Ampleforth's governance

A significant part of the March 23-25 Ofsted report looked at governance of the school. The report said:

The St Laurence Education Trust and the Ampleforth Abbey Trust remain linked closely.

The corporate and sole trustee of the Ampleforth Abbey Trust, the Ampleforth Abbey Trustees (a company limited by guarantee) is one of eleven members of the St Laurence Education Trust. The Ampleforth Abbey Trust met the financial losses of the St Laurence Education Trust in the 2017–18 and 2018–19 financial years. The Ampleforth Abbey Trust owns the land the school’s buildings sit on.

The links between the abbey and the school are evident in the everyday life of the school. Some facilities, such as information technology, including telephony, continue to be shared between the abbey and the school. Up until mid-January, emails from the headteacher to all academic staff were also sent to some members of the monastic community. A dean, who resides in the monastery, is on the senior leadership team of the school. The dean ensures that the school’s Benedictine ethos remains central to the school’s leadership team.

This is much more serious than it looks at first sight. After all, who cares who runs the school so long as it is run well? But this needs to be taken in the context of the report on Ampleforth and its sister school Downside by the Independent Inquiry into Child Sexual Abuse (IICSA), which contained the following conclusion.

A strict separation between the governance of these two abbeys and schools will be required if safeguarding arrangements are to be free from the often‑conflicting priorities of the abbeys. This took too long to achieve at Ampleforth.

In his closing remarks to the hearing, Ampleforth's legal representative claimed that this separation had already been achieved.

The evidence heard by the inquiry and in the documents submitted since show that, since 1997, the college and the junior school at Ampleforth had been run by a separate educational trust, the St Laurence Education Trust. Since 2010, that trust has a majority of lay trustees, has always been chaired by a deputy chair, who is a layperson, and, whenever safeguarding issues were discussed, that deputy lay chair took the chair of the trust. Since this year, 2017, the St Laurence Education Trust not only has a majority of lay trustees, but it also has a lay chair, Claire Smith.

It is the St Laurence Education Trust, not the abbey, which runs the school. That is intended to be a permanent arrangement. Ampleforth took the decision in 1997 to separate the school effectively from the Abbey Trust and has been working ever since to solidify that aim. That has continued to be the position, and will continue to be the position as it is now embedded in its constitution. The combined effects of the changes to the composition of the trust has been its composition has altered from that of an entirely monastic trusteeship to one which is now one-third monastic and two-thirds lay, creating an open structure which is accountable to external lay people.

So complete separation was regarded as essential by IICSA. It was claimed by Ampleforth’s legal representative that it had already been achieved in 2017, and this seems to have been accepted at face value by IICSA. Its report said "this took too long to achieve at Ampleforth" suggesting that IICSA believed that the separation was complete at the time of writing the report. And yet here is Ofsted saying that this separation is a mirage – it doesn’t exist in practice.

As recently as 29th December 2020, the head teacher Robin Dyer was robustly extolling the virtues of the current senior leadership team (SLT) and governors (including several newly-appointed) in an interview with Times Radio.

“I run the school. My SLT and the new Board of Trustees. We run the school. We're not beholden to the monastery as was in the past.”

In a document linked to an email sent by the school to parents and former pupils on 7th December 2020, the school stated.

“Driven by our failures in the past, over the past 18 months we have put in place a robust safeguarding regime in consultation with the Charity Commission; a new governance structure, including new Trustees, that has effectively separated the Abbey from the College; and a new and experienced senior leadership team. During this time, the Independent Schools Inspectorate has endorsed our actions through two successful inspections and the Charity Commission has discharged their Interim Safeguarding Manager. Ofsted’s report and the DfE’s action does not reflect the school we are today.”

So that’s on at least two separate occasions that the school has claimed that a separation has been implemented. The separation was claimed to be complete in 2017 when Ampleforth's legal representative spoke at IICSA, and an entirely separate separation was claimed by the headmaster to have occurred in the 18 months up to December 2020. And yet Ofsted has found the organisations "remain linked closely".

The linkages actually go deeper than even Ofsted mentioned in its report. In a letter to the Secretary of State Gavin Williamson, Richard Scorer, a solicitor who represented many Ampleforth abuse survivors at the IICSA hearings, described the extent of the dependency of the school on the abbey and the the effect of this on the school's ability to achieve good safeguarding practice.

Ofsted also had words to say about the composition of the governing body of the school.

All but two trustees are connected to the school as past pupils, spouses of past pupils or parents of pupils. The chair of trustees identified the need for the inclusion of more trustees from an educational background who have no previous or current connections with the school. He identified rightly the benefits a more diverse board of trustees would bring to the school.

This realisation is very new to the school, since it appointed two new trustees in June 2019 and another six in September 2019, and even with these new appointees only two trustees had no previous or current connection with the school. As noted above headmaster Robin Dyer was extolling the current board of trustees as recently as December 2020.

This is another area where what the school says and what is happening are somewhat at odds. Here is part of the Chair of Trustees' message to parents on 16 April 2021.

Over the past 18 months, we have wanted to increase the diversity of our Trustees, something which has been hard to do under the current circumstances. To reinforce the independence of the College’s governance, we will ensure that half of our Board is made up of trustees without links to Ampleforth College or to the Abbey by this autumn.

The "current circumstances" presumably means the Enforcement Notice. But that was only in place for the last five months, not eighteen. If it has really been serious about increasing diversity among the trustees for eighteen months, then it must have been attempting this without any tangible result almost ever since the last six (mostly non-diverse) trustees were appointed. But to the best of my knowledge there has been nothing in previous messages to parents about looking for new trustees from a more diverse background. On the contrary they said in December that over the last 18 months they had put in place "a new governance structure, including new Trustees" making no mention of the fact that they thought it still in need of radical change.

I suspect that neither the school, nor Ofsted or even DfE had considered this until Richard Scorer wrote to DfE on 25 February pointing out his concern about the lack of diversity in the trustees.

Of the eleven current trustees of St Laurence Education Trust shown on the Ampleforth College website, nine are former pupils or parents of former pupils. ... As you may be aware, a lack of diversity of background within trustee boards and governing bodies has been identified by the Independent Inquiry into Child Sexual Abuse as a risk factor for safeguarding failings in schools.

Of course, I'll stand corrected if the trustees decide to publish minutes of trustee meetings over the past 18 months in which progress in the search for diverse trustees is reported.

Ofsted hasn't said in its report what changes in governance would be needed in order to pass its next inspection. Whatever they are, given the number of times Ampleforth has claimed that a separation has been achieved when it wasn't, it is to be hoped that Ofsted examines the small print of any changes very carefully.

Ampleforth's Ofsted reports

Ampleforth made two applications to DfE to have the ban on new pupils lifted. In each case DfE commissioned Ofsted to conduct an inspection.

The first inspection took place on 6-8 February, and was a miserable failure for the school. As compared to the emergency Ofsted inspection of 24-25 September 2020, which resulted in the ban on pupils being imposed, there was very little improvement. The Independent Schools Standards the school was inspected against and is supposed to meet come under a number of headings.

Part 3. Welfare, health and safety of pupils

• The school passed paragraph 7(b) when it had failed in September
• The school continued to fail paragraphs 7, 7(a), 8, 8(a) and 8(b)
• The school failed paragraphs 16, 16(a) and 16(b) which it had passed previously

Part 5. Premises of and accommodation at schools

• The school passed paragraphs 28(1) and 28(1)(d) when it had failed in September

 Part 8. Quality of leadership in and management of schools

• The school continued to fail paragraphs 34(1), 34(1)(a), 34(1)(b), 34(1)(c) and 34(2)

In addition the school was assessed against various of the National Minimum Standards for residential provision in schools.

• Standard 11.1 remained unmet 
• Standards 13.3 and 13.4 remained unmet.

So the February inspection was not a marginal technical failure for Ampleforth, easily fixed by a tweak to a couple of processes and giving them a bit of time to "bed in". It was comprehensive, showing major weaknesses in most of what the school does about safeguarding. If the school was going to pass the next inspection, major changes would be needed.

This is not how the head teacher described it at the time. In a letter to parents on 9th March 2020 he said:

We have heard from the Secretary of State tonight that he recognises and welcomes the progress we have made but still requires further evidence before he will lift the restriction. However, he explicitly encourages us to hold a further inspection with the College now fully reopened after lockdown. We understand that he felt he could not revoke based on an inspection which took place when only very few children were on site.

Although disappointing, this remains in line with the messages we have been getting over the last few days, that one final push is required and that we are still on track for revocation before the end of term. We are formally writing to the Department for Education tomorrow to request that Ofsted return for a further visit. We have every confidence that this will deliver the outcome that we believe fairly represents Ampleforth College.

The school made that further application for the ban to be lifted and so DfE commissioned another inspection. Ofsted visited on 23-25th March. As you can see from the report, it was a disaster. There was not one single paragraph of either the Independent School Standards or the National Minimum Standards for boarding which had been failed in February which were now passed. On the contrary, Ofsted failed them again on paragraph 7(b) of the Independent School Standards which they had failed in September 2020 but passed in February 2021.

Here are some of the inspectors' comments in the report.

Leaders, including trustees, still do not know the full extent of poor recording and misreporting of safeguarding incidents over time. Five hundred and ninety-nine entries on the school’s online data storage tool, relating to 213 pupils who have already left the school, have not been checked yet.

It is worth noting that the fact that many reportable safeguarding incidents came to light in January when an external consultancy was engaged to help. The latest Ofsted inspection was on 23-25 March so they have had about 2 months to look through this.

When the February Ofsted report was published which first raised these incidents, the school tried to pass this off in public as data lying unsuspected in databases. That of course won't wash at all because the data must have been typed into the database by members of staff, and a decision made at the time not to report these incidents to the authorities. 

Despite attending safeguarding training, the designated safeguarding lead and the deputy designated safeguarding leads, on occasion, do not recognise potential risks to pupils that require following up. Deputy designated leads triage cases when they occur. Some do not have the knowledge required to triage competently or confidently. Even after triaging cases, potentially serious risks are not identified and followed up consistently well. During the inspection, the deputy safeguarding leads found it difficult to navigate the school’s online data tool for recording and managing safeguarding concerns.

This in as many words is saying that the Designated Safeguarding Lead and deputies don’t know how to do their jobs and can’t even operate the data system designed to record concerns. This is frighteningly bad. (The school has since advertised for a new Designated Safeguarding Lead.)

When pupils leave the school and transfer to another school in England, staff ensure they take up the place at their new school. Staff do not routinely check that pupils are admitted to overseas schools in a similar manner. As a result, these pupils are not safeguarded to the same extent as pupils transferring to schools in England.

Its arguable that children transferring abroad are potentially more at risk than those transferring, within the UK, given possible concerns about FGM or forced marriage. That’s why the rules apply irrespective of what country the pupil is transferring to.

Although some improvements have been made since the previous inspection in February 2021, weaknesses in the school’s safeguarding practice remain. A culture of safeguarding is still not embedded. These standards remain unmet.

It’s worth remembering that the February inspection (the one before this one) was commissioned by DfE at the school’s request so that the ban on new pupils could be lifted. The emergency inspection which resulted in the ban on new pupils took place in September 2020. They’ve now had six months to improve things. They aren’t even close.

Leaders have implemented a new safeguarding policy since the last inspection. The new policy refers to allegations against staff. The policy does not make explicit reference to the list of situations, as identified in paragraph 211 of ‘Keeping children safe in education’, when the allegations process should be followed.

The designated safeguarding lead made changes to the school’s new and published safeguarding policy during the inspection. However, some advice is incorrect, contradictory and unhelpful. For example, paragraph 10.2 states: ‘Anyone can make a referral. Any such referral must be made immediately and in any event within 24 hours of you becoming aware of the risk.’ Waiting 24 hours is not acceptable before making a referral to an appropriate body.

Similarly, in the ‘reporting a concern about a student’ flow chart on page 14, the policy states that the designated safeguarding lead and deputy safeguarding leads will ‘review the concern and make a decision no later than 24 hours about the next steps’. Concerns must be dealt with immediately.

The use of the words ‘should’ and ‘must’ is not consistent throughout the school’s new safeguarding policy. On occasion, the policy states how staff should respond to a safeguarding issue and, at other points, how staff must respond to the same issue.

Leaders did not know that they should inform the local authority when a pupil is removed from the school’s roll in-year, in accordance with paragraph 4.25 of the DfE’s ‘The Independent School Standards –Guidance for independent schools (2019)’.

This standard was met at the time of the last inspection but is now not met.

Getting your written policy right is actually the easiest part of doing safeguarding. It can be hard to get people to get people to follow good practice, but it is just about impossible if you don’t have a clear and correct policy to work from. Nobody knows where they stand.

There is an electronic system to record pupils’ attendance in lessons. Vulnerable pupils’ non-attendance is addressed within 15 minutes. Other pupils’ non-attendance is not addressed until they have missed an entire lesson and failed to turn up for the next lesson. This means that sometimes staff do not know where some pupils are or that they are safe.

It does seem rather a basic matter that in order to ensure pupils in your care are protected you have to know where they are.

There was a near-miss road traffic accident on site in early March 2021. The driver was a visitor to the school who was not accompanied by a member of the school’s staff. Just last week, a further serious safeguarding incident, relating to an unaccompanied visitor to the site, occurred. This second incident demonstrates that the school’s risk assessment policy and procedures are not applied consistently. Leaders’ actions to mitigate risks to pupils are not effective. A secure culture of safeguarding is not embedded in all aspects of the school’s work.

This speaks for itself.

Parents remain supportive of the school’s leadership. The statement ‘I can’t imagine that there is a safer school in the country at the moment’ is a typical response to Ofsted’s most recent survey of parents’ and carers’ views.

Ampleforth in its public statements repeatedly relies on parental endorsement. But the fact is that this is a boarding school – most of the parents aren’t around to see what is going on. If 20% of them have even read the school’s safeguarding policy it would be surprising.  But even if some have read it, for it to be understood it is essential to have a thorough understanding of safeguarding framework described by a former CEO of a large children’s charity as ‘a thicket.’

An external agency continues to support leaders to fulfil their statutory safeguarding duties. The agency has completed a review of the school’s counselling records. The counselling chronologies on the school’s online data storage tool are incomplete. The chief executive officer of the agency told inspectors that the school’s expertise in keeping pupils safe is improving.

Many of the actions in the external agency’s rapid improvement plan have been addressed. The trustee with oversight of safeguarding, who is carrying out some operational tasks in addition to strategic responsibilities currently, understands the need to develop a strategic plan to improve safeguarding further. The trustee told the inspectors that the next step for leaders is to develop such a strategic plan.

Ampleforth has in recent years been subject to devastating criticism from the Independent Inquiry into Child Sex Abuse (IICSA), has failed a number of Independent Schools Inspectorate inspections, been issued with a Warning Notice by DfE, failed an emergency Ofsted inspection and two follow-up inspections commissioned at the school’s request. And only now are they thinking that a strategic plan to improve safeguarding might be a good idea? That ship should have sailed years ago.

In January 2021, in its first review of the school’s safeguarding records, the external agency identified a number of recent cases of very serious child-on-child abuse. Subsequent to this, and to make sure all necessary actions have been taken, the designated safeguarding lead and deputy designated safeguarding leads have reviewed the online safeguarding records for every pupil who attends the school currently. Leaders plan to review the remaining online records of 213 former pupils by 3 July 2021.Trustees are not confident that they have a full knowledge of all child-on-child abuse that has taken place since the current online data storage tool for recording and managing safeguarding concerns was set up.

This is really quite deadly. IICSA’s primary criticism of Ampleforth was that it didn’t report safeguarding incidents to the authorities when it should have, and the school and abbey have been energetically claiming ever since that everything is different now, that the mistakes are all in the past. And yet, when an external body took a detailed look at the books, it turned out that a number of serious incidents still hadn’t been reported, and that the school even now isn’t sure whether all recent incidents that should have been reported actually have been, even though it appears to have a new "online data storage tool" that has been set up for that specific purpose. This is not "all in the past", these problems are very much in the present.

While the reporting of incidents is part of the Independent School Standards, there’s no legal obligation on any member of staff to make a report of abuse. So if the school chooses not to report there is little in practice that Ofsted and DfE can do to insist. All DfE can do in the end is to close the school if it sees persistent failures. Is has no other sanction. In all the cover-ups of abuse that have happened at Ampleforth in the past and which were investigated by IICSA, no individual has ever been prosecuted for failing to report abuse, because it isn’t a crime.

Leaders uploaded a new safeguarding policy to the school’s website this month. The new policy, like its predecessor, contains contradictions. This new policy did not go out for consultation to, and scrutiny by, the whole staff. The online version of the policy was amended by the school during this inspection, but the version number remains the same, version 1.0.

Some staff are dissatisfied with the way that changes are managed. Comments in Ofsted’s survey of staff include: ‘there is not time in our busy days to read and embed the amount of new policies coming in’; ‘too many policies in a short time frame and no time to actually read and embed them’; ‘changes are made without consultation and often decisions are reactive rather than proactive’; and ‘the chaotic organisation is incredibly difficult to adhere to as a teacher/tutor who has to put these overwhelmingly complex protocols and procedures into practice’.

There is a distinct sense in this comment from Ofsted of Corporal Jones of Dad’s Army running around in a complete funk shouting “Don’t panic! Don’t panic!”. The impression is that the senior management genuinely have little or no idea what they should be doing. It looks as if they don’t yet even realise how much of what they are doing is wrong, let alone how to put it right.

There is not a single area in which the school failed in February where Ofsted was able to say that “the standards are now met”. On the contrary, there was one area where the school had previously met the requirements where Ofsted said they were “now not met”. The most charitable thing the inspectors were able to say was that:

Although some improvements have been made since the previous inspection in February 2021, weaknesses in the school’s safeguarding practice remain. A culture of safeguarding is still not embedded.”

So the school failed the Ofsted inspection in March about as badly as it failed in February. The tone of the two reports is remarkably similar. There is little or no tangible progress towards meeting the standards that all other independent schools must meet.

Ampleforth's ban lifted

The DfE lifted Ampleforth College’s ban on new pupils on 19th April. The decision had been pre-announced to the school, which wrote to parents on 16 April saying.

I am pleased to let you know that the Secretary of State for Education has decided to remove the restriction order. This follows Ofsted finding many improvements to our safeguarding procedures during their recent visit and the DfE’s request for, and acceptance of, an action plan demonstrating our long-term commitment to safeguarding excellence.

Curiously the first public mention of the ban being lifted came on 16 April, not from a statement by the DfE, but from the blog of the local MP Kevin Hollinrake.

I am delighted that the imposition of a restriction order by the Department for Education prohibiting the recruitment of new pupils has been lifted at Ampleforth College. This is good news for the school and for the local economy.

It was always my concern that the school should be given a fair hearing and a clear pathway to resolve outstanding issues. The school will be closely monitored and given a set of targets to meet to ensure that outstanding areas of concern are dealt with speedily and I wish the Head Teacher, the staff, pupils and parents well in the months ahead.

The Daily Telegraph was also tipped off about the decision, and published an exclusive on 16 April saying:

Ampleforth College has been saved from closure following an intervention from the Education Secretary, the Daily Telegraph has learned.

The leading Benedictine school has had its ban on admitting new pupils overturned after officials at the Department of Education (DfE) said they were satisfied with its safeguarding arrangements.

At this point, the Ofsted report on which the DfE decision was based had not been published, so the Telegraph wasn't actually in a position to say that DfE was "satisfied". in any case, this rather contradicted Kevin Hollinrake's statement that "the school will be closely monitored and given a set of targets to meet", which suggests that DfE is far from satisfied.

The Ofsted report was published on 19 April, the same day that the restriction order was lifted. DfE of course had an advance copy of the Ofsted report (they commissioned the inspection after all), so knew precisely what was in in it. Now it is published one can reasonably wonder what on earth Williamson was thinking. The school has failed (again) to meet the required standards for safeguarding and leadership.

On 19 April the news started to filter out and various papers covered it. They noticed that the ban had been lifted despite the school failing, but mostly seem not to have realised how badly the school was still failing.

The Ofsted report will be analysed in the next article.

The ban at Ampleforth

Ampleforth College, St. Benedict's sister school in Yorkshire, has been served with an Enforcement Notice by the Department for Education, banning it from accepting any new pupils. The decision clearly has been made in person by the Secretary of State for Education, Gavin Williamson MP.

According to the letter published on the gov.uk website there was an Ofsted inspection on 24-25 September and as a result:

the Secretary of State for Education (“the SoS”) is satisfied that one or more of the independent school standards (“the ISS”) are not being met in relation to the School.

This isn't just one bad report. This has being going on for nearly five years. The letter goes on to say:

In taking this decision, the SoS has principally had regard to Ofsted and ISI inspection reports from January 2016 to the present day, and the School’s response to regulatory action.

And he makes it clear that the school has been warned.

Further, following an inspection carried out by the Independent Schools Inspectorate (“the ISI”) on 7-8 March 2018, which also found that the ISS were not being met, a statutory notice was issued to the School pursuant to section 114 of the Act, requiring an action plan. An action plan was submitted in response to that notice on 11 June 2018 but was deemed to be unacceptable and was rejected by the SoS on 10 July 2018. The School was advised of this decision by a letter dated 10 July 2018.

Williamson acknowledges that the school has complained, and it cuts no ice with him.

It is acknowledged that the School has filed a complaint against Ofsted’s recent findings, and the SoS has carefully considered that complaint, as well as correspondence which sets out the School’s views on the contents of the report. However, having taken this into account, the SoS is satisfied that the standards are not being met.

He describes the specific clauses of the Independent School Standards that are not being met. There are a number of clauses, but the school's failure to meet the first is the most important.

7. The standard in this paragraph is met if the proprietor ensures that—

(a) arrangements are made to safeguard and promote the welfare of pupils at the school; and

(b) such arrangements have regard to any guidance issued by the Secretary of State.

There's a similar clause specific to boarding provision and also a clause about leadership which are also listed as having been failed. But basically this is about inadequate safeguarding.

It's not just ISI and Ofsted inspection reports that have been critical of safeguarding at the school. Ampleforth (along with Downside School) was the subject of an excoriating report by IICSA (the Independent Inquiry into Child Sex Abuse).

The ban on new pupils comes into effect in 28 days unless the school decides to appeal the notice, and it has announced it will do so. This was included in an article in The Guardian about the notice.

A spokesperson for the college said it had noted the department’s intent to serve notice of an enforcement action.

“We will be appealing this on the basis that we believe, and have been advised, that it is unjustified and based on incorrect information,” the spokesperson said.

Governments (especially Conservative ones) don't like to close private schools - it means that they would have to educate the pupils at public expense instead. For the just under 500 pupils at Ampleforth, that means an extra £3m or so per year on the education budget. So Gavin Williamson will have needed some persuading that he had to act.

Enforcement Notices like this are pretty rare - there have only been eight in the last three years, mostly against small newly-established little local religious schools, usually with only 50 pupils or so. For an old public school like Ampleforth to get an enforcement notice is completely unprecedented.

A few people on Twitter have suggested that this is all an anti-Catholic or at least anti-religious move. This is a classic example.

I would like to express my deep anger at the Dept of Education doing its best to destroy a wonderful spiritual school. Ampleforth. It has completely revamped after the previous awful crimes. But nasty woke bastards want it closed. It will survive and thrive.

— Seb Leslie (@CllrSebLeslie) November 27, 2020

But this accusation is ridiculous with respect to this government. First the cabinet is stuffed to the roof with privately educated ministers, including several Old Etonians. William Rees-Mogg (Leader of the House of Commons) was married by the Abbot of Downside, and the public inquiry heard evidence to the effect that Michael Gove intervened when Secretary of State for Education in a local safeguarding investigation into Downside School. This government cannot remotely be described as "woke" and is clearly not disposed against private education and specifically not against Catholic private education.

So we have to conclude that the Ofsted evidence is compelling enough to persuade a Conservative Secretary of State for Education, well-disposed towards private education and with prominent Catholics among his cabinet colleagues, to act against Ampleforth.

But we haven't seen the Ofsted report, so we can't tell. The school has seen it and has said it is complaining, and has objected to publication. This isn't the first time in my experience that a school has complained against an adverse inspection report. In 2011 St. Augustine's Priory School in Ealing in west London complained about an adverse inspection report from the Independent Schools Inspectorate, and even sought Judicial Review of the report.

The history of this is interesting. The JR was put on hold while the school went through the Stage 1 complaints process with ISI. This did the school no good at all, the final report was even more damning than the original, because its conclusions were more clearly stated and more carefully evidenced. The report was published and the JR case abandoned. The head teacher resigned (actually being escorted off the premises) and several of the governors were replaced.

As it happens, irrespective of the Stage 1 complaint, the JR would have stood almost no chance of success. To overturn a government administrative decision (which is what an inspection report is in effect) you need to demonstrate not only that a different decision could reasonably have been reached but also that nobody with two brain cells to rub together would ever have honestly come to the original decision. (Lawyers would put it differently, but that's the essence of it.) Very few cases reach that extremely high bar.

This is highly relevant to Ampleforth. They are in a much more precarious position than St. Augustine's Priory School were. They have already received an enforcement notice banning them from taking more pupils. As independent schools aren't financially viable unless they are full, this will lead to the closure of the school sooner rather than later.

So the school has a choice to make. Do they fight or do they co-operate? If they genuinely believe the Ofsted report is a load of hogwash and think they can prove it, then they may well decide to fight, and the initial indication is that they will do so. They told the papers they would appeal and have asked parents and alumni to help with lots of supportive public testimonials on social media.

But very interestingly the statement on the school's own website is subtly different from what they said to the papers when the story first broke.

Ampleforth College notes the Department for Education’s publication on Friday 26 November of the intent to serve notice of an Enforcement Action.

We strongly believe, and have been advised, that this is completely unjustified and based on incorrect information. We will be pursuing a number of different options to resolve the situation before the restriction is enforced, including an appeal, and we are very confident this can be achieved.

Note the difference. Here they say that they are "pursuing a number of different options ...  including an appeal". That is wording that signals that they might not fight, that an appeal may well not happen.

They have a huge problem with an appeal if (privately) they conclude that the Ofsted report is sufficiently solid that they are not going to overturn it. To get into a legal fight you need a good case. St. Augustine's is a cautionary tale of how you can (metaphorically speaking) get your head handed back to you on a plate if you try to fight a legal battle without evidence. You can assert things without evidence in social media but you can't get your lawyers to do that in court. As President Trump has discovered, if you ask them to, they drop you as a client. So all the social media in the world won't help them if they have no evidence.

So if the Ofsted report is solid, and given the school's long history of failure to meet standards for child protection that almost every school in the country manages routinely to achieve, it is going to be extremely hard to persuade the Tribunal to which they have to appeal that the Secretary of State's decision is so precipitate and disproportionate that it should be overturned. Either that or they prove that DfE lacks the legal power to issue the notice. Basically, their chances are miniscule. It's just not going to happen. Gavin Williamson will have been advised by the government legal service (full of very good lawyers) before he made his decision.

If the school and its lawyers reach that conclusion, then an appeal is ruled out - it would fail and that failure would only serve to further antagonize the DfE, whose mercy they will have to beg for. So at the end of this month the ban on new pupils would come into effect.

The school will then have to try and persuade Gavin Williamson at some point in the future that it really has changed and that it is safe for him to lift the ban. That means they will have to work extremely fast. A new action plan (better than past ones) will have to be drawn up. It will have to be far more robust than previous rejected plans. The school will need to demonstrate in this plan that sticking to it will effectively make a relapse into old habits impossible. That might require a more thorough separation, both physically and organisationally from the habits occupying the adjacent monastery. That is what St. Benedict's School did with respect to Ealing Abbey following Lord Carlile's report.

They can then submit their plan to DfE, get on with implementing it and invite DfE to commission Ofsted to inspect again before the end of the academic year. A good report can lead to a request to DfE to lift the ban on new pupils in time for September. If an appeal is ruled out, this is the only way I can see for the school to survive.

But this would involve a public admission that their safeguarding really hasn't been up to scratch all these years, even though they have been loudly telling parents otherwise. This risks a calamitous loss of confidence by parents in the school. Parents will find it very hard to understand if the school chooses not to appeal the notice given the extent to which they have been whipped up to participate in a PR campaign in the school's defense. Nobody likes to be taken for a sucker.

Not all parents will withdraw their children, but some will. More parents may hesitate to take up a place at the school. It's one thing to discount the risk of your child being sexually abused when the school gives you a strong assurance that the mistakes of the past are over and the risk is now minimal. It's quite another to discount that risk when the school admits to lying over its earlier assurances. In fact, the more solid the case against the school, the greater the risk of admitting it and trying to placate the DfE. The school may find itself financially unviable because not enough parents are prepared to send their children there. They may need to re-hire their old PR consultants Chelgate run by former pupil Terence Fane-Saunders to try and head off this eventuality.

I don't know what the school will do. They can fight the DfE or they can appease it. I don't see how they can do both at the same time, as any failed attempt at fighting will make appeasement much less likely to succeed. I also don't know what's in the Ofsted report that has caused DfE to take this action and how solid it is.

If the school is genuinely prepared to do a good job of protecting its pupils and be seen to do so to the satisfaction of a skeptical DfE, then fine. I have no wish to see a good safe school close. But if they haven't and either can't or won't put in that effort, then the school must and will close. Time will tell.

Departure from Downside

The monks of Downside have announced their intention to leave Downside Abbey and find a new home. In some ways it is not a great surprise. There are only 12 monks left, the governance of Downside School was made independent last year and they are presumably rattling around in premises designed for several times as many people.

But we need also to consider the backdrop of the abuses so thoroughly documented by IICSA. The inquiry found that over decades there had been a refusal to cooperate with the statutory authorities over child sex abuse perpetrated by monks. Given that old attitudes die hard, removing the monks from the vicinity of the school is probably best all round, both for the safety of the pupils and to move the monks out of the reach of temptation.

There has been a little comment on Twitter expressing regret at the monks’ departure. Few of these have faced squarely the background of abuse. Where it has been referred to it has been described as a “period of evil” which has brought down the Abbey. I’m profoundly sceptical about that interpretation. Admittedly we only know about abuse victims from the last few decades. Any older victims are now dead and unable to tell their story. But there’s no reason to think the abuse only happened within living memory.

Some conservative Catholics put the blame on Vatican II and the changes that followed. But I know of Benedictine abuse which preceded Vatican II.

One of the great characteristics of the Catholic Church and Catholic faith is its attachment to continuity and stability. It deals in what it regards as unchanging eternal truths. So why would we not believe that the church’s attitude (and that of the Downside monks) towards covering up abuse has been similarly stable over a long period? Without access to historical records that I’m pretty sure have long since been destroyed there is no means of ever of proving it. 

But if it is true that abuse and cover up has been going on since the abbey and school were established in Somerset in 1814, then the monks’ departure from next door to the school is a matter for celebration, not sorrow.

IICSA report - The Abbey statement

Oh dear. The new Abbot Dominic Taylor has made a statement on the Abbey website, and unfortunately it is clear that they are back to their old minimising tricks.

It doesn't start well.

The Abbot of Ealing on behalf of the Monastic Community of Ealing apologies [sic] profusely for the events that have given rise to very serious criticisms outlined in the Inquiry of wrongs by past members of the Community.

Past members of the community? Some of the Inquiry's most trenchant criticism was directed towards Abbot Martin Shipperlee, who to the best of my knowledge (as demonstrated by a page on the Ealing Abbey website devoted to him) is still a member of the Community. I think I would have heard if he had been expelled or laicised. Not that it is likely to happen, at least not because of any of his failings as Abbot.

Any abuse of children is wicked and deeply sinful. We accept the Inquiry's findings that actions were not taken that could have reduced serious risk and harm to the children in our care.

Fine so far as it goes, which is no distance at all.

The children affected are in our daily prayers and we recognise the shame brought upon us. We also accept this.

Prayers are all very well, but has it really not occurred to the Community that some rather more active response could conceivably have been considered?

Since 2012 whilst continuing to support the Benedictine ethos, St Benedict's School is now an entirely separate institution and the Monastic Community exercises no control in either the governance or management of the school.

It is hard to work out precisely what to make of this. First of all, it isn't true. Yes, the Abbey and School are now two separate charitable trusts, each of whom has its own governance structure and provides its own accounts to the Charity Commission. But page 27 of the school's most recent (August 2018) accounts lodged with the Charity Commission lists the governors of the school, among whom are Dom Ambrose McCambridge, Abbot Martin Shipperlee and Dom Dominic Taylor. I presume Abbot Martin Shipperlee has since resigned and been replaced by another monk. Admittedly the monks do not form a majority on the board of governors, but this is still hardly a situation where the Abbot can justifiably claim that the Monastic Community "exercises no control" over the governance of the school.

So this looks like another effort at minimisation - trying to distance the Monastic Community from the disgraceful events at the School. I can see why it is being done, but perhaps more effort might instead have been made to reform the Community do that such distancing isn't actually necessary?

Terrible lessons have been learned about the causes and recognition of abuse and the actions that should have followed whenever any suspicions arose.

We recognise that these events have had appalling consequences on the victims and we have used our very best endeavours to ensure that this can never be repeated.

I really wish I could be confident that this was true. Unfortanately I cannot. The reason is that the safeguarding page of the parish website says "Ealing Abbey follows the NATIONAL SAFEGUARDING POLICIES AND PROCEDURES OF THE CATHOLIC CHURCH OF ENGLAND & WALES".

Unfortunately the capitalisation of the title (which is copied directly from the Parish website) does not improve the content. I have reviewed the content. The church's national procedures contain shortcomings I complained about 10 years ago in respect of the school's safeguarding policies. If the Monastic Community were serious about employing its "very best endeavours" to improve safeguarding, they would have noticed this and tried to do something a bit better. I don't know whether they haven;t noticed, or whether they noticed and didn't bother. Neither reflects terribly well on them.

But what strikes me most about this statement is how entirely free of content it is beyond general expressions of regret. There is no action underway or even proposed that would give substance to their "very best endeavours". In that respect it is massively tone-deaf, and quite frankly an insult to generations of pupils who suffered from the attentions of abusers (including monks) at the school.

IICSA Report - Outside agencies

Those running Ealing Abbey and St. Benedict's School, and those committing abuses there (sometimes but not always the same people) were able to get away with the abuse and the cover up for so long because of mistakes, systemic problems and plain incompetence on the part of outside agencies.

First I'll raise a point not made in the report perhaps because the report is not making recommendations at this stage. The non-abusers in senior positions in the Roman Catholic Church are highly-educated, law-abiding people. Both hyphenated adjectives are important. They are law-abiding because they don't want to get into trouble with the law. After all, they see themselves as the good guys. They are highly-educated and therefore are able to judge with great precision how close to the edge of the law they dare encroach.

They did not promptly report suspicions of abuse because legally they didn't have to. (During the Downside & Ampleforth hearing, Abbot Richard Yeo clearly stated that unreported incidents would have been reported had there been a law requiring it, and that he would have obeyed such a law.) But we have no "mandatory reporting" in the UK, and as a result clerical loyalty and maintaining the reputation of the church took priority over the welfare of the children in the church's care.

Had a mandatory reporting law existed (as exists in about 80% of countries worldwide) requiring those with reasonable suspicions to report them, it would have been utterly impossible for Soper, Pearce and Maestri to have abused unhindered for so long. To give one characteristic example from the report:

Dr Dachs was the lay headmaster of St Benedict’s senior school between 1986 and 2002. During this time Pearce was head of the separate junior school. As such, Pearce was not under Dr Dachs authority, however like Abbot Rossiter and Soper, Dr Dachs was aware of the complaints about Pearce. For example, on 19 October 1998, the parents of RC-A631 complained by letter to him. Dr Dachs did not raise those concerns with any external authority.

Harsha Mortemore, senior accounts assistant at St Benedict’s, stated that when she raised her concerns with Dr Dachs he warned her “If you know what’s good for you, keep your head down and do your job.” Dr Dachs has denied this.

Had there been a mandatory reporting law in place at the time these events occurred, it is most unlikely that Dr. Dachs would have dared to say what the inquiry clearly believes he did say to Ms. Mortemore. With a mandatory reporting law in place, and if he were foolish enough still to say it, it is quite possible that Ms. Mortemore, knowing she had the law on her side, would have been emboldened to call Ealing Children's Services directly. In doing so she would have had two things to report: her original concerns about Pearce and what would have been Dr. Dachs' potentially criminal action in telling her to keep quiet.

This is how a mandatory reporting law would utterly change the landscape. It would empower those who wish to report but (like Ms. Mortemore) justifiably fear the consequences for themselves if they do. It would make suppressing reports a criminal act and therefore very dangerous.

But we don't, and as a result those fragmentary reports that did reach external authorities were often missed, though inadequate correlation, or plain incompetence. As a result the inquiry has harshly criticised the Metropolitan Police, The Crown Prosecution Service, the Charity Commission, the Independent Schools Inspectorate, the Department for Education and Ealing Council Children's Services. If criticism of these bodies is less than that of the church, it is because their failure was down to incompetence rather than malice. They were not actively engaged in a cover-up of abuse that they knew had happened.

Metropolitan Police Service
In 2001, the police did not adequately investigate complaints from four separate boys. Commander Jerome giving evidence said that this was unreasonable as there was evidence of sexual assault. There was a similar failure in 1992.

There is no evidence that the 1992 case file relating to RC-A595 was properly considered. There is nothing in the police records to indicate that the allegation of RC-A418 was referred to social services. This was particularly striking as Pearce was still working and living at the Abbey, adjacent to the school. Given the concerted effort of a teacher, Katherine Ravenscroft, and a monk, Father Alban Nunn, to bring concerns about Pearce to the Metropolitan Police’s attention, it is regrettable that this investigation into RC-A418’s complaint should then have been handled and dismissed in such a manner.

The report details several other failures to investigate Pearce appropriately, some of these dated back to the early 1990s. Pearce was eventually convicted in 2009.

Then there was Soper. He absconded in 2011 when supposedly on his way from Rome to the UK to attend a police bail appointment. It took five years to track him down.

After Soper absconded in March 2011, the Metropolitan Police waited over four years before passing the task of reaching him to a specialist team with dedicated resources. Two officers who were then involved, DS Chris Sloan and DS Shaun Richardson, told us that:

“In hindsight the ‘manhunt’ for SOPER should not have been left with the original investigating Child Abuse Investigating Team (CAIT) overseen by a single investigating Officer. This task should have been passed to those with specialisms in this area of work, who have a wide range of resources at their disposal. Once this was done, in and around December 2015 and primacy was passed to an MPS Major Investigation Team (MIT), SOPER was detained in Kosovo within six months (May 2016).”

Crown Prosecution Service
A case concerning Pearce was passed to the CPS in 1992. Although arguably even by today's standards "this would still be a challenging case to prosecute" there were in the CPS advice not to prosecute, as the report notes:

Mr McCabe’s reasoning as set out in his written advice raises other questions:

• He concluded that there was no corroborative evidence, whereas Gregor McGill, Director of Legal Services at the Crown Prosecution Service, agreed that there was some evidence that corroborated RC-A595’s account.
• Mr McCabe noted that there was no medical evidence of a physical injury from the alleged indecent assault. However, it is unlikely that any injury would have resulted from an assault of the nature alleged. As Mr McGill told us:

“A prosecutor today would not expect there to be medical evidence arising from an indecent assault of the nature alleged by the complainant and would be aware that the absence of such evidence is not evidence of no assault having occurred.”
• Mr McCabe stressed that there had been a delay in RC-A595 telling his sister, and some inconsistencies between the accounts he gave to his sister and mother. As Commander Jerome noted, neither delay nor inconsistency is unexpected in the context of a young boy having gone through a traumatic incident.

Of themselves none of these considerations should have been seen as a bar to prosecution.

Again, there were errors handling Soper's case.

Soper was not convicted until 2017, although in 2004 the Crown Prosecution Service decided not to prosecute him in respect of the allegations made by RC-A622 of abuse and multiple rapes.

Although these were grave allegations, Claudette Phillips, the Crown Prosecution Service reviewing lawyer, having advised orally, in writing justified her decision not to charge only very briefly, expressing the view that the allegation “is essentially the victim’s version of events against the suspects [sic]”. She also failed to consider whether other supporting evidence might be available or could be sought, and did not advise the Metropolitan Police on these points. The decision not to charge and the advice given were inadequate. Mr McGill accepts this, although he told us that “we approach these cases in a completely different way in 2019 than we did in 2004”.

The Charity Commission
The Charity Commission carried out two statutory inquiries into Ealing Abbey/St. Benedict's. The report states:

The first inquiry (from 2006 to 2009) was opened following concerns of child sexual abuse being brought to its attention anonymously in June 2006 in respect of Pearce and RC‑F41. Its purpose was to establish whether the trustees had taken appropriate action and what further steps were required, if any.

The inquiry was not impressed with the approach taken.

The Charity Commission’s conclusion that appropriate steps were being taken was based on little more than assurances given by Ealing Abbey that there were restrictions on Pearce, precluding access to children. The Commission did not seek to identify in any detail what those restrictions were, nor did it consider how they were being implemented or how compliance was being monitored. Michelle Russell, Head of Compliance at the Charity Commission between 2007 and 2011, told us that this reliance on the assurances of charity trustees “was the approach that was taken by the Commission generally as a regulator at that time”. The Charity Commission also found that the school’s child protection policies and procedures were adequate. This again appears to be in part based on the Trust’s assertion in correspondence that they were. Relying on assurances given by a body under investigation can never be a sufficient substitute for independent scrutiny.

One would have thought that last sentence was a classic statement of the bleeding obvious, but it didn't occur to the Charity Commission at the time.

On learning that Pearce had abused another child despite the assurances given, the Charity Commission opened another investigation which resulted in a critical report. The strength of the criticism was, according to Ms. Russell when giving evidence “quite unusual language for us to say publicly”. Despite this criticism, no further regulatory action was taken.

We then move to perhaps the most shocking aspect of the Charity Commission's actions at this time. The report states:

A further point is that, during this second inquiry, Charity Commission correspondence risked suggesting that protecting the charity’s name required contesting allegations of abuse as a matter of course. For example, a senior compliance and support manager stated in a letter of May 2008:

“A charity’s reputation is one of its biggest assets. As such, we would expect the trustees to take measures to protect the reputation of the Charity in the future. As a minimum, we would expect the trustees to monitor carefully the outcome of any criminal investigation or prosecution or civil claim into Father Pearce or any other person involved with the Charity in a similar capacity and to take appropriate steps to protect the Charity’s name and reputation as necessary. We would also expect the Charity to take reasonable steps to defend its name and reputation if any charges or proceedings were initiated against the Charity. If such a situation were to arise, I would suggest that you contact the Commission for advice.”

This letter, and the penultimate sentence in particular, could give the impression that defending reputation was more important than protecting children from abuse. While she said this was not the Commission’s intention, Ms Russell agreed that there was a risk that it might be read that way, and that it was something for the Commission to reflect on.

Given that Ealing Abbey was already inclined to cover up even well-founded allegations of abuse, this advice in my view could only have been taken by those in charge as an open invitation to redouble their efforts.

The Charity Commission appears not to have even considered taking regulatory action when it was clear that the efforts of Ealing Abbey were inadaquate:

Beyond providing “regulatory advice and guidance”, the Charity Commission relied in its report upon the fact that Ealing Abbey was undertaking “an independent review”. It requested a copy of this review, and said it would “actively monitor the Charity to ensure that this happens”.

The independent review referred to was that undertaken by Philip Wright and John Nixson in 2009. As discussed in Part D, that review was wholly inadequate. Its deficiencies were pointed out to the Charity Commission in 2010 by Mr Jonathan West, to whom the Commission responded in December 2010:

“The independent review that the trustees confirmed would be carried out is a matter for the Charity. The Commission cannot intervene in the administration of a charity.”
However no reference was made in this letter to the possibility, in certain circumstances, of the Commission appointing an interim manager.

Independent Schools Inspectorate
The Inquiry concluded that the ISI made a right pig's ear of its 2009 inspection.

The 2009 inspections were flawed in a number of ways.

The inspectors did not obtain a full picture of child protection concerns in respect of St Benedict’s, including the extent of the offences for which Pearce was convicted and the fact of the Charity Commission inquiry. Whilst the deficiencies in the level of disclosure given by the school and Abbot Shipperlee as chair of governors was a contributory factor, this does not provide a sufficient excuse. The ISI itself should have undertaken further steps to obtain and check relevant information both prior to and during their inspection, especially when the inspectors discovered that David Pearce had recently been convicted of sexually abusing a pupil. As explained by Kate Richards, Chief Inspector since 2017, the ISI now makes specific inquiries of both the local authority and the school itself about allegations and safeguarding incidents, as well as searching for relevant information in the public domain.

The ISI found, wrongly, that the school’s child protection policy was compliant, despite obvious defects, in particular with regard to external reporting. These were picked up in the 2010 inspection but should have been identified earlier. The failure is the more striking given the fact that the reporting inspector noted in his pre-inspection commentary:

“We shall need to be particularly alert and meticulous in checking all policies and procedures concerned with child protection.”

The 2009 ISI reports confused the independent review into Pearce’s offending (which was undertaken by Mr Nixson and Mr Wright) and what the inspector was told about advice provided by the Diocesan child protection officer and another safeguarding professional in respect of RC-F41’s restrictions. The senior school report stated:

“A serious incident involving a member of the monastic community caused the trustees to request an independent review of the measures taken to minimise risk.”

This plainly related to the review into Pearce’s re-offending, but it went on to state that the advice of that independent review had been implemented, which was an error. The advice of Mr Wright and Mr Nixson arising out of their review had not even been given at the time of the ISI inspection, still less implemented.

It took members of the public to inform them of the magnitude of their failure.

On 11 February 2010, shortly after the publication of its reports, Mr Jonathan West contacted the ISI expressing concerns. He did not think that the independent review had yet happened, as the Charity Commission had reported that it had been promised but not received in December 2009. The next day another member of the public, Michael Grant, contacted the ISI because he was “appalled by the report with regards to the issue of child protection”. He referred to the fact that David Pearce was the former head of the junior school and had lost a civil action as well as being “jailed for eight years after thirty-five years of systematic abuse”.

The ISI, on the DfE's instructions, kept a much closer and more critical eye on St. Benedict's thereafter. The inquiry clearly thinks that these interventions made all the difference. They clearly think that the shortcomings of the 2009 inspection were probably not an anomaly but on the contrary were characteristic of the organisation.

However, had it not been for the intervention of members of the public, the ISI might not have re-appraised the safeguarding arrangements at St Benedict’s in 2010 and thereafter. Its approach to the inspection of St Benedict’s in 2009 fell far short of what should be expected of an independent inspectorate.

Department for Education
The DfE doesn't fare well either. As the report says:

The DfE’s involvement with Ealing Abbey and St Benedict’s was limited until significant problems were identified.

In 2007, the DfE agreed to commission an ISI inspection of St Benedict’s in 2009. There is no evidence that the DfE relayed to the ISI before its 2009 inspections the fact that the Charity Commission had contacted the DfE in 2007 regarding allegations made against Pearce and RC-F41.

In 2009, the ISI asked the DfE whether it should do anything in addition to that scheduled inspection, following an email from Ealing Children’s Services. That email arose from an anonymous letter which made reference to “things being hushed up”. The DfE contacted the local authority designated officer (LADO) at Ealing, and was told by the LADO that the Ealing Child Protection Strategy Group wanted to flag with the DfE the comments in the letter “that indicated the school ethos was to cover up any problems”, although no other information or explanation was given in the letter. The LADO said that the headmaster, Christopher Cleugh, had appeared to cooperate fully. The LADO did not relate the history of Pearce’s offending with RC-A621, nor the fact of his arrest and pending prosecution, or that RC-F41 had also been the subject of historic allegations. Ealing Council (through its LADO) should have been in a position to inform the DfE of such facts.

It appears that it was only after concerns were raised with the ISI by Jonathan West and Michael Grant that the independent education and school governance division of the DfE became aware of the Charity Commission report of December 2009, and the scale of the problem at Ealing Abbey and St Benedict’s. This was despite exchanges in 2006/7 with the Charity Commission, the exchange in 2009 with the LADO and the DfE having a press cuttings service to alert it to safeguarding issues in independent schools.

Ealing Council Children's Services
We have another catalogue of error and incompetence here.

Despite the long-standing importance of its role, Ealing Council’s case records prior to 2009 were stored on one officer’s drive and were deleted when he left. As a result, it was unable to find any record in respect of the complaints of RC-A418 in 2001, RC-A6 and RC‑A419 in 2004, the imposition of restrictions upon David Pearce in 2005 or the civil judgment against him in 2006. Carolyn Fair, the Director of Children’s Services at Ealing Council, has explained that the council’s response to allegations “became systematic” in 2009. Records of referrals are now processed and stored on a computerised social care database.

The inadequacy of historic record-keeping at Ealing Council is reflected in the insufficiency of the information provided by the LADO to the DfE in June 2009. The DfE contacted the LADO at Ealing, and was told by the LADO that the Ealing Child Protection Strategy Group wanted to alert the DfE to a concern “that indicated the school ethos was to cover up any problems”, although no other information or explanation was given. Most notably, there was no information given about the allegations against Pearce or his impending trial, nor was anything said about RC-F41 despite the Council having been informed in 2006 of historical allegations made against him. The DfE was entitled to expect more detail from the local authority, as in effect Ms Fair admitted. She stated that it was only around 2009 that the LADO role was created and a more consistent approach to record-keeping adopted at Ealing Council Children’s Services:

“If this LADO role and experience had been established in May 2009 I would expect the LADO to inform the then DCSF, now DfE, due to the number of specific allegations within one establishment.”

This however is extremely odd. The LADO role was defined in legislation long before 2009. What on earth was Ealing doing without one until then?

Afterword
A journalist spoke to me the other day. One of her questions was about why I had put in all the effort I did over the years. This report gives one good reason why. It had to be done and hardly anyone else was doing very much.