Edward Argar
MP for Melton and Syston · Conservative · United Kingdom
“I will not keep the Committee long. I am very pleased to see the hon. and gallant Gentleman, the Minister, still in post, as this is a policy area that he has cared deeply about throughout his life. I share the broad support for the instrument expressed by the shadow Minister, my hon.”
“I appreciate it may be set out in the 2006 or 2025 primary parent legislation to these draft regulations, but if he can, I would be grateful for a little clarification. Finally, paragraph 10.1 of the explanatory memorandum refers to the legislation being continuously monitored.”
“I live in my patch and I know that there will be genuine local fury at the contempt this Government have shown for my constituents in approving a Leicester city land grab, which has cross-party opposition locally.”
“Lady was right to highlight in her remarks the importance of timely discharge from hospital as a key element of whether we can achieve that flow into hospital beds and have hospital bed capacity to allow an A&E department or emergency department to function.”
“That should not be a challenge; I suspect that that data is already extant in some part of the system. She is proposing a very moderate measure, which would pull all that together in one place, and allow it to be focused on and looked at in the round, rather than in disparate little penny packets of data.”
“Gentleman’s point, however, that with many of these things—both clinicians and coroners grapple with this—it is often complex to determine the actual most significant contributory factor. My hon.”
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“Clause 24 sets out the sorts of things that the Secretary of State may consider when deciding whether an individual is appropriate to be appointed as an advocate. Those include previous qualifications, the individual’s geographical location and the impacted community and its needs. That ensures that decisions are made with a victim-centric approach. In taking a decision to appoint an advocate, the Secretary of State may have regard to the geographical area of the incident and, as previously set out, any particular community directly affected. The Secretary of State will be able to appoint more than one advocate in respect of the same major incident where that is deemed necessary. Each major incident will be different and likely to require a specific set of skills and experience from the advocate.”
“Lady eloquently set out, that significant concerns remain about the extent to which the voices of the victims are heard, the agency that they have, and how fully they are supported in participating in the processes that aim to establish what happened and why. Clause 24 marks an important step forward. As well as giving the Secretary of State the power to appoint an advocate, the clause defines “major incident” and “harm” for part 2 of the Bill. It is not possible to predict the exact nature of future incidents or disasters where an IPA may be required. The definition of a major incident is therefore intentionally broad to ensure that the Secretary of State has maximum flexibility to appoint an IPA to respond to a wide range of incidents. The Government’s intention is to appoint an advocate as soon as possible after a major incident.”
“I will speak to clause 24 now, and to new clause 15 in my concluding remarks, once I have heard what the right hon. Member for Garston and Halewood wishes to say about it. Clause 24 enables the Secretary of State to appoint independent public advocates for victims of a major incident. Thankfully, major incidents—or public disasters—involving significant loss of life and serious injury are relatively rare in this country. However, they do happen, and when they do the processes that follow can be complex and daunting for victims and the bereaved. Despite the progress made in recent years, it is clear, as the right hon.”
“Members to make full use of their positions to hold the Government to account through urgent questions and similar means of bringing Ministers to the Dispatch Box.”
“Our view is that the IPA as proposed in the Bill achieves that, while balancing the need to be mindful of public funds and the right process to be followed after a major incident. New clause 15 would establish a permanent IPA that could determine independently of Government that an event is a major incident. As has been previously set out, we do not think that a permanent body is necessary, given the rarity of the events in question for which the IPA would be deployed. Furthermore, we believe it is right and proportionate that the Secretary of State, who is accountable to Parliament, decides what a major incident is and when to appoint an IPA. Should individuals disagree with the Secretary of State’s decision in respect of a particular incident, I would expect my fellow right hon. and hon.”
“It would fundamentally alter the structure and operation of the IPA by establishing a permanent independent public advocate. She and I probably fall on opposite sides of the debate about a standing or an ad hoc IPA. She rightly highlighted the pros and cons on both sides of that debate. She falls on one side, and I fall slightly more on the other. I suspect that we may yet return to that debate. There are many possible models for an IPA. The clauses in part 2 of the Bill introduce an IPA that reflects the model we consulted on in 2018, with the responses we received to it. We have heard from victims that a swift deployment of the IPA to provide support in the immediate aftermath is vital.”
“I am grateful, as ever, to the right hon. Lady not only for her campaigning on behalf of her constituents and others, but for her ministerial career—the roles she held as Minister for Children, Minister for Northern Ireland and at the Ministry of Justice. What runs through that is her commitment to ensuring that those who are vulnerable, or who do not always have agency or a voice, are heard, and that their interests are respected and reflected in the actions of Government. I pay tribute to her. I also pay tribute to Lord Wills for not only his work but his evidence, as well as the meeting that the right hon. Member for Garston and Halewood and I had with him previously. I am grateful to the right hon. Lady for her new clause 15.”
“Furthermore, the number of victims might change over time, and people might withdraw their consent, so the quorum approach is not the best way to address the issue. Victim engagement, agency and a sense of empowerment are, as the right hon. Lady says, vital. Those are good things, but they will not achieve what we seek: in the aftermath of a major incident, to carry the trust of people that the IPA is on their side. Although I understand its intent, our concern is that the new clause is not the best way to achieve that. Question put and agreed to. Clause 24 accordingly ordered to stand part of the Bill. Ordered, That further consideration be now adjourned. —( Fay Jones .)”
“Lady envisions, would need to meet before supporting victims. That would necessitate the IPA gaining the support of 50% plus one of the bereaved and injured. I sympathise with the intention to involve victims in the process—I take the point about agency and trust. However, I cannot see how that might work in practice without potentially, in the immediate aftermath of an incident, delaying the deployment of the IPA. That would cause concern. In the immediate aftermath, it is unlikely that all eligible victims could be easily identified and surveyed to ascertain whether they would want an IPA to be deployed. They might not even be in the right place mentally or emotionally to be able to engage with such a question.”
“That will ensure that the Secretary of State has maximum flexibility to appoint an IPA to respond to a wide range of incidents. Defining a major incident as proposed in the new clause could arguably require a finding of fact or a pre-judgment of cause before the IPA could be deployed, especially regarding proving a failure in health and safety or regulation. Again, there is a risk that that could cause delays in the support of the IPA reaching the victims as well as presenting wider legal issues for the IPA. We believe that the definition in clause 24 as it stands is the right one for primary legislation, but, as I have said, I will provide additional detail through a policy statement and will work with the right hon. Lady on that if she so desires. I turn finally to requirement two, which the IPA, as the right hon.”
“Clause 25, which we will turn to, provides for an effective system of support for the IPA by making provisions for a secretariat and remuneration. We therefore consider that that aspect is duplicative in the amendment tabled by the right hon. Lady. I turn to the definition of a major incident and the specific points that the right hon. Lady has included. Again, we do not believe it is necessary to include additional considerations in the Bill. Given the unpredictable nature of the incidents in question, the definition of a major incident is purposefully broad—one might say “permissive” in this context—and further detail can be set out in a policy statement, as I mentioned earlier, while providing a degree of flexibility given what might be a subjective decision and the nature of the circumstances.”
“I do not think that is in any way what is being suggested; the hon. Lady misunderstands. Our view is that the accountability for making that decision should rightly sit with the Secretary of State, not with another party. The right hon. Member for Garston and Halewood takes a different view. I respect her perspective and understand where she is coming from. She rightly acknowledged that there were pros and cons to both approaches. She believes that the pros of a standing advocate outweigh the cons. I find myself on the other side of that argument and I suspect we might return to it. A decision by the Secretary of State could in extremis be challenged through the court system, but we do not envisage that being necessary. The IPA will be supported by a permanent secretariat; the Ministry of Justice has already allocated funding for that.”
“In the absence of any detail on how such a consultation would be held, it is difficult to see how that could be achieved in reality—especially in the initial aftermath, when the number and identity of the victims will be unknown. I note the intent behind the right hon. Lady’s probing amendment, but urge her not to press it.”
“In all the circumstances that I have described above, let me be clear that the victims will be considered by the Secretary of State, and their needs will be paramount. I believe that victim agency is crucial, as the right hon. Lady set out. That has come through strongly during the debates on this part of the Bill. Although the amendment serves as an important reminder of that principle, it is not necessary given the sets of circumstances that I outlined previously that require a degree of flexibility. If, in each of the examples that I have described, the Secretary of State were required to hold a formal and legal consultation with the victims, that could severely cut across the ability of the IPA to be flexible and to adapt quickly to changing demands.”
“It may be appropriate, following a greater understanding of the developing needs of the victims, to supplement one advocate for another who, on reflection, may turn out to be better suited by virtue of their skills or expertise. I believe that having that flexibility is important, and the amendment would remove that flexibility in the circumstances that I have outlined. Thirdly, throughout the various debates on this part of the Bill it has been highlighted that victims must have confidence in the advocates in order for them to be effective. I entirely agree. I therefore imagine another use for the power to be removing advocates who may not command the confidence of victims, or standing down the IPA because victims decide that they no longer want the support offered.”
“We will consider the clause in detail later, but briefly we believe that it is necessary to provide the IPA with resilience should major incidents happen concurrently, or should there be a very large number of victims to support. It is in that context that it may be necessary for the IPA to change its composition during its lifetime. We imagine being able to flex the resource required to support victims to allow the IPA to be as agile as possible, and following peaks of activity it may be prudent to reduce the number of advocates actively supporting victims. The power allows the Secretary of State the flexibility to do that. Secondly, we have always stressed the importance of being able to deploy the IPA as quickly as possible following a major incident.”
“It would be helpful if I explained the rationale behind including the provision in the Bill, and I hope to reassure her that the power will be used carefully, and that we will consider the needs of victims when doing so. The Secretary of State will not take such a decision lightly, and any decision will be open to challenge through a judicial review in the courts. There are a few scenarios in which we imagine that the Secretary of State may use his or her discretion to terminate the appointment of an advocate using the power. First, as the Committee may be aware, clause 26 allows the Secretary of State to appoint multiple advocates to support victims after a particular major incident.”
“It is a pleasure to be back before you this afternoon, Mr Hosie. I thank the right hon. Member for Garston and Halewood for her amendment, which would require the Secretary of State to consult victims before terminating an advocate’s appointment on such grounds as the Secretary of State considers appropriate. That stands apart from a termination of appointment in accordance with the terms of appointment, which will cover issues such as incapacity, misconduct and a failure to exercise functions. I am grateful to the right hon. Lady for highlighting that this is a probing amendment, and I hope that I can give her some reassurances.”
“Lady for tabling the amendment and allowing us the opportunity to have this brief debate.”
“Work is already under way to ensure appropriate separation between the Department and those working in the secretariat. Finally, the advocates have the autonomy under the reporting function to include any relevant matters in their reports to the Secretary of State. Later, we will come to amendments to clause 29 on how that may interact with the independence of the IPA. As I will set out in more detail then, I am willing to work with the shadow Minister on that, to see if there is a landing zone that satisfies the Government’s position and the intentions behind the amendment. I do not believe amendment 24 is necessary as it is already covered by the Government’s intent, and in our view it is already being delivered in the Bill. I am none the less grateful to the hon.”
“I do, however, agree that the IPA must be independent and be seen to be so—and it will be. The Government are absolutely committed to an operationally independent IPA and I am happy to work with the hon. Lady to ensure that that is as clear as we can make it, or to find where we can reach consensus on some elements. Our provisions ensure that the advocates will have autonomy to take decisions and utilise their experience in a manner that they deem appropriate. That is why the functions of the IPA as set out in the Bill are broad and non-exhaustive, and further allow the IPA to support victims as it sees fit. We are, therefore, already delivering on the functional independence in the Bill. The advocates will be supported by a permanent secretariat provided by the Ministry of Justice.”
“I am grateful to the shadow Minister for the amendment and her remarks. As she set out, her amendment seeks to clarify the functional and operational independence of the IPA. I support the intention behind it, and she highlighted the oral evidence we heard in Committee. We do, however, have some drafting concerns that need to be reflected on further, which means that at this point I cannot support the amendment. I will set out my reservations, which equally the hon. Lady might herself wish to reflect on. It may be helpful not to refer specifically to the “Ministry of Justice”, to guard against any potential machinery of government changes. It is also important to ensure that the amendment would not prevent the Secretary of State from agreeing terms of reference with advocates, to provide them with guidance and clear parameters.”
“I do not know whether we will be able to close the gap between us, but as with everything, I am happy to try.”
“I appreciate that there are concerns about transparency, and as I have with previous groups of amendments, I can commit to considering with the right hon. Lady what more can be done in that respect. The IPA needs to be as effective as possible in supporting victims, and it is important that we get this right to the best of our ability in this House. Our concern is that giving the IPA the power to obtain and review all documentation could in practice introduce a further layer of complexity to the system, and I do not want to do that. I appreciate that there may be differences between the Government’s conception and that of the right hon. Lady of how the IPA will work in terms of its primary focus and function, but as before I am happy to work through that with her.”
“We consulted on the IPA in 2018, and the feedback from that consultation reinforced the need to provide clarity and support to victims following a major incident. The amendments would significantly change the purpose and role of the IPA and would introduce new responsibilities to collate, check and store information, diverting the focus away from the primary purpose that we envisaged. I appreciate that the right hon. Lady has been entirely consistent and transparent in putting her arguments with clarity. Our view is that introducing such data-controlling powers could conflict with the work of pre-existing investigative authorities, such as the work of inquiries, which already have the power under the 2005 Act to compel information and witnesses.”
“Lady’s intention behind amendment 73: to allow advocates to set up an independent panel akin to the Hillsborough Independent Panel. I pay tribute to those who worked with and on that panel, which had a pivotal role in uncovering the truth. I point out that it did not have any data-compelling powers, but it none the less did phenomenal work in questing after the truth, and revealing information that had for so long eluded others. Returning to amendments 70 and 72, the Government believe that the IPA’s key focus should be on supporting victims and the families of those affected by a major incident, rather than an investigatory approach. I appreciate that this is another area where the right hon. Lady and I may take a slightly different perspective, but I hope that we can continue to work through that in the coming months.”
“It will ensure that a broader range of police records are retained by forces in the future, meaning that there is less risk of losing or altering important records for future scrutiny, as occurred with Hillsborough. Furthermore, a statutory duty of co-operation was introduced in February 2020, placing a responsibility on police officers to give appropriate co-operation during investigations, inquiries and formal proceedings, and to participate openly and professionally in line with what is expected of a police officer when identified as a witness. A failure to co-operate is a breach of the statutory standards of professional behaviour and could result in disciplinary sanctions. I also understand the right hon.”
“Under the last Labour Government—a Government in which the right hon. Lady served, I believe—section 35(3) of the Inquiries Act 2005 came into force, making it a criminal offence to intentionally suppress, conceal, alter or destroy information during an inquiry, punishable by up to six months in prison or a fine. Secondly, the Public Records Act 1958, as amended, sets out the legal requirements for the care and preservation of public records. The College of Policing will also introduce a new code of practice, titled “Police Information and Records Management”, which will be laid before Parliament, and which details key principles for the management of all police information and records.”
“Another key theme that the right hon. Lady has highlighted is the power of transparency as a way to address, as I think Lord Wills highlighted—she mentioned him in her remarks—the instinctive approach of public bodies and organisations to conceal, or seek to evade responsibility, when something has gone horrifically and tragically wrong. Given the terrible experience of those affected by the Hillsborough disaster, I appreciate the concern surrounding the danger of documents and information being destroyed, changed or suppressed by public bodies or others. However, since the Hillsborough tragedy and the injustices that followed, there have been significant developments in the justice system that give us greater opportunities to get to the truth of what has happened. Statutory protection against cover-ups now exists.”
“I am again grateful to the right hon. Member for Garston and Halewood for her amendments. Amendments 70 and 72 would make the IPA a data controller, enabling them to obtain and review all documentation relating to a major incident. Amendment 73 sets out that advocates may support victims by establishing an independent panel to establish the truth of what happened. It is important that, in all our deliberations on this part of the Bill, we strive to continually remember just what a devastating tragedy Hillsborough was, and that its impact was compounded by the indefensible wait for the truth—indeed, the concealment of the truth. So I am entirely sympathetic to the intention behind her amendments. When we have spoken about this matter in the past, the key themes of empowerment and agency have come through.”
“They will be independent, working on behalf of the victims of major incidents, and focused on ensuring that victims get the independent support they need.”
“We imagine that the IPA will spend time, especially in the immediate aftermath, in the affected community, and it is right that we provide them with the means and resources to be able to do that effectively. We will do right by victims by ensuring that the IPA is adequately resourced. We have already made progress on that front by providing funding for a full-time secretariat from the Ministry of Justice to support the advocates. The day rate or salary of the advocates is still under consideration, but it will be made public when certain. It will be proportionate and reflect the crucial role that they will play. Finally, the clause makes it clear that advocates will not be servants or agents of the Crown.”
“As I have set out, it may be necessary to replace an advocate if they do not command the confidence of victims; to reduce the number of advocates actively supporting victims where that is appropriate and the needs of victims decrease; or to substitute advocates in response to the changing needs of victims and a greater understanding of the expertise required. To highlight that, I point to the parallel power for Ministers in the Inquiries Act 2005. As I have said, and I think we all agree, the IPA must be operationally independent. That does not mean they can be unaccountable, and I believe our provision strikes an appropriate balance. The clause enables the Secretary of State to pay advocates for their vital work and cover reasonable expenses such as travel and accommodation.”
“As public money will be used to pay for the advocates, it is right to provide for that ability to agree terms mutually. The terms will include, as normal, conditions that could lead to the termination of an appointment, such as misconduct or incapacity. The advocate may resign after giving notice. As previously discussed, the Secretary of State has a power under the clause to terminate the appointment of an advocate. I hope that the right hon. Lady and the Committee more broadly are reassured about the circumstances in which that power is likely to be used in practice.”
“Clause 25 requires the Secretary of State to agree terms with an individual who is to be appointed as an advocate. The clause makes it clear that an individual officially becomes an advocate once they agree to their terms of appointment. The clause further provides for a framework by which advocates may be remunerated, removed and equipped with the necessary secretarial support to support victims. It is vital that at the outset terms are set out and agreed between the Secretary of State, who is accountable for his or her decision, and the individual who will act as an advocate. That will provide clarity and set out the expectations around the functions and scope of the advocate, and is in keeping with other independent appointments such as inquiry panel members.”
“I am grateful to the hon. Lady for her comments. Question put and agreed to. Clause 25 accordingly ordered to stand part of the Bill. Clause 26 Appointment of multiple independent public advocates Question proposed, That the clause stand part of the Bill.”
“The clause is intended to deal with such situations by granting the Secretary of State the ability to appoint multiple advocates for the same and different major incidents. We hope that it gives the IPA the greatest ability to serve victims. It was endorsed by the respondents to the 2018 consultation.”
“The clause gives the Secretary of State the power to appoint a lead advocate where multiple advocates have been appointed for the same major incident. The Government believe that the ability to appoint multiple advocates for the same major incident will ensure that the IPA has the necessary capacity and resilience to support victims. Let us cast our minds back to 2017, when the awful and tragic events in Manchester and at Grenfell Tower happened only a few weeks apart. The number of victims in need of support was in the hundreds, if not higher, and it would not have been possible for a single advocate to provide the right amount of support to all the victims in two very different geographical locations.”
“That approach will allow for engagement with the families about the type of support they need from an IPA.”
“It is a difficult balance to strike; like so many things do in public life and in our work, it requires people to behave in a reasonable and responsible manner. I am confident that that that will be the case, but the right hon. Lady is right to highlight the challenges were it not. We will set up a register of individuals from a range of different professions, backgrounds and geographical areas to enable the IPA to respond to the broadest range of circumstances and the unpredictable nature of major incidents. It will also enable the Secretary of State to appoint an advocate as soon as possible and then appoint further advocates over a slightly longer period, including community advocates, to ensure that voices are reflected and the confidence of victims is maintained.”
“The right hon. Lady will know the legal connotations of the phrase “have regard to”. What we are seeking to do is recognise that while there may be a lead advocate, there will potentially be other advocates in the team who have particular strengths and expertise. In appointing more than one advocate, I am sure that the Secretary of State will have due regard to ensuring that the team is coherent and able to work together. It is important that if we are bringing different advocates with different areas of expertise into a team, their voices are able to be heard. There is an expectation that they will behave reasonably and have regard to that principle. Equally, I would not want the lead advocate to be able to silence the expertise of others in the team.”
“The IPAs are not envisaged as akin to the Hillsborough Independent Panel; they are to be set up as independent public advocates, but the office can have multiple holders simultaneously, if that makes sense, to draw on different expertise. The key element lies in the word “independent”. We are confident that the measures that we are putting in place will create and sustain that independence. I appreciate that the hon. Lady might press back on that on Report or in subsequent debate, but on that basis we consider the clause to strike the right balance. Question put and agreed to . Clause 26 accordingly ordered to stand part of the Bill . Clause 27 Functions of an independent public advocate”
“Their tireless fight for the truth—and the right hon. Lady’s tireless fight for the truth on their behalf—is to be commended, but it should never need to be repeated. Victims and the wider public deserve to know the truth and to get answers to their questions. However, our concern is that the way to achieve this cannot be one that potentially puts a victim’s right to formal legal justice in jeopardy by duplicating or cutting across the work of other investigatory bodies. I recognise that there are questions about independence and the IPA’s power to get to the truth. I am happy to reflect on that further, and to reflect with the right hon. Lady on whether there are other ways that we can seek to achieve what she seeks without the potential legal jeopardy that might exist if it were done in this way.”
“I remind Members that the Hillsborough Independent Panel was established many years after the Hillsborough tragedy, which meant that it did not run the risk of undermining or prejudicing any ongoing formal legal proceedings. I note that in the helpful explanatory statement from the right hon. Lady, she states that she believes the panel should be established at an early stage following an incident. I am slightly wary of that and the possible interrelationship with other legal processes. Establishing an independent panel at an early stage—a panel that has the power to require disclosure of all relevant documents and information—could pose a threat to other investigatory processes, particularly criminal trials or other legal proceedings. No one should suffer the same injustices as those affected by Hillsborough.”
“I appreciate that the matter of debate between the right hon. Lady and I is whether the focus should be on support or the investigatory role, and how to draw that line, but if the IPA is primarily focused on supporting victims, signposting and building a relationship of trust with them, could they be considered to be truly impartial in an investigatory role? If they stepped away from their role as an advocate to focus on the work of the panel, would that affect the ability to support victims? I do not posit any direct answers to that, but I pose those questions, to which I suspect we will return subsequently, possibly on the Floor of the House or in discussions outwith this Committee.”
“Non-statutory inquiries are funded by public funds, so it is right that the decision to set one up remains with the Government. As I emphasised earlier, the Hillsborough Independent Panel did not have any data compelling powers. As Ken Sutton, who has been referenced previously and who led the secretariat for the Hillsborough Independent Panel, noted in our oral evidence sessions, the panel was able to access information and documentation without the need for data compelling powers. What is more, it is important to avoid any conflict between different investigatory functions. In my reading of them, the right hon. Lady’s amendments do not clarify what the role of an advocate would be in relation to the panel, how it would work in practice and, crucially, what impact it would have on the support available to victims.”
“Again, I am grateful to the right hon. Member for Garston and Halewood for tabling amendments 74 and 75, which I will address together. As she set out, the amendments would enable the IPA to establish an independent panel, akin to the Hillsborough Independent Panel, in consultation with victims. As we have said, those affected by the Hillsborough disaster had to wait far, far too long for truth. I again pay tribute to the Hillsborough Independent Panel, which played a crucial role in uncovering the truth and correcting the public narrative after so many years. I turn to the substance of the amendments. As I mentioned previously, it is worth remembering that the Hillsborough Independent Panel was a non-statutory inquiry set up by the Home Secretary.”
“Many people will have never had any interaction with the inquest process, and it will be unfamiliar and possibly daunting at a particularly vulnerable time. In order to help the IPA to signpost victims, to amplify their voices, and to ensure that they have access to information to which they are entitled, we believe it is important to amend the 2009 Act to allow an advocate to be an interested person. In practical terms, that will aid the IPA in helping the bereaved to get answers to their questions and to fully participate at inquests on their behalf. I commend clauses 27 and 28 to the Committee.”
“We believe it is appropriate for advocates to work with a child’s parent or guardian, who ordinarily will be best placed to provide information and support in a manner that best suits the child. Clause 27 enables the IPA to support people under the age of 18 through a representative. That ensures that those under the age of 18 are not excluded. Once the individual in question reaches the age of 18, they can then receive the support directly. Clause 28 amends section 47(2) of the Coroners and Justice Act 2009 to allow an advocate to be an interested person in relation to an inquest into a death caused by a major incident. That will help the advocate to effectively carry out their support functions for the bereaved and to access information relating to the inquest to which they are entitled.”
“The functions of the IPA as set out in clause 27 are consistent with the approach the Government consulted on in 2018. They provide for the IPA to effectively deliver its aims of advocating for victims with public authorities and allow it to fulfil its intent of supporting victims through the processes that follow a major incident. Turning to who the IPA will support, clause 27 makes provision for advocates to support victims through a representative—for example, where a victim or a group of victims cannot speak English, or an injured victim is not able to engage directly. The clause prohibits the IPA from directly supporting people under the age of 18.”