Submissions

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Our submissions draw on specialist expertise to inform state and federal policy and legislation. We develop these in consultation with our member organisations, survivor advocates, and other subject matter experts. This is to ensure the experiences of victim survivors and the specialist family violence sector shape government policy and legislation.

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2025-26 Victorian State Budget Submission

Safe and Equal is calling on the Victorian Government to prioritise funding for three critical focus areas in the 2025—26 Victorian State Budget.

Submission on the draft Advice on the National Suicide Prevention Strategy

Safe and Equal welcomes the opportunity to provide feedback on the draft Advice on the National Suicide Prevention Strategy and highlight the relationship between family violence and suicide and identify opportunities to strengthen the draft to more explicitly account for, and address, this relationship.

Submission to South Australia’s Royal Commission into Family Violence

Safe and Equal welcomes the opportunity to make a submission to South Australia’s Royal Commission into Family Violence.

Submission to the Victorian Inquiry into Women’s Pain

As the peak body for specialist family violence services and organisations in Victoria working across the continuum from prevention to response, our submission is focused on the intersect between family violence and women’s experiences of pain.

Submission into the Standing Committee on Social Policy and Legal Affairs Inquiry into Family Violence Intervention Orders

Safe and Equal welcomes the opportunity to contribute to the Standing Committee on Social Policy and Legal Affairs Inquiry into family violence intervention orders.

Submission to the Victorian Legislative Assembly’s Legal and Social Issues Committee Inquiry into Capturing Data on Family Violence Perpetrators in Victoria

Safe and Equal welcomes the opportunity to provide a submission into the Victorian Legislative Assembly’s Legal and Social Issues Committee Inquiry into Capturing Data on Family Violence Perpetrators in Victoria.

Safe and Equal’s submission to the Australian Law Reform Commission’s inquiry into justice system responses to sexual violence

Safe and Equal endorsed the Sexual Assault Services Victoria submission and provided this submission focussing on the co-occurrence of sexual violence within a family violence context.

Submission to the Third Family Violence Rolling Action Plan

Safe and Equal welcomes the opportunity to provide feedback on the development of the third and final Rolling Action Plan (RAP) under ‘Ending family violence – Victoria’s 10-year plan for change’.

2024-25 Victorian State Budget Submission

Safe and Equal is calling on the Victorian Government to ensure family violence funding is continued, as one of four critical areas to prioritise in the 2024-25 State Budget.

Response to the Inquiry into the rental and housing affordability crisis in Victoria final report

Safe and Equal welcomes the Final Report of the Inquiry into the rental and housing affordability crisis in Victoria, released last week by the Legislative Council Legal and Social Issues Committee.

Response to National Autism Strategy

Safe and Equal recently responded to the consultations for the development of a National Autism Strategy being undertaken by the Department of Social Services

Submission to the National Housing and Homelessness Plan

Safe and Equal welcomes the opportunity to contribute to the National Housing and Homelessness Plan, answering the question ‘How can governments and community service providers reduce homelessness and/or support people who may be at risk of becoming homeless in Australia?’

Submission to the Independent Review of the National Disability Insurance Scheme

Safe and Equal recently responded to the Independent Review of the National Disability Insurance Scheme (NDIS).

Submission to the Senate inquiry into the Worsening Rental Crisis in Australia

Safe and Equal recently responded to the Senate Standing Committees on Community Affairs inquiry into the Worsening Rental Crisis in Australia.

Submission to Draft regulations and Regulatory Impact Statement for social services

Safe and Equal welcomes the opportunity to contribute to the consultation on the Draft Regulations and the Regulatory Impact Statement on the Social Services Regulation.

Submission to the Inquiry into the Rental and Housing Affordability Crisis in Victoria

Safe and Equal welcomes the opportunity to contribute to the Inquiry into the Rental and Housing Affordability Crisis in Victoria.

Safe and Equal’s submission to the MARAM 5-year evidence review

Safe and Equal is pleased to provide a submission to the Multi-Agency Risk Assessment and Risk Management Framework’s (MARAM) 5-year evidence review.

Family Law Council Consultation Submission Summary

Safe and Equal recently responded to an online Family Law Council consultation on the experiences of children and young people moving thorough the Australian family law system.

2023 State Budget Submission

Safe and Equal calls for continued investment, collaboration and action for the specialist family violence services and primary prevention sectors in the 2023 State Budget.

Employment White Paper Response

Safe and Equal welcomes the focus of the White Paper on a sustainable care industry alongside women’s economic participation, experiences of the labour market and the challenges of ensuring women have equal opportunities and equal pay.

Five-year legislative review – Submission to the Family Violence Reform Implementation Monitor

Safe and Equal welcomes the opportunity to contribute to the Family Violence Reform Monitor’s Independent legislative review of family violence reforms.

Submission to the Inquiry into children affected by parental incarceration

Safe and Equal welcomes the opportunity to contribute to the Inquiry into Children of Imprisoned Parents. As the peak body for specialist family violence services that provide support to victim survivors in Victoria, our response to this inquiry centres the devastating and long-term impacts of family violence on children and their incarcerated family members.

Safe and Equal Response to the NHHA Issues Paper

Safe and Equal welcomes the opportunity to comment on the Productivity Commission’s review of the effectiveness of the National Housing and Homelessness Agreement (NHHA).

Submission to the Social Housing Regulation Review Interim Report

Housing, homelessness and family violence are inextricably linked. Therefore, as the peak body for specialist family violence services in Victoria, Safe and Equal has a special interest in making sure social housing meets the needs of victim survivors and supports their safety. Proper regulation is one mechanism to help achieve this.

Feedback for the Draft National Plan to End Violence Against Women and Children 2022 – 2032

Safe and Equal welcomes the opportunity to comment on the draft National Plan to End Violence Against Women and Children 2022-2032.

Current Scheme Implementation and Forecasting for the NDIS: Response to the Terms of Reference

Safe and Equal welcomes the opportunity to contribute to this inquiry on the Current Scheme Implementation and Forecasting for the National Disability Insurance Scheme (NDIS).

2022 State Budget Submission

Whilst the significant amount of investment in improving Victoria’s family violence system following the Royal Commission is much welcomed, a range of complex factors are creating clear gaps and pressure points. These must be addressed immediately to ensure every victim survivor can access the support and safety they need at the time they need it.

Submissions
Archive

This section includes submissions developed by Domestic Violence Victoria (DV Vic) prior to merging with Domestic Violence Resource Centre Victoria (DVRCV) to form Safe and Equal.

2021

Submission to the Social Housing Regulation Review
7 October 2021

This submission highlights principles that DV Vic and DVRCV believe should underpin social housing regulations and how they relate to victim-survivors of family violence.  These include:

  1. Housing is well and consistently integrated with a range of support services;
  2. Housing providers must be adequately trained and equipped to work with tenants with a range of complex needs; and

Tenants need to be genuinely involved at all levels of social housing regulation on an ongoing basis.

Download Submission to Social Housing Regulation Review.

Submission to the Successor National Plan to End Violence Against Women and Children
24 August 2021

DV Vic and DVRCV welcome the Commonwealth Government’s development of the successor National Plan to End Violence against Women and appreciate the opportunity to contribute towards its development.

In this submission, we highlight key priorities and focus areas that should be incorporated into the successor National Plan to address the issues and themes that emerged during consultations with our members and the Survivor Advisory Group (now called the Expert Advisory Panel) and that would address gaps and shortcomings identified in recent inquiries and research.

Download Submission to the Successor National Plan to End Violence Against Women and Children.

ParentsNext: Examination of Social Security (parenting payment participation requirements – class of persons) Instrument 2021
10 May 2021

DV Vic and DVRCV welcome the opportunity to provide a submission to the Parliamentary Joint Committee on Human Rights on ParentsNext: Examination of Social Security (Parenting payment participation requirements – class of persons) Instrument 2021.

While we understand the importance of addressing barriers to further education and employment, we have serious concerns about the human rights implications of the measure on victim survivors of family violence. These concerns include:

  • impacts of non-compliance on an adequate standard of living
  • lack of flexibility of the ParentsNext program in practice
  • ineffectiveness in addressing barriers to education and employment
  • ineffectiveness of compulsory participation.

These concerns align with the key points elaborated on in the submission by the Council of Single Mothers and their Children (CSMC), whose submission DV Vic and DVRCV endorse.

Download Submission to ParentsNext: Examination of Social Security (Parenting payment participation requirements – class of persons) Instrument 2021

Consultation on Establishing a 10-year Strategy for Social and Affordable Housing
27 April 2021

DV Vic and DVRCV welcomes the commitment of the State government and Homes Vic to ensure Victorians can access a safe, affordable and appropriate home. The 10-year strategy for Social and Affordable Housing shows a strong commitment to ensuring people in Victoria can access a safe, affordable and appropriate home.

DV Vic and DVRCV believe that victim survivors have a right to a safe, affordable and appropriate home and that the Victorian Government has a responsibility to realise this possibility.

We look forward to working with Homes Vic and the Victorian Government to extend and strengthen the Strategy’s vision for victim survivors.

Download Submission to the Consultation on Establishing a 10-year Strategy for Social and Affordable Housing

Joint Standing Committee on the National Disability Insurance Scheme – Inquiry into Independent Assessments
7 April 2021

This submission broadly addresses the terms of reference for the inquiry with a specific focus on the implications of independent assessments for victim-survivors of family violence with disability.

This submission also builds on the DV Vic/DVRCV’s recent submission to the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability and highlights some of the positions outlined therein.

Download Submission to the Joint Standing Committee on the NDIS – Inquiry into Independent Assessments 

2021–22 Victorian State Budget
3 August 2021

This submission looks at the needs, impacts and solutions for specialist family violence services regarding access to adequate and sustainable resources within the broader family violence service system.

The investment in groundbreaking family violence reforms resulting from the Royal Commission into Family Violence is changing the family violence system to achieve the vision of the Royal Commission. For specialist family violence services, the impact of these system reforms is profound.

However, to achieve the long-term vision of the Royal Commission, we must ensure that all elements of the service system are funded adequately into the future. There is still more to be done to “lift the whole of the system” commensurately and sustainably.

Download 2021–22 Victorian State Budget Submission

Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability Issues Paper - Violence and abuse of people with disability at home
16 March 2021

The content of this submission draws on the practice wisdom and expertise of our member services who work with victim survivors of family violence as well as current research and evidence examining the experiences of victim survivors with disabilities.

Family violence includes violence, abuse, neglect and exploitation of victim survivors with disabilities that occurs within the context of family, domestic, intimate and ‘family-like’ relationships, including violence perpetrated by a carer (paid or unpaid).

We highlight key issues and themes that emerged during the consultations with our members and following a review of available research and evidence.

Download Submission to the Violence and Abuse of People with Disability at Home Issues Paper

Consultation on a Bill for a new Online Safety Act
18 February 2021

The Online Safety Bill strengthens many of the existing schemes, adds a cyber-abuse scheme, and increases the power of the eSafety Commissioner. DV Vic welcomes the commitment of the Australian Government to improve Australia’s online safety laws.

DV Vic believes that victim survivors have a right to use technology, and that internet service providers, social media services or relevant electronic services have a responsibility to ensure the online safety of their users. While there are significant improvements, we submit that some of the proposed changes can be strengthened to support victim survivors.

Download Submission for a new Online Safety Act

Victorian LGBTIQ+ Strategy Directions Paper
22 February 2021

The LGBTIQ+ community was identified by the Royal Commission into Family Violence as one of the community groups at increased and particular risk of family violence. Evidence is emerging that LGBTIQ+ people experience family violence at commensurate, if not higher, levels to the rest of the community.

The Private Lives 3 report found that almost two in five (38.5 per cent of 6815) respondents reported being abused by a family member, including both birth and chosen family.

The establishment of the Victorian LGBTIQ+ Strategy and proposed LGBTIQ+ taskforce provide a valuable opportunity for connection and alignment between the vision for LGBTIQ+ communities and the family violence reform agenda in Victoria.

Our submission in response to the LGBTIQ+ Strategy Directions Paper reflects this.

Download Submission to the Victorian LGBTIQ+ Strategy

Victorian Law Reform Commission Improving Justice Responses to Sexual Offences Inquiry
1 February 2021

Sexual assault that occurs within the context of family violence is common and underreported. While reform activity since the Victorian Royal Commission into Family Violence is resulting in specialist family violence responses being developed by the justice system, the reality for many victim survivors is that they still confront barriers in accessing justice, safety and support. These barriers are compounded by the hidden nature of sexual assault, the misconception that most sexual assault is committed by strangers and the lack of understanding about the nature and dynamics of sexual assault in the context of family violence.

In this submission we seek to bring attention to the complexity that stems from the co-occurrence of family violence and sexual assault. We highlight the importance of developing ‘whole of system’ victim-centred and trauma-informed processes and responses.

Co-occurrence in this submission, refers to ’when an intimate partner uses sexual violence’. Consequently, comments made in this submission primarily relate to how justice responses can be improved for adult victim survivors of sexual violence.

To provide context for our submission, we first detail the prevalence, nature and dynamics of sexual assault within the context of family violence including the risk and safety implications for victim survivors. We then respond to questions where DV Vic can contribute relevant knowledge and expertise.

The answers we provide speak to the broad themes that cut across all the Inquiry issues papers. These are:

  • equitable access to justice
  • designing responses that meet the needs and experiences of all victim survivors
  • building on past reforms and complementing current reform activity that is underway
  • considering a range of justice options.

Download the Submission to Victorian Law Reform Commission

Victorian Youth Strategy
17 January 2021

We believe young people are incredibly resilient, resourceful and creative. We support the proposed vision statement that young Victorians should be supported to participate and contribute fully and safely in the community, with equitable opportunity to do so. We submit however, that the capacity for young Victorians to live freely and reach their potential now, and into the future, is vastly impacted by experiences of family violence and the community attitudes that underpin and drive patriarchal, gendered violence.

This submission points to the need for the new Victorian Youth Strategy to reflect the true diversity in experiences of family violence among young people. Without a well-informed and nuanced approach, young people will continue to fall through the gaps of the service system.

We suggest that a key priority for Victoria should be system collaboration that addresses systemic barriers to young people escaping family violence in accessing the support they need. As long as the youth service system remains largely siloed, young people with multiple or intersecting support needs will continue to be disadvantaged. While we understand these issues better than ever, a significant gap remains in data and knowledge when it comes to young people and family violence. The development of the new Victorian Youth Strategy provides a critical opportunity to build nuanced policy platforms that recognise and reflect the diversity of young people in our state.

Download Submission to the Victorian Youth Strategy

2020

Victorian LGBTIQ Strategy Discussion Paper
22 September 2020

DV Vic recognises that family violence occurs in all communities. We have been particularly engaged over recent years with providing direct support to the specialist family violence service sector as well as championing change to improve access and inclusion for LGBTIQ people.

Rather than addressing specific questions in the LGBTIQ Strategy Discussion Paper we have sought to provide an overview of our key learnings that touch on questions raised for consideration, particularly in relation to inclusive services and family violence. We have done this in the hopes that our experience will provide guidance for the development of the strategy and contribute to greater inclusion of Victorian LGBTIQ communities across service sectors.

Download Submission to Victorian LGBTIQ Strategy Discussion Paper

Review of Real Estate Education Regulations
22 September 2020

In December 2019, DV Vic provided a submission to Consumer Affairs Victoria regarding changes to the proposed Residential Tenancies Regulations 2020 under the Residential Tenancies Amendment Act 2018 (Vic) to increase support, protections and housing security for victim survivors of family violence. These changes are in line with the recommendations of the Victorian Royal Commission into Family Violence.

We support the changes and the increased protections they will provide for victim survivors of family violence in private rental accommodation once they are fully implemented.

Download Submission regarding proposed changes to Residential Tenancies Regulations

National Inquiry into Family, Domestic and Sexual Violence
10 August 2020

We acknowledge the commitment and action taken to date by governments across Australia to address violence against women and their children. While the National Plan to Reduce Violence against Women and their Children 2010-2022 has laid the foundations for a national approach, there is much that can be strengthened to provide increased coordination and consistency.

Across Australia numerous inquiries have been held into family, domestic and sexual violence, with deep interrogation of the prevalence, dynamics, impact, prevention and response efforts, and legal and public policy landscape. These past inquiries provide the Australian Government with extensive information and analysis to inform the next steps of national leadership, coordination and investment through the next national plan. We encourage this committee to consider and review this evidence alongside the emerging research and trends, while maintaining a focus on the safety, wellbeing and freedom of victim survivors.

We also encourage the committee to broaden their view when considering the terms of reference and making recommendations to inform the next national plan. Any actions taken to address violence against women and children and address gender inequity necessarily means keeping those who use harm, violence and control in view and engaged, and actively involving all parts of society in the journey towards equality and respect.

Given the plethora of information available, this submission will direct the committee’s attention to the existing and emerging evidence, and unresolved recommendations, and highlight key areas for further focus and reform. We appreciate government commitment to innovate, try new approaches and generate ideas to make headway on an intractable social problem. However, care must be taken not to fall into the trap of producing stand-alone or siloed responses, hoping that one new addition or change will, by itself, make all the difference. Reducing violence against women and children is a long-term, intergenerational goal requiring sustained, scaffolded, and coordinated actions and investment.

Download Submission to National Inquiry into Family, Domestic and Sexual Violence

Implementation of the Royal Commission recommendations
3 August 2020

Since the Royal Commission into Family Violence, the Victorian Government has invested nearly $3 billion to implement the Royal Commission’s recommendations. This investment has created rapid change reflective of an ambitious reform agenda, on a scale not previously attempted.

In many instances the impact of the immediate reforms is only just starting to be felt as the reform agenda moves from design to implementation and measuring outcomes.

In this submission, DV Vic points to several areas requiring priority attention as the family violence reforms progress. Chief among them is implementation coordination and planning, including greater transparency and accountability in reform governance.

This submission also includes evidence emerging from the impact of the COVID-19 pandemic. It discusses COVID-19 in relation to the agility and readiness of the family violence response system in Victoria to respond to whole of community crises.

Download Submission on the Implementation of the Royal Commission recommendations

National Inquiry into Homelessness
11 June 2020

Family violence is the most common reason that victim survivors of family violence, including children, become homeless. Our submission focuses on the following points within the Terms of Reference as they relate to victim survivors of family violence:

  • Opportunities for early intervention and prevention of homelessness.
  • Services to support people who are homeless or at risk of homelessness.

This submission complements other submissions made by our colleagues in the community services sector with a range of expertise. This submission intends to bring a specific family violence lens to this other work. As a member of the Australian Women Against Violence Alliance (AWAVA), DV Vic endorses AWAVA’s submission to this Inquiry.

Download Submission to National Inquiry into Homelessness

Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability Issues Paper – Criminal Justice System
7 April 2020

Current research shows that people with disabilities are more likely to experience family violence than people without disabilities. Further, women and girls with disabilities experience higher rates of violence and abuse than men with disabilities and “the intersection of gender and disability increases the risk of violence against women and girls with disabilities”.

This submission primarily focuses on family violence against women with disabilities that results from the intersection of systemic gender-based discrimination against women and disability-based discrimination against people with a disability.

Download Submission to Criminal Justice System Issues Paper

Joint Select Committee on Australia’s Family Law System
5 February 2020

Numerous inquiries have been held into the family law system and “the intersection between family violence and family law”.

We submit that these inquiries provide the government with an extensive analysis of what is problematic within the current family law system, and proposed solutions, to form the basis of immediate reform.

Given the amount of existing evidence, we continue to question the necessity of this Inquiry. We are reluctantly engaging in the Inquiry to ensure that it is informed by the voices of victim survivors and the organisations that support them.

We submit that change to a system, that is widely acknowledged as needing immediate reform to ensure the safety of victim survivors and their children, cannot be delayed awaiting the outcome of this Inquiry when proposed solutions have already been developed.

Download Submission to Joint Select Committee on Australia’s Family Law System

Non-fatal Strangulation Offence Consultation Paper
5 February 2020

No to Violence (NTV) and DV Vic welcome the opportunity to provide our feedback on Victoria’s proposed stand-alone strangulation offence.

We commend the Victorian Government for highlighting the serious issue of non-fatal strangulation in the context of family violence, as well as the impacts of non-fatal strangulation on victim survivors’ physical and psychological health and emphasising the association of non-fatal strangulation with family violence risk and serious injury.

However, NTV and DV Vic would like to highlight that family violence – including non-fatal strangulation – is not simply a matter for the civil and criminal legal systems to identify and respond to. Rather, family violence is a complex social problem that all segments of the Victorian community play a role in addressing.

Download NTV and DV Vic combined submission: Non-fatal strangulation offence

Religious Freedom Bills – Second Exposure Drafts
5 February 2020

DV Vic appreciates the opportunity to provide this submission on the second exposure drafts of the Religious Freedom Bill 2019, Religious Discrimination (Consequential Amendments) Bill 2019, and the Human Rights Legislation Amendment (Freedom of Rights) Bill 2019 (‘the Religious Freedom Bills’).

DV Vic supports the right of all to freedom of thought and belief, including the freedom of religion, without discrimination. DV Vic also supports the right for all people to live free from discrimination, oppression and violence.

The draft Religious Freedom Bills introduce important protections from discrimination based on religious beliefs and represent some progress towards protection from religious vilification. However, DV Vic considers they also permit harmful discrimination against, and exclusion of, already marginalised and oppressed groups. The draft Religious Freedom Bills therefore fail to strike an ethical balance between freedom of religion and the protection of the fundamental human rights of others.

DV Vic does not support the position expressed in the proposed reforms that the right to religious freedom is absolute – where the manifestation of the right to religious freedom violates other fundamental rights and is harmful to others.

Download Submission on the second exposure drafts of the Religious Freedom Bills

Inquiry into Homelessness in Victoria
5 February 2020

Family violence is the most common reason that women and children become homeless.
Nearly half (47 per cent) of people accessing specialist homelessness services agencies in Victoria in 2017–18 listed family violence as their primary reason for seeking support. This is compared to only 31 per cent in 2014–15 when Victoria’s Royal Commission into Family Violence released its report. Nearly half of the people who reported experiencing family violence were single parents and the vast majority (94 per cent) were female.

The increase in family violence-related presentations is likely to be a positive indication. It is a sign that Victoria’s family violence reforms are enabling more people to come forward and seek help. However, the increased awareness of family violence among the community means that the increase in demand is unlikely to wane. The Victorian Government needs to plan accordingly.

Download Submission to the Inquiry into Homelessness in Victoria

Proposed Residential Tenancies Regulations 2020
14 January 2020

The passage of the Residential Tenancies Amendment Act 2018 (Vic) was a significant opportunity to update the Residential Tenancies Act 1997 (Vic) to better reflect the contemporary private rental market and improve the rights and protections for tenants throughout Victoria.

It was also a significant opportunity to respond to issues identified by the Royal Commission into Family Violence relating to victim survivors’ ability to maintain and access safe and affordable housing in the private rental market.

The Regulations are an important next step in ensuring that the Residential Tenancies Act upholds the safety and rights of victim survivors of family violence, as envisioned by the Royal Commission.

Download Submission to proposed Residential Tenancies Regulations

2019

2020–21 Victorian State Budget Submission
6 December 2019

On behalf of our members, and particularly the specialist family violence services for victims survivors across the state, DV Vic has made submissions related to two main themes:

  • investing in the central role of specialist family violence services within the family violence system
  • other family violence sector investment priorities that add the greatest value to the systemic response to family violence within the overall reform agenda.

Download 2020–21 Victorian State Budget Submission

Royal Commission into Victoria’s Mental Health System
12 July 2019

DV Vic’s submission to the Royal Commission into Victoria’s Mental Health System calls for a social justice, violence-informed approach to mental health. Our submission discusses gaps in the system, the need for trauma and violence-informed therapeutic interventions, carer relationships where there is violence, and intergenerational effects of family violence on mental health.

Download Submission to Royal Commission into Victoria’s Mental Health System

Review of Early Access to Superannuation
24 February 2019

DV Vic responded to the Review of Early Access to Superannuation for victim survivors of family violence calling on the Australian Government to abandon this proposal. We reiterated the concerns we raised in early 2018, when this scheme was originally proposed, that women already have significantly less superannuation compared to men. Allowing victim survivors to access their superannuation early would put women experiencing family violence at greater risk of poverty later in life. We also argued that it is the government’s responsibility to support victim survivors of family violence. Allowing early access to superannuation is a move towards individualising a systemic social problem instead of committing to a strong social safety net that supports all women equally.

Instead of allowing early access to superannuation, we called on the Australian Government to:

  • fund services that support victim survivors of family violence such as specialist family violence services, financial counsellors and community legal services
  • fix the social security system by increasing income support payments to a level that does not leave recipients in poverty
  • fund a national Flexible Support Package program based on the Victorian model to fill this systemic gap in other states.

Finally, we highlighted several concerns about the implementation of early access to superannuation for victim survivors of family violence, should this scheme go ahead.

Download Submission to Review of Early Access to Superannuation

Senate Inquiry into ParentsNext
24 February 2019

DV Vic wrote a submission to the recent Senate Inquiry into the ParentsNext program calling on the Australian Government to abandon the compulsory and mutual obligation aspects of this program immediately.

ParentsNext is a compulsory ‘pre-employment’ program aimed at ‘vulnerable’ parents (overwhelmingly single mothers, many of whom are Aboriginal) who are on income support payments for more than six months and have children between six months and six years of age. Participation in the program is tied to the receipt of parents’ parenting payment. There have been numerous reports of women and their children being cut off from payments and put at risk of poverty and homelessness as a result.

DV Vic echoed the significant concerns raised across the community services sector about this program – namely that it is punitive, requires new mothers to participate in additional activities when many may already be struggling to adjust, and puts them at increased risk of poverty.

DV Vic highlighted the fact that a significant number of mothers required to participate in this program will have experienced family violence. ParentsNext undermines the principles of recovery and replicates power imbalances present in an abusive relationship by making women participate in the program instead of giving women the ability to choose what is best for them and their children.

By focusing the ParentsNext program on Aboriginal communities, ParentsNext also replicates a colonial mentality that refuses to give Aboriginal communities self-determination. We also argue that cutting victim survivors off their income support payments puts women and children at increased risk of family violence. Lack of economic resources is one of the main barriers to women and children leaving abusive relationships. Cutting women off from their income increases the chances that a woman and her children will be forced to return to a violent perpetrator to escape poverty and/or homelessness.

Download Submission to Senate Inquiry into ParentsNext

2018

Australian Law Reform Commission’s Review of the Family Law System Discussion Paper
3 December 2018

DV Vic made a submission to the Australian Law Reform Commission’s Review of the Family Law System: Discussion Paper. We reiterated the need to transform the family law system’s culture to one that meets the needs of victim survivors of family violence and their children.

We supported proposals that will help facilitate a coordinated trauma-informed response to the diverse and intersecting needs of family law system users, especially victim survivors. We also discussed what else should be done to move away from an adversarial system that can replicate the dynamics of family violence.

We emphasised that achieving any cultural change in Australian family law will require the Australian Government to commit to adequately funding the family law system, particularly to providing affordable legal representation and specialist support to victim survivors of family violence. This funding must also be supported by a commitment to co-designing these reforms with those currently disadvantaged by family law processes, such as women with disabilities, Aboriginal and Torres Strait Islander women, women from culturally and linguistically diverse backgrounds and lesbian, gay, bi-sexual, transgender and/or intersex women.

Download Submission to Review of the Family Law System Discussion Paper

Family Violence Information Sharing and Risk Assessment and Risk Management Framework
11 July 2018

DV Vic and endorsing organisations No to Violence, Domestic Violence Resource Centre Victoria, Djirra, inTouch, Multicultural Centre Against Family Violence and Women with Disabilities Victoria provided feedback on the redeveloped Family Violence Risk Assessment and Risk Management Framework and the Family Violence Information Scheme.

The submission responds to the following documents:

  • Family Violence Risk Assessment and Risk Management Policy and Practice Document
  • Framework Legislative Instrument – Family Violence Protection Act 2008
  • Regulatory Impact Statement – Family Violence Protection (Information Sharing and Risk Management) Amendment Regulations 2018
  • Family Violence Protection (Information Sharing and Risk Management) Amendment Regulations 2018.

It is guided by the consultation questions provided by Family Safety Victoria, and feedback is organised into key themes.

Download Submission to Family Violence Information Sharing and Risk Management Framework

Child Information Sharing Scheme Regulatory Impact Statement and Regulations
19 June 2018

DV Vic and No to Violence provided feedback on the Child Information Sharing Scheme Regulatory Impact Statement and Regulations in a joint submission.

The key points of our submission recommend:

  • managing the interdependencies of the Child Information Sharing (CIS) Scheme, Family Violence Information Sharing (FVIS) Scheme, and the The Family Violence Multi-Agency Risk Assessment and Management Framework (MARAM) by redeveloping the current implementation plan and timeline
  • training and capacity-building programs to develop consistent practices for child information sharing across prescribed organisations
  • establishing an overarching governance group to provide oversight of the interdependent CIS Scheme, FVIS Scheme and the Framework
  • aligning the reviews for both the CIS Scheme and FVIS Scheme to contribute to an overall understanding of the impacts of these schemes
  • further consideration of an implementation plan for data collection to strengthen the capacity of the two-year and five-year reviews.

Download the Submission to Child Information Sharing Scheme RIS and Regulations

Child Information Sharing Scheme Ministerial Guidelines
5 June 2018

DV Vic wrote a joint submission on the Child Information Sharing Scheme Ministerial Guidelines with Victoria Legal Aid, Djirra, Women’s Legal Service Victoria, Federation of Community Legal Centres and No to Violence.

The submission said the guidelines will play an important role in supporting the application and implementation of the Child Information Sharing Scheme. It sets out what is important in an information sharing regime to encourage help-seeking behaviour and individual and community empowerment to make decisions that keep children safe.

The submission also highlighted that practitioners are more likely to share information appropriately when they understand their professional responsibilities and are informed of the risks of sharing information. It suggests ways of providing greater instruction to Information Sharing Entities and practitioners, taking into account the possible risks associated with sharing information and the need for appropriate safeguards.

Download the Joint Submission on Child Information Sharing Scheme Ministerial Guidelines

Australian Law Reform Commission’s Review of the Family Law System Issues Paper
30 May 2018

Australia’s family law system needs a fundamental transformation in culture to better meet the needs of victim survivors of family violence and their children.

The changes to the system should have a key focus on meeting the rights of women and children to safety. They should support a move away from an adversarial system that replicates the dynamics of family violence. We recommended the implementation of a coordinated psychosocial case management service that is responsive to the diverse and intersecting needs of family law system users, especially victim survivors of family violence.

Download Submission to Review of the Family Law System Issues Paper

Sentencing Advisory Council: Sentencing and Compensation Orders Reference
4 May 2018

DV Vic provided verbal and written submissions to the Sentencing Advisory Council on whether restitution and compensation orders should become sentencing orders. Key highlights of DV Vic’s submission were:

  • Restitution and compensation orders should not become sentencing orders in cases of family violence.
  • Financial reparation should not become a purpose of sentencing in cases of family violence.
  • DV Vic supports the proposal that survivors of family violence should be given the option to assign their rights to enforce restitution and compensation orders to the state.
  • For those survivors of family violence who choose to retain the right to enforce the order via civil means, DV Vic believes new strategies are required to improve civil enforcement and increase access to justice for survivors of family violence, including removing fees relating to civil enforcement; provision of free legal information, advice and representation to victims seeking to enforce orders; provision of specialist family violence support; and court-based case management.
  • Restraining an alleged family violence offender’s asset for the purposes of meeting any future restitution and compensation order will have negligible positive outcomes for survivors of family violence, and may in fact increase the risk of violence and/or deter survivors of violence from seeking assistance via the criminal justice system.

Early Release of Superannuation Benefits Discussion Paper
1 March 2018

DV Vic responded to a discussion paper from Commonwealth Treasury on the early release of superannuation benefits.

Download Submission to Early Release of Superannuation Benefits Discussion Paper

2017

Family Violence Information Sharing Guidelines, Regulations and Regulatory Impact Statement
24 October 2017

DV Vic made a submission to Family Safety Victoria on the Family Violence Information Sharing Guidelines, Regulations and Regulatory Impact Statement that complement the Family Violence Protection Amendment (Information Sharing) Act 2017.

Download Submission to Information Sharing Guidelines Regulations and RIS

Department of Health and Human Services Child Information Sharing Consultation Paper
6 October 2017

DV Vic made a joint submission on the Child Information Sharing Consultation Paper with Victoria Legal Aid, Women’s Legal Service Victoria, Federation of Community Legal Centres, No to Violence/Men’s Referral Service, Safe Steps Family Violence Response Centre, Domestic Violence Resource Centre Victoria and Berry Street.

The submission put forward a range of safeguards for the child information sharing regime to engender a culture of information sharing that promotes safety. It made suggestions to make sure that information sharing mechanisms do not deter family violence victim survivors (adults, children and young people) from accessing services and do not exacerbate risk in circumstances where family violence perpetrators use information to control partners and children.

Download Submission to DHHS Child Information Sharing Consultation Paper

Family Violence Protection Amendment (Information Sharing) Consultation Draft Bill 2017
15 March 2017

DV Vic joined Victoria Legal Aid, Women’s Legal Service Victoria, Federation of Community Legal Centres and Law Institute Victoria to write a joint submission on the Family Violence Protection Amendment (Information Sharing) Consultation Draft Bill 2017.

Download Submission on Family Violence Protection Amendment (Information Sharing) Draft Bill

Proposed Child Safety and Wellbeing Information Sharing Regime
1 February 2017

DV Vic and No to Violence wrote a joint submission on the proposed information sharing regime for child safety and wellbeing.

Download Submission to Proposed Child Safety and Wellbeing Information Sharing Regime

Exposure Draft of the Family Law Amendment (Family Violence and Other Measures) Bill
16 February 2017

DV Vic fully supports the submission made on the exposure draft by Women’s Legal Services Australia, including their recommended amendments. In particular, DV Vic highlights those recommendations related to women being directly cross-examined by their abuser, and appropriate resourcing and training to embed structural changes.

Download Letter of support for Family Law Amendment Bill Exposure Draft

2016

Victorian State Budget 2016–2017
14 October 2016

DV Vic recently made a submission and key recommendations to the 2016–2017 Victorian State Budget process.

Download Submission to State Budget 2016–17

Family Violence Information Sharing Legislation Consultation Paper
1 August 2016

DV Vic supports the needs for this legislative reform but argues it will only be effective in a clearly prescribed and regulated environment that pertains to family violence and the purpose of women and children’s safety.

Download Submission on Family Violence Information Sharing Legislation Consultation Paper

2015

Senate legal and constitutional affairs references committee inquiry into ‘revenge porn’
This short submission points out the critical importance of understanding the use of ‘revenge porn’ in the context of intimate partner violence, with attention to the particular dynamics of family violence. Sharing, or threatening to share or publish private sexual material is a means of coercive control over a partner or ex-partner and is an increasingly common form of perpetrator behaviour.

Download Submission to Inquiry into Revenge Porn

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