Ireland Says Welcome: Appeal to Minister O’Gorman to address new and long-standing human rights concerns and disparities in the international protection system


Ireland Says Welcome letter to Minister O'Gorman



Ireland Says Welcome is a Comhlámh membership group sharing news, information and refugee
solidarity initiatives in Ireland and across Europe. Our vision is of a welcoming, inclusive and
participatory Ireland for those escaping war, persecution and poverty.

To: Roderic O’Gorman, Minister for Children, Equality, Disability, Integration and Youth
by email to:
20th June 2022

RE: Appeal to Minister O’Gorman to address new and long-standing human rights concerns and disparities in the international protection system and refocus on the objective of humanely addressing the accommodation needs of all who arrive in Ireland seeking international protection given the Government’s commitment to end the for-profit accommodation system known as Direct Provision by 2024.

Dear Minister,

We welcome recent improvements in the initial reception process for people seeking international protection, in particular Ukrainians availing of Temporary Protection reported positive experiences in their initial reception.

We are particularly pleased to see the prompt and efficient response of the Dept. of Justice in issuing Temporary Protection Letters and the Dept. of Social Protection in issuing PPS numbers. In the vast majority of cases, people arriving from Ukraine have been met with empathy and humanity in the airport, and at Intreo offices, including a warm reception and suitable areas for children to play while paperwork has been processed promptly. As reported by the Ukraine Action in Ireland survey (June, 2022), 90% of respondents were highly satisfied with the service of receiving Temporary Protection and PPSN.

We echo the recommendation from the roundtable on ‘Migration in our Common Home’, chaired by Social Justice Ireland, that “the ‘human rights first’ approach should be the blueprint for a reshaping of Ireland’s International Protection system”.

However, we have grave concerns about:

  • the disparity between the experience of Ukranians arriving under the Temporary Protection Directive and that of people from Ukraine, and from other countries who seek asylum. People seeking asylum continue to experience delays and unequal access to social welfare, accommodation (emergency, medium and long term) and public services.

On the primary issue of accommodation, we are concerned that the actions of IPAS under the Department of Children, Equality, Disability Integration and Youth (DCEIDY) are compounding accommodation challenges, particularly in

  • the allocation of for-profit contracts to accommodation providers
  • the poor government support to effect accommodation pledges
  • the consideration of expensive, sub-standard modular housing as a solution.
  1. Act to prevent a multi-tiered International Protection system.

In the implementation of the Temporary Protection system, aspects of our international protection process were recognised as inappropriate for people fleeing war. In contrast to the experience of people seeking asylum, arrivals from Ukraine availing of Temporary Protection can immediately access a Temporary Protection Letter, and thereby receive a PPS number, giving them the right to work, right to social welfare etc. We ask the Minister to commit to making the mechanisms for accessing state services, as experienced by that availing of temporary protection, the standard for all people seeking asylum, while their asylum claim is considered. The current system where some Ukranians can access their rights immediately, but others have to survive for protracted periods without these rights is of grave concern and serves only to create disharmony and unrest amongst those fleeing war and other atrocities. We commend the Movement of Asylum Seekers of Ireland (MASI) for drawing UN attention on the issue of Direct Provision in their recent submission to the United Nations and agree that those subject to the Direct Provision system warrant ‘an apology, an independent inquiry; and redress measures’.

It is evident there are discrepancies in eligibility for social welfare payments and housing supports, with many people in the international protection process not receiving the necessary social supports. The discrepancies in housing supports manifest in different ways for those availing of temporary protection v’s those seeking asylum but in many cases sufficient and equal accommodation supports are not being offered.

Preferred social welfare payments for all seeking social protection in Ireland are mainstream payments such as Jobseekers/Disability Allowance/One Parent Family Payment/State Pension. Newly-arrived job seekers should be afforded the recognition that many will require time to adjust, recover from trauma and learn English or new skills. Students and Under 25s are particularly at risk of not being able to avail of sufficient payments to survive in Ireland. Supplementary welfare allowance should be awarded automatically as a temporary measure to ensure arrivals have some payment if for whatever reason mainstream payments are not accessible. This will serve as a barrier against destitution and it is important that staff in the Department of Social Protection receive clear guidance regarding awarding of this payment. The preferred housing payment for those seeking protection in Ireland is a mainstream housing payment such as Housing Assistance Payment (HAP)/Rent Supplement. Although we do not necessarily agree with HAP as the standard housing support for society, it is the current system and so we advocate for it to be equally accessible. We recognise that the Dept. of Housing has long resisted allowing international protection applicants to apply to local authorities for social housing supports. This precludes HAP which requires recipients to first join a housing list. While this problem is not insurmountable and should be addressed, a mainstream housing payment could take the form of Rent Supplement from the Department of Social Protection, which we understand has been awarded sporadically to a small number of Ukranians arriving under the Temporary Protection Directive. This needs to be accessible to all and that needs to be communicated.

In light of the cost of living crisis, we welcome the proposed Host Payment for Pledged accommodation, however we would be gravely concerned if it becomes a substitute for a housing payment, as this would be disempowering for guests and would exacerbate the power imbalance inherent in shared accommodation pledges.

All people who arrive in Ireland seeking International Protection should be treated equally in line with UN ICCPR Article 26. A mainstream social welfare payment and mainstream housing supports should be made available and accessible for all in need of international protection.

2. Address housing challenges fairly and humanely

– Emergency Accommodation

Our group has been distressed to see the reopening of Direct Provision centres that were closed following extensive protests, including hunger strikes against human rights abuses. In particular we continue to be made aware of abuses of power by direct provision centre managers. IPAS continues to operate these contracts with hotels without appropriate governance, feedback loops or escalation paths. May we ask for information on the policies and guidelines that govern the award of emergency accommodation contracts by IPAS.

The use by IPAS of camp beds and floor space in congregated settings such as Citywest Hotel, the Red Cow Hotel, gyms and community buildings brings us to a new low in the standard of emergency accommodation being utilised in the state. This practice should not become normalised for any group in need of housing support in Ireland. People must be provided with accommodation which respects their dignity. Housing should be integrated within the community, and consist of own door accommodation with security of tenure.

We are concerned about reports of short notice moves by IPAS, forcing people to change location, despite children already attending local schools, community links having been established, and paid employment having been secured in many cases. We seek a commitment from the Minister to ensure IPAS end the practice of short notice moves.

– Medium Term Pledged Accommodation

In our Comhlámh Member Group we have multiple Red Cross hosts, Community Sponsorship group members and current Afghan Ascent hosts, as well as the creator of the Register of Pledges and so we are familiar with the various programmes and we have been disappointed to see the government discard the policies and practices of the mature shared pledge program operated by Irish Red Cross safely and efficiently for the past 6 years. This failure to staff and scale a program we know works has resulted in a failure to effect more than a fraction of the 25,000 accommodation pledges (not to mention the services and goods pledges).

To our understanding, sufficient, appropriately-trained and experienced Caseworkers have not been engaged by the implementation partners (understood to now include UN International Organisation for Migration (IOM), multiple NGOs and local authorities). It appears however there is no role in the process for someone familiar with both hosts and guests who can undertake the matching of pledges. Caseworkers, known and trusted by both hosts and guests, are needed for the vital work of matching those needing accommodation to pledged properties with efficiency and a high level of professionalism and safe-guarding. There also needs to be in the process responsible for the necessary ongoing wrap-around supports to ensure the success of pledges and the successful reception and integration of guests into communities. From 2017 up to recently this service was provided by the Irish Red Cross who matched pledges and provided ongoing support based on the needs of the guest, the host and their community. Neither the Red Cross nor other organisations experienced working with migrants are sufficiently staffed to scale these programs to the degree required.

Regarding the bulk of accommodation pledges, recorded by the Red Cross, we understand IPAS are managing the accommodation pledge processing – except preliminary administration, which is still being undertaken by the organisations gathering pledges. We are concerned several critical steps previously carried out by Red Cross Caseworkers are entirely missing from the IPAS process.

The essential steps include

  • vulnerability screening of service users to ensure only those suited to pledged accommodation are housed in this way
  • service user onboarding (including informed consent for data capture and data sharing)
  • screening of shared pledges by trained social care professionals for safe-guarding
  • working with service users to match a pledge to their needs
  • goal setting and sign-posting to ensure those who wish to can access appropriate state and community services.

We are particularly concerned about the potential for safeguarding to fall through the cracks. Reporting structures, escalation paths, clear lines of communication and facilitated mediation are essential mechanisms that ensure safeguarding. A Garda background check at a point in time does not alone constitute safeguarding. There are numerous factors which may make a potential host unsuitable, which are simply not covered by a Garda background check. In the past, the Red Cross has ensured safeguarding with dedicated professional Caseworkers, (trained
professionals from a social care background, who are known, trusted and accessible to both hosts and guests.

A typical light casework model for pledged accommodation could take the form:

Month 1: 5 hrs/week Ensure each person arriving accesses their basic entitlements, i.e. social
welfare and housing support, medical card, links to GP and dentist, school as
appropriate. Time for a Caseworker to facilitate matching a pledge to the
service users’ needs. Time spent on this important step results in fewer failed
pledges and fewer repeat placements which are time-consuming and a bad
experience for hosts and guests.
Month 2-3:
1 hr/week
Allow a small amount of time for goal setting and sign-posting. This is critical
for good integration outcomes and ensures people can link in with local
organisations serving their needs. Prioritise any mediation that is required to
ensure the long-term success of the pledge.
Month 4-6: Escalation path for critical issues only.

Considering cost – to place 1,000 people in pledged accommodation for 6 months with light casework support, would require 16 Caseworkers, at a cost of €600,000. This is a small cost to ensure the success of leveraging 6 months of accommodation for 1,000 people. The massive generosity shown by the Irish public is not being met with the necessary government supports to operate the program safely and effectively. Unless designated persons are responsible for ensuring people can access their rights and entitlements, vulnerable people will fall through the cracks.

The Red Cross alone have received in excess of 25,000 pledges, which represents an opportunity to remove the profit motive from social housing supports and offer a more humane, integrated initial reception for those seeking international protection. Can the Department of Children, Equality, Disability Integration and Youth commit to the relatively small cost of funding Caseworkers experienced supporting migrants, in order to ensure pledges can be utilised promptly and safely?

In cases where pledges fail, it is essential to have an accommodation provider of last resort. The only option currently appears to be for guests to return to the emergency facility at CityWest Hotel. Many hosts will not be comfortable with this and so are put in the difficult position of continuing to host, even when it does not suit them, for example for health or other reasons. Is there any facility for mediation where challenges arise, and is there any respite or alternative pledge process that could be used in such cases? May we ask, under the current system who is the contact point for hosts or guests who experience serious problems living together and who is the provider of last resort should pledges fail and what is the standard of accommodation that will be utilised?

Many generous hosts in Ireland are already hosting people they met through social media, friends of friends, or through organisations such as the Irish Refugee Council, the Scoop Foundation and Helping Irish Hosts.

It is understood that IPAS hold information on people arriving in Ireland who have registered their need for accommodation supports and that the UN International Organisation for Migration also holds records of people seeking international protection.

In May of this year, some hosts identified by the Red Cross as having already matched with guests outside of their program reported receiving calls from a variety of sources including Tusla, Department of Children and Dept. of Social Protection asking them to email their guests’ details to the department. Hosts were rightly reluctant to share guests’ details in this manner. Transparency on data sharing is required under GDPR and communication of the data sharing practices governing the program would be welcome. Please confirm that no persons data is being held in government or other databases without their informed consent.

Finally, all hosting arrangements should be recognised as equal, as should all people be treated equally and given autonomy as regards their accommodation needs. The necessary casework, financial and other supports outlined above, should be made available to all hosts and their guests equally, regardless of how the pledge was first registered or arranged. Thank you Minister for your time in considering this letter sent on World Refugee Day 2022, and we look forward to hearing back from you with the necessary clarifications.

Yours sincerely,

Niamh Phelan, Sally Roddy
On behalf of: Comhlámh Ireland Says Welcome Group