Section 4.1: Establishing a Review Group
4.1.1 When the SPR threshold is met, the Church body must establish a Review Group to manage the process of establishing, coordinating and responding to the Review. The Review Group will remain in place for the duration of the SPR process. The role of the Review Group includes:
- Setting the Terms of Reference (ToR) and initial Key Lines of Enquiry (KLOE), including whether there are any previous Lessons Learnt Case Reviews where the recommendations have not been implemented.
- Completing the data protection arrangements with the Reviewer.
- Specifying the resources required for the Review to occur, including administrative support. In some cases, more than one Reviewer will be required.
- Selecting the Reviewer/s.
- Engaging with the victims, survivors and respondents to identify how they want to be involved in the process and what support they require in order to participate.
- Agreeing on the methodology and participants for the Review.
- Devising a plan for the implementation and evaluation of the SPR recommendations.
- Providing support to the Reviewer and ensuring the timetable is adhered to.
- Quality assuring the final report.
4.1.2 Chairing arrangements must be agreed on a case-by-case basis, but they are likely to be the DSAP Chair (in dioceses or cathedrals), Director/Deputy Directors or Safeguarding Lead bishops1 if the SPR is commissioned by the NST, bearing in mind the data protection requirements which will apply.
Good Practice Advice
The Chair will determine membership of the group. The size will be determined by the complexity of the case and the available resources but is likely to be four to five people. This is not intended to add an additional layer of bureaucracy, but to administer and manage the Review process. This will include who will be the point of contact for the Reviewer, the victims and survivors or their family and the respondent. The Chair has discretion to appoint other members with relevant expertise, if required.
The Group is likely to involve the following roles, but it will depend on the case and the resources:
- A member of clergy e.g. chaplain, archdeacon.
- A HR officer if the Church Officer is employed or a volunteer in a lay role.
- A member of the safeguarding team, if there is a member who was not involved in the original case.
- An individual who can make commitments about resources.
- An independent member e.g. from statutory services or the DSAP.
Where the case is likely to be very high profile, either locally or nationally, consideration should be given to having an additional independent person on the Review Group.
Given the resource implications of a SPR, consideration should be given to whether there should be someone on the group who can give those commitments. Alternatively, the Group needs to clarify how those decisions will be made. Other professionals may need to advise the Review Group depending on the circumstances of the case. The victims, survivors and Church officers/respondents need to be made aware of who is on the Review Group.
The Review Group is responsible for signing off the final report. See section 4.6 for further details.
The Review Group is not a legal entity from a data protection perspective, and the data controller will therefore be the relevant members who make the decisions about the processing of personal data by the Review Group. The Review Group should put in place a document which sets up and governs the management of the Group, and sets out which individual(s) manage the Group on behalf of its members and are likely to act as the controller, or the members of the Group act as joint controllers.
As the data controller, the Review Group are responsible for complying with the UK GDPR, including being able to demonstrate compliance with data protection principles, and taking appropriate technical and organisational measures to ensure processing is carried out in line with the UK GDPR. The members of the Review Group may, however, be exempt from paying the data protection fee under the not-for-profit exemption. The Review Group should undertake the ICO self-assessment to check if this applies.