Requirements
4C.10 A Church Safety Plan must contain a review date based on the specific circumstances of the case but must also allow for earlier review should these circumstances change. As a minimum, every Safety Plan must be reviewed every 12 months.
4C.11 The review must be carried out by the Safeguarding Officer (or nominated member of their team) in consultation with the subject of the plan, relevant statutory agencies and anyone involved in providing support and monitoring the arrangements set out in the plan.
4C.12 If the Safeguarding Officer is satisfied at any review that the level of risk is such that a plan is no longer needed, the plan must be ended, and all relevant parties must be notified. The decision to end a plan must be made in consultation with the subject of the plan, relevant statutory agencies and anyone involved in support and monitoring arrangements.
4C.13 In the event of a person who is subject to a Church Safety Plan moving and continuing to worship in a different diocese, the Safeguarding Officer must ensure that a copy of the Church Safety Plan is shared with the Safeguarding Officer in the new diocese.
4C.14 Where the PSO becomes aware of a breach of the Church Safety Plan, they must report the breaches to the DSO. Where statutory agencies are involved, the DSO must inform the statutory services of the breach.
Guidance
4C.10-4C.12 - Church Safety Plans Reviews
Church Safety Plans must be kept under regular review to ensure that they remain effective in managing risk. It is good practice for a Plan to be reviewed by the same group who drafted it. As a minimum, the Safeguarding Officer, the respondent and anyone involved in providing support and monitoring the Plan must be part of the review. A review should cover the following considerations:
- what is and is not working;
- whether there have been any breaches;
- a review of any risk and protective factors;
- any changes required to the terms or requirements in the Plan (including whether the Plan continues to be needed); and
- an agreement on the date of the next review.
Reviews might trigger the need for a revised risk assessment. A consideration of all risk factors, including any changing or new factors must be part of the review and should be explored if relevant.
Minutes should be kept from all review meetings and retained in the case files held by the Safeguarding Officer.
4C.13 - Sharing information about the Church Safety Plan
It must be made clear to the parties who are involved in drafting, providing support, and monitoring the Plan that the information included will be treated with sensitivity. The information should only be disclosed to the parties involved in providing support or monitoring compliance, provided that it is necessary and proportionate to do so. Only those parties should be informed about the facts, except in situations where material needs to be referred to statutory services. In certain circumstances, victims, survivors and / or their families may also need to be informed, but this should be done with advice from statutory services and the information shared should be only what is necessary and proportionate. Data protection and legal advice must be sought before sharing any information about the Plan with others and the rationale for sharing the information must be recorded.
When a person who is subject to a Plan moves to a different diocese within the Church of England or to the Church in Wales, a copy of the Church Safety Plan must be shared by the Safeguarding Officer with the Safeguarding Officer in the receiving diocese, for risk management purposes1 . The relevant statutory agencies may also need to be informed in these circumstances. The receiving diocese should review the Church Safety Plan and may undertake their own risk assessment to ensure that any new contextual factors have been taken into account and built into the Plan. If a Church Safety Plan was ended before someone decided to move to a different diocese, the Safeguarding Officer should not share a copy of the Church Safety Plan, but should inform the receiving diocese that the individual had a Church Safety Plan in place, for how long and when it was ended.
When a person who is subject to a Plan joins a different denomination (e.g. Roman Catholic, Methodist), the Safeguarding Officer should contact a relevant safeguarding professional within that denomination and inform them about the individual’s background. This should only be done after taking data protection / legal advice and the information shared must be minimal – necessary, accurate and proportionate. The relevant statutory agencies may also need to be informed in these circumstances.
4C.14 - Breaches of a Church Safety Plan
A Church Safety Plan is for the benefit of both the person who presents safeguarding risks and the Church, in order for someone to worship and participate safely. If a person who poses a safeguarding risk refuses to sign a Church Safety Plan or refuses to comply with the terms of it, consideration should be given as to what other actions could be taken. This might be excluding them from any activities or events which are not open to the public in the same way as a service. Any breach of the Church Safety Plan must be reported to the Safeguarding Officer as soon as it becomes known. If the person refuses to agree to appropriate restrictions on Church attendance, then it may also be necessary, for safeguarding purposes, to make a wider circle of people aware of that person’s history. This would need to be discussed with the relevant Data Protection Officer and the Diocesan Registrar first, to ensure that there is sufficient purpose and an appropriate lawful basis for sharing that information.
If other agencies are involved (e.g. the police, probation service), they must also be informed, at the earliest opportunity, about a person’s unwillingness to agree to a Church Safety Plan or any breach of the Plan’s requirements.
- 1Following the Independent Inquiry into Child Sexual Abuse, dioceses, cathedrals, a number of royal peculiars and the National Church Institutions that form part of the Church of England and the Church in Wales have put in place an Information Sharing Agreement. A separate agreement has also been put in place for HR-related information.