A few months ago, the National Safeguarding Steering Group, who oversee the Church’s safeguarding work, proposed the establishment of an ombudsman service for safeguarding complaints. The National Safeguarding Panel were consulted and felt that this would not resolve significant problems with the current complaints processes. The National Safeguarding Steering Group subsequently agreed that there needed to be robust complaints procedures in place before an ombudsman service is developed. The Panel then determined that it would be appropriate to examine the current complaints processes, and this took place at our October meeting.

Information was presented to the Panel by Nathalie Ballard, National Safeguarding Team Policy Officer, and Howard Dellar, a lawyer who acts as the Diocesan Registrar to a number of dioceses. Colin Perkins, Diocesan Safeguarding Advisor from Chichester submitted their Diocese’s complaints procedure for discussion.

Nathalie outlined research on the principles of complaint procedures. They often launch straight into a bureaucratic process, but evidence shows this approach should be avoided by using an informal approach focused on the complainant’s concern. This suggests that more weight needs to be put into training on the informal complaints handling approach. She also noted people feel vulnerable when making complaints and sensitive handling is crucial to retain communication and trust.    

Howard explained his role as a Diocesan Registrar and outlined his experience in relation to the Clergy Discipline Measure. In many dioceses all complaints against clergy are made under that particular process on many different issues, however this is not appropriate. Examples were given including theological issues, and disputes within the church, such as the structure of services. He felt that there need to be  other options for handling low level complaints informally.

Colin said that a wide range of types of complaints are received across the Diocese of Chichester and establishing a complaints process that is effective for all is challenging. He clarified that when a complaint is made, the process is normally initially handled internally, however when an allegation of abuse is made, external parties are informed immediately. Chichester’s complaints procedure has strong guidelines as to what should be referred to the Police and what should result in a Clergy Disciplinary Measure.

Panel members put a number of questions to Nathalie, Howard and Colin.

The main areas highlighted were:

Clergy Discipline Measure

The Clergy Discipline Measure is often used to resolve complaints that could be dealt with by a less onerous process. Where complaints are made appropriately under the Clergy Discipline Measure, the process is designed to try and achieve any penalty by consent. This may mean appropriate penalties are not agreed, as there is an incentive to avoid a lengthy process which might lead to a tribunal. Few cases reach tribunal, and fewer result in a penalty.

There needs to be greater clarity about the separation of complaints and discipline processes. Complaints of a more minor nature e.g. about hymns or the flowers, should not be dealt with by a discipline measure.

Structure of the church

The Church has a fragmented structure so creating one complaints process for the Church of England as a whole would be difficult. However, a national complaints process would allow for annual submission of data, giving the opportunity to reveal commonalities and address changes that need to be made.

Each diocese has a different degree of wealth and this can impact on their ability to thoroughly investigate complex complaints. A solution might be to have a role of a Complaints Officer regionally or nationally to handle safeguarding complaints.

Process and training

Complaint timescales are not always consistent. The process can move slowly if it reaches the point of external agency involvement when they may be dictating progress. Diocesan staff may not have had the appropriate training to handle a complaint competently.

There is a difficulty when the same person is expected to be both the person investigating concerns and the person who provides support to the person under investigation.

Support for complainants

Where complaints relate to a safeguarding matter, there is a lack of support for vulnerable complainants. Independent advocates for survivors and victims should be an option at all stages of the process.


The panel made a number of recommendations:

  • The definitions of the processes already in place need to be much sharper e.g. how and when should the Clergy Discipline Measure be used and what is the process for other complaints outside of that?
  • A preference for one standardised complaints procedure for all dioceses, or at least a requirement to have complaints processes based on the same principles. There should be a staged approach which seeks to resolve matters informally only escalating to a more formal level if required. It needs to include clarity on links to the Clergy Discipline Measure.

  • More informal resolution will require training and resources and learning from the issues that arise from the complaints made.

  • Research regarding the complaints processes of other churches and other professions and organisations should inform any proposed changes.
  • Victims and survivors would benefit from the support of an independent advocate at all stages of the complaint process.

Update on the Clergy Discipline Measure Working Group

At its meetings in May and June the National Safeguarding Panel considered the Clergy Discipline Measure in relation to safeguarding matters. A blog on that can be found here.

The Church had committed to establishing a working group to review the measure. This is chaired by Tim Thornton, Bishop at Lambeth. Tim reported on progress to the National Safeguarding Panel. The working group has met and made good progress. There is a consensus that there needs to be change, and specifically an improvement in dealing with safeguarding issues. A number of workstreams have been put in place and it is hoped that there can be some early recommendations for change.