
by Anon
The latest diocesan guidelines for ministry in our local church have just come though the letter box. It is exactly the kind of thing you’d expect to read. It is a document drafted with “legal support” from the diocese, and by our “safeguarding team”. My reaction to the document, as a clergyperson, was one of fear and incredulity. The letter and document tells me that failure to comply could result in the loss of my ministry, and perhaps in criminal prosecution.
Some of the letter is very sensible, albeit lacking legal nuance. I am told that the definition of a child is “anyone under 18”. I have a small youth group that are under-18s, and am keenly aware that the age of consent is 16. The laws on the consumption of alcohol are rather grey at the best of times, and once a child reaches the age of 16 they can join the armed services, and will soon be able to vote. They can drive a car at 17, and with parental permission, marry at 16. Treating a 17-year-old as a child in any church youth group doesn’t seem very smart to me, but I understand the need of the diocese to be risk-averse.
The definition of a vulnerable adult (or protected adult) advanced by the diocese is also vague. The diocesan document says “temporary impairment” could place any adult in this category. So it will cover anyone recently bereaved, or struggling with some other serious pastoral or personal crisis. (I think to myself, the church is full of such people all the time, and all of us who minister, including me, fall into this category – surely the church is a God’s field hospital for the broken?).
My diocese says that everyone who ministers in the congregation is now required to be regulated according to the new guidance. If someone is in regular contact with children or vulnerable/protected adults in any interface that is “ministry”, this requires “authorisation” by the bishop. Ministry is defined as “anyone who has regular contact providing religious activities”. That could be overseeing the orange squash and biscuits for the children after church. If that is a regular duty, and there is a rota, then this falls within the regulatory framework, and so volunteers who are on the rota need to trained and subject to the criminal bar (DBS) checks.
The guidance acknowledges that someone stepping in to help on this rota as an emergency to fill a gap would be acceptable. But if that person is regularly helping, they need to be checked, regulated and licensed/authorised. Anyone with “regular contact” in any sphere of ministry with children or protected/vulnerable adults is now subject to such regulatory scrutiny.
The diocese tells me that this is my responsibility. It also tells me that in the church “safeguarding is everyone’s responsibility”. All of this is presented as “new guidance”, though please note, it is not guidance, because the threats and penalties for not following it make it clear that these are mandatory stipulations.
My diocese also has some other mantras that appear, on the face of it, to be unrelated to the new safeguarding .guidance. We have been repeatedly told – I cannot remember a decade of my ministry when the bishop at the time has not said – that we are to encourage “every-member ministry” in our churches. That “all Christians have a ministry and vocation”. That the church – especially the laity – have to be “released” to discover what ministry they have. And that being part of the church is to belong “to the whole ministry of the baptised people of God”.
If this is true, then I think to myself, not unreasonably, that it would appear that everyone attending church, unless very occasionally or just very casually, needs some kind of licence to enable them to be part of a congregation. After all, if they are doing so regularly, they must have some kind of ministry and vocation.
Anyone could find themselves ministering to a bereaved person who happens to come to church, and simply asks for prayer and consolation from the person they are sitting next to. I’d hope most of my congregation would know what to do, and could extend compassion, help, support, prayer to such a person. (But please note, the new guidelines from my diocese say that anyone sitting in the pews faced with this kind of pastoral situation should immediately find the licensed or authorised person to respond to the person in need, and absolutely not step in – so the bereaved must be left until the correctly vetted respondent is found).
Then I think of those in our congregation for whom the legislation and ‘guidance’ ostensibly protects. Our youth group takes an evening service once a month, and it ministers powerfully to the rest of the congregation. Those who are retirees and of advanced years find the energy and exuberance of the youth-led services to be inspiring and moving, and a young person will often deliver a short talk that rouses the congregation. Does the youth group leading the worship and the ministry like this need to be vetted by the diocesan safeguarding protocols? Or should such ministry not be allowed, as the youth are all under-18?
Every week the Sunday School children give us feedback – within the worship – on what they have learned. Many adults in the congregation can find this more inspiring and moving than the sermons. Jesus and the New Testament had some important things to say about the wisdom that comes from the (seemingly) young and foolish. I wonder if these short, regular children’s slots in worship need vetting?
And we do have some in our congregation who are, quite clearly, protected or vulnerable adults. They have a range of physical and mental disabilities, and live in either nearby sheltered accommodation or a local care home. They vary in age from young to old. They always come with their carers or are accompanied by family and friends. But they have a ministry in our congregation too. Some take a slot by being on welcoming duty, in leading our intercessions, or being on the rota for reading one of the lessons. Without fail, the rest of the congregation testify to how much this ministers to them. So I find myself asking who is offering the ministry here, and who is being ministered to?
If I read the guidance from the diocese correctly, it operates with a prevailing presumption that he able-bodied and ‘mentally-normal’ (for want of a better phrase) are the those who need to be licensed, and those who are less able or classified as children or vulnerable are the ones to be protected. But the experience of my own church suggests that this paradigm doesn’t work. We minister to each other.
The safeguarding guidance we have seems to have missed the quiet revolution in disability theology that has matured in power and influence over the last 25 years, and which grew out of secular developments in disability studies. The guidance also seems peculiarly ignorant of the literature in the field. I think of Nancy Eiesland, The Disabled God: Towards a Liberatory Theology of Disability (Nashville, Abingdon Press, 1994). Or of Josie Byzek’s assertion that “people have disabilities because people are human – impairment is a natural part of the human state.” We all have vulnerabilities. That is part and parcel of what being a human is.
To begin with, disability theologians had focused on issues of accessibility of places of worship. But the same theologians would later argue that theological reflection on disability could not be limited to questions of rights and access alone. They began to question the underlying theological anthropology of Christian churches. Theologians such as John Swinton, Brian Brock and John Hull have written powerfully and persuasively in this field. Part of their argument is that the majority of theologians in history were ‘able-bodied’ and that, therefore, the experience of disability had not been taken into account in the development of doctrine.
For example, in John Hull’s case (a theologian who gradually went blind), he showed how most theologians had developed negative biblical hermeneutics on the metaphor of blindness. But that only works because the people writing the theology were sighted. Hull developed a hermeneutic that narrated blindness in a more positive theological light. (John Hull, In the Beginning There Was Darkness: A Blind Person’s Conversations with the Bible, London, SCM Press, 2001).
The new diocesan safeguarding guidelines seem to be oblivious to these major developments in theology. And it reminds me of the puzzling ‘Q&A’ that features in Luke 10: 10:25-37. A lawyer asks Jesus, “Who is my neighbour?”. Jesus answers the lawyer’s question with a story about a good Samaritan – a person who would have posed all kinds of ritual, tribal, religious and implied threats and risks to the victim of the story, who would have been a God-fearing Judean.
One important feature of the parable is that the Samaritan would have been perceived as posing an additional threat to the most vulnerable individual in the parable. So we could argue that in being perceived as a potential threat to the victim, the Samaritan also renders themselves vulnerable. Come to think of it, I find it hard to imagine any ministry that does not involve some risk and vulnerability on the part of those giving or receiving. So, having taken another careful look at the new diocesan guidelines on safeguarding, I have concluded the following.
First, the guidelines assume that all ministers are able-bodied and in a constant state of optimum mental stability, and thus not vulnerable persons. To me, this seems a paradoxically vulnerable and exposing position to inhabit, and a theologically elitist way of understanding ministerial roles. It is almost bound to create additional cultures of risk rooted in dangerous fantasies of impeccability. Even if such projections are rejected by the minister, others could hold the minister accountable to them, and ask the church hierarchy to weigh and judge a minister against them.
Second, our children and vulnerable adults undoubtedly have ministries, and the scriptural witness affirms that factors of age, infirmity, capacity and agency do not inhibit any person from being an agent of God’s grace. They can plainly minister with considerable power and impact. If any person who meets this criteria has a regular slot or designated role (e.g., reading a lesson, welcoming duties, leading prayers, etc), then the diocesan guidelines on safeguarding say that these persons should be vetted, regulated and licensed.
Third, since it is hard to exempt any person attending church from processes of diocesan authorisation – the bar is set very low as “regular contact with children or protected adults in any recognised role…” – who in my congregation is exempt from this? If safeguarding covers everything, then surely it is nothing? Unless, of course, everyone attending church as part of the ecology of every-member ministry needs vetting and authorising, simply in order to fulfil their vocation as a faithful Christian.
Having read the new diocesan safeguarding guidelines, and as a minister, I can only say that I feel vulnerable and unsafe as never before. But the same guidelines make no provision for me in what has clearly become an extremely precarious role.








