The new vetting and barring scheme to protect children, launched in October, was greeted with mass confusion. Despite the complexity of the issue, the Independent Safeguarding Authority did not publish its guidance on the scheme until the day it was launched.
Even lawyers are struggling to understand the rules. It's not surprising, because even the ISA itself appeared to be unaware that the new regime would be so wide-ranging.
Sir Roger Singleton, chair of the ISA, is now reviewing the scheme.
The intent behind the legislation is laudable. The existing Criminal Records Bureau scheme is wholly inadequate, offering only a snapshot in time of a person's criminal background. Now, anyone wishing to work closely with children or vulnerable adults will, over a period of five years, have to register with the ISA.
But is the Government's new approach proportionate? It is vitally important to protect vulnerable people, but the sad truth is that no amount of regulation can stop abuse. Nursery worker Vanessa George's horrific crimes would not have been prevented under either system, because there were no prior concerns and she had no criminal record.
Children are more at risk of being sexually abused by a member of their extended family than by a teacher or care worker.
And the new rules are arbitrary: a volunteer who works with children once a month will be required to register, but a person who volunteers every five weeks will not.
Currently, if a volunteer sports group asks parents to transport children, they will have to register. But if the parents themselves decide to drive the children, they will not. In real life, the parents may well be the voluntary group. So do they need to register? No one knows. Confusing? Yes.
This is bound to affect volunteering. Many authors, including Philip Pullman, have refused to visit schools. It has been argued that people with nothing to hide should not object to registering, but this is missing the point. If the new scheme deters volunteering, then we are betraying children, not protecting them.
Already there is a dearth of male primary school teachers. This is tragic - as is the fact that many men would not pick up a child that has fallen over for fear of a false accusation.
The Government has a vital task ahead of it. We need a better system - that is not in dispute. However, a requirement to register that corrodes normal relations between adults and children fails us all.
Rosamund McCarthy writes in a personal capacity.