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IICSA Independent Inquiry into Child Sexual Abuse

The Anglican Church Investigation Report

Contents

B.1.2: Safeguarding structures

National safeguarding structure

4. The Archbishops’ Council is responsible for the delivery of safeguarding work across the Church of England. It sets its own budget (although a draft is submitted to the General Synod for approval annually). Since 2013, there has been a significant increase in the funding of Church safeguarding.

Table 1: Funding for Church of England safeguarding by the Archbishops’ Council

Spending on safeguarding
2013 £37,000
2014 £168,000
2015 £401,000
2016 £1,086,000
2017 £1,391,000
2018 £1,582,000
Budget for safeguarding
2019 £1,963,000
2020 £3,189,000

Source: ACE027643_107-108

5. There are several national bodies which provide day-to-day guidance to dioceses on safeguarding issues. Their roles often overlap, although the National Safeguarding Team is the “key national resource for the provision of strategy, advice, policy and training development”.[1]

Table 2: Church of England national safeguarding structure

National Safeguarding Panel National Safeguarding
Steering Group
National Safeguarding Team
Body of external experts.

Provides strategic advice to Archbishops’ Council and House of Bishops.
Lay and clerical members appointed from within the Church.

Provides strategic oversight of national safeguarding activity and monitoring of National Safeguarding Team.

Recommends development of safeguarding processes to Archbishops’ Council, House of Bishops and National Church Institutions.
18 full-time equivalent employees.*

Provides support to Church bodies on safeguarding policy, training and casework.

Provides progress updates on a quarterly basis to the Archbishops’ Council – also reports to House of Bishops on policy and strategic direction.

* [2]

National Safeguarding Panel

6. As a result of the recommendations from the report of the Archbishop’s Visitation to the Diocese of Chichester, the National Safeguarding Panel (NSP) was created in 2014. It is an advisory body of external experts, including two survivors of child sexual abuse. The NSP provides “high level strategic advice” about the Church’s safeguarding systems to the Archbishops’ Council and House of Bishops.[3] It also represents “an important element in the scrutiny and oversight of the Church’s safeguarding activity”.[4]

7. The NSP was chaired by Bishop Peter Hancock (then Lead Bishop on Safeguarding) until September 2018, when Ms Meg Munn was appointed as its first independent chair to “hold the Church to account for the progress it is making”.[5]

8. Ms Munn concluded that the NSP “did not have a separate identity from the Church”.[6] She reviewed the NSP’s membership and revised its terms of reference (approved by the Archbishops’ Council in April 2019). Its membership is now more independent and diverse, and its meetings have increased from four to six times annually.[7] Ms Munn replaced a “rubber-stamping approach” with a focus “in-depth on one issue, and through that, bringing that challenge and scrutiny”.[8] The NSP now “takes a specific issue linked to safeguarding and investigates it in detail” in a similar way to a select committee in Parliament.[9]

9. The NSP 2019 annual report outlined its recommendations for training, complaints, the Clergy Discipline Measure and the Church’s response to the Inquiry’s recommendations. It also set out areas on which it will focus in the future, namely redress, quality assurance, working with other faiths on safeguarding and the Past Cases Review 2.[10]

National Safeguarding Steering Group

10. The National Safeguarding Steering Group (NSSG) was created in 2016 to provide strategic oversight of national safeguarding activity. Members include the Lead Bishop on Safeguarding, members of the House of Bishops, Archbishops’ Council and Church Commissioners, a cathedral dean, and the chair of the NSP.

11. The NSSG is the “primary driver of standards”, in addition to monitoring the performance of the National Safeguarding Team (NST).[11] It makes recommendations on the development of safeguarding processes to the Archbishops’ Council, the House of Bishops and the National Church Institutions.

12. In April 2018, following the Inquiry’s public hearing about the Diocese of Chichester, the NSSG identified a number of issues which required urgent remedial action. It agreed (with the subsequent endorsement of the House of Bishops) key priorities for the future:[12]

  • Clergy selection, suitability and discipline, including:
    • introducing a revised national policy on permission to officiate (PTO)[13] and
    • producing a publicly available national register[14] of clergy.
  • Structure, independence, oversight and enforcement, including:
    • developing a proposal for an independent ombudsman service, to examine the handling of safeguarding complaints, address survivors’ concerns and provide “an independent complaints mechanism”;[15]
    • considering the findings of the Social Care Institute for Excellence (SCIE) final overview report following the completion of the independent dioscesan safeguarding audits; and
    • analysing the benefits and risks associated with the development of a national safeguarding service employing all safeguarding staff centrally.
  • Support for survivors, including:
    • work with the Roman Catholic Church to develop a central community hub-and-spoke model of support known as Safe Spaces and
    • work with survivors to develop an independently chaired Independent Survivors’ Panel.

The Church provided us with updates on this work during the third public hearing.

National Safeguarding Team

13. The NST was established in 2015. It provides advice and support to dioceses, cathedrals, National Church Institutions and other Church bodies about safeguarding policy, training and casework. It reports quarterly progress to the Archbishops’ Council and to the House of Bishops on matters of policy and strategic direction.[16]

14. The Church’s first full-time National Safeguarding Adviser (NSA), Mr Graham Tilby, was appointed to lead the NST. According to Bishop Hancock:

When Mr Tilby was appointed there was a lack of cohesion around practice and policy, and safeguarding staffing levels within the national church were clearly inadequate.[17]

Upon his appointment, the NSA identified “gaps in legislation”, an absence of “whole-church thinking” and “variability in professional competence across the dioceses”.[18]

15. Since its creation, the NST has made a number of changes to safeguarding at a national level.

15.1. The NST’s resources have increased, including the addition of three “key” posts: a training manager, a senior casework manager and a policy manager.[19] It now consists of 18 full-time equivalent employees, supported by associates to progress specific elements of the team’s business plan.

15.2. In September 2016, the NST appointed two provincial safeguarding advisers, one for each of the provinces of Canterbury and York, to provide professional safeguarding advice and support. They also act as direct links between the NST and the dioceses of each province.

15.3. The NST established a framework of external oversight by commissioning the SCIE to conduct independent diocesan safeguarding audits. This work was undertaken between 2015 and 2017, before being extended to cathedrals. The audits are now planned to take place on a five-year rolling programme.

15.4. In March 2018, the NST recruited a safeguarding support officer to professionally advise the Lead Bishop on Safeguarding and to expand pastoral engagement with victims and survivors by offering “significantly increased contact and support”.[20]

16. In June 2018, an assurance review of the NST was conducted by the Archbishops’ Council’s internal audit team. The audit report acknowledged that “the profile of safeguarding within the Church of England has increased, and the foundations for a positive safeguarding culture are being laid”.[21] However, it also identified a number of difficulties, including:

  • a lack of formal enforcement powers over individual dioceses;
  • insufficient engagement with victims and survivors;
  • a limited ability to effectively prioritise and resource key safeguarding activities; and
  • a substantial volume of casework, which meant that a casework management system was “desperately needed”.[22] It often had to manage cases which spanned a number of dioceses, or where the profile or complexity of the case meant that it was more sensibly dealt with at that level.

17. In September 2018, the Archbishops’ Council agreed that the head of safeguarding should be a member of the senior management team of the National Church Institutions.[23] This led to the creation of the role of Director of Safeguarding, held by Ms Caslake since July 2019.[24] She is responsible for the strategic leadership of the NST, engaging with the chair of the NSP and supporting the Lead Bishop on Safeguarding.[25] In spring 2020, Ms Caslake proposed the creation of a regional safeguarding service, staffed by professionals, to provide support both to dioceses and to the NST. It would supervise diocesan safeguarding advisers (DSAs), commission arrangements for independent reviews and risk assessments, and lead regional networks for survivor engagement.[26] The regional advisers would develop consistency between dioceses, work with cathedrals, develop more sophisticated systems of data analysis, and create a system for resolution of disputes and complaints. This was in development in April 2020.[27] A budget of some £1.4 million in additional funding has been approved ‘in principle’, but not finalised, to invest further in training and development of diocesan, parish and national staff and developing the model of regional safeguarding.[28]

18. Further planned improvements include:

  • A national online case management system to document all ongoing safeguarding cases and promote a consistent approach across dioceses.[29] A new design and procurement process will take place in mid-2020, with the system expected to be introduced in June 2021.[30]
  • An information-sharing protocol to improve consistency of approach.[31]
  • Implementing the changes recommended by the SCIE final overview report (published in April 2019).[32]
  • A survivor-led strategy and a Survivors Charter.[33]
  • Considering a form of ombudsman scheme or complaints procedure.[34]
  • Implementing safeguarding progress reviews – structured conversations with each diocese following their audit to review progress.[35]
  • Revising and updating guidance, including the Safeguarding Training and Development Practice Guidance.[36]
  • Implementing continuing professional development for DSAs, and changes in safeguarding training.[37]
  • Producing an e-manual of all national safeguarding policies to be placed on the main Church of England website.[38]
  • Developing national standards to create consistent expectations for safeguarding work in each diocese.[39]
  • Assisting in the development of a Master’s degree in Promoting Safer Organisations: Safeguarding for Senior Leaders.[40]
  • Drafting guidance about dealing with posthumous allegations against church officers.
  • Working with the rest of the Anglican Communion to produce guidance on managing child sexual abuse throughout the Anglican world.[41]

Dioceses

19. The majority of safeguarding practice is undertaken locally within dioceses. Each diocese – “the key institutional unit of the Church” – is responsible for supporting the safeguarding response of its parishes and other local Church bodies.[42]

20. By the end of 2018, all 42 Diocesan Synods had adopted the House of Bishops safeguarding policies and practice guidance issued in 2017.[43] Church officers across all dioceses had access to safeguarding policies and practices with regard to children and adults. By July 2019, all dioceses had some form of safeguarding strategy or plan in place (as required by the relevant practice guidance) as well as a system for responding to and recording safeguarding concerns and allegations.[44]

21. Safeguarding funding at the diocesan level has increased significantly, rising from a total of £895,000 in 2014 to £5.9 million in 2018.[45] However, funding varies considerably between dioceses. We were told by the current DSA for the Diocese of York that there should be parity across dioceses” in resourcing, so that victims and survivors receive “the same experience regardless of where they are in the country”.[46] The Archbishops’ Council has accepted that work is required to ensure safeguarding provision is consistent across the dioceses, but it has not yet established the means by which such consistency can be achieved.[47]

The diocesan safeguarding adviser

22. Each diocese now employs or commissions a diocesan safeguarding adviser (DSA), as required by the Diocesan Safeguarding Advisors Regulations 2016.[48] All safeguarding concerns should be reported to the DSA.[49]

23. All DSAs must have “appropriate qualifications and experience”.[50] This includes a relevant professional qualification in, for example, social work or criminal justice, and the equivalent of at least Level 3 training accreditation in child or adult protection.[51] As a result, DSAs typically come from professional backgrounds such as the police, health, education and social services. They must undergo safeguarding training and attend NST events to promote the implementation of practice guidance.[52]

24. The role of a DSA requires “a number of specialist skills”.[53] As well as coordinating the provision of safeguarding training, working with offenders and providing support to those who have suffered abuse, DSAs are responsible for advising the diocesan bishop on all safeguarding matters, including the referral of safeguarding concerns to statutory agencies and clergy risk assessments.[54]

25. As discussed below, 33 dioceses have a formal agreement with cathedrals. Some also have formal agreements with religious communities or theological training institutions to provide joint safeguarding arrangements. Where this is not the case, the DSA is expected to liaise regularly with the named safeguarding leads … and offer advice on safeguarding matters, as required”.[55]

The Diocesan Safeguarding Advisory Panel

26. By June 2018 (the last date for which figures are available), 38 of the 42 dioceses had established a Diocesan Safeguarding Advisory Panel (DSAP).[56]

27. The DSAP monitors diocesan requirements relating to safer recruitment, criminal record disclosures and safeguarding training. It is expected to “oversee safeguarding arrangements in the diocese”, although it has no powers of enforcement.[57] Each DSAP should be chaired by an independent lay person and have a “balanced membership[58] of the diocese’s senior staff team, church officers and statutory agencies such as the police and social services.

28. Dr Eleanor Stobart, in her 2018 independent review of the Church’s training and development framework, noted discrepancies between dioceses.[59]

28.1. DSAP chairs exercise their role differently, with no consensus across dioceses as to how to achieve the appropriate level of scrutiny.

28.2. In “some dioceses a bishop or senior member of clergy may simply approach someone who they consider would be ‘ideal’”; a more transparent process for recruiting chairs would demonstrate that the Church is not “drawn towards using some sort of ‘old boys’ network”.[60]

28.3. Some dioceses have little or no representation from professionals in external agencies, due to “time constraints and lack of resources in the statutory sector.[61]

29. The new independent chair of the NSP has suggested that the DSAP’s role could be extended. Diocesan bishops might be required to report their safeguarding decisions to the DSAP, to increase the accountability of bishops, who have “a lot of power … a lot of influence, and they aren’t really held to account”.[62]

The diocesan bishop

30. Within each diocese, the diocesan bishop exercises significant autonomy, including in relation to safeguarding. He or she has overall responsibility for upholding effective safeguarding arrangements in the diocese, although the guidance identifies that advice should be sought from the DSA about the execution of these functions.[63]

31. Not every diocesan bishop has complied with this guidance in respect of consultation with safeguarding professionals. In its safeguarding audit for the Diocese of Chester in May 2016, SCIE noted that Dr Peter Forster, Bishop of Chester, “takes lead responsibility for safeguarding and does not delegate it to any of his staff, choosing to retain overall control”.[64] He took all decisions about the threshold for referral to statutory agencies.[65] The DSA was unable to take effective action to prevent this.

32. Following the SCIE audit in the Diocese of Chester, the Diocesan Safeguarding Advisors Regulations were amended in July 2017 to clarify that the DSA is able to refer matters to the police, with or without the agreement of the diocesan bishop.[66]

33. As a result of criticism made in the SCIE interim report, compulsory safeguarding training for all diocesan bishops has been in place since 2015.

34. The sampling exercise (see Annex 3) considered by the Inquiry showed that day-to-day safeguarding management was carried out by the DSA, without intervention from diocesan bishops. The final SCIE overview report concluded that in audits subsequent to their interim report:

there has been no evidence of any conflicts on such decision making and many Bishops have been clear that operational responsibility for casework lies with the safeguarding team and their independence is critical”.[67]

35. Following independent audits in all 42 dioceses and a number of cathedrals between 2016 and 2019, the SCIE overview report stated that:

Bishops have embraced their leadership role in safeguarding generally with some helpfully making positive public messages around its vital importance and integral place in Christian life.[68]

However, it was less clear “how this breaks down in terms of strategic, operational and theological/spiritual leadership” in a religious context. While theological leadership lies with clergy and the bishop in particular, there was a “lack of clarity around what can be delegated and who has the ultimate operational responsibility for case decisions”, including who receives referrals and decides on next steps.[69]

36. Mr Colin Perkins (DSA for the Diocese of Chichester) stated that even now the DSA may not provide a “sufficient counterweight to episcopal authority  especially in situations of disagreement or conflict”.[70] There remained, as Mr Perkins said, a potential conflict of interest between a bishop’s “sense of pastoral responsibility towards his/her clergy, and the responsibility to ensure good safeguarding and disciplinary practice in their diocese”.[71]

37. Mr Perkins advocated for the creation of a new role – the diocesan safeguarding officer (DSO) – to undertake key safeguarding tasks such as risk assessments, suspension and reports to statutory agencies. The diocesan bishop would be informed of the outcome of those actions rather than being involved in delivering them”.[72] Mrs Edina Carmi is an independent safeguarding consultant who has conducted a number of reviews of the Church of England, including for this Inquiry. She considered that a DSO or similar officer would “certainly be an improvement”, although safeguarding should still be at a “more national level” such as a national safeguarding service.[73]

38. Archbishop Justin Welby also supported further change in this respect:

there needs to be a failsafe mechanism which holds bishops accountable … if the bishop fails, there is a failsafe means in which [the DSAs] go to their regional supervisor or the national director and say, ‘I am really concerned about this’, and that the national system or the regional system can call in cases”.[74]

In his view, there were “considerable advantages[75] to DSAs controlling operational safeguarding, making “sure that the DSA has the final word”.[76]

Parishes

39. The parish is the heart of the Church of England. Each has a parochial church council (PCC) which organises the day‐to‐day administration of the parish and is the main decision‐making body. By mid-2019, all dioceses confirmed that they had a system for monitoring safeguarding in parishes. Ninety percent of parishes had a parish safeguarding officer (PSO) to advise on parish safeguarding matters, although each parish should have one according to Church guidance.

Parish clergy

40. The role of parish clergy is to “provide leadership concerning safeguarding, and to encourage everyone to promote a safer church”.[77] Many are part-time or non-stipendiary (ie unpaid).[78] They are often responsible for multiple parishes across a wide geographical area. Parish priests therefore require support from the Church, at both a diocesan and national level, to assist with safeguarding, including training, guidance and pastoral oversight of volunteers. They often have significant responsibilities in smaller and less well-attended parishes, and may need to give considerable support to the PSO.

The parish safeguarding officer

41. The PSO acts as “the key link between the diocese and the parish concerning safeguarding matters”.[79] He or she should ensure that diocesan safeguarding guidance is being fully implemented within the parish. On a day-to-day basis, the PSO should be the person in the parish to whom most people will turn when a safeguarding concern arises, including receiving allegations and concerns about children or adults. He or she is expected to report all concerns to the DSA, as well as to ensure that necessary referrals are made.

42. The Parish Safeguarding Handbook (published in July 2018 and amended in November 2019) is distributed to parishes via diocesan safeguarding teams.[80] It sets out key safeguarding responsibilities for parishes and is intended to “support the day-to-day safeguarding work of parishes”.[81] It is designed to be used by the parish priest and the PSO, who will often be a lay person acting on a voluntary and part-time basis. The parish will require considerable support from the diocese in most safeguarding situations.

Cathedrals

43. Cathedrals are largely autonomous bodies and are governed on a day-to-day basis by the dean and chapter.[82]

Safeguarding in cathedrals

44. Each cathedral is now expected to have a safeguarding officer, who should work with the dean and chapter to implement the House of Bishops’ policy and guidance.[83]

45. Dean Stephen Lake (Lead Dean on Safeguarding) told us that, of the 42 cathedrals, four employ a dedicated safeguarding professional. A further 29 have a service level agreement or memorandum of understanding with their diocesan teams to provide safeguarding services.[84]

46. A programme of independent safeguarding audits by SCIE was initiated in 2018 and is due to be completed in 2021. SCIE has made some positive – albeit early – findings, noting for example that there are “strong systems and procedures for keeping people safe and well-monitored” at Canterbury Cathedral.[85]

Choirs

47. An additional consideration for cathedrals is that all have choirs, which may be made up of both adults and children. Children may be drawn from a choir school or local schools.[86] Cathedrals with choir schools produce their own safeguarding policies. Schools also have a statutory requirement to produce their own policies in accordance with Department for Education guidance. As explained by Dean Lake, cathedrals and schools should liaise in the preparation and implementation of policies, to avoid inconsistencies.[87]

48. All cathedrals have a safeguarding policy that covers the care and well-being of the choristers during periods when they are on cathedral premises or involved in the life of the cathedral. Such a policy should make clear when choristers become the responsibility of the cathedral.[88]

49. Adult choristers in cathedrals must undergo basic and foundation levels of safeguarding training if they are to sing with children.[89] An adult chorister singing with children must have a criminal record (Disclosure and Barring Service or DBS) check at basic level,[90] while a more detailed enhanced DBS check must be sought for those with responsibility for teaching, training or supervising children or vulnerable adults.[91]

50. The SCIE audit of cathedrals (intended to be completed by March 2021) may identify further issues with safeguarding practice in cathedrals.[92]

References

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