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Official Response

SUBJECT: Asylum accommodation and support transformation REQUESTED BY: UK Visas and Immigration DATE: 31 January 2017 SUBMITTED BY: Grace Pengelly [email protected] David Bradwell dbradwell@churchofscotland. org.uk

This is a joint response from the Baptist Union of Great Britain, the Methodist Church, the United Reformed Church and the Church of Scotland to the consultation “Asylum accommodation and support transformation – NGO and voluntary sector written exercise”.

Introduction

We welcome this opportunity to contribute to the UKVI’s review of the accommodation and support provided for asylum seekers. The Baptist Union of Great Britain, The Methodist Church, The United Reformed Church and the Church of Scotland1 make this response in view of our shared concern for the wellbeing and rights of those seeking asylum in the UK. There are members and leaders of our churches at a local level who have experienced the asylum system; both as asylum-seekers themselves, but also as individuals supporting members of their community as they go through the asylum process

Throughout the UK, our Churches and congregations are associated with a diverse range of asylum and refugee support projects: our response draws on the experiences and knowledge of asylum seekers and refugees, as well as the volunteers who support them, and is based on the ethical and moral principles of the Christian tradition of welcoming the stranger, upholding the dignity of every person and working for the common good.

We are disappointed that the timeline given by the UKVI (20 December with a deadline of 31 January) does not provide enough time for voluntary sector organisations to be able to research, draft and sign off on submissions, especially as this timeframe overlapped with public holidays. We request that consultations which seek responses from the voluntary sector should be open for 12 weeks as standard. The shorter window for responses in this consultation has meant we have not been able to gather and present as much evidence as we would have liked. This raises questions about the efficacy of the overall process if consultees are unable to feed in information adequately. We hope that the AAST project team will compensate for this shortcoming by arranging a commensurate number of engagement sessions that will enable a wider range of organisations and agencies to contribute to the review. We have responded to the questions where we have evidence or views which we hope will be of use.

1 The Church of Scotland is currently leading a multi faith project of co-ordinated support and work with refugees and asylum seekers, called Scottish Faiths Action for Refugees (www.sfar.org.uk) Page 2 of 8

Existing provision

1. Please provide examples of what you consider to be the strengths of the COMPASS, and preceding Target, arrangements for asylum accommodation and support?

2. Please provide examples of where you think the COMPASS, and preceding Target arrangements of asylum accommodation and support could be improved upon.

2.1 There appears to be little evidence indicating that the private sector outsourcing of accommodation and support services can be described as a success. We do not believe that the companies selected to deliver COMPASS have the necessary expertise to successfully provide for the complex needs of some of the most vulnerable people within the United Kingdom. Although it was hoped that the transition from Target to COMPASS in 2012 would enable the UKVI to monitor and review delivery, we continue to have concerns about the inability of suppliers to meet the demands of their contract.

Accommodation standards

2.2 In spite of media attention received by some particularly serious examples of poor property maintenance, and the National Audit Office’s 20142 review of COMPASS, we continue to receive reports that the conditions of accommodation provided under COMPASS are failing to meet their contractual obligation to provide “safe, habitable, fit for purpose and correctly equipped homes.”

2.3 One of our churches in Selly Park in Birmingham supports a number of refugees and asylum seekers. One family supported by Church members lives in accommodation serviced by G4S, and reported that the beds in their flat were broken and they were forced to sleep on blankets on the floor. Although G4S promised in April 2016 to deliver two bed frames and one mattress by July, the bed frames had still not arrived by September. Subsequent phone calls made to G4S have gone unanswered. This means that the mother and son were either forced to share the one mattress provided, or decide who has the greatest need. The impact on children of having to use shared facilities is well documented: children are more likely to display signs of psychological distress and it may also affect their education prospects. Visitors to the family also highlighted the “the dire condition of the...building, with rubbish and food waste dumped against the back wall, and visible holes in the wall which enabled rats to get in and out.”

2.4 Last March, serious allegations3 were raised by the Scottish Refugee Council4 against Orchard and Shipman, a subcontractor of Serco, which manages the accommodation for asylum seekers in

2 https://www.nao.org.uk/wp-content/uploads/2014/01/10287-001-accommodation-for-asylum-seekers-Book.pdf

3 http://www.jointpublicissues.org.uk/glasgow-allegations-of-asylum-seeker-mistreatment-degrading- disrespectful-and-dehumanising/

4http://www.scottishrefugeecouncil.org.uk/news_and_events/news/2819_scottish_refugee_council_calls_for _investigation_into_housing_for_people_seeking_asylum Page 3 of 8

Glasgow. These allegations included one case of a mother and baby housed in a cockroach infested property in Glasgow. We do not believe this was an isolated incident, but instead highlights the failings of several COMPASS suppliers, and the failings of the Home Office to effectively monitor delivery and compliance.

Support standards

2.5 A second area of concern relates to the overall user experience provided by private companies when attempting to raise a complaint or concern about the quality of their accommodation. A common report made by asylum seekers is that their complaints fall on deaf ears, and that the complaints “services” provided by agencies are often unresponsive.

2.6 More worrying, are reports of dehumanising or degrading treatment by contractual staff as highlighted by the ‘wristbands’ incident in Cardiff5, and ‘red doors’ controversy in Middlesbrough and Stockton6. Our experience of supporting asylum seekers and refugees in drop in centres and support groups highlights the bravery and resilience of individuals who have often reached the UK after a series of traumatic episodes. We are gravely concerned by the evident lack of expertise and knowledge surrounding service user needs within companies like G4S and Serco, who in subsequent select committee interviews appear to have been overwhelmed by the scale of the contract and complex needs of service users.

2.7 We would welcome the inclusion of an independent scrutiny clause in future accommodation and support contracts, a new independent means of complaint for asylum seekers, and for the Home Office to start recording complaints by type and region so that these figures may be available to the public on a quarterly basis7.

Good practice and innovation

3) Please describe any good practice lessons, or examples of innovation, from your sector which could be relevant to a future asylum support model?

3.1 Despite financial constraints, there continue to be many service innovations around the country.

3.2 The Wycombe Refugee Partnership, a multi-faith group, has been pioneering the resettlement of successful asylum applicants at the time when their Asylum Support terminates. The work of the Partnership has shown both the importance of bringing together a broad package of support tailored to each case (including with health, employment, schools, language tuition, befriending and more specialist needs) and the requirement to support individuals and families through a process of transition beyond the current scope of COMPASS.

5 https://www.theguardian.com/uk-news/2016/jan/24/asylum-seekers-made-to-wear-coloured-wristbands- cardiff

6 https://www.theguardian.com/business/2016/jan/26/g4s-jomast-bosses-admit-number-asylum-seeker-red- doors-too-high-select-committee

7 https://www.theyworkforyou.com/wrans/?id=2016-12-19.58248.h&p=11804 Page 4 of 8

3.3 In Scotland, the development of a national Poverty Truth Commission8 has helped ensure that those affected by decisions made at a policy level are central to the decision-making process. The Poverty Truth Commission brings together some of Scotland’s key decision makers with those living at the sharp end of poverty. The Commission operates on the basis that poverty will only be truly addressed when those who experience it first-hand are at the heart of the process: its motto is ‘Nothing about us, without us, is for us.’ This model is now being replicated in a number of other parts of the UK, including Chester and West Cheshire, Salford, Leeds, Birmingham and Wolverhampton.

3.4 We believe that this model, which in this case would recognise that asylum seekers are ‘experts by experience’ when it comes to determining the type of support and accommodation they require, could prove instructive to the work of the UKVI as it contemplates the future of AAST. We believe that many of the problems that have emerged in relation to COMPASS could have been flagged at a much earlier stage had proper consultation with past, current and prospective residents taken place.

3.5 There are also lessons to be learned from some of the successes the Syrian Vulnerable Persons Resettlement (VPR) scheme has achieved; the experiences of those local authorities with previous experience of resettlement programmes were more positive than those who are new to resettlement. Those with more experience were able to deliver the coordinate support needed due to the established networks that had developed over time. The knowledge hubs established by the Convention of Scottish Local Authorities, the Local Government Association and the Welsh Local Government Association have enabled programme teams to share materials and case studies. This model of sharing best practice could be replicated within a future provision model, as the number suppliers who have developed the requisite knowledge base and experience begins to mature.

3.6 Adequate funding has also been key to securing the resettlement of Syrians under the VPR scheme. Whilst local authorities can claim £8,520 for each refugee resettled, G4S reportedly receive less than half this amount from the government - £3,412 per year.9 As the UKVI considers the future of accommodation and support provision, we recommend that it urgently reviews and increases the level of financial support provided to suppliers, whichever model of provision is selected.

3.7 As with the examples listed above, it is far easier for the voluntary sector to engage and provide the additional expertise and best practice when they are involved in delivery under some local authority oversight. Experience from organisations working in Glasgow for many years, including the Scottish Refugee Council, suggests that there was significant deterioration in the quality of provision and oversight from when it was a direct responsibility of Glasgow City Council to when it was contracted out to Y-People, and then a further deterioration when the service was handed to Serco / Orchard and Shipman. In this respect, private sector outsourcing is largely detrimental to this field.

Segmentation

Q.4 Would you consider such a segmented approach to be appropriate for ensuring quality of service provision to service users? What are the potential benefits and risks?

8 http://www.faithincommunityscotland.org/poverty-truth-commission/

9 http://www.migrantsrights.org.uk/files/news/EMBARGOED_Migration_Crisis_report.pdf Page 5 of 8

4.1 There are benefits to segmented provision. A discrete aspect of support might be better delivered by a specialised agency, and would also enable the Home Office to monitor more closely which aspects of provision are not being met properly.

4.2 However, those seeking asylum in the UK often have to engage with multiple organisations and agencies, and are frequently required to repeat their experiences to each provider (so that they can assess need). If a segmented approach were undertaken, it would be important that the appropriate communications channels are established amongst teams so that asylum seekers are not forced unnecessarily to repeat their ordeal.

4.3 For those service users who suffer from poor mental health, isolation, or who don’t speak English a ‘one stop shop’ service might be preferable.

Q.5 Under such a segmented approach, are there specific services which you, as voluntary sector organisation, would have an appetite to provide or support. What barriers to delivery or constraints would need to be overcome to facilitate your provision?

5.1 Faith communities are well placed to help support the integration of asylum seekers through intercultural dialogue and ESOL provision. Three examples:

 The congregation at Wesley Hall Methodist Church, Blackburn, have responded to the arrival of asylum seekers within their community by hosting a drop-in at the church every Tuesday (the ARC Project10).

 St David’s Church of Scotland in the Knightswood area of Glasgow run a drop-in for asylum seekers every Friday11, with a language class plus crèche as well as a charity shop where donated items can be sold on or given away to those in need.

 The Open Doors project in Hull offers a weekly drop in session, offering a light breakfast, clothes, some cash support, ESOL classes, Immigration advice and support for migrant workers12.

5.2 Whilst small scale, such examples of informal community development already exist throughout the UK: funding, practical knowledge and outreach workers would help facilitate this provision.

6. Are there potential supplier groups/types (e.g social housing providers) for different services, which are not currently involved in service delivery under COMPASS, which we should consider in a future arrangement?

6.1 Churches, faith and community groups. We suggest that there is a considerable potential pool of volunteers as well as large number of venues which will be accessible, affordable and appropriate for additional integration and advice services. It may be that the Home Office and local authorities

10 http://www.blackburn.anglican.org/images/news/2010arcvolunteers.pdf

11 http://stdavidschurch.weebly.com/asylum-seekers-drop-in.html

12 http://opendoors-hull.org.uk/ Page 6 of 8 could support this development directly, or to work with the national Church and faith bodies to assist in communication and co-ordination of this work on a local and regional basis.

Vulnerability

7. With reference to specific vulnerable groups, or aspects of vulnerability, please discuss the needs of these individuals, and how the accommodation and support offer might need to be configured to adequately meet these needs.

7.1 It is our belief that the substandard accommodation and inadequate support currently being offered under the current COMPASS contracts contribute to the mental and physical deterioration of its most vulnerable users. However, in addition to identifying and responding to the needs of particular groups, it is important to recognise that living in temporary accommodation is a stressful period for anyone, meaning that suppliers of accommodation must enforce high standards of care and welfare support to all those who rely on its services.

7.2 A Barnardo’s report13 exploring concerns around the lives of asylum seeking children in temporary accommodation, highlights assertions made earlier in this submission regarding the impact that the quality and location of accommodation has upon children. They recommended that the standards of accommodation for asylum-seeking families should meet ‘at least the same standards required for housing statutorily homeless households with children’.

7.3 The report also raised concerns about the very serious problems that emerge as a result of racial harassment and recommended that children should not be housed in areas where there is a history of harassment or reason to believe their presence will aggravate community tensions. Barnardo’s argues that there are many legitimate reasons why families may preference one dispersal area over another – and that ‘families with children should have the right to express reasonable preference about the regional location of their accommodation before dispersal and for this preference to be taken into account.’

7.4 Research conducted by the University of Strathclyde and the British Red Cross14 looking at the challenges pregnant women in Scotland face during their time seeking refugee protection highlighted that housing was the most common practical complaint for the women interviewed. A substantial number of participants complained about the state of the accommodation provided and/or had experienced multiple moves due to poor standards. It noted that ‘living in a dirty, cramped house meant that many of them were not feeling able to relax and feel at home.’ Several women complained about not being able to speak to Orchard and Shipman when needed. The report also notes that in addition to anxieties related to their condition, the asylum process itself is a cause of stress. The study supports the evidence that depression and anxiety can drastically limit their ability to engage in activities outside the home, resulting in the isolation of both mother and child.

13 http://www.barnardos.org.uk/like_any_other_child_asylum_report08_full.pdf

14http://www.redcross.org.uk/~/media/BritishRedCross/Documents/About%20us/A%20Healthy%20Start %20Report.pdf Page 7 of 8

7.5 We received the following report of a young woman’s experience of being told to leave her accommodation by the Home Office shortly after her child had died: ‘After I lost my baby I received a letter from the Home Office telling me I had to leave my accommodation within two weeks; because I was no longer entitled. I didn’t have anyone, and didn’t have anywhere to go. I was c-sectioned and recovering and no-one came to help me, I was sick and no-one helped.’ In this instance, the existence of effective communications channels between the health service and the Home Office could have helped identify this individual as being particularly vulnerable, and prevented her from enduring another psychologically traumatic experience so shortly after she had lost her child.

7.6 In addition to improving the material standards of accommodation, it is evident that staff employed by accommodation suppliers need to receive better guidance and training on working with vulnerable adults and children. Courses such as Mental Health First Aid15, which teach people how to identify, understand and help those who may be developing a mental health issue, could be included within a future provision model as a basic requirement.

Contingency provision

8) Please provide examples (national or international) of contingency approaches which have worked well in similar environments? What are the pros and cons and how could they be replicated in asylum support?

Move-on arrangements

9) What arrangements or structures do you think ought to be in place to allow supported asylum seekers who are granted asylum access to employment or mainstream benefits?

9.1 There is a good body of evidence (Red Cross16,Refugee Council17) which shows that the twenty- eight day ‘grace period’ is not enough time for individuals to successfully transition to employment or mainstream benefits after a claim for asylum is granted. Individuals moving on from asylum support are often unfamiliar with the UK welfare system, may not have good English, and may find themselves cut off from their available support network due to their dispersal. Very little useful information or support is provided for asylum seekers before their claim is granted. All of these factors can make transitioning a confusing and chaotic experience, and results in many refugees becoming destitute.

9.2 Finding accommodation within such a short time frame is particularly challenging – if an individual opts to move into private rental accommodation, their lack of money and references may make this a very difficult process. Those moving on from receiving financial support may have no other source of income, many turn to loan companies during this period.

15 https://mhfaengland.org/

16http://www.redcross.org.uk/~/media/BritishRedCross/Documents/About%20us/Research%20reports%20by %20advocacy%20dept/Move%20on%20period%20report.pdf

17 http://www.refugeecouncil.org.uk/assets/0003/1769/28_days_later.pdf Page 8 of 8

9.3 We would like to echo some of the recommendations made by the British Red Cross concerning ways in which the UKVI could address the needs of refugees during the move-on period in future provision models.

 By extending the grace period allowed to remain in asylum accommodation to 40 days, the risk of there being a break in support would be decreased.

 Ensure agencies involved in the move-on process (DWP, JCP, Home Office) are trained to properly to deal with the needs of refugees.

 Crucially, the Home Office must work much more closely with AAST providers to ensure that there are regular opportunities for asylum seekers to have the processes they are involved in, and systems they will need to navigate if their claim is successful, explained to them.

9.4 The Refugee Integration Service18, run by the Scottish Refugee Council, offers refugees advice and assistance in relation to a number of these issues, and would be an excellent body for the UKVI to consult with in relation to improving its performance during the move-on period.

We hope this evidence will be of use to the project team as they begin to evaluate the provision of AAST. We are happy to be contacted for further information relating to our evidence if required.

18http://www.scottishrefugeecouncil.org.uk/how_we_can_help/i_have_refugee_status/leave_to_remain_in_ the_uk/refugee_integration_and_employment_s