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IICSA Independent Inquiry into Child Sexual Abuse

Sexual Abuse of Children in Custodial Institutions: 2009-2017 Investigation Report

E.13: Recording and auditing

Recording by individual establishments, local authorities and the Youth Custody Service

207. Her Majesty’s Prison and Probation Service (HMPPS) explained that allegations are logged by safeguarding leads in particular establishments, who complete “referral documentation and ... logs” to track actions and progress. We were told these can be viewed by Youth Custody Service staff and inspectorates at visits. Mention was also made of Security Information/Intelligence Reports, and of child protection files being opened on individual cases.[1][2][3]

208. However, it is unclear whether these systems are effective in practice. Many institutions found it difficult to access some of the prevalence data the Inquiry sought, or to provide it to us with ease or in an accurate and accessible way.

209. Carolyne Willow, a children’s rights campaigner and founder of Article 39, had also found it difficult to obtain data from local authorities and from the National Offender Management Service (as it then was) about the numbers of sexual abuse allegations in custody.[4]

210. Angus Mulready‐Jones, HMIP, considered that if there was to be a duty to collect data on sexual abuse in custodial establishments, this should be a duty on central government, because it is the government which has an obligation to detain children safely. These data would also ensure that government had an accurate and complete understanding of child sexual abuse occurring in custody.[5][6]

211 . Peter Savage, Head of Operational Contract Management, Youth Custody Service, accepted that improvements are needed to the way in which the Youth Custody Service keeps records of disclosures of abuse, and how they are investigated. This will be considered in the current safeguarding review.[7]

Recording by national surveys

212. As we explained in the summary of the Inquiry’s prevalence analysis in Part C, several issues concerning how the HMIP survey records allegations of abuse have been identified.

213. Dr Janes, Legal Director of the Howard League for Penal Reform, considered the way the HMIP survey is carried out and the challenges of collecting information of this nature may affect how accurately it represents the scale of child sexual abuse in custody. In her view:

“there is a big gap in the evidence base as to the prevalence of sexual abuse among children in custody ... any enhanced monitoring and scrutiny of the nature, prevalence and response to sexual abuse in custody is likely to be helpful in preventing it from occurring in future and to assist the authorities to deal with it effectively.” [8]

Recording by the police

214. Chief Constable Simon Bailey, the National Police Chiefs’ Council’s lead on child protection, said that although there had been improvements, the accurate recording of crime presented challenges for the police. He considered there would be merit in requiring police forces to record that an allegation of sexual abuse had taken place in custody.[9]

Auditing and sharing information

215. In 2014, the Association of Independent LSCB Chairs concluded that there was limited scrutiny of the outcomes of abuse and neglect allegations in custody.[10]

216. Alan Wood, the Inquiry’s independent expert witness, stressed the importance of auditing. To make progress towards reducing child sexual abuse and allowing it to be detected and investigated, it is essential that there is a collection of consistent, accurate, trackable, quantitative and qualitative data available in relation to allegations.[11]

217. Sara Robinson explained that HMPPS has introduced an annual thematic review across the sector. Each provider will submit a thematic review of their locally managed complaints, safeguarding and whistleblowing matters to the Youth Custody Service. Central teams, including an audit team which sits outside the Youth Custody Service, will review this information so that lessons can be learned. It is also considering whether information about allegations of sexual abuse can be collected at a central level, to enable HMPPS to address difficulties.[12][13] It could also be enhanced, at an institutional level, by adopting something like the quarterly meetings and monthly safeguarding meetings put in place by Medway STC, to look at trends and developing issues.[14]

218. Katherine Willison, Director of Children’s Social Care, Practice and Workforce within the Department for Education (DfE), described two processes for information sharing:

  • The Children and Social Work Act 2017 introduced a new arrangement whereby local authorities are under a duty to notify the National Safeguarding Panel within five working days of a serious incident. The local authority will then decide whether to carry out a serious case review and the national panel will decide whether any type of learning review is required.[15] This means the national panel will have oversight of all incidents of serious harm across a range of institutions and therefore has the ability to identify any trends.

  • The second process specifically related to SCHs and requires registered managers of SCHs to notify Ofsted if there has been a serious event in the home. Ofsted will collate this information and use it to form lines of enquiry in relation to the regulation and inspection of those homes.[16]


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