National safeguarding policies

51. While each diocese might have its own system to manage safeguarding concerns, the Church of England has legislation and regulations relating to safeguarding, and national policy and guidance (prepared by the NST and the NSSG) to ensure a necessary level of consistency.^[1]

52. The Church’s safeguarding policies, practice guidance and training framework have undergone a “wholesale revision” since 2015.^[2]

52.1. A new statutory duty requires bishops, authorised clergy and other church office holders to have “due regard” to the House of Bishops’ safeguarding guidance.^[3] There may be disciplinary consequences for those who fail to do so.^[4]

52.2. The Church’s policy statement – Promoting a Safer Church (approved by the House of Bishops in December 2016 and published in March 2017^[5]) – brings all Church bodies within the umbrella of national policy and guidance. It confirms a “whole church approach to safeguarding” to ensure “that all those within the Church, regardless of their role, have a part to play”.^[6]

52.3. Key Roles and Responsibilities of Church Office Holders and Bodies Practice Guidance (2017) updates and expands previous guidance. For example, it requires cathedrals to appoint a safeguarding officer to work with the dean and chapter to implement national policy.^[7]

52.4. Responding to, Assessing and Managing Safeguarding Concerns or Allegations Against Church Officers (2017)^[8] makes clear that the DSA should receive all concerns or allegations and refer them to the appropriate statutory agencies within 24 hours.

53. Further changes are also planned. As set out above, in February 2020, the NSSG approved the introduction of a set of nationally agreed safeguarding standards.^[9] The Archbishops’ Council anticipates that the national standards will represent “an important step in transforming the safeguarding practice of the Church”.^[10]

54. Ms Caslake said that the standards will form part of a quality assurance framework, identifying what issues need to be covered by the Church, the expectations in each area and the information that will be required to determine how the standards are being achieved.^[11]

55. The Church has circulated a two-year plan to update, rationalise and combine key policies,^[12] including obtaining feedback from those using the guidance and survivors to identify areas of concern, and providing examples of good practice.

56. There remain a number of concerns about the Church’s current policies.

56.1. As noted in the SCIE overview report, the Church uses terms such as ‘practice guidance’ to cover a variety of national policies, procedures and guidance.^[13]

56.2. In its Chichester/Peter Ball Investigation Report, the Inquiry recommended the amendment of Canon C30 to require clergy to comply with the House of Bishops’ safeguarding guidance, as the term “due regard” lacks sufficient clarity.^[14]

56.3. Mrs Carmi considered that the Responding to, Assessing and Managing Safeguarding Concerns or Allegations Against Church Officers guidance would benefit from a number of improvements.^[15] These included:

• emphasising the need to offer victims the opportunity to speak directly and alone to safeguarding officers, and the need to investigate the history of any allegations or offending;
• providing guidance about appropriate timescales;
• advising that conflicts of interest are to be avoided; and
• preparing templates for risk assessments to ensure:
  • sufficient focus on assessment prior to establishing a management plan;
  • advising on what is and what is not low risk; and
  • providing further guidance about implementing and managing safeguarding agreements.

Since the third public hearing, the Church has introduced a new risk assessment template and a new safeguarding agreement template, together with compulsory training for those carrying out such assessments.^[16]

Diocesan policies

57. Each diocese is responsible for implementing locally the House of Bishops’ national policies and guidance. Some dioceses regarded producing local policies as a “duplication of effort” which is likely to provide “no or limited added value”. Others supported the introduction of local policies, which they found easier to comprehend than the large volume of national documentation.^[17]

58. SCIE identified issues in relation to diocesan safeguarding policies:

• Dioceses varied in their approaches to complaints procedures. Procedures were not in place in every diocese. The Church told us that, as at 2018, there were 40 dioceses which had either a complaints or whistleblowing policy, or both.^[18] Where they existed, they were often “very brief and partial … only covering particular aspects of safeguarding work”.^[19] Most procedures did not provide clear expectations of the process (including timescales and expected responses) and were not easily accessible.
• The use of whistleblowing procedures in dioceses was “equally variable”.^[20] Some applied only to specific groups of staff, such as cathedral employees, and might not be applicable to volunteers. Many dioceses did not have a whistleblowing procedure in place at all.

This further supports the case for consolidating Church policies, procedures and guidance.