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IICSA Independent Inquiry into Child Sexual Abuse

The Anglican Church Investigation Report

Contents

B.1.4: Safeguarding in recruitment and training

59. The Church of England must recruit the “right clergy” and other church officers, and “train them well”.[1] Archbishop Justin Welby observed that “we should see whether people … get safeguarding”.[2]

Safeguarding in recruitment

60. Although the Church has national Safer Recruitment guidance, each diocese is responsible for ensuring that it has in place proper recruitment procedures.[3] Every diocese reported in 2018 that it complied with this guidance.[4] Throughout the selection process various qualities and skills are assessed, but this report focuses on the extent to which safeguarding is considered during selection and training. Bishop Mark Tanner, a member of the Ministry Council (which is responsible for the procedures for selection for ordination) and the chair of the Church’s Selection Oversight Group, admitted that the Church is still “playing catch-up” in respect of selection and training in this regard.[5]

Clergy

61. A candidate for ordination is sponsored by a specific bishop (the sponsoring bishop), and the process is overseen by the diocesan director of ordinands, who works with candidates to prepare them for assessment.[6]

Process for ordination
Process for ordination

62. In addition to submitting four references and a full CV, the Church’s recruitment policy requires a candidate to undergo an enhanced DBS check.[7] He or she must also submit a confidential declaration form about whether a court has made a finding that “you have caused significant harm to a child and/or vulnerable adult, or … that any child and/or vulnerable adult was at risk of significant harm from you”.[8] A candidate cannot go further in any discernment process without satisfactorily meeting these requirements.[9]

63. Candidates are then measured against seven selection or formation criteria, agreed in 2014. However, there is no criterion concerned specifically with safeguarding and suitability for work with children.[10] A revised set of criteria including one specific safeguarding criterion was proposed in 2018 but was rejected by the House of Bishops[11] as it was considered too simple, suggesting that safeguarding was a “one time action” rather than “a present, continuous action”.[12]

64. Diocesan directors of ordinands also use a ‘traffic light questioning’ tool to identify issues that require further exploration with a candidate which include safeguarding.[13] Concerns will be referred to the DSA and to statutory services if required.[14]

Process for ordination

‘Traffic light’ questioning tool

Source: ACE026777_001

65. The Church of England is reviewing its recruitment processes to improve safeguarding through its Future Clergy Review, which is considering:

  • replacing the criteria with a selection framework focussing on the qualities expected of candidates, including the ability to deal with abuses of power, understanding and awareness of child protection and adult safeguarding, and an ability to follow guidance and take advice from safeguarding experts;[15] and
  • using mandatory psychological assessment to provide an initial appraisal of a candidate’s fitness to practise,[16] albeit that this cannot be a silver bullet”.[17]

66. A shared discernment framework, including an updated set of qualities, was produced in March 2020.[18]

67. At the Bishops’ Advisory Panel stage (which involves interviews, presentations and exercises to assess candidates), a candidate must also declare that they have “read, understood and are committed to the Church of England’s policy on Promoting a Safer Church”.[19] The panel then makes a recommendation, but it is the sponsoring bishop who decides whether a candidate should proceed to ecclesiastical training.[20] This is a decision where there is the potential for lack of transparency and consistency. Since the third public hearing, the Church of England has written to all bishops to clarify their responsibility for ordaining candidates and has put in place measures intended to ensure transparency and consistency in this area.[21]

68. By the end of the first stage of ecclesiastical training (Initial Ministerial Education Phase 1 – IME1 – which takes three years full time or longer on a part-time basis at a theological education institute (TEI)), a candidate should leave “knowing how to recognise signs of abuse, knowing how to respond appropriately, knowing how to keep records, knowing how to refer”.[22] Safeguarding is not part of the current academic curriculum for IME1.[23] At present, safeguarding training is limited to online basic awareness safeguarding training (C0) before commencing IME1 and then foundation safeguarding training (C1) before commencing any placement within a parish.[24] However, in future, the Church will require that both C0 and C1 are completed before commencing IME1.[25]

69. Upon successful completion of ecclesiastical training, a Principal’s Recommendation to Ordain is issued by the principal of the TEI. This sets out if a candidate is ready to be ordained and whether they have the right personal qualities and skills.[26] Other than setting out the safeguarding training received, the recommendation is unlikely to comment explicitly on safeguarding. The Cambridge Theological Foundation considered that it was unclear how anything beyond a theoretical knowledge of safeguarding would be assessed as there will be few, if any, opportunities during IME1 for ordinands to respond to such issues in the context of current theological training.[27]

70. The Church of England is now working to develop its assessment at the conclusion of IME1 so that it would be more in line with a ‘fitness to practice’ approach taken in other professions.[28] Other professions where ethics and child protection are a focus involve practical assessment of someone’s ability to apply safeguarding issues in practice during their training.

71. The ordaining bishop will decide whether to ordain the candidate as a deacon, which is required before they can become a curate. Prior to commencing curacy, a candidate must undertake leadership safeguarding training (C2). As a curate, he or she will complete safeguarding training for clergy and lay ministers (C3) and the second stage of Initial Ministerial Education (IME2).[29]

72. At the conclusion of their curacy, a candidate will be ordained provided he or she has completed satisfactorily the Assessment at the End of Curacy against the formation criteria.[30] Under the ‘Relationships’ element of this assessment, a candidate must show that they “understand policies and best practice in safeguarding and their application in a variety of contexts”.[31]

73. After ordination, when clergy move from one diocese to another, any known safeguarding risks or previous allegations should be identified by one diocese to another, so that the new diocese can manage any risk. This was achieved previously by sending a ‘safe to receive’ letter, reflecting the opinion of the sending bishop. In 2012, this was replaced by a ‘clergy current status letter’, a formal and standard document, completed following a review by the sending bishop of an individual’s ‘blue file’ (a personnel file) of any concerns about the individual or their work of which the receiving bishop should be aware.[32]

74. A list of names (the caution list) is kept by each archdiocese of clergy who have either been subject to clergy discipline, behaved contrary to the teachings of the Church or “about whom there was some concern”.[33] Bishop Hancock told us that the caution list is issued to all diocesan bishops and could be shared with suffragan or area bishops if appropriate.[34]

The selection of bishops

75. A candidate’s potential to fulfil their safeguarding responsibilities is considered part of the process for selecting a bishop. It has been included in interviews since 2013. Since January 2016, a candidate must provide a written submission in support of their application, to explain the actions he or she would take as diocesan bishop to ensure that children and vulnerable adults are protected, survivors receive appropriate pastoral care and a culture is created “in which all will flourish and which is coherent with the safeguarding policies of the Church of England”.[35]

76. Once selected, a bishop must be consecrated by the Archbishop of Canterbury. Archbishop Welby has said that he would not consecrate any bishop unless they had completed safeguarding training at the appropriate level.[36] As far as safeguarding is concerned, “the buck stops with the diocesan bishop”.[37]

Lay ministers and volunteers

77. Lay ministers – readers and licensed lay workers – are recruited within dioceses by a Diocesan Reader Board, in accordance with Reader Selection in the Church of England 2014 guidance. The Church’s Safer Recruitment guidance also applies to these appointments and requires:

  • references to be obtained, which must specifically comment on “an individual’s suitability to work with vulnerable people”;
  • candidates to submit a confidential declaration;
  • interviews, including about the applicant’s values and attitude to working with children or vulnerable adults; and
  • a DBS check if the Church is minded to recommend the applicant. Lay ministers working with children will require an enhanced DBS check with barring information unless they are supervised or do not fulfil the frequency criteria.[38]

They are required to undergo C3 safeguarding training, which places them at the same level as ordained clergy.[39]

78. The Safer Recruitment guidance must also be followed for the appointment of volunteers who may have contact with children, including churchwardens and members of the parochial church council.[40]

78.1. Volunteers must provide a confidential declaration form and two references, which should include commenting on the applicant’s experience of working with children and any evidence that they would not be suitable to work with children.[41]

78.2. Volunteers must also undergo DBS checks before starting work and then every five years.[42]

78.3. A person will be disqualified from the office of churchwarden or as a member of the parochial church council if they are convicted of certain criminal offences or are included on the DBS barred list.[43] A diocesan bishop may waive disqualification for conviction but must consult the DSA before doing so.[44]

79. The level of DBS check an individual requires depends on whether the work they will be doing is legally defined as ‘regulated activity’ with children. The definition of regulated activity does not always apply easily to the way that a church operates. In broad terms, regulated activity includes:

  • any form of teaching, training, instruction and caring for children if that activity is unsupervised, or providing guidance on physical, educational or emotional well-being, again if unsupervised; if supervised by someone who has a DBS check, then other volunteers do not need to have such checks; and  
  • work in a limited number of establishments – including schools, but not including work done by supervised volunteers in those settings – which must be undertaken frequently or on more than three days in any period of 30 days. 

(There is no statutory definition of what is considered to be supervision.)

80. Susan Young, Director of the Public Protection Directorate at the Home Office (which has partial policy responsibility for vetting and barring), explained that the intention was to “scale it back to common sense levels”. She says that regulated activity will include activities which provide “the highest levels of risk”. The Home Office states that regulated activity does not include minimal or limited access to vulnerable groups.[45]

81. As a result, for example, the following volunteers may not be subject to a DBS check:

  • adults in a choir with children if they are supervised by an adult with a DBS check;
  • individuals working with children in cathedrals such as organists and choirmasters if they are supervised; and
  • those performing confirmations if supervised.

The Inquiry is aware of examples of such individuals being convicted of child sexual offences, including Mark Mytton, Michael Walsh and Duncan Hanner.[46]

82. In deciding whether to obtain an enhanced DBS check, Church of England guidance dated 2017 recommends that the DSA considers the following question:

Does the role mean that the relevant individual either supervised/unsupervised on a frequent/infrequent basis, trains, instructs, cares for or supervises children or provides advice/guidance on physical, emotional or educational well-being to children?[47]

Ongoing safeguarding training

83. The Safeguarding Training and Development Framework was introduced by the House of Bishops in January 2016.[48] Members of clergy and non-clergy office holders attend regular safeguarding training every three years.[49]

Table 3: Church of England safeguarding training modules

Module Who attends Learning aims How often
C0
(Basic awareness)
Recommended* for anyone who needs a basic level of awareness of safeguarding.

May include but not limited to vergers, servers, welcomers, caretakers, refreshment helpers, shop staff, sidepersons, parochial church council members, church wardens, bell ringers, choir members/music group members, employees of the Diocesan Boards of Education and Finance.

This course is a prerequisite for attendance at any other core training module.
Develop a basic awareness of safeguarding in the context of the Church and Christian pastoral care. Refreshed every three years by a revised C0 module.
C1
(Foundation)
Required for anyone who has safeguarding responsibilities or contact with children, young people and/or adults who may be vulnerable.

Including but not limited to: safeguarding officers, safeguarding lead on PCC, church wardens, readers in training, ordinands prior to placement, spiritual directors, pastoral visitors, bishops visitors, helpers at activities, servers, church administrative staff, members of religious communities who are in active ministry and work with vulnerable groups.
Situate safeguarding in the context of the Church and equip participants with knowledge and skills in knowing what, when and how to report concerns. Must refresh every three years through a refresher module known as C5.†

Completing C1 and C2 gives an equivalent level of training to C3. The difference is the content and focus of the case studies.
C2
(Leadership)
Required for anyone who has safeguarding leadership responsibilities or responsibilities for leading activities involving children, young people and/or adults who may be vulnerable.

Including but not limited to safeguarding officers, safeguarding lead on PCC, church wardens, youth and children’s pastors, bishops visitors, directors of music, bell tower captains, home visitors, ordinands prior to leaving TEI, safeguarding leads in religious communities, choir leaders.
Equip parish officers to embed healthy parish safeguarding practice.

To explore the roles and personal vulnerabilities of parish officers in implementing parish safeguarding procedures and responding to serious situations.
Must refresh every three years through a refresher module known as C5.

Completing C1 and C2 gives an equivalent level of training to C3. The difference is the content and focus of the case studies.
C3
(Clergy and
Lay ministers)
Required for all those holding a license, commission, authorisation, permission to officiate from a Bishop – ordained and lay.

Including but not limited to: all clergy holding a licence or licensed/authorised lay ministers and readers.

For those holding PTO, the Bishop granting permission should determine the level of training required in consultation with the Diocesan Safeguarding Adviser; for those whose ministry will be active C3 is the required module, for those for whom PTO will rarely be used it may be more practicable for C1 to be completed.
Equip incumbents, licensed and authorised ministers to embed healthy parish safeguarding practice and respond well to safeguarding situations. Must refresh every three years through a refresher module known as C5.

* C0 is mandatory for those who are required to complete further safeguarding training core modules. However, it is recommended for anyone in the church, including those who are not in any form of ministry or church officer role.
† C5 refresher will be mandatory for those required to do C1, C2 and C3. This module has yet to be developed. 

Source: ACE025773_044-046

84. Safeguarding training is organised in dioceses. It is delivered by qualified trainers engaged by the dioceses.[50] Between January 2016 and March 2019, both clergy and volunteers attended training:[51]

  • 69,000 people completed basic training (C0);
  • 68,000 people completed foundation training (C1);
  • 16,178 people completed the leadership module (C2); and
  • 1,600 people completed the senior leadership module (C4). 

While these are significant numbers for this three-year period, there remain 56,000 people who need to complete the foundation stage of training.[52]

85. In 2017, data returned by the dioceses showed that 73 percent of licensed clergy and 63 percent of readers had up-to-date safeguarding training compared to 62 percent and 50 percent respectively in 2015. Sixty-one percent of clergy with permission to officiate had up-to-date safeguarding training in 2017, compared with 33 percent in 2015.[53]

86. In her 2018 report, Dr Stobart concluded that the framework was “neither interpreted nor implemented consistently” across dioceses, cathedrals and other Church bodies.[54] She noted that participants in some dioceses considered that the framework was “too ambitious while others were of the view that it was a necessary part of standardising safeguarding across the Church.[55] As set out in Dr Stobart’s report, some participants said that they were:

a long way from seeing a Church where men and women are equal, where there is less deference to those in power and where everyone’s voice is heard and respected equally. Participants felt that until some of these changes are ingrained, safeguarding will remain on the periphery.[56]

87. Church officers who attended training felt that they had a good understanding of their safeguarding duties.[57] As a result, Dr Stobart made five recommendations, including that:[58]

  • a process should be introduced to enable diocesan safeguarding trainers to report to their local bishop any member of clergy who attends training and “does not engage”;
  • clarity is required about whether formal training arrangements should always exist between a diocese and cathedral, TEIs and religious communities; and
  • the Church must decide whether there should be stronger central guidance and oversight of safeguarding.

The NST has already initiated a number of actions in response, including publishing a revised version of the framework in 2019. This included guidance on how to monitor attendance and engagement with training. New modules focusing on the seal of the confessional and grooming will be introduced.[59] The Church has also revised its senior leadership training.[60] In February 2020, it produced a new draft plan for the future development of safeguarding training.[61]

88. Since 2010, clergy on ‘Common Tenure’ have been required to have ministerial development reviews (MDRs) annually or at least every two years.[62] Usually the diocesan bishop will conduct the MDRs of senior colleagues and delegate the remainder. Feedback is provided by parishioners and others within the diocese on any issue they deem significant, although it is not sought expressly about safeguarding.[63] Within the Church, MDRs are about spiritual reflection and formation, rather than performance.[64] As the Church has now provided safeguarding training to a large proportion of clergy, Archbishop Welby told us that there is a better baseline against which conversations can be held, in ministerial development reviews or otherwise, about the degree to which leaders, clergy and others are acting appropriately in safeguarding.[65]

89. There is also regular and compulsory safeguarding training (C4) for bishops, introduced in 2016, which was revised and updated in 2019.[66] A modular training course was also introduced in 2019 for all safeguarding leads (for dioceses, and for cathedrals and other institutions) to be provided with standardised risk assessment training and to introduce a new national standard risks analysis.[67]

90. Volunteers are not required to complete any training prior to appointment but must attend training after they start and the modules required will be dictated by their role.[68] The Church considers it is good practice, though not compulsory, to have regular reviews and supervision for volunteers, so that they feel supported and issues can be discussed and dealt with.[69]

Permission to officiate and the National Clergy Register

91. In the Chichester/Peter Ball Investigation Report, we concluded that “The system for granting permission to officiate (PTO) did not have sufficient regard to safeguarding”.[70]

92. The Church of England intends to introduce a publicly accessible national register of clergy who hold office, have a licence from the bishop or have permission to officiate. It will identify an individual’s current and past posts, their licence or PTO, and safeguarding training, as well as confirmation that they hold a valid DBS certificate.[71] To do so, the Church will produce regulations requiring diocesan bishops to inform the Archbishops’ Council of those acting as clergy and other ministers within their diocese. It is anticipated that this regulation will go before Synod for approval before March 2021.[72]

References

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