Multi-Agency Public Protection Arrangements (MAPPA): national guidance

7. National Accommodation Strategy for Sex Offenders (NASSO)

7.1 The National Accommodation Strategy for Sex Offenders in Scotland (NASSO) sets out how housing contributes to the MAPPA arrangements for Registered Sex Offenders (RSOs) – those subject to the Sex Offender Notification Requirements (SONR). It explains the roles and responsibilities of local authorities, social housing providers and other statutory agencies involved in the accommodation and management of RSOs. It also sets out the requirements for information sharing between Responsible Authorities and housing providers.

Housing agencies

7.2 Housing agencies include both local authority housing services and Registered Social Landlords (RSL).

Local authority housing services

7.3 Local authority housing services are included as a Responsible Authority (included within in the wider local authority remit).

7.4 Local authorities (including those who have transferred their housing stock) are responsible for ensuring the development of a strategic response to the housing of individuals subject to the SONR. To do so they must involve and talk to RSLs in their area. This should include an assessment of local need and provision for the range of housing for individuals subject to the SONR and should clarify the contribution by RSLs in their area.

7.5 The key housing contact in each local authority is the Sex Offender Liaison Officer (SOLO). The main aim of the SOLO role is to be the initial point of contact for housing enquiries for individuals subject to the SONR and to be the link between the Responsible Authorities and social housing providers under a DTC. In this role, the SOLO will:

• Identify housing providers who could potentially assist with rehousing using information about the individual from the Responsible Authorities;
• Make sure that the liaison arrangements for identifying suitable housing and supporting the management of risk by the Responsible Authorities includes the housing provider; and
• Liaise pro-actively with Responsible Authorities and housing providers on on-going risk management and community safety issues.

Disclosure

7.6 While it is for each local authority to determine the level of disclosure required when recruiting a SOLO in accordance with their organisation's security clearance procedures, it is advised that as a minimum, an enhanced disclosure check should be undertaken. This should be reviewed on a regular basis.

Registered Social Landlords

7.7 RSLs are DTC agencies and as such they have to co-operate with the Responsible Authorities. RSLs do not themselves have responsibility for assessing and managing risk. The key housing contacts in each RSL is the Link Officer. The role of each RSL is to contribute to the Responsible Authorities management of risk by:

• exchanging information on housing with the Responsible Authorities;
• identifying and allocating housing that has been assessed as suitable by the Responsible Authorities;
• liaising with the Responsible Authorities on their on-going management and monitoring of the risks the individual may pose; and
• having in place arrangements with the SOLO and the other Responsible Authorities to deal with situations where a property is no longer suitable and/or the individual's safety is at risk, or if there are behaviour changes that suggest that the individual poses a risk to the community.

7.8 Housing providers depend on effective information sharing protocols and a co-ordinated approach by Responsible Authorities. Responsible Authorities must therefore ensure that:

• they have effective liaison arrangements in place with the SOLO;
• housing providers receive (through the protocols for information sharing) sufficient information to manage tenancies occupied by individuals subject to the SONR;
• they consider the size and stock profile of landlords when making decisions about housing; and
• they respond effectively to on-going issues of community safety (including issues for specific victims) identified by housing providers.

Environmental risk assessment

7.9 An environmental risk assessment (ERA) is used to identify housing-related risk and informs decisions on the most suitable housing for each individual subject to the SONR that will minimise the risks to the community. The assessment brings together information on the individual, proposed property and location and nearby households to enable a decision on housing an individual to be made that will minimise the risks to the community.

7.10 An ERA must be carried out for every new RSO on initial registration and any subsequent change of address. Thereafter, as a minimum an annual review will be carried out for:

• all RSOs being managed at MAPPA levels 2 and 3;
• all RSOs level 1 high / very high risk individuals;
• all individuals subject of a Sexual Offences Prevention Order (SOPO) or a Risk of Sexual Harm Order;
• all individuals who have committed contact offences against children or adults at risk of harm; and
• any other individual who is subject to notification and it is deemed necessary to do an ERA. For example, home leave addresses and additional registered addresses.

7.11 Where an annual review has not been done, the Responsible Authorities should record their reasons for not completing one.

7.12 An ERA is accurate at the time it is undertaken, but the changing nature of communities mean that the Responsible Authorities must keep risk management arrangements under constant review. Social housing providers should make sure that the Responsible Authorities routinely receive, on a case by case basis, relevant information on changing household composition in the area. Updates should be supplied within the timescales agreed with the Responsible Authorities.

7.13 When information is received that the risk to the RSO or the community has increased significantly, Responsible Authorities should discuss and consider the suitability of the address. If measures cannot be put in place to mitigate the risk, then where appropriate the RSO should be moved from the address. This can be considered outside of the usual MAPPA meeting process. Where information suggests for example that a RSO has communicated with a family who has young children in same block of flats where the RSO resides then it may be necessary to discuss with agencies involved in Child Protection and consideration given to next steps. Further information on child protection can be found in the National Guidance for Child Protection in Scotland 2021.

7.14 Housing circumstances must be discussed and considered at MAPPA review meetings. Where appropriate, information is shared at MAPPA Level 2 and 3 review meetings and decisions recorded as to the suitability or otherwise of environmental risk assessed properties being allocated to RSOs. All agencies involved with the management of the individual including the local authority, SOLO and RSL Link Officer should be involved in these meetings.

7.15 Please note that whilst the NASSO only covers individuals subject to the SONR, if the person concerned is a Restricted Patient or an Other Risk of Serious Harm individual (MAPPA Category 3), in practice the Responsible Authorities should be agreeing a local approach to using the same principles and arrangements for the housing of these MAPPA individuals.