The Vetting and Barring Scheme

Sir Roger Singleton's review

On December 13th 2009 the Schools Secretary announced the outcome of the review of the extent of the Vetting and Barring Scheme, essentially who will have to register. These announcements made three significant changes to the impact of the scheme on Sunday Schools and youth groups:

1. Only brothers and sisters who work with children every week will have to register (previously it was once a month). So only those who teach in Sunday School every week, or youth leaders who are present every week, will need to register.
2. Only those who work four days out of 30 will have to register (it was three). This will take many weekend activities out of the scope of the scheme. Note however that leaders of week-long camps and holiday clubs will need to register.
3. Regarding hosts for youth weekends, we have received clarification from the Independent Safeguarding Authority which appears below.

Having said all that, our general advice would be that registration should be seen as a friend not an enemy. It is a piece of tiresome paperwork, but once it's done it's done for life, and it brings potential benefits:

• It reassures the parents of children who would like to visit your Sunday School or CYC that their offspring will be in safe hands.
• It may be required by organisations such as those renting halls, or insurance companies.
• If anything were to go wrong you can be seen to have acted responsibly.

Please note that this page attempts to address our responsibilities with relation to CRB checks and ISA regsitration. It does not address wider responsibilities for child protection. More general advice is available from the Christadelphian Support Network.

Guidance from the Independent Safeguarding Authority

The ISA has published a document called 'Vetting and Barring Scheme Guidance' which can be downloaded in pdf format from here. Alternatively you can obtain printed copies from their contact centre on 0300 123 1111. They expect these to be available from 5 April.

In addition they have provided a guide to completing the application forms on their web site. Individual youth leaders should click on 'Guide for Applicants'; if you need to check the forms of other youth leaders, click on 'Guide for Regsitered Bodies'.

Frequently asked questions

1. Why has the Vetting and Barring Scheme been introduced?
2. How does the scheme work?
3. We are a 'faith group', not a business. Does the scheme apply to us?
4. We are all volunteers, not employees. Does this really apply to us?
5. Our Sunday School / CYC /etc only has children of Christadelphian families. Do we still have to register?
6. How do I know if our ecclesia’s / committee’s activities come under the Vetting and Barring Scheme?
7. When does the scheme start?
8. What about hosts for a Youth Weekend?  Do they need to register with the ISA?
9. My only role is to transport children to and from activities; do I still need to be registered?
10. I already work with children and young people; when will I need to do anything about registration?
11. Do 'employers' (i.e. ecclesias, camps, youth weeks, etc) have to register?
12. What is the difference between a CRB application and ISA registration?
13. Who needs to make sure people working with children or vulnerable adults are registered?

1. Why has the Vetting and Barring Scheme been introduced?

The Caretaker who abused and murdered two girls in Soham ‘slipped through the net’ and was able to work in a position in which he was able to form a trusting relationship with children. If he had had to register with an agency that could vet his suitability to work with vulnerable people (against known information) he could have been prevented from taking the post.

The enquiry that followed his conviction recommended that all those who work with children or vulnerable adults should be registered to prevent this kind of situation arising in the future.

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2. How does the scheme work?

Someone who is working, or wants to work, with children or vulnerable adults registers with the Independent Safequarding Authority (ISA); if they have a conviction or appear on a list of barred individuals (for instance, if an enhanced CRB check suggests they would pose a risk) they will be barred from registering.
Ecclesias, or other organisations such as camps, will have to check that individuals they want to work regularly with children (a regulated or controlled activity - see below) are registered with the ISA. If they are not, the ecclesia, camp, etc. will be prevented by law from using their services and it will be a criminal offence to do so.

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3. We are a 'faith group', not a business. Does the scheme apply to us?

Yes it does. The Act makes no distinction, and we should not be surprised at this given the publicity that has been given to problems within some churches.

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4. We are all volunteers, not employees. Does this really apply to us?

Yes, no distinction is made between paid and voluntary work. The term ‘employee’ refers to someone working with vulnerable groups, whether or not they are paid.

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5. Our Sunday School / CYC / etc only has children of Christadelphian families. Do we still have to register?

It is very likely that you will have to register, as there is no differentiation between activities that are open to the general public and those that are for closed groups. However, the provisions of the Safeguarding Vulnerable Groups Act (2006) “[do] not apply to any activity which is carried out in the course of a personal relationship and for no commercial consideration”.
A personal relationship is defined as “a relationship between or among friends” where “a friend of a person (A) includes a person who is a friend of a member of A’s family.”
It may be possible to argue that where only children of Christadelphian families are provided for the activity is carried out between friends. Where this is the case we would recommend those involved discuss the situation directly with the ISA as they may not take this view. It appears to us not to be in the spirit of the Act and, of course, would preclude another child from joining until registration and checking had taken place. So if a child wanted to start bringing a friend you would have to turn the new child away.

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6. How do I know if our ecclesia’s / committee’s activities come under the Vetting and Barring Scheme?

The Scheme covers two types of activity, ‘controlled’ (which is for ancillary workers in agencies like the Health Service and has no application to faith groups) and ‘regulated’. Many ecclesias and committees will run these.

• A regulated activity, as far as it relates to our community, is any activity involving contact with children or vulnerable adults and is of a specified nature (e.g. teaching, training, care, supervision, advice or in certain circumstances transport) on a frequent, intensive and/or overnight.
• ‘Frequent’ means once a week or more. (Note - this was changed as a result of Sir Roger Singleton's review; previously it was once a month or more)
• ‘Intensively’ means on four occasions or more in 30 days (previously three), or overnight.
• ‘Overnight’ is defined as between 2am and 6am
• A child is any one under the age of 18, except in employment settings where the age limit is 16.

Examples of people running a regulated activity include:

• Someone teaching in a Sunday School rota or leading a CYC every week.
• Hosts at a youth weekend where the ecclesia makes arrangements for accommodation (see below for more details).
• Someone leading a week-long camp or Holiday Club.

The ISA's Guide to the Vetting and Barring Scheme includes the following examples:

Riyaz volunteers at his local church Sunday school and at Scouts every week. He frequently teaches and supervises the children. The church and the head of the Scout group must both check that he is ISA registered.

B.30 A number of adults help at a Sunday school on a rota basis. Each adult helps out once every three weeks. That is not frequent and so registration is not required. However, see paragraph B.19 above. Rotas of this nature sometimes have to be adjusted at short notice, to cover sickness absence and unexpected absences. The church is able to check the ISA registration status of these volunteers and in this way establish a pool of helpers who can be called on flexibly without running the risk of committing offences.
[Paragraph B.19 is rather long to include here, but in brief what it says is that it's best to register a pool of workers so that rotas can be changed at short notice without worrying that you might be committing an offence.]

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7. When does the scheme start?

The Scheme is being phased in:

Since 12 October 2009:

• The creation of two new ISA barred lists. These lists replace the existing List 99 and POCA, POVA Lists.
• Access to these new ISA lists is available on request as part of an Enhanced CRB check.
• Eligibility for Enhanced CRB checks has been expanded to include more employment and voluntary positions; such roles will be known as regulated positions.
• Standard CRB checks are longer be available for those working with children or the vulnerable. 
• There is no change to the current application form or application process.
• Employers, social services and professional regulators have a duty to refer to the ISA any information about individuals who may pose a risk. This means that an ecclesia must inform the ISA if someone is convicted of a 'relevant offence', or if they have evidence that someone may pose a risk to children.
• There are criminal penalties for barred individuals who seek or undertake work with vulnerable groups and for employers who knowingly take them on.

From 26 July 2010:

• New teachers, youth leaders and youth weekend hosts will be able to register with the ISA, and ecclesias will be able to check that they have done so.
• A new combined ISA registration and CRB application form will be available.
• Ecclesias will be able to register an interest in an individual with the ISA to be informed of any changes to their registration.
• A 5 year roll-out of the scheme for those currently working with vulnerable groups starts.

From 1 November 2010:

• New Sunday School teachers, youth leaders and weekend hosts will be required by law to register.
• Ecclesias will be required to check their status.
• The ISA have pointed out that if teachers/leaders/hosts have been 'appointed' before 1 November for activities which begin after 1 November they are not regarded as 'new'.

From 2011 (dates to be confirmed):

• Existing teachers and youth leaders with no CRB check must apply for ISA registration.
• Thereafter existing teachers and youth leaders with CRB checks will also need to apply for ISA registration, starting with those whose CRB checks are the oldest.

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8. What about hosts for a Youth Weekend?  Do they need to register with the ISA?

Originally the ISA informed us that if children under 18 would be staying with their hosts for a full weekend (Friday, Saturday and Sunday), then their hosts would need to be registered.

However, in December 2009 the UK Government accepted the review of the VBS carried out by Sir Roger Singleton, and we sought clarification from the Independent Safeguarding Authority regarding the impact on Youth Weekends.

The ISA response reads: If the parents of the children ok the family that you place the children with then there will not be a requirement to register with the Scheme. However if your organisation [i.e. the hosting ecclesia] arranges the placement and the family do not have a choice then there will be a requirement to register.

Effectively what this means is that an ecclesia arranging a youth weekend will need to decide what to do. Fundamentally there are two options:

• Either the hosting arrangements can be made effectively a personal matter between the parents of the children attending the weekend, and their hosts. In this case the hosts would not need to register. This may seem an attractive option, but it also removes the freedom for the hosting ecclesia to make last-minute changes which are often necessary when dealing with large numbers of young people.
• The other option is for the ecclesia to arrange who will stay with whom, as would normally be the case. In this case hosts will need to register. This may seem an arduous task, but it should be remembered that registration is for life - it needs to be done only once.

Overall our recommendation would be that youth weekends should be planned well in advance and that those who plan to act as hosts should register. The clarification above does however leave room for manoeuvre.

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9. My only role is to transport children to and from activities; do I still need to be registered?

Transport is regarded as a regulated activity when it is organised solely for children and vulnerable adults and people caring for them to and from a regulated activity and it is organised on behalf of the providers of that activity. Therefore if you are asked to transport children on behalf of the ecclesia/CYC etc. you will need to register. If, however, it is a personal arrangement between you and the children’s parents or guardians you will not.

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10. I already work with children and young people; when will I need to do anything about registration?

Unless you take on a new role, either within the Christadelphian community or elsewhere, you will have to register at some point in the 5 year roll-out of the scheme. Currently the plan is:

• Year 1 (July 2010) new entrants to the workforce and those moving jobs. This would include new Sunday School teachers and youth leaders.
• Year 2 those who have never had a CRB check before.
• Year 3 those with CRB checks over three years old.
• Year 4 those with more recent CRB checks.
• Year 5 the remainder of those who have had a CRB disclosure & those who work in a controlled activity.

God willing, information will be disseminated through the CSSU when each phase comes in.

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11. Do 'employers' (i.e. ecclesias, camps, youth weeks, etc) have to register?

No. Initially a wrong impression was given that all employers had to register. Ecclesias will not have to register, nor will camps, or any other organisation. So arranging brethren, for instance, will not have to register unless either.

• They are also directly involved in providing services to children or vulnerable adults, in which case they register like anybody else, or ...
• ... they are a ‘Defined Office Holder’. This may affect, for instance, the trustees of children’s charities.

What an ecclesia or camp will have to do is to 'register an interest' in each of its youth leaders. What this means is that if subsequently someone is barred by the ISA from working with children, the ecclesia will be informed. To do this an ecclesia will have to provide the individual's registration number and date of birth, and it will require the individual's consent. 'Registration of interest' is now being referred to as subscribing (although not exclusively).

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12. What is the difference between a CRB application and ISA registration?

To register with the ISA you will need to have an enhanced CRB check. so there's quite a lot of overlap. But there are benefits as well:

• You will only have to register with the ISA once, whereas CRB checks expire and have to be repeated.
• You will only have to register with the ISA once, whereas in the past CRB checks had to be carried out for each organisation you worked for.

The Government is planning to look again at the requirement for CRB’s once ISA registration has come in.

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13. Who needs to make sure people working with children or vulnerable adults are registered?

It will be the responsibility of each ecclesia to make sure that its Youth Leaders have registered.

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