5. Every complaint or suspicion of abuse from within or outside the School will be taken seriously and followed up and in all proper circumstances, as set out in this policy, will be referred to an external agency such as the social services department of the local authority (SSD), the child protection unit of the police (CPU) or the NSPCC. In each case, the matter should be referred to Ealing Child Protection Advisors (020 8825 6134).It sounds all very good, doesn't it! Acronyms are scattered around, lots of long words are included, and everything is to be "taken seriously". What more could you ask for?
Piffle. It's all show and no substance.
To say that a complaint will "be taken seriously" commits the school to no specific action.
To say that a complaint will be "followed up" commits the school to no specific action.
To say that a complaint will "in all proper circumstances" be referred to an external agency leaves it to the school to decide what "proper circumstances" consist of. Admittedly it says "as set out in this policy", but it will not surprise you to know that the rest of the policy is sufficiently vague that this doesn't really add anything.
So, in essence, there is no commitment on the part of the school to refer incidents, allegations or suspicions of abuse to any outside agency. The wording is sufficiently shot through with qualifications that the school can do almost anything it likes and it would still be consistent with this paragraph of the policy. The school is in essence retaining absolute discretion as to whether any complaint is referred to an outside agency. In essence, there is no policy on this.
And it is inappropriately vague about which agencies will be referred to. The policy states "an external agency such as" and then gives a list, giving no indication as to which kind of agency should be contacted in any specific circumstance.
We have a duplication here: "Ealing Child Protection Advisors" is part of Ealing Social Services Department (SSD).
It is entirely inappropriate for NSPCC to be on this list. There is no circumstance under which the NSPCC should be contacted, they have no statutory role in investigating complaints of child abuse within schools. They have no doubt been included to make the document look impressive to those who don't know what it is supposed to contain.
This is what the policy ought to specify: In every case of an allegation, suspicion or incident of adult-on-child abuse the matter shall be reported by the Designated Teacher to the Local Authority Designated Officer for Child Protection (LADO), (part of the local authority SSD). In every case of an allegation, suspicion or incident of child-on-child abuse the matter shall be reported by the Designated Teacher to the Children's Services of the local authority SSD.
There's a whole lot more that ought to be done in terms of record-keeping and so on which isn't described here, but the essential point is this issue of always reporting to the defined external agency. Not "in proper circumstances". Always. There are no improper circumstances for referring cases, and if the Designated teacher is in any doubt about whether there is a case to refer, he or she should phone up the LADO or Children's Services and consult with them.
What then happens in an adult-on-child case is that the LADO reviews the information, consults as appropriate, and the outcome of the review is one of three possible courses of action for the case.
- It may be the subject of a police and/or joint police and Social Care investigation and possible action through the courts; or
- It may be the subject of a disciplinary investigation; or
- The matter may be remitted to the school to be dealt with.
The key point about this process is that it is not the school's decision as to what route is taken. The school has a conflict of interest, in that it has its reputation to maintain. That conflict of interest must be removed by taking away from the school any discretion as to whether an allegation is passed on.
Unless there is this commitment to always reporting cases, including and especially in cases of complaints of abuse by members of staff, then the policy is entirely worthless.