Hi all
Promised I would post my comments. Here is our response (warning - very long!). I have registered on the website but am still getting the message re: the survey so e-mailed my comments in instead.
Bristol Fawcett response to Sexual Entertainment Venue Draft Policy
Bristol Fawcett, established in 2001, is a Bristol-based organisation whose members support the aims of the Fawcett Society and work at a local level to:
?Raise awareness of Fawcett and the work that Fawcett does
?Campaign and lobby to improve policy and services for women and girls.
?Bring an informed gender equality perspective to local decision making bodies.
Our response draws on the views of our membership which includes citizens of Bristol and South Gloucestershire, members who work in Bristol and surrounding areas, academics, policy experts and women who work in the front line of service provision to women and girls including those affected by domestic abuse and sexual violence.
The essential factor to be taken into account is the negative impact on women, and on womenʼs equality ? made by SEVs. This impact is both general ? in its contribution to the normalising of the sexualisation of women which erodes womenʼs equality ? and specific in that:
??lap dancing and exotic dancing clubs make women feel threatened or uncomfortable? (Royal Town Planning Institute Guide on Gender and Spatial Planning)
?psychological trauma, substance abuse and sexual assault are rife among women who work in SEVs (e.g. Holsopple: 100% of 18 women interviewed had been sexually assaulted by customers; see also www.object.org.ukʼs Stripping the Illusion resource pages and film).
We are confident that any gender impact assessment of the operation of SEVs will demonstrate unmitigable negative impact.
We do not think that the Council should under any circumstances agree to licence a SEV.
However we are mindful that Philip Kolvin QC, Chairman of the Institute of Licensing, has produced a set of suggested conditions for application to SEV licences. In the event that a nil policy is not adopted, we support his recommendations.
?No contact between performers and audience and a minimum of 1 metre separation between performers and audience
?Performers confined to stage area
?Prevention of filming performers
?Zero tolerance policy on customers who break rules of conduct. Contravention warrants a lifetime ban from the premises
?Prohibition of private booths
?CCTV coverage of all public areas
?Controls on exterior advertising and signage
?Prohibition of advertising in public spaces, including on billboards, telephone booth boards, and leafleting.
In addition we recommend the following:
?A register to be kept of all staff working each night and valid proof to be held on the premises of the age of each of the performers
?No fee to be charged by any club to a performer for working in the club
?No ʻsmoking areasʼ to be allowed at the front of clubs to minimise the potential for harrassment of women living, working and passing through the area. All smoking areas must be in private areas away from public spaces.
?No advertising allowed in media that is not exclusively aimed at adults ? this would exclude local ʻfamilyʼ newspapers for example.
We understand that currently venues that host SE fewer than 12 times a year will be exempt from requiring a licence and this has the potential to put workers at risk because of lack of conditions so it is important that general policy includes statements on the following:
?Frequency: A clear commitment from the local authority and a member of staff specifically tasked to monitor and keep a record of the ʻinfrequentʼ performances.
Sexual Entertainment Venues: the gender equality perspective
In 2005, the Child and Woman Abuse Study Unit at London Metropolitan University were commissioned by Glasgow City Council to review lap dancing and table dancing clubs. The study (www.glasgow.gov.uk/NR/rdonlyres/AF8653FD-9FC4-4DE6-8238-CE629C7D6C3E/0/LapdancingReport.pdf) concludes that there is evidence that activities within lap dancing clubs are in direct contradiction with equality between men and women, and normalise menʼs sexual objectification of women.
Having commissioned the review by CWASU, Glasgow City Council made the following statements.
This Local Authority views table dancing as a form of commercial sexual exploitation which demeans and exploits women and encourages the perception by some men, of women as objects. This runs counter to the Councilʼs aims to promote a city in which all citizens are treated with respect and dignity. Images of women and ʻentertainmentʼ which demean and degrade women portraying them as sexual objects plays a part in ʻnormalisingʼ sexual violence and contributes to male abuse of women being acceptable, tolerated, condoned and excused. Such entertainment runs counter to explicit commitments by a range of private, public and voluntary agencies to promoting womenʼs equality.
Abuse and violence against women is now defined broadly and is recognised by governments in the context of promoting human rights and eliminating discrimination in society. It is also recognised that different forms of violence and abuse perpetrated by men are linked to broader gender inequalities and menʼs abuse of power. The UN General Assembly adopted the following definition of violence against women:
?The term violence against women means any act of violence by men that results in or is likely to result in physical, sexual or psychological harm or suffering to women? ?It also includes physical, sexual and psychological violence occurring within the general community, including rape, sexual abuse, sexual harassment and intimidation at work and elsewhere?
The Scottish Executive subscribes to this definition and furthermore states that ?Violence against women as defined (by the UN above) reflects an imbalance of power between men and women and also more general gender inequalities. Such abuse cannot be eradicated until there is an equal balance between men and women in society and relationships.? ...
It is the Councilʼs belief that areas, which have sexually oriented businesses, including table-dancing venues, are detrimentally affected through increase in crime and disorder.
South Gloucestershire Council's conditions
Bristol Fawcett has some specific comments on the draft policy:
Section 4 - consultations on applications made:
Please could the Council include in the policy the undertaking to publicise all sex entertainment venue applications on its website as soon as possible after an application is made.
Section 6.3 - opportunity to object to a licence application
We believe that objectors should have the right to speak in a hearing and would like to see this statement amended by the removal of the words "in specified circumstances". Section 7.6 states that objectors will be given the opportunity to speak at a hearing.
Section 10.11 - the policy refers to the applicant's right to "freedom of expression". We would urge the Council to consider the information provided above regarding the impact of SEVs on women and to be mindful of the fact that women's freedom to move around in the vicinity of lap dancing clubs can be severely curtailed by the presence of a SEV.
Response to standard conditions listed in Appendix C
Section 2.1 - opening times: the policy states that no SEV should open outside of the hours of 9am to 6pm. This presumably refers to sex shops only. It is highly unlikely that a lap dancing club would apply to open between these times.
Response to conditions applicable to entertainments involving nudity, semi-nudity or transparent clothing
We strongly advise that conditions applicable to these establishments contains the rule that there are no private dance areas. This is to protect the safety of the performers and to ensure that no illegal activity can take place in the venue away from security personnel and CCTV.
Section 1.6 - we strongly advise that a complete no-touching rule with a 3 metre distance between performer and customer at all times is enforced on the licence. Allowing any kind of contact between customer and performer - for example the "customary kiss on the cheek of the patron by the dancer at the conclusion of the performance" - is open to interpretation. This kind of interpretation has precedent in Newquay and resulted in an extremely time consuming and costly licence review.
Allowing any kind of touching, particularly "kisses on the cheek", is effectively blurring the boundaries between visual sexual stimulation and physical sexual stimulation, i.e. prostitution. We would also like the Council to be mindful of the impact on women living, working and passing through an area resulting from unwanted attention from men who have consumed alcohol and had limited sexual contact from someone who has also sexually stimulated them by performing a lap dance.
In addition, allowing any kind of contact between performer and customer severely compromises the safety of the performer and the safety of women living, working and passing through an area. In the Holsopple report, referred to above, all 18 lap dancers interviewed for the study had been sexually assaulted during the course of their work. We strongly urge the Council to remove any allowable physical contact from conditions that will be applied to a SEV licence.
Conditions applicable to table dancing
Section 2.3 - we strongly urge that no private booths are allowed in any SEV for reasons highlighted above.
Section 2.9 - it is highly unlikely that a "simple handshake greeting" will take place in a lap dancing club! Please refer to the statement above concerning physical contact.
We also strongly urge the Council to include strict conditions on further payments once inside the venue. The current pay structure of the venues which disadvantages performers and can be conducive to prostitution. Please see the testimonies from ex lap dancers on the Object website for anecdotal evidence of this.
We would also suggest that members of the Council's licensing committee and its officers watch the Dispatches DVD broadcast in October 2008 for more information on the industry. The makers filmed undercover in lap dancing clubs up and down the country in a variety of clubs. If the Council needs a copy of this DVD, Bristol Fawcett can make a copy or copies available. This documentary provides an unbiased and factual report on the activities which take place in lap dancing clubs.
On behalf of Bristol Fawcett Society
References:
i · Around half of women in England and Wales experience domestic violence, sexual assault or stalking in their lifetime (British Crime Survey 2008). It is estimated that there were 3,490 rapes in Bristol in 2006/7 (Safer Bristol Rape and Sexual Assault Strategy 2008-11). 22% of MPs are women. Women working full-time earn on average 16% less per hour than men working full-time and the gender pay gap in the South West is 21.5% (ONS 2009 Annual Survey).
· Daily sexualised messages create conducive contexts for violence, reinforce gender inequalities and undermine information campaigns about healthy sexual relationships (Home Office VAWG Consultation, 2009). Mainstream media are pushing a set of norms that undermine women's control over their own sexuality whilst purporting to represent a liberalisation of sex and women's sexual expression. Such representations serve to value females primarily for their ʻsex appealʼ rather than creative or intellectual abilities, and in doing so reinforce gender inequality. There is a clear link between the consumption of sexualised images and the acceptance of aggressive attitudes and behaviours as the norm (Home Office, 2010)
· "Exposure to the sexualised female ideal is linked with lower self-esteem, negative moods and depression in
young women and girls. Adolescent girls exposed to adverts featuring idealised women have significantly higher State Depression scores; and frequent exposure to films, TV and music videos featuring idealised images is linked to lower self-esteem (particularly among Black and Latino young people), stress, guilt, shame and insecurity.? (Home Office, 2010)
· A considerable proportion of young womenʼs aspirations have been reduced to being glamour models and lap dancers (EVAW 2008); Women in Journalism (2007); Girls' Schools Association (2010).
- The financial arrangements in place in SEVs normally require dancers to hand over house fees in order to be allowed to dance and the financial incentives are for clubs to admit as many dancers as possible, causing competition and limited earning capacity for individuals.