On 19^th October 2022 David Neal, the Independent Chief Inspector of Borders and Immigration (ICIBI) published the report of his office’s inspection of the use of hotels for housing unaccompanied children. The report highlights concerns set out by the ECPAT UK report Outside the Frame that the Home Office has no authority to accommodate unaccompanied children in this way outside of the UK’s child welfare legislation. The ICIBI makes a strong recommendation to the Home Office to develop a clear exit strategy within six months acknowledging the rights of children, in particular their best interests. The report resonates with our strong recommendation to the Home Office to cease the unlawful accommodation of unaccompanied children and to fulfil its statutory duties under Section 55 of the Borders, Citizenship and Immigration Act 2009.

What was meant to be an emergency solution has now been kept in place for over 14 months with no end in sight. The ICIBI report’s findings are that Home Office staff have no authority to accommodate children but that the Home Office is now effectively operating unregistered children’s homes. The most shocking assertion made by the ICIBC is that they found limited evidence of progress on a concrete exit strategy from the use of these hotels.

The report also finds significant failings in the safeguarding arrangements in these hotels:

• social workers were only available during office hours with opportunities to assess young people at risk of trafficking being missed
• referral processes were marked by a lack of clarity over who was responsible for making the referral, and therefore National Referral Mechanism (NRM) in particular, fell through the gaps
• 2 hotels had staff living onsite, with access to the master keys, who had not been Disclosure and Barring Service (DBS) cleared
• team leaders who are responsible for the daily operation of these hotels have little too no previous experience of working with children, many coming from law enforcement backgrounds

As highlighted in our earlier response to the Home Office’s use of hotels in partnership with Children England and signed by over 70 organisations we continue to strongly recommend:

• The UK Government must prioritise cross-departmental collaboration particularly between the Home Office, the Department for Education and the Department for Levelling up, Housing & Communities to ensure the lawful care and protection of unaccompanied children.
• The Home Secretary must immediately cease to unlawfully accommodate unaccompanied children and fulfil the statutory duties under Section 55 of the Borders, Citizenship and Immigration Act 2009.
• The Secretary of State for Levelling Up, Housing & Communities must ensure local authority children’s services have sufficient resource and capacity to fulfil their legal obligations to care for children in need in their area.
• The Secretary of State for Education must ensure that all cases of unaccompanied children going missing are considered at high risk of exploitation and that serious incident notifications are made to the Child Safeguarding Practice Review Panel.