Refugee and Asylum Seeker Delivery Plan

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Refugee and Asylum Seeker Delivery Plan

CONSULTATION RESPONSE

Children in Wales is the national umbrella organisation in Wales for children and young people’s issues, bringing organisations and individuals from all disciplines and sectors together. One of its core aims is to make the United Nations Convention on the Rights of the Child a reality in Wales. Children in Wales campaigns for sustainable quality services for all children and young people, with special attention for children in need and works to ensure children and young people have a voice in issues that affect them.

Children in Wales membership covers a vast array of organisation who work to improve the lives of children in Wales and includes voluntary/third sector organisations, professional associations, local authorities and health bodies, as well as many smaller community groups, schools and individual members. At the time of writing, there are over 260 members. Children in Wales facilitates over twenty forums and networks across Wales, and is represented on external committees, networks and management boards. Children in Wales works in partnership with the National Children’s Bureau in England, Children in Scotland and Children in Northern Ireland, and internationally is active in Eurochild and the International Forum for Child Welfare.

Children in Wales works closely with its member organisations and has established working relationships with the Welsh Government and other funders. A key role for our organisations is to maintain a constructive flow of information between those working to develop policy and legislation and those working directly with children and young people. Our conference and extensive training programme, together with the forums and networks that are supported or managed by Children in Wales, serve as a means for ensuring that our members and Welsh Government officials are kept informed of current and evolving developments in the field, and that these developments help shape policies and enhance practice.

Our Response

Children in Wales welcomes the opportunity to respond to this consultation and have structured our response in accordance with the questions Welsh Government are seeking responses to. Our response has been informed by our work in this policy area over a number of years, our engagement with members and organisations, including through our Children and Young People’s Advocacy Providers Group and our attendance at the recent consultation event held in Treforest by Welsh Government.

Children in Wales is an inaugural member of the newly established Welsh Refugee Coalition.

Q1 -Do you think the priorities included in the draft Refugee and Asylum Seeker Delivery Plan will improve life for asylum seekers and refugees in Wales? If you think any of the priorities should not be included please provide your reasons below

We welcome the revised Refugee and Asylum Seeker Delivery Plan and the opportunity to give consideration to the identified actions proposed, which we will provide comments on under our response to questions 3-7.

Since the revised plan was published for consultation, the biggest humanitarian refugee crisis to hit Europe has taken place and is projected to get worse.

The UK Syrian Vulnerable People’s Resettlement Scheme (SVPRS) has been put in place with a commitment to relocate 20,000 Syrian refugees by 2020, with 1,000 being relocated directly from Syrian to Wales. Whilst we welcome the leadership and support shown by Welsh Government and local authorities in Wales, these developments will have significant implications for our communities and services, including health, education, housing, social services as well as overarching policy frameworks such as community cohesion.

The timing of this consultation is unfortunate given its publication on the same day as the First Minister’s Summit. We do not see how a revised Refugee and Asylum Seeker Delivery Plan can be issued without reference to the above and the actions which Welsh Government and partners will be delivering as a consequence of these unprecedented developments.

The revised Refugee and Asylum Seeker Delivery Plan must respond to the needs of all asylum seekers and refugees regardless of their country of origin or the circumstances which have brought them to Wales

In direct response to the question, we would very much hope that the delivery plan, if effectively implemented and supported by adequate resources with sufficient capacity within existing services at an operational level does improve the lives of asylum seekers and refugees. However, we are yet to be reassured that there is indeed sufficient capacity and resources in place at a national level to ensure that the Plan is delivered equitably and consistently across Wales to a standard that we would all expect and which is required. Whilst there are some excellent services being delivered locally by dedicated and specialist individuals and agencies, the picture across Wales is patchy with there being a danger that vulnerable groups will continue to fall through gapsin service provision. Changes instigated by the Home Office have not helped, with Wales losing many vital face to face services.

We would suggest that aOutcome Measurement Frameworkis produced alongside the anticipated Performance Indicators to help provide the necessary evidence base for Welsh Governmnet to be able to determine if lives have been improved and the impact this Plan has had in achieving this

It is also worth being mindful that asylum seekers and refugees are not one community group. All will have different experiences, backgrounds, language skills, barriers and needs. Any outcome measurement framework will need to take account of this.

Q2 -Do you think there should be any other priorities addressed in the Refugee and Asylum Seeker Delivery Plan? If so, what should they be? Priorities can only be considered if they are devolved to the Welsh Government – see

In addition to the points made above, we would welcome some reference to existing resources and programmes in place and/or delivered under the current or previous Plan so as to ensure that vital knowledge and information does not ‘get lost’, forgotten or reproduced, thus wasting vital time and resources.

We are suggesting this as an interim solution in the absence of a commitment to refresh the current Refugee Inclusion Strategy which is woefully out of date.

Our preferred option is for there to be a commitment to produce a new strategy with a complimentary action and delivery plan which is forward looking setting out a programme of action for the next 5 years.

As an interim arrangement, we would suggest that this revised Plan is supported by an introduction section which captures all that has been achieved since 2008 and which is still significant and relevant. This could include resources such as the All Wales Child Protection Procedures Protocol on unaccompanied asylum seeking children and other key resources such as the Big Lottery Funded Including Families Project website which will help remind professionals what is already in the public domain.

Q3 - Do you think the actions to deliver the priorities on ’Section 1 Health and Social Services’ are the most appropriate actions for refugees and asylum seekers? What other actions do you think will help tackle the priorities in this section?

Mental health

Priority 1 – This we welcome. We would hope that this guidance is all inclusive in terms of identifying support both in universal services at Tier zero level which refugees and asylum seekers have a right to access, to more specialist mental health provision. Clear links must be made to the Mental Health Measure and Together for Mental Health.

Priority 2 – Not sufficiently clear what the output from action will be and which organisations will be engaged – Third sector, Local authorities? What are the links between this and the Hate Crime agenda and programme of work. Is there an opportunity to dovetail this work with other work already being undertaken under the equality portfolio?

Priority 3 – there will be resource implications

Physical Health

Priority 1 - there will be resource implications dependent on the interpretation of ‘adequate resources’.

Priority 2 – Information and advice on accessing general medical services and their availability in dispersal areas is welcome but unclear at this stage what the specific actions are

Priority 3 – the term ‘failed’ should be changed to ‘refused’.

UASC

Priority 1 – we look forward to the publication of legal and policy briefing on LAC and care leavers

We are disappointed with the third action that ‘Welsh Government will explore the need for a Guardianship model for Wales’. We are unclear what action, if at all, will be delivered and why there is still perceived to be a need to explore whether this is a resource which is needed. It is now over 10 years since Save the Children with Cardiff University published their ground breaking report ‘Uncertain Futures’ which advised Welsh Government to consider how best it can provide accessible, specialist and well-funded independent advocacy support for UASC in Wales. The 2008 Concluding Observations from the United Nations Committee on the Rights of the Child also called for Governments to appoint guardians for UASC, raising their concerns over the lack of support for, and increased vulnerability of this group of children and young people.

The Refugee Inclusion Strategy and action plan made a commitment to put in place sustainable advocacy provision to support UASC 0-25 which we were advised through the annual updatein June 2014 that this was ‘on schedule’. We have also witnessed the loss of the only specialist post in Wales delivered previously by the Welsh Refugee Council.

As 2015 comes to a close, Wales is still waiting.

We have also had successive reports on the work of the Scottish Guardianship service which has demonstrated the value this services brings to vulnerable children and young people. We have also had a number of key report on advocacy in Wales, yet the specific needs and specialist support for UASC in Wales has remained peripheral.

We urgently call on the Welsh Government to commit to deliver the action set out in the current action plan to enable UASC to access face to face advocacy, support and advice wherever they are and whenever they need this. Given the extreme vulnerability of this group of children and the risks they face, we believe that the time for exploring has long since passed and that a national specialist advocacy asylum support service for children in Wales should be developed and commissioned with adequate and sustainable resources attached. Consideration will also need to be given to ensuring that transition arrangements are in place once a UASC reaches adult status.

Maternity and Children

We are concerned that some families may miss an initial health assessment and that robust processes should be in place in every local authority area to ensure this is followed up, given the potential safeguarding concerns. We welcome the proposed work with PHW to revise existing guidance but remain concerned that the availability of services to implement the guidance will be inconsistent across Wales and subject to local determinism by local health boards.

Q4 - Do you think the actions to deliver the priorities in ’Section 2 Education’ are the most appropriate actions for refugees and asylum seekers? What other actions do you think will help tackle the priorities in this section?

Further Education – in addition, we would expect further education colleges, particularly in dispersal areas, to provide face to face support to accompany information and advice, with named specialists adequately trained.

ESOL – we are concerned over the funding and capacity levels for ESOL provision and that existing provision is proving insufficient to meet current and future demand. Given the importance of ESOL to enable asylum seekers and refugees to access FE, employment or training, this should be a priority area for Welsh Government.

Education – more training will be required for teachers to enable every school to have a specialist support who is able to respond in a timely manner to any specific barriers facing refugee and asylum seeking children in their schools.

With the relocation of children from Syria in non-dispersal areas, the biggest challenge will be to integrate children into local schools with full language and curriculum support which will become more significant over time.

It is unclear what action will be taken by Welsh Government to ‘work with key stakeholders to build on Keeping Learners Safe’ noting that this guidance makes limited reference to asylum seeking children, only signposting the reader to other resources. Training for school leads and governors should be made routinely available. Interaction with children through a whole school approach to tackling hate crime should be in place in every school.

We look forward to learning what specific actions the All Wales Anti-Bullying Leadership Group will be undertaking with regard to tackling bullying and hate crime in schools against asylum seeking and refugee children

Q5 -Do you think the actions to deliver the priorities in ‘Section 3 Housing and Advice Services’ are the most appropriate actions for refugees and asylum seekers? What other actions do you think will help tackle the priorities in this section?

Priority 1 - the term ‘failed’ should be changed to ‘refused’.

We would welcome reference to the Welsh Government funded Meic 24hr advice, information and support helpline within this section to promote its availability amongst asylum seeking and refugee children

Q6 - Do you think the actions to deliver the priorities in ‘Section 4 Gender based violence, hate crime, modern slavery and community cohesion’ are the most appropriate actions for refugees and asylum seekers? What other actions do you think will help tackle the priorities in this section?

We would welcome a specific section on ‘Safeguarding’ within this section. This could include reference to actions and existing resources to tackle FGM, Trafficking and Child Sexual Exploitation, including the new resource for schools - Hidden – hosted on the Welsh Government digital learning website

We would also welcome reference to actions underpinned by the Violence against Women, Domestic Abuse and Sexual Violence (Wales) Act 2015 including the Live Fear Free Helpline to provide help, advice and emergency support. Reference and a link should be made to the Live Fear Free Campaign on a domestic abuse leaflet aimed at 16-24 year olds which Children in Wales, through our Young Wales project helped inform and develop with Welsh Government.

We would suggest that Priority 2 under the Community Cohesion heading is identified as a separate heading of ‘Tackling Poverty’. It is however unclear in this section what specific actions will be in place to tackle poverty amongst refugees and asylum seekers, as the narrative in their section is fairly general. What specific work is being undertaken under the Communities First Programme for example? The Wales Refugee Coalition is calling for a new ‘Destitution Fund’ to be set up to ensure that no person is left destitute, regardless of their nationality of migration status.

We would suggest that Welsh Governmnet examine the data returned by the Communities First, Families First and Flying Start programmes in Wales to ascertain how much intervention and support is provided to refugee and asylum seeking families. This would help open up the debate in terms of sharing experiences and good practice amongst the partnerships and agencies delivering these programmes. Additional Performance Indicators could be developed to help capture this knowledge.

There are duties placed on a range of Welsh Authorities to tackle child poverty under the Children and Families Measure and which will also be a requirement under the Well Being of Future Generations Act. Whist we note that the National Museum for Wales is references in Section 5, it would be of interest to reinforce the duty placed on the other Welsh Bodies to put in place actions to tackle child poverty, which would include many asylum seeking and refugee families in Wales

Q7 - Do you think the actions to deliver the priorities in ‘Section 5 Arts’ are the most appropriate actions for refugees and asylum seekers? What other actions do you think will help tackle the priorities in this section?

Whist we welcome the actions and partnership work being undertaken in this Section, we would welcome consideration being given to identifying and listing the actions being undertaken by local authorities through their art, sport and leisure programmes across Wales. So for example, what are local authority leisure centres doing to promote access?

Q8 -Do you think the actions to deliver the priorities in ‘Section 6 Employment’ are the most appropriate actions for refugees and asylum seekers? What other actions do you think will help tackle the priorities in this section?