The Safer Recruitment and People Management Guidance was approved by the National Safeguarding Steering Group in April 2021 and, following the development of a detailed implementation plan, came into effect on the 4 January 2022. The policy is one way in which the Church aims to fulfil its commitment to ‘Promoting a Safer Church’ and sets out the minimum requirements for safer recruitment and appointments whilst also ensuring continued vigilance once someone is in a role. The policy applies to paid roles and voluntary positions where there is substantial contact with children and /or vulnerable adults.
The Guidance has not previously been examined by the National Safeguarding Panel, although the Panel did take part in an online consultation in 2020 as the policy was being developed. During that consultation, the Panel noted the benefit of comprehensive and detailed guidance documents in respect of paid employees, whilst those for volunteers should be shorter but as rigorous from a safeguarding perspective.
The scrutiny session offered the Panel an opportunity to explore how the guidance was developed, establishing the successes, challenges and learning as well as the approach adopted towards policy implementation. The Panel also sought to understand how the guidance connects with the learning from the Independent Inquiry into Child Sexual Abuse, IICSA and the emerging themes from other projects, such as the Past Cases Review 2, which the Panel considered in its previous meeting.
The Panel questioned Clare Worrell, Church of England Human Resources Business Partner for the National Safeguarding Team, Deborah McGovern, National Safeguarding Policy Lead and Mandy McPhee, Diocesan Safeguarding Advisor, Hereford. This ensured that the Panel heard a range of perspectives including the experience in a diocese.
The Panel were told that the previous guidance had been in place since 2016. Concerns had been raised that it was not clear which actions were requirements and what was good practice advice. The revision sought to bring clarity to the policy and therefore rigour to safeguarding practice.
Before the meeting the Panel were asked to watch the video which has been prepared to support greater understanding of the need for this policy.
Deborah McGovern said that the use of staff and volunteers in the video to explain their understanding and experiences helped to develop people’s thinking. Safeguarding requirements in recruitment and people management are important for the contribution they make to safer churches and should not be viewed as unnecessary bureaucracy.
The Panel asked what the impact of the policy will be in dioceses. Mandy McPhee said the requirements had always been there, the guidance was now presented in a way that was much easier to manage and apply, particularly in her work with parishes. She acknowledged that the scale and scope of the policy represented a challenge, yet this challenge had always existed.
Mandy felt that the ongoing challenges are around compliance with every stage of the recruitment process from ensuring that adverts are created for vacant roles, application forms are completed, interviews held, and references taken up. This can be difficult for small parishes. The policy is easier to use now with relevant templates and model interview questions being supplied, but there remains a need for Diocesan Safeguarding Advisors to support those working with the policy. Clare Worrell added that the various steps of policy consultation tried to address these challenges, whilst consistently emphasising the benefits of following a clearly defined process.
Deborah McGovern acknowledged they had learnt from the process. After some initial negative reaction, they undertook a “sense check” with a target group of 14 people representing different roles in the church including parish clergy, diocesan human resources staff, diocesan secretaries and safeguarding leads. This was invaluable as there was strong feedback that the policy was too big and unwieldy and problems with presentation. The second draft was much clearer and reflected distinctions between mandatory requirements and guidance. Clare Worrell highlighted the benefits of virtual meetings which made engagement easier and more readily available.
The Panel questioned how the team engaged with those that were really resistant. Mandy McPhee emphasised that the Diocesan Safeguarding Advisors were assertive by nature and not afraid to challenge, where appropriate. She advised that there had been good communication and challenge throughout. Positive feedback was given to Clare Worrell and Deborah McGovern that those involved in developing the policy felt valued and that any feedback, positive or otherwise, was welcomed.
The Panel asked what role survivors had played in the policy development. Deborah McGovern stated that they had contacted the two principal survivor reference groups but that this offer of engagement and the outcomes sought were not as clear as they could have been. It was acknowledged that engagement with survivor representative groups could have been enhanced and extended prior to the policy development stage. The Diocesan Safeguarding Advisors could have also been brought in earlier to help improve survivor involvement. Mandy McPhee recognised that parishes had a role too in making the changes meaningful and relevant for survivors. There was a need for survivors to see and feel that their experiences are important and have led to improved processes at a parish and diocesan level.
The Panel were pleased to hear that contact has been made with the recently introduced Disclosure and Barring Service regional outreach workers. Clare Worrell advised that there are strong links with the dedicated Church of England contact. Four Disclosure and Barring Service workshops had been run with others planned in the near future. The learning needs to be cascaded throughout the Church. The relevant links and requirements are in the e manual.
The Panel asked about the resource implications for dioceses. Mandy McPhee recognised that for successful implementation, there is a need to ensure confidence throughout the church in handling the requirements. The Diocesan Safeguarding Advisers have to balance this coaching with other demands, so to support implementation Mandy has developed a 12-month delivery plan. This includes newsletters, drop-in days, hard copy packs for safer recruitment job descriptions and Disclosure and Barring Service checks. There is a benefit to dioceses and parishes of having a six-month lead in time supported by an implementation plan and this will be followed for implementing other policies.
The Panel asked how the new practices will be monitored and evaluated and how will survivors contribute to an evaluation process. Mandy McPhee acknowledged the importance of the relationship between the national team and dioceses, yet felt it was a diocesan level responsibility to monitor and evaluate the policy. In terms of collective Church oversight, Deborah McGovern noted the value of ongoing engagement and feedback but also felt there was a role for the new Quality Assurance Framework with collating, monitoring, and evaluating various aspects of policy.
It was noted that the IICSA recommendations 1 and 8 are key drivers to deliver quality assurance across the entire Church, with consistency of quality practice being essential. The pilot phase of a regional model would help inform the future direction of quality standards across 43 dioceses and 16,000 parishes.
The Panel asked how it is intended to engage Diocesan Safeguarding Advisory Panels as they have a key role overseeing and monitoring safeguarding standards. Deborah McGovern informed the Panel that whilst there were no specific requirements for these bodies in terms of the policy, it should be an area that they examine particularly in terms of compliance with the training requirements and Disclosure and Barring Service checks.
Final points were made about the importance of guarding against complacency. Specifically, it must be recognised that safeguarding responsibilities don’t begin and end with recruitment, continued supervision is equally important. There is also a need to understand how the policy is applied to casual employment, including church musicians. Deborah McGovern believed that induction and training would be key. There is a need for people to be more mindful and cognisant of the risks with casual employment.
Conclusions & recommendations
The Panel welcomed the following:
- The intention of the National Safeguarding Team to engage in discussion with survivors and diocesan staff as the first stage of any new policy development or policy review, even ahead of starting drafting.
- An approach that considers dissent and objections to draft policy, as indicators that there are issues that need to be addressed.
- The use of “sense checks” as part of a thorough consultation process and their importance in understanding the best way to achieve policy objectives.
- Presenting policies with a clear distinction between processes that must be followed and advice and guidance on good practice, the latter being possible to update as appropriate.
- In relation to the Safer Recruitment and People Management policy, that the policy is not just about recruitment but about what happens subsequently.
- The example of good practice from Hereford where the Diocesan Safeguarding Advisor has actively visited parishes to build relationships to promote understanding and successful implementation of the policy.
The Panel made the following recommendations:
- To the National Safeguarding Team – that in order to ensure successful survivor engagement, it is important to specify how they are being asked to contribute to policy development.
- The National Safeguarding Steering Group should consider where the accountability lies for monitoring and evaluating policy implementation across church institutions to ensure compliance with policy and procedures. This is particularly relevant to the development of the quality assurance framework and the work being done to address IICSA recommendations 1 & 8.
- The National Safeguarding Steering Group should consider how the role of Diocesan Safeguarding Advisory Panels (and their equivalents) can be standardised to ensure that all dioceses are monitoring and evaluating policies and procedures.
- The National Safeguarding Team to ensure that focus continues to be placed on the importance of the “people management” part of the new policy alongside the welcome improvements to recruitment.