09/07/2025
According to the first UK Independent Anti-Slavery Commissioner, Kevin Hyland OBE, one-in-five victims of modern slavery report having come into contact with healthcare services during the time they were being trafficked. [1] This means that it is essential that health and social care professionals have an understanding about modern slavery. This article considers the Modern Slavery Act 2015 (“the Act”), what some of the signs are that someone may be a victim and what should be done if this is suspected. This article focuses on identifying patients who are at risk. However, it is also recognised that the health and social care sector have individuals working in the sector who themselves are victims of modern slavery and issues of employment and modern slavery are considered.
According to the Home Office, there were almost 20,000 potential victims of modern slavery referred to authorities in 2024. [2] Modern slavery experts estimate the actual number to be much higher – with the use of police data, they have estimated that there could be as many as 100,000 modern slavery victims living in the UK. [3]
Identifying a victim of modern slavery
Experiences of victims of modern slavery differ; there is no blueprint for a victim. A person may make a disclosure about their experience, but often people who are victims are in fear either for themselves or others.
In its ‘Identifying and supporting victims of modern slavery: guidance for health staff’ guidance [4], the Department of Health and Social Care gives a helpful overview of features which should raise a suspicion that the patient may be a victim of modern slavery.
If the person:
- Is accompanied by someone who appears controlling, who insists on giving information and coming to see the health worker;
- Is withdrawn and submissive, seems afraid to speak to a person in authority and the accompanying person speaks for them;
- Gives vague and inconsistent explanation of where they live, their employment or schooling;
- Has old or serious injuries left untreated;
- Either gives vague information or is reluctant to explain how the injury occurred or to give a medical history;
- Is not registered with a GP, nursery or school;
- Appears to be moving location frequently;
- Appearance suggests general physical neglect;
- Struggles to speak English;
- Has no official means of identification or suspicious looking documents.
In addition, children and young people might show the following signs:
- Have an unclear relationship with the accompanying adult;
- Go missing quickly (sometimes within 48 hours of going into care) and repeatedly from school, home and care;
- Give inconsistent information about their age.
As well as spotting these signs, someone may make a disclosure to staff about their situation or experience.
The Act, the duty to Notify and Safeguarding duties
Under section 52 of the Act, First Responder Organisations have a duty to notify the Home Office when they encounter a potential victim of modern slavery via the National Referral Mechanism (“NRM”). NHS organisations and staff and health and care workers working in the private sectors do not fall within the scope and duties of section 52 and cannot directly refer to the NRM. However, staff do have duties under the Care Act 2014 and the Children’s Act 1989 where there is evidence of abuse, neglect or significant harm. By following local processes a First Responder Organisation (such as the Local Authority or police) can make a referral to the NRM based on information received from health and social care staff.
If there is an immediate threat to the staff or patient’s safety then staff should contact the police.
If there is no immediate threat, staff should discuss concerns with the Designated Safeguarding Professional or Local Authority Safeguarding Adults Team or Child Protection team depending on the age of the patient and follow your local adult safeguarding policies and procedures. Staff can contact the police non-emergency number 101 and a request can be made to speak to the Anti-Slavery Unit for specialist input.
All victims, or suspected victims, of slavery under the age of 18 must be referred to the Child Safeguarding team and thus Children’s Social Care urgently under child protection procedures. Depending on the concerns raised children should not be allowed to leave and the police should be contacted if the child absconds or is removed.
Mental Capacity, Consent and Language Barriers
The usual principles under the Mental Capacity Act 2005 apply, which set out that those over 16 years of age are presumed to have the capacity to make decisions, including about their care and decisions on whether to agree to, or refuse, an examination, investigation or treatment, unless it is established that they lack capacity.
When considering capacity and discussions around consent both for treatment and referrals in relation to modern slavery, consideration should be given to language barriers and the potential use of interpreters. You should only use independent and qualified interpreters and not people who are accompanying the patient to interpret.
Victims of modern slavery may have experienced complex physical and emotional trauma. Even where an adult has already been removed from a harmful situation, they are at significant risk of re-victimisation.
How we can help
We can assist with:
- Strategic governance reviews in relation to modern slavery for children and adults at risk.
- Policy and process formulation around safeguarding children and adults at risk, including modern slavery.
- Safeguarding training and development programmes for all levels of health and social care professionals including induction input.
- Advice and support around specific child protection incidents which may involve health and social care professionals and organisations in investigations external and internal including inquests.
- Support and guidance around involvement in statutory children and adult safeguarding reviews.
