Children's charities do not doubt that a recent £330m overhaul of the vetting procedure for people working with children and vulnerable adults will improve security. But their enthusiasm is tempered by fears that the new system could create a false sense of security, might contain loopholes and could discourage potential volunteers.
Under the existing system, an employer recruiting someone to work with children or vulnerable adults applies to the Criminal Records Bureau for a 'disclosure' showing a candidate's current and spent convictions, cautions, reprimands and any warnings held on the Police National Computer. An 'enhanced disclosure' also includes "any relevant and proportionate information held by the local police forces". The employer can then decide whether the candidate is suitable.
The Independent Safeguarding Authority, created as a result of the Safeguarding Vulnerable Groups Act 2006, takes things one step further: it seeks to bar unsuitable people.
From 12 October 2009, anyone starting a new job that involves working with children or vulnerable people will have to register with the ISA at a cost of £64 (Third Sector Online, 2 April). The ISA will assess applications using information gathered by the CRB and, if it deems them suitable, will register them. Records will be updated automatically for life - unlike CRB checks - and registrations can be withdrawn if new information comes to light.
Registration of people already working with vulnerable people will start with those whose CRB clearance dates back furthest. Once the system is fully operational, employers will be allowed to take on only registered people. They will still be able to apply for enhanced disclosures.
Most agree that the new system will be an improvement. But even enthusiasts admit that it is not perfect.
Zoe Hilton, child protection policy adviser at the NSPCC, says that charities will have to be wary of assuming that everyone who is registered is suitable. For example, the CRB won't have a record of people with criminal records in other jurisdictions, or offences that do not lead to a criminal record, such as speeding penalties. She adds that, although initial ISA registration requires enhanced disclosure, the ongoing monitoring may not go into this level of detail.
But Hilton welcomes the fact that the new rules focus on the type of contact the person has with the vulnerable person, rather than on the type of organisation they work for.
"If it all runs smoothly, decisions will be made on actual evidence of risk, rather than what list a person happens to be on, so this should allow for higher standards and greater consistency," she says.
However, she is not in favour of the rule that allows people on the ISA's barred list to be involved in 'controlled activities', defined as support work such as catering and reception work or roles that involve access to sensitive information about vulnerable people.
"We don't think that makes any sense," she says. "It muddies the water and makes assumptions about risk."
Iain Millar, deputy director of human resources at children's charity NCH, agrees that the system is an improvement, provided employers are vigilant. However, he says the cost of the scheme is disappointing for charities. "During the consultation period, it was suggested that costs would not rise above those for the CRB check," he says.
Registration will be free for volunteers, but some groups are concerned that the scheme will discourage them. "CRB checks in themselves are very off-putting for senior volunteers, ex-offenders and people who value their privacy," says Dame Elisabeth Hoodless, executive director of volunteering organisation CSV.
But Kate Engles, policy and information officer at Volunteering England, says: "One of the things that previously put people off volunteering was the need for duplicated checks, and this will remove that need."
The Home Office is unable to say how long the scheme will take to phase in, or how long the registration process will take for each of the 11.3 million people in England, Wales and Northern Ireland who will need to register (Scotland will have an equivalent scheme).
The department says it will run advertising, hold meetings between stakeholders and ISA officials, and send direct mail and email updates in the run-up to the launch. But Engles warns that charities shouldn't wait until 2009: "They must start reading about it now so that they are fully prepared."
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