Speech by Joanne Grenfell, lead bishop for Safeguarding, on Managing Code of Practice debate

Synod, after two days of powerful debate particularly around the Makin Review and future of safeguarding, it is now time for us to focus on important policy work.

This is the first of two Safeguarding Codes of Practice for consideration.

As a Synod, you have previously approved Codes in relation to safeguarding practice reviews in July 2023 and the learning and development framework in July 2024. These were really good debates getting to the heart of our policy and practice and I look forward to hearing your views today.

It is worth noting that two Codes of Practice on Religious Communities have been deemed approved as the requisite number of requests for a debate was not reached – however I do encourage you to read the Codes on the website, and they will come into effect in March.

What does this new Managing Allegations code of practice do?

Well, it sets out the processes for assessing and managing safeguarding concerns and allegations in our Church. It is in many respects a technical document, aimed at safeguarding professionals and others who will manage the process. As such, it is a vital document in ensuring we are a safer church.

Why do we need this new Managing Safeguarding Concerns and Allegations Code of Practice?

There are three principal reasons.

Firstly, the current House of Bishops’ Practice Guidance on Responding to, assessing and managing safeguarding concerns and allegations against church officers has been in existence since 2017. In that time, we know that both Church structures and safeguarding processes have moved on considerably. Feedback was continually received that having one pathway for all types of concerns and allegations was not helpful, as doing so fails to distinguish between an allegation of direct abuse or harm and concerns of a more procedural matter, whether committed inadvertently or not. The current practice guidance also fails to distinguish between nuances such as the employment status of a respondent or where a concern is raised against an elected church officer – such as a churchwarden. We’re addressing these issues now.

Secondly, in 2020 the Independent Inquiry into Child Sexual Abuse published their report on the Church of England. IICSA made a number of recommendations which we have been implementing over the last few years. Our processes also need to be updated to take account of those changes – such as the change over from DSA to DSO and the new Clergy Risk Assessment Regulations which Synod approved yesterday.

Thirdly, in 2021 Synod passed the Safeguarding Code of Practice Measure (2021). As you will recall this replaced the former ‘duty to have due regard’ in existing guidance with a ‘duty to comply’ with the requirements of a Code. This was an IICSA recommendation designed to bring absolute clarity to each of our responsibilities in relation to safeguarding.

These Codes contain both requirements – which as I have said are mandatory – and guidance on how a person is to comply with the requirements. All requirements are clearly marked as such and are in a blue box in the document.

As a result of these changes, therefore, the time has come to place our managing allegations process into one of these Codes and give it the firm basis it requires.

Time does not allow me to go through every detail of the proposed Code – it is a detailed document and by necessity it is long.

But let me highlight some areas for you:

• There are now clear pathways with detailed guidance on how to deal with allegations and managing risk with different categories of Church Officer for example, clergy, employees, volunteers, elected members of bodies and those who are deceased.
• The list of ‘relevant persons’ – who are required to comply with the requirements of the Code – is set out clearly at the start and each requirement is clearly directed to one of these persons or bodies. It is important to note that the ‘relevant person’ is the one who has responsibility for making the requirement happen, and who has the ultimate accountability if it does not. That does not mean they are necessarily the person who will carry out the requirement. For example, if a Bishop is a relevant person for a particular requirement, in practice this might carried out by another suitable person – but always with a clear line of accountability.
• A new process for dealing with allegations about failing to follow safeguarding procedures where there is no direct abusive behaviour has been developed. This focuses on learning and development where that is a more appropriate disposal. A learning culture creates a safer culture. This will not however prevent appropriate action being taken when these process failures put other at risk of harm.
• The process for respondents is also clearer, with appropriate support built in. Summary guides are being prepared to make the process clearer.
• There is now much more clarity on the role and functions of the Safeguarding Case Management Group (formerly known as ‘core groups’) with improved structures, decision making processes and escalation where necessary.

The development of this Code and the Code on Reporting requirements which we will consider a little later have been developed with, and informed by, victims and survivors. As ever, I am so grateful to those who have helped us with this work.

I wish to also thank those staff members who have worked on the Code – there have been many but particularly Deborah McGovern in the NST who has led on this work recently. Thank you, Deborah.

Lastly Synod, after yesterday’s debate and vote on the future of our independence safeguarding structures, you may be asking if we should go ahead with changes like this. Would it not be better to wait?

I suggest to you that the answer to that question is firmly – no. Now is the time. We know only too well at the moment that this is not an academic question – but a real live issue for the Church right now.

It is essential that this work led by our safeguarding professionals, who I hugely value and commend to you, continues apace. We would be negligent if we didn’t continually improve our processes and move forward in this way. Further changes and updates are possible if they are needed at a later stage. Work is already underway in preparation for Synod’s decision, so as to be ready to implement this policy, if approved, from September.

We have a continuing responsibility to improve the way that safeguarding is delivered. I commend this Code to you and ask that you approve it.