Below is a short summary of the key points from both responses, with the full consultation response available to download at the bottom of the page.
The RCPCH responded to the , providing a synthesis of the available evidence and a clinical consensus and highlighting to the government a number of key issues and considerations in relation to the introduction of mandatory reporting of child sexual abuse.
The key points were as follows:
- All types of child abuse must fall under any mandatory reporting duty
- A children’s rights-based approach must be followed and a children’s rights impact assessment must be carried out
- A Government systems impact assessment must be carried out
- Measurable outcomes for children must be built into any plans
- Clearer definitions must be provided before further consultation
We are disappointed to see an absence of response to most of the above in the Home Office (‘the Department’)’s , which sets out plans for the introduction of mandatory reporting. Our full response to the initial call for evidence, outlines further the rationale for the above, and would encourage this to be reconsidered in response to this new consultation.
Our response to this second consultation, attached below, highlights a number of concerns, including:
- The impact assessment produced by the Home Office is, by its own omission, not evidence based. We have identified a number of errors in the assessment which would lead to significant under estimation of the costs to the health, social care and police sector. We are therefore concerned that the social care system will not be equipped to adequately investigate increased reports, resulting in under-investigation and children continuing to experience harm.
- The policy as it stands has not been designed with an outcomes focus and there is no information offered as to how data will be collected and assessed in relation to any introduction of mandatory reporting.
- The policy as it stands focuses on ‘verbal disclosures of abuse’. This is discriminatory towards younger children and non-verbal children, and we are concerned that the home office has not made provisions for this.
- The home office calculations suggest that a maximum of 9 individuals will be convicted for child sexual abuse as a result of this policy as it stands. We do not feel that this is sufficiently effective to warrant the use of resource and feel that this resource could be better spent on other CSA prevention methods with a larger evidence base.
RCPCH has extended its offer to engage further on this matter to the Home Office, the Department for Health and Social Care and the Department for Education. We will strive to work with the Government to ensure that this important policy area is implemented with an outcomes, evidence-based focus to better support victims and protect children and young people from child sexual abuse.