On Thursday 10 January 2019, David Bolt, the Independent Chief Inspector published a report on the Home Office’s safeguarding of vulnerable adults. Describing the purpose of the report Bolt said that how well the Home Office’s Borders, Immigration and Citizenship System (BICS) recognises and responds to the needs of vulnerable individuals “is a test not just of its competence but also of its capacity for compassion, both of which have been questioned in recent months.” You can read this report here. The Home Office has accepted all four recommendations. You can read about the department’s response here.  

Scope of report

The inspection focused on the work of frontline staff in Border Force and Immigration Enforcement, and specifically:

 –          how they identify vulnerable adults during encounters with non-detained migrants

–          how they are trained, supported and managed to understand and carry out their safeguarding responsibilities towards vulnerable adults

–          how they record information about vulnerable adults on Home Office systems

–          how and when they pass on vulnerable adults internally to another Home Office unit or to another relevant agency.

Note that asylum accommodation was excluded from the scope of this inspection on the basis that it was covered in the previous report (you can read here)

Report highlights

The report pays particular attention to the challenge of defining vulnerability. Although most definitions agree that vulnerable individuals require appropriate care and protection, the policies, guidance and practice related to vulnerable adults have developed within individual BICS directorates without an overarching strategy. The report notes this is in contrast to children, where the Home Office has a ‘well-developed understanding’ of vulnerability and child safeguarding practices which are fully embedded across BICS. The Home Office response states it is working to develop a consistent definition of vulnerability, including via consulting with key stakeholders including the Refugee Council.

The report also discusses the challenge of identifying vulnerable adults. Although there are certain defined cohorts, such as Potential Victims of Modern Slavery (PVoMS), these are still challenging to identify. BICS staff typically have ‘one-off’ or paper-based encounters which, in addition to lack of relevant skills and experience and the challenge in defining vulnerability, can limit their ability to identify vulnerable individuals. Nonetheless, the report regularly points out the professionalism of the BICS frontline staff it observed.

The report also discusses the Asylum Safeguarding Hub which was created in September 2016 for pre-decision asylum support. A senior manager of the Hub noted that the biggest challenge with the Hub was ‘changing the “mindset” of asylum casework teams to think first about “high risk” and not the “182-day decision target”.’ The report includes a note about the lack of coordination between the Hub and the Refused Case Management team, not least because there were only 5 staff working on safeguarding in the RCM.

Training and guidance has been developed within each directorate: Border Force has implemented its ‘Safeguarding and Modern Slavery’ officers (SAMs) for immediate, on-hand support to frontline officers; UKVI is using the Safeguarding Hub; and IE is ‘somewhere in between with its local safeguarding co-ordinators for each business area.’ Much of the training is delivered via e-learning and it was recommended that there should be more classroom-based learning ‘from the experts.’

The report notes critics’ concerns about hostile environment policies and how they can increase vulnerability in some circumstances. The Home Office’s response to this is that it needs to ‘strike the right balance between protecting the vulnerable and ensuring the maintenance of legitimate immigration control.’ During the inspection, some Home Office staff expressed concern about ‘the risk that individuals might look to “play the system” by claiming vulnerability’.

Lack of reliable and consistent record keeping was also raised, as noted in part 1, d, iii of the report’s recommendations where it recommends a complete overhaul of the ‘Special Conditions’ flags, which denote categories of vulnerability. The Home Office’s response is that their new Atlas caseworking system will improve this area, although they recognise the need to supplement this with improvements in training, guidance, and process.

Responding to the report, Andy Hewett, Head of Advocacy at the Refugee Council, said:

“We very much welcome the Chief Inspector looking into this important issue. We are encouraged the Home Office has accepted all of the recommendations and is taking responsibility for improving their work in this area. The introduction of the safeguarding hub is a significant step in the right direction. We also look forward to continued engagement with officials to further the Home Office’s understanding of ‘vulnerabilities’ and to ensure the Home Office responds appropriately to the needs of vulnerable adults. “