27. The current CSAS safeguarding policies and procedures are available on the CSAS website. They include policies on responding to allegations, information-sharing and data protection, safer recruitment and safer working practices, and Disclosure and Barring Service (DBS) checks. The website contains references to UK legislation and other statutory guidance that underpins the policies and procedures, along with other sources of material including the national safeguarding training standards set out in Towards a Culture of Safeguarding. In addition to the CSAS website, a variety of safeguarding leaflets and posters are on display in churches and mass centres.
28. Mr Pearson said that, following the appointment of Dr Colette Limbrick as the director of CSAS (in June 2015), there had been a “significant programme of review and improvement of policy”.[1] The redrafting of any policy involves consultation across the Church, including with child protection staff and the safeguarding commissions. Legal advice is sought to ensure a proposed policy does not contravene canon law or civil law.[2] Mr Pearson said that:
“any changes to policy or procedures are robustly scrutinised by the NCSC and the Survivors Advisory Panel before they are recommended for submission to Bishops and Religious Leaders”.[3]
29. No witness told us that the policies were inadequate. Mrs Edina Carmi, an independent safeguarding consultant, was commissioned by the Inquiry to undertake a review of a number of recent diocesan and religious safeguarding files. Her review involved consideration of the CSAS policy for managing allegations and concerns relating to children. When asked if she thought this policy was fit for purpose, she said:
“if you were to strip all the policy and guidance so you could actually see what the instructions are, within it is the embryo of a procedure that could work, if you could then sort of make it clear who does what and when, so you would reorder it. But it needs a complete review. It needs that stripping of the information that’s not needed if you are trying to find out what you need to do, and it needs extra parts added. You also need to integrate all the bits and pieces that you’ve got in lots of other documents so it’s all in one document, not duplicated … So overall, there’s the embryo within it of what could become a ‘fit for purpose’ procedure.”[4]
30. Adrian Child (director of CSAS 2007–2015) considered that “by and large” there was a national acceptance that safeguarding requirements needed to be followed.[5] His successor, Dr Limbrick, stated that she was not aware of any diocese or religious institute that either deliberately adopted a policy that was inconsistent with a CSAS safeguarding policy or refused to comply with a CSAS safeguarding policy.[6]
31. When Stephen Spear (a lay member of the NCSC between June 2016 and July 2019) was asked if he had seen any evidence of the NCSC systematically monitoring compliance with safeguarding policies and procedures, he said “I’ve seen none at all”.[7]
32. Throughout its public hearings, the Inquiry heard examples of non-compliance with CSAS policies and procedures.
32.1. In January 2011, Abbot Martin Shipperlee moved RC-F41 from Ealing Abbey due to safeguarding concerns, to an address in the Diocese of Brentwood. He failed to inform the Diocese of Brentwood, in breach of the CSAS cross-boundary placement policy.[8]
32.2. A 2018 audit of the Archdiocese of Birmingham found that the Archdiocese’s policies and procedures were not in accordance with CSAS policies and procedures and the Archdiocese’s reviews of safeguarding agreements were not conducted with the frequency they should have been.[9]
33. The NCSC introduced auditing of safeguarding commissions to monitor implementation of policies and to “create greater consistency of good practice”.[10] Where sub-standard safeguarding practice is identified, CSAS makes recommendations to the NCSC but neither CSAS nor the NCSC are able to ensure that the recommendations are implemented. Dr Limbrick told us that the bishop or religious leader would be responsible for enforcement.[11] Recent audits of safeguarding commissions have shown that consistent compliance with policies and procedures remains some way off (see Part G).
34. When the NCSC and CSAS were established, they were not vested with any powers to enforce compliance with their policies. Accountability for safeguarding practice sits within the diocesan or religious safeguarding commission itself, with the bishops or religious leaders responsible for enforcing compliance with policies and for taking remedial action where there are concerns.[12] If CSAS considered the bishop or religious leader was not performing his safeguarding role properly, he would be reported to the Charity Commission. Dr Limbrick told us that she has never made such a report, but she recalled that a diocesan safeguarding coordinator referred a religious order to the Charity Commission.[13]
35. Danny Sullivan (chair of the NCSC between 2012 and 2015) described the lack of authority provided to the NCSC as “a gaping hole” in the Church’s approach.[14]