Recommendations - The Anglican Church investigation report
These recommendations were made in the Anglican Church investigation report.
Introducing diocesan safeguarding officers in the Church of England
Recommendation
The Church of England should create the role of a diocesan safeguarding officer to replace the diocesan safeguarding adviser. Diocesan safeguarding officers should have the authority to make decisions independently of the diocesan bishop in respect of key safeguarding tasks, including:
i) escalating incidents to the National Safeguarding Team, statutory authorities and the Charity Commission;
ii) advising on the suspension of clergy in safeguarding matters;
iii) investigating and/or commissioning investigations into safeguarding incidents;
iv) risk assessments and associated plans for church officers and members of the congregation; and
v) supporting complainants in safeguarding-related issues.
Diocesan safeguarding officers should be employed locally, by the Diocese Board of Finance. The diocesan safeguarding officer’s work should be professionally supervised and quality assured by the National Safeguarding Team. The National Safeguarding Team should set the broad requirements for anyone applying to be a diocesan safeguarding officer (adapting as required the existing requirements in respect of diocesan safeguarding advisers).
It should be enshrined in policy that those who are volunteers and who do not follow the directions of diocesan safeguarding officers should be removed from responsibility of working with children.
Responses
On 25 November 2020, the Church of England stated that it fully accepts and supports this recommendation. The Church of England noted that further work will be needed on the details of how to implement this. In the meantime, the Church will look to put an interim arrangement in place, whereby a small number of independent professionals are recruited, who could provide independent oversight of safeguarding work, and in due course, could form the new independent trustee body.
The Church of England also intends to amend Canon 30 and the associated Diocesan Safeguarding Advisors Regulations to accommodate this recommendation. The Church of England has also asked the National Safeguarding Team produce a project plan to deliver independent safeguarding based on the recommendation.
On 15 December 2020, the Church of England voted unanimously that a proposal on an interim oversight model of that National Safeguarding Team will be put in place before the February Synod in 2021. The model will include the creation of a new safeguarding board with a majority of entirely independent members. The Church of England has stated that the board could then help determine the approach to implementing full independent oversight, as outlined in the Inquiry’s recommendations. The detailed arrangements for this will be worked out fully through a consultation with survivor groups and dioceses.
On 25 February 2021, the Archbishops’ Council approved the next steps in the independent oversight of the National Safeguarding Team, with the first phase to be implemented by early July 2021. The first phase proposes appointing an Independent Safeguarding Board (ISB) to provide professional supervision and quality assurance of case work and the handling of complaints. Under the proposals, Diocesan Safeguarding Officers (DSOs) will continue to be employed by the Diocesan Boards of Finance whilst relating to the ISB via the National Safeguarding Team. In order to implement the shift from advisers to officers, the ISB may from time to time issue practice guidance, propose best practice models and offer general guidance to DSOs. DSOs may also seek specific guidance and support for their decisions from the ISB and appeal to the ISB should difficulties arise within the diocese which compromise their effectiveness.
On 29 March 2021, a joint response from the National Safeguarding Steering Group, the House of Bishops and the Archbishops’ Council stated that Canon C30 and the associated Diocesan Safeguarding Advisor Regulations will be amended to accommodate the change to Diocesan Safeguarding Officers and clarify further that safeguarding decisions are made by the DSO, not by clergy. The regulations will also set out the independence of the DSO. It was agreed that a pilot regional model to provide professional supervision for diocesan safeguarding professionals will be taken forward. The joint response stated that the Archbishops’ Council aims to have the interim independent structure of oversight of safeguarding in place by the end of summer 2021.
The revised Safer Recruitment and People Management policy, which will be considered by the National Safeguarding Steering Group (NSSG) in April 2021, requires all staff/volunteers working with children and vulnerable adults to have completed their mandatory safeguarding training before probation or settling in periods can be signed off. Subject to approval by the NSSG, this policy is due to come into effect in November 2021.
This recommendation will also be addressed in the revision of ‘Responding to Allegations Against Church Officers’, which is currently ongoing. The policy is due to be considered by the NSSG for approval in December 2021, with an expected implementation date of June 2022.
Responding to safeguarding complaints in the Church of England
Recommendation
The Church of England should make changes and improvements to the way in which it responds to safeguarding complaints (whether related to allegations of abuse, or a failure to comply with or respond to the Church’s safeguarding policies and procedures) to:
- disapply the 12-month time-limit for all complaints with a safeguarding element brought under the Clergy Discipline Measure;
- reintroduce the power to depose from holy orders where a member of the clergy is found guilty of child sexual abuse offences;
- introduce a mandatory ‘code of practice’ to improve the way that safeguarding issues are handled across the Clergy Discipline Measure and capability procedures, including a framework for responding to issues that do not amount to misconduct;
- make clear that penalty by consent must never be used in relation to such complaints;
- ensure confidentiality agreements are not put in place in relation to such complaints; and
- ensure that those handling such complaints are adequately and regularly trained.
Responses
On 25 November 2020, the Church of England stated it endorses the proposals to replace the Clergy Discipline Measure 2003 with a new set of provisions. These will place emphasis on the standard of conduct which is required of clergy and which will also make provision for the handling of poor practice or capability. The Church of England also notes that this new approach will make specific provision for matters which have a safeguarding element.
On 4 December 2020, the Church of England’s Working Group published a progress report on its review of the working of the Clergy Discipline Measure (CDM) 2003. The Group’s work identifies significant areas for change to the Measure as it stands and proposes that new legislation is needed to replace the Measure. In the interim, a number of measures have been developed, including regular training for key participants in the CDM process. The Working Group also notes that the possible reintroduction of the penalty of Deposition from Holy Orders will most likely be considered as part of the longer-term work dealing with replacing the CDM.
On 29 March 2021, the Church of England (CoE) stated that it endorses the proposals of the CDM working group to replace CDM 2003 with a new set of provisions. Those provisions will include a disciplinary process and will be accompanied by a mandatory code of practice, which will emphasise the standard of conduct which is required of clergy. The proposed CDM reform will also disapply the 12 month time limit for all safeguarding-related complaints.The CoE also stated that legislation to reintroduce the power to depose from holy orders will be brought forward as soon as practicable.
In addition, the CoE stated that the National Church Institutions’ Legal Office has taken steps to introduce new training for those who handle complaints in dioceses in connection with the special measures which may be required, which continues to be developed.
Following operational safeguarding advice in the Church in Wales
Recommendation
The Church of Wales should make clear that the operational advice of provincial safeguarding officers must be followed by all members of the clergy and other Church officers.
It should be enshrined in policy that those who are volunteers and who do not follow the directions of provincial safeguarding officers should be removed from working with children.
Responses
On 7 April 2021, the Church in Wales (CiW) stated that it will make clear in upcoming revisions to its safeguarding policy, procedural documents and training materials that the operational advice of provincial safeguarding officers should be followed by all church officers, including clergy. The CiW also introduced a new cause of action in the Disciplinary Tribunal, with sanctions including removal and disqualification from holding any office or membership in the CiW. There is also a power of suspension whilst investigation and/or disciplinary proceedings are ongoing.
The CiW noted that some volunteers will not be directly subject to the jurisdiction of the Disciplinary Tribunal. The CiW stated that it will revise its procedural guidelines to make clear the expectation that such volunteers should be removed from working with children. The CiW intended to publish this guidance by autumn 2021.
On 7 January 2022, the Church in Wales stated that the timetable for adopting its updated procedural guidance was delayed.
Record-keeping in the Church in Wales
Recommendation
The Church in Wales should introduce record-keeping policies relating to safeguarding, complaints and whistleblowing. These should be implemented consistently across dioceses. The Church should develop policies and training on the information that must be recorded in files.
The Church should provide its provincial safeguarding officers with the right to see personnel files of clergy, office holders, employees or others if concerns and complaints are raised about child protection or safeguarding.
Responses
On 7 April 2021, the Church in Wales (CiW) stated that its national online safeguarding case management and record-keeping system was launched in January 2020 and that it serves as a single searchable repository of all CiW safeguarding and whistleblowing case data. The CiW stated that Provincial Safeguarding Officers already have the right to view the personnel files of clergy and agrees that its procedural guidance needs to make clear to the various employers of other church staff that the same applies to lay personnel. The CiW committed to publish this guidance by autumn 2021.
On 7 January 2022, the Church in Wales stated that the timetable for adopting updated procedural guidance had slipped.
Information-sharing between the Church of England and the Church in Wales
Recommendation
The Church of England and the Church in Wales should agree and implement a formal information-sharing protocol. This should include the sharing of information about clergy who move between the two Churches.
Responses
On 29 March 2021, the Church of England (CoE) stated that the two churches are seeking to strengthen information-sharing arrangements by putting in place an information-sharing protocol and sharing agreement as swiftly as is practicable. The House of Bishops policy ‘Personnel Files Relating to Clergy’ (2018) will be amended to provide for the sharing of a copy of a Church of England clergy file with the Church in Wales when a member of clergy takes a position in the Church in Wales, and the Church in Wales will do the same with any relevant policy changes required on their side.
On 6 April 2021, the Church in Wales (CiW) stated that negotiations between the Church of England’s safeguarding information-sharing task group and the Church in Wales will be concluded and policies and private notices updated by July 2021. The CiW stated that the aim of updating these policies are to result in the full sharing of personnel files when clergy move between England and Wales and vice-versa.
On 24 June 2021, the Church of England (CoE) announced that the updated June 2021 edition of the House of Bishops' handling of Clergy Personal Files policy supports the Inquiry’s recommendation on data sharing between the Church of England and the Church in Wales, and clarifies the lawful basis on which clergy personal data is processed.
On 28 July 2021, the Bishops of the Church in Wales approved a new personal files policy for the clergy, which came into effect immediately.
Information-sharing between the Church of England, Church in Wales and statutory partners
Recommendation
The Church of England, the Church in Wales and statutory partners should ensure that information-sharing protocols are in place at a local level between dioceses and statutory partners
Responses
On 29 March 2021, the Church of England (CoE) stated that it will develop template information-sharing agreements which may be adapted and used by dioceses on a local level with statutory partners, such as local authorities. The CoE also stated that initial discussions with the National Association of Police Chief Officers were held at the end of 2020 and an information-sharing agreement to be used between police and the Church of England and the Church in Wales has been proposed and is being reviewed by all parties. It is expected that this work will conclude by December 2021.
On 7 April 2021, the Church in Wales (CiW) stated that it has been involved in joint meetings with representatives of the National Police Chiefs’ Council and the Church of England with a view to agreeing a national information-sharing agreement, or a template sharing agreement with national guidance on how it should be rolled out across each church organisation and each police force. The CiW also stated that discussions are continuing with the CoE about the best means of taking forward co-ordinated national conversations with other statutory partners.
Support for victims and survivors
Recommendation
The Church of England and the Church in Wales should each introduce a Church-wide policy on the funding and provision of support to victims and survivors of child sexual abuse concerning clergy, Church officers or those with some connection to the Church. The policy should clearly set out the circumstances in which different types of support, including counselling, should be offered. It should make clear that support should always be offered as quickly as possible, taking into account the needs of the victim over time.
The policy should take account of the views of victims and survivors. It should be mandatory for the policy to be implemented across all dioceses.
Responses
On 25 November 2020, the Church of England stated that it will continue with the development of a redress scheme and with the interim pilot scheme. The Church of England is also engaging with a number of survivors in urgent need and some emergency payments have already been made.
On 29 March 2021, the Church of England (CoE) stated that the ‘Responding well to victims and survivors of abuse’ policy is being revised and will specify a minimum level of support that all Church bodies must provide to survivors in terms of therapeutic support. Victims and survivors have been consulted in the revision of the policy and the Church will continue to involve survivors in the next stages of development. Formal approval of this policy by the National Safeguarding Steering Group is expected by summer 2021, with implementation effective January 2022.
In addition, the CoE stated that it is developing national proposals for redress within the Church, including financial compensation, support for rebuilding lives, emotional well-being support and apology. The CoE stated that a Redress Scheme Development Manager has been recruited to take this work forward and that meetings will commence shortly with survivors and key stakeholders across the Church.
On 7 April 2021, the Church in Wales (CiW) stated that it has now introduced Independent Sexual Violence Advisor (ISVA) support for survivors via two different sources. The first is ‘Safe Spaces’, operated by Victim Support, and the second is specific to the CIW and is run by New Pathways. The CiW commits to offer funding towards such counselling as may be recommended by the ISVA where the abuse was committed by the CiW clergy, or in a church context. The CiW also stated that the sufficiency of this provision will be reviewed regularly, in consultation with its Safeguarding Panel, Safeguarding Committee, and the providers of the ISVA service.
On 4 February 2022 the Archbishops' Council of the Church of England provided an update on their Interim Support Scheme for provision for immediate help and support to victims and survivors. It also provided an update on plans for the Church of England to implement a national redress scheme.
External auditing of safeguarding policies and procedures in the Church in Wales and Church of England
Recommendation
The Church in Wales should introduce independent external auditing of its safeguarding policies and procedures, as well as the effectiveness of safeguarding practice in dioceses, cathedrals and other Church organisations. Audits should be conducted regularly and reports should be published.
The Church of England should continue independent external auditing of its safeguarding policies and procedures, as well as the effectiveness of safeguarding practice in dioceses, cathedrals and other Church organisations. Audits should continue to be conducted regularly and reports should continue to be published.
Responses
On 29 March 2021, the Church of England (CoE) noted that the National Safeguarding Steering Group, House of Bishops and Archbishops’ Council remain committed to the programme of five yearly independent audits which began in dioceses in 2015. The safeguarding audits will continue during 2021, with a small number taking place in 2022. The CoE also stated that it will introduce a new quality assurance framework, which aims to develop national safeguarding standards against which the Church’s safeguarding practice can be measured. The draft standards were developed in the summer of 2020 and will undergo further consultation, with final approval expected in summer 2021.
On 6 April 2021, the Church in Wales (CiW) stated that it plans to undertake an audit of a random sample of safeguarding casework during the course of 2021 and to agree a programme of internal and external peer review in 2022 and 2023. The CiW intends to publish the findings from these external audits and intends that they become a regular part of its landscape of quality assurance.
On 14 September 2021, the Church of England (CoE) stated that its Governance Review Working Group has recommended changes to the Church's national governance structures. In line with the Inquiry's recommendation, it recommends that the oversight of the national Church’s safeguarding activities should be carried out by a separate independent body. The recommendation is to be considered by the Church's governance bodies during the autumn.
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Anglican Church investigation report
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