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A Safeguarding Hub – 25-minute read

Last month, The Guardian ran a story about a ‘group of parents’ who were intending to take legal action against their local authorities, to ensure their children were housed in residential care homes closer to where they live. The children were looked after by the local authorities, but this wasn’t about the parents trying to wrestle back full care of their children. Instead it was a challenge as to why children social care had accommodated the children so far away from the area where the parents lived. However, the headline was slightly misleading because the story focussed solely on one father’s dispute with Bromley social services. The author of the article appeared to have used a fair amount of artistic licence in suggesting that there was a wave of parents ready to take on the system over the use of out-of-borough placements. However, the news piece did raise the very important issue of children being accommodated far away from the local authority who ultimately have responsibility for their care.

In this case the child had been placed in the Midlands, some 130 miles away from his original home in south-London. The child’s father argued that the distance was a significant problem when it came to visiting and supporting the child, hindering his attempts to rebuild his relationship with his son and eventually welcome him back to the family home. The unnamed father also raised issues over the quality of his son’s education and safeguarding whilst placed so far away. Despite concentrating on the one father, the author is correct when suggesting that this is very common problem, quoting figures collated by the all-party parliamentary group (APPG) for runaway and missing children and adults. These figures show out of area placements have increased by 77% since 2012.

In May last year the chair of the APPG raised these concerns in the national media. Ann Coffey MP, used the phrase “farmed out” when referring to vulnerable children placed in care home far away from their home boroughs. Mrs Coffey accused the government of not honouring a pledge made in 2012 to reduce the number of out-of-borough placements. She pointed out that rather than a reduction, there had been a significant increase, with 61% of children in residential care now placed ‘out of area’. The APPG argued that out of area placements makes children more vulnerable to exploitation and impacts on the pacing authority’s ability to safeguard them adequately. This claim was supported by the NSPCC who linked distant placements to children missing from care, highlighting the fact that a missing child is at greater risk of physical abuse, grooming and sexual exploitation.

Never one to mince her words, Mrs Coffey also suggested that the reason for the rise was because of the lack of choice in care provision. She accused private children’s home of capitalising on the lack of provision, by inflating the prices they charge local authorities, to accommodate the ever-growing number of children in care. She also said that the “private sector marketplace in social care is catastrophically failing children. The system is working in the interests of the providers but not for the children themselves. It is not fit for purpose.”

Unsurprisingly these comments drew the ire of children home providers, represented by the Independent Children’s Homes Association (ICHA). They questioned the statistics relied on by the APPG, suggesting that they were unreliable and gave a false impression. The ICHA also said in a statement that the link between out-of-area placements and children going missing, child sexual exploitation, offending, drugs, could not be substantiated with the data that was relied on. Unfortunately the ICHA did stretch the imagination a bit, when they also suggested that the number of children going missing is “very low”, which is simply not the case in the UK.

Our view

Whilst the idea of allowing a child to live near their home and within their own local authority area is the ideal situation, there will always be children who require out of authority placements to ensure that there is effective safeguarding in place. However, out of area and distant placements should be kept to a minimum and be case specific. Unfortunately, we have found with missing children the reality is somewhat different. We feel that there are far too many children placed in distant placements when there appears to be no valid reason for doing so, other than the lack of local care provision.

Whilst we often advise and push for local authorities to place certain children far away from their home area, we would only come to this view after much deliberation, seeing it as one of the last tactical options left to safeguard an individual child. Out of area or distant placements should be the exception rather than the rule, but unfortunately, we have seen many examples where children are placed in certain areas because of a lack of children’s home availability locally, or in the mistaken belief that placing a child far away will prevent them going missing. It rarely gets to the heart of the issue.

We would generally only advise distant placements where there is a real danger to the child, if they were to remain in their home area. Examples would be where the child is likely to exploited by a gang, is involved in county lines drug trafficking or is extremely vulnerable to CSE (Level 2 or 3). Even in these circumstances we are mindful that this not always the right thing to do. The 2015 Catch 22 report – ‘Running the Risks’ puts forward interesting and compelling evidence that moving a child to a distant placement to break the ties, is not always the best thing to do and often increases missing episodes. Where a child is placed out of area, it is crucial that procedures are followed, regardless of whether the child is placed in Ofsted regulated provision, or semi-independent accommodation. Below is what should happen to ensure effective safeguarding.

When considering any distant placement, the responsible authority is required to consult and share information with the area authority in which the child is being placed. There is a statutory obligation to notify the authority when the child is placed and when they also leave the area. This must be a written notification outlining the arrangements for the placement and what is hoped to be achieved (summary of objectives). It should also contain the following information:

  • placing authority details
  • name and date of birth of the child
  • legal status
  • details of the new placement, including the name and address of the carer
  • date the placement will commence
  • expected length of the placement
  • previous address (family address)
  • any education establishment attended by the child
  • details of current (last) placement, including the type of placement, e.g. secure, children’s home
  • contact details of the child’s Social Worker or other lead professional
  • name and address of child’s GP
  • reason why the child is being placed in a distant placement

A copy of the child’s care plan should also be forwarded.

There is no power of veto by the area (host) authority over the responsible authority’s decision to place the child in their area. The child’s Independent Reviewing Officer (IRO) must be consulted before any final decision is made about making an out of authority placement (whether distant or not). Dependent on the case, the views of the child and their parents/guardian should also be sought.

When the most appropriate placement has been identified a number of individuals and agencies need to be informed. The primary aim of ensuring that all relevant parties are notified is to guarantee that those involved in the child’s care have an opportunity to make necessary arrangements to respond to the child’s needs. Those to be notified are:

  • the child
  • the parents or others with parental responsibility (PR)
  • the child’s carers or representatives
  • any other agencies involved with the child;
  • any person who has in place a child arrangement order dealing with contact
  • the child’s Independent Reviewing Office (IRO)

Notification should be in writing. Whilst all the above fall within the regulation and must be informed, professionals can use their discretion and are able to advise any other person who has sufficient interest in the child’s wellbeing. If disclosure to anyone might lead to the child suffering significant harm then that person/agency should not be informed.  It is best practice to provide explanations as to why the child is being moved.

 Our Comment:  We still come across cases where the responsible authority has failed to inform another authority that they have placed a child in their area. Usually this occurs in 16+ accommodation, but we have also seen it within children home settings. One bad example we are aware of was:

A looked after child (Child A) from a large city, was placed in a children’s home in another large city. Rather than a rural location, the new inner-city setting was almost identical in locality to the one that the child had just left. Child A was at substantial risk of CSE, a regular missing child and had also been previously trafficked by CSE perpetrators. The child was under the responsible authority’s multi-agency sexual exploitation protocol, had an allocated social worker and an IRO. They failed to notify the new local authority or the local police CSE team that the child had moved into the area. The home was provided with very little information and they were not proactive in asking for more detail. The fact that Child A was particularly vulnerable to CSE was not fully communicated to the care home staff. By the time that Child A began to ‘flag up’ on the local police systems, the child had made two separate allegations of serious sexual assault and had been missing more than eight times. One of the serious sexual assaults occurred during a missing episode. The child had been in the new placement less than a month. It is an area of huge risk to fail to tell a local authority (and in CSE cases, the local police), that a vulnerable child has moved into their area.

A word on criminal and sexual exploitation information sharing - Where a child is subject of an exploitation protocol/investigation, it is vital that there is communication between the responsible authority and the host authority prior to the child being placed in the home. In addition to the statutory requirements, it is best practice for the responsible authority to make contact with the CSE or CCE special point of contact at the host authority to make them aware the child is in the area. This will give the host authority the chance to review the case at their local Child Sexual and Criminal Exploitation meeting.

There is statutory guidance on children who go missing from home, care or education. This sets out the steps local authorities and their partners should take to prevent children from going missing and to safeguard them when they are missing. A children’s home should be aware of the governments national guidance on missing including the response from the police (Approved Professional Practice on the management, recording and investigation of missing - 2017). They should also be aware of their local authority’s policy on missing, which should follow national guidance but may include local protocols agreed between the authority and police.

Where a child has a history of missing or is likely to go missing there should be a strategy within their placement and care plans to minimise missing episodes and risk. In addition, any child who moves to a new placement and has a history of missing should ideally have a specific Missing Child Risk Assessment Record. In London, we know this as a pre-incident risk assessment. This specifically covers areas which may prompt a child to want to go missing – mental illness, family problems, sexual abuse, FGM, trafficking etc.

The care home must have a protocol and procedures in place so that staff know their roles and responsibilities when they report a child missing from care. It is good practice to contact the local police Missing Person Unit and share the protocol so that police can comment and provide feedback on its content.

When a child returns from a missing episode, police are required to carry out a ‘Prevention Interview’ (formally known as a Safe & Well check). The placing authority is also required to offer an independent Return Home Interview (RHI) within 72 hours of the child’s return. Whilst the RHI is not the responsibility of the home, they have obligation to ensure that they gather as much information as they can about the missing episode. Gathering intelligence and information, is crucial in informing and shaping future risk assessments. The manager or registered person should ensure that records are kept detailing all individual incidents of missing/absence from the home. The placing authority should be notified immediately that the child is missing.

Our Comment:  There is much debate about return home interviews (RHI). Some of the questions are:

  • is it feasible and practical to offer a RHI every time a child returns from a missing episode, given the volume of missing children nationally?
  • isn’t it better to do one very excellent quality RHI after a minimum number of missing episodes, rather than several interviews that are diluted and become ‘routine’?
  • is the timescale of 72 hours from police notification realistic and achievable?

Regardless of these much-debated questions, what we see is that children who are in distant placements suffer more from a lack of RHI’s, compared to children who are placed nearer to home. When they are carried out, they tend to be done by the visiting social worker during a routine visit to the child and therefore lose their independency.

For more on missing children, please see our articles:

Missing Children – what you need to know

Missing Children – the role of the Police

Missing Children – risk management 

Emergency placements are inevitable, but effective planning should minimise the need to place a child in emergency accommodation. There will always be occasions where a placement breaks down suddenly. These can include:


  • where a carer refuses to have the child back
  • where keeping the child at their current home would place them at immediate risk
  • where a child becomes looked after they have been remanded by the Court

Even in an emergency local authority should as far as it is reasonably practicable, seek placements that meet the needs of the child. There is no requirement for written information to be provided when a child is placed under emergency provisions, but local authorities should strive to ensure that the carer has sufficient information to keep the child and other people within the home safe. In a world where communication is now at our fingertips, there should be no excuse for failing to provide information pertaining to risk. All other requirements i.e. notify the receiving area authority, inform and consult the child’s parents, guardians IRO and others, must be undertaken within 5 working day.

Placements outside E&W, but still within the UK will need to be fully justified. It will normally only occur where it is in the child’s best interest to be placed with a relative who lives elsewhere within the British Isle. The regulations do not apply outside England and Wales but the local authority should follow the same principles that would apply within E&W.

When the responsible authority proposes to terminate a child’s placement, there must be a case review and further consultation with the various people who were originally consulted when the child was placed there. This doesn’t have to happen where the carer/registered person has ‘given notice’ to terminate the placement, or where a parent for a Section 20 accommodated child wants the child returned to their care.

In a case where the placement is terminated, either by the authority or the carer, the responsible authority is required to make arrangements to accommodate the child elsewhere. If it is the responsible authority who terminate, then they should have made alternative arrangements prior to giving notice, unless they consider that there is an immediate risk of significant harm to the child; or they need to do so to protect others from serious injury. However, they should then seek to find alternative accommodation as soon as possible. The IRO should informed as soon as is practicable.

Regardless of the circumstances, the outgoing carer(s) should strive to prepare and support the child’s move, as best as they can.

In our world of missing children, this is one of our biggest problems when dealing with children reported missing from a residential setting. Moving placements can be traumatic and it is a fact that the odds of a child going missing within 24 hours of a new placement are extremely high. We often find that there is a peak of missing episodes in the first 3 to 4 weeks after the child has moved in. It is important that carers are empowered to help children quickly adapt and feel at home in their new home. It is also crucial that the provider is told about ALL potential safeguarding issues.

To ensure that the best possible transition and to maximise safeguarding, it is best practice for the carer to be provided with the following:

  • family history - family, race, religion and culture
  • background - circumstances around why the child has become looked after
  • any disabilities or other special needs
  • any specialist interventions, therapeutic support or extra tuition the child is receiving and what the plan is for that support to continue
  • long term plan and objectives for the child, together with timeframes
  • relevant parts of the care plan (rarely happens)
  • any health issues, treatment and medication
  • contact details of the lead professional, their manager, the IRO and independent visitor
  • how the carer can obtain support or seek advice around the child if necessary (including out of office hours);
  • names and contact details of and any other key people/agencies - school, designated teacher for looked after pupils, GP, dentist etc.
  • relevant content of the child’s health and education plans (PEP) and the role they the carer will play in implementation
  • any existing contact arrangements/orders – with parents, siblings, relatives etc.

Our Comment: One of the vulnerabilities we come across regularly is where residential placements tells us that they didn’t know a child was at risk of exploitation, had gang involvement or was likely to run away. The excuse they often give is that they were not provided with a risk assessment by the placing authority. There are several reasons whilst carers are not always provided with the fullest appropriate information. One reason is often the confusion around information sharing i.e. what information should be shared and is it legal to tell the carer? Another reason is far more controversial, a reluctance for local authorities to provide carers with full details of the child’s negative behaviour, in a bid to secure the placement. Whilst this is rare, it can happen. Carers must know in advance about the child’s previous risk behaviours, any exploitative situations they may place themselves in, history of missing, CSE, gang associations etc.  – in other words, whilst it isn’t a requirement, it is a no brainer to provide the carer with a full risk assessment. Of course, there may be information that isn’t relevant or appropriate to share, but this should be rare and where it involves risk then there must be some recorded justification for not sharing. It’s all about reducing risk and maximising safeguarding.

Time and time again we come across cases of children reported missing where the police are met with a comment similar to “he has only been with us a short while and we know very little about him”. Examples of not “knowing anything” about a child have included:

  • not knowing his family background
  • not having names and contact details of parents
  • not knowing he was a gang member
  • not knowing he has displayed previous harmful sexual behaviour
  • not knowing he self-harms or has in the past attempted suicide

This shouldn’t happen and a care placement should never take children they “know very little about”, even where it is an emergency placement. Far too often we see cases where 2 to 4 weeks later the carer still hasn’t received full details of the child and associated risk, nor have they been proactive in trying to obtain that information. This makes everyone vulnerable – the placement, the local authority, but more importantly the child. When a care home hasn’t been communicated all the risk, scenarios like this can develop:

  • serious disorder/violence – staff/carers not being aware that they have accepted two rival gang members into the home or the home becomes a ‘target’ for rival gangs to congregate and commit acts of violence against each other
  • arson – staff not aware that a child with a previous for fire setting
  • false allegations – staff not aware that a child has made false allegations of abuse or assault against previous care home staff. This doesn’t necessarily mean that the home will refuse to admit the child, but they can minimise risk by having 2 members of staff present with the child at all times
  • criminal and sexual exploitation – staff not aware of how a child is vulnerable to exploitation i.e. use of the internet identity, or perpetrators or vehicles that may attend the home
  • missing – staff not aware of previous missing episodes, what areas a child might go, how long they are likely to be gone etc
  • drugs & alcohol – previous and current drug use; what type of drug, does this necessitate stricter room searches

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