1. The points in the ‘how will we achieve this’ column of the ‘provision of services in safe accommodation’ theme are really good, but should be extended to all victims of domestic abuse, not just those in ‘relevant’ accommodation schemes, particularly those in council temporary accommodation.
2. There is very little mention of how the Strategy fits in with the council’s duties under the Housing Act 1996 as amended by the Domestic Abuse Act 2021. The provision of safe accommodation to those approaching the council for assistance must surely be one of the most, if not the most, important opportunity the council has to respond to Domestic Abuse and will give survivors of abuse a viable way out of their situation.
3. The way that location of accommodation is considered by the Housing Department when discharging housing duties should be reviewed. At the moment too much weight is given to the police’s assessment of risk without consideration of the risk of social isolation from moving away from employment and support networks, as well as the individual’s own wishes. The risk assessment framework should be set out to balance these different factors, and agencies should recognise that risk-averse approaches will often leave victims at greater risk if they turn down accommodation offers in different parts of the country.
4. At the moment the governance structure outlined on page 16 of the strategy involves many different organisations across diverse sectors, but it is not clear that there is one single point person who is responsible for the council’s work in this area. At the moment there are a large number of organisations in the statutory and voluntary sector that provide services in the community but do not have a uniform way of responding to domestic abuse and there is no clear pathway for survivors to access support, particularly for those who do not meet the threshold for MARAC. This means that the support provided will be haphazard depending on which organisation they first approach. A point person would help co-ordinate the support that is available and identify gaps in provision. We also believe there should be a named Councillor appointed to liaise with the council around the domestic abuse services in the borough
5. Para 21.12 of the Homelessness Code of Guidance states that ‘Housing authorities should have policies in place to identify and respond to domestic abuse’. Whilst victims of domestic abuse would be dealt with under the Multi-Agency Adult Safeguarding Policy and the Children’s Services Procedures Manual, there does not appear to be a specific policy / procedure which focuses on how different service areas should respond to domestic abuse. At the moment it is not clear what the Adult Safeguarding Team does if someone is being abused but does not meet the s.42 criteria or DASH referral criteria.
6. There should be a formal process in place that means that relevant information is shared between the housing department and safeguarding teams so that information about abuse is automatically picked up in the assessments undertaken by the housing department. Housing staff should contact the adult safeguarding team as standard when carrying out s.184 inquiries in case the individual is known to the safeguarding team. Equally the safeguarding team should contact the housing department when safeguarding alerts are raised as various duties under the Housing Act 1996 will often be triggered by the safeguarding alert itself.
7. The commitment to training on reframing negative language used by professionals which can place blame and responsibility on the non-abusive partner is very welcome.
8. There should be more detail on how survivor voices will be incorporated into commissioning processes and domestic abuse consultations. When and how often will this be done? How will the council ensure that feedback is obtained from socially excluded groups? Who will be responsible for this? What formats will be used? What happens if the feedback is not positive? – the draft strategy states that success will be achieved when positive feedback is obtained in relation to services, but constructive negative feedback would be a sign that the feedback process has been successful and will enable services to improve.
9. It is not clear in the draft strategy who will be responsible for identifying needs for future provision and how this will be tracked. Many of the points in the ‘what will success look like’ could be more specific, measurable and time-bound – how will progress be reviewed to ensure improvements are made as quickly as possible?
10. Information sharing agreements and procedures should be reviewed to ensure they comply with the Data Protection Act, particularly the data minimisation principle. This ensures that data is shared only amongst directly relevant organisations. Victims should have control over how their data is used and therefore need to be able to access privacy notices when disclosing such sensitive information so they understand the scope of the sharing and their rights, including the right of access and the right to object. Many survivors report distress arising from their lack of control over many aspects of their situations. Ensuring that data protection law is followed will help people have more control over their lives and will hopefully lead to an improvement in their wellbeing. A Data Protection Impact Assessment should be carried out by the MARAC if one has not been done already.
11. Before covid-19 the Housing Options service often required people to use the phones in the customer service centre which meant it was impossible to provide the required information securely. Services should operate so that personal data is kept secure by default and design, as required by the Data Protection Act 2018.