Coventry Women’s Voices response to Coventry City Council consultation on Sex Entertainment Venues

Our full response 

Coventry already has one of the highest incidents of rape in the country ¹ and our members are naturally extremely concerned about the safety of women working in, or in the vicinity of SEVs.

In particular we are concerned that.
Lap dancing clubs have a negative impact on women’s safety in the vicinity.

Data from Avon and Somerset Police has shown that in a two year period sexual and violent crime increased by 82% within a 50 metre radius of Sex Entertainment Venues in Bristol compared to 45% in the rest of the city centre.²

In the London Borough of Camden there was a 50% increase in sexual assaults in the borough after the rapid expansion of lap dancing clubs³.

Lap dancing clubs normalise the idea that women are always sexually available. This is particularly worrying when there is a widespread popular belief that women are somehow responsible for any sexual assault they suffer. The recent findings of the enquiry into the grooming of teenage girls in Rochdale where social services concluded that a fourteen year old girl who had been repeatedly raped had made a ‘lifestyle decision’ and was a prostitute is just the most recent example of victim blaming. The fact that in this case both police and social services demonstrated these victim blaming attitudes shows how even those who should be expected to understand sexual exploitation can fail in their duty to protect the most vulnerable.

The UK Royal Institute of Town Planning has concluded that ‘Evidence shows that in certain locations, lap dancing and exotic dancing clubs make women feel threatened or uncomfortable’⁴.

Many of our members are concerned that lap dancing clubs would attract stag parties and other groups of men into the city centre at night, increasing intimidation and making them feel unsafe. At a recent meeting in Bristol members heard a series of examples from Bristol residents about harassment, abuse and intimidation they suffered when walking past lapdancing clubs in Bristol or waiting for busses close to clubs. Our members do not believe that this is the atmosphere the City Council should be encouraging in Coventry.

Women working in lap dancing clubs are vulnerable to abuse and exploitation

Women working in lap dancing clubs generally pay a fee to club owners and then have to compete with each other for private dances. Whatever the ‘no touching’ and other rules in the club, women in this situation will be under a great deal of pressure to offer sexual services in order to make any money⁵, As a result trauma, substance abuse and sexual assault are rife among women working in SEVs.⁶

Under the Public Sector Equality Duty contained within the Equality Act Coventry City Council is obliged to have ‘due regard’ on the impact of its policies and practices on equality between women and men. We notice that the impact assessment of this policy highlights the possible negative impacts on women who might have sought work in a SEV but would not be able to find such work as a result of the ‘nil’ policy. We believe that the impact assessment should reflect the positive impact a ‘nil’ policy would have on the women of Coventry. This relates to the overall negative impact of SEVs on normalising the sexualisation of women and the specific threats to the safety and well-being of women working in, or living, working or socialising in the vicinity of SEVs.

We are aware that there have been questions raised about a possible legal challenge under the Human Rights Act if a club were denied a licence. Dr James Harrison co-director of the Centre for Human Rights in Practice at Warwick University who examined this issue concluded that:

‘As long as local authorities make some form of rational assessment of the character of the area this is highly unlikely (one could even go as far as to say almost impossible) to be subject to any kind of successful legal challenge. The courts have always given a great deal of discretion to public authorities in cases where they are exercising this kind of social control’

Lord Hoffman, giving judgement in the case of Belfast City Council vs. Misbehaving ltd (where the council were found not to have breached the human rights act in denying a licence to a sex shop) commented: “I find it difficult to imagine a case in which a proper exercise by the Council of its powers under the Order could be a breach of an applicant’s Convention rights.”

Philip Kolvin QC, Chairman of the Institute of Licensing, states⁸:

”Where a rational decision has been taken by the licensing authority in accordance with the principle of the statute, it is most unlikely that the decision will be held to have been a disproportionate interference with human rights.”

Indeed, before the Policing and Crime Bill became law – enabling local authorities to license lap dancing clubs as Sexual Entertainment Venues under the LGMPA - the Minister of the Crown in charge of the Bill made a written statement that the new law, including the provision to set nil policies, was compatible with the Human Rights Act 1998.

The most pressing Human Rights issues to consider when deciding on an SEV policy relate to the rights of women not to be exploited, harassed or assaulted. In addition the Council should consider its duties under the Equality Act to promote equality between women and men.