Select Committee on Home Affairs Appendices to the Minutes of Evidence


Memorandum by the Central Council of Physical Recreation



  The CCPR welcomes the establishment of the CRB and supports measures to ensure greater protection for children and vulnerable adults. However there are concerns about some details of the CRB's operation. Particularly proposed charges for criminal records checks will have an adverse affect on sport and recreation which is supported by the tireless efforts of 1.5 million volunteers. Proposed charges will place a financial strain on voluntary clubs which are funded by membership fees, and be a disincentive to volunteering. The NCVO have estimated that charges will deter 60 per cent of volunteers in the 19-21 age group. The CCPR urges Government to follow the example of the Scottish Executive by meeting the costs of criminal records checks for volunteers in England and Wales from public funds.


  1.1  On behalf of the national governing bodies of sport and recreation, the Central Council of Physical Recreation (CCPR) is pleased to respond to the Home Affairs Select Committee inquiry into the Criminal Records Bureau (CRB).

  1.2  The CCPR welcomes the establishment of the CRB as a measure designed to improve the safety of children and vulnerable adults. Criminal records checks will be part of wider child protection policies already being undertaken by governing bodies. However there is concern among members about some of the details of the CRB's operation, particularly the proposed charges for obtaining disclosure certificates.


  2.1  Volunteers provide the backbone of UK sport, with an estimated 1.5 million people offering their time unpaid to sport and recreation. On average volunteers work 125 hours per year, with the annual labour market value of their time an estimated £1.5 billion. The value of volunteer time is approximately seven times the amount sport receives from the lottery, thereby illustrating the significance of voluntary effort.

  2.2  Most of this volunteer effort is channelled through the work of an estimated 150,000 voluntary sports clubs in the UK. These clubs are voluntary community based organisations, who are mainly non-profit distributing and funded from membership fees. These clubs provide a crucial link in this country's sporting development, and are a significant contribution to make to the Government's wider social agenda.

  2.3  The Prime Minister highlighted the contribution sport and recreation could make across policy issues, in a speech to British Olympic medal winners on 11 January 2001. Mr Blair said that investment in sport was

    "a pro-education policy; a pro-health policy; an anti-crime policy and an anti-drugs policy".


  3.1  Individuals will have to apply for a disclosure certificate through a registered body. It is anticipated that the larger sport and recreation governing bodies will apply for registered status as umbrella organisations on behalf of member clubs. It is not yet clear what arrangements smaller governing bodies, who do not have the administrative capacity to process applications, will make. Such bodies require advice and assistance on how best to proceed on this issue, and the CCPR will be exploring this with the members.

  3.2  However, there is concern that the draft "Code of Practice for Registered Bodies" drawn up by the Home Office may be administratively cumbersome. Governing bodies often only have a handful of office staff but membership in the thousands. Some of the requirements of administering the system, for example having to physically store documentation relating to applicants, will pose a large imposition on clerical staff. In terms of the cost implications, the Rugby Football Union has suggested that registered bodies be given financial assistance to fund the start up costs of administering the system.


  4.1  The Government have indicated that charges for criminal records checks are likely to be in the region of £10 per disclosure. The cost will be met either by the applicant or the employer.

  4.2  Such a charge is potentially crippling to the voluntary sector. For example the Scout Association would be required to carry out checks on an estimated 70,000 volunteers, costing them £750,000 per year when administrative costs are included.

  4.3  Furthermore the charge, effectively a tax on volunteers, would be a deterrent on voluntary effort. Research by the National Council for Voluntary Organisations (NCVO) has shown that 60 per cent of 19-21 year olds, and half of those aged over 65 (key age groups for volunteering) would be discouraged from volunteering if they had to pay for checks. Clearly those least able to pay for checks will be the lower social groups, impacting upon the Government's social inclusion agenda.

  4.4  Tamworth Sports Council have pointed out that a swimming gala involving a number of clubs could involve up to 50 volunteers. The Council argues that to expect the clubs to meet the cost of criminal checks on such a large number of people is "prohibitive", adding:

    "Asking volunteers, who have already freely given up their time, to pay for themselves would further dry up the stream of helpers and further jeopardise the existence of clubs".

  4.5  A further disincentive to volunteers could come from the administrative costs of the system. It is possible that registered bodies may pass on a handling charge to applicants, which will hit volunteering further.

  4.6  It is not yet clear for how long disclosure certificates will be valid. Making volunteers apply for checks on an annual basis will place a cumulative financial strain on the voluntary sector.

  4.7  The Home Office is currently undertaking a regulatory impact assessment of the impact of charging on the voluntary sector. The results of this assessment should be published as soon as they are available.

  4.8  Our members were greatly encouraged by the recent announcement from the Scottish Executive stating that it would meet the cost of criminal checks on volunteers in Scotland, at the cost of £1 million per year. Making the announcement Jackie Ballie, who had chaired the Voluntary Issues Review Group, said:

    "With this announcement we are demonstrating how highly we value the work of the voluntary sector. Their contribution can be seen throughout Scotland—in youthwork, children's play, homes and hospital visiting".

  4.9  We would urge the Government to make a similar commitment to the voluntary sector in England and Wales, particularly in light of the recent comments by the Chancellor Rt Hon Gorden Brown MP about the value of volunteering, and the Government aim of recruiting a million more volunteers over the next four years. The Government has indicated that underwriting the cost of volunteer checks would not be sustainable on the public purse. However, if the Government cannot meet the costs, then how can the voluntary sector be expected to afford them?


  5.1  The CRB will only cover England and Wales, working alongside the Scottish Criminal Records Office, and whatever system is introduced for Northern Ireland. In order to reduce the administrative burden on registered bodies there must be greater co-operation between the different criminal records agencies.

  5.2  For example, would an applicant applying for a position with a UK wide remit have to apply for multiple checks with different agencies? Since CRB checks would cover convictions in the UK as a whole, it would seem logical to make only a single application.


  6.1  The Home Office draft "Code of Practice for Registered Bodies" urges caution in employing people from overseas due to difficulties in obtaining information on individuals. Whilst this is sensible in the short term, in the long term the Government should work towards greater international co-operation in the sharing of criminal records data to make it more easily accessible to employers.

  The CCPR has approached the European Commission to see what assistance could be given in respect of European checks.


  7.1  The CCPR is seeking clarification from the Home Office as to whom is to be held liable in the event of inaccurate data. Could national governing bodies of sport, in their role as umbrella organisations, be drawn into any legal disputes? Should governing bodies take out insurance policies to protect themselves against such an eventuality?

  7.2  In evidence to the Social Inclusion, Housing and Voluntary Sector Committee established by the Scottish Parliament, reference was made to an audit carried out by the Metropolitan police. This had revealed that 86 per cent of the criminal records information processed in 16 London boroughs contained errors. Clearly this raises questions about potential future litigation concerning inaccurate data.


  8.1  The CCPR is pleased to respond to the Home Affairs Select Committee inquiry into the CRB. Sport and recreation welcomes the establishment of the CRB as a measure to ensure greater protection for children and vulnerable adults.

  8.2  Sport and recreation in the UK is sustained by the tireless efforts of 1.5 million volunteers, making a valuable contribution to this country's sporting development, as well as health, education, crime and social exclusion issues.

  8.3  However, there is particular concern about proposed charging for criminal record checks. Such a measure will impose a financial strain on voluntary sports clubs and be a disincentive to volunteering. The recent announcement by the Scottish Executive that it will meet the costs of volunteer checks in Scotland is greatly encouraging, and we urge the Government to take a similar stance in England and Wales.

18 January 2001

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