Children's Wellbeing and Schools Bill

Written evidence submitted by the National Network for Child Employment and Entertainment (NNCEE) (CWSB141)

Written Evidence to Children Wellbeing and School Bill select committee

Submitted Ed Magee Chair

1.0 Executive Summary

· NNCEE supports the changes to the hours of employment for children and the change in hours on Sunday

· NNCEE will collaborate with the Department for Education (DFE) regarding types of employment roles and guidance

· NNCEE is concerned that hours will not resolve issues around televised sporting activities

· NNCEE is concerned that some job roles will still not be accessible to young people in the creative industries

2.0 The National Network for Child Employment and Entertainment (NNCEE) was formed in 1994. It is an association of mostly local authority officers who have responsibility for the licensing of children of compulsory school age who are working part-time or taking part in performances and entertainment. NNCEE members from across the UK working together to improve working conditions and safeguarding for children in employment and entertainment, promoting consistency of practice nationally for local authorities and other organisations in this field.

3.0 Support for Legislative change

3.1 NNCEE welcomes and supports the change in latest hour from 7pm to 8pm and the removal of the current two-hour employment limit on Sundays. These changes will enable more young people to access employment opportunities, as current child employment legislation is outdated.

3.2 NNCEE will collaborate with colleagues in the DFE and employment organisation to review the proposed Secretary of State regulations on the types of job roles young people can undertake. This included supporting the review of DCSF guidance on child employment last updated in 2009. NNCEE will assist in rolling out guidance and training for local authorities across England and promote legislation changes to young people, parents, and local employers.

4.0 Concerns and clarifications

4.1 NNCEE is concerned that the later hour does not fully address employment of young people in televised and live sporting events where play under floodlights or later televised times mean children of statutory school age cannot work beyond 8pm. This affects young referees, ball assistants or front of house staff. Young people taking part in the actual sport are not impacted by this legislation as they can be covered by a sporting licence where appropriate.

4.2 The later hour does not reflect the work / shift patterns of some organisations that young people could work on at weekends or during school holidays. Activities in hospitality, non-performances in theatres, sporting arenas and cinemas would be excluded. Currently children working backstage in non-performance activities such as wardrobe, sound, prompting are unable to gain experience in these jobs until they are over statutory school age. NNCEE suggest allowing hours later than 8pm on Friday or Saturday for older 15- and 16-year-olds provided the next day is not a school day or no more than three days during school holidays ensuring the total time does not exceed the permitted hours. Arrangements must be made to ensure young people would get home safely.

4.3 NNCEE seeks clarification on when the current byelaws for child employment will cease and Secretary of State regulations will replace them

4.4 Additional clarification requested include:

· Safeguarding checks for employers as currently there is no requirement for disbarring checks (DBS) where young people work

· Application of legislation to elective home educated, traveller, gypsy and roma young people

· Regulations for social influencers / content creators who may be children or taking part in content created by their parents

· Self-employed young people advertising skills such as tutoring, gardening, and baby sitting on apps currently outside child employment legislation

· Restrictions on roles such as provision of personal care, working in environments that pose health and safety risks

· Role of sport coaches, young people taking part in work experience where the job roles for paid employment are not permitted, and in voluntary organisations as part of employment training or community-based awards such as the Duke of Edinburgh award.

· Changes in technology and streaming of church services affection paid choristers. This is currently covered by performance licences, but should this be classed as employment?

· Employment of young people from the EU or other countries with different statutory school ages

· Speed of amendments to legislation and Secretary of State regulations.

· Flexibility for Year 11 pupils who have completed exams but are not above statutory school age

· Application of Section 559 of the Education Act 1996 to Academy schools.

5.0 Conclusion

NNCEE is happy to attend in person to answer any questions the committee might have. NNCEE have long advocated for changes in child employment legislation and has collaborated closely with the DFE and employment organisation to bring about these changes. The current legislation is outdated and has prevented some young people from accepting jobs. NNCEE is concerned about the reduction in permit requests since the pandemic, which may indicate more children are working illegally and at risk. The new bill will allow more young people to gain valuable work experience, aiding their future careers.

6.0 Publication

NNCEE is happy for its submission to be published.

24 January 2025