Can I just say, I'm pleased to see a number of members submitting their own personal submissions to this consultation - the level of detail and value that are in these is incredibly powerful.

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Newton - as Menace points out, details are in The Record, which you should have been sent by email last Friday. Otherwise, go to the homepage of the UNLOCK site and there is a direct link to the Latest Issue.

forever changes - there absolutely is a need for individuals to respond. You can ask that your personal details remain anonymous. Our experience in the past is that many of these consultations are judged numerically - one response (no matter how many people it is on behalf of) is only counted as one.

As for the substance of the changes, I think it is important that people give proper consideration to the changes and develop reasoned arguments either for or against - a tendancy to just disagree isn't always the best option.

1. Notify all foreign travel rather than just over 3 days - if you accept that notification of foreign travel is necessary, then the 3-day threshold does seem rather strange - surely it is all or nothing. In my view, it is proportionate to have foreign notification, and therefore I find it hard to disagree principally with the removal of what is otherwise an anomaly.

2. Notification weekly if NFA - again, I find this hard to argue against. If it is the case that many people report NFA (more than actually are NFA) it would seem right to incentivise people to give a true address. Obviously, for those truly NFA this will without doubt cause an additional burden, but I cannot imagine that there would be many people who are truly NFA.

3. Registering those under 18 living in the same property - this requires the notification for a child (including their own) under 18 residing for any period (presumably they’d have to stay at least one night, and not just entering the house). This includes those convicted of sexual offences that in no way involve children. It’s also not clear how this links with the Home Offices Child Sex Offender Disclosure Scheme. I’d perhaps suggest this need should be limited to, for example, those barred from working with children (i.e. those on the barred list) and not just those on the SOR – I can understand if for people convicted of sexual offences against children though.

4. Notification of bank and credit card details – I can understand passport details (as you can’t travel without notification, and this is to monitor this). The argument is to align it with Scotland (who currently have this) and to avoid people changing their name to evade detection, as well as to assist the police in investigating offences of accessing indecent images where credit card payments have been involved. Again, why then should this apply to all RSO's. Furthermore, the police can surely get access to this information anyway, and presumably they can’t just monitor peoples accounts, they have to ask the bank permission if they investigating a specific concern, which they could do anyway.

It's important to say that the above is purely my own personal views, and does not reflect UNLOCK's policy position on this - I'm not responsible for our policy work, and I'm not sure where we are at on this subject.

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I hope Unlock will formally respond to this additional opportunity for the Police to harass reformed offenders. Is there any point in responding individually, most if not all ppl on the SOR will object but be worried about their being identified plus their comments placed on the Home Office website. Having read the home office consultation it gives no justification for any of the additional measures though I noted one excuse was to align powers with those in scotland - does this mean offenders in England and Wales are exempt from notification if they move to Scotland (and vice-versa)?

As a frequent traveller my first worry now from the proposals is being stopped from leaving the country which is flagged as a possible outcome of the new notification.

I will also have to notify the Police if I stay at a friends or relatives where there's someone under 18 and said innocent ppl will not be happy at getting police attention.

What are the police going to do with bank/credit card details

Post Edited (forever changes) : 05/07/2011 01:15:20 (GMT+1)

https://www.homeoffice.gov.uk/publications/about-us/consultations/notification-sex-offenders/ has links to the actual document and the impact assessment (which would be a joke if its consequences weren't so serious).

Yes the ECPAT source document which is used extensively to back up the proposals wouldn't stand up as A level homework, its quite shocking - examples from newspaper reports in the main quoted as fact, unreferenced cases and reference to people being found not guilty on a 'legal technicality' which obviously means the prosecution did not prove their case beyond reasonable doubt. they also refer to another case of someone found not guilty as if he was really guilty....desperate stuff and it seems to have fooled Cameron. All but 1 of the examples  they do give are actually people already living and working abroad, not travelling abroad - but that 'fact' seems to have eluded them

not as detailed as the other brilliant contributions by menace, christopher and andy h but here was mine

Post Edited (forever changes) : 05/08/2011 11:11:53 (GMT+1)

I think your last sentence hits the nail on the head

I can only talk about my internet sex offending but I know neither the SOR nor any other restrictions imposed by the court has stopped me reoffending - all that's doing is punishing me further . I've stopped myself reoffending - thanks to the education I received via croga.org and books like 'Cybersex unhooked' by David L. Delmonico et al ( free to read/download at https://www.internetbehavior.com/services/cyber_unhooked.htm ) and 'In the shadows of the net' by Patrick Carnes et al. All these made me realise I had an addiction, the astonishing thing for me was that the word 'addiction' was never mentioned on the i-SOTP which seemed to try to make internet sex offenders fit the model of contact sex offenders rather than look at them as different animals.

On top of that I don't want to go through any of the kind of xxxx I've been through ever again: I don't want to be blasted all over the papers every few weeks for 18 months and have my life destroyed again. I'm addressing all the things that had gone wrong in my life that gave me low-self esteem, created social isolation, loneliness, made me alcoholic etc and laid the pre-conditions that led me to offend after 40+ crime-free years of adult life.

This has gone way off topic (SOR proposed changes) - and led by 2 Forum Moderators! If we have to have one at all please let's have a new thread for the Trumpton riots

I had an email from home office asking if it was ok to quote from my submission (without actually saying which bit), has anyone else had a response?

Very well put Christopher. Andy - I hope you will also be submitting your points to the consultation process, as both your response and Christopher's have caused me a number of "I should have thought of that!" moments.

Andy - my personal opinion is that half of those tasked with reviewing these documents before proceeding do little more than scan the highlights, and certainly do not delve too deeply into the source material, simply accepting it at face value as is presented to them.

I have now submitted my considered response to these proposals and in the interests of transparency, thought I would upload it here for others to view.

Feel free to read through it.

For those who have yet to read this months issue of The Record, you will have missed an article by Andy H outlining proposed changes to the Sex Offenders Register, affecting all those who are subject to the notification requirements.

Briefly, it is proposed to add the following requirements to the current arrangements:

i) notify the police of all foreign travel (currently only travel outside of the UK for three or more days is notified)
ii) notify weekly where they are registered as having 'no fixed abode' (where a registered sex offender has no sole or main residence and instead must notify the police of the place where they can regularly be found)
iii) notify the police when living in a household with a child under the age of 18
iv) notify the police of passport, bank account and credit card details and provide the police with proof of identification at each notification

Whilst this consultation is targeted towards key groups and agencies managing sexual offenders, public responses are welcomed. As such, this gives Unlock members who would be affected by these proposals to present their opinions. The consultation documents outline the proposals in reasonable detail, and it is clear that they are seeking opinions on whether the measures are proportionate to the risks presented in these "loopholes" in current legislation.

As such, if you read through the documentation and feel that the proposed measures are disproportionate to the perceived risk, or that the costs involved might be better utilised elsewhere in the justice system, I suggest you submit a detailed and considered response to this consultation.

There seems, as ever, to be slightly dubious thinking going on at the Home Office on this. Theresa May is entitled to her own opinions, but not to her own facts.

Firstly, I have yet to see evidence of lower rates of sexual-offence recidivism in countries that have some sort of 'register' when compared to those that don't. Obviously there are difficulties in finding comparable data given the differences in the archiving of criminal conviction information, but it shouldn't be too hard to get a 'ballpark' comparison figure - if only someone at the Home Office or Ministry of Justice could bother. Given this - where is the evidence base suggesting that increasing the scope of the notification requirements would result in fewer offences (other than just because CEOP or the police are asking for it which is not, in itself, evidence).

Secondly, I am in the process of doing some research on MAPPA statistics with a view to co-authoring an article. So far as I can see there is a massive downgrading of Category 1 (Registered Sexual Offenders) from Level 2 and 3 management down to Level 1 (the proportions at each Level have changed over the last 6 years and very significantly in the last 2). Curiously the MoJ figures differ from those provided by individual MAPPA reports when looked at collectively - I'm trying to figure out why this should be. But if more MAPPA teams are taking the view that they can manage a higher proportion of RSOs at Level 1 (lower risk) - why the need to collect more personal data on RSOs?

Thirdly, the presumption seems to be (still) that a massive reduction in sexual offending can be achieved by reducing recidivism. Whilst things like provision of SOTP courses seems to have some efficacy in this area (albeit mostly in those with a low/medium 'risk of reconviction), I'm not convinced that there is a huge problem of mass recidivism amongst those previously convicted of sexual offences. In fact, almost all of the evidence (including the official MoJ statistics) points to the contrary position - that convictions for sexual offences are overwhelmingly 'first timers' (i.e. people without previous in this category of offending, or as is often the case, any previous convictions). There might well be more sexual offences being discovered, prosecuted and convicted, but that is not the same thing as more sexual recidivism. This being the case, there is no reason to think that making the SOR more stringent in its requirements would lead to a fall in the rate of sexual offending since most of the offences are committed by people not previously known to the police. MAPPA reports that the rate of 'serious further offences' is actually very low - so why the need to gather yet more data?

On a related point, I am also curious as to whether the published rate of sexual offending (and sex offence recidivism) includes people convicted or cautioned for breaching the notification requirements or a SOPO (which are offences under the Sexual Offences Act 2003). If so, what would be the effect on the statistics of excluding these 'technical' offences (i.e. if a person fails to notify the police of a change of address is that counted as a 'sexual offence' in the statistics?)

I think Newton makes an interesting suggestion - why isn't the level of information required linked to the risk-management level of the individual rather than 'blanket'? Having said that, I'm not convinced that the processes involved in risk-management decisions are sufficiently robust and are more guess work than scientific.

Post Edited (AndyH) : 05/07/2011 12:31:50 (GMT+1)

Hi Menace,

Quite, quite brilliant!
Why is such rationality never applied by the goons at the Home Office when they draft this rubbish? My suspicion is that the Minister says, "I want to bring in this legislation, go and write the evidence base that supports it" rather than what is the sensible thing - see what the actual evidence suggests, and then draft the policy in relation to the evidence.

Inspired by both of you I've decided to have a look at this myself. Is it just me... or is most of what we've come up with between us really, really obvious to anyone with a capacity for logic and rational thought? I have real concerns with regards the quality of people that the Home Office employs to produce this stuff.

Have dealt with foreign travel first - I'll add what I can think of for the other proposals later:


Having read the consultation document and impact assessment provided by the Home Office I have concerns not only as to the extent of planning that has been made in relation to the proposed legislative changes but also questions as to the quality of evidence presented proposing that the changes are necessary. I therefore doubt whether the proposed changes would have any efficacy in reducing sexual offending overseas.

The ECPAT UK report which is cited within the consultation document and the impact assessment includes a number of what are optimistically described as ‘case studies’. These are not, as one might expect, instances of primary research conducted by ECPAT UK, but are in fact, media reports of cases where British citizens have been convicted for child sexual abuse overseas. These are as follows:

Case study 1   A BBC news report of two British men convicted of abusing children in an Albanian orphanage. However, there was no report of these men being registered sexual offenders prior to their journey to Albania.

Case study 2   A report from the Bangkok Post of a British man paying for sex with children in Cambodia, in this instance the man is reported as having previous convictions for Internet sexual offences.

Case study 3   A report from the Daily Mail of a British man committing sexual offences against Latvian street children. There was no mention of the man having previous sexual convictions or of being a registered sexual offender.

Case study 4   A BBC report of a British man being sentenced to life imprisonment for raping a girl in Goa, India. Again there is no suggestion that the man was a registered sexual offender.

Case study 5   A report from the ‘This is Gloucestershire’ website (owned by the Daily Mail and General Trust) of another British man, alleged to have committed sexual offences against young boys in Goa, India. Once again, there is no suggestion that the man was already a registered sexual offender and the court proceedings against the man were actually dismissed meaning that the case against him is unproven and he remains not guilty of any offence.

Such a selection of information as ‘evidence’ in support of changes to the current system of notification for foreign travel are immediately evident as causing concern. Firstly, using tabloid newspaper reports as the factual basis for a change of Government policy is completely irresponsible and would extend a worrying trend for the development of policy in Home Affairs on the basis of media pressure. The previous Government made a number of changes to the notification requirements in 2003 and introduced the Child Sex Offender Disclosure Scheme in 2010 on the basis of campaigns run by the News of the World. A number of senior executives of this paper are now under investigation for alleged criminality over a number of years and there are suggestions that data from the police national computer in relation to former Labour MP Martin Salter was sold to the News of the World who targeted him because he refused to support their campaign for ‘Sarah’s Law’. The fact that the most high-profile 'lobbyist' for changes to the management of registered sexual offenders was allegedly prepared to use such coercive tactics against a democratically elected member of the legislature should be of grave concern.

Secondly, there is no evidence to suggest that the men in these case studies would have been prevented from committing the offences described (or in one case alleged offences) if a requirement to notify the police of all foreign travel was added to the notification requirements. It cannot be ascertained that most of these men were even subject to the notification requirements in the first place (as they were not registered sexual offenders).

The ECPAT UK report also cites (p13) that of 33 cases of child abuse committed in educational institutions highlighted by CEOP, 23 were identified as having previous convictions for offences against children. However, it does not state whether these were sexual offences committed or whether the previous convictions were sexual in nature. Also, there is no reference provided to the original source of this data, or any opportunity to assess the methods used or the purposes for which CEOP collected it. Was the data, for instance, collected by CEOP searching for registered sexual offenders who had disappeared overseas without notifying the police? Or was this abuse committed by people who had travelled overseas having given the police notification of their intention to travel? Or were these cases of people who had historic convictions for child abuse but who were not subject to the notification requirements? Without knowing the answers to these questions it is impossible to say whether or not the majority of child sexual offences involving British people overseas are committed by those with previous convictions and who are also subject to the notification requirements.

The report states at the outset that “Since the mid-1990s ECPAT UK has documented over 120 cases of British nationals accused of sexually exploiting children overseas” (p7). This means that on average less than 10 cases are documented each year by ECPAT UK and, whilst this is still too many, there is no suggestion that these cases are exclusively offences committed by individuals subject to the notification requirements. If these offences are, as is entirely plausible, committed by those with no previous convictions for sexual offending and who are therefore not registered sexual offenders, it is difficult to ascertain what impact changing the foreign travel notification requirements would have.

Based upon the current arrangements, there is scope for police to apply for a foreign travel order to block overseas travel in cases where a registered sexual offender is thought to pose a risk of committing sexual offences in their destination country. The Ministry of Justice, in the 2010 MAPPA annual reports cites the following number of FTOs being used over a 5-year period: 2005/6   (1), 2006/7 (3), 2007/8 (1), 2008/9 (12) and 2009/10 (15). Clearly there is not a large-scale problem of registered sexual offenders travelling overseas for more than 3 days to countries where the police have reasonable suspicion and credible evidence that they might sexually abuse children, otherwise the use of FTOs would be much greater than 32 over 5 years.

The proposal to require all foreign travel to be notified is based upon suggestions of a ‘loophole’ that allows registered sexual offenders to arrange trips of less than 3 days. The ECPAT UK report states that “the Child Exploitation and Online Protection Centre (CEOP) records that in 2008/9 approximately 56% of travelling sex offenders caught were apprehended in South East Asia” (p7). Given that travel to South East Asia takes at least a full day in each direction, not to mention the expense of return tickets and travel within the countries visited, that leaves one day in which the travelling sex offender can commit their offences. I would imagine that the number of registered sexual offenders who can afford to make such a trip and who chose to do so in less than 3 days is, in reality, negligible. The consultation document proposes that the ‘loophole’ is used for travel to Eastern European counties, quoting that: “CEOP records 20% of activity by travelling sex offenders as having taken place in European countries in 2008/9” (p11). However, once again this does not state what proportion of this 20% are registered sexual offenders and what proportion are sex offenders who have not yet been convicted of an offence and made subject to the notification requirements.

The Home Office, and other organisations, appear to have thought about the problem of British citizens travelling overseas to sexually abuse children as one that can be solved by restricting the travel of registered sexual offenders. It is, however, not only plausible but probable that the problem is actually with unregistered sexual offenders rather than with individuals already subject to notification requirements. Before proceeding with the proposed changes in relation to foreign travel notification, the Home Office should do the following:

•   Collect reliable and independent data on what proportion of sexual offences committed by British citizens overseas can be attributed to registered sexual offenders, and what proportion to individuals with no previous history of sexual offending or requirement to notify their foreign travel to the police.
•   Review whether the current process of applications for foreign travel orders is fully understood and utilised by the police.
•   Determine whether issues of overseas child sexual abuse can be tackled more appropriately through the work of the Department for International Development, in order to identify children ‘at risk’ (particularly in South East Asian countries) and make provisions in partnership with the respective Governments of these countries to remove them from situations where they might be exploited by travelling sex offenders.

Post Edited (AndyH) : 04/08/2011 17:17:44 (GMT+1)

In advance - apologies to everyone else for my turning this into a nerdy discussion about stats between me and Ian! For those that have no idea what we're talking about this gives a good synopsis: en.wikipedia.org/wiki/Meta-analysis or en.wikipedia.org/wiki/Systematic_review



Doesn't that rather depend upon how you operationalize the variables involved? Even in medicine there are loads of confounding variables, but that's exactly why they do systematic reviews. Take things like studies of whether SSRIs work for treating the symptoms of depression. Sure you can do double-blinded trials against placebos, but how do you even go about measuring a concept like depression in the first place, or knee or back pain for that matter? There is still plenty of subjectivity in measuring things that are medical. Individual studies always have flaws, but if you compare lots of studies collectively you minimise the impact of these problems. I don't see any reason why Government's can't undertake a meta-analysis/systematic review on the effect of sex-offence registers, even with all the confounding variables... at least on a theoretical basis in our example here. Practically speaking, the main issue is getting hold of sex-offence re-conviction rate data from each of the countries but if you could do this there's no reason a meta-analysis couldn't be conducted. Most countries record this data routinely (unfortunately massive criminal record databases aren't exclusive to the UK!)

Remember that even with all the cultural and legal differences between countries you effectively still have a range of large-scale experimental studies. Into our meta-analysis we put all the countries that have introduced sex-offender registers - the UK, USA, Ireland, Australia, Canada, New Zealand. Even though there are variations of laws in each country, what we effectively have is a series of 'effect-sizes' that can be measured. Let's say our consistent measure is the rate of re-conviction for those sentenced for sexual offences for a period of say 10 years. For each country we can compare re-conviction rates before and after introducing a register. The fact that each individual country is a different 'experiment' conducted under slightly different conditions isn't too much of an issue as we're not comparing their legal systems with each other, rather we are weaving together the effect-sizes from each country to create an overall measure of the impact of introducing a register for sex-offenders. Provided you weight your analysis based-upon sample sizes so that smaller studies (New Zealand) aren't allowed to have the same impact as the bigger ones (United States) you should get a pretty good idea of what impact registers have.

Nerd alert...
Your outcome is a blobbogram or forest-plot - I've uploaded an image of the Cochrane Collaboration logo which is of a blobbogram for people who still have no idea what I'm going on about (you might need to click on it to see it properly). In the picture, each of the horizontal lines represents the effect-size for a different study, the width of the line represents the 'confidence interval' for the data for that study (so if you're pretty certain your data is a reliable measure of your effect-size it's a narrow line, if you're less certain the line is wider). If any part of the line touches the vertical 'no effect' line then you have to assume that your intervention doesn't make any difference. In the diagram (completely random - nothing to do with sex-offender studies by the way), you can see that most of the individual studies touch the 'no-effect' line - BUT, you might notice a pattern - that they're all over to the left a bit. Which means that when you look at just one study, you might not find anything significant, but if you look at them all collectively, you see a pattern emerge. The little diamond is the overall effect-size for all the studies taken together, which shows a slight effect-size which we might not have noticed otherwise. This might not seem very interesting - but this slightly dull-sounding statistical method has probably saved millions of people's lives around the world - maybe even your own if you were born prematurely (I won't bore you further with why).

So how is this all relevant? What I'm suggesting is - wouldn't it be good to have a meta-analysis looking at the effect of introducing sex-offender registers on re-conviction rates by comparing all the countries where they've been introduced? At least that way we'd have some reliable evidence on whether spending loads of money monitoring 35,000 people for years on end is worthwhile.

Post Edited (AndyH) : 07/08/2011 23:37:30 (GMT+1)

In relation to the third proposal...


In order to consider whether this change is necessary, or likely to have any positive effect on rates of sexual offending against children, it might be helpful to know the answers to the following questions:

a)   What number of children under 18 are victims of sexual offences committed by people subject to the notification requirements with whom they live?

b)    What number of children under 18 are victims of sexual offences committed by people with whom they live and who are NOT subject to the notification requirements and who do not have previous convictions for sexual offences?

c)   What the difference is between the two figures above and whether imposing the additional proposed notification requirement would make any significant difference in reducing the number of children who are abused by people with whom they live?

Again the Home Office seems to have formed the conclusion that a reduction in the number of sexual offences against children can be achieved by extending the notification requirements. However, the Ministry of Justice MAPPA annual report for the year 2009/10 (p13) states that 104 ‘serious further offences’ were charged to Category 1 cases under MAPPA (registered sexual offenders). I would imagine that of these offences a negligible number are committed against children under 18 with whom the offender is living. Indeed it is not even explicitly stated that these 104 serious further offences are all sexual. Given this situation, what reason is there to believe that extending the notification requirements against ALL 34,939 registered sexual offenders (MAPPA report, p8) would significantly reduce child sexual abuse?

I note that there is no suggestion to restrict the additional requirement to those convicted of offences against victims aged under 18 or to those who are managed at higher risk MAPPA levels 2 and 3 - rather this is being seen as a blanket policy covering all those subject to notification.

Post Edited (AndyH) : 05/08/2011 09:26:16 (GMT+1)

Okay, I've done a bit more work on this and will submit the document attached. I have to say that it is very concerning that these proposals are only open for an 8-week consultation period - is this the bare minimum that the Home Office is required to consult for I wonder? The fact that these proposals are being put forwards without any substantive evidence suggests that the Government feel that they can do whatever they like in relation to sex-offenders because no-one will notice or, indeed, care.

Just discovered something that I find rather odd about all of this and have emailed the Home Office to ask about it...

Dear Sir/Madam,

Further to my last email and submission of my responses, I have a specific enquiry about the length of this consultation.
It is stated on the Home Office website (www.homeoffice.gov.uk/publications/about-us/consultations/notification-sex-offenders/) that the consultation lasts from 14th June 2011 to 8th August 2011 – a period of 8 weeks
However, the HM Government Code of Practice for Consultation states (as Criterion 2 on page 8) that: “Consultations should normally last for at least 12 weeks with consideration given to longer timescales where feasible and sensible.” (www.berr.gov.uk/files/file47158.pdf)

Can I please enquire as to who made the decision to have a shorter length consultation on these issues and why was this decision made?

Yours faithfully.....

I've just noticed that the 12 week minimum is suggested in the consultation document itself on page 19. So why does the same document on page 5 only allow for an 8 week consultation? Anyone would think that they were just doing all this as a paper exercise!!!

Post Edited (AndyH) : 05/08/2011 14:45:15 (GMT+1)