Churches' Child Protection Advisory Service
RESPONSE TO SIR ROGER SINGLETON
re CHILDREN’S PROVISIONS IN THE VETTING AND BARRING SCHEME
1.0
The Churches' Child Protection Advisory Service
1.1
The Churches' Child Protection Advisory Service (CCPAS) welcomes the
opportunity to comment on matters raised in Sir Roger Singleton’s letter of
19 October 2009.
1.2
CCPAS is a UK-wide, independent, Christian charity providing professional
advice, support, training and resources in all areas of safeguarding children and
vulnerable adults to churches, para-church organisations, other faith and nonfaith based organisations and to families and those affected by abuse. A
significant amount of work is undertaken with Local Safeguarding Boards across
the country and with other faith organisations, eg Councils of Mosques.
According to independent research, some 37% of all churches in England use
CCPAS services. Our safeguarding magazine ‘Caring’ for churches and
denominations has a mailing list of 19,000 copies. Assistance is readily
accessible from professionally qualified and experienced child protection staff
through a 24 hour telephone helpline and via the internet.
1.3
We have a specific project working with African communities in relation to the
issue of spirit possession, working closely with other organisations and statutory
agencies. CCPAS has pioneered procedures for working with offenders in
churches, and our policies are used across the faith spectrum, and
recommended by the National Offender Management Service in their MAPPA
guidance.
1.4
Specifically, in relation to issues concerning criminal records checks and the
new Vetting and Barring Scheme, CCPAS is one of the largest CRB umbrella
bodies, carrying out in the region of 30,000 checks a year for faith and non-faith
organisations. This involves giving advice on blemished disclosures and
assisting groups in responding to the range of safeguarding issues raised in
relation not only to those who apply to work with children and young people who
could pose a risk to children or vulnerable adults, but others known to be part of
a congregation in a place of worship.
2.0
ISA and Vetting and Barring
2.1
In March 2009, CCPAS carried out a survey of all churches in England. This
included a question in relation to knowledge of the Independent Safeguarding
Authority. There was a distinct lack of awareness of the ISA and the new
Regulations amongst almost two thirds (64%) of churches. Roman Catholic
churches were more aware of the requirements than other denominations (61%),
especially the smaller ones. The larger the church, the greater the likelihood of
an awareness of ISA requirements. Clearly the level of ignorance about the ISA
was a matter of some concern, but unfortunately the void in terms of lack of
information was later to be filled largely by misleading press reports in relation to
the Vetting and Barring service which, of course, in turn led to the request of the
Secretary of State for Sir Roger to give fresh and independent consideration to
these matters.
2.2
Between September 2009 and July 2010, CCPAS is sponsoring 17 ISA
roadshows across England and Wales. We hope to be adding some venues in
Northern Ireland. To date, 4 roadshows have been held, with presentations
being given by officials from the Department for Children, Schools and Families,
and the Home Office. Several hundred participants have attended across the
range of different churches and faith organisations, with some people from nonfaith groups attending too. These two-hour events have involved a presentation
lasting for about 45 minutes with the remainder of the time being allocated to
questions and discussion.
2.3
It is of significance in our view that not a single person has objected to the
scheme, and the only issues raised in relation to the terms ‘frequent’ and
‘intensive’ have related to their application. (See example below in relation to
Cathedral guides). The feedback we have received does not, therefore, support
in any way the concerns which have been expressed in the media. In our view,
the challenge is not so much in terms of making any fundamental changes, but in
helping the general public to understand the requirements in simple terms. We
recognise that this is not an easy task.
3.0
Some specific observations
3.1
As indicated above there is, in our experience, universal support for the scheme.
We believe that the government has got the balance right, though some
clarification regarding certain roles is necessary. We appreciate that some
aspects will be clarified in sector guidance in due course.
3.2
There is a difference between the Vetting and Barring Scheme guidance
published in October 2009 in regard to the frequency and intensiveness test, and
that stated in Sir Roger’s letter of 19 October. The guidance in relation to the
intensive nature of the contact refers to 3 days or more in a single 30 day period,
whereas Sir Roger’s letter refers to 2 consecutive days over the 30 days.
3.3
We feel there could be a case for granting an exemption in certain areas, e.g. in
relation to school exchanges where a teacher is coming from abroad. ISA
registration in these circumstances would appear to be quite meaningless as
individuals will have no history in the UK to on which to base that registration. It
could give a false reassurance about an individual.
3.4
We would also question the need for registration for ‘one off’ events that faith
communities engage in. For example a one week holiday club running Monday to
Friday for a few hours each day. Often additional workers are called upon to
assist the regular children’s workers just for this activity. We question whether
these additional workers need to register with the Scheme. [OFSTED have
altered their criteria for registration for day care provision from 5 days to 14 days
in recognition of such activities.]
3.5
A point raised with CCPAS by a cathedral concerns the role of guides
responsible for showing groups of children around. They are normally in the
company of their teachers. This involves tens of thousands of children visiting
cathedrals every year. However, an individual guide is only going to meet a
single child on one occasion in all probability, even though they could be
‘employed’ in showing groups around for 5 days a week. Such individuals
therefore have frequent contact with children, but are like many others such as
shop workers and taxi drivers, who are currently excluded from the provisions of
registration yet have contact with children in the course of their day to day work,
though do not have on-going supervision responsibilities for the same children.
Some clarification in regard to such activities would be helpful.
3.6
In commenting on the Faith Sector Guidance one of the scenario answers from
the ISA was that individuals cannot be ISA registered for working abroad. This
will exclude all UK based charities and missionary organisations from the need to
register for such activities. In asking a question about a church group going out
on mission the reply in the draft guidance was:
“The scope of the Vetting and Barring Scheme does not extend beyond England,
Northern Ireland and Wales, meaning that it would not be possible for individuals
working outside the UK to register. For those working in Scotland, registration
would be required with the Protection of Vulnerable Groups Scheme which is a
comparable system to the Vetting and Barring Scheme.”
This is, in our view, a potential loop hole.
CCPAS is happy to provide further information on any of the above points or generally.
David Pearson
Chief Executive
6th November 2009