1. We are organising a camp working with young people from a number of sending churches. Do we need a separate child protection policy?

Every organisation working with children needs a policy relevant to their circumstances and range of activities. Our model policy can be adapted for special events. Parents, young people and the sending organisation must be made aware of the safeguarding policy and who they should contact if they have concerns. With some joint events it might be sufficient to act under the policy of one of the participating churches or organisations. Where several groups are involved together in an activity it will be important to work within one set of policy guidelines and this should obviously be agreed by all participating groups before the event takes place.

2. On the subject of keeping records, we have included this statement: ‘All documents related to those working with children in the church must be kept securely and for an indefinite period.' The deacons have expressed concern about this. How long is ‘indefinite'?

Much of the advice about keeping records for an indefinite period originates from insurance companies policies. The reason behind this is that many allegations of abuse are of an ‘historic’ nature. It can be years after an alleged incident that an adult makes a police statement. A church can be asked for information about something that may have occurred ten, twenty, or even thirty years previously. Any records from that time could be helpful to a police/social services investigation. This information could also be helpful to the church if legal action were then pursued on the grounds of negligence.

There is no time limitation on the investigation and prosecution of criminal matters. For a civil claim any action will generally have to be brought within three years of the alleged incident and where a child is concerned, by the age of 21 (i.e. within three years of becoming an adult). Having said this, courts can and do waive this requirement, in recent cases by as much as 30 years! The possibility of a negligence claim can never be ruled out, and it follows that any records maintained by the church could be an important part of a defence. In particular records need to be kept concerning any allegation of abuse and the action that was taken by the workers involved. It will be helpful to retain old copies of the church’s child protection policy because producing such a document could be evidence of good intentions, even if it might have fallen short in practice. The more information on record that a church has about the child protection process, training, details about workers etc, in existence at the time, the more helpful this will be for all those involved. It is important not to try to cover up inadequacies. If a church is found to be culpable then the due process of law must run its course, but in exercising good sense child protection and complying with insurance policies, this offers the best protection for both a child and the church/organisation involved.

If you were to ask a lawyer how long you should keep information, then in all probability they would tell you for the lifetime of the child. In fact, so far as statutory bodies providing services for children are concerned, they are required to maintain certain information for 70 years.

3. Can we register our child protection policy with CCPAS?

We require copies of all documents produced from our material to be registered with us for copyright reasons (see below). We are also happy to hold any policy even if it is not based on our model policy. All policies should be reviewed at regular intervals, so it is important to keep us up to date too, by submitting revised documents as and when they are produced. We will keep the latest version of the policy for two years and we work on the assumption that if we have not received a revision within that period of time, then it will be out of date anyway.

4. Can you check over our policy and provide detailed comments?

If the policy is based on our current model, all the essential areas will be covered. If you are unsure about any point, then you can always ring our helpline. If a more detailed assessment of the policy is required we will happily do this, though a charge will be made.

5. Can another church/organisation use our policy to help them prepare their own?

This is not something to which we can agree. The policy is copyright material and we have, in the past, received serious complaints where, for example, a church has copied another church’s policy making subtle changes which conflict with good child protection practice. Such a policy, which ‘appears’ to be based on the CCPAS model, could bring this organisation into disrepute. It is also important to remember that working practice is changing all the time and it is essential that churches and groups are using our latest recommendations. Contact should be made directly with us so that we can supply the manual direct to the organisation/place of worship.

Finally, every church or organisation is unique. A policy that has been prepared specifically for a certain group, by necessity will miss out or include areas that are not relevant to another. This is why each policy must be group specific.

6. Should we make a copyright statement?

All policies produced with the help of our model either directly or indirectly should contain the following statement:

‘This document is based on a Model Child Protection Policy supplied by the Churches' Child Protection Advisory Service. A copy of the policy and all amendments will be filed with CCPAS. This Policy must not be copied by other churches/organisations without the written agreement of CCPAS.'

7. Can we place our policy on our website?

For the reasons already given in the last question, we are unable to agree to requests of this nature. It is important for your church or organisation to make general statements to the effect that:

• you take child protection seriously
• there is a detailed policy in place following recommended good practice
• a copy is available for inspection in the church office.

You could state that the policy is based on CCPAS model policy and even provide a link to our website.

8. We have been requested by Children’s Social Services to alter our policy so that all concerns are referred to Children’s Social Services rather than our workers contacting CCPAS for advice. Must we comply with this request?

Whilst we understand Children’s Social Services’ reasons for making this request, there is no obligation to do this if you prefer to use the CCPAS model policy as it stands.

Children’s Social Services could be unaware of the professionalism and expertise of CCPAS and apprehensive about referrals being made to a non-statutory child protection agency. They may well need reassuring about CCPAS’ role and the basis on which we deal with such concerns.

CCPAS is the lead Christian child protection agency.  The model safeguarding policy in our manual, ‘Safe and Secure’ was previously endorsed by the Department for Children, Schools and Families (now known as the Department for Education).  Our organisation employs Social Workers experienced in child protection, and who have worked for local authorities for many years.  All our advice will be confirmed in writing.

Sometimes, it will be apparent that a child could be at risk of significant harm and you will have no doubt about the need to contact either Children’s Social Services or the Police. In other cases, such as poor parenting, the situation is less clear, and you may wish to take advice. Sometimes individuals are reluctant to contact the authorities direct and this is where CCPAS can be of help because we offer ‘independent’ advice. Social Services Departments have received a bad press (sometimes quite unjustifiably), and it’s not always easy therefore to make that first call. This is particularly true if it means contacting them without consulting the parents (as is often necessary) and perhaps in circumstances where the individuals involved are part of a church community. There is evidence that, without our advice, some calls would just not be made.
Another reason people contact us is because we provide an out-of-office hours service. Although in theory Children’s Social Services offer the same, it is not always as accessible with less staff to deal with referrals. We have been able to reassure callers on the action they should take, either waiting until the Social Services Department offices are open again or if immediate action is required giving advice on what they should do.
The important thing is that workers are able to respond promptly to concerns, whether or not they phone Children’s Social Services, Police or CCPAS in the first instance, being assured of our support whichever agency is contacted.

9. We would like to reproduce information from CCPAS’s safeguarding Manual ‘Safe and Secure’ (or some other CCPAS publication). Can we do this?

If you are including a quote of up to 50 words, then we are happy for you to do this without prior permission, on the proviso you acknowledge the source and quote CCPAS contact details. We also ask that you send us a copy of the publication when produced. Prior consent is needed for longer passages and full articles. We will normally agree to this because we want our information to be circulated to as wide a readership as possible, though please bear in mind that sometimes the copyright may belong to another organisation. The model policy and forms contained in ‘Safe and Secure’ are designed to be adapted for use but please observe the conditions set in the manual and ensure these are respected in any document produced. Applications should be made in writing (not by e-mail) to the Director of CCPAS, P O Box 133, Swanley, Kent BR8 7UQ.

10. Our building is let out to groups that have nothing to do with our church. Although we have our own safeguarding policy, would we be responsible if, say, a child was accosted by someone also hiring out a room on the premises who has nothing to do with the church?

Although in one sense we all have a ‘duty of care’ and we do what we reasonably can to safeguard children and vulnerable adults, the prime responsibility for a child should be with the carer concerned. So someone hiring the premises would need to take responsibility for ensuring the safety of any child in their care. However, your church should make it clear what it provides (e.g. use of toilets/kitchen facilities) and make sure the premises is safe. Also the hirer should agree to abide by your church’s safeguarding policy if they do not have their own or it is inadequate. In terms of a hirer reporting possible abuse, you should act in the same way as any allegation and in accordance with the church’s safeguarding policy.

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