Agenda Item 5B Page 45

Agenda Item 5b Page 45

b Children and Young Peoples Scrutiny Sub-Committee June 2008

Action Plan Progress Report following Audit Commission Audit of Children and Young Peoples Service against Bichard Recommendations

All Wards

Report authorised by : Phyllis Dunipace Executive Director Children and Young Peoples Service

Executive summary

The Audit Commission conducted an Audit of Lambeth Children and Young Peoples Service (CYPS) to evaluate progress being made in implementing the findings from the Bichard Inquiry which was set up by the Government to identify failures following the murder of Jessica Chapman and Holly Wells by Ian Huntley in Soham in 2004. There had been public disquiet when it was discovered that Ian Huntley had been known to the authorities over a number of years.

The Audit of Lambeth CYPS took place in late 2006 and reported in early 2007. Since that time a Steering group headed by the Divisional Director of Children’s Social Care Yashi Shah has implemented an action plan designed to deliver the recommendations of the Audit. This report outlines the progress made to date in delivering the recommendations of the Audit.

Many of the recommendations made in the Bichard Inquiry are now included in statutory guidance and London wide procedures, and responsibility for this work is now included in the governance arrangements of Lambeth Safeguarding Children Board (LSCB) which has a dedicated inter agency sub committee for this area of work.

Summary of financial implications

None Recommendations (1) That Committee note the progress being made in implementing the recommendations of the Audit Commission Audit against the Bichard recommendations. (2) That Committee instruct officers to prepare a further report in 6 months.

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Consultation

Name of Directorate or Organisation Date sent Date Comments consultee to response appear in report consultee received para: from consultee

Internal Phyllis Dunipace Executive Director of Children 28.5.08 and Young Peoples Services Fateha Salim Head of Legal Services 28.5.08 Farrukh Akbar Divisional Director Resources 28.5.08

Report history

Date report drafted: Report Date report sent: Report no.: deadline: 26.05.08 06.06.08 30.5.08 76/08-09 Report author and contact for queries: Cathy Blair Assistant Director Social Care 020 7926 4526 [email protected]

Background documents

An Independent Inquiry Arising from the Soham Murders - Sir Michael Bichard

Implementation of Bichard Recommendations - Audit Commission Report into London Borough of Lambeth 2006-07

Appendices

Appendix 1 London Borough of Lambeth Action Plan to implement recommendations arising from Audit Commission Report 2007

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Action Plan Progress Report following Audit Commission Audit of Children and Young People’s Service against Bichard Recommendations

Context

1.1 Following the murder of Jessica Chapman and Holly Wells by Ian Huntley in Soham, Cambridgeshire there was widespread disquiet when it became clear that Ian Huntley had been known to the authorities over a number of years. The subsequent Bichard Inquiry into the child protection procedures in Humberside and Cambridge Constabulary was particularly critical of data handling and vetting arrangements in these two bodies. In addition to criticism of the police, the Bichard report published in June 2004, was critical of North East Lincolnshire Social Services Department for the lack of sharing of information with other agencies, including the police. The Bichard report noted that the interview and recruitment processes which led to Ian Huntley’s appointment at Soham Village College were also flawed. The parallel Serious Case Review 1 focused on a number of concerns regarding the way that Social Services, Schools, Education Departments and the Police exchanged information regarding allegations made against Ian Huntley.

1.2 The Audit Commission audited Lambeth Children and Young Peoples Service against the key recommendations of the Bichard Inquiry in late 2006, reporting in early 2007. Children and Young People’s service responded to the recommendations arising from the Audit through an action plan (Appendix 1) and the progress to date is reported below.

Findings of Bichard Inquiry

1.3 In summary the key issues for the relevant services for children and young people and police authorities arising from the Bichard and Serious Case Review Reports were as follows:

• There were inadequate arrangements in place to identify individuals whose patterns of offending behaviour cause concern

• Agencies need to share intelligence on potential causes of concern more effectively

• Poor document retention arrangements undermine the ability to identify full case histories

• Inadequate training in procedures for reporting concerns for staffing contact with vulnerable children can prevent their early identification

Audit Commission Process in Lambeth

2.4 The lead inspector interviewed a number of staff and read a number of documents to arrive at his findings. The staff and managers that were interviewed were as follows:

1 An independent review conducted by the Local Safeguarding Children Board whenever a child dies and abuse or neglect is suspected or confirmed

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• A set up meeting with the Executive Director, and members of the senior management team

• Interviews with senior managers

• Key social services staff responsible for writing policies, securing compliance and commissioning

• A secondary school head teacher

• Directorate, and corporate HR leads

• PCT as statutory partner

Key Lines of Enquiry, Recommendations and Progress

2.5 The Audit Commission audit of London Borough of Lambeth focused on 8 key lines of enquiry. These are identified below, together with the recommendations arising from the audit and progress to date.

Key Line of Enquiry

2.6 General Approach – how has Council tackled Bichard ?

Recommendations Arising from Audit

R1 Identify an individual with overall responsibility for implementing the Bichard Recommendations

R2 Put in place a steering group with representatives of relevant staff groups and an action plan for establishing clear responsibilities and monitoring progress

R3 Update the publication ‘There and Back Again’ with relevant references and guidance on the Bichard recommendations

Progress to Date

A steering group chaired by Yashi Shah Divisional Director for Children’s Social Care was established and Yashi Shah was identified as the lead officer for this work in the short term. From January 2008 the responsibility for progressing the work plan was transferred to Lambeth Safeguarding Children Board (LSCB) and a multiagency group chaired by the Assistant Director for Safeguarding within Social Care is responsible for continuing progress under the governance of LSCB. The Lambeth publication ‘There and Back Again’ which is a guide for schools involved in providing outdoor education and organising educational visits for children has been updated to reflect Bichard guidelines and re circulated.

Key Line of Enquiry

2.7 Has a policy for reporting to the police incidences of alleged criminal offences or concerns regarding potential abuse been put in place?

Recommendations Arising from Audit

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R4 Produce an easily accessible summary of the policy for reporting to police for all for reporting to the police incidences of alleged criminal offences or concerns regarding potential abuse of children

Progress to Date

The All London Child protection procedures were launched in February 2008, this launch attracted over 200 professionals across Lambeth including the statutory and voluntary sectors and faith communities. The procedures include clear procedures for all staff to follow regarding the reporting of criminal offences against children.

The LSCB safeguarding leaflet has been distributed council wide to raise awareness of everyone’s responsibility to report and respond to child abuse. A new screening form is included in the social care software for recording abuse and training has been provided to managers. In February LSCB launched a policy guidance on sexual exploitation of young people which re inforces best practice, and training on this and other safeguarding issues is ongoing.

Key Line of Enquiry

1.7 Have all staff who have contact with children received appropriate guidance and training in the application of that policy?

Recommendations Arising from Audit

R5 Raise awareness of training opportunities and monitor attendance to ensure priority staff receive training and there is comprehensive coverage of all staff who have contact with children

Progress to Date

National online training has been available to Head teachers and school Governors since July 05. This has been publicised in the Lambeth ‘Working Together’ newsletter. Heads and Governors have voiced a preference for traditional training sessions over online sessions. Three members of staff at Lambeth have been accredited to deliver this training (it can only be delivered by accredited trainers). 84%of schools now have at least head teacher or governor trained, 3 further sessions are taking place in June, which will target the 9 remaining schools.

An article regarding Bichard implementation has also been published in ‘Every Lambeth Child Matters’ Training has been provided to senior managers across all agencies, further training is planned from June 2008.

Key Line of Enquiry

1.8 Do record retention arrangements ensure full case histories are available for all children deemed to be at risk?

Recommendations Arising from Audit

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R6 Raise the understanding and awareness of record retention arrangements

Progress to Date

Policies for CYPS on Records Management and Access to Records have been produced and new systems are being implemented, some staff training has taken place. This is being led by Strategy and Performance Division within CYPS.

Key Line of Enquiry

1.9 Is there a clear information sharing policy which is disseminated to all relevant staff? Are arrangements in place to facilitate the sharing of information regarding ‘at risk’ children with other local agencies?

Recommendations Arising from Audit

R7 Implement Lambeth Information Sharing and Assessment Protocol in full as a matter of priority

R8 Review the current understanding and awareness by staff of arrangements to facilitate the sharing of information regarding ‘at risk’ children with other local agencies

Progress to Date

Lambeth Information Sharing and Assessment (LISA) protocol which is a strategic interagency protocol has now been agreed by the Children and Young People’s Partnership Board. The Common Assessment Framework (CAF) has been successfully introduced and over 900 staff across the partnership have received CAF and Information Sharing training to date and a proportion of these places were reserved for social care staff.

Information sharing guidance is contained within the All London Child Protection procedures and included in all child protection / safeguarding training provided by LSCB

Key Line of Enquiry

1.11 Are there arrangements for checking potential staff including those from private and voluntary organisations, agency staff and employees of partners working with the Council?

Recommendations Arising from Audit

R9 Review all guidance and documentation relating to the recruitment and selection of staff involved in work with children to ensure that it is up to date in reflecting the most recent issues arising from the Bichard recommendations and other safeguarding issues

Progress to Date

The following Council policies have been reviewed

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• Recruitment and selection guidelines • Policy and guidance on Criminal Records Bureau (CRB) vetting • Staff code of conduct in relation to CRB checks • Retention of records of allegations against staff • Reference request letter (includes section in relation to criminal convictions)

The policies and procedures relate to permanent and agency staff, reflect the requirements of the Bichard recommendations and have been approved by the project group, CYPS Departmental Leadership Team, Strategy and Corporate Service Departmental Leadership Team and trade unions.

The NHS South East London Shared Services Partnership guidance entitled 'Criminal Records Bureau (CRB) Checks: Disclosure of Information Guidelines' for managers and staff in the NHS was looked at when developing the corporate policy, as recommended by the Audit Commission.

The LSCB Safer Recruitment sub group monitors the safer recruitment practices of partners. All partners confirm that their procedures are compliant with required standards

Ongoing action is being taken regarding commissioned services. Within the CYPS the commissioning framework has been reviewed to ensure that all new contracts set standards for recruitment and allegations management and arrangements are in place for monitoring.

All voluntary organizations commissioned by CYPS will be required to undertake a self assessment of compliance with standards.

Partners are reviewing contract compliance and reporting to LSCB Safer Recruitment sub group

Key Line of Enquiry

1.12 Are there arrangements in place to monitor compliance with the above policies and to investigate cases of non compliance?

Recommendations arising from Audit

R10 Put in place robust arrangements to monitor progress in implementing the Bichard recommendations

R11 Clarify the roles and responsibilities of senior management, HR , internal audit and partnership boards in monitoring arrangements in order to improve transparency about accountability for compliance

R12 Develop the monitoring and review procedures of the Lambeth Information Sharing and Assessment Protocol

R13 Disseminate feedback from monitoring and review so that staff understand the progress made and what remains to be accomplished

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Progress to Date

LSCB sub committee have required each partner agency to undertake self audit against Government Office for London (safer recruitment) standards, the Council and partner agencies report compliance with these standards. PCT and Council have used external consultants to assist in this audit.

Currently each agency is preparing self audit against standards for management of allegations against staff, this requires each agency to report on the transparency of roles within their organisation. The Local Authority Designated Officer Role (LADO) whose role is to receive and monitor allegations made against staff is in place and regular reporting of allegations is made to LSCB. There has been an increase in reporting of allegations against staff across the partnership. This is likely to be as a result of training and awareness raising of new requirements to refer to the LADO when allegations are made against an employee in their personal life that may suggest that they pose a risk to children e.g. domestic violence, neglect of own children.

LSCB sub committee are currently requiring spot audit of recruitment standards by HR departments across partner agencies, and will take responsibility for scrutinising practice through the LSCB governance arrangements.

The Lambeth Information and Assessment protocol has been amended to reflect the requirements of the Children Act 2004, and duty to cooperate which contains a framework for sharing information. This is reflected in the All London Child Protection Procedures and in local protocols.

Information contained in this report reflecting progress against the recommendations will be shared with staff through written briefings.

Conclusion

1.13 Since the time of the Bichard Audit, many of the recommendations made by the Audit Commission have become enshrined in statutory guidance e.g. Working Together 2006 and the All London Child Protection Procedures. The progress made in Lambeth in implementing the recommendations of the Bichard Audit has placed the department in a strong position in the implementation of these new regulations.

1.14 A follow up meeting with the Inspector commended Lambeth on the progress that had been made in implementing the recommendations.

1.15 Compliance of externally provided services with Bichard standards is currently being addressed and systems for audit and contract monitoring are evolving. The LSCB is well placed to scrutinise and monitor this work as part of its statutory function. The commitment of all agencies within the partnership through self audit is demonstrating that progress is being made.

1.16 This is an area of work that requires continual scrutiny and ongoing monitoring, it will feature significantly in the forthcoming Joint Area Review, where attention to safe recruitment, including compliance with CRB checks will be inspected.

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2. Comments from Executive Director of Finance and Resources

2.1 There should be no immediate financial implications resulting from this as the changes are more operational in nature and do not require additional funding beyond what is already available to CYPS and LSCB.

2. Comments from Director of Legal and Democratic Services

3.1 The Audit Commission may, by virtue of section 10 of the Local Government Act 1999 make an inspection of the Council’s compliance with its best value duties under this Act

3.2 The Audit Commission shall report on their inspection and within it may require the Council to take and record any action required under the report

3. Results of consultation

None

4. Organisational implications

4.1 Risk management:

Risk to the organisation are through poor practice in recruitment and selection procedures; information sharing; management of allegations against staff; retention of records.

The recommendations made by the Audit Commission enables the Council and partner agencies and CYPS in particular to ensure that its practice is of the highest standard and that vulnerable children and young people are appropriately safeguarded. Failure to implement these recommendations would the leave the organisation at risk of non compliance with statutory guidance contained in Working Together 2006 and the All London Child Protection procedures, both of which have been published since this audit was undertaken.

4.2 Equalities impact assessment:

The requirements relate to all staff and all children and young people with whom the CYPS is in contact. There are no specific equalities issues, compliance with the recommendations will enable the Council to evidence positive outcomes in safeguarding all vulnerable children and young people.

4.3 Community safety implications: None .

4.4 Environmental implications: None.

4.5 Staffing and accommodation implications:

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4.6 Any other implications: None

5. Timetable for implementation

6.1 As reported all actions have been progressed.

Bichard Recommendations Implementation Action Plan

Recomme ndation No. Recomme ndation made by Audit Commissi on January 07 Priority Context Owner Progress Report Complete d R1 Identify an individual with overall High There was no named individual Divisional Yashi Shah, Divisional Director Social Care, has been given overall responsibility for implementing at the time of the inspection Director responsibility the Social Bichard recommendations. Care

R2 Put in place a steering group with Med No group existed at the time of Divisional A project group, chaired by Yashi Shah, was established in February representatives of relevant staff the inspection Director 2007 and has met on a monthly basis since then. An action plan has groups and an action plan for Social been established and four working groups created to oversee the establishing clear responsibilities Care implementation of recommendations relating to: and monitoring progress. • Safer Recruitment

• Information Sharing Page 55 • Records Management • Training Working group chairs have provided progress updates at every project group meeting R3 Update the publication 'There and Med There and Back Again is Head of ‘There and Back Again’ has been updated and has been sent to all Back Again' with relevant guide published by LBL for Schools schools references and guidance on the schools etc involved in HR Bichard recommendations. providing outdoor education and organising

visits for children. This was last published in July 2003 and contains no reference to or guidance on Bichard type issues. R4 Produce an easily accessible High The Council follows the London Local Integrated Children’s System (ICS) was introduced in October 2006 summary of the policy for Child Protection Guidelines as a Safeguard and includes a record of where a decision is taken not to inform the reporting to the police incidences policy for reporting to police. ing police. LSCB policy on sexually exploited young people has been of alleged criminal offences or There is no executive summary Children’s implemented and training for social care staff about requirement to concerns regarding potential or digest produced for staff. Board report criminal offences to police abuse of children Manager

Commissi on January 07 Priority Context Owner Progress Report Complete d Recomme ndation No. Recomme ndation made by Audit

Agreed with Bichard Inspector that the publication of a ‘Safeguarding’ leaflet for staff will fulfill this recommendation. Leaflet needs to include headline information and reference to policies and procedures. Staff must be made aware that it is their responsibility to familarise themselves with and apply polices and procedures.

R5 Raise awareness of training Med There is a lack of clarity Training Training for School Heads and Governors: Partia opportunities and monitor amongst managers Working • National online training has been available since July 05 to all lly attendance to ensure priority staff regarding which Council Group head teachers and one nominated governor. This has been receive training and there is and staff from other publicised in the Lambeth ‘Working Together’ newsletter comprehensive coverage of all agencies have been • Heads and Governors have voiced a preference for traditional Page 56 staff who have contact with trained. Members of the training sessions over online sessions. Three members of staff at children Lambeth have been accredited to deliver this training (it can only sub group delivering the be delivered by accredited trainers). There have been resource training do not necessarily issues that have affected the delivery of sessions but funding has know this. It was unclear if now been secured a log was being kept, 84%of schools now have at least head teacher or governor trained, although there is a HR 3 further sessions in June data base which may be capable of retaining this Training for other Lambeth staff: data . • HR reported that the electronic training recording system, LMS, has been operational since Nov 2006. This automatically records all training booked via Lambeth Professional Development Centre and individuals can also log any external training on their own record • A Bichard awareness session is now included in the CYPS Staff Induction • Managers across CYPS have been asked to identify staff requiring training at different levels • A Bichard training and communication plan has been developed by the working group and this will be launched shortly

An article regarding Bichard implementation has also been published

Commissi on January 07 Priority Context Owner Progress Report Complete d Recomme ndation No. Recomme ndation made by Audit in ‘Every Lambeth Child Matters’ Training has been provided to senior managers across all agencies, further training is in progress

R6 Raise the understanding and High There is insufficient awareness Records The Records Management group produced a Records Management awareness of record retention across all staff groups of the Managem Policy for CYPS and a records access schedule. A draft corporate arrangements content of ent Records Management Policy has also been developed. The corporate relevant arrangements for record Working data protection officer has advised that both policies are used by CYPS retention or of the importance of Group understanding and following record retention arrangements

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R7 Implement the Lambeth High The LISA protocol was the Informatio The position has changed and LISA protocol is no longer relevant, due Information information sharing protocol for n Sharing to the implementation of the Common Assessment Framework (CAF) Sharing and Assessment (LISA) partnership working at the time Group and associated information sharing policy. Information sharing training Protocol in of the Inspection and it related to is delivered alongside CAF training full as a matter of priority sharing of information about service users between the 900 staff across the partnership have received Information Sharing council and its partners Training to date and a proportion of these places were reserved for social care staff

Information Sharing sessions combined with CAF& Lead Professional training are ongoing. The All London child protection procedures contain guidance on information sharing and this is included in all LSCB training

R8 Review the current understanding High There is a lack of clarity Informatio The All London child protection procedures contain guidance on and awareness by staff of among officers regarding n Sharing information sharing and this is included in all LSCB training. Lambeth arrangements to facilitate the (1) whether the LCPG has Group Information and Assessment Protocol has been updated and agreed by sharing of information regarding been supplemented by CYPSPB 'at risk' children with other local Lambeth specific guidance agencies

Commissi on January 07 Priority Context Owner Progress Report Complete d Recomme ndation No. Recomme ndation made by Audit and (2) the scope of dissemination to staff of any guidance.

R9 Review all guidance and High The guidance used at the Safer All corporate HR policies have been reviewed. The Safer Recruitment documentation relating to the time of the inspection did Recruitme working group has completed an update of: recruitment and selection of staff not sufficiently reflect nt • Recruitment and selection guidelines involved in work with children to safeguarding issues and Working • Policy and guidance on CRB vetting

ensure that it is up-to-date in Bichard recommendations Group • Staff code of conduct in relation to CRB checks reflecting the most recent issues • Retention of allegations against staff arising from the Bichard • Reference request letter (includes section in relation to criminal recommendations and other convictions)

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Training on new HR policies and procedures has been provided to senior managers and further training is planned

The LSCB Safer Recruitment sub group monitors the safer recruitment practices of partners. All partners confirm that their procedures are compliant with required standards

Ongoing action is being taken regarding commissioned services. Within the CYPS the commissioning framework has been reviewed to ensure that all new contracts set standards for recruitment and

Commissi on January 07 Priority Context Owner Progress Report Complete d Recomme ndation No. Recomme ndation made by Audit allegations management and that arrangements are in place for monitoring. All voluntary organizations commissioned by CYPS will be required to undertake a self assessment of compliance with standards.

Partners are reviewing contract compliance and reporting to LSCB Safer Recruitment sub group partia l Action required: • Confirmation of practice in relation to partners commissioned services

R10 Put in place robust arrangements High LCSB The Project Group has been responsible for monitoring progress in Page 59 to monitor progress in implementing the Bichard recommendations implementing the Bichard recommendations From January 2008 the LSCB has taken on responsibility for further developments

R11 Clarify the roles and High This recommendation refers to LSCB The LSCB and its HR sub-committee have responsibility for responsibilities of senior arrangements being in place to monitoring compliance in the long term and providing feedback to management, HR, internal audit monitor compliance with staff groups. and partnership boards in the policies and procedures by staff monitoring arrangements in order and to investigate cases of non to improve transparency about compliance accountability for compliance. The monitoring function was not as explicit or widely understood as is necessary in order to make an impact at the time of the Inspection and there was little if any feedback to staff groups regarding compliance

Commissi on January 07 Priority Context Owner Progress Report Complete d Recomme ndation No. Recomme ndation made by Audit monitoring

R12 Develop the monitoring and Med The LISA protocol was the Informatio See progress report against recommendation 7. The LISA protocol has review procedures of the Lambeth information sharing protocol for n Sharing been updated Information Sharing and partnership working at the time Group Assessment of the Inspection and it related to Protocol. sharing of information about service users between the council and its partners

R13 Disseminate feedback from Med There is little if any The LSCB and its HR sub-committee have responsibility for monitoring and review so that feedback to staff groups on monitoring compliance in the long term and providing feedback to Page 60 staff understand the progress the findings from staff groups. The training working group will monitor in the short term made and what remains to be monitoring compliance so accomplished that the importance of compliance is not under- pinned through the monitoring function.