cabinet 29 june 2011 report of quality of life portfolio holder...

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CABINET 29 th June 2011 Report of Quality of Life Portfolio Holder Landlord Anti Social Behaviour Policy RECOMMENDATIONS That Cabinet; Approve the proposed Landlord Anti-Social Behaviour (ASB) Policy Agree the action plan for the achievement of accreditation under the House- Mark and Social Landlords Crime and Nuisance Group Anti Social Behaviour Accreditation Scheme Approve in principal the integration on a full time basis of a landlord services staffing resource within the Community Safety Hub subject to further reports to the Appointments and Staffing Committee PURPOSE Cabinet are asked to approve the Landlord Services Anti Social Behaviour Policy shown at Annex One. This policy should be read within the context of the draft Corporate Anti Social Behaviour Policy shown elsewhere on the Cabinet agenda. The particular contractual and regulatory obligations which relate to Council tenancies require the Council to have a clearly stated policy and procedures in its role as a landlord. However, these are complementary to and support the aims and objectives of the Corporate Anti Social Behaviour policy in every respect. Following consultation with tenants the Council is committed to the achievement of the House- Mark and Social Landlords Crime and Nuisance Group Anti Social Behaviour Accreditation Scheme. An assessment has been made of the Council’s current level of service in relation to the standard and Cabinet are asked to approve an action plan shown at Annex Two for the achievement of accreditation by April 2012. A key feature in improving the services provided to tenants and other customers will be the full integration of the Landlord services team into the Community Safety hub. Although a member of the estates management team currently has a hot desk and attends routine morning briefings at the police station this is not a full time presence and enquiries regarding Anti Social Behaviour from tenants are not routed directly through the hub. An assessment has been undertaken, supported by external consultants, to identify the most effective means of achieving full integration and a report is provided at Annex Three detailing the outcomes of this assessment. This report identifies the need for a dedicated staffing resource to be located within the Community Safety Hub to provide greater capacity and effectiveness for the Council is dealing with Anti Social Behaviour. Cabinet are asked to approve this proposal subject to a planned review of the Landlord Services staffing structure later in the year. RESOURCE & VALUE FOR MONEY IMPLICATIONS It is anticipated that the proposals contained within this report will enable a greater amount of legal work to be undertaken in house. Therefore savings arising from a reduction in the level of Agenda Item 9

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Page 1: CABINET 29 June 2011 Report of Quality of Life Portfolio Holder …democracy.tamworth.gov.uk/documents/s390/9 Landlord ASB... · 2016-02-01 · Accreditation Scheme by 2012. Despite

CABINET

29th June 2011

Report of Quality of Life Portfolio Holder

Landlord Anti Social Behaviour Policy RECOMMENDATIONS

That Cabinet;

• Approve the proposed Landlord Anti-Social Behaviour (ASB) Policy • Agree the action plan for the achievement of accreditation under the House-

Mark and Social Landlords Crime and Nuisance Group Anti Social Behaviour Accreditation Scheme

• Approve in principal the integration on a full time basis of a landlord services staffing resource within the Community Safety Hub subject to further reports to the Appointments and Staffing Committee

PURPOSE Cabinet are asked to approve the Landlord Services Anti Social Behaviour Policy shown at Annex One. This policy should be read within the context of the draft Corporate Anti Social Behaviour Policy shown elsewhere on the Cabinet agenda. The particular contractual and regulatory obligations which relate to Council tenancies require the Council to have a clearly stated policy and procedures in its role as a landlord. However, these are complementary to and support the aims and objectives of the Corporate Anti Social Behaviour policy in every respect. Following consultation with tenants the Council is committed to the achievement of the House-Mark and Social Landlords Crime and Nuisance Group Anti Social Behaviour Accreditation Scheme. An assessment has been made of the Council’s current level of service in relation to the standard and Cabinet are asked to approve an action plan shown at Annex Two for the achievement of accreditation by April 2012. A key feature in improving the services provided to tenants and other customers will be the full integration of the Landlord services team into the Community Safety hub. Although a member of the estates management team currently has a hot desk and attends routine morning briefings at the police station this is not a full time presence and enquiries regarding Anti Social Behaviour from tenants are not routed directly through the hub. An assessment has been undertaken, supported by external consultants, to identify the most effective means of achieving full integration and a report is provided at Annex Three detailing the outcomes of this assessment. This report identifies the need for a dedicated staffing resource to be located within the Community Safety Hub to provide greater capacity and effectiveness for the Council is dealing with Anti Social Behaviour. Cabinet are asked to approve this proposal subject to a planned review of the Landlord Services staffing structure later in the year. RESOURCE & VALUE FOR MONEY IMPLICATIONS It is anticipated that the proposals contained within this report will enable a greater amount of legal work to be undertaken in house. Therefore savings arising from a reduction in the level of

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external legal support will provide additional funding to meet any future costs. These costs may include premises costs, additional training and publicity. LEGAL/RISK IMPLICATIONS The Council, due to its contractual and regulatory obligations as a Landlord, is required by the Anti Social Behaviour Act 2003 to have Policy and Procedures for dealing with Anti Social Behaviour as this relates to Council tenancies. This compliments and supports the over-arching corporate policy and recognises the multi-agency response required to respond across a range of tenures. The management of Anti-Social Behaviour is an area of high risk. This is not least because of the sensitivity of such issues and the vulnerability of many customers. Clear polices and procedures are essential to ensure the robust assessment of the vulnerability and support needs of those affected by all types of anti social behaviour. SUSTAINABILITY IMPLICATIONS The Council has committed, via the Landlord Delivery Plan, to achieve recognition under the Housemark and Social Landlords Crime and Nuisance Group Anti Social Behaviour Accreditation Scheme by 2012. Despite the changing political, social and economic environment there is still a requirement from the CLG for Landlords to have clear standards in relation to tackling anti social behaviour. Having consistent and ‘joined up’ services for tackling anti social behaviour is a corporate and strategic ambition. An Equality Impact Assessment of the proposals contained in this report has been completed and is attached at Annex Four. BACKGROUND & CONSULTATION In 2010/11 the Landlord Estate Management Team dealt with 658 incidents of Anti Social Behaviour. Approximately 80% of these related to noise nuisance and around 5% resulted in formal legal proceedings, i.e. injunction, possession; demotion. The Estates Management Team have focused on early intervention and working in a multi-agency setting to ensure legal action is a last resort. During the last twelve months thirty Acceptable Behaviour Contracts have been signed with tenants and residents. These agreements, developed in partnership with the police service are intended to promote good behaviour and acceptable conduct. To meet commitments made in the Landlord Services Delivery Plan work has been undertaken in recent months to:

1. draft a Landlord Anti Social Behaviour Policy together with a set of procedures (Annex One)

2. undertake a gap analysis and produce a action plan in relation to the House-Mark and Social Landlords Crime and Nuisance Group ASB Accreditation Scheme (Annex Two)

3. provide proposals for the integration of the landlord services team to fully integrate within the co-located hub based at the police station to provide a joined up and seamless approach to risk managing and problem solving cases and anti social behaviour. (Annex Three)

Consultation on the proposals has been undertaken with tenants and the policy fulfils obligations contained within the agreed Local Offers, which were developed with tenants. In accordance with the localism agenda, tenants will continue to scrutinise progress with the action plan and service delivery through the Tenant Consultative Group and the Performance Chamber. The Portfolio Holder for Quality of Life is also a member of the Landlord Services

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Project Board overseeing the delivery of the Landlord Services Delivery Plan. A workshop, facilitated by Landlord Services, was held in 2010 with a range of stakeholders. This informed the gap analysis and the action plan attached. In addition the results from the independent status survey were received in April 2011 and satisfaction with the landlord response to Anti Social Behaviour is improving (from 50% in 2008 to 61% in 2011). The actions contained in the attached action plan will further improve satisfaction. An action plan for the achievement of accreditation is shown at Annex Two. In summary this action plan focuses on the following areas for improvement:- Building Block Key Strengths Key Areas for Improvement Demonstrates Leadership & Strategic Commitment

Corporate ambition to ASB – TCSP 2010-13 Corporate ASB policy Commitment in the 2009-2012 Landlord Delivery Plan measure through Landlord Co-regulatory framework Political scrutiny through Community & Well-being, together with Cabinet Updates

Tenant and Members support for the ASB service Improvement Plan Evidence of routine challenge by Tenants and Members

Has a performance culture that leads continual improvement

Clear Landlord PIs and Local offers around ASB Orchard module in development for effective case management

Training Plan linked to ASB service improvement plan Robust benchmarking required via HQN Call Handling to be mapped corporately

A diverse range of tenants can easily access the service

Range of access routes to the service include WEB, face to face etc Status Survey shows evidence of improving satisfaction with landlord ASB Mystery shopping and satisfaction survey undertaken by Tenant Regulatory team EIA routinely completed and reviewed

Map call handling capabilities in relation to vulnerability and risk corporately Explore options around dedicated free phone ASB hotline corporately including out of hours Consistent management of cases through routine audit and checking

Tenants are encouraged to influence how the service is delivered

TP strategy 2010-2012 Landlord Co-regulatory framework including TCG Media and Comms Plan Satisfaction Diary and Plans

Consideration should be given for a tenant service improvement group on ASB

Protects through swift enforcement action

Landlord uses range of tools Case studies available showing possession as a last resort Examples of urgent injunctive relief Strong partnerships with a range of partners including the police

Dedicate resources to the co-located hub Evidence of cases being monitored based on clear trigger points from IT system

Provide Support for victims and witnesses

Landlord victim and vulnerability matrix in place Budget for victim support measures Referral arrangements for Tamworth ASB & Victim Support champion

Procedures need to be reviewed in relation to victim support Victim Support Protocol to be developed

Tackles the causes and prevents ASB

Reviewing Tenancy Agreement Allocations Policy deals with suspension for ASB Local Lettings plan to sustain tenancies Tenancy visits being expanded under handyperson property MOT service

Tenants Handbook to be developed More focused use of CCTV and surveillance methods to deter crime Link to health colleagues to monitor mental health impact Focused business plan on wider

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New tenancy visit in place Some Diversionary activities in place

regeneration schemes and investment in housing through decency and environmental improvements

Encourages individual and Community responsibility

Estate Walkabouts and Inspections in plan Local offers re-issued with clear service standards Range of community events and funs days Intergenerational initiatives at sheltered schemes (16-18yr old on NVQ raining for beauty)

Explore use of good neighbour agreements Look at community impact assessments Use of incentive schemes to reward good behaviour

Ensure the approach to VFM is bedded in.

Clearly identified budget for ASB External use of mediation services at low cost

Value for Money statement and benchmarking required on Landlord ASB costs Assess VFM costs of mediation and legal services

Integration with the Community Safety Hub Already, staff in the estate management team, hot desk and attend routine morning briefings at the police station. Under the Safer Estates Framework housing staff have always worked closely with the community safety team and police colleagues, as well as range of other specialist agencies and partners, to tackle and deter anti social behaviour. The creation of the co-located hub has presented a real opportunity to not only integrate geographically, but to have a structured and shared multi-agency approach to problem solving and risk management of cases. Already, housing officers have been able to escalate and receive prompt resolution to ongoing issues in relation to neighbour nuisance in a way that was not possible previously. The functionality report shown at Annex Three undertaken with the support of external consultants identifies that, based on the Council’s ambitions and national standards current staffing resources dealing with Anti Social Behaviour are insufficient. The report recommends the creation of a specific staffing resource in the form of a dedicated officer to be

Based at the co-located hub, managed under the landlord team, responsible for all legal and serious case work

Champion and facilitate the work around the action plan to improve standards and achieve accreditation of the ASB service.

Appointments & Staffing Committee have already approved Phase One of a restructure of landlord services management team which has included the creation of a tenancy sustainment team. As part of this first Phase of organisational change savings in management costs have been identified for potential reinvestment in front line service provision. As part of the second Phase of organisational change further reports will be submitted to Appointments and Staffing committee to consider the creation of a staffing resource to provide the capacity for the Council’s ambitions in relation to Anti Social Behaviour Services and the development of the collocated hub. Such proposals will be informed by the outcomes of the Transforming Tamworth Project.

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Tamworth Borough Council Landlord Services

Anti Social Behaviour Policy Version 3 – 6th June 2011

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Tamworth Borough Council

Landlord Services Anti Social Behaviour Policy Statement

June 2011 1. Introduction and statement of approach to anti social behaviour

2. Statutory and regulatory obligation

3. Definition of anti social behaviour

4. Service standards

5. Leadership and strategic commitment

5.1 Our values, objectives and commitment

5.2 Our partners and sharing information

5.3 Our performance

6. An accessible and accountable anti social behaviour service

6.1 Access to the service

6.2 Publicising our service

6.3 Accountable to our tenants

7. Prevention and early intervention

7.1. Allocations and new tenancies

7.2. Prevention of anti social behaviour

7.3. Early intervention

8. Support for victims and witnesses

9. Prompt enforcement action

9.1. Enforcement

9.2. Casework

9.3. Gathering evidence

9.4. Closing cases

10. Value for money services

11. Individual and community responsibility

12. Protecting our staff

13. Training our staff

14. Complaints

15. Review of the Policy

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1. Introduction and statement of approach to Anti Social Behaviour

This Landlord Services Anti Social Behaviour (ASB) Policy Statement supports the Council’s corporate commitment to ensure that Anti Social Behaviour is dealt with quickly and effectively.

The purpose of establishing a Landlord Services ASB policy is to identify for the benefit of our tenants and partners our approach to dealing with ASB as a landlord and what tenants can expect from Tamworth Borough Council Landlord Services if they are affected by ASB and report the problem to us.

We are working to reduce ASB across the Borough. We are committed to supporting victims and witnesses of ASB and using all available powers and means to tackle the issue by a combination of prevention, support, diversion and legal enforcement where a perpetrator does not change their behaviour.

Landlord Services will develop and maintain procedures for the effective handling of ASB complaints and work closely with colleagues in other departments within the Council to achieve a satisfactory outcome for the complainant and the community.

2. Statutory and regulatory obligations

Tamworth Borough Council is required by the Anti Social Behaviour Act 2003 to publish a statement of its policies and procedures as a local authority landlord for dealing with anti social behaviour. We will prepare a summary of our current policy and procedures for dealing with ASB and this will be available to tenants and members of the public.

This Landlord Services ASB Policy Statement represents the approach of the council as a landlord. It is not intended to be a statement of the whole approach of the council to tackling ASB. For information on what the council is doing overall to tackle ASB in Tamworth please refer to the Tamworth Borough Council Corporate ASB Policy Statement or contact the Community Safety Team.

To demonstrate to our tenants and our regulators that we are determined to take positive action to deal effectively with all forms of anti social behaviour on our estates we are committed to developing high quality services that exceeds the requirement of the Chartered Institute of Housings ASB Standard and achieving external accreditation of our ASB services.

3. Definition of Anti Social Behaviour

Tamworth Borough Council uses the following definition of anti social behaviour based on the Crime and Disorder Act 1998:

“Behaviour that is likely to cause harassment, alarm or distress to one or more persons not of the same household”.

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We also accept that there are other definitions of anti social behaviour such as conduct which is capable of causing a nuisance or annoyance. A broad definition of anti social behaviour is difficult but what is important to us in defining anti social behaviour is the effect of the behaviour on members of the community.

Examples of behaviour considered to be anti social include:

• Threatening and intimidating behaviour

• Using abusive or insulting words including graffiti

• Behaviour or language which constitutes a hate incident or crime

• Damaging or threatening to damage another person’s home or possessions

• Noise arising from nuisance neighbours

• Rubbish dumping

• Using Council properties for any criminal, immoral or illegal purpose

4. Service standards

We have clear service standards when dealing with anti social behaviour which have been developed with our tenants. We have a number of national standards that we have to meet that are set out by our regulator. In order to provide the best possible service to our tenants we have developed ‘Local Offers – our customer promise to you’

All our services standards as a landlord are set out in our publication ‘Tamworth’s Local Offers – our customer promise to you’. We have set out below and throughout this document the service standards that tenants can expect from us when dealing with ASB. We will also set out these standards in a separate information leaflet for tenants.

5. Leadership and strategic commitment

We will demonstrate strong leadership and a commitment to tackling ASB.

5.1 Our values, objectives and commitment

We have a shared vision with our public and private sector partners of “One Tamworth Perfectly Placed”

To support the delivery of this vision we have established two strategic priorities and work streams to deliver them. Strategic Priority two is “to be healthier and safer in Tamworth”

To achieve this, we will:

• Address the causes of poor health in children and young people;

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• Improve the health and well-being of adults by supporting them to live active, independent lives;

• Reduce the harm and wider consequences of alcohol abuse on individuals, families and society;

• Implement ‘Total Place’ solutions to tackling crime and ASB in designated localities; • Develop innovative early interventions to tackle youth crime and ASB; and • Create an integrated approach to protecting those most vulnerable in our local communities

We have a Landlord Delivery Plan that includes challenging targets to improve our ASB service. We will not tolerate ASB and dealing with ASB is a core housing management activity for Landlord Services for which we will allocate sufficient resources to ensure we deliver our promise to our tenants.

When we receive a report of ASB we will:

• Assess the risk and vulnerability of the victim and prioritise the case accordingly

• Ensure reports are treated confidentially when requested and take a proactive approach and deal promptly with the complaint and attempt to resolve the problem at the earliest opportunity.

• Encourage victims and witnesses to work with the Council and other agencies and prioritise actions based on an assessment of the risk to individuals and the long term sustainability of our communities.

• Be assertive in our approach and take appropriate action against perpetrators

• Tackle ASB through effective co-ordination of Council services and by working together and with external partners to develop effective measures to prevent ASB and divert individuals away from problem behaviour.

5.2 Our partners and sharing information

The Council cannot always resolve ASB complaints in isolation. Often incidents of ASB are complex and require the input of a number of different agencies. The Tamworth Community Safety Partnership is a group made up of the Council, Police, Primary Care Trust, Fire and Rescue Service and other agencies that together work to reduce crime and disorder and improve community safety in the Borough of Tamworth.

As a key partner the Council actively contributes to the work of the partnership through a specialist Community Safety Team. In order to ensure a co-ordinated approach to the issue of anti social behaviour the Community Safety Partnership set shared objectives for all partners and facilitate joint working with external agencies and all Council services through regular joint operational meetings and the establishment of an ASB Action Group to address the behaviour of the most persistent ASB offenders in the Borough.

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The Council adopts the general principle that information should only be disclosed to individuals with a legitimate and reasonable right to that information. Information received from victims and witnesses of ASB will be treated as having been given in confidence and we will do all we can to protect the identity of victims and witnesses.

The Council will share information internally and with external partners using an agreed Information Sharing Protocol for the purpose of preventing and tackling anti social behaviour and crime.

The new Community Safety Hub established at the police station provides an opportunity to exchange data and intelligence in a operational manner that serves to better co-ordinate response to cases of ASB.

5.3 Our performance

We will monitor our performance on ASB by measuring how well we deliver on our service promises to tenants. Our performance against our agreed service standards will be measured and we will publicise the results. We will also benchmark our service against other similar organisations to ensure that we learn from others and continue to improve.

We will work towards the establishment of a single system for recording all incidents of ASB across all Council services so that we can share information and continue to improve the services we provide.

We will ensure that we deliver a consistent high quality ASB service by:

• Developing the Landlord Delivery Plan and a service development plan as the vehicle for delivering service improvements

• Providing tenants with the opportunity to shape and review services through the Tenant Consultative Group and other arrangements

• Ensuring that service improvement targets are linked to team and individual personal development plans

We will measure and assess our performance against our targets and service standards by:

• Conducting regular surveys of service users to assess their levels of satisfaction

• Opening up the ASB service to scrutiny for example by developing a programme of focus group meetings, mystery shopping and tenant inspection

• Providing information on our ASB performance to elected members, tenants, staff and partner agencies

6. An accessible and accountable Anti Social Behaviour service

We will provide an accessible and accountable ASB service to our tenants.

6.1 Access to the service

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We want to provide a service that is widely accessible to all our tenants. We want to encourage the reporting of ASB and will ensure that tenants are aware of how to report ASB to us. At present there are a number of ways to do this including:

• Face to face by visiting Customer Services at Marmion House

• By telephoning Customer Services on 01827 709709

• By using the on line form to report ASB at www.tamworth.gov.uk

• Direct to Landlord Services

When we respond to complaints of ASB we will:

• Refer cases to the Police for urgent action where there is an immediate risk of harm

• Acknowledge the complaint within 24 hours and provide details of our Service Standards to complainants and the name of the member of staff handling the case

• Make initial contact and interview a complainant within 10 days

• Make contact with a complainant within 24 hours where the incident involves a hate incident or hate crime or a physical assault

6.2 Publicising our service

We want to ensure all our tenants are aware of the service that we provide. We will provide information on how the service is delivered and tailored to meet local needs and how well we are performing through our newsletter ‘Openhouse’, information leaflets and other publications. We want to share information on ASB with our tenants. This is essential if tenant’s are to support the work we do to deal with ASB. The Council will work with the media and use other means to publicise our work in this area and successful actions to prevent or tackle ASB. We will do this to:

• Ensure that the community are aware of the work that Landlord Services and our partners are undertaking

• Build community confidence to report incidents of ASB • Deter individuals from engaging in ASB • Assist in the enforcement of court orders where the perpetrator is continuing to cause

problems We will consider publicity on a case by case basis.

6.3 Accountable to our tenants

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We want to provide services that meet the needs of our tenants and are delivered equally. To do this we are working towards achieving the following objectives:

• Continuing to collecting information about the demographic profile of our tenants and using this information to review and shape our services

• Measuring the satisfaction of service users for example through surveys or focus group meetings and using customer feedback to contribute to service improvements

We cannot tackle ASB without the help and support of the community. We will work with residents and community groups to develop a neighbourhood approach to tackling ASB that focuses on locally agreed strategies for preventing and tackling ASB.

We will involve residents in partnership initiatives and publicise the work we do to prevent and deal with ASB. We will provide a range of opportunities for tenants from all groups to get involved in shaping and scrutinising our services.

7. Prevention and early intervention

We will focus on prevention and early intervention and provide support to enable perpetrators to change their behaviour.

We recognise that it is better to prevent ASB occurring than to have to deal with the consequences. 7.1 Allocations and new tenancies We will ensure that our approach to allocations contributes towards building sustainable communities. We will carry out thorough pre tenancy checks and ensure that our tenancy agreement sets out clearly what constitutes ASB. New tenants will be made aware of the standard of behaviour expected and the consequences of breaching the tenancy agreement. To achieve this we will:

• Adopt local lettings policies where necessary • Ensure new tenants are aware of the obligations of the tenancy agreement relating to anti

social behaviour • Provide new tenants with information on their community responsibilities and our approach

to anti social behaviour • Identify and access support for new tenants to sustain their tenancies

7.2 Prevention of Anti Social Behaviour There are many initiatives for the prevention of ASB in Tamworth and these include education programmes, Turnaround, CCTV, Street Wardens, area walkabouts and inspections, Police and PCSO patrols and Neighbourhood Watch Schemes.

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We will work with partner agencies to identify potential ASB hotspots and share information to target resources at areas worst effected by ASB. We will work together with partners, the community and voluntary groups in the provision of diversionary activities including youth and school projects. We will publicise and promote access to diversionary activities either provided by us or our partners. 7.3 Early intervention We will intervene early in complaints of ASB and deal with problems quickly preventing them from escalating. Where appropriate and to resolve complaints promptly we will deliver either ourselves or in partnership with other agencies the following interventions:

• Mediation – sometimes people may not realise they are causing a problem to their neighbours. Mediation may be appropriate if the problem could be solved by two parties talking to each other

• Acceptable Behaviour Agreements – these are written agreements between an individual, the Council and the Police. The agreement is a promise that the individual will not carry out certain acts which are seen by others as anti social

• Warnings – in many cases it will be enough to issue either a verbal or written warning to a perpetrator to get them to stop causing problems

• Support – prevention through support may be an appropriate response in certain cases. We will ensure staff are aware of how to access services such as mental health and drug and alcohol teams to establish support packages. We will proactively participate in partnership arrangements to safeguard children and vulnerable adults.

8. Support to victims and witnesses

We will adopt a supportive approach to working with victims and witnesses of ASB.

We recognise that support for victims and witnesses is essential to tackling ASB. We will do all we reasonably can to identify those that are vulnerable and their support needs.

We will publicise the support available to help victims and witnesses and our service standards. Witness support arrangements will be put in place which subject to an assessment of the needs of the individual on a case by case basis will include:

• Focus casework on supporting victims and witnesses

• Responding to the risk and vulnerability of victims and witnesses

• Ensuring victims and witnesses are kept up to date with their case at regular agreed intervals

• Not disclosing the name of any victim or witness without their prior consent

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• Providing advice on additional security for their home

• Considering an extra presence by Council staff around the neighbourhood including patrols by Street Wardens

• Providing staff with the information they need to make referrals to other specialist victim support agencies such as the Victims and Witness Support Champion

• Use appropriate legal action in response to complaints of witness intimidation

• Support victims and witnesses through the legal process or support victims to take their own action.

9. Prompt enforcement action

We will protect the communities in which we work through prompt enforcement action to deal with ASB before it escalates.

9.1 Enforcement

In Tamworth we will try to resolve cases without the need to take legal action against individuals. However where the behaviour is persistent or of such a serious nature we will not hesitate to take enforcement action against the perpetrators of ASB where this is the most appropriate and proportionate means of protecting individuals and the community.

In some cases, it may be more appropriate for us to support others in taking legal action, for example, the Police or the Community Safety Team. We will ensure that staff are aware of the full range of tools and powers that are available to us as a local authority landlord and to our partners and they are trained and have procedures in place to ensure that tools are used appropriately. There are a wide range of powers and measures available to the Council and Landlord Services to tackle ASB. The appropriate legal action will depend on the individual case but these may include:

• Notice of Intention to Seek Possession - where there is evidence of a breach of the tenancy conditions a notice will be served. If the breach is serious or continues we may issue possession proceedings.

• Possession proceedings – in cases where a Council tenant, members of their household or visitors are causing ASB and the behaviour is a breach of the tenancy conditions a court may be able to order that the tenant has to leave their home

• Demoted Tenancy proceedings – as an alternative to possession proceeding the Council can ask a court to demote the tenancy for a period of 12 months. A demoted tenancy can be ended more easily if the ASB continues.

• Anti Social Behaviour Orders – these are orders used to prohibit a perpetrator from specific acts of anti social behaviour

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• Injunctions – this is an order that will prevent a person from behaving in a particular way or entering a particular area

• ASB Closure Orders – the Council can make an application to the court for an order which closes a property associated with significant and persistent disorder for a limited period of time

9.2 Casework We will adopt consistent and robust case working principles and practices that are victim focussed. We will:

• Provide all complainants with a copy of an agreed Action Plan within 10 days

• Maintain regular contact with a complainant on an individually agreed basis or at least every 20 days to inform them of the progress of their case

• Regularly undertake sample quality audits of ASB complaints to ensure that policies and procedures are followed

9.3 Gathering evidence We will take a proactive approach to gathering evidence from a wide range of sources to support effective enforcement action. Our approach will be proportionate to the effect that the ASB has on the victim and the community. In certain cases we may utilise CCTV surveillance or engage professional witnesses to gather evidence such as Street Wardens, PCSO’S, the Police or other council employees. 9.4 Closing cases

Once a complaint has been resolved or we are satisfied that we have done everything that was reasonable but it is not possible to take any further action we will close a case. However before we close a case we will:

• Review the case fully to ensure that no further action is required or could be taken

• Contact the complainant to explain the reasons for closing the case

• Provide the complainant with an opportunity to challenge the decision

10. Value for money services

We will deliver an excellent ASB service to our tenants by considering a balance between cost and quality.

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We recognise the need to achieve value for money in all that we do. Value for money is important because we want to ensure that we have the resources to continually improve the quality of the service we provide. Landlord Services have produced a value for money impact statement and is continuing to deliver efficiencies in services and savings.

We want to apply our value for money principles to the ASB service and to do this we will:

• Develop mechanisms to capture, calculate and monitor the cost of dealing with incidents of ASB such as graffiti removal, vandalism and fly tipping and benchmark those costs against similar organisations to demonstrate value for money

• Use existing ASB service costs and service improvement proposals to allocate resources and set realistic budgets

• Review all procured services to maximise efficiencies

• Ensure that ASB service costs are scrutinised by tenants and members

• Provide tenants with appropriate cost information when considering service development proposals

• Encourage all staff and tenants to identify value for money opportunities

11. Individual and community responsibility

We will work with our tenants and partners to promote and encourage community cohesion.

We will work to build strong communities on our estates by promoting individual responsibility and tolerance. We will do this by:

• Promoting and supporting tenant groups

• Developing Good Neighbour Agreements with tenant support and encouraging tenants to resolve neighbour disputes directly

• Promoting initiatives to develop inter-generational tolerance

• Developing award schemes that will reward positive behaviour

12. Protecting our staff

Tamworth Borough Council will not tolerate any threats or abusive behaviour towards our staff. We will take firm action against any person who acts in such a manner towards staff carrying out their work in respect of this ASB Policy or any other service. We will protect staff by taking legal action against a perpetrator if this becomes necessary. 13. Training our staff

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The Council places great importance on the training of staff to deliver services to the public. Tackling anti social behaviour effectively requires our staff to be knowledgeable and well trained. We will make sure that all staff dealing with ASB clearly understand and deliver our ASB Policy and Procedures.

14. Complaints

We are committed to providing the best possible service at all times. Sometimes we make mistakes or residents may feel that we have not taken appropriate action to resolve their ASB issue. If you have a concern we want you to let us know by talking to the member of staff that is handling your case. If it cannot be resolved and you wish to make a complaint you can:

• fill in a Tell Us form on line at www.tamworth.gov.uk

• visit any of our offices and complete a Tell Us form

• telephone Customer Services on 01827 709709

• text TBCTELLUS followed by your comment to 88020

• write to Tamworth Borough Council, Marmion House, Lichfield Street, Tamworth, B79 7BZ

15. Review of Landlord Services Anti Social Behaviour Policy Statement

This Landlord Services Anti Social Behaviour Policy Statement will be reviewed annually to ensure that it is relevant and up to date. When we review this policy we will involve staff, residents and other key stakeholders and assess the contribution that the policy has made towards meeting our corporate targets. The policy will also be subject to regular Equality Impact Assessments to ensure that it meets the needs of the community and has no adverse effect on a particular group.

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Annex Two Anti Social Behaviour Accreditation Action Plan Action Leader Start Date Review Set up an ASB service Improvement Group (SIG) of residents, staff and members with clear terms of reference.

Leanne Allwood June 2011 August

Introduce a checklist to improve the review/audit of existing cases files and assess compliance with service standards and case management procedures.

Tina Mustafa July September

Prepare revised Landlord Services ASB Policy Statement. Consult with residents and arrange Cabinet approval for new policy statement.

Tina Mustafa & Leanne Allwood 29 June 2011 Complete

Implement revised and updated secure tenancy agreement. Consider grouping all ASB related clauses into single section (eg Your Community Responsibilities" including all nuisance behaviour such as inconsiderate parking, refuse disposal etc).

Sue Philp November 2010 Cabinet July 2011

Develop an ASB strategy (preferably a joint TCSP strategy) & regularly report to elected members on progress against strategic aims (see Action Code 2 - combine reports).

Rob Mitchell June 2011 October 2011

Establish reports for elected members, residents and staff that demonstrate performance against ASB local offer standards and KPI's.

Tina Mustafa & Leanne Allwood July 2011 September

2011

Implement Orchard computer ASB package. Jackie Lee March 2011 April 2012

Implement revised ASB procedure guide for staff linked to corporate procedure.

Tina Mustafa & Sue Philp April 2011 December

2011 Deliver staff training to support the implementation of the new ASB policy and procedure guide. Training to include TBC procedures, case management skills and the range of tools and early intervention techniques available to TBC. This training to be combined wherever required with Corporate Approach.

Sue Philp May 2011 April 2012

Develop and deliver a training programme to residents groups setting out the new ASB procedures and current tools available to Tamworth for tackling ASB.

Leanne Allwood November 2011

February 2012 Incorporate methods for measuring customer satisfaction with ASB service into the work programme/plans for the Resident Involvement Team. Include questions aimed at measuring satisfaction with witness and victim support services.

Leanne Allwood 2012 2014

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Establish appropriate and challenging targets for improving customer satisfaction with the ASB service.

Tina Mustafa & Sue Philp Ongoing

August Report the results of satisfaction with the ASB service at agreed frequencies to elected members, residents, staff and residents groups.

Tina Mustafa & Leanne Allwood December 2011

March 2012 Carry out an Equality Impact assessment of the new ASB policy and procedure and build into a service improvement plan any action required to alleviate any adverse impact.

Sue Philp August 2011 November 2011

Develop a Demoted Tenancy Policy and Procedure. Lisa Hall December 2011

January 2012 Establish referral arrangements for specialist victim and witness support services available through the Community Safety Team.

Lisa Hall September 2011 December

2011 Establish a protocol to share information with the Victim and Witness Support Champion.

Lisa Hall September 2011 December

2011 Prepare a witness support information leaflet which explains the support available, service standards and includes advice on the court process.

Rob Mitchell & Dave Fern October 2011

December 2011

Review sign up checklist to ensure that tenants responsibilities are clearly communicated.

Lee Birch August 2011 September 2011

Include a revised ASB information leaflet in every new tenant sign up pack.

Sue Philp & Lisa Hall October 2011 November

2011 Establish a service level agreement with the local mediation service provider. Sue Philp December 2011

January 2012 Develop a Support Services Directory. Sue Philp December 2011 January 2012 Develop a standard suite of ASB letters and forms to compliment the new ASB procedure and aid the delivery of the ASB service linked to Corporate procedure

Jackie Lee & Sue Philp November 2011

January 2012 Conduct a procurement exercise for external ASB legal services providers

Procurement Team February 2012

May 2012

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Tamworth BC ASB Service Review

Landlord Services ASB function and integration with the Community Safety Team

6th May 2010

David Higgins

Associate Consultant

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1.0 Introduction

TBC recognise that dealing with ASB is a corporate responsibility which requires greater levels of co-operation and integration with the work of the Community Safety Partnership. As a registered provider of social housing the TSA require TBC Landlord Services to show that they are working in partnership with other public agencies to prevent and tackle anti social behaviour in neighbourhoods where they own homes. To meet the required regulatory standard TBC must deliver a service that is able to share intelligence and resources with partners to achieve successful outcomes.

HouseMark were commissioned by TBC to review the Landlord ASB policy and operational procedures as the basis from which to further develop the service. In addition, work has been undertaken to establish an overarching corporate ASB policy statement providing the opportunity to establish a framework for delivering consistent ASB services across all departments starting with minimum corporate service standards.

As the department which deals with the largest proportion of ASB complaints in the Borough, Landlord Services supports partnership working and the preliminary proposals for the co-location of a member of staff within the Corporate Community Safety Team as the most effective means of achieving the desired levels of integration.

This report summarises the main findings of a review of existing Landlord ASB services based upon staff interviews and a review of supporting documentation. It should be noted that no service users have been interviewed. The report provides recommendations for developing the landlord ASB service based upon the location of a directly managed member of staff co-located within the Corporate Community Safety Team.

2.0 Background and Context Tamworth Borough Council manages over 4,500 homes. Currently the ASB service is delivered by 4 housing officers based centrally at Marmion House. The day to day operational responsibility for the ASB service rests with a Team Leader who reports to the Housing Manager (Estates Management). The Team Leader acts as the main point of contact with the Community Safety Partnership. The Housing Officer role is challenging and includes all aspects of tenancy management with the exception of arrears recovery and allocations. At present Housing Officers deal with in excess of 400 ASB complaints annually and generally manage an ongoing caseload of 20 complaints each. Evidence suggests that dealing effectively with ASB is a major priority for tenants. The last STATUS Survey reviewed (2008) revealed that as many as 1 in 6 tenants had reported ASB to

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TBC. Whilst respondents were generally happy with the handling of their complaint relatively high proportions were dissatisfied with the final outcome (43%) and the length of time to deal with the report (33%). In responding to the concerns of tenants there are a number of key drivers that need to be considered in the provision of ASB services both now and into the future:

Financial: the resources available to deliver a high quality service and the savings achieved by successfully tackling ASB by reducing void turnover, minimising repair costs and other costs associated with damage and vandalism Sustainability: long term viability of the areas where TBC operate will be significantly affected if ASB is not dealt with effectively. Customer perception: ASB is such an important issue for tenants and satisfaction is likely to be low unless TBC is recognised as a landlord that takes ASB seriously and is effective in tackling problems. Regulation and inspection: the TSA will expect landlords to prioritise and be effective in an area which is a high priority for residents. Community safety: tackling ASB effectively can only be achieved in the context of the work of the local community safety partnership. 3.0 Delivering an ASB Service - Retaining the existing arrangements TBC recognises the need to deliver continuous improvements and shape services around the needs of tenants. However the existing arrangements present significant challenges to achieving continuous improvement, closer links to the corporate community safety function and value for money. Landlord Services may find it more difficult to play a full and active part in wider partnership activity around ASB. Similarly the opportunity to draw effectively upon partnership resources for the benefit of tenants could be missed or made more difficult, particularly around aspects like out of hour’s services and sharing specialist equipment. Whilst the current service is seen by many tenants as helpful (STATUS) there appears to be a limit within the existing structure on the ability of staff to develop the expertise required to deliver an enhanced service. This is not a matter of competence but rather capacity demonstrated by the need at present to procure some basic ASB services from legal advisers such as the preparation of witness statements. The current arrangements tend to make a more co-ordinated approach to ASB less likely. There is a commitment amongst the team to deal effectively with ASB but there is a risk that individual initiatives and activities take place in isolation rather than as part of a strategic departmental and corporate approach to problems in particular locations.

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The risk with the existing arrangements could be mitigated but this is likely to require additional resources at the front line or the procurement of more external ASB services, both of which will have cost implications. The quality of the ASB service may be improved in this way but it would not necessarily achieve the intended closer and more effective links with the Community Safety Team and management time would be diverted into the supervision and monitoring of further externally procured services.

4.0 Delivering an ASB Service - Developing a specialist role The ASB Accreditation Gap Analysis Report should give an indication of the work required to prepare the service to successfully achieve accreditation. However the challenge for TBC will be to continue to develop and improve services that meet the changing needs of tenants and exceed regulatory standards.

In the context of Tamworth, Landlord Services are now committed to delivering on Local Offers around the ASB service. TBC have promised to:

• acknowledge all ASB complaints within 24 hours

• agree a customer action plan within 10 working days

• arrange a mutually acceptable time for interview with a complainant within 10 working days

• contact a customer within one working day for serious allegations such as hate crimes or physical assault

• keep in contact with the complainant on an individually agreed basis

• keep the identity of victims/witnesses confidential when requested

• work with the Police, Tamworth Bourough Council Community Safety Team and other support agencies to reduce nuisance within the borough

• offer a range of solutions to help solve your complaint (eg advice and support, mediation or legal action)

• be accredited with the Respect Standard by 2012/13 reflecting our commitment to preventing, enforcing and educating against anti social behaviour

• offer and publicise surgeries in the ARCHes to discuss solutions to anti social behaviour

• support the corporate community safety hub to offer an integrated approach to resolving anti social behaviour issues

• carry out an annual telephone satisfaction survey achieving at least 80% satisfaction.

These Local Offers which will be subject to tenant scrutiny will be a challenge to deliver under the current arrangements. There is a risk that these standards may not be achieved or the service meet the standard required for accreditation unless adequate capacity and expertise is

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available in house. It is therefore recommended that the resource required to drive forward the ASB service should come from the creation of an Anti Social Behaviour Co-ordinator role.

There are obvious direct human resources and financial implications relating from the creation of a new ASB Co-ordinator role and consideration will need to be given as to how this may fit within the existing organisational changes proposed within Landlord Services. However it is recommended that such a post could be established at Scale 6 reporting to the Tenancy Sustainment Manager (or Co-ordinator) co-located between the Community Safety Hub and Marmion House based on the following key functions:

Supporting Housing Officers:

• Housing Officers would continue to be the first point of contact for tenants and manage all ASB complaints in the first instance.

• Provide advice and support to Housing Officers in their management of cases.

• Carry out periodic reviews of Housing Officer cases to ensure high levels of compliance with operational procedures.

Undertaking high level casework:

• Investigate and manage serious cases of anti-social behaviour including enforcement or intervention action where appropriate. This would include:

o Interviewing tenants and residents, both those suffering from anti-social behaviour and the alleged perpetrators.

o Carrying out or arranging any surveillance required to collect evidence, including use of any necessary equipment.

o Preparing and collecting detailed statements of evidence. o Liaison with other agencies especially the Police. o Liaison with legal advisers to ensure that all evidence is collected. o Appearing at court on behalf of TBC.

• Prepare notices of seeking possession and draft and issue legal proceedings in straightforward matters including presenting applications to court at first hearings (eg DIY injunctions).

• Lead on enforcing serious breaches of tenancy requiring legal action (eg sub-letting, no access for gas safety inspections).

Preventing ASB:

• Work closely with tenants, colleagues and partners to implement initiatives to prevent and deter ASB whenever possible

Delivering training:

• Provide regular training and briefings to Housing Officers. Act as a source of good practice and facilitate shared learning across the team.

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• Provide specialist expertise to deal with anti-social behaviour • Keep up to date on legal remedies available and best practice initiatives being undertaken

to tackle anti social behaviour • Contribute to the delivery of training to partners and colleagues in other departments

Leading on Service Development & Performance monitoring

• Contribute to the development of appropriate policies, procedures and strategies • Lead on the implementation of an ASB service delivery plan including involving tenants

and colleagues as necessary. • Compile information and statistics on the ASB service for presentation to colleagues,

Management, elected members and partners. • Ensure that publicity and information on anti-social behaviour policies and procedures are

available and up to date including preparing materials publicising ASB activities and successful enforcement action (eg articles in Openhouse).

• Monitor ASB levels and trends including analysing costs and outcomes related to established ASB standards.

Co-ordinating internal and external services:

• Lead on the co-ordination of corporate ASB services (eg EHO, CCTV)

• Arrange and manage externally procured services (eg mediation, surveillance)

• Ensure services are delivered to an agreed standard by developing service level agreements where necessary (eg with mediation services).

Working with partners:

• Work alongside the Community Safety team to strengthen existing partnerships

• Act as the main point of contact between Landlord Services and the Tamworth Community Safety Partnership and participate in the TCSP Joint Operations Group and ASB Action Group.

• Develop new partnerships that will contribute to preventing and tackling ASB (eg mental health services, floating support)

• Contribute on behalf of Landlord Services to the development and delivery of any joint Corporate/Community Safety Strategies or action plans.

5.0 Synergy with Community Safety Team

The TBC Community Safety Team covers a range of functions and includes an ASB Officer with responsibility for delivering that part of the Community Safety Action Plan relating to ASB and Racial Harassment, a Victim and Witness Champion and a Domestic/Sexual Abuse Partnership Officer.

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A Landlord Services ASB Co-ordinator working within the Community Safety Team will achieve greater integration with these services and enable the post holder to adopt a wider corporate perspective. Resources will be more effectively targeted for the benefit of TBC tenants particularly specialist witness and victim support.

In addition co-operation between other members of the Community Safety Team and the Police will lead to swifter more effective intervention in cases involving TBC tenants resolving cases sooner before they escalate by sharing information and co-ordinating joint responses.

It should be pointed out that in the future this proposal has the potential to lead to the establishment of a Community Safety Team that directly provides specialist ASB services across all council departments including Landlord Services based on a service level agreement model. At present however Landlord Services may wish to retain an ASB function in the department in order to have control over the delivery of service improvements to tenants and ensure that regulatory and local service standards are achieved.

6.0 Conclusion

In conclusion it is recommended that the creation of a specialist Landlord Services ASB role based at the Community Safety Hub is taken forward based upon the functions outlined above. This will not only achieve the intended improved integration of ASB services but also lead to a more consistent high quality response to all tenants who report ASB. In addition the appointment of an officer with the skills and experience to undertake higher levels of case preparation and DIY injunctions is likely to see significant savings in legal costs.

Further assistance can be provided in preparing a suitable job description, person specification and required competencies.

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Further information

For further information visit our website www.housemark.co.uk or call 024 7646 0500. HouseMark, 4 Riley Court, Millburn Hill Road, University of Warwick Science Park, Coventry CV4 7HP.

About HouseMark

HouseMark is the leading provider of performance improvement and value for money solutions to the social housing sector and is jointly owned by the Chartered Institute of Housing and the National Housing Federation; two not-for-profit organisations which reinvest their surpluses in the social housing sector.

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Annex 4

Equality Impact

Assessment Toolkit

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Equality Impact Assessment Procedure

Existing Policy/ Procedure/ Practice

New Policy/ Procedure/ Practice

Identify a group to carry out the EIA (group to consist of at least 3

individuals)

Individuals to read and consider policy/ procedure/ practice

Group to meet and carry out EIA using

template

Is there sufficient information to

satisfactorily complete the EIA

YES NO

Complete Action Plan

Identify further requirements eg: • Consultation with experts,

individuals, groups • Data collection • Monitoring

Carry out EIA whilst developing the policy, considering points 1 to 20 on the EIA template. Consider seeking

views from stakeholders

Build in findings to the policy/ procedure/

practice and note on EIA template

Consult where appropriate

Consider questions 21 – 24 on EIA

template

Complete Action Plan

Give copy of EIA to corporate equalities

Publish EIA

Give copy of EIA to corporate equalities

Publish EIA

Review and Monitor

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Equality Impact Assessment Template Name of policy/ procedure/ practice to be assessed

Landlord Anti Social Behaviour (ASB) Policy

Date of Assessment 9 May 2011

Is this a new or existing policy/ procedure/ practice?

New Officer responsible for the Assessment

Tina Mustafa Department Housing & health

1. Briefly describe the aims, objectives and purpose of the policy/ procedure/ practice?

The Landlord ASB policy provides the framework for meeting the statutory and contractual obligations of Landlords to tenants to deal with ASB

2. Are there any associated policy/ procedure/ practice which should be considered whilst carrying out this equality impact assessment?

Information Sharing Protocol, Safeguarding Policy, Housing ASB policy, Environmental Health Noise policy, Hate Crime policy, Call Handling procedures, Street Scene policies and HR policies.

3. Who is intended to benefit from this policy/ procedure/ practice and in what way?

Tenants, Service users, our staff, partner agencies, stakeholders and the wider community.

4. What are the desired outcomes from this policy/ procedure/ practice?

The Landlord ASB policy fits into the Corporate ASB Policy which is an overarching statement of the Council’s commitment to ensure that Anti Social Behaviour is dealt with quickly and effectively.

5. What factors/ forces could contribute/ detract from the outcomes?

Factors contributing to an effective require clear joined up commitment, strong leadership, effective resources both people and funding, skills, knowledge and commitment of staff and appropriate access channels to report. Factors to detract lack of or unsuitable IT system, poor communication, lack of staff training, lack of resources and the resilience of key staff.

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6. Who are the main stakeholders in relation to the policy/ procedure/ practice?

Tenants, service users, staff, Councillors, 3rd sector, the wider community and partners.

7. Which individuals/ groups have been/ will be consulted with on this policy/ procedure/ practice?

Please explain Housing, Environmental Health, Transforming Tamworth, Customer Services, Community Safety and the police.

8. Are there concerns that the policy/ procedure/ practice could have a differential impact on racial groups?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). All aspects of vulnerability are at the forefront of this policy. The Corporate Hate crime and Safeguarding policies support this policy.

9. Are there concerns that the policy/ procedure/ practice could have a differential impact due to gender?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). There are no gender specific issues.

10. Are there concerns that the policy/ procedure/ practice could have a differential impact due to them being transgender or transsexual?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). Links are developing with local LGBT groups.

11. Are there concerns that the policy/ procedure/ practice could have a differential impact due to disability?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). By default the impact of ASB on service users will have a differential impact based on their capacity and various customer characteristics. This is addressed through the risk management / vulnerability assessments done throughout the case. There are links to the initial assessment of victims and the subsequent more detailed scoring matrix assessment which is particularly relevant for recognising disability.

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12. Are there concerns that the policy/ procedure/ practice could have a differential impact due to sexual orientation?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). Please see above

13. Are there concerns that the policy/ procedure/ practice could have a differential impact due to age?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise).

14. Are there concerns that the policy/ procedure/ practice could have a differential impact due to religious belief?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). No. We are mindful of contact with alleged perpetrators and complainants on religious festivals.

15. Are there concerns that the policy/ procedure/ practice could have a differential impact on Gypsies/ Travellers?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). The over-arching corporate ASB policy is not tenure specific. The Landlord ASB policy builds on the contractual relationship but recognises the wider community impact. Dedicating a housing officer at the co-located hub will improve this cross-tenure approach to problem solving.

16. Are there concerns that the policy/ procedure/ practice could have a differential impact due to dependant/caring responsibilities?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). The risk assessment matrix should support dependent/carers.

17. Are there concerns that the policy/ procedure/ practice could have a differential impact due to them having an offending past?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). Cases are dealt with on an individual basis on relevant evidence

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18. Are there concerns that the policy/ procedure/ practice could have an impact on children or vulnerable adults?

Y

N √

Please explain, your reasoning, giving details of existing evidence (either presumed or otherwise). Will be a positive impact as it will support and identify there specific needs.

19. Does any of the differential impact identified

cut across the equality strands (e.g. elder BME groups)?

Y

N √

Please explain

20. Could the differential impact identified in 8 – 19 amount to there being the potential for adverse impact in this policy/ procedure/ practice?

Y

N √

Please explain

21. Can this adverse impact be justified: • on the grounds of promoting equality of

opportunity for one group? • For any other reason?

Y N Please explain for each equality heading on a separate piece of paper (questions 9 – 20). N/A

22. As a result of carrying out the equality impact assessment is there a requirement for further consultation?

Y N √

Please explain The Tenant Consultative Group has been involved in the development of the policy and tenants have contributed to the specific detail.

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23. As a result of this EIA should this policy/ procedure/ practice be recommended for implementation in it’s current state?

Y √

N

Please explain

PLEASE COMPLETE THE FOLLOWING ACTION PLAN FOR ALL IMPACT ASSESSMENTS

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Equality Impact Assessment Action Plan Complete the action plan demonstrating the changes required in order to meet TBC’s commitment to equality and diversity. The action plan must contain monitoring arrangements, the publishing of results and the review period required for this policy.

ACTION/ ACTIVITY RESPONSIBILITY TARGET PROGRESS Additional consultation with Tenants Consultancy Group and RSL’s

Leanne Allwood As per TCG work plan 2011

Monitoring arrangements:

Data collected quarterly

Publication:

Review Period:

Reviewed 12 monthly unless otherwise stated

Expand as appropriate

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Signed (Completing Officer)…… ……………………... Date ……9 May 2011…. Signed (Head of Department) ………Tina Mustafa…………….. Date ………………………. Signed Corporate Diversity/ Equality ………

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