The Diocese of Liverpool has published the summary of findings by our Independent Reviewers as part of the national Past Cases Review 2 from the Church of England. You can read the national report here.
Implementation of recommendations
The role of the DSAP
The report recommendations
Foreword: Bishop of Warrington
Safeguarding is a critical part of the ministry of the church and we must all work hard to make our worshipping communities safe spaces for all.
So, I welcome this review and this report. Like many of my colleagues across the Church of England I know that collectively we have made great strides in the area of safeguarding yet we have a long way to go. The recommendations contained within this report will help us, as a Diocese of Liverpool, work to improve safeguarding culture for all.
The report shows that we have not always got it right. For that and for every person who has suffered abuse in our diocese I am sorry. I am deeply sorry for all those who feel that they have been let down by our systems and procedures, for those who felt they could not report the abuse they have suffered, or those who feel let down or unheard by the church.
This report contains many lessons for us as a diocese. We will aim to learn from and implement the 20 recommendations that are contained within this report. Similarly, we will work to learn from the recommendations contained in the national report.
We acknowledge that one of our weaker areas has been enabling the survivor voice to be heard. This is an area we continue to work on. And we are grateful to all who have come forward as part of this process. I would also like to continue to encourage anyone to come forward and report that is not right.
We have strengthened our approach to safeguarding practice and work hard on improving the culture across the worshipping communities in our diocese so that in all places and among all individuals safeguarding is given the utmost priority. We remained determined to improve. As a diocese, we pledge our ongoing commitment to making our church a safe place for all. The actions in this report will continue to help us achieve that goal.
The Rt Revd Beverley Mason
Acting Bishop of Liverpool and Bishop of Warrington
The Diocese of Liverpool commissioned a review of its past case files in accordance with the framework set out by the National Safeguarding Team (NST). We employed two nationally approved Independent Reviewers (IRs) to enable the review to be complete and submitted to the NST for its deadline of December 2021.
The specific objectives of PCR2 are:
- To identify all information held within parishes, cathedrals, diocese, or other church bodies, which may contain allegations of abuse or neglect where the alleged perpetrator is a clergy person or other church officer and ensure these cases have been independently reviewed.
- To ensure all allegations of abuse of children, especially those that have been recorded since the original PCR, have been handled appropriately and proportionately to the level of risk identified.
- To ensure that recorded incidents or allegations of abuse of an adult (including domestic abuse) have been handled appropriately demonstrating the principals of adult safeguarding
- To ensure that all the support needs of known survivors have been considered.
- To ensure that all safeguarding allegations have been referred to the DSA and are currently being/have been responded to in line with current safeguarding practice guidance
- To ensure that cases meeting the relevant thresholds have been referred to statutory agencies.
The IRs reviewed 1292 files relating to living members of the clergy and readers of Liverpool Diocese. They also reviewed the file of any church officer employed by the diocese that was considered to have their current or past church role that required or requires them to have substantial contact with children and/or adults at risk of abuse.
During the review, the IRs found 2 files that contained issues they believed needed to be addressed immediately and 13 referred to the Diocesan Safeguarding Advisor (DSA) for consideration. Two further files were referred to the Bishop of Liverpool’s office with non-safeguarding concerns relating to financial irregularities they believed required further investigation.
At the time of writing this report there are no safeguarding concerns reported to the DSA that have not been resolved or are not being dealt with.
The files reviewed spanned a period of up to 60 years. Whilst current and recent files were of a good standard, the older the file the greater the divergence with current standards and priorities relating to the protection of children, adults, and victims and survivors. The priorities of protecting the reputation of the Church of England and its clergy were evident in those older files. However, the journey the church has been on is apparent and the files show it has moved considerably over the years in respect of its priorities towards victims and survivors, the use of professional safeguarding staff, and engaging with other agencies where appropriate.
With one exception, the recommendations that were put forward had the object of improving on what currently exists. The exception relates to the introduction of an electronic records management system for various files that are currently paper based. The system needs to be national to cater for the movement of clergy and readers between dioceses. Based on the evidence within the files reviewed and the interactions of the IRs with diocesan staff they believe the diocese has a good foundation to move the work of safeguarding forward.
This section highlights the conclusions that were made by the IRs in their report.
The review by the IRs has shown that the number of files that raised concerns of a significant or immediate nature has been relatively small in number. Where cases of concern were raised, they were dealt with efficiently by the DSA team. The vast majority of concerns, observed in the files, related to those that were of some age and to members of the clergy that are not currently engaged in an active ministry.
The absence of records in older files has on occasions, hindered the current view of whether certain events of the past complied with the policies in place at the time in relation to child and adult ‘safeguarding’.
No victims, survivors or witnesses have contacted the DoL PCR2 IRs, but the processes were in place for such contact.
There are varying levels of safeguarding knowledge and confidence within the diocese. Although the majority of files demonstrated the necessity to prioritise safeguarding, this did not always translate into an actual referral to the DSA team.
Current recruitment practices do not fully embrace the safer recruitment requirements and have the potential for improvement at the diocesan level. The IRs have little or no evidence from the files reviewed to comment on what practices occur at a parish level, which is outside the scope of the review. They do recognise some of the limitations that the autonomy within the CoE church structure presents to the DSA and the senior clergy within the diocese in satisfying themselves that safeguarding is fully embedded in all parish activity.
The evidence in recent files demonstrate that, in most cases, effective ‘Safeguarding’ processes and procedures were applied when issues were raised.
Improvements in relation to safeguarding awareness, application and practice could be made within the cathedral and diocese. Those areas where improvements are suggested are:-
- Safeguarding awareness.
- Blemished Self Declarations.
- An improvement in the content on certain file types relating to safeguarding details.
- Aspects of the granting of PTO
- Domestic abuse.
- Work in the cathedral and some parishes.
- An Electronic records system.
- Training for staff in key positions frequently dealing with specific, complex, social issues.
The diocese had the appropriate safeguarding policies and practices in place as required. The diocese had an effective DSA team in place that is well regarded by those who have experienced it. The diocese had effective and supportive leadership at a senior level. The clergy were collectively well supported by an able group of lay persons
The willingness to learn, demonstrated in conversation with members of the diocese, suggests that the PCR2 report, its conclusions and recommendations will be considered seriously and that the diocese will work closely with the PCR2 Reference Group in taking the work forward. The cooperation of staff from the diocese with the PCR2 process has been full and unfettered. The IRs were made to feel welcome and that the review was been taken seriously.
Implementation of local recommendations
There were 20 recommendations made in the report. The reviewers stated that where recommendations have been made it is to take the diocese to a higher standard rather than to implement something new or highlight deficiencies. The exception to this is the recommendation relating to the introduction of an electronic records management system.
You can find the full recommendations at the end of this summary.
The Diocese has a staff working group that has developed a timed action plan for assessing and implementing the identified recommendations. This is led by the safeguarding team and is accountable to the Diocesan Safeguarding Advisory Panel. We anticipate that all recommendations in the direct control of the diocese will be completed by January 2023.
The PCR2 Survivors Strategy was agreed and published on 29th April 2020. The document refers to the independent support offered by the NSPCC and signposts the contact information on the Diocesan and NST websites. The Diocesan website has a dedicated page ‘Support for survivors and victims’ which contains relevant information and signposts to where both how the DSA team may be contacted and a number of other related non-church organisations.
The policy is specifically for PCR2 and provides details of the role of the Advocate for Survivor Care and how victims and survivors can engage with the process and the links to national policy. There are no named persons on the policy nor links or contact numbers for further support and reference is not made to the Authorised Listener Service.
It is recognised that support is available and is offered frequently, but, due to the lack of details regarding the plans and implementation of support in individual cases and their outcomes, the IRs were unable to make a judgement regarding the quality of support given outside of that via the safeguarding team.
It would not be unusual to find no evidence of feedback regarding support that has been offered to victims and survivors as these plans, activities, and outcomes would remain confidential within the counselling relationship with feedback only being shared if, for example, there were problems. The IRs acknowledge it is a delicate balance to secure involvement from those affected by abuse. Being respectful of an individual’s views need to be balanced against avoiding distress to victims by re-living experiences from requests to meet an IR. This is particularly relevant in cases of an aged nature where issues may not have been addressed correctly at the time with the potential for mistrust. In the IRs experience, getting the balance right is extremely difficult.
The DoL benefits from strong leadership by the Chair of the PCR2 Reference Group. The chair is well-qualified for the role having extensive experience in both legal and ecclesiastical matters. During both meetings the IRs attended they observed the Chair appropriately lead and coordinate challenge of the review.
The DoL is supported by strong DSAP and PCR2 reference groups, the latter of which has met on three occasions since its inception. It comprises of a good representation from statutory and voluntary agencies, including a clergy victim/survivor representative, voluntary victim agency representation, representation from Merseyside Police along with parish and cathedral representation.
1.Consideration should be given to the DSA team having sight of 'blemished’ self-declarations to enable these and any blemished DBS checks to be risk assessed by the safeguarding professionals.
2. Theological Educational Institutions should consistently provide information to the diocese as to when students have completed safeguarding training and at what level this was undertaken.
3. HR and LML files held by the DoL should all clearly show what level of checks and safeguarding training are required for a post or commission and a record those matters relating to the individual taking up the same.
4. Consideration should be given to a cost benefit analysis of purchasing an electronic recording system for safeguarding case management which also includes the facility to record cases that do not currently meet the team’s threshold for intervention at that stage.
5. Consideration should be given to the option of the Bishop of Liverpool, in conjunction with the senior leadership of the cathedral, the DSA and the Assistant Diocesan Secretary, writing to all clergy in the diocese and the cathedral to remind them of their safeguarding obligations including the requirement to report concerns to the DSA without delay.
Such a letter could also take the opportunity to raise awareness of the role and responsibilities of other agencies to investigate safeguarding concerns. The IRs would suggest the inclusion of the potential consequences, for all, of not following these policies.
6. The DoL considers its current practice and policy relating to domestic abuse to ensure it contains current best practice for the identification of, and response to, such incidents within a clergy family with particular regard to situations involving a tied home.
7. The DoL should consider reviewing the PCR2 Victim/Survivors policy to include the contact details of the NSPCC helpline, the DSA the PCR2 Victim Advocate. Additionally, the review may also consider if messages within the policy require any strengthening in respect of managing the expectations of victims and survivors concerning potential outcomes and the levels of information sharing that could be expected.
8. The DoL should consider approaching the LADO regarding the implementation of a multiagency feedback form from agencies to provide feedback to the DSA and her team when statutory investigations conclude (often a considerable time after referral) to allow for a more informed diocesan investigation. This form should include an evidence-based conclusion and the views of those involved in the investigations, to support the dioceses investigations which are assessed at the level of on balance of probability, not beyond reasonable doubt. This is of particular importance in cases that did not proceed to any statutory censure or sanction.
9. For the DoL to consider the implementation of a Safeguarding Team referral form, with guidance, to assist with the provision of full details of the concern. This should include cases for initial referral that do not progress in order that any cumulative concerns can be recorded, reviewed, and shared with agencies if needed
10. The DoL should ensure there is clear guidance to clergy and officers as to the thresholds of where allegations of bullying become a safeguarding concern.
11. The current diocesan bishops, aided by the DSA, should review the practice of granting PTO licences to those entering the diocese based purely on the CCSL received from the originating diocese. The bishops should satisfy themselves that they are aware of the risks this may pose and that they are comfortable with the levels of risk such a practice presents.
12. That consideration is given as to how to raise awareness, at all levels across the diocese, of domestic abuse, its full and wider definition, and the vulnerabilities of victims.
13. The DoL should consider the inclusion of a section, specifically relating to safeguarding issues, within the MDR documentation.
14. The DoL should consider reviewing the policies relating to Whistleblowing and Professional Boundaries to see if they can be strengthened in respect of supporting junior members of clergy who make complaints against more senior colleagues.
15. The practice of the Bishop of Liverpool to provide a start and end date to the granting of PTO licences should be considered as standard practice for all bishops within the diocese. Additionally, the DoL should consider, as part of their assessment process for appointing new staff or in the granting of PTO, the use of a social media/internet search for adverse issues that may not be present on a CCSL or on an individual’s application.
16. The DoL should ensure that all interview panels for the recruitment of persons who will have direct contact with children, young people or vulnerable adults include a person suitably qualified in ‘safer recruitment.’
17. The DoL should consider implementing a safeguarding team feedback sheet for completion when persons are allocated tasks relating to safeguarding concerns and actions taken to address safeguarding failures.
18. All clergy and church officers’ files should contain a Statement of Particular's that details the postholder’s safeguarding responsibilities as set out in the 2016 commitment by the CoE national church. Such a statement should also set out the serious nature of failing to follow those procedures
19. When a new post is created, or a current one vacated, the SoP, job description and person specification are reviewed to ensure compliance with safe recruitment guidance
20. The CoE should ensure that incumbents of posts that come into frequent contact with such issues as, modern slavery, female genital mutilation, stalking and harassment, honour-based violence and forced marriage, are provided with the relevant modules. Further consideration should be given to whether such modules should be of a mandatory nature.