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Strasbourg dismisses compensation claim for not allowing asylum seeker to work

Daniel Negassi v the United Kingdom (application no. 64337/14) was an appeal to the European Court of Human Rights with a complaint that the Home Office’s failure to grant Mr Negassi permission to work, while waiting for a decision on his asylum claim, was a breach of his right to respect for his private life under Article 8 of the European Convention of Human Rights (ECHR). Though handed down several months ago, it is worth looking at as a rare example of judicial consideration of this kind of claim. Complaint to the European Court of Human Rights Mr Negassi argued that the refusal to grant him permission to work constituted…

23rd November 2017 By James Packer

Asylum age assessments: the Court of Appeal is not a tribunal

In Bedford County Council v GE (Eritrea) [2017] EWCA Civ 1521 the Court of Appeal refused to overturn an age assessment simply because the local authority disagreed with judicial findings of fact. The judgment upheld the Administrative Court’s decision that GE was born on 27 September 1994, making her 16 years old when she entered the UK. The facts GE was born in Eritrea in 1994. After parental bereavement she moved (via Sudan) to Libya with her uncle. Following the outbreak of war she escaped Libya by boat. In May 2011 GE entered the UK hidden in a lorry. GE was arrested in Dover and immediately claimed asylum. The UK…

16th November 2017 By Clare Duffy

EU countries accused of criminalising humanitarian help for migrants

Laws designed to combat trafficking are being misused to target those giving humanitarian assistance to migrants trying to reach the EU, the Institute for Race Relations says. A new report by the think tank finds that criminal laws are being used to punish people simply “seeking to uphold standards of decency” – by rescuing people at risk of drowning in the Mediterranean, for instance, or giving food and water to migrants on the street. Case studies from around Europe show that: In Greece and Italy, volunteers working with NGOs are under investigation and threat of prosecution for their sea rescue missions. In France, as one court rules the criminalisation of…

14th November 2017 By Conor James McKinney

Man in immigration detention for 45 months loses judicial review

Taskiran v Secretary of State for the Home Department [2017] EWHC 2679 (Admin) is a sad case. A web of domestic immigration law and international agreements have resulted in Mr Taskiran undergoing almost four years of immigration detention, which the court found legal. Mr Taskiran was brought to the United Kingdom from Turkey aged 13. In March 1994 his family, including his refugee father, were granted Indefinite Leave to Remain. However, Mr Taskiran became addicted to crack cocaine. This seems to have fuelled a long history of offending: between August 1994 and January 2014, he had 27 convictions for 54 offences. In January 2014 he was convicted of rape and sexual…

7th November 2017 By Paul Erdunast

Home Office responds to committee report, 15 months later

The government has responded to a report by MPs on the work of the Immigration Directorates – a mere 456 days after the report came out. When Home Affairs Select Committee began its enquiry, Brexit had not yet happened. It published its report on 27 July 2016, a matter of days after Theresa May replaced David Cameron in 10 Downing Street. The response came back on 26 October, and is published today. The Home Secretary apologised for the “unacceptable” delay, which she put down to a number of internal and external factors, including the need to amend the Government’s response in light of a legal determination on Home Office country guidance. Many of…

3rd November 2017 By Conor James McKinney

Could Catalan separatists qualify for refugee status in the UK?

Carles Puigdemont, erstwhile President de la Generalitat de Catalunya, fled Spain to Belgium this week following his parliament’s unilateral declaration of independence for Catalonia. Several of his ministers followed him into exile. A European Arrest Warrant will soon be issued seeking their extradition back to Spain to face criminal charges. Meanwhile, eight other Catalan ministers who stood their ground were detained yesterday by Spain’s high court and face charges of rebellion, sedition and misuse of public funds for their roles in the independence referendum, which was illegal under Spanish law. Other senior Catalan politicians face similar charges but their cases are complicated by parliamentary immunity. Puigdemont and his ministers breached Spanish…

3rd November 2017 By Colin Yeo

Help Refugees loses Dubs amendment case, will appeal

Help Refugees has lost its challenge to the Home Office’s delay in relocating child refugees under section 67 of the Immigration Act 2016. The decision in R (on the application of Help Refugees Limited) v Secretary of State for the Home Department [2017] EWHC 2727 (Admin) was handed down today. The charity immediately committed to an appeal. Court ruling is disappointing, but it is not the end. We will continue to fight for the rights of refugee children! https://t.co/iUXNVkKC1y — Help Refugees (@HelpRefugees) November 2, 2017 The judicial review took aim at the Home Office’s dilatory approach to the ‘Dubs amendment’. That section, inserted into the 2016 Act after dogged campaigning,…

2nd November 2017 By Conor James McKinney

New community sponsorship funding announced

£1 million in Home Office funding is now available to help with community sponsorship of refugees. The department says that The fund is for the community sponsorship scheme which enables community groups to take on the rewarding role of welcoming and supporting refugee families in the UK. Sponsor groups can include charities, businesses, local authorities, community groups and third sector organisations. The fund is designed to give experienced organisations the resources to provide training and support to groups who want to sponsor refugees. It aims to bring people together from across society to support vulnerable refugees through community sponsorship. Applications are through the gov.uk Contracts Finder portal. The deadline is…

1st November 2017 By Conor James McKinney

Host state handles the asylum claim if Dublin III transfer takes too long

Majid Shiri, an Iranian national, arrived in Austria through Bulgaria in 2015. He made an asylum claim in Bulgaria in February of that year but claimed asylum in Austria the following month. The Austrian authorities asked Bulgaria to take Mr Shiri back under the Dublin III Regulation, which ‘take back request’ Bulgaria accepted. In July the Austrian authorities decided his removal to Bulgaria was lawful, a decision then annulled “on account of Mr Shiri’s vulnerability owing to his state of health”. This decision was reinstated in September. By then, Mr Shiri was in a position to argue that Austra had become the member state responsible for examining his asylum application because…

1st November 2017 By Paul Erdunast

Guest post: barriers to migrants accessing public services

Getting to the UK and applying for the right to stay is only the start of the battle, writes trainee housing solicitor John Murphy. Newcomers to the UK, whether they have immigration status or not, face formidable obstacles in accessing services such as housing or social security. This is a look at some common scenarios and how foreign nationals and their advisers deal with them. They are based on real client cases. Scenario one: the single male refugee Soon after getting refugee status, he will receive a letter telling him his National Asylum Support Service support is about to stop. He can try to rent in the private sector but he…

30th October 2017 By John Murphy

Book review: The Child in International Refugee Law by Jason Pobjoy

The Child in International Refugee Law by Jason Pobjoy, a barrister at Blackstone Chambers, is an extremely useful, practical and important contribution to the international protection of child refugees. I cannot do better than Pobjoy’s own summary of the themes that run through this work: The hypothesis advanced in this book is that progressive developments in the interpretation of the Refugee Convention, coupled with a greater understanding of the relationship between international refugee law and international law on the rights of the child, enable the Convention to respond in a sophisticated and principled way to refugee claims brought by children. This will require a creative alignment between refugee law and…

27th October 2017 By Colin Yeo

“Madness, despair and horror” at Halloween

With Halloween approaching, a refugee charity is combining spooky tales with support for free movement. The Dead Poets Live event in London on Saturday 28 October promises “the most terrifying poems ever written”, read by a collection of well-known actors. It is not known whether the works of “madness, despair and horror” derive from Appendix FM but enquiries are ongoing. The remaining tickets are £13, with all proceeds going to Safe Passage. The charity says that it has helped to settle 1,150 refugee children in the UK since beginning work in 2015 as a partnership between Islington Law Centre, Bhatt Murphy and Doughty Street Chambers. It will issue judicial review proceedings…

26th October 2017 By Conor James McKinney

Court of Appeal: private religious belief does not risk persecution

The difficulty of presenting asylum claims based on religion is well known. Such claims raise difficult evidential problems, which are addressed in this detailed post by Colin Yeo. But AS (Iran) v Secretary of State for the Home Department [2017] EWCA Civ 1539 seems to pose a novel difficulty: should a claim by a person who would exercise their religion in utter privacy be accepted? Factual background and First-tier Tribunal decision The appellant is an Iranian national. She had made a previous asylum claim in the UK on the basis of her political activities, but was refused and removed to Iran in 2009. In 2012, she returned and shortly afterwards made a…

23rd October 2017 By Thomas Beamont

Guest post: citizenship for sale – at a cost stateless people can ill afford

Stateless people in the UK face enormous hurdles in the road to becoming British citizens. One of those barriers is the extraordinarily high cost of acquiring British citizenship, writes Asylum Aid’s Cynthia Orchard. The UK government has taken some steps to ensure its approach to statelessness complies with international law. In many respects, British nationality law complies with the 1961 Convention on the Reduction of Statelessness. Further, the UK introduced a statelessness determination procedure in 2013, which was an important step towards achieving compliance with the 1954 Convention relating to the Status of Stateless Persons. There is, however, considerable room for improvement in the UK’s treatment of stateless persons. This…

5th October 2017 By Cynthia Orchard

How not to support a victim of human trafficking: a demonstration by the Home Office in R (FT) v SSHD

The Upper Tribunal overturned several decisions concerning the grant of Discretionary Leave to Remain to a victim of human trafficking in FT, R (on the application of) v the Secretary of State for the Home Department [2017] UKUT 331(IAC). The background to the case is that of the Home Office failing to appropriately identify the individual concerned as a victim of human trafficking, and subsequently unlawfully placing him in immigration detention for four years. The facts of the case are stark. After a childhood of regular beatings with rods and belts by his mother and his alcoholic father, his uncle borrowed money from people traffickers to send him to the United Kingdom. The…

29th August 2017 By Paul Erdunast

Study finds asylum judges fail to assist vulnerable appellants

Really interesting study, which should be carefully considered in the Immigration and Asylum Chambers. …There are clearly dangers to an overly rule-bound judicial approach, as conveyed by Conley and O’Barr’s (1988) description of ‘the proceduralist judge’ whose ‘high priority on maintaining procedural regularity’ (498) ‘may become condescending or sarcastic’ (500) and may present the law as ‘remote and inaccessible’ (502). Yet our findings raise concerns over the inequitable use of procedural discretion when it is afforded to judges. Substantive discretion – that is a judge’s freedom to reason and decide without encumbrance – is a different matter and a central requirement of judicial independence. We have demonstrated, however, that where…

15th August 2017 By Colin Yeo

How to correct a mistake in a country guidance case

What happens where the Upper Tribunal makes a mistake in a country guidance case? And in what circumstances will the Court of Appeal have jurisdiction to hear an appeal against an Upper Tribunal decision that has already been remitted to the First Tier Tribunal? Both of these interesting issues crop up in AA (Iraq) v Secretary of State for the Home Department [2017] EWCA Civ 944. The Case of AA AA was an Iraqi who claimed asylum in the UK in 2009. His appeal has now been in the court system for over 8 years (and counting). The initial application was rejected and several appeals dismissed until AA benefited from…

14th August 2017 By Nick Nason

Article 3 and the extradition of a British national to Taiwan

The Supreme Court in the case of the Lord Advocate (representing the Taiwanese Judicial Authorities) (Appellant) v Dean (Respondent) (Scotland) [2017] UKSC 44 considered the first occasion on which Taiwan has sought to extradite a British national. On appeal from the Appeal Court of the High Court of Justiciary (‘the Appeal Court’) the Supreme Court considered the correct test for Article 3 of the European Convention for the Protection of Human Rights and Fundamental Freedoms (‘the ECHR’) within extradition cases and, in doing so, it reviewed the prison conditions that may reach the Article 3 threshold. This case may extend beyond extradition cases and could be useful guidance for other cases including…

11th August 2017 By Chris Desira

Syrians can now upgrade to full refugee status: new form issued

Particularly relevant to Syrians who were not granted formal refugee status and instead got the lesser status of Humanitarian Protection: This form is for people resettled under the Vulnerable Persons Resettlement Scheme or the Vulnerable Children’s Resettlement Scheme who wish to request their status in the UK is changed from Humanitarian Protection to refugee status. Source: Request to change humanitarian protection status to refugee status – GOV.UK

10th August 2017 By Colin Yeo

Home Office inspectors release series of reports: highlights for lawyers

For some reason the Home Office has just released a swathe of inspection reports into a wide range of Home Office operations. In practical terms, this makes it impossible for the press to pick out more than one or two stories from the reports and it therefore very effectively reduces scrutiny. Usually I have nothing better to do than sit and read these reports when they are hot off the press (!) but 10 in two days seems excessive even to me I cannot stir myself to read all of them. It is almost as if there is something to hide somewhere in there. Nevertheless, I am going to confine…

14th July 2017 By Colin Yeo

New Refugee Action report slams inadequate, creaking asylum support system

After more than a decade since Limbuela, and three years after Refugee Action, Home Office policy continues to drive asylum seekers into destitution. The Refugee Action report, Slipping Through the Cracks, candidly outlines these failings of the asylum support system. This is hardly the first time these sorts of flaws have been exposed. The whole report features real stories and quotes from the asylum seekers let down by the process, and is well worth a read. The first problem is the decrease in support level over time. Rates used to be set at 70% of mainstream benefits. This meagre level seems princely compared to the current non-emergency (“Section 95”) support…

12th July 2017 By Paul Erdunast

Upper Tribunal rules it unsafe to return anyone to Libya

The violence in Libya has reached such a high level that substantial grounds are shown for believing that a returning civilian would, solely on account of his presence on the territory of that country or region, face a real risk of being subject to a threat to his life or person. This is the country guidance the Upper Tribunal gave in the case of ZMM (Article 15(c)) Libya CG [2017] UKUT 263 (IAC), overturning the earlier country guidance of AT and Others (Article 15c; risk categories) (CG) [2014] UKUT 318 (IAC). The Tribunal gave country guidance on the following issues: Is the Appellant at risk under Article 15(c) if returned to Libya?…

3rd July 2017 By Nath Gbikpi

An immigration lawyer reviews Paddington

In tribute to beloved author Michael Bond (1926-2017), who died yesterday, I am republishing this blog post reviewing the film Paddington, based on the character created by Bond. The blog post was originally published on 1 December 2014 and versions of it appeared in the New Statesman and Financial Times. Law is pretty abstract. Unlike the role of a doctor or a builder, that of a lawyer is difficult to explain to a young mind. When my children eventually ask me about what I do when I “work” (confusingly simultaneously a place I seem to go to and a thing I do at home; either takes me away from them) my plan is to…

29th June 2017 By Colin Yeo

In depth look at the new Home Office settlement policy for refugees after five years

In March 2017 the Home Office has announced a new policy of reviewing whether all refugees require protection at the end of a 5 year initial period of Refugee Status. This policy is effective for all existing and future applications for Indefinite Leave to Remain (‘ILR’) as a Refugee. This policy has now been effective for three months and, with Refugee Week upon us, it is a good opportunity to delve into it in greater detail. The application process Those recognised as refugees will usually be granted a period of 5 years limited leave. When that leave is due to expire they must apply for ILR. The Home Office gives…

22nd June 2017 By Chris Desira

Athens Refugee Legal Support Project: what is happening on the ground and how to donate

Image (c) Sarah Booker The pilot of the Athens Refugee Legal Support Project has now run for 2 months now. We work out of a community centre in Athens with the support of ILPA and Garden Court Chambers. Weekly reports from UK legal volunteers (solicitors, barristers, case workers) tell a similar story. The Greek asylum service is overburdened. Greek lawyers on the frontline are overstretched and the majority of refugees do not receive any advice or representation prior to receiving the initial decision on their asylum claim. If refused they can expect an excruciatingly long appeal process. To make matters worse, many reside in squats, unable to access accommodation from…

21st June 2017 By Free Movement

Should refugees claim asylum upon arrival in their first ‘safe’ country?

“Why don’t asylum seekers stop before they get here?” I have been asked this question many times. There are lots of safe countries on the way, so the argument goes. Why wait until they arrive in the UK to make their claim? They’re not going to get killed in France, after all. The insinuation is that the application for refugee status is cover for the real motive, probably economic, and the UK best serves those ends. With Refugee Week upon us, I wanted to explore this question. A numbers game Firstly, a few facts. During 2016, to the south, 123,370 people claimed asylum in Italy, and 85,244 in France. To…

20th June 2017 By Nick Nason

What is the legal meaning of “refugee”?

This week is Refugee Week. The Free Movement blog is about communicating complex legal issues in immigration and asylum law in a clear way so I have amended and republishing this blog post explaining what a refugee actually is in legal terms. I have also collected together some of our previous blog posts about asylum issues. I hope you find it useful and interesting! I am also making my refugee law ebook freely available for this week. The ebook is a detailed examination of refugee law as it is understood and practiced in the UK. Use code “refugeeweek” as you are making a purchase and a 100% discount will be…

19th June 2017 By Colin Yeo

UK unlawfully denies transfer to UK of refugees living for 18 years in Cyprus British Sovereign Base

R (Bashir) v Secretary of State for the Home Department [2017] EWCA Civ 397 The British Sovereign Base Areas (“SBAs”) are small British-run areas on the Cyprus islands that survived the former colony’s independence. The Home Office has taken the position for a number of years that the Refugee Convention does not apply there. The Court of Appeal has unanimously held that in doing so, then-Home Secretary Theresa May acted unlawfully in denying refugees from the SBAs access to the UK. Background facts The claimants had been rescued from a fishing boat in the Mediterranean in 1998. They had been taken to one of the British Sovereign Base Areas in…

6th June 2017 By Thomas Beamont

Country guidance issued between hearing and promulgation will still bind tribunal

Is the First-Tier Tribunal (FTT) bound to take into account a Country Guidance (CG) case that is issued by the Upper Tribunal after the date of the FTT hearing, and after the date the FTT judge signs the determination, but before that determination is promulgated? The short answer, in general, and for the very unfortunate appellant in NA (Libya) v Secretary of State for the Home Department [2017] EWCA Civ 143, is yes. Timeline The Libyan appellant in this case had been refused asylum and appealed against the decision to the tribunal. The appeal was heard by the FTT and allowed. The decision was made on the basis of information…

26th May 2017 By Nick Nason

Coruscating criticism by President of Home Office behaviour in refugee family reunion case

To summarise, figuratively the Secretary of State does not have a leg upon which to stand either factually or legally. These were the words used by Mr Justice McCloskey, president of the Upper Tribunal, in the judicial review case of Mohamed Al-Anizy. Needless saying, he was not very impressed by the Secretary of State´s behaviour, in this case in relation to her application (or, rather, non-application) of its guidance on family reunion for refugees. Background of the case The Applicant, Mr Al-Anizy, is a husband and father of four children, aged between 3 and 10 years old. The family are Kuwaiti Bidoons. The Kuwaiti authorities issued a warrant of arrest…

19th May 2017 By Nath Gbikpi

Home Office unlawfully relies on Albania guidance for five years

LC (Albania)  v Secretary of State for the Home Department [2017] EWCA Civ 340 The Home Office has relied on outdated guidance to determine asylum applications from Albanian nationals, the Court of Appeal has held. The judgment in LC (Albania) will have far-reaching effects for those people denied protection under bad law over a number of years. The judgment also reiterates the approach to be taken when considering the future behaviour of asylum applicants if they return to their home country. Asylum claims based on sexuality Guidance for determining asylum applications on sexuality identity grounds was articulated in HJ (Iran) and HT (Cameroon) v SSHD [2010] UKSC 31 (“HJ (Iran)”)….

12th May 2017 By Thomas Beamont

Help needed with research project: “Vicarious Traumatisation: The Impact on Solicitors Working with Traumatised Asylum Seekers”

Vicarious or secondary traumatisation refers to the emotional impact of bearing witness and engaging in an empathic way with traumatic material. As a solicitor or caseworker, working with asylum seekers and refugees can be extremely rewarding, but also very emotionally demanding. This electronic research project (conducted by Line Rønning, a psychology student from the University of Copenhagen and Jocelyn Blumberg, clinical psychologist at the Traumatic Stress Clinic, Camden & Islington NHS Foundation Trust), aims to explore the hypothesis that despite training in maintaining a professional distance and an objective stance, solicitors and caseworkers working with trauma survivors may experience vicarious traumatisation. This may be due to bearing witness and engaging…

12th May 2017 By Colin Yeo

Immigration and Refugee Board of Canada guidelines on cases involving sexual orientation and gender identity and expression

1.1 The purpose of this Guideline is to promote greater understanding of cases involving sexual orientation and gender identity and expression (SOGIE) and the harm individuals may face due to their non-conformity with socially accepted SOGIE norms. This Guideline addresses the particular challenges individuals with diverse SOGIE may face in presenting their cases before the Immigration and Refugee Board of Canada (IRB) and establishes guiding principles for decision-makers in adjudicating cases involving SOGIE. 1.2 This Guideline applies to all four divisions of the IRB, namely, the Immigration Division (ID), the Immigration Appeal Division (IAD), the Refugee Protection Division (RPD), and the Refugee Appeal Division (RAD). 1.3 This Guideline applies to…

8th May 2017 By Colin Yeo

Home Office application to delay Calais Jungle child asylum case refused by tribunal

In an oral decision in the case of R (on the application of AO & AM) v Secretary of State for the Home Department (stay of proceedings – principles) [2017] UKUT 168 (IAC) given on 28 March 2017, the Upper Tribunal refused the Secretary of State’s application to stay the Judicial Review proceedings of AO and AM, two unaccompanied minors previously in the Calais Jungle, and who had been refused their transfer to the UK under the expedited Dublin III process. In the decision Mr Justice McCloskey, President of the Upper Tribunal, offers very useful and interesting guidance on the principles to be followed in applications to stay proceedings pending…

3rd May 2017 By Nath Gbikpi

Update from first volunteers for Athens Legal Support Project

A few months ago a group of UK volunteer immigration lawyers, together with the support of ILPA (Immigration Law Practitioners’ Association) set up the Athens Legal Support Project, a 4 month pilot to run from 10 April through to July 2017 to provide legal advice and support to refugees and Greek lawyers in Athens. A few weeks ago we launched our JustGiving page https://www.justgiving.com/crowdfunding/Athenslegalsupportpilotproject and have had the most incredible response and support. In the last 3 weeks alone we have raised over half our target already. Our first volunteers, Julia Lowis and Jo Bezzano, have just returned from Athens, and with our first blog. Please continue to support us….

28th April 2017 By Nicola Braganza

Supreme Court refuses damages to refugee wrongly prosecuted for illegal entry

Shortly after Christmas in 2009, a young woman from Somalia flew into Stanstead and claimed asylum. She had just turned 18. As later accepted by the Home Office, she had experienced severe depredations in her home country. This included her rape at the age of six in the presence of her disabled mother, and the murder of both of her parents. She fled Somalia in 2008, initially to Yemen, where she spent the next year. She was eventually able to fly to Europe with the help of an agent, who provided a British passport to facilitate her entry into the UK. After claiming asylum, the young woman from Somalia was…

26th April 2017 By Nick Nason

Report finds refugees made homeless when granted refugee status

There is an excellent report out today by the All Party Parliamentary Group on Refugees about the problems faced when a refugee is granted refugee status following an asylum claim. Essentially, central government asylum support and accommodation is immediately terminated and local authority support takes time to become available. This leaves many refugees homeless and destitute just as they are finally recognised as a refugee. The report recommends: The creation of a National Refugee Integration Strategy, to be overseen by a specially appointed cross-departmental Government Minister for Refugees. More than doubling the so-called move on period from Home Office support, the time given to newly recognised refugees to find new…

25th April 2017 By Colin Yeo

New case on children seeking entry under the Dublin Regulation

Official headnote: (I) The question of whether the Secretary of State has made a decision on the exercise of the discretionary power in Article 17 of the Dublin Regulation is one of fact which will be determined on the basis of evidence, direct or inferential. (II) Article 17 is an integral part of the Dublin regime. The suggestion that the Article 17 discretion falls to be exercised only where the family reunification criteria in Article 8 are not satisfied is misconceived. (III) Article 17 has a role in circumstances where one of the overarching values of the Dublin Regulation, namely expedition, is not being fulfilled in the procedures and systems…

21st April 2017 By Colin Yeo

Please donate: crowdfunding campaign for the Athens Legal Support Project for refugees

Much needed and important project: Our urgent priority is to fund Greek interpreters. We need 2 interpreters per day for the 3 month duration of the project. At a cost of about €70 per day, we need to raise in the region of £9,000. Any funds remaining will be put towards flights, accommodation and subsistence for volunteer lawyers, the costs of which will be kept to a minimum, but allowing £450 per lawyer for the duration of the project amounts to £11,000. ILPA is also assisting to fund accommodation. I have already made my donation.

18th April 2017 By Colin Yeo

Rare and worrying insight into asylum casework at the Home Office

After that, targets increased to the point that almost everything became subservient to the end-decision. We were set a target of 220 “units” a year. Only an interview or a decision would count as a unit – any casework would not. If I had to call social services because I was concerned about a child, it didn’t count towards this target. It might be an afternoon’s work to do all the right referrals, but ultimately this wouldn’t be credited. That sort of work was disincentivised. If you wanted to do the right thing, you would have to take the productivity hit and risk performance management procedures, ultimately with the threat…

10th April 2017 By Colin Yeo
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