Response to Department for Education Working Together to Safeguard Children: Changes to Statutory Guidance Consultation

5 September 2023

Dear Sir or Madam,

As the specialist body regulating social workers in England, we welcome the opportunity to comment on the Department for Education’s (‘the Department’s’) revisions to the Working Together to Safeguard Children statutory guidance

Consultation feedback

We have submitted a separate response to the consultation on revisions to non-statutory Information Sharing Advice to support practitioners in the duties and decisions they take to share information, which this guidance relates to.

We welcome the revision of statutory guidance that will strengthen multi-agency working across the system to support and protect children and their families, and ensure social workers are able to deliver strong, effective and consistent child protection practice.

Feedback on the guidance

The consultation proposes to allow a broader range of practitioners to lead direct work with children under section 17 of the Children Act 1989, with social worker qualified practice supervisors and managers providing oversight for key decisions and activity. We would welcome clarity on the professions that this would apply to and the skills and knowledge they would be expected to have to carry out this function. It would also be helpful to understand the division of roles and responsibilities between the lead practitioner and the social worker providing oversight. We understand the need to strike a balance between national guidance and local implementation. However, the national guidance could provide some level of prescription for clarity of the role and responsibilities of social workers to allow for regional and local variation, depending on particular circumstances.

Similarly, changes to section 2 of chapter 3 of the proposed guidance includes a requirement that the lead practitioner should:

• carry out an assessment of suitability of a mother and baby placement.
• attend the Mother and Baby Unit Admissions Board to represent the best interests of the child.

We welcome further clarity on who might carry out this role, the skills and knowledge expected of that professional, and where it is not a social worker what the oversight might look like.

Section 4 of the consultation introduces new national multi-agency practice standards for child protection for all practitioners who come into contact with children who may be suffering or have suffered significant harm. It also outlines the actions all practitioners should take where there are concerns about actual or likely significant harm to a child. Social workers in England are required to meet and uphold professional standards set by us. We would therefore encourage the Department to ensure that the new multi-agency practice standards align with our professional standards, as well as any standards and frameworks applicable to other relevant professions.

We welcome the retention of Chapter 4 of the guidance, titled ‘Organisational responsibilities’, and in particular the section addressing responsibilities of adult social care services. As the regulator for all social workers in England, we recognise the importance of strong links between children and families and adult social care services. We therefore welcome the inclusion of guidance to support the working relationships across services.

General comments

The Home Office is currently consulting on a proposed Mandatory Duty to report Child Sexual Abuse. We would welcome clarity on how the revision of Working Together aligns with the development of the duty (and any associated guidance). Given that the proposed duty for reporting child sexual abuse may be mandatory it will be important to align these pieces of work so that social workers and other professionals are clear on how guidance will enable them to carry out their duties correctly and effectively.

We welcome the proposal to undertake an annual review of the Working Together guidance. This will ensure it remains informed by current practice and will continue to have an ongoing positive impact on multi-agency working.

We have also submitted a response to the Department’s consultation on revisions to non-statutory Information Sharing Advice to support practitioners in the duties and decisions they take to share information. We understand that the information sharing guidance will sit alongside a future revision of Working Together. We would welcome further clarity on whether the next annual revision of the Working Together statutory guidance will include a revision of the information section to bring it in line with the information sharing guidance.

I hope the Department finds this feedback helpful.

Yours sincerely

Colum Conway
Chief Executive