The Round-Up: rough sleeper immigration raids and charity collaboration

Homelessness outreach charities are helping Immigration Enforcement round up and deport London’s migrant rough sleepers.


Several nights a week, immigration patrols are out targeting rough sleepers in London, now a prime focus for raids under Theresa May’s “hostile environment” policy.

The arrests are carried out by Home Office “Immigration Compliance and Enforcement” (ICE) teams. But they rely on the active collaboration of the Mayor, local councils, and homelessness charities. Charity outreach workers set out to help homeless people. But through a creeping process of changes they are being turned into informers, while some of the city’s most vulnerable people are disappeared into the nightmare of indefinite detention and deportation.

This investigation shows how:

  • Outreach teams from charities St Mungo’s, Thames Reach, and Change, Grow, Live (CGL) conduct regular joint “visits” with Immigration Enforcement officers, as often as fortnightly in central boroughs. Freedom of Information (FOI) responses show 141 such patrols organised by the GLA and 12 London boroughs last year. This figure does not include Westminster, the biggest concentration of London homelessness, where patrols are likely to be even more frequent.

  • Joint visits in just eight of these areas led to 133 rough sleepers being detained, while 127 people were deported in under a year in Westminster alone.

  • Charity bosses say their role is to persuade non-UK rough sleepers to leave “voluntarily”. But the FOI figures show that detention and enforced deportation is more common; in any case, so-called “voluntary” departures are carried out under the threat of force.

  • Outreach teams also routinely pass on locations of non-UK rough sleepers to ICE, including through the London-wide CHAIN database, and through local co-operation agreements.

  • The GLA has contracted St Mungo’s and Thames Reach under “payment by numbers” schemes where fees depend on the number of rough sleepers they get out of the country.

  • EU and other European Economic Area (EEA) nationals are the main targets, as they make up nearly half of London rough sleepers. Migrants from Romania, Poland, and other East European countries are particularly affected.

  • In May 2016, the Home Office toughened the rules so that European rough sleepers can be arrested for deportation if found sleeping rough on just one night.

  • Tough policy on migrant rough sleepers was “intensely lobbied” for by Westminster Council, and encouraged by the “Mayor’s Rough Sleeping Group”, which included senior charity managers from St Mungo’s, Thames Reach, Homeless Link, and also Crisis.1

  • Rough sleeper deportations are at the cutting edge of Theresa May’s “hostile environment” approach where immigration controls are spreading across schools, hospitals, and housing.

The “hostile environment” is based on collaboration. But it can be broken by solidarity and resistance. We are already seeing examples of refusal by some homelessness workers and campaigners; the conclusion gives some ideas for how it could spread.

Click here for a PDF version of the report.

Can you help?

We are continuing to collect information and evidence about rough sleeper patrols.

If you are a homelessness worker, rough sleeper, or have any information that you’d like to share with Corporate Watch, email us at contact[at] or call 020 7426 0005. We will respect your confidentiality.

If you have any immediate information about ICE raids, we suggest you contact Anti Raids Network: email: twitter: @antiraids

About this report

This investigation has used three main kinds of sources:

  • Freedom of Information (FOI) responses, which for the first time give some figures on rough sleeper immigration patrols. Requests were refused by the Home Office, but answered by the majority of London borough councils.2

  • Official policy statements and documents, which were accessed through FOI requests or were already in the public domain.

  • Personal interviews with homelessness workers, (former) rough sleepers, and other eyewitnesses.

We have included excerpts from some of these interviews between the sections of the report. Some are in the form of direct quotations, and some as excerpts from interview notes. All have been anonymised to maintain interviewees’ confidentiality.

A few words

In official documents, the Home Office uses the term “deportation” only for the minority of cases where people have been convicted of criminal offences. It officially describes all other deportations as “removals”. In the homelessness sector, an even nicer sounding word, “reconnection”, is common. But in this investigation we use the common word “deportation” to refer to all cases where people are taken out of the country by government agencies and their contractors.


1. Rough sleeping in London

2. Joint visits: outreach workers and ICE patrolling together

3. Data sharing: the CHAIN database and local co-operation agreements

4. Just what is “reconnection”?

5. Homelessness as abuse: the May 2016 policy

6. “Intense lobbying”: Operation Adoze and the Mayor’s Rough Sleeping Group

7. Paid by numbers: the rough sleeper deportation Social Impact Bond

8. Conclusion: how does collaboration happen?

Appendix: a response from Thames Reach

Eyewitness account: a passer-by, December 2016

“I was walking to Charing Cross Station to catch the last train home, it must have been a bit after 11PM. There are always a lot of homeless people sleeping round there at night, on Adelaide Street, near the shelter at St Martin’s church. Then I saw there were three vans parked up there, Immigration Enforcement. I went back up onto Chandos Place, I think, and that’s where I saw a whole load of them, there must have been fifteen or twenty, Immigration Officers and Police together. They were just in a mob surrounding a couple of homeless people. One guy was shouting that it wasn’t right. I started challenging them, but they seemed to have finished whatever they were doing, they started walking back to their vans. There were two other guys with them, dressed in normal clothes, they didn’t look like police, more casual. When I tried to talk to them and ask what they were doing they wouldn’t meet my eye. They looked away, almost like they were ashamed.”

1. Rough sleeping in London

First, a snapshot of London street homelessness. 8,096 people were recorded sleeping rough in London in the year up to April 2016. This figure comes from the “CHAIN” rough sleeper database, a system updated and used by homelessness workers across London, funded by the GLA and managed by St Mungo’s.  As any Londoner with their eyes open knows, rough-sleeping is on the increase, and the CHAIN figures show a 7% rise on the year before. By far the biggest number is in Westminster, where 2,657 people were seen sleeping out in 2015-16. Street homelessness is clustered around the central boroughs, with Camden (641), Lambeth (445) and the City of London (440) next on the list.

Outside London, rough sleepers are predominantly British nationals. In London, less than half are British (41.2% , from the same CHAIN figures). Almost half (47.3%) come from other European countries, and in particular from central and eastern Europe, above all Romania (19.5%) and Poland (8.7%). Overwhelmingly (46.2% of the total count), the European rough sleepers are from countries in the “European Economic Area” (EEA), which includes all EU countries plus Iceland, Lichtenstein, Norway and Switzerland. In normal circumstances, these Europeans have a right to live and work in the UK. There are also smaller numbers of African (5.5%), Asian (4.9%), and American (1.2%) people sleeping rough in London.

Across London, councils commission specialist homelessness charities to run their rough sleeper outreach teams. The central London boroughs with major street homelessness generally contract outreach providers directly. The biggest player by far is St Mungo’s, which runs outreach services for Westminster and other central boroughs. St Mungo’s also runs a number of other key services contracted by the GLA, such as the central “No Second Night Out” (NSN0) hubs where first-time rough-sleepers may be brought, and the “Routes Home” project, which aims to “reconnect” foreign national rough sleepers with their countries of origin (discussed more below).

Outside the centre of London, many councils with lower numbers of rough sleepers sign up for a pan-London outreach service commissioned by the GLA. This is called “London Street Rescue”, and is contracted to another charity called Thames Reach. Basically it involves three teams in vans responding to reports of rough sleepers all around the city’s periphery.

Another charity called “Change, Grow, Live” (CGL), runs street outreach services across the UK and in two central London boroughs, Camden and Lambeth.These are run under the label “Safer Streets”. There are also a number of other charities involved in more specialist outreach services across London.

Eyewitness account: arrested near Charing Cross

“I had been sleeping near Charing Cross on my own for about a month. I was never contacted by any outreach workers before the Immigration Officers came, they arrested me on the spot and took me to detention. I told them I was working for 18 months before, but it didn’t matter. Now I am in detention, they say they are going to deport me back to [an Eastern European country]. I have nowhere to live there.”

2. Joint visits: outreach workers and ICE patrolling together

The Freedom of Information requests asked the GLA and borough councils how many times in the last year their outreach teams had conducted joint visits to rough sleepers together with Immigration Enforcement. They also asked how many people had returned “voluntarily” to other countries as a result of these visits, and how many people had been detained.

Many councils did not answer, claiming that they don’t hold this information. Westminster, the council with by far the most rough sleepers and organised rough sleeper services, was amongst these. As we will see below, Westminster has actively lobbied for a toughened “enforcement approach” to European rough sleepers, and in November and December 2015 it ran a key pilot project with the Home Office called Operation Adoze. We know from a Home Office response to a question in parliament that exactly 127 EEA nationals encountered in Westminster during this operation were deported through Operation Adoze, either in those two months or by September 2016. So there is certainly active Immigration Enforcement in Westminster, and active data gathering too.

Twelve other London councils did reply saying that they had carried out joint visits with ICE the year before. They included all the other inner London boroughs with 160 or more rough sleepers. Between them, they counted 133 such visits, so about 11 each, just under one a month, in each borough.

Based on their replies, there seems to be a rough correlation between the number of rough sleepers in a borough and the number of Immigration Enforcement operations. Camden, number two for rough sleepers after Westminster, said that its outreach teams made 24 joint visits with Immigration Enforcement in the previous year, i.e., one a fortnight. Lambeth, with 445 rough sleepers, had 17 joint visits. (These are two areas operated by CGL “Safer Streets” teams.) Tower Hamlets, with 377 rough sleepers, had 16 joint visits. Lewisham (199 rough sleepers) had 15 joint visits, while Kensington & Chelsea (225) and Hammersmith & Fulham (161) each had 14. The outliers were Southwark and Ealing, which had 373 and 219 rough sleepers, but only five and two joint visits respectively.

What about the other boroughs? Many replied that they had not been involved in any joint visits. However, these were mainly outer London boroughs where outreach is run by the GLA through London Street Rescue (Thames Reach). A number of these councils said that they did not hold the data, and several recommended contacting the GLA instead.

A similar FOI request was also made to the GLA. It replied that London Street Rescue (LSR) had made 923 outreach “shifts” altogether during the “2016/17 financial year” in its areas, and Immigration Enforcement had been present on eight shifts.

This number seems very low compared to other areas. However, it is the case that the LSR outreach service is small compared to inner London equivalents. Also, raids in outer London are often focused on bigger “camps” where ten or twenty people may be sleeping together. It could be that outreach teams often don’t visit these camps themselves, but just report their location to ICE and police who then move straight to a larger operation.

Altogether, the FOI responses identify at least 141 occasions where ICE officers went on patrol together with outreach workers. And this number doesn’t include Westminster or the City of London, which are maybe the most heavily patrolled areas of all.

What happens on these “joint visits”? Of the 12 councils that gave numbers, only seven also answered the further questions about “voluntary returns” and detentions: the other five said they “do not hold” this information.3 The GLA also answered these questions, so we have eight respondents altogether, who between them said they had conducted 83 joint visits. We are told that these 83 patrols resulted in 55 people agreeing to “voluntary return”, and 133 people being detained.

The nationalities involved mirror the general demographics of London rough sleeping. For example, the GLA said that it its eight patrols with ICE, London Street Rescue helped nine people sign up for “voluntary return”. They were from Hungary, India, Poland and Romania. And they helped ICE detain 28 people. They were from Romania, Lithuania, Poland, Latvia, Nigeria, Bulgaria, and Slovakia.4

It is worth noting here one point about the FOI data. As we will see, in their official statements Thames Reach, St Mungo’s and other “partners” are keen to emphasise that their work with Immigration Enforcement is directed at what they call “voluntary reconnection”. Detention and enforced deportation is presented as an exceptional last resort. This is not what the figures show. On the contrary, when charity workers and Immigration Enforcement go out together, detention is a standard result.

However, it could be that most arrests take place not on the initial patrol but at a later date. The role of the joint patrols for ICE is then largely one of “intelligence gathering”. One charity worker explained that, in their experience, “joint shifts” generally consisted of two outreach workers accompanied by one ICE officer. The ICE officer would mainly note locations of foreign rough sleepers and issue paperwork such as a “minded to remove” notice which commands people to report for an assessment interview.

Certainly, a lone ICE officer will not make arrests, but will typically come back later with an arrest team. In raids on rough sleepers, as opposed to raids on other groups, ICE will also commonly request police back-up. Actual arrests may take place with or without any outreach workers present. We have heard of cases of both, as some of the eye witness accounts excerpted in this report testify.

Interview summary: a raid in Haringey

20 people, mostly from Poland, were sleeping rough together near Seven Sisters. A large immigration raid took place with ICE and Police late in the evening. Police and Thames Reach had come to the site prior to this, along with a crew from the BBC. 11 people were detained. Only one was released, all others were removed from the UK. Individuals who were not detained immediately were given 30-day notices of removal and required to report to Home Office during that period. ID documents were confiscated.

3. Data sharing: the CHAIN database and local co-operation agreements

Joint patrols are just one part of the picture. Another form of collaboration is less direct and more routine: every night outreach workers gather information on non-UK rough sleepers, and their managers then pass on this information to become Immigration Enforcement “intelligence”.

As the Home Office has so far declined to answer Freedom of Information requests, we don’t know just how much use ICE makes of information collected by local authorities and homelessness charities. We do know that these organisations routinely meet and share information. In particular, every month the GLA passes information from the CHAIN roughsleeper database to Immigration Enforcement.

The agreement to share this data was made between the GLA and the Home Office in May 2015. According to minutes from that month’s meeting of the “Mayor’s Rough Sleeping Group”, where the agreement was discussed, the data is said to be “aggregate and anonymous”, but enough to identify “locations of non-UK rough sleepers”.

And CHAIN is not the only data sharing route: outreach teams routinely hand on “intelligence” at the local level, too. The FOI requests also asked councils about their overall policies on collaboration with the Home Office. A number of replies shed light on this.

Hammersmith and Fulham council disclosed a “local protocol” produced by St Mungo’s for its outreach teams. According to this document, which appears to be from 2015, St Mungo’s outreach workers should assess the nationality of all rough sleepers they encounter and, if they are European citizens, also assess whether they are “exercising their treaty rights”: for example, seeking employment or education. The St Mungo’s document states in bold type the procedure to be followed if a rough sleeper is judged to “not exercise their treaty rights” over a period of time:

“These individuals’ details will be passed on to the ICE by the outreach team. Following this a joint shift will be agreed with outreach, ICE, Parks Police to target/tackle these individuals.”

As we will see below in Section 5, the approach is likely to have got tougher since this document was produced, and European rough sleepers can now be marked for detention immediately.5

The GLA disclosed a guidance document from Thames Reach, issued to its London Street Rescue teams. According to this guidance, outreach teams should assess all rough sleepers, whatever their nationality, and decide on a “Single Service Offer” (SSO), or way of proceeding with that individual, which is recorded on CHAIN.

For a UK national, for example, this could mean “support to access benefits or work and accommodation.” But in 2014 the Government restricted EEA nationals’ access to Job Seeker’s Allowance and then Housing Benefit, meaning that this traditional route off the streets – a hostel place, and benefits to support them into work and stable housing – is no longer open to most European rough sleepers. Instead, as the Thames Reach document shows, the standard offer for non-UK nationals is now “supported reconnection” to “their country of origin”. (See Section 4 below).

If people refuse offers of “supported reconnection”, they will instead be “brought to the attention of HOICE” (Home Office Immigration Compliance and Enforcement). “These clients will be the subject of [a] local authority task and targeting meeting or will be encountered by HOICE staff during joint outreach shifts.”

The Thames Reach guidance is at pains to state that such “enforcement” is a last resort, and ICE will only be involved after people have consistently refused “offers of support”. We also get a similar message from St Mungo’s, via a FOI reply from Islington Council. According to Islington’s reply:

St Mungo’s would assess any rough sleeper met in the borough. If there was a query over their immigration status they would refer to our in-house legal team for advice. If that offer was not taken up and they did not engage with our service St Mungo’s would then refer to ICE/Home Office. Any EEA national not exercising their treaty rights would be offered a supported reconnection and referred to Specialist team in-house. If the reconnection was refused and there was no engagement with the St Mungo’s service they would be referred to ICE/Home Office.”

As we will see below, since May 2016 Home Office policy is that any EEA national found sleeping rough is “abusing their treaty rights”. The standard “offer” then made to European rough sleepers, particularly since benefits options were removed in 2014, is: leave the country. Thames Reach and St Mungo’s say they aim to persuade people to take up this offer “voluntarily”. If rough sleepers don’t comply, the charities then pass on their details for “enforcement”: i.e., detention and deportation. In either case, the basic outcome is the same, they are out of the UK.

One final point: whatever the charities intend, ICE are not bound to wait until people have refused “voluntary reconnection”. The information they get from joint visits and CHAIN may help them find non-UK rough sleepers even before they are classed as non-complying. Former rough sleepers we interviewed told us they were detained before any “reconnection” process began.

Eyewitness Account: detained in Central London

“I had somewhere to stay, but I had an argument with my partner and that’s why I was sleeping rough in [Central London]. They arrested me and put me here. I have agreed to voluntary return to [Eastern Europe] because I want to get out of detention, if you don’t agree you can stay here for months.”

4. Just what is “reconnection”?

Reading through the councils’ and charities’ official documents, you certainly won’t find any mention of “deportation”, and most likely not “detention” either. The word “removal”, when it is used, generally comes prefixed by “voluntary”. But preferred over all of these is a glorious euphemism: “reconnection”.

We have already seen from the FOI figures that forced detention is actually a much more common outcome of “joint visits” than “voluntary removal”. But we should also mention another two questions. Just how “voluntary” are voluntary reconnections/removals? And just what happens to people who have been “reconnected”?

Voluntary return” is a Home Office term, meaning that people leave the country unrestrained, without a security escort. Voluntary returns are much preferred by the Home Office for cost reasons. Enforced removals typically involve three security escorts, provided by the contractor Tascor, who must each be paid for their shifts and their plane tickets.

Although actual physical force is not used, “voluntary returns” are also generally coercive: i.e., they are carried out under the threat of violence. “Returnees” are told that they will be removed forcibly if they do not agree to the procedure. Lotte Lewis Smith, in a recently published investigation on “voluntary return” of asylum seekers, documents a typical case:

‘Hannah’ said the Home Office tried to coerce her and her young child into accepting voluntary return to East Africa by threatening to cut her asylum support when her initial asylum application was refused. Whilst at her local Home Office reporting centre, Hannah said she was approached by an employee who asked if she would consider returning home ‘voluntarily’ and even offered to help pack her bags and order her a taxi to the airport. According to Hannah, she proceeded to threaten her and her son with deportation if she didn’t accept this ‘help’.”

The same approach is used with rough sleepers, encouraged from the top. An internal report of the Mayor’s Rough Sleeping Group, made up of GLA and council officials alongside senior managers from St Mungo’s and Thames Reach (discussed further in Section 6 below), recommends:

“when support is offered, it can be helpful to make clear that, if it is refused, enforcement will be used – for example, when offering reconnection to EU nationals not exercising treaty rights.”

Another point is that detention and “voluntary reconnection” often go together. Many people sign up for “voluntary reconnection” whilst already locked up. The eyewitness account quoted above shows the clear incentive to do this: people may be held indefinitely in the misery of detention centres before escorted removal, and can get out much earlier by agreeing to leave “voluntarily”. Again, Lewis Smith gives an example:

“The UK is the only EU country with no time limit on immigration detention. Since being refused asylum, 19-year-old ‘Aamir’ from Afghanistan has been held at Harmondsworth Immigration Removal Centre, near Heathrow Airport, for eight months. He has no idea when he’ll be released or deported. Without adequate access to legal or psychological support in detention, and no release date, Aamir is considering ‘voluntarily’ returning to Afghanistan […] ‘I can’t sleep or eat. There is no one to talk to. I feel like I’m going crazy,’ he told IRIN. ‘I don’t want to go back to Afghanistan – my whole family is dead there – but I am scared I’ll kill myself if I don’t leave this place soon.’”

The EEA nationals being “reconnected” may not, typically, face such a hostile fate as an Afghan deportee. But what does await them?

In 2009, Thames Reach was awarded the GLA’s contract for running the “London Reconnection Team” (LRT), which arranged “voluntary reconnections” for rough sleepers in London referred by outreach teams or other services. For example, the LRT would generally pay their travel expenses. By February 2016, Thames Reach boasted that it had achieved “over 3,000 reconnections”. However, neither Thames Reach nor the GLA have made any evaluation of what happened to the people “reconnected”.

In April 2016, St Mungo’s took over the London Reconnections Team contract, now renamed “Routes Home”. The terms of this contract make clear that St Mungos must “work in close partnership with the Home Office and the Police”. “Details of all reconnections are expected to be shared with the Home Office”, and St Mungo’s must “ensure that details of clients refusing reconnection are recorded and passed to relevant referral agencies and the Home Office.”

Under the previous contract, Thames Reach had a relationship with a Polish charity called Barka which provided accommodation for Polish returnees. Insiders say this service had some issues, as Barka was a strongly Christian organisation that insisted on teetotalism in its hostels. In any event, this arrangement was ended with the handover to St Mungo’s in 2016.

The contract does demand that St Mungo’s monitors what happens to people after reconnection in one respect: it has a target for numbers of people not returning “to a rough sleeping lifestyle in London” within six months of removal. But there is no need to track what happens to “reconnected individuals” who stay away. There is no record of how many end up back on the streets in Bucharest (Romania) or Warsaw (Poland), where conditions are extremely tough. What matters, it seems, is just that they are not on the streets of London.

One Romanian NGO study, dating from 2009, put the total number of rough sleeper deaths on the streets of Bucharest at around 300 a year. In January and February 2012, during a six week deep-freeze, Eastern Europe saw staggering numbers of deaths of homeless people: more than 200 in Russia, 74 in Romania, 135 in the Ukraine and 82 in Poland. This last winter, between 1st November 2016 and 7th January 2017, 53 people died of hypothermia in Poland.

5. Sleeping rough is abuse: the May 2016 policy

In May 2016, coincidentally or otherwise a month before the Brexit vote, the Home Office made life even tougher for European rough sleepers.

For the moment, people from “European Economic Area” (EEA) countries, still normally have the right to live in the UK. But there are certain limitations on this right. The general rule is that an EEA national can stay for three months without condition, and after that if they are “exercising Treaty rights”. This means: being employed or self-employed, seeking work, studying, or being “self-sufficient”.

However, in May 2016, the Home Office issued new guidance which created an exception for rough sleepers. Sleeping rough, even just for one night, was now defined as an “abuse of Treaty rights”. This means that rough sleepers can be arrested and deported (or, to use the official jargon, “administratively removed”) immediately, even if they are otherwise “exercising Treaty rights” (e.g., working), or have been in the country less than three months. Although ICE officers are supposed to consider someone’s personal circumstances and whether deportation is “proportionate”.

The guidance was slightly amended on 1 February 2017. The issue is reworded as a “misuse of the right to reside”.6 More importantly, the Home Office has back-pedalled a touch on its hardline approach, as the new guidance further expands on the idea of “proportionality”. For example, ICE officers are meant to consider whether someone is “persistently sleeping rough” or, on the other hand, may be “taking steps to find accommodation and exercise Treaty rights”. It would not be proportionate to remove someone if “while there has been a misuse of rights, it appears unlikely it will continue.”

If an Immigration Officer considers that removing a rough sleeper is “proportional”, they can immediately issue removal papers. These consist of a “liability to removal” notice; and, usually simultaneously, a “decision to remove” letter. “Removal directions”, which may contain flight information, are usually served later in detention, with 72 hours notice. For EEA nationals, the “decision to remove” letter should give 30 days notice before deportation, and within that time they have 14 days to appeal. Someone can be arrested and detained as soon as the “decision to remove” notice is served; but if an appeal is lodged, a deportation should be put on hold while it is heard.

In practice, as two of the eyewitness accounts in this report mention, appeal rights are often disregarded or abused by ICE.

Alternatively, if an Immigration Officer wishes to investigate further, they can issue a letter notifying someone that they must come to a “minded to remove” interview.

Just how do ICE officers assess whether removing a rough sleeper is “proportional”? ICE teams are unlikely to have the skills or resources to assess homelessness issues and whether individuals are “taking steps to find accommodation and exercise Treaty rights”. In our view, if any proportionality assessment is made at all, it is likely to be led by the outreach and “reconnections” workers they are liaising with.

But, if so, the new February guidance means that St Mungo’s, Thames Reach and other charity workers will start to play an even more central role in immigration enforcement. It will no longer be a question of just providing intelligence. Decisions about whether or not an individual is detained or deported will increasingly rest in the charities’ hands.

Interview summary: another raid in Haringey

The interviewee was woken up at 12am at his sleeping site in Haringey along with 7 other people. The raid consisted of 12 people including ICE, Police and Thames Reach outreach workers. The interviewee reported that ICE initially came for someone else but came back to serve a 30-day notice of removal and confiscated people’s ID documents. He asked for the papers to make an appeal, which was refused by the Immigration Officers. The interviewee says he doesn’t understand why Thames Reach cooperates with enforcement agencies. The interviewee had been in the UK for 11 years, working intermittently, and has no criminal convictions.

6. “Intense lobbying”: Operation Adoze and the Mayor’s Rough Sleeping Group

The “abuse” policy fits in the context of a range of new tough measures – Theresa May’s “hostile environment” approach – which extend immigration control to new areas of everyday life and seek to turn thousands of workers in housing, schools or hospitals into ICE informants and collaborators.

In October 2013, then Home Secretary Theresa May announced the parliamentary bill that became the Immigration Act 2014. In her own words, the aim of the act was: “to create a really hostile environment for illegal migrants”. In the more formal language of the act itself, the main aim is to “limit … access to services, facilities and employment by reference to immigration status”. The Immigration Act 2016 made these measures harsher still, and added some new ones.

They include introducing questions on nationality and immigration status into the “schools census”, in which teachers are meant to collect immigration data from children as young as five. In healthcare, new hospital charges plus massive information sharing through the “NHS Digital” patient database. And the “right to rent” rules, where landlords and agents are required to check tenants’ passports and refuse housing to “illegal” migrants.

In all these areas, the push is clearly coming from the Home Office. Hospital or school managers may not be putting up much resistance so far, but they don’t seem to be actively calling for these measures. The same can’t be said for the homelessness sector. In London, the GLA and Westminster Council have been particularly willing and active protagonists. And they have been backed by their charity partners such as St Mungo’s and Thames Reach.

In London, escalating collaboration with ICE was encouraged and developed throughout 2015 by a GLA body called the “Mayor’s Rough Sleeping Group(MRSG). This was chaired in the Boris Johnson era by deputy mayor for housing Richard Blakeway – who now works for housing developer Wilmott Dixon. This group brought together senior officials from the GLA and central London boroughs, the Metropolitan Police and Home Office, plus top managers from St Mungo’s and Thames Reach, as well as other charities including Homeless Link and (on occasion) Crisis.

Minutes show that collaboration around “non-UK rough sleepers” was discussed regularly through 2015 and 2016. For example, the May 2015 meeting discussed the agreement to pass on CHAIN data (see Section 3 above), and established a working group on how to improve joint operations.

This working group drew up a policy paper which made various conclusions, all in favour of greater cooperation with ICE as part of “the use of enforcement in tackling rough sleeping”. To quote a couple of representative passages, it advised that:

“The Police and ICE are not the only agents of enforcement and it is important that different agencies support enforcement work along a spectrum of activity. Outreach workers, as well as Safer Neighbourhood Teams and Community Safety Officers, have an important part to play.”

“There was consensus among participants that partnership working, above and beyond the commitment of resources, is essential to effective use of enforcement. Information-sharing was identified as being of particular importance.”

The paper was presented to the next MRSG meeting in August 2015. It was immediately followed on the agenda by an item headed “joint working between rough sleeping services and ICE”. This discussion was led by Petra Salva, whose title according to her twitter account is Director of “Rough Sleeper, Migrant & Criminal Justice services” at St Mungo’s. Salva discussed a further “guidance” document that St Mungo’s was drawing up on the topic together with another charity, Providence Row.

But the guidance document was not ready by the next meeting, held in December 2015. The group wanted to wait for the outcome of a pilot scheme called Operation Adoze.

Operation Adoze was in fact the trial of what would become the new “abuse of treaty rights” policy. It was carried out initially just in Westminster, in November and December 2015, involving Home Office Immigration Enforcement, Westminster Council, and St Mungo’s Westminster outreach teams. For the first time, the outreach teams and ICE could immediately target someone sleeping rough for deportation, rather than having to assess whether they were “not exercising their treaty rights” over a sustained period. As mentioned above, 127 people were deported in this operation.

In January 2016, the pilot was extended to a handful of other central boroughs. Then, in March 2016, the government declared it a success, announcing it as national policy in the Budget speech. This announcement was warmly welcomed in a press release from St Mungo’s which celebrated “the success of the Operation Adoze pilot”, applauding the “new approach in which immigration officials work with Local Authorities and outreach workers to connect rough sleepers to services that can return them home”.

After the policy was formally implemented in May 2016, Westminster council also crowed about it, and indeed claimed responsibility, in its audit committee report from 30 June 2016. This states: “after intense lobbying, Operation Adoze (Home Office policy change that was piloted in Westminster) has been announced as a national policy approach.”

Interview summary: sleeping in a car

A man from [a Western European country] had been sleeping in his car on a residential street in South London. It seems residents made a complaint to the council, who then arranged for an ICE visit within two weeks. The man was given a “notice of removal” and told to report to Lunar House, Croydon. He made an appeal, which should have meant that the removal was put on hold. However,when he reported to Lunar House he was arrested and spent nearly 2 months in detention before being removed. His appeal was never heard.

7. Paid by numbers: the rough sleeper deportation Social Impact Bond

Operation Adoze was not the first pilot scheme for rough sleeper deportations. Central boroughs have been carrying out joint patrols with ICE, in one form or another, for several years. The first pilot scheme we are aware of was Operation Ark, in 2010-11. This also took place in Westminster, and also involved St Mungo’s and Thames Reach.

We will just give one further example here, which again involves these two charities. In 2012, St Mungo’s and Thames Reach were commissioned by the GLA to implement an “innovative” pilot project addressed at “entrenched rough sleeping”. The key feature of this project was that it was funded through a new form of private finance initiative called a “Social Impact Bond” (SIB). This is a financial technique largely pioneered in the US by investment bank Goldman Sachs, and promoted in the UK by a consultancy called “Social Finance Ltd” which is sponsored by hedge fund boss and Conservative party donor Andrew Law (see here).

The basic idea is that the scheme is at least partly funded by private investors, and carried out by private contractors; and both get “paid by results” depending on how well specific “social impact” targets are met. In the Rough Sleeper SIB, there were five targets, including the obvious ones of reducing numbers of people still sleeping rough and getting them into secure accommodation. But the second highest paid target, up to 25% of payment, was the number of “reconnections abroad”. In short: St Mungo’s and Thames Reach were paid by the number of people they got out of the country.

It turns out that they didn’t do so well. Their target after two years was a total of 142 “reconnections”: 57 for St Mungo’s, and 85 for Thames Reach. Yet by that point they had only managed to remove 77 people (34 and 43 respectively). Possibly outreach workers working on the project were not as keen to chase deportation targets as their managers.

The majority of these removals appeared to involve the charities persuading people into “voluntary reconnection”. However, a 2015 GLA document on the scheme suggests that the success rate was due to improve in year three thanks to an increasing use of force: “with ten SIB clients having recently been referred to the Home Office for administrative removal, the number of reconnections in this year may well exceed the providers’ in-year target.”

On another hopeful note, in the Government’s evaluation report, both St Mungo’s and Thames Reach said they expected “performance against this outcome to improve due to recent changes in the benefits regime.” The restrictions of Jobseeker’s Allowance and Housing Benefit entitlements for EEA individuals then coming int force should “provide a compelling reason for non-UK nationals who cannot claim asylum to return to their home country.”

The same report, though, noted some challenges faced by outreach workers trying to persuade their clients to “go home”. It noted that “having staff who can speak home languages was identified as an element to building relationships”. But even then there was “some mistrust and anxiety reported amongst non-UK members of the cohort who hope to find work rather than return to their home country.” One St Mungo’s “Navigator” was quoted saying:

“Now I’ve got a lot of reconnections and our clients gossip. They ask me ‘but you are going to get paid for that, you want me to go back, if you get rid of me you are going to get a payment’…. To me that feels like a problem… It’s putting the relationship on edge. They trust me and I don’t want to lose that.”

The private finance aspect of the deportation SIB was developed by the “ethical bank” Triodos Bank. According to their website: “As lead advisers on the deal, Triodos Corporate Finance successfully secured £650,000 of working capital funding from a small group of socially driven institutional and private investors.”

While the Social Impact Bond itself has now ended, elements of its approach have been “mainstreamed” into other rough sleeper services. For example, the GLA London Reconnections Team / Routes Home contract won by St Mungo’s in April 2016 (see Section 4 above) again involves “payment by results”. 10% of the contract fee is awarded if St Mungo’s get 95% of a target number of people out of the country, and if they don’t come back within 6 months.

8. Conclusion: how does collaboration happen?

Targeting and deporting foreign rough sleepers is systematic and routine. It involves the collaboration of many different organisations, and many different individuals.

At the top, the orders come from the Home Office – but also from local authorities. In particular, we have seen how the Mayor and GLA have been instrumental in coordinating “enforcement”, and how Westminster Council “lobbied intensely” for tough new rules. Other councils, too, have enacted and promoted the same policies.

Then there are the charity managers. Bosses at St Mungo’s, Thames Reach, CGL, Homeless Link, and others, are dependent on government, GLA and council funding for their salaries and promotions. But they are not just reluctant parts of this system. Senior managers of all the charities just named were members of forums such as the “Mayor’s Rough Sleeper Group” that helped coordinate it. Some have enthusiastically supported collaboration with ICE. Others, such as Crisis, may not be such active participants: but they have not publicly opposed this collaboration.

Managers set the policies but, of course, they only work if outreach workers actually follow them on the street.

Street outreach workers, we believe, are generally people with empathy and compassion. They didn’t go into their jobs to be cops or border guards, but to support people in need. So how does it happen that they end up as part of a system targeting the most vulnerable for indefinite detention and deportation?

In many authoritarian systems, change is introduced incrementally, through a slow or “creeping” process, so that those involved may not notice how it happens. This is how some homelessness workers describe the shift in the sector since 2010, as new targets and ways of working with Immigration Enforcement have been introduced one by one.

In many systems based on collaboration, it is crucial that people are insulated from the consequences of their actions. They do not see what happens next. In the rough sleeper deportation system, this is true in a number of ways. For example:

  • Outreach workers input rough sleeper locations into the CHAIN database: but they may not realise that this information is passed on to ICE arrest teams.

  • Outreach workers accompany ICE on joint visits: but they may usually just see ICE officers handing out notices, while actual arrests may be carried out later, out of their sight.

  • Outreach workers help arrange “reconnections”: but they may not know what actually happens to people after they’ve left.

  • Outreach workers refer rough sleepers who do not accept “voluntary reconnections” onto ICE: but may not know what happens next, e.g., whether individuals are detained. Nor may they have any conception of what the nightmare of indefinite detention and deportation really means.

In all these ways, and more, workers are insulated from the consequences of their collaboration. In addition, they may be led to genuinely believe that their actions are the best ones possible.

For example, one homelessness worker told us how teams began to accept the new focus on “reconnection” outside the UK because it came just as other options were disappearing. The new rules on benefits introduced in 2014 meant that many European citizens lost access to Jobseeker’s Allowance and Housing Benefit, so could no longer use this help to get “back on their feet” in the UK. At the same time, cuts to emergency accommodation were making it harder to find shelter places.

In that situation, it is understandable that outreach workers may think that they are doing the best they can for someone by pushing them to accept “voluntary reconnection”. And if the person doesn’t accept the “offer”? Yes, outreach workers pass on the information that will lead ICE arrest teams to foreign rough sleepers. But what happens with that information, they may feel, is not their responsibility. They can tell themselves that they are just cogs in a bigger system, just “doing my job”.

Finally, it is not only outreach workers who play essential roles in this system. In a sense, we are all implicated. St Mungo’s and other charities need funding from the GLA, but they also need our donations. And when ICE teams round up rough-sleepers right in the centre of London, they can only operate because thousands of citizens around them stand silent or walk on by.

How can we fight it?

Where a system is based on collaboration, it can be broken by resistance and solidarity. Resistance means refusal: refusing to work with ICE or hand over information, refusing to turn a blind eye. Solidarity is crucial because individuals who stand alone in refusing may often be picked off one by one. So let’s talk to colleagues in our workplaces, or friends and neighbours, and find ways to support each other in refusing.

There are already some small signs of resistance to rough sleeper deportations. We have heard of some homeless support agencies and projects that have stopped referring people to outreach teams that collaborate with ICE. We have also heard of some local outreach teams that have resisted collaboration, if only by “going slow” on passing over information.

We can’t put names to these examples. So far, such resistance by homelessness workers takes place “off the radar”. It could be a big step forward if projects start to openly distance themselves from the round-up policy.

Here are just a few thoughts on how resistance could grow. Homelessness workers and organisations could:

  • Refuse – or just “forget” – to hand over information to the Home Office on non-UK rough sleepers, including through the CHAIN database.

  • Stop cooperating with St Mungo’s, Thames Reach and other collaborating charities until these stop working with the Home Office.

  • Make public statements condemning the targeting of foreign rough sleepers and refusing to collaborate.

  • Pass on information about raids to the antiraids network. (Email: twitter: @antiraids).

Individuals could:

  • Stop donating or volunteering with organisations that collaborate.

  • Communicate with your local council about their role in collaboration.

  • Join the new campaign to support targeted rough sleepers coordinated by North East London Migrant Action (NELMA) , and supported by Housing Action Southwark and Lambeth (HASL), Haringey Housing Action Group (HHAG) and others. So far this has included producing legal rights “bust cards” for homeless people in Romanian, Polish, and more languages. Or start something similar in another area.

  • Pass on information about raids to the antiraids network. And don’t just stand by if you see a raid in progress! Here are a few ideas of things you can do.

 Appendix: response from Thames Reach

We contacted St Mungo’s and Thames Reach for comment before publishing this report. We set out the main factual points and also asked the following questions:

  • What steps, if any, do you take to keep in touch with and provide support for people who have been “reconnected” out of the country?
  • Do you have any general statements to make about why you cooperate with ICE in these ways. Do you do this for financial reasons? Do you do so reluctantly, under pressure from commissioners, or do you believe that it is the right thing to do?
  • How would you answer those who say that providing information which helps ICE arrest, detain and deport non-UK rough sleepers is incompatible with your mission of supporting vulnerable people?
  • What would you say to former “clients” who have experienced the misery of the indefinite detention system and forced removal as a result of your cooperation with the Home Office, and cannot understand why outreach workers are involved in this?

St Mungo’s did not answer, but Thames Reach sent us the following reply:

“Thames Reach has worked with vulnerable rough sleepers for over 30 years and our staff witness on a daily basis the dangers of sleeping rough, the detrimental effect it has on people’s health and the potential for destitute people to die on the streets.

In order to work effectively we have developed a wide range of partnerships that enable us to help rough sleepers move away from the streets including partnerships with accommodation providers, migrant charities and the Home Office.

Thames Reach can provide support to help non-UK nationals find legal work so they can successfully make a new life in this country. We also help people access legal support in situations where people have complex immigration issues to resolve.
However, Thames Reach also knows from years of experience that for most destitute non-UK rough sleepers, their best option is to come off the streets and be helped to return home voluntarily.

The cost of their travel is covered, and they are put back in touch with family and friends and connected with accommodation providers and support agencies, including drug and alcohol treatment services and mental health specialists. We stay in touch with individuals to ensure that they are successfully getting their lives back on track.

Rough sleepers from the EEA who are in breach of government residency guidelines because they have not found employment face administrative removal by the Home Office.

If people do not take up a voluntary reconnection and are subject to administrative removal, we will work alongside the Home Office to help put support mechanisms in place for them to ensure that their return home is undertaken safely and with dignity.”

End Notes

1. To be clear: while Crisis participated in the MRSG, including meetings where extending collaboration with the Home Office was discussed, we have not heard or seen evidence that Crisis has actively participated in this collaboration. However, we have not seen evidence of them publicly opposing this collaboration either.

2.The data referenced in this section comes from FOI requests made by Liam Sheehan to the borough councils and GLA. All of the replies can be publicly accessed at under the heading Rough Sleeping EEA nationals.

3.The respondents were Southwark, Tower Hamlets, Lewisham, Haringey, Waltham Forest, Lambeth, and Islington.

4. Note though that the two categories are not necessarily mutualy exclusive: i.e., people can also sign up for voluntary returnafter they are in detention. This is discussed in Section 4 below.

5.Although the Hammersmith & Fulham document is not dated, there are reasons to think it is out of date. For one thing, it also refers to Immigration Enforcement under the old name of UKBA. But also, the new Home Office policy issued in May 2016 states that EEA nationals are now treated as “abusing their treaty rights” immediately they are found rough sleeping. I.e., there is no more three months grace period. See Section 5 for more on this.

6.The legal basis of this guidance is now the The Immigration (European Economic Area) Regulations 2016, made in November 2016 and which came into force on 1 February 2017. These replace the previous EEA Regulations 2006. They set out in general terms the idea of a misuse of the right to reside, but don’t explicitly define rough sleeping as a misuse, which is an interpretation of the Regulations by the February 2017 Home Office guidance.