(Public Pack)Agenda Document for Cabinet, 24/04/2019 16:00

CABINET MAYOR

Mayor John Biggs

CABINET MEMBERS

Councillor Sirajul Islam (Statutory Deputy Mayor and Cabinet Member for Housing)

Councillor Rachel Blake (Deputy Mayor and Cabinet Member for Regeneration and Air Quality)

Councillor Asma Begum (Deputy Mayor and Cabinet Member for Community Safety and Equalities)

Councillor Amina Ali (Cabinet Member for Culture, Arts and Brexit) Councillor David Edgar (Cabinet Member for Environment)

Councillor Danny Hassell (Cabinet Member for Children, Schools and Young People)

Councillor Denise Jones (Cabinet Member for Adults, Health and Wellbeing) Councillor Candida Ronald (Cabinet Member for Resources and the Voluntary

Sector) Councillor Motin Uz-Zaman (Cabinet Member for Work and Economic Growth)

[The quorum for Cabinet is 3 Members]

MEETING DETAILS

Wednesday, 24 April 2019 at 4.00 p.m. C1, 1st Floor, Town Hall, Mulberry Place, 5 Clove Crescent, London,

E14 2BG

The meeting is open to the public to attend.

Further Information

The public are welcome to attend meetings of the Cabinet. Procedures relating to Public Engagement are set out in the „Guide to Cabinet‟ attached to this agenda.

Contact for further enquiries: Matthew Mannion, Democratic Services, 1st Floor, Town Hall, Mulberry Place, 5 Clove Crescent, London, E14 2BG Tel: 020 7364 4651 E-mail: [email protected] Web:http://www.towerhamlets.gov.uk

Scan this code for an electronic

agenda:

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Public Information

Attendance at meetings. The public are welcome to attend meetings of Cabinet. However seating is limited and offered on a first come first served basis. Please note that you may be filmed in the background as part of the Council‟s filming of the meeting. Audio/Visual recording of meetings. The Council will be filming the meeting for presentation on the website. Should you wish to film the meeting, please contact the Committee Officer shown on the agenda front page.

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A Guide to CABINET

Decision Making at Tower Hamlets As Tower Hamlets operates the Directly Elected Mayor system, Mayor John Biggs holds Executive powers and takes decisions at Cabinet or through Individual Mayoral Decisions. The Mayor has appointed nine Councillors to advise and support him and they, with him, form the Cabinet. Their details are set out on the front of the agenda. Which decisions are taken by Cabinet? Executive decisions are all decisions that aren‟t specifically reserved for other bodies (such as Development or Licensing Committees). In particular, Executive Key Decisions are taken by the Mayor either at Cabinet or as Individual Mayoral Decisions. The constitution describes Key Decisions as an executive decision which is likely

a) to result in the local authority incurring expenditure which is, or the making of savings which are, significant having regard to the local authority‟s budget for the service or function to which the decision relates; or

b) to be significant in terms of its effects on communities living or working in an area comprising two

or more wards in the borough.

Upcoming Key Decisions are published on the website on the „Forthcoming Decisions‟ page through www.towerhamlets.gov.uk/committee

Published Decisions and Call-Ins Once the meeting decisions have been published, any 5 Councillors may submit a Call-In to the Service Head, Democratic Services requesting that a decision be reviewed. This halts the decision until it has been reconsidered.

The decisions will be published on: Friday, 26 April 2019

The deadline for call-ins is: Friday, 3 May 2019 Any Call-Ins will be considered at the next meeting of the Overview and Scrutiny Committee. The Committee can reject the call-in or they can agree it and refer the decision back to the Mayor, with their recommendations, for his final consideration. Public Engagement at Cabinet The main focus of Cabinet is as a decision-making body. However there is an opportunity for the public to contribute through making submissions that specifically relate to the reports set out on the agenda. Members of the public may make written submissions in any form (for example; Petitions, letters, written questions) to the Clerk to Cabinet (details on the front page) by 5 pm the day before the meeting.

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http://www.towerhamlets.gov.uk/committee

LONDON BOROUGH OF TOWER HAMLETS

CABINET

WEDNESDAY, 24 APRIL 2019

4.00 p.m.

Pages

1. APOLOGIES FOR ABSENCE

To receive any apologies for absence.

2. DECLARATIONS OF DISCLOSABLE PECUNIARY INTERESTS

9 - 12

To note any declarations of interest made by Members, including those restricting Members from voting on the questions detailed in Section 106 of the Local Government Finance Act, 1992. See attached note from the Monitoring Officer.

3. UNRESTRICTED MINUTES

13 - 20

The unrestricted minutes of the Cabinet meeting held on 27 March 2019 are presented for approval.

4. ANNOUNCEMENTS (IF ANY) FROM THE MAYOR

5. OVERVIEW & SCRUTINY COMMITTEE

5 .1 Chair's Advice of Key Issues or Questions

Chair of Overview and Scrutiny Committee (OSC) to report on any issues raised by the OSC in relation to unrestricted business to be considered.

5 .2 Any Unrestricted Decisions "Called in" by the Overview & Scrutiny

Committee

(Under provisions of Article 6 Para 6.02 V of the Constitution).

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6. UNRESTRICTED REPORTS FOR CONSIDERATION

6 .1 Gangs and Serious Youth Violence Scrutiny Review Action Plan 21 - 70

Report Summary: This item provides the report and actions taken to address the recommendations made from the Scrutiny Review on the issue of Gangs and Serious Youth Violence in Tower Hamlets.

Wards: All Wards L Lead Member: Cabinet Member for Children, Schools and Young

People

Corporate Priority: TH Plan 3: Strong, resilient and safe communities

6 .2 Strategic Plan 2019-22 71 - 98

Report Summary: To approve the Council‟s Strategic Plan for 2019-22

Wards: All Wards L Lead Member: Mayor Corporate Priority: All Priorities

6 .3 The Tower Hamlets Safeguarding Partnership (THSCP) - an Overview and Update on the new Safeguarding Children arrangements

99 - 150

Report Summary: The Children and Social Work Act 2017 and revised statutory guidance require a new partnership body to be established to support Childrens Safeguarding. The report outlines the issues, timelines, development works and next steps for the establishment of the Tower Hamlets Safeguarding Partnership.

Wards: All Wards L Lead Member: Cabinet Member for Children, Schools and Young

People

Corporate Priority: A borough that our residents are proud of and love to live in

6 .4 Enforcement Policy Review 151 - 268

Report Summary: To agree the review and update to the Council‟s overarching Enforcement Policy The report details proposed changes to the Enforcement Policy that must be published.

Wards: All Wards L Lead Member: Cabinet Member for Environment Corporate Priority: A borough that our residents are proud of and

love to live in

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6 .5 Growth and Economic Development Plan 2018-2023 269 - 316

Report Summary: This report presents the council‟s draft Growth and Economic Development Plan 2019-2023, which incorporates consultation feedback. The consultation on the draft Growth and Economic Development Plan ran from November 2018 to February 2019. The Tower Hamlets Growth and Economic Development Plan aims to deliver sustainable and inclusive economic growth enabling all our residents and businesses to prosper.

Wards: All Wards L Lead Member: Cabinet Member for Work and Economic Growth Corporate Priority: A borough that our residents are proud of and

love to live in

6 .6 Adoption of statement of Community Involvement 317 - 378

Report Summary: The Council is required to maintain an up to date Statement of Community Involvement, setting out how we will consult on planning matters in the borough. This item is for the adoption of an updated statement of Community Involvement.

Wards: All Wards L Lead Member: Deputy Mayor and Cabinet Member for

Regeneration and Air Quality

Corporate Priority: A borough that our residents are proud of and love to live in

6 .7 Nomination to Outside Bodies 379 - 384

Report Summary: It is the responsibility of the Mayor to nominate representatives to certain Outside Bodies on behalf of Tower Hamlets Council. This report proposes appointments to Outside Bodies for the Mayor to consider and a list of Outside Bodies for which nominations are recommended to be discontinued following the recommendation of a review by the General Purposes Committee.

Wards: All Wards L Lead Member: Mayor Corporate Priority: A dynamic outcomes-based Council using digital

innovation and partnership working

7. ANY OTHER UNRESTRICTED BUSINESS CONSIDERED TO BE URGENT

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8. EXCLUSION OF THE PRESS AND PUBLIC

Should the Mayor in Cabinet consider it necessary, it is recommended that the following motion be adopted to allow consideration of any exempt/restricted documents. “That, under the provisions of Section 100A of the Local Government Act, 1972 as amended by the Local Government (Access to Information) Act, 1985, the Press and Public be excluded from the remainder of the meeting for the consideration of the Section Two business on the grounds that it contains information defined as Exempt in Part 1 of Schedule 12A to the Local Government, Act 1972”. EXEMPT/CONFIDENTIAL SECTION (PINK) The Exempt / Confidential (Pink) Committee papers in the Agenda will contain information, which is commercially, legally or personally sensitive and should not be divulged to third parties. If you do not wish to retain these papers after the meeting, please hand them to the Committee Officer present.

9. EXEMPT / CONFIDENTIAL MINUTES

Nil items.


10 .1 Chair's Advice of Key Issues or Questions in Relation to Exempt /

Confidential Business

Chair of Overview and Scrutiny Committee (OSC) to report on any issues raised by the OSC in relation to exempt/confidential business to be considered.

10 .2 Any Exempt / Confidential Decisions "Called in" by the Overview &

Scrutiny Committee

(Under provisions of Article 6 Para 6.02 V of the Constitution).

11. EXEMPT / CONFIDENTIAL REPORTS FOR CONSIDERATION

12. ANY OTHER EXEMPT/ CONFIDENTIAL BUSINESS CONSIDERED TO BE URGENT

Next Meeting of the Committee: Wednesday, 22 May 2019 at 5.30 p.m. in C1, 1st Floor, Town Hall, Mulberry Place, 5 Clove Crescent, London, E14 2BG

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DECLARATIONS OF INTERESTS - NOTE FROM THE MONITORING OFFICER

This note is for guidance only. For further details please consult the Members’ Code of Conduct at Part 5.1 of the Council’s Constitution. Please note that the question of whether a Member has an interest in any matter, and whether or not that interest is a Disclosable Pecuniary Interest, is for that Member to decide. Advice is available from officers as listed below but they cannot make the decision for the Member. If in doubt as to the nature of an interest it is advisable to seek advice prior to attending a meeting. Interests and Disclosable Pecuniary Interests (DPIs) You have an interest in any business of the authority where that business relates to or is likely to affect any of the persons, bodies or matters listed in section 4.1 (a) of the Code of Conduct; and might reasonably be regarded as affecting the well-being or financial position of yourself, a member of your family or a person with whom you have a close association, to a greater extent than the majority of other council tax payers, ratepayers or inhabitants of the ward affected. You must notify the Monitoring Officer in writing of any such interest, for inclusion in the Register of Members’ Interests which is available for public inspection and on the Council’s Website. Once you have recorded an interest in the Register, you are not then required to declare that interest at each meeting where the business is discussed, unless the interest is a Disclosable Pecuniary Interest (DPI). A DPI is defined in Regulations as a pecuniary interest of any of the descriptions listed at Appendix A overleaf. Please note that a Member’s DPIs include his/her own relevant interests and also those of his/her spouse or civil partner; or a person with whom the Member is living as husband and wife; or a person with whom the Member is living as if they were civil partners; if the Member is aware that that other person has the interest. Effect of a Disclosable Pecuniary Interest on participation at meetings Where you have a DPI in any business of the Council you must, unless you have obtained a dispensation from the authority's Monitoring Officer following consideration by the Dispensations Sub-Committee of the Standards Advisory Committee:-

- not seek to improperly influence a decision about that business; and - not exercise executive functions in relation to that business.

If you are present at a meeting where that business is discussed, you must:-

- Disclose to the meeting the existence and nature of the interest at the start of the meeting or when the interest becomes apparent, if later; and

- Leave the room (including any public viewing area) for the duration of consideration and decision on the item and not seek to influence the debate or decision

When declaring a DPI, Members should specify the nature of the interest and the agenda item to which the interest relates. This procedure is designed to assist the public’s understanding of the meeting and to enable a full record to be made in the minutes of the meeting.

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Agenda Item 2

Where you have a DPI in any business of the authority which is not included in the Member’s register of interests and you attend a meeting of the authority at which the business is considered, in addition to disclosing the interest to that meeting, you must also within 28 days notify the Monitoring Officer of the interest for inclusion in the Register. Further advice For further advice please contact:- Asmat Hussain, Corporate Director, Governance and Monitoring Officer. Tel 020 7364 4800

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APPENDIX A: Definition of a Disclosable Pecuniary Interest (Relevant Authorities (Disclosable Pecuniary Interests) Regulations 2012, Reg 2 and Schedule)

Subject Prescribed description

Employment, office, trade, profession or vacation

Any employment, office, trade, profession or vocation carried on for profit or gain.

Sponsorship Any payment or provision of any other financial benefit (other than from the relevant authority) made or provided within the relevant period in respect of any expenses incurred by the Member in carrying out duties as a member, or towards the election expenses of the Member.

This includes any payment or financial benefit from a trade union within the meaning of the Trade Union and Labour Relations (Consolidation) Act 1992.

Contracts Any contract which is made between the relevant person (or a body in which the relevant person has a beneficial interest) and the relevant authority—

(a) under which goods or services are to be provided or works are to be executed; and

(b) which has not been fully discharged.

Land Any beneficial interest in land which is within the area of the relevant authority.

Licences Any licence (alone or jointly with others) to occupy land in the area of the relevant authority for a month or longer.

Corporate tenancies Any tenancy where (to the Member’s knowledge)—

(a) the landlord is the relevant authority; and

(b) the tenant is a body in which the relevant person has a beneficial interest.

Securities Any beneficial interest in securities of a body where—

(a) that body (to the Member’s knowledge) has a place of business or land in the area of the relevant authority; and

(b) either—

(i) the total nominal value of the securities exceeds £25,000 or one hundredth of the total issued share capital of that body; or

(ii) if the share capital of that body is of more than one class, the total nominal value of the shares of any one class in which the relevant person has a beneficial interest exceeds one hundredth of the total issued share capital of that class.

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CABINET, 27/03/2019 SECTION ONE (UNRESTRICTED)

1

LONDON BOROUGH OF TOWER HAMLETS

MINUTES OF THE CABINET

HELD AT 4.06 P.M. ON WEDNESDAY, 27 MARCH 2019

C1, 1ST FLOOR, TOWN HALL, MULBERRY PLACE, 5 CLOVE CRESCENT, LONDON, E14 2BG

Members Present: Mayor John Biggs Councillor Sirajul Islam (Statutory Deputy Mayor and Cabinet Member for

Housing) Councillor Rachel Blake (Deputy Mayor and Cabinet Member for

Regeneration and Air Quality) Councillor Asma Begum (Deputy Mayor and Cabinet Member for Community

Safety and Equalities) Councillor Amina Ali (Cabinet Member for Culture, Arts and Brexit) Councillor David Edgar (Cabinet Member for Environment) Councillor Danny Hassell (Cabinet Member for Children, Schools and Young

People) Councillor Denise Jones (Cabinet Member for Adults, Health and Wellbeing) Councillor Candida Ronald (Cabinet Member for Resources and the Voluntary

Sector) Councillor Motin Uz-Zaman (Cabinet Member for Work and Economic Growth)

Other Councillors Present:

Councillor Abdal Ullah Councillor Andrew Wood (Leader of the Conservative Group)

Officers Present:

Janet Fasan (Divisional Director, Legal, Governance) Dan Jones (Divisional Director, Public Realm) Debbie Jones (Corporate Director, Children and Culture) Neville Murton Corporate Director, Resources) Denise Radley (Corporate Director, Health, Adults & Community) Will Tuckley (Chief Executive) Menara Ahmed (Hate Crime Policy & Partnership Manager) Ann Corbett (Divisional Director, Community Safety) Sharon Godman (Divisional Director, Strategy, Policy and

Performance) Alan McCarthy (Asset Strategy Capital Delivery & Property

Services) Ralph Million (Senior Strategic Asset Manager, Place) Matthew Mannion (Head of Democratic Services, Governance) Joel West (Senior Democratic Services Officer)

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Agenda Item 3


2

1. APOLOGIES FOR ABSENCE Apologies for absence were received on behalf of:

Ann Sutcliffe (Dan Jones, Divisional Director, Public Realm) is deputising.

Asmat Hussain (Janet Fasan, Divisional Director, Legal) is deputising.

Tom McCourt (Dan Jones also deputising)

2. DECLARATIONS OF DISCLOSABLE PECUNIARY INTERESTS There were no Declarations of Disclosable Pecuniary Interests.

3. UNRESTRICTED MINUTES RESOLVED

1. That the unrestricted minutes of the Cabinet meeting held on Wednesday 27 February 2019 be approved and signed by the Chair as a correct record of proceedings.

4. ANNOUNCEMENTS (IF ANY) FROM THE MAYOR The Mayor made a number of announcements including that:

The Council’s work tackling hate crime and violence against women and girls had been recognised at the Local Government Chronicle (LGC) Awards ceremony with a ‘Team of the Year’ award. He highlighted how important this issue was to the Council and congratulated the team, volunteers and champions for their hard work.

Two Individual Mayoral Decisions had recently been taken. The information was available on the website for those who wished to view them.

The Council had held a successful staff awards ceremony earlier in the day and it had been uplifting seeing the good work that was being championed from across the Council.


5.1 Chair's Advice of Key Issues or Questions

No Pre-Decision Scrutiny Questions were tabled. Councillor Abdal Ullah, Chair of the Overview and Scrutiny Committee, provided the meeting with a verbal update on the recent work of the Committee. In particular he reported that the Committee were considering ideas for the future of Overview and Scrutiny to ensure it is able to robustly perform its work. A report on this was expected soon.

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In addition he highlighted a number of issues that the Committee had discussed at its last meeting including:

A discussion on progress made in respect of Children’s Services and he thanked the Lead Member and officers for the time they had given to the Committee on this issue.

A discussion on community safety in light of recent terrorist attacks across the world.

A spotlight session on street cleanliness, waste collection and recycling.

A discussion on parking issues.

An interesting spotlight session with the Chief Executive and he was grateful to the Chief Executive for making time available to attend the meeting.

The Mayor thanked him for his update and in particular highlighted the concern the Council placed on community safety.

5.2 Any Unrestricted Decisions "Called in" by the Overview & Scrutiny Committee Nil items.

6. UNRESTRICTED REPORTS FOR CONSIDERATION

6.1 Violence Against Women and Girls Strategy 2019-24 Councillor Asma Begum, Deputy Mayor and Cabinet Member for Community Safety and Equalities, introduced the report on the new Violence Against Women and Girls (VAWG) Strategy 2019-24. She highlighted that the strategy was linked to the Council’s Strategic Plan and that some actions, such as the signing of the VAWG Charter, had already been delivered. She highlighted how the Council had worked to cover the biggest concerns raised by those impacted such as on potential homelessness and it had looked at how to overcome barriers to seeking support. During discussion a number of points were noted including:

This was a high level strategy and the underpinning action plan would follow.

It was also noted that the strategy had been developed as a partnership approach.

Working with schools to educate young people was vitally important.

Violence took in a wide range of issues including actions such as coercive control.

The Council worked to ensure services were available for both men and women who were victims of violence.

The Mayor thanked everyone for their contributions, welcomed the report and agreed the recommendations as set out.

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RESOLVED

1. To agree the Violence Against Women and Girls Strategy 2019-24 2. To agree that the Violence Against Women and Girls Strategy 2019-24

be published.

6.2 Children’s Services Improvement Programme, Quarterly Progress Report (Quarter 3- 2018/19) Councillor Danny Hassell, Cabinet Member for Children, Schools and Young People, introduced the report setting out the latest update on the Children’s Services Improvement Programme. He took Members through a number of the areas of improvement demonstrated including around staff recruitment and retention and culture change. He also highlighted areas where work was ongoing such as on investigating new ideas around restorative justice and the much stronger auditing of cases working through the systems. Finally he noted that there were a number of areas that required further improvement including ensuring a consistent service quality for all service users. The Mayor welcomed the report and discussion of the topic and highlighted that he and Lead Members had been involved in many meetings examining progress against this improvement plan. He agreed the recommendations as set out. RESOLVED

1. To endorse the progress made in delivering the children’s services improvement programme.

2. To agree the next steps in the improvement journey which will be

updated on in the next report.

6.3 Tower Hamlets Brexit Commission Report: Impact of Brexit on Tower Hamlets Councillor Amina Ali, Cabinet Member for Culture, Arts and Brexit, introduced the report from the Tower Hamlets Brexit Commission. She highlighted that the exact nature of the country’s exit from the European Union had not yet been confirmed which added to the risks for the Council and the potential local impact. She explained that the report looked to identify both risks and opportunities for the local area and local businesses.

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During discussion a number of particular issues were noted including:

The need to work with other London Boroughs to lobby for funding to replace European funding streams.

Lobbying in other areas such as to have the skills budgets devolved to Councils and to lift the immigration salary cap.

The ongoing work to publicise the rights of EU citizens, including those who were staff.

It was important to take opportunities that arose especially in encouraging new businesses to open in the area from around the world.

The Mayor thanked everyone for their contributions. He highlighted the importance of the Council showing leadership to deal with whatever scenario was finally agreed at a national level. He agreed the recommendations as set out. RESOLVED

1. To note the Brexit Commission report attached in in Appendix 1 to the report.

6.4 Asset Management: leases and disposals

The Mayor introduced the report on two proposed property leases and a land disposal. He took the report in two parts. Pat Shaw House and 401 Mile End Road In terms of taking on leases at the above properties the Mayor welcomed the report. He highlighted that the proposals had been scrutinised by Lead Members and were seen as offering value to the authority. He noted the exempt appendix and agreed the recommendations as set out. Wayside Gardens In relation to the proposed disposal of land, the Mayor considered that on balance this was the right approach in order to enable the development to go ahead. However, he was acutely aware of the lack of open space in the borough and welcomed the work officers were undertaking to explore options for recreating this space. He also asked for more details on the agreement with the developer including in respect of control over future use of the disposed site. Finally, he also noted the exempt appendix. Following discussion, the Mayor agreed the decision in principle but asked for more information in relation to the issues highlighted above. Following the satisfactory conclusion of that discussion he proposed taking an Individual Mayoral Decision to confirm his view.

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RESOLVED Wayside Gardens

1. To agree in principle that the land at Wayside Gardens is declared surplus to the Council’s requirements and is sold to the developer’s property holding subsidiary, Drakar Limited, on the basis set out in this report.

2. To note that a final decision will be taken via an Individual Mayoral

Decision subject to final consultation between the Mayor and lead officers.

Pat Shaw House and 401 Mile End Road

1. To agree to the Council entering into leases of two properties owned by Gateway Housing Association at the rents and other main terms set out in paragraph 3.3 of the report and the exempt Appendix 4 to the report.

2. To note that the properties will be manged by the Council’s Housing

Options Service to provide 40 units of temporary accommodation for people in priority housing need.

3. To delegate authority to the Acting Corporate Director, Place to agree

all other terms of the leases.

4. To authorise the Corporate Director, Place in liaison with the Corporate Director, Governance to enter into the necessary legal agreements required to implement the recommendations above

6.5 Contracts Forward Plan 2018/19 – Quarter Four

Councillor Candida Ronald introduced the report. She highlighted the contracts set out in the Appendices to the report including in the forward plan of contracts. The Mayor agreed that all listed contracts set out in Appendix 1 could proceed to contract award after tender. RESOLVED

1. To note the contracts summary at Appendix 1 to the report.

2. To confirm that all contracts set out in Appendix 1 to the report can proceed to contract award after tender

3. To authorise the Divisional Director, Legal to execute all necessary

contract documents in respect of the awards of contracts referred to at Recommendation 2 above

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4. To note the procurement forward plan 2019-2022 schedule detailed in Appendix 2 to the report.

7. ANY OTHER UNRESTRICTED BUSINESS CONSIDERED TO BE URGENT Nil items.

8. EXCLUSION OF THE PRESS AND PUBLIC Nil items.

9. EXEMPT / CONFIDENTIAL MINUTES Nil items.


10.1 Chair's Advice of Key Issues or Questions in Relation to Exempt / Confidential Business Nil items.

10.2 Any Exempt / Confidential Decisions "Called in" by the Overview & Scrutiny Committee Nil items.

11. ANY OTHER EXEMPT/ CONFIDENTIAL BUSINESS CONSIDERED TO BE URGENT Nil items.

The meeting ended at 5.21 p.m.

MAYOR JOHN BIGGS

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Cabinet decision

24 April 2019

Report of: Debbie Jones, Corporate Director Children and Culture

Classification: Unrestricted

Gangs and Serious Youth Violence Scrutiny Review Action Plan

Lead Member Councillor Danny Hassell, Cabinet Member for Children, Schools and Young People

Wards affected All wards

Key Decision? No

Forward Plan Notice Published

7 March 2019

Reason for Key Decision N/A

Strategic Plan Priority / Outcome

People feel safer in their neighbourhoods and anti-social behaviour is tackled

Executive Summary This report submits the report and action plan in response to the recommendations of the Scrutiny Review Session on Gangs and Serious Youth Violence.

Recommendations: The Mayor in Cabinet is recommended to:

1. Note this report and the progress made since the Scrutiny Review report was published in March 2018, as set out in Appendix 1.

2. Approve the action plan which sets out the Council’s response to the recommendations of the Scrutiny Review Session in Appendix 2 to the report.

3. Support the continuation of efforts made through newly implemented initiatives to disrupt gang activity, with particular attention on the improved quality and timeliness of services for children at risk of becoming involved in gang activity and serious youth violence.

4. Acknowledge the recognition of Ofsted in monitoring visit reports as to the

improvements made in Children’s Social Care

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Agenda Item 6.1

1 REASONS FOR THE DECISIONS 1.1 This report outlines the findings and recommendations from the scrutiny review sessions on gangs and serious youth violence (Appendix 1) which was approved at OSC in March 2018. The Council’s responses to these recommendations are outlined in the action plan in Appendix 2 and both documents are now due for consideration by Cabinet. 2 ALTERNATIVE OPTIONS 2.1 Cabinet may decline to agree the action plan. This is not recommended as the report outlines work undertaken by Councillors and officers to identify areas of improvement and the Council’s response which identifies actions it is taking and will take to implement these recommendations. 3 DETAILS OF THE REPORT

3.1 The Gangs and Serious Youth Violence Scrutiny Review was chaired by Councillor Danny Hassell in his role as Scrutiny Lead for Children’s Services in order to obtain an overview of the scale and impact of Gangs and Serious Youth Violence in the Borough and the work currently being planned and delivered by the Council and its partners.

3.2 The review was held over two sessions in January and February 2018. It

followed the 2017 Ofsted review of Tower Hamlets’ Children’s Services, as one of the recommendations that arose was that the Council should “Urgently improve the quality and timeliness of services for children who are at risk of becoming involved in gangs and serious youth violence. Ensure the alignment of those services with those for children who go missing and those who are vulnerable to sexual exploitation and radicalisation. Ensure that comprehensive and accurate intelligence and data inform service developments.”

3.3 The review was underpinned by three core questions:

1) What is the true scale and impact of Gangs and Youth Violence issue

in Tower Hamlets?

2) What are common factors that lead to involvement in Gangs?

3) How can the Council and its partners work together more effectively to reduce the impact of gangs in the borough and help young people

avoid or exit gang involvement?

3.4 The two sessions were attended by the following people:

Cllr Dave Chesterton Chair of Overview and Scrutiny Committee Cllr Clare Harrisson Overview and Scrutiny Committee Member Cllr Rabina Khan Overview and Scrutiny Committee Member Cllr Shafi Ahmed Overview and Scrutiny Committee Member (Substitute)

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David Burbidge Co-opted member of the Health Scrutiny Committee Fahimal Islam Young Mayor

Shaiam Islam Deputy Young Mayor Cllr Amy Whitelock-Gibbs Lead Member for Education and Children’s Services Claire Belgard Interim Head of Integrated Youth and Community Services Nikki Bradley Service Manager Youth Justice, Children’s Social care and Family Interventions Debbie Jones Corporate Director, Children’s Services Nancy Meehan Interim Divisional Director, Children’s Social Care Adam Salmon Ending Gang, Group and Serious Youth Violence Coordinator Paula Wilkinson Crime Reduction & Rapid Response Team Manager Mike Hamer Deputy Chief Inspector Sean Drislane Detective Inspector Maurice Mason Community Safety and Partnership Manager, London Borough of Hackney John O’Shea Bow School Daniel Rose Director of Spotlight Khalid Sugulle St Giles Trust

Joe Williams Spotlight, Poplar HARCA

3.5 The report makes a series of twenty recommendations which can be categorised into the following four areas:

Approach and Focus: recommendations 1-5 Analysis, Knowledge and Understanding: recommendations 6-8 Communications, Joint-Working and Engagement: recommendations 9-14 Training and Capacity Building: recommendations 15-20

3.6 A comprehensive action plan has been developed responding to the recommendations set out in the scrutiny review report in Appendix 1. Many of these actions are underway or completed. The improvements made have been noted by Ofsted when conducting monitoring visits of children’s social care.

4 EQUALITIES IMPLICATIONS 4.1 Different communities and cohorts of the population experience anti-social

behaviour and associated crime differently. Those most vulnerable to becoming both perpetrators and victims of ASB and crime include:

Young people Parents/guardians of children Residents from the BAME community Residents with a disability

4.2 Although it was identified during the review that a majority of young people

currently involved in gangs are from BAME communities, this is broadly representative of the diversity of the local population. Similarly, although gang involvement is predominantly male dominated, the impact on women and girls through direct involvement or families is an area of specific focus. Community cohesion and empowerment was at the heart of the review and the focus for recommendations.

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5 OTHER STATUTORY IMPLICATIONS 5.1 This section of the report is used to highlight further specific statutory

implications that are either not covered in the main body of the report or are required to be highlighted to ensure decision makers give them proper consideration. Examples of other implications may be:

Best Value Implications,

Consultations,

Environmental (including air quality),

Risk Management,

Crime Reduction,

Safeguarding. 5.2 There are no other statutory implications. 6 COMMENTS OF THE CHIEF FINANCE OFFICER 6.1 There is no request for new funding to implement the recommendations of the

Scrutiny Review Session on Gangs and Serious Youth Violence. The recommendations are being implemented with existing resources in several council departments.

7 COMMENTS OF LEGAL SERVICES 7.1. The Overview and Scrutiny Committee may consider any matter affecting the

area or its inhabitants and may make reports and recommendations to the Full Council or the Executive, as appropriate, in connection with the discharge of any functions. It is consistent with the Constitution and the statutory framework to prepare an action plan to address the issues identified and make further recommendations for improvement.

7.2. The Council’s functions in relation to children include a duty under section 11 of the Children Act 2004 to make arrangements to ensure that its functions are discharged having regard to the need to safeguard and promote the welfare of children. Section 10 of the Act also requires the Council to make arrangements to promote cooperation with its safeguarding partner agencies including schools, the police, probation services and the youth offending team.

7.3. The action plan and initiatives to disrupt gang activity are consistent with this legislative framework and Government guidance; in particular the statutory guidance Working Together to Safeguard Children (2018), and the Government’s Serious Violence Strategy published in 2018.

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____________________________________ Linked Reports, Appendices and Background Documents Linked Report

NONE Appendices

Appendix 1 – Gangs and Serious Youth Violence Scrutiny Review Report

Appendix 2 – Gangs and Serious Youth Violence Scrutiny Review Action Plan

Appendix 3 – Ofsted Monitoring Letter 25th May 2018 Background Documents – Local Authorities (Executive Arrangements)(Access to Information)(England) Regulations 2012

NONE Officer contact details for documents: N/A

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1

Gangs and Serious Youth Violence

Scrutiny Review Report

March 2018

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Chair’s Foreword

The safety and wellbeing of all residents in our borough is of paramount importance and so I was pleased to be able to lead this review into how we can better keep our young people away from violence and make Tower Hamlets a safer place for everyone. I am grateful to the wide contributions made to this review; by Council officers, partner agencies, fellow Councillors and most importantly the Young Mayor and Deputy Mayor. It is only right that we listen carefully and respond to the concerns of young people in our borough.

Following the Ofsted inspection of children’s services last year, it became clear that the work the Council and partners are doing needed to be further strengthened to ensure that we keep young people safe here. Since that time there have been improvements to our work in this area and this is most welcome. This review has helped to clarify what work still needs to be undertaken in relation to gangs and serious youth violence to ensure effective interventions to keep young people safe.

The review group has looked at the current work being done by the Council, partners and other agencies. We considered work undertaken by a number of different teams at the Council (social care, community safety and youth services). It is vital that this work is undertaken with strong partnerships both within the Council and with partners and residents in the community. Our responsibility is to provide effective, high quality service and interventions.

There was also a strong feeling that the approach of the Council in relation to gangs and youth violence should have the confidence of the local community and involve them in tackling this issue. Furthermore we should have a strong emphasis on listening to the views of young people and those who have been the victims of youth violence and their families.

Given the constraints of this work, it is inevitable that this review has not been able to explore all the areas that we might have wished. In particular further work needs to be undertaken to understand the effect of gangs and serious youth violence on women in the borough and services need to gain further insight into the lived experiences of young people in Tower Hamlets. This will ensure that we can achieve the ambition of making our borough a much safer place.

I hope that this report contributes strongly to the development of further work in this area.

Councillor Danny Hassell

March 2018

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Summary of Recommendations

Approach and Focus

Recommendation 1:Our approach to dealing with those involved in or victims of gangs and youth violence should consider the needs of the whole family and adopt a safeguarding approach.

Recommendation 2:The Council should develop a new Gangs and Youth Violence Strategy which reflects the concerns of the community and young people and has a strong focus on the voices of victims and of empowering the community.

Recommendation 3:Develop a more co-ordinated and holistic approach to address gangs and serious youth violence such as a wider ‘exploitation’ team. Recommendation 4:Our assessments of children entering the care system should more thoroughly consider the mental health needs, including an understanding of the specific impact of violence on their lives.

Recommendation 5:Ensure that there is funding and coordination that covers interventions for young people over the age of 18.

Analysis, Knowledge and Understanding

Recommendation 6:Undertake further analysis of the gangs profile in the borough. This should include, but not be limited to, the age, ethnic profile, education levels, disability and mental health needs of those involved.

Recommendation 7:Improve and develop our understanding of the impact of County Lines and Child Sexual Exploitation (CSE) on our looked after children who are placed outside of borough.

Recommendation 8:Further work needs to be undertaken to develop a more comprehensive understanding of impact on women as a result of gangs and gang activity in the borough, in particular Violence Against Women and Girls (VAWG). This should include the voices and experiences of those who have been victims of gangs and serious violence.

Communications, Joint-Working and Engagement

Recommendation 9:Current engagement with Job Centre Plus should be expanded to include the Council’s WorkPath as employment is considered an effective opportunity for gangs exit.

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Recommendation 10:Consider ways in which the risk and vulnerability of young people attending the London East Alternative Provision (LEAP) can be better understood and develop an effective support package for young people re-entering secondary school when moving from the LEAP.

Recommendation 11:Engage with schools and the police to better understand their policies around exclusions in relation to carrying knives and/or drugs.

Recommendation 12:Wider engagement should be undertaken with the local community and other stakeholders, including schools, faith groups and TRAs to increase an understanding of community concerns and how they might help contribute to our response.

Recommendation 13:Consideration should be given to whether the Council should lead on delivering a social care/youth worker presence in A&E, including the paediatric A&E at Royal London in order to support early identification and intervention of those involved in gangs or subject to exploitation by gangs.

Recommendation 14:The Council should work in partnership with the police in order to develop effective disruption activity in relation to gangs, drugs and CSE, ensuring that it utilises all of the tools and powers at its disposal. Training and Capacity Building

Recommendation 15:Current training being delivered to staff on gangs and serious youth violence should be offered to all staff, including agency staff in relevant roles and partner agencies in the future.

Recommendation 16:Instigate a programme of training for local residents, where appropriate, to act as community advocates.

Recommendation 17:Develop a peer led programme to raise awareness of risks and vulnerabilities and support peers through mentoring.

Recommendation 18:Ensure that there are effective, reflective supervisions for staff to ensure that they can raise sensitive issues in a supportive setting.

Recommendation 19:Provide training to youth workers in developing an understanding of youth courts and the youth justice system.

Recommendation 20:The Council and partners should offer a quality assured preventative programme to schools, in order to spot early warning signs and develop the resilience of young people.

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Introduction

1.1 Gangs and Youth Violence is a high profile issue not just locally but across the world. Although perception of gang related violence and offences often outweighs the actual number of incidents, there is an unacceptable level of gang activity within London and the London Borough of Tower Hamlets that needs addressing.

1.2 The Borough has a relatively high number of younger residents, an ethnically diverse population and high levels of deprivation. These are all factors that are frequently associated with gangs and related criminal and anti-social activity.

1.3 In 2017 the London Borough of Tower Hamlets underwent an Ofsted review of its Children’s Services and one of the recommendations that arose was that the Council should “Urgently improve the quality and timeliness of services for children who are at risk of becoming involved in gangs and serious youth violence. Ensure the alignment of those services with those for children who go missing and those who are vulnerable to sexual exploitation and radicalisation. Ensure that comprehensive and accurate intelligence and data inform service developments.”

1.4 Recognising the national and local context, the aim of this review was to explore the work of the authority and its partners in tackling the problems of Gangs and Youth Violence and its effects on victims, the local community and those involved.

1.5 The review was underpinned by three core questions:

a) What is the true scale and impact of Gangs and Youth Violence issue in the Tower Hamlets?

b) What are common factors that lead to involvement in Gangs?c) How can the Council and its partners work together more effectively to

reduce the impact of gangs in the borough and help young people avoid or exit gang involvement?

1.6 The review was chaired by Cllr Danny Hassell, Scrutiny Lead for Children’s Services over two sessions held in January and February 2018. The first session was held at the Town Hall and looked at current approach and practices, existing research and findings and examples of good practice being delivered in other areas. The second at Spotlight youth centre and looked at real-life case studies, feedback and findings from reviews and the work of key partners in the borough.

1.7 Other members of the review panel included;

Cllr Dave Chesterton Chair of Overview and Scrutiny CommitteeCllr Clare Harrisson Overview and Scrutiny Committee MemberCllr Rabina Khan Overview and Scrutiny Committee MemberCllr Shafi Ahmed Overview and Scrutiny Committee Member (Substitute)David Burbidge Co-opted member of the Health Scrutiny Committee

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1.8 Also in attendance for the review;

Fahimal Islam Young MayorShaiam Islam Deputy Young Mayor

1.9 The review was supported by;

William Tompsett Senior Strategy, Police and Performance Officer

1.10 The panel received evidence from members of the Executive, a range of officers and experts including;

London Borough of Tower Hamlets:

Cllr Amy Whitelock-Gibbs

Lead Member for Education and Children’s Services

Claire Belgard Interim Head of Integrated Youth and Community Services

Nikki Bradley Service Manager Youth Justice, Children’s Social care and Family Interventions

Debbie Jones Corporate Director, Children’s ServicesNancy Meehan Interim Divisional Director, Children’s Social Care

Adam Salmon Ending Gang, Group and Serious Youth Violence Coordinator

Paula Wilkinson Crime Reduction & Rapid Response Team Manager

Metropolitan Police:

Mike Hamer Deputy Chief InspectorSean Drislane Detective Inspector

External experts:

Maurice Mason Community Safety and Partnership Manager, London Borough of Hackney

John O’Shea Bow SchoolDaniel Rose Director of SpotlightKhalid Sugulle St Giles TrustJoe Williams Spotlight, Poplar HARCA

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2. National, Regional and Local Context

2.1 Although Gangs have a reputation for high level of crime and anti-social behaviour, reliable statistics and data are difficult to qualify and attribute. One major issue is that the definition of Gangs is constantly evolving. It is also an issue that crime data is not always directly connected to gang activity so a lot of the evidence is anecdotal or based on perception.

2.2 The current and generally accepted definition of a Gang is:

“A relatively durable, predominantly street-based group of young people who (1) see themselves (and are seen by others) as a discernible group, (2) engage in a range of criminal activity and violence, (3) identify with or lay claim over territory, (4) have some form of identifying structural feature, and (5) are in conflict with other, similar, gangs” - Hallsworth and Young1

2.3 The accepted definition has however become dated with gangs sometimes recognising the benefit of working together instead of in conflict and there being less evidence of being publicly identifiable through symbols, colours etc in order to reduce their visibility to the authorities.

2.4 There have been a large number of studies and reviews made into Gangs and youth Violence over the past looking at impact, factors for involvement, intervention activities and overall approach to understanding and tackling the issues.

2.5 A study of existing reports and published papers was made and presented to the Review Panel summarising the perceived key findings and common themes. Six documents were chosen for review offering different perspectives and highlighting varying aspects of gangs and youth violence. These were:

Dying to Belong - Centre for Social Justice, 2009 - https://www.centreforsocialjustice.org.uk/core/wp-content/uploads/2016/08/DyingtoBelongFullReport.pdf

Gang Prevention Programme - Waltham Forest, 2017 - http://democracy.walthamforest.gov.uk/documents/s55871/4a.%20Report%20on%20Waltham%20Forests%20Gang%20Prevention%20Programme.pdf

Preventing Gang and Youth Violence - Home Office, 2015 - http://www.eif.org.uk/wp-content/uploads/2015/11/Final-R1-Overview-Preventing-Gang-Youth-Violence.pdf

Children’s Voices - Children’s Commissioner, 2017 – https://www.childrenscommissioner.gov.uk/wp-content/uploads/2017/11/Childrens-Voices-A-review-of-evidence-on-the-subjective-wellbeing-of-children-involved-in-gangs-in-England-2.pdf

What Works to Prevent Gang Involvement, Youth Violence and Crime – Home Office, 2015 –

1 Dying to Belong, Centre for Social Justice, 2009 - https://www.centreforsocialjustice.org.uk/core/wp-content/uploads/2016/08/DyingtoBelongFullReport.pdf

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https://www.centreforsocialjustice.org.uk/core/wp-content/uploads/2016/08/DyingtoBelongFullReport.pdf


http://democracy.walthamforest.gov.uk/documents/s55871/4a.%20Report%20on%20Waltham%20Forests%20Gang%20Prevention%20Programme.pdf



http://www.eif.org.uk/wp-content/uploads/2015/11/Final-R1-Overview-Preventing-Gang-Youth-Violence.pdf

http://www.eif.org.uk/wp-content/uploads/2015/11/Final-R1-Overview-Preventing-Gang-Youth-Violence.pdf

https://www.childrenscommissioner.gov.uk/wp-content/uploads/2017/11/Childrens-Voices-A-review-of-evidence-on-the-subjective-wellbeing-of-children-involved-in-gangs-in-England-2.pdf






8

http://www.eif.org.uk/wp-content/uploads/2015/11/Final-R2-WW-Prevent-Gang-Youth-Violence-final.pdf

Female Voice in Violence – Race On The Agenda (ROTA), 2011 - http://www.rota.org.uk/content/rota-march-2011-female-voice-violence-project-final-report-it-my-life

2.6 It was agreed that there are common themes identifiable from these studies/reports that should be kept in mind in developing future initiatives and approach.

Social and economic triggers Family background Education Strong link to drugs Cross-boundary activities Perceived status and lack of options/opportunities Need for joined up working on early prevention and enabling exit

2.7 It was also noted that there is a definite need for quality information to be shared and used effectively in a joined up approach across services and geographical boundaries. Also, a balanced approach between safeguarding and enforcement, recognising the vulnerability of those involved is essential.

Trident Command Risk Matrix

2.8 Across London, the Trident Command Risk Matrix is used to identify and rank gang members and their propensity to perpetrate violence. It is the primary tool used to identify whether or not a young person is a member of a gang. Locally, matrix is managed by the police with input and consultation from partner organisations.

2.9 Decisions to remove individuals from the gangs matrix are jointly made by the police and partners and support is offered by the Youth Offending Team ad St Giles Trust where possible to those coming off the matrix.

2.10 According to the matrix, at the time of the review there were 3,495 gang members and 250 gangs in London. 70% of these members were aged 17-23 years old and two thirds of these members had also been victims of crime themselves. 97.8% of these members were male and 77.6% were identified as BAME.

2.11 The Mayor’s Office for Policing and Crime (MOPAC) 2manage a Gangs Dashboard showing the scale of gang flagged crime and perception of gangs as an issue for all boroughs. Figure 1

2 MOPAC Gangs dashboard https://www.london.gov.uk/what-we-do/mayors-office-policing-and-crime-mopac/data-and-statistics/crime%20/gangs-dashboard

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http://www.rota.org.uk/content/rota-march-2011-female-voice-violence-project-final-report-it-my-life


https://www.london.gov.uk/what-we-do/mayors-office-policing-and-crime-mopac/data-and-statistics/crime%20/gangs-dashboard

https://www.london.gov.uk/what-we-do/mayors-office-policing-and-crime-mopac/data-and-statistics/crime%20/gangs-dashboard

9

Figure 1

2.12 The London Borough of Tower Hamlets currently has 8 identifiable gangs with a total of 73 nominals on the matrix (down from 119 over the past year). The local profile is one of the youngest of all London boroughs. Gang-flagged offences have reduced from 220 to just 45 since January 2016 and knife crime has remained relatively stable despite considerable increases in all other areas of London.

2.13 There are very strong links between gangs and the local drug trade with Tower Hamlets having the highest number of known heroin and crack cocaine users in London. Many young people are lured into drug-dealing for gangs by the promise of status and money or through bullying and coercion. Once part of the system, threats of violence against them and their families are used to keep them under control of the gang leaders and make it seem impossible to leave or approach agencies for help.

Co-Offending Groups

2.14 Co-Offending Groups (COGs) is a term adopted to refer to young people who may not be on the gangs matrix (either due to lack of evidence linking them to a specific gang or not having committed a serious violent offence) but who are affected by or at risk of involvement. The COG panel works in alignment with the Youth Offending Team and currently focuses on young people up to the age of 18 years old to identify and offer support and intervention activities. There are plans to expand the remit to include a wider age-range up to 25 and include habitual knife carriers.

2.15 COG partners work closely with schools, St Giles Trust and the Schools Police Officer. There is also a Youth Advisory Group setting up to work within Spotlight.

2.16 Gangs Awareness Training is being delivered to Tower Hamlets Social Workers to build understanding and awareness in direct response to the Ofsted report. This training is mandatory and the possibility of expanding access to other agencies and parents is being considered.

2.17 There are a number of local support structures in place and available to young people to help avoid and exit gang involvement. These include:

Youth Offending team

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Police Gangs Team Youth Services Children’s Social Care St Giles COG Intervention/SOS Services St Giles MTU Services (at the Royal London Hospital) Schools and London East Alternative Provision Voluntary and Community Services

County Lines

2.18 One of the growing areas of concern involving London Gangs is County Lines. This represents a move from the more saturated and violently competed drug market in the capital to enter drug markets of smaller towns outside of London, especially around the south coast.

2.19 Gangs often use young children to transport drugs and set up distribution and safe houses through coercion and human trafficking with a known link in some areas with looked after children.

2.20 County Lines presents a number of issues for enforcement agencies as most of the offences take place outside of London and the borough. Local police resources are limited and focused on reducing crime committed within the borough. Police outside of London often have difficulty identifying where to refer offenders back to. Previously, the young people being forced to transport the drugs have had little protection and were treated as the offenders whereas recent laws on human trafficking have enabled them to be treated as victims with the focus shifting to focus on identifying and stopping the organisers.

2.21 The Mayor’s Office for Policing And Crime (MOPAC) are funding a £3million County Lines project to provide a single point of contact for London for regional police and agencies to refer children and young people back to, shared mapping of data across the capital and to support rescue and support services supplied by St Giles Trust.

Youth Services

2.22 The majority of the Youth Services at Tower Hamlets is an open access universal service, not primarily in place to address gangs. However, it is recognised that this is a relatively well resourced borough with protective factors such as access to positive activities, peer networks and adult role models. Preventative measures that are in place include access to safe spaces outside of school and the family.

2.23 Youth Services is a frontline community resource, well placed to work with local partners to address issues. They are also able to deliver outreach and work to address local problems.

2.24 A review carried out during 2016 highlighted poor/declining performance in the area and a relatively poor reputation. The offer from the services was considered dated with poor quality venues and a disjointed delivery that was not understood by young people.

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2.25 The service has since been redesigned and relaunched in February 2018 with the following improvements made:

Better quality hub venues, open for longer Increased hours for front lone staff and more full time front line staff –

able to plan, train and work more with communities Mixed economy of delivery and commissioning Significant investment in buildings and on-going investment in ICT and

marketing New outcomes framework New branding and uniforms

2.26 There are now 8 directly delivered hubs open from 3.30 -9pm and 10 commissioned hubs opening 15 hours per week. These hubs offer:

A safe place for young people to meet friends Structured positive activities – sports, games, arts, music, informal

education Information, advice and guidance – health, relationships, education

and employment Facilities – ICT suite, training kitchen, hair salon, chill out space,

dance studio, music studio, sports hall, climbing wall. Gym and football pitches

Individual assessment, intervention plan and signposting or onward referral

2.27 The Early Help and Transitions work of Youth Services offer referral through the Early Help Hub or Social Inclusion Panel. Early Help assessment considers the whole family unit and the team offer specialist experience with young people “Not in Education, Employment or Training” (NEET), Child Sexual Exploitation (CSE), Prevent and Gangs. They work with Children’s Social Care, edge of care and early help services such as parenting support.

Rapid Response Team

2.28 Tower Hamlets as an Inner London borough has challenges in key crime types, notably those linked to the workforce of drug markets and drug lines. These can include violent crimes and exploitation. The age range of the drug line workforce both inside and outside of London is usually varied, early teens through to middle aged people at the top responsible for importing drugs and weapons. Some have extensive criminal histories that began in their early teens.

2.29 Young adults known as “Olders” recruit younger people to distribute drugs including trafficking them within and outside of London. Olders use power and coercive control including grooming and exploitation techniques which are also evident in other forms of abuse such as domestic violence, child sexual exploitation or radicalisation to control their workers.

2.30 In the borough, visible drug dealing and monetary exchanges are evident despite CCTV cameras. Drug markets are also visible along the DLR and Overground transport routes which provide opportunities for customers to travel in, pick up their supply and continue with their journey.

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2.31 People susceptible to being groomed can have limited critical thinking skills, inadequate education, additional educational and mental health needs, food poverty, lack of capable guardians and a negative perception of gaining legitimate employment opportunities.

2.32 The Rapid Response Team (RRT) work in conjunction with internal and external partners in specific geographical locations to decrease crime and antisocial behaviour. They attend operational and community safety, crime and anti-social behaviour problem solving meetings to deploy services as appropriate to reduce crime and anti-social behaviour.

2.33 RRT gathers and shares community information with partners and ensures younger residents’ views are heard by professional to inform working practices. They make use of social media such as WhatsApp to be able to understand community tensions and provide information about risks to police and Council colleagues. The deployment of RRT teams allows them to respond to immediate or emerging community tensions by operating street-based outreach in community settings. They keep in regular contact with the borough control room and feed back to groups like the Tension Monitoring or Gold Groups.

2.34 Detached workers are deployed to areas experiencing crime and anti-social behaviour to reduce opportunities of people becoming victims and or perpetrators of crime or anti-social behaviour including:

Violent crimes – knife crimes and gang associated violence

Violence against women and girls – repeat victimisation and/or exploitation

Community resilience against hate crimes and exploitation by extremists

2.35 RRT, police and other partners deliver a joint response, for example through home visits, Estate Awareness Days, Community Safety Walkabouts, Weapon Sweeps, programme delivery and use of resources in the area. The RRT mobile units provide medium to long-term (up to 12 weeks) tailored group sessions in accordance with identified risk and individual needs to ensure safe exit from offending and exploitation.

2.36 Based on identified needs, RRT provides outcome-focused interventions around learning, life skills and employment. These are designed using community information gathered through foot deployment and the mobile units. Young people vulnerable to being exploited can be identified by the school/Pupil Referral Unit as being at risk pf exploitation and grooming by peers and/or older gang members and the RRT can promote specialist support services and refer young people when needed.

2.37 RRT are coordinating a pan-borough monthly outreach meeting with internal partners and local third sector partners to promote collaborative working, manage risk and coordinated work with victims and their families. This meeting links in with Child and Adult Social Care and other meetings arranged by police colleagues

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2.38 In December 2017, RRT received comprehensive training from “Crying Son’s”, an organisation with a track record of training frontline police officers on how to understand and identify violence, vulnerability and exploitation attributed to drugs and county lines. This was followed by scenario training designed to increase practitioner implementation of risk management operational plans, in line with statutory safeguarding responsibilities and information sharing protocols. Both sessions are being repeated in March 2018 for a wider audience including Social Workers and third sector provision. It is hoped that this will build capacity in the borough.

2.39 In January 2018 the Safer London Foundation delivered Empower training focussing on Child Sexual Exploitation. The team are now working with St Giles Trust in relation to accredited NVQ Level 3 Key Working with young adults who are outside of mainstream services. RRT work in partnership with the Department for Work and Pensions (DWP) Hackney and Tower Hamlets Gangs lead. DWP have developed this as a specialised area taking into account risk and clients being ‘job ready.’ There are implications to parent benefit entitlement for Housing and Council Tax for non-dependent children and young adults over 18 and living at home. RRT coordinate liaison with DWP and clients to resolve these issues.

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3. The Hackney Model

3.1 The Community Safety Partnership Manager from the London Borough of Hackney presented the model and approach they have adopted.

3.2 Hackney’s strategic priorities are focused on reducing violence and serious violent offences with their gang violence being recognised as a particular issue. Hackney has set up an Integrated Gangs Unit (IGU) made up of the Youth Offending Team, Probation, Victim Support, Police, St Giles Trust and a dedicated analyst all working together. The IGU have responsibility for managing their Gangs matrix and hold monthly tasking meetings looking at dynamic evidence. Having these different agencies working together in the same location encourages greater information sharing and a co-ordinated approach to delivering strategic and operational activity.

3.3 The IGU also hold weekly tasking process meetings which enables them to react quickly to new incidents and changes, They are closely aligned to internal Council based resources such as Trading Standards and parks teams to share information. There is currently a focus on developing stronger working relationships with head teachers to share information on matters such as knife seizures as well as to improve access to mentoring for young people.

3.4 Hackney currently have 20 active gangs and around 150 gang members on their matrix. They have become particularly aware recently of the emergence of online activity which leads to greater involvement between gangs. However, most of their recent conflict and violence is being caused by existing gangs moving their operations out of the area and leaving a power struggle between rival groups. They also have a profile of older victims but younger gang members.

3.5 Hackney focuses their gang related activity around three themes – Enforcement, Diversion and Prevention. There is an acceptance that there is no single activity that can fully tackle the issue and impact of gangs on its own so a combination of measures are in place including intelligence lead “Stop and Search” with the support of the local community.

3.6 Resources are continually becoming more limited and the need for realignment rather than increase is vital. Community policing is an area that Hackney have looked at refocussing alongside working with St Giles Trust and a scheme called Mentivation to deliver engagement with young people and promote involvement in positive activities including music and sport with the help of strong positive role models.

3.7 Empowering families and the local community has been a strong theme with training being provided for parent advocates through the Parents’ Voice group and the support of a Borough Unite conference organised by the local community. The Community Safety Partnership also works closely with Empower Safer London to promote child safety and tackle exploitation.

3.8 Hackney have been successful in securing funding for safeguarding and neighbourhood working which will be used to focus on those at risk of involvement with gangs rather than those already on the matrix. Co-production is a strong theme going forward with the Community and Voluntary

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Service bidding for funding to train parents and peers as mentors and to work closely with the local Faith Forum.

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4. Partner Examples

4.1 Two partnership organisations were specifically featured during the review process.

Spotlight

4.2 Set up by Poplar HARCA, Spotlight is a youth focused facility whose vision is to create a place where young people could think creatively, gain confidence and pursue opportunities they may not have thought possible.

4.3 Opened in 2014, Spotlight was created in response to local young people saying they had nowhere to go that was just for them. The design and offer was based on research conducted by young people with over 200 respondents and secured £4million in funding.

4.4 Since opening, Spotlight has engaged nearly 6,000 young people of which 42% are female. The success in serving such a relatively high proportion of female users has been attributed to a mixture of offering safe and secure facilities, female focussed activities and plenty of female staff. There is also a balance between mixed use and female only spaces and services. There have been over 100,000 attendances in the various activities offered with a programme based around the three themes of Get Creative, Get Active and Get Inspired.

4.5 According to the Metropolitan Police’s Annual Crime Count, Lansbury Ward saw a 40% reduction in all crimes from 1,153 incidents in 2013 to 693 in 2015. This is significantly higher than the 18% reduction recorded for the whole borough and most wards went down by 17-20% during the same period. This coincides with the opening and development of spotlight and it’s positive work with young people.

4.6 As well as activities, Spotlight also offer access to specialist support to young people suffering from mental health issues, child sexual exploitation and drug and alcohol abuse all within a safe and non-threatening environment. They are also developing programmes of leadership including Youth Committee, Spotlight reps and Community Heroes.

4.7 Spotlight is now commissioned by the local authority to deliver a youth service contract covering a third of all youth service in the borough. They have expanded to deliver across 6 centres, 5 nights a week and engaging an additional 2,400 per year. They have also extended the target age range including in Poplar and Mile End through detached and late night centre based activities.

4.8 Poplar HARCA are fully aware of high levels of youth violence and tension/frustration in the local area and, wherever possible, look to find methods of resolution including mediation provided by youth workers from Spotlight. However, their housing management situation does allow for “last resort” options of evictions should they be needed.

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4.9 For more information on Spotlight and the services they offer their website can be found at https://wearespotlight.com/.

St Giles Trust

4.10 St Giles Trust work with a number of authorities and agencies across London and further afield to provide a number of programmes that help young people who are either involved with or at risk from gangs.

4.11 Their SOS Project offers intensive help to young people exposed to or at risk of violence, vulnerability and exploitation. The work encompasses gangs work and family support as well as child exploitation and human trafficking.

4.12 In addition, the SOS+ Programme prevents disadvantaged young people becoming involved in gang crime and serious youth violence. It offers interactive sessions in schools, pupil referral units and colleges which offer practical tools and knowledge to young people on how to steer clear from violence and crime.

4.13 St Giles also work in The Royal London Hospital’s Major Trauma Centre in Whitechapel, East London, to offer intensive support to young people who have been admitted as victims of serious youth violence and sexual violence.

4.14 One of the strengths of St Giles Trust is that they are considered “experts by experience” in that the workers who provide support and advice to young people have first-hand experience of the situations they are talking about. The young people the work with can relate to the workers through shared experiences and language.

4.15 For more information on the work of St Giles Trust visit their website at https://www.stgilestrust.org.uk/.

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5. Approach and Focus

5.1 The underpinning aim of the Tower Hamlets Ending Gangs, Group and Serious Youth Violence Strategy 2015-18 is to reduce the harm caused by gang, group and serious youth violence in the borough and its associated forms of abuse. The work is guided by the following key principles based on prevention, intervention and enforcement:

The authority and its partners will not tolerate gang, group and serious youth violence and its associated abuse in Tower Hamlets

Our work will be underpinned by a safeguarding approach Young people (and families) who are at risk of involvement in gang, group

and serious youth violence and the associated forms of abuse will be offered targeted interventions at the earliest point to discourage involvement with support from the appropriate partners

If young people (or families) continue to engage in gang, group and serious youth violence the partnership will use all the enforcement options available, while continuing to offer support with appropriate interventions

The partnership makes a strong commitment to data and intelligence sharing to reduce the harm caused by gang, group and serious youth violence and its associated forms of abuse.

5.2 Findings throughout the review and in existing reports and case studies all highlight the importance of understanding and supporting the needs of the family and young people caught up in gangs and youth violence. The psychological and physical impact of threats of violence and sexual violence against individuals and family members pose a significant risk to all involved.

5.3 Many of the young people involved in gangs are not doing so out of choice but through fear of violence and retribution. Protection for them and their families need to be built in to any strategy or activity to help facilitate gang exit or diversion.

5.4 The current Ending Gang, Group and Serious Youth Violence Strategy runs to 2018 and is based on historic data and evidence. The Gangs situation has evolved since the strategy was adopted in 2015 with greater understanding and intelligence available to help shape improvement and service delivery.

5.5 The delivery of the 2015-2018 Strategy has led to a greater understanding of key issues and a more integrated partnership approach involving the Council, police and key community partners including the commissioning of St Giles Trust and Spotlight.

5.6 The model of Hackney’s Integrated Gangs Unit reinforces the benefit of developing a strong joined-up strategic approach to tackling Gangs and Youth Violence. The Council should look to ensure its new strategy is co-produced with partners and the community to strengthen delivery of priorities.

RECOMMENDATION 1:

Our approach to dealing with those involved in or victims of gangs and youth violence should consider the needs of the whole family and adopt a safeguarding approach.

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RECOMMENDATION 2:

The Council should develop a new Gangs and Youth Violence Strategy which reflects the concerns of the community and young people and has a strong focus on the voices of victims and of empowering the community.

5.7 Historically, tackling gangs and their impact on the local community has been viewed primarily as an enforcement issue. However, it is now universally agreed that many of those involved with gangs are themselves victims of abuse in many forms too. Also the nature of gangs is more complex than public perception so activity needs to be delivered in a way to support those involved or at risk to make positive life choices and have the confidence to move away from the gangs.

5.8 Additionally, the wider issues of exploitation, violence and the factors leading to gang involvement make a multi-agency and multi-disciplinary approach necessary in order to develop effective and holistic responses to this issue. Hackney’s example of an Integrated Gangs Unit bringing together multiple agencies within one team has proved to be a successful approach.

5.9 The issue of County Lines (see 2.18), its direct relation to gang activity and its cross-boundary and multi-issue nature highlight how complex the subject of gangs and youth violence is. The Mayor’s Office for Policing and Crime (MOPAC) is funding development work in this area to help provide more detailed intelligence and information sharing to enable the police, local authorities and partners to address the wider issues more effectively.

5.10 The Troubled Lives, Tragic Consequences3 thematic review conducted in 2014 highlighted the need to be aware of and understand the importance of the life experiences of young people brought to the attention of Children’s Services. This includes violence and other forms of abuse they may have suffered from peers, social groups or families. The impact of these experiences over time played a significant role in the behaviour and life choices of the individuals in the review and it is understood that identifying and challenging these at an earlier stage may have led to more effective interventions.

5.11 The review concluded that a greater understanding educational, mental health and disability needs of young people and their links to potential gang

3 http://www.childrenandfamiliestrust.co.uk/wp-content/uploads/2015/12/Troubled-Lives-Summary-Report-Final1.pdf

RECOMMENDATION 3:

Develop a more co-ordinated and holistic approach to address gangs and serious youth violence such as a wider ‘exploitation’ team.

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involvement was needed in order to help early identification of vulnerable young people and more effective delivery of intervention work.

5.12 Gang involvement is spread across a wide age range and although Children’s Services and associated agencies are focussed on supporting and working with under 18 year olds, it is recognised that many vulnerable young adults involved with gangs and violence have lower educational and emotional ages and are equally at risk.

5.13 By concentrating efforts on young people, the Council and partners have managed to reduce the number and proportion of under 18s on the Gangs Matrix. Figure 2

Figure 2

Current Matrix Matrix A Year Ago

Age Number % Number %13 0 0.0 2 1.514 0 0.0 4 3.115 2 2.6 7 5.316 4 5.2 8 6.117 6 7.8 19 14.518 10 13.0 11 8.419 11 14.3 19 14.520 7 9.1 9 6.921 4 5.2 11 8.422-25 26 33.8 26 19.826-35 7 9.1 15 11.513-17 12 15.6 40 30.513-18 22 28.6 51 38.918+ 65 84.4 91 69.5Over 18s 55 71.4 80 61.1

Total 77 100.0 131 100.0

5.14 Some partner agencies are already extending their support work to include young adults and the Council’s Rapid Response Team is transitioning to be able to work with a wider age range. There is already coordinated work underway with Department for Work and Pensions (see 2.39). However, resources are limited and in order to offer services and support to a wider group, sourcing and securing additional funding is vital.

RECOMMENDATION 4:

Our assessments of children entering the care system should more thoroughly consider the mental health needs, including an understanding of the specific impact of violence on their lives.

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RECOMMENDATION 5:

Ensure that there is funding and coordination that covers interventions for young people over the age of 18.

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6. Analysis, Knowledge and Understanding

6.1 One of the key issues facing Tower Hamlets in its work with gangs and youth violence is the shortage of data and information currently available. In order to provide more robust intelligence in order to better focus resources, it is considered vital that dedicated analytical staff are in place and able to source, interpret and disseminate data effectively.

6.2 Although it is generally accepted that the local gang profile is predominantly male and matching the local ethnic population mix, there is not a full set of data to confirm this in detail. There are also currently gaps in information regarding the mental health needs of youths involved with gang activity and the possible scale of child exploitation that is usually linked to gangs.

6.3 County Lines has quickly become a significant national issue but due to its cross-boundary nature it has been difficult to collect meaningful data and build up a full profile of its impact. Similarly, it is known that vulnerable young people are being used and exploited by older people involved in criminality in order to facilitate the drug trade in this way but increased research and data sharing with other authorities and police outside of the borough would enable a more detailed picture of the impact on looked after children placed outside of the borough in particular.

6.4 Much of the focus of gangs and youth violence is on the male perpetrators and victims as these are the significant majority. However, studies show that there is a significant impact on females either through direct involvement with gangs and gang members or through family involvement.

6.5 The threat of physical, emotional and sexual violence against women from gangs was made evident in the Race On The Agenda study Female Voice in Violence4 highlighting child protection and safeguarding issues, a lack of confidence in traditional support services, the need for national and local responses and the need to address attitudes of boys and men towards

4 http://www.rota.org.uk/content/rota-march-2011-female-voice-violence-project-final-report-it-my-life

RECOMMENDATION 6:

Undertake further analysis of the gangs profile in the borough. This should include, but not be limited to, the age, ethnic profile, education levels, disability and mental health needs of those involved.

RECOMMENDATION 7:

Improve and develop our understanding of the impact of County Lines and Child Sexual Exploitation (CSE) on our looked after children who are placed outside of borough.

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females. The improvement of local knowledge around the impact of gangs on females would enable strengthening the protection and support that can be targeted to this group.

RECOMMENDATION 8:

Further work needs to be undertaken to develop a more comprehensive understanding of impact on women as a result of gangs and gang activity in the borough, in particular Violence Against Women and Girls (VAWG). This should include the voices and experiences of those who have been victims of gangs and serious violence.

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7. Communications, Joint Working and Engagement

7.1 It has been noted that one major cause for gang involvement is the perceived lack of opportunity for success through legitimate work. Local young people who either struggle through the traditional education system or perceive cultural stereotyping to limit their choices can be vulnerable to promises of status and money obtainable through gangs involvement.

7.2 Similarly, young people who have been caught up in gangs often believe that they will not be given opportunities to find work and because of their past and so feel trapped in gangs and criminal activity in order to maintain an income and support themselves or their family.

7.3 Providing positive options for employment and training will give those wishing to avoid or leave gangs with the means to support their choice.

7.4 The work of London East Alternative Provision (LEAP - formerly the Pupil Referral Unit) to support young people outside of the traditional school system is an important and valued resource. The opportunities offered and support offered there are of a high standard however there is potentially a challenge for young people who move back into the school system to readjust and settle.

7.5 The LEAP currently takes pupils from 17 schools located across both borough and city with the proportion of pupils with minority ethnic backgrounds, English as a second language and special educational needs and/or disabilities (SEND) being above the national average.

7.6 In order to ease the transition back into schools and provide the best opportunity for young people to succeed, it is important to understand their individual needs and offer tailored support to suit them.

7.7 During the review, it was recognised that there was a perceived understanding that all schools maintained a zero-tolerance policy regarding carrying drugs and knives that would lead to automatic exclusion. It was felt that such a policy could be detrimental to the development and education of the young person involved, potentially forcing them into more negative life choices.

RECOMMENDATION 9:

Current engagement with Job Centre Plus should be expanded to include the Council’s WorkPath as employment is considered an effective opportunity for gangs exit.

RECOMMENDATION 10:

Consider ways in which the risk and vulnerability of young people attending the London East Alternative Provision (LEAP) can be better understood and develop an effective support package for young people re-entering secondary school when moving from the LEAP.

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7.8 This was proved to not be a universal policy and further investigation has been recommended to understand the policy of local schools in this matter in order to provide a joined up approach to supporting young people in education.

RECOMMENDATION 11:

Engage with schools and the police to better understand their policies around exclusions in relation to carrying knives and/or drugs.

7.9 A common theme that arose throughout the review was the need for greater involvement, engagement and support for the local community in empowering them in tackling gangs and youth violence or the circumstances that lead to this.

7.10 Faith groups, families, schools and resident associations all offer a local knowledge and are community stakeholders that can provide peer support and challenge in ways that may be more readily accepted than the police and local authority.

7.11 There have been good examples in the past of family based intervention and mediation work carried out within the community and local youth workers operating out of Spotlight show the benefit of positive peer role models.

RECOMMENDATION 12:

Wider engagement should be undertaken with the local community and other stakeholders, including schools, faith groups and TRAs to increase an understanding of community concerns and how they might help contribute to our response.

7.12 Many victims of youth violence who end up in hospital are still unwilling to give details of what they have been through to the police or authorities due to the fear they have of what might happen to them or their families. Also, the presentation of young people with certain conditions may help to identify those at risk of exploitation as a result of gang activity. It is believed that the placement of social care/youth workers with A&E departments would enable trained professionals to spot potential victims of gang and youth violence and provide specialist support where it is most needed.

7.13 In addition to the work done by St Giles Trust, the Rapid Response Team are due to recruit a new A&E Coordinator post to engage with victims of violence at the Royal London Hospital who receive treatment and are discharged.

7.14 St Giles Trust currently deliver a service with 2 caseworkers embedded in the Major Trauma Centre of Royal London Hospital offer support to young people who are admitted as a result of serious youth violence and sexual violence. When young people are referred to them by the hospital staff, they assess their needs then support them whilst they are still in hospital, on discharge and offer follow up services in the community to help them stay safe and reduce the likelihood of future admissions. Usually, this involves helping the young person find a safe place to stay as returning to their home area can often have risks of reprisals. Once the young person’s situation is stabilised,

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we will help them engage with services offering support around education, skills and training.

RECOMMENDATION 13:

Consideration should be given to whether the Council should lead on delivering a social care/youth worker presence in A&E, including the paediatric A&E at Royal London in order to support early identification and intervention of those involved in gangs or subject to exploitation by gangs.

7.15 Disruption activity forms a strong method of deterrent for gangs by making it harder for them to conduct their business. The visibility of police and other agencies on the street pro-actively tackling gangs and youth violence also serves to reassure local residents and manage the perception of crime and community safety.

7.16 The review was informed of activities such as intelligence led use of Stop and Search and vehicle searches had been effective in this and other boroughs and the coordinated focusing of police and Council resources in this area would help manage level of incidents. Whilst the Council have a role to play in this area, the work must be led by the police who have the tools and powers to undertake this.

RECOMMENDATION 14:

The Council should work in partnership with the police in order to develop effective disruption activity in relation to gangs, drugs and CSE, ensuring that it utilises all of the tools and powers at its disposal.

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8. Training and Capacity Building

8.1 Tower Hamlets has recently rolled out mandatory training for its social work staff around gangs and youth violence in order to build resilience in this area. In order to provide a joined up and informed approach across the Council, it was felt that it would be beneficial to offer this training to staff in different departments and relevant agency staff.

RECOMMENDATION 15:

Current training being delivered to staff on gangs and serious youth violence should be offered to all staff, including agency staff in relevant roles and partner agencies in the future.

8.2 Training local families and community members to identify and help resolve issues within the local areas was seen as a key factor to empowering communities to tackle anti-social behaviour and neighbourhood problems. This has been used as a method for improving pride of place within other boroughs.

8.3 It was felt that many issues could be dealt with more effectively and less confrontationally if local people were trained to act as mediators and advocates rather than involving the local authority, police or other agencies that could be seen as more threatening or less approachable.

RECOMMENDATION 16:

Instigate a programme of training for local residents, where appropriate, to act as community advocates.

8.4 One comment made during the review was that “young people should be part of the solution”. It was also pointed out that positive role models from within the young people’s peer groups had had a significant impact on life choices.

8.5 Hackney have made a point of bidding for funding to offer training and support for young people to act as mentors as this is seen as an effective way to counteract the negative influences of gang members and groomers sending out influencing messages to recruit new members.

RECOMMENDATION 17:

Develop a peer led programme to raise awareness of risks and vulnerabilities and support peers through mentoring.

8.6 One area highlighted through case studies and the Troubled Lives, Tragic Consequences5 review in particular was the difficulty some staff had in challenging difficult or sensitive concerns particularly around cultural and family issues. Although this has improved significantly since the review, ongoing development and support is needed to ensure all staff feel

5 http://www.childrenandfamiliestrust.co.uk/wp-content/uploads/2015/12/Troubled-Lives-Summary-Report-Final1.pdf

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comfortable in raising concerns such as these, putting the safety of young people first.

RECOMMENDATION 18:

Ensure that there are effective, reflective supervisions for staff to ensure that they can raise sensitive issues in a supportive setting.

8.7 It was raised at the review that there was a lack of understanding amongst many young people of the youth justice system and the consequences of certain actions and activities. In particular, it was noted that quite often young people when arrested were being advised not to answer police questions during interviews which proved to be detrimental to their case overall.

8.8 In order to offer accessible support to young people at risk of involvement with the youth court and youth justice system, youth workers should be familiar with the general processes in order to offer meaningful advice and guidance. An offer was made for Spotlight’s youth workers to visit the youth court and receive training in this area.

RECOMMENDATION 19:

Provide training to youth workers in developing an understanding of youth courts and the youth justice system.

8.9 Case studies presented to the review highlighted where some young people had been evidencing signs of concern through their behaviour and actions that had not been picked up by their families or schools. Awareness in this area has improved but a coordinated and robust programme delivered in partnership with schools, the local authority and partners would help strengthen this key area further.

8.10 There is also a general acknowledgement that many vulnerable young people are not aware of their own vulnerability or feel able to make informed choices. It was considered appropriate that greater training in critical and consequential thinking was to be provided in schools particularly for those who may be at risk from gang influence, exploitation and grooming.

RECOMMENDATION 20:

The Council and partners should offer a quality assured preventative programme to schools, in order to spot early warning signs and develop the resilience of young people.

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Appendix 2 Gangs and Serious Youth Violence Scrutiny Review Action Plan

Recommendation 1: Our approach to dealing with those involved in or victims of gangs and youth violence should consider the needs of the whole family and adopt a safeguarding approach. This would be assisted by ensuring that current training being delivered to staff on gangs and serious youth violence is offered to all staff, including agency staff in relevant roles (recommendation 15) and that training is delivered to youth workers to develop an understanding of youth courts and the youth justice system (recommendation 19). Additionally, in order to best support staff who work in these areas, we need to ensure that there are effective, reflective supervisions in place to ensure that they can raise sensitive issues in a supportive setting (recommendation 18).

Comments from Service: The Multi-Agency Exploitation Team has been in place since May 2018. The team is comprised of a number of specialist police officers in the areas of exploitation, CSE, Missing Children, Gangs and Youth Offending. Police Officers sit alongside the Missing, Gangs & Child Sexual Exploitation Coordinators from Children‟s Social Care. The strong commitment from both the police and Children‟s Social Care has led to a focus on disruption of perpetrators and a focus on criminally exploited children, including those involved in gang and drug distribution activity as victims. While the Exploitation Team focuses on those children most at risk, the ethos and expertise has permeated into all other teams within social care. Ofsted noted in May 2018, “A renewed focus on children as victims of exploitation rather than the criminalising of their behaviour is leading to an enhanced understanding of their circumstances and analysis of risk. Social workers now have a better understanding of children’s lived experience. Together with partner agencies, they are increasingly diligent in their attempts to work with and support these young people and their brothers and sisters.” Gangs Awareness Training with St Giles has been delivered to professionals, with more sessions booked on an ongoing basis. Adult Social Care is in the final stages of developing a Critical Thinking Skills training package for its social workers, which is being looked at as an additional tool for Social Workers in Children‟s Social Care to reinforce the application of learning and insights from the gangs awareness training and instill greater confidence in the application of the workforces‟ established social work skills in relation to this particularly challenging area of work. The resources that the Youth Justice Team use with young people explain the various orders that youth courts can give them, rather than explaining the court process itself, they also require updating. The YJS can (update these and) make them available, but to deliver the original proposal that these be adapted to create an online self-taught module youth workers can use to inform themselves about youth courts and the youth justice system, someone will have to be identified with the necessary skills and resources to convert these into an online resource. The youth service has a commitment in the service plan 2018-19 to deliver this

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training for staff. Recruitment to key posts was completed over the summer and the training plan is being reviewed by the new Head of Service. Further training is available from the youth justice board on-line learning platform.

Actions Responsible Officer Deadline

To ensure that a safeguarding approach is embedded within work around gang members and victims, taking into account the needs of the whole family

DD Children‟s Social Care

Ongoing

Increase participation on training currently being delivered to staff DD Children‟s Social Care

Ongoing

Identify whether there is capacity within the Youth Justice team to update resources and upload online

DD Youth & Commissioning

April 2019

Deliver training to youth workers DD Youth & Commissioning

April 2019

Staff supervisions to be reviewed to ensure they meet the needs of staff DD HR & DD Children‟s Social Care

July 2019

Recommendation 2: The council should develop a new Gangs Strategy which reflects the concerns of the community and young people and has a strong focus on the voices of victims and of empowering the community. This would complement recommendation 8, which asked that further work was undertaken to develop a more comprehensive understanding of impact on women as a result of gangs and gang activity in the borough, in particular Violence Against Women and Girls (VAWG). This should include the voices and experiences of those who have been victims of gangs and serious violence. Both approaches should involve wider engagement with the local community and other stakeholders, including schools, faith groups and TRAs to increase an understanding of community concerns and how they might help contribute to our response (recommendation 12).

Comments from Service: The refreshed strategy will be entitled “Violence, Vulnerability and Exploitation” in recognition of the wider impact on gangs and the exploitation of young people related to gang activity. Work has already commenced with a number of meetings held with key stakeholders to look at the scope and direction of the strategy. The strategy will be governed by the Community Safety Partnership and jointly developed by both Children & Culture and Health, Adults and Community Directorates. Public Health is undertaking a Joint Strategic Needs Analysis which will provide much of the evidence base for the new strategy. The aim is for the final strategy to be presented to Cabinet in Autumn 2019. The development of the strategy will include engagement with young people who have been victims of, or previously involved with, gang activity in the borough as well as CSE survisors.

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A refresh of the Violence Against Women and Girls (VAWG) Strategy has been completed and the new VAWG Strategy was approved by Cabinet in March 2019. This process included consultations with both professionals and survivors. The Domestic Violence One Stop Shop is ongoing weekly with increased survivor drop in due to improved awareness. The VAWG Charter has been co-produced and was launched in November and a Communications Strategy is being developed. Public health is developing a Violence JSNA, which will in part inform the above strategy. The work will include qualitative insights (e.g. focus groups).


Develop a strategy focusing on gangs and victims DD Community Safety / DD Children‟s Social Care

Autumn 2019

Launch a VAWG Charter DD Community Safety Completed – November 2018

Undertake a refresh of the VAWG strategy DD Community Safety Completed – March 2019

Consult with victims of gangs and serious violence Public Health Ongoing

Recommendation 3: Consider how we structure our activity in response to gangs and exploitation to ensure that it is a more holistic approach such as a wider ‘exploitation’ team, which will be supported by undertaking further analysis of the gangs profile in the borough including the age and ethnic profile of those involved (recommendation 6).

Comments from Service: In May 2018, Ofsted noted “there has been a substantial improvement in the quality of practice with this group of exploited children and their families. The recent co-location of key staff and the creation of a dedicated, authoritative, multi-agency exploitation team is very effective in responding quickly to high-risk situations…the exploitation team has an increased awareness of the multiple and overlapping risks to all children…these alternative methods of multi-agency interventions and engagement with young people are having a positive impact”. In addition, the Police Integrated Gangs unit was located with the Exploitation Team in December 2018. The mobilised Exploitation Hub has analytical capacity that the council simply hasn‟t possessed up until now. An integral part of the teams work is mapping and better understanding of both the borough‟s gangs‟ profile and the networks/mechanisms that drive the criminal/sexual exploitation of young people. The London Crime Prevention Fund is funding two analysts, one of whom sits in the Hub. Ofsted noted “effective multi-agency mapping meetings assist professionals to identify, track and understand common associations across gang memberships…Emerging information and intelligence is continually and quickly evaluated, leading to

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effective action to disrupt perpetrators and defuse emerging incidents..” The presence of the Integrated Gangs Unit alongside the Exploitation team has now further strengthened our capability in analysing intelligence of gang activity.


Create a multi-agency, co-located Exploitation team which includes the Police DD Children‟s Social Care

Completed – May 2018

Use the Exploitation Hub to improve analytical capacity DD Children‟s Social Care

Ongoing

Extract further data from the Violence JSNA in order to provide a more comprehensive understanding and renew the gangs profile

DD Children‟s Social Care

July 2019

Recommendation 4: Our assessments of children entering the care system should more thoroughly consider the mental health needs, including an understanding of the specific impact of violence on their lives. This understanding can be enhanced if our understanding of the impact of County Lines and Child Sexual Exploitation (CSE) on our looked after children who are placed outside of borough is improved and developed (recommendation 7)

Comments from Service: A „Contextualised Assessment‟ helps to better understand the impact and of a child or young person‟s historical background impact and what is required to address it. There are already statutory reviews and Strength and Difficulty Questionnaires in place to address the areas of mental health needs and can trigger an assessment earlier if required to do so. Both Children Looked After (CLA) and Leaving Care Service (LCS) have access to Tower Hamlets in-house CAMHS whereby a child or young person can receive immediate support without having to be placed on a waiting list. The borough is actively participating in the London Crime Protection Funded, pan-London, Response and Rescue County Lines project. Officers sit on the steering and operational boards and LBTH is seen as one of the four lead boroughs. Utilising the Response and Rescue East London analyst, we are reviewing and improving our analytical product relating to children subject to County Lines. This work is be helped by the mobilised Exploitation Hub whereby social workers and managers can seek advice and assistance in cases where children and young people are placed out of borough.


Introduce an annual Contextualised Assessment DD Children‟s Social Care

January 2019

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Provide training on working with young people at risk of sexual exploitation DD Children‟s Social Care

Ongoing

Recommendation 5: Ensure that there is funding and coordination that covers interventions for young people over the age of 18, including adopting the approach from recommendation 9, in which current engagement with Job Centre Plus should be expanded to include the Council’s WorkPath, as employment is considered an effective opportunity for gangs exit

Comments from Service: Young WorkPath (Careers Service) recently transferred from the Education and Partnerships Division in the Children‟s Services Directorate into the Growth and Economic Development Division, within the Place Directorate and focuses on the statutory groups of NEET, risk of NEET and more vulnerable young people. Using similar mechanisms and the shared knowledge and resource of WorkPath, young people are supported to explore aspiration, opportunities and apprenticeships to promote a self-reliant and sustainable lifestyle. The council‟s WorkPath and Young WorkPath services support residents through a journey of assessment, advice, skills, experience, jobs and progression. Where referrals are received from Youth services, Schools, PRU or other organisations, the services will do an assessment of the barriers to work that the client discloses. WorkPath and Young WorkPath (Careers Service) work in close partnership with partner support organisations including Streets of Growth who specifically target those currently/previously involved with gangs, Street Elite and Wise Youth Trust who, although not targeting gangs, engage with youth through sport to promote inclusion, education and training and the Building Crafts College in Stratford delivering construction related training to mostly those clients that had previously been excluded from school have ended up in a PRU.The services also work alongside the Supporting Stronger Families team who are co-located in the WorkPath offices. The team utilises Jobcentre Plus secondees and receive referrals from the Youth service team. WorkPath offers liaison with „Integrated Offender Management‟ (IOM) referrals from Probation (clients with high risk of reoffending) and the „Community Rehabilitation Company‟ (CRC) (clients with low to medium risk of reoffending). These clients are often accompanied by their supporting officers from these teams when meeting WorkPath advisers. WorkPath have also brokerage officers that are experienced in youth services and work closely with internal teams to maximise support and opportunity pathways. Members of the Rapid Response Team have received comprehensive Community Safety Training to enable the teams reach to 18+. RRT continue to collaborate with relevant providers to increase client prosperity and ensure accessible and appropriate

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training is available. This aims to address any skills gaps and provide support which is aligned to being job ready. Credible information is provided to maximise opportunities for meaningful employment, communicating detailed information about types of positions available, associated requirements and possible in work benefits. RRT meet with DWP, Catch 22 and Workpath regularly to identify employment and training opportunities. RRT are working with the Young People‟s Housing Accommodation Forum. This forum works with both young people leaving care and young adults 18+ in supported accommodation non LAC residents with complex needs and risk associated with violence vulnerability and or exploitation.


To expand the remit of the Rapid Response Team to improve engagement with those aged 18 and over

DD Community Safety Completed

Launch Young Workpath to support those between 16-24 into training and employment

DD Growth and Economic Development

Completed

Community Safety to develop a Mayoral Growth Bid to develop intensive one-to-one support

DD Community Safety Completed

Ensure that the Council‟s Workpath is fully utilised in offering employment opportunities to gang members

DD Growth and Economic Development/ DD Youth and Commissioning

Ongoing

Recommendation 10: Consider ways in which the risk and vulnerability of young people attending the London East AP can be better understood, and develop an effective support package for young people re-entering secondary school when moving from the London East AP

Comments from Service: Strategic leadership from Divisional Directors of Childrens‟ Services needed to agree a pathway and their services input into this. Behaviour and Attendance Partnership will consult with school leadership and recommendationis will be implemented by the Strategic Fair Access Panel.


Further develop and improve on the already successful reintegration rate of DD Education and July 2019

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young people reintegrating from London East Alternative Provision into secondary schools by developing a collaborative, partnership pathway which includes a co-ordinated response from Childrens‟ Social Care, the Youth Service, CAMHS and Education to ensure vulnerable children and families receive a holistic package of support which will secure a successful transition to a new school.

Partnerships

Schools are an important mechanism through which we can educate and support young people, as identified in recommendations 12 and 20. We need to engage with schools and the police to better understand their policies around exclusions in relation to carrying knives (12) and offer a quality assured preventative programme to schools, in order to spot early warning signs and develop the resilience of young people (20)

Comments from Service: Strategic leadership from Divisional Directors of Children‟s‟ Services and Police to inform contextualised approach, whilst the Behaviour and Attendance Partnership consult with school leadership, informed by good practice examples identified The Strategic FAP Panel will implement the recommendations.

Working collaboratively with the exploitation team, St Giles and the youth justice team have developed an educational training programme for schools and youth centres, focusing on current issues such as serious youth violence, criminal/ sexual exploitation, gangs/ groups, county lines and drug awareness is under development.


Undertake a wide consultation with all partners to determine what effective risk management strategies can be implemented to reduce exclusions related to the carrying of weapons, whilst balancing the need for schools to safeguard all their pupils from physical harm.

DD Education and Partnerships

July 2019

To identify/create a preventative programme to schools DD Education and Partnerships

Completed

Recommendation 13: Consideration should be given to whether there should be a social care/youth worker presence in A&E, including the paediatric A&E at Royal London in order to support early identification and intervention of those

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involved in gangs or subject to exploitation by gangs.

Comments from Service: The Violent Crime Reduction Officer is based with the Major Trauma Unit, at the Royal London Hospital. The RRT Violent Crime Reduction Officer will engage adults and young people requiring medical treatment for injuries attributed to violent / knife crimes.The RRT Violent Crime Reduction Caseworker provides needs led wrap around support to high risk adults and young people, who have been victims of violent crimes including knife crime (not in-patients).


Identify whether there is officer capacity already within the service to provide such a presence. If not, begin recruitment (contingent on budgets)

DD Community Safety Completed VCRO in post as of 02/01/2019

Recommendation 14: The council should work in partnership with the police in order to develop effective disruption activity in relation to gangs, drugs and CSE, ensuring that it utilises all of the tools and powers at its disposal.

Comments from Service: Environmental Health and Trading Standards carry out a range of Licensing enforcement activities and under age sales test purchases. Although they do not specifically target gangs/drugs/CSE, they have an impact. Operation Continuum - This is a partnership operation involving police and Local Authority. Over the past year this partnership activity has resulted in;

190 total arrests for drug offences and drug supply 91 people charged 31 men sentenced to a combined total of more than 100 years' imprisonment Large quantities of Class A drugs and Cannabis seized £171k in cash seized under the Proceeds of Crime Act 4 firearms recovered during raids 164 drugs stop and searches conducted 399 ASB Warnings issued 25 weapon sweeps conducted 33 weapons recovered from weapon sweeps including knives and other offensive weapons 93 people arrested, assessed and referred in to drug treatment

The Partnership Task Force (PTF) was increased (from 1-5) to 1 Sergeant and 10 Constables on 5th September. These officers are funded by the Mayor. The section 92 agreement with MOPAC and Police is for a resource of 4 Sergeants and 20 constables. These additional officers will be released when the Borough Commander is able.

Weekly tasking process chaired by council officer focuses on drugs, violence and agrees deployments across the borough.

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These deployments are based on call analysis to the police, information received from residents, ME‟s, and intelligence from other council departments and Registered Providers.

Apart from key locations, the PTF are also focussing on the top 10 vehicles identified as being associated with drug dealing and exploring ways to disrupt the activity of dealers often referred to as an „Achilles Heel‟ approach.

Where users are identified, the PTF offer appointments to engage with treatment service

The multi-agency Exploitation Team undertakes work with the most vulnerable teenagers in the borough, joining up work around Child Sexual and Criminal Exploitation, missing children and County Lines. Information sharing and intelligence has enabled surveillance and disruption activity to be undertaken.


Increase the Partnership Task Force owing to additional funding from Mayor Metropolitan Police Service – Tower Hamlets

Completed – September 2018

Prepare for release of additional officers as per the section 92 agreement Metropolitan Police Service – Tower Hamlets

Ongoing

Including the community in plans to tackle gangs and serious youth violence was recommended in 16 and 17, both by instigating a programme of training for local residents, where appropriate, to act as community advocates, and by developing a peer led programme. This shouldraise awareness of risks and vulnerabilities and support peers through mentoring.

Comments from Service: Recommending using local residents was based on the Chicago/Ceasefire model of Violence Interrupters, one of the methodologies being explored, (alongside the Glasgow model) by the GLA‟s new Violence Reduction Unit for the application of a London wide Public Health response to violence and knife crime. There may be an opportunity for an LBTH officer to join a fieldtrip to Chicago in April next year to see first-hand how they apply the model and discuss how it might best be adapted to meet the specific needs/dynamics of Tower Hamlets. In regards to the peer-led programme, it was proposed that the newly established Youth Independent Advisory Group woud be invited to lead on this piece of work. When consulted on this, they felt it was a bigger project than they wanted or felt able to take on this early in their formation. They also indicated that although they might at a future date be in a position to co-design such a programme, they wouldn‟t be able to deliver the project, it would be beyond the scope and resourcing of the YIAG to deliver this, particularly the mentoring component. A separate group would need to be established (and resourced) to deliver an initiative of this size and ambition. After LBTH discussions with Glasgow violence reduction their recommendation to train young people to deliver training to their peers regarding gangs/ groups, CSE, staying safe, county lines, criminal exploitation is under consideration to be

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10

employed with in LBTH education settings. The Youth Service's A Team Arts project currently runs a 3 hour CSE workshop called 'Her Link' in schools, Youth Centres and Community Centre. The March 2019 Parent and Family Conference included parental workshops on gangs and county lines.


Undertake an assessment, as part of the Violence, Vulnerability and Exploitation Strategy development, to establish which, if any training programme should be implemented

DD Community Safety / DD Children‟s Social Care / DD Youth and Commissioning

Sept 2019

Identify whether it is feasible to establish and resource a group DD Youth & Commissioning

Sept 2019

Make a decision on whether training young people to deliver training is viable DD Youth & Commissioning

Sept 2019

Decide whether the CSE workshop should continue into 2019/20 DD Youth & Commissioning

Sept 2019

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Ofsted is proud to use recycled paper

25 May 2018

Debbie Jones Director of Children’s Services London Borough of Tower Hamlets Town Hall Mulberry Place 5 Clove Crescent London E14 2BG , London SW18 2PU

Dear Debbie

Monitoring visit to Tower Hamlets children’s services

This letter summarises the findings of the monitoring visit to the London Borough of

Tower Hamlets children’s services on 1 and 2 May 2018. This was the third

monitoring visit since the local authority was judged inadequate for overall

effectiveness in April 2017. The inspectors were Brenda McLaughlin, HMI, Kate

Malleson, HMI, and Tom Anthony, a seconded inspector.

Inspectors evaluated the local authority’s arrangements for the help and protection

of vulnerable adolescents. In particular, they focused on whether the considerable

failures, identified in the 2017 inspection, to help and protect children at risk of

exploitation and those missing from home or care, are now being addressed.

A range of evidence was considered during the visit, including discussions with social

workers and their managers. Inspectors looked in detail at children’s cases and met

with committed staff across agencies, who are resolute in their efforts to engage

with and protect these highly vulnerable children. They reviewed the quality of

practice provided by the out-of-hours emergency duty team (EDT) as well as the

quality of practice provided to children at risk of being radicalised. Inspectors spoke

to the chair of the safeguarding children’s board and explored with senior leaders

how the reconfiguration of targeted and early help services could identify and

prevent the exploitation of vulnerable children sooner. Additionally, inspectors looked

at local authority performance management and quality assurance information and

the effectiveness of audit activity.

Clive House 70 Petty France Westminster London SW1H 9EX

T 0300 123 1231 [email protected] www.ofsted.gov.uk

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Overview

A major challenge for Tower Hamlets is the alarming increase in violent knife crime

(13 knife-related incidents in the past six weeks) linked to drug-related gang activity,

and involving young and vulnerable boys and girls. These are often sexually and

criminally exploited children, those missing from home and care and young people

associated with gangs. They are mainly children with very complex needs who are

known to a number of agencies, sometimes for many years, due to adversity

suffered in childhood. Too many are not accessing education or training.

Previously, the local authority’s relationships with key safeguarding partners were

underdeveloped, with too many staff working in isolation. Senior leaders across all

agencies have recognised that the complexity of issues in relation to exploited

children means that a joint multi-agency approach is required. Consequently, the

revised early help strategy is intended to address former weak practice for this group

of children. This is now an important priority for the local authority and the

safeguarding children’s board. Working relationships with stakeholders are

developing to help and protect these vulnerable children. This is beginning to have a

positive impact, leading to more effective and innovative practice. Children’s services

are actively seeking to do more to help and support schools.

Since the previous inspection and the monitoring visit in December 2017, there has

been a substantial improvement in the quality of practice with this group of exploited

children and their families. The recent co-location of key staff and the creation of a

dedicated, authoritative, multi-agency exploitation team is very effective in

responding quickly to high-risk situations. A renewed focus on children as victims of

exploitation rather than the criminalising of their behaviour is leading to an enhanced

understanding of their circumstances and analysis of risk. Social workers now have a

better understanding of children’s lived experience. Together with partner agencies,

they are increasingly diligent in their attempts to work with and support these young

people and their brothers and sisters.

Reliable and effective intelligence gathering processes have been developed to

support the sharing of information on a daily basis. This has led to perpetrator

disruption activities, as well as prompt actions to prevent serious youth violence and

other gang-related activities escalating.

Overall, while social work practice remains variable across all teams, increasingly,

vulnerable adolescents receive higher levels of support and intervention. This is a

discernible difference to the previous poor practice and indicates a noteworthy

change in culture in frontline social work, which is encouraging.

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3

Findings

Tower Hamlets multi-agency safeguarding hub (MASH) promptly identifies risk to

exploited children. Decisions on thresholds for services are made by suitably qualified

and experienced social workers and managers and are considered at the daily MASH

meeting. Most gang-affiliated young people, victims and perpetrators of serious

violence, those at risk of sexual and criminal exploitation and children missing from

home or care benefit from an effective multi-agency response. For example, young

people arrested for perpetrating knife crime are considered as high risk due to the

possible retaliation by other gangs. They are appropriately allocated to social

workers, who carry out a safeguarding assessment of the young person and also the

potential risk to family members. This would not have happened before.

The exploitation team has an increased awareness of the multiple and overlapping

risks to all children. Although very recently established (March 2018), these

alternative methods of multi-agency interventions and engagement with young

people are having a positive impact. The team has a good understanding of the

Tower Hamlets gang’s profile. Effective multi-agency mapping meetings assist

professionals to identify, track and understand common associations across gang

memberships, including drug misuse, radicalisation, serious youth violence, child

sexual exploitation and children who going missing. Emerging information and

intelligence is continually and quickly evaluated, leading to effective action to disrupt

perpetrators and defuse emerging incidents in collaboration with the community

safety rapid response team.

The monitoring visit in December 2017 identified an inconsistent and confused

response to assessing risk to children missing from home and care. Since then,

urgent action has been taken by the newly appointed missing coordinator. This has

had a significant and positive impact on the quality of practice for children who go

missing. Arrangements for the completion of return home interviews (RHIs) have

been streamlined and are effective. Data shows that the service has improved the

timeliness of interventions. Inspectors found that the quality of RHIs has improved. A

specifically trained group of professionals from the MASH, EDT and the early help

service regularly visit children to conduct the interview. There is a strong emphasis

on getting alongside young people at the earliest opportunity. The development of a

weekend RHI service carried out by the same practitioners is helping children to

develop purposeful relationships with professionals and avoids them having to repeat

their story.

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4

Multi-agency child protection strategy meetings are now being convened

appropriately in response to risks to exploited and missing children. Although local

authority audits and inspectors found that the outcome of strategy meeting decisions

and actions are not routinely recorded, it is evident that there has been improved

attendance by other agencies. This is effective in sharing information about risk and

concerns. The majority of children at risk of sexual and criminal exploitation or who

have a missing episode are entered onto the local authority electronic system. This

assists managers in identifying and tracking children with multiple vulnerabilities. A

comprehensive dataset is reviewed by the divisional director and this information is

shared with the LSCB ‘vulnerable children exploitation group’. Child exploitation

screening tools are used effectively to recognise risk. This informs the undertaking of

timely risk assessments and the development of coherent safety plans. The most

serious concerns for children’s safety are now escalated for regular senior

management review and direction.

Strong partnership work to counter the risk to children from radicalisation is having a

positive impact. The changing nature of potential threats in this highly complex and

sensitive area continues to be well understood. Work to reduce risk is suitably

targeted through strong, effective intelligence-sharing with relevant partner

agencies. A peer review of the Tower Hamlets ‘Prevent’ programme took place in

March 2018, which was positive. However, the review found that there is a challenge

in respect to the local population perception of the ‘Prevent’ agenda. It is a priority

action within the wider council to address this. The review also recommends that the

local authority supports the learning and development of elected members so that

they further develop their leadership role in this area. Inspectors found that the

preventing violent extremism dedicated team, which is led by an experienced and

knowledgeable manager, ensures assessments for children at risk of radicalisation

receive a proportionate and timely response.

The reconfigured child-focused out-of-hours emergency duty team (EDT) is led by a

committed and innovative manager and is delivering a much improved quality service

to vulnerable adolescents. The team is well resourced and its work is increasingly

effective. It provides a well-coordinated and timely response when children go

missing. The communication between out-of-hours and day services is effective, with

the EDT ‘footprint’ visible on children’s records. This contributes to a more complete

picture about the frequency, nature and level of risk that children experience.

Improved communication with the police is enhancing joint working. Wider

engagement with accident and emergency health partners helpfully identified an

information-sharing gap, which both parties have addressed. Management oversight

of the EDT team is strong and challenging, but also aspirational and supportive. The

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5

service is outward facing and engaged in pan-London learning and development

forums. Although changes need to become embedded, children at risk of harm out of

hours are starting to become safer.

The recruitment and retention of staff is a priority and challenge for Tower Hamlets.

The local authority is successfully recruiting permanently to senior and middle

manager posts. However, the service currently relies on high numbers of agency

staff, particularly in assessment and intervention teams, although there is some

success with agency workers transitioning into permanent posts. Managers are

promoting the ‘growing your own’ recruitment of social workers, with a

comprehensive training and support package for newly qualified workers that is

intended to attract additional permanent staff.

In summary

The evidence gathered during this visit has identified substantial, but very recent,

improvements to the quality of multi-agency and social work practice for vulnerable

adolescents and their families. This is extremely encouraging given the particularly

complex challenges involved in this work. Political leaders and managers are

demonstrating considerable determination and commitment to embedding and

sustaining these changes, while simultaneously addressing the areas of poor

practice.

I am copying this letter to the Department for Education. This letter will be published

on the Ofsted website.

Yours sincerely

Brenda McLaughlin Her Majesty’s Inspector

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Cabinet Decision

24 April 2019

Report of: Will Tuckley, Chief Executive


Draft Strategic Plan 2019-22 and OBA delivery approach

Lead Member Executive Mayor

Originating Officer(s) Adam Boey: Senior Strategy and Policy Manager Afazul Hoque: Head of Corporate Strategy & Policy


Key Decision? Yes


28 February 2019

Reason for Key Decision Significant impact on persons living in two or more wards


All priorities

Executive Summary

This report presents the Council‟s Strategic Plan 2019- 2022 at Appendix 1 for approval by the Mayor in Cabinet. It details the Council‟s priorities and outcomes that will be delivered over the next three years in the context of national, regional and local challenges. The plan reflects the ambitions of the Council to become an outcome based organisation ensuring our interventions and activities have a positive impact on local people.

Recommendations: The Mayor in Cabinet is recommended to::

1. Adopt the draft Strategic Plan for 2019-22 at Appendix 1;

2. Endorse the proposed approach to strategic delivery as set out in paragraph 3.5-3.8; and

3. Delegate to Divisional Director Strategy, Policy & Performance to finalise

the Plan following Cabinet in consultation with the Mayor. 1 REASONS FOR THE DECISIONS 1.1 The Strategic Plan is the main strategic business planning document of the

Council. It sets out the corporate priorities and outcomes, the high level

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Agenda Item 6.2

activities that will be undertaken to deliver the outcomes, as well as the measures that will determine whether we are achieving the outcomes.

1.2 In line with the budget setting process, the Strategic Plan is a rolling three-

year plan which is updated annually so that it accurately reflects the Council‟s priorities.

1.3 Importantly, the Council‟s vision is to become a dynamic outcomes-based

organisation using digital innovation and partnership working to respond to the changing needs of our borough.

1.4 This renewed focus on outcomes requires us to think differently. Working

together across traditional organisational boundaries, we need a relentless focus on what has the biggest impact on outcomes. This needs us to question not only how our services are performing, but also whether we are doing the right things to deliver the impact needed.

1.5 The proposed approach to delivering on the Strategic Plan embeds Outcomes

Based Accountability and Budgeting (OBA/OBB) in our planning and performance approach for 2019-20

1.6 OBA and OBB will underpin the Council‟s approach to strategic planning and

performance management - ensuring planned activity is explicitly linked to corporate priorities (outcomes) and that delivery is measurable.

1.7 The first step of the OBA/OBB journey is the Strategic Plan – setting out

corporate priorities for Members and staff. A draft Strategic Plan for 2019-22 is presented as this first step (Appendix 1).

2 ALTERNATIVE OPTIONS 2.1 The Strategic Plan could remain as it is for 2018-19. This means the Council‟s

planned activities would not be reflective of 2018-19 achievements and progress.

2.2 The Mayor and Cabinet may choose to further amend the Strategic Plan. If the Plan is amended, regard would need to be given to the Council‟s medium term financial plan, as well as any impact arising from the changes.

2.3 The risk of not fully implementing an outcomes-based approach in LBTH is that effort and resources may continue to be expended without realising results and impacts for the residents and communities of the borough. Demonstrating outcomes to people is the central facet of the OBA/OBB approach – linking action to impact.

3 DETAILS OF THE REPORT 3.1 The Strategic Plan is arranged around three priority areas and a set of 11

corporate outcomes, which were agreed as part of the budget setting process in February 2018.

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3.2 In order to support delivery of these priority areas the Council will work

towards delivering the following priorities and outcomes: Priority 1 - People are aspirational, independent and have equal access to opportunities

1. People access a range of education, training, and employment

opportunities.

2. Children and young people are protected so they get the best start in life

and can realise their potential.

3. People access joined-up services when they need them and feel healthier

and more independent.

4. Inequality is reduced and people feel that they fairly share the benefits

from growth.

Priority 2 - A borough that our residents are proud of and love to live in

5. People live in a borough that is clean and green.

6. People live in good quality affordable homes and well-designed

neighbourhoods.

7. People feel safer in their neighbourhoods and anti-social behaviour is

tackled.

8. People feel they are part of a cohesive and vibrant community.

Priority 3 - A dynamic outcomes-based Council using digital innovation and partnership working to respond to the changing needs of our borough

9. People say we are open and transparent putting residents at the heart of

everything we do.

10. People say we work together across boundaries in a strong and effective

partnership to achieve the best outcomes for our residents.

11. People say we continuously seek innovation and strive for excellence to

embed a culture of sustainable improvement.

Progress to date – OBA/OBB 3.3 The Council has been on a transformation journey over the last two years -

Smarter Together has highlighted the need to continue to move towards an outcomes based service - with agreement to transform strategic planning and performance management across the organisation.

3.4 Over the past year, the Council has been developing its Outcomes Based

Accountability and Budgeting approach – working across the service areas to understand what activity leads to the outcomes we aim to achieve for people. This has involved:

Developing logic models describing key outputs and outcomes - a conceptual representation of how activity leads to the achievement of intermediate (short- and medium-term) and long-term (strategic) outcomes;

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Mapping costs to outcomes and high-level activity from the models; and

Identifying a small number of relevant key performance indicators that allows the Council to measure delivery and achievement of outcomes.

Proposed next steps for 2019-20 Increasing the pace 3.5 Publishing the refreshed 2019-22 Strategic Plan – which is the translation of

the administration‟s manifesto commitments and the cornerstone for the Council‟s business planning and sets the framework for performance management. The Strategic Plan establishes the „Golden Thread‟ that sets requirements for delivery of strategic priorities (outcomes) and will be the basis of business planning across the Council.

3.6 A streamlined business planning phase from April to May is anticipated –

requiring only that services demonstrate their connection to delivering Strategic outcomes, manifesto pledges, and equalities priorities; improvement activity and be SMART (Specific/Measurable/Achievable/Realistic/Time-related). Furthermore, services will be specifically required to embed action to deliver manifesto pledges and to address inequalities identified in the borough profile.

Empowering services to deliver 3.7 Both Cabinet and CLT need to be assured of, and provide assurance of

delivery, respectively. The proposed approach devolves responsibility for delivery of Strategic outcomes, manifesto pledges, and equalities priorities to service areas – providing the Golden Thread of accountability.

Support, Guidance and Systems 3.8 This is a major culture change for the organisation and will take at least 6

months to fully embed. This work is being carried out in stages to ensure that the principles and expectations are understood, and work practices can be adapted to embed OBA:

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Timetable

Deliverable Decision maker Proposed date

Strategic Plan Cabinet 24 April 2019

Service Plans Corporate Directors

June 2019

Full set of revised measures (quantity, quality, outcome)

Mayor & Cabinet Members

22 May 2019

Performance targets 2019/20 & monitoring arrangements

Mayor & Cabinet Members

19 June 2019

4 EQUALITIES IMPLICATIONS 4.1 The Strategic Plan has been informed by the Borough Equality Assessment

and subject to an Equality Assurance Checklist. The screening exercise has

OBA JOURNEY at LBTH

2018 March 2019

April May June September

OBA development:

Logic models

Output/quantity/quality measures

Draft dashboards

Business planning:

Strategic Plan

Service Plans

Target setting

Performance:

Quarterly Cabinet Members Dashboards

Quarterly corporate performance reporting

Service performance reporting through monthly Outcome Team Meetings, CLT, and MAB oversight

OBA IMPLEMENTATION

Performance management: preparation

Performance management: monitoring/reporting

Business planning

OBA DEVELOPMENT

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indicated that a full EA is not required as the Strategic Plan is focused on tackling inequality and fully exhibits due regard equality.

4.2 The Plan also includes the Council‟s obligation to publish an annual equality

objective as defined by the Public Sector Equality Duty. 5 OTHER STATUTORY IMPLICATIONS 5.1 This section of the report is used to highlight further specific statutory



Consultations,


Risk Management,

Crime Reduction,

Safeguarding.

Data Protection / Privacy Impact Assessment. 5.2 No other statutory implications. 6 COMMENTS OF THE CHIEF FINANCE OFFICER 6.1 The Strategic Plan 2019-2022 is a core planning document and provides a

framework for allocating and directing financial resources to priorities over the next three years.

6.2 In the event that, during the implementation of individual projects and schemes, financial implications arise outside the current budget provision, officers are obliged to seek the appropriate financial approval before further financial commitments are made. This report has no other financial implications.

7 COMMENTS OF LEGAL SERVICES 7.1 The Strategic Plan specifies how the Council will prioritise delivery of its

functions and thus ranges across the Council's statutory powers and duties. The proposed priorities are capable of being carried out lawfully and it will be for officers to ensure that this is the case.

7.2 Section 3 of the Local Government Act 1999 requires best value authorities, including the Council, to “make arrangements to secure continuous improvement in the way in which its functions are exercised, having regard to a combination of economy, efficiency and effectiveness”. The development of a Strategic Plan, together with its delivery and subsequent monitoring will contribute to the way in which the best value duty can be fulfilled. Monitoring reports to members and actions arising from those reports will help to demonstrate that the Council has undertaken activity to satisfy the statutory duty.

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7.3 In all aspects of the strategy there are clear implications for persons who have

a protected characteristic for the purposes of the Equality Act 2010. Therefore, not only should an Equality Assessment occur (and potentially a number of them as parts of the strategy are implemented) but a clear strategy on an equalities consultation may be necessary whilst some of the decisions relating to the actions under the strategy are still at a formative stage. This is to ensure that the Council informs itself properly of the effects of the decisions on such persons. It will then be in a position to properly comply with the Equality Duties under that act.

____________________________________ Linked Reports, Appendices and Background Documents Linked Report

None Appendices

Appendix 1. Draft Strategic Plan 2019–22 Background Documents – Local Authorities (Executive Arrangements)(Access to Information)(England) Regulations 2012

None Officer contact details for documents:

Adam Boey, Senior Strategy and Policy Manager (Corporate SP)

Afazul Hoque, Head of Corporate Strategy & Policy

Thorsten Dreyer, Head of Intelligence & Performance

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Tower Hamlets Strategic Plan 2019-22

Contents

Foreword by John Biggs, Mayor (To be added) ............................................................. 2

Introduction by Will Tuckley, Chief Executive (To be added) ........................................ 3

Our Priorities and Outcomes ......................................................................................... 4

Priority 1 - People are aspirational, independent and have equal access to opportunities ................................................................................................................. 5

Priority 2 - A borough that our residents are proud of and love to live in .................. 10

Priority 3 - A dynamic outcomes-based Council using digital innovation and partnership working to respond to the changing needs of our borough .................... 15

The Borough by numbers (To be added) ..................................................................... 19

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Foreword by John Biggs, Mayor

(To be added)

Page 80

Introduction by Will Tuckley, Chief Executive

(To be added)

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Our Priorities and Outcomes

The Strategic Plan is an important precursor to the Council’s Performance Management and Accountability Framework and is the main strategic business planning document of the Council. It sets out the corporate priorities and outcomes, the high level activities that will be undertaken to deliver the outcomes, as well as the measures that will help us determine whether we are achieving the outcomes.

The Council is looking to deliver the following priorities and outcomes over the next three years:

Priority 1 - People are aspirational, independent and have equal access to opportunities

1. People access a range of education, training, and employment opportunities. 2. Children and young people are protected so they get the best start in life and

can realise their potential. 3. People access joined-up services when they need them and feel healthier and

more independent. 4. Inequality is reduced and people feel that they fairly share the benefits from

growth.


5. People live in a borough that is clean and green. 6. People live in good quality affordable homes and well-designed

neighbourhoods. 7. People feel safer in their neighbourhoods and anti-social behaviour is tackled. 8. People feel they are part of a cohesive and vibrant community.

Priority 3 - A dynamic, outcomes-based Council using digital innovation and partnership working to respond to the changing needs of our borough

9. People say we are open and transparent putting residents at the heart of everything we do.

10. People say we work together across boundaries in a strong and effective partnership to achieve the best outcomes for our residents.

11. People say we continuously seek innovation and strive for excellence to embed a culture of sustainable improvement.

The plan is a key link in the ‘Golden Thread’ and used to inform directorate, service and team planning. It also sets out how the Council will deliver the objective and priorities set out in the new Tower Hamlets Plan developed by the Tower Hamlets Strategic Partnership.

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Priority 1 - People are aspirational, independent and have equal access to opportunities

Tower Hamlets is one of the most vibrant and diverse communities in the UK. Almost 140 languages are spoken in our schools alone. People value the rich cultural offer that comes with this mix, and the new opportunities to celebrate this diversity that we have worked hard to create.

Over the past three decades our population has more than doubled and we are still growing: the population recently broke through the 300,000 mark and is projected to be approaching 400,000 by 2027. We are also a young borough - the fourth youngest in the UK: almost half of our residents are aged 20-39.

This priority provides a focus for our efforts to ensure that our residents can achieve their aspirations and gain from the benefits of living in a borough that is economically vibrant, resilient and diverse.

There are four overarching outcomes under Priority 1 that the Council’s actions for the coming year are focussed on achieving and these are described in more detail in the sections that follow.

Outcome 1: People access a range of education, training, and employment opportunities.

High quality education is a stepping stone to high quality employment. In partnership with the Tower Hamlets Education and Partnership and our schools, we will continue to work hard to help our young people do well at school and go on to reach their full potential. Beyond school, we also want to support them and their families to be aspirational about their future and to have the opportunity to thrive in good jobs. This means equipping young people with the skills and confidence to succeed in the modern economy.

We want to help local residents to capitalise on the dynamic employment growth occurring around them. We want to encourage employers and education providers to work closely together in the design and delivery of education and skills training to reflect the needs of the job market. Higher education is not for everyone and people should be offered a range of routes into employment, including work placements and apprenticeships. We will push for economic investment that is coordinated and focused and for a borough that is a dynamic place for innovation and those who want to set up a business.

What actions will we take? 1. Agree common expectations with key stakeholders e.g. schools, New City

College, Job Centre Plus, the business community 2. Develop action plans based on individual needs assessments for those young

people and adults we are supporting into education, training and employment opportunities (note – this action also supports Outcome 4)

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3. Develop a careers education programme for young people in years 7-9 (aged 11 to 14)

4. Identify key skills and training for employment support professionals 5. Provide support to start-ups and existing business 6. Develop business networks and contacts with hiring managers 7. Provide access to entry point learning which promote personal development 8. Improve our understanding of the current and future London labour market-

What will we measure?

Young people who are in education, employment or training

Pupils who are attending secondary school regularly

New enterprises created with support from the Council's business development programmes

Adult learners who complete a course successfully

Adults supported into sustainable employment by the WorkPath service

Outcome 2: Children and young people are protected so they get the best start in life and can realise their potential

The formative years from 0 to 5 are absolutely critical to the future health and wellbeing of infants in Tower Hamlets. The integrated early years’ service works with partners and stakeholders to address levels of provision and quality in early education and childcare. Similarly, health visitors play a crucial role in identifying and supporting our youngest children in need, making sure they get the best start in life. We want to ensure high quality provision to support the learning, development and care of young children to prepare them for school and their futures.

We have an important responsibility to safeguard and promote the welfare and safety of children in need. To do this, we will work with parents and families in the best interests of the children by listening to their views when making decisions. With our partners we will be launching our children’s campaign with the aim of making Tower Hamlets a child friendly borough.

We want children and young people to be able to live in a safe environment, ensuring the best health and developmental outcomes.

What actions will we take?

1. Provide high quality training for staff working in social care and early help services. This training will need to link closely with the training goals of our partners, and wherever possible, training should be delivered jointly to strengthen joint working.

2. Engage effectively with system partners such as health and the police to ensure that services are complementary and there is no duplication of services or resources.

3. Create and map clear pathways into early help from social care and other universal services; and to develop consistent understanding of thresholds across services and agencies.

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4. Use the new Safeguarding Children Partnership to establish partnerships between children; young people; families and schools, health staff and other stakeholders

5. Continue to offer Family Group Conferencing to families in need at the earliest stage.

6. Collate data and feedback from children; young people; families and the wider community and further develop mechanisms for youth and parental voice.

7. Provide varied high quality activities outside of school for children and young people.


Long-term looked after children who are in stable placements

Families who are seeing the benefits of being supported before problems escalate

Pupils who are regularly attending school in reception year

Young people engaging with the youth service who achieve a recorded outcome

Outcome 3: People access joined-up services when they need them and feel healthier and more independent

We are committed to improving the health and wellbeing of our local population and the quality of the care services they receive. At the heart of this is ensuring our services are person centred, coordinated and make a tangible and positive difference to people’s lives. We have a strong commitment to deliver in a joined-up way with a strong local Tower Hamlets focus, working in partnership with people and their communities, the voluntary and community sector and statutory providers. We aim to give the people of Tower Hamlets one of the best systems of interconnected health and care in the country.

Through further close partnership working, prevention, early intervention and working with our communities, we will tackle health inequalities, improving the quality of life for our residents and managing demand for services.

Through the Tower Hamlets Together partnership with the NHS and local community and voluntary sector, we aim to reduce the need for people to be treated in hospital, by supporting them to stay healthy and to access support earlier to prevent health problems. We also want to give people more control over their own health and wellbeing and manage their health in community settings.

What actions will we take? 1. Run activities and programmes that encourage residents to have healthy

lifestyles, including encouraging children’s healthy weight and nutrition 2. Provide evidence-based early intervention and prevention programmes, helping

residents to be as healthy as possible for as long as possible 3. Change how we provide information to residents on health and care, making it

easier for people to get advice and help at an early stage

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4. Integrate health and care so that residents get a better, more joined-up experience of both systems

5. Make better use of technology and equipment in health and care, recognising its potential to improve how people manage their health conditions and care needs

6. Staff in adult social care will do more to empower people, focusing on the strengths and abilities of social care users as well as the things they need help with

7. Offer choice and personalised support to social care users, including the promotion of direct payments so that people have more control over the care they receive


People who are more independent after being supported through reablement services

Delayed discharges from hospital attributable to council social care services

Proportion of adult social care users who are receiving a direct payment

Residents’ self-reported level of physical activity

Residents’ self-reported level of health

Children’s participation in physical activity (Daily Mile)

Outcome 4: Inequality is reduced and people feel that they fairly share the benefits from growth

While we want people to have positive associations about life in Tower Hamlets, we cannot deny that Tower Hamlets is a borough of contradictions.

Despite the economic opportunities in our borough, many in our community do not benefit from them. The borough is the tenth most deprived local authority in England and has the highest levels of pensioner poverty and child poverty in England. The employment rate of residents is below the national average and some people in our communities find it more difficult to find work than others.

The borough is also tackling some of the toughest health inequalities in the UK caused by deprivation and related housing and employment needs – these are addressed in Outcomes 1 (education, training, employment), 3 and 7 (health), and 6 (housing).

What actions will we take? 1. Support households impacted by Universal Credit 2. Deliver initiatives to prevent homelessness and rough sleeping 3. Work with partners to deliver initiatives to tackle poverty 4. Develop Finance and Welfare advice provision in the borough 5. Review and improve local childcare offer


Women and residents from BAME backgrounds supported into sustainable employment by the WorkPath service

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Residents’ self-reported level of health for groups experiencing health inequalities

Residents who are better off financially after receiving advice on maximising their household income

Households prevented from becoming homeless

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Tower Hamlets is one of the most dynamic and exciting places in the country. It is a borough with a rich history; people are proud to be part of this community. Tower Hamlets is also a place of contrasts and contradictions, where a thriving economy co-exists with high levels of poverty. But above all it is a place of opportunity. A place where we can build on the stories of our past, on the great progress we have already made, and on our many strengths, to ensure that this is a borough where all residents can thrive.

Our vision for Tower Hamlets is that it is clean and well looked after, where our air quality is better and our streets and estates safer, a fairer place with more access to affordable housing and where more of our residents achieve their potential.

We know that strong and resilient communities are happier and healthier communities, when people look out for each other they benefit in terms of their health and well-being, from their connections with the people around them.

Against a backdrop of reducing public sector resources and increased confidence to report crime, we will focus more on crime prevention and reducing fear of crime. We will also work closely with communities to tackle crime and anti-social behaviour.

We will work together as a community to support greater integration and cohesion, helping to build bridges between different parts of the community, tackling social isolation and contributing to making the borough a safer place.

There are four overarching outcomes under Priority 2 that the Council’s actions for the coming year are focused on achieving, and these are described in the following sections.

Outcome 5: People live in a borough that is clean and green

We want residents to enjoy a good quality of life in an environment that has a positive influence on everyone health and wellbeing. While in many ways the local environment for residents is improving, increases in the number of people that live, work and pass through the borough presents many challenges in ensuring the impact of growth on the local environment is managed. Providing a clean local environment with improved open spaces for a growing population presents a complex challenge to meet within a small borough footprint and against financial constraints. Similarly, managing the impact of a growing population on the environment through reducing congestion, air pollution, and the levels of waste and co2 produced presents a significant challenge in how we work with stakeholders to reduce the effects of growth. We are already making good progress in delivering a range of measures to improve air quality and CO2 emissions in the borough and are ambitious in our approach to improve the local environment which residents experience, The Love Your

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Neighbourhood Programme will further improve the quality of the local environment for those who live and work in the borough through delivering street cleanliness, waste management, transport and infrastructure initiatives to create a more pleasant environment. In order to meet the challenge of growth we remain committed to the delivery of affordable homes within the borough and improving the quality and management of housing across the borough. We will continue to progress our approach to regeneration across the borough to ensure we capitalise on opportunities presented by development, ensuring that residents share the benefits or growth and that the appropriate infrastructure is in place to facilitate this. What actions will we take? 1. Implement new arrangements to improve cleansing and the quality of the local

environment 2. Deliver the Council’s Waste Strategy with initiatives to encourage/enforce waste

reduction and recycling amongst residents and businesses 3. Deliver the Mayor’s ambitious Love Your Neighbourhood programme to make

our streets safer, cleaner and more sociable places to use and to deliver the new investment around street lighting, footways and carriageways throughout the borough

4. Deliver initiatives to maintain and improve existing parks and green spaces 5. Deliver the Air Quality Action Plan 6. Promote use of cleaner fuel types amongst residents and businesses 7. Take targeted action to reduce CO2 emissions across residential and community

buildings 8. Agree and deliver a Biodiversity Action Plan to protect and enhance wildlife

across the borough


Level of public realm cleanliness

Level of recycling

Level of CO2 emissions generated by the Council’s activities

Primary school pupils benefiting from a school street at their school

Residents' access to nature through biodiversity projects

Outcome 6: People live in good quality affordable homes and well-designed neighbourhoods

We want the borough to be a place where people are proud to live and enjoy their lives. Accessing good quality, affordable housing is an ongoing challenge in a borough which has a fast growing population, low income levels for many households and a fast growing private rented sector with high private rents and house prices. Pressures on the high demand and limited supply of social housing lead to complex challenges concerning overcrowding, homelessness and rough sleeping, while the

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expansion of the private sector as of source of housing presents challenges to ensure that this stock is in good condition and well managed. Finally while Tower Hamlets delivers amongst the largest numbers of housing and affordable amongst Local Authorities each year, we continue to have stretching housing delivery targets from the GLA and have three designated Opportunity Areas designated to accommodate projected population growth of about 25% by 2031. This level of growth within our borough’s 2,157 hectare footprint present significant challenges to ensure the correct social, economic and physical infrastructure is in place to accommodate this growth, that residents have a vital say and role in regeneration and that opportunities that arise from growth are accessible for our residents. What actions will we take? 1. Work with housing associations and other partners to improve the supply of

affordable housing (note – this action also supports Outcome 4) 2. Identify sites for new Council homes and commence delivery 3. Adopt the Local Plan and produce robust development strategies and policy

guidance 4. Develop and deliver a borough programme for regeneration 5. Deliver the Council’s programme of estate renewal and initiatives to improve

housing conditions (note – this action also supports Outcome 4) 6. Negotiate and deliver strategic infrastructure 7. Continue to drive improvements to the planning process 8. Deliver the programme of Liveable Streets


Level of household overcrowding

Level of homeless households moved into permanent accommodation

Level of affordable homes completed

Residents’ satisfaction with the local area as a place to live

Outcome 7: People feel safer in their neighbourhoods and anti-social behaviour is tackled

Tower Hamlets is a vibrant, diverse and exciting place to live, work and visit and we want everyone to feel safe and enjoy all that it has to offer, however residents report that crime was their top concern in 2018. Tackling the interlinked issues of violence, anti-social behaviour (ASB), drugs and alcohol is a significant challenge for the borough. The Council is working closely with a range of partners to deliver a holistic response that includes looking at drugs and alcohol misuse as a health issue, and addresses the root causes and consequences of crime, abuse and exploitation. The Council will make use of all the tools and powers available to it to prevent issues occurring and to focus on robust enforcement against the drugs market and its associated violent crime and ASB. We will continue to fund additional police officers and support Operation Continuum activity. The Council will also seek to reduce the

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harm caused to communities by offering improved support to victims, safeguarding people at risk of abuse or neglect, and effective treatment services for those with addictions. In addition the Council will be reviewing its approach to CCTV and evaluating its Neighbourhood Management Pilot to assess what more can be done to enhance feelings of safety by ensuring that its response is evidence led and co-produced with residents.

What actions will we take? 1. Provide education and awareness-raising to prevent and tackle issues including

violence against women and girls, safeguarding and exploitation 2. Run a new specialist substance misuse project and get more people into

treatment programmes, so that more people get the help they need 3. Make it easier for residents to report ASB to the Council 4. Continue partnership working with the Police to carry out geographic drugs

operations (‘Operation Continuum’) so that drugs markets are continually disrupted

5. Invest in CCTV, Police personnel and other resources to proactively tackle crime and ASB, enabling us to identify hotspots and take swift action

6. Hold perpetrators of crime and abuse to account, using the full spectrum of our enforcement powers when needed

7. Work closely with the community to prevent, identify and tackle crime, ASB, abuse and community tensions

8. Provide personalised support for victims, including new specialist support to victims of knife crime at the Royal London Hospital


Residents’ concern about crime and anti-social behaviour

Young people entering the youth justice system for the first time

Residents’ feeling of safety in their local area

Drug users successfully completing treatment

Victims of violence against women and girls or hate crime who feel safer after engaging with victim support

Outcome 8: People feel they are part of a cohesive and vibrant community

Tower Hamlets is a place with a rich history- from its beginnings as an historic docks and manufacturing area it has grown and developed at a faster rate than anywhere else in the UK. This culturally rich and diverse area faces unique challenges as it moves from a place of deprivation to become an extension of the Central London economic powerhouse and a vibrant borough in its own right.

We are also one of the most vibrant and diverse communities in the UK. Local people are proud of the high levels of community cohesion, and value the rich cultural offer that comes with this mix. The Voluntary and Community Sector is crucial to the economic and social life of the borough, for example, as an employer,

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service provider, and provider of community space. We need to continue to ensure the sector is aligned as much as possible to what citizens in the borough want and need. Starting later this year, the new The Local Community Fund (LCF) Programme will focus on outcomes for local residents and making a positive impact on their lives, while building the capacity of local voluntary and community sector organisations.

In February 2019, the government published its Integrated Communities Action Plan which we will use to develop Council’s Cohesion Framework to help embed cohesion in all our business. This will have a focus on building positive relationships valuing diversity, supporting equality of opportunity and enhancing a sense of belonging.

What actions will we take? 1. Work with stakeholders and communities to tackle emerging tensions and issues

within and between communities including those generated by hate crimes or extremism

2. Roll out community-led improvement projects & programmes including supporting the voluntary & community sector to deliver services and bring people together

3. Improve services for refugees and people fleeing harm 4. Deliver projects to support integration of new communities 5. Deliver initiatives to celebrate diverse cultures of our borough


Level of hate crime

Residents' level of volunteering

Residents' perception of people from different backgrounds getting on well

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Priority 3 - A dynamic outcomes-based Council using digital innovation and partnership working to respond to the changing needs of our borough

Tower Hamlets is the UK's most dynamic, innovative and exciting place. Change is happening at a faster rate than any time in our history. We are seeing a rapid expansion in the number of homes and jobs and a changing, growing population. The vast majority of residents (92%) have access to the internet.

With these increased pressures and reduced funding, we need to embrace technology and work with residents and partners to make the most of our resources.

To get the best outcomes, the Council needs to be more agile, leaner and strategic, and cannot deliver everything. So we will commission services when other organisations are in a better position to provide them. We will work in partnership with stakeholders to share resources and become more than the sum of our parts.

We will also use digital innovation to improve services and to give people the opportunity to take a greater role in improving our borough.

Smarter Together is the Council’s blueprint for transformation. Smarter Together will make us become a dynamic outcomes-based organisation using digital innovation and partnership working to respond to the changing needs of our borough. Our transformation is shaped by three lenses – Partnership, Outcomes and Digital.

o Partnership: Collaboration with residents, businesses and partners at the earliest stage.

o Outcomes: Services will be delivered by organisations that offer the best outcomes for our residents. That means measuring the difference we are making in people’s lives. We will become agile in responding to issues and finding solutions inside and outside the Council.

o Digital: Accessing most Council services will feel similar to the best online experiences. Smart technology will allow people to transact, feedback and measure services with ease.

There are three overarching outcomes under Priority 3 that the Council’s actions for the coming year are focused on achieving, and these are described in the following sections.

Outcome 9: People say we are open and transparent putting residents at the heart of everything we do

Our residents are varied and have a range of needs. Everyone who lives, works, studies, and visits or does business in Tower Hamlets will use a Council service in some form, whether they are visiting one of the Council’s parks, applying for a parking permit or simply walking down one of our streets.

We want to make it easier for people to contact us online. Helping our residents to become confident dealing with us online helps them to become more independent

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financially, socially and practically. This will help them in other areas of their lives, such as getting information about jobs, or getting a better deal from their energy provider.

We will be ‘digital by default’ (which means that this will generally be the main way that people contact or do business with us for straightforward matters).

Every resident should feel that they have received excellent customer service when dealing with us and should be able to easily connect with us whenever they want. In most cases we should be able to meet their needs first time around. To do this we will need to work with our residents to get feedback, as well as analysing the information provided by people using our services.

We need to transform our approach to business intelligence and insight. The Council and its partners collect and store vast amounts of data on our citizens, businesses and communities that we use as part of our everyday service delivery and transform into intelligence to inform service planning. However much of this data is fragmented and underused – we need to unlock the potential of our data giving staff the power to make better informed decisions to deliver better outcomes for our citizens and communities.

Through positive delivery of our Community Engagement Strategy, we want to strengthen our relationship with local people by enabling them to be actively involved in the design and delivery of services.

What actions will we take? 1. Work with internal and external stakeholders to deliver improvements in the

Council’s consultation and engagement approach 2. Develop a digital Strategy which supports our work to improve customer services

though digital platforms 3. Develop initiatives to increase democratic participation by local communities 4. Deliver a Communications Strategy to tell the story about the Council


Service user satisfaction with the Council's online service offer

Residents’ satisfaction with Idea Stores and libraries

Residents’ perception of being involved in Council decision-making

Residents’ perception of Council transparency

Residents’ perception of being kept informed by the Council

Outcome 10: People say we work together across boundaries in a strong and effective partnership to achieve the best outcomes for our residents

We will work in partnership with stakeholders to share resources and become more than the sum of our parts.

The Tower Hamlets Strategic Partnership is the borough's Local Strategic Partnership bringing together key stakeholders to provide and improve services and outcomes for local residents. In particular it gives residents more powerful input in the way

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services are provided and ensures that all aspects of the community work together to achieve the objectives of a borough plan.

As partners have reflected on the key opportunities and challenges facing the borough, we have also thought hard about how we are going to achieve our objectives. In a time of austerity and uncertainty, ‘less of the same’ will not be enough. Public sector organisations in the borough are already making big changes to the ways that they work, and this will need to continue. And as the richness of our conversations about the role of organisations and people beyond the public sector has shown, we really do all need to play our part. Responsible local businesses, a thriving voluntary sector and residents themselves are critical to achieving this Plan.

What actions will we take? 1. Understand public sector investment, commitments and resourcing across Tower

Hamlets 2. Deliver a Tower Hamlets place-based campaign 3. Develop a clear set of priorities for partnership working 4. Work with partners to mitigate impact of Brexit on communities and

stakeholders in Tower Hamlets 5. Improve collaborative working and integration with partners to drive

improvements against the four priority areas of the Tower Hamlets Plan


Residents’ satisfaction with Council and partner response to anti-social behaviour (ASB)

Children and young people receiving support from mental health services

Older people who have not returned to hospital after being supported through reablement services

Residents supported into sustainable employment by the WorkPath partnership

Outcome 11: People say we continuously seek innovation and strive for excellence to embed a culture of sustainable improvement

Public services are under huge long-term financial pressures and are also facing rising demand from service users. There are already many initiatives underway to change the way that public services are designed and run in Tower Hamlets, such as the integration of health and social care.

We as civic leaders will need to increase our efforts, and ensure a greater coherence of approach across our organisations.

We are calling this a ‘whole system’ approach to change in Tower Hamlets, and it will require us to work together in new ways, build better alignment of our respective efforts in service of our shared aims, and put the interests of the borough above those of our individual organisations.

What actions will we take?

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1. Deliver the Smarter Together Transformation Programme 2. Deliver improvements to how we use our land and buildings 3. Improve the IT infrastructure and modernise applications to enable innovation 4. Develop a modern workforce within the Council through culture change 5. Embed Outcomes Based Budgeting across the Council 6. Deliver a programme of service reviews to improve operational effectiveness 7. Review business intelligence processes and procedures to support better

outcomes for local people 8. Change our approach to performance management to focus on better outcomes

for residents


Council staff turnover rate

Council staff sickness absence rate

Media and press view of the Council

Residents’ perception of the Council doing a better job than last year

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The Borough by numbers

(To be added)

Council Spending by Strategic Priority Outcome (To be added)

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Cabinet Decision

24 April 2019

Report of: Debbie Jones, Corporate Director Children and Culture


The Tower Hamlets Safeguarding Children Partnership (THSCP) Arrangements

Lead Member Councillor Danny Hassell, Cabinet Member for Children, Schools and Young People

Originating Officer(s) Daniel Devitt Project Manager THSCP


Key Decision? No


26 February 2019

Reason for Key Decision N/A


Priority 1: People are aspirational, independent and have equal access to opportunities Outcome 2: Children and young people are protected so they get the best start in life and can realise their potential

Executive Summary

The Children and Social Work Act 2017(CSWA17) included radical changes to children‟s safeguarding and child death review. Transitional guidance requires local responses to the new system to be published by June 2019, new partnerships and child death review systems to be operational by September 2019 and migration from the current arrangements and full implementation by March 2020. The development of the Tower Hamlets Safeguarding Children‟s Partnership (THSCP) is being steered by an executive group consisting of the key local partners from LBTH, Clinical Commissioning Group and local Police. Underlying principles in support of the development of the Tower Hamlets Safeguarding Children Partnership are focussed on Child Protection, Assurance and Learning. Support was received from the LSCB Executive in December 2018 to commence detailed planning of the new system. This paper gives an overview of progress to date and next steps. Recommendations: The Mayor in Cabinet is recommended to:

1. Note the progress to date in the development of the Tower Hamlets Safeguarding Children Partnership and Child Death Review (CDR) systems outlined in (paragraphs 3.1 to 3.14 and appendices A, B and C)

2. Approve the authority of the Corporate Director Children and Culture to Page 99

Agenda Item 6.3

act on behalf of LBTH at the THSCP (paragraph 3.4) 3. Approve the move to the shared CDR function in North East London

(paragraph 3.13) 4. Note the indicative budget outlined in paragraph 3.7 and works underway

to scope the full costs of the THSCP (paragraph 3.1). 5. Note the works underway to scope the full costs and contribution to North

East London CDR systems (paragraph 3.8.) 1 REASONS FOR THE DECISIONS 1.1 The THSCP is the local response to the statutory changes arising from the

Children and Social Work Act 2017. Significant work has been undertaken from August 2018 to scope the impact of the new legislation and frame a robust local response to it.

1.2 The recommendations above are essential decisions if the THSCP is to become an operational entity within the required timescales and the local CDR systems established by September 2019.

1.3 Agreement to delegate authority for the Corporate Director Children and Culture to act as the statutory lead for the council is also sought.

1.4 Support is sought for the resourcing of the THSCP.

1.5 Support is sought for the migration of the existing Tower Hamlets Child Death Overview Panel (CDOP) to the new wider area footprint (City and Hackney, Waltham Forest, Newham and Tower Hamlets) in order to meet statutory guidance for the new CDR system.

2 ALTERNATIVE OPTIONS 2.1 No alternative options have been explored as the establishment of the

Safeguarding Partnership is a statutory duty. The THSCP has been designed to meet or exceed the requirements of statutory guidance and present a value for money, agile and robust partnership.

3 DETAILS OF THE REPORT 3.1 The Children and Social Work Act 2017 (CSWA17) requires the establishment

of new children‟s safeguarding and Child Death Review (CDR) systems. Transitional guidance issued requires local plans to be published by June 2019, operational delivery alongside a continuing Local Safeguarding Children Board (LSCB) from September 2019, and full implementation to be achieved by the end of March 2020. The new CDR must be operational by September 2019. There are a number of key differences between the old and new systems outlined in the table below.

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Theme Old System New System

Voice of the Child

Seen as best practice and good to do but not mandatory at LSCB level – often requested via delivery partners is NHS consultation systems, Social Care apparatus etc.

Mandatory requirement to support the inclusion of meaningful Voice of the Child input and build operate and iterate the new system in partnership with children, young people, families and the wider community.

Local area Children’s Safeguarding Business

Delivered by LSCBs Delivered by Safeguarding Children Partnerships

Local Leadership

Pivotal role of the LSCB Chair as an independent champion and system leader working with local partners

Abolished in the new system in favour of the three statutory partners and the Independent Scrutineer.

Local Safeguarding accountability

Ultimately all system partners - but key accountability in practice via the Independent Chair and usually the Director of Children‟s Services

Three statutory leads acting as or on behalf of the accountable leads for local authority, CCG and Policing in the area served by the partnership

Local Multi-Agency Partnership Working

Delivered through the LSCB Operations Group with Education, Third Sector and statutory agencies and partnership

Delivered through the Relevant Agencies including but not limited the following agencies and organisations: o Schools, colleges and other

educational providers o Housing – a representative

Registered Social Landlords and Housing Associations and Tower Hamlets Housing

o Youth Justice/ Probation (including National Probation and CRC Probation)

o Department for Work and Pensions

o Voluntary Organisations represented by the Tower Hamlets Voluntary and Community Sector

Review of cases

Mix of local and serious case methodologies – linking into National panel via Department for Education.

Focus has often been on retrospection and detailed historical issues, with increasing length and complexity of reviews.

Local case review and linkage to a National Safeguarding Practice panel that can request a serious case review for cases of potential national importance, system impact

Focus on agile and timely action planning and system intervention.

Structure, A degree of local Expectation that each area will

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outputs and standards

adaptation but overall LSCB format (executive group, wider partnership groups, Communications, Learning and Development and other groups working key vulnerable cohorts) defined by Working Together to Safeguard Children (WTSC) 2015

Impact and effectiveness of whole system captured via Section 11 audit responses and inspections

Outputs include SCRs and annual reports, ongoing assurance or themed works.

innovate and find appropriate solutions to local issues.

Light touch requirements from WTSC 2018.

Local structure largely driven by the Arrangements agreed between LA, CCG and Police.

Impact captured via local Section 11 audits and Joint Targeted Area inspections.

Outputs include local case review, larger scaled reviews when requested by national panel, annual reports and ongoing assurance or themed works.

Child Death Review

LSCB Subgroup reporting via LSCB into HWBB etc

New CDR system at wider footprint with two statutory partners (CCG and Local Authority)

Table 1 Differences between the Old and the New Children’s Safeguarding systems

3.2 The Arrangements Document: The structure and functions of the new system

are captured in an Arrangements document. This outlines the operational procedures and underlying principles for the THSCP, plan for LSCB workload migration, how local case reviews methodology, local quality and assurance linkages, strategic leadership and oversight in Tower Hamlets and the wider system. Alongside this a THSCP risk register is under development and exploration of potential risks and mitigations is underway. Work is being informed by feedback from the Children‟s Services Improvement Board, Corporate Safeguarding Group, LSCB Executive Board and LSCB Operational Group and ongoing engagement with strategic and operational partners.

3.3 Operational footprint: The THSCP will operate in a single area – the local authority footprint for Tower Hamlets. To ensure the development of a mature and stable system this will remain the case for at least two years. It is recognised that close working with local area neighbours and partners is essential and we will work towards ensuring that partners across North East London are closely involved in the development of the THSCP. Specific priorities include CDR, policing and work with the wider NHS in North East London.

3.4 Strategic Leadership: The THSCP is jointly led by the three named statutory

partners who function as the decision-making Executive for the THSCP and act as representatives of their respective agencies. They are supported in this role by the Independent Scrutineer, which replaces the role of the independent chair in the LSCB.

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Organisation Named Accountable Lead

Role

London Borough of Tower Hamlets

Debbie Jones Director of Children‟s Services

Tower Hamlets Clinical Commissioning Group

Jane Milligan Delegated to Selina Douglas

Accountable Officer NEL CCGs Managing Director WEL CCGs

Tower Hamlets and Hackney Basic Command Unit Metropolitan Police

Sue Williams Chief Superintendent Shared BCU Tower Hamlets and Hackney

Table 2 The THSCP Statutory Partners

3.5 The statutory partners will be accountable to their own organisational leadership, and to each other, but to strengthen this they will present updates as a collective to local strategic groups (Health and Wellbeing Board, Corporate Safeguarding Group, Children‟s Services Improvement Board, Children and Families Partnership Board etc).

Fig 1 Indicative structure of the THSCP March 2019

3.6 Additionally, it is proposed that the Independent Scrutineer will provide a

support and challenge function for the partnership and a direct link to the council‟s Chief Executive‟s office and Cabinet Member for Children, Young People and Schools. This provides direct assurance and updates on the works

Executive Group

( Barts Health, LA public Health, THEP, Relevant Agencies

Voice of the Child/Representation from CYP

Executive Group

(LA, CCG, MPS - Statutory Partners/Accountable Officers

THSCP Secretariat

Strategy Manager, Administrratror, Data Analyst

Communications, System Learning and Training Group - potentially shared with SAB

Task and Finish Core Processes and Priority Themes

Development Groups

Reccomendatons and Oversight Group ( extracting issues from incidents, CDR processes, local, regional and national themes

Safeguarding Adults Board

Independant Scrutineer

Potential THSCP governance and reporting to:

Cabinet/Lead Member Children and Families

Health and Wellbeing Board

Children and Families Partnership Board

THT /BWGW Board

CQRMs

Multi Agency Safeguarding Committee

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delivered by the THSCP and of the maturation and strengthening of the partnership ad a whole. The statutory partners are supported by a wider group composed of “Relevant Agencies” including Education, Public Health, The Voluntary and Community Sector etc. with a flexible membership in line with the evolving needs of the THSCP.

Theme LSCB Chair Independent Scrutineer

Overall role in the system

Independent Chair and overall lead for driving strategy business across the partnership.

In WTSC 2018 effectively a light touch audit role with some responsibility for directing format of partnership outputs – i.e. style of local review and annual report.

In THSCP the role is envisaged as a more developed challenge and critical friend function that will work to develop the working relationships of the statutory partners and

Lead on liaison with Joint Area Targeted Inspections and support for statutory partners‟ link to national panels.

Chairing of Partnership Groups

Often delivered by LSCB Chair – Usually Exec Group chairing as a minimum.

Independent Scrutineer does not do this – they attend /support the groups and these are chaired by the statutory partners or local strategic leads.

Line Management/ Accountability

Often via Chief Exec of the LA, sometimes DCS.

Potential issues in the new guidance on who manages the role and how to secure independent stewardship and support of the partnership. In the local version proposed, the role will link directly to either or both the CE of the Local authority, Lead member for Children and Families to ensure that the IS can act appropriately with regards to the three statutory partners.

Table 3 Comparison of functions between the LSCB Chair and Independent Scrutineer

3.7 Budgetary requirements: The current LSCB system costs on average £185k

per annum with the lion‟s share of contributions met by the local authority. Work is underway to scope the likely costs of the THSCP and contributions required from each local partner.

3.8 Costs for the CDR systems are currently being mapped in North East London and

a separate assessment of the contribution to the local CDR is being undertaken. 3.9 The THSCP will have two main areas of expenditure, Secretariat and Local

Review.

Secretariat: In line with the proposed structure there will be three main members of the secretariat, with an additional fourth member potentially to be

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sourced from either local authority or NHS expertise as a contribution in kind or as a direct cost pressure.

Role Proposed Grades- Indicative only

Approximate costs per annum

Independent Scrutineer Independent consultant at a day rate of £600 per day with 8 days per calendar month for the first two years of the THSCP operation dropping to 2 days pcm.

£57,600 pa for 2 years dropping to £14400 pa thereafter.

Strategy Manager FT PO8 position £72000

Administrator/Coordinator FT PO5 £58.400

Data Analyst 0.5 WTE PO5 to be confirmed £29.200

Total potential cost Circa. £217,200

Table 4 Proposed THSCP staffing and indicative costs

3.10 Local Review: A key feature of the new system is the move away from Serious Case Reviews (SCR) in favour of local review. It is anticipated to be less resource intensive than and SCR, but the likely budget required for local reviews is currently unknown. The THSCP is exploring a flexible cost sharing model akin to the tripartite structures currently used in joint commissioning. This would outline the thresholds whereby a particular partner would or would not be required to support the costs of local review and a panel comprised of the statutory partners, Independent scrutineer and other relevant personnel would be convened to determine the allocation of cost sharing across the THSCP.

3.11 Contributions to the THSCP: Specific budgetary contributions from each

partner are still to be determined. Scoping of financial and other contributions in kind for the new system is being mapped. Currently the LSCB receives contributions from a range of non-statutory partners such as the London Fire Brigade. Work is underway to understand if these contributions can continue in addition to those requested from the THSCP statutory partners.

3.12 Child Death Review Systems: Under the new legislation formal collaboration

between responsible partners for child death reviews will be undertaken at greater scale, with a footprint determined by a minimum of 60 cases reviewed each year enabling the formation of Child Death Review systems covering larger area than the previous local arrangements. There are a number of significant changes to the CDR system

Changes Implication

Shift of lead responsibility from Department for Education to Department of Health and Social Care

The new system creates Child Death Partnerships with Local authority and Clinical Commissioning Groups

Larger “footprint” of the local CDR systems with a minimum 60 caseload.

CDOP s will need to amalgamate in London; each Integrated Care System or area would have 1 or 2 rather than the current 5 to 7 CDOPs.

Development of a new “key worker” to act as a single point of contact with the bereaved.

This has been generally welcomed but there is no new resource to deliver this function. Specifics of how it should be implemented are currently unclear.

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Establishment of Child Death Review Meetings (CDRM).

This requires significant development of acute and community mortality and morbidity review meetings.

Themed review meetings for high volume or high complexity deaths.

Cases of high volume or complexity considered together to enhance expert review

Revision of additional requirements to address a number of “complex” circumstances.

Includes deaths of UK-resident children overseas, with learning disabilities, in adult healthcare settings, suicides, inpatient mental health settings, deaths in custody.

Table 5 Differences between the CDOP and CDR systems 3.13 To meet the requirements two CDR systems are proposed in North East London.

The first based around the Barking, Havering and Redbridge systems and a second based around City and Hackney, Waltham Forest Newham and Tower Hamlets. This allows for the wider area working required by the new guidance and the continuance of local assurance and review of child deaths in each area.

3.14 The new CDR system arrangements must be operational by no later than

summer 2019. See Appendix C for more detail on the CDR system.

4 EQUALITIES IMPLICATIONS 4.1 The THSCP seeks to provide a local response to the new statutory

requirements. An EIA has been completed and this has identified no adverse impact. In addition, with regards the statutory requirement to capture youth voice as a core part of the design and operational phases of the work works with the Youth Service and other youth facing representatives has commenced to refine and strengthen this essential component of the THSCP. The government EIA states the following: “These measures have no direct equality impacts by reference to the protected characteristics. The measures replace one framework for assessing and learning from serious incidents with another. More effective working of this nature should have a beneficial impact on all children engaged with child protection and safeguarding services, including those with protected characteristics.”1

5 OTHER STATUTORY IMPLICATIONS 5.1 The THSCP is the local response to the statutory requirement to deliver a

Safeguarding Partnerships to replace the Local Safeguarding Children‟s Board. The Department of Education requires plans for the new partnership to be published by June 2019, a partnership to be operational alongside the existing LSCB by September 2019 and full migration of all children‟s safeguarding functions by March 2020. With three statutory partners from the CCG, Police and Local Authority outlined in section 16E of the Children and Social Work Act 20172 requires that they are the most senior accountable leads for safeguarding at local level.

1 See https://www.parliament.uk/documents/impact-assessments/IA16-008.pdf

2 See http://www.legislation.gov.uk/ukpga/2017/16/part/1/chapter/2/crossheading/local-arrangements-for-safeguarding-and-

promoting-welfare-of-children/enacted Page 106

https://www.parliament.uk/documents/impact-assessments/IA16-008.pdf

http://www.legislation.gov.uk/ukpga/2017/16/part/1/chapter/2/crossheading/local-arrangements-for-safeguarding-and-promoting-welfare-of-children/enacted


5.2 The CSWA17 and WT18 are clear on the need for the statutory partners to lead

the local system, taking direct accountability for both strategic and operational functions of the partnership. The three statutory partners have equal and joint responsibility for local safeguarding arrangements. 3 Local safeguarding accountability resides with these three senior officers. Alongside new requirements for local review processes the THSCP has a new statutory role, the Independent Scrutineer which will, in addition to the core responsibilities of liaison with Joint Targeted Area Inspections, format of local reviews and THSCP outputs, will have a key role in supporting, mentoring and providing independent challenge to the statutory partners and ensure that non statutory partners and Youth Voice are central to the THSCP.

6 Risks and mitigations: A full Risk Register is being assembled to support the THSCP and high-level risks captured in the appended report.

7 COMMENTS OF THE CHIEF FINANCE OFFICER 7.1 Tower Hamlets Council (LBTH) is currently engaging with the other two

statutory partners (THCCG and Police) to scope the cost of running the Safeguarding Children Partnership (SCP) and the match funding required by all three statutory partners.

7.2 Under the existing arrangement, LBTH is the major financial contributor to the running cost of the LSCB. In 2017-18, the LSCB budget was circa. £186K of which LBTH contributed circa. £145K.

7.3 Although the cost of running the SCP is still being scoped, it is clear that the cost is likely to be higher than the cost of the current LSCB considering the increased responsibility of the SCP. The indicative cost of the secretariat function is circa. £217K and this does not include the cost of the Local Reviews.

7.4 The discussion around the cost of the SCP presents an opportunity for the match funding by statutory partners to be examined.

7.5 It is expected that an update paper will be presented to Cabinet once the cost of running the SCP has been determined and match funding agreed by the three statutory partners.

8 COMMENTS OF LEGAL SERVICES 8.1 The changes to the Children Act 2004 („the Act‟) introduced by the Children and

Social Work Act 2017 are outlined in the body of the report. The revised Act shares responsibility for safeguarding equally between the three statutory safeguarding partners, and requires that local arrangements must be designed and kept under review to meet changing local need. The proposals for the THSCP comply with the legal framework of the Act, supporting regulations and

3 See WT18 Chapter 3 P73

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/729914/Working_Together_to_Safeguard_Children-2018.pdf Page 107

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/729914/Working_Together_to_Safeguard_Children-2018.pdf


Chapter 3 of the statutory guidance, Working Together to Safeguard Children (2018).

8.2 The 2018 Guidance sets out that the council‟s chief executive will be the lead representative for the council. This can be delegated to a senior officer who has the authority to speak for the council, take decisions on behalf of the organisation and commit them on policy, resourcing and practice matters and hold their own organisation to account in respect of implementing local arrangements. However, the chief executive will ultimately remain responsible for any actions or decisions on behalf of the council.

8.3 The safeguarding partners must select which of the other relevant agencies set out in the Child Safeguarding Practice Review and Relevant Agency (England) Regulations 2018 they will work with to safeguard and promote the welfare of children, and the agencies selected must act in accordance with the local arrangements. The Guidance sets out that the safeguarding partners must ensure that all schools, colleges and other educational providers in the area to be fully engaged in the new safeguarding arrangements. Inclusion of the Managing Director of the Tower Hamlets Education Partnership (THEP) with additional representation from the Further Education sector as relevant agencies meets this requirement.

8.4 The statutory requirements for Child Death Reviews are set out in sections 16M-16Q of the Act and Chapter 5 of the Guidance. These must be carried out in partnership between the council and the CCG, and two or more local authority areas may combine to undertake CDRs. The proposals contained within Appendix C comply with the statutory framework and Guidance.

_________________________________ Linked Reports, Appendices and Background Documents Linked Report NONE Appendices

Appendix A - Report to the Corporate Safeguarding Group 15 February 2019 – Refreshed report 29th March 2019

Appendix B - Draft THSCP Arrangements Document

Appendix C - WELC CDR systems overview report Background Documents – Local Authorities (Executive Arrangements) (Access to Information) (England) Regulations 2012

NONE Officer contact details for documents: N/A

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Tower Hamlets Safeguarding Partnership

Update Report Meeting Date: 29th March 2019

Title of Report:

Update for the Corporate Safeguarding Group (CSG) on the Tower Hamlets Safeguarding Childrens Partnership

Author(s): Dan Devitt

Presented by: Debbie Jones

Status of Report (select one please)

For information

Update by Request of the BWGW Board

Action(s)/Decision Required

For Information Feedback on THSCP Progress requested

Is there a policy or decision that needs documenting and communicating post the decision?

NA

Appendices NA

Date report was presented to CSG Original report was 15/02/2019 This version updated to reflect Approval for Safeguarding Partnership and Child Death Review System at WELC footprint on March 26th 2019

Executive Summary

The Children and Social Work Act 2017(CSWA17) radically changed the safeguarding landscape in England and included replacement of Local Safeguarding Children Boards with new locals Safeguarding partnerships led by three Safeguarding Partners (LA/ Police and NHS). Transitional guidance issued in 2018 gives clear requirements and timescales for the functions and establishment of the new system. Local plans are to be published by June 2019, operational alongside a continuing LSCB from September 2019 with full implementation is achieved by the end of March 2020. Discussions with the Corporate Safeguarding group in December 2018 have informed an approach to governance and assurance with suggested linkages with key LBTH strategic leaders to ensure that the THSCP is both well connected to local systems and acting in an appropriately robust and independent manner. Alongside this a THSCP Risk register is under development and exploration of potential risks is underway. Current risks include the fragmentation of local safeguarding childrens systems, loss of key works or data in progress and finance for the THSCP. Works to date have focussed on the drafting of key programme materials:

Arrangements - including key governance and reporting arrangements, structure of the THSCP working groups, outline functions and relationship with wider NHS, Police and Local authority systems in North East London.

Job descriptions – Including Independent Scrutineer, Strategy Manager, Administrator/Co-ordinator. (An additional Data analytics function is required and will be potentially sourced via LBTH Public Health, Strategy Directorate or local NHS)

Programme plan with key milestones, outputs and metrics, Risk Register, Equality Impact Assessment, communications and training plan and related programme materials

Budget outline statement for the statutory partners

Outline of migration of works from the LSCB – between September 2019 and March 2020

Outline of local review methodology options for replacement of Serious Case Review.

Alongside this a three tier communications engagement and mobilisation plan is being drafted to address the needs of three core system elements: 1 The new statutory partners 2 Wider partnership – including current LSCB Partnership members

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3 Wider system and public - including an emphasis on continuity of operational delivery.

Aligned to this are the separate requirements for the establishment of new Child Death Review (CDR) arrangements in North East London and Tower Hamlets Together - Workforce and Organisational Development work stream assessing the potential for Safeguarding training across partners to be standardised TH CCG APPROVED the shift of CDR functions to a WELC footprint, and the delegated authority of the CCG’s statutory partner on 26/03/2019.

Key issues/Decisions/Recommendations

Details of update/ recommendations/decisions/ timescales for decisions (delete as applicable)

CSG are asked to: Note this report and feedback on the Arrangements and draft job descriptions and overall programme progress.

Details on who has been consulted with on this paper to date and details of further plans for consultation.

The works represented here have been shared with the LSCB, Born Well growing Well and Tower Hamlets Together systems. Further consultation will follow from the LSCB sessions in February and March 2019. Draft job descriptions are being scoped with LBTH

Discussion of how best to utilise LBTH and wider Youth voice apparatus to support the Voice of the Child in the THSCP on an ongoing basis is underway with Sanjea-Marie Green Head of the Youth Service.

Partner updates/engagement or briefings already planned include: Transitional Executive Board Meeting 25

th February 2019,LSCB Operations Group 26

th February 2019, NEL Child Death Review

systems meeting Friday 1st March 2019, TH CCG Board 26

th March, Mayors Advisory Board

4/04/2019 and Cabinet on the 24th April 2019

Risk implications

1. There is a risk that the THSCP will either be inadequate in meeting or exceeding the statutory requirements, or through complexity of the task not be available to meet the statutory deadlines outlined above - failure to deliver the required changes will amount to a failure to discharge statutory responsibilities and deliver a stable child protection system for Tower Hamlets.

2. There is a potential for fragmented local safeguarding arrangements as local areas develop new systems with minimal statutory guidance to direct them and a move away from the standardised LSCB approach to a local partnership that could be significantly different from neighbouring systems.

3. There is a potential for data loss or lack of progress in case work as it is migrated between the existing LSCB and the new system.

4. The financial requirements of the evolving system are as yet unknown and come at a time when all partners are experiencing reduced resources.

Budget/Legal Issues

Discussions between statutory partners to the THSCP will need to address the real cost in terms of time, personnel and budgets associated with local reviews of childrens safeguarding. Costs incurred by the new system will fall into two main categories Personnel: The THSCP requires three new roles and job description reflecting the new system requirements. One is on a part time/consultant basis and two others are yet to be graded by LBTH Human Resources. An additional role - providing Data/Analytics support may be available via LBTH Public Health or local NHS partners. Local Review: The development of a new approach to local case review and commissioning implications are being scoped. Indicative budget information is being sought from the LSCB and other areas. Nationally the cost of local reviews has been on average of circa £8000 per case up to £15000 for more complex cases.

Equalities considerations

An Equality Impact Assessment is underway.

CYP Engagement Issues

CYP Engagement will be a key feature of the new system and is being explored with local engagement partners including LBTH Youth Service

Integration Issues: Page 110

TBC

Report Detail

In 2015 the Government commissioned the Wood Review of Local Children safeguarding arrangements and from this framed the Children and Social Work Act 2017(CSWA17). This requires the establishment of a new safeguarding system. Transitional guidance issued in 2018 gives clear requirements and timescales for the functions and establishment of the new system. Local plans are to be published by June 2019, operational alongside a continuing LSCB from September 2019 with full implementation is achieved by the end of March 2020. The development of the Tower Hamlets Safeguarding Children Partnership (THSCP) is being steered by an executive group consisting of the key statutory local partners, supported by a small group of essential local stakeholders. Discussions with the Corporate Safeguarding group and LSCB executive in December 2018 have informed an approach to governance and assurance with suggested linkages with key LBTH strategic leaders to ensure that the THSCP is both well connected to local systems and acting in an appropriately robust and independent manner. Key features of the system will be captured in an Arrangements document which will outline the operational procedures and underlying principles for the THSCP, including a statement of how LSCB workload will migrate to the new system, how local serious case review will be delivered and links the local Quality and assurance mechanisms, key strategic leadership in Tower Hamlets and the wider system. Key items for the THSCP arrangements are outlined below. Alongside this a THSCP Risk register is under development and exploration of potential risks is underway. Current risks include the fragmentation of local safeguarding childrens systems, loss of key works or data in progress THSCP Arrangements Overview: The new system requires new arrangements to drive an agile and responsive system offer. With an emphasis on rapid review, iterative/continuous improvement and a focus on outcomes the new system has many features aligned to Quality Improvement and related service system developments. A key feature of this is the need to move away from static bureaucratic processes and develop more fluid and impactful systems of review, challenge, challenge and ultimately improvement. Early Identification and Early Help are key concepts and related borough wide strategic priorities. The THSCP will operate in parallel with the existing LSCB as it matures and liaise to ensure that the existing arrangements are seamlessly handed over as required by the transitional guidance from DfE. Operational footprint: The THSCP will operate in a single area – that of the local authority and CCL footprint for Tower Hamlets. To ensure the development of a mature and stable system is developed it is envisaged that this will remain the case for at least two years prior to any further consideration of cross borough working or development. It is recognised that close working with local area neighbours and partners is essential, and in the case of the Policing and NHS in north East London ( including Child Death Review systems) aspects of the new system, we will work towards ensuring that partners across North East London are closely involved in the development of the THSCP. Strategic Leadership: The THSCP is led by the three named statutory partners, the London Borough of Tower Hamlets, Tower Hamlets CCG and the Central East Basic Command Unit (BCU)1 of the Metropolitan Police. They form the core partnership and function as the decision making Executive for the THSCP. They will have the authority or delegated authority to speak on behalf of the safeguarding partner they represent, make decisions on behalf of their organisation or agency and commit them on policy, resourcing or practice matters, and hold their own organisation or agency to account on how effectively they participate in and implement the local arrangements. They are supported in this role by the Independent Scrutineer.

Organisation Named Accountable Lead Role

1 NB: The BCU is shared with the Hackney Safeguarding system. The new BCU will operate a single front door for

police support and resources for safeguarding across all ages and agendas.

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London Borough of Tower Hamlets

Debbie Jones Director of Children’s Services

Tower Hamlets Clinical Commissioning Group

Jane Milligan Delegated to Selina Douglas

Accountable Officer NEL CCGs Managing Director WEL CCGs

Tower Hamlets and Hackney Basic Command Unit Metropolitan Police

Sue Williams Chief Superintendent Shared BCU Tower Hamlets and Hackney .

To strengthen the THSCP the Arrangements and job description for the Independent Scrutineer role have been set out to ensure system linkages are direct and appropriate. The Statutory Partners will be accountable to their own organisational leadership, and to each other, but to strengthen this they will present updates to local strategic groups (Health and Wellbeing Board, Corporate Safeguarding Group, Childrens Services Improvement Board, Children and Families Partnership board etc). Additionally, it is proposed that the Independent scrutineer will provide a direct link to the LBTH Chief Executives office and Lead Member for Childrens service. Currently the feasibility of one or both of these leaders providing a shared line management or stewardship of the role is being explored. Regardless of the eventual reporting lines it is suggested that a close working relationship between them and the Independent scrutineer role is cultivated so that the IS can provide direct assurance and updates on the works delivered by the THSCP and of the maturation and strengthening of the works between the statutory and non statutory partnership members.

Relevant agency partners of the Executive Group: The Statutory partners are supported by a wider membership of Relevant Agencies from the local system. including but not limited the following agencies and organisations:

o Schools, colleges and other educational providers o Housing – a representative Registered Social Landlords and Housing Associations and Tower

Hamlets Housing o Youth Justice/ Probation (including National Probation and CRC Probation) o Department for Work and Pensions o Voluntary Organisations represented by the Tower Hamlets Voluntary and Community Sector

Structures and Roles: The essential role of the three statutory partners outlined in section 16E of the Children and Social Work Act 20172 requires that they are the most senior accountable leads for safeguarding at local level. The CSWA17 and WT18 are clear on the need for the statutory partners to lead the local system, taking direct accountability for both strategic and operational functions of the partnership. The three statutory partners have equal and joint responsibility for local safeguarding arrangements. 3 Local safeguarding accountability resides with these three senior officers Critical to the success of the THSCP will be the strengthening of the relationships between and operational culture between the three statutory partners, their relationship with non-statutory partners and independent scrutiny, and the wider system. Key to this will be the relationship between the statutory leads themselves, and the Independent Scrutineer (IS) who will throughout act as a critical friend, and touchstone to support their works. The IS will in addition provide additional system linkage and assurance to the LBTH Chief Executive and Lead Member for Children and Families services and act as a key point of contact for Adults Safeguarding and local NHS and police. The THSCP will have an agile and responsive structure with three core sub groups supporting the Executive Partnership, Independent Scrutiny, Youth Voice and wider non statutory partnership input.

2 See http://www.legislation.gov.uk/ukpga/2017/16/part/1/chapter/2/crossheading/local-arrangements-for-safeguarding-and-promoting-welfare-of-

children/enacted 3 See WT18 Chapter 3 P73

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/729914/Working_Together_to_Safeguard_Children-2018.pdf Page 112





Fig 1 Indicative structure of the THSCP February 2019

System

Component Core role and functions/

relationships Composition/frequency

Executive Group – Statutory Partners

Key responsible/accountable leads for the local area

As per WT 18 Meeting frequency - ongoing with diarised sessions TBC

Independent Scrutineer

Challenge/support for Statutory Partners Assurance of local system leaders

Independent consultant with very high levels of experience in delivering comparable oversight, insight and support in a childrens safeguarding context. Links to LBTH Chief Exec/Lead Member – wider system Ongoing – Development phase 8 days pcm Delivery phase – 4 to 6 days pcm for the first two years

THSCP Secretariat Core Staff of two with additional analytics support

Two Full Time permanent positions

Strategy Manager PO8 TBC

Administrator/Coordinator PO5 TBC

Additional analytics support potentially from LBTH public Health, LBTH Strategy and policy or local NHS.

Youth and Wider Executive Group – Relevant Agencies

Challenge support/design/ service user experience capture

Ongoing feed into design and delivery processes – monthly/quarterly works in support of THSCP

Wide range of statutory and voluntary and community sector partners including but not limited to Education, Training Probation, services and community organisations.

Operational Group: Learning and communications

Cascade of system level alerts and curation of training resources and wider communications outputs

Monthly/Quarterly

Potentially Shared resource with Adults Safeguarding Board

Potentially Chaired by one of the three statutory Partners

Operational Group: Recommendations and Oversight Group

Scrutiny of ongoing works, cases and themes emerging - challenge/support for framing recommendations/practice

Monthly/Quarterly – dependant on issues/caseload and format of recommendations received


Operational Group: Task and Finish Core

Rolling programme of task and finish groups tackling priority themes, developing resources,

Task and finish working groups are assembled on a as required basis and are tasked with constructing or reviewing

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Processes and Priority Themes Development Groups

protocols and procedures and mainstreaming into practice - with support from the Learning and communications group.

specific products, processes or protocols addressing specific agenda items with the aim of developing prototypes for testing to include into Business As Usual operations.


Fig 2 Outline of core system components for the THSCP

A full delivery plan and initial processes and procedures will be available by March 2019 to support delivery for the THSCP by September 2019. Works to date have focussed on the drafting of key programme materials:

The Arrangements – the core procedures and agreements between the three statutory partners under which the partnership will be delivered including statement on local serious case review and systems learning, including key governance and reporting arrangements, structure of the THSCP working groups, outline functions and relationship with wider NHS, Police and Local authority systems in North East London.

Job descriptions for the Independent Scrutineer, THSCP Strategy Manager and THSCP Administrator/Co-ordinator roles (An additional Data analytics function is required and will be potentially sourced via LBTH Public Health, Strategy Directorate or local NHS)

An indicative budget position statement indicating set up and recurrent/non-recurrent spend associated with the THSCP and contributions required by partners.

A detailed programme delivery and action plan to support the roll out of the THSCP, links with local Quality Assurance systems, migration of LSCB workload Risk Register, Equality Impact Assessment, communications and training plan and related programme materials

Outline system and public communications and engagement plans to support the new arrangements

Outline of migration of works from the LSCB – between September 2019 and March 2020

Outline of local review methodology options for replacement of Serious Case Review Risks and mitigations: There are obviously a number of key risks associated with the development of the THSCP. A full Risk Register is being assembled to support the THSCP. Key initial risks are outlined below.

Risk Likelihood HIGH MEDIUM LOW

Impact HIGH MEDIUM LOW

Mitigation

THSCP will either be inadequate in meeting or exceeding the statutory requirements, or through complexity of the task not be available to meet the statutory deadlines

LOW HIGH Dedicated project resource has been assigned to the project and regular updates on progress to date and timelines are shared to ensure delivery of project outputs are proceeding as desired.

Potential for fragmented local safeguarding arrangements as local areas develop new systems with minimal statutory guidance to direct them and a move away from the standardised LSCB approach to a local partnership that could be significantly different from neighbouring systems.

HIGH HIGH Works with North East London, pan London and Natjonal safeguarding partners are commencing to share details and outputs to avoid

There is a potential for data loss or lack of progress in case work as it is migrated between the existing LSCB and the new system.

MEDIUM HIGH THSCP development works are proceeding in partnership with LSCB partners and sessions are being arranged to look at and provide the detailed assurance that these risks will not

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manifest in lost project outputs, case progress or organisational memory.

The financial requirements of the evolving system are as yet unknown and come at a time when all partners are experiencing reduced resources.

MEDIUM HIGH Mapping of the cost of the THSCP is underway and there is already a commitment from all partners to support the statutory requirements. Detail cost mapping is underway for personnel and local review systems. A session will be held shortly to scope out the available resources and achieve an equitable and sustainable contribution from all three statutory partners.

Additional works: Tower Hamlets Together - Workforce and Organisational Development work stream. Separate but pertinent works in the Tower Hamlets Together system are assessing the practicality of a shared training resource to support coherence across a range of agendas. A task and finish group is being assembled that will look at the potential for Safeguarding training across partners to be standardised in line with the Medical Royal Colleges Intercollegiate document with a particular focus on supporting the THSCP works. CDR Systems: Aligned to this are the separate requirements for the establishment of new Child Death Review (CDR) arrangements in North East London. Discussion with CDR partners is ongoing and emergent footprints are suggesting two CDR systems. The first aligned to the Barking Havering and Redbridge, and the second across Waltham Forest, Newham, City and Hackney and Tower Hamlets footprints. Approval from TH CCG for the [proposed move to the WELC footprint was received on 26th March 2019.

Appendices: NA

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Logos to be inserted here

Tower Hamlets Safeguarding Children Partnership

Arrangements

Version Control

Issue Date Author Date of the Next Review

Lead officer

Draft 1

November 2018

Daniel Devitt Ongoing - draft Dan Devitt

Draft 1.1

January 2019

Dan Devitt Ongoing draft Dan Devitt

Draft 1.2

March 2019

Dan Devitt Ongoing draft Dan Devitt

Draft 1.3

March 2019

Dan Devitt Ongoing Draft Dan Devitt

Page 117

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Contents Glossary .......................................................................................................................... 5

Safeguarding partners Error! Bookmark not defined. Safeguarding partners [68] ................................ Error! Bookmark not defined.

Leadership ............................................................... Error! Bookmark not defined.

Geographical area .................................................. Error! Bookmark not defined.

Relevant agencies .................................................. Error! Bookmark not defined.

Schools, colleges and other educational providers .......... Error! Bookmark not defined.

Information requests .............................................. Error! Bookmark not defined.

Independent scrutiny ............................................. Error! Bookmark not defined.

Funding .................................................................... Error! Bookmark not defined.

Publication of arrangements ................................. Error! Bookmark not defined.

Dispute resolution .................................................. Error! Bookmark not defined.

Reporting ................................................................. Error! Bookmark not defined.

Introduction:

This document aims to present a summary of the key organisational and procedural arrangements underpinning the Tower Hamlets Safeguarding children Partnership (THSCP).

It presents an approach to how the complexities of delivering local safeguarding processes, and the professional practices and culture that support it should be delivered. Through this we seek to outline the operational details in Tower Hamlets and share our vision of how the new system will strengthen local child protection.

We hope that this captures the detail of the arrangements we are putting in place and the aspirations and determination we share in ensuring that we have the best possible child protection and wider safeguarding systems, procedures and culture in Tower Hamlets.

The new partnership is driven by three core principles - Child Protection, Assurance of the system and operational culture and Learning driving decisive and quick action to address the challenges inherent to children’s safeguarding. We aim to ensure that the THSCP delivers an exemplary standard of practice and partnership working. Supporting and driving the Early Help Strategy we aim to ensure that children and their families have access to early help. The overall aim is that children and their families will have access to the right help at the right time and from the right person. Early Help and identification of issues can stop small problems from escalating and delivery of the right Early Help Services can result in a reduced

Comment [DD1]: A full Ta le of contents will follow when the Arrangements are agreed

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subsequent need for statutory services We believe that Early Help is most effectively delivered through an integrated partnership of stakeholders that are best placed to deliver the right support at the earliest opportunity in order to stop problems escalating and to improve life chances. Responsive, agile and impactful Safeguarding Children systems are a core aspect of this.

Our thanks go out to those who have helped in crafting these arrangements and we call upon all partners in Tower Hamlets across statutory and voluntary and community sector services and the wider community to help us deliver on the vision the arrangements support.

We are clear eyed on the challenges that lie ahead and the complexity of the task we face.

We have much to do. Together we can succeed. Together we will succeed.

INSERT Photo and Signature



Debbie Jones DCS LBTH

Jane Milligan Accountable Officer East London Integrated Health and Care system Selina Douglas Managing Director TH CCG

Sue Williams Borough Commander Central East Metropolitan Police Service

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Glossary

BASU Business As Usual

BWGW Born Well Growing Well

CSWA17 Children and Social Work Act 2017

CCG Clinical Commissioning Group

CDOP Child Death Overview Panel

CDR Child Death Review system

CQC Care Quality Commission

DCS Director of Children’s Services

ELFT East London Foundation Trust

MD Managing Director

THCC Tower Hamlets Clinical Commissioning Group

LBTH London Borough of Tower Hamlets

NELCA North East London Commissioning Alliance

LA Local Authority

LSCB Local Safeguarding Children Boards

LDNSCB London Safeguarding Children Board

Ofsted Office for Standards in Education, Children's Services and Skills

DfE Department for Education

DHSC Department of Health and Social Care

THT Tower Hamlets Together

THVCS Tower Hamlets Community and Voluntary Sector

WT18 Working Together 2018 the core statutory guidance for multi Safeguarding children revised following the 2017 legislation – sometimes referred to as “The Guidance”.

EHS Early Help Strategy 2018-2021 LBTH.

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1. Vision The vision of the Tower Hamlets Safeguarding Children Partnership is that the three statutory partners (Local Authority, NHS CCG and Metropolitan Police Base Command Unit, the wider Relevant Agencies in the wider local system, community and voluntary sector and community work together to ensure that everyone does everything they can to ensure that all Tower Hamlets children and young people are safe, supported and successful.

The THSCP is clear that safeguarding children and promoting their welfare is everybody’s business. This is demonstrated by a robust and sustained commitment to children’s safeguarding at the highest levels in each agency. The core principles for this are laid out below in section 5.

Building on an established track record of partnership working and a clear-eyed view of the challenges we face, our vision is that the Tower Hamlets Safeguarding Children Partnership will be characterised as follows:

Focus on the intrinsic and extrinsic needs, contexts and requirements of children, young people, their families and wider communities as a central and visible component of the partnership with tangible, positive outcomes for children and their families

Decisive strategic leadership from the statutory partners

A responsive partnership supported and challenged by the Independent Scrutineer

Statutory and Relevant Agencies and other local partners committed to the priorities outlined above and to the wider safeguarding needs of children and young people promoting their welfare

That this commitment is evident in their contribution to the work of the partnership and outputs including learning and recommendations

Effective and consistent engagement by senior strategic leaders, who are able to influence safeguarding in their individual agencies

Effective and collaborative working relationships supported by shared approached to driving quality and improvement

Strong evidence of effective collaboration of partners and relevant agencies at both strategic and operational levels with timely self-assessment and audits against Section 11 compliance and action planning

Substantial and impactful participation by voluntary sector and lay/co-opted members to help the THSCP deliver its functions within a vibrant and ever changing local multicultural context

A strong culture of accountability and challenge driven by the Independent Scrutineer and statutory partners, that results in increased understanding across the partnership and measurable improvements in the quality of practice

An intelligence and data led approach to the work of the partnership, identification of trends, priorities and needs to drive targeted support and assist understanding of the effectiveness of the partnership.

A learning and improvement framework is committed to continuous improvement in the quality of safeguarding practice

THSCP is a robust multi-agency partnership that enables all children and young people to be safe in their homes and communities, and to fulfil their potential. The partnership coordinates the work of all agencies and ensures that this work is effective in achieving the best outcomes for Tower Hamlets children and young people.

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2. Voice of the Child - Youth Voice/Engagement Apparatus Central to the development of the new system is the need to ensure that the Voice of the Child is at the centre of the structures and informs both the planning and delivery of all of the service functions needed to deliver a comprehensive approach to child protection and the wider safeguarding agenda.

Tower Hamlets is well served with a rich range of youth engagement structures. These include: The Youth Parliament and Young Mayor, The Youth Engagement Squad at Barts Health, The Healthwatch Young Influencers, the Children in Care Council and service level user experience groups across BWGW life course.

There are many more youth consultation and representation groups in the borough and we are seeking to identify key partners, especially those with existing education or social care participation groups, to help us build a youth voice offer for the THSCP. We are establishing a broad spectrum of youth engagement participatory and contributory opportunities. These will include a range of surveys to gauge the experience of children in the borough of the local safeguarding systems, specifically their experience of the Section 11 culture.

Alongside these we are seeking to engage with local parents, cares and other children and young people including those at risk or known by the criminal justice systems, victims of crime, the bereaved and other key groups.

3. National Context The Children and Social Work Act 2017 received royal assent on 27th April 2017, and amends the Children Act 2004 (‘the Act’). Section 16E of the Act requires each Local Authority Area to establish local arrangements for safeguarding and promoting the welfare of children (1) The safeguarding partners for a local authority area in England must make arrangements for—

(a) the safeguarding partners, and (b) any relevant agencies that they consider appropriate, to work together in exercising their functions, so far as the functions are exercised for the purpose of safeguarding and promoting the welfare of children in the area.

(2) The arrangements must include arrangements for the safeguarding partners to work together to identify and respond to the needs of children in the area. (3) In this section— “relevant agency”, in relation to a local authority area in England, means a person who—

(a) is specified in regulations made by the Secretary of State, and

(b) exercises functions in that area in relation to children; “safeguarding partner”, in relation to a local authority area in England, means—

(i) the local authority; (ii) a clinical commissioning group for an area any part of which falls within the local authority area; (iii) the chief officer of police for a police area any part of which falls within the local authority area.”

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4. The Geographical Area of the partnership. In accordance with Working Together 2018, the geographical footprint for the Partnership will be the London Borough of Tower Hamlets.1 Wider area system level working will of course be supported where appropriate but for the first two years of operational a local borough focus is anticipated until such time as the local system reaches maturity. This does not preclude collaboration with health and policing partners at wider area scales where this is appropriate and necessary.

5. Context for the Migration of functions from the Tower Hamlets LSCB

In 2017 an Ofsted report into children’s services in the borough rated children’s services as overall inadequate.2 The report noted that the LSCB was inadequate and was not at the time discharging its statutory functions. This response was embraced by LBTH and its partners, and remedial actions undertaken.

By January 2018 an interim inspection noted significant improvements to the services provided in the borough. Subsequent inspections3 have noted continuous positive progress and highlighted areas for prioritisation and further improvement. Much work remains to be done and there is no local complacency on the need to improve the work of children services and safeguarding in the borough.

The need to develop the THCSP has provided an opportunity to refresh and revise their work across all areas of child protection and ensure that the new system exceeds the statutory requirements for safeguarding laid out in legislation and WT18.

A key focus on the development works for the THSCP is the assessment of structures, outputs, processes and procedures to determine their fit to the new system, and their positive impact in support of local safeguarding. The initial stages of operational establishment for the THSCP will be on the migration of functions from the existing system to the new, and a thorough analysis of how best to deliver the new system and utilise existing assets.

6. The Purpose, Principles and Priorities of the Partnership A. Purposes The key principles of the Tower Hamlets Safeguarding Children Partnership and its Sub Groups are outlined below: In accordance with section 8 of WTSC 2018 Chapter 3 Section 8 the core purposes of the Partnership are:

1 Working Together 2018, “Every local authority, clinical commissioning group and police force must

be covered by a local safeguarding arrangement.”, chapter 3, paragraph 16, p. 75: 2 See: https://files.api.ofsted.gov.uk/v1/file/2753062

3 See https://reports.ofsted.gov.uk/provider/44/211

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https://files.api.ofsted.gov.uk/v1/file/2753062

https://reports.ofsted.gov.uk/provider/44/211

“to support and enable local organisations and agencies to work together in a system where: • children are safeguarded and their welfare promoted • partner organisations and agencies collaborate, share and co-own the vision for how to achieve improved outcomes for vulnerable children • organisations and agencies challenge appropriately and hold one another to account effectively • there is early identification and analysis of new safeguarding issues and emerging threats • learning is promoted and embedded in a way that local services for children and families can become more reflective and implement changes to practice • information is shared effectively to facilitate more accurate and timely decision making for children and families

This includes

Developing policies and procedures for safeguarding and promoting the welfare of children, including – Taking action where there are concerns including thresholds – Recruitment and supervision – Investigation of allegations – Cooperation with neighbouring authorities

Participating in the planning of services for children in the local authority area

Communicating the need to safeguard and promote the welfare of children

Procedures to ensure a coordinated response to unexpected child deaths (this will be led by the local Child Death Review partnerships and systems that are emerging in North East London)

Collecting and analysing information about child deaths

Monitoring the effectiveness of what is done to safeguard and promote the welfare of children

Undertaking local Child Safeguarding Practice Reviews and liaison with the national panel.

B. Principles The overarching principles which underpin the work of the partnership are as follows: Principle Working definition

Child Protection

WT184 defines safeguarding as: • Protecting children from maltreatment • Preventing impairment of children's health or development • Ensuring that children grow up in circumstances consistent with the provision of safe and effective care •Taking action to enable all children to have the best outcomes Ultimately all of these involve an element or focus on the protection of children and to strengthen this the THSCP will adopt an all-encompassing definition of Child

4 Page 6 WT18


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Protection to ensure all safeguarding agendas refine their focus and impact to support the overall child protection offer in the borough. This approach is informed by and compliments the Restorative Practice5 ethos that is currently being rolled out across social care partners in LBTH, and augments the work towards a “trauma informed” approach to working with vulnerable children, young people and adults arising from the Adverse Childhood Experiences agenda that is being explored. It is a key support mechanism for the Early Help Strategy6

Assurance The THSCP must be able to assure itself and the wider system and community it serves that the services discharged on behalf of or directly by the partnership are delivering the appropriate heath care and education interventions offers and services required to support the child protection and wider safeguarding agenda. Delivery of services of the required standard in terms of quality, timeliness, sensitivity and cost is a crucial requirement. Alongside this and in line with WT18 7 there is a need to ensure the system is child centred and throughout captures the voice of the children and wider communities the system serves to drive improvement and sensitivity and impact of the partnership. Building upon Ofsted, CQC and JTAI recommendations the partnership will develop a dynamic approach to assurance. This will evolve at pace alongside wider health, education and social care system changes in the borough, North East London, Pan London and nationally, including the evolution of Sustainability and Transformation Plans and Integrated Care Systems. Robust, timely, proportionate interagency working and information sharing and a focus on action planning, impacts and outcomes will be key in developing the new system with clear lines of governance, scrutiny and accountability underpinning all of the partnerships work. Assurance for partners and local system will be delivered through a series of reviews, audits, process and practice developments, all feeding into local assurance reports and the annual report and the Independent scrutineer.

Learning. Building upon the child centred approach the partnership needs to ensure that it is able to learn, analyse and adapt its operations and processes. This must be in line with both the issues and learning arising from operational delivery and the wider evolution of statutory services with a bearing on the wider safeguarding agenda in the borough, across North East London and at Pan London or national levels. Central to this will be the voice of the child”” and the use of assurance and quality mechanisms to inform programmes of change to update staff on key agenda areas and the “core sections” of the revised safeguarding legislation. A genuinely “whole system response” is essential and will only be possible to deliver through engagement with all those working to protect children on a cultural and operational level rather than simply relying on the modification of processes alone. A core feature of the new system are robust mechanisms to communicate with the wider system and ensure all partners have access to appropriate role specific training on child protection and the wider safeguarding agenda. Learning from local, regional and national cases will provide a core additional imperative to bring about the agile, responsive and continually improving ethos the agenda requires. A standardised recommendations template – similar to that used by the CDR process – capturing learning and issues across a range of intrinsic and extrinsic factors to the child and the context of the issues arising from the child protection and wider

5 See https://l30relationalsystems.co.uk/children’s-services/

6 See https://www.towerhamlets.gov.uk/Documents/Children-and-families-services/Early_Help_Strategy.pdf

7 Page 9


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safeguarding proceedings will be a product of all case reviews to drive improvement and service responsiveness across the partnership.

In addition to these principles, the core purpose of Tower Hamlets Safeguarding Children Partnership is to enable agencies to work together so that

excellent practice in multi-agency safeguarding is the norm

partners effectively hold each other to account

they proactively identify and respond to new and emerging safeguarding issues

whole system learning is promoted and embedded in frontline practice

information is shared effectively

Tower Hamlets’ children, families and communities are safe, supported and successful

Explicit links with the local Safeguarding Adults Board on areas of shared concern and interest and developed and strengthened. This will in particular look at how best to address Contextual Safeguarding. (See section xxx below)

Contextual Safeguarding developed by Carlene Firmin at the University of Bedfordshire8 to inform policy and practice approaches to safeguarding adolescents. Contextual Safeguarding is an approach to understanding, and respond to, young people’s experiences of significant harm beyond their families. It recognises that the different relationships that young people form in their neighbourhoods, schools and online can feature violence and abuse. Parents and carers often have little influence over these contexts, and young people’s experiences of extra-familial abuse can undermine parent-child relationships. Contextual Safeguarding, therefore, expands the objectives of child protection systems in recognition that young people are vulnerable to abuse in a range of social contexts.

Throughout there will be an emphasis on Early Help and Identification to understand the needs of vulnerable children and young people, their parents carers and communities. We will ensure they are protected and supported and wherever possible we act to prevent safeguarding issues arising and minimise the harm and impacts arising from those that do occur. This is essential across a wide range of agenda areas from Neglect to Child Sexual Exploitaton, or Child Death Review.

C. Priorities

The THSCP works to ensure that local services work knowledgeably, effectively and together to safeguard children and young people and to support their parents. The Partnership’s priorities will be informed by detailed analysis of local need and will target the most vulnerable children and their families for support. The Partnership’s priorities will be informed by the Joint Strategic Needs Analysis, learning coming out of local and national Child Safeguarding Practice Reviews, system-wide developments in safeguarding practice such as the Tower Hamlets Social Work Academy, Restorative Practice Model, Contextual Safeguarding and Adverse Childhood Experiences agendas.

The Partnership’s priorities will be agreed at an annual Partnership Away Day. The agreed priorities will be outlined in a 24-month Business Plan and will be reviewed at each meeting of the Partnership.

7. Membership

8 See https://contextualsafeguarding.org.uk/about/what-is-contextual-safeguarding

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https://contextualsafeguarding.org.uk/about/what-is-contextual-safeguarding

Statutory Partners

The Director of Children’s Services (DCS) representing the Council

The Accountable Officer for the East London Integrated Health and Care system discharged through the Managing Director of the Tower Hamlets Clinical Commissioning Group (CCG)

The Commander of the Borough Command Unit (BCU) of the Metropolitan Police

The essential role of the three statutory partners outlined in section 16E of Children Act 2014, as amended by the Children and Social Work Act 20179 requires that they are the most senior accountable leads for safeguarding at local level.

The amended 2014 Act and WT18 are clear on the need for the statutory partners to lead the local system, taking direct accountability for both strategic and operational functions of the partnership. The three statutory partners have equal and joint responsibility for local safeguarding arrangements. 10

Critical to the success of the THSCP will be the strengthening of the relationships between and operational culture between the three statutory partners, their relationship with non-statutory partners and independent scrutiny, and the wider system.

The THSCP must have the leadership, resources, data intelligence, supporting multi-agency agreements, governance, and responsive systems and processes it requires to deliver comprehensive child protection and wider safeguarding offers. Key to this, and perhaps most important of all will be the relationship between the statutory leads themselves, and the independent scrutineer who will throughout act as a critical friend, and touchstone to support their works.

8. Independent Scrutineer Independent scrutiny of the THSCP will be developed to ensure compliance with WT18 and provide an objective and robust scrutiny of local arrangements is available to serve the partnership. This role will support wider system assurance processes and play a key role in supporting joint Targeted Area inspections, providing a “critical friend” and objective analysis of local works including the annual report produced by THSCP, local case review and outputs from the working groups, non-statutory partners and inclusion of Youth voice in the system.

9. Relevant Agencies - Wider system Partners of the Executive Group

Wider system input and expertise will be sought via these key local agencies and strategic leaders

9 See http://www.legislation.gov.uk/ukpga/2017/16/part/1/chapter/2/crossheading/local-arrangements-

for-safeguarding-and-promoting-welfare-of-children/enacted 10

See WT18 Chapter 3 P73


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The Tower Hamlets Safeguarding Children Partnership’s will work with other relevant agencies including but not limited to

o Schools, colleges and other educational providers o Housing – a representative Registered Social Landlords and Housing

Associations and Tower Hamlets Housing o Youth Justice/ Probation (including National Probation and CRC Probation) o Department for Work and Pensions o Voluntary Organisations represented by the Tower Hamlets Voluntary and

Community Sector Partnership Members must be sufficiently senior and delegated to speak with authority, to make decisions and commit resources on behalf of their agency, provide commitment, consistency and continuity in membership link with their counterparts/sectors through relevant forums, etc. Partnership Members must contribute actively to the work of the THSCP, provide constructive support and challenge, and act as a ‘critical friend’ to other partner agencies in the monitoring and delivery of their safeguarding responsibilities. A culture of trust, openness and learning is key to this and it is every partners responsibility to promote this. The Independent Scrutineer and statutory partners are, in particular responsible for creating a working culture and environment where this style of working is the norm. A limited number of deputies for the partnership wider membership and statutory partners are to be identified and their training and development in support of the THSCP works is to be identical to the substantive members. It is expected that relevant agencies listed above will ensure appropriate briefing and support is available to cover absence by other members from that sector and so do not require a deputy – e.g. head teachers, voluntary sector. Where a Member does not attend two consecutive meetings this absence will be reviewed with them on behalf of the Tower Hamlets Safeguarding Children Partnership Chair, by the Tower Hamlets Safeguarding Children Partnership Strategy Manager, and after this may be added to the Tower Hamlets Safeguarding Children Partnership Risk Register. Partners and relevant agencies are expected to ensure appropriate membership and commitment to the Sub Groups and Task and Finish Groups, according to the membership agreed in their terms of reference.

10. Tower Hamlets Safeguarding Children Partnership Structure and Governance

To meet these statutory requirements the Tower Hamlets Safeguarding Children Partnership has agreed the following structure and governance arrangements.

As part of the independent scrutiny and development of the Partnership, the THSCP will have an Independent Scrutineer (IS) as outlined above who has significant experience at a

senior level in the strategic co-ordination of multi-agency services to safeguard and promote the welfare of children.

The IS will be appointed by the Statutory Partners.

The IS will be accountable to the THSCP and will work closely with the Statutory Partners who hold statutory responsibilities for the co-ordination of multi-agency working to support and safeguard children and Statutory Partners. This accountability will be in the form of an

Comment [DD2]: PLEASE NOTE THE STRUCTURE AND GOVERNANCE HAVE OBVIOUSLY NOT BEEN AGREED – THIS SECTION – AS WITH ALL OTHERS NEEDS AGREEMENT BY THE PARTNERSHIP AND REDRAFTING IN LINE WITH WHAT IS THE FINAL DECISION OF THE STATUTORY PARTNERS.

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annual report to the Statutory Safeguarding Partners (that is, Director of Children, Schools and Families, the BOCU Chief Officer and the Chief Executive Officer of the CCG) and wider system including the the Chief Executive Officer of the Council, Health and Wellbeing Board and other local governance structures as required.

The statutory partners are the effective chairs for the THSCP and working groups. Statutory Membership and wider and confirmed at the Annual Business Planning Meeting.

Business will be conducted through the Tower Hamlets Safeguarding Children Partnership (‘Executive Group) which holds the statutory responsibilities and duties; the Tower Hamlets Safeguarding Children Partnership will have ultimate accountability for ensuring that the responsibilities are achieved.

Business will be conducted through Tower Hamlets Safeguarding Children Partnership meetings, Sub Groups, correspondence and exchange of information between meetings.

The Tower Hamlets Safeguarding Children Partnership will prioritise and organise its work through the Annual Business Plan; and regular monitoring of the Plan and Risk and Challenge Registers.

The Tower Hamlets Safeguarding Children Partnership will deliver its functions through Sub-Groups. The key Sub-Groups will be the

Communications, System Training and Learning Group

Task And Finish Working Groups

Recommendations and Oversight group – incorporating a case review function.

THSCP will, where appropriate, collaborate across a sub-regional geographical footprint (to be determined); in order to support wider area safeguarding agendas (such as Gangs and County Lines)

The THSCP structure and core working groups is included below

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Fig X THSCP Core Functions and Reporting Lines

The Statutory Partners will co-ordinate the work of the Partnership, prioritise actions and ensure the coverage of statutory functions and the business plan by ensuring governance and connectivity across the Sub Groups and ad hoc task and finish groups. The Statutory Partners will enable commissioning agencies to secure and plan delivery of the total work programme. It will contribute to Board and agency self-evaluation and to challenge and improvement priorities. The Statutory Partners will drive the THSCP agenda, seek assurance that the Partnership’s priorities are being delivered, provide guidance and leadership to Sub-Group Chairs and will report to and be accountable to the THSCP and wider system.

The initial model for the THSCP has been developed to support the strategic and operational systems needed to support the delivery scrutiny and assurance required for children’s safeguarding in the new system. It is crucial that the forms of the THSCP follow the functions required of it. The Structure and outputs of the THSCP will be reviewed on an ongoing basis and an annual structural update issued if required.

System Component Core role and functions/relationships

Composition/frequency

Executive Group – Key responsible/accountable As per WT 18

Executive Group

( Barts Health, LA public Health, THEP, Relevant Agencies

Voice of the Child/Representation from CYP

Executive Group

(LA, CCG, MPS - Statutory Partners/Accountable Officers

THSCP Secretariat

Strategy Manager, Administrratror, Data Analyst

Communications, System Learning and Training Group - potentially shared with SAB

Task and Finish Core Processes and Priority Themes

Development Groups

Reccomendatons and Oversight Group ( extracting issues from incidents, CDR

processes, local, regional and national themes

Safeguarding Adults Board

Independant Scrutineer

Potential THSCP governance and reporting to:

Cabinet/Lead Member Children and Families

Health and Wellbeing Board

Children and Families Partnership Board

THT /BWGW Board

CQRMs

Multi Agency Safeguarding Committee

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Statutory Partners leads for the local area Meeting frequency - ongoing monthly from September 2019 with diarised sessions every two months from March 2020.

Independent Scrutineer Challenge/support Independent consultant with very high levels of experience in delivering comparable oversight, insight and support in a children’s safeguarding context. Ongoing – Development phase 8 days pcm from appointment circa March 2019 and Delivery phase from March 2020– 4 to 6 days pcm

Youth and Wider Executive Group – Relevant Agencies and Voice of the Child

Challenge support/design/ service user experience capture

Ongoing feed into design and delivery processes – monthly/quarterly works in support of THSCP. Delivered through the Relevant Agencies including but not limited the following agencies and organisations: o Schools, colleges and other

educational providers o Housing – a representative

Registered Social Landlords and Housing Associations and Tower Hamlets Housing

o Youth Justice/ Probation (including National Probation and CRC Probation)

o Department for Work and Pensions Voluntary Organisations represented by the Tower Hamlets Voluntary and Community Sector

Learning and communications

Cascade of system level alerts and curation of training resources and wider communications outputs

Quarterly formal meetings Chaired by one of the three statutory partners with support from the Independent Scrutineer.

Recommendations and Oversight Group

Scrutiny of ongoing works, case reviews, alerts arising and themes emerging - challenge/support for framing recommendations/practice

TBC – dependant on issues/caseload and format of recommendations received Chaired by one of the three statutory partners with support from the Independent Scrutineer.

Task and Finish Core Processes and Priority Themes Development Groups

Rolling programme of task and finish groups tackling priority themes, developing resources, protocols and procedures and mainstreaming into practice - with support from the Learning and communications group.

Task and finish working groups are assembled on an “as required basis” and are tasked with constructing or reviewing specific products, processes or protocols addressing specific agenda items with the aim of developing prototypes for testing to include into Business As Usual operations. Overall operation to be steered or chaired by one of the three statutory partners with support from the Independent Scrutineer.

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The THSCP will be evaluated internally by the statutory and non-statutory partners and wider local system via reports to the LSCB, Health and Well Being Board, THT Board and sector level structures. External assessment of preparedness and suitability of the THSCP response will be through liaison with and assessment by external regulatory or statutory partners including DfE, DHSC, Ofsted, Joint Targeted Area Inspection and the CQC. The IS will have a key role in driving the evaluation and quality assessment and service improvement of local safeguarding arising from THSCP works.

Quarterly project updates will be generated and circulated as required to inform local, follow from the development of the THSCP outcomes and impacts framework.

Sub Groups and Short Term Task and Finish Groups will be tasked by the Tower Hamlets

Safeguarding Children Partnership with agreed Terms of Reference and Work Plans and will be given delegated responsibility to act on the Tower Hamlets Safeguarding Children Partnership’s behalf to progress the agreed Business objectives. There should be multi-agency leadership and chairing of such working groups. (See Appendix 2 – Tower Hamlets Safeguarding Children Partnership Structure). It is essential that members of the Tower Hamlets Safeguarding Children Partnership demonstrate their commitment to the partnership by ensuring agency attendance to Sub-Groups and undertake specific tasks as agreed at meetings. The Tower Hamlets Safeguarding Children Partnership will liaise with and receive relevant reports from other local Strategic Partnerships, such as the Health and Well-Being Board. At times it will be appropriate to agree joint work with such partnerships.

11. Accountabilities The Tower Hamlets Safeguarding Children Partnership is responsible for appointing (or dismissing) the Independent Scrutineer, with advice of a panel of Tower Hamlets Safeguarding Children Partnership members (including lay members). A Panel of the Statutory Partners, including the Chief Executive Officer of the Council, will meet with the Tower Hamlets Safeguarding Children Partnership’s Independent Scrutineer at least three times per year to review the Tower Hamlets Safeguarding Children Partnership’s work. The Statutory Partners will have executive authority to make decisions on behalf of the Tower Hamlets Safeguarding Children Partnership between meetings, consulting the IS as appropriate. The Statutory Partners will report on any such decisions to the Board no later than the next meeting of the Partnership or in writing. The THSCP has the responsibility to decide whether a local or national Child Safeguarding Practice Review (CSPR) is appropriate in accordance with the criteria set out in Chapter 4 of Working Together 2018. The THSCP partners hold statutory responsibility for communication with the Child Safeguarding Practice Review Panel regarding decision-making in relation to local and national Child Safeguarding Practice reviews. This will usually be actioned via the Recommendations and Oversight working group.

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12. Local Case Review

The Tower Hamlets Safeguarding Children Partnership is accountable to its member agencies and to the local community for its work. This accountability will be demonstrated through the Tower Hamlets Safeguarding Children Partnership Annual Report, through which the Tower Hamlets Safeguarding Children Partnership will evaluate the effectiveness of its own work, as well as that of the local multi-agency partnership. The Annual Report will be shared with the Chief Executive of Tower Hamlets Council, with the Health and Well-Being Board, Ofsted and the Department of Education. It will also be published on the Tower Hamlets Safeguarding Children Partnership website.

The Tower Hamlets Safeguarding Children Partnership aspires to be accountable to the Children and Young People of Tower Hamlets. We will work with the CSF Participation Manager and the LAC and Permanency Manager to ensure meaningful participation, consultation and accountability with young people The Tower Hamlets Safeguarding Children Partnership will work within and will comply with statutory guidance and limitations. Statutory Partners and Relevant Agencies will be accountable to the Tower Hamlets Safeguarding Children Partnership by ensuring appropriate representation and attendance on the Tower Hamlets Safeguarding Children Partnership, the Executive Group or Sub Groups, as agreed. All Relevant Agencies will respond to information requests from the Tower Hamlets Safeguarding Children Partnership in relation to data, commentary, evaluation, planning, performance and resources in order to assist the Tower Hamlets Safeguarding Children Partnership in the completion of its objectives. Such data will be governed by any limitations of the Data Protection Act 2018. A safeguarding partnership can require a person or body to comply with a request for information under section 16H of the Children Act 2004 (as amended by CSWA 2017). Where Partners and Relevant Agencies are asked for information or consulted on Tower Hamlets Safeguarding Children Partnership business or draft documents between meetings it is expected that agencies will make a definite response and not assume that no response means agreement. Where an agency does not respond to such a request, this will be raised at the following Tower Hamlets Safeguarding Children Partnership meeting. The THSCP needs confirmation of agreement and sign up to the THSCP Business Plan. The THSCP will be quorate if at least three separate statutory partners are present. The Executive Group will be quorate if all statutory partners are present. The IS as part of their independent function, will have the responsibility to disclose wrong doing, maladministration or organisational dysfunction to the Office for Standards in Education, Children's Services and Skills (Ofsted) and the DfE, if it becomes clear that the THSCP is failing to fulfil its statutory responsibilities and normal processes of challenge and dispute resolution have become untenable.

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13. Business Planning and Meetings – Annual Cycle The THSCP will be established by September 2019. The business cycle below will commence in the following year from March 2020 to allow for the achievement of operational readiness and the core business of migration of caseloads and issues from the Tower Hamlets LSCB.

March THSCB – Away Day to review year & agree revised Business Plan April Start of the Business Year

Sub-Group Meeting Cycle Begins

May The Executive Group Meeting Section 11 process begins June Partnership Meeting (Main Board)

Sub-Group Meeting Cycle Continues July Executive Group Meeting Sept Partnership Meeting (Main Board), Tower Hamlets Safeguarding Children Partnership Annual Report approved

Sub-Group Meeting Cycle Continues Oct Annual Agency Peer Reviews - QA & Challenge Meetings Nov Executive Meeting Tower Hamlets Safeguarding Children Partnership

Budget review / forward planning of priorities for referral to other partnerships & agencies for next year’s planning cycle

Jan (mid) Partnership Meeting (Main Board) Feb Executive Group Meeting – to plan March Away Day

Meetings will be scheduled to avoid school holidays where possible and to prevent clashes with other Strategic Partnerships.

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14. Resources11 The Tower Hamlets Safeguarding Children Partnership will have a shared budget to further its objectives. Partner agencies will agree contributions each autumn for the following business year. Local Reviews The cost of any local child safeguarding practice review will be borne by additional subscription from the statutory partners who have been involved in the case (mainly Children, Schools and Families, the Police and the CCG as the lead service commissioners). There are a number of guiding principles underpinning the resourcing of local reviews.

The overall aim of local review

To improve the safeguarding of children and young people where possible within Tower

Hamlets.

To support the dleivery of high quality services.

To strengthen through proportionate candour and constructive challenge the safeguading

partnership to deliver an intergrated and comprehensive offer for children and young

people.

Transparency and appropriate sharing of information and access to professionals and local

agency information such as assessments and referrals underpins the entire partnership

All reviews snhould have an outline of estimated costs and that this is monitored on an

ongoing basis to ensure overall grip on resources and crucially timelines.

All local reviews will empahsise rapid delivery of initial learning points and have clear concise

recommendations.

In response action plans will be requested from partners and these will be orientated to

deliver positive mitigating actiosn to minimise harms encountered by those affected and

inform local practice updates as a priority.

Agencies’ sole focus is on meeting the safeguaridng needs of children and young people.

Individuals and agencies do not fulfil a gate-keeping function with reagrds to resourcing of

local reviews and will not make decisions informed by budgets.

Joint funding decisions and disputes should not delay the delivery of a local review once agreed that such a review is warranted.

11

The published arrangements should set out clearly any contributions agreed with relevant agencies, including funding, accommodation, services and any resources connected with the arrangements. See Working Together 2018, chapter 3, paragraphs 36-37

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OPTION 1The outline costs of the commissioning of the review, independent author/s, legal advice, media work will be estimated as part of the planning of the Local Review and apportioned according to agency/sector involvement in the case. The cost of dissemination of lessons will be borne as part of the Tower Hamlets Safeguarding Children Partnership Training Budget. OPTION 2 Applications for local review funding will in the first instance, be considered through

the Statutory Partners. They will, with the support of the Strategy Manager and the

Independent Scrutineer initially determine

1 If one or more statutory partner or Relevent agency should bear the total cost of

fhe review – in line with which agency is the primary responsible partner for the area

of review or best placed to deliver the review.

2 If more than one statutory partner or relevant agency are deemed appropriate to

deliver the review then a proportional system is enacted were contributions are

agreed by the statutory partners in consultation with the independent scrutineer with

this highest level of contributions raised to a maximum of 80% of the cost of the

review to ensure that all reviews have contributions from all three statutory partners.

3 Where a relelvent agency is deemed the appropriaye agency to deliver the review

they will bear the cost up to 80% of the total review cost with the remaining reached

through negotiation with the statutory partners on a shared risk pooling basis.

Partner agencies will bear the costs of the attendance and contribution of their representatives and will ensure that sufficient time is given to Members to attend meetings and undertake the work of the Board. Partner agencies will take responsibility for chairing the range of Sub Groups to ensure that there is leadership across several disciplines. The Tower Hamlets Safeguarding Children Partnership will be supported by a Business Manager, Administrator/s and part-time Training Officer. The London Borough of Tower Hamlets will host the THSCP staffing component and THSCP meetings. Partners may be encouraged to support appropriate meetings or training, where possible and appropriate. The Tower Hamlets Safeguarding Children Partnership will not routinely seek legal advice on all its work but only when it is needed.

15. Delegation of key responsibilities

To further its objectives the THSCP will where appropriate delegate its responsibilities and activities by theme and through its Business Plan and the Sub Group Annual Work Plans. However, the Statutory Partners of the THSCP will remain accountable for the work

Comment [DD3]: Options for local review resourcing

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undertaken even where it has been delegated. The table in Appendix XXX shows the main areas of delegation/responsibility. This will be reviewed annually at the Business Planning Away Day in March.

16. Dispute Resolution Safeguarding partners will work to resolve disputes locally. If agreement cannot be reached the amended Children Act 2004 allows the Secretary of State to take enforcement action against any agency which is not meeting its statutory obligations.

17. Reporting The Tower Hamlets Safeguarding Children Partnership will publish an annual report. The report will set out the work that partners have done as a result of the arrangements and how effective the arrangements have been in practice. It will also include actions relating to local child safeguarding practice reviews and what the safeguarding partners have done as a result.

In addition, the report will also include:

evidence of the impact of the work of the safeguarding partners and relevant agencies on outcomes for children and families

a record of actions taken by the partners in the report’s period (or planned to be taken) to implement the recommendations of any reviews

ways in which the partners have sought and utilised feedback from children, young people and families to inform their work and influence service provision

The annual report, including local challenges to safeguarding and any national implications arising from these; the report will then be sent to the Secretary of State for Education, the DfE and to Ofsted, the Child Safeguarding Practice Review Panel within seven days of publication.

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Appendix 1: Tower Hamlets Safeguarding Children Partnership

Membership (including Statutory Partners, Relevant Agencies, Co-

opted Members and Advisors)12 SP Statutory Partner

RA Relevant Agency Partner

C Co-opted (lay members are co-opted members)

V Voting

PO Participant Observer

A Advisor

B Board support


A Independent Scrutineer

SP V Statutory Member - LBTH

SP V

Statutory Member – TH CCG

SP V

Statutory Member – MPS BCU

PO

Strategy Manager

RA Relevant Agency Member – DPH/Deputy

RA Barts Health NHS Trust – Safeguarding Lead

RA East London Foundation Trust - Safeguarding Lead

RA THEP

RA Relevant Agencies

o Schools, colleges and other educational providers o Housing – a representative Registered Social Landlords and

Housing Associations and Tower Hamlets Housing o Youth Justice/ Probation (including National Probation and CRC

Probation) o Department for Work and Pensions o Voluntary Organisations represented by the Tower Hamlets

12 See statutory guidance Working Together 2018 Chapter 3 page 73 and pages 76-77

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Voluntary and Community Sector

B THSCP Administrator- Co-ordinator

P V Assistant Director of CSC & YI, CSF

P V

Assistant Director of Education, CSF

C V

Director of Public Health Tower Hamlets, Community & Housing

C V

Safeguarding Adults Manager, Community & Housing

R V

Housing Needs Manager, Community & Housing

R V Head Teacher Primary School ‘Rep of Governing Body of a Maintained School

R V

Special School

R V

Maintained secondary school

R V

Representative of the proprietor of a city technology college, a city college for technology or the arts, or an Academy

R V

Independent Sector School

R V

CP Officer, Registered Social Landlord

R O

Tower Hamlets Council Lead Member Children’s Services Non-voting

R A

Designated Doctor for Child Protection, Tower Hamlets CCG Non-voting

R A

Designated Nurse Safeguarding, Tower Hamlets Clinical Commissioning Group Non-voting

R A

Principal Social Worker Non-voting

R V Consultant Child and Adolescent Psychiatrist, ELFT

A Service Manager, Policy, Planning and Performance Non-voting

BS

THSCP Strategy Manager Non-voting

BS

THSCP Co-Ordinator Non-voting

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Statutory Partners will nominate an agreed senior Agency Deputy who is able to speak and take decisions on their Agency’s behalf

Relevant Agencies will cover each other and do not require a deputy for their own agency.

Advisers will not have deputies

Where a Sub Group Chair is appointed who is not a Board Member they will be co-opted to the Board but will not be a voting member, unless they are deputising for an Agency Member.

Sub Group Chairs may be asked to attend the Executive if the business of their sub group is on the agenda.

Executive Group Membership

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Appendix 2: Delegation of key responsibilities

Responsibility / Action Leadership Detail

To ensure the effectiveness of what is done by each body … Initial focus will be on establishment of new system and migration from old system. Thereafter assess whether THSCP partners are fulfilling their statutory duties as set out in Chapter 3 of Working Together 2018 (section 11 Children Act 2004)

Tower Hamlets Safeguarding Children Partnership Statutory partners, Independent Scrutineer, Executive Group Quality Assurance Sub Group for the monitoring of agency and multi-agency service delivery

Annual Agency QA & Peer Reviews (section 11) Multi-Agency Data Set Single Agency Audit and Multi-Agency Audit Programme

Developing policies and procedures for safeguarding and promoting the welfare of children in the area of the authority, including policies and procedures…

Task and Finish Groups which may share works or collaborate with neighbouring local systems

Tower Hamlets Safeguarding Children Partnership subscribes to the London Child Protection Procedures (LCPP); it should be exceptional for the Tower Hamlets Safeguarding Children Partnership to have its own Policy or Protocols, except where it is necessary to localise the LCPP or that there is particular need such as Neglect Domestic abuse Parental Mental ill-health Drug and substance abuse Youth Violence Child Sexual Exploitation

Monitoring of agendas/children who are particularly vulnerable

LAC Online Safety FGM County Lines Missing Children Gangs and Serious Youth Violence Trafficking Cultural abuse Radicalization/Terrorism/Prevent?

Training Monitor and evaluate the effectiveness of training, including multi-agency training

Learning and Development Sub Group which may be shared with the Safeguarding Partnerships of one or more local authorities.

Training Strategy Annual Training Needs Analyses Commissioning the annual Tower Hamlets Safeguarding Children Partnership multi-agency training programme

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Undertake training needs analyses and commission multi-agency training

Recruitment and supervision

Corporate HR

Partner Agencies are responsible for the implementation of the policies

Allegations concerning persons who work with children

Children, Schools & Families – will provide the LADO

Quarterly data to QA Sub Group Annual LADO Report to Tower Hamlets Safeguarding Children Partnership

Responsibility / Action Leadership Comment

Private fostering

Children, Schools & Families – will assess referrals from Partners

Annual Private Fostering Report to Tower Hamlets Safeguarding Children Partnership

Communicating to persons and bodies in the area of the authority the need to safeguard and promote the welfare of children

Tower Hamlets Safeguarding Children Partnership Chair Tower Hamlets Safeguarding Children Partnership Business Manager/Support Group Training and Development Sub Group

Governed by the agreed Communications Strategy which will be reviewed each year as part of the Annual Business Review

Local and national Child Safeguarding Practice Reviews and other Learning Improvement Reviews

Statutory Partners with the Independent Chair advised by Executive Group Quality Assurance Sub Group will be responsible for Actions arising from reviews

Designated Doctor, Designated Nurse and Principal Social Worker will have role in advising

Child Death Reviews

Child Death Overview Panel

With Public Health and CCG at WELC footprint

Learning and Improving System

Tower Hamlets Safeguarding Children Partnership All Sub Groups and All Partners

Learning and Improvement System to be reviewed

Learning and Improving - monitoring and evaluating the effectiveness of what is done by the authority and their Board partners individually and collectively to safeguard and promote the

Quality Assurance Sub Group Learning and Development Sub Group will promote the lessons

The Quality Assurance Sub Group will commission multi-agency audits and monitor single agency audits Termly Practitioners Safeguarding Briefings on local and national learning

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welfare of children and advising them on ways to improve

from CSPRs, audits and other learning processes.

Lessons posted to the Tower Hamlets Safeguarding Children Partnership website

Monitoring the effectiveness of Initial Child Protection Conferences ICPCs (WT 2018 Chapter 1 page 48)

Quality Assurance Sub Group

Each multi-agency audit will include at least one ICPC and once per year there will be an audit of ICPCs. Data on ICPCs will also be included in the Tower Hamlets Safeguarding Children Partnership Data Set

Participating in the planning of services for children

Tower Hamlets Safeguarding Children Partnership Executive Group

The Tower Hamlets Safeguarding Children Partnership will receive feedback from the Health and Well Being Board and expects to be consulted on any planning which includes the safeguarding of children or promotion of their welfare; e.g. Domestic Abuse Strategy

Responsibility / Action Leadership Comment

Annual Report

Tower Hamlets Safeguarding Children Partnership Chair and all agencies with support of the Sub Group Chairs and the Business Manager

Rigorous and transparent assessment of the effectiveness of local services To include any identified weaknesses and any lessons from reviews (WT 2018 Chapter 4)

Participation and Consultation with young people

Participation Strategy


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Governing Body Meeting Enclosure

Date of meeting 26th March 2019

Agenda item

Title of report: Update on Child Death Review Systems

Author(s): Chetan Vyas (WELC) Daniel Devitt (Tower Hamlets Together)

Presented by: Sandra Moore/Helen Davenport

Executive summary

The Children and Social Work Act (2017), Working Together: transitional guidance (2018) and the subsequent Child Death Review Statutory and Operational Guidance (updated January 2019) set out how Local Authorities and Clinical Commissioning Group are required to come together as Child Death Review Partners.

This will result in a change to the way the current Child Death Overview Panel are required to function and each Partner is required to agree and publish their new arrangements by 29 June 2019. Under the old guidance the process was under the remit of the London Borough of Tower Hamlets.

The TH CCG Governing Body is requested to approve migration of local Child Death review processes to a WELC Child Death Review System footprint..

Recommendation

Information Approval X To note Decision

The Governing Body is asked to: Approve the migration of local Child Death Review to a WELC Child Death Review system footprint to meet the statutory deadline of September 2019.

Conflicts of Interest NA

Key issues To deliver the required statutory changes and begin the process of scoping resources, structures and processes required the accountable leads for each area (Local Authority and Clinical Commissioning Group leads) must agree a footprint for the new CDR system and approve a task and finish group to scope the system changes required to establish the new CDR system by Summer 2019.

Timelines:

Plans for the CDR system and new partnership must be published by June 2019

The CDR system and safeguarding partnership has to be

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operational from September 2019

The Safeguarding partnership can be established and operate alongside a continuing LSCB until full implementation is achieved by the end of March 2020, similarly handover of caseloads from the old CDOP system to the new CDR system to be concluded by March 2020 with unresolved reviews concluded by then.

The new CDR system arrangements must be operational by no later than summer 2019.

Aligned to this are the separate requirements for the establishment of new safeguarding children arrangements in shadow form alongside LSCB by sept 2019 and hand over to the system by March 2020.

Report history This report is based upon a series of drafts circulated to Local authority Public Health, TH CCG Safeguarding and CDOP partners in Nortth East London. A variant report has been shared with all WELC footprint partners to secure alignment of approach to the migration of the new CDR system.

Patient and Public involvement

The changes in legislation and statutory guidance and new requirements were informed by national consultations. The new CDR system has explicit requirements for capturing the Voice of the Bereaved and will considerably strengthen local system ability to engage the public through delivery of the new system.

Link to the Board Assurance Framework

The THSCP and CDR system changes have key links to the TH CCG BAF.

Objective1 : To work in partnership to commission high quality hospital services that are accessible, provide the appropriate treatment in the right place, and achieve good patient outcomes for people of all ages living in the borough

Objective 2: To commission person‐ centred, integrated health and care service that are sustainable and that equally meet the mental and physical needs of our residents

Specific Corporate objectives this will help address include:

CO (1) - To work in partnership to commission high quality hospital services that are accessible, provide the appropriate treatment in the right place, and achieve good patient outcomes for people of all ages living in the borough

CO (2) - To commission person-centred, integrated health and care service that are sustainable and that equally meet the mental and physical needs of our residents

CO (3) - To contribute towards a financially sustainable and responsive health and care economy which delivers value for money and innovation and supports the appropriate use of services

CO (4) - To support local people and stakeholders to have a greater influence on services we commission

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CO (5) - To promote equality both as an employer and a commissioner of health care services

CO (6) - To create a high performing and sustainable workforce that continuously learns and is engaged in delivering our ambitions.

Impact on Equality and Diversity

The WELC CDR system seeks to provide a local response to the new statutory requirements. An EIA is being undertaken to ensure no adverse impacts are developed. In addition, with regards the statutory requirement to capture Bereaved Voice and the new role of the Key Worker strengthen this component of the CDR system. The overarching government EIA for the Chjildren and Socail Work Act 2017 which directs the move to the new system states the following: “These measures have no direct equality impacts by reference to the protected characteristics. The measures replace one framework for assessing and learning from serious incidents with another. More effective working of this nature should have a beneficial impact on all children engaged with child protection and safeguarding services, including those with protected characteristics..”1

Resource requirements These are currently being scoped. A know finnancial implication for the continued usage of eCDOP is noted in section 5.0 below and is estimated at circa £13k for the WELC footprint.

Next steps If APPROVAL is forthcoming work will commence on delivering the WELC footprint CDR system.

1.0 Purpose

The purpose of this paper is:

To INFORM Tower Hamlets CCG Governing Body of the proposed Waltham Forest, East London and the City (WELC) Child Death Review System (CDR) arrangements

For Tower Hamlets CCG Governing Body to APPROVE the proposed Waltham Forest, East London and the City (WELC) CDR arrangements

2.0 Context

The Children and Social Work Act (2017), Working Together: transitional guidance (2018) and the subsequent Child Death Review Statutory and Operational Guidance (updated January 2019) set out how Local Authority areas must begin their transition from Local Safeguarding Children‟s Boards to a new system of multi-agency arrangements and local and national child safeguarding reviews

1 See https://www.parliament.uk/documents/impact-assessments/IA16-008.pdf

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https://www.parliament.uk/documents/impact-assessments/IA16-008.pdf

Based on the 2016 Wood Review of Local Safeguarding,2 the Children and Social Work Act 3 (CSWA17) has significantly altered elements of safeguarding in the English system. Under the new legislation Local authorities and Clinical Commissioning Groups are named as „child death review partners‟ and must make arrangements for the review of each death of a child normally resident in the local authority area. Formal collaboration between responsible partners for child death reviews will be undertaken at greater scale, enabling the formation of Child Death Review systems - comprising of provider delivered Child Death Review Meetings (CDRM) and Child Death Overview Panels covering larger operational footprints with a minimum case review level of 60 cases per annum.

The purpose of setting out key features of a robust child death review process is to enable the standardisation of outputs from Child Death Reviews as much as possible.

This in turn should enable effective thematic learning from reviews, i.e. a local review may be able to identify specific learning but trends analysis at a national level may identify modifiable factors that could be altered to prevent future deaths.

Indeed, the aim of the published Child Death Review; Statutory and Operational Guidance (England) (Updated January 2019) is to do this by setting out standardised approaches to:

Immediate decision making and notifications

Investigating and information gathering

The child death review meeting

The Child Death Overview Panel

Family engagement and bereavement support

3.0 Proposed North East London approach

To enact the new requirements with regards to larger Panels across a wider footprint, the Barking and Dagenham, Havering and Redbridge (BHR) geography are proceeding to one panel across their footprint.

Child Death Review; Statutory and Operational Guidance (England) (Updated January 2019) states that the child death review footprint, whilst locally agreed, should typically cover 60 child deaths per year, thereby enabling appropriate thematic learning to take place. This means that any future Panel needs to be across a wide geographical footprint than just Tower Hamlets.

To this end, discussions have been taking place between Health and Local Authority partners across the Waltham Forest, East London and the CITY (WELC) footprint,

2 https://www.gov.uk/government/publications/wood-review-of-local-safeguarding-children-boards

3 http://www.legislation.gov.uk/ukpga/2017/16/contents/enacted

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https://www.gov.uk/government/publications/wood-review-of-local-safeguarding-children-boards

http://www.legislation.gov.uk/ukpga/2017/16/contents/enacted

comprising City and Hackney, Newham, Tower Hamlets and Waltham Forest and they have agreed in principle to work together to develop a WELC Panel, acknowledging that this needs to be formally approved by respective Boards/ Committees.

The Tower Hamlets CCG Governing Body is formally requested to APPROVE moving to a WELC Panel.

All Child Death Review Partners are being asked to approve moving to this new arrangement through the same core structure of this paper during March and April 2019 to meet the nationally mandated timeline.

4.0 Timelines

The nationally set timelines are outlined below:

All Child Death Review Partners are required to publish details of their new arrangements by 29 June 2019

The transition to the new arrangements need to be undertaken by 29 September 2019

5.0 eCDOP System

The electronic case management system (eCDOP), has supported standardisation of processes and effective collation of data across London CDOPs and is currently used by Partners across the WELC geography. Healthy London Partnership (HLP) have confirmed that they will cover the costs of this system across the WELC geography for 2019/ 2020 – c£13k.

From 2020/ 2021, the WELC system, Health and Local Authorities, will need to cover the costs of this system.

6.0 Next steps

Upon receipt of formal approval, the Partners will work collaboratively to ensure appropriate systems and processes are in place across WEL with regards to the afore mentioned standardised approaches thereby ensuring the transition by 29 September 2019 is possible. Partners are securing support to enable this to happen.

7.0 Recommendation

The Tower Hamlets CCG Governing Body are asked to APPROVE moving to a WELC Panel

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Cabinet Decision

24th April 2019

Report of: Ann Sutcliffe, Corporate Director Place


Corporate Enforcement Policy 2019

Lead Member Councillor Cllr David Edgar, Cabinet Member for Environment

Originating Officer(s) David Tolley – Head of Environmental Health and Trading Standards


Key Decision? Yes


17 January 2019

Reason for Key Decision Significant impact on communities living or working in two or more wards


A Borough that our residents are proud of and love to live in. People feel safe in their neighbourhoods and anti-social behaviour is tackled.

Executive Summary

On 8th September 2010, Cabinet agreed a council-wide Enforcement Policy. The Enforcement Policy is concerned with the Council's exercise of its criminal and quasi-criminal enforcement functions. Whilst some of the sanctions available to the Council are civil in nature, such as forfeiture of goods and money, the Enforcement Policy is not concerned with purely civil enforcement such as the enforcement of debts. Rather, it is concerned with offences and contraventions of legislation that fall within the Council's responsibility to enforce. This report details proposed amendments to the Council‟s Enforcement Policy, the accompanying Regulatory Investigatory Powers Act (“RIPA”) Policies for directed surveillance and the use of covert human intelligence sources. The policies are being reviewed to take account of changes in legislation, including changes brought about by the Regulators Code.

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Agenda Item 6.4


1. Consider the report and agree the proposed Enforcement Policy at Appendix 1.

2. Agree the revised Enforcement Policy along with the policies on the use of

covert surveillance and the use of covert human intelligence sources under the Regulation of Investigatory Powers Act 2000.

1 REASONS FOR THE DECISIONS 1.1 To ensure that the Council‟s enforcement decision making process is clear

and transparent, embracing the Regulators Code.

1.2 The Council‟s policies need to reflect current changes to legislation and good practice, and to be reviewed regularly to be both relevant and up to date.

2 ALTERNATIVE OPTIONS 2.1 The Council can choose not to update its Enforcement Policy but it may mean

that formal enforcement action taken by officers fails. 3 DETAILS OF THE REPORT 3.1 This Policy is being reviewed and revised to take account of changes in

legislation and the introduction of the Regulators Code, which replaces the Regulators Compliance Code. The intention of the revised policy is to create a clearer, consistent approach covering all regulatory service across the Council. This also assists to enhance and formalise our joint working and partnership approach.

3.2 The Council-wide enforcement policy adopted by the Council on 8 September

2010 introduced five key principles of enforcement, in accordance with the provisions of the Legislative and Regulatory Reform Act 2006 and the Regulators Compliance Code namely –

Raising awareness of the law and its requirements.

Proportionality in applying the law and securing compliance.

Consistency of approach

Transparency about the actions of the Council and its officers.

Targeting of enforcement action.

3.3 The revised Policy takes account of the principles set out in the Regulators Code, which replaces the Regulators Compliance Code. The new code sets out 7 principles of enforcement as follows:

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Raising awareness of the law and its requirements and providing advice and guidance to assist those regulated

Proportionality in applying the law and securing compliance

Consistency of approach

Transparency about the actions of the Council and its officers

Targeting of enforcement action

Basing regulatory activities on risks

Accountability 3.4 The Council must have regard to this code when developing standards,

policies or procedures that guide their regulatory activities. The specific regulatory functions which are carried out by the Council are set out in Part 3 of the schedule to the Legislative and Regulatory Reform (Regulatory Functions Order) 2007 and include the following:

a) Agricultural b) Animal Health and Welfare c) Anti-Social behaviour d) Children e) Consumer and business protection f) Companies g) Education h) Entertainment i) Environment j) Food standards and safety k) Housing l) Intellectual property m) Licensing n) Public Health and Safety o) Road Transport p) Weights and measures

3.5 The main enforcement areas covered by the Council are as follows;

Environmental Health, including Consumer Protection, Trading Standards, Health and Housing, Noise, enforcement in relation to premises required to be smoke free, Health and Safety, Food Safety, Licensing, special treatments enforcement, illegal tobacco

Market enforcement, including unlicensed street trading

Corporate anti-fraud, including benefit fraud, parking fraud and social housing fraud

School attendance

Planning

Building Control

Elections

Environmental including fly-tipping, littering and ASB related activities.

3.6 The Enforcement Policy is concerned with the Council‟s exercise of its criminal and quasi-criminal enforcement function. The Policy will assist

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Council officers to carry out their duties consistent with the principles of enforcement set out in the Regulatory Code. The Council‟s Enforcement Policy highlights that the Council‟s enforcement activities support the Strategic Plan priority of „A Borough that our residents are proud of and love to live in ; ‟ People feel safe in their neighbourhoods and anti-social behaviour is tackled‟.

3.7 Key Implications: The Council is responsible for enforcing a wide range of

legislation within the London Borough of Tower Hamlets. The Corporate Policy summarises the Council‟s overall approach to the use of enforcement powers generally, and outlines what residents, businesses, consumers and workers can expect from enforcement officers. This could range from criminal prosecutions at one end of the spectrum to informal warnings and advice at the other

3.8 A revised Corporate Enforcement Policy will promote a consistent approach

and ensure that all departments involved in enforcement are complying with its principles. At the same time it allows flexibility for each service area to develop its own enforcement mechanisms, taking on board the legal and operational differences between the service areas.

Changes in Legislation 3.9 It is necessary to update the Council‟s current Enforcement Policy as there

has been various changes in procedure and legislation that have taken place that need to be reflected in the refreshed policy.

3.10 Since the Policy was last reviewed the Regulators Code has come into effect.

Consideration of the new Code would suggest that there should be seven principles relating to enforcement in place of the current five. The suggestion is to add the following two principles to reflect the regulators code:

Accountability and

Enforcement based on risk 3.11 Since the change in legislation, enforcement activity has taken account of the

additional two principles set out in the new Regulators Code, and the revised Enforcement Policy now reflects this.

3.12 The main suggested changes to the council-wide enforcement policy reflect

the following:

a) Regulators code b) Changes to RIPA policies as a result of the changes introduced by the

Protection of Freedom Act 2012 c) Primary Authority Partnership Scheme

d) Changes to procedures relating to anti -social behaviour brought about by the Anti-Social behaviour, Crime and Policing Act 2014 e) A suggestion that there should be 7 principles relating to enforcement in place of the current 5, as a consequence of the regulators code.

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3.13 There are two RIPA Policies appended to the Council-wide Enforcement Policy. One relates to Directed Surveillance and the other one covers Covert Human Intelligence Sources. They have both been reviewed and amended to reflect changes brought about by the Protection of Freedoms Act 2012.

3.14 The Protection of Freedoms Act 2012 received Royal Assent on 1 May 2012.

Sections 37 and 38 of the Protection of Freedoms Act amend Parts 1 and 2 of the Regulation of Investigatory Powers Act 2000 (“RIPA”) so as to require local authorities to obtain judicial approval for activities under RIPA. This means that before obtaining or disclosing communications data under Part 1 of RIPA, or conducting covert surveillance or using a covert human intelligence source under Part 2 of RIPA, the Council will require its own authorisation to be approved by a justice of the peace. This adds an extra layer of approval. The requirement for judicial approval to conduct covert surveillance, or use a covert human intelligence source, under Part 2 of RIPA came into force on 1 November 2012.

3.15 The Secretary of State has made the Regulation of Investigatory Powers

(Directed Surveillance and Covert Human Intelligence Sources (Amendment) Order 2012, as permitted by the Protection of Freedoms Act 2012 which came into force on 1 November 2012. The order imposes additional conditions that a Local Authority authorisation of covert surveillance must meet. The Order restricts the Council‟s use of covert investigation to the following offences –

An offence punishable by a maximum term of at least 6 months of imprisonment.

An offence under section 146 of the Licensing Act 2003 (sale of alcohol to children).

An offence under section 147 of the Licensing Act 2003 (allowing the sale of alcohol to children).

An offence under section 147A of the Licensing Act 2003 (persistently selling alcohol to children).

An offence under section 7 of the Children and Young Persons Act 1933 (sale of tobacco etc. to persons under eighteen).

An offence under section 141A of the Criminal Justice Act 1988 (sale of knives and certain articles with blade or point to persons under sixteen)

An offence under Regulation 31 of the Pyrotechnic Articles (Safety) Regulations 2015 (prohibition on making fireworks & other pyrotechnic articles available to persons younger than the minimum age limit)

3.16 The Council‟s RIPA policies are appended to the Enforcement Policy. The

policies need to be amended to reflect the need to additionally obtain court approval and the limitation on the use of covert investigation to specified offences. A revised Enforcement Policy with is set out in Appendix 1 to this report.

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4 EQUALITIES IMPLICATIONS 4.1 An equalities impact assessment checklist has been undertaken and is

attached at Appendix 2. 5 OTHER STATUTORY IMPLICATIONS 5.1 This section of the report is used to highlight further specific statutory

implications that are either not covered in the main body of the report or are required to be highlighted to ensure decision makers give them proper consideration.

5.2 Best Value: The report assists with the regularising decision-making in areas

in which the Council is already active. The enforcement policy seeks to ensure that enforcement action is targeted to the Council‟s policy objectives. This is likely to lead to efficient enforcement action than a less-controlled enforcement effort.

5.3 Environmental: The Enforcement policy seeks to support the strategic plan

which promotes and improves the economic, social and environmental well-being of Tower Hamlets. The extent that the Enforcement Policy aligns enforcement action with the Strategic Plan will tend to promote sustainable action for the environment.

5.4 Risk Management: Enforcement action has a variety of inherent risks, including the potential for over or under-enforcement, discrimination, adverse cost orders and damage to the Council‟s reputation. The principles of enforcement contained in the policy provide a sound basis for decision-making that will reduce the likelihood of any adverse outcomes.

5.5 Crime reduction and Safeguarding: Enforcement in its broadest sense acts as a deterrent for crime and will therefore likely reduce all form of crime within the Borough. The Enforcement Policy sends a clear message to the perpetrator whilst supporting the victim, that the Council will undertake enforcement where necessary.

6 COMMENTS OF THE CHIEF FINANCE OFFICER

6.1 This is a report of the proposed revised Enforcement Policy along with

policies on the use of covert surveillance and the use of covert human intelligence sources under the Regulation of Investigatory Powers Act 2000.

6.2 There are no financial implications arising from the recommendations in this report however the enforcement policies are designed to meet the Council‟s requirements to minimise the risk of fraud, error and omission to Council‟s services, finances and assets.

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7 COMMENTS OF LEGAL SERVICES 7.1 The Regulators‟ Code (the Code) came into statutory effect on 6 April 2014

under the Legislative and Regulatory Reform Act 2006. It provides a clear, flexible and principle-based framework for how regulators should engage with those they regulate.

7.2 The Council is obliged to have regard to the Code when developing policies

and operational procedures that guide the council‟s regulatory activities including enforcement action.

7.3 If the Council concludes, on the basis of material evidence, that a specific provision of the Code is either not applicable or is outweighed by another relevant consideration, the Council is not bound to follow that provision but should record that decision and the reasons for it.

7.4 One of the requirements of the Code is that Regulators should provide a clear Enforcement and Prosecution Policy that sets out our approach to enforcement and outline that the council will take a consistent, fair, transparent and proportionate approach so as not to place too onerous a burden on local businesses, organisations, customers and the public. The Policy should be available to businesses & members of the public.

7.5 Although, the preparation and publishing of the policy is not in itself a legal requirement. However, if the Council does not adopt a revised Enforcement Policy and there is no common reference point, there is a risk that the principles are inconsistently applied across different service areas. This might increase the risk of legal challenge and reduce the fairness and effectiveness of the Council‟s approach to enforcement. The adoption of a policy is considered to be best working practice and will also assist the both Councils to demonstrate that it has regard to the Code.

7.6 In relation to prosecutions, the Council is required to follow the provisions of the Code for Crown Prosecutors, which have been incorporated into this Corporate Enforcement Policy.

7.7 In addition, the Council must have due regard to the Public Sector Equality Duty under the Equality Act 2010 when carrying out any functions including developing any policies that may have any effect on any protected persons, in particular the duty to eliminate discrimination, harassment and victimisation and advance equality of opportunity and fostering good relations.

7.8 The Council also have a duty under the Human Rights Act 1998, when carrying out any function, not to act incompatibly with rights under the European Convention for the Protection of Fundamental Rights and Freedoms.

____________________________________

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Linked Reports, Appendices and Background Documents Linked Report

NONE Appendices Appendix 1: Enforcement Policy 2019 Appendix 2: Equality Impact Checklist Background Documents – Local Authorities (Executive Arrangements)(Access to Information)(England) Regulations 2012

NONE Officer contact details for documents: Or state N/A

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January 2019

DRAFT

LONDON BOROUGH OF

TOWER HAMLETS

ENFORCEMENT POLICY

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INDEX

1. Introduction .............................................................................. 3

2 The Basis for Enforcement ...................................................... 4

3 Principles of Enforcement ........................................................ 8

4. Authorisations and Delegations .............................................. 12

5. Investigations ......................................................................... 14

4 Enforcement Options ............................................................. 14

7. Levels of Enforcement Action ................................................. 27

8. Young people ......................................................................... 32

9. Other Enforcement Agencies ................................................. 33

10. The Role of Legal Services ................................................... 34

11. The Code for Crown Prosecutors .......................................... 35

12. Equalities and Diversity ......................................................... 37

13. Changes to the Policy ............................................................ 38

14. Complaints ............................................................................ 39

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APPENDICES

A. LBTH Policy on the Use of Covert Surveillance: Regulation of

Investigatory Powers Act 2000

B. LBTH Policy on the Use of Covert Human Intelligence

Sources.

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1. Introduction

1.1 This Enforcement Policy is concerned with the Council’s

exercise of it’s criminal, quasi criminal enforcement

functions. Whilst some of the sanctions available to the

Council are civil in nature, such as forfeiture of good and

money, this policy is not concerned with purely civil

enforcement such as the enforcement of debts. Rather it is

concerned with offences and contraventions of any

legislation that fall within the Council’s responsibility to

enforce.

1.2 This policy has been developed in accordance with the

general principles of the Regulators Code, Hampton Report

and the Enforcement Concordat. All relevant stakeholders

have been consulted and current government guidance and

relevant codes of practices have also been considered.

1.3 The Policy will assist Council officers to carry out their duties

consistent with the principles of enforcement set out in

section 3. The Enforcement Policy helps to promote efficient

and effective approaches to inspection and enforcement,

with the aim of complying with regulator’s requirements

without imposing unnecessary burdens. It will assist the

community and other members of the public to understand

why the Council approaches enforcement in a particular way

in individual cases.

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1.4 The Policy is a high-level document that applies to all of the

Council's relevant enforcement functions. It is recognised

that individual service areas within the Council that carry out

enforcement may have to take into account considerations

specific to the regulatory framework in which they operate.

To this end, there may be additional service-specific

enforcement policies that operate under the broad umbrella

of this policy.

1.5 Some regulatory activities involve consultation with other

agencies before deciding on the most appropriate course of

action. Sometimes there will be more than one agency that

can take action to resolve an issue. If there is a shared role

with other agencies, wherever possible, our enforcement

activity will be co-ordinated to minimise duplication, delays or

to increase effectiveness.

2 The Basis for Enforcement

2.1 The Council will target its enforcement action having regard

to the following –

The Tower Hamlets Plan

The Tower Hamlets Strategic plan

The Tower Hamlets Local Plan

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Any external targets or requirements imposed under

relevant legislation.

2.2 The Tower Hamlets Plan makes clear the role of

enforcement in the goals of the Council and the Tower

Hamlets Partnership. The Tower Hamlets Plan provides the

Tower Hamlets Partnership long-term vision for the

borough’s local aspirations, needs and priorities. Overall,

the Partnership is trying to achieve One Tower Hamlets, a

borough where everyone has an equal stake and status;

where people have the same opportunities as their

neighbours; where people have a responsibility to contribute;

and where families are the cornerstone of success. This is

the broad vision of how to improve the well-being of Tower

Hamlets.

2.3 The key objective in the Tower Hamlets Plan is that of

tackling inequality by building a strong, inclusive and fair

borough. This means a place where we have strong,

resilient and safe communities. As part of tackling and

preventing crime, the Council will have regard to prevention

and reducing re-offending. However, the Council will also

actively enforce and will promote its successes to support

the Tower Hamlets Plan objectives. Another key Tower

Hamlet Plan objectives that enforcement may support are to

help people feel safe and live in a cohesive community.

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2.4 All enforcement action is based upon an assessment of the

nature of the offence and the risk, nuisance, harm or

disadvantage being caused.

2.5 This Policy has been written with regard to the Regulators’

Code which came into force on 6th April 2014 The

Regulators Code is a central part of the Government’s

better regulation agenda. Its aim is to embed a risk-based,

proportionate, consistent and targeted approach to

regulatory activity and enforcement among the regulators it

applies to. The Code also aims to develop transparent and

effective dialogue and understanding between regulators

and those they regulate.

2.6 The Council fully acknowledges and endorses the rights of

individuals who may be subject to enforcement. It will

ensure that enforcement action will be taken with due regard

to:

Police and Criminal Evidence Act 1984

Criminal Procedures and Investigation Act 1996

Human Rights Act 1998

Regulation of Investigatory Powers Act 2000

Legislative and Regulatory Reform Act 2006

(“LRRA” and The Regulators Code made under

section 22 of the LRRA 2006

The Ministry of Justice Simple caution for Adult

Offenders Guidance, as amended

The Code for Crown Prosecutors

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Primary Authority Partnership Scheme

Equal rights and anti-discrimination legislation

Other relevant legislation and guidance.

2.7 Where specific advice or direction on enforcement action

exists, this will be taken into account as appropriate. For

example, in relation to licensing the Council will have regard

to the guidance issued under section 182 of the Licensing

Act 2003. Specific advice or direction may come from

sources such as internal operating directions or

arrangements.

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3 Principles of Enforcement

3.1 The Council's approach is founded on firm but fair regulation,

around the principles of:

raising awareness of the law and its requirements

and providing advice and guidance to assist those

regulated

proportionality in applying the law and securing

compliance

consistency of approach

transparency and accountability about the

actions of the Council and its officers

targeting of enforcement action and basing

regulatory activities on risks

Basing regulatory activities on risk

Accountability

3.2 The above principles take account of those set out in section

21 of the Legislative and Regulatory Reform Act 2006

(“LRRA”), the Legislative and Regulatory Reform

(Regulatory Functions) Order 2007 and the Regulator’s

Code published 6 April 2014. The Regulators Code

clarifies the provisions contained in the previous Regulators

Compliance Code in a short and accessible format.

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Raising Awareness

3.3 The first step in enforcement is to prevent contraventions of

the law by raising awareness and promoting good practice,

by providing advice, information, guidance and support. The

aim is to assist those regulated to under standand meet

their responsibilities to comply. In this way the Council

Officers will engage with those they regulate and support

them to comply and grow by sharing information about

compliance and risk. The Council recognises that where a

business has entered into partnership with a Primary

Authority, the Primary Authority will provide compliance

advice and support. This advice will be taken into account

when considering whether to take enforcement action,

and/or the most appropriate enforcement action to take.

Proportionality and Accountability

3.4 Proportionality is about balancing the crime or the wrong

being investigated and the risk, nuisance or disadvantage

being caused. Our activities will reflect the level of risk to

the public and enforcement action taken will relate to the

seriousness of the offence.

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Consistency

3.5 Consistency means taking a similar approach in similar

circumstances to achieve similar ends. The Council aims to

achieve consistency when: responding to requests for

service; offering advice; and deciding upon enforcement

action.

3.6 Consistency does not mean uniformity. Officers will need to

take account of many variables when making decisions,

including: the seriousness of the breach; any history of

previous breaches; the attitude of the offender; and the

capacity of the offender.

3.7 Whilst the appropriate officer will be expected to exercise

judgement in individual cases, the Council will continue to

strive to promote consistency, including: advice, guidance

and training for its officers; and arrangements for effective

liaison with other enforcing bodies.

Transparency

3.8 Transparency means helping those who are regulated and

other individuals to understand: what is expected of them;

and what they should expect from the Council as an

enforcing authority.

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3.9 Transparency involves distinguishing between statutory

requirements and other advice and guidance, explaining why

an officer will or has taken enforcement action; explaining

how to comment or complain about the service provided and

routes to appeal.

Targeting

3.10 Targeting means ensuring that enforcement is directed

primarily where:

activities give rise to the most serious risks,

nuisances, disadvantages or other similar

situations;

where the law places an absolute duty upon the

Council;

activities are least well controlled/managed.

3.11 Action will be primarily focused on those who are

responsible for a risk or activity and are best placed to

control it.

3.12 Targeting will reflect local needs and national priorities.

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4 Authorisations and Delegations

4.1 For enforcement action or action taken in connection with

legal proceedings, decisions will be taken by officers duly

authorised under legislation, or with delegation under

schemes of delegation maintained by the Council, as

relevant or appropriate to the subject area (“Authorised

Officers”).

4.2 Pursuant to the Council’s Constitution, the responsibility for

instituting or participating in legal proceedings lies with the

Divisional Director Legal or officers nominated by the

Corporate Director – Governance and the Divisional Director

Legal Services, or officers nominated by the Corporate

Director. Accordingly, the decision whether or not to

prosecute offences will be taken within Legal Services. This

decision will typically be taken on instructions from

Authorised Officers.

4.3 Relevant Officers will be authorised to carry out enforcement

actions in accordance with schemes of delegation made

under the Council’s Constitution.

4.4 Where any action is taken which may lead to or bear upon a

prosecution or simple caution, or give rise to other

enforcement action, e.g. service of a notice, the Council’s

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Legal Services will require to be satisfied as to the adequacy

and legality of documentation, procedures and evidence.

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5 Investigations

5.1 The Council will determine the appropriate approach to

investigation having regard to the content of this policy,

including the principles of enforcement, (set out in section 3

of this Policy document).

5.2 As set out in paragraph 2.6 above, the Council respects the

rights of individuals and will have regard to the statutes and

guidance there set out. The Council will follow the policies

set out in Appendices A and B to this Policy when using,

respectively, covert surveillance, or communications data or

covert human intelligence sources under the Regulation of

Investigatory Powers Act 2000.

5.3 In respect of the regulatory functions exercised by the

Council which are specified in Part 3 of the Schedule to

the Legislative and Regulatory Reform (Regulatory

Functions) Order 2007, as amended, the Council will, in

determining the appropriate form of any investigation,

comply with the requirements of the Regulators’ Code.

6 Enforcement Options

6.1 There are a wide range of enforcement options open to the

Council to take and each will be dependant upon the

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circumstances of the offence, Not all options will apply to

every enforcement service, e.g. revocation of street trading

licences is an option available specifically to Market

Services.

6.2 Examples of the options that may be available, depending

on the subject enforcement area are set out below.

Guidance is given in section 7 of this policy as to the

appropriate level of enforcement to take in an individual

case.

No action

6.3 The Council may choose to do nothing in respect of an

apparent contravention of the law. This may be appropriate

in relation to low level offending where the offender

immediately puts right what was wrong (e.g. littering where

the offender immediately picks up after being spoken to, and

has no previous history of such offending. This may also be

suitable in low level offending where the offence arose as

result of a genuine mistake or misunderstanding.

Prevention

6.4 The Council may take action designed to prevent further

offending.

6.5 A preventative approach can also be used to explain legal

requirements and, where appropriate, the means to achieve

compliance. An educative approach may be considered

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necessary when new legislation has come into force that will

require time for businesses to fully understand and

comply with (e.g. if new Food Regulations were

introduced). This may involve the Council in undertaking

pro-active education programmes.

Warning

6.6 A warning is a written notification from the Council to an

offender, that identifies the offending conduct and offence,

and warns the offender that any further like breach of the law

will lead to more serious enforcement action. A warning may

be considered where the following conditions are met:

The offence is not serious;

The offender admits the offence;

The risk of re-offending is considered minimal; and

Enforcement action has not previously been taken

against the offender.

Simple Caution

6.7 The administration of a Simple Caution is a non-statutory

disposal of offences committed by adult offenders. The

simple caution provides a means of dealing quickly and

simply with less serious offences where the offender has

admitted the offence. It records an individual’s criminal

conduct for possible reference in future criminal proceedings

or security checks. Administering a simple caution diverts

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offenders from appearing in criminal courts, whilst at the

same time reducing the likelihood of re-offending.

6.8 The Council will exercise discretion when deciding whether

to administer a simple caution on a case by case basis. In

doing so, the Council will have regard to the aims of a simple

caution set out in the preceding paragraph and any relevant

guidance. Relevant guidance includes the MOJ Guidance on

Simple cautions for adult offenders as amended.

6.9 In each case, the Council will consider whether a caution is

appropriate to the offence and the offender and whether it is

likely to be effective in the circumstances. In considering

whether a Caution is appropriate, the Council will consider

the following factors:-

Is there sufficient evidence of the suspect's guilt?

Has the suspect made a clear and reliable

admission of the offence (either verbally or in

writing)? A Caution will not be appropriate where a

person has not made a clear and reliable admission

of the offence (for example where intent is denied or

there are doubts about the person’s mental health

or intellectual capacity or where it is likely that the

person could avail themselves of the provisions of a

statutory defence).

Is it in the public interest to use a Caution as the

appropriate means of disposal? Officers should

take into account the public interest principles set

out in the Code for Crown Prosecutors.

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6.10 If there is a victim, then the Council will also take into

account the victim’s views before administering a simple

caution.

Enforcement notice

6.11 The Council has a variety of statutory powers to issue

enforcement notices. For example, in food safety cases the

Council may issue a Hygiene Improvement Notice under the

Food Safety Act 1990. Another example is the Council’s

power to issue an abatement notice under the

Environmental Protection Act 1990 in respect of statutory

nuisances (eg. noise nuisance). The Council will consider

whether or not an enforcement notice is an appropriate

response by reference to the provisions of any applicable

statutory provision and the circumstances of the case.

Works in default

6.12 In some cases, the Council has power to carry out works

to remedy non-compliance with an enforcement notice, or

to deal with a dangerous situation. If there is immediate

danger, the Council will be primarily concerned with

remedying that. In other cases, the Council will have

regard to a cost benefit analysis.

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Injunction

6.13 An injunction is a court order that requires a person to do, or

to refrain from doing, specified acts. The Council has some

statutory powers that enable it to seek injunctions, such as

section 222 of the Local Government Act 1972 and the

Antisocial Behaviour Act 2014. These actions will be in the

form of:

The Council will generally only consider injunctions for

enforcement purposes where it can be demonstrated that

prosecution will afford an inadequate remedy, or there is a

significant risk to the safety, health or economic welfare of

the public at large or to individuals.

Review or revocation of licence

6.14 The Council is responsible for administering a variety of

licences and permissions, such as under the Licensing Act

2003. Where there are contraventions of the law associated

with those licences and permissions, the Council has

statutory powers enabling review or revocation. The Council

will exercise those powers having regard to its

responsibilities under the applicable legislation. The Council

will consider whether other enforcement action should be

taken or, if it has been taken, whether further enforcement

action is appropriate.

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Criminal Behaviour Orders – CB0’s

6.15 The Council has power under Part 2 of the Anti-Social

Behaviour Crime and Policing Act 2014 to apply for a

Criminal Behaviour Order (“CBO”) against a person who has

caused or is likely to cause harassment, alarm or distress to

any person not of the same household.

A “CBO” is a court order available following any criminal

conviction that will prohibit a person from doing anything that

is described in the order (e.g. the individual entering a

defined area) or may require a person to do something

described in the order (e.g. attendance at an education

course on alcohol and its effects).

Public Spaces Protection Order

6.16 The Council also has power under Part 2 of the Anti-Social

Behaviour Crime and Policing Act 2014 to make a Public

Spaces Protection Order (“PSPO”). A PSPO allows the

Council to place restrictions or impose conditions on

activities which people can carry out in a designated area of

a public space.

6.17 PSPO’s can prohibit any activity, if the council is satisfied on

reasonable grounds, that the activities have had or are likely

to have, a detrimental effect on the quality of life of those in

the locality and the actions are likely to be persistent in

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nature. The restrictions imposed must be justified. An FPN

can be issued for breach of the terms of a PSPO.

Community Protection Notice (CPNs)

6.18 The Council has power under Section 43 Anti-social

Behaviour, Crime and Policing Act 2014 to issue a CPN

when the conduct of an individual is having a detrimental

effect on the quality of life of those in the locality, is

persistent or continuing in nature and unreasonable.

6.19 There are no restrictions on the types of behaviour that a

CPN can refer to, e.g it can relate to noise nuisance, rubbish

in gardens or littering. Any person aged 16 years or over

can be issued with a notice, they can also be served on

businesses. The notice will require the behaviour to stop and

if necessary reasonable steps be taken to ensure that it is

not repeated in the future.

Community Protection Warning (CPW)

6.20 Before issuing a CPN, the authorised officer must give a

written warning to the offender setting out the antisocial

behaviour and a timeframe for compliance.

6.21 Failure to comply with a CPN is a criminal offence which

may result in a Fixed Penalty Notice being issued by the

Council.

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Closure Powers

6.22 Part 4(3) of the AntiSocial Behaviour Crime & Policing Act

2014 replaced several existing closure powers with a power

to temporarily close premises. There are two stages to the

power a closure notice and a closure order.

6.23 The closure notice can be issued by either the police or the

Council without the need to go to a court. Once a closure

notice has been issued, an application must be made to a

magistrate’s court for a closure order, unless the notice is

cancelled. Closure orders can be issued for a period of up to

six months. The court can issue a closure order if they are

satisfied that:

A person has engaged, or is likely to engage, in disorderly,

offensive or criminal behaviour on a premises; or

There has been, or is likely to be, serious nuisance or

disorder near or associated with the use of a premises,

and an order is necessary to prevent it from continuing.

Civil Penalties

6.24 The Council has the power to issue Civil Penalty notices for

specific breaches under the Housing Act 2004. The Housing

and Planning Act 2016 provides powers that permit local

authorities to impose a civil penalty of up to £30,000 as an

alternative to prosecution for a range of offences under the

Housing Act 2004, and where a landlord or property agent

has breached a banning order under the Housing and

Planning Act 2016.

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Fixed penalty notice (FPN)

6.25 The Council has power to issue FPNs in respect of a certain

offences where prescribed by legislation such as the Clean

Neighbourhoods and Environment Act 2005 or the Antisocial

Behaviour Crime and Policing Act 2014. FPNs provides the

recipient the opportunity to pay a penalty in respect of

offending conduct, rather than being prosecuted. Receiving

a notice is not a criminal conviction, but failure to pay may

lead to prosecution for the original breach. Receiving an

FPN is not a criminal conviction, but failure to pay may lead

to prosecution for the original breach. The recipient of an

FPN may choose to have the matter dealt with in court. In

these circumstances the Council will give consideration to

the same matters applicable on prosecution (with the

exception of considering alternatives to prosecution).

6.26 The Council will generally only consider the use of FPNs

where the following conditions are met –

The offence is one for which a FPN may be issued

under a relevant statutory power.

The issue of a FPN is a proportionate response

The offender admits the offence, or at least has not

indicated to the issuing officer that the offence is

denied.

The risk of re-offending is considered minimal.

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Enforcement action has not previously been taken

against the offender (with the exception of no action, a

warning or a FPN having been taken); and the offender

has not been given an FPN in the preceding six

months or two FPNs in the preceding 12 months.

There is evidence to support prosecution if the offender

does not pay the FPN

The offender understands why the FPN is being issued

Juveniles aged 10-15 years

If the offender is known to the enforcement officer (or

any officer with him at the time of the alleged offence),

an FPN can be issued on the spot and their parents

notified as soon as possible. However, it is advisable

that it is issued in the presence of a parent or legal

guardian.

If the offender is not known by the enforcement officer

(or any officer with him at the time of the offence), their

parents or legal guardians details should be obtained

to make further enquiries.

Confiscation

6.27 A confiscation order is made after conviction to deprive the

defendant of the benefit that he has obtained from crime.

The Council may seek confiscation under the Proceeds of

Crime Act 2002.

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6.28 The Council is generally committed to taking action for

confiscation when it is available, so that offenders do not

benefit from their crimes. The Council will seek to obtain, so

far as possible, confiscated monies in order to apply them to

the support of its enforcement work.

6.29 In determining whether confiscation is appropriate, the

Council will have regard to the relevant statutory power and

the circumstances of the case. The Council will take into

account a cost benefit analysis of whether confiscation

action should be taken, recognising that the costs of the

action need to be weighed against the likely amount of the

confiscation order.

Prosecution

6.30 The Council is empowered to prosecute a variety of common

law and statutory offences. In some instances, the Council

is tasked to be an enforcing authority by statute. The Council

also has a general power to enforce arising from section

222 of the Local Government Act 1972.

6.31 Before recommending prosecution to Legal Services, the

instructing officer must be satisfied that there is sufficient,

reliable and admissible evidence to prove that the offence

was committed by the accused.

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6.32 The later sections of this Policy set out the considerations

that will be applied by the Council in determining whether or

not to prosecute.

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7 Levels of Enforcement Action

7.1 There will be circumstances in which the Council has

available several enforcement options. In determining the

appropriate level of enforcement action, the Council will

always take into account the circumstances of the individual

case. Even where the Council is targeting a particular type

of behaviour, it will be appropriate to consider individual

circumstances.

7.2 In choosing a particular enforcement option, the Council will

have regard to the basis for enforcement (section 2 of this

Policy), the principles of enforcement (section 3 of this

Policy) and the general approach to each option (section 7

of this Policy). The Council will also have regard to the

following matters when deciding between options –

The seriousness and effect of the offence

The previous history of the party concerned

Whether the offence was intentional, accidental or

otherwise

The offender’s attitude to the offence and whether

he or she has shown remorse

The willingness of the alleged offender to prevent a

recurrence

The consequences of non-compliance

The deterrent effect of a prosecution on offenders

and others

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Whether there is sufficient evidence to prove the

offence

The age, capacity or vulnerability of the offender.

7.3 In respect of the regulatory functions exercised by the

Council which are specified in Part 3 of the Schedule to the

Legislative and Regulatory Reform (Regulatory Functions)

Order 2007, as amended, the Council will, before taking

enforcement action, comply with the requirements of the

Regulators’ Code. The responsible officer should consider

whether it is appropriate to discuss the circumstances with

those suspected of the regulatory breach and, if so, take

that discussion into account when deciding on the best

approach. Reasons should be given to the person against

whom enforcement action is taken, at the time the

enforcement action is being taken.

7.4 There are particular considerations that apply before the

Council will prosecute. The Council will apply the Code for

Crown Prosecutors to any proposed prosecution, as further

explained in section 11 of this Policy. The Council will also

have regard to the following:

the seriousness of the alleged offence;

the level of risk, nuisance or harm caused;

the history of the individual concerned;

availability of key witnesses and their willingness to

co-operate;

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willingness of the prospective defendant to prevent

a recurrence;

whether a defence exists and the likelihood of the

defendant being able to establish such a defence;

probable public benefit of a prosecution and the

importance of the case, e.g. whether it may create a

legal precedent;

whether other formal action would be more

appropriate or effective;

any explanation offered by the defendant;

the age, capacity or vulnerability of the offender;

the vulnerability of any victim;

whether, owing to circumstances beyond the

offender’s control, the commission of the offence

was unavoidable.

7.5 If prosecution is an option, the Council will generally

consider it to be appropriate where one or more of the

following apply –

There has been a serious breach of or blatant

disregard for the law.

There is a refusal to achieve basic minimum legal

requirements.

There has been a previous prosecution.

There has been a Simple Caution administered

within the preceding 2 years.

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There has been a refusal to accept a Simple

Caution

There has been a refusal to heed an earlier

warning.

An FPN has been given in the preceding 6 months

or two FPNs in the preceding 12 months.

7.6 Before issuing a warning or caution, consideration will be

given to whether the person has received any previous

warnings or cautions for similar breaches and when those

were given. If the person has been given a warning or

caution for a similar offence within the previous two years, or

if the person has a history or pattern of more than one

warning or caution for similar offences, then it may be

inappropriate to adopt this enforcement action again.

7.7 The factors referred to above are not exhaustive. In particular

there may be Service-specific factors to be taken into

account. A decision as to the appropriate enforcement option

will depend on the particular circumstances of each case.

The Council will make an overall assessment having regard to

the importance of all relevant factors and the circumstances

of the case.

7.8 The responsible officer should in each case make a written

record of the reasons for any enforcement action taken.

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7.9 The Council will give consideration to how its enforcement

action affects individuals and groups within Tower Hamlets.

In appropriate cases, the Council may use information about

offenders and particularly any trends observed to develop

measures for addressing the causes of offending and re-

offending. Such measures may affect the Council’s

determination of the appropriate level of enforcement action in

an individual case.

7.10 The Council also reserves the right to seek banning orders

under the Housing Act 2004 or Prohibition Orders under the

Food safety legislation to prevent individuals carrying on

businesses/activities in these areas.

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8 Young people

8.1 From time to time, Council Enforcement Officers will be

required to deal with persons under the age of 18 as

offenders. Council Officers will not interview a Youth

about an offence unless an appropriate adult is present

and in full compliance with the relevant parts of the Police

and Criminal Evidence Act 1984 (PACE) Code C.

8.2 The Council will not normally prosecute any person who on

the day of the relevant offence is under the age of 18 but

will, in accordance with Home Office guidance consider,

where possible, ways of diverting youths away from the

criminal justice system.

8.3 The Council may, however, prosecute a person under the

age of 18 where the offence is of a serious nature (e,g.

assault, fraud etc.) or the person has been given a youth

caution or the person has previously been convicted of an

offence.

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9. Other Enforcement Agencies

9.1 The Council will co-operate as appropriate with other

enforcement agencies (for example, the Metropolitan police,

HMRC and the Federation Against Copyright Theft),to

ensure the efficient and effective regulation of activities in

Tower Hamlets. The Council will take into account, amongst

other things, the terms of this Policy in determining the

appropriateness of co-operation.

9.2 Section 2 of this Policy identifies the relationship between

the Community Plan and the Council’s enforcement action.

The Council’s co-operation with other agencies will be

affected by the Community Plan and other partnership

arrangements.

9.3 Where the Council has concurrent or overlapping powers of

enforcement with other agencies, the Council will liaise as

appropriate with those agencies to ensure effective co-

ordination, avoid inconsistencies, ensure that any action

taken is the most appropriate in the circumstances and

agree the lead prosecuting agency.

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10. The Role of Legal Services

10.1 Legal Services is a department within the Council,

headed by the Corporate Director, Governance and

based at 6th Floor of Mulberry Place, 5 Clove Crescent,

London E14 2BG. Pursuant to the Council’s Constitution,

the responsibility for instituting or participating in legal

proceedings lies with the Corporate Director, Governance

and Divisional Director, Legal or officers nominated by the

Corporate Director, Governance. Accordingly, the

decision whether or not to prosecute offences will be

taken within Legal Services. This decision will typically

be taken on instructions from Authorised Officers.

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11. The Code for Crown Prosecutors

11.1 In determining whether or not the Council will

prosecute an offence, the Council will consider the

matters set out in section 7 above, including the Code

for Crown Prosecutors.

11.2 The Code for Crown Prosecutors sets out the basic

principles to be followed by Council Prosecutors when

they make case decisions. The decision on whether or

not to go ahead with a case is based on two tests

outlined in the Code.

The evidential test

11.3 This is the first stage in the decision to prosecute.

Prosecutors must be satisfied that there is enough

evidence to provide a “realistic prospect of conviction”

against each defendant on each charge. Prosecutors

must consider the reliability of the evidence; the

credibility of any witness; and the admissibility of the

evidence. They must also consider what the defence

case may be and how that is likely to affect the

prosecution case. A “realistic prospect of conviction” is

an objective test. It means that a jury or a bench of

magistrates, properly directed in accordance with the

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law, will be more likely than not to convict the

defendant of the charge alleged. (This is a separate

test from the one that criminal courts themselves must

apply. A jury or magistrates’ court should only convict if

it is sure of a defendant’s guilt.) If the case does not

pass the evidential test, it must not go ahead, no

matter how important or serious it may be.

The public interest test

11.4 If the case does pass the evidential test, Prosecutors

must then decide whether a prosecution is needed in

the public interest. They must balance factors for and

against prosecution carefully and fairly. Some factors

may increase the need to prosecute but others may

suggest that another course of action would be better.

A prosecution will usually take place however, unless

there are public interest factors tending against

prosecution which clearly outweigh those tending in

favour. Prosecutors will only start or continue a

prosecution if a case has passed both tests.

11.5 Consistent with section 10 of this Policy, the decision

whether or not to prosecute rests ultimately with

Director of Governance and the Divisional Director,

Legal.

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12. Equalities and Diversity

12.1 In conducting enforcement work, the Council will be

mindful of its statutory responsibilities, in relation to

equal rights and anti- discrimination legislation, for

example under the Equality Act 2010. The Council will

take into account Valuing Diversity: Our Policy

Statement On Equality and Diversity. The Council will

take steps to gather information as appropriate in

relation to relevant equality strands, in order to assess

the impact of enforcement action.

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13. Changes to the Policy

13.1 The Council will keep this policy under review and may

amend the policy from time to time as it considers

appropriate.

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14. Complaints

14.1 The Council operates a corporate complaints system.

If there are any complaints regarding the Council’s

enforcement action or the application of this Policy,

then they may be made and dealt with in accordance

with the corporate complaints system. This is without

prejudice to any other rights that a person may have at

law.

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APPENDIX 1

LONDON BOROUGH OF TOWER

HAMLETS

POLICY ON THE USE OF COVERT

SURVEILLANCE

REGULATION OF INVESTIGATORY

POWERS ACT 2000

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CONTENTS

1. Introduction…………………………………………...2

2. Responsibilities……………………………………….9

3. Directed Surveillance………………………………..11

4. Priorities……………………………………………....13

5. Authorisations………………………………………...15

6. Duration/ Review/ Renewal……………………....…21

7. Cancellations……………………………………........23

8. Retention and destruction of product surveillance..24

9. Combined Authorisations…………………..….........25

10. Security of Covert Technical Equipment………..... 26

11. Communications data……………………………….27

12. Central Recording…………………………………….30

13. Training………………………………...……………...32

14. Member Oversight…………………………………....33

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1. Introduction

1.1 The Regulation of Investigatory Powers Act 2000 (“RIPA”)

provides a statutory framework for public authorities to use

covert investigatory techniques such as surveillance, where

necessary and proportionate, for the purpose of preventing

or detecting crime and disorder. If such activities are

conducted by council officers, then RIPA regulates the use of

these powers in a manner that is compatible with the Human

Rights Act 1998. Surveillance includes; monitoring,

observing or listening to persons, monitoring or observing

their movements, conversations or their other activities or

communications, and the recording of anything monitored,

observed or listened to in the course or surveillance. It also

includes surveillance by or with the assistance of a

surveillance device.

1.2 Part ll of Chapter ll RIPA sets out the provisions in relation to

Directed Surveillance. This is covert surveillance that is not

intrusive, but is carried out in relation to a specific

investigation or operation in such a manner as is likely to

result in the obtaining of private information about an

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individual (other than by way of an immediate response to

events or circumstances, such that it is not reasonably

practicable to seek authorisation under the 2000 Act).

Surveillance is covert when the subject of the surveillance is

unaware that it is being carried out. The provisions aim to

regulate the use of these investigative techniques and to

prevent the unnecessary invasion of the privacy of

individuals.

1.3 Intrusive surveillance is covert surveillance that is carried

out in relation to anything taking place on residential

premises or in a private vehicle. Local authorities cannot

authorise surveillance that is intrusive

1.4 Relevant Officers of the London Borough of Tower Hamlets

are authorised in certain circumstances to use RIPA to

undertake directed surveillance and access low level

communications data in order to detect and prevent crimes

such as anti-social behaviour, offences under the trading

standards legislation, and fraud. Typical examples of

directed surveillance include covertly following people,

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covertly taking photographs of them, and using hidden

cameras to record their movements

1.5 Whilst RIPA itself does not provide any specific sanction,

where an activity occurs which should otherwise have been

authorised, any evidence thereby obtained may be

inadmissible in court. The activity may also be unlawful

under the Human Rights Act 1998 and may result in an

investigation by the Ombudsman and/or the Investigatory

Powers Tribunal.

1.6 RIPA provides that responsibility for authorising directed

surveillance, use of a Covert Human Intelligence Source

(CHIS) or acquisition of communication data lies with a

Divisional Director, Head of Service, Service Manager or

equivalent. RIPA was amended by the Protection of

Freedoms Act 2012. Since 1st November 2012 the internal

authorisation for such surveillance methods does not take effect

until such time as a Magistrate has made an order approving

it. The government introduced this requirement to impose a

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statutory check on local authorities and to ensure that powers

are only used to prevent serious crime.

1.7 This Policy must be read in conjunction with the current Home

Office Guidance and relevant Codes of Practice.

1.8 The Council has broad statutory functions and takes targeted

enforcement action in relation to those functions having regard

to the following –

The Tower Hamlets Plan

The Tower Hamlets Strategic Plan

The Tower Hamlets Local Plan

Any external targets or requirements imposed under

relevant legislation

The Councils Enforcement Policy

1.9 There may be circumstances in the discharge of its statutory

functions in which it is necessary for the Council to conduct

directed surveillance for one or more of the following purposes

Preventing or detecting crime where the offence

attracts a maximum custodial sentence of 6 months or

more or where the offence relates to the underage sale

of alcohol, tobacco and other age related products

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Preventing disorder where the disorder involves a

criminal offence punishable by a maximum term of at

least 6 months imprisonment, whether on summary

conviction or on indictment

1.10. As a consequence of the Protection of Freedoms Act

2012 the council’s use of RIPA is restricted to the

following offences:

An offence punishable by a maximum term of at

least 6 months imprisonment

An offence under section 146 of the Licensing Act

2013 (sale of alcohol to children)

An offence under section 147 of the Licensing Act

2003 (allowing the sale of alcohol to children)

An offence under section 147A of the Licensing

Act 2003 (persistently selling alcohol to children);

or

An offence under section 7 of the Children and

Young Persons Act 1933 (sale of tobacco etc. to

persons under eighteen)

o An offence under section 141A of the Criminal Justice Act 1988 (sale of knives and certain articles with blade or point to persons under sixteen)

o An offence under Regulation 31 of the Pyrotechnic Articles (Safety) Regulations 2015 (prohibition on making fireworks & other pyrotechnic articles available to persons younger than the minimum age limit)

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The crime or disorder detected or to be prevented, must meet the

crime threshold. The crime threshold came into force on 1st

November 2012 and only applies to directed surveillance

Basis for lawful surveillance activity

1.11 The Human Rights Act 1998 gave effect in UK Law to the

rights set out in the European Convention on Human Rights

(ECHR). Some of these rights are absolute, while others are

qualified, meaning that it is permissible for the State to

interfere with those rights if certain conditions are satisfied.

Amongst the qualified rights is a person’s right to respect for

their private and family life, home and correspondence, as

provided for by article 8 of the ECHR. It is Article 8 that is

most likely to be engaged when public authorities seek to

obtain private information about a person by means of covert

surveillance. Article 6 of the ECHR, the right to a fair trial, is

also relevant where a prosecution follows the use of covert

techniques, particularly where the prosecution seek to

protect the use of those techniques through public interest

immunity procedures.

1.12 The Council understands that it is obliged to comply with the

provisions of the Regulation of Investigatory Powers Act

2000 (“RIPA”) in order to conduct directed surveillance. The

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Council believes that by complying with the provisions of

RIPA, the Council should also ensure that any directed

surveillance comes within the qualification in Article 8(2) of

the ECHR and, accordingly, the Council should not breach

its obligation under section 6(1) of the Human Rights Act

1998.

1.13 The Investigatory Powers Commissioner’s Office (IPCO) has

recommended as best practice that public authorities

develop a corporate policy. The Council concurs with the

OSC that a corporate policy is best practice and has had

such a policy in effect since 27th July 2004. This document is

the Council’s corporate policy in relation to directed

surveillance. The Council also has a policy in place in

respect of the use of covert human intelligence sources,

which is contained in a separate document.

1.14 The Council has prepared guidance notes and a procedure

manual on the use of directed surveillance, which should be

read with this policy.

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2. Responsibilities

2.1 The Divisional Director, Legal Services is responsible for the

following –

Ensuring the proper implementation of this policy and

the guidance and procedures that go with it.

Ensuring the Council complies with the requirements of

Part II of RIPA (directed surveillance)

Ensuring that due regard is given to any code of

practice issued pursuant to section 71 of RIPA.

Engaging with commissioners and inspectors when

they conduct inspections under RIPA.

Overseeing the implementation of any

recommendations made by a commissioner.

2.2 The Divisional Director Public Realm and Divisional Director

Community Safety are the Council’s authorising officers for

the purposes of considering applications for authorisation to

conduct directed surveillance, with the exception of cases

where confidential information is either targeted or likely to

be obtained. In these cases the Chief Executive should give

authorisation, and in their absence, the person who is their

deputy. If the Divisional Director Public Realm or Divisional

Director Community Safety are unavailable and the

Divisional Director Legal Services agrees that it is

appropriate in respect of a specified application, then the

Head of Audit and Risk or the Head of Community Safety

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may act as the Council’s authorising officer in respect of that

application.

2.3 The Council considers that applications for authorisation to

conduct directed surveillance should be of a high and

consistent standard. For this reason, all applications should

be cleared by a gate-keeper before consideration by the

authorising officer. The Council’s gate-keeper is the Head of

Community Safety. In the absence of that officer, the

Intelligence Team Leader, Risk Management & Audit may

act as Gatekeeper although they must not act as the

authorising officer for an application where they have been

the gatekeeper..

2.4 All officers have responsibility to ensure that directed

surveillance is only conducted where there is an

authorisation from the authorising officer and a Justice of

Peace has approved the authorisation.

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3. Directed Surveillance

3.1 Terms used in this policy have the meanings given by RIPA

or any relevant code of practice made under section 71 of

RIPA.

3.2 Directed surveillance is surveillance which is covert (i.e.

secret) but not intrusive, that is, it takes place other than in

residential premises or private vehicles, and is undertaken:

for the purposes of a specific investigation or a specific

operation

in such a manner as is likely to result in the obtaining of

private information about a person (whether or not one

specifically identified for the purposes of the

investigation or operation); and

it is conducted otherwise than by way of an immediate

response to events or circumstances, the nature of

which is such that it would not be reasonably

practicable for an authorisation under Part II of RIPA to

be sought for the carrying out of the surveillance

The surveillance must only be carried out for the

purpose of preventing or detecting a criminal offence

punishable by a maximum term of at least 6 months

imprisonment

3.3 Intrusive surveillance is covert surveillance that is carried

out in relation to anything taking place on residential

premises or in any private vehicle. It involves the presence

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of an individual inside the premises or in the vehicle, or is

carried out by means of a surveillance device. Surveillance

equipment mounted outside the premises will not be

intrusive, unless the device consistently provides information

of the same quality and detail as might be expected if they

were in the premises/vehicle, e.g. by means of a zooms lens.

The Council is not permitted to conduct intrusive surveillance

under RIPA and so will not use intrusive surveillance.

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4. Priorities

4.1. The Council will use directed surveillance where an

authorisation has been obtained under RIPA, and only in

accordance with the terms of the authorisation and where a

Justice of the Peace has approved the authorisation.

4.2. An authorisation may only be granted where

it is necessary for one of the following purposes: (1)

preventing or detecting crime; (2) preventing disorder;

It complies with any additional conditions imposed by

the Secretary of State under RIPA. From 1 November

2012 this means that the Councils use of RIPA is

restricted to the following offences:

An offence punishable by a maximum term of at least 6

months of imprisonment;

An offence under section 146 of the Licensing Act 2003

(sale of alcohol to children);

An offence under section 147 of the Licensing Act 2003

(allowing the sale of alcohol to children)

An offence under section 147A of the Licensing Act

2003 (persistently selling alcohol to children); or

An offence under section 7 of the Children and Young

Persons Act 1933 (sale of tobacco etc. to persons

under eighteen)

An offence under section 141A of the Criminal Justice Act 1988 (sale of knives and certain articles with blade or point to persons under sixteen)

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An offence under Regulation 31 of the Pyrotechnic Articles (Safety) Regulations 2015 (prohibition on making fireworks & other pyrotechnic articles available to persons younger than the minimum age limit)

The action proposed must be necessary and proportionate and

approved by a Justice of the peace

4.3. Having regard to the permitted purposes and to the

requirements in the Council’s Enforcement Policy that

enforcement action should be targeted (to the Council’s

stated objectives), the Council’s current priorities for the use

of RIPA are –

Anti-social behaviour

Underage sales of knives, tobacco, alcohol and

fireworks

Detecting and preventing Fraud, including misuse of

disabled parking badges

Unlawful street trading of tobacco

Breach of Premises License conditions including

touting

Bribery Act offences

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5. Authorisations

5.1 Prior to directed surveillance taking place RIPA provides that

the surveillance must be authorised by the councils

authorising officer as defined in section 2 of this policy and

approved by a justice of the peace

5.2 Surveillance can only take place where it is for the purpose

of preventing or detecting crime or of preventing disorder

where the crime threshold is met and relates to an offence of

the kind specified in paragraph 4.3 above. The authorisation

and approval must ensure that the surveillance is both

necessary and proportionate as well as limiting any potential

collateral intrusion. Further the authorisation will need to

consider whether confidential information is likely to be

obtained as a result of the covert surveillance. Confidential

information includes confidential personal information.

5.3 The Council is committed to only using directed surveillance

in accordance with RIPA and the Code of Practice. The

Council has adopted a guidance manual to assist officers to

make applications and grant authorisation in accordance with

RIPA and the Code. The Council will have regard to the most

recent relevant Code of practice. The current Code came

into force on 20 September 2018.

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Procedure for authorising

5.4 The Council is committed to achieving a consistent high

standard in applications for authorisation to conduct directed

surveillance. All applications must first be submitted to the

Council’s gatekeeper as specified in section 2 of this Policy.

Only when the gatekeeper has cleared the application may

the authorised officer consider it.

5.5 Matters for the Authorising Officer to consider:

The type of offence – Consider whether the application

passes the crime threshold

Necessity and proportionality -The 2000 Act first requires

that the person granting an authorisation must believe that

the authorisation is necessary in the circumstances of the

particular case under section 28(3) (b) of RIPA. Once

necessity is established then proportionality must be

considered. Officers seeking an authorisation under the RIPA

2000 Act should ensure that there is a justifiable interference

with an individual’s Article 8 rights, i.e. it is necessary and

proportionate for those activities to take place, and there is

no less intrusive means of achieving the same aim.

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The following elements of proportionality should be

considered:

• Balancing the size and scope of the proposed activity

against the gravity and extent of the perceived crime or

offence;

• Explaining how and why the methods to be adopted

will cause the least possible intrusion on the subject

and others;

• Considering whether the activity is an appropriate use

of the legislation and a reasonable way, having

considered all reasonable alternatives, of obtaining the

necessary result;

• Evidencing, as far as reasonably practicable, what

other methods have been considered and why they

were not implemented

5.6 The above involves balancing the intrusiveness of the activity

on the target subject and others who might be affected by it,

against the need for the activity in operational terms. The

activity will not be proportionate if it is excessive in the

circumstances. Each case will be judged on and be unique

on its merits. Consideration should be given to whether the

information which are sought, could reasonably be obtained

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by other less intrusive means. All such activity must be

carefully managed to meet the objective in question.

When setting out the proportionality of the surveillance, it is

important that the applications include clear statements of

the other reasonable possible methods of obtaining the

desired information and the reasons why they have been

rejected. This approach will also apply, equally to arguments

for the necessity of surveillance.

5.7 Before authorising surveillance the Authorising Officer should

take into account the risk of intrusion into the privacy of

persons other than those who are directly the subjects of the

investigation or operation (collateral intrusion). Measures

should be taken, wherever practicable to avoid or minimise

unnecessary intrusion into the lives of those not directly

connected with the investigation or operation. Those carrying

out the surveillance should inform the Authorising Officer if

the investigation or operation unexpectedly interferes with

the privacy of individuals who are not covered by the

authorisation. As part of the process an assessment should

be made of the risk of what is termed “collateral intrusion”. If

collateral intrusion is inevitable, publication of the

material/evidence obtained must be carefully controlled. If

the evidence is used in court proceedings, it may be possible

to deal with collateral intrusion by editing.

5.8 The authorising Officer should be aware of sensitivities in the

community to any directed surveillance.

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5.9 The authorising Officer should be aware of similar activities

being undertaken by other public authorities.

5.10 The Authorising Officer should have regard to the current

Code of Practice

5.11 All authorisations are required to have a Unique Reference

Number (“URN”) and the officer seeking the authorisation

must obtain the URN from Legal Services at the time of

preparing the application (i.e. prior to seeking authorisation)

and the authorising officer should not authorise that

authorisation unless a URN has been provided.

5.12 After the Council’s authorising officer has authorised the

directed surveillance, they must immediately notify the

Divisional Director Legal Services or nominee who will

update the central record and make the necessary court

application to obtain approval from a justice of the peace.

Magistrates Approval

5.13 Approval can only be given if the Magistrate is satisfied that:

a) There were reasonable grounds for the authorising

officer believing that the directed surveillance or

deployment of a CHIS was necessary and

proportionate and that there remains reasonable

grounds for believing so

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b) The authorising officer was of the correct seniority

within the organisation, that is, a Divisional Director,

Head of Service, Service Manager or equivalent

c) The granting of the authorisation was for the correct

purpose, that is, preventing and detecting crime and

disorder and satisfies the serious offence test (crime

threshold)

d) Any other conditions set out in any order under Part

2 of RIPA are satisfied

No investigation may commence unless and until a Justices

approval has been obtained.

5.14 Written authorisation may be given by the authorising Officer

for 3 months

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6 Duration/Review/Renewal

6.1 An authorisation for directed surveillance lasts for 3 months

before having to be renewed. When authorising directed

surveillance, the authorising officer is required to set a date

for review of that authorisation. This is known as the first

review. The Code of Practice requires regular reviews be

undertaken by the authorising officer to assess the

continuing need for the surveillance. The frequency of

reviews must be considered at the outset by the authorising

officer. Reviews should take place as frequently as is

considered necessary and practicable, on a case by case

basis. This frequency should increase where the surveillance

is providing access to confidential material or involves

collateral intrusion.

6.2 Authorisation forms do not expire, they must be reviewed,

renewed, where necessary (by application to the court) or

cancelled once they are no longer required, whether the

surveillance is conducted or not.

6.3 During a review, the authorising officer who granted or last

renewed the authorisation may amend specific aspects of

the authorisation, for example, to cease surveillance against

one or a number of named subjects or to discontinue the use

of a particular tactic.

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6.4 Authorisation for renewal is required to be approved by a

Justice of the Peace at the Magistrates Court. Where

applicable Authorisations should be renewed on application

to the Court before the maximum period in the authorisation

has expired. The Authorising Officer must consider the

matter afresh including taking into account the benefits of the

surveillance to date, and any collateral intrusion that has

occurred. This will need to be explained to the Justice of the

Peace. An authorisation cannot be renewed after it has

expired.

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7 Cancellations

7.1 If on a review, the authorising officer is satisfied that the

authorisation is no longer necessary on the ground under

which it was granted or renewed, or it is no longer

proportionate to what is sought to be achieved by carrying it

out, then the authorising officer must request that the

authorisation be cancelled and no further surveillance under

that authorisation is to be carried out.

7.2 The date the authorisation was cancelled should be centrally

recorded and documentation of any instruction to cease

surveillance should be retained. On cancelling a directed

surveillance authorisation, it is good practice to keep a

record detailing the product obtained from the surveillance

and whether or not objectives were achieved, although there

is no requirement to do so.

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8. Retention and destruction of product surveillance

8.1 Where the product of surveillance could be relevant to

pending or future criminal or civil proceedings, it should be

retained in accordance with established disclosure

requirements, or for a suitable period, and be subject to

review. There is nothing in RIPA which prevents material

obtained from properly authorised surveillance from being

used in other investigations. Authorising Officers must

therefore ensure that they follow the procedures for handling,

storage and destruction of material obtained through the use

of covert surveillance. Authorising Officers must also ensure

compliance with the appropriate data protection

requirements.

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9. Combined Authorisations

9.1 From time to time, it may well be that the directed

surveillance will be undertaken by a Covert Human

Intelligence Source (“CHIS”). If it does, then both actions

must be authorised. A single authorisation can combine the

two, however, and this should be done on the application

form used for the authorisation of the CHIS.

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10. Security of Covert Technical Equipment

10.1 The Council also requires each Service that uses covert

technical equipment when undertaking surveillance to ensure

that such equipment is securely locked away when not used.

Further, such equipment will only be issued to an officer who

has authorisation to use it. There will be a logging in and out

book and the officer will be required to sign for the

equipment. In signing for the equipment, the officer will be

reminded that misuse of the equipment is a disciplinary

offence.

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11. Communications Data

11.1 Communications data is information held by communication

service providers (for example, telecommunications, and

postal companies). The Act makes provision for obtaining

communications data from such service providers and the

disclosure to any person of such data. The RIPA

(Communications Data) Order 2003 came into force in

January 2004. It allows Local Authorities to acquire limited

information in respect of subscriber details and service data.

It does not allow Local Authorities to intercept, record or

otherwise monitor communications data, or access the

content of communications data.

11.2 Communications data is the “who”, “when” and “where”

communication but not the “what”. It is broadly split into 3

categories: “traffic data” i.e. where a communication was

made from, to whom and when; “service data“ i.e.. the use

made of the service by any person e.g. itemised telephone

call records (numbers called), itemised records of

connections to internet services; “subscriber data” i.e.. any

other information that is held or obtained by an operator on a

person that they provide a service to e.g. who is the

subscriber, to a particular telephone number, or who is the

account holder of an email account, information about the

subscriber to a PO Box number.

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11.3 Under RIPA Local Authority can only authorise the acquisition

of the less intrusive types of Communication data: service

use and subscriber information. Under no circumstances can

Local Authorities be authorised to obtain traffic data under

RIPA. Local authorities are not permitted to intercept the

content of any persons communications and it is an offence

to do so without lawful authority.

11.4 Communications data can only be obtained for the sole

purpose of the prevention or detection of crime and/or

disorder. Further, the test of necessity must be met before

data is obtained. The conduct involved in obtaining the

communications data must be proportionate to what is

sought to be achieved, and the risk of collateral intrusion

must be considered.

11.5 Material cannot be obtained until a Justice of the Peace has

granted approval. Authorisations and notices are valid for a

period of one month from the date of the judicial approval.

11.6 Communications data can be accessed using two different

methods:-

- The granting of Authorisations, or

- The service of notices

11.7 An Authorisation would allow the Council to collect or

retrieve the data itself from the service provider. A notice is

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given by the Council to a postal or telecommunications

operator and requires that operator to collect the data and

provide it to the council.

11.8 Integral to the acquisition of communication data under RIPA

is the single point of contact (SPoC). The role of the SPoC is

to enable and maintain effective cooperation between a

public authority and communication service providers in the

lawful acquisition and disclosure of communications data.

11.9 Any notice of authorisation must be passed to the service

provider through a SPoC. The Council currently uses

National Anti-Fraud Network (NAFN) as its single point of

contact. The NAFN provides a SPoC service to local

authorities, precluding each authority from the requirement to

maintain their own trained staff. Local Authorities using the

SPoC at NAFN will still be responsible for submitting any

applications to the JP and a designated person in the Local

Authority is still required to scrutinise and approve any

applications. The Local Authority’s designated person is the

Council’s authorising officer for covert surveillance. The

Local Authority investigator (i.e. the applicant) will then

submit the relevant judicial application and supporting

documents to the JP. The JP will then record its decision on

the judicial application form and the local authority

investigator will upload a copy of the order to the NAFN

SPoC. The NAFN SPoC will then require the communication

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data on behalf of the Local Authority in an efficient and

effective manner.

12. Central Recording

12.1 A central register of all Authorisations, Reviews, Renewals,

Cancellations and Rejections will be maintained and

monitored by the Divisional Director Legal with regards to

Directed Surveillance and CHIS.

12.2 The Council is required to keep records in relation to

authorisations centrally. Those records will be maintained by

Legal Services.

12.3 The relevant authorising officer must provide copies of all

authorisations and all reviews, renewals and cancellations to

the Divisional Director, Legal, or a person nominated by

either of them. The authorisation officer must provide those

documents forthwith i.e. within a week following signing by

the authorising officer.

12.4 The Council will retain records for a period of at least three

years from the ending of the authorisation. The Investigatory

Powers Commissioner’s Office (IPCO) may audit/review the

Council’s policies and procedures, and individual

authorisations, Reviews, Renewals, cancellations and

Rejections.

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12.5 The documents to be stored will include:-

A copy of the Forms together with any supplementary

documentation and notification of the approval given by the

Authorising Officer and the Magistrates Court

• The date and time when any instruction was given by the

Authorising Officer

A record of the period over which the surveillance has taken

place

The frequency of reviews prescribed by the Authorising

Officer

A record of the result of each review of the authorisation

A copy of any renewal of any authorisation, together with the

supporting documentation submitted when the renewal was

requested

The unique reference number (URN) for the authorisation

A record of the date of the cancellation of the authorisation

12.6 All officers are expected to use the most up to date versions

of forms recommended by the Home Office.

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13. Training

13.1 Authorising officers can only authorise, once they have

undertaken training on the operation of RIPA and the Code

of Practice. The Council’s gatekeepers may only clear

applications for consideration by the authorising officer after

undertaking the same training as the authorising officers.

13.2 All officers who may seek to use directed surveillance during

an investigation must also have undertaken training on the

operation of RIPA and the Code of Practice.

13.3 The Council will arrange appropriate training courses at

regular intervals. It is expected that members of the

Corporate Leadership Team will require authorising officers,

gatekeepers and those who may apply to conduct directed

surveillance to undertake the training.

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14. Member oversight

14.1 The Council’s Standards Committee will review this Policy

and have oversight of the Council’s conduct of directed

surveillance. If issues arise, the Standards Committee will

make recommendations to Cabinet for action.

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Page 233


March 2019

APPENDIX 2

LONDON BOROUGH OF TOWER

HAMLETS

POLICY ON THE USE OF COVERT

HUMAN INTELLIGENCE SOURCES

REGULATION OF INVESTIGATORY

POWERS ACT 2000

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CONTENTS

1. Introduction ............................................................................. 2

2. Definition of CHIS ................................................................... 6

3. Responsibilities ................................................................... 10

4. Authorisations ...................................................................... 13

5. Combined Authorisations ..................................................... 18

6. Reviews and Renewals ...................................................... 189

7. Cancellations ...................................................................... 21

8. Controller/Handler……………………………………………...22

9. Security of Covert Technical Equipment ............................. 25

10. Central Recording .............................................................. 26

11 Training .............................................................................. 27

11. Member Oversight .............................................................. 28

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1. Introduction

1.1 The Regulation of Investigatory Powers Act 2000 (“RIPA”)

came into force on 26 July 2000 and provides a statutory

framework for public authorities to use covert investigatory

techniques, such as surveillance and covert human

intelligence sources (CHIS), where necessary and

proportionate, for the purpose of preventing or detecting

crime and disorder. If such activities are conducted by

council officers, then RIPA regulates the use of these powers

in a manner that is compatible with the Human Rights Act

1998. RIPA sets out the circumstances in which the use of

directed surveillance and CHIS may be authorised. Local

authorities ability to use these investigation methods are

restricted in nature and may only be used for the prevention

and detection of crime or the prevention of disorder. In

addition to defining the circumstances when these

investigation methods may be used, RIPA also directs how

applications should be made, and by whom. It also makes

provision for the approval, review, renewal, cancellation and

retention of records.

1.2 Part II of RIPA provides for the authorisation of the use and

or conduct of covert human intelligence sources,

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1.3 The Council has broad statutory functions and takes targeted

enforcement action in relation to those functions having

regard to the following:

• The Tower Hamlets Plan, adopted under section 4 of the

Local Government Act 2000

• The Tower Hamlets Strategic Plan

• The Tower Hamlets Local Plan

• Any external targets or requirements imposed under relevant

legislation.

• The Councils Enforcement Policy

This policy must be read in conjunction with the current Home

Office Guidance and relevant Codes of Conduct.

1.4 The Council understands that it is obliged to comply with the

provisions of RIPA, in order to use covert human intelligence

sources. The council believes that by complying with

the provisions of RIPA, the Council should also ensure that

any use of CHIS comes within the qualification provided in

Article 8(2) of the European Convention on Human Rights

(ECHR) and, accordingly the Council should not breach its

obligations under section 6(1) of the Human Rights Act 1998.

1.5 Whilst RIPA itself does not provide any specific sanction

where an activity occurs, which should otherwise have been

authorised, any evidence thereby obtained may be

inadmissable in court, the activity may also be unlawful

under the Human Rights Act 1998, and may result in an

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investigation by the Ombudsman/or the Investigatory Powers

Tribunal.

1.6 The use of CHIS involves any action on behalf of a public

authority to induce, ask or assist a person to engage in the

conduct of CHIS, or to obtain information by means of the

conduct of a CHIS. In general, therefore, an authorisation for

use of CHIS will be necessary to authorise the steps taken

by the Council in relation to a CHIS, and the conduct of the

CHIS. It is necessary to ensure that the CHIS is clear on

what is and is not authorised at any given time and that all

the CHIS activities are properly risk assessed.

1.7 RIPA provides that responsibility for authorising directed

surveillance, and use of a CHIS lies with a Divisional

Director, Head of Service, Service Manager or equivalent. The

Protection of Freedoms Act 2012 amended RIPA so that local

authorities must obtain an order from a judicial authority approving

an authorisation before it can take effect. This requirement has

been in force since 1st November 2012. Parliament

introduced this requirement to put a statutory check on local

authorities and to ensure that powers are only used to stop

serious crime.

1.8 The Investigatory Powers Commissioner’s Office (IPCO)

has recommended as best practice that public authorities

develop a corporate policy. The Council concurs with the

OSC that a corporate policy is best practice, and has had

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such a policy in effect since 27 July 2004. This document is

the councils corporate policy in relation to covert human

intelligence sources, the council also has a policy in place in

respect of the use of directed surveillance, which is

contained in a separate document.

1.9 The council has prepared guidance notes and a procedure

manual on the use of CHIS, which should be read with this

policy.

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2. Definition of Covert Human Intelligence Sources (CHIS)

2.1 A person is a CHIS if he/she establishes or maintains a

personal or other relationship with a person for the covert

purpose of obtaining information or to provide access to any

information to another person, or to disclose information

obtained by the use of such a relationship, or as a consequence

of the existence of such a relationship.

2.2 Not all human sources of information will fall within this

definition, and so an authorisation under RIPA will not always

be appropriate. A person who reports suspicions of an

offence is not a CHIS. It is only if they establish or maintain a

personal relationship with another person, for the purpose of

covertly obtaining or disclosing information that they become

a CHIS. By way of example, people who complain about

anti-social behaviour, and are asked to keep a diary will not

normally be a CHIS as they are not required to establish or

maintain a relationship for a covert purpose. A test purchase,

where a straight transaction takes place where there is no

interaction between buyer and seller is not a CHIS.

2.3 A relationship is established or maintained for a covert

purpose, if and only if, it is conducted in a manner that is

calculated to ensure that one of the parties to the relationship

is unaware of the purpose.

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2.4 A relationship is used covertly and information obtained is

disclosed covertly, if and only if, the relationship is used or

the information is disclosed in a manner calculated to ensure

that one of the parties to the relationship is unaware of the

use and disclosure.

2.5 “Establishes” in a relationship means “set up”. Therefore it

does not require, as “maintain” does, endurance over a

particular period of time. Whether or not a relationship exists

depends on all the circumstances, including the length of

time of the contact between two people and the nature of the

covert activity.

2.6 In some cases, members of the public may volunteer or

provide information that is within their personal knowledge,

without being asked or tasked to do so by a local authority. In

such a case a relationship will not have been established or

maintained for a covert purpose, and as a consequence the

source will not be a CHIS for the purposes of RIPA, and no

authorisation under RIPA will be required.

2.7 In some circumstances the local authority may task a person

to obtain information covertly and this may result in

authorisation under Part II of RIPA. However this will not be

true in all circumstances, for example, where the tasks given

to a person do not require that person to establish or

maintain a relationship for the covert purpose of obtaining,

providing access to, or disclosing the information sought, or

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where the information is already within the personal

knowledge of the individual. In those circumstances the

person will not be a CHIS.

2.8 An individual who because of their work or role has access to

personal information may voluntarily provide information to

the council on a repeated basis and will need to be managed

appropriately. The Council must keep such human sources

under constant review to ensure that they are managed with

an appropriate level of sensitivity and confidentiality and to

establish whether at any given stage, they should be

authorised as a CHIS. Determining the status of an

individual is a matter of judgment by the Council.

2.9 The times when the Local Authority will use a CHIS are

limited.

2.10 If there is a need to use a CHIS who is a juvenile, it will be

necessary to obtain the written consent of the juvenile’s

parent or responsible adult, prior to authorisation. The

duration of such an authorisation is one month, as opposed

to 12 months, as it is for the other types of CHIS

authorisation. There are additional safeguards for juveniles

identified within the Regulation of Investigatory powers

(Juveniles) Order 2000 and the relevant Code of Practice.

2.11 There may be occasions when the Local Authority may wish

to use a CHIS as part of directed surveillance. It should be

noted that the crime threshold which applies to directed

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surveillance does not apply to the use of a CHIS. As

regards directed surveillance, the local authority can only

authorise the use of surveillance under RIPA to prevent or

detect criminal offences which are punishable by a maximum

term of at least 6 months imprisonment (whether on

summary conviction or on indictment) or are related to the

underage sale of alcohol or tobacco. The crime threshold

came into effect on 1st November 2012.

2.12 Unlike directed surveillance, which relates specifically to

private information, authorisation for the use or conduct of a

CHIS do not relate specifically to private information, but to

the covert manipulation of a relationship to gain information.

ECHR case law makes it clear that article 8 includes the right

to establish and develop relationships. Accordingly, any

manipulation of a relationship by the local authority is likely

to engage article 8, regardless of whether or not the local

authority intends to acquire private information. The local

authority will therefore consider an authorisation wherever

the use or conduct of a CHIS is likely to engage an individual

right under Article 8 of the ECHR, whether this is through

obtaining information, particular private information, or simply

through the covert manipulation of a relationship.

3. Responsibilities

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3.1 The Divisional Director, Legal Services is responsible for the

following –

The integrity of the process in place for the

management of CHIS

Ensuring the proper implementation of this policy and

the guidance and procedures that go with it.

Ensuring the Council complies with the requirements of

Part II of RIPA.

Ensuring that due regard is given to any code of

practice issued pursuant to section 71 of RIPA.

Engaging with commissioners and inspectors when

they conduct inspections under RIPA.

Overseeing the implementation of any

recommendations and post inspection action plans

made by a commissioner.

3.2 The Divisional Director Public Realm and Divisional Director

Community Safety are the Council’s authorising officers for the

purposes of considering applications for authorisation to use

covert human intelligence sources, with the exception of cases

where confidential information is either targeted or likely to be

obtained. If the Divisional Director, Public Realm or

Divisional Director Community Safety are unavailable and the

Divisional Director, Legal agrees that it is appropriate in respect

of a specified application for authorisation, then the Head of Fraud

and Risk may act as the Council’s authorising officer in respect

of that application.

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3.3 In cases where the covert human intelligence source is

targeted to obtain confidential information or confidential

information is likely to be obtained, then the Council’s

authorising officer is the Chief Executive, or, in the Chief

Executive’s absence, the person acting as Chief Executive.

3.4 The Council considers that applications for authorisation to

use covert human intelligence sources should be of a high

and consistent standard. For this reason, all applications

should be cleared by a gatekeeper before consideration by

the authorising officer. The Council’s gate-keeper is the

Head of Community Safety. In the absence of that officer,

the Intelligence Team Leader- Audit & Risk Management

may act as the Gatekeeper.

3.5 All officers have responsibility to ensure that covert human

intelligence sources are only used where there is an

authorisation from the authorising officer, and a Justice of the

Peace has approved the authorisation.

3.6 Section 29 of the 2000 Act deals with the responsibilities of

the controller and handler relating to the record keeper for

any covert human intelligence source. Officers nominated to

control, handle and record-keep in respect of a covert human

intelligence source must be trained to the satisfaction of both the

authorising officer and the Divisional Director, Legal before any

authorisation may be granted.

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3.7 The Council is committed to only using directed surveillance

in accordance with RIPA and the Code of Practice. The Council

has adopted a guidance manual to assist officers to make

applications and grant authorisations in accordance with RIPA and

the Code. The Council will have regard to the most recent relevant

Code of practice. The current Code came into force on 20

September 2018.

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4. Authorisations

4.1 Prior to a CHIS being used RIPA provides that the use must

be authorised by the Councils authorising Officer as defined

in section 3 of this policy.

4.2 The Authorising Officer must believe that an authorisation for

the use and conduct of a CHIS is necessary in the

circumstances of the particular case on the ground specified

in section 29(3) of RIPA, being, for the prevention and

detection of crime or the prevention of disorder.

4.3 If the use or conduct of the CHIS is deemed necessary on

the relevant ground, the Authorising Officer must also believe

that it is proportionate to what is sought to be achieved by

carrying it out. This involves balancing the seriousness of the

intrusion into the private or family life of the subject of the

operation (or any person who may be affected) against the

need for the activity in investigative and operational terms.

4.4 The Authorisation will not be proportionate if it is excessive in

the overall circumstances of the case. Each action

authorised should bring an expected benefit to the

investigation or operation and should not be disproportionate

or arbitrary. The fact that a suspected offence may be

serious will not alone render the use or conduct of a CHIS

proportionate. Similarly, an offence may be so minor that any

deployment of a CHIS would be disproportionate. No activity

should be considered proportionate if the information which

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is sought could reasonably be obtained by other less

intrusive means.

Proportionality

4.5 The following matters should be considered:

Balancing the size and scope of the proposed activity against

the gravity and extent of the perceived crime or offence

Explaining how and why the methods to be adopted will

cause the least possible intrusion on the subject and others

Considering whether the activity is an appropriate use of the

legislation and a reasonable way, having considered all

reasonable alternatives of obtaining the necessary result

Evidencing, as far as reasonably practicable, what other

methods had been considered and why they were not

implemented.

Collateral Intrusion

4.6 Before authorising the use or conduct of a source, the

authorising officer should take into account the risk of

interference with the private and family life of persons who

are not intended subjects of the CHIS activity (collateral

intrusion). Measures should be taken, wherever practicable,

to avoid or minimise interference with the private and family

life of those who are not the intended subjects of the CHIS

activity. Where such collateral intrusion is unavoidable, the

activities may still be authorised providing this collateral

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intrusion is considered proportionate to the aims of the

intended intrusion. Any collateral intrusion should be kept to

the minimum necessary to achieve the objective of the

operation. All applications should therefore include an

assessment of the risk of any collateral intrusion, and details

of any measures taken to limit this, to enable the Authorising

Officer to fully consider the proportionality of the proposed

use or conduct of a CHIS

4.7 Where the use of the CHIS is likely to result in the obtaining

of confidential information, the activity must be authorised by

the Chief Executive or on their absence the Monitoring

Officer. Confidential information includes, but is not limited to

matters subject to legal privilege, confidential personal

information and confidential journalistic material.

4.8 The Authorising Officer should be clear as to the reason why

the CHIS is necessary and the nature of the conduct that the

CHIS will be involved in.

Security and Welfare

4.9 Where the council deploys a CHIS, it should take into

account the safety and welfare of that CHIS when carrying

out actions in relation to the authorisation or tasking. Before

authorising the use of or conduct of a CHIS, the authorising

officer should ensure that a risk assessment is carried out to

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determine the risk to the CHIS of any tasking and the likely

consequences should the role of the CHIS become known.

4.10 The ongoing security and welfare of the CHIS after the

cancellation of the authorisation, should also be considered

at the outset. Consideration should also be given to the

management of any requirement to disclose information

tending to reveal the existence or identity of a CHIS to, or in,

court

Extent of authorisations

4.11 Any authorisation under Part II of RIPA for the use or

conduct of a CHIS will provide lawful authorisation for any

such activity that:

Involves the use or conduct of a CHIS as is specified or

described in the authorisation

Is carried out by or in relation to the person to whose actions

as a CHIS, the authorisation relates; and

Is carried out for the purposes of, or in connection with, the

investigation or operation described

It is important that the CHIS is fully aware of the extent and limits

of any conduct authorised and that those involved in the use of a

CHIS are fully aware of the extent and limits of the authorisation in

question.

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Duration of authorisation

4.12 A written authorisation will, unless reviewed, cease to have

effect at the end of 12 months, beginning with the day it took

effect, except in the case of juvenile CHIS when it lasts for

one month.

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5. Combined authorisations

5.1 A single authorisation may combine two or more different

authorisations. For example an authorisation for directed

surveillance and the conduct of a CHIS. This does not

preclude the local authority from obtaining separate

authorisations.

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6. Reviews and Renewals

Reviews

6.1 Regular reviews of authorisations should be undertaken by

the Authorising Officer to assess whether it remains

necessary and proportionate to use a CHIS and whether the

Authorisation remains justified. The review should include

the use made of the CHIS during the period authorised, the

tasks given to the CHIS and the information obtained from

the CHIS. The results of the review should be retained for at

least three years. Reviews of authorisations should take

place as frequently as considered necessary and practicable.

Where the use of a CHIS provides access to confidential

information or involves significant collateral intrusion

authorisations should be reviewed more frequently.

6.2 An authorisation for use of a CHIS lasts for a maximum of 12

months before having to be renewed.

Renewals

6.3 Before an Authorising Officer renews an authorisation, he

must be satisfied that a review has been carried out of the

use of a CHIS, as outlined above and that the results of the

review have been considered.

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6.4 If before an authorisation would cease to have effect, the

authorising officer considers it necessary for the

authorisation to continue for the purpose for which it was

given, he may renew it in writing for a further period of

twelve months.

6.5 A renewal takes effect at the time at which the authorisation

would have ceased to have effect but for the renewal. An

application for renewal should therefore not be made until

shortly before the authorisation period is drawing to an end.

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7. Cancellations

7.1 The authorising officer who granted or renewed the

authorisation must cancel it is it is satisfied that the use or

conduct of the CHIS no longer satisfies the criteria for

authorisation or the grounds on which it was granted.

7.2 Where necessary, the safety and welfare of the CHIS should

continue to be taken into account after the authorisation has

been cancelled.

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8. Controller/Handler

8.1 The Council is required to ensure that arrangements are in

place for the proper oversight and management of a CHIS,

including appointing individual officers as defined in section

29(5)(a) of RIPA. Where the use of a CHIS is authorised

then section 29(5)(a) of RIPA requires the Council to have at

all times a person holding a position with the Council who will

have day-to-day responsibility for dealing with the source

(“the handler”). This will not be the officer seeking

authorisation but will be the responsibility of the person who

supervises the investigation.

8.2 The person identified as the handler will have day to day

responsibility for:

• Dealing with the CHIS on behalf of the authority concerned

• Directing the day to day activity of the CHIS

• Recording the information supplied by the CHIS

• Monitoring the CHIS’s security and welfare

The CHIS handler is responsible for bringing to the attention of the

CHIS controller any concerns about the personal circumstances of

the CHIS in so far as they might affect the validity of the risk

assessment, the conduct of the CHIS, and the safety and welfare

of the CHIS. In appropriate circumstances the authorising officer

should consider whether or not to allow the authorisation to

continue.

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8.3 Further, section 29(5)(b) of RIPA requires the Council to

have at all times another person holding a position with the

Council who will have general oversight of the use made of

the source (“the controller”). The controller is the officer

responsible for the general oversight of the use of the

source. The controller will be the Service Manager for the

Service in which the officer seeking the authorisation is

based so that the Service Manager will be the controller and

will be the person managing the handler.

8.4 Although an authorising officer can also act as the controller

of a source, the Council will not permit an authorising officer

to be responsible for authorising their own activities, e.g.

those in which they, themselves, are to act as the source or

in tasking the source. Therefore if the authorising officer

would be the Service Manager for the handler then a Service

Manager of the same level from another Service will be the

controller.

8.5 Additionally, section 29(5)(c) of RIPA requires the

Council to have at all times a person holding a position with

the Council who will have responsibility for maintaining a

record of the use made of the CHIS. This will be the Service

Head (i.e. the Service Manager’s manager) responsible for

the service area using the covert human intelligence source.

If the service area falls within the authorising officer’s

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responsibility, then the Corporate Director of Place must

maintain the record.

8.6 Guidance suggests that a local authority may prefer to seek

the assistance of the police to manage its CHIS. In such a

case a written protocol between the parties should be

produced in order to ensure that an identified CHIS is

properly managed. Without such an agreement the local

authority must be capable of fulfilling its statutory

responsibilities. Where the CHIS is not a Council Officer

then the intention is to seek assistance of the police. Where

the CHIS is a Council Officer then prior to the authorisation

being sought, the investigating officer must give

consideration to seeking the assistance of the Police and if it

is decided not to, then justification for that decision must be

included within the risk assessment for the use of the CHIS.

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9. Security of Covert Technical Equipment

9.1. The Council requires each Service that uses covert technical

equipment when undertaking surveillance to ensure that

such equipment is securely locked away when not used.

Further, such equipment will only be issued to an officer who

has authorisation to use it. There will be a logging in and out

book and the officer will be required to sign for the

equipment. In signing for the equipment, the officer will be

reminded that misuse of the equipment is a disciplinary

offence.

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10. Central Recording

10.1. The Council is required to keep records in relation to

authorisations centrally. Those records will be maintained by

Legal Services. These records should be updated whenever

an authorisation is granted, renewed or cancelled and should

be available to the relevant Commissioner or an Inspector

upon request. Records should be retained for at least 3

years from the end of the authorisation to which they relate.

10.2. The relevant authorising officer must provide copies of all

authorisations and all reviews, renewals and cancellations to

the Divisional Director, Legal, or a person nominated by

either of them. The authorisation officer must provide those

documents forthwith following signing by the authorising

officer.

10.3. All officers are expected to use the most up to date versions

of forms recommended by the Home Office.

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11. Training

11.1 Authorising officers can only authorise once they have

undertaken training on the operation of RIPA and the Code

of Practice. The Council’s gatekeepers may only clear

applications for consideration by the authorising officer after

undertaking the same training as the authorising officers.

11.2 Officers may only undertake the roles of controller, handler,

or record-keeper if they have undertaken training in the

discharge of those roles. If there are no officers who have

been trained to the satisfaction of the authorising officer and

the Divisional Director - Legal, then the Council will not

use covert human intelligence sources.

11.3 All officers who may seek to use covert human intelligence

sources during an investigation must also have undertaken

training on the operation of RIPA and the Code of Practice.

11.4 The Council will arrange appropriate training courses at

regular intervals. It is expected that members of the

Corporate Leadership Team will require authorising officers,

gatekeepers and those who may apply to conduct directed

surveillance to undertake the training.

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12. Member Oversight

12.1 The Council’s Standards Committee review this Policy and

will have oversight of the Council’s use of covert human

intelligence sources. If issues arise, the Standards Committee

will make recommendations to Cabinet for action.

Page 263


APPENDIX TWO: EQUALITY ANALYSIS QUALITY ASSURANCE CHECKLIST

Name of ‘proposal’ and how has it been implemented (proposal can be a policy, service, function, strategy, project, procedure, restructure/savings proposal)

Corporate Enforcement Policy 2019

Directorate / Service

Place / Public Realm

Lead Officer

David Tolley, Head of Environmental Health and Trading Standards

Signed Off By (inc date)

2/1/19

Summary – to be completed at the end of completing the QA (using Appendix A) (Please provide a summary of the findings of the Quality Assurance checklist. What has happened as a result of the QA? For example, based on the QA a Full EA will be undertaken or, based on the QA a Full EA will not be undertaken as due regard to the nine protected groups is embedded in the proposal and the proposal has low relevance to equalities)

Proceed with implementation As a result of performing the QA checklist, the policy, project or function does not appear to have any adverse effects on people who share Protected Characteristics and no further actions are recommended at this stage.

Stage

Checklist Area / Question

Yes / No /

Unsure

Comment (If the answer is no/unsure, please ask the question to the SPP Service Manager or nominated equality lead to clarify)

1 Overview of Proposal

a Are the outcomes of the proposals clear? Yes This report is to ask the decision making body to agree:

1. Consider the report and agree proposed Enforcement

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Policy at Appendix One. 2. Agree the revised Enforcement Policy along with the Policies on the use of covert surveillance and the use of covert human intelligence sources under the Regulation of Investigatory powers Act 2000.

b

Is it clear who will be or is likely to be affected by what is being proposed (inc service users and staff)? Is there information about the equality profile of those affected?

Yes The Enforcement Policy is concerned with the Councils exercise of its criminal and quasi-criminal enforcement function. The Policy will assist council officers to carry out their duties consistent with the principles of enforcement set out in the regulatory code. The Councils Enforcement Policy highlights that the council’s enforcement activities support the Strategic Plan priority of A Borough that our residents are proud of and love to live in : People feel safe in their neighbourhoods and anti-social behaviour is tackled

2 Monitoring / Collecting Evidence / Data and Consultation

a

Is there reliable qualitative and quantitative data to support claims made about impacts?

Yes The wider community will be affected by the policy in that they may be the direct victims of the people or businesses against whom enforcement action is taken, or they may indirectly benefit from our enforcement action as a result of the protection that the apprehension of criminals affords because it prevents further harm being done to other people.

Is there sufficient evidence of local/regional/national research that can inform the analysis?

Yes The Enforcement policy helps to deliver the Strategic Plan, which is locally accountable and responsive regulation for all – achieving a safe. Healthy, clean, green and fair trading landscape for residents, business and visitors.

b

Has a reasonable attempt been made to ensure relevant knowledge and expertise (people, teams and partners) have been involved in the analysis?

Yes It is a legal requirement to publish an Enforcement Policy, Government Guidance and Codes of Practice have been followed in producing this Policy. Teams across the Council have been consulted.

c Is there clear evidence of consultation with stakeholders and users from groups affected by the proposal?

Yes Consultation undertaken internally, however this is an overarching policy and individual service protocols/processes will dictate enforcement decisions.

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3 Assessing Impact and Analysis

a

Are there clear links between the sources of evidence (information, data etc) and the interpretation of impact amongst the nine protected characteristics?

Yes .The policy is specifically designed to provide information for people or businesses whom enforcement action is taken against. It will affect them to the extent that decisions to take enforcement action will be influenced by the content of the policy however the policy is a tool to protect them from illegal discrimination and is therefore for their benefit.

b

Is there a clear understanding of the way in which proposals applied in the same way can have unequal impact on different groups?

N/A Such enforcement action will be monitored and reported back through various mechanisms i.e. Committee reports/ Government returns etc. The policy does not discriminate, however the targeting of proactive enforcement may affect only a particular community within the Borough for justifiable reasons, particularly in business sectors where there is over representation of groups from particular backgrounds.

4 Mitigation and Improvement Action Plan

a

Is there an agreed action plan?

No The Enforcement policy is designed to ensure that enforcement decisions are fair, proportionate and consistent. The decision to take enforcement action against an individual will by its nature have an adverse impact on that individual, however the impact that that decision has on the individual is not itself an Equalities issue.

b Have alternative options been explored

Yes This is statutory requirement to publish an Enforcement Policy

5 Quality Assurance and Monitoring

a Are there arrangements in place to review or audit the implementation of the proposal?

Yes Yes, via internal processes

b

Is it clear how the progress will be monitored to track impact across the protected characteristics??

Yes The effective and efficient application of enforcement powers is reliant upon the integrity of the officers involved. There will always be a potential for inappropriate enforcement arising from bias, however this should be mitigated during the checks and balances of more senior officers and solicitors who vet files and oversee enforcement decisions.

6 Reporting Outcomes and Action Plan a Does the executive summary contain sufficient Yes

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information on the key findings arising from the assessment?

Equality Assessment Criteria

Decision Action Risk

As a result of performing the QA checklist, it is evident that due regard is not evidenced in the proposal and / or a risk of discrimination exists (direct, indirect, unintentional or otherwise) to one or more of the nine groups of people who share Protected Characteristics. It is recommended that the proposal be suspended until further work or analysis is performed – via a the Full Equality Analysis template

Suspend – Further Work Required

Red

As a result of performing the QA checklist, the policy, project or function does not appear to have any adverse effects on people who share Protected Characteristics and no further actions are recommended at this stage.

Proceed with implementation

Green:

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Cabinet Decision

24 April 2019

Report of: Ann Sutcliffe, Corporate Director of Place


Draft Growth and Economic Development Plan 2018-2023

Lead Member Councillor Motin Uz-Zaman Cabinet Member for Work and Economic Growth

Originating Officer(s) Vicky Clark, Divisional Director, Growth and Economic Development Ekim Bireroglu, Senior Strategy, Policy and Performance Officer, Governance Keiko Okawa, Senior Strategy and Policy Manager, Governance


Key Decision? Yes


7 March 2019

Reason for Key Decision Significant effects on communities living or working in an area comprising two or more wards


People are aspirational, independent and have equal access to opportunities / People access a range of education, training, and employment opportunities.

Executive Summary

This report presents the Council’s Growth and Economic Development Plan 2018-2023. The plan sets out the Council’s priorities and actions which aim to build an economy that works for local people and ensures everyone can benefit from the borough’s success. The Council’s vision is to create a Tower Hamlets that delivers sustainable and inclusive economic growth enabling all of our residents and businesses to prosper. This is aligned with priorities set out by the Council’s Strategic Plan 2019-2022, (People access a range of education, training and employment opportunities) and the Tower Hamlets Partnership’s Tower Hamlets Plan (tackling inequalities by building a stronger, more inclusive and fairer borough). The consultation on the draft Tower Hamlets Growth and Economic Development Plan ran from November 2018 to February 2019. We invited responses from a range of interested parties to help inform further discussions on the plan and its objectives. The overarching conclusion of the consultation showed support for the vision and priorities in the plan.

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Agenda Item 6.5


1. Approve the Growth and Economic Development Plan. 1. REASONS FOR THE DECISIONS 1.1 The objective of the Growth and Economic Development Plan is to deliver the

Council’s priorities of building an economy that works for local people. Our proposed approach is to enable residents and businesses to prosper by connecting them to growth and economic development opportunities.

1.2 The development of this plan is identified as an action in the Strategic Plan 2019-2022. It considers the needs and requirements for the Council’s further support to residents and businesses. Residents, business bodies, businesses and other stakeholders have been engaged in consultations.

1.3 Partners have also closely been engaged through the Growth and Economic Development Partnership Board. The outcomes and impact of the plan will be reported as part of the Council’s Performance Management and Accountability Framework.

2. ALTERNATIVE OPTIONS

2.1 ’Do nothing’ option. The lack of a plan will limit the Council’s ability to

enhance and embed effective work to deliver growth and economic development.

2.2 We could choose to develop a partnership strategy. However, this will require a longer timeframe for the development of a plan and delay the implementation of the Council’s actions. Furthermore, while the Growth and Economic Development Partnership has been consulted on this plan, a co-developed growth strategy may not give sufficient, tangible priorities/actions that all partners including the Council will take away to deliver. As the Council is required to respond to the issues and equip young people with employment tools as soon as possible, identifying a Council Growth and Economic Development Plan is needed ahead of a partnership strategy.

3. DETAILS OF THE REPORT Growth and Economic Development Plan - Summary Introduction and background 3.1 The Tower Hamlets Growth and Economic Development Plan 2018-2023

aims to build an economy that works for local people and ensures that everyone can benefit from the borough’s success. The Council’s vision is to

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create a Tower Hamlets that delivers sustainable and inclusive economic growth enabling all of our residents and businesses to prosper.

3.2 This aim and vision are aligned with priorities set out by the Council’s

Strategic Plan 2019-2022(e.g. Priority 1: People are aspirational, independent and have equal access to opportunities) and the Tower Hamlets Partnership’s Tower Hamlets Plan (tackling inequalities by building a stronger, more inclusive and fairer borough).

Why do we need a Growth and Economic Development Plan?

3.3 Currently, Tower Hamlets is a borough of sharp contrasts. While 4.3% of

people working in Canary Wharf earn over £100k p.a., it is estimated that around four in ten households in the borough are living below the poverty line.

3.4 Residents identify a lack of jobs as one of their top three areas of concern.

This is in the context of low skills, poor qualifications, and inequality. Inequality can act as a significant barrier in the search for employment and progression with much lower rates for certain groups, including those from ethnic minority communities, including newly arrived migrants and refugees, people with disabilities or health issues, and women.

3.5 The on-going challenges of austerity and welfare reforms coupled with the

uncertainty around the possible economic impact of UK’s withdrawal from the European Union have required us to find innovative solutions and seize opportunities to ensure our residents get the best deal possible.

3.6 With regards to Brexit, irrespective of the terms of the UK’s departure from the

EU, it should be assumed that Brexit is most likely to have an impact on local government, the local economy, the borough’s workforce and the way organisations operate. The expectation is that this will present new challenges for the council, the borough’s population and its businesses but also create new opportunities to do things differently.

3.7 The magnitude of these effects remains unknown as they depend on the eventual form of Brexit, and knowledge of the post Brexit UK economic environment across a range of dimensions such as trade, migration, and regulation.

3.8 To best prepare the borough for the UK’s departure from the EU, the Mayor of

Tower Hamlets launched the Tower Hamlets Brexit Commission tasked with examining the likely impact of Brexit on Tower Hamlets across a range of areas including public, economic and social implications. The council will carefully monitor the Tower Hamlets Brexit Commission Report and the outcome of Brexit negotiations and adjust our Growth and Economic Development approach accordingly.

3.9 Given the above, the incentive to further invest and strengthen our local economy has never been stronger. We believe that ‘inclusive growth’ is the way forward to address the challenges and opportunities ahead, and is an

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absolute necessity to achieve greater prosperity, independence and access to opportunities for all our residents.

3.10 To achieve ‘inclusive growth’ we will complement and strengthen local, regional and national initiatives that are already in place to create better prosperity and growth for our local people and businesses. By drawing on these strategies and initiatives we want to create a plan that is applicable to the Tower Hamlets growth context.

3.11 We have identified three main priorities that we believe will deliver results.

● Priority 1: Preparing our young people for success; - We will make the transition from education to employment work better for

our young people. To achieve this we propose a targeted approach to equip young people in the borough with the tools they need to understand and navigate the options that are available to them.

● Priority 2: Helping our working age residents thrive;

- We will ensure all working age residents in the borough get the best possible outcomes in terms of their jobs and careers – by looking where we can complement and strengthen existing ongoing projects such as WorkPath.

● Priority 3: Creating the conditions for business growth - We will support our existing businesses in the borough to thrive and to

stay in Tower Hamlets as they grow. We will also identify ways in which we can attract a diverse business base – so that there are more job opportunities for people with different kinds of interest and aptitudes. The case for expanding our business base is further enhanced by business rates reform which will see the borough retain a greater proportion of business rates income. Tower Hamlets’ position as one of the UK’s leading business destinations is both an opportunity and challenge in this regard, as the desirability of locating in the borough drives up commercial property values.

3.14 In all cases we will try to invest rather than just spend. We will commission

activities that will either; - Generate a direct financial return to invest in further activity - Lever in substantial sums of external investment - Increase the proportion of national funding streams accessed by Tower

Hamlets residents and businesses or - Create a ‘virtuous circle’ of positive actions and outcomes that will

become embedded over time. 3.15 The plan answers the following questions:

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- Why do we need to further enhance growth and economic development?

- What is growth and economic development? - What are our long-term aims? - Why have we chosen these priorities? - What is our immediate work? - How will we know if our work is successful?

3.16 This plan is being developed in parallel with the Tower Hamlets Regeneration

Strategy, which will take an overview of the borough’s development as a place to live and work. Complementing the Regeneration Strategy’s focus on place, this plan looks at thematic interventions to help people and businesses across the borough succeed.

National, regional and local policy context 3.17 To develop this Growth and Economic Development Plan, national, regional

and local responses to the current challenging economic and financial situation, including the impact of the austerity, were reviewed.

3.18 The government published the Industrial Strategy in 2017. It aims to boost

productivity by backing businesses to create good jobs and increase the earning power of people throughout the UK with investment in skills, industries and infrastructure.

3.19 The Mayor of London has initiated a series of policies to address economic

and social exclusion. The latest policy is the Mayor’s Economic Development Strategy (2017) which sets out aspirations to deliver the following amongst other things: - Better educational opportunities for all, a lower cost of living, fairer pay and

employment practices, better health and less poverty - Creating the conditions for growth – through enhanced workspace, better

transport and infrastructure, more innovation and better skills, and by encouraging enterprise and entrepreneurship.

3.20 The priorities of the Growth and Economic Development Plan are set out

within this context. 3.21 We also draw on other strategies to strengthen our plan; referenced as and

when applicable throughout this document.

4. Consultation 4.1 The consultation on the draft Tower Hamlets Growth and Economic

Development Plan (2018-2023) ran from November 2018 to February 2019.

4.2 We invited responses from a range of interested parties to help inform further discussions on the draft plan and its objectives.

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4.3 Three groups of respondents were identified as key audiences in the consultation process:

The education sector

Representative business bodies

Individual businesses from a range of sectors across the borough 4.4 In summary, consultees were asked for their feedback on the vison and

priorities outlined in the draft plan. They were also asked for their views on how to achieve the vision of sustainable and inclusive economic growth.

4.5 The overarching conclusion of the consultation with the education sector was that there are opportunities to collaborate and support each other, across organisations, in improving careers support provision and that these opportunities should be explored in partnership with the business community.

4.6 The consultation with representative business bodies, including the East London Business Alliance (ELBA) and Canary Wharf Group, showed strong support for the vision and priorities in the draft plan. Some constructive suggestions were given.

4.7 For example, in relation to priority 1, Craft Central, a charity focused on supporting innovation and employment in creative industries, suggested that the focus on preparing young people for success should also include self-employment opportunities as well as education, training and careers.

4.8 ELBA stressed the need to think about how we can help schools deliver and monitor themselves against the benchmarks in the context of the recent developments with the Gatsby Benchmarks. Canary Wharf Group agreed that the careers service within schools does not always reflect current growth areas and new sectors.

4.9 On priority 2 ELBA mentioned that they would like there to be more of an emphasis on the support for the working poor, not just those who are unemployed. Canary Wharf Group suggested a more collaborative approach with partners in the borough who also provide employment and training support to residents to help reduce duplication of assistance and provide a more streamlined action plan from the view of the local resident.

4.10 As for priority 3, the biggest single barriers to business growth mentioned were:

General economic uncertainty

Very risk-averse banking

Costs / availability of premises

Business rates

Lack of SME awareness of what support is actually available

Lack of digital skills

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4.11 Canary Wharf Group stressed that there is still an £85bn productivity gap in the UK SME and charity sectors which digital can help close. The biggest opportunity exists for sole traders, as 41% fall within the low digital capability bracket.

4.12 The consultation with businesses from a range of sectors across the borough resulted in submissions that were also in agreement with the suggested approach in the draft plan.

4.13 Respondents strongly agreed the draft Growth and Economic Development Plan will create the conditions in which businesses can grow sustainably and residents can prosper.

4.14 Respondents identified the following as the single biggest barrier to residents seeking employment in Tower Hamlets - Lack of suitable qualifications - Poor command of spoken and written English - Extended periods out of the labour market

4.15 Respondents identified the biggest barriers to growing businesses in Tower

Hamlets as: - Lack of suitably qualified staff - Rising rents and lack of flexible and affordable workspace

4.16 The majority of respondents strongly agreed that the increased cost of renting

and the lack of workspace that can adapt with the growth of a business is forcing small companies to move out of Tower Hamlets.

4.17 All respondents strongly agreed the Council has a role to play in identifying and securing flexible workspace using either its own assets or through discussions with developers.

4.18 Based on the consultation responses received, it was decided that the vision and approach set out in the draft plan were in line with the informed views of relevant stakeholders and therefore, it should proceed without any fundamental changes.

5. EQUALITIES IMPLICATIONS 5.1 An equality impact assessment is attached. Our research indicates that this

plan will have a positive impact on residents as a whole. Particular focus is given to young people and adults including women and people with disabilities.

6. OTHER STATUTORY IMPLICATIONS 6.1 This section of the report is used to highlight further specific statutory

implications that are either not covered in the main body of the report or are

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required to be highlighted to ensure decision makers give them proper consideration. Examples of other implications may be:


Consultations,


Risk Management,

Crime Reduction,

Safeguarding. 6.2 There are no other statutory implications. 7. COMMENTS OF THE CHIEF FINANCE OFFICER

7.1 Following the conclusion of the consultation on the Council’s Growth and

Economic Development Plan (2018-2023), this report seeks the approval of the Mayor in Cabinet for the formal adoption of the plan.

7.2 In conjunction with other Council strategies, the Growth and Economic

Development Plan will assist in the prioritisation of activities within programmes which are designed to encourage local enterprise, support local businesses and improve employment opportunities for residents. The plan will give rise to various initiatives which will be considered by the Mayor in Cabinet as they are developed. The cost implications will be incorporated within the Council’s Medium Term Financial Strategy as they become known; with the likelihood that external funding will be available to support various programmes. In addition to the support provided to residents and businesses, successful implementation of the plan should lead to an expanding business base which will provide the opportunity for the Council to generate additional resources from business rate retention at a time when it is becoming ever more dependent on locally raised sources of income.

7.3 The costs associated with the development of the plan, including the

consultation process, were mainly staffing related and have been financed from within existing budgetary provision.

8. COMMENTS OF LEGAL SERVICES 8.1 The Council does not have a legal duty to adopt a policy of this nature.

However, the Council does have a legal duty to consider how something it procures and/or the method of its procurement will benefit the economic environmental and social well-being of the borough.

8.2 Therefore, adopting a plan of this nature will significantly assist the Council to

meet this legal duty. 8.3 Each part of the plan will be subjected to the Council’s equalities assessment

processes as the Council must ensure that it’s policies comply with the equality act 2010.

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____________________________________


Strategic Plan 2019/2022

The Tower Hamlets Plan 2018-23

Appendices

Appendix A: Draft Growth and Economic Development Plan

Appendix B: Draft Growth and Economic Development Plan Equality Impact Assessment

Background Documents – Local Authorities (Executive Arrangements)(Access to Information)(England) Regulations 2012

None Officer contact details for documents: Ekim Bireroglu, Senior Strategy, Policy and Performance Officer, Governance (ext. 1693)

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Tower Hamlets Growth and Economic Development Plan 2018-2023

Page 279

Contents

Foreword

Introduction

What makes growth and economic development?

Local picture

What we intend to do

Priority 1: Preparing our young people for success

Priority 2: Helping our working age residents thrive

Priority 3: Creating the conditions for business growth

Implementation and monitoring arrangements

03

04

08

09

15

16

20

25

28

02

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Foreword

Welcome to the Tower Hamlets Growth and Economic Development Plan 2018-2023. It sets out the approach that the council and its partners will take to shape the growth of our economy over the next five years. We want to build a borough that has, at its heart, a commitment to fairness that allows all our residents to benefit from its success.

Tower Hamlets is a great place to live and work with a rich history that we are rightly proud of. It is a history that has seen generations of hardworking people embody the entrepreneurial spirit of the East End; creating opportunities for success and working tirelessly for themselves, their families and their communities.

People from across the world have been attracted by the character of this borough. They have made it their home and added new chapters to its story. The diversity they have introduced to our communities is one of our greatest strengths.

But Tower Hamlets is a place of contrasts where the towers of Canary Wharf and

the offices of the City Fringe sit next to communities that have not always felt able to benefit from the success that they see on their doorstep.

There are families that fear their children may not be able to secure the jobs they dream of and there are young people who, despite having the determination to succeed, lack the confidence and knowledge to access the opportunities they can see all around them.

We have bold ambitions to create the pathways that will allow our residents to succeed in whatever sector they choose. We want entrepreneurs who aspire to create new businesses to be able to do so right here in Tower Hamlets and young people to know they can reach their potential in any career. Fundamentally, we want to build a fairer economy for our residents.

This is not a vision that we can realise alone. It will require genuine partnership working to achieve our goals.We already work closely with our partners

in the public sector, civil society and the worlds of business and education. This Growth and Economic Development Plan provides us with an incentive to strengthen those ties and to push forward with a new determination and focus.

Our partners have already played a key role in helping to shape the strategic approach set out in this plan.

We look forward to working with you to deliver this as we guide Tower Hamlets through its future growth and work to make its next chapter genuinely fairer for all.

John BiggsExecutive Mayor of Tower Hamlets Cllr Motin Uz-ZamanCabinet Member for Work and Economic Growth

03

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Introduction

The Tower Hamlets Growth and Economic Development Plan 2018-2023 aims to build an economy that works for local people and ensures everyone can benefit from the borough’s success. The council’s vision is to create a Tower Hamlets that delivers sustainable and inclusive economic growth enabling all of our residents and businesses to prosper.

This aim and vision are aligned with priorities set out by the council’s Strategic Plan 2019-2022 (e.g. Priority 1: People are aspirational, independent and have equal access to opportunities) and the Tower Hamlets Partnership’s Tower Hamlets Plan (tackling inequalities by building a stronger, more inclusive and fairer borough).

Why do we need a Growth and Economic Development Plan?

lTower Hamlets was historically one of London’s poorest areas and a place where many new immigrants settled on arriving in London. More recently it has become a borough of sharp contrasts. While some people remain very poor, there are also pockets of high earners. This situation is particularly acute now with only 3% of household income being over £100k p.a while it is estimated that around four in ten households in the borough are living below the poverty line, after housing costs are considered.

lThe significant growth and economic changes that have taken place in the Tower Hamlets have unfortunately resulted in the borough evolving from a deprived area, to a deprived

area with an expanding oasis of wealth. Many residents have not been able to access the economic success our borough offers, leaving them living in poverty alongside enormous wealth.

lThere is a mismatch between residents’ skills and the jobs available in the borough and (for some also) beyond Tower Hamlets. Data indicates that borough residents with

04

of household income is over

£100k

3%Only

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lower skill levels are significantly less likely to be in employment than the London average. And those who are in employment are most likely to be the working poor.

l It is therefore not surprising that residents identify a lack of jobs as one of their top three areas of concern.

l The on-going challenges of austerity and welfare reforms coupled with the uncertainty around the possible economic impact of the UK’s withdrawal from the European Union have required us to find solutions which increase the life chances of our residents.

lAs for the latter, irrespective of the terms of the UK’s departure from the EU, it should be assumed that Brexit is most likely to have an impact on local government, the local economy, workforce and the way organisations

operate. The expectation is that this will present new challenges for the council, the borough’s population and its businesses but also create new opportunities to do things differently.

lThe magnitude of these effects remains unknown as they depend on the eventual form of Brexit, and knowledge of the post Brexit UK economic environment across a range of dimensions such as trade, migration, and regulation.

l To best prepare the borough for the UK’s departure from the EU, the Mayor of Tower Hamlets launched the Tower Hamlets Brexit Commission tasked with examining the likely impact of Brexit across a range of areas including public, economic, and social implications. The council will carefully monitor the Tower Hamlets Brexit Commission’s progress and

the outcome of Brexit negotiations and adjust our Growth and Economic Development Plan accordingly.

lWhen considering all of the above, the incentive to further invest and strengthen our local economy has never been stronger. We believe that ‘inclusive growth’ is the way forward to address the challenges and opportunities ahead. It is an absolute necessity to achieve greater prosperity, independence and access to opportunities for all our residents.

lTo achieve this we will complement and strengthen local, regional and national initiatives that are already in place to create better prosperity and growth for our local people and businesses. By drawing on these strategies and initiatives we want to create a plan that is applicable to the Tower Hamlets growth context.

05

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We have identified three main priorities that we believe will deliver results.


lWe will make the transition from education to employment work better for our young people. To achieve this we propose a targeted approach to equip young people in the borough with the tools they need to understand and navigate the options that are available to them.

●Priority 2: Helping our working age residents thrive

lWe will ensure all working age residents in the borough get the best possible outcomes in terms of their jobs and careers – by looking where we can complement and strengthen existing ongoing projects such as WorkPath.


lWe will support our existing businesses in the borough to thrive and to stay in Tower Hamlets as they grow. We will also identify ways in which we can attract a diverse business base – so that there are more job opportunities for people with different kinds of interest and aptitudes. The case for expanding our business base is further enhanced by business rates reform which will see the borough retain a greater proportion of rates income. Tower Hamlets’ position as one of the UK’s leading business destinations is both an opportunity and challenge in this regard, as the desirability of locating in the borough drives up commercial property values.

In all cases we will try to invest rather than just spend. We will commission activities that will either;

– Generate a direct financial return to invest in further activity– Lever in substantial sums of external investment – Increase the proportion of national funding streams accessed by Tower Hamlets residents and businesses or,– Create a ‘virtuous circle’ of positive actions and outcomes that will become embedded over time.

The plan answers the following questions:– Why do we need to further enhance growth and economic development?– What is growth and economic development?– What are our long-term aims?– Why have we chosen these priorities?– What is our immediate work?– How will we know if our work is successful?

06

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This plan has been developed in parallel with the Tower Hamlets Regeneration Strategy, which will take an overview of the borough’s development as a place to live and work. Complementing the Regeneration Strategy’s focus on place, this plan looks at thematic interventions to help people and businesses across the borough succeed.

National, regional and local policy context

To develop this Growth and Economic Development Plan, national, regional and local responses to the current challenging economic and financial situation, including the impact of austerity, were reviewed.

The government published the Industrial Strategy in 2017. It aims to boost productivity by backing businesses to create good jobs and increase the

earning power of people throughout the UK with investment in skills, industries and infrastructure.

The Mayor of London has initiated a series of policies to address economic and social exclusion. The latest policy is the Mayor’s Economic Development Strategy (2017) which sets out aspirations to deliver the following amongst other things: lBetter educational opportunities for all, a lower cost of living, fairer pay and employment practices, better health and less poverty.lCreating the conditions for growth – through enhanced workspace, better transport and infrastructure, more innovation and better skills, and by encouraging enterprise and entrepreneurship.

The priorities of the Growth and Economic Development Plan are set out within this context.

We also draw on other strategies to strengthen our plan; referenced as and when applicable throughout this document.

Consultation

lThis plan sets the direction for Tower Hamlets growth and economic development over the next five years. It is a bespoke plan, not addressing all areas but highlighting those where Tower Hamlets has a particular need to improve and has a particular chance to transform and lead.

l It goes without saying the council cannot deliver inclusive growth alone. We will therefore involve, engage and seek views from our communities, to ensure that residents can take advantage of opportunities and investments whilst working with our partners to make this a reality.

07

2023

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What makes growth and economic development?

What is growth and economic development?

In this plan, we aim to deliver ‘inclusive growth’, which connects our residents to the opportunities that exist in the labour market through better understanding and access to education, training and employment and proactively influence and shape the nature of employment opportunities. This includes boosting employers’ demand for skills as well as shaping the occupational and sectoral make-up of the economy.

Growth and economic development encapsulates a wide range of measures – involving a ‘cross cutting’ and integrated activity where the physical development of a place is linked to public service, place management and wider drivers of change such as employment, skills, investment, enterprise, innovation, productivity, quality of life and positioning.

The Growth and Economic Development Plan is a roadmap for attracting new investment and ensuring long-term sustainable and inclusive growth. The focus of our plan is to help connect our residents and local businesses to growth and economic development by:

lRemoving barriers that are locking our young and working age residents out of the jobs market

lCreating the conditions for business growth by ensuring the right kinds of support and space are available

We acknowledge spatial development and regeneration also have implications for employment and skills. These dimensions will be considered with the council’s work on regeneration in parallel with this plan.

By focusing on finding solutions to the above in consultation with partners, businesses and wider community, we will create better conditions for inclusive growth, economic development and employment generation.

08

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Local picture

Economy, employment and inequalities

lThe rise of Canary Wharf as a global financial district has had many positive effects on local employment through the spread of associated service industries such as law, accountancy and consultancy services, as well as retail and leisure.

lThis has resulted in Tower Hamlets being one of the highest economic and employment growth areas in the country with an estimated 278,000 jobs in the borough and one of the highest numbers of new business start-ups. There are more jobs than we have residents – approximately 1.36 jobs for every working age resident.

lHowever, Tower Hamlets is also a place of contrast and contradictions. There is no correlation between the

economic growth of the borough and better living standards for some people. A significant portion of our residents are living next to a thriving economy unable to reap its benefits.

lOur borough remains deprived despite dramatic population and economic growth, and improvements in local educational outcomes. Persistent inequality requires further

intervention in order for residents to access the benefits from economic development. The skills of many residents are ill suited to the new jobs that are being created.

What type of businesses are based in the borough

lWhile the economic profile of Tower Hamlets is dominated by some of the world’s largest financial and professional service organisations based in Canary Wharf, the borough has a wide range of local businesses including small family companies, creatives, start-ups, light manufacturers and small-to-medium- sized enterprises (SMEs).

09

278,000

1.36

jobs in the borough

jobs per resident

There are an estimated

that’s

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lThe vast majority of businesses based in Tower Hamlets are small businesses. 98% of enterprises employ fewer than 50 people and nine in ten are ‘micro’ businesses which employ fewer than 10 people. 7% of enterprises are sole traders. On the other hand, only 0.5 % of the borough’s enterprises are large businesses which employ 250 employees or more.

lBusinesses in the financial and insurance industry only account for 3% of enterprises in the borough. The largest industries are ‘professional, scientific and technical’ which account for a quarter of our businesses and ‘information and communication’ which make up 18% of businesses. This industrial structure is largely similar to that in London as a whole.

lThe vast majority of local enterprises (97%) are in the private sector, 3% are in the non-profit sector, and less than 1% are public sector enterprises.

10

0.5%7%

employ 250 employees or

more

are sole traders

98%of businesses employ fewer

than 50 people

90%of businesses employ fewer

than 10 people

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11

Employment and skills

l Fewer than 15% of all the jobs in Tower Hamlets are taken by those living within the borough. Most are taken by those commuting in, with the skills and qualifications to work in the growth employment areas.

lThose who have the skills to participate in the growth economy are among the highest earners in the country. According to the updated Local Economic Assessment, Tower Hamlets has, after the City of London, the second highest earnings levels in London.

lThis is while 14% of borough residents – almost twice the London average – have no qualifications – and 25.9% are not in employment. It is also worth noting that there are 20.9% workless households in the borough. In contrast, over a third of residents are qualified to degree level or above, which is consistent with the London average. With fewer residents at intermediate skill levels than is typical for London, there is thus a polarisation of skill levels within the borough. 15%

Fewer than

of jobs taken by residents

14%

25.9%

20.9%

of residents have no qualifications

are not in employment

workless households in the borough

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Diversity

lTower Hamlets is also the 4th most linguistically diverse area in England and Wales. The 2011 Census identified at least 90 different languages being used in the borough. Over one third of adults (35%) in Tower Hamlets use a main language other than English.

lWhile this is a great richness for our borough as a majority of this group are fluent in English, around one quarter (18,311 residents) said they could not speak English ‘well’ or ‘at all’ . This is equivalent to 9% of the borough’s adult population - the second highest proportion in England, after Newham. This undoubtedly results in many of our residents being locked out of the job market.

Skills, education and employment

l Furthermore, borough residents atlower skill levels are significantly less likely to be in employment than the London average. A similar polarisation exists in the borough’s jobs market. There are high numbers of entry-level jobs and a relatively high number of extremely well paid jobs, but opportunities for progression between these are limited.

lThere has been an overall upward trend in terms of educational attainment outcomes at the secondary level since 2011. In the final year of the previous framework, Tower Hamlets exceeded the national average in terms of educational attainment at the secondary level, with over two-thirds of pupils achieving five or more GCSEs at grade C or above.

lProvisional results indicate that this year’s performance has fallen below the national average for the first time. Despite the general attainment trend being positive, the council is mindful of this anomaly. It should however be noted that it is too soon to assess the long term implication and impact of these changes.

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lThe employment rate of residents is below the national average. We also know that in-work poverty is increasing in the borough. Furthermore, although many of our young people do well at school, improvements in education do not always translate into better sustained opportunities in the jobs market for them, and too few go on to the best universities and break into top jobs.

lTower Hamlets has the highest worklessness rate in London, at 7.7%, and the highest rate of poverty as well – 39%. This is partly a result of the changes taking place in the structure of employment. For men, the manufacturing jobs that once sustained median incomes, skills sets and career progression have disappeared. For women, the white collar administrative work that performed the same function has also been reduced. In both cases, technology is a key catalyst of change.

l In addition to low skills and poor qualifications, inequality also plays a significant factor in the search for employment, with much lower employment rates for certain groups, including those from ethnic minority communities, newly arrived migrants and refugees, people with disabilities or health issues, and women.

Poverty at households

lThe Indices of Deprivation 2015 showed that nearly 40% of children in Tower Hamlets live in income deprived households. Our borough also topped the same table for older people, with nearly half (49.7%) in that category.

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7.7%

40%

39%

49.7%Highest

worklessness rate in

London

Highest poverty rate in

London

of children live in income deprived households

of older people live in income deprived households

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lThe data also indicates that around half (48.7%) of Tower Hamlets households had an income below the median Tower Hamlets income of £30,805 (i.e. they are in the under £30K group).

lThis translates to an estimated four in ten households in Tower Hamlets living below the poverty line, after housing costs are taken into account. This is the highest poverty rate across all local authorities in England and Wales, and almost double the national average.

Impact of poverty

lGrowing up in poverty can have troubling implications in adulthood. According to the Social Mobility Advisory Group report of 2017, “socio-economic disadvantage continues to be the most significant driver of inequality in terms of access to and outcomes from higher education”.

lThe report noted that “eighteen year-olds from the most advantaged groups remain 2.4 times more likely to enter university than their disadvantaged peers, and 6.3 times more likely to attend one of the most selective institutions in the UK. Having graduated from university, students from disadvantaged backgrounds are less likely to go into professional jobs, and if they do they are likely to be paid less”.

l It is against this backdrop that many young and working age residents find it very difficult to access good quality jobs in the borough. Our pioneering WorkPath service already helps many residents improve their skills and find work. The Growth and Economic Development Plan looks at other interventions to reinforce this approach.

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households living below the

poverty line

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What we intend to do

Our approach

The relevant council services will work together to deliver the priorities. Residents, third sector organisations and others will be invited to participate in consultation on the draft plan. In addition, the Growth and Economic Development Partnership will be consulted separately.

The Growth and Economic Development Partnership works to deliver the following priority outcomes:

lCreating opportunity by supporting aspiration and tackling poverty: - More residents in good quality, well-paid jobs - Young people realising their potential - Securing real jobs for local residents from new development

lHarnessing economic growth - Actively attracting and securing inward investment, particularly in skilled industries - Maximising social value and coordinating business engagement - Promoting the historic entrepreneurial energy of our communities

Current initiatives by the council

●The council’s Growth and Economic Development programme covers three main priorities:

lThe WorkPath service helps people to get work ready and to find jobs. This includes support with CV writing, ESOL and job searching as well as apprenticeships and other vocational training in high demand areas.

lThe Enterprise team delivers the Ready Programme – a suite of projects designed to help businesses start, grow and reach new markets.

lThe High Streets and Town Centres team delivers a series of projects designed to improve the look, feel and trading conditions of our town centres and markets, making them successful places to do business and attractive places to spend time.

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The challenge that we face:

Despite Tower Hamlets historically exceeding the national average in terms of educational attainment at the secondary level, this is not translating into excellent progress or sustained employment outcomes for our young people.

Context

lTower Hamlets offers high quality secondary schools which are judged by Ofsted as being among the best in the country. Provision in the borough for 14 to 19 year olds includes a general further education institution, arts and music college, a technical college and a college offering alternative education and pre-employment training.

lYoung people in the borough have traditionally achieved very good results at Key Stage 4. However, there

have been challenges associated with the new grading system introduced in 2016 – in Key Stage 5, A Level attainment has been less strong in general, and results show performance in some specific subjects in particular could be improved. In spite of this, it should be noted that results remain good for many schools.

lThere is a wide range of education, employment and training options at both post 16 and post 18 in Tower Hamlets. However in recent years the choice of subjects at post-16 levels has become increasingly narrow. To this end there is a need to explore how sixth forms in the borough can deliver a more collaborative offer which identifies and addresses any gaps in the overall range of courses and brings students together more effectively to enhance their study experience. This would also contribute to clearer and better understood pathways into employment.

lThe Draft Learning and Achievement Strategy for 14 to 25 year olds is seeking to address these issues. A comprehensive review is being under taken to establish a full picture of post 16 provision from all schools and colleges in the borough. The council will assess the findings from this review to clarify gaps in borough wide academic and vocational provision with the aim of identifying ways sixth forms can work together to optimise use of their resources to improve their offer to students.

lTower Hamlets is the home of Queen Mary, one of the best and most inclusive universities in the country. It is also the source of significant clusters of knowledge intensive industries – financial and business services, digital and tech, and medtech.

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l In spite of these highlights, evidence suggests that our young residents are not always able to navigate their way through the system to take advantage of these opportunities.

lThe barriers young people face are multifaceted and complex but all the evidence suggests that young people, especially from poor, working class, migrant and ethnic minority backgrounds, can lack the information, awareness and confidence necessary to make informed choices about their future.

lTo this end, a more targeted approachto enable young people to access information about their career options early on is needed.

What we are proposing to do:

lWe will make sure all our young people, not just the brightest, understand the range of opportunities open to them early on. The aim is to equip young people with the tools they need to make the right decisions in their pursuit of further education, training and/or employment.

lTo this end, we will be exploring good practice options and liaising with schools to pilot a programme of careers education early in secondary school, before critical options and choices are made. The scheme will involve three different strands of intervention to support the transition from school to work.

1. The first strand - an early secondary year 7-9 careers education programme, is intended to expand young people’s horizons and help them understand more about the many exciting career options in Tower Hamlets and the wider London economy. Its purpose is to enthuse, motivate and inform our students before they choose their GCSE options.

2. The second strand will involve working with our schools to boost the career guidance sessions offered in the GCSE year to ensure that all our young people are able to get comprehensive and informed advice on their post-16 options. This will also involve supporting parents to raise their awareness of options.

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3. For the third strand the intention is to develop a ‘finishing school’ to support all of our young residents during their transition from education to the world of work, whether that is after GCSEs, A Levels or following graduation. There are several examples of excellent practice in this area already but they are intense and expensive; the challenge will therefore be to develop a quality programme which we can afford to replicate for everyone.

What are we already doing?

l Improving employment opportunities for young people has been a local priority for a number of years. Our key strategies, such as the Employment Strategy, the Children and Families Plan, and the Procurement Strategy all involve some form of work experience, apprenticeships, entry level posts and graduate jobs as well as career progression opportunities for targeted groups.

lThere are also a number of organisations in Tower Hamlets that support young people in their options post 16. Statutory or publically funded organisations such as schools and the careers service provide support to young people throughout secondary school.

lWe also currently have a number of initiatives such as: – Mayor’s Apprenticeship Commitment – Pathways to Success – Tower Hamlets Education Business Partnership where volunteers work with young people helping them to prepare for life after sixth form – Employment and training Initiatives – the council works in partnership with employers and organisations in Tower Hamlets to increase job and training opportunities through Young WorkPath, Idea Stores, Arts and Professional Development

– Career Services – Positive Actions for Young People (PAYP) – Young People Preparing for Adulthood (YPPA) Task Group

Challenges to this approach include:

lThe complex nature of educational provision in the borough and the financial incentive structure for educational providers to retain studentslThe crowded curriculum which makes it difficult to find space for non-GCSE subjectslThe innovative nature of some activities which may require piloting and which will need us to identify partner schools

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What will we do in the next 12 months?

lDevelop a programme of activity

lSecure approval and funding

lStart pilot activity in at least one secondary school

What will have changed in the five years?

lThe first pilot cohort will have completed their GCSEs and there will be a measurable improvement in outcomes

lYoung people will have access to improved guidance and support, at different stages in their journey, as well as greater opportunities to develop the life skills needed to successfully transition from education to employment

How will we know if it’s working?

lTeachers report improved engagement in classroom study

lYear 11 students feel more confident in their post-16 choices

l Fewer young people in the pilot project drop out or change course in Year 12

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Priority 2: Helping our working age residents thrive

The challenge that we face:

There is a mismatch between residents’ skills and the jobs available in the borough and (for some also) beyond Tower Hamlets. Data indicates that borough residents with lower skill levels are significantly less likely to be in employment than the London average. Those who are in employment are most likely to be the working poor.

Context

lSupporting our young people is essential but it is a long term investment. Meanwhile many of our working age residents are struggling to make their way in the economy for a variety of reasons including:

– low skills, – poor qualifications, – language barriers for especially new migrants and refugees. – poor communication skills in

general also act as a significant barrier – health issues including disability and mental health – in most cases all of the above also unsurprisingly can lead to limited understanding of the labour market

lThese factors act together (or single handedly) to create a cycle of disadvantage. Socio-economic disadvantage and inequality can be the biggest barriers to securing sustainable and well-paid employment. For instance issues such as lack of adequate housing or homelessness and the availability, cost and quality of childcare are significant barriers to many finding and sustaining work. Inequality also plays a significant factor in the quest for employment with much lower rates for certain groups, including those from ethnic minority

communities, people with disabilities or health issues, and women.

lEmployment is the most important route out of social and economic exclusion. But the consequences of being unemployed go wider than lack of money. It can contribute to ill-health and can deny future employment opportunities.

l Furthermore, the length of time out of the labour market can create significant psychological barriers that hinder attempts to move into employment. Being out of work for a long period of time can reduce self-confidence and lowers aspirations, all of which can affect motivation and capacity to make what is a significant change.

lThis is also too often the case for our residents from migrant backgrounds who face many barriers which at different levels affect the

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effectiveness of their strategies to find employment or start a new business.

lPoor command of English is often cited as the most prominent barrier to employment alongside insufficient knowledge about the range of opportunities available to retrain when qualifications are not recognised in the UK and lack of understanding of the equivalence between overseas and British qualifications.

lMigrant residents make up 98% of all

those with low proficiency in English. 17% of Tower Hamlets residents who were born outside the UK cannot speak English well or at all. For many this barrier means the inability to work in their trained professions.

l It can also be difficult for overseas-qualified migrants to gain equivalent professional recognition allowing them to practice in the UK.

l It is very much within this context residents have identified lack of jobs as one of their top three areas of concern. Our priority is to equip our residents through training support and brokerage to access jobs.

lExclusion from the job market is not just a loss for the economy but can also lead to social exclusion which brings with it a wide range of problems to the individual as well as the wider community.

lWe aim to complement and strengthen the work already taken place to get our residents into work by working closely with businesses to identify support and skills needed to unlock barriers and create new opportunities.


lOur pioneering WorkPath service already supports many of our

residents with a suite of programmes designed to help them into work.

lThese range from brokerage services for those who just need a little help to link them to the right job through to our pioneering Working Start programme, which offer six months’ paid experience, coupled with a tailored training programme, to get people with limited skills and experience or very low confidence back into work. These programmes are expensive but the returns are enormous: to the individual, to the employer and to the state in terms of benefit savings.

l ESOL classes are delivered at our Idea Stores and learning centres to improve and empower residents to find work.

What will we do in the next 12 months?

lThrough our Growth and Economic

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Development Partnership Board and other networks we will work with employers and training partners to identify areas of skills shortage in the borough and create a pipeline of willing and able employees. Brexit, a cause for concern in many regards, may create opportunities here as European service sector employees leave London.

lWe will commission projects which support people once they have found work to help them progress into better paid employment and develop their career.

lWe will work with smaller employers across the borough to help them understand the benefits of upskilling their workforce, particularly through apprenticeships.

lWe also need to make the most of the development in the borough –

continuing to challenge developers and contractors to open up opportunities to local people and, through their development, create the preconditions for more employment.

lWe will continue to explore the best way to overcome barriers to employment. For example through ESOL provision by building on and implementing best practice for supporting people into work.

lWe will encourage businesses to pay the minimum wage and support initiatives to enable residents achieve a level of skills that increases their earning potential.

Projects already underway

WorkPathOur pioneering WorkPath employment service provides support for all Tower

Hamlets residents at all levels of work, skills and experience. These services include:

lProviding medium to long term support and guidance to clients that are furthest away from the labour market by assigning them to specialists to prepare for employment.

lSupporting Stronger Families – co-located team working with and funded by Growth and Economic Development. Designed to identify and address multiple barriers families/individuals furthest away from employment through a more holistic approach that takes into account their complex needs. These barriers include mental health, relationships, parenting difficulties, emotional and self-esteem challenges that hinder some families’ ability to gain employment, volunteering and/or training opportunities.

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lBrokerage – clients that are job ready are assigned to the brokerage team to prepare and forward them for employment opportunities.

Our Working Start programmes support women and older residents back into employment through specialist training and paid work experience.

lOur childcare training programme creates apprenticeships at Level 2, providing additional workforce capacity which frees up more experienced workers to study for their Level 3 qualifications.

lThe Mayor’s Apprenticeship Commitment works with small firms to highlight the benefits of apprenticeships and help them deal with the associated paperwork.

lOur employer engagement team delivers targeted recruitment and training programmes tailored to

live vacancies and large scale recruitment.

lProvide bespoke sector specific ESOL/English/Maths courses. This initiative supports clients who struggle with basic skills as a barrier to securing and progressing in work, as well as Vocational courses.

lOutreach programmes deliver support to clients in various locations (i.e. children centres, Job Centre Plus etc.) to ensure the service is accessible by all.

The Tower Project Jobs Enterprise and Training (JET) service l Is a supported employment

service for young people and adults with learning disabilities and autism. Haggerston Perk is London’s first Supported Internship Café and was developed by JET Services to support young people with learning disabilities to progress into paid work

in East London’s thriving hospitality sector. Haggerston Perk Café was developed by the Tower Project in partnership with the LBTH Enterprise Team, Peabody Housing Association, The Space Group and Climpson and Sons.

Public health and the Health and Wellbeing Board do work on employment and health related initiatives.

lThe Tower Hamlets Health and Wellbeing Board vision is to create stronger links between organisations that support and impact people’s health and wellbeing and work together with residents to improve the health and wellbeing of everyone living and working in the borough.

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lMore than 5,000 people will have been supported into work through WorkPath.

lMore than 1,000 apprenticeships will have been created in Tower Hamlets businesses.


lResidents access a range of education, training and employment opportunities.

lResidents are resilient/have better control over their lives.

lResidents have improved access to quality employment opportunities.

lResidents are job ready.

lResidents have appropriate competencies and skills.

l Local employers offer job opportunities.

lEmployers are able to support employees effectively.

l Fewer families at risk of financial exclusion.

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5,000people supported into work through

WorkPath

1,000apprenticeships

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What is our challenge?

lTower Hamlets has a strong economy but it is very much polarised between very large firms and small businesses. Providing the support and opportunity for small firms to grow can create more skilled and semi-skilled roles that allow hard working people with a variety of talents to earn a living wage.

lHistorically, jobs that used to fill this function were in the secretarial and manufacturing roles which have disappeared from London since World War Two. However interesting trends in re-shoring short run manufacture together with high levels of entrepreneurship in newer sectors could create a chance to grow this mid-level again. We will investigate how we can accommodate this type of business growth by encouraging the provision of appropriate business space.

lAnother challenge for businesses is the upward pressure on renting rates created by the combination of changing demographics and London’s thriving economy. This is making some retail and small business processes increasingly unaffordable and requires further exploration about what action can be taken to support businesses.

Context

lThe dominance of financial services in Canary Wharf powers the borough economy but emerging sectors such as tourism, leisure, creative services and knowledge based industries offer significant potential for further growth.

lThe diversification of the Tower Hamlets economy is something that we believe will create jobs for a wider portion of our residents with different

skill-sets and we would like to invest in the growth of these sectors.

l In Tower Hamlets and across the UK, support is generally focused toward start up enterprises, while larger firms particularly in the financial and business services and tech sectors have the resources to buy in specialist expertise. Mid-size companies are often overlooked and unable to get the support that they need.

lMid-size businesses have a great potential to bring in great revenues and profit and employment opportunities. In Germany SMEs – particularly mid-size businesses that have been enabled to grow – employ the majority of the country’s workforce, enjoying robust growth and loyal staff.

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What we are going to do

lTo maximise benefits for local people, the council, with partners, need to provide first class support that will enable Tower Hamlets small and medium size businesses to start, grow and prosper.

lThis will be achieved by building on and enhancing our existing support programmes that are already enabling individuals and businesses to address barriers to growth, raise productivity and compete on an international scale.

lWe will also review our planning, development and investment policies to maximise the provision of ‘grow-on’ spaces to retain and attract growing businesses for Tower Hamlets. Being proactive in this area will also serve to enhance our priority of increasing

our business rates income. We will investigate the particular challenges that businesses face as they grow and develop and adopt our enterprise support programme accordingly. We will actively develop our networks of businesses to improve our intelligence on how we can support them further and to help them to connect with each other. We will also explore the prioritisation of particular business sectors.


l Implementing a programme of business support for Tower Hamlets businesses and entrepreneurs.

lDeveloping a Workspace Strategy to sit alongside the Local Plan and inform the provision of workspace in new developments.

l Implementing the High Street and Town Centres Strategy. This strategy sets out a vision and detailed programme of support for the borough’s town centres and high streets. The overall vision is that by 2020 Tower Hamlets will have competitive and dynamic high streets and town centres that are places at the heart of the community, which celebrates our East End heritage, support local economic growth and enhance the health and well-being of people who live in, work near and visit our borough.

l Improving our ability to secure local employment through s106 agreements with developers building in our borough.

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Tower Hamlets will have more small and medium sized firms with between 20 and 100 employees.


lOur new enterprise programme will be up and running and supporting firms with growth potential.

lTower Hamlets’ policies and strategies will reflect the need for grow-on space.

lAt least one major development including grow-on space will be seeking planning approval.

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Implementation and monitoring arrangements

The progress of identified actions and indicators will be monitored through the council corporate performance monitoring process.

The Growth & Economic Development Partnership Board is a sub-board of the Tower Hamlets Partnership. The board works in partnership to understand, facilitate and promote a dynamic local economy in Tower Hamlets with high levels of growth benefitting local people and businesses.

The board will monitor the progress of identified actions.

Furthermore, this plan needs to be understood in the context of the Tower Hamlets Local Plan. What has been proposed has been referenced in parallel with the Local Plan and we will be working with our partners to develop and deliver the issues raised in this plan.

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1

Equality Analysis (EA) Section 1 – General Information (Aims and Objectives) Name of the proposal including aims, objectives and purpose (Please note – for the purpose of this doc, ‘proposal’ refers to a policy, function, strategy or project)

Tower Hamlets Growth and Economic Development Plan 2018-2013

The Tower Hamlets Growth and Economic Development Plan 2018-2023 aims to build an economy that works for local people and ensure that everyone can benefit from the borough’s success. The Council’s vision is to create a Tower Hamlets that delivers sustainable and inclusive economic growth enabling all of our residents and businesses to prosper. This aim and vision are aligned with priorities set out by the Council’s Strategic Plan 2018-2021(e.g. Priority 1: People are aspirational, independent and have equal access to opportunities) and the Tower Hamlets Partnership’s Tower Hamlets Plan (tackling inequalities by building a stronger, more inclusive and fairer borough). To achieve this vision, the draft Growth and Economic Development Plan proposed measures structured around three key priorities: Priority 1: Preparing our young people for success. This priority aims to make the transition from education to employment work better for our young people. Priority 2: Helping our working age residents thrive. This is about supporting working-age residents to secure the best possible outcomes in terms of their jobs and careers. We propose to achieve this by identifying opportunities to compliment and strengthen existing employment, skills and training projects such as WorkPath. Priority 3: Creating the conditions for business growth. This priority aims to support businesses based in the borough to thrive and to stay in Tower Hamlets as they grow. It is also about identifying ways in which we can attract a diverse business base, creating the sort of varied employment market that will provide job opportunities for people with a broad range of interests, skills and aptitudes.

Financial Year

2019/20

See Appendix A

Current decision rating

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2

Conclusion - To be completed at the end of the Equality Analysis process (the exec summary will provide an update on the findings of the EA and what outcome there has been as a result. For example, based on the findings of the EA, the proposal was rejected as the impact on a particular group was unreasonable and did not give due regard. Or, based on the EA, the proposal was amended and alternative steps taken) Name: (signed off by) Date signed off: (approved)

Service area: Growth and Economic Development Team name: Growth and Economic Development Division Service manager: Vicky Clark, Divisional Director Growth & Economic Development Name and role of the officer completing the EA: Ekim Bireroglu, Senior Strategy, Policy and Performance Officer, Governance

Section 2 – Evidence (Consideration of Data and Information) What initial evidence do we have which may help us think about the impacts or likely impacts on service users or staff? Equality and diversity has been a key principle throughout the development of the Growth and Economic Development Plan. This includes ensuring substantial benefit for the diverse groups which make up Tower Hamlets’ population. The aim is to especially offer tailor support for people that are furthest from the labour market which serves to address inequality, as protected groups are most likely to experience labour market inequality. In developing this Growth and Economic Development Plan, national, regional and local responses to the current challenging economic and financial situation, including the impact of austerity, were reviewed. The following data sources have been considered:

Tower Hamlets Household Income 2018 – Borough Statistics

Tower Hamlets Poverty- Borough Profile

Tower Hamlets Borough Profile Employment 2018

Tower Hamlets Annual Residents Survey 2018

Tower Hamlets Borough Profile Economy 2018

GLA - Skill Strategy for Londoners Evidence Base- 2018

Tower Hamlets Local Economic Assessment Data refresh for 2015-2016

Language in Tower Hamlets Analysis of 2011 Census data

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3

Trust for London Poverty and inequality data for Tower Hamlets

Tower Hamlets Labour Market Research Paper NOMSI

Deprivation in Tower Hamlets Analysis of the 2015 Indices of Deprivation Data

Working in Partnership: Enabling Social Mobility in Higher Education- the Final Report of the Social Mobility Advisory Group 2016

A Guide to UK League Tables in Higher Education – Higher Education Policy Institute 2018

Social Mobility Commission – Ethnicity, Gender and Social Mobility 2016

A Profile of the Migrant Population in Tower Hamlets- 2018

Tower Hamlets Borough Equality Assessment 2016/17 Evidence shows that:

There is a mismatch between residents’ skills and jobs available in the borough and (for some also) beyond Tower Hamlets.

Residents identify lack of jobs as one of their top three areas of concern.

The on-going challenges of austerity and welfare reforms coupled with the uncertainty around the impact of the UK leaving the EU have required us to find solutions which increase the life chances of our residents.

The incentive therefore to further invest and strengthen our local economy has never been stronger. We believe that “inclusive growth” is an absolute necessity to achieve greater prosperity, independence and access to opportunities for all our residents.

The plan will be particularly helpful for people who have the following.

lack of motivation or confidence

lack of relevant qualifications or training

long-term unemployment

childcare issues;

physical health, mental health or disability issues

little or no work experience

language skills barriers

basic skills, including literacy, numeracy and ICT

coping as a single parent

debts, arrear or issues with managing your money

Drug dependencies or addictions

Lack of contacts, networks or just knowing where to start Section 3 – Assessing the Impacts on the 9 Groups Please refer to the guidance notes below and evidence how you’re proposal impact upon the nine Protected Characteristics in the table on page 3? For the nine protected characteristics detailed in the table below please consider:-

What is the equality profile of service users or beneficiaries that will or are likely to be affected?

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Use the Council’s approved diversity monitoring categories and provide data by target group of users or beneficiaries to determine whether the service user profile reflects the local population or relevant target group or if there is over or under representation of these groups

What qualitative or quantitative data do we have? List all examples of quantitative and qualitative data available (include information where appropriate from other directorates, Census 2001 etc) - Data trends – how does current practice ensure equality

Equalities profile of staff? Indicate profile by target groups and assess relevance to policy aims and objectives e.g. Workforce to Reflect the Community. Identify staff responsible for delivering the service including where they are not directly employed by the council.

Barriers? What are the potential or known barriers to participation for the different equality target groups? Eg-communication, access, locality etc.

Recent consultation exercises carried out? Detail consultation with relevant interest groups, other public bodies, voluntary organisations, community groups, trade unions, focus groups and other groups, surveys and questionnaires undertaken etc. Focus in particular on the findings of views expressed by the equality target groups. Such consultation exercises should be appropriate and proportionate and may range from assembling focus groups to a one to one meeting.

Additional factors which may influence disproportionate or adverse impact? Management Arrangements - How is the Service managed, are there any management arrangements which may have a disproportionate impact on the equality target groups

The Process of Service Delivery? In particular look at the arrangements for the service being provided including opening times, custom and practice, awareness of the service to local people, communication

Please also consider how the proposal will impact upon the 3 One Tower Hamlets objectives:-

Reduce inequalities

Ensure strong community cohesion

Strengthen community leadership. Please Note - Reports/stats/data can be added as Appendix

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Target Groups

Impact – Positive or Adverse

What impact will the proposal have on specific groups of service users or staff?

Reason(s)

Please add a narrative to justify your claims around impacts and,

Please describe the analysis and interpretation of evidence to support your conclusion as this will inform decision making

Please also how the proposal with promote the three One Tower Hamlets objectives?

-Reducing inequalities

-Ensuring strong community cohesion

-Strengthening community leadership

Race

Positive Employment rates vary considerably by ethnicity: the employment rate for White residents in Tower Hamlets averaged 83 per cent during 2014-2016, compared with just 59 per cent for BME residents - a gap of 24 points. The ethnic gap in rates in Tower Hamlets is almost twice as wide as the gap observed in London (13 points). The aim of the Growth and Economic Development Plan is to build an economy that works for local people and ensure everyone can benefit from the borough’s success. Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone but especially of groups who have traditionally been excluded from the job market. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

Disability

Positive The relationship between disability and employment is complex because of the huge diversity within the population of disabled people. While some disabled people are not able to do paid work because of their impairment, others see the opportunity and right to work as crucial. Overall, disabled people are less likely to be in work than non-disabled people (47 vs. 77 per cent) and disabled people who are economically active are more likely to be unemployed (12 vs. 8 per cent). 18 Employment rates are particularly low for people with a learning disability (6.8 per cent) and people in contact with secondary mental health services (7.1 per cent). Disabled people are also much more likely to be economically inactive than non-disabled people (47 vs. 16 per cent). Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone but especially of groups who have traditionally excluded from the job market. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

Gender

Positive In common with most areas, women in Tower Hamlets have a lower employment rate than men (60 vs. 78 per cent). However, the size of the gender gap is a bit wider in Tower Hamlets than in London (66 vs. 80 per cent). Within the BME population, employment rates are very low for women - just under half (48 per cent) of BME women are in work, compared with 70 per cent of BME men. While the gender gap in rates is also evident within the White population, it is far narrower (78 vs. 86 per cent). Employment rates for BME women are lower in Tower Hamlets than in London (48 vs. 57 per cent), however, the opposite is true for White women, who have a higher employment rate in Tower Hamlets than London (78 vs. 72

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per cent). Consequently, the ethnic gap in employment rates between White and BME women is twice as wide in Tower Hamlets than in London (30 vs. 15 percentage points). Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone but especially of groups who have traditionally excluded from the job market. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

Gender Reassignment

Positive There is currently no data available on trans-gender or trans-sexual people in the UK, but qualitative research finds that employment is the most problematic area of life for trans people.23 42 per cent of trans people who were not living full-time in their acquired gender said that it was their job or workplace which prevented them from doing so. Around a quarter of trans people (23 per cent) changed job or intended to do so because of their transition. Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone but especially of groups who have traditionally excluded from the job market. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

Sexual Orientation

Positive There is a lack of data on employment for lesbian, gay and bisexual (LGB) people, even at a national level, as sexual orientation is currently not captured in most official survey data. However, in the Labour Force Survey, same-sex couples could identify as cohabiting or in a registered civil partnership when completing the survey. Analysis comparing these self-identifying same-sex couples with married different-sex couples found that men in same sex couples were almost as likely as married men to be in work (70.9 vs. 72.8 per cent). On the other hand, women in same sex relationships were more likely to be in work than married women (79.2 vs. 72.7 per cent). The analysis also found that men and women in same-sex relationships earn slightly more than their counterparts in different-sex marriages. However, while the available data does not show any inequalities in employment rates or wages, there is evidence of workplace discrimination. A quarter (26 per cent) of LGB employees are not open about their sexual orientation at work and one in five (19 per cent) LGB employees say they have experienced verbal bullying from colleagues, customers or service users because of their sexual orientation in the past five years. Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone but especially of groups who have traditionally excluded from the job market. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

Religion or Belief

Positive In Tower Hamlets, employment trends by religion correlate broadly with trends by Race. Muslim residents are the only religious group to have an employment rate below the borough average, at 39 per cent compared with 59 per cent of all residents.38 Muslim residents are also more likely to be economically inactive (48 per cent) than the average for all residents (33 per cent). Among residents who are economically active, Muslims face an unemployment rate that is twice that of the borough average (25 per cent vs. 12 per cent). Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone but especially of groups who have traditionally excluded from the job market. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

Age

Positive Employment levels vary considerably across different population groups. By age, employment rates tend to peak for people in the 25-49 age group: during 2014-16, almost four in five adults in this age group were in work (78 per

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cent). Employment rates begin to fall as people get older: just 58 per cent of Tower Hamlets residents aged 50-64 were in work during 2014-16, lower than the proportion regionally or nationally (69 and 70 per cent). This is consistent with the relatively high claim rate for out-of-work benefits in this age group: in November 2016, 25 per cent of those aged 55-64 were in receipt of out-of-work benefits in Tower Hamlets compared with just 14 per cent across London (Figure 5.6). Most of this group were in receipt of disability-related benefits such as Employment and Support Allowance. The employment rate in Tower Hamlets is also lower for those aged 65 and over: around 8 per cent of these residents are still in work compared with 13 per cent in London. Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone but especially of groups who have traditionally excluded from the job market. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

Marriage and Civil Partnerships.

Positive There is a lack of data on employment of this group. Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

Pregnancy and Maternity

Positive There is no official data on pregnant women’s participation in the labour market, but we do know that employment rates for women with children are lower than those for women without children. Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone but especially of groups who have traditionally excluded from the job market. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

Other Socio-economic Carers

Positive Socio-economic disadvantage and inequality can be the biggest barriers to securing sustainable and well-paid employment. For instance issues such as lack of adequate housing or homelessness and the availability, cost and quality of childcare and caring responsibilities are significant barriers to many finding and sustaining work. The service do not hold data for this group but equalities data will be collected as a part of the monitoring process of this plan (or a future user survey). Our ambition is to ensure that interventions proposed will have an overall beneficial impact on the life chances and economic wellbeing of everyone but especially of groups who have traditionally excluded from the job market. Equalities data will be collected as a part of the monitoring process of this plan (or a future user survey).

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Section 4 – Mitigating Impacts and Alternative Options From the analysis and interpretation of evidence in section 2 and 3 - Is there any evidence or view that suggests that different equality or other protected groups (inc’ staff) could be adversely and/or disproportionately impacted by the proposal? Yes? No? X If yes, please detail below how evidence influenced and formed the proposal? For example, why parts of the proposal were added / removed? (Please note – a key part of the EA process is to show that we have made reasonable and informed attempts to mitigate any negative impacts. An EA is a service improvement tool and as such you may wish to consider a number of alternative options or mitigation in terms of the proposal.) Where you believe the proposal discriminates but not unlawfully, you must set out below your objective justification for continuing with the proposal, without mitigating action.

Section 5 – Quality Assurance and Monitoring Have monitoring systems been put in place to check the implementation of the proposal and recommendations? Yes? X No? How will the monitoring systems further assess the impact on the equality target groups? The progress of identified actions, indicators and equalities data will be monitored through the council corporate performance monitoring process. Does the policy/function comply with equalities legislation? (Please consider the OTH objectives and Public Sector Equality Duty criteria) Yes? X No? If there are gaps in information or areas for further improvement, please list them below: The Service currently collects specific equality monitoring data on an annual basis on the Council’s employment support service (WorkPath) delivery published as part of the Council’s Public Sector Equality duty. The data is structured around the following headings:

- Access to service - Composition of users of WorkPath - Satisfaction level of users - Performance Information - Composition of clients placed into work through WorkPath,

Currently gender reassignment and pregnancy are not monitored. Equalities data will be collected as a part of the monitoring process of the Growth and Economic Development Plan.

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The last data set can be found here: https://www.towerhamlets.gov.uk/lgnl/community_and_living/equality_and_diversity/public_sector_equality_duty/public_sector_equality_duty.aspx

How will the results of this Equality Analysis feed into the performance planning process? The Service already monitors Equality performance as part of the Council’s Public Sector Equality Duty. The priorities set out in this Plan will also be monitored through the Council’s Strategic Plan which is a central part of the council’s Performance Management and Accountability Framework. The aim of this plan is to help us determine whether we are achieving our stated outcomes. The Council will also as an when necessary conduct Equality Impact Analysis on specific measures that will be rolled out as part of the evolution of the Growth and Economic Development Plan.

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https://www.towerhamlets.gov.uk/lgnl/community_and_living/equality_and_diversity/public_sector_equality_duty/public_sector_equality_duty.aspx

https://www.towerhamlets.gov.uk/lgnl/community_and_living/equality_and_diversity/public_sector_equality_duty/public_sector_equality_duty.aspx

10

Appendix A (Sample) Equality Assessment Criteria


As a result of performing the analysis, it is evident that a risk of discrimination exists (direct, indirect, unintentional or otherwise) to one or more of the nine groups of people who share Protected Characteristics. It is recommended that the use of the policy be suspended until further work or analysis is performed.


Red

As a result of performing the analysis, it is evident that a risk of discrimination exists (direct, indirect, unintentional or otherwise) to one or more of the nine groups of people who share Protected Characteristics. However, a genuine determining reason may exist that could legitimise or justify the use of this policy.

Further (specialist) advice should be taken

Red Amber

As a result of performing the analysis, it is evident that a risk of discrimination (as described above) exists and this risk may be removed or reduced by implementing the actions detailed within the Action Planning section of this document.

Proceed pending agreement of mitigating action

Amber

As a result of performing the analysis, the policy, project or function does not appear to have any adverse effects on people who share Protected Characteristics and no further actions are recommended at this stage.


Green:

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Cabinet Decision

24 April 2019

Report of: Ann Sutcliffe, Corporate Director of Place


Adoption of Statement of Community Involvement

Lead Member Councillor Rachel Blake, Deputy Mayor for Regeneration and Air Quality

Originating Officer(s) Adele Maher, Strategic Planning; Steven Heywood, Planning Officer

Wards affected All

Key Decision? Yes


31 January 2019

Reason for Key Decision Significant effect on communities living in two or more wards


People are aspirational, independent and have equal access to opportunities; A dynamic outcomes-based Council using digital innovation and partnership working to respond to the changing needs of our borough.

Executive Summary

The Council is required, under Part 2, Section 18 of the Planning and Compulsory Purchase Act 2004, to prepare a Statement of Community Involvement (SCI) that sets out how the Council will consult with stakeholders in the preparation of planning documents and the taking of planning decisions. The planning service keeps the SCI under review to ensure that it reflects current practice and legislative requirements. The current SCI was adopted in 2012 and partially updated in 2017 in advance of the Local Plan examination, to ensure the section on planning policy consultation was reflective of the most recent legislation. As planned at that time, the SCI has now been completely updated, and this document is intended to fully supersede the 2012/2017 SCI.


1. Approve the adoption of the updated Statement of Community Involvement, to supersede the 2017 version.

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Agenda Item 6.6

2. Note the specific equalities considerations as set out in paragraphs 4.1 to 4.3.

1. REASONS FOR THE DECISIONS 1.1 The Council is required by legislation to prepare a Statement of Community

Involvement (SCI), setting out how the Council will consult on planning matters in the borough (under the Planning and Compulsory Purchase Act 2004, section 18).

1.2 The Council is also required to ensure the SCI remains up-to-date, with a review period of five years under the Town and Country Planning (Local Planning) (England) (Amendment) Regulations 2017.

1.3 The currently adopted SCI was partially updated in 2017. However, this refresh focused primarily on the sections of the document relating to consultations on planning policy. This was done to ensure that these sections were up-to-date before the examination of the emerging Local Plan. At the time of adopting this partial refresh, it was intended that a full update would be produced in 2018.

1.4 Without this full update, some sections of the SCI could be considered not to have been reviewed for over five years, as the last full update of the SCI was adopted in 2012.

1.5 This report presents a fully updated SCI for adoption by the Council, in order to meet statutory requirements.


2.1 To not adopt the updated SCI, and to rely on the currently adopted SCI –

which is the partial refresh adopted in 2017.

2.2 There is a risk that if this option is taken, parts of the SCI could be considered not to have been reviewed within five years of the adoption of the 2012 SCI. This is because the 2017 refresh primarily focused on the sections of the document relating to planning policy, with the intention of work being undertaken on a full update in 2018. The Council is required by regulations to review the SCI at least once every five years.

3. DETAILS OF THE REPORT 3.1 The Council is required by legislation to prepare a Statement of Community

Involvement (SCI), setting out how the Council will consult on planning matters in the borough. The Council is also required to ensure that the SCI remains up-to-date, and is reviewed at least once every five years. The relevant legislation is the Planning and Compulsory Purchase Act 2004, and

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the Town and Country Planning (Local Planning) (England) (Amendment) Regulations 2017.

3.2 The Council‟s current SCI was adopted in 2017. This was a partial review and refresh of an SCI which was first adopted in 2012. The review was undertaken to ensure that the sections of the SCI relating to plan making were fully in line with the latest legislation on that matter. This was felt necessary in order to demonstrate at the examination of the emerging Local Plan that the plan had been consulted on in line with both the Statement of Community Involvement and the most recent legislation on local plan consultations.

3.3 The report sent to Cabinet on 19 September 2017 (under „Alternative Options‟) considered the option of undertaking a full review of the SCI at that time, but concluded that this would require significant officer time during a period when the emerging Local Plan needed to take priority. It therefore stated that “a second stage of the SCI update is needed to review the principles of consultation in relation to the development management process, with the intention to go out to public consultation in summer 2018”. The updated SCI presented in this report is the culmination of that second stage.

3.4 A public consultation was held on the SCI between 5 November 2018 and 18 January 2019. Eleven responses were received from the consultation. The process of the consultation and officer responses to the representations are set out in the attached Consultation Statement.

3.5 The updated SCI presents some changes from the previous version, described in the following paragraphs.

General Changes

3.6 The new SCI is half the length of the previous version. This has been achieved by condensing some sections of the document, and removing other sections that were considered unnecessary. The introductory matter has been significantly shortened. The „portrait of Tower Hamlets‟ communities‟ chapter has been removed, as this information does not need to be included in an SCI. The section on „types of consultations and costs‟ has been removed – the cost information had a primarily internal function, helping planning officers to evaluate which consultation techniques to use in particular cases, and provided no benefit to the public in terms of understanding how the Council would conduct consultation exercises. References to the different types of consultation techniques that can be used have been retained. Appendices 2 and 3 have been incorporated into the main document, and have been significantly condensed – as these appendices set out the details of how the Council will consult on planning matters, they better form part of the main document, and the language and level of detail has been simplified to that which could easily be understood by members of the public without a planning background. The language of the document has been improved to remove jargon as far as possible, and to only include information that would be relevant to members of the public interested in finding out more about planning consultations.

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Neighbour Notification Boundaries

3.7 The new SCI alters the boundaries used for sending neighbour consultation

letters for planning applications – these are the letters sent to close neighbours of proposed developments to alert them to what is being proposed and explain how they can comment on the proposal. Current practice is to send neighbour notification letters to all properties with 20 metres of a major or strategic development (defined as 10 or more homes, a residential site area of more than 0.5ha, non-residential applications for more than 1000sqm of floorspace, or non-residential site areas of more than 1ha), and 10 metres of a non-major development.

3.8 Evidence gathered in the course of preparing the SCI found that the response rate to these neighbour notifications is very low. In 2017-18, 111,538 neighbour notification letters were sent, and a total of 13,036 comments on planning applications were received – a response rate of only 11.7%, even if we assume that all comments were generated in response to neighbour notification letters (which is unlikely to actually be the case, as there are other methods of finding out about planning applications – site notices, newspaper notices, local interest groups, the online planning register, and so on). In the previous two years, the response rate was similarly low, at 8.4% in 2016-17 and 12.9% in 2015-16. Some large applications in densely populated areas generate very large numbers of notification letters in return for a very small response – for example, one application looked at during the SCI update process generated 6,830 letters at an estimated cost of almost £11,000, and received only 45 comments, a response rate of 0.65%. Not all applications cost quite so much or receive quite so few responses, but the overall cost of preparing and printing neighbour notification letters was estimated at just over £68,000 in 2017-18. This evidence was presented as part of the consultation material for the SCI, and no comments were received on it.

3.9 The new SCI therefore redefines the neighbour notification boundaries in response to the evidence gathered that shows current practices to be inefficient (paragraphs 4.20 to 4.28, and related table). The 20m boundary will still be used for strategic developments (those with 150 homes or more, 15,000sqm or more of floorspace, or exceeding 30 metres in height), and will be reduced to 10m for other major developments, and 5m for non-major development. For non-major developments that do not create any additional floorspace, only neighbours within the same building will be notified. The new SCI is clear that these boundaries are minimums – for applications where there is a public interest in consulting more widely, they can be extended.

3.10 This approach is not intended to reduce the amount of consultation the Council undertakes on planning matters, but to make the consultation process more efficient. Neighbour notification letters will continue to be combined with site notices, press notices, information available on the Council‟s website, and other forms of consultation described in the SCI.

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New Techniques for Consultation

3.11 The new SCI adds a section on new techniques for consultation (section 5). This describes possible ways in which the Council may use technology to consult on planning matters in the future. These suggestions are based on ideas that the planning service are currently considering, or which the communications service have indicated are possible to implement, dependent on resources. The wider corporate transformation agenda may lead to the Council adopting more ambitious goals for the use of new technology in consultation processes – these can be captured in future updates of the SCI, as and when they are implemented.

Alterations 3.12 Some minor alterations have been made to the SCI document since this

report was approved at MAB. A number of minor typos or poorly phrased sentences have been fixed. It has been noted that developments which require Environmental Impact Assessments have a statutory requirement for 30 days consultation; and that when there are public holidays during a consultation period, we are required to add that time on to the overall consultation period. A table has been inserted showing what we are statutorily required to do in terms of planning application consultations, and what our actual practice is – demonstrating that we often consult for longer than is legally required, in order to ensure all stakeholders have adequate chance to comment. It has been made clear that residents do not need to receive a latter to be able to comment on a planning application – everyone is welcome to comment. And it has been clarified that properties across the street from a planning application site will be notified, even if they fall outside of the official boundary for sending neighbour letters.

3.13 These changes have stemmed from discussions with the Deputy Mayor for Regeneration and Air Quality.

4. EQUALITIES IMPLICATIONS 4.1 A Quality Assurance Checklist has been completed, which identified that a full

Equalities Impact Assessment was not required.

4.2 The SCI does raise some equalities considerations, and regard has been given to the Equalities Act 2000 in the production of the document. The document makes clear (section 2) that „hard-to-reach‟ and underrepresented groups need to be considered when preparing for planning consultations, and that consultations should be made accessible to those with disabilities (bullet point on „outreach and accessibility‟). In response to a consultation comment received from the Tower Hamlets legal department, this bullet point emphasises that people who do not speak English as a first language are considered a „hard-to-reach‟ group and should be considered when preparing planning consultations. A consultation statement should be prepared after major consultations, describing the processes undertaken in preparing for the

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consultation and how the consultation was made accessible (bullet point on „openness‟).

4.3 Under these circumstances, rather than attempt to formulate a detailed translation policy for the planning service as part of the SCI, the new SCI includes, as one of its principles, that „those who do not speak English as a mother tongue‟ should be considered as one of the „hard-to-reach‟ groups when preparing for planning consultations. In this way, different parts of the service can approach this issue in the manner most appropriate to their work.




Consultations,


Risk Management,

Crime Reduction,

Safeguarding. 5.2 Best Value Implications: The new SCI reduces the boundaries for sending

out neighbour notification letters – this change is discussed in more detail in paragraphs 3.7 to 3.10 above. In the 2017-18 financial year, approximately £68,000 was spent on preparing and printing neighbour notification letters, and the changes in the new SCI should reduce this significantly – neighbour notification boundaries have been halved for all but the biggest applications, so costs should also be roughly halved (although the precise costs will depend on how many and what kinds of applications come forward in a given financial year, and there is discretion for the planning service to use wider neighbour notification boundaries for applications where this would be appropriate).

5.3 Consultations: A public consultation was held between 5 November 2018

and 18 January 2019. The details of the consultation process, the representations received, and officer responses to them can be found in the attached Consultation Statement.

5.4 Environmental: The new SCI will have a potentially beneficial impact on the

environment through the reduction of neighbour notification letters (see paragraph 5.2 above, and paragraphs 3.7 to 3.10 earlier in this document). In the 2017-18 financial year, the planning service generated 111,538 neighbour notification letters – this was already a significant reduction on the previous two years (when around 165,000 and 180,000 letters had been produced), and is likely to be reduced further under the new SCI. The neighbour notification boundaries have been halved for all but the biggest applications, so the number of letters produced should also be roughly halved (although the precise numbers will depend on how many and what kinds of applications

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come forward in a given financial year, and there is discretion for the planning service to use wider neighbour notification boundaries for applications where this would be appropriate).

5.5 Risk Management, Crime Reduction and Safeguarding: There are

considered to be no implications for these issues stemming from this proposal.

6. COMMENTS OF THE CHIEF FINANCE OFFICER 6.1 This report seeks approval by the Mayor in Cabinet of the updated Statement

of Community Involvement which sets out how the Council will consult on planning matters.

6.2 The main costs associated with the development of the Statement of

Community Involvement are staffing related and have been financed from within existing resources, as have the costs associated with the consultation process.

6.3 The proposed revision of neighbourhood notification boundaries (paragraphs

3.7 to 3.10) will reduce the number of consultation letters that it will be necessary to send in relation to planning applications, leading to savings in the printing and distribution costs associated with the process. Although it is not possible to exactly quantify the scale of these savings due to the varying consultation requirements that are associated with different types of planning applications, with historic expenditure of £68,000 related to neighbour notification letters during 2017-18, it is expected that these costs will be approximately halved in future, reducing possible budgetary pressures in this service area.

7. COMMENTS OF LEGAL SERVICES 7.1. Section 18 PCPA 2004 requires that the local planning authority must prepare

a statement of community involvement. The statement of community involvement is a statement of the authority‟s policy as to the involvement in the exercise of the authority‟s functions under sections 13, 15, 19, 26 and 28 of the Act and Part 3 of the 1990 Act of persons who appear to the authority to have an interest in matters relating to development in their area.

7.2. A statement of community involvement must set out the local planning authority's policies for giving advice or assistance under (a) paragraph 3 of Schedule 4B to the 1990 Act (advice or assistance on proposals for making of neighbourhood development orders), and (b) paragraph 3 of Schedule A2 to the PCPA (advice or assistance on proposals for modification of neighbourhood development plans). The statement of community involvement is a local development document. There is no longer a requirement for the SCI to be examined by an independent Planning Inspector, however all Local Plan documents must comply with the requirements for community involvement as set out in this document.

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7.3. The Town and Country Planning (Local Planning) (England) (Amendment) Regulations 2017 introduced the requirement to review a statement of community involvement every five years, starting from the date of adoption. This statutory instrument sets a period of five years within which an authority should undertake an assessment of whether its development plan documents, and its Statement of Community Involvement remain up to date

____________________________________


Cabinet, 19 September 2017, Item 5.12 – Tower Hamlets Local Plan 2031: Managing Growth and Sharing the Benefits (Regulation 19 Consultation) and Adoption of the Statement of Community Involvement (SCI) Refresh

Appendices

Appendix 1 - Statement of Community Involvement 2019

Appendix 2 - Consultation Statement

Appendix 3 - Quality Assurance Checklist Background Documents – Local Authorities (Executive Arrangements)(Access to Information)(England) Regulations 2012

None Officer contact details for documents: Steven Heywood

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1

STATEMENT OF COMMUNITY

INVOLVEMENT LONDON BOROUGH OF TOWER HAMLETS

April 2019

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Contents

1. Introduction 3

2. Our Principles 5

3. Plan-Making 7

4. Development Management 15

5. Exploring New Ways to Consult 28

Appendix A – Specific and General Consultation Bodies 30

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1. Introduction

1.1. Tower Hamlets is one of the fastest growing areas in the country with high levels

of new development coming forward each year. In the year 2016-17, 4,844 new homes were completed in the borough and another 7,799 were given planning permission. Growth on this scale requires a careful approach, in consultation with residents, businesses, community groups, and other stakeholders. The Council makes decisions on planning applications in accordance with national legislation and our own local planning policies, in a way that respects existing local communities, meets our needs for future housing growth, and provides the job opportunities, services, and open spaces that make the borough an attractive place to live and do business.

1.2. The Tower Hamlets Statement of Community Involvement sets out how you can get involved in the planning of your local area. This includes preparing the Local Plan and other planning policies, and the process for making decisions on new developments.

1.3. All local authorities are required to produce a Statement of Community Involvement and to keep it updated. The previous Tower Hamlets Statement of Community Involvement was adopted in July 2012 and updated in September 2017. The 2017 update made minor changes to bring the Statement in line with changes in legislation related to policy making.

1.4. The new Statement of Community Involvement includes a number of additional

changes that:

Reflect further changes in planning legislation, regulations and policy since the 2017 update.

Propose changes to how we notify residents about planning applications in their area.

Set out our expectations for how developers should engage with the local community before submitting a planning application.

Set out how the Council is exploring the use of digital technology to reach out to residents more effectively.

The Planning System 1.4. The planning system in England is a ‘plan-led’ process. This means that a local

planning authority (usually a council such as Tower Hamlets) develops a plan for the area that sets out how land will be used and developed over a certain period of time, based on national and regional planning legislation and guidance and local evidence. This is the Plan-Making element.

1.5. Applications for development are submitted to the local planning authority and decisions are mostly made based on the plan for the area (with some exceptions

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4

for permitted development). It is best practice to discuss proposals under a pre-application process, before submitting an application. This is the Development Management element.

1.6. The process of developing planning policy and making decisions on applications

will be explored in more detail in the relevant sections of this document. The Layout of this Document 1.7. The rest of this document is laid out as follows:

Part 2 explains Tower Hamlets’ commitment to engaging with residents and other groups who may be interested in planning and new development within our area. It sets out the principles of how we will engage.

Part 3 focuses on the Plan-Making process, explaining how different planning documents will be consulted on, and the techniques that will be used.

Part 4 looks at consultations on planning applications, including what the Council expects developers to do in terms of pre-application engagement with the local community, and how to comment on a planning application.

Part 5 explains how the planning service will explore the use of digital technology, including social media, to enhance the local planning process.

Reviewing the Statement of Community Involvement 1.8. The SCI will be kept under review and updated when necessary to reflect current

practice and changes to consultation methods. Consultation statements prepared after a consultation should identify how effective engagement was, and whether there are particular groups that are not being reached. If particular problems are identified, these should also be addressed by an update of the SCI. If no review has taken place sooner, a review will be undertaken five years after the date of adoption of the SCI.

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2. Our Principles

2.1. Tower Hamlets Council is committed to engaging with local people,

organisations and businesses on all aspects of our work and services. Our commitments to engage are set out in the Community Engagement Strategy 2018-2021, which sets out four priority outcomes:

Communities lead the way in making Tower Hamlets a great place to live

Communities have the power to influence issues that affect them

Activities to involve communities are focused and purposeful

Tower Hamlets is digitally active 2.2. It is important that these intended outcomes be reflected in the way in which

we consult on planning matters. To that end, our consultations will prioritise:

Clear and non-technical information. Information for consultations will be written in plain English as far as possible, and if technical words have to be used, their meaning will be explained. Where possible, translations and large print versions will be made available. We will ensure that consultations have a clear purpose, and that this purpose is explained.

Early engagement. Consultation will take place as early as possible in the development of new proposals to allow the community to help shape planning in Tower Hamlets. Early engagement will also help to avoid delays in the planning process caused by important or unexpected comments being raised at a late stage of the process.

Appropriate scale. The length of our consultations and techniques used will be appropriate to the type of document, the level of planning, and the impact of the proposals.

Flexibility. The Council will aim to arrange consultation events at a range of times and places, to make it convenient for as many people as possible to attend an event.

Variety of methods. We will use a variety of consultation techniques as appropriate, including workshops, drop-in information sessions, press launches, online surveys and social media. This will allow us to reach as many people and groups as possible.

Outreach and Accessibility. When preparing for consultations, we will consider how to engage with ‘hard-to-reach’ groups that are traditionally underrepresented in planning. This may include younger people, those with no access to the internet, those who do not speak English as a mother tongue, and those with disabilities. When organising consultation events, we will aim to make them accessible to those with disabilities.

Coordination. Through effective internal coordination and greater collaborative working with our partners, we will aim to combine consultation activities and improve information sharing to avoid duplication, deliver better value for money, and avoid the risk of consultation fatigue.

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Openness. We will keep accurate records of responses to consultations, and prepare a Consultation Statement after each consultation ends. The Consultation Statement will summarise the process and results of the consultation, and will explain how the responses received have fed into the Council’s decision-making on planning matters. Consultation Statements should also explain how the consultation was made accessible to as many people as possible. This will be made available on the Council’s website.

Monitoring. We will monitor and review the effectiveness of all consultation activities, including seeking feedback from participants to help ensure we can consult more effectively in the future.

Privacy. We will treat all data submitted as part of consultation activities in line with the General Data Protection Regulations (GDPR) to ensure your personal information is protected.

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3. Plan-Making

3.1. Plan-making is how Tower Hamlets Council develops the planning policies

against which proposals for most new developments will be assessed. Planning in England is policy-led, and having local planning policies in place is important to ensure that development in Tower Hamlets takes place in way that is agreed with the community. The hierarchy of planning policy can be seen in the diagram below:

3.2. The National Planning Policy Framework (NPPF) is a statement of policy from the UK government which sets out what local planning policies should include or take account of. The London Plan is developed by the Mayor of London and the Greater London Assembly. The other three types of document – the Local Plan, Neighbourhood Plans, and Supplementary Planning Document and Guidance – are produced by the Council or community groups within our area (in the case of Neighbourhood Plans).

3.3. Collectively, the adopted London Plan, Local Plan and Neighbourhood Plans form the Development Plan for Tower Hamlets. Most development applications (with exceptions such as for permitted development) will be assessed against this Development Plan and the National Planning Policy Framework.

3.4. The NPPF and national planning legislation are clear that Local Plans should be created in consultation with the community. The rest of this section will set out how we will engage with the community in the creation of planning policies.

Techniques for Consultation 3.5. There are a number of different techniques that can be used to consult with the

community, depending on what is appropriate to the scale, importance, and level of development of a particular piece of planning policy.

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3.6. These types of consultation vary in terms of:

Their material costs (for example, the cost of printing materials or postage costs)

Their use of staff time (for example, through the time taken to produce materials, or the need to attend public events)

The potential size of their target audience (for example, they may be aimed at the general public as a whole, or at small groups of key stakeholders; and the use of particular technologies such as the internet may restrict or open up access to certain groups)

3.7. Consultation techniques also vary in the level of engagement they allow. Some methods (such as a poster or leaflet) may aim primarily to inform the community that a consultation is taking place, the topic of that consultation, and that their views would be welcome; other techniques (such as public exhibitions or Q&A sessions) may provide opportunities for the community to engage more directly with Council staff, to ask questions and expand their understanding of the proposals before submitting their responses; still other techniques (such as interactive workshops) allow for a high level of direct engagement with proposals. All of these methods can be appropriate in different circumstances, and a combination of them will be used wherever possible.

3.8. The types of consultation available to the Council are set out below. When

selecting consultation techniques, Council officers will ask themselves:

whether they are meeting the statutory requirements for engagement (where they exist);

how best to use the available material and staff resources;

how to most effectively reach relevant groups within the community (including traditionally hard-to-reach groups);

whether the level of engagement is suitable to the scale and content of the planning policies being consulted on.

Consultation Techniques

Documents being made available for inspection at Council offices, libraries and Idea Stores

Placing information on Tower Hamlets’ website

Providing information on social media platforms (including, where appropriate, Twitter, Facebook, Instagram, LinkedIn and YouTube)

Posters and leaflets

Public notice advertisements in local newspapers

Email or postal notifications to our database

Presentations at meetings

Public exhibitions, displays, and stalls

Press releases sent to local newspapers

One-to-one meetings with relevant stakeholders

Articles and advertisements in internal publications (aimed at staff and local councillors)

Sending letters to statutory bodies

Interactive workshops

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Tower Hamlets Local Plan 3.9. The Local Plan is the key planning policy document produced by Tower Hamlets,

which sets out the policies against which planning applications will be assessed. This includes a mix of high level strategic policies that apply to almost all development, more detailed specific development management policies that apply to certain types of developments, and also site allocations that secure certain uses such as schools and open spaces on large sites identified across the Borough. The preparation of a Local Plan is governed by legislation that requires a number of stages and types of evidence to be produced. This also involves multiple stages of consulting, engaging or informing the community.

3.10. At all stages of the process, the Council has a legal requirement to make information available to interested residents and organisations, as well as a legal duty to consult the specific and general consultation bodies (these are listed in Appendix A).

3.11. In line with national requirements, when preparing a new Local Plan we will

make consultation materials available at the Town Hall, on our website, and in local libraries. We will advertise the consultations through the local newspaper, and on our website and social media channels. In addition, we will also contact all those who are on our planning policy database with updates about consultations – to be added to this list, please contact us at [email protected].

3.12. Where appropriate, we will consult using additional tools and methods such

as working with established community groups and partnerships, and arranging public exhibitions and interactive workshop sessions. These methods will be more appropriate at the earlier stages of plan-making.

3.13. The stages of Local Plan production are set out in the table below. Stage Opportunities to get involved Our commitment

Stage 1 Regulation 18

This is an options testing phase that may be repeated a number of times. Proposed policies will be detailed and based on evidence, but further comment is needed from the community and other stakeholders to identify potential problems and to ensure the plan represents the needs and interests of all stakeholders.

We will consult widely for a minimum of six weeks, and publish a consultation statement afterwards setting out who was involved in the consultation, the main issues raised, and how we have responded to these issues.

Stage 2 Regulation 19

In this stage, a more complete draft of the Local Plan is published for further comment from stakeholders. At this stage, comments should focus on the

We will consult for a minimum of six weeks, and publish a consultation statement after the

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legal compliance and soundness of the proposed plan – with a sound plan defined as one that is positive, justified, effective, and consistent with national policy. When responding to this stage of consultation, you should make it clear if you want to participate in stage 4, the public examination of the plan.

consultation finishes.

Stage 3 Regulation 22 Submission

At this stage, the plan is submitted to the Secretary of State for an independent examination to be organised.

There is no consultation on this stage, but we will notify all those who made comments on stage 2.

Stage 4 Regulation 24 Examination

At this stage, an independent inspector will be appointed by the Secretary of State to examine the Local Plan and make recommendations for any modifications that are needed to make the plan legally compliant and sound. A series of public hearings will be held on the topics included in the plan. If you wish to take part in these hearings, you should make this clear in your response to stage 2. The hearings will be open to the public to watch.

We will advertise the dates, times, and locations of the hearings at least six weeks before they take place.

Stage 5 Regulation 26 Adoption

After the public hearings are complete, the inspector may make a number of recommendations for modifications before the plan can be adopted. If so, these will be consulted on in the same manner as stage 2.

If the modifications are accepted the plan can be adopted, and we will produce an adoption statement and make it and the plan available to view.

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Case Study: Local Plan Consultation The new Tower Hamlets Local Plan, which was submitted for examination in February 2018, went through two Regulation 18 consultations (stage 1 of the above table) before a more final document was presented for Regulation 19 consultation (stage 2). The first Regulation 18 consultation ran from December 2015 to February 2016, and was based on a document called ‘Our Borough, Our Plan’, which summarised the main issues facing the borough and provided initial ideas of how they could be addressed. The second Regulation 18 consultation put forward a more detailed draft plan containing a vision, objectives, policies, and potential development sites for the borough, and ran from November 2016 to January 2017. For the consultations, summary booklets that explained the proposals were produced and placed in Idea Stores and libraries and made available at consultation events. A dedicated webpage for the new Local Plan was set up, and a survey with 25 questions was published to gather feedback on the proposals. Emails and letters were sent to local community groups, businesses, housing providers, and everyone on the plan making database to alert them to the consultation, and Twitter was also used to reach a wider audience. Advertisements were placed in bus stops during the first consultation, and information panels were placed around the borough for the second. During both consultations, a series of public events were held, with Council officers attending to answer questions, promote discussion and receive comments from members of the public, community organisations and local businesses. More detailed workshops were held with councillors, residents, and neighbourhood planning forums, and focus groups were held with specific groups around issues relating to conservation and design, health and wellbeing, youth, disabled people, developers, and housing providers. By using a range of engagement techniques, the Council ensured a wide range of responses was received to both consultations, with over 100 responses to both consultations, split between residents, developers, and the specific and general consultees.

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Supplementary Planning Documents (SPDs)

3.14. SPDs provide detailed guidance on how policies or proposals in the Local Plan will be implemented, and provide advice to developers on how development proposals can be made acceptable. They will go through three stages:

Stage Our commitment

Preparation At this stage, we will publish on the Council’s website the intention to produce an SPD and ask for comments from interested people or organisations. We may also arrange other events or workshops to discuss the content of the SPD. A consultation statement will be prepared, setting out who was involved in this stage, the comments they made, and how these comments were addressed.

Consultation A completed draft of the SPD will be published for formal consultation. We will make available copies of all consultation material (including the consultation statement) at the Town Hall, on our website, and at local libraries, as well as contacting the specific and (where appropriate) general consultation bodies (as set out in Appendix A). We will consult for at least four weeks, and a further consultation statement will be prepared after the consultation is finished.

Adoption Upon adopting the SPD, we will prepare an adoption statement and make it, the SPD, and the consultation statement available at the Town Hall, on our website, and at local libraries.

Neighbourhood Plans

3.15. The neighbourhood planning process allows for local communities to create

planning policies for their own areas through Neighbourhood Plans and Neighbourhood Development Orders. These plans and orders are prepared by local groups known as Neighbourhood Planning Forums – the Council has a role in assisting these groups in the production of a plan or order, but much of the responsibility lies with the forums themselves. This process includes three stages:

Neighbourhood Area – a neighbourhood area must be designated with clear boundaries, and not overlapping with any existing neighbourhood area.

Neighbourhood Forum – a forum consisting of at least 21 people who live in, work in, do business in, or represent the neighbourhood area must be designated. This organisation will be responsible for developing a neighbourhood plan or development order.

Neighbourhood Plan or Development Order – at this stage, the neighbourhood forum can create planning policy for the area. This is a

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lengthy stage, which includes a number of consultations – including some which are the responsibility of the forum rather than the Council.

3.16. Tower Hamlets Borough Council has prepared detailed guidance explaining

all three stages of the process, and these guidance documents set out the legal requirements for consultation on both the forum and the Council, as well as setting out the Council’s further commitments to engaging with neighbourhood forums. This guidance can be found at https://www.towerhamlets.gov.uk/lgnl/planning_and_building_control/planning_policy_guidance/neighbourhood_planning/Setting_up_a_Neighbourhood_Forum_and_Area.aspx.

3.17. Once an independent examination of a neighbourhood plan has been

completed, there is a duty for Tower Hamlets Council to consult with the neighbourhood forum on new development proposals in the relevant neighbourhood area.

Other Planning Policy Documents

3.18. The Plan-Making team produces and consults on a number of other

documents, and opportunities to get involved in these are set out in the table below.

Document Opportunities to get involved

Community Infrastructure Levy (CIL)

CIL is a levy charged on most new development in Tower Hamlets, which contributes some of the funding towards new infrastructure in the borough. The current CIL charging schedule was adopted in April 2015. When adopting a new CIL charging schedule, consultation requirements are similar to those for a Local Plan. We will prepare a preliminary draft and consult on this; then prepare a final draft and consult again. After this, an independent examination of the charging schedule will take place before adoption. As well as consulting with local residents and organisations, we will take care to consult closely with local developers and infrastructure providers in preparing a CIL charging schedule. Note that the CIL regulations are expected to change later in 2019, and this may remove the requirement to undertake two rounds of consultation on CIL charging schedules. If the CIL regulations are changed after the adoption of this SCI, Tower Hamlets will alter their consultation process in line with the new regulations.

Local Infrastructure Fund (LIF)

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development (known as the LIF area). There are four LIF areas in Tower Hamlets, and the LIF will be spent on local infrastructure following consultation with the community. Consultation will be undertaken using the same techniques as those uses in the preparation of the Local Plan.

Survey of Area and Local Development Scheme

The Survey of Area, as mentioned in planning regulations, corresponds with Tower Hamlets’ Annual Monitoring Report, which monitors the effectiveness of the Local Plan policies. The Local Development Scheme sets out the timetable for Tower Hamlets to produce Local Plan documents. When these documents are produced, Tower Hamlets will provide for a 4 week period during which people can comment on their content before they are finalised and published.

Other documents We will consult on other planning documents (including but not limited to Article 4 Directions, Conservation Area Character Appraisals, Masterplans and Development Briefs) according to the scale, detail and nature of the documents.

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4. Development Management 4.1. Development Management is an integral part of the planning process. It puts

development plans and policies into action to achieve sustainable development. Development Management includes the process by which planning applications (including applications for planning permission, listed building consent, advertisement consent and prior approval) are decided.

4.2. Development Management includes pre-application engagement, which aims to shape development and deal with key planning issues well in advance of an application being submitted. Pre-application consultation is not mandatory, but is strongly encouraged – we believe that early engagement leads to better development proposals, and increases the likelihood of a proposal complying with the Development Plan.

4.3. Development Management also includes monitoring compliance with approved plans and enforcement when unauthorised development takes place. The Council has a Planning Compliance Policy which explains how we carry out those duties.

4.4. If an applicant (whether an individual, business, public body or other organisation) submits a planning application, this is assessed against the policies in the Development Plan, national planning policy and legislation, supplementary guidance and other material considerations before a decision is made. It is important that the community who may be affected by development proposals are involved and are able to have their say. The views of local residents, businesses, organisations and community groups can help the Council to seek improvements or amendments to development proposals and ensure any impacts are dealt with.

4.5. The flow chart below summarises the stages of consultation and public

involvement in the development management process:

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Pre-application Stage – developers are strongly encouraged to engage in a variety of ways with residents and other local stakeholders. This is the stage where residents can have the greatest influence on proposals. The best way to get involved at this stage is to attend pre-application events when they are held or engage with developers on social media or through surveys when they make these options available, and to discuss any concerns with your local councillor. See paragraphs 4.7 to 4.13 below.

Application Stage – a formal consultation is organised by the Council, and residents are invited to make comments on the submitted proposals. At this stage, comments are influencing whether a development is approved or not. The best way to get involved at this stage is to read the proposal documents, and submit detailed, specific comments on why they should or should not be approved. See paragraphs 4.14 to 4.30 below.

Decision Making Stage – if there is substantial public interest in the proposal, the decision will be made at a committee meeting. Residents are able to speak at these meetings to express local views on the proposal. The best way to get involved at this stage is to discuss your concerns with your local councillor, or to ask to speak on the application at committee. See paragraphs 4.31 to 4.35 below.

The best time to get involved!

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4.6. The table below describes the stages a development proposal may go through in

more detail (although this is indicative only, and there will be exceptions to this standard pathway):

1. Pre-Application Stage

The Council provides pre-application advice to applicants on a proposed application.

The applicant undertakes pre-application consultation with the local community. This is strongly encouraged for major and strategic applications (which includes residential applications with 10 or more dwellings or an area of 0.5 hectares or more; for other uses, those with over 1000m2 of floorspace or an overall area of 1 hectare or more).

Locally elected members such as, the mayor and councillors may also have the opportunity to comment at this stage.

2. Application Stage

The Council carries out statutory notification with the public and other stakeholders. This will always meet the minimum standards required by planning legislation and in some cases will be supplemented by additional consultation depending on the type of application.

Council officers assess the application against planning policy, taking into account the results of consultation.

Council officers make a recommendation on the application.

A final decision is made. Most applications are determined by senior planning officers. Larger applications and those where there is substantial public interest are decided by a Committee of the Council.

3. Post-Application Stage

If planning permission (or a related consent) is granted, it may be subject to conditions requiring further details to be submitted and approved.

Sometimes amendments to permissions are requested. This may involve submission of material or non-material amendments. Applications for material amendments and reserved matters (following grant of outline permission) will be subject to consultation similar to the application stage above

If permission is refused, an appeal to the Planning Inspectorate on behalf of the Secretary of State may follow. The procedures for notifying the local community are set out in national regulations.

Pre-Application Advice and Consultation 4.7. Tower Hamlets believes in the principle of early engagement. This means

working with developers, residents, and other stakeholders at the earliest possible stage in the process to shape development proposals and identify and

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overcome potential obstacles. This requires respect for each other’s interests, reasoned and open communication, and early consultation. If done well, this process makes applications more likely to be recommended for approval. The Council strongly encourages those who hope to bring forward applications for development on complicated or sensitive sites to consult with the Council and the local community at the pre-application stage. This is the stage at which local residents and other stakeholders are most able to influence the development of proposals – if they are only consulted at a later stage, after a formal planning application is submitted, their level of influence over and ownership of the process is reduced, and engagement may be perceived as tokenistic.

4.8. Tower Hamlets offers a pre-application advice service to applicants, providing professional planning advice before an application is submitted. For most types of applications there is a charge for this service, but for some developments – such as householder applications affecting only a single house – applicants can instead call or visit the Duty Planner service free of charge. Details of charges for pre-application advice can be found at https://www.towerhamlets.gov.uk/Documents/Planning-and-building-control/Development-control/Application-processing/Pre_application_advice_guidance_note.pdf.

4.9. As part of the pre-application advice service, the Council strongly encourages

meaningful engagement with local residents, businesses, community groups, and other stakeholders before submitting a planning application. This stage of consultation is optional, and there is no statutory requirement for applicants to consult before submitting an application. However, as part of the principle of front-loading, we believe it can be very useful in identifying issues, responding to concerns and ensuring the views of those affected can help to improve the design of new development or influence the outcomes that will benefit their area.

4.10. The Council can advise developers on good practice for engagement,

including the length and extent of any consultation, contact details for potentially interested stakeholders in the local area, engagement methods, and when the consultation should be held.

4.11. For consultation to be meaningful, it should be held towards the beginning of the pre-application process, while there is still a realistic opportunity for the local community to help shape proposals before they are submitted as a formal application. If consultation is held just before submitting the application, the designs are likely to be more fixed and there are fewer opportunities for community engagement to influence the proposals.

4.12. Engagement methods that can be used include:

Conservation and Design Advisory Panel (CADAP) – organised by the Council, this involves a presentation of a proposal to a panel of independent built environment practitioners, who provide written feedback on any proposal.

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Exhibitions, Community Forums and workshops – organised by the applicant to provide information about their proposals and an opportunity for feedback.

Letters, leaflets and questionnaires – organised by the applicant, this involves sending a summary of the proposals and how to respond to properties which may be affected. This will focus on informing and getting the views of the properties most affected – this could be just a few streets, or whole neighbourhoods.

Creating a dedicated website – organised by the applicant, and could show the evolution of proposals and provide a facility for feedback to be recorded.

A presentation of the scheme to elected members – organised by the Council and including presentations to the Mayor, cabinet members, local ward members and members of the Council’s Development Committees.

4.13. Consultations on very large schemes have included community forums, which, facilitated by Council officers, has enabled local residents to express their concerns over large scale development and lack of associated infrastructure. This has directly contributed to developers amending their proposals to include schools and health centres in applications.

4.14. Developers should clearly explain how comments received during a pre-application consultation process have been taken into account and influenced the submitted application. This can be done in a number of ways, but is often included in the Design & Access Statement, Consultation Report, or Planning Statement.

Case Study: Pre-Application Consultation Millharbour Village is a proposed development across a collection of linked sites in the northern part of the Isle of Dogs. This is an area experiencing high levels of residential growth with several major developments under construction or at the planning stage. In 2014, pre-application discussions commenced with two main landowners about their aspirations to develop their sites at 2 Millharbour and 3 Millharbour. Both developers were looking to bring forward proposals for residential-led, mixed use development. The Council encouraged the land-owners to work together to produce an urban design framework so that their individual proposals would be part of a comprehensive development to create new high quality and sustainable place. All parties recognised the importance of early engagement with the local community. Pre-application engagement with the local community took place over several months, in advance of both planning applications being submitted. The consultation principles included front-loading community involvement, actively seeking and encouraging participation, being transparent and keeping the community up to date.

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Consultation on Planning Applications 4.15. There are many different types of planning applications, and the exact type is

based on the nature of the proposed development. For each of these different types of application, there are different requirements for the Council to notify residents and to consult stakeholders.

4.16. The Tower Hamlets website is the key resource for finding out information about and commenting on planning applications. Planning applications can be searched at https://development.towerhamlets.gov.uk/online-applications/, and users can register with the site to receive updates on saved applications and notifications when applications are submitted within a defined area. By clicking

Both development teams used a range of techniques including stakeholder meetings, public exhibitions, media publicity and a project website. Around 5,000 residents within a 400 metre radius were contacted and invited to attend initial exhibitions and events. In addition to local residents, key stakeholders were identified and invited to exhibitions and interactive workshops. These included local councillors, members of the youth forum, community groups and businesses. The engagement process identified key issues relating to the amount and type of open space to be provided and how the development could accommodate a range of uses that would help to define it as a destination and heart of a new community, rather than just another high density residential development. Workshops encouraged stakeholders to think about what the “ingredients” of Millharbour Village could be and included interactive sessions where participants could put forward their ideas. In one workshop children and young people illustrated their ideas by making pizzas – each ingredient representing something that they would like to see in the new developments. Both developers took on board the feedback they received and this led to a refinement of the development proposals to include two substantial public open spaces, one to provide active play spaces for children and young people and a space for quieter relaxation. The pre-application feedback helped the developers finalise their proposals to provide space for the Lanterns theatre and performing arts school, space for a future primary school, nursery space, a mixture of commercial and retail uses. Following the submission of the applications, statutory public consultation and consideration by the Strategic Development Committee, planning permission was granted in September 2015 for the development at 2 Millharbour and September 2016 for the development at 3 Millharbour.

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on the ‘weekly/monthly lists’ tab, lists of recently submitted applications can be found, as well as lists of recent decisions on planning applications. An interactive map of planning applications can also be found at https://www.towerhamlets.gov.uk/lgnl/planning_and_building_control/planning_applications/search_and_comment_planning_applications.aspx.

4.17. In most cases, we will notify you through one or more of the following ways:

A letter from Tower Hamlets if you live in a building close to the application site

A site notice near the application site – these will usually be attached to a lamppost or similar object. Notices will be displayed for a minimum of 21 days.

A notice in a local newspaper

4.18. The site notice, press notice or neighbour letter will explain where the planning application can be viewed, which will usually be on the Tower Hamlets website at www.towerhamlets.gov.uk/planning and how to make comments. Site notices and neighbour letters will also contain a Quick Response code (QR code), that can be scanned with a smartphone and will take you to the relevant page on the Council’s website.

Changes to how we use neighbour letters and site notices

4.19. National legislation in the Town and Country Planning (General Development Management) Order 2015 sets out situations were site and press notices must be used and situations where there is discretion to use either site notices or letters to notify people occupying nearby properties that an application has been received. This legislation says that letters must be sent to the occupiers of “adjoining land or properties”, but there is no definition of what this means. The SCI provides an opportunity to define how we will interpret this minimum requirement in a way that works well in Tower Hamlets.

4.20. Research shows that the Council sends out large volumes of neighbour letters on planning applications and yet the response rate is disproportionately low. Sometimes the number of responses received is less than 10% of the number of letters sent. However the costs of printing and posting neighbour letters are substantial. We need to reduce the number of letters sent – but this should not affect how people have their say on planning applications. There are many ways to find out about and track the progress of applications in your area using the Council’s website and you do not need to have received a letter to make a comment.

4.21. The previous Statement of Community Involvement used boundaries of 20

metres for consultation on all major development applications and 10 metres for non-major development. After consultation on potential changes, this SCI sets out some changes to those boundaries – these changes are designed to be

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proportionate to the scale of development being proposed, the magnitude of the impacts that could arise from the development and the likely level of public interest.

4.22. The 20 metre boundary will continue to be used as the starting point for the

most significant major development proposals. These would include applications for strategic development that has to be referred to the Mayor of London (e.g. more 150 or more new homes, or buildings more than 30 metres tall), local plan site allocations, developments that require an Environmental Impact Assessment, and major infrastructure projects. A site notice (or notices) will also be displayed and the application will be advertised in the local press.

4.23. For other major development proposals, the consultation boundary will be 10

metres. A major development is defined as one where 10 or more dwellings will be constructed; where a residential site is more than 0.5 hectares in area; or where a non-residential use will be more than 1 hectare in area (1 hectare is around the size of Trafalgar Square). A site notice will be displayed and the application will be advertised in the local press

4.24. The consultation boundary for non-major development has been reduced to

5 metres, which would effectively be the properties directly adjoining the application site.

4.25. The notification boundaries are minimum requirements. Where there is likely

to be an impact on a building or group of buildings just outside this boundary, we will ensure that occupiers of these properties are notified. Properties that face towards an application site, but are on the opposite side of a road or street will be notified, even if they fall outside of the notification boundary.

4.26. In cases where no new floor-space would be created, for example

applications for new shop-fronts or internal changes of use, a site notice will be displayed and only residents of properties within the same building who may be affected will be notified.

4.27. The table below shows the minimum consultation methods for all types of

application.

Type of development Website Site notice

Press notice

Neighbour consultation letters – minimum standards

1. Major and strategic development* •10 or more residential units •1000 square metres of floor space

Yes Yes Yes Strategic Development* Occupiers of land or properties which are adjacent to and/or have a common boundary with the application site and

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•Sites of more than 1 hectare •Development where the application is accompanied by an Environmental Statement •Includes changes of use where the above apply.

addresses that are within 20 metres of the boundary of the application site and properties directly facing the application site across a road or street. Other major development Occupiers of land or properties which are adjacent to and/or have a common boundary with the application site and addresses that are within 10 metres of the boundary of the application site and properties directly facing the application site across a road or street

2. Non-major development •Less than 10 residential units •Less than 1000 square metres of new floor space •Sites of less than 1 hectare •Householder development •Includes changes of use where the above apply •Telecommunications apparatus that is not permitted development

Yes No No Occupiers of land or properties which are adjacent to and/or have a common boundary with the application site, are directly opposite across a road or street or any of the property would be within 5 metres of the application site.

3. Non-major development where no additional floor space is created •Except telecommunications apparatus and changes of use. •For example, new shop-fronts

Yes Yes No Occupiers of properties within the same building.

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4. Applications for development or demolition that would affect the character or appearance of a Conservation Area or the setting of a scheduled ancient monument.

Yes Yes Yes Apply standards in 1, 2 or 3 above as appropriate.

5. Departures from the Development Plan


6. Any application affecting a public right of way or footpath/way •Excluding pavement crossovers, new/revised vehicular or pedestrian accesses


7. Applications for Listed Building Consent

Yes Yes Yes Only if works would affect the external parts of the building and are accompanied by a planning application. Apply standards in 1, 2 or 3 above as appropriate.

8. Advertisement Consent a) Signage on shop fronts or business premises b) Free-standing advertisements c) Large scale advert hoardings.

Yes Yes No

a) Site notice only.

b) Apply standards for non-major development.

c) Apply standards for major development.

9. Prior Approval – telecommunications

Yes Yes Yes Apply standards in part 2 above.

10. Prior Approval – larger household extensions

Yes No No Occupiers of neighbouring properties that adjoin and/or directly opposite the site

11. Applications for permission in principle

Yes Yes No Apply standards in part 2 above.

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12. Applications for reserved matters after the granting of outline permission

The starting point will be the consultation that would now apply under the revised SCI for the original application.

13. Applications for variation or removal of planning conditions

The starting point will be the consultation that would now apply under the revised SCI for the original application.

14. Applications for minor material amendments

The starting point will be the consultation requirements that would now apply under the revised SCI for the original application. A reduced neighbour notification area may be used, depending on the nature of the amendments Anyone who commented on the original application will be included as a minimum.

15. Applications for non-material amendments (e.g. technical amendments)

By definition no consultation would be necessary.

16. Lawful development certificates

Legal determinations and by definition no consultation would be necessary.

* Strategic Development refers to applications that must be referred to the Mayor of London before a decision can be made. The full definition of applications of Potential Strategic Importance (PSI) is set out in the Mayor of London Order 2008 (as amended). In Tower Hamlets, this is development of 150 or more new homes, 15,000 square metres or more of floor space, or buildings exceeding 30 metres in height. Major development refers to residential applications for 10 or more units or a site area of more than 0.5 hectares; or non-residential applications for more than 1000 square metres of floorspace or a site area of more than 1 hectare. How long is the consultation period? 4.28. National legislation requires that Council’s allow a minimum of 21 days for

any comments to be made on planning applications, with a few exceptions:

The period is extended to 30 days for applications accompanied by an Environmental Statement made under the 2017 EIA Regulations

The period must be extended when it includes bank or public holidays – by the equivalent amount – e.g. notifications over the Easter holiday would be extended by two days.

4.29. Notification periods have to strike a balance between allowing enough time

for comments to be made and ensuring decisions are made in a timely manner. Whatever the period, it is always helpful to receive comments as soon as possible.

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4.30. Taking account of the national legislation, the scale and complexity of some major developments in Tower Hamlets and the need to maintain timely decision making, the SCI proposes extending the notification period to 30 days for all major development. The table below provides a summary.

Type of development National requirement for letters and notices

Tower Hamlets notification period

All major development (including strategic applications)

21 days 30 days

EIA development 30 days 30 days

Non-major development 21 days 21 days

Amendments to applications where consultation has already taken place

Not required 14 days

How to Comment on a Planning Application 4.31. We welcome all comments on development proposals in the area, and

comments do not have to be written in a particular style or format to be considered. However, comments must be made in writing. Any member of the community can submit comments on any planning application, as long as it is within the consultation period. There should be no need to hire a solicitor or other professional.

4.32. We ask that people take the time to look at an application before commenting on it. Information on planning applications can be searched for on the Tower Hamlets website at: https://www.towerhamlets.gov.uk/lgnl/planning_and_building_control/planning_applications/search_and_comment_planning_applications.aspx, or by contacting the Planning and Building Hotline on 020 7364 5009.

4.33. When making a decision, we can only take account of certain issues that are

legally allowed to influence planning applications – these are known as material considerations. You are welcome to make comments on other aspects of an application, but to influence the planning process you should try to consider and refer to these material considerations. Material considerations include:

Planning policies, including the National Planning Policy Framework, the London Plan, and the Tower Hamlets Local Plan and Supplementary Planning Documents. This can also include emerging plans that have been through at least one round of public consultation.

Previous planning decisions, including appeal decisions

Loss of light or overshadowing

Loss of privacy or overlooking

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Design, appearance and materials of a development

Layout and density of buildings

Traffic, highway safety and parking

Noise, smells and other disturbances resulting from the use of a new development

Loss of trees or other nature conservation effects

Effect on listed buildings or conservation areas

Capacity of physical infrastructure such as public drainage or water systems

Deficiencies in social facilities such as school places

Contaminated land

4.34. We cannot ordinarily consider issues such as a potential reduction in the value of a property or loss of a private view – but the reason why these things might happen could potentially be material considerations.

4.35. All comments received on planning applications must be made open to public inspection – please only include information that you are comfortable being made publicly available.

Making Decisions on Planning Applications 4.36. After the consultation on a planning application is finished, a planning officer

will write a report setting out their recommendation. A final decision will then be taken by either a senior planning officer or a Committee of the Council. In Tower Hamlets, like in most planning authorities, the majority of applications are decided by senior planning officers, using powers delegated by the Council.

4.37. Generally, only larger and/or controversial applications, with outstanding policy conflicts or objections, will be considered by a Committee. Tower Hamlets has two planning committees – Development Committee and Strategic Development Committee.

4.38. The Development Committee determines applications for development

involving 35 or more new homes, over 10,000 square metres of floorspace, or over 5,000 square metres of retail floorspace.

4.39. The Strategic Development Committee determines applications involving 500

or more new homes, 15,000 square metres or more of floorspace, or where any part of the development would be more than 30 metres tall (approximately 10 storeys), or more than 25 metres tall on sites adjacent to the River Thames. The full terms of reference for both committees are available on the Council’s website at http://democracy.towerhamlets.gov.uk/uuCoverPage.aspx?bcr=1.

4.40. Applications must also be decided by the committees if the Council receives

20 or more objections and is recommending that permission should be granted, or 20 or more representations in support and is recommending that permission

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should be refused. Online comments, emails, letters and petitions are all counted. Only signatures from people whose names are on the Tower Hamlets electoral roll will be counted for this purpose.

4.41. Planning officers will make recommendations on an application based on planning policy documents, responses from the consultation, and any other relevant guidance at national and local level. Officers will not generally respond to individual letters or objections, but will address the key issues and comments in their report. While officers will take into account all comments, they will use their judgement to reach a final decision which may not reflect your own comments on the application. A report will be prepared which sets out how the application was assessed and how comments received following consultation were taken into account.

4.42. If the application is to be considered by a Committee, all those who made comments on it will be notified by email of the date and time of the Committee meeting. All meetings are held in public and anyone can attend. The Council allows members of the public and applicants to address the committee, although the number of speakers and the time they are given to speak is limited. You can find out more about how to register to speak and our procedures on our website. Public speaking is not allowed for items deferred from previous meetings where representations have already been made.

4.43. If you have commented on a planning application, you will be notified by

email (if provided) of the decision – we will aim to do this within five working days of the decision being made.

4.44. The applicant may choose to appeal against the Council’s decision. In these

circumstances, the application is decided by the Planning Inspectorate, and your comments will be forwarded to the Inspectorate, who may choose to publish them on their own website.

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5. Exploring New Ways to Consult 5.1. Tower Hamlets Council is committed to improving the way it consults with our

local community. The Council’s Community Engagement Strategy 2018-2021 includes a commitment to being open and digitally connected so that residents can communicate with us across multiple platforms. We are developing new digital tools to allow this to happen and it is anticipated that the Council will begin to roll these improvements out in 2019 and 2020.

5.2. The planning service is also considering some specific interventions that can be made in relation to planning consultations. Some of these interventions will require more extensive consideration, due to resource concerns – but all of them are currently being explored by the Council.

5.3. All site notices will include Quick Response codes (more commonly known as QR codes). These consist of black and white square designs, similar to a barcode, which can be read by smartphone cameras. Anyone who sees a site notice will be able to use the QR code to be directed to the relevant planning application on the Council’s website.

5.4. It is our intention to provide links to live planning consultations on Facebook and

Twitter, and possibly LinkedIn. We will also consider the use of geo-targeted (i.e. seen only by people located within the borough or a specific locality) online advertisements for particularly important consultations, where it is considered an effective use of limited budgets. In advance of this, careful consideration will need to be given to what information will be broadcast in these ways, to avoid information fatigue among our followers and to make the best use of the Council’s digital channels.

5.5. The planning service will consider the creation of a regular planning newsletter

or digest, which will provide summarised information about major planning applications and decisions, appeal hearings, pre-application consultations, and planning policy consultations. Careful consideration will need to be given to how this is implemented, to avoid consultation fatigue among recipients.

5.6. We will consider the possibility of webcasting planning committee meetings and

possibly local plan examination hearings.

5.7. We are currently exploring the use of 3D imaging in planning applications to demonstrate height, scale, and massing of applications in context, and will consider how best to use this technology when engaging with the public.

5.8. These changes will make a positive difference to the way we advertise our

consultations and should increase the number of responses received and how we engage. There will be further opportunities to harness the power of new technologies more fully and to implement innovative new ways to consult on

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planning policy and planning applications, and the Council is considering these new ideas as they arise.

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Appendix A – Specific and General Consultation Bodies

Specific Consultation Bodies

Mayor of London (Greater London Authority)

London Boroughs of Greenwich, Hackney, Lewisham, Newham, Southwark, Waltham Forest, the City of London, and the London Legacy Development Corporation

Lee Valley Regional Park Authority

Coal Authority

Environment Agency

Natural England

Secretary of State for Transport

The Historic Buildings and Monuments Commission for England

Transport for London

NHS London

Thames Water

Phone, broadband, gas, and electricity companies operating within the borough

General Consultation Bodies

The Mayor and ward councillors

The Residents’ Panel

Registered housing providers

Neighbourhood planning forums

The Young Mayor and Deputy Young Mayors

Equalities forums

The Metropolitan Police

The Canal and River Trust

Marine Management Organisation

Port of London Authority

Health trusts and emergency services

Other borough-wide groups and developers

Other voluntary bodies, some or all of whose activities benefit any part of the borough

Bodies which represent the interests of different groups in the borough, e.g., amenity societies, residents’ associations, equalities groups, other community groups that express interest

All people who have advised the Council that they are interested in being informed about a particular plan being prepared

To be added to the Planning Policy database to be informed about the progress of planning policy documents, provide your contact details by:

Email: [email protected]

Phone: 020 7364 5009

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Post: FREEPOST, London Borough of Tower Hamlets, PO Box 55739, London E14 1BY

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London Borough of Tower Hamlets Statement of Community Involvement Consultation Statement January 2019 Introduction 1.1. This statement sets out the consultation activities that were undertaken and the

responses that were received on the London Borough of Tower Hamlets’ updated Statement of Community Involvement (SCI).

1.2. The redrafted SCI was undertaken to bring the document fully up-to-date, following a partial refresh in 2017. That refresh focused on updating the plan-making element of the SCI, in advance of the examination of the emerging Local Plan. The new SCI now updates the development management section of the document, to reflect current legislation and practice, and adds a brief section on the ways in which the Council is exploring the use of digital technology to enhance future consultations.

1.3. This document consists of two parts: the first describes the process of the SCI

consultation, the second sets out the responses received and how the Council is responding to them.

The SCI Consultation Process Consultation Period 2.1. The SCI consultation took place between 5 November 2018 and 18 January 2019

- a total of 11 weeks. This was a longer consultation for a document of this kind, as it was felt that this length of time was necessary to carefully consider the content and allow the Council to accommodate the proposed consultation events as well as account for part of the consultation stretching into the Christmas holiday period, when people may have found it more difficult to make the time to respond.

2.2. The consultation was originally planned to finish after 10 weeks, on 13 January 2019. However, a number of small but necessary changes to the content of the document were identified shortly after the consultation began. An updated version of the consultation document was uploaded to the Council’s website and sent to the borough’s libraries and Idea Stores on 9 November 2018. Although no responses had been received by this date, it was decided to extend the consultation by one week, to ensure that all consultees had the full 10 week period to consider the corrected document.

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Publicity 2.3. The consultation document was made available for inspection at the Town Hall

reception at Mulberry Place and in all of the libraries and Idea Stores in the borough. These are:

Bow Idea Store, 1 Gladstone Place, Roman Road, E3 5ES

Canary Wharf Idea Store, Churchill Place, E14 5RB

Chrisp Street Idea Store, 1 Vesey Path, East India Dock Road, E14 6BT

Watney Market Idea Store, 260 Commercial Road, E1 2FB

Whitechapel Idea Store, 321 Whitechapel Road, E1 1BU

Bethnal Green Library, Cambridge Heath Road, E2 0HL

Cubitt Town Library, Strattondale Street, E14 3HG

Tower Hamlets Local History Library and Archives, 277 Bancroft Road, E1 4DQ 2.4. The document was also made available on the Council’s website at

https://www.towerhamlets.gov.uk/lgnl/planning_and_building_control/consultation_and_engagement/statement_of_community_involve.aspx. This page included a description of how responses could be submitted by post or email, details of the consultation events, and an explanation about the extension of the consultation deadline.

2.5. An email was sent out to everyone on the plan-making team’s email database, which represents those people who have confirmed that they wish to be kept up-to-date on planning policy consultations. This email explained the purpose of the consultation and how responses could be submitted, and contained details of the consultation events.

2.6. Further emails were sent out to all the members of the Council’s Developers’

Forum, and to all the members of the Tower Hamlets Housing Forum Executive. The former was very similar to the general mass email that was sent; the latter asked the members of the Executive to circulate the consultation details among their tenants, and to let the Council know if any of the tenants expressed an interest in attending the workshop event. Four responses were received to this email indicating that the details had been circulated – other recipients may have circulated the details without confirming this to the Council.

Consultation Events 2.7. Five consultation events were held in November 2018, four drop-in exhibition

sessions at Idea Stores across the borough (set out in Par 2.8), and one workshop held at the Town Hall. The events were held at a range of times, including weekdays, weekday evenings, and weekends, and aimed to provide fair geographical representation across the whole borough. The events were all held near the beginning of the consultation period, partly because of officer availability in December, and partly because it was thought that the events would provide an introduction to the updated SCI, and recipients would then

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need some time to consider what to include in a more detailed written response to the consultation.

2.8. The events were held at the following times and places:

Drop-in: Wednesday 14 November, 5.30-7.30pm, Bow Idea Store

Drop-in: Friday 16 November, 1.30-3.30pm, Chrisp Street Idea Store

Drop-in: Thursday 22 November, 5.30-7.30pm, Canary Wharf Idea Store

Drop-in: Saturday 24 November, 1.30-3.30pm, Whitechapel Idea Store

Workshop: Thursday 29 November, 6-8pm, Tower Hamlets Town Hall 2.9. For the drop-in events, five A1 exhibition posters were developed. These briefly

summarised the content of the updated SCI, and described the changes between the current SCI and the new one. They also explained how to respond to the consultation, and included the consultation questions from the SCI document. At the events, pens, paper, and post-it notes were provided for attendees to record their thoughts, and three officers were in attendance at all the events to answer questions and guide attendees through the information.

2.10. There were no attendees at any of the drop-in consultation events.

2.11. For the workshop, the intention was to hold a brief presentation on the content of the document, containing much of the same information as the exhibition posters. There would then be a question-and-answer session with the whole group of attendees. The majority of the session would then be taken up with small group work – attendees would be split into small groups on separate tables, and each group would be given one of the exhibition posters. Groups would work with a Council officer to discuss the content of the SCI in each area, to address the consultation questions, and to leave responses and ideas on post-it notes attached to the posters. These would be collected and processed by officers after the event. All attendees would also be encouraged to submit a more detailed written response during the remaining consultation period.

2.12. Potential attendees were asked to notify the Council of their intention to

attend, in order to control numbers. One resident indicated an interest in attending, but decided not to upon discovering that they were due to be the only attendee. No other residents informed the Council of their intention to attend the workshop. Three officers attended the workshop session regardless, in case any attendees arrived unannounced. One attendee arrived, just over halfway through the allotted time for the workshop. The officers discussed the content of the SCI with them, as described above.

Responses to the SCI Consultation 3.1. A total of 11 responses were received to the SCI consultation.

3.2. Two of these were from local residents (including one based on notes taken

from the one attendee at the workshop event). Two were internal responses

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from Tower Hamlets officers. Five were from statutory organisations – the Canal and River Trust, the Marine Management Organisation, Natural England, the Port of London Authority, and Transport for London. One was from a community organisation, the Globe Town Assembly. One was from a business organisation, Canary Wharf Group.

3.3. The table below contains a summary of the comments made in the responses to

the consultation – in some cases these have been paraphrased for reasons of space. The table also sets out the Council’s response to each suggestion.

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Consultee Type Comment Response

Statutory Organisation (Canal & River Trust)

The Canal and River Trust should be added to the list of General Consultees in Appendix A.

Agreed. Proposed change: add ‘The Canal and River Trust’ to Appendix A, under General Consultation Bodies.


We note that the Council will advise developers on potentially interested stakeholders for pre-app consultations. The Canal and River Trust should be considered a potentially interested stakeholder on applications within their notified area.

This is noted, and requires no change to the text of the SCI. The Canal and River Trust has been added to Appendix A, as a general consultation body, and would be considered as a stakeholder for relevant pre-application consultation.


There should be a firm commitment to contact individuals and organisations that have stated they want to participate in Local Plan examinations – if an attempt to make contact fails, the Council should seek to reach an alternative contact or use an alternative form of communication.

The point is noted – however, contacting parties who have expressed an interest in participating in Local Plan examinations is the responsibility of the Programme Officer. The Council works with the Programme Officer where necessary to try to ensure contact is made with all interested parties, but we cannot guarantee this will always be possible, and we do rely on interested parties providing up-to-date contact information. It is felt that no change to the text of the SCI is required to address this.

Statutory Organisation (Marine Management Organisation)

The Marine Management Organisation should be added to the list of General Consultees in Appendix A.

Agreed. Proposed change: add ‘Marine Management Organisation’ to Appendix A, under General Consultation Bodies.

Statutory Organisation (Natural England)

Natural England is supportive of the principle of meaningful and early engagement with the general community, community organisations, and statutory organisations, both in terms of shaping policy and participating in the process

The response is noted and welcome.

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of determining planning applications.

Statutory Organisation (Port of London Authority)

The Port of London Authority should be added to the list of General Consultees in Appendix A.

Agreed. Proposed change: add ‘Port of London Authority’ to Appendix A, under General Consultation Bodies.

Statutory Organisation (Port of London Authority)

With regard to the proposed changes to neighbour letters and site notices, the Port of London Authority seeks confirmation that it will still be formally consulted on all applications in close proximity to all areas which fall within its navigational jurisdiction and land ownership, which includes the River Thames and River Lea.

As a general consultation body, the Port of London Authority would still be contacted in relation to relevant planning applications – the proposed change to neighbour letters and site notices does not affect this.

Statutory Organisation (Transport for London)

TfL welcomes the opportunity for early dialogue or being informally consulted at the early stages of plan preparation and the production of other policy documents to ensure that the evidence base is adequate for any issues which are relevant to TfL.

This response is noted.

Internal (Plan-Making)

Some councils are starting to webcast council meetings and Local Plan examination hearing sessions – this could be considered in the SCI.

It is understood that the Council’s Committee Services team are currently considering how to implement webcasting of committee meetings. If this technology is successfully implemented, it could potentially be expanded to future Local Plan examination hearings. Proposed change: addition of a paragraph in chapter 5 stating “We will consider the possibility of webcasting planning committee meetings and possibly local plan examination hearings”.

Internal (Plan-Making)

Will consultation on modifications be listed as a discreet stage in the Local Plan consultation

This is not felt necessary, as the modification process has already been adequately covered under the adoption stage of the relevant table.

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process?

Internal (Legal) The current SCI does not make it clear whether translation services are available for planning application consultations. This should be clarified in the new SCI.

The new SCI makes clear, under the bullet point on ‘outreach and accessibility’ in chapter 2, that people who do not speak English as a first language should be considered in the preparation of any planning consultation.

Internal (Legal) Paragraph 2 of the current SCI sets out the policies and legislation that have affected the production of the SCI. The Equalities Act 2000 is not listed here.

The relevant paragraph is no longer included in the revised SCI, as it was felt unnecessary to the purpose of the document. The Equalities Act was, however, considered in the preparation of the document, and this will be described in the Cabinet report for adopting the SCI.

Resident Locally focused Facebook advertisements could be used to alert people to planning consultations.

Geo-located Facebook adverts may be considered suitable for some planning consultations, for example plan making and pre-application engagement – the process would be easy to implement, though careful consideration will have to be given to the best use of resources, and this could be introduced on a pilot basis initially. A reference to this will be added to the text. Proposed change: addition to paragraph 5.4 stating “We will also consider the use of geo-targeted (i.e. seen only by people located within the borough or a specific locality) online advertisements for particularly important consultations, where it is considered an effective use of limited budgets”.

Resident More in-house digital skills would be of benefit to the Council, including possibly hiring more social media staff.

This comment is noted, and has been passed on the communications team to consider.

Resident The consultation document is disappointing – it lacks imagination and is in the typical impenetrable style that Tower Hamlets uses for its planning communications. I was hoping to

In order to be able to focus resources on the content and consultation of the SCI, it was decided that desktop publishing would be undertaken once the document was completed. The final adopted SCI will be professionally designed, to make it more readable and accessible. Every

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see a new style adopted that would indicate the Council is raising its game.

attempt has been made to make the language of the document as accessible as possible, while accepting that certain planning terms still have to be used in a document of this kind. The language will be reviewed again before adoption to ensure it is as clear as possible and avoid jargon.

Resident Principles – there is a need to ensure communication is proactive, extensive, user-friendly, professional, and attractive for the local population to engage with. Approaches should be borrowed from commercial marketing.

It is believed that these principles are included in chapter 2. Proactivity is covered under early engagement and outreach and accessibility; extensiveness is covered under appropriate scale and variety of methods; user-friendly is covered under clear and non-technical information and flexibility; professionalism is, we believe, covered under all the headings and expected as standard from Council officers; and attractiveness is again covered under clear and non-technical information and outreach and accessibility.

Resident Example of good consultation – Canada Water Masterplan. They hold lots of public engagement events, have kept me regularly updated by email for years, their material is easy to understand and navigate and visually attractive. The scale and seriousness reflects the scale of the development, and this approach should have been applied to the Isle of Dogs.

The example is noted and will be circulated to senior managers within the Planning Service as a suggestion of good practice.

Resident People who have not contributed to earlier stages of consultation should still be informed and given a chance to engage in later stages of consultation – later stages should not only be notified to those who previously responded.

The majority of consultation activities allow for this already. In the case of Local Plan examination hearings, this process is not under the Council’s control – it is set out in legislation. The inspector of a Local Plan can only allow speakers at the hearings based on previously submitted responses, which are taken as the starting point for a continuing discussion. At this stage, the Programme Officer only contacts those who have previously

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submitted comments, to continue to contribute further to the process; if the Council/Inspector were to contact and allow other people who had not previously submitted comments, this may raise new issues that would not have been considered in the same way as formally submitted comments and it may unfairly raise expectations that they would have a further chance to contribute.

Resident Social media use should be enhanced – there isn’t a dedicated social media feed that I can follow, so it’s hit and miss as to what is received.

The Council has some dedicated social media feeds, which have a Council-wide focus, rather than being specific to the planning service. We have considered the possibility of running social media feeds dedicated to planning matters in Tower Hamlets, but have concluded that we could achieve greater reach and a more varied range of residents through more effectively utilising the existing social media feeds to advertise planning consultations. This is discussed in chapter 5 of the SCI.

Resident Access to local papers is limited in some parts of the borough, and notices in newspapers shouldn’t be the only way the Council communicates.

Noted, and this is not the only way the Council communicates on planning issues – one of the purposes of the SCI is to set out a wider range of methods by which we will communicate.

Resident A weekly digest of applications, broken down by area or ward would be helpful – this could also update on decisions, appeal hearings, pre-application consultations, and general planning consultations.

This is a very useful point, and one the Council will explore. We will need to carefully consider the resource challenges which will have to be overcome before such a digest could be implemented, but it is believed that some form of update may be possible. At present it is possible to easily create a self-service report of applications received and decisions made, by week or by month for the whole authority or by ward, through the public access system at https://development.towerhamlets.gov.uk/online-applications/search.do?action=weeklyList

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Proposed change: addition of a paragraph to chapter 5 stating “The planning service will consider the creation of a regular planning newsletter or digest, which will provide summarised information about major planning applications and decisions, appeal hearings, pre-application consultations, and planning policy consultations. Careful consideration will need to be given to how this is implemented, to avoid consultation fatigue among recipients”.

Resident The Council’s website is atrocious – difficult to find out when an application is submitted, and then difficult to navigate the many documents included with an application. A regularly updated map showing the location of all development would be helpful. The search mechanism needs to be improved. The mechanism for signing up for updates needs to be improved. Some of the resources do not open on tablet computers. It is difficult to know what is currently going on with an application in terms of key dates. In my experience, people often do not submit online comments because of the problems with this system.

The problems that some residents have with the planning register website are noted. . The Council is in frequent contact with the external provider to ensure effectiveness. This provider makes regular updates to the system, which may improve functionality. These comments have been passed on to the team that deals with the public access system on the Council’s website, and they will consider whether to pass on further suggestions to the system provider. In particular, we are considering possible ways of improving the indexing of documents on large applications, which should make navigating the documents simpler. In terms of documents not opening on tablet computers – all documents are made available in pdf format, which should work on all electronic devices. If a file will not open at all, please contact the Council, as there may be a problem with the file. In terms of search functions, the weekly and monthly search functions can be useful, and can be limited to individual wards – this can be found

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at - https://development.towerhamlets.gov.uk/online-applications/search.do?action=weeklyList An interactive map of planning applications is already available at https://www.towerhamlets.gov.uk/lgnl/planning_and_building_ control/planning_applications/search_and_comment_planning_ applications.aspx This map is updated daily.

Resident Neighbour letters do not work when it comes to keeping the wider community informed, because they only go to very near neighbours. I am interested in development all along Westferry Road because of potential impact on traffic and public transport, but would only be notified about developments right next to me.

Neighbour letters are used as a primary means of notifying residents on planning applications along with site notices, press notices and website information. The Council’s current and proposed SCI go beyond the statutory minimum requirement to notify adjoining occupiers by adopting wider consultation boundaries. While the point about areas of local interest is noted, a balance needs to be struck, particularly as the Council deals with around 3,000 applications of all types each year. For wider areas of interest, residents can use the search function on the public access system to focus in on types of application, by ward and within date parameters. Searches can be saved to make repeat searches straightforward.

Resident Consultation needs to discuss the demolition and construction phases as well as the final development, as these phases can have a large impact on daily life - the public should be consulted on this aspect.

The discussion of demolition and construction phases is not excluded from current consultation practice, and the Local Plan contains policies which aim to reduce the impact of these phases. As the SCI covers the process of consultations rather than prescribing the exact content of them, it would be inappropriate to alter the text to reference this.

Resident The Council’s current policy about what I will be informed of after registering interest in a

If you have submitted comments on a pre-application proposal, application or plan, you will be kept updated. The wording of Council

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development is unfathomable, and I don’t understand if I will be kept informed or not after submitting comments.

planning documents is regularly reviewed to try to ensure they are as clear and accessible as possible. Residents can view applications and register to receive notifications if the plans are amended or a decision is made.

Resident The Council could improve communication about the stage a proposal or plan has reached, and summarise the responses the Council has received from interested parties and local people.

The Council published consultation statements (such as this one) after all planning policy consultations, summarising the consultation process and responses received. Comments made on planning applications are publically viewable, and summarised in committee reports. Comments at pre-app consultations should be reflected in the planning application, usually in the Design & Access statement, although a more explicit reference to the expectation that this will be done could be included in the SCI text. Proposed change: addition of new paragraph in Pre-Application Advice and Consultation section. “Developers should clearly explain how comments received during a pre-application consultation process have been taken into account and influenced the submitted application. This can be done in a number of ways, but is often included in the Design & Access Statement, Consultation Report or Planning Statement.”

Resident Residents’ Associations and Right to Manage groups from private leasehold estates should be given the same status in consultations as Tenants’ Associations on social housing. They should be able to opt in to become a formal body to be consulted.

Tenants’ Associations do not have any formal or special status in consultations. Both Residents’ and Tenants’ Associations, if they wish to be included in planning consultations, should ask to be placed on the planning policy consultation database, or should use the search tools available on the online planning register to keep track of planning applications coming forward in their area.

Resident The council could do a better job of clearly The SCI is aiming to do this. The language of the SCI will be reviewed

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explaining the different stages of consultation and what can and can’t be consulted on at each stage – using less legalese.

before adoption to make it as accessible as possible. Please provide any specific suggestions should you have them.

Resident Almost all of the Council’s communication on planning is in dry, legalistic, impenetrable language – should use clear, plain English.

The use of clear English is a principle of the SCI. The wording of planning documents published by the Council is regularly reviewed to try to make them as accessible as possible. However, in some cases, the use of technical terms is necessary for statutory reasons.

Resident Unclear about the role of pre-app consultation, and why it is the best time to get involved – I go to lots of them, but never know if my comments are taken into account, and never get informed when the application is then submitted. Developers do a very poor job of advertising these pre-app consultations, and their behaviour varies widely – from listening, to being dismissive.

As the Council cannot make pre-application consultation mandatory, much of the responsibility here is on the developers themselves. The new SCI aims to provide guidance as to how a pre-consultation application can be improved. Pre-application consultations could also be included in the proposed newsletter, if this is implemented. Proposed change: add the word ‘meaningful to alter paragraph 4.9 to read “…the Council strongly encourages meaningful engagement…’.

Resident Tower Hamlets should encourage planning inspectors to provide a slot in appeal hearings for local residents to speak.

Time for residents to speak can already be allotted during hearings, but only at the Inspector’s discretion – the Council has no additional power to require this, but is happy for residents to have this time to speak if the Inspector allows it.

Resident The accessibility of planning consultations needs to be improved. Parts of the borough, such as the west of the Isle of Dogs, are not well served by libraries, so making documents available in libraries should be the bare minimum. Consultation events need to take place in the community, at a range of times and locations.

This is a principle of the new SCI.

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Resident 3D map images should be made available to help people understand the size and scale of developments.

The Council is currently exploring the use of 3D imaging in planning applications. Proposed change: addition of a paragraph to chapter 5 stating “We are currently exploring the use of 3D imaging in planning applications to demonstrate the height, scale and massing of applications in context, and will consider how best to use this technology when engaging with the public”.

Resident The proposed weekly digest and the improved website should include more information on listed buildings at risk and how the Council is managing the risk.

This is noted, and information on this issue could potentially be included in the proposed newsletter or digest, if it is implemented. In addition, more information on heritage at risk can be found at https://historicengland.org.uk/advice/heritage-at-risk/.

Resident Big developers should each be asked to make a small contribution of, for example, £5,000 to support improved public consultation. This will benefit developers because better coordination will save everyone money, result in a better built environment, and make residents less upset with the Council and developers.

Under current legislation, the Council has no power to require this from developers.

Community organisation (Globe Town Assembly)

We support the commitment to the four priority outcomes in paragraph 2.1; the identification that pre-app stage is the best time to get involved; the encouragement of developers to engage in pre-app consultation; and the use of QR codes on site notices and neighbour letters.

This is noted and the support is welcome.

Community organisation

We recognise the Council has limited resources and therefore understand the need to reduce

This is noted.

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(Globe Town Assembly)

consultation boundaries.


The planning portal tool would be more useful if it were possible to request automatic notification of planning applications within a specific area, rather than having to search manually. This will be particularly important if consultation boundaries are to be reduced, and improvements to the website should be made before the boundaries are reduced.

It is possible to use the planning public access system to save a search with particular location, application type or date criteria, which makes re-running the search straightforward, or to use the weekly and monthly search function within a particular ward at https://development.towerhamlets.gov.uk/online-applications/search.do?action=weeklyList. In addition, an interactive map of planning applications can be found at https://www.towerhamlets.gov.uk/lgnl/planning_and_ building_control/planning_applications/search_and_comment_planning_ applications.aspx. The public access system has a help page, however there is an opportunity to make this information more accessible and prominent on the planning website.


The suggestion of a fortnightly email summarising key developments in an area would be of interest – community organisations such as ourselves could then share these with our members.

The Council will explore this option in more detail. We will need to carefully consider the resource challenges which will have to be overcome before such a digest could be implemented, but it is believed that some form of update may be possible. Proposed change: addition of a paragraph to chapter 5 stating “The planning service will consider the creation of a regular planning newsletter or digest, which will provide summarised information about major planning applications and decisions, appeal hearings, pre-application consultations, and planning policy consultations. Careful consideration will need to be given to how this is implemented, to avoid consultation fatigue among recipients”.

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The Globe Town Assembly would like to be added to the planning policy database and would like to be listed as a General Consultation Body.

The Assembly has been added to the planning policy database. Rather than refer to the Assembly by name in Appendix A (as the list would become very long if all relevant community groups were listed by name), a change will be made to emphasise that other community groups can fall under the relevant bullet point. Proposed change: add “other community groups that express interest” to the penultimate bullet point under ‘General Consultation Bodies’.

Business organisation (Canary Wharf Group)

We endorse the Council’s commitment to engaging with local communities, organisations and businesses. Canary Wharf Group shares this aim. We are in support of the Council’s consultation principles. We welcome the Council’s ambition to increase the use of digital technologies. On the whole, Canary Wharf Group is supportive of the revised SCI.

This support is noted and welcomed.

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EQUALITY ANALYSIS QUALITY ASSURANCE CHECKLIST

Name of ‘proposal’ and how has it been implemented (proposal can be a policy, service, function, strategy, project, procedure, restructure/savings proposal)

Adoption of Statement of Community Involvement

Directorate / Service

Place

Lead Officer

Steven Heywood

Signed Off By (inc date)

Marissa Ryan-Hernandez, 29.1.2018

Summary – to be completed at the end of completing the QA (using Appendix A) (Please provide a summary of the findings of the Quality Assurance checklist. What has happened as a result of the QA? For example, based on the QA a Full EA will be undertaken or, based on the QA a Full EA will not be undertaken as due regard to the nine protected groups is embedded in the proposal and the proposal has low relevance to equalities)

Example Proceed with implementation As a result of performing the QA checklist, the policy, project or function does not appear to have any adverse effects on people who share Protected Characteristics and no further actions are recommended at this stage. The proposal requires that equalities issues be considered during consultations on planning matters, but there are no identified impacts on the nine protected groups that stem directly from the proposal.

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Stage

Checklist Area / Question

Yes / No /

Unsure

Comment (If the answer is no/unsure, please ask the question to the SPP Service Manager or nominated equality lead to clarify)

1 Overview of Proposal

a Are the outcomes of the proposals clear? Yes The proposal is for the adoption of an updated Statement of

Community Involvement, which sets out how the Council will engage with stakeholders on planning matters.

b

Is it clear who will be or is likely to be affected by what is being proposed (inc service users and staff)? Is there information about the equality profile of those affected?

Yes The impact of the proposal will be on all potential stakeholders for engagement on planning matters in the borough, as the proposals in the SCI apply uniformly. The Statement of Community Involvement recognises the need for planning consultations to explicitly consider how to consult with ‘hard to reach’ or otherwise underrepresented groups, including people with protected characteristics. This is included in the currently adopted SCI, and does not represent a change in policy. Therefore, there are no identified impacts on people with protected characteristics. The SCI is in conformity with all relevant planning legislation and regulations.

2 Monitoring / Collecting Evidence / Data and Consultation

a Is there reliable qualitative and quantitative data to support claims made about impacts?

N/A There are no identified impacts on people with protected characteristics, so no claims about impacts are made.

Is there sufficient evidence of local/regional/national research that can inform the analysis?

N/A There are no identified impacts on people with protected characteristics.

b

Has a reasonable attempt been made to ensure relevant knowledge and expertise (people, teams and partners) have been involved in the analysis?

Yes A formal public consultation was held for eleven weeks on the SCI document; the Plan Making, Development Management and Planning Technical Support teams have all been involved in its production; and the Council’s reporting cycle for adoption will now allow for further input.

c

Is there clear evidence of consultation with stakeholders and users from groups affected by the proposal?

Yes A formal public consultation was held for eleven weeks on the SCI document, and was open to representations from all interested parties. There is no statutory consultation period for SCIs, but this was a longer consultation than is usually

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held on this type of document, and included five events for stakeholders to attend to discuss the proposals. A consultation statement has been produced, setting out the consultation process, the representations received and the Council’s response to them.

3 Assessing Impact and Analysis

a Are there clear links between the sources of evidence (information, data etc) and the interpretation of impact amongst the nine protected characteristics?

N/A There are no identified impacts on people with protected characteristics.

b

Is there a clear understanding of the way in which proposals applied in the same way can have unequal impact on different groups?

Yes There is an acknowledgement in the SCI that planning consultations need to give particular consideration to engaging ‘hard to reach’ or otherwise underrepresented groups, and that without this consideration, these groups are likely to remain underrepresented.

4 Mitigation and Improvement Action Plan

a Is there an agreed action plan?

N/A There are no identified impacts on people with protected characteristics, and therefore no mitigation has been identified.

b

Have alternative options been explored

N/A Because no mitigation actions have been identified as necessary, alternative options for mitigation have not been assessed. The SCI is clear that equalities issues must be considered in planning consultations – the only alternative to this would be to not mention such issues in the SCI, which would be unacceptable in terms of the Council’s requirement to consider equalities.

5 Quality Assurance and Monitoring

a

Are there arrangements in place to review or audit the implementation of the proposal?

Yes Each planning policy consultation must lead to the production of a consultation statement, which sets out the process used for consultation, and the results of the consultation. This includes identifying any areas for improvement. Pre-application consultations on proposed developments will also be expected to explain how consultation took place and what the results were. The SCI will be reviewed within the next five years after adoption.

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b

Is it clear how the progress will be monitored to track impact across the protected characteristics??

Yes Consultation statements should set out how ‘hard-to-reach’ or otherwise underrepresented groups have been considered in planning a consultation. This includes identifying any areas for improvement. At the stage of submitting any planning proposal for consideration that has been consulted on under the policies of the SCI, the Council will consider the impact of the proposal on people with protected characteristics, and how the consultation considered the needs of these people.

6 Reporting Outcomes and Action Plan

a Does the executive summary contain sufficient information on the key findings arising from the assessment?

N/A There is no executive summary.

Appendix A (Sample) Equality Assessment Criteria


As a result of performing the QA checklist, it is evident that due regard is not evidenced in the proposal and / or a risk of discrimination exists (direct, indirect, unintentional or otherwise) to one or more of the nine groups of people who share Protected Characteristics. It is recommended that the proposal be suspended until further work or analysis is performed – via a the Full Equality Analysis template


Red

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As a result of performing the QA checklist, the policy, project or function does not appear to have any adverse effects on people who share Protected Characteristics and no further actions are recommended at this stage.


Green:

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Cabinet Decision

24 April 2019

Report of: David Courcoux, Head of the Mayor’s Office


Nominations to Outside Bodies 2018/19

Lead Member Mayor John Biggs

Originating Officer(s) Matthew Mannion, Head of Democratic Services


Key Decision? No


N/A


A dynamic outcomes-based Council using digital innovation and partnership working to respond to the changing needs of our borough

Executive Summary

It is the responsibility of the Mayor to nominate representatives to certain Outside Bodies on behalf of Tower Hamlets Council. Paragraph 3.4 of the report lists two proposed appointments to Outside Bodies for the Mayor to consider. Although all appointments are reviewed regularly, they are, unless stated elsewhere in this report, valid until such time as they are amended or renewed by a Mayoral decision. Paragraph 3.6 includes a list of Outside Bodies for which nominations are recommended to be discontinued following the recommendation of a review by the General Purposes Committee.


1. Agree the nominations to outside bodies as shown in Paragraph 3.4.

2. Agree to discontinue nominations to the outside bodies as shown in Paragraph 3.6 as proposed by the General Purposes Committee review.

1. REASONS FOR THE DECISIONS 1.1 Having representatives on outside bodies increases the Council’s

engagement with the local community and improves its potential to offer leadership and guidance in relation to activities taking place in the borough.

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Agenda Item 6.7

1.2 A review of the Councils outside bodies was conducted by the General

Purposes Committee in 2018 and recommendations were made to the Mayor, including a list of outside bodies to which the Committee felt the Council should no longer appoint representatives.


2.1 The Mayor could decide not to make appointments to outside bodies at all.

However, this is not recommended as it would reduce the Council’s opportunity to be involved in and to support good work within the community and it would also reduce the Council’s leadership opportunities. There are also a number of bodies where the Council is required or expected to provide a representative.

2.2 The Mayor could decide to continue nominating representatives to the outside bodies listed in Paragraph 3.6. However, this is not recommended as it would be contrary to the recommendation of the General Purposes Committee, which followed a full review of both the process of outside body nominations and the bodies themselves.

3. DETAILS OF THE REPORT 3.1 Participating in the work of outside bodies is an important part of the role of

elected Members but is different in nature from other aspects such as being a member of a local authority executive or sitting on regulatory committees. In some cases it will involve actively representing and defending the authority’s interests on local authority associations. In others it will involve becoming a trustee of a charity or a director of a company limited by guarantee. In this case Members have a duty to act in the best interests of the organisation to which they have been appointed rather than exclusively pursue the authority’s interests. There are potential tensions in carrying out this role effectively. To this end guidance will be sent to all those nominated to outside bodies.

3.2 A key part of this role is ensuring that information about the activities of outside bodies is communicated to the Council. Much of this may take place through day to day contact with colleagues or with officers responsible for that area of work.

3.3 This is the fourth round of nominations to Outside Bodies in 2018/19. The previous rounds of nominations were made as Mayoral Decision Numbers 181 to 183.

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3.4 The nominations to be made to Outside Bodies are:

Outside Body Mayor or Council Nomination

Nominees permitted

2018/19 nominee(s)

Stepney Relief in Need Charity

Mayor 3 Councillor James King; Councillor Dipa Das

Docklands Sailing and Water Sports Centre

Mayor 1 +1 deputy

Councillor Bex White

3.5 At the request of the Mayor, a review of the Councils outside bodies was

undertaken by the General Purposes Committee in 2018. The Committee made several recommendations to the Mayor, including a recommendation that the Council should no longer nominate representatives to some outside bodies. In addition, some outside bodies are no longer operational or have changed their governing documents and so no longer allow for LBTH representatives. The Mayor, having considered the above, has indicated he no longer wishes to nominate representatives to some bodies previously on the Council’s outside bodies list.

3.6 The Outside Bodies proposed to be removed from the list are

Cultural Industries Development Agency

Green Candle Dance Company

Merchant Navy Welfare Board

The Henderson Charity

Women’s Library Council

Jagonari Women’s Education and Resource Centre

East London Nursing Society Trust. 4. EQUALITIES IMPLICATIONS 4.1 Nominating representatives to outside bodies increases the Council’s

engagement with the local community and improves its potential to offer leadership and guidance in relation to activities taking place in the Borough.




Consultations,


Risk Management,

Crime Reduction,

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Safeguarding,

Data protection. Risk Management Implications 5.2 Where appropriate it is important that any training/support needs of new

appointees are identified by the bodies concerned and that appropriate training and support is delivered.

5.3 The nomination of representatives to outside bodies enables the Council to strengthen links with the community. The nomination of representatives also contributes to the Council’s leadership role in the community.

6. COMMENTS OF THE CHIEF FINANCE OFFICER 6.1 There are no direct financial implications arising from this report. 7. COMMENTS OF LEGAL SERVICES 7.1 Pursuant to section 9D(2) of the Local Government Act 2000, any function of

the Council which is not specified in regulations is to be the responsibility of the Council’s executive under executive arrangements. The relevant regulations which specify non-executive functions are the Local Authorities (Functions and Responsibilities) (England) Regulations 2000 (“the Functions Regulations”).

7.2 The Functions Regulations specify a category of functions which may be (but need not be) the responsibility of a local authority’s executive. These are sometimes referred to as local choice functions. Included in the category of local choice functions is the appointment of any individual to any body, other than the Council or a joint committee, and the revocation of any such appointment. The Council’s Constitution (part 3.2.2) specifies that responsibility for such appointments lies with the Mayor if the appointment is made in relation to or in support of an executive function.

7.3 All of the appointments in paragraphs 3.4 and 3.6 relate to local choice functions and are the responsibility of the executive. The Mayor therefore has responsibility for these appointments under the Constitution.

7.4 When considering appointments or the approach to be taken to appointments, the Council must have due regard to the need to eliminate unlawful conduct under the Equality Act 2010, the need to advance equality of opportunity and the need to foster good relations between persons who share a protected characteristic and those who don’t (the public sector equality duty). It is important to be satisfied that any process followed is supportive of equal opportunity.

____________________________________

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Review of External Appointments, General Purposes Committee, 8 February 2018

Mayoral Decision 181 - Nominations to Outside Bodies 2018/19 – Tranche 1, Mayor's Executive Decision Making, Thursday, 30th August, 2018.

Mayoral Decision 182 - Nominations to Outside Bodies 2018-19 Tranche 2, Mayor's Executive Decision Making, Monday, 1st October, 2018

Mayor's Executive Decision Making 183 - Nomination to Outside Bodies 2018-19 - Tranche 3, Monday, 29th October, 2018.

Appendices

None Background Documents – Local Authorities (Executive Arrangements)(Access to Information)(England) Regulations 2012

NONE. Officer contact details for documents: Joel West, Senior Committee Officer, 020 7364 4207

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