Will it work?

The release of the Safeguarding Structures Board's report to Synod (SSB) has reminded me that I intended to look at how Faithful Responsibility (FR) might have helped prevent or at least mitigate the harms caused in past cases. I've therefore taken the opportunity to analyse both proposals against a selection of recent cases that cover some of the major criticisms of church processes. I will add more as I analyse them.

I look at the case from the perspective of a member of the public watching a news item, (click the title to go to the link) rather than reading the report of a public inquiry or watching an hour long documentary.

Father Alan Griffin and the Two Cities Report

Issues raised:

1. + Sarah's failure to read the report

   1. In her interview, +Joanne rightly points out that Sarah did the correct thing in referring the report to the professionals. But this is not generally known to be Best Practice and is not embedded in our policies and procedures.

      1. FR will, by process and structure design, remove any control of concern investigation from bishops.

      2. SSB does not address this issue.

2. Autocratic Management of the Safeguarding Team

   1. This came from an interview with a former member of the team and included concerns about whistleblowing and use of Non-Disclosure Agreements.

      1. Both FR and SSB have provision for a genuinely independent complaint resolution system, though neither explicitly deals with complaints from within the investigating team.

      2. FR does move the investigation process from the diocesan bubble, which may lessen the pressures on leaders to protect the organisation.

3. Lack of Pastoral Care of clergy

This came from both the former team member and, more critically, though referenced but not covered in detail in the news item, the Coroner's Regulation 28 Prevention of Future Deaths report, which listed the following failures (drastically edited for space and note the Coroner's comment: Usually, I find that I am able to summarise matters of concern succinctly. However, in this instance I find that I am unable to convey the breadth of the systemic and individual failings that have come to light during the course of this inquest without such a level of detail):

1. The initial report was not properly recorded and categorised + The person making the allegations did not accuse Father Alan of sexual abuse but this is what was passed on to the Roman Catholic (he was by then a RC priest) team. + The meeting at which the disclosures were made was neither structured nor appropriate for the nature of the content. + The Safeguarding Adviser was not involved in the initial decisions on process. She said that legal advice should be sought before proceeding, but her recommendation was not acted upon + Father Alan was aware of the investigation but was not told of the accusations for a year

   1. FR creates a portal for raising concerns that will, as part of its remit, categorise them and allocate them to the appropriate party.

   2. FR assumes notification of a respondent but does not detail the process. This needs to be more detailed. A Co-Pilot review concluded: "The proposal contains no arrangements for pastoral care or support for alleged perpetrators at any stage of the safeguarding process." We clearly need to address this.

   3. Apart from standardising diocesan systems, SSB has no recommendations here. Co-Pilot was even more critical of the lack of this in SSB than in FR.

2. The Church of England failed to properly engage with the inquest in a timely manner and had made no attempt to learn lessons from Fr Alan's death.

   1. By making the investigation process independent, FR enables the church to question the process without 'marking its own homework'. The external provider is also more likely to respond quickly and positively as their contract depends on good performance.

   2. SSB does not address the issue of independent investigation.

   3. Both FR and SSB introduce independent oversight and auditing.

3. The Church of England asked the coroner to avoid making a report that included criticism of individuals for "filtering or verifying allegations". The coroner's response was that, "a duty of care and competence in a situation such as this one is not in any way incompatible with the moral duty we all have, and the legal duty that bodies such as the church have, to try to keep children and the vulnerable safe."

   1. In FR, there is a note suggesting the need for remodelling leadership to improve pastoral care generally, but this is not part of the formal proposal.

   2. SSB does not address the issue at all.

   3. See our Blog post FROM SCANDAL TO SAFE

4 Failure to implement all recommendations of the Robson Review

This was challenged in the interview and I've not had time to identify which parts were and were not addressed but my reflection is that such a lack of response is baked into diocesan structures and cultures.

i. FR makes the receipt and investigation of safeguarding concerns entirely independent. This allows, but does not ensure, a more responsive culture to be built from the start.

ii. SSB does not directly address this issue.

Matthew Ineson / Trevor Devamanikkam

1. 8 disclosures by Matthew to 5 bishops and no action

   1. FR removes disclosure and initial investigation from diocesan control. A bishop failing to ensure that a report was made would be subject to legal action as FR makes disclosure a legal duty.

   2. SSB does not address this issue.

2. Appointment of people criticised in reports to new posts with no apparent sanctions

   1. FR creates an independent body (albeit still reporting to the National Church) that issues a Certificate of Ministry, without which no one can be appointed to a protected role. Without the candidate having this certificate, no church official could make an appointment.

   2. SSB does not directly address this issue, though it would begin to shift the culture in a positive direction.

3. Failure to consult victims before restoring a criticised person to ministry.

   1. FR's National Ministry Council includes Survivors, However, there is currently no requirement for those directly involved to be consulted.

   2. SSB does not address this issue. A Co-Pilot review produced something I'd never seen before - a big red X, which was followed by a lengthy description of everything this proposal does not do in this area.

4. Failure of hierarchy to take Safeguarding seriously. Whilst sometimes seen as a controversial character, (I should declare an interest here in that whilst she was Minister for DCMS and I was working with a group trying to stop suicide promotion online, I was impressed by her determination to not bow the knee to the tech giants. After her removal, the online safety bill was watered down to homeopathic levels.) Nadine Dorries, herself a survivor of church abuse, gets to the root of the matter (see brief excerpt below).

   1. FR is a fundamental, wide-ranging rebuilding of the safeguarding system, whilst retaining most of the improvements made over recent years.

   2. SSB improves oversight of processes and procedures but only addresses the independent management of crises. It does nothing to separate the institution's management from critical decisions on what to report or investigate, when to report or investigate, or who is fit for ministry (assuming they have a clean DBS record.)