Care Bill [Lords]

Written evidence submitted by the Social Landlords Crime and Nuisance Group (CB 27)

1 Introduction

1.1 We, the Social Landlords Crime and Nuisance Group (SLCNG) are a national membership body of around 300 registered providers of social housing.(housing providers). Formed in 1995, our members manage around 75% of the nation’s social housing (over 3 million homes).

1.2 Protecting people from harm is central to our purpose and within this our members take their Safeguarding obligations and responsibilities very seriously.

1.3 This submission makes the case for amending the Care Bill to require representation of housing providers on Safeguarding Adults Boards (SABs).

2 Why housing providers’ should be included on SABs

2.1 Earlier in the passage of the Care Bill a recommendation that housing providers should be included in the list of statutory members of SABs was not pursued. The Government stated in their response to the recommendations of the Joint Committee on the draft Care and Support Bill that ‘We have intentionally restricted core statutory membership to a few core public bodies, leaving local areas with maximum flexibility whilst securing the statutory position of adult safeguarding. We anticipate and expect membership to be far wider. We would be most concerned if SABs did not address the role, contribution and responsibilities of housing providers in adult safeguarding. We would also expect SABs to draw on the housing sector for in-put, collaboration and advice. Government will not dictate how this happens, as this will depend on local circumstances, which vary widely across the country. For example, in some areas the SAB may operate sub-groups, including one devoted to housing-related issues that reports back to the main Board’

2.2 Whilst recognising that there are many examples of effective practice, the reality is that issues around information sharing and partner agencies’ engagement stubbornly persist. The July 2013 report Multi-Agency Working and Information Sharing Project- Early Findings [1] identified multiple barriers to further progress.

2.3 That same report found that some areas cited a lack of engagement from their housing partners as a barrier to setting up their multi-agency working and information sharing approaches. Ironically, this is a point that is made in reverse by housing providers in several areas who report that they "struggle" for inclusion in local partnerships despite their proactive approaches to the relevant authorities.

2.4 The difficulties around housing providers’ inclusion/engagement are arguably experienced most acutely in relation to non-local authority housing providers (principally housing associations). In this context it is important to recognise that a majority of the nation’s social housing stock now managed by ‘private registered providers’ (housing associations) whose role and the huge contribution they make is too often misunderstood.

2.5 The difficulty of communicating with adult social care staff, for example, is articulated by one experienced professional as follows: "A particular bug bear is their not infrequent refusal to share information or to include housing staff in multi-agency strategy meetings, justified by the view that they are not deemed to be in ‘the circle of trust’."

2.6 It is evident from official reports and individuals’ experiences that there is a longstanding impasse which, while it persists, means that the real losers are the vulnerable service users.

2.7 Put simply, anticipation and expectation in relation to housing providers’ inclusion in SAB arrangements is insufficient to deliver the consistency of practice needed across all areas.

3 Benefits of housing providers’ inclusion

3.1 Housing providers’ representation on SABs would

· encourage greater leadership and involvement by housing staff in adult safeguarding

· improve the quality of Serious Case Reviews/Safeguarding Adults Reviews

· contribute to wider agendas including prevention and awareness raising, domestic abuse, crime, hate crime, self-neglect, hoarding, anti-social behaviour, poverty

· reach into local communities, address professional boundaries, reinforce that safeguarding is everyone’s business, contribute funding, involve housing in the development of policy

· improve joint working between housing and adult social care.

4 Disbenefits of continued non-inclusion of housing providers’

4.1 Too often, housing providers are seen as the "poor relation" when it comes to safeguarding issues. SLCNG members have experiences where a safeguarding meeting, for example, has been held about one of their tenants, but they have not been invited as they were not seen to be essential partners. Apart from the obvious health and safety risks this may pose to their staff, the safeguarding team were denied knowledge held by the housing provider.

4.2 Housing forms a central and crucial part of a person’s life and housing providers play an essential part in ensuring the wellbeing of tenants and their families. Similarly, housing forms an essential part of the support package for all vulnerable adults and helps to sustain them living in the community.

4.3 SLCNG members are increasingly housing more and more people who have a range of issues making them vulnerable to exploitation and/or abuse in some instances, such as having their tenancies ‘taken over’ by drug dealers.

4.4 There are many instances where housing providers have found it difficult to get other support services to engage until they are at the point of eviction or other legal action. Such situations are both wasteful of the resources of all organisations involved and a cause of avoidable anxiety to individuals involved.

4.5 A requirement to include housing providers in SABs would significantly reduce or remove the risk of such instances recurring in the future.

5 Logistical issues and overcoming them

5.1 Arguments put forward against housing providers’ representation on SABs frequently cite the view that there are just too many providers in an area (there could be dozens) to make inclusion manageable. .

5.2 This is not sufficient reason to abandon or forego the benefits of including housing providers. Many areas have resolved the same logistical issues in relation to housing providers’ involvement in Community Safety Partnerships, for example, via the operation of a collective or consortium approach. The same or similar approaches could be applied equally well to SABs

6 Conclusion

6.1 ‘The role of housing in preventing and addressing adult abuse is neglected in legislation, policy, practice and research’ (Joint Committee on the Draft Care and Support Bill, 2013, para.163, p.42).

6.2 The inclusion in the Care Bill of a Clause requiring housing providers’ representation on SABs would address not only the first of these neglected areas (legislation) but would also improve policy and practice.

January 2014

Prepared 29th January 2014