Education Bill

Memorandum submitted by the Institute of Career Guidance (E 61)

1. Introduction

1.1 The Institute of Career Guidance (ICG) is the largest career guidance professional association in the UK, with over 4000 members (3000 in England) who work in a variety of settings with young people and adults.

1.2 The ICG requires all members to adhere to its Code of Professional Ethics (Appendix 1). The first point of the code requires members to ensure impartiality at all times in the delivery of career guidance.

1.3 The ICG maintains a Register of Professional Practice, membership of which requires the holding of recognised professional qualifications and a commitment to ongoing continuous professional development (Appendix 2).

1.4 The focus of this submission by the ICG is on Clauses 26 and 27 of the Education Bill. Commentary on and proposed amendments to these clauses and sub clauses are presented below.

2. Careers Guidance – the Context

2.1 Consideration of the clauses in the Bill must be set within the context of the Government’s plans for the introduction of an all age careers services (aacs) in England, encompassing the work of the Next Step (adult careers service).

2.2 The ICG welcomed the Government’s intentions to establish an aacs for England based on the key principles of independence and professionalism.

2.3 However Parliament is now being asked, through the provisions in this Bill to agree to fundamental changes to how careers guidance, information and advice will be provided for young people in education in England without there being clarity on what role the aacs will have in the provision of services.

2.4 We understand that the aacs will not be resourced by Government to provide face to face career guidance for young people in education. If this proves to be the case, it will be a misnomer to describe the remit of the aacs as ‘all age’. It will also unnecessarily raise an expectation in young people, their parents and key stakeholders that cannot be met.

2.5 We strongly support the importance attached to the professionalisation of the career guidance sector. The Governments encouragement of the leading professional careers associations, including the ICG, to work together through the Career Professional Alliance (CPA) is a significant development.

2.6 It is unclear however, whether Government will be prepared to underpin the establishment of the new arrangements for career guidance services in England with a commitment that publicly funded career guidance should be provided by career guidance professionals.

2.7 The ICG considers that the Government (as a matter of urgency) now needs to share its vision and a coherent plan for the provision of career guidance services, encompassing the provisions in this Bill, the role of the aacs and the requirements to be placed on providers of career guidance services

3. Key Recommendations

3.1 The ICG considers that:

· Government should introduce a requirement that all publicly funded career guidance, including that secured by schools, must be delivered by career guidance professionals. This will ensure that the provision of career guidance is impartial, includes information on all available education, training and employment options and promotes the best interests of pupils

· Career guidance professionals should be defined as ‘individuals that can evidence that they subscribe to the required professional standards and ethical principles of the profession and hold the necessary qualifications to practice as a career guidance practitioner’. The ICG considers that this requirement can be best met through career guidance professionals holding membership of a register of professional practice of a careers professional association.

3.2 The ICG considers that:

· The duty placed on schools to secure independent career guidance services will result in the majority of pupils not having access to face to face career guidance services provided by career guidance professionals due to the limited resources likely to be made available by schools for this purpose.

· The Secretary of State should discharge his duty to provide career guidance for young people in education by adequately funding the aacs to provide face to face career guidance services delivered by career guidance professionals.

3.3 The ICG considers that:

· Providers of career guidance services to schools must be required by Government to meet quality assurance standards that are akin to those required of the providers of the aacs.

· Schools provision of career guidance should be subject to assessment by Ofsted.

4. Provisions in the Education Bill

4.1 Clause 26 (4)

4.1.1 The intention of this clause is to repeal the duty on schools and FE institutions to permit access by persons involved in providing education and training support services. This has, until now, included access by careers advisers for the purposes of providing career guidance for pupils. The ICG understands that in future it is intended that access to schools and pupils will be by agreement between the school and the provider of career guidance services. It would be helpful to know how people attending further education institutions, 6th Forms and others undertaking part time vocational education, including apprenticeships will be able to access career guidance services in future?

4.2 Clause 26 (5)

4.2.1 Our main concern in relation to this clause is what duties will be placed on schools, and on the providers of independent career guidance to schools, to contribute data to the National Client Caseload Information System (NCCIS). Without such a requirement it is difficult to see how the data collected by Government on the post 16 destinations of young people will have any validity as it will be far from comprehensive. It is also to be hoped that the NCCIS data will be joined up to the CRMS data of Nextstep to provide a comprehensive data record on individuals, to enable the aacs to support their clients and, in particular, in relation to their transition from education.

4.3 Clause 27 (2) – 42A Provision of Career Guidance in Schools in England (1)

4.3.1 The duty to be placed on schools to secure the provision of independent careers guidance presented in an impartial manner will not in our view, be robust enough to make this a reality.

4.3.2 We are very concerned that the DfE has intimated that this requirement could be deemed to be satisfied by schools securing access for their pupils to national telephone and online career advice resources, to be provided as part of the aacs offer.

4.3.3 The ICG believes that all young people should have the option to review their career decisions in a face to face situation with a career guidance professional. Without this personalised support we consider that the social mobility of young people will be significantly impeded and that access to career guidance services will become even more of a post code lottery than it currently is.

4.3.4 We are particularly concerned that schools in the most disadvantaged areas of the country, with access to limited resources, will be unable to fund significant level of face to face services. State schools are unlikely to be able to pass on the costs of careers guidance to parents, as is the case in many independent schools.

4.3.5 The ICG considers that the Government must fund the aacs to provide face to face services for young people in education, requiring the service to work in partnership with schools and local authorities to determine how this resource can be best deployed in order to ensure that as many young people as possible can have access to career guidance services when, where and how they need it.

4.3.6 The drive to attain independent career guidance must not override a requirement for career guidance provision secured by schools to meet acceptable professional quality standards.

4.3.7 The ICG endorses the government’s view that access to independent career guidance is essential for young people and fully supports the requirement for career guidance to be provided in an impartial manner that will promote the best interest of pupils. We are however concerned that Government is equating independence as a requirement to achieve impartiality of careers information, advice and guidance provision.

4.3.8 The ICG considers that the independence of provision will not in itself guarantee that career guidance is presented in an impartial manner. Membership of the Institute of Career Guidance requires that at all times our members act impartially, a principle enshrined in our code of ethical standards and principles.

4.3.9 In our view, what is paramount in the provision of career guidance is that it provided in an impartial client centred manner, first and foremost, and that the securing of this requirement must be the priority for Government.

4.3.10 The ICG considers that this can be best achieved by placing a requirement on schools that career guidance must be secured from career guidance professionals who are registered with an accredited careers professional body.

4.3.11 This approach is entirely in tune with the Governments intent to professionalise the career guidance sector. It is also reflective of how other professional services ensure client centeredness and professional impartiality.

4.3.12 Should Government not be prepared to amend this legislation in this way, there must be safeguards put in place which require that all providers of career guidance services to schools must be able to comply with Government determined quality standards as required of the aacs. We are particularly concerned that the requirement for IAG to be presented in an impartial manner will be difficult to evidence without this provision.

4.3.13 Given that Government is intent on replacing the duty on schools to provide a programme of careers education with a duty to secure careers guidance we also consider that this new duty should be subject to inspection by Ofsted. This would go some way to ensuring that schools are compliant with their duty and provide valuable evidence of the quality and impact of this provision.

4.4 Clause 27 – 42A (4) b

4.4.1 The ICG considers that young people require information on all career options available to them and for them to understand the implications, including costs and benefits, of their choices.

4.4.2 We propose that 4 (b) be amended to read "includes information on the full range of options (and their career implications) available in respect of 16-18 education, training and employment with training, including apprenticeships".

4.5 Clause 27 (2) – 42A (5)

4.5.1 This clause identifies how it intends to ensure that career guidance secured by schools will be independent (and therefore presented in an impartial manner). The Governments solution is to focus on the employment status of the individual providing the career guidance, by barring teachers or anyone else employed or engaged at the school to fulfil this role.

4.5.2 We are sympathetic as to why the Government has chosen to set out the requirement in relation to career guidance in this way, seeking to respond to concerns that in certain situations, e.g. where schools have a 6th Form, that the career guidance received by pupils may not always be impartial due to influence exerted by schools on pupils to enter the 6th Form. The ICG has examples provided by members of where pressure has been applied on them, as independent career guidance specialists, and on individual pupils by teaching staff, challenging or contradicting career guidance given on post 16 options. Our members view is that it has been possible to resist these actions by schools because they are not employed by the school.

4.5.3 However the ICG has also received expressions of concern from members who are professionally qualified and experienced careers guidance practitioners employed by state secondary schools for the purposes of providing career guidance and career related learning for the pupils. These members present a strong case that the career guidance they provide is impartial, client centred and in the best interest of pupils.

4.5.4 We do not believe that Government would wish to put at risk the employment of committed and experienced careers guidance professionals who are currently employed by State schools.

4.5.5 Unfortunately, in adopting this approach, Government does not state who can provide independent career guidance to pupils. As this clause stands, there is no requirement on schools to secure career guidance from career guidance professionals and we are very concerned that this could encourage unqualified and unsuitable individuals and organisations to present themselves to schools as being able to satisfy their requirement.

4.5.6 The Governments intent to exclude schools from employing career guidance practitioners is not consistent with career guidance provision in further and higher education e.g. many colleges and universities employ career guidance professionals to provide career guidance for their students and potential students.

4.5.7 No professional should be put in a position that restricts their employment options. It is not for Government to determine what role career guidance professionals can undertake for their employer or who they can be employed by.

4.6 Clause 27 – 42A (6)

4.6.1 The Government is proposing that the securing of independent, impartial career guidance for pupils should begin at the age of 13 up until the age of 16 i.e. for pupils in years 9-11 inclusive. This seems to be extremely short sighted given the intention to raise the age of participation in learning to 18 by 2015. Career decisions taken at 18 are becoming increasingly complex due to increased competition for higher education places, greater range of opportunities in employment and training, including apprenticeships and critical decisions required in relation to the costs and future returns of continued education.

4.6.2 The ICG believes that access to impartial, independent careers guidance should be extended in line with the raising of the participation age. We propose that 6b be amended to read "ending with the expiry of the school year in which the majority of the pupil’s class attain the age at which they are no longer required to participate in learning".

4.7 Clause 27 (2) – 42A – Provision of careers guidance in schools in England (7) – Careers Guidance – a Definition

4.7.1 The term careers guidance, by its very essence, encompasses a wide range of underpinning activities in support of individual career development and decision making about current and future learning and work options. The ICG considers that what is meant by the term career guidance should be clearly defined and has adopted the following definition of careers guidance as agreed by the Organisation for Economic Co-operation and Development.

4.7.2 "Career guidance refers to services and activities intended to assist individuals at any age and at any point throughout their lives to make educational, training and occupational choices and to manage their careers. The activities may take place on an individual or group basis and may be face to face or at a distance (including help lines and web based services). It will include career information provision, assessment and self assessment tools, counselling, interviews, careers education programmes, taster programmes, work search programmes and transition services"(Extract taken from OECD, 2003).

4.7.3 We consider that this is a far more appropriate descriptor of what career guidance constitutes from the definition contained in the Bill – to quote "careers guidance means guidance about careers".

4.8 Clause 27 (3) (4) – Careers Education in Schools

4.8.1 These clauses repeal the statutory requirement on schools to provide a programme of careers education for pupils between the ages of 11 and 16. In our view this is a backward step. Best Practice evidence clearly demonstrates that career guidance is most effective when it is integral to identifiable career related learning, which can be delivered in a variety of ways including as a cross curricular theme. We understand Government will still expect schools to provide careers education for their pupils, but we also know the pressure schools are under to target their resources on core curriculum subjects. We are concerned that without this requirement being retained, many schools will marginalise careers education, and this will be particularly detrimental for pupils with limited access to parental or peer networks and who may not be enabled to review their career options with a career guidance professional through their school.

4.8.2 We note that the Act retains a requirement for schools in Wales to provide programmes of careers education, a move which is warmly welcomed by our members from Wales who support the Careers and the World of Work 11-19 Framework. The Welsh Assembly Government is at the forefront of seeking to secure high quality programmes of careers education for young people up to the age of 19 and they are to be commended for their work in this regard.

4.8.3 We note with interest that careers and work related education supported by independent publicly funded career guidance is valued not only in Wales but also in Northern Ireland and Scotland. We would welcome the committees views on why it is no longer considered necessary to be provided for pupils attending secondary schools in England?

March 2011
Appendix 1

The ICG Code of Ethical Principles

The ICG, whilst recognising the diversity of backgrounds and work settings of its members, requires all members to adhere to the highest standards of professional behaviour as set out in the seven principles below:


Professional judgement must be objective and take precedence over any external pressures or factors that may compromise the impartiality of career guidance offered to clients. When providing career guidance, members must ensure that advice is based solely on the best interests of and potential benefits to the client.


Members are expected to respect the privacy of individuals, disclosing confidential information only with informed consent, except where there is clear evidence of serious risk to the client or welfare of others.


Members have a duty of care and are expected always to act in the best interests of their clients.

Members should develop and maintain professional and supportive working relationships with colleagues both inside and external to their own organisation.

Members must fulfil their obligations and duties to their employer, except where to do so would compromise the best interests of individual clients.

Members have a duty of care to themselves, both in terms of their personal integrity and their personal safety.


Members must actively promote equality and work towards the removal of barriers to personal achievement resulting from prejudice, stereotyping and discrimination.

Members should treat clients equally regardless of their gender, age, race, disability, religious beliefs or sexual orientation.


Members must promote access to services in a range of ways that are appropriate and ensure inclusion.


Members are accountable for their actions and advice to the public and must submit themselves to whatever scrutiny is appropriate to their office.


Members will maintain their professional competence, knowledge and skills through participation in continuous professional development informed by reflective practice.

Appendix 2

ICG Criteria for a ‘qualified career guidance practitioner’

The ICG Policy states that:

a) a ‘qualified’ career guidance practitioner should be able to provide evidence at the equivalent of NVQ4 that they:

i) have studied [1] appropriate theories of vocational and career/s guidance, including theories of career choice, and theoretical approaches to the conduct of professional interventions

ii) have studied professional practice in vocational and career/s guidance, and are competent in the practical implementation and conduct of guidance intervention involving interviewing and group work

iii) have studied the ethical considerations and implications of their autonomous professional practice and have experience of its application

iv) have a commitment to their own continuing professional development [2] , ethical practice and the advancement of their own professional knowledge and understanding

b) Anyone who has already attained:

· The Diploma in Careers Guidance

· The Qualification in Careers Guidance / Qualification in Careers Guidance and Development (Scotland)

· NVQ Level 4 in Advice and Guidance with specified units

· NVQ Level 4 in Learning Development and Support Services with specified units

will be recognised as meeting the above criteria, and considered to be a ‘qualified’ career guidance practitioner, provided they also satisfy the CPD conditions.

c) Anyone wishing to be considered ‘qualified’ by the ICG, will need to provide evidence that they have studied as specified under i, ii and iii above. The ICG will hold, and make available, a list of those Approved Centres and relevant qualification that will exempt applicants from producing supplementary evidence of their studies.

[1] The term ‘studied’ in i , ii, iii is used to mean that they have undertaken an independently assessed course – full time, part time, distance or e-learning – covering these topics.

[2] The ICG website currently describes commitment to CPD in relation to entry to the Register of Practitioners as having ‘achieved 25 points within the 12 months prior to application or participated in 5 distance activities from the following broad categories


[2] 1. Work-based, non accredited learning

[2] 2. Self directed learning

[2] In service training 5

[2] Reflective Practice 5

[2] Supervising/mentoring 5

[2] Case study 5

[2] Work-shadowing/experience 5

[2] Temporary secondment/promotion 5

[2] Involvement in development projects 5

[2] Reading / research/reflecting-theory and practice 10

[2] Self-funded learning 10

[2] 3. Formal, accredited learning

[2] 4. Professional activity

[2] Training event 5

[2] Additional related qualification 20

[2] Published article

[2] Delivering INSET/lecture 5

[2] Leading a practice team 5

[2] Active involvement in a professional association 5

[2] Contribution to ICG Community of Practice 5

[2] Participation in events with relevant clear learning outcomes 5