Memorandum submitted by John Allen


Executive Summary


1 The absence of anyone with extensive home education experience in the Expert Reference Group, little use of evidence from home educators and the discounting of the published research on home education are major flaws.

2 Registration according to Recommendation 1, combined with the effects of Recommendations 23 and 24 combine to change the legal freedom to home educate with an unjustified annual provisional licence to do so from the LA.

3 Attempts to impose restrictive views of educational approaches and philosophy, as well as curriculum, by narrow definitions of 'suitable' and 'efficient' education are not compatible with the acceptable diversity of home education.

4 The details of Recommendation 7 infringe the legal and civil liberties of home educators.

5 Proposed support of home educators should not be compulsory, and there should be no obligation to accept part or any of it.

6 Concerns over safeguarding children are unjustified and open to manipulation by pressure groups opposed to home education in part or as a whole.

7 The report will probably harm, rather than help, good relationships and mutual trust between Local Authorities and home educators.





1 The European Academy for Christian Homeschooling (TEACH) began 10 years ago as a support organisation for those families home educating using the Accelerated Christian Education (ACE) curriculum (which is used in over 130 countries worldwide), and has a current membership of about 780 families, mostly in the UK, but some in Europe, and UK expatriate members in other countries. It provides

training and support for all families using the ACE curriculum

support is given by phone, email or letter from the main office or by a nationwide system of Contact Families and Regional Coordinators, and includes academic, legal and pastoral support and help in dealings with the Local Authorities

membership of TEACH gives access to a qualification - the International Certificate of Christian Education (ICCE)

there is also an annual national residential conference and more regular local meetings as well as intermittent Interactive Days throughout the British Isles


2 There are a number of general points that arise on reading the Report which need to be considered first.

a why was there nobody with practical home educating experience on the expert panel (to provide the necessary expert information)? As far as we can see, there was nobody with the relevant first hand experience and information to give the evidence the panel surely needed so desperately.

b why was so little of the evidence from home educating families used? There are a disproportionate number of quotes and other evidence from non-home educators.

c why did Mr Badman discount the published research on home education? He says 'I believe...' at least 16 times in the report, but what he believes is not significant compared to the evidence from the substantial amount of peer- reviewed research currently available.

d why now? Mr Badman says (Para 1.4) that the Guidelines are unworkable (but only according to the Local Authorities), when the evidence is they have not been given enough time to see if they work.

e why does Mr Badman say (Para 3.1) 'I am not in any way arguing that elective home education is intrinsically wrong...'? Unless he is aware that the opposite impression is given in the rest of the Report?


3 When Recommendations 1, 23 and 24 are taken together then the effect is to change the freedom to home educate to a provisional licence to do so from the LA. Para 3.11 may say 'This review does not argue against the rights of parents..' but the practical effect of these three Recommendations will be to abrogate those rights, and leave home educators subject to the whims and ideas of the LAs; and there is considerable evidence that a number of them are lamentably ignorant of elective home education, and some are actually hostile. These Recommendations need changing to protect the freedom to home educate.


4 Recommendation 1 has 12 subsections, some of which need specific comment.

Subsection 7 mentions the 'requirements of registration', with no evidence as to what they might be, other than the simple freedom to do it. What (if any) are the requirements?

Subsection 8 says parents 'must provide a clear statement of their educational approach...' with no protection for those whose LA disapproves of their educational approach or (say) use of a Christian curriculum. The evidence is that some LAs will see this as a possibility of enforcing a specific approach and curriculum. This is a long way from Article 2 of Protocol 1 of the European Convention on Human Rights which says 'No person shall be denied the right to education. In the exercise of any functions which it assumes in relation to education and to teaching, the State shall respect the right of parents to ensure such education and teaching is in conformity with their own religious and philosophical convictions.'

Subsections 9 and 10 suggest discussing the home educators plans with the LA and with schools. This is ridiculously nave. All the evidence available is that most home educators do not want discussion and advice from schools or LAs regarding their plans - if they did, they would not be home educating in the first place. All the evidence is that home education is most definitely not 'doing school at home' but a different educational philosophy, and trying to make it 'doing school at home' is not an option.


5 There is no real evidence produced to justify the sweeping and alarming proposals in Recommendation 2. There is no evidence given to justify forcing home educators into the straitjacket of the Rose review, when there is ample evidence that widely differing curricula and educational approaches can provide an efficient and effective education as measured by the later lives of home educated children. Years of experience give sufficient evidence that this process of governmental definition of 'suitable' and 'efficient' will inevitably be very narrow and prescriptive. There is also some evidence that the Rose review itself does not have universal approval, and should not be made the measure of all other approaches. It is nice of Mr Badman to suggest the home educators should be engaged in this, although the wording suggests they will, or should, have little impact. We have yet to see if home educators would want to be associated with this Recommendation's attempt to stifle their freedom with a governmental definition.


6 Recommendation 4 proposes that a Consultative Forum should be set up for home educating parents to 'secure their views and representative opinion'. However Para 1.3 of the report makes the quite unexceptional statement that 'to attempt to categorise the views of home educators or regard them as an homogenous group would simply be wrong'. This diversity is further acknowledged in Para 4.9. Yet despite the evidence in the report attesting to the tremendous diversity in home education, the report then proposes a Forum for 'representative opinion'. This is, perhaps, a little optimistic. It is likely that the only representative opinion would be 'leave us our freedom'. In addition, Para 4.9 has a couple of quotes. It is not surprising that the British Humanist Association would wish to suppress Christian home education, although it is thought-provoking that the report sees fit to quote it. The quotation from the Education Division of the Church of England omits the conclusion at the end, 'We have seen no evidence to show that the majority of home educated children do not achieve the five Every Child Matters outcomes, and are therefore not convinced of the need to change the current system of monitoring the standard of home education. Where there are particular concerns about the children in a home-educating setting this should be a matter for Children's Services.' The reason they found no evidence is, of course, because there is none; certainly there is none in the report to justify the more controversial proposals. And, whilst there is no evidence that home educated children do not achieve the ECM outcomes, there is some evidence that not all schoolchildren achieve them.


7 Repeated reading of Recommendation 7 reveals it to be not so much controversial as inflammatory. On the evidence of this recommendation, the only conclusion is that home educators are (contrary to English law) guilty until they can prove themselves innocent: no other conclusion is possible from the way it rides rough-shod over civil liberties. Para 5.5 talks of 'good relationships and mutual trust, respect and open communication between the home educating family and the local authority', but this Recommendation will harm rather than improve them. In detail:-

before training, the designated LA officials should be vetted to exclude those hostile to home education or a section of it, such as Christian home education or autonomous learning. It would be invidious for those known to be hostile to be involved in assessment, and would not be fair on them or the families. It would be best if these officials could be found from past or present home educators, as only these will have the invaluable knowledge and personal experience to be able to assess the evidence accurately.

no-one has right of access to a home without a warrant or well founded suspicion of wrongdoing. Which rationale is used to support this recommendation? Article 8 of the European Convention of Human Rights speaks of a right to private and family life, a right which is not protected by LA officials having the right to intrude. Home education is not a crime, and those who home educate should not be treated as if they were criminals.

no-one has the right to interview a young child alone. To exempt home educated children from this protection merely because they are home educated is simply discriminatory under the terms of the Equality Act 2006. At the least, children should have a supportive advocate to prevent any manipulation or pressurising by any unsympathetic officials.

to argue that only by right of access to the home and right to interview the child on their own can officials ensure they are safe and well is insulting, offensive and inaccurate. All the evidence from the real world is that abuse and harm to children is related to other factors entirely, not to home education.

home education is not 'doing school at home' and to try and assess the effectiveness of home education on that basis is impractical.


8 All the evidence on the current situation is that the selection and training of LA officials is critical, and it will continue to be so. The problems are what sort of training and who plans it and who delivers it. Pious talk regarding the 'essential difference, variation and diversity in home education practice' are all very well, but there needs to be some form of monitoring to prevent these officials slipping back into wanting 'doing school at home'.


9 Recommendations 10 to 12 deal with issues around LA support for home educators. As Para 5.7 shows, apart from access to public examinations, there is very little agreement as to what, if any, support is wanted or needed. In TEACH we try and provide support to our members in a variety of ways, including local and national meetings and activities. The evidence from our experience is that many, if not most, of our members prefer not to avail themselves of our support, but simply want to be left alone in peace to get on with it themselves. The evidence is that this approach is also quite widespread in the wider home educating community. We would hope and expect that our membership would seek any support they need from within TEACH and we are constantly looking at ways to improve this. We also not only aim for support, but TEACH members can access (and are encouraged to do so) the International Certificate of Christian Education as an alternative to state qualifications. These Recommendations, then, raise some concerns.

is this kind of support from these sources to be compulsory?

if a family declines any or all of the offers of support, will there be hostility, suspicion, removal of registration or other unfounded sanctions?

There is no evidence that these concerns have even been considered. It should be made clear that 'support' is not mandatory, and that no conclusions, adverse or otherwise, can be drawn from declining to use it.


10 Safeguarding is the theme of Recommendations 21 to 25. As a general point, no evidence is given for this ill-advised conflation of welfare and educational policies. There is also no definition attempted for the terms 'abuse' or 'harm'. There are those who consider teaching your children your religious beliefs (but not any irreligious ones!) to be 'child abuse'. On that definition, all members of TEACH are child abusers! Other examples no doubt spring to mind. Given the wide diversity of home educating practice mentioned frequently in the report, it is certain that some home educators will be considered child abusers by some pressure group or other. Experience would show that lack of careful definition here would be an open invitation to the ideologically committed to raise the cry of abuse. Further, the evidence from the real world is that Para 8.4 is inaccurate, as attending school does not help protect against harm; rather, it may provide the opportunity for it, as in bullying.


11 Para 8.2 acknowledges the argument that the review has helped to create a climate where home educators are guilty because they are home educators and need to prove their innocence. No evidence is given, nor any argument attempted, to dispute that allegation. Further, Para 8.12 has the sentence ' So saying is not to suggest there is a causal or determining relationship (between home education and child abuse)...' Experience shows that these denials are only necessary when the thing denied is, in fact, implied or suggested, and indicates that the suggestion that there is a causal link between home education and child abuse is at least implied. Para 8.12 also has a glaring irrationality. It is repeatedly affirmed (Para 1.3, Para 6.1) that the number of home educated children is not known. It is therefore impossible - not difficult, but impossible - to know whether the number of children known to children's social care is 'disproportionately high relative to the size of their home educating population' (which is the unknown). Also being known to children's social care may just mean that the family is home educating and nothing more as there is some evidence that in some LAs all home educated children are known to social services simply because they are home educated.


12 Recommendations 23 and 24 have been mentioned before, as, together with Recommendation 1, they provide a basis for removing the freedom to home educate and change it into a provisional, annually renewed, licence. The evidence for this is the inclusion of the fourth grounds for 'properly evidenced concerns' (whatever 'properly evidenced' may mean), which reads 'anything else which may affect their ability to provide a suitable and efficient education'. This ' catch-all' ground for concern will enable the ideologically and irreligiously motivated to raise concerns because the educational approach (such as autonomous learning) is disapproved of , or religious convictions leading to a Christian education may also be considered something that prevents a suitable and efficient education. The complete lack of definite evidence as to which elements of the diversity of home education will be considered 'safeguarding concerns' needs to be addressed.


13 The Guidelines on Home Education of 2007 provided an excellent opportunity to build the 'good relationships and mutual trust' that Mr Badman repeatedly encourages. All the evidence is that this report is developing the opposite.


September 2009