Select Committee on Home Affairs Appendices to the Minutes of Evidence


Memorandum by Age Concern England



  1.1  Age Concern England (the National Council on Ageing) brings together Age Concern Organisations working at a local level and 100 national bodies, including charities, professional bodies and representational groups with an interest in older people and ageing issues. Through our national information line, which receives 285,000 telephone and postal enquiries a year, and the information services offered by local Age Concern Organisations, we are in day to day contact with older people and their concerns.

  1.2  Our submission concentrates primarily on the implications for volunteering by and with older people.


  2.1  We welcome the Government's initiative in taking steps to provide protection for children and other vulnerable people against those who might wish to harm them. Such harm might take various forms, some of them amounting to abuse. Age Concern guidelines on protecting older people from abuse identify a number of types of abuse—physical, sexual, psychological or emotional, and financial.

  2.2  We fully endorse the establishment of the inquiry given the widespread concerns and questions about the operational aspects of the Bureau and the impact of its activity upon employing and volunteering organisations working with vulnerable groups.

  2.3  We acknowledge the usefulness of criminal record checks as one means of determining whether a person wishing to work with vulnerable people (on a paid or unpaid basis) is suitable for the job or voluntary position in question.

  2.4  Age Concern provides services for older people, many of whom might be defined as vulnerable adults within the Police Act 1997 and the draft definition being used by the Criminal Records Bureau for consultation. We also place older people as volunteers with children and young people through our Intergenerational Network. Our comments therefore apply to our work with all age groups and the likelihood of our needing to require the Enhanced Disclosure to be made available to us in order to place large numbers of volunteers.

  2.5  Our comments cover the following areas:

    —  The usefulness of criminal record checks in recruitment and placement and use of the information.

    —  The cost and administration of the service.

    —  The definition of Vulnerable (Adults) and possible impact upon people's attitudes to work with older people.


  3.1  We acknowledge that there is no substitute for high standards of recruitment of volunteers, as with recruitment for paid employment; also that disclosure is an additional piece of information to be considered in the recruitment process, not a substitute for good practice. However, a criminal record check gives only a snapshot of a person's history and as such has a limited life as a means of ensuring that an individual wishing to cause harm to vulnerable people is identified by disclosure. The cost of and time spent in managing the process (by the Home Office and organisations working with volunteers) need to balanced with this in mind.

  3.2  The information disclosed is potentially extensive, all of which has to be carefully interpreted and the context of the recorded activity understood. We are concerned that the extensive nature of the Enhanced Disclosure might have two very undesirable effects:

    —  Employing/volunteer placement organisations might make judgements about the suitability of candidates on the basis of disclosure out of fear, prejudice or ignorance. The possible effect of this is that people with disclosure records in general are discriminated against notwithstanding their suitability for working with vulnerable people.

    —  People with criminal records (including offences/information which could be deemed irrelevant to their suitability to work with vulnerable groups) could exclude themselves for fear of discrimination, thus working directly against the objective of increasing active participation in civic life through volunteering.

  3.3  We are also concerned about how disclosure information is passed on. For example, it is common for volunteers to work with more than one agency at a time. There needs to be a system in place to minimise the need for duplication in undertaking checks. It is also possible that a volunteer might change from a placement within the host organisation that does not require disclosure to one that does. Good record keeping and personnel systems within voluntary organisations should identify the need for implementation of the disclosure process. However, this could place an added pressure on the thousands of smaller voluntary groups which are less likely to have the infrastructure to manage this well, which are also likely to be organisations more dependant upon volunteers in their operational management as well as service provision. Another concern is that in the event of the disclosure process being required, there may be a delay in giving a new placement to an existing volunteer, who may become disillusioned and thereby `lost' by the placement organisation.


  4.1  The impact of charging for the service is a major concern for voluntary organisations. Our member organisations and groups involve at any one time anything from 50 to 500 volunteers each. Statistics on volunteer turnover across our federation are not yet available but we estimate that we could be facing the need for up to 100,000 checks per year, without any means of recouping the cost. This is likely to have a significant impact upon our organisations in an environment where there tends to be little availability of funding to support volunteers and volunteering infrastructure, due to funder interests being primarily aimed at the service to users. We believe this to be a common problem in the voluntary sector.

  4.2  We are also concerned that if prospective volunteers are encouraged to pay for themselves, this again presents an additional potential barrier to volunteering, not least if poorly funded voluntary organisations start to expect prospective volunteers to fund their own disclosure check.

  4.3  The administration of the service, particularly with regard to the time taken for the disclosure process, needs to be responsive and manageable, not least with checks for volunteers, whose interest, once captured needs to be sustained. We believe that any delay beyond that reasonably planned for other recruitment requirements (for example the taking of references) will create an additional serious barrier to the promotion of volunteering, with the possible outcome that willing and suitable volunteers are `lost' and services to vulnerable people are unable to function satisfactorily.


  5.1  We understand that this inquiry is not aimed primarily at the definition of vulnerable adults. We are mindful however, that the current draft definition is broad. This in itself may be found to be valid, but the danger exists that organisations undertake responsibilities to protect their vulnerable users in an overly cautious manner by giving the widest possible interpretation of vulnerability to older service users. This may significantly increase the work of the Bureau and the potential for delay in the process. Importantly, it may also encourage organisations concerned about protecting themselves from criticism or claims for damages, to desist from working with more vulnerable groups in society or categorise more people than necessary as vulnerable, not least those who by virtue of chronological age alone, already face prejudice and age discrimination. As an organisation actively working against age discrimination we are keenly aware of the fine balance between inadvertent discrimination through over protectiveness and the duty of care to service users. In a society where age discrimination legislation does not yet exist, ageist employment practices and attitudes pervade at all levels and their impact should not be overlooked nor minimised in the context of this inquiry.

January 2001

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