TIME TO GO NATIONWIDE?

It's 43 years since the BBC last went "Nationwide" but we fear it's going to be at least another 43 years before we see true independent safeguarding, not only in the CofE but across the Faith sector.

Recently, Sam Carling MP spoke in parliament about mandatory reporting of safeguarding concerns in the context of his personal experience with Jehovah's Witnesses. That caused us to look at their website, where we could find no reference to what we understand as safeguarding. Google AI informs us that the relevant body in the UK is the Kingdom Hall Trust. That organisation does not have a website but has claimed to have legally compliant policies. So we looked at a few other, mostly faith-based, organisations. Our choice was random but all that we looked at are included, though the depth we went to with each varied.

(If we'd asked Google the right question, we would have found this NSPCC link which lists the key Faith group safeguarding policy pages!)

The Baptist Union of Britain website has a Safeguarding button on the front page, albeit amongst many others. Clicking that takes you to a page with Report a Concern button. That tells you to report it to the Designated Person for Safeguarding in the church, or to contact the police in an emergency. The Union has comprehensive policies but appears to devolve management of safeguarding concerns to the designated person in each individual church.

The food bank charity, Trussell Trust also has comprehensive policies with a dedicated central team, who can be contacted by email, and give the number for another organisation, 31:8, available by phone between 7am and midnight. It is not clear if this is a contractual arrangement or just a pointer to 31:8.

The Muslim Council For Britain website doesn't have safeguarding listed in its menu but a guide for mosques and madrassahs can eventually be found in the resources section (including information - on 'current' training courses - that has not been updated for 2 years.) There is no easy-to-access information on reporting a concern. The guide is interesting in that it begins similarly to CofE training with the theology of safeguarding and then outlines some serious cases involving mosques and madrassahs and the lessons that can be drawn from them. Like the Baptist Union, all management of safeguarding is delegated to local organisations.

The Methodist Church has a gratifyingly prominent Safeguarding link on their home page. Sadly, clicking the link doesn't currently (we contacted them and received a very positive reply) give any instructions on what to do to report a concern. Like the CofE page, you have to drill down a few levels. The case management structure is similar to the CofE's, albeit with regional managers overseeing multiple equivalents of CofE diocesan teams. The comprehensive suite of policies is easily accessible but we noted that planned reviews have not all been done. Like those of the CofE, the actual documents are wordy and difficult to follow. For example, it is unclear from the various policies exactly how a safeguarding concern is to be handled. One section suggests that the concerns should be made to the Superintendent Minister (equivalent to an Area Dean) who then consults the Safeguarding Officer, whilst another suggests that it is first taken to the local minister and then, possibly, to the District Safeguarding Officer.

The United Synagogue has no mention of safeguarding on its website front page. To find it, you go the menu items at the bottom of the page, click on Byelaws and Other Policies and then scroll down the alphabetical list of Public Policies till you find Safeguarding. There is no guidance on reporting a concern until you get into the relevant PDFs. They have managed to encapsulate their child safeguarding policies into one 35 page document, (for which we give thanks!) It is evident that they worked closely with the London Safeguarding Children Partnership in developing their policy, which is in line with those of a typical school. Where it's weak is in what happens if there's a concern within the wider faith community.

The Roman Catholic Church in the UK devolves Safeguarding - and all other responsibilities - to the dioceses. A look at a local parish only has 'Safeguarding Policy' as a link right at the bottom of the page. This then links to the Brentwood Diocesan Safeguarding page. To report a concern you either need to click a "Contact us" button at the bottom of the page or the menu item 'Victim and Survivor' and then another click, though it's not obvious, on 'Ready to make contact' which gives contact details for the diocesan team. At no point in this process are you advised to contact the Police or Social Services in cases of immediate risk. A 'Parishes' menu item outlines how a report made in the parish is to be dealt with. There's also a list of FAQs, including "I have a safeguarding concern - what should I do?' in which advice is given (in small, pale green font) to contact police or social services in cases of immediate risk.

An even smaller-font menu item at the bottom of the page links to the CSSA - Catholic Safeguarding Standards Agency. This is a nominally independent company though its board includes senior clergy. It has powers that include aspects of those similar to our proposals for a National Ministry Council and National Safeguarding Team. Safeguarding responsibility is clearly delegated to the dioceses - the CSSA is an oversight body only. The National (England and Wales) website has a dropdown menu for Safeguarding with 'Report Abuse' the first item. This takes you to very clear guidelines for reporting (emphasising the duty to report and also to involve statutory agencies.) The Elliott report of 2020 set out the principles that the church should work to (executive summary here), effectively emulating a Professional Standards Board (though it's not immediately clear if this includes maintaining a list of approved practitioners.) The Catholic Church has implemented the structures set out in the report (Church of England please note) though the policy and procedures demanded are either in waiting or carefully hidden!

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What is apparent is that the CofE is by no means alone in not having independent safeguarding, and is arguably further along that road than most of those in our random sample.

Also apparent is that the scope of Safeguarding is unclear. CofE Basics Training implies that the village church is responsible for uncovering everything that happens in its village. The Charities Commission standards includes a similarly wide range of issues under 'Safeguarding'. What the Public are concerned about is the failure to properly act on the most serious abuse cases. For more discussion in this, see our What is and Is Not Safeguarding blog post. As noted in page 7 of our report, Faithful Responsibility, (page 3 of the easy-print/read version) other sectors of life in the UK are regulated by Independent bodies. So, is it time to "Go Nationwide" with the genuinely Independent Safeguarding that the Charities Commission, the Public and the Press are demanding from the Church of England?

Faithful Responsibility provides a ready-made template for a Nationwide Independent Safeguarding structure for all charities working with vulnerable people (including overseas perhaps.) Many non-faith-based charities will already be under the oversight of local and national government regulators so we propose initially limiting this to Faith-based charities.

Based on Faithful Responsibility's report for the Church of England we propose (in summary - see the Report for full details):

1. Overall regulation would be by, or under the control of, the Charities Commission, which would approve overall standards and appoint a Safe-Faith Council (SFC) responsible to the Commission for:

   1. Maintaining a Register of Faith Based Charities which are following this process, and sharing this with HMRC (see FUNDING below)

   2. Providing Independent Review of disputed Case Management Outcomes

   3. Issue and Management of Certificates of Ministry, without which no person will be allowed to hold any designated ministry position in a Faith-based Charity.

   4. Appointing and overseeing the work of a National Safe-Faith Team (NSFT)

2. The National Safe-Faith Team (NSFT) would be responsible for:

   1. Operating (probably via an external contractor, see thirtyone:eight for an example of what it could look like as they are already doing 90% of this) a National Portal for:

      1. Reporting and Recording of Safeguarding Concerns

      2. Triaging and allocating investigation of serious concern reports to the appropriate statutory authority, Regional Group (see 3.) or, for other concerns, to an appropriate contact (probably inside the faith organisation concerned.)

      3. Providing general advice on Safeguarding Practice

   2. Owning all safeguarding policy and procedures for Faith-based charities, with only organisation-specific areas able to be edited (e.g., theology of Safeguarding, organisation structure, etc.) The writing, update, etc., could be done internally or by an external contractor.

   3. Processing all safer recruitment, including DBS and obtaining references. Again, this could be subcontracted to external suppliers - Thirtyone Eight already do much of this or click for an example (known to us) who do a bit more than Thirtyone Eight.

   4. Providing and delivering (online) training resources appropriate to different levels. As with Policies and Procedures, these could have adaptable areas for different Faith contexts but would have a common base.

   5. Running a National Register, which brings together recruitment, training records, concerns and case management data into one system. This system would recommend the issue, limited issue, denial or withdrawal of Certificates of Ministry to the SFC.

   6. Coordinating all safeguarding case management, assigning cases to regional groups as appropriate and supervising cross-regional cases.

   7. Commissioning and instructing Independent Auditors of Safeguarding.

   8. Commission, audit and oversee the work of Regional Groups (ideally multiple, independent suppliers formed by the many excellent specialists currently working across the sector, not by monopolistic big businesses.)

3. The Regional Groups would:

   1. Conduct all Case Management related to a geographical area.

   2. Provide Survivor Communication and/or arrange Survivor Support.

   3. Provide in-person, group training for leaders of worshipping communities (equivalent of clergy, through to bishops) in their area. This would focus on leadership responsibilities but also facilitate sharing of experiences and best practice across the faiths.

   4. Ensure that the NSFT is appraised of issues and recommendations for policies, procedures and training.

   5. Facilitate audit activities in their region.

4. Each Faith-Based Charity would be responsible and accountable, at every level, for:

   1. Clearly identifying the body at each level which is accountable for ensuring that the organisation is creating a safe environment for all it has contact with.

   2. Clearly identifying who (by role and name) holds the legal duty to implement safeguarding and comply with case management processes.

   3. Supporting and monitoring groups of and individual worshipping communities, ensuring they meet their safeguarding duties.

   4. Facilitating quality assurance and learning, and supporting continuous improvement. FUNDING

5. It would be a condition of being able to claim Gift Aid from HMRC that a Faith-based charity providing relevant services is registered with, and follows the guidance of the SFC.

6. Funding for the overall system would be by hypothecated reductions in Gift Aid recovery from HMRC. There are 12,500 parishes in the Church of England. A 1% point (i.e., from 25% to 24% of any donation) would yield £3.6m from the CofE - about what it costs to run Thirtyone Eight, the safeguarding charity that supports 12,000 members with policies, procedures, audits, training, DBS checks, and a phone/online/email portal for queries and concern reporting. Our proposal goes beyond what Thirtyone Eight provide but not massively so, which suggests that the required hypothecation would be less than 2 percentage points. Charities would save on the expense of each constantly updating core policies and procedures as legislation and guidance changes, and by having more efficient Safer Recruitment procedures and dedicated advice lines - our own work in commercial settings showed up to 400% gains in productivity simply by using dedicated resources, and that was before taking advantage of chatbots or other options for dealing with routine queries.

   STAFF REDEPLOYMENT

7. The big issue with this proposal (and with Faithful Responsibility's original proposal for the Church of England alone) is the change in employment of staff currently engaged in casework and provision of case-specific advice. Some will lose the case-related work and others will find that their role in the current organisation is redundant.

   1. Our expectation is that most staff whose role is no longer within a charity would transfer under TUPE to either the National or a Regional body.

   2. Our vision is that the best current staff would form, own and lead Regional Groups.

   3. There is a danger that the large outsourcing groups would see this as another opportunity to raid the public's pocket. Given their abysmal track-record in so many areas, this is our biggest fear with this proposal and would welcome any suggestions to stop it from becoming a Panorama exposé in 2036.