Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative

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Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
Rights Lab

              Safe Car Wash
               App Report

                    Rights Lab
             University of Nottingham
Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
Foreword                                                                                          Foreword

           Foreword
           -
           Long before The Clewer Initiative and the       That so many people downloaded and
           Santa Marta Group joined together to launch     used the Safe Car Wash app is indeed an
           the Safe Car Wash app, hand car washes had      encouraging sign, but we obviously have
           been named as a key battleground in the fight   more work to do in understanding why
           against modern slavery in the UK. However,      some people may be reluctant to report
           data was patchy. Law enforcement did not        what they have seen.
           have the resources to count each hand car
           wash, let alone investigate them all.           As well as noting the limits of our advocacy,
           We designed the Safe Car Wash app as            the report is also limited by the data available
           a way to bring the issue into the mainstream,   to the researchers. To encourage more people
           in the hope that the general public would       to use the Safe Car Wash app, we worked
           see a role for themselves in mapping and        with our developers to make it as simple
           reporting modern slavery in hand car washes.    as possible. That meant no complicated
                                                           questions, and very little room for nuance.
           We were seeking to combat a phenomenon          As a result we don’t know why one person
           that Pope Francis calls the globalisation of    called the helpline, when another, who may
           indifference, where the laudable value of       have seen almost exactly the same
           tolerance is twisted. Instead of looking out    concerning signs, chose not to.
           for our neighbour, finding common ground,
           and exploring our differences, we ignore        Alongside this report into the data generated
           them. This indifference fuels modern slavery,   by the app, we have been pleased by the
           because as a society we have chosen to          anecdotal feedback that we have received
           ignore the most vulnerable.                     from law enforcement, that the app’s data
                                                           has been exactly what we envisaged it to
           In that light we were encouraged to see how     be: a piece of the puzzle, which they can
           many people did download and use the Safe       put together with their own intelligence and
           Car Wash app but until now we have only         experience. As a result of their feedback
           been able to look at the headline figures.      and this report we have made a few updates
           This report is the first time we have been      to the Safe Car Wash app which will make
           able to dig into the data. The value of         it simpler and more effective for both users
           robust research and evaluation cannot be        of the app and users of the data.
           overestimated. With such a hidden crime,
           more and better information is needed           Modern slavery can only be ended through
           across the board.                               partnership. We hope the Safe Car Wash app,
                                                           and this report, will inform policy makers and
           Broadly, this report confirms what we had       those on the front line as they engage with
           already surmised. Many hand car washes          the problem of exploitation in hand car
           are suspect and do not protect their workers.   washes. We hope too that this report provides
           A lack of protective equipment and fearful      a useful example of what can be achieved
           and withdrawn body language are far more        by bringing together technology, insight,
           common than one would hope.                     and people of goodwill, while highlighting
                                                           the gaps that are still to be filled.
           We were disappointed to learn that only
           18% of those who were prompted to call          The Rt Revd Dr Alastair Redfern,
           the Modern Slavery Helpline did so, whilst      The Clewer Initiative
           acknowledging that they may have called at      The Rt Revd Patrick Lynch,
           another time, or reported in a different way.   Santa Marta Group

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Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
Introduction                                                                                          Introduction

               Introduction
               -
               The Home Office estimates that there are          activities has unearthed exploitative labour
               10,000 – 13,000 victims of modern slavery         and employment practices. Reports,
               in the United Kingdom (UK)i, many of whom         press coverage, and investigations
               are forced or coerced into performing work        describe excessive working hours,
               for little or no pay and exploited in a variety   withholding of wages or below national
               of industries. One area where exploitation        minimum wage (NMW) payments and
               is said to be prevalent is the hand car wash      working without adequate protective safety
               (HCW) sector, a popular form of car wash          gear and equipmentii. Reportedly, there exists
               service, which is performed manually.             a spectrum of abuse in HCWs. While some
               Prior to 2004 the presence of HCWs as a           workers are subject to some form of labour
               business activity was virtually non-existent,     and employment violation, others are forced
               but research suggests that they now               into modern slavery, compelled to work
               dominate the car wash market.                     gruelling hours under the threat of violenceiii.
                                                                 The lack of data makes it difficult to estimate
               Although HCW operations have grown at             the prevalence of labour exploitation and
               an exponential rate, their activities, business   modern slavery, which is critical to address
               models and workforce are only just beginning      abuses in this high-risk trade.
               to gain attention. Recent scrutiny of HCW

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Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
The Safe Car Wash app                                                                                                                                                     The Safe Car Wash app

The Safe Car Wash app
                                                                                                   “
                                                                                                   Thank you for providing us access to this tool against
                                                                                                   modern slavery and human trafficking (MSHT). From
                                                                                                   the data we reviewed we did find three identifiable car
-                                                                                                  wash locations which showed potential signs of MSHT
                                                                                                   that had not been brought to our attention previously.”
In June 2018, The Clewer Initiative and the       and the National Police Chiefs’ Council.         Kent and East Sussex
Santa Marta Group, in partnership with a          These agencies are given real-time access        Serious Crime Directorate
number of stakeholders, launched the Safe         to the data to help develop the intelligence
Car Wash app, which seeks to provide a            required to lead effective investigations.

                                                                                                   “                                             “
community intelligence-led approach to
mapping car washes across the UK and              In order to further understand the data
gathering data in relation to modern slaveryiv.   collected, The Clewer Initiative and Santa
Since then it has been downloaded                 Marta Group generated a dataset including
8225 timesv. The app enables users to             app users’ responses from June 26th to           The Gangmasters and Labour Abuse              Modern day slavery is a rising threat
anonymously provide information on                December 3rd 2018, and shared it with the
                                                                                                   Authority (GLAA) have worked closely          to our communities, and because of its
the location and setting of the car wash,         Rights Lab at the University of Nottingham
                                                                                                   with The Clewer Initiative (TCI) on the       hidden nature, is a major concern - we
workers’ access to suitable clothing, living      for analysis. Entries that have been partially
                                                  completed by the users are excluded from         development of the ‘Car Wash App’, and        all need to be alert to it, wherever we live.
arrangements, the presence of minors                                                               we are one of the organisations ‘badged’      Councils are committed to protecting the
working on site, and the cost and method          this dataset, which comprises 2271 entries.
                                                  This report outlines the findings from the       within it. We are the link between the        most vulnerable in society, but everybody
of payment. Users are prompted to call the
                                                  data, and reflects on how the app might          TCI [The Clewer Initiative] and UK law        has a role to play in tackling this terrible
Modern Slavery Helpline if their answers
                                                  promote a better understanding of the            enforcement and we have ensured that          crime. This is why the LGA has been
indicate that there is a likelihood of modern
slavery or exploitation at the car wash.          industry and promoting higher standards          every police force has a ‘log on’ to the      pleased to be involved in the development
Anonymous data collected from the app is          in the future.                                   database and particularly the map of car      of the Safe Car Wash app, and encourages
shared with the National Crime Agency, the                                                         washes that the app creates. We see great     people to use it to help identify these
Gangmasters and Labour Abuse Authority,                                                            value in the use of technology in the fight   ruthless profiteers and rescue their
                                                                                                   against Modern Day Slavery and Labour         victims from lives of servitude. Reporting
                                                                                                   Exploitation and commend TCI for the          any concerns through this app could
                                                                                                   leading role they have taken in this area     make a world of difference to people
                                                                                                   and the lead they have given to willing       being exploited at the hands of heartless
                                                                                                   partners – ourselves included.”               gangmasters.”
                                                                                                   Gangmasters and Labour                        Councillor Simon Blackburn
                                                                                                   Abuse Authority                               Chair of the Local Government
                                                                                                                                                 Association’s (LGA) Safer and
                                                                                                                                                 Stronger Communities Board

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Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
Acknowledgements                                                                              Acknowledgements

                   Acknowledgements
                   -
                   We would like to thank the Clewer Sisters     modern slavery in hand car washes and
                   and Trustees, as well as the CCLA for         for the work you do to help end modern
                   making the Safe Car Wash app possible.        slavery. Finally to all those who have used,
                   Thank you also to the Gangmasters and         and continue to use, the Safe Car Wash
                   Labour Abuse (GLAA), the National Crime       app - in the complex landscape of modern
                   Agency (NCA), the Local Government            slavery you are bringing clarity and insight,
                   Association (LGA) and the National Police     thank you.
                   Chiefs’ Council (NPCC) for your support
                   of the Safe Car Wash app. We owe a debt       This report was produced and funded by the
                   of gratitude to all those who advised us on   Rights Lab at the University of Nottingham.
                   what the app should look like and the key     It was authored by Dr Akilah Jardine and
                   indicators we needed to include, thank you    Dr Alison Gardner (Rights Lab Governance
                   for giving us your time and expertise.        Programme), with assistance from Dr Selim
                   Thank you to the Modern Slavery Helpline      Cakir (Rights Lab Business Programme),
                   for providing insight into the reporting of   and Dr Mike Gardner.

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Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
Application usage                                                                                                                                                                                       Application usage

                                                                                                                   Figure 1
                                                                                                                   Safe Car Wash app monthly usage

                                                                                                                   1000

Application

                                                                                               Number of entries
                                                                                                                    800

usage
                                                                                                                    600

                                                                                                                    400

-                                                                                                                   200

When the app was launched in June 2018,        Taxi Drivers Association and the Car Wash
                                                                                                                      0
there was a high-level of application usage.   Advisory Service also publicised the app
Modifications were subsequently made           to their members. Heightened public and                                     June       July      August   September    October   November   December
to the app in July 2018 that sought to         media attention to abuses occurring in this
respond to early user feedback. The app        sector also contributed to the promotion of                         (Source: Safe Car Wash app online car wash report, 2018)
was promoted through the grass roots           the app, in particular, media coverage of the
networks of The Clewer Initiative and          Environmental Audit Committee’s inquiry into                        The app has been welcomed by many                   I had with the helpline it looked as if this was
the Santa Marta Group and through the          the social and environmental impact of hand                         national and local anti-slavery activists.          a case of labour exploitation but not slavery.
Gangmasters and Labour Abuse Authority         car washes (HCWs).                                                  Regular users of the app commented:                 I was assured the information I'd given would
(GLAA), the National Police Chiefs’ Council                                                                                                                            be passed on to GLAA.”
(NPCC), National Crime Agency (NCA),           Although usage dropped after the initial                            “The Safe Car Wash app is something I
and the Local Government Association           marketing push in June 2018, there was                               have started using since becoming aware           Judith, Sheffield
(LGA). Trade bodies such as the London         evidence of stabilisation and a steady rate                          of modern slavery within the car washing          Safe Car Wash app user
                                               of reporting from September 2018 onwards.                            business. It's really easy to use and being
                                                                                                                    available on your phone, it doesn't cause         “I found the Safe Car Wash app very clear and
                                               See Figure 1 (right)                                                                                                    easy to use, and it was great that it was able
                                                                                                                    suspicion while you're having your car
                                                                                                                    washed. It has helped me to really take            to prompt me to ring the Modern Slavery
                                                                                                                    notice of the subtle differences between           Helpline as a result of my answers. When
                                                                                                                    how different car washes are run. It helps         I spoke to them, I was able to answer most
                                                                                                                    in many ways from spotting the signs               of their questions easily because the app
                                                                                                                    when something’s not right, to giving the          had already prompted me to consider the
                                                                                                                    confidence to report it.”                          questions they asked me. Using the app has
                                                                                                                                                                       also helped me to be more aware of the signs
                                                                                                                   Helen, Lichfield                                    to look out for not only at carwashes,
                                                                                                                   Safe Car Wash app user                              but in other industries too…”
                                                                                                                   “The safe carwash app is extremely quick and       Anna, Norfolk
                                                                                                                    easy to use, with straightforward questions.      Safe Car Wash app user
                                                                                                                    I found it satisfying to know that following it
                                                                                                                    through with a conversation to the Modern         “I really like the App - it's simple and easy to
                                                                                                                    Slavery Helpline has contributed to providing      use and gets some important information
                                                                                                                    local information that may enable further          straight to the people who need it. Perhaps
                                                                                                                    investigation by the Police.”                      more importantly it makes people stop
                                                                                                                                                                       and think about their behaviour and if it is
                                                                                                                   Elizabeth, Portsmouth                               contributing to the exploitation of others.
                                                                                                                   Safe Car Wash app user                              I'd recommend everyone download
                                                                                                                                                                       it and use it.”
                                                                                                                   “I found the app very easy to use and I got
                                                                                                                    through to someone at the Modern Slavery           Mike, Lincoln
                                                                                                                    Helpline very quickly. From the conversation       Safe Car Wash app user

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Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
Patterns of reporting                                                                                             Patterns of reporting

                                      Patterns of
Figure 2
Car wash reports using the Safe Car
Wash app, June - December 2018

                                      reporting
                                      -
                                      Figure 2 (left) demonstrates the initial        exceptions). Finally, Wales and Scotland
                                      spread and intensity of reports submitted       were not specifically targeted in the initial
                                      from the Safe Car Wash app between June         marketing for the app, and this is probably
                                      2018 and December 2018. In this study we        reflected in the low number of reports from
                                      have focussed on the reports rather than        those areas.
                                      exact car wash locations for a number of
                                      reasons. Within the dataset there were          There are a number of possible explanations
                                      duplicate location reports (as one might        for reporting being higher in some parts
                                      expect for a car wash causing concern).         of the country than others. The first is that
                                      We also found that some users chose to          some (urban) areas simply have a higher
                                      submit their report from an alternative         density of car washes, and rural areas such
                                      location, away from the car wash, so the        as Exmoor, Yorkshire and Cumbria certainly
                                      geo-location did not always reflect the         show fewer reports. However, we know that
                                      position of the car wash itself, an issue       car washes still exist in rural locations,
                                      we pick up further in the analysis section.     so it is probable that some under-reporting
                                      For this reason, it was sometimes difficult     is occurring, particularly as the 2000 plus
                                      to clarify which points represented an          entries in the data at this point will be an
                                      accurate car wash location, without ground-     incomplete reflection of the total (estimated
                                      truth verification of every data point, which   10,000-20,000) car washes in the UK.
                                      was outside the scope of this research.         Another potential reason is that awareness
                                      However, it is important to recognise that      and thus usage of the app was higher in
                                      statutory agencies are still able to draw       some parts of the country than others.
                                      effectively on the data to identify high-risk   For instance, Nottinghamshire is the national
                                      car washes, using local knowledge.              headquarters for one of the agencies
                                                                                      involved in advising on the app, and The
                                      The map shows that there are a higher           Clewer Initiative, and may therefore have
                                      intensity of reports within some centres        had a higher number of regular users.
                                      of urban population, as one might expect,
                                      but that intensity is not directly correlated   For the app to give a more accurate picture
                                      with population size and density.               of distribution, it will be important to
                                      For example, there appears to be a              encourage users to pinpoint the car wash
                                      high intensity of reporting in and around       locations using the app, even if they do not
                                      Nottingham, compared to comparably-             have specific concerns or subsequently enter
                                      sized cities such as Bristol or larger cities   additional information at another site. The
                                      like Manchester. In some more rural regions     map also perhaps highlights the opportunity
                                      of the country, fewer reports were emerging     to promote the app further in rural regions,
                                      than we might expect. Many significant          as well as Wales and Scotland, particularly
                                      market towns include at least one report,       given the church’s unique capacity to reach
                                      but not all (Hereford, Wetherby,                into rural communities.
                                      and Bridgwater, for instance being

(Source: Safe Car Wash app, 2018)

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Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
Reporting to the Modern Slavery Helpline                                                                Reporting to the Modern Slavery Helpline

Reporting to the                             CAR WASH SETTING
                                             17% of users identified fearful workers
                                                                                              exploitation is their accommodation style.
                                                                                              For instance, in some cases workers were
                                                                                              reportedly found living on the car wash

Modern Slavery Helpline
                                             at the car wash.                                 site in converted shipping and storage
                                             The Safe Car Wash app asked users                containersx. The Safe Car Wash app asked

-
                                             if anyone appeared over-controlling              users to look out for nearby caravans,
                                             or intimidating and if the body language         containers, mattresses and bedding on site
                                             of workers appeared fearful or withdrawn.        as evidence of workers living on site. 14%
                                             17% of reports identified fearful workers        of reports suggested that workers were
Although 41% of users were asked to          at the car wash. This aligns with research       living on the car wash site.
call the Modern Slavery Helpline by the      in which law enforcement officials described
application, only 18% called the helpline                                                     ACCESS TO SUITABLE CLOTHING
                                             varying methods used to control workersvi,
and 82% did not. There were a total of       including physical abuse, threats, coercion,     48% of Safe Car Wash app reports
126 cases where the helpline was called,     debt bondage, withholding of wages               commented that workers did not have
so the intensity of this type of report      and intimidation.                                access to suitable clothing.
is much lower. See Figure 3 (below).
Factors which seemed to encourage            MINORS WORKING ON SITE                           Safe Car Wash app users were asked to
people to call the helpline are explored                                                      look out for gloves and boots to determine
in the next section of this report.          8% of reports logged children working            if workers had access to suitable clothing.
                                             on site.                                         Reports on HCW activities have described
                                             Users were asked if there appeared               workers operating with potential harmful
                                             to be minors working at the car wash.            chemicals used to wash cars, such as
                                             8% of users logged children working on site.     hydrochloric acid, and working in poor
                                             Generally, in the UK the minimum age a child     and unsafe conditions. Health and safety
                                             can work is 13 years for part-time work and      regulations require employers to take
                                             16 years for full-time workvii. School-aged      practical steps to manage health and safety
                                             children under the age of 16 are not entitled    risks and to protect workers from harmxi.
                                             to the national minimum wage (NMW),              This includes providing workers with
                                             while young persons over the age of 16 are       appropriate personal protective clothing
                                             entitled to a wage significantly lower than      and equipment. 48% of Safe Car Wash
                                             the NMWviii. While employing children and        reports commented that workers did not
                                             young persons in car washes may not be           have access to suitable clothing.
                                             unlawful, their age and cost of their labour     Because of the nature of the work,
                                             increases their vulnerability to exploitation.   employees should be provided with
                                             WORKERS LIVING ON SITE                           adequate clothing and gear to protect
                                                                                              them from harm such as safety shoes and
                                             14% of reports said that workers were            gloves. Workers operating without personal
                                             living on the car wash site.                     protective equipment could indicate that
                                                                                              employers are in breach of health and
                                             Research on the nature and prevalence            safety regulations.
                                             of labour exploitation in the HCW sector
                                             reported that workers are housed in
                                             different accommodation types,
                                             some provided by their employersix.
                                             A key factor that may suggest worker
Figure 3
Users employing the app to call the Modern
Slavery Helpline, June - December 2018

(Source: Safe Car Wash app, 2018)

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Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
Reporting to the Modern Slavery Helpline       Reporting to the Modern Slavery Helpline

FAIR PAY
The average price paid for a HCW
service was £7.10.
Users of the Safe Car Wash app were
requested to input the cost paid for the
HCW service used. A low cost could
indicate an exploitative business model
where workers are paid below the national
minimum wage (NMW). An assessment of
the car wash industry by Waves, Tesco’s
HCW supplier, suggests that a breakeven
cost for an outside wash is £6.88 including
value added tax (VAT) and £11.10 including
VAT for an inside and outside washxii.
This takes into consideration a number
of expenses including the cost of labour,
materials and resources. Though these
figures are likely to vary across the UK,
the cost of a HCW service below this price
could suggest that workers are not paid the
NMW. The app did not identify the type
of service users received at the car wash,
however the average price paid for a HCW
service was £7.10. Although this is higher
than the estimated price for an outside wash
by Waves, the price of a car wash service is
not sufficient to determine the prevalence
of exploitation, and other factors need to
be taken into consideration such as the car
wash setting, health, safety and working
conditions and method of payment.
PAYMENT
80% of car wash visits had a cash only
policy, 41% of users had to pay the
manager directly and 87% were not
offered a receipt.
The Safe Car Wash app asked users if the
car wash only accepted cash, if a receipt
was offered, and if they had to pay the
manager. These variables could suggest
that the car wash is evading tax, national
insurance and NMW obligations. 80% of
responses entered in the Safe Car Wash
app stated that the car wash had a cash
only policy, while 41% had to pay the
manager directly. Further, 87% reported
that they were not offered a receipt.

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Safe Car Wash App Report - Rights Lab University of Nottingham - Rights Lab - The Clewer Initiative
Modern slavery reporting                                                                                                                                                                    Modern slavery reporting

                                                                                              Figure 4
                                                                                              Risk factors identified by users who were prompted
                                                                                              by the app to call the Modern Slavery Helpline

                                                                                                                                                                   89%

Modern slavery
                                                                                                                   74%

                                                                                                                                                                                      58%

reporting                                                                                                                                  31%

-
                                                                                                                               76%
                                                                                                                                                       15%
                                                                                                     £6.47                                                                     7%
41% of users were requested to call the      another means. We need to conduct more
Modern Slavery Helpline. Of these 18%        research to understand why this may be, but
                                                                                                   Average No access Workers              Fearful     Minors Cash only    Receipt     Pay
called the helpline and 82% did not.         the data suggests that some features were              price to suitable living on           workers     working policy      offered   manager
                                             perceived as more worrying than others.                        clothing     site                         on site                       directly
Research on exploitative labour and          Figure 5 (right) illustrates the comparison
employment practices in HCWs have            between data entered by users who called              (Source: Safe Car Wash app, 2018)
reported a spectrum of abuse. While          the MSH when prompted to do so, and those
workers may be subject to some form          who did not call. The price paid for the car
of labour or employment violation,           wash service was similar for both users.         Figure 5
others may be victims of modern slavery.     The average price paid by users who did          Risk factors comparison between users who
Users of the Safe Car Wash app were          not call the MSH is £6.50 and £6.36 for          called the MSH and those who did not call
prompted to report their concerns to the     those who did call.
Modern Slavery Helpline (MSH) if there
was a high likelihood that exploitation is   Factors such as the average price of a car       No access
occurring at the car wash. Users were also   wash service, minors working on site and                                                                                                   73%
                                                                                              to suitable
encouraged to contact the police if they     receipt offered showed similar data entries by     clothing                                                                                       78%
saw something of immediate concern.          users who did not call the helpline and those
                                             that did. However, the cash only policy and        Workers                                   24%
Figure 4 (right), demonstrates the average   the presence of fearful workers were               living on
price of the car wash service and the                                                                 site                                26%
                                             higher for those who called the helpline in
risk factors entered by users, who were      comparison to those that did not. Further,           Fearful                                       29%
subsequently prompted by the app to call     data entered on workers’ lack of access to          workers
the Modern Slavery Helpline.                 suitable clothing was higher for users who                                                               35%
A cash-only policy and paying the manager    called the helpline compared to those that
                                                                                                 Minors
                                             did not. This suggests that the factors most                                       16%
directly were the most commonly identified                                                    working on
features of settings in which user entries   likely to influence users’ attitude towards             site                       16%
suggested a high level of risk.              modern slavery reporting in car washes are
                                             cash only policy at a car wash, the presence      Cash only                                                                                               86%
However, many users chose not to call the    of fearful workers and workers operating             policy
                                                                                                                                                                                                               96%
helpline using the app, although we don’t    without suitable clothing.
know if they subsequently called using                                                           Receipt
                                                                                                                  5%
                                                                                                 offered
                                                                                                                  6%

                                                                                                     Pay
                                                                                                                                                                           58%
                                                                                                manager
                                                                                                 directly                                                                55%

                                                                                                                 Users who did not call         Users who called

                                                                                                             (Source: Safe Car Wash app, 2018)
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Analysis                                                                                                                                                                                    Conclusion

Analysis                                                                                            Conclusion
-                                                                                                   -
This study demonstrates the potential of the     log location of car washes even if they do not     Gathering data on the scope of the hand car       While more work needs to be done to
Safe Car Wash app as a means to record           use the services provided, in order to gain        wash sector in the UK is pivotal to tackling      improve public reporting, the Safe Car Wash
data and raise awareness of signs of modern      a fuller picture of the industry as a whole.       abuses in this sector. The Safe Car Wash app      app demonstrates the importance of citizen
slavery and labour exploitation, but further                                                        provides important emerging evidence to           science in shedding light on pernicious
development of the app could overcome            However, while the app seeks to inform law         build our knowledge of HCWs including their       practices, particularly in sectors where
some existing limitations. In addition,          enforcement, it also aims to raise awareness       geographical spread and the prevalence of         exploitation is often described as ‘hidden’, yet
this study is a snapshot based on five months    of modern slavery in car washes to members         modern slavery risk factors. Although in its      thrives in plain sight. Leveraging the real life
of usage. We know that the car washes            of the community. Consequently, it is              early stages, the data arising from the Safe      experiences and insights of the public can
featured in these reports are at present just    important that any changes that seek to            Car Wash app also has potential to provide        act as a catalyst for change by broadening
a sample of the car wash industry, which is      improve the app as a data collection tool          further insight into HCW activities               our understanding of the nature of car
estimated to include between 10,000 and          do not diminish users' experience and deter        by mapping car wash operations.                   wash activities, the prevalence of labour
20,000 businesses. A longer-term study with      individuals from using the app.                                                                      exploitation and modern slavery, and building
further contextual data, including a ground-                                                        There are also likely to be benefits of this      essential evidence for the approaches needed
                                                 The higher number of persons who did not           app which are not yet captured by this
truth reality-check to look at the app’s         contact the Modern Slavery Helpline when                                                             to tackle abuses.
effectiveness in logging car wash locations,                                                        data, including the extent to which the
                                                 prompted to do so - in comparison to those         app has raised users’ awareness of exploitative
and experiences of law enforcement               who did - demonstrates that more needs
agencies in utilising intelligence, would                                                           labour practices and promoted a public
                                                 to be done to understand the factors that          conversation about labour abuse in car
provide valuable additional information.         influence public reporting of abuses.              washes. This conversation is now starting
In the short term, some further adaptations      Research on local media and public                 to yield important policy changes, such as
could improve the utility of the app for data    perceptions of modern slavery highlighted          moves towards national and local regulation.
collection and mapping. These include            several concerns that hinder public reporting

                                                                                                    “
giving users the opportunity to review data      of modern slavery cases, such as the lack of
before submission, providing more detailed       sufficient information to be able to confidently
categories for the type of service received,     report on behalf of potentially exploited
and adding the capacity to log the location      persons and the concern that reporting might
                                                 make matters worse for workersxii.                 The Clewer Initiative and the Santa
and name of a car wash without making a
                                                                                                    Marta Group recognised the risks in
full data entry. The Clewer Initiative and the
                                                                                                    the car wash industry. Mobilising their
Santa Marta Group may also wish to consider
whether to give new recommendations on                                                              respective parishes to gather data
the use of the app, encouraging individuals to                                                      through the Safe Car Wash app has
                                                                                                    resulted in a Parliamentary Committee
                                                                                                    Inquiry now looking to regulate
                                                                                                    the industry to prevent forced and
                                                                                                    exploitative labour in the industry”
                                                                                                    Kevin Hyland OBE
                                                                                                    First UK Independent Anti-Slavery
                                                                                                    Commissioner (2015-2018)

20                                                                                                                                                                                                  21
Appendix                                                                                                                            Appendix

Appendix
-
i “ 2018 UK Annual Report on Modern             ix Jardine, A, “Labour exploitation in hand
      Slavery,” (2018) HM Government,                 car washes,” 14
      accessed December 14, 2018
                                                  x Gangmasters and Labour Abuse Authority,
https://assets.publishing.service.gov.uk/            accessed December 14, 2018
government/uploads/system/uploads/
attachment_data/file/749346/2018_UK_              http://www.gla.gov.uk/media/3537/external-
Annual_Report_on_Modern_Slavery.pdf, 4            natureand-scale-of-labour-exploitation-
                                                  reportfinal-version-may-2018.pdf, 16
ii Akilah Jardine, “Labour exploitation in
    hand car washes,” (2018) University of        xi “Health and safety made simple: the basics
    Nottingham, accessed December 14, 2018             for your business,” Health and Safety
                                                       Executive, accessed December 14, 2018,
http://www.antislaverycommissioner.co.uk/
media/1238/labour-exploitation-in-hand-car-       hse.gov.uk/simple-health-safety/ index.htm
washes.pdf                                        xii “Written evidence submitted to the
iii Ibid                                                Environmental Audit Committee hand
                                                        car washes inquiry by the Downstream
iv “Safe Car Wash app,” The Clewer Initiative,         Fuel Association,” (2018) Parliament Data,
     accessed December 14, 2018                         accessed December 18th, 2018,
https://www.theclewerinitiative.org/              http://data.parliament.uk/writtenevidence/
safe-car-wash-app/                                committeeevidence.svc/evidencedocument/
                                                  environmental-audit-committee/hand-car-
v As of March 25, 2019.                           washes/written/84625.pdf
vi Jardine, “Labour exploitation in hand         xiii Birks, J and Gardner, A (2019) Introducing
    car washes,” 15                                     the Slave Next Door: Local media and
vii “Child employment,” Gov.uk,                       public perceptions of modern slavery
       accessed December 18, 2018,                      (Forthcoming.)

https://www.gov.uk/child-employment
viii “Child employment,” Gov.uk, accessed
       December 18, 2018,
https://www.gov.uk/child-employment/
paying

                                                                                                     You can find more information on
                                                                                                     the work of The Clewer Initiative and
                                                                                                     Santa Marta Group on their websites.
                                                                                                     www.theclewerinitiative.org
22                                                                                                   www.santamartagroup.com               23
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