Section 6.5-6.12: Church Safety Plans

Guidance 

6.5 – 6.6 - Church Safety Plans

The aim of a Church Safety Plan is to set clear boundaries which allow a respondent to continue to deliver their role and ministry in the Church safely. A Church Safety Plan is not meant to be punitive in nature. Church Safety Plans can be put in place to protect both the complainant, other members of the Church, and the respondent. The intention behind setting certain boundaries is to acknowledge the risks that have been identified and find proportionate ways to manage them.

Church Safety Plans are most effective when they are drafted in a collaborative manner. The Safeguarding Officer, other members of the SCMG (where a SCMG was held), anyone involved in monitoring the Plan (such as churchwardens or Parish Safeguarding Officers) and the respondent should be involved in the drafting of the Plan. This will ensure that the requirements contained within the Plan are sufficient and proportionate for the management of the risks identified, as well as enforceable.

The drafting of the terms of the Church Safety Plan should be informed by the findings of any safeguarding enquiries and risk assessments carried out and should include considerations of both risk and protective factors. When drafting a Plan, Safeguarding Officers and others are asked to consider what the risks within the Church context are, what is working well, and what can be done to further mitigate the identified risks. The needs of complainants should be central to any discussions about a Church Safety Plan, balanced against the need to restrict the worship and work of the respondent. Careful consideration should be given to situations in which the complainant is a member of the respondent’s family and attends the same church.

A template for a Church Safety Plan is provided. The types of requirements that may be included in a Church Safety Plan include:

• not meeting children, young people and/or vulnerable adults alone on Church ground;
• stopping and avoiding any contact with the victim and their family;
• attending designated meetings only;
• sitting apart from children, young people and/or vulnerable adults during service;
• staying away from areas of the building where children, young people and/or vulnerable adults meet;
• only attending a house/home group where there are no children, young people and/or vulnerable adults;
• declining hospitality where there are children, young people and/or vulnerable adults present;
• never working or being part of a mixed-age group that includes children, young people and / or vulnerable adults;
• taking no official role in the Church or any role of responsibility where they are trusted by others1 .
• attending services at a particular time of day.

It is important to note that members of clergy, by the nature of their role, are trusted individuals who will inevitably come into contact with children, young people or vulnerable adults as part of their ministry. As such, imposing blanket requirements, such as “never meeting with children, young people and / or vulnerable adults”, will not be an effective or realistic way to manage risk. Instead, requirements should be specific and should include mitigations.

The Safeguarding Officer will have a duty to monitor the overall compliance of a respondent with the Plan, but compliance with specific requirements may be delegated to other relevant members of the Church (for instance, senior members of clergy who oversee the respondent’s professional development and ministry, or Church Officers at the parish level, such as churchwardens). Anyone involved in the monitoring of the Plan will need to meet with the respondent regularly, maintain records of any contact and share those records with the Safeguarding Officer or relevant statutory agencies, as needed. It is important to note the risks that an individual may present will be held by the relevant DBF, PCC or other governance body. In their roles as trustees, DBF and PCC members, Cathedral Chapter members and others have a responsibility to manage safeguarding risks within their organisation2 . They should, therefore, seek to work closely with the Safeguarding Officer and should ensure that they are content that safeguarding risks are appropriately managed.

It must be made clear to the parties who are involved in the drafting and monitoring of the Plan that no information about the Plan must be disclosed to others unless there is a clear purpose and justification for doing so.  This would include where the respondent breaches the Plan, therefore requiring further disciplinary or otherwise action to be taken by the Church; or where information needs to be shared with statutory services, for the protection of children, young people or vulnerable adults or if it is in the public interest to do so. Expert advice must be sought before sharing any information about the Plan with others and the rationale for sharing the information should be recorded in the case files.

In the event of a person who is subject to a Church Safety Plan moving and continuing to exercise ministry in a different diocese, a copy of the Church Safety Plan should be shared with the Safeguarding Officer in the new diocese.  If a respondent moves to a different Christian denomination or Church, or to a role outside of a Church, advice should be sought from statutory services and the relevant Data Protection Lead as to what information may need to be shared with the respondent’s new organisation / employer. Please also refer to guidance in the section on “Responding to safeguarding concerns / allegations involving non-recent events, where the respondent is alive but has left the Church Body in which the events are alleged to have taken place” above.

6.7-6.8 - Church Safety Plan Reviews

Church Safety Plans should 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 should 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 should 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 or on MyConcern or equivalent case management system.

Breaches of Church Safety Plan

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, 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 or the Diocesan Registrar first, to ensure that there is sufficient purpose and an appropriate lawful basis for sharing that information.

If statutory agencies are involved, 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. In certain circumstances, agencies may use this information to apply other powers that they may have.

6.9-6.12 - Ending a Church Safety Plan

If at any point, the Safeguarding Officer is satisfied that the respondent no longer poses a risk, they must consider ending the Plan. To do this, the Safeguarding Officer should conduct a final risk assessment including gathering feedback from any monitoring parties involved,  and where appropriate, the SCMG and from statutory services.  Where a Plan has ended due to the death of the respondent, then no further action is needed beyond appropriate recording.

The Safeguarding Officer must meet with the respondent to discuss this decision, allowing them the opportunity to provide input.

Once the decision is agreed to end the Plan, the decision must be given in writing to the respondent and communicated in writing to any relevant stakeholders. This must be recorded, along with the rationale and any ongoing recommendations, on the respondent’s file.

• 1Individuals included in a barred list or who have been convicted of certain offences are disqualified from holding specific offices in the Church, including membership of a PCC, deanery synod, diocesan synod or the General Synod, see the Church Representation Rules 2022 (as amended), Rule 68.
• 2See the Charity Commission guidance on “Safeguarding and protecting people for charities and trustees”