IICSA Report on Anglican and Roman Church: conclusions & recommendations

In our third blog comparing the recent reports published by IICSA into the Anglican and Roman Catholic churches we look at and compare some of the conclusions and recommendations reached in the reports.

 The Anglican Church of EnglandThe Anglican Church in Wales  The Roman Catholic Church
General commentsThe investigation found that the system of child protection was under resourced. Safeguarding personnel were ignored and overlooked whilst the reputation of clergy and the Church was prioritised. Senior leaders in the Church apologised for its actions, accepting that failings identified were “profoundly and deeply shocking”.   Since the publication of the Archbishop’s Visitation to the Diocese of Chichester in 2013 much has improved in terms of governance, training, audit, personnel, policies and procedures. However, there is a lack of challenge in decision-making and there remain areas with insufficient oversightThe Church in Wales has a centralised safeguarding structure with provincial safeguarding officers responsible for safeguarding in dioceses. However, greater resources, both in funding and personnel, are requiredBetween 1970 and 2015, there were 931 allegations or concerns of child sexual abuse made by 1,753 individuals against clergy, members of religious institutes, and lay workers. These complaints involved more than 3,000 instances of alleged abuse made against 936 alleged perpetrators. The National Catholic Safeguarding Commission’s (NCSC) annual reports  show that the Church still receives over 100 allegations of child sexual abuse per year.
Engaging with victims and survivors  Engagement with and support for victims and survivors requires improvement. The Church has been slow to find ways to engage effectively with victims and survivors or to learn from its experiences. The Safe Spaces project, which was first proposed six years ago as an online resource and national helpline for survivors in partnership, has taken too long to implement.   A Church-wide policy on the funding and provision of support to victims and survivors of child sexual abuse concerning clergy should be introduced. The policy should clearly set out the circumstances in which different types of support, including counselling, should be offered  There has been very little systematic provision by the Church in Wales for victims and survivors of child sexual abuse such as counselling, therapy, and other forms of help. A Church-wide policy on the funding and provision of support to victims and survivors of child sexual abuse concerning clergy should be introduced. The policy should clearly set out the circumstances in which different types of support, including counselling, should be offered  Safeguarding files found an imbalance in the support offered to perpetrators, which was described as “extremely comprehensive”, and the support offered to victims which was in some cases entirely absent or, in one case, “grudgingly offered”.   In 2015, the NCSC established the Survivor Advisory Panel (SAP) to provide advice to the NCSC from the victim and survivor perspective. The response of the Catholic Church in England and Wales to allegations of child sexual abuse also focused too often on the protection of the clergy and the Church’s reputation. In some cases, members of the dioceses and religious institutes actively took steps to shelter and shield those accused of child sexual abuse.  
Safeguarding policies and practices  Prior to 2013 many of the Church’s safeguarding policies had significant weaknesses and implementation of those policies was patchy. The review and redraft of the policies by the National Safeguarding Team since 2015 has been comprehensive. For example, the Parish Safeguarding Handbook, launched in 2019, and the e-safeguarding manual help to reinforce and simplify the safeguarding message. The church has been far too slow in implementing safeguarding recommendations and practices. The Code of Conduct  recommended in the Cumberlege review and the Safe Spaces project are examples of programs that have taken over five years to implement.  
Structure of safeguarding  The Church of England has struggled to develop a model for effective safeguarding within its organisational structure. Independent and professional diocesan safeguarding officers should be appointed to take operational decisions about safeguarding. This provides a route, outside of the diocese, through which concerns can be raised. They officers should also monitor and seek to provide consistency between dioceses and to lead work on survivor engagement. Such a proposal may help to provide the level of oversight which has thus far been lacking.   The officers also need sufficient authority to take action, without the approval of the diocesan bishop, in respect of key safeguarding tasks such as: reporting safeguarding matters to statutory authorities, the National Safeguarding Team, and the Charity Commission;commissioning investigations for safeguarding incidents;commissioning and instructing risk assessments;ensuring that pastoral support is given to complainants;advising on the suspension of clergy in safeguarding matters;   Diocesan bishops should help congregations and clergy to understand safeguarding and to make it a priority, “intrinsic to the beliefs” of the Church, but they should not hold operational responsibility for safeguarding.   The role of the National Director of Safeguarding should have overall responsibility for managing safeguarding within the Church and providing oversight of those operating at a diocesan level. The diocesan safeguarding officer’s work should be professionally supervised and quality assured by the National Safeguarding Team.   Cathedrals still had much more to do in respect of safeguarding. The Church has promoted a new Cathedrals Measure which make Cathedrals become charitable organisations and regulated by the Charity Commission. This will be the first time that cathedrals become externally accountable.The Church in Wales has an independent safeguarding body which reviews all complaints and decisions about whether complaints go to the Clergy Discipline Tribunal. This body is not tied to a diocese. Having a disciplinary tribunal process which is wholly separate to the dioceses has provided a measure of independence and impartiality.The 2001 Nolan report brought about significant changes to child protection structures at parish, diocesan and national levels of the Catholic Church. The Catholic Office for the Protection of Children and Vulnerable Adults (COPCA) was established as the national unit for child protection and set up formal commissions and recruited child protection coordinators and parish representatives. Safeguarding training is now a component part of training for the clergy or religious life.   The Cumberlege review in 2007 brought about further changes to the Church’s child protection structures. The National Catholic Safeguarding Commission (NCSC) was created in 2008 with responsibility for setting the strategic direction of safeguarding policy and for monitoring compliance with the national policies and procedures. The Catholic Safeguarding Advisory Service (CSAS) replaced COPCA.   The Elliott review in 2018 has a broad remit including reviewing the safeguarding infrastructure, organisations, arrangements, policies and procedures, alignment of diocese and religious congregations, accountability and training and was due to be published in October 2020. The IICSA report has not considered its final report.  
Recruitment and Training of ClergyThere are examples of clergy being ordained despite a history of child sexual offences and examples of clergy who were unable or unwilling to properly fulfil their safeguarding responsibilities. Attitudes to safeguarding ought to be an important element of the selection and training of clergy The Catholic Bishops’ Conference of England and Wales should ensure that safeguarding training is mandatory for all staff and volunteers in roles where they work with children or victims and survivors of abuse. It should also be a requirement that regular refresher training is completed
Auditing There is no existing programme of external auditing which provides independent scrutiny of its safeguarding policies and procedures. Audits should be conducted regularly and reports should be publishedAuditing of the diocesan safeguarding commissions was introduced in 2006. Since then CSAS has conducted three further rounds of audits and the audits themselves have evolved from a ‘tick-box exercise’ to a more comprehensive review of safeguarding practice. An audit in 2019 found “good evidence of cooperation” between the diocesan and independent religious safeguarding commissions and the statutory agencies.   Inadequate and insufficient recording was particularly apparent in the review of files from the religious institutes.  
Record Keeping Poor and insufficient record-keeping continues to be a serious problem. There should be clear policies in place on record-keeping and training should be provided to safeguarding staff on the information that must be recorded in files. Additionally, safeguarding staff need to have access to the relevant personnel files.   
Offender Safeguarding management The Church in Wales is producing written procedural guidelines concerning the establishment, monitoring, and review of offender management safeguarding agreements. This is a much needed area for improvement. 
Information SharingInformation-sharing about matters relevant to safeguarding between the Church of England and the Church in Wales is piecemeal and lacking any formality. Furthermore, the Church in Wales and the statutory authorities have no formal information-sharing protocol with the police forces and social services departments in Wales. Finally, The Church of England and the Church in Wales should agree to implement a formal information-sharing protocol which includes  information about clergy who move between the two Churches 

While there have undoubtedly been improvements in all the Church’s response to child sexual abuse, Church leaders need to do more to encourage and embed a culture of safeguarding.


Abhinav Parameshwar
Trainee Solicitor, BLM
abhinav.parameshwar@blmlaw.com

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