This guidance has been drafted to support organisations and teams working in temporary accommodation. The Welsh Government greatly appreciate the hard and at times stressful work that has been undertaken by Local Authority Homelessness teams and Support Providers to rapidly meet the needs of rough sleepers.
We recognise the vast amount of existing experience and expertise many of the teams providing support already possess, some of which may extend beyond the reach or inclusion of this document. We encourage these experienced teams to continue to use their professional judgment and existing approaches where possible to address challenging behaviour. Others may be new to working in these settings and we hope that this provides helpful insights.
Whilst you are able to meet the needs of many people who have been rough sleeping there is a very small cohort of people who, due to their behaviours, are not safe to remain in temporary accommodation. For this very small minority there is no safe housing solution without active input from wider public service partners. To meet the needs of this small number of people they require coordinated interventions with a number of agencies including, HM Prison and Probation Service, the Police, substance misuse and mental health agencies. All of these agencies should be partnering with local authorities via the Homelessness Centralised Coordination Cells.
The lockdown brought about by the COVID-19 pandemic has resulted in the emergency housing of considerable numbers of people, many of whom have experiences of complex trauma, mental health problems and/or substance misuse issues.
Experiences of complex and repeated trauma, such as Adverse Childhood Experiences, can result in people:
- seeming to have difficulty managing their emotions
- reluctance to trust
- self-harming or having an uncontrolled drug and/or alcohol problem
- appearing impulsive and not considering the consequences of their actions
- appearing withdrawn and reluctant to engage with help which is offered
- exhibiting anti-social or aggressive behaviour
Psychologically informed approaches are intended to help staff and services understand where these behaviours are coming from, and to be able to work more creatively and constructively with people.
For a number of those individuals, adjusting to their new circumstances may be difficult. Many will require intensive tenancy, mental health or substance misuse support. It is vital that support services are in place to address these needs alongside the provision of accommodation. Being inactive and uncertainty about the duration of the lockdown and what the future holds in the long-term, may lead to increased frustration. In a few cases, this may be displayed as anti-social and challenging behaviour which poses a risk to individuals and others. In rare cases, this behaviour may be severe and require a more interventionist approach and/or engagement with enforcement agencies in order to safeguard staff and other residents.
For the staff supporting individuals in these settings, instances of challenging behaviour can be difficult to manage, particularly for those that have less experience supporting a client group with high and complex needs. Ensuring the safety and well-being of staff and people using services is paramount.
This guidance and the separate flow charts are for local authorities and housing providers delivering supported and temporary accommodation. In particular for people who have been housed through the programme of emergency housing. It sets out the practical measures for staff to safely deal with situations where an individual who has been accommodated displays challenging or anti-social behaviour (ASB) that presents a risk to themselves, other residents and to members of staff.
Managing these challenges and encouraging people to positively change their behaviour will be essential to the success of the emergency accommodation programme and will ensure individuals are able to transition from temporary to more sustainable forms of housing.
There are a number of principles on which the guidance is based:
- all services should take a psychologically informed approach, with additional training needs identified and addressed as required
- the safety of staff and people using services is paramount
- all accommodation should have an appropriate level of staffing (in both capacity and expertise) to meet the needs of the people being accommodated
- prevention is always the best approach
- wherever possible de-escalate
- local authorities, support agencies and local police and community safety partners should jointly plan and coordinate service responses based on individual need
Inter-Agency Working and Co-ordination
Co-ordination through the homeless centralised co-ordination cell is essential to planning inter-agency working with people staying in emergency accommodation – working with Area Planning Boards and mental health services.
Many services and commissioners are planning and adapting services to meet the current emergency. The Welsh Government has issued guidance to assist substance misuse and homelessness services, and those working with vulnerable populations. This is relevant to those with drug and/or alcohol use disorders, co-occurring mental health issues and complex needs.
People using services will frequently have a range of support needs and will often be known to a number of agencies. Systematic and mutually agreed lines of communication between mental health, substance misuse, offender management, community safety and housing support agencies is essential to ensure clients’ needs are identified and met.
Partner agencies will have support workers who are, or have been, working with people who are being accommodated. Some will have support plans which address issues and challenges arising within the temporary accommodation. Likewise, Neighbourhood Policing Teams are likely to know some of these people and will have agreed inter-agency approaches to support provision.
Local authorities should work closely with Neighbourhood Policing Teams, through the Homelessness Co-ordination Cell, to ensure that forces have a clear understanding of the issues on ground and are able to provide a consistent and timely response. Good planning and clearly understood referral and communication arrangements will provide additional reassurance for staff. Police teams may be able to take practical steps, by dropping into accommodation settings on informal visits, providing increased patrols in ‘hot spots’ and including warning indicators on high risk addresses where there are repeat disturbances.
Coordination cells set up weekly teleconference meetings with service providers and statutory partners to monitor service provision. Organisations involved could include:
Public Health Wales, DWP, Police and Community Safety representatives, local health board, accommodation & support service providers (including substance misuse and mental health service providers).
In some local authority areas senior Police officers have provided direct support to co-ordination cells, strengthening effective collaboration between organisations and integration of services, where needed.
One local authority has developed good partnership working between its housing department, the Area Planning Board, an Addictions Unit and Rapid Prescribing Service. There are regular nurse-led clinics at hotels being used for emergency accommodation and a number of people are receiving assessments and treatment for their addiction.
Well-being and support for staff and other people on site
Ensuring staff well-being and safety is of the utmost importance and crucial to successful service delivery. Whilst many staff supporting residents will have ample experience working with a high needs client group, other staff may have been redeployed from other service areas to provide additional resource to meet emergency need. It is important to recognise that other people who are victims or witnesses of incidents may experience trauma and require support.
Even experienced staff may find it difficult to respond to challenging behaviour in this new context. For example, staff who have experience in providing support within supported accommodation settings may be doing so on a much larger scale, where high numbers of people have been placed in block booked hotel accommodation. This can present a different set of challenges and may require staff to adapt existing procedures and approaches to suit the environments.
Local authorities and support providers must plan and coordinate approaches and ensure that there are measures in place to support staff and ensure each person is equipped to fulfil their role confidently and safely. Measures to support this could include:
- Ensuring, wherever possible, staff receive induction training and support in dealing with clients with complex needs. Particular consideration should be given to the provision of service specific inductions in addition to training, for staff who have been redeployed from other business areas and services. Consider using the ACE Aware Wales online training (see Appendix) which can be used by staff dealing with traumatised clients, enabling them to understand how trauma can present itself as a form of anti-social behaviour.
- Ensuring appropriate numbers of staff on site and that staffing rotas include experienced staff on site where possible.
- Emphasising the importance of supervision, reflective practice and peer support
- Providing staff with support services and contacts. For example, if a traumatic incident has taken place teams must be given the opportunity to debrief and talk about their experience following the incident.
- Sharing targeted communications emphasising the importance of staff welfare and the support available (for example – through national helplines such as C.A.L.L. which offers emotional support and information/literature on Mental Health and related matters to the people of Wales).
- Providing personal protective equipment (PPE) and adequate cleaning supplies as necessary. Public Health Wales has issued an advice note in relation to use of PPE in Housing, health, social care and support settings.
Other people living in the accommodation will, at times, face trauma as a result of threats or violent incidents. If an incident has taken place, as soon as practicable, teams must check other service users are both physically and psychologically supported. They will require reassurance and an opportunity to talk through the incident as well as an opportunity to identify any support they require. Services should ensure that they have the contact details for national services such as the C.A.L.L. helpline and local mental health services.
Premises suitability and management
Accommodation of varying types has been sourced in order to provide emergency accommodation at this time. Local authorities should have regard to suitability and risk assessments when placing individuals into emergency accommodation.
It is also important to establish and maintain clear lines of communication with accommodation proprietors so that they are reassured about their ability to keep you informed about any issues with residents.
The nature of accommodation available will also vary across local authority areas. As a result, there will not be a ‘one size fits all’ approach to premises management. However, it will be important to consider how premises management strategies can be adopted to suit accommodation types in an effort to prevent instances of ASB and challenging behaviour developing. The following should be considered:
- The number of clients accommodated on the premises
- Location (e.g. access to outreach and support services including whether floating or onsite support is necessary)
- Client needs: these will be varied with some groups requiring specialist support with healthcare and vulnerability. Proximity to specialist support services such as mental health, addiction (including pharmacies for prescriptions) and VAWDASV services should be considered.
- Level of comfort and access to essential facilities
- Clearly communicate to residents the expectations and responsibilities around behaviour and interaction with other residents and staff
- Security requirements: Homeless people with complex needs are a prime ‘client group’ for organised crime gangs and drug dealers, so ensuring they are as ‘shielded’ as possible from such people will be important. Reports suggest organised criminal gangs have adapted to lockdown and are using ‘key worker’ uniforms and ID (posing as care workers, community volunteers, supermarket staff, delivery drivers, etc.) to avoid being stopped by the police. Groups at particular risk of exploitation include people with learning disabilities, mental health problems or addiction issues and women involved in sex work.
- Access to Wi-Fi, reading materials and appropriate activities to prevent boredom.
Whilst having a high concentration of clients in block booked hotel accommodation can help with focussing support (particularly staff with experience of supporting people who present challenging or difficult behaviours) and provision of essentials such as food and medication, having a high concentration of clients in one place may require additional security and staffing resource.
It may also be helpful to consider how to use different floors to separate certain groups e.g. those who display challenging behaviour when placed together. Public Health Wales advice should also be followed in relation to cohorting and separating those who are displaying symptoms and are self-isolating.
Where possible a dispersed approach to emergency accommodation may help to separate out groups displaying challenging behaviour and keep the overall number of clients in each premises low. However, it may make support service provision more challenging and require increased use of floating support and/or remote support.
It will be particularly important to consider client needs and risk to assess suitability where individuals are placed into dispersed accommodation such as Airbnb properties.
The emergency housing programme may lead to concern from members of the community where people are being housed. Local authorities and providers should take appropriate steps to communicate that safeguarding measures have been taken to support the staff and residents within their supported accommodation settings as well as for the wider community. This could include providing relevant emergency contact numbers and the publication of policies that are being followed, to be made available online or through published written materials.
Support services and de-escalation
The Welsh Government strongly endorses a psychologically informed approach to supporting people who are homeless or at risk of homelessness. More information on this approach to understanding a person’s needs can be found in the resources section at the end of this guidance
Many of these individuals have experience of trauma, mental health problems or substance misuse issues which are likely to be exacerbated by the additional anxiety, isolation and pressure of the lockdown. Whilst provision will look different in different areas, it is critical that support provision is in place to ensure individuals get access to essential supplies, medication and any additional clinical provision such as mental health and substance misuse services. Individual needs should be assessed and documented. Staff should have in place an assessment process for service users to establish their level of need for support.
Where a resident has a mental health or substance misuse support need, it is important to have an understanding of their needs and any support or prescriptions they require. Where a resident is alcohol dependent, it is essential to understand the severity of the addiction, as acute withdrawal from alcohol can present risks to the health of an individual. Where necessary, teams will need to discuss with substance misuse support agencies the most appropriate way to address a person’s dependency, including referral. The involvement of specialist services as early as possible could help to prevent escalation and ensure that people can remain in accommodation safely. The Welsh Government has issued guidance for substance misuse and homelessness services, which includes specialist harm reduction advice.
It is also important that services have an awareness and understanding of how exploitation could lead to behaviours that are interpreted as anti-social behaviour. Due to low incomes and the prevalence of (often undiagnosed) mental health problems, autism and learning disabilities in the homeless population, people being placed in emergency accommodation are at a higher risk of exploitation. Services should ensure that staff are aware of the signs of county lines and cuckooing and work with the police to address any concerns. People in this situation should be supported to avoid or escape exploitation. Similarly, many women involved in sex work have been or continue to be victims of abuse. Some of them will be coerced and exploited through sex work, which will affect their ability to adhere to rules and regulations. Services should take a trauma informed approach to supporting them, rather than penalising them for perceived anti-social behaviour.
Ensuring this support is in place is vital in reducing instances of ASB and challenging behaviour and prevention is always best. Staff teams should, through discussion with the individual, ensure that they have an understanding of service users’ needs and the best approaches to de-escalating an individual’s behaviour. This may include developing an understanding of ‘triggers’ that may lead to a person’s behaviour deteriorating.
In addition, there are preventative steps that can be taken to reduce the need for people to leave their rooms/accommodation and to keep clients entertained and occupied. Taking such steps can reduce pressure on personal budgets, anxiety over which can sometimes cause disruptive behaviour. A wide range of small items may make a difference and often providers will be able to source them from donations. Examples of this type include:
- Providing mobile phones and communication tools so that clients can keep in touch with friends and family and access remote support (including providing access to the internet)
- Reading material, radios, televisions/DVD players, jigsaws, and games consoles
- Shoes, clothing and underwear
- Watches or alarm clocks
- Toiletries and items for personal care – electric shavers or toothbrushes, hair dryers
- Supplying basic kitchenette equipment in self-contained rooms – crockery, microwaves, kettles, small fridges
Approach for dealing with ASB and challenging behaviour
It is important to acknowledge the challenging context within which those accommodated and staff are in at this time. Whilst residents may display ASB and challenging behaviour for a variety of reasons, the specific context created by the emergency response to COVID-19 may result in behavioural reactions that are specifically caused by these circumstances such as:
- People living in single rooms when they are more used to the freedom of walking around their local area when living on the streets
- the stress and challenges that are caused by lockdown and isolation requirements
- increased noise nuisance due to more people being confined to larger settings
- provision of support services being increasingly offered remotely which may not be as effective for some individuals
- behaviour caused by increased drug/alcohol intake during lockdown or inability to obtain access to substance due to the lockdown
- behaviour caused by starting treatment for drug/alcohol addiction and struggling with coping strategies to manage distressing emotions
The need to keep people inside to comply with lockdown requirements and PHW guidelines may make it difficult for staff to address challenging behaviour, as the consequences for failing to meet expectations are unclear and do not incentivise individuals to change their behaviour. However, in many cases, existing approaches and policies in this area will still be relevant and should be followed where appropriate.
Refusing to self-isolate
Where a person is displaying symptoms and is refusing to self-isolate, staff should follow procedures laid out here.
If behaviour does not improve or escalates, more formal action might be taken. Ideally, support should be sought through the local Homelessness Co-ordination Cell before involving the police.
Managing low level anti-social and challenging behaviour
These are behaviours that are manageable within the accommodation setting and could include:
- smoking, consuming alcohol or other substances in rooms
- having unauthorised visitors
- minor damage to property
- low level verbal altercations with other residents and staff
The starting point for dealing with this behaviour should always follow a psychologically informed approach. This focuses on de-escalation and attempting to engage with the individual, to help them orientate to more positive behaviours. This could include:
- gaining a good understanding of the cause or reasons for a person’s behaviour
- working with them to address the cause/s
- distraction through conversation, relaxation, exercise or other activities that promote a greater sense of well-being
- informal meetings with individuals to talk about ways to change or address behaviours
- working with individuals to create acceptable behaviour agreements to encourage them to take ownership of their behaviour and identify positive solutions
- motivational interviewing techniques – particularly ‘rolling with resistance’
- using a peer support approach to allow discussions to take place with someone with lived experience
- consideration of personal budgets or the provision of items that could help the person to reduce boredom and frustration and therefore increase the likelihood of positive behaviours
Where challenging behaviour is assessed as being rooted in a specific support need, staff should consider the benefits of engaging more closely with outreach services in the following areas:
Mental health services
Work with local support agencies to ensure staff feel supported and have appropriate training in de-escalation techniques. Services should have contact details for their local mental health crisis teams, Community Mental Health Teams and Local Primary Mental Health Support Services.
Substance misuse services
There are significant risks for people who may be withdrawing from addictive substances, or are ingesting higher than normal volumes of substances at this time, compounded by the lack of availability or quality of substances. It is important to ensure that staff have easy access to substance misuse services.
Prioritise keeping individuals safe and in contact with substance misuse support and counselling services, as well as providing emotional support and coping strategies to manage distressing emotions. Some people may also need assistance to access prescriptions.
Very challenging and high risk behaviour
In some rare cases, behaviour displayed may be so severe or extreme that it requires an escalation from previous engagement strategies and/or an immediate intervention from the police in order to safeguard the individual themselves, other residents and staff. Such behaviour includes:
- Serious assaults
- Serious self-harming behaviour and/or suicidal ideation or attempt
- Threats to life
- Incidents involving weapons
- Other criminal activity (e.g. drug dealing)
Where a call is made to emergency services the police will respond based on a risk assessment of the incident being reported. On receipt of a call, delivered via 999 or 101, the police will establish the content of the call and determine the urgency of the police response required (if any).
The response provided will be determined by police call handlers utilising an assessment tool called ‘THRIVE’ (see Appendix). They will establish the current ‘Threat, Harm, Risk, Investigation, Vulnerability & Engagement’ factors, together with available intelligence, tactical options and capabilities to mitigate the risk and likelihood of harm occurring.
On behalf of forces across Wales, South Wales Police have committed that:-
- Police will respond to threats to staff or incidents of anti-social behaviour in the accommodation, where staff require assistance to control or diffuse the incident, as per the THRIVE principles.
- Police patrols will provide the same approach as now in respect of identifying suspicious activity in the vicinity of rough sleeper premises and responding to reports from providers and local citizens where there is suspicion of drug dealing and once again using THRIVE principles.
- Officers engaging with rough sleepers seeking to buy drugs from dealers will encourage them to make use of the substance misuse services available as part of an approach to reduce reliance on dealers
- Police will respond to any incidents of anti-social behaviour in accordance with the THRIVE principles, with a focus on calming and diffusing tensions where incidents occur.
- Police who identify rough sleepers on the streets will engage to encourage them to move into, or return to, their accommodation
- Where Police engagement identifies a concern a ‘returning’ rough sleeper has in relation to the accommodation, they will liaise with providers to help address those concerns and encourage the rough sleeper to return.
- Where Police patrols identify ‘new’ rough sleepers, Officers will provide information about the accommodation and support available in relation to COVID-19 to encourage those rough sleepers off the street.
Local authorities and providers are strongly encouraged to record any incidents of serious and high risk behaviour and communicate any actions taken with their local homelessness co-ordination cell. Doing so will help manage the further housing of individuals, either within the housing setting, or at another location.
Police in one local authority area made arrangements so that housing providers do not have to dial 101 when issues arise. In other areas, attendance of Police at regular weekly meetings, with officers given specific with responsibility for rough sleepers and can be contacted directly has helped address challenging behaviour.
Removal from accommodation and or the duty to accommodate
Local authorities should exhaust all support options before deciding to remove someone from emergency accommodation at this time. As the behaviour being displayed by individuals may be unique to the person, setting and the unusual circumstances brought about by the COVID-19 lockdown, a single, common solution is unlikely to be available. Therefore, a variety of options should be considered. These can include the following.
- Providing additional, dedicated support for the individual.
- Ensure that the medical needs of the individual have been addressed. Are they receiving the correct type and level of prescription drugs needed? Have the relevant Area Planning Board for substance misuse and related partners (including mental health services) been engaged to work with the individual? Are they receiving psychological support to address immediate distress levels and underlying causes of behaviour?
- Separation from residents or members of staff who they find antagonistic and providing a safe space for individuals to be alone. This can involve the use of temporary self-contained, modular accommodation, to be used alongside appropriate medical or emotional support
- Where possible, relocating to alternative accommodation in the area, made available by the local authority or a housing association.
- Relocation to another nearby local authority (following agreement with the host authority), some of whom may be able to offer alternative types of accommodation and/or an enhanced level of support.
- Consideration of whether the person is suitable for Housing First (subject to local provision)
Where an individual’s behaviour continues to cause alarm or distress to staff and other residents and does not improve, despite all attempts being made to engage with them, or where their behaviour is serious and high risk and requires immediate intervention, it may be necessary to remove them from the accommodation setting. It must be stressed that this step should only be taken in the most severe cases of high risk behaviour and be used as a last resort when all other methods have failed.
Where a person is removed, the local authority must work with partner agencies involved in meeting the needs of a service user. Partners engaged as part of the co-ordination cell should arrange a case conference to plan how best to support the client and managed the risks they present to themselves or others. It is important that decisions and approaches to support are documented in an individual’s personal housing plan or support plan. The recordings should document discussions and actions taken in relation to this decision to be able to demonstrate all previous steps taken to address the behaviour and this is a last resort.
Even where this step is taken, the local authority should use this time to continually monitor and review the person’s needs and what measures can be put in place to bring the individual back into emergency accommodation.
Appendix 1: additional guidance
Trauma Informed and ACE training materials can be found at:
Practitioner guide: working with people in the criminal justice system showing personality difficulties: A practical guide for all staff who come into contact with offenders who might have personality difficulties.
UK government public guidance for managing mental health and well-being during covid
Probation service contacts
Wales Probation Taskforce: Wales.ProbationTaskforce@justice.gov.uk