Memorandum submitted by Recruitment and
Employment Confederation
1. INTRODUCTION
1.1 This submission is in response to the House
of Commons Education Committee call for evidence on the role and
performance of Ofsted.
1.2 The response outlines the role of the REC
and REC Childcare, the interaction between our members, nannies
and Ofsted. This response comments solely on issues relating to
the supply of nannies by REC Childcare agencies.
2. ABOUT THE
REC AND REC CHILDCARE
2.1 The REC represents around 8,000 recruitment
company branches, estimated to constitute half of all recruitment
agency branches by number but a higher proportion by turnover.
2.2 Over 85% of the industry is made up of small
businesses. In 2008-09 the recruitment industry generated a turnover
in excess of £22 billion and placed 1 million people into
temporary jobs every week in every sector of the labour market.
2.3 REC Childcare is one of 20 specialist sector
groups, covering the entire recruitment industry run by the REC.
REC Childcare represents agencies who deal primarily with the
placement of nannies, nursery staff and maternity nurses. The
group comprises over 140 recruitment agencies across the UK.
2.4 The REC supports members with their responsibilities
through the provision of free legal services, model contracts
and advice and guidance on setting up an agency. Correct and ethical
recruitment is the prime concern of the REC and all our members'
sign up to a Code of Professional Practice and are subject to
random inspections.
3. RESPONSE FROM
REC CHILDCARE—SUMMARY
3.1 REC Childcare is calling for a complete overhaul
of the way nannies are registered on the Ofsted Voluntary Register,
which ensures their application and documentation are properly
scrutinised and checked as part of the registration process. Alternatively
we would like to see the introduction of a professional compulsory
registration process for all nannies, with the responsibilities
for registering on such a register, being removed from Ofsted
and given to a separate body tasked with registration and revalidation
of all nannies.
3.2 Ofsted run a Voluntary Childcare Register,
the primary aim of which is to facilitate the voluntary registration
of nannies in order to allow working parents to utilise childcare
vouchers to offset the salary paid to a nanny. However, the name
Ofsted has meant that parents view the register as a verification
that a nanny is suitable to work with children.
3.3 Parents believe that the registration process
involves the checking of appropriate documentation, which as you
will see in our response is not the case. There is great faith
in this system. A recent survey carried out by the REC and social
media network Mumsnet found that two thirds (67%) of the 1,000
mums surveyed see Ofsted registration as a thorough stamp of approval.
3.4 There are numerous flaws in the system; unqualified
nannies are slipping through the net by not being required to
provide proof at the application stage that they have all of the
relevant documentation required to enable them to be registered.
A system of self-declaration (the applicant simply ticking boxes
to say they meet the criteria) appears to be acceptable to Ofsted
and they rely on a small number of physical inspections each year
to verify these declarations.
3.5 Nannies have also been found to be producing
false documents to support their application to be on Ofsted's
Voluntary Childcare Register. In one particular case, a REC Childcare
agency discovered that a nanny who had successfully registered
on the Voluntary Childcare Register had a false visa and was illegally
working in the UK, yet was able to produce a letter from Ofsted
confirming her registration on the Register.
3.6 In a high profile case which received much
media attention, a member of the REC's Childcare group applied
and successfully received certification to be on the Ofsted Voluntary
Childcare Register, despite having none of the requirements to
enable her to be on the Register.
3.7 Once a nanny is registered, they receive
a letter from Ofsted confirming their registration. This has no
expiry date on it, which means that even if that nanny is "removed"
from the register, they would still have a letter to show to unsuspecting
parents.
3.8 The REC is seriously concerned about the
implications of all of this, but most importantly fears for the
welfare of children if rogue nannies are able to obtain work by
being on the Voluntary Childcare Register. To further compound
the situation, anecdotal evidence shows that only 10% of nannies
on the Voluntary Childcare Register are inspected, highlighting
just one flaw in the system.
3.9 There have also been cases reported of Ofsted
auditors inspecting nannies with clearly no knowledge of what
it is a nanny does (as opposed to a childminder or nursery), and
no real idea of what it is they are supposed to be inspecting
often calling into question the professionalism of nannies placed
by our members.
3.10 Further evidence shows that parents are
increasingly hesitant to agree to an Ofsted inspection of their
nanny as they feel this somehow calls into question their own
parenting skills.
3.11 The role of the Post Office in this registration
system is wholly inappropriate. There is much anecdotal evidence
from nannies who have registered to show that the Post Office
is not properly trained in the process and does not know what
documents it needs to view, or how it should be inspecting those
documents.
3.12 The function of the Post Office appears
to be simply in order to process the CRB application, and therefore
they just tick boxes to say documents have been produced without
fully checking them and with no understanding at all of the actual
voluntary registration process. Parents place a lot of trust in
Ofsted, and therefore in the Ofsted Voluntary Register. Due to
the flaws in the system, this trust is misplaced.
3.13 REC Childcare believes that if the registration
and revalidation of nannies process were to be tightened up, the
costs of administering such a process could be covered by the
reduced need for external auditors used by Ofsted who at the moment
are not correctly briefed on how to conduct inspections on the
competencies of a nanny.
4. WHAT THE
PURPOSES OF
INSPECTION SHOULD
BE AND
THE PERFORMANCE
OF OFSTED
IN CARRYING
OUT ITS
WORK
4.1 Our response relates to inspections or audits
of nannies on the Ofsted Voluntary Childcare Register. REC Childcare
believes that inspections are most effective when a correct brief
is provided. The purpose of an inspection or audit of a nanny
is clearly to ensure that the nanny is suitable and capable of
carrying out the tasks required. However, as stated on the Ofsted
website:
Registration on the Childcare Register relies on
the applicant making a declaration to confirm that they will meet
the requirements of registration. Ofsted carries out a Criminal
Records Bureau (CRB) check on the applicant but does not normally
carry out any other checks. We do not usually interview applicants
for the Childcare Register to assess their suitability, as we
do for the Early Years Register.
4.2 This reliance on the applicant and lack of
checks as part of registration on the Ofsted Voluntary Register
(with the word Voluntary often dropped not just by Ofsted but
by nannies wanting to boost the credibility of the Register) feeds
through to a fundamentally poor inspection regime, with the purpose
of inspections often missed.
4.3 Nannies have often approached REC Childcare
members to complain that they are being inspected as though they
were childminders, with often distressing questions about the
suitability of living conditions being asked.
4.4 This latter point often raises concern amongst
parents, who often feel they themselves are being audited by Ofsted
for the suitability of the environment in which they are raising
children and as a result auditors are sometimes refused entry
to homes by parents.
4.5 The performance of Ofsted inspections is
hindered by the performance of Ofsted and the lack of an adequate
system put in place to register nannies. This lack has given rise
to problems as raised above in 3.4 to 3.7
5. THE CONSISTENCY
AND QUALITY
OF INSPECTION
TEAMS IN
THE OFSTED
INSPECTION PROCESS
5.1 Ofsted inspection teams are often freelance
auditors contracted by Ofsted to carry out audits. As a result
there are inherent inconsistencies from audit to audit (for example
the primary case above of inspecting nannies as childminders).
5.2 It would be easy to question the suitability
and professionalism of the external auditors used, however we
believe the lack of consistency is a result of systemic failure
both inherent (due to the nature of using outside contractors)
and in the information given to auditors by Ofsted.
6. THE WEIGHT
GIVEN TO
DIFFERENT FACTORS
WITHIN THE
INSPECTION PROCESS
6.1 As discussed previously the weight given
to different factors in the inspection process is imbalanced and
we would welcome the ability to see what factors Ofsted use in
their inspections of nannies.
6.2 Outside the Ofsted inspection process, there
should be a shift in focus away from inspections and towards effective
registration and revalidation of nannies with dated certificates
once revalidated, to ensure the confidence parents place in the
system is valid.
7. WHETHER INSPECTION
OF ALL
ORGANISATIONS, SETTINGS
AND SERVICES
TO SUPPORT
CHILDREN'S
LEARNING AND
WELFARE IS
BEST CONDUCTED
BY A
SINGLE INSPECTORATE
7.1 The Ofsted Voluntary Register does not work.
The focus within Ofsted is on education and anecdotal evidence
suggests only 10% of nannies on the Ofsted Voluntary Register
are inspected. This is a low number which does not justify the
confidence placed in the Register.
7.2 Given all the factors above REC Childcare
are calling for either the overhaul of the way that nannies are
registered on the Ofsted Voluntary Register of the for the introduction
of a compulsory registration of all nannies, where their application
and documentation are properly scrutinised and checked.
7.3 We believe these responsibilities should
be removed from Ofsted and given to a separate body tasked with
registration and revalidation of all nannies. This move could
also encompass other children's services which currently fall
under the remit of Ofsted, to allow a more focussed approach on
the protection of children to be conducted.
October 2010
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