69. The Inquiry commissioned Mrs Carmi to conduct a desktop audit of the Church’s written records for samples of casework as well as its safeguarding policies.

70. To ensure a representative sample, the Inquiry obtained a full list of all safeguarding casework undertaken by the Church in Wales between April 2017 and April 2018. One case was selected from each diocese for analysis, in order to provide a recent snapshot of various aspects of safeguarding in practice. Mrs Carmi also considered the quality of the Church’s guidance and the extent to which it was followed by dioceses, although she was not able to speak to victims and survivors or those engaged with the safeguarding processes.

71. A summary of key sample cases can be found in Annex 3, together with Mrs Carmi’s report. For ease of reference, the individual cases are identified by initials only. (For example, ‘Wa1’ is used to refer to the first sample case from the Church in Wales.)

72. Mrs Carmi identified a number of concerns.

72.1. The Church in Wales’ safeguarding policy, in Mrs Carmi’s view, provided comprehensive guidance and procedures for the Church. It was “less good at explaining what happens once cases have been referred to the provincial safeguarding officers”. It did not give clear explanations of when and how to undertake internal investigations, risk assessments or put in place safeguarding agreements.^[1] The Church in Wales has undertaken to review their policies in order to address the concerns raised by Mrs Carmi and an updated policy will be released in summer 2020.^[2]

72.2. Mrs Carmi concluded that the documents she reviewed from the provincial safeguarding team were sometimes difficult to understand. It was not always clear what happened and when. There was no case record providing a log of each contact, such as telephone calls and internal discussions. This included the work of the Provincial Safeguarding Panel. It was not always evident what, if any, decisions or recommendations had been made by the panel.^[3] There were no notes of discussions at, for example, panel meetings, to provide a rationale for any decisions. Following the third public hearing, the Church in Wales purchased an electronic case management system.^[4] As a result, in August 2019 the Provincial Safeguarding Panel began formally minuting its discussions and conclusions.^[5]

72.3. There was a reluctance to implement suspension in a case examined by Mrs Carmi (known as Wa1).^[6] First, a priest refused to implement the suspension of a lay person with responsibilities in a parish, contrary to the clear advice of the PSO and Provincial Safeguarding Panel. The bishop then did not suspend the priest for failing to follow the guidance of the PSO and Provincial Safeguarding Panel. There was also a reluctance by the diocese to carry out a full investigation into the concerns.^[7] In Mrs Carmi’s view, responsibility for suspension should be transferred to PSOs in such cases. Archbishop Davies agreed that it would be appropriate for there to be a direction from safeguarding professionals to the bishop that they must suspend, although there is “something to be said for the bishop being the person who might … ultimately suspend”.^[8] The Church in Wales is putting in place alternative routes to suspension in the event that a bishop refuses to implement suspension on professional advice, which is expected to be in force by September 2020.^[9]