Skip to main content

IICSA published its final Report in October 2022. This website was last updated in January 2023.

IICSA Independent Inquiry into Child Sexual Abuse

The Roman Catholic Church Investigation Report


G.4: Audit of recent safeguarding case files

10. Much of the evidence during the case studies focussed on the historical response of the Roman Catholic Church to allegations of child sexual abuse. In order to examine more recent responses of the Church, the Inquiry instructed Mrs Edina Carmi to conduct an expert analysis of a selection of recent diocesan and religious institute safeguarding files. Mrs Carmi is an independent safeguarding practitioner with a background in social work and has been involved in safeguarding in a religious context since 2001.[1]

11. The Inquiry requested the two most recent child sexual abuse safeguarding files that were referred to the statutory authorities from 10 dioceses and 10 religious institutes.[2] Two religious institutes (the Society of the Sacred Heart and Our Lady of Fidelity) reported that no safeguarding allegations had been made against them and so Mrs Carmi reviewed 36 safeguarding files. The majority of files involved allegations against clergy and members of religious institutes, many of whom were teachers. Other files involved allegations against lay members of the Church, for example a volunteer youth worker. A small number of files involved Church members who were registered sex offenders and were the subject of safeguarding agreements. Mrs Carmi was also provided with current and past CSAS policies and procedures as well as statements from safeguarding staff and clergy involved in the cases. As this review was a “desktop audit of the paperwork” of a relatively small number of files, Mrs Carmi did not speak to victims and survivors or any members of the respective safeguarding teams involved.[3]

12. Mrs Carmi’s report sets out her expert opinion on the quality of policies and procedures, the extent to which these were followed by dioceses and religious institutes, and the adequacy of the steps taken by each institution in response to the sample cases.[4] Mrs Carmi identified a number of broad themes.

12.1. Support to the victim was inadequate, particularly when compared with support provided to the alleged perpetrator. Mrs Carmi stated that:

the service seems to function extremely well when it comes to supporting perpetrators, and which is in stark contrast with a lack of support in many cases for – and the lack of consideration of perhaps supporting victims, survivors and their families”.[5]

For example, in 27 of the cases no support was offered to the complainant or their family.[6] In her view, this was appropriate in only five of these cases. By contrast, Mrs Carmi described that the support provided by the Church to perpetrators was “extremely comprehensive” and included emotional support, help with accommodation, assistance with legal representation and provision of regular updates.[7] In her view, there needed to be “more comprehensive procedures and guidance, as well as training” regarding, for example, who was to offer support, how and when the offer was to be made, and the identification of the support required.[8] There is a CSAS national policy which sets out how support is to be provided to those affected by allegations of abuse and so it is difficult to understand why this policy is not being consistently applied.[9]

12.2. Potential conflicts of interest when clergy are in safeguarding roles. In Mrs Carmi’s view, formal safeguarding positions should not be held by members of the clergy because:

it is more likely to be a conflict of interest, and they are unlikely to have the requisite experience, training, skills for it, although I do accept there are some that have had previous training as social workers, but, even still, I would think it would be a conflict”.[10]

One of the files from the Diocese of Liverpool concerned actions taken by the safeguarding coordinator who was a member of the clergy. In 2017, a priest was arrested on suspicion of sexually assaulting four altar boys in the 1980s. The priest was allowed to remain in ministry with a safeguarding agreement in place but Mrs Carmi found no evidence that this decision was based on any risk assessment. In relation to the safeguarding coordinator, Mrs Carmi said “you got the sense that this was a colleague that we were talking about”.[11] For example, he was “constantly keeping the priest updated on where things were with the prosecution”.[12]

12.3. Insufficient liaison with safeguarding commissions. The safeguarding commissions “have both a strategic and detailed case management function” and play a key role in deciding whether there is a need for an investigation into potential risks posed by an alleged perpetrator.[13] In 14 of the 36 cases, Mrs Carmi said that there was “no mention” of notification, consultation or discussion with the safeguarding commission. In another four cases, “there were references to such activity having happened, but no actual evidence of when it occurred and with what outcome”.[14] Mrs Carmi said that “records need to contain internal discussions and telephone conversations, including decisions and the rationale for them” and that those records should be kept on the safeguarding file.[15]

12.4. Variation of practice in safeguarding planning. Mrs Carmi found that the variety of “different documents within the procedure manual” contributed to “a wide variation of practice in relation to safeguarding practice, suggesting that the procedures on this are not well understood”.[16] In her view, the Risk Information Framework (the tool for making a risk assessment) did not appear to “be producing a good quality risk assessment”. Mrs Carmi also found “little evidence” that safeguarding plans were reviewed.[17]

12.5. Assessment of risk in the event of an acquittal or ‘no further action’ by the statutory authorities. There were 10 cases where Mrs Carmi considered that further investigation was necessary to understand the potential risk of individuals who were either acquitted after a criminal trial or where the police or statutory authorities decided to take no further action. She said there were “sufficient concerns but actually no investigation undertaken, that’s where you don’t know what the risk is”.[18] In one case file from the Institute of Our Lady of Mercy, a nun was accused of sexually abusing one of her pupils in 1967–71. No risk assessment was located in the file either at the time the allegation was made in 2011 or at any time thereafter. The Institute of Our Lady of Mercy commissioned a preliminary enquiry report which Mrs Carmi considered to be “a very comprehensive, well-argued report”.[19] It recommended that a risk assessment be completed. However, the safeguarding panel set up to consider the preliminary enquiry report did not accept that recommendation and their reasons for doing so could not be ascertained from the records in the file. Mrs Carmi thought “that risk assessment was by then very much overdue”.[20]

12.6. Record-keeping. Mrs Carmi noted “a wide variation in standards of recording, and a difference between religious orders and dioceses in particular”.[21] For example, she said that most religious institutes provided “what appeared to be sparse records[22] with less evidence of any overview, records of telephone calls, internal communications and the rationale for decision-making. In Mrs Carmi’s view, the CSAS CM1 form (which is available on its website) is an invaluable guide to a case file and a useful tool for the safeguarding officers to use when an allegation is reported.[23]

13. More generally, when she and her fellow auditor reflected on the culture of safeguarding, Mrs Carmi told us that:

we had the distinct impression that this was one which was largely focused on the needs of the clergy as opposed to the needs of victims and survivors”.[24]

She observed that there was “a sense of hostility and irritation in some responses to alleged victims, with inadequate compassion and understanding of their current problems and the link of these with past abuse”.[25]

CSAS policies and procedures

14. Mrs Carmi said that she found it difficult to follow the policies and procedures given the number of different documents in the CSAS procedures manual that might apply to a single issue. She found this led to duplication within and between documents and that the format was not clearly numbered, which led to a difficulty in cross-referencing information.

I find them extremely difficult and I’m somebody who has spent some years actually writing child protection procedures”.[26]

15. Whilst some witnesses found the policies and website helpful,[27] Mrs Carmi was not the only witness to encounter these difficulties. Mr Child told us that he found that the lack of hyperlinks on the current CSAS website made “the whole affair rather unwieldy”.[28] Similar views were expressed by members of the Church that conduct safeguarding work. For example, Sister Agnes Clare Smith, the safeguarding coordinator for the Institute of Our Lady of Mercy, said that the CSAS website was “not easy to navigate … some of the information sections on the website, particularly the policies and procedures are very dense”.[29] Monsignor Seamus O’Boyle (the Episcopal Vicar for Safeguarding in the Archdiocese of Westminster) said that, while the CSAS policies and procedures were helpful, they “can be disjointed with information relating to the same topic held in different areas”.[30]

16. The policies and procedures section of the CSAS website contains important instructions and guidance for those involved in safeguarding within the Church, but the website is not easy to use. The policies and procedures themselves are also sometimes difficult to follow. The CSAS website needs review, to ensure that the policies and procedures are easy to access and that the documents themselves are more easy to understand.


Back to top