aligning responses as defined under SR2 is recommended.
NTCOSS also notes that while funding could be directed to TFHC to implement an extensive program of community awareness raising about coercive control and DFSV, it is critical that any such program is implemented and supported as a whole of government response and initiative. Breaking down silos between agencies as part of DFSV responses is vital for long term change.

PROPOSAL SR 8
It is proposed that the DFSV-ICRO reform agenda include consideration of funding to significantly expand the availability of training in relation to DFV, including training and education specifically tailored to police, prosecutors, judges, lawyers and front-line workers to assist in identifying and responding to coercive control and DFV.
Please refer to response under SR23.

PROPOSAL SR 9
It is proposed that the DFSV-ICRO reform agenda include consideration of a major NT-wide public health campaign about healthy and safe relationships, to make people aware that coercive control is a form of DFV.
Refer to SR7.

PROPOSAL SR 10
It is proposed that the NT progressively work towards a specialist approach to DFV (incorporating civil and criminal law) centred around the Local Court in the following areas:
Southern Region
• continuation of the Specialist Approach in Alice Springs
• commence discussions in Tennant Creek
Northern Region
• commence discussions in Darwin
• commence discussions in Katherine

It is further proposed that:
a. The specialist approach to DFV be permitted to evolve in each location to take into account local needs and circumstances but that it be guided by a set of Territory-wide overarching shared principles to ensure consistency and co-ordination and to align with good practice.
b. The DFSV-ICRO reform agenda include consideration of funding for a DFV Co-ordinator/Registrar position in each Local Court (other than Alice Springs which already has that position) and a central position in the AGD dedicated to support the development of the response.
c. The Specialist Approach to DFV in the Local Court in Alice Springs continue and that the DFSV-ICRO reform agenda include consideration of funding to strengthen its approach in line with its Internal Evaluation Report.
d. AGD identify funding to conduct the three-year external evaluation of the Specialist Approach for the period July 2020 to June 2023.
e. The Local Court commence discussions with key stakeholders about the establishment of a Specialist Approach to DFV in the Local Court in Darwin, Katherine and Tennant Creek.
f. AGD consider how a more integrated specialist approach can be fostered in bush courts, and that this be done in collaboration with the Aboriginal Justice Unit, as part of the Aboriginal Justice Agreement.
g. The DFSV-ICRO reform agenda include consideration of funding for a comprehensive training package on DFV for all personnel working in the justice system, including both introductory and advanced courses.
h. The DFSV-ICRO reform agenda include consideration of funding for additional specialist DFV training for judges, with a two–tiered approach:
a. advanced understanding of the dynamics of DFV;
b. best practice court craft and a trauma-informed approach to handling DFV matters in court.
NTCOSS supports the establishment and expansion of a specialist approach to DFSV across the Territory as noted above. Emphasis must be placed on working with community service providers already operating in this space, and on the learnings and evaluation being carried out in Alice Springs as part of the Specialist Approach pilot. Noting language used in the above recommendation, ‘good practice’ must be defined and reflected within the evaluation. Ensuring adequate resourcing for the provision of therapeutic supports as part of this (such as men’s behaviour change programs and partner support workers, noting currently only of which two are funded across the region) is critical, noting concern from service providers regarding the current level of resourcing.
Please refer to SR23 for further response to SR10.g.
NTCOSS notes comments made regarding SupportLink as part of this Review. NTCOSS notes member feedback relating to issues pertaining to SupportLink as previously raised through the Cross Agency Working Group (CAWG), directly with the provider and other DFSV regional networks, and the lack of review or evaluation carried out on the service since its introduction. Before the service is possibly expanded, it should be evaluated to ensure it is fit for purpose (particularly noting that if a 24 Hour

Referral Service is to be developed (SR15) this would most likely increase referrals through this pathway).
PROPOSAL SR 11
It is proposed that the Commissioner of Police – in collaboration with the DFSV-ICRO and informed by consultation with DFSV specialists – revise the police General Order on DFV and other relevant policy and procedures to:
a. convey a contemporary understanding of DFV, that reflects the centrality and seriousness of coercive control and psychological abuse;
b. assist police officers to identify the ‘red flags’ for coercive control;
c. assist police to identify and manage the high risk factors associated with DFV in a way that is aligned with the NT’s Risk Assessment and Management Framework (RAMF) including:
i. history of DFV between the parties;
ii. coercive control;
iii. choking;
iv. threats to kill;
v. pregnancy of new birth;
vi. actual or pending separation;
d. guide police officers on when to initiate a Police DVO;
e. guide police in identifying the person most in need of protection where there are mutual allegations of violence or signs that both parties may have used violence (also a process for an internal review where mutual DVOs are being considered);
f. guide police in relation to appropriate responses to intoxicated victim-survivors (to prioritise safety and so that the best practice response is not downgraded if victims are intoxicated);
g. encourage the use of recorded statements for victim evidence where possible;
h. guide police responses in remote contexts where there are limited services and options for safe accommodation available.
It is further proposed that the police General Order on DFV – or a summary of police procedures in responding to DFV – is made available to DFV service providers to facilitate continuous improvement of inter-agency responses to DFV.
NTCOSS supports the revision of the General Order on DFV in collaboration with NT Police, the community sector and other relevant stakeholders. NTCOSS notes member feedback relating to the fact that the General Order is still currently confidential and that a summary of the order has not been provided. NTCOSS supports a collaborative, transparent approach to the above.
NTCOSS notes member feedback regarding SR11.g relating to recorded statements, on seeking clarity as part of the reform if this also includes body cam footage.
PROPOSAL SR 12
It is proposed that a review of police training on DFV be conducted to bolster the training with respect to DFV and coercive control. Consideration should be provided to:
a. compulsory training for all police officers in the NT;
b. high level training for selected officers;

. the identification of selected police members as DFV champions to foster best practice through NT Police (see the Scottish model).
It is further proposed that the review be jointly conducted by the DFSV-ICRO and the police Training and Assessment Advisory Committee (TAAC), and include representation from Police with a high level of DFSV experience and DFSV experts outside of NT Police.
NTCOSS supports a review of police training, however, encourages an independent, external evaluation of the training undertaken by a content specialist. Such a review can then be fed back to the DFSV-ICRO and the TAAC. NTCOSS notes member feedback relating to general compulsory training for all officers needing to provide a greater base line understanding of DFSV within communities with a trauma informed approach (inclusive of vicarious trauma) and be provided on an ongoing basis as part of professional development.
PROPOSAL SR 13
It is proposed that NT Police, in collaboration with DFSV-ICRO, institute effective practices to assess and manage risk associated with DFV that are aligned with the NT’s Risk Assessment and Management Framework (RAMF), including:
a. At the scene,
i. ensure the immediate safety of alleged victims, alleged offenders and children,
ii. ensure that the parties are interviewed separately to accurately identify risk in the context of the relationship overall.
b. Develop a modified CRAT specifically for frontline police to assist them to accurately assess and manage risk of harm, or further harm, from DFV during operational duties that:
i. is aligned with, and informed by, the RAMF/CRAT,
ii. assists frontline police to accurately identify the person most in need of protection,
iii. meets police requirements and is compatible with the existing police IT systems (Promise/Serpro),
iv. minimises administrative burden for frontline police officers,
v. is incorporated into the NT Police Minimal Response
c. Continue to use the CRAT to identify victims at risk of serious harm for referral to the Family Safety Framework inter-agency response.
NTCOSS supports the modification of the CRAT and the implementation of effective practices to assess and respond to risk pertaining to DFSV for front line responders, particularly NT Police. NTCOSS notes that some of this work has already commenced internally within the NT Police and supports its continuation.
NTCOSS notes member feedback that as current risk assessment tools are varied and improved for front line responders, this must be incorporated into the evaluation and use of Support Link as a referral tool, if it is to continue to be used on an ongoing basis.

PROPOSAL SR 14
It is proposed that, in accordance with the proposed legislative amendments (see proposal LR 11 above), the Commissioner of Police require police to provide a certificate to the Court at the first mention in all applications for DVOs, that summarises the defendant’s criminal history and a history of all DVOs that have been in force, in accordance with the legislative amendment.
It is further proposed that this be an automated system in similar terms to the generation of criminal histories to ensure the certificates can be generated efficiently by police with minimal administrative burden. Alternatively the process could mirror to current practice for the production of antecedent reports for courts in criminal matters.
NTCOSS addresses this suggested reform as part of the legislative component. Please refer to the supplementary submission upon release.

PROPOSAL SR 15
It is proposed that the DFSV-ICRO reform agenda include consideration of funding for TFHC to establish a 24-Hour DFV Specialist Referral Service and that TFHC and NTPFES via the DFSV-ICRO develop an appropriate service model so the service operates effectively across all the regions of the NT and in urban and remote community settings.
While NTCOSS supports the consideration of the implementation of a 24-Hour Specialist Referral Service, ensuring that any such service is developed in consultation with the specialist sector, the general community sector and impacted communities is critical (particularly noting that a one size fits all approach in terms of model development will not necessarily work). Ensuring that any model is fully costed on a long-term basis as part of any implementation plan, with evaluation and monitoring embedded into the approach, must be prioritised. The development of any such service must also align with previous recommendations provided under the development of Action Plan 2, as well as the Aboriginal Justice Agreement and other related frameworks.

PROPOSAL SR 18
It is proposed that as part of the DFSV-ICRO reform agenda, AGD review the capacity of legal services to provide legal assistance to protected persons and defendants in proceedings under the DFV Act, with a view to:
a. strengthening the provision of legal advice and assistance for protected persons in DVO proceedings;
b. introducing a service in Alice Springs to provide legal advice, assistance and support to male defendants in DVO proceedings;
c. identifying other service gaps in relation to legal assistance for proceedings under the DFV Act.

PROPOSAL SR 19
It is proposed that as part of the DFSV-ICRO reform agenda consideration be given to whether:
a. existing DFV support services for victim-survivors and defendants involved proceedings under the DFV Act at court are resourced adequately to meet current demand;

b. an expansion of specialist DFV courts in the NT would require an increased capacity for support.
NTCOSS supports recommendations provided under SR18 and SR19, however notes that there is no measurable outcome within SR18 and SR19 and no commitment to fund any such outcomes or recommendations notes the importance of providing recommendations post any review for long term change, particularly including evaluation and monitoring and adequate consultation with the service sector.

PROPOSAL SR 20
It is proposed that the DFSV-ICRO reform agenda include consideration of funding for a specialist trauma-informed counselling service for women prisoners who have experienced DFV, sexual abuse, child abuse or other forms of trauma.
NTCOSS supports SR20 and notes specific member support for this piece of work, including previous work carried out by the Top End Women’s Legal Service (Attachment C) and the Kunga Stopping Violence Program.7
Please refer to SR10 and SR22 for further comment on Alternatives to Custody programs and behaviour change initiatives that also may influence and/or incorporate resourcing for a specialist trauma-informed counselling service for women prisoners who have experienced DFSV or other forms of trauma.

PROPOSAL SR 21
It is proposed that DFSV-ICRO in collaboration with TFHC and AGD (including AJA and NTCS) give consideration to developing a costed plan to increase the availability of high quality DFV perpetrator programs in the NT. It is proposed that programs are:
a. aligned with recognised good practice and standards for DFV programs
b. able to provide a culturally competent and cultural safe program for Aboriginal participants
c. address all forms of abuse, including coercive control
d. prioritise victim safety
e. operate across three settings but with shared principles:
i. correctional settings;
ii. residential facilities / Alternatives to Custody settings (For example the DFV Alternatives to Custody being developed as part of the AJU in Alice Springs);
iii. community based settings.

PROPOSAL SR 22
It is proposed that DFSV-ICRO give consideration to establishing a multi-agency oversight committee or body comprised of key agencies (TFHC, AGD, AJU, NTCS) and DFV experts whose purpose is to ensure a suite of accountable high quality DFV perpetrator programs are provided in the NT that prioritise victim safety and offender accountability. The committee or body may include a review of existing programs, development of best practice standards, and recommendations as to which programs should be declared or approved for the purposes to the DFV Act and the Sentencing Act 1995.
While NTCOSS supports a collaborative approach to the development of high-quality perpetrator programs in the Territory (SR21 and SR22), it is also critical that the community service stakeholders currently engaged in this space, or with expert knowledge, are involved in any future development. Further, ensuring that previously committed evaluations(including on men’s behaviour change programs and the Alternatives to Custody program in Alice Springs) are completed, made available to stakeholders and used to create a basis for further program development is critical to ensuring programs are developed in line with best practice, are community led, co-designed and are fit for purpose. The need to increase service delivery across this space (particularly noting the changes to Mandatory Sentencing and Community Based Orders) is central to progress.
NTCOSS notes previous comment provided regarding the development of minimum standards for behaviour change programs that centre victim-survivor safety being central to this work.
It is critical to ensure that any individual representing their agency or organisation on any such committee or body charged with ensuring accountable, high quality perpetrator programs has adequate specialist knowledge, as well as ensuring representation on any such body provides for cultural knowledge and diversity that represents the communities across the Territory.

PROPOSAL SR 23
It is proposed that the DFSV-ICRO reform agenda include consideration of funding for TFHC to significantly expand the implementation process and training for the NT’s DFV Risk Assessment and Management Framework (RAMF) to ensure that the approach to DFV risk assessment and management is consistent across the system, and that coercive control is recognised as a predominant feature of DFV.
NTCOSS notes numerous recommendations throughout the Review pertaining to training development and funding. NTCOSS recommends the following in this regard;

  • A full independent review of the RAMF and CRAT is carried out before it is expanded, to ensure it is fit for purpose and adapted where necessary (particularly for front-line responder’s ease of use and in remote contexts).
  • A gaps analysis is carried out assessing current training being carried out across the Territory and current need, including noting where evaluations of training packages have been undertaken and the related outcomes, including within government agencies.
  • The DV Resource Centre model, previously committed to by this government, is consulted on and implemented to assist with training needs pertaining to DFSV.

PROPOSAL SR 24
It is proposed that the DFSV-ICRO reform agenda include consideration of strengthening the Family Safety Framework (FSF) as an action based, integrated, multi-service response for women experiencing or at risk of experiencing serious harm or death because of DFV.
NTCOSS supports the strengthening of the FSF, and notes previous member requests for the FSF to undergo a second review process to inform this work.

PROPOSAL SR 25
It is proposed that TFHC, in collaboration with DFSV-ICRO, give consideration to developing guidelines on how MACCST will deal with children exposed to, and affected by DFV, and their families, that is aligned with the NT’s DFV Risk Assessment and Management Framework (RAMF). The guidelines should prioritise victim safety and offender accountability and include:
a. responses to children who are primary victims or otherwise exposed to DFV;
b. responses to non-offending adults who are victims of DFV;
c. responses to DFV perpetrators; and
d. responses to the high risk factors outlined in the RAMF (these are summarised in Part 3.6 above).
As noted under SR24, NTCOSS supports member requests for a review of the FSF. A review can be used to inform the development of guidelines on how the Child Wellbeing and Safety Partnerships (formally MACCST) may be able to deal with children exposed to, and affected by DFSV. NTCOSS notes advice previously provided that the Child Wellbeing and Safety Partnerships do also have allowances that where a FSF does not operate in community, a single person who is experiencing DFSV can seek support through this mechanism (similarly to an FSF). NTCOSS recommends further work is done to understand the cross over between these two pieces of work, ensuring that the integrity of the FSF is strengthened to better support victim-survivors.

PROPOSAL SR 26
It is proposed that, as part of the DFSV-ICRO reform agenda, consideration be given to:
a. establishing a model for a systems-driven DFV Death Review Process in the NT;
b. including consideration of funding to implement the model for a DFV Death Review Process in the NT; and
c. linking the DFV Death Review Process to the ongoing inter-agency leadership and governance structure for DFSV going forward.
NTCOSS notes support from members for the establishment of a Death Review Process in the NT, in line with other jurisdictions

For more information, or to discuss this submission further, please contact:
Tessa Snowdon Senior Policy Officer tessa@ntcoss.org.au