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Pillar 3 of 6

Child Criminal Exploitation
The Police Perspective

What schools are documenting that never reaches a police intelligence system. The Modern Slavery Act statutory defence in practice. An interactive step-by-step referral pathway. Cuckooing: intelligence tensions and school protocols. And what the Crime and Policing Act 2026 changes.

5 articles Interactive pathway tool Last reviewed: May 2026
⚖️ Aligned with the College of Policing APP: This guidance reflects the College of Policing's Authorised Professional Practice (APP). Treat child criminal exploitation as child abuse: apply the APP Investigating child abuse and safeguarding children module (and its CSE guidance where relevant). Where exploitation indicators are present, consider a National Referral Mechanism referral under the Modern Slavery Act 2015, and work through the National Decision Model, with the Code of Ethics at its centre.
3.1
What Schools Are Seeing That Police Might Not Know About
3.2
Recognising Children as Victims: The Modern Slavery Act Framework in Practice
MSA s.45
3.3
The CCE Referral Pathway: School Concern to Police Investigation
Interactive tool
3.4
Cuckooing: Working With Schools When a Child's Home Is Involved
3.5
The Standalone CCE Offence: Crime and Policing Act 2026
New law
3.1 What Schools Are Seeing That Police Might Not Know About

County lines intelligence tends to reach police in two ways: a stop and search that reveals drugs, or a MASH referral triggered by a crisis. What it rarely captures is the four months of low-level indicators that a school pastoral team has been quietly logging. This article is about how to access that picture — and what to do with it.

What schools observe that rarely surfaces in police intelligence

  • Peer group shift. A young person who abruptly stops mixing with established friends and begins associating with older, unfamiliar individuals — often from outside the school's catchment area. Teachers notice this because they see the same cohort every day.
  • Phone behaviour changes. Unexplained second phones, guarding phones anxiously, leaving lessons to take calls, receiving money transfers on phones visible to teachers.
  • Unexplained cash and possessions. New trainers, branded clothing, or cash that cannot be explained — noted by pastoral staff across multiple observations, not a single incident.
  • Attendance patterns. Not blanket absence, but strategic absence — Mondays after weekends away, or absence that coincides with county lines delivery cycles. Schools track this; the patterns often mean more than the overall percentage.
  • Withdrawal and mood changes. Becoming guarded, monosyllabic, or visibly anxious — particularly around phone alerts and at certain times of day. A trusted teacher may have noticed a specific turning point.
  • Vocabulary shift. Adopting language or terminology associated with gang culture or drug supply — noted by staff who know the young person's baseline communication style.
  • Selective engagement with adults. Actively avoiding certain staff members, or conversely, becoming overly dependent on one trusted adult — often the first sign of a disclosure being built towards.

How to have a productive CCE intelligence conversation with a DSL

The DSL holds the school's safeguarding picture. They are not an intelligence asset — they are a partner with a professional duty to share information that protects a child. The following approach tends to produce better results than a direct request for information.

  • Open broadly: "What have you noticed about [child's] presentation over the past six months? Any changes in peer group, behaviour, or how they interact with staff?"
  • Ask about context, not incidents: "Is there a pattern to when you see the changes — certain days, times of term, after weekends?"
  • Ask about near-disclosures: "Has anything been said, even informally, that you felt might be significant but wasn't a formal disclosure?"
  • Do not ask leading questions. You may need the school's evidence in future proceedings. Anything that looks like coaching undermines its value.
  • Be explicit about reciprocity: Tell the DSL what you can share back, and why you sometimes cannot. If you cannot tell them the address of a suspected cuckooed property, say so and explain why — it builds trust for next time.
  • Leave a feedback loop: Agree on what the DSL should do if they observe specific behaviours or receive a disclosure. Make it concrete: "If [child] mentions staying somewhere new, call me directly before recording anything else."

What schools can share with police

Legal basis: Data Protection Act 2018, Schedule 2, Part 1, paragraph 2 permits disclosure of personal data to law enforcement where withholding would likely prejudice the prevention or detection of crime. Working Together 2026 (Ch. 1) is explicit: information sharing in the interests of a child's welfare can proceed without consent where consent would put the child at greater risk or undermine an investigation.
  • Pastoral concerns, attendance patterns, and behavioural observations held in the school's safeguarding records
  • Information formally documented in the DSL's concern log and referral records
  • General community-level concerns (without identifying specific children) to help police understand a school's context
  • Evidence to support an NRM referral — see Article 3.2

What schools cannot share without careful consideration

  • Information that would identify other children involved in the same network (additional safeguarding implications)
  • Information that, if shared, would alert a perpetrator or compromise an ongoing operation
  • Confidential disclosures where sharing would put the disclosing child at materially greater risk — this requires DSL judgment, and the DSL may need to consult their MASH duty team

The right venue for detailed sharing on complex cases is the MASH strategy discussion — both agencies share in a structured, recorded multi-agency context.

Primary source: Information Sharing: Advice for Practitioners (HM Government, 2023) — the definitive guide for all multi-agency information sharing in safeguarding contexts.
Last reviewed: May 2026 · Sources: Working Together to Safeguard Children 2026 · Data Protection Act 2018, Schedule 2, Part 1, para 2 · KCSIE 2025
3.2 Recognising Children as Victims: The Modern Slavery Act Framework in Practice
Guidance only. This article provides a working overview of the Modern Slavery Act 2015 s.45 statutory defence. Charging decisions must be made with CPS input. Consult your force's Modern Slavery lead or CPS liaison before applying this framework to a specific case. This is an area of developing case law. CPS legal guidance →

The cultural shift: from offender to victim

Until relatively recently, a child found running drugs on a county line was commonly processed as a young offender. The Modern Slavery Act 2015 and subsequent CPS guidance have changed the legal landscape — and the operational expectation — significantly. The child being exploited in a county lines operation is, in the absence of evidence to the contrary, a victim of trafficking and exploitation. The legal framework reflects this.

Section 45 MSA 2015 — The statutory defence explained

Modern Slavery Act 2015, s.45: A person under 18 has a full defence to any offence committed as a direct consequence of being a victim of slavery or a relevant exploitation. The prosecution bears the burden of rebutting the defence beyond reasonable doubt.

In practical terms, this means:

  • A child found in possession of a quantity of drugs, carrying a knife as a debt enforcement tool, or using a phone that facilitated supply — has a full statutory defence if they were being criminally exploited at the time
  • The defence applies to any offence, not just drug supply
  • The child does not need to have been formally identified as a victim via the NRM
  • The child does not need to acknowledge they are a victim — a coached or coerced denial does not extinguish the defence
  • CPS guidance directs prosecutors to apply this framework at the charging stage, not wait for it to be raised as a trial defence

What this means for how you build intelligence in schools

If the goal is to build a case that identifies and prosecutes the people exploiting children — rather than the children themselves — the intelligence you gather needs to reflect the exploitation relationship, not just the criminal activity. The questions to ask a DSL shift accordingly.

  • Not "what has [child] been doing?" but "what has changed about [child], and when did it start?"
  • Not "was [child] involved in this incident?" but "do you have a picture of who [child] has been associating with over the past 6 months?"
  • Ask specifically about signs of coercion, debt, fear, control — the grooming and exploitation process
  • Ask whether the school has documented specific changes, and whether anything was said that suggested pressure from outside

This intelligence builds the exploitation picture — which is what you need for a trafficking or CCE prosecution — rather than drug supply evidence that locks the charging question onto the child.

NRM referral process — summary

  • Any police officer is a designated First Responder and can submit an NRM referral
  • Referrals are submitted online via the Home Office NRM portal (gov.uk)
  • The Single Competent Authority (SCA) makes a Reasonable Grounds decision within 5 working days
  • A Conclusive Grounds decision follows after a minimum 30-day recovery period (reduced from 45 days in December 2022); there is no fixed target timeframe for the CG decision itself
  • The child does not have to consent to a referral — though consent is preferable and should be sought
  • Schools can provide supporting evidence for the NRM referral. Ask the DSL what they have documented — attendance records, concern logs, specific observations — and request a written statement if appropriate
Police action point: If you are building an NRM referral for a child and have a school contact, ask the DSL directly: "Can you provide a written account of what you've observed over the past 6 months that you'd be willing to include in our referral?" Schools are often unaware they can contribute to this process.
Last reviewed: May 2026 · Sources: Modern Slavery Act 2015 s.45 · Modern Slavery: Statutory Guidance 2023 · CPS Human Trafficking guidance · Working Together 2026
Interactive Tool 3.3 — The CCE Referral Pathway: School Concern to Police Investigation
Important: This pathway reflects the national framework under Working Together 2026. Your force and local authority may operate a modified model. Always follow your force's safeguarding SOPs and your Local Safeguarding Children Partnership's (LSCP's) local protocol. Timeframes shown are national standards — your MASH may operate different response windows.
Stage 1 of 8
3.4 Cuckooing: Working With Schools When a Child's Home Is Involved

When a vulnerable person's home is taken over by a county lines network for drug storage and supply, the child connected to that home occupies a uniquely dangerous position. They may be living in the cuckooed property, or they may be the child of the person whose home has been taken. Schools are often the first place where signs of cuckooing become visible — and the information they hold can matter to your operation, even if you can't tell them why.

School-visible indicators that a child's home may be cuckooed

  • Sudden change of home address or emergency contact details submitted to school — parents giving a new address without obvious explanation (moving house is typically communicated differently)
  • Child arriving unusually early or being collected by unfamiliar adults — people the school doesn't recognise, sometimes in vehicles that don't match the family's known circumstances
  • Visible anxiety about going home, in contrast to apparent relief on arriving at school — a pattern staff notice when they know the child
  • Frequent references to "staying over" or "sleeping at a friend's" beyond what was normal for that child
  • Parents or carers presenting as fearful, evasive, or visibly stressed at school events or contacts — out of keeping with how they previously engaged
  • Contradictory or rehearsed-sounding information about home circumstances when staff ask open questions — particularly if the child glances at a phone or appears to check a prepared answer
  • Changes in demeanour specifically linked to home-related discussions — the child who is otherwise beginning to re-engage suddenly shuts down when home comes up

The intelligence tension: what police can and cannot share

This is one of the most operationally sensitive areas of police-school working. You may know — or strongly suspect — that a child's home address is a cuckooed property. Sharing that address with the school creates a direct risk: the information may inadvertently reach the perpetrators, compromising your operation and potentially endangering the cuckooed person and the child.

The working arrangement that protects both the operation and the child:
  • You can tell a DSL: "We have intelligence that [child's name] may be experiencing changes at their home situation that are a safeguarding concern. We'd ask you to monitor closely — particularly any changes in address, who collects them, or anything they say about home."
  • You should not share: the specific address suspected, the nature of the criminal operation, or the identity of suspects
  • The DSL then has a framework for increased monitoring and safeguarding support, without knowing the operational details that would compromise the investigation
  • If the child makes a disclosure at school, the DSL will refer to MASH — and the MASH is the appropriate venue for sharing more detailed intelligence in a controlled, multi-agency context

If a child discloses at school that their home is being used

This is a Section 47 situation. Immediate MASH referral is required. Advise the DSL on the following specific points — because well-meaning responses can compromise both the child's safety and the investigation.
  • Do not allow the school to question the child further. Any further questioning risks contaminating an Achieving Best Evidence (ABE) interview. The child has made the disclosure — that is sufficient. The DSL should note what was said, word for word, and stop there.
  • Do not allow the school to contact the parents or carers of the child. If the property is cuckooed, contacting the family alerts the perpetrators. Even a routine "we need to speak to you about [child]" call can be enough to prompt destruction of evidence or violence against the cuckooed person.
  • Keep the child at school until MASH has been contacted and provided specific guidance on the plan for the child's safe collection or transfer.
  • If the disclosure reveals an immediate risk to other people in the property — the cuckooed person, siblings, other occupants — contact the MASH immediately and consider whether emergency police attendance is required.
Last reviewed: May 2026 · Sources: Working Together 2026 · Modern Slavery Act 2015 · Children Act 1989 s.47
3.5 The Standalone CCE Offence: Crime and Policing Act 2026
Legislative status: The Crime and Policing Act 2026 received Royal Assent on 29 April 2026. It creates a standalone offence of child criminal exploitation. Commencement of specific provisions may be subject to commencement orders — officers should confirm with their force legal team or CPS liaison before charging under any new provision, and check CPS guidance for the latest operational position.

The problem with the old legal landscape

Before 2025, there was no standalone criminal offence of child criminal exploitation. CCE cases were prosecuted under a patchwork of existing legislation:

  • Modern Slavery Act 2015, ss.1–2 — slavery, servitude, forced labour, and human trafficking; used where movement and recruitment of children was involved
  • Serious Crime Act 2007, ss.44–46 — encouraging or assisting an offence; used for network organisers who directed operations without direct involvement
  • Common law conspiracy — for those coordinating wider criminal networks
  • Misuse of Drugs Act 1971 — drug supply charges, which captured the criminal activity but often rendered the exploitation invisible in the prosecution narrative

The result was that many prosecutions focused on what the child was made to do — carry drugs, intimidate debtors — rather than on what was done to the child. Organisers at the top of a county line were sometimes charged only for drug supply conspiracy, with no reference to the exploitation of the children who ran it.

What the Crime and Policing Act 2026 introduces

The Act creates a standalone offence of child criminal exploitation, covering those who cause, incite, or exercise control over a child for the purpose of criminal exploitation. The offence centres on the exploitation relationship — what was done to the child to procure their involvement — rather than exclusively on the criminal activity the child performed.

  • The offence is directed at those who exploit children — the recruiters, controllers, and organisers — not the children themselves (who retain the s.45 MSA defence)
  • A prosecution can be built around the grooming process, coercion, debt bondage, and control — without the prosecution needing to prove a specific drug supply chain end-to-end
  • This makes school intelligence — which documents the grooming and coercion process — potentially direct evidential material, not just safeguarding background
  • The CCE offence carries a maximum sentence of 10 years' imprisonment

Additional offences created by the Act

The Crime and Policing Act 2026 also creates two further offences directly relevant to CCE operations:

  • Cuckooing offence — a standalone offence of taking over or controlling a person's home for criminal purposes (maximum sentence: 5 years' imprisonment). This directly addresses the scenario where a child's home or a vulnerable adult's address is seized by a county lines network. Previously prosecuted under a patchwork of offences; the new provision makes the exploitation of the home itself the criminal act.
  • Internal concealment offence — an offence targeting the use of children (and others) to internally conceal drugs or other contraband. This fills a longstanding gap where the act of concealment within a person's body was inadequately addressed by existing supply charges.

What this means for the school's role in evidencing exploitation

Prior to the Act, what a school documented was primarily relevant to safeguarding and welfare proceedings. The new offence changes this. Systematic school records showing the progression of grooming behaviours — peer group isolation, gift-giving, increasing control — can form part of the prosecution evidence base for the CCE offence itself.

Practical implication for school visits: When speaking to a DSL about a child you believe is being exploited, ask specifically whether their safeguarding records document the progression of the child's situation — not just individual incidents. A timeline showing how a child's behaviour changed over months is the kind of evidence that supports a CCE prosecution. Ask the DSL to preserve and not overwrite earlier records, even where they seem minor in isolation.

What it does not change

  • The s.45 MSA statutory defence for children remains in full force
  • NRM referral processes are unchanged
  • The MASH referral pathway and strategy discussion requirements are unchanged
  • CPS charging guidance will determine how the new offence is used in practice — this article does not substitute for that guidance
Pending CPS guidance: The CPS is expected to issue specific charging guidance for the new CCE offence. Until that guidance is published, officers should not assume that the new offence will be applied in a particular way by prosecutors in their area. Check CPS guidance →
Last reviewed: May 2026 · Sources: Crime and Policing Act 2026 (Royal Assent 29 April 2026) · Modern Slavery Act 2015 s.45 · CPS human trafficking and exploitation guidance · Working Together 2026
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