Does discretionary reporting work?

We now know that several schools which have had abuse scandals or tragedies where pupils have died have not been effectively implementing statutory guidelines on reporting child protection concerns.

I've blogged recently about Bishop Bell School and their complete lack of record-keeping concerning the activities of Jeremy Forrest until he abducted a pupil to France. I've blogged extensively about the efforts it took to get St Benedict's School to publish a good safeguarding policy. I've blogged about what the Serious Case Review into Daniel Pelka's death found about safeguarding at Little Heath School, which he attended during the last six months of his life.

So we definitely have a situation where scandals and tragedies have happened at schools which implement bad safeguarding, but this doesn't tell us how widespread bad practice is.

So I decided to do a bit of research. Following the Pelka Serious Case Review, I decided to check out the safeguarding policies of all the schools in Coventry, which is the local authority covering Little Heath School.

I decided to obtain the safeguarding policies for as many schools as I could, by downloading the policy from the school website where it was available, or by requesting a copy of the policy from the school, formally under the Freedom of information Act if the school didn't respond to a simple request. I obtained the policies for 114 schools, which is most of Coventry's primary and secondary schools.

I then checked each policy and assessed it against the following 10 criteria

1. The policy names and briefly describes the kinds of abuse that is covered: physical, sexual, emotional and neglect.
2. The policy describes the signs of abuse that staff should look out for.
3. The school has a named designated teacher for child protection.
4. The school also has a named designated governor for child protection
5. The policy instructs all staff to promptly inform the designated teacher of allegations or incidents of abuse, and sets out the procedure for doing this.
6. It requires that designated teacher to inform the local authority designated officer promptly of all allegations or incidents of abuse.
7. All conversations informing the local authority designated officer are backed with written confirmation.
8. The school commits to periodic safeguarding training for all staff, with advanced training for the designated teachers and head teacher.
9. The policy does not depend on external documents for a description of any reporting procedures to be carried out by the school.
10. The school policy has a revision and publication date, and has been updated within the last 12 months.

This is not all one would expect to see in a good safeguarding policy. this is the bare minimum necessary to have a reasonable assurance that effective reporting arrangements are in place so that child protection concerns are brought to the attention of social services, so that the necessary support can be provided to the child, whatever that might turn out to be.

The reasoning behind these criteria is as follows

1. The policy names and briefly describes the kinds of abuse that is covered: physical, sexual, emotional and neglect
Unless the kinds of abuse that should be reported are described, staff won't know what they should be looking out for. It is quite clear that at Little Heath there was confusion as to what counted as a child protection concern.

2. The policy describes the signs of abuse that staff should look out for
Again, unless staff are told of the kinds of signs that might indicate abuse, they won't know what to report. Staff aren't required to make a diagnosis, but just to be aware of signs which might indicate abuse, so that they can refer their concerns to people properly trained in this area.

3. The school has a named designated teacher for child protection
Good practice requires that there is a designated teacher to whom staff in the first instance report their concerns. The designated teacher keeps the school's safeguarding records and co-ordinates the communication with social services and other outside agencies. Unless staff know who the designated teacher is, they don't know who to report to.

4. The school has a named designated governor for child protection
Every school has to have a governor with specific responsibility for safeguarding, and unless somebody else is specifically given the role, the responsibility rests with the chair of governors. The safeguarding governor should be reviewing the policy to ensure it is consistent with current guidance (which does change from time to time), and oversees the operation of the procedures. if staff are concerned about how safeguarding is operating within a school, they need to know who to contact.

5. The policy instructs all staff to promptly inform the designated teacher of allegations or incidents of abuse, and sets out the procedure for doing this
This is vitally important. Staff have to know what to do if they have a concern. They have to know what to report, who to report to, what information they need to include, they need to know how quickly the report must be made, they need to know about proper record keeping, and they need to know how to deal with a child who discloses abuse, for instance by not asking leading questions. This reporting procedure needs to be prescriptive.

6. It requires the designated teacher to inform the local authority designated officer promptly of all allegations or incidents of abuse
This is the second key link in the chain. It is one thing for teachers to tell the designated teacher of concerns, but no support or intervention will happen unless it is clear what the designated teacher will do with the reports. What should happen is that the designated teacher immediately informs the LADO (Local Authority Designated Officer for Child Protection). There will always be marginal cases where it isn't clear whether the concern is serious enough to justify a referral, but the rule in such circumstances should be that the Designated Teacher phones the LADO, discusses the case informally, and then acts according to the LADO's advice to formally report the case or not.

7. All conversations informing the local authority designated officer are backed with written confirmation
If you don't write it down, it never happened. You must keep records, and if you communicate with the LADO, follow it up in writing. A written follow up serves two purposes. First, there is a record, a paper trail. Second, a written followup serves to greatly reduce any scope for misunderstanding that might have occurred during any phone conversation with the LADO.

8. The school commits to periodic safeguarding training for all staff, with advanced training for the designated teachers and head teacher
Simply having a policy isn't enough. Child protection concerns don't arise every day, and so there needs to be periodic training of all staff in how to recognise sings of abuse and how to report them. In addition, the Designated Teacher and other senior staff need advanced training in the kinds of inter-agency work their role will involve them in - such things as case conferences, record keeping, ongoing monitoring of children at risk and so on.

9. The policy does not depend on external documents for a description of any reporting procedures to be carried out by the school
If the school's own safeguarding policy doesn't contain the school's arrangements for reporting concerns to the LADO, then we have what is known as a "self-assembly" policy, where you have to build the policy out of component parts in other documents. This is a recipe for confusion and for nothing actually getting done right. So the reporting arrangements relevant to points 5, 6 and 7 need to be wholly within the school's own safeguarding policy.

10. The school policy has a revision and publication date, and has been updated within the last 12 months
There are two reason why the policy needs to be reviewed on a regular basis. First, circumstances may change. The designated teacher might have moved to another job, statutory guidance might have changed, the Local Safeguarding Children Board's recommendations may have changed. These changed need to be brought into the school's policy where relevant. Also, a regular review ensues that governors and senior staff keep safeguarding in mind.

It is possible to argue that good safeguarding practice can exist without a good written policy. It's theoretically possible, but really unlikely, because a clear written set of procedures is needed to ensure that staff know what to do. A good written policy doesn't guarantee good practice, the policy might be being ignored. But I would argue that good practice is extremely unlikely unless there is a good policy. So checking written policies should be a good indicator of whether good practice is widespread.

So these are the criteria I checked all 114 policies against. I'll describe the results in my next blog.