SAFECHAIN™ Policy Brief for the Domestic Abuse Commissioner

SAFECHAIN™ Policy Brief for the Domestic Abuse Commissioner

Strengthening Safeguarding Infrastructure, Participation Integrity and Institutional Accountability for Survivors of Domestic Abuse

Version 2.0

Prepared by

Samantha Avril-Andreassen
Founder – SAFECHAIN™

Executive Summary

Domestic abuse is not solely a safeguarding issue.

It is also a systems issue.

Survivors frequently encounter multiple institutions simultaneously, including:

• family courts;

• police safeguarding units;

• housing authorities;

• healthcare providers;

• local authorities;

• legal representatives;

• financial institutions;

• domestic abuse services.

While each institution may operate within established safeguarding frameworks, survivors often experience those systems as fragmented rather than coordinated.

The result can be a cumulative safeguarding burden whereby vulnerable individuals are repeatedly required to disclose traumatic experiences, navigate complex procedural environments, and advocate for themselves while simultaneously recovering from abuse.

SAFECHAIN™ has been developed as a safeguarding governance and interoperability framework intended to explore whether stronger coordination, participation safeguards, documentation continuity, and institutional accountability can improve outcomes for survivors.

This briefing proposes that future safeguarding reform should move beyond crisis response and examine the broader infrastructure through which survivors interact with institutions.

The Structural Safeguarding Challenge

The United Kingdom has developed substantial legislative protections for victims of domestic abuse.

These include:

• Domestic Abuse Act 2021;

• Human Rights Act 1998;

• Equality Act 2010;

• Serious Crime Act 2015;

• Family Procedure Rules;

• Practice Direction 3AA;

• statutory safeguarding duties across public bodies.

Despite these protections, survivors frequently report difficulties arising not from the absence of law but from the operational interaction between institutions.

Common themes include:

• repeated disclosure of abuse;

• fragmented information sharing;

• inconsistent recognition of vulnerability;

• participation barriers within legal proceedings;

• economic abuse and coercive debt;

• housing insecurity;

• safeguarding blind spots;

• procedural escalation during periods of trauma.

SAFECHAIN™ proposes that safeguarding reform must examine these structural interactions rather than viewing each institution in isolation.

Participation Integrity in Family Proceedings

One of the most significant safeguarding challenges concerns participation.

Many survivors encounter family proceedings while experiencing:

• trauma;

• post-traumatic stress;

• anxiety disorders;

• coercive control;

• housing instability;

• economic hardship.

While legal rights may formally exist, the practical ability to exercise those rights can be significantly affected by vulnerability.

SAFECHAIN™ refers to this as Participation Integrity.

Participation Integrity concerns whether an individual is genuinely able to:

• understand proceedings;

• engage with evidence;

• prepare documentation;

• instruct legal representatives;

• attend hearings;

• respond to deadlines;

• communicate effectively.

The framework proposes that safeguarding systems should place greater emphasis on participation capacity rather than assuming equal procedural capability between parties.

Procedural Attrition and the Weaponisation of Process

Survivors frequently report that prolonged procedural environments can become overwhelming.

This may arise through:

• repeated applications;

• extensive disclosure requirements;

• escalating legal costs;

• information overload;

• complex procedural timetables;

• prolonged litigation.

SAFECHAIN™ refers to this phenomenon as procedural attrition.

Procedural attrition does not necessarily imply misconduct.

Rather, it recognises that process itself may become a source of pressure where significant disparities in resources, expertise, or resilience exist.

The framework proposes that future safeguarding reform should examine whether prolonged procedural environments may inadvertently disadvantage vulnerable participants.

The issue is not simply access to justice.

It is the ability to remain engaged with justice.

Coercive Debt and Economic Abuse

The Domestic Abuse Act 2021 recognises economic abuse as a form of domestic abuse.

However, financial harm frequently extends beyond the relationship itself.

Survivors may experience:

• coercive debt;

• damaged credit records;

• housing insecurity;

• mortgage arrears;

• financial exclusion;

• inability to access legal representation;

• dependency created through financial control.

SAFECHAIN™ proposes that economic abuse should be understood as a safeguarding issue rather than solely a financial issue.

The long-term effects of coercive debt can influence:

• housing stability;

• healthcare access;

• employment;

• participation in legal proceedings;

• recovery from abuse.

Future safeguarding infrastructure should therefore include greater recognition of financial vulnerability indicators.

Documentation Continuity

Survivors often describe having to repeatedly retell traumatic experiences to different institutions.

A single survivor may disclose substantially the same information to:

• police;

• housing services;

• healthcare professionals;

• social workers;

• court services;

• domestic abuse organisations.

Repeated disclosure may contribute to:

• retraumatisation;

• information fatigue;

• inconsistencies caused by trauma-related memory difficulties;

• safeguarding inefficiencies.

SAFECHAIN™ explores whether documentation continuity models could reduce the burden of repeated disclosure while preserving privacy, consent, and data protection.

Institutional Blind Spots

The Macpherson Report highlighted how institutional failures may arise through systemic processes rather than individual intent.

SAFECHAIN™ applies this principle to safeguarding environments.

Institutional blind spots may arise where:

• information is fragmented;

• agencies operate independently;

• vulnerability indicators are not visible;

• safeguarding responsibilities become diffused;

• communication pathways are unclear.

The result may be that no individual institution sees the complete safeguarding picture.

Future reform should therefore consider how institutions can maintain independence while improving safeguarding visibility.

SAFECHAIN™ Infrastructure Proposal

SAFECHAIN™ proposes a privacy-protected safeguarding interoperability framework built upon five pillars.

Participation Integrity

Recognition of participation barriers arising from trauma, vulnerability, disability, or economic disadvantage.

Documentation Continuity

Reducing unnecessary duplication of disclosure across institutions.

Safeguarding Visibility

Improving awareness of safeguarding indicators while maintaining confidentiality.

Institutional Accountability

Supporting transparent governance, auditability, and safeguarding oversight.

Cross-Agency Coordination

Improving institutional coherence without altering statutory authority.

Relevance to the Domestic Abuse Commissioner

The Domestic Abuse Commissioner plays a critical role in identifying structural issues affecting survivors.

SAFECHAIN™ is therefore presented not as an operational intervention model but as a contribution to broader discussions regarding:

• safeguarding reform;

• institutional accountability;

• participation rights;

• economic abuse;

• trauma-informed governance;

• procedural fairness;

• cross-agency safeguarding.

The framework aligns closely with the Commissioner's objectives of improving how institutions respond to domestic abuse across the wider safeguarding ecosystem.

Policy Recommendations

SAFECHAIN™ recommends further exploration of:

1. Participation Integrity assessments within family proceedings.

2. Greater recognition of coercive debt as a safeguarding issue.

3. Trauma-informed procedural safeguards across public institutions.

4. Documentation continuity mechanisms to reduce repeated disclosure.

5. Cross-agency safeguarding visibility frameworks.

6. Research into procedural attrition affecting vulnerable litigants.

7. Institutional accountability measures focused on safeguarding outcomes rather than isolated organisational performance.

8. Pilot evaluation of privacy-protected safeguarding interoperability infrastructure.

Conclusion

Domestic abuse safeguarding cannot be viewed solely through the lens of individual incidents.

It must also be viewed through the systems that survivors are required to navigate afterwards.

The challenge facing policymakers is not simply how institutions respond to abuse.

The challenge is how institutions respond when abuse intersects with housing, finance, health, safeguarding, legal proceedings, and recovery simultaneously.

SAFECHAIN™ proposes that stronger safeguarding outcomes may depend upon stronger institutional coordination, participation safeguards, documentation continuity, and accountability infrastructure.

The objective is simple:

To ensure that survivors are not required to carry the burden of navigating fragmented systems at the precise moment they are most vulnerable.

© 2026 Samantha Avril-Andreassen. All rights reserved.

SAFECHAINN Ltd (Company No. 12038453)

Registered Office:
71–75 Shelton Street,
Covent Garden,
London,
WC2H 9JQ

Version 2.0
SAFECHAINN Ltd