Integrating GS2429 and Faithful Responsibility

The Safeguarding Structures Programme Board submitted GS2429 (click to read/download) to General Synod on 11th February 2026. It was approved overwhelmingly. Whilst we were promised a response (by last September) from Archbishops Council to our proposals, none has been forthcoming. Accordingly, with advice from our friends in the media and a wise bishop, we have offered to assist with the Board's ongoing work.

The key features of GS2429 (my emphases) are:

• A vision for a new charity, provisionally named as the Independent Safeguarding Authority. This charity will be an operationally independent organisation, led by a majority-independent non-executive Board. Executive functions of the charity will be led by a Chief Safeguarding Officer, whose operational safeguarding responsibilities will be a protected function of the charity and not subject to Board discussion or determination.

• A plan for a new, standardised complaints handling process comprising:

  • A standard mandatory process for each Diocesan Board of Finance and other relevant Church bodies to follow; and

  • A national external ombudsman-style body to provide resolution of complaints after processes within Church bodies have been exhausted.

Already Done by Faithful Responsibility

These are the areas where we think Faithful Responsibility's work (FR) can contribute to the Board, (SSB):

1. The proposed Independent Safeguarding Agency (ISA, noting that the name will probably change) and the National External Ombudsman together embody much, but not all, of what FR proposes for the National Ministry Council.

2. A key element of FR is the process for Safer Recruitment and, linked to this, the process for dealing with the outcome of concern investigations.

   1. Among the points brought up in Synod were the diversity in process and policy between dioceses and the difficulty in finding people to undertake the work at parish level. FR proposes centralising the 'safer' element of safer recruitment including DBS necessity and checks, reference gathering, etc., and adds in the capability to look further into, for example, past concerns that individually did not result in action. For clergy, this was once the 'blue file' and mine is apparently "unusually thick" according to one bishop. FRs proposed national database could have this for all appointments.

   2. The David Tudor case highlights the difficulty of managing a person about whom multiple serious concerns have been raised but with no sustained criminal conviction. Likewise, the scandal of bishop Peter Ball being able to continue to minister after the concerns raised in the 1970s and then after the Caution he received in 1993 would be addressed by FR's proposed Certificate of Ministry. This is issued by the Independent NMC/ISA and can be withdrawn or subject to restrictions. Whilst a bishop could still appoint someone without that certificate, or ignoring any restrictions, (they thus remain responsible and accountable), they would probably be foolish to do so.

3. FR proposes that all members of Archbishops Council, ISA/NMC, NST and Diocesan leadership (minimum of Bishops) undergo Trauma informed Practice. training. We note that Chelmsford diocese has already done this and recommend consulting them.

4. FR proposes changes in canon law to clarify the responsibilities and accountability of church officials.  However, note our blog post on the Seal of the Confessional.

5. FR proposes Independent Regional Safeguarding Teams who would manage investigations. Synod voted decisively against an amendment to implement this (349:1 if I recall correctly). Briefly, our reasons for this are:

   1. In reviewing multiple cases that resulted in media reports, a common theme emerged - the role of bishops. Whilst Synod (see +Philip North's speech in the GS2429 debate) and the few diocesan safeguarding teams who have responded to us are passionately in favour of keeping safeguarding investigations in-house, this is, from our reading of all investigations and from stories we have heard from survivors, completely unsustainable.

   2. A point raised in passing at Synod was the disparities in resources and allocation of those resources between dioceses. This is discussed in detail here. Creating Regional Teams would eliminate this.

   3. We don't have access to detailed workloads for current Diocesan teams (with Chelmsford team's annual reports being a rare example of candour) but suspect that much of their work could indeed remain locally based. It is the investigation of serious concerns that must be made Independent. We note that this is sometimes done already by referral to the National Team but usually only after the horse that bolted from the stable has died of old age.

6. FR proposes a central portal for managing incoming concerns and queries.

   1. It is not easy for an individual to make a report. Parish Safeguarding Officers are the source of most reports in the one diocese from which we've found a report with statistics. Why? Halfway through this blog is a comparison of the Scouts and the CofE websites. Many dioceses do not provide 24/7 coverage.

   2. A single portal would enable 24/7 Independent (i.e., with no filtering, however well intentioned, by the parish) reporting.

   3. This would address any variation in advice across dioceses. We admittedly only have anecdotal evidence for this but don't doubt that it happens.

   4. Our commercial experience is that separating such work from the equivalent of investigation or support work results in greatly increased efficiency.

7. FR proposes the creation of a national database, which would ensure that multiple minor concerns arising across dioceses would be apparent and the individual helped to deal with any underlying problems before a serious concern arises.

8. A speaker at Synod raised the issue of church officers operating in non-CofE contexts (e.g., Iwerne /John Smyth). FR proposes a mechanism to address this.

9. Archbishops Council continues to downgrade Safeguarding in its priorities (it gets a possible mention in #7.) FR proposes requiring that it and Bishops Councils behave like every PCC we know and make it the first topic on every agenda.

Not (or not fully) Covered by Faithful Responsibility

These are the areas that we are aware we have not yet addressed or which our past-case work-throughs have highlighted as needing additional detail):

1. Our decision making on sanctions is weak. We are working on a hybrid model, combining a 'points-based' system combined with case-by-case discretion. The former would create automatic 'red lines' and the latter would enable more nuanced decision making in less clear-cut cases.

2. The implementation plan for moving from Diocesan to Regional Teams is not detailed. Based on my commercial experience, I would recommend:

   1. Initially working with one team that is open to trying new ways. Divide their work up into what would go National, Regional and Local and model this to see what problems it raises. Fix them rapidly as we go until it works.

   2. Assuming a. is successful, spread this to a group of dioceses, with the National & Regional roles fulfilled by specific groups drawn from these teams and probably also the NST. Again, fix rapidly as we go.

   3. Alongside b., work with the NST to select a supplier for the National Portal and first Regional Team and then run a trial with the dioceses involved in step b., again using rapid improvement methodologies.

   4. Meanwhile, work out the TUPE requirements and detail of the Regional Teams, and National Portal.

   5. Do it. In the commercial world, I've done similar projects over periods ranging from 3 days total (including moving machines the size of a house) to a year, depending on complexity, risk and technology. This project is not complex in itself but it is in terms of the plethora of non-combatants wanting to decide when and where to advance. (Yes, you can include me!)

3. FR contains no arrangements for pastoral care or support for alleged perpetrators at any stage of the safeguarding process. This needs addressing. See the Jay Report pages 28-29.

4. FR makes a brief reference to the need for a radical change in leadership culture to address the root cause of all safeguarding failures but gives no details.

   1. See From Scandal to Safe, noting 70s guru Peter Drucker's maxim on the three most important factors in implementing change:

      1. Senior management commitment

      2. Senior management commitment

      3. Senior management commitment

   2. Real change will not be achieved through the ISA/NMC, etc., precisely because they are Independent. It has to start at the very top but I fear Archbishops Council is too atrophied to be an engine of change so the best hope is with the Bishops. There are some who are beginning to operate in supportive ways and it would be good to get them together to work out how to take it much further and much faster.

5. The reliance of the church on protracted reviews, the results of which are mostly honoured only in the breach and fine words.

   1. Lengthy reviews never fix problems until the victims are too old or too dead.

   2. We need to normalise very rapid problem solving that gets to the root cause of every failure and eliminates it immediately.

      1. In the factories I was responsible for, the target time for problems with a single process step, in both production and administration, was 3 minutes.

      2. For complex problems with an overall business process, the target was a week. In that week, we would typically see the elimination of errors and 40% productivity gains.

      3. My record was 3,000% productivity gain and error reduction from 15% to zero from a two week project in a very complex business process.

      4. My fellow author implemented a complete and successful safeguarding system for a far more difficult environment than the church in 6 months.

      5. Can we please get on with it?

6. The role of Survivors in both the design and operation of the system needs more careful thought.

   1. Both FR and SSB propose having Survivor representatives in the ISA/NMC. Let me be controversial here. Every survivor's experience is different. How can a 'token few' truly represent the overall view? FR leaves this a bit open by saying that the representatives would be 'chosen by' Survivor Groups, not necessarily 'chosen from'.

   2. Likewise, the integration of Survivor experience and views into the sanctions process must be thought through. The judicial model of victim statements is perhaps a model to be considered, though we would need advice from experts in the field as to how that works in, for example, these two cases:

      1. In an historic case, the 'victim' has suffered severe consequences over decades from the abuse perpetrated on them. The resulting sanctions, even where no criminal conviction was secured, would probably be severe.

      2. A victim in a recent case is still in thrall to their abuser and asks for clemency. Would a severe sanction cause harm to that victim?

   3. I don't have an answer to b. The Peter Ball case may give some guidance.

7. This is not an exhaustive list. Please help us add to it.