You can download our full consultation response at the bottom of this page.
The Royal College of Paediatrics and Child Health (RCPCH) welcomes this opportunity to respond to Welsh Government’s consultation on proposed statutory guidance on the Single Unified Safeguarding Review (SUSR) process. We welcome any initiative which strives to improve the safeguarding of vulnerable children, the protection and promotion of children’s rights, child protection per se, and outcomes for vulnerable children.
For those reasons, we are pleased to see this work going ahead.
Ensuring children are seen and heard
- In principle this statutory guidance is a good idea.
- The implications of the statutory guidance could bring with them unintended adverse consequences as one size does not necessarily fit all.
- Richer data and the potential for wider aspects of safeguarding the child needs to be considered further.
- The process seemed to be a little generic and the child element of this may not get as much time.
- Children and young people have not been considered; therefore, will be lost in this model. We need to ensure that they are central to the review process and that the themes and services available for them are adequately highlighted.
- We think there should be an opportunity for additional information to be provided specifically about and for children and young people, rather than it all being written within one document.
- We would welcome a chapter on children and young people as it is key that their voices are heard in the safeguarding reviews.
- We feel that all protected characteristics (Equality Act 2010) need to be considered throughout all cases as we believe all areas to be relevant.
- Although not a protective characteristic, suicide and the implication of suicide also needs to be considered for all parts of the different reviews.
Resourcing multi-agency working
- We welcomed the proposed multi-agency repository. We consider this resource to be positive in terms of information as it will look at all core features and try to combine all reviews going forward. This has the benefit of looking at safeguarding from a family perspective (ie family around the child / adopting family unit around child / team around the child).
- The College is keen that the voices of its members are heard with the review process. Where there are children involved there needs to be a paediatric involvement / input.
- At present, things are not going very well and there needs to be a mechanism in place by way of a clear proposal to build in this paediatric involvement and input.
- Our members feel that the review process has to be resourced and funded appropriately. We understand that it is difficult to find chairs and authors for the review processes across Wales and we have concerns about resourcing of initiatives. We would like to receive assurance about how these proposals would be resourced in the future.
- There needs to be a clear proposal as to how these chairs and panel members are sourced, resourced and trained,
Independence and appeals
- Our members feel that Chairs being independent is important. Best practice would be to employ independent Chairs from the public sector, but due to the lack of funding for safeguarding boards in Wales currently this is difficult to achieve.
- Our members recognise it is problematic identifying people due to the level of work (on top of their day job) and the lack of funding. Therefore, it is important for people to be identified and trained.
- In terms of the reporting process, exception reporting needs to be utilised to affect change. If policy continues having someone to review against it, this could potentially cause disputes between families and professionals.
- We welcome the development of a central repository. Our members agreed that reporting on themes nationally is positive. However, there are assumptions that all reviews are published but they are not, therefore this needs to be highlighted.
- Our members recognised that the biannual themed events and training are important as having these mechanisms in place would effectively address issues which may arise in the future.
- We consider partnership involvement and governance structures going forward to be key, our members feel that there is a need to ensure that evolution is used.
We respond to a wide range of consultations to ensure that the College’s position, and ultimately children’s health, is represented. Members can get involved in current consultations by contacting the Wales team at firstname.lastname@example.org.