APPENDIX 6
Memorandum by the National Association
for Voluntary Organisations
1. SUMMARY OF
NCVO'S POSITION
1.1 NCVO welcomes the principle of checks
as a key means of protecting children and vulnerable adults. NCVO
believes that criminal record checks should be provided free for
volunteers. We are pleased to note the Scottish Executive's decision
to provide free checks for volunteers in Scotland through an Executive
funded central registered body. There is no reason why a similar
scheme cannot be adopted in England and NCVO would urge the Committee
to recommend this. The Scottish decision also creates the
anomaly whereby UK wide organisations who have volunteers in both
England and Scotland will have to pay for some checks and not
others.
2. INTRODUCTION
2.1 About NCVO
NCVO is the largest general membership body
for charities and voluntary organisations in England. NCVO has
sister councils in Wales, Scotland and Northern Ireland. Established
in 1919, NCVO gives voice to over 1700 organisations ranging from
large "household name" charities to small self help
groups involved in all areas of voluntary and social action at
the local level. NCVO champions the cause of the voluntary sector.
It believes that the voluntary sector enriches society and should
be promoted and supported. It works to increase the effectiveness
of the sector, to identify unmet needs and to encourage initiatives
to meet those needs.
2.2 NCVO's expertise in relation to this Inquiry
NCVO welcomes the opportunity to submit written
evidence to the Home Affairs Committee's inquiry into the Criminal
Records Bureau (CRB). The introduction of criminal record checks
through the CRB will have a major impact on the sector. Its operation
is therefore of particular importance to the voluntary sector.
2.3 NCVO has worked closely with the CRB,
submitting comments on its draft plans. NCVO sits on both the
CRB Ministerial Advisory Board and the Customer Forum.
2.4 Our submission has been informed by
consultation with our members. Many member organisations have
submitted evidence to us of how the charges for criminal records
will affect them. NCVO can supply the Committee with information
and case studies in writing or as part of oral evidence, if called.
3. BACKGROUND
TO GOVERNMENT
POLICY ON
THE CRB
3.1 The issue of charges to volunteers for
criminal records checks arises out of the passing by Parliament
of the 1997 Police Act. Part V of the Act sets out that all people
working with children and adults "at risk" should be
subject to checks on their criminal records, and provided the
power to charge fees for such checks. The Act as finally passed
includes provision for the ability for exemptions from charges
to be made, which was proposed by the Government when in opposition.
4. PREDICTED
COSTS OF
THE CRB AND
CRIMINAL CHECKS
4.1 NCVO has concerns about:
— the Government's prediction of the
cost of individual checks ("Disclosures"), and
— the Government's estimation of the
overall cost of allowing free checks for volunteers.
5. COST OF
INDIVIDUAL DISCLOSURE
CERTIFICATES
5.1 The Government has always said that
it wants the fees charged for checks to be as low as possible
whilst covering the costs of the Bureau. The Government had consistently
predicted that the cost of the Enhanced Disclosure was likely
to be £10, with the Standard and Basic Disclosures costing
less than this. In April 2000, Home Office Minister of State Charles
Clarke MP stated that "until the Bureau's operating costs
have been determined, it will not be possible to fix the charges,
but the cost has been previously estimated at between £5
and £10, depending on the type of certificate".[12]
Deputy Home Secretary Paul Boateng MP also said in a Westminster
Hall debate that the costs of checks were likely to be "up
to £10 for a certificate".[13]
5.2 NCVO is concerned that the final cost
charged by the CRB for checks may well be higher than has been
indicated, not least because the CRB fee is not the only cost
that individuals will face when applying for an Enhanced Disclosure.
For these higher Disclosures, the application will have to be
countersigned by a Registered Body who will confirm that the application
meets the relevant criteria. These Registered Bodies will have
to pay a fee for registration with the CRB. They will also face
their own costs of administering the applications. Unless the
Registered Body meets these costs out of existing budgets, they
will have to charge a fee to applicants in addition to the CRB
charge for the check.
5.3 The actual cost of the CRB check itself
is also not certain. Planning by voluntary organisations has been
predicated on the likely cost of the checks being £10. It
would be helpful if more concrete indications were made of the
actual cost that will be charged by the CRB. The most recent Government
statements have appeared to move away from giving a figure—most
recently saying that "the fees for such checks have not yet
been settled"[14].
With the launch of the registration process for the CRB only three
months away, we see no reason why a revised indication of the
cost cannot be publicly given. As part of their inquiry, the
Committee might like to ask when this figure will be released.
5.4 It should also be noted that for most,
these costs are new costs. Many organisations will also wish to
continue the checks that they currently carry out to ensure the
highest safety standards.
6. OVERALL COST
OF CRB CHECKS
ON VOLUNTEERS
6.1 The Government have given estimations
of the total cost of exempting volunteers from charges for Disclosures.
This varied from £48 million to £200 million. They have
also said that a Regulatory Impact Statement will be produced
before the end of February 2001—two months before the CRB's
registration process starts.
6.2 Research by NCVO indicates that the
number of checks that are likely to be needed via the voluntary
sector is much lower—in fact we believe that the total costs
to be:
— around £11 milliom per year—based
on £10 for an enhanced level check, or
— around £16 milliom per year—based
on £15 for an enhanced level check.
6.3 NCVO believes that this would not be
an onerous burden on the public purse. The alternative is for
the cost to be borne by individuals and organisations. Whilst
the cost on many individual voluntary organisations will be a
major part of their budgets, the overall cost for the state of
exempting volunteers is not high.
6.4 The CRB has carried out market research
to forecast demand. Information from this forecast could be used
to estimate the overall likely demand for criminal record checks
by volunteers and therefore the likely cost of exempting volunteers.
Debate on this issue is hindered by the fact that this information
has not been published, despite a number of Parliamentary questions
on the subject. The Committee might consider asking the CRB
for information from these forecasts.
7. PUBLIC FUNDING
FOR CRB CHECKS
BY VOLUNTARY
ORGANISATIONS
7.1 The Government has suggested in correspondence
that voluntary organisations should apply for funding to cover
the costs of criminal record checks to government departments
when applying for grants. NCVO correspondence with Ministers suggests
that departments do not believe that this cost will be high and
have not applied for increased funds during Spending Review 2000
to cover this.
7.2 The DETR said that they do not anticipate
the cost of certificates featuring prominently when voluntary
organisations apply for funding from DETR but that the department
would consider those costs a legitimate element in applications.
The DTI and DCMS did not consider costs of checks in applications
for funding to "sufficiently substantial" to include
them in SR2000. However, there is no consistency in policy between
departments over whether they will cover the costs of checks in
funding applications.
7.3 This also overlooks the fact that most
voluntary organisations are funded locally with no funding relationship
with central government. This would potentially leave a situation
whereby some voluntary organisations with funding relationships
with particular government departments would be covered whilst
others who have a funding relationship with a different department
or who operate at a local level will not be covered. This would
be neither equitable nor fair.
8. IMPACT ON
VOLUNTARY ORGANISATIONS
AND VOLUNTEERS
8.1 As suggested above, the implications
for individual voluntary organisations will be significant. NCVO
has conducted a survey of member organisations likely to be affected.
NCVO has also conducted research into the potential effect of
charging on those considering volunteering.
8.2 The scale of the impact on the voluntary
sector is disproportionate to other sectors, given the amount
of activity and support work with children and young people that
takes place in the sector. There are some 120,000 active registered
general charities, of which 15 per cent work with children and
young people - equivalent to some 18,000 organisations. This figure
does not include other charities where working with children is
not the main object but who may include projects with young people.
In addition, there are some 150,000 amateur sports clubs, the
majority of which also involve young people. The extension of
checks to vulnerable adults will extend the number of organisations
affected.
8.3 The majority of the voluntary sector
is made up of small voluntary organisations with few staff and/or
volunteer-led. They are often the least able to access checks
at present. The potential implications for them are considerable,
whilst the cost on the public purse would be small. These groups
rely predominantly on voluntary contributions.
8.4 It is difficult to estimate the overall
effect that charges will have on those wishing to volunteer. However
research carried out by ICM Research for NCVO found that many
would be discouraged from volunteering if they had to pay for
a check:
— six out of 10 19-21 year olds
— four out of 10 45 to 54 year olds
— five out of 10 of those over 65
— five out of 10 of those in work
9. CONCLUSION
9.1 Charging volunteers for criminal record
checks could undermine much of the positive work done in recent
years to promote volunteering. It could also affect the ability
of many voluntary organisations to carry out their work. NCVO
is therefore asking the Committee to recommend that the Government
introduce a system of free checks for volunteers along the lines
of the Scottish model.
January 2001
12 House of Commons PQ115923, 23.3. Back
13
Westminster Hall debate on the voluntary sector, 15.6.00, column. Back
14
House of Commons PQ142534, 21.12.00. Back
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