Select Committee on Home Affairs Appendices to the Minutes of Evidence


Memorandum by the Scripture Union (England and Wales)



  1.1  Scripture Union is a Christian registered charity and a limited company. It has been established for over 130 years, with 130 paid staff and 5,000 volunteers a year. It works throughout England and Wales with children, young people and families in school, church, community and residential settings. Much of its work is with churches across denominations.

  1.2  We have comprehensive policies and procedures, not least in the area of Safe Care of Children, and have been following the establishment of the Criminal Records Bureau with interest and some concern, as follows:—


  2.1  There is no legal requirement for those working with children to request Disclosures from the CRB. It does appear to be an offence to employ someone if a Disclosure would have shown convictions preventing them working with children. Is there really freedom of choice? Will insurance companies take the risk of insuring those who elect not to use the CRB, however comprehensive the current selection procedures of these prospective clients may be?

  2.2  Enhanced Disclosures provide information in a way that conflicts with Human Rights Act 1988.

  2.3  We would value a consistent definition of "child". The Education Act 1996, defines a child as "a person who is not over compulsory school age, that is, generally under age 17 who has not yet lawfully left school". We have discovered Social Services procedures differ with regard to 16 and 17 years and lack consistency across the country.

  2.4  There appears to be inconsistency in plans for retention of record. The draft Explanatory Guide for the Code of Practice states a Registered Body may retain a certificate and associated correspondence for six months, with the possibility of a further six months should a dispute arise. Other legislation, such as the Sex Discrimination Act 1975 and the Race Discrimination Acts 1976, require details of applications for employment to be retained for 12 months.


  Throughout the period of its establishment, the CRB has declared itself concerned to provide Enhanced Disclosures for those who "regularly care for, supervise, train or are in sole charge of children or vulnerable adults". A definition of "regular" is urgently needed. Like many others, we have a variety of paid and voluntary staff who have different levels of involvement with children. Some carry out daily full time work with children in a school or church setting; others work in a residential context 24 hours a day, but only for a week annually; others have "regular" access to the child at home through the production of printed or electronic materials. The concern has to be the availability of direct access to the child, rather than the amount of days in a year that a person has that access. Is it rather unsupervised access to children (and vulnerable adults) that should be the issue?


  4.1  Money is only one issue for charities. Much greater is the effect on administrative procedures, and damage to ministry. We greatly depend on short term volunteers. There are implications for our residential holidays, particularly during vacations. We greatly value the work of approximately 3000 volunteers, and aim to encourage young adults to be involved . Large numbers become committed to working with the charity for many years. Many would speak of the character building, positive life changing experience that they receive during this time. We aim to have teams in place as soon as possible in any year to allow for appropriate training and team building to take place; we already do scrupulous checks and insist on all screening procedures being completed satisfactorily before direct contact with children begins. Administratively it is a pressurised time, and we stop allowing applications when we won't be able to process them appropriately before the event begins. My understanding is that before a Disclosure is sought from the CRB all other selection procedures must have been followed and the in-principle decision taken about the applicant's suitability for the post. The original statement was that the aimed for turn-around time would be five days; in November 2000 CRB'S Director, stated that it was aiming at 15. While this may be more realistic, it is alarmingly long; in effect it is asking people to volunteer almost a month sooner than they do now. For students, that means making decisions before becoming immersed in the build up to their exams; that is unrealistic. Fifteen days delay in finalising selection will rule them out.

  4.2  Most voluntary organisations employ a small number of paid staff. There would be a three week delay before an offer of employment could be confirmed. Assuming an applicant wouldn't give an employer notice without confirmation, this could double the length of time before availability to commence duties. Should the offer be withdrawn when the Disclosure arrives, any second choice applicant is unlikely to still be available, and even if they were, another 15 days process begins.

  4.3  There have been many debates but no definite announcements of costs. We are trying to put together a budget for the next financial year to allow for becoming a registered body (if necessary), increasing administration (something every charity dreads), absorbing Disclosure costs for volunteers (to encourage people to still come forward—and so that it's not more costly to volunteer if you live in England and Wales rather other parts of the UK).

  4.4  We cannot budget accurately, but must put in a realistic contingency—and this may necessitate setting aside plans for ministry development.

  4.5  Should the Bureau be able to rule out harm to children , no cost would be too high and anything would be worthwhile.


  5.1  Access for voluntary organisations to DfEE's List 99 or the Department of Health list would be welcome.

  5.2  For it to work effectively, everything depends on police officers understanding the nature of any task being offered to any person across the country and interpreting what is `relevant information' which should be revealed. If an applicant has moved house, information will be sought from the previous place of residence, so police officers will need to be interpreting data in the same way. How can employers be sure police officers appreciate the intricacies of the variety of tasks to interpret the data appropriately? How much longer (than 15 days) do we need to allow in order for several forces to provide information?

  5.3  I am gravely concerned by the apparent ease by which a person could set herself up, declare herself the recipient of a Disclosure and assume an air of respectability with no accountability at all—a perfect opportunity for abusers.

Lesley Blight

Director of Field Ministries, Scripture Union

January 2001

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