by Josephine Stein

What is the purpose of safeguarding? What and who exactly is safeguarding for in the Church of England and what is at stake? And how can one assess how well structures, processes and people achieve safeguarding objectives?
The best way to understand ecclesiastical safeguarding is to benchmark its practices against other sectors which have proven successful, such as aviation and healthcare. The aviation industry rewards workers for promptly reporting dangerous situations, including those arising from their own mistakes. Professionalism underpins patient safety and well-being in the healthcare sector, with the General Medical Council setting standards for the professional duty of candour (www.gmc-uk.org). This requires healthcare professionals to inform patients, as well as their colleagues, employers and relevant organisations, when things go wrong and how they are being set right (see Matthew Syed, Black Box Thinking).
What a contrast to the Church!
Safeguarding in the Church is adversarial, requiring those who suspect problems to report them to their Diocesan Safeguarding Advisor / Officer. The DSA/O can then instigate a process which is protracted, expensive and damaging to just about everyone involved. Survivors are often forced to drive the complaints process while the Church delays, obscures and frustrates the process. The Clergy Discipline Measure is unsuitable for responding to safeguarding allegations and has been weaponized against innocent clergy. Many of the people who ought to be protected are severely harmed, most notably survivors, but also the accused.
A large operation exists to control safeguarding, generating numerous policies and guidelines along with periodic compulsory training, ‘lessons learned’ reviews (including PCRs 1 and 2) and compliance audits.
‘Standards for the Professional Conduct of the Clergy’ do not address self-reflection in clergy nor behavioural standards of ministry, let alone a professional duty of candour.
Perpetrators may be shunned but are not cared for in the way one would expect of a Christian institution; care for survivors is perceived as grudging and inadequate. According to former DSA, spiritual director and psychotherapist Fiona Gardner, the institutional Church has a corporate personality resembling those of individual perpetrators of abuse (Gardner, 2021). Not surprisingly, 100% of a sample of 2,000 survivors reported that the Church’s responses to disclosures were worse than the original abuse.
What lessons are being learned? Are we any safer as a result of Church safeguarding activities?
Much has been said and written about the need to change the culture of the Church, but what this means is very unclear. It may take a very long time to effect widespread behavioural change and confidence in safety if left to the powers that be.
Meanwhile, how can the Church’s safeguarding activities achieve better value for money?
Assessing the state of the Church’s safeguarding culture and of ‘value for money’ needs to be provided by an evaluation conducted by independent professionals, following a clear and inclusive methodology. The process involves gathering input from all groups of people affected by safeguarding, and collating views including both shared and differing understandings. Those who have been abused (survivors) represent the most important group in an evaluation as ‘end users’ of safeguarding practice, along with the small proportion of clergy who have been falsely accused of abuse.
Who are the other stakeholders? In addition to perpetrators, PCCs and congregations, there are safeguarding professionals, lawyers, trainers, reviewers, administrators and insurers; and clergy such as parish priests, cathedral canons and deans, archdeacons and bishops.
Stakeholders would be asked what they believe the specific objectives of safeguarding currently are and ought to be. All will have views on this as well as on the effectiveness of safeguarding systems currently in place. And all will have particular interests of their own which are not necessarily articulated.
The next step is for the evaluators to identify verifiable objectives. These will reveal which safeguarding systems and structures are working well and if not, what remedial steps would be required. Not least, evaluators will see how spending maps onto safeguarding objectives.
To identify value for money, evaluators need to gather data on safeguarding spending. This has been notoriously difficult to pin down as the Church either does not collect the relevant statistics centrally, nor necessarily provide information, for example to General Synod, on safeguarding expenditure by the National Church.
However, it is possible to estimate safeguarding expenditure by the dioceses and the National Church Institutions (NCIs) ahead of a full evaluation, because the main element is personnel. A survey of all 42 diocesan safeguarding webpages showed that they employ 182 DSAs, assistants, trainers, case workers and administrative assistants. Some work part time, but other Church officers serve on core groups/case management groups or support safeguarding through their other roles such as membership on Diocesan Safeguarding Advisory Panels and General Synod; archdeacons have coal-face responsibilities and consultants are brought in e.g. to conduct case reviews, for risk assessment and to deliver training – and there are costs associated with time attending training sessions. Salary data can be estimated from sampling job advertisements.
In response to a General Synod question (Tim Bull, November 2021), data were provided on the staff on the National Safeguarding Team (NST) and gross expenditure from 2016 – 2020; these can be extrapolated. The NST currently employs 26.5 FTE staff/consultants and spends approximately £4.4 million/year. Other NCI staff having safeguarding as part of their portfolio come from comms, ministry, legal and HR departments. Members of the National Safeguarding Working Group based in Church House service the National Safeguarding Steering Group and contribute to safeguarding work by the Archbishops’ Council, the House of Bishops, General Synod and other bodies.
Reputational managers and external lawyers, who in turn contract medical experts for advice in civil cases, also add to the costs of safeguarding along with insurance. In addition, the Church brings in consultants and temporary staff to conduct audits and Past Cases Reviews, plus ‘lessons learned’ reviews in cases of major safeguarding failures. Although precision is difficult, costs estimates are possible based on information in the public domain, familiarity with consultancy rates and indicative research data.
Bishops’ expenses are covered by the Church Commissioners, who paid for external lawyers involved with IICSA.
There are safeguarding meetings, ‘Safeguarding Summits’, conferences and workshops (although blended and online meetings have lowered costs).
There are also payments to survivors bringing civil suits, through the Interim Support Scheme plus money for counselling and therapeutic support, most often from dioceses.
It goes beyond the scope of this particular exercise to make detailed estimates of current safeguarding expenditure; it might come to about £30 million/year for the Church as a whole. However, one thing seems clear to me. The CofE safeguarding apparatus employs or contracts a great many people in an ever-expanding process with the creation of more new and revised policies, more updated training, more reviews, more audits and a concomitant increase in expenditure. There is a proliferation of new bodies (Safe Spaces, the National Safeguarding Panel, the Interim Support Scheme, the Independent Safeguarding Board and a Redress Fund under development) that together consume a great deal of time and money; they employ or contract more and more people.
What safeguarding achievements can be attributed to each activity? Does the associated expenditure represent ‘value for money’? A comprehensive, independent evaluation would need to answer these questions. However, based on my experience as research director for an evaluation of a 25-country European programme with structural similarities to the CofE, I would expect that savings of at least half of current expenditure could be achieved if the Church’s safeguarding structures and activities were to be rationalized. Some of the money saved could be redirected towards achieving the verified objectives identified by the evaluators as insufficiently resourced.
Church safeguarding culture can be assessed through (1) examining IICSA evidence; and (2) benchmarking against other denominations and secular sectors such as aviation and healthcare whose safety records outperform the Church.
Safeguarding cannot simply be a matter of complying with edicts handed down from the National Church. The objectives of safeguarding need precise articulation, along with their respective importance / value.
All the laws in the world do not prevent crime; nor does the Church’s adversarial approach to safeguarding protect survivors or those facing allegations – along with their families and congregations.
We must never forget the ‘core business’ of the Church. It is Christianity. Living the faith involves confession, repentance, efforts to set right the damage done and asking for forgiveness. Christians are expected to take responsibility for their sins – and for the harm done to others. A hierarchical system based on adversarial processes to deal with safeguarding failures is inherently dangerous. And the trend towards employing more non-Christian people with secular work experience based on putting adherence to rules ahead of the well-being of people exacerbates the dangers at the expense of the vulnerable. We need to put the love of God and of our fellow human beings first, as Jesus did when healing on the Sabbath. That is our calling and our discipleship.
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Dr Josephine Anne Stein
Independent researcher, policy analyst and survivor of ecclesiastical abuse