Policy paper

Response to a report on the use of hotels for housing unaccompanied asylum seeking children

Published 29 February 2024

September – October 2023

The Home Office thanks the Independent Chief Inspector of Borders and Immigration (ICIBI) for this medium inspection report of the use of hotels for housing unaccompanied asylum-seeking children re-inspection.

In its formal response to the recommendations, the Home Office has given full consideration that all UASC hotels have now been closed.  The Home Office will however apply any findings from the ICIBI Report more broadly, if standing up hotels, when required on a short-term emergency basis in future and where applicable.

The ICIBI identified several areas for improvement and has made 5 recommendations. Work was already in place to deliver some of the recommendations. The Home Office has accepted 4 recommendations and partially accepted 1 recommendation.

Recommendation 1

Strengthen assurance and monitoring mechanisms to ensure it is satisfied that contractors are meeting safeguarding and other requirements, including, but not limited to:

  • Disclosure and Barring Services (DBS) clearances of all staff working in hotels
  • training of all staff working in hotels
  • raising a concern (including whistleblowing) in hotels
  • health and safety hazards and fire safety works in hotels

Partially accepted

DBS clearances: The Home Office requires that a record of the Disclosure and Barring Service (DBS) checks for all staff on site are provided for inspection. Monthly spot checks on these records are conducted at short notice and as part of the operational assurance visits. The record of checks includes DBS reference number, date of issue, whether member of staff is registered with the update service, date checked and their role.

A standard operating process (SOP) has been put in place to support this process outlining actions to take in the event a member of staff is unable to provide a valid DBS check. Should a staff member on site fail to provide a DBS record the individual will be asked to leave the hotel and excluded until they are able to provide evidence of a valid DBS check.

Whilst DBS checks officially do not have an expiry date, to strengthen the assurance processes and ensure a robust process is in place, the Home Office instructs that DBS renewals are required annually.

Training: Appropriate bespoke safeguarding refresher training, developed by the Safeguarding Advice and Childrens Champion (SAAC) and delivered by the social work team manager and senior practitioners has been rolled out to ensure the best learning environment for each individual member of the team. An assurance process is in place to ensure adherence.

Whistleblowing: A standard operating process (SOP) for staff on the whistleblowing procedure, is in place. This SOP outlines the process to follow and encourages staff to raise any concerns they have with the Home Office via various channels.

Health and safety: Fortnightly health and safety (including fire hazard) checks were conducted by hotel team leaders accompanied by Home Office staff and hotel management team member. The findings from these checks were documented and reviewed by the Home Office UASC operational team and raised with the CTM who conduct further inspections to appropriately address concerns.  These additional inspections were conducted by the health and safety compliance lead for CTM.

Recommendation 2

Review the role of team leaders and introduce professional supervision and support to ensure they are able to meet the challenges of managing operations to safeguard the safety and welfare of the children accommodated.

Accepted

A review of the business model for team leaders took place Spring of 2023 as a result the role of the Home Office liaison officer has been created to bridge the gap.

We also conduct 1:1 supervision of day shift Team Leaders every 8 weeks, this includes mandatory safeguarding refresher training, SOP refresh and trauma-informed practice.

We have introduced weekly reflective supervision at the remaining hotel in operation under team leaders and social worker team manager and/or senior practitioner presence. This time is used to discuss cases, situations and safeguarding which supports each team leader to think about each child individually and focus on all signs of potential trauma.

Recommendation 3

Work with partners to provide advocacy support for children, to act on their behalf, for example in terms of challenging their length of stay in the hotel, or ensuring the needs of the child are met.

Accepted

The Home Office does not have statutory obligation to accommodate UASC.  Nevertheless, the Home Office takes the safety of those in its care, seriously and therefore continue to work closely with Kent County Council and local authorities across the UK to urgently address the needs and concerns for UASC.

Recommendation 4

Work with partners to provide written information for children, as necessary in their own first language, including:

a) what will happen to them next, in terms of their transfer and

b) placement, to better prepare them for this move

c) how to raise a concern or provide feedback

d) how to make a formal complaint

e) safety plans and other measures put in place to support them

Accepted

As per the High Court ruling, since 31 January 2024 the Home Office no longer provides temporary accommodation to UASC. However, it will continue to work on including a step-by-step process guide on National Transfer Scheme, so children understand the process fully. 

Whether a child has the ability to read or not, all assessments, safety plans and complaints process will be carried out with the assistance of an interpreting service, either face to face or via the phone. All documents, briefings and updates will be explained by the relevant staff (either nursing team, team leader, social work team) so that the child understands the purpose of the assessment and next steps.

If a child is unable to read, this information will be documented and provided as part of the handover as the child moves through the system.

Recommendation 5

Set out a clear strategy for exiting hotels used for UAS children in partnership with Kent County Council, taking account of the High Court’s directions.

Accepted

Although the Home Office did not have an official documented exit strategy at the time of the inspection, various approaches to hotel closure have been tested since December 2022.  As a result, all hotels ring-fenced to accommodate UASC have now been closed.

Ending the complete use of hotels for UASC is an absolute priority and the Home Office continue to work with Kent County Council and local authorities across the UK to increase the number of care placements available.