Consultation Paper on a Victims’ Strategy

Submission by Democratic Dialogue
on the Consultation Paper on a Victims’ Strategy

9 November 2001

1. Introduction

This document is Democratic Dialogue’s response to the Consultation Paper on a Victims' Strategy made public on the 6^th of August 2001 by Mr Dermot Nesbitt and Mr Denis Haughey, MLAs in the OFMDFM with responsibility for victim issues.

Democratic Dialogue is Belfast’s first think-tank organisation focusing on policy formation in Northern Ireland. Democratic Dialogue’s response to the Consultation Paper is part of a wider project we are undertaking focusing on victim-related policy issues in 2001/2002. As such, the opinions of a number of role-players in the sector were sought in the writing the submission.

In addition, on Tuesday the 23^rd of October 2001, Democratic Dialogue held a Roundtable discussions aimed at exploring the questions raised in the Consultation Paper. A number of papers were presented and detailed discussion held. The papers presented are available on request.

2. Structure of the Submission

This submission begins with some broad points about context and outlines Democratic Dialogue’s approach to the issue of developing a Victims’ Strategy. We argue for a very specific approach that attempts to disentangled some of the current blockages within the so-called ‘victims debate’. The approach we argue for under 3., is then used to inform our responses to the questions posed in the Consultation Paper.

3. Developing a Comprehensive Strategy: A Proposal

The current context in which the issues relating to so-called ‘victims’ of the conflict are being dealt with is difficult and complex, a point acknowledged in the Ministerial Forward to the Consultation Paper. Furthermore, the issue of dealing with the victims of conflict is, and has always been, a highly politicised issue. This is inescapable as it is political by its very nature. To this end, Democratic Dialogue appreciates the sentiment expressed in the Consultation Paper that one ‘cannot afford to shy away from’ the issues involved in meeting the needs of so-called ‘victims’.

As the OFMDFM knows, there is much suspicion (and at times animosity) between and within so-called ‘victims’ groups, the statutory sector and the voluntary sector (this is dealt with in more detail under 4.7). There is competition for resources, not to mention the ongoing struggles over the definitions of concepts such as ‘victim’. This seems to be fuelled by an anxiety that such definitions will be narrowed in one way or another resulting in the sidelining of specific interests. There is a powerful perception in some sectors that victim-related issues were only put on the agenda in order to attempt to balance a process of prisoner release. The entire debate at its core is also profoundly about the issue of the acknowledgement of wrongdoing and suffering, a point to which we will return later.

At the same time, it would be unfair to say that nothing has been done to address these problems. Funding has been made available and a proliferation of so-called victim-related projects and government responses have ensued, including the Victims Unit in OFMDFM which seems to have received broad acceptance from most groups and political parties. Some very creative community-based projects aimed at healing have been developed, various statutory initiatives attempted and the very fact that an interdepartmental strategy is being developed can only be seen as positive.

However, Democratic Dialogue is of the opinion that in order for a comprehensive strategy to be developed and implemented, the historical context — and current state of affairs as briefly outlined — need to be used as backdrop, albeit a fragmented and fraught one, for understanding and developing any new strategy.

To this end, the values and ethos mentioned in the Consultation Paper are welcomed. However, Democratic Dialogue is deeply concerned with how the work in this area, and any governmental strategy, can best address the needs that are clearly out there without further polarising the sector and/or adding to the confusion about the proliferation of services, bodies and Units set up to serve the needs of those most affected by the conflict.

We feel that any new strategy needs to begin by returning to the fundamentals of the real issue at hand and how best this can be addressed, rather than simply building on the momentum of a process which, in part, has caused as much division as it has attempted to address.

Many speak of about the ‘needs of victims’ as if understandings of these needs are commonly shared — yet, our interaction with groups suggests that people have very different understandings and perceptions of the same issues.

Correctly the Consultation Paper notes that the needs of victims are varied and can change over time. Encouragingly the Paper also highlights that needs stretch beyond the boundaries of health-related concerns to the education, housing and social sphere.

However, in analysing the Consultation Paper carefully we feel that it leans towards dealing with and offering what can broadly be termed services to those, and their families, who have survived violent conflict-related incidents. This reinforces the assumption — with or without intent — that all needs of victims of conflict related violence can be dealt with by offering individuals improved and extensive services. Individual services are critical and we support them, but feel service delivery needs to be placed within a wider context and take cognisance of a range of other issues that are impacting upon it. This is also important because in some cases whole communities and not just individuals have been affected.

For the sake of simplicity, we would like to argue that when developing a comprehensive strategy to deal with those affected by the conflict it should be recognised that two related — but in many ways distinct — kinds of needs must be dealt with.

The first we can describe as the psychosocial needs of those who were affected by conflict related incidents, i.e. dealing with the physical, psychological and social needs of those affected through strategies such as counselling, befriending, assistance with housing benefit, compensation, social support, etc.

The second can be described as what we can call the historical legacy needs related to the conflict. This is not about services or physical forms of support at all, but is primarily about issues such as acknowledgment of wrongdoing and suffering, the drive by those affected to clarify the circumstances of certain violations, justice and remembrance, as well as the feelings that some of those affected have of marginalisation, fear and exclusion.

From the so-called victims’ perspective these two issues are not separate and their healing is dependent on both. We could also talk about the entire psychosocial needs of communities. However, from a policy perspective we feel the distinction we have made between the two kinds of needs is necessary and useful in disentangling some of the current blockages in the so-called ‘victims debate’ as it currently stands.

To this end, we believe on reflection that the Consultation Paper deals primarily with the first issue, i.e. the concern with services to so-called ‘victims’. However, dealing with the historical legacy of the conflict is more complex. Clearly, offering accessible and appropriate services and support through a range of departments will meet some of these needs at the individual and community level — but services and support will never be sufficient to meet the needs of those affected with regard to acknowledgement, justice, truth-recovery and remembrance. Democratic Dialogue is of the opinion that unless these two processes are separated out at a policy-level (and both dealt with), the latter issues will dominate the former and the issues will become conflated and difficult to disentangle.

We feel this is what is currently happening with, for example, so-called ‘victims groups’: the public and politicians seeing the funding of services and support — rightly or wrongly — as being tied up with the issue of official acknowledgement of their suffering. This feeds into the often-mentioned debate of ‘deserving and undeserving victims’, or the ‘hierarchy of victims’.

In fact, we would go so far as to argue that term ‘victim’ has become inextricably linked with the conflicting interpretations of the process of acknowledgement and the historical legacy of the conflict, and as such should be abandoned at a policy level as a way of identifying and talking about the debate.

Thus, if one was truly to design a comprehensive strategy to meet the needs of the "surviving physically and psychologically injured of violent conflict related incidents" — a very helpful phrase used in the Consultation Paper — we are firstly of the opinion that any overall strategy at this stage should move away from the language of addressing ‘victim issues’. The issue has become too politically loaded and has lost any specific meaning, in fact meaning fundamentally different things to different people. Thus, we propose the strategy become a ‘Strategy to Address the Impact of Conflict Related Incidents of Violence’ and not a ‘Victims’ Strategy’ as such.

Furthermore, if we are to understand the needs of those who have been affected by the conflict in a more holistic way (and in line with our analysis above) we feel two distinct (but related) programmes need to be considered — namely a ‘Programme to address Psychosocial Needs’ and a ‘Programme to address the Historical Legacy of Violence’.

In terms of the Consultation Paper we feel most of the issues discussed (e.g. service provision, support, etc.) fall into the former. Clearly, much more thinking needs to go into what issues should fall under the latter and designing strategies to address issues such as acknowledgement, justice, and remembrance are incredibly difficult, albeit vital, in societies in transition.

Our suggestion would therefore be to rather narrow the focus of the current strategy exclusively to a plan to address the psychosocial needs of those affected by the conflict. We feel this is more consistent with the main thrust of the Consultation Paper as it stands. To purport that the strategy will deal with all ‘victims needs’ at this stage will only create further animosity and division because for many who have been affected some of these needs extend beyond what the Consultation Paper seems to be currently proposing.

Nonetheless, if this approach was taken, it would need to be unequivocally acknowledged that although the offering of services can help, a strategy aimed addressing the psychosocial needs will not completely deal with the broader issues of acknowledgment of wrongdoing and suffering, the drive to clarify the circumstances surrounding certain violations, justice and remembrance, or even result in complete healing for many who have suffered. We feel it would be correct to voice this so as to dispel the assumption that no matter how comprehensive and well-implemented the ‘victim strategy’ is, it will not address all the needs of those affected.

Therefore, we would advocate that a process for discussing the ‘historical legacy’ issues such as acknowledgement, justice and remembrance needs to begin at least within Assembly structures. We understand some of the issues fall within the remit of the NIO (at least at a practical level), but they are critical to developing a comprehensive strategy and discussion on them needs to, at the very least, be opened up. However, from a policy perspective — at least at this stage — we would recommend keeping these debates as separate as possible from the process of initial service delivery.

We firmly believe that the issues such as acknowledgement, justice and remembrance need to be addressed in some way for there to be true resolution of the conflict for those affected (not to mention the society at large). In the healing process these issues are not separate from the delivery of services to those affected, and they are delineated here for policy-making purposes. Dealing with the ‘psychosocial needs and ‘historical legacy issues’ can happen through community attempts to deal with them, but ideally should also be issues that Government attempts to address both through its structures and in partnership.

4. Questions posed in the Consultation Paper

It is within the arguments outlined above that we have attempted to present opinions on each of the questions in the Consultation Paper.

4.1 How best can the Inter-Departmental Working Group on Victims interact with victims and their representatives (section 4.3)?

In line with our above arguments, we believe that the working group should be renamed the Inter-Departmental Working Group on the Impact of Conflict Related Incidents of Violence. Its main focus at this stage, as is outlined in the Consultation Paper, should remain the development of a co-ordinated approach to the delivery of services, awareness raising of the needs of those affected by the conflict and an examination of funding issues. However, we believe it should be clear that it is only dealing with these service delivery issues at this stage in detail.

Nonetheless, it is recommended that the IDWG begin to discuss how the ‘historical legacy issues’ can be dealt with. We recommend that the IDWG discuss and design a process as to how the Assembly can begin to address issues such as acknowledgment of wrongdoing and suffering, clarifying the circumstances surrounding certain violations, justice and remembrance as components of the dealing with the multiple needs of those affected by the conflict. We are aware that some of these issues in operation may fall within the remit of the NIO, however, we feel the IDWG (and ultimately the Assembly) needs to consider the issues and discuss how they can be resolved and integrated with the evolving strategy being developed.

In terms of services, we are very supportive of the inter-departmental working group approach. The group should interact with those affected by the conflict — and with service providers — primary through an Advisory Committee made up of representatives from various local Psychosocial Support and Advisory Panels (see below, formerly Trauma Advisory Panels). Four representatives (two from the voluntary and two from statutory sector) would be elected by local Psychosocial Support and Advisory Panels to sit on the Advisory Committee (16 members). The Advisory Committee would have direct access and communication with the IDWG, the OFMDFM and ultimately the Assembly.

The local Panels could take their structure, and geographical spread, from the process begun through the establishment of Trauma Advisory Panels. However, the Trauma Advisory Panels should be reconstituted through a public appointment process and in line with the thrust of the strategy proposed here and be referred to as Psychosocial Support and Advisory Panels. It is proposed that the term ‘psychosocial support’ be used instead of ‘trauma’ as ‘trauma’ is often seen as a term associated exclusively with psychology and psychiatry, whereas psychosocial implies all sectors that can offer support including social services, housing, health, etc,. These Panels should be made up of so-called ‘victim groups’, community and voluntary organisations, and statutory service providers (from across the board) who offer support to those and their relatives who have been affected by the conflict.

Diagram of proposed structure not available in web version, for hardcopy email mail@brandonhamber.com

4.2 Does the draft Action Plan contain meaningful targets, the implementation of which will lead to a noticeable improvement in the services provided for victims (section 4.6)?

The Action Plan contains a number of useful and interesting steps, some of which could definitely improve service provision, and most we would welcome if implemented.

However, we feel the reasoning behind the inclusion of certain issues and how these relate to a broader strategic vision are not clear. In fact, many of the action steps read as objectives, rather than specifically as actions.

Thus, our main point is that the plan as it stands seems to be going in a range of directions without any clear strategy behind it. It seems to be attempting to deal with (using the analysis we posed above) both the ‘psychosocial issues’ and the ‘historical legacy issues’ simultaneously, but not in any coherent fashion. The plan, in our opinion, would be better structured if some issues were placed under a heading of ‘Psychosocial Support’ and this would include items focusing on housing support, counselling, small business development skill development, etc., and others under ‘Dealing with the Historical Legacy’, or at the very least other sub-headings such as ‘Acknowledgement’, ‘Commemoration’ and ‘Justice’.

We also think there is too much focus on the issues of re-skilling at the expense of dealing with the specific mental health care needs of individuals. International experience teaches that dealing with long-term impact of violence on individuals cannot simply be overcome by attempting to get them employed, or to access more housing benefit, for example. Although, these are vitally important and it is commendable that they are there as they show a holistic understanding of the impact of violence, there needs to be more focus in the plan on the long-term physical and psychological needs of those who have suffered as a result of a violent incident. International experience and research suggests these needs linger for decades and require both statutory and extensive community-based intervention.

From another angle, and in light of our earlier analysis, we feel the justification and understanding of including certain issues in the Action Plan needs to be carefully scrutinised. Above we made a distinction between the ‘psychosocial needs’ of those affected and the ‘historical legacy issues’ and some of the issues mentioned in the Action Plan (such as steps focusing on memorials, story telling, etc.) would fit with the latter. However, in order for it to be useful, the reasons for dealing with these ‘historical legacy issues’ and not others (say, mentioning other documentation projects such as the BBC ‘State Apart Series’, or the Legacy Programmes as a form of storytelling, or supporting community-based storytelling and commemoration) would need to be justified in the final strategy document.

This is again reinforced by issues in the Action Plan from 21.-25. about young people. With these particularly, it is not clear as to which issues some of the recommendations are being addressed, e.g. are the parenting skills related directly to those who suffered as a result of the conflict, or just in general?

On a separate issue, point 19. about inquest papers and whether counselling be offered — the idea of carrying out further research would be a waste of resources; as there are no doubt studies out there which would justify supporting people who would go through such a process.

In conclusion, the question asks about ‘noticeable improvements in the services’ and some of the suggestions made no doubt will help. However, some issues such as the storytelling, or memorial suggestions — as much as we would be in favour of such programmes — are not about service delivery at all, making answering a question about improved service delivery impossible. This reinforces our earlier points that the strategy needs be clear as to what issues in relation to those affected by the conflict it is attempting to address, i.e. psychosocial support and/or historical legacy issues. If the latter is included this needs to be more delineated and contextualised in the entire strategy.

4.3 Are there targets or target areas which should be included in the draft Action Plan which currently are not (section 4.6)?

This is a difficult question to answer as in many senses it depends on the approach adopted by the overall strategy. If a narrow focus is taken focusing on service delivery, there are many areas that need to be considered, for example, the training of GPs, community nurses, and other allied professionals in offering support and appropriate referral; an evaluation of the role of interdisciplinary teams within the health care service and their support to those affected by the conflict, and processes being set up (and evaluations) of necessary community programmes to address the needs of people. In addition, one would also need to think of other types of services and whether these need to be offered to those who see themselves as affected by the conflict, including the provision of structures which can offer legal advice and social assistance.

However, if one sees the strategy as dealing with the ‘legacy of the conflict issues’ then the door is wide open for many different initiatives — a plethora of examples and suggestions can be found in reports of several truth commissions, such as those in Chile and South Africa. These might include, among other things, curriculum development and how the impact of the conflict is explained and historicised for learners (this is largely captured in 20. of the action plan); the role of Government bodies in breaking down intolerance and stigma attached to ‘victims’, this may require careful scrutiny of the usage of the very term ‘victims’ and other loaded terms such as ‘criminal victims’ or ‘terrorist victims’; cultural acts aimed at reconciliation and commemoration strategies such as new shared days of remembrance or memorials could be considered; as well as developing strategies to teach human rights so as to ensure non-repetition.

Again, in line with earlier arguments, any of the examples above — or gaps — would only be useful if part of a comprehensive strategy with a clear statement of what issues it is trying to address.

4.4 How can funders make the funding process easier to understand and access (section 4.7)?

The issue is not only about making funding processes more accessible using approaches such as meeting ‘plain English’ standards, distributing calls for funding widely and holding community information sessions — it is also about understanding the nature of the work to be funded. We believe that the funding of support work to psychosocial related programmes for those affected by conflict poses a number of difficulties for traditional funding processes. Most of the aims of the projects funded are not easily quantifiable — impacts of successful projects are generally qualitative such as a ‘greater sense of inclusion’, ‘feeling less anxious’, ‘feeling more resolved’.

Consequently the work of such programmes rarely fits traditional funding language of ‘outcomes’ and ‘indicators’. The result is that those applying for funding try to and tailor their applications to fit that agenda when the funders and those funded know it is not really adding up. To truly understand the work, and design funding processes suitable for funding this type of work, much more work needs to be done in understanding the nature and extent of support that is being offered. Funding agencies need to make more use of ‘field workers’ who can gather what can be termed ‘thick’ descriptions of community projects. Community-based projects need to also be empowered to explain and document what they do. It is only when we get this right that the funding cycle will be better understood by those funding and those funded — resulting in increased understanding and access.

4.5 What other methods can be used to raise awareness of victims’ issues (section 4.9)?

The establishment of the structures (and the public appointment processes) as suggested by our submission — as well as some of the suggestions in the Action Plan in the Consultation Paper (e.g. including so-called ‘victims’ in all consultations) — would by their nature raise awareness about the issue. However, in line with our earlier analysis, we would suggest that the issue of how and what is conveyed to the public about the issue be considered more carefully and attempts made to remove some the qualifying statements that are attached to victims (i.e. the deserving and undeserving victims debate).

To this end, it may be useful for the Victims Unit to produce a public document, which, based on the work that has already documented the impact of the conflict, outlines the main parameters of the impact of the conflict on those affected. In fact, the entire first component of any comprehensive strategy should be based on such foundation. It may be useful to get the Assembly to ratify such a document to ensure that it is officially acknowledged that many people are still suffering from the impact of the conflict very directly.

4.6 What statutory sector partnerships need to be developed (section 4.11)?

One of the key areas where partnerships need to be developed would be between different agencies. The Consultation Paper moves towards this in recognising the importance of education, housing, health and social service issues for those affected by the conflict. This is reinforced by the moves towards trying to establish an IDWG. However, such a process needs to be matched by localised working forums and partnerships between the same role-players.

The South African process of developing a Victim Support Programme for Victims of Crime under the National Crime Prevention Strategy provides a useful parallel. The strategy argued for an inter-departmental committee to deal with the issues. This was set up at a national level — and although a number of joined-up and creative programmes and policies were recommended many of these were not implemented as similar localised structures were not in place.

4.7 How best can the statutory sector work in partnership with the voluntary/community sector (section 4.12)?

It is encouraging that the issue of statutory and voluntary interaction is highlighted because partnership between the two is vital. Nevertheless, it is important to move from a base that acknowledges substantial levels of mistrust between the sectors. Almost all community and so-called ‘victim groups’ will voice the opinion that the statutory sector has failed in its responsibility in the past to meet the needs of those affected in the conflict. The statutory sector, if one is to be general, most often retorts that it did what it could within the context and is suspicious of the quality of services that community groups offer and offered. There are also difficulties and strong differences of opinion within the statutory sector. Whether these perceptions are right or wrong, a gap exists between service providers at a number of levels.

Thus, the starting point for building lasting partnerships is to deal with some of these issues in a constructive manner — forums need to be created where constructive discussion and reflection can be held.

At the same time, various structures can support this process and practically begin developing such partnerships. This relates specifically to the suggestions of having an Advisory Committee and local Psychosocial Support Advisory Panels (see suggestions in 4.1) made up of representatives from both sectors. Importantly, however, all people on these panels should be selected through public appointment processes to ensure maximum participation and a legitimation of these bodies.

4.8 How best can those who carry out or commission research engage with victims to ensure that relevant research is carried out and followed up on (section 4.15)?

There is much that could be said about the process of engaging in research with those affected by the conflict. On one level, the process of research with such individuals should be no different to that of any other research process, i.e. all research should be passed through an ethics process, subjects’ participation should be voluntary, principles of confidentiality should be respected, all those researched have a right to access the final product and reportbacks should be mandatory. A process of openly discussing the research agenda and what can be expected of either parties should be discussed before the research commences. Where possible the research should be done in partnership with, and be empowering for, those involved. All researchers should be trained in aspects of research and performance monitored.

A further issue to consider is training researchers to manage the potential for vicarious traumatisation. This can affect them personally and how they undertake their work and how they relate to those affected by the conflict. For example, high levels of traumatisation with some of the staff and researchers were observed during the life of the South African Truth and Reconciliation Commission. Some of these symptoms and signs of vicarious traumatisation which TRC staff have experienced have included nightmares, paranoia, emotional bluntness, physical problems (e.g. headaches, ulcers, exhaustion, etc.), high levels of anxiety, irritability and aggression, relationship difficulties and substance abuse related problems. Some of those who interviewed victims of violence, as well as those who simply read and processed harrowing statements, experienced these problems.

In conclusion, those researching in this area should be trained in ethical research methods as mentioned. They should receive specific training about the context of the conflict and its psychosocial impact on individuals and communities, as well as on themselves. In addition, all those interviewing victims of violence should be trained on how to do this in a psychologically sensitive manner and be equipped with referral lists and useful phone numbers of support agencies — for themselves and those they are interacting with.

4.9 What steps, if any, do OFMDFM and the NIO need to take to ensure that victims know the relevant part of Government to access for help (section 5.3)?

The fact that there is some confusion between the OFMDFM and NIO functions with regards to so-called victim issues is well known. There have been several attempts to clarify this and the publication of the different remits in the Consultation Paper has been useful in reinforcing the distinctive roles. The only way, other than continually publicising the difference to help understand the situation would be to begin to move towards actually amalgamating the process. This could prove incredibly difficult and is currently legally impossible. However, if one takes a holistic view of the issue at hand it is clear from our arguments that some of the issues under the remit of the NIO will impact on the way those affected by conflict will attempt to deal with the situation, e.g. compensation, justice. The IDWG will have to discuss these issues and find ways to resolve the potential confusions if it is to ensure a comprehensive approach to those affected by the conflict is developed.

4.10 If such seminars or conferences were to be held, what subjects should they address (section 5.5)?

There are many issues that could be dealt with through conferences and seminars. However, in line with the broad thrust of this submission, we feel that greater exploration of the complexities of dealing with the impact of the conflict should be undertaken. Such events need to look at the long-term nature of dealing with the issues at hand (international precedence would suggest that it will be for the next few decades that the impact of the conflict on individuals and their families will be felt). The relationships between the different aspects that those affected by violence need to be addressed, such as their social, psychological and economic needs. The way that different governments deal with the legacy of violence (and their failures such as trying to find short-term solutions to a long-term problem) would also make for fruitful investigation.

Furthermore, discussion on the interrelationship between healing and issues such as truth, justice, reparation, commemoration and acknowledgment needs to take place. Exploration of community and culturally specific methods for dealing with the impact of violence can also be useful, along with understanding local and traditional forms of support, coping and resilience.

4.11 If the Touchstone Group is to be replaced, what should replace it? Who would be on any new group and how would they be selected (section 5.6)?

In line with our arguments in 4.1, we would support the establishment of an Advisory Committee to advise and guide the work of the OFMDFM and IDWG. This would be similar to the concept of the Touchstone Group. However, the selection process for the membership to that group should be public and transparent and have come through public appointment of individuals to the Psychosocial Support and Advisory Panels as argued in 4.1. It is vital that the representatives of the group are seen as legitimate and appropriate for the task at hand and are publicly appointed.

4.12 Should a Victims Commissioner be appointed? If yes, what should their role and remit be and how would a Commissioner fit with the other potential structures outlined in this Chapter (section 5.7)?

We are not convinced that a Victims Commissioner would be a useful addition to the current structure. We are primarily concerned that the appointment would help cement forms of ‘victimhood’ and become another controversial issue within the debate creating further division rather than ameliorating it.

In line with our earlier debates and our delineation of issues between ‘psychosocial service issues’ and ‘historical legacy issues’, we feel a post like Victims Commissioner could conflate the issues once again. To expand: if the main tenets of the Consultation Paper form the basis of the strategy then the strategy will largely be dealing with service delivery related issues and not ‘historical legacy issues’ such as acknowledgement, justice and remembrance. Although the services, as we have stated, are vitally necessary they are not sufficient to deal with all the needs of so-called victims. By creating a Commissioner for this process it will reinforce the perception that this individual is tasked (either in writing or in perception) with smoothing and dealing with the difficult and fraught issue of addressing the ‘service’ and ‘historical legacy’ needs of those who have suffered through incidents of violence.

To deal with service related issues, the structures and processes outlined in this submission, supported with a publicly accepted Advisory Committee and Panels, should be sufficient to guide the OFMDFM’s implementation and delivery of accessible and appropriate services. If these bodies are working properly there is no need for a Commissioner, whose appointment would inevitably be followed by some bureaucratic structure creating more confusion for those wanting to access the system.

We have noted that discussions on the ‘historical legacy issues’ need to begin through the IDWG, Advisory Committee and Panels. Any involvement or discussion in these issues from the Assembly perspective, given their highly charged nature, should be run through a highly representative process and not tasked to one individual who will invariably be pulled between perspectives, or branded as carrying a specific political agenda — rightly or wrongly.

Thus, we feel the emphasis should be on getting structures operating at local and Assembly level before any decision on a Commissioner is taken. After careful consideration, we are also not convinced by any arguments that say that so-called ‘victims’ need an additional ‘listening ear’ or ‘champion’. It appears that if you ask most people they will say that action is what is needed. The introduction of a new person into the system will result in another round of consultations, specifically with the so-called ‘victims groups’, who have been subjected to a number of such consultations over the last few years. In the final instance, we feel the Assembly — as a representative body of the people — should be seen as a whole to be prioritising and dealing with this issue, not an individual.

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Reference: www.brandonhamber.com/publications/sub-ddvictims.htm