An inspection report examining the use of hotels for housing unaccompanied asylum-seeking children has been published this week, but the findings make for unsettling reading.

The report criticises the operation of what are effectively unregistered children’s homes and confirms that this is not an area in which the Home Office should be operating. It goes on to describe an operation “notable for its piecemeal and inconsistent development”, which fails to effectively identify and meet the needs of the children being housed. Publishing the report, David Neal, the Independent Chief Inspector of Borders and Immigration said:

“It is clear that the housing of these extremely vulnerable children in hotels represents a significant challenge to the Home Office, in both ethical and operational terms.”

The housing of unaccompanied asylum-seeking children in temporary hotel accommodation began in July 2021. Concerns about the suitability of the Kent Intake Unit have been ongoing since 2016. Last year Kent County Council warned that its services were at breaking point, and they could not accept any more unaccompanied child migrants into their care. It was not until the Council decided to no longer accept statutory responsibility for asylum-seeking children arriving in the county that the Home Office decided to place those children in hotels instead, pending permanent local authority placements via the National Transfer Scheme.

Housing children in hotels was originally an interim solution. Indeed, this is not an area in which the Home Office should be operating, although they do still have a duty under Section 55 of the Borders, Citizenship and Immigration Act 2009 to safeguard and promote the welfare of children who are in the United Kingdom. The reality is that the Home Office has now been utilising hotels for unaccompanied asylum-seeking children for over a year, with limited evidence of progress towards a concrete alternate strategy.

Since July 2021, the Home Office has used six hotels to accommodate children. The report noted the speed at which the operation was rolled out, with local authorities given as little as 24 hours notice of a hotel opening; a similar approach to that taken by the Home Office when opening Penally Camp and Napier Barracks. In the report on Penally Camp and Napier Barracks, published last year, it was noted that “the need to move at speed is not a satisfactory excuse” for unacceptable conditions. The same is true here.

The majority of young people housed in hotels between July 2021 and February 2022 were aged 15 and over, comprising 1,146 (89.5%) of all children. Although, there was one child as young as 10, and one baby who arrived with their mother, who was herself under the age of 18. These numbers have increased significantly over the summer, with provisional reports suggesting that 3,256 children have now been housed in hotels since last October.

Unfortunately, no agency or government department holds a statutory responsibility for the children housed in these hotels. The Home Office has not assumed statutory responsibility and is not operating as a corporate parent. The local authorities where the hotels are located do not hold statutory responsibility for these children as they are not considered “looked after”. A child is looked after by a local authority if their care is being provided with accommodation for more than 24 hours, under section 20 of the Children Act 1989. Without a looked after status, children will not be fully assessed or provided with a dedicated social worker and key worker. Children in hotels are consequently denied the same legal entitlements and protections as those provided to a looked after child, and are thus prevented from accessing the relevant safeguards this status affords under the Children Act 1989. However, the Home Office have acknowledged Section 55 of the 2009 Act, and the United Nations Convention on the Rights of the Child policy of “best interests” of the child, which should be considered when making decisions about standards, service design and operational delivery of its policy.

The evolving nature of the operation has also meant the services, structures and approaches have developed in a reactive, as required, manner. This has lead to concerning gaps in the extent to which the operation safeguards young people and actively promotes their wellbeing. The report notes that the operation was struggling to meet the change in state from emergency set-up to “business as usual”. One Home Office staff member commented: “as nothing has gone wrong there is complacency. But, if something does go wrong, we donʼt have a leg to stand on”.

Specific failings described in the report include onsite nurses who are unable to prescribe medication and who do not have access to emergency first-aid bags. In all but one of the hotels inspected, the kitchens were permanently closed, with food provided from another location and each meal served in a takeaway container. Staff confirmed that their contract prevented them from serving meals on plates.

Children placed in hotels are not enrolled in school nor provided with any kind of formal or informal education whilst housed in hotels, a failure that means their basic educational needs are left unmet. Access to legal advice is not provided within hotels. And mental health support is also not available onsite.

Finally, staff living onsite at two of the hotels had not been cleared by Disclosure and Barring Service (DBS) through criminal record checks. The report found that there was no consistent requirement for hotel staff to have a criminal records check completed, and the absence of such checks had only come to light when highlighted by inspectors. In the Folkestone hotel, three resident hotel staff members lived permanently in the basement. They had access to the master keys, but they had not undergone checks. Four resident hotel staff members had also not undergone checks in the Hythe hotel.

The report made four time-bound recommendations. In its response to the report, the Home Office accepted one of these: a recommendation that only those with an enhanced DBS check should be allowed to reside or work at the hotels. The Home Office committed, with immediate effect, to preventing individuals without a clear enhanced disclosure and barring service check from residing and working at hotels currently being used to house young people, and for any hotels used by the Home Office in the future.

The Home Office only partially accepted the other three recommendations. In response, the Independent Chief Inspector stated that: “…it is disappointing to note that the time-bound nature of the recommendations appears to be a barrier to full acceptance, that overall the pace of implementation appears slow and that processes necessary to ensure the safeguarding of children remain “in development”. This approach continues to ignore the vulnerability of these children.”

The Home Office has stated that they will assess the collective needs of individuals housed in hotels within one month. However, they will only use external expertise to conduct this assessment “if required”. Building on this assessment, they will develop a challenge and scrutiny mechanism to monitor the delivery of the housing operation within three months. The specific focus will be safeguarding children’s welfare.

The Home Office has only committed to developing and beginning to deliver a viable and sustainable exit strategy from the use of hotels within six months. A significant period of time for those vulnerable young people housed in such temporary accommodation, seemingly ignoring the extent of the vulnerability of these unaccompanied asylum-seeking children.