GBV 66

Communities, Equality and Local Government Committee

Gender-based Violence, Domestic Abuse and Sexual Violence (Wales) Bill : Stage 1

Response from: Community Housing Cymru Group



 Gender-based Violence, Domestic Abuse and Sexual Violence (Wales) Bill

Community Housing Cymru Group response


About Us

The Community Housing Cymru Group (CHC Group) is the representative body for housing associations and community mutuals in Wales, which are all not-for profit organisations. Our members provide over 155,000 homes and related housing services across Wales. In 2012/13, our members directly employed 8,000 people and spent over £1bn in the Welsh economy.[1] Our members work closely with local government, third sector organisations and the Welsh Government to provide a range of services in communities across Wales.


Our objectives are to:

·         Be the leading voice of the social housing sector.

·         Promote the social housing sector in Wales.

·         Promote the relief of financial hardship through the sector's provision of low cost social housing.

·         Provide services, education, training, information, advice and support to members. 

·         Encourage and facilitate the provision, construction, improvement and management of low cost social housing by housing associations in Wales.


In 2010, CHC formed a group structure with Care & Repair Cymru and CREW Regeneration Wales in order to jointly champion not-for-profit housing, care and regeneration.



General points

We welcome the opportunity to respond to this consultation and support the general principles of the Gender-based Violence, Domestic Abuse and Sexual Violence (Wales) Bill and the need for legislation to improve the Public Sector response in Wales to domestic abuse, gender-based violence and sexual violence.

Community Housing Cymru is a member of the Third Sector Partnership Gender Network, which brings together a number of interested organisations and recently fed into the Network manifesto.

Welsh housing associations have taken a strategic approach to these issues and have delivered preventative and supportive mechanisms for many years.

Housing associations do not just provide bricks and mortar.  All of our members provide care and/or support in addition to their landlord role. They support a variety of potentially vulnerable groups across Wales, including:

Our members aim to provide services that support people to live as independently as possible, in safe, vibrant environments. The type of service and accommodation can vary greatly depending on client group – from specialist dementia care at purpose built schemes to floating support to help individuals maintain their tenancy and develop key skills for independent living.

The Equality Act 2010 already requires housing providers to give due regard to the need to eliminate discrimination and to advance equality of opportunity.  Registered providers and housing associations already safeguard their position by complying with the general duty and this includes the establishment and application of policies and procedures regarding anti-social behaviour. 

Housing associations have responded positively to calls from Housing & Regeneration Minister Carl Sargeant, for robust domestic abuse policies to be put in place to protect both their tenants and staff. As of August 2014, all Welsh housing associations reported that they have domestic abuse policies in place for both tenants and staff. This follows work from CHC with our members to ensure they are able to build on and improve existing practice, for example, by partnering with The Equality and Human Rights Commission to deliver training to members at our recent Resource Conference and also sharing good practice via our links with Peabody – a recognised leader in dealing with domestic abuse.

If housing associations are to continue to provide the current level of support to tenants, funding must continue to allow them to grow and develop their housing stock. 

We recognise that social housing tenants may be more likely to have higher support needs than the general population.  Falling revenue budgets mean vital services will be cut, but we believe the Welsh Government should prioritise preventative services. In October 2013, Nick Bennett, then CEO of Community Housing Cymru along with several other third sector organisations including Care and Repair Cymru, wrote an open letter which was published in the Western Mail, asking that Assembly Members use their political powers to help protect vital preventative services during times of economic uncertainty, when a rise in domestic abuse would usually be expected.[2]  The Supporting People budget which helps 56,000 people to live independently each year was subsequently protected. 


RSLs need to be able to take action against individuals who endanger other tenants through their conduct; therefore the proposals in the Renting Homes on anti-social behaviour are very much welcomed, particularly around introducing a more flexible approach to joint tenancies.




The publication of national and local strategies


Members recognise the importance of taking a strategic approach to tackling domestic violence and many have policies in place and are working with local authorities and specialist services to ensure they link in with national and local strategies.  We actively promote this good practice to encourage consistency.


For example, Monmouthshire Housing Association has a tenant and staff domestic violence policy and liaises with Gwent Police on a daily basis to safeguard victims of domestic abuse.


Several members have domestic violence policies built into their lettings policies.  For example, Coastal Housing in Swansea consulted with their tenants whilst developing their integrated policy. 


The sector recognises that while women are disproportionately affected by domestic violence, men can also be victims.  Grwp Gwalia Currently run two domestic violence projects, including one for men, participate in best practice groups and feed into a broader statistical database.


Gwalia manage a number of domestic abuse projects that meet the needs for male/female victims of domestic/sexual violence.  Gwalia are responsible for the Management of Cedar House which is a 5 bedroom refuge for male victims of domestic/sexual abuse.  It is the only male refuge in South Wales, however this means there are rarely any voids and it can be difficult to access. 


Cedar House is funded by Supporting People.  In 2012 Gwalia was successful for receiving a tender with Housing Advice Centre (HAC) in Pontypridd and through their referrals Gwalia supports victims (male/female) in the community.  The main aim of this service is to assist victims who are at risk of homelessness’ due to domestic abuse.  Gwalia is the only project in Rhondda Cynon Taff that supports low/medium male clients who are at risk of domestic abuse. 


All of the statistics for Gwalia are fed into a quarterly report for HAC and the Domestic Abuse & Sexual violence coordinator.  Gwalia provide supported housing for clients experiencing complex needs and we know from research that domestic abuse and complex needs can go “hand in hand”.  For this reason all staff working in supported accommodation access domestic abuse training/support.


Alongside this, Bron Afon’s approach to preventing domestic abuse and supporting victims has been highlighted by Welsh Government as good practice. Bron Afon hold a daily conference call with partners, and are able to evidence the positive impact this has had on victims.







The appointment of a Ministerial Adviser on Gender-based Violence, Domestic Abuse and Sexual Violence.


We support the introduction of a Ministerial Adviser as a central point of contact through which we can feed in information and data and raise emerging issues. 


Any potential barriers to the implementation of these provisions and whether the Bill takes account of them.

We have not identified any potential barriers within the proposals but we recommend that all further policy in this area is made in consultation with key partners such as housing providers, local authorities and Police Commissioners.


Whether there are any unintended consequences arising from the Bill.

Although there are no unintended consequences arising from the Bill, we are wary of further duties being place on housing providers in future. As demonstrated by the full compliance with domestic abuse policies across the sector, and a number of the good practice examples highlighted, the social housing sector is committed to tackling and preventing instances of domestic abuse, and supporting victims.

[1] Measuring the Economic Impact of Welsh Housing Associations, November 2012

[2] In support of Supporting People, Cymorth Cymru July 2013