Guide to Making a Submission to the Draft ‘Sex Work Regulations 2016’

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What’s a Submission?

A submission can be as simple as a letter on how you feel about the way you work as a Victorian sex worker:

  • How do you feel about mandatory testing for STIs/HIV every three months?
  • Are you a Private Worker who feels the current restrictions on in-calls are too harsh?
  • Do you feel you have less ability to go to the police if you need to as a sex worker in Victoria?
  • Are you concerned that registering with the CAV/BLA will subject you to future discrimination?
  • Are you a street based sex worker affected by current policing operations?
  • Have you been affected by stigma and/or discrimination as a sex worker?
  • Do you work in a brothel and feel you are subject to working conditions that you cannot organise to change, like other workers would be able to do (through unions, by accessing the Workplace Ombudsman, or WorkSafe)?
  • Is there a way that you would prefer to work? Many sex workers indicate sex work decriminalisation, the system currently in place in New South Wales as their preference – do you feel this way?

A submission doesn’t have to be longer than a few paragraphs and it doesn’t have to be a technical document.
It’s often the case that government receive many form letters to submission processes, writing something in your own words, about your own experience can be very powerful.

What has changed between the Draft ‘Sex Work Regulations 2016’ and the previous regulations?

Very little. The most significant changes are:

  • Full body shots, photographs in advertising will no longer be restricted to head and shoulders only – but only on the internet.
    There are restrictions on these, as advertising cannot contain representations of: “..the bare sexual organs, buttocks or anus of a person, or frontal nudity of the genital region; or bare breasts; or a sexual act or simulated sexual act; or a person under the age of 18 years..”
  • Advertisements may now contain references to race, colour or ethnic origin.

You can see the full listing of changes at – Sex Work Regulations 2016 Consultation – Consumer Affairs Victoria
**NOTE – SUBMISSION DEADLINE NOW EXTENDED TO 5:00PM, FRIDAY 4th MARCH**

Sending Your Submission to Consumer Affairs Victoria

There are a number of methods of sending your submission in:

  • Email your submission directly to the CAV via – cav.consultations@justice.vic.gov.au
  • Post your submission directly to the CAV via –
    Sex Work Regulations 2016 Consultation
    Policy and Legislation Branch
    Consumer Affairs Victoria
    GPO Box 123
    Melbourne VIC 3001

NB – For anyone who wishes to list a return contact email or postal address other than their own please feel free to list Vixen Collective’s email and/or postal address:
Email address – vixencollectivemelbourne@gmail.com or, Postal address –
Vixen Collective
Melbourne Flinders Lane
PO Box 525
Flinders Lane, VIC 8009

Other References

Wanting other information on Victorian legislation/regulations or reference material? Check the list below and hopefully you will find a helpful link:

Information on Legislation/Regulations
Scarlet Alliance: Sex Industry Law – Victoria

General Articles
The Sexual Health of Sex Workers: no bad whores, just bad laws
Sex Work Legislation Stands in the Way of Australia’s Commitments

Academic Articles
Mandatory Testing for HIV and Sexually Transmissible Infections among Sex Workers in Australia: A Barrier to HIV and STI Prevention
Improving the health of sex workers in NSW: maintaining success

Other
Sex Workers Stand In Solidarity in Calling for the Full Decriminalisation of Sex Work! – Media Release
The Principles for Model Sex Work Legislation

 

If you have questions on the submission process, contact Consumer Affairs on cav.consultations@justice.vic.gov.au

 

TO DOWNLOAD THIS GUIDE AS A PDF DOCUMENT, CLICK HERE – VSG_ISW-DSWR2016

 

Have any feedback on this guide?  Contact Vixen Collective on Twitter at @VixenCollective or visit our website for more information at vixencollective.blogspot.com.au

See below for examples of submissions…

——————–

Example of a Submission by a Victorian Sex Worker

 

Sex Work Regulations 2016 Consultation
Policy and Legislation Branch
Consumer Affairs Victoria
GPO Box 123
Melbourne VIC 3001
Email: cav.consultations@justice.vic.gov.au

 

27th February 2016

To whom it may concern,

My name is Nell and I am a brothel based sex worker in Melbourne.

The Victorian licensing system makes it incredibly difficult for both my work and personal life. I’ve described a few of these here.

Mandatory testing is a perpetual reminder that the government views me as “dirty” and a threat to public health. I am treated as though I do not know how to care for my health, like I can’t make decisions about my own body. I am perfectly aware of the risks of STIs, just like other sex workers and we get tested without needing to be told. We are not ticking time bombs of infection and disease. This policy is a blatant attack on our bodily autonomy and basic human dignity.

Within the licensing system, police are not my protectors, but are instead monitor my very existence. This is expressed in legislation, but also in police behaviour. If I am subject to a crime, violent or otherwise, at work or not – going to police for assistance isn’t even remotely an option. The threat of being outed, discrimination, interpersonal violence, and just generally horrific treatment by people as a result. This means that I turn to my peers, other sex workers and community for support, because reporting to the police is not an option.

Stigma is a harm so major and all-encompassing that it is a challenge to explain its damage in only a few words. People’s perceptions of sex work as a social evil, or of sex workers as victims, mean they can become abusive or abandon us when we are outed. My relationships with family and friends were so severely damaged by their discovery of my work, that I’ve been forced to completely reshape and rebuild my life. Other sex workers have supported me, but many of my family and friends have subjected me to emotional abuse and threats. The licensing systems perpetuates this stigma.

Decriminalisation, along with a commitment to alleviate stigma (through media, education, and so on) will make an enormous difference in our lives. We deserve to be heard, to be listened to, to be the decision makers on issues relating to us.

Yours sincerely,

Nell.

——————–

Example of a Submission by an Inter-State Sex Worker

 

Sex Work Regulations 2016 Consultation
Policy and Legislation Branch
Consumer Affairs Victoria
GPO Box 123
Melbourne VIC 3001
Email: cav.consultations@justice.vic.gov.au

 

27th February 2016

To whom it may concern,

I am a sex worker from NSW, I am writing because having worked in Sydney under decriminalisation I know that this is a system that supports my health and safety.

 

Under decriminalisation of sex work in NSW:

 

  • I do not have to register my name with the government like private workers do in Victoria, creating opportunities for discrimination later in life.
  • I am not subject to mandatory STI/HIV testing because, like sex workers everywhere across Australia, I maintain my sexual health as part of my work – and, as studies show sex workers have sexual health at least as good or better than the general population.
  • If someone threatens me or is violent to me when I am working, I can go to the police more easily than a Victorian sex worker. Because the police do not regulate the sex industry in NSW, I can get assistance from the police like any other person in the community.
  • I have the ability to choose between a variety of different ways of working, and do what suits me best. If I want to work privately in an environment I control – which is best for my safety – then I can do this.
  • Although as a sex worker I am still subject to stigma and discrimination, I am supported by sex worker community through a funded state based peer sex worker organisations – SWOP NSW.

 

Victorian sex workers should have access to the same rights and opportunities that NSW sex workers do.

 

The Victorian Government needs to end mandatory testing of STIs/HIV, the registration of sex workers, remove the police as regulators of the sex industry in Victoria, and most importantly fully decriminalise sex work in Victoria.

 

Yours sincerely,

Alice West

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