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IICSA Independent Inquiry into Child Sexual Abuse

Children Outside the United Kingdom Phase 2 Investigation Report

D.4: Reform

40. The limits on the application of disclosure and barring regimes to individuals from England and Wales who travel overseas, described in this part of our report, are not merely technical failings. They allow those with predatory tendencies to exploit the system and sexually abuse children abroad. The Inquiry is clear that this patchwork regime needs to be reformed in order to become more effective.

41. The following emerged during our investigation as key proposals for reform in this area:

  • strengthening of the ability of the DBS to access overseas convictions and intelligence information from overseas;[1]
  • the reinstatement of COBIS’s permission to conduct enhanced DBS checks;[2]
  • improvements to the ICPC scheme, including placing it on a statutory footing and making it mandatory;[3]
  • greater promotion of the ICPC regime in different countries abroad;[4]
  • the merger of the DBS and ICPC regimes;[5] and
  • the creation of a centralised international system.[6]

42. These proposals for reform have to be seen in the context of other ongoing initiatives in this area.

43. The International Task Force on Child Protection has undertaken extensive multidisciplinary work to devise its international protocol on managing allegations of child abuse by educators and other adults and develop its recommendations for teaching establishments about giving references.[7]

44. In 2018, the Secretary of State for the Department for International Development (DFID) wrote to 179 of DFID’s major partners (UK charities working overseas) requesting that they provide a statement of assurance on four key points which are essential to effective safeguarding.[8]

45. DFID subsequently launched new due diligence standards for its funding, which help gauge a partner’s ability to apply safeguarding of children and adults in their work. The standards cover six areas: safeguarding, whistleblowing, human resources, risk management, codes of conduct and governance. This includes, in human resources, a focus on a partner’s vetting and recruitment processes, and questions about what processes the partner follows, albeit that neither the DBS nor ICPC process is mandated.[9] The FCO’s programme team carries out diligence assessments of potential partners, through which they assess the adequacy of the policies, processes and practices evidenced by the potential partner. Its contractual terms and conditions for suppliers requires that DBS, Department for Education and criminal record checks are carried out.[10]

46. DFID also announced the following initiatives in October 2018, aimed specifically at improving vetting across the international aid sector:

  • a new pilot scheme run by Interpol to improve background checks on aid-sector staff, provide advice to employers on international vetting and identify high-risk individuals;
  • the testing by UK NGOs of a new ‘passport’ for aid workers to prove an individual’s identity and provide background information on their previous employment and vetting status; and
  • a new disclosure of misconduct scheme across the aid sector, to which 15 organisations had signed up by 18 October 2018.[11]

47. The first of these initiatives will be implemented through Project Soteria. This is a five-year project, commencing in early 2019, in which Interpol, ACRO, DFID and Save the Children are involved. There will be a pilot of an online platform to strengthen background checks on staff across the aid sector globally and to improve information-sharing between law enforcement agencies about individuals of interest. The project will also involve a team of seven to nine specialists and investigators operating from both Africa and Asia to provide support to national crime agencies and strengthen their criminal records systems and information-sharing capabilities. The project is looking at the feasibility of creating an international regime.[12]

48. As set out in Part F, reform is needed to simplify these processes and make them more robust.


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