Consultation response on our strategy for 2023 to 2026
16 March 2023
Consultation response on our strategy for 2023 to 2026
Published: 16 March 2023
- Introduction
- Why we consulted on the strategy
- How we prepared for the consultation
- How we consulted
- What you said
- What we did
- Equality impact
- Read the strategy
Introduction
Our first corporate strategy was published in May 2020 and covers the period through to the end of March 2023. It explains the strategic priorities for how we would begin to regulate the social work profession in England. It covers both the delivery of our statutory responsibilities, and the approach and behaviours we would take in doing this.
Since we started as a regulator, we’ve been delivering our statutory responsibilities and have made good progress against these priorities. We’re proud of what we’ve achieved in enhancing public protection and starting the journey of improving confidence in and within the social work profession. We’re proud of the values and behaviours we have demonstrated—values, in keeping with those of the social work profession, of openness, integrity and respect. But this is only the start.
In our strategy for 2023 to 2026 we set out how we intend to make further progress on our ambitions.
The draft strategy that we consulted on from September to December 2022 is based around 3 guiding themes:
- Prevention and impact: adapting our approach to public protection increasingly towards the prevention of harm.
- Regulation and protection: further improving our regulatory activity through our relationships with the profession and employers.
- Delivery and improvement: the approach and behaviours we'll need to secure effective delivery.
These guiding themes are set out in more detail in the strategy.
While the strategy will set out our plans for the next 3 years, some of the activity we start during this period will go beyond 2026 as we seek to deliver long-term, positive transformation to social work in England.
Why we consulted on the strategy
Before finalising the strategy, we wanted to consult widely with everyone who has an interest in the social work profession in England. This would help us to ensure that the strategy, and priorities within it, are clear, helpful, and that they are the right ones. It would also provide us with feedback on whether we could improve our priorities set out in the draft strategy, and whether there are important areas within our role as regulator which we might be missing.
How we prepared for the consultation
We believe in the power of collaboration and share a common goal with those we regulate–to protect the public, enable positive change and ultimately improve people’s lives. Collaboration and co-production are key to what we do, and so we undertook a wide range of engagement activity, starting with our people and moving into a programme of external engagement.
This included 2 national pre-consultation events in July 2022. These were attended by social workers, people with lived and learned experience of social work and representatives of national and local organisations. These events were an opportunity to discuss with people:
- what they thought about Social Work England as the specialist regulator
- what they want social work in England to look like in the future
- what we could do in our role as the regulator to help social work deliver a better service to the public
The events also offered the opportunity for people to feedback on our approach to education and training, and gathered sector insight ahead of the publication of our third Social Work in England report in early 2023.
In addition to the events, we also ran a number of pre-consultation regional focus groups and other engagement events focused on specific interest groups. Together, this gave us rich and substantive feedback to inform this draft strategy. The main themes identified from these discussions were:
- the role and importance of regulation, and our role as the specialist regulator, as part of supporting professional identity. Plus, how improved understanding and data about the workforce can help support this
- the value and limitations to our role in championing the profession, including in the media and social media
- how we can improve our processes, focusing on:
- fitness to practise, recognising the inherent challenges and need for care in this area
- our continuing professional development (CPD) requirements
- the changes and challenges in the professional environment in the last few years. This includes the impact of the COVID-19 pandemic, staff shortages and turnover, and agency work. This will feed into our work on identifying and preventing harm
- our approach to education and training. There were concerns about:
- consistency across the education sector
- the critical importance of transition from education to employment
- the skills, behaviours and learning experiences which are important for social work students
We also worked with our National Advisory Forum and our board to guide this engagement. We discussed potential aims and objectives of the strategy, and are grateful to them for their supportive challenge and ideas.
How we consulted
We launched our consultation in September 2022 for 12 weeks, closing on 1 December. We held 2 national online consultation events in October 2022, followed by some regional focus groups and discussions facilitated by our regional engagement leads. We also held 3 specific focus groups with people with lived experience:
- parents and families where there has been a child safeguarding concern including experience of care proceedings
- adults with experience of using social work services including adults with mental health issues
- adults with additional sensory needs
In addition to the feedback from these events, we received a number of direct responses through our consultation form and dedicated email address. This feedback was from both individuals and organisations.
What you said
Here, we provide a summary of the feedback we received about the proposed strategy. We found there was some repetition of themes in feedback across the different areas of the strategy.
Our proposal to enable more local resolution of concerns
Respondents were mostly supportive of our ambition to resolve concerns about social workers locally where it is safe and appropriate to do so.
The most common themes among supportive responses were that the proposals in our strategy were a good first step, and that the overarching ambition was sound. A number of respondents felt that resolving issues locally wherever possible is the best option.
Around a third of respondents wanted to see us bring more clarity to the proposals, particularly around information and evidence in favour of local resolution and detail about how we will ensure impartiality at a local level to avoid bias. The risk of discrimination was a factor in many responses, although only a few individual responses opposed the ambition on this basis; most felt that it was an issue that could be appropriately addressed. Respondents valued the additional insight that local resolution could bring to individual cases. But many also felt that we should look to ensure transparency, set clear expectations, and be sure to promote and uphold the robustness of local systems. The Professional Standards Authority agreed that the proposal was proportionate, and that its success was dependent on the policies that underpin it and how we communicate it to employers.
Improving our approach to regulation
There was no clear consensus on any particular issue in relation to how we could continue to improve our approach to regulation. Nevertheless, we received a wide range of useful, and sometimes challenging, suggestions. Many related to our processes. Respondents wanted to see us deal more quickly with fitness to practise cases and ensure we learnt and disseminated lessons from them and were transparent about themes emerging in our cases. Other suggestions included a 2-yearly renewal cycle, a plea to freeze registration fees, and fewer sanctions.
More broadly, a few respondents were interested in embedding sensitivity to equality, diversity and inclusion issues, potentially through an additional professional standard dedicated to equality, diversity and inclusion. We were praised for our approach to co-production by some and urged to continue or strengthen this commitment.
Some respondents wanted us to be more ‘visible’ or ‘assertive’ in promoting or defending the reputation, rights, and pay and conditions of social workers. While some of this falls outside our statutory remit as an independent professional regulator, we note this feedback alongside those respondents – including a range of organisations such as the British Association of Social Workers (BASW), the Professional Standards Authority, the Association of Child Protection Professionals (AOCPP), and National Organisation for Practice Teaching (NOPT) – who identified general and specific problems facing the social work workforce as critical challenges which could impact on our ability to regulate effectively and on standards in the profession. This is work that we have started to take forward using our unique insight across the whole of the profession.
Developing our leadership role in addressing risks to public protection
Respondents gave feedback that fell broadly into 3 topics in relation to this question.
Many respondents wanted us to focus on support for social workers in various respects. There were calls on us to support the workforce:
- with education, training and CPD
- through the fitness to practise process
- who need to whistleblow on poor practice or working conditions
- generally, recognising the high pressure and emotional impact of the role
We were also encouraged to look at how we could support local authorities and other employers to support social workers in these cases. There were calls for us to make sure, in doing so, that workforce concerns and views were at the heart of our values and decision making. Also that we should ensure we involve social workers as well as other professionals and academics in formulating our responses to need among social workers.
Other calls relating to strengthening the profession included some matters outside our statutory remit, such as seeking to address caseloads, or to lobby politicians or the media on behalf of the profession. But most respondents wanted us to use our national voice and platform to raise awareness and understanding of social work as a profession in the public forums in which we participate. A small but significant number of responses were specific in asking us to consider focusing attention on risk – what it is, how it is understood and assessed, and what we and other regulators do to respond to it.
There were several responses calling for us to collect and share more data about the makeup of the profession , both individually and in collaboration with other regulators and public bodies, all with a focus on outcomes. A number of respondents also wanted us to look in more detail at the context around social work practice – in relation to fitness to practise concerns but also more general workforce challenges and pressures. There were also calls relating to specialist practice – for us to annotate and hold a database of specialist practitioners, and to give directed CPD for practice educators.
Barriers we might face to achieving our strategic ambitions
We had fewer responses about the barriers we might face over the next 3 years, but there were some important points. A number of respondents felt that there was insufficient professional trust in us as the regulator. A few respondents felt we do not engage employers sufficiently, or listen enough to social workers. And some saw our processes as bureaucratic, all potential barriers to our ability to deliver on our strategic ambitions.
How we could share data and insight to drive positive change
Many respondents wanted us to share data and insight about examples of good social work practice with others as well as highlighting learning from failures and challenges. This included relevant agencies, other professions and professional regulators, service directors, media, politicians, social workers and the general public, through a variety of media, such as online and in-person events, newsletters and social media. Some went further and encouraged us to agree joint strategies with other agencies.
What is needed from the regulator of social work
The most common response here again was ‘support’, from more than a quarter of respondents. From those who gave more detail, we heard that they want streamlined processes, greater promotion of wellbeing, reduced or no fees, and more value for money.
As above, a large number of respondents wanted us to be more visible and impactful on discussions around issues affecting social work. In many cases this was related to the workforce issues mentioned above, the desire to be protected from vexatious or malicious complaints, and the challenge of a rising numbers of agency workers making it hard to maintain standards cultures.
A number of respondents wanted us to attend to CPD related issues, such as encouraging employers to better support social workers to complete their CPD requirements, sharing innovation in CPD, and making CPD more useful and meaningful.
What we did
Here we explain how we responded to your feedback and made changes to the draft strategy, as well as also explaining other changes made.
To give a clearer picture on our strategic priorities, we reduced the number of objectives from 18 to 10. We also created a new section outlining some guiding principles on how we will approach our work with care and respect. This includes further embedding our commitment to engagement and co-production and that equality, diversity and inclusion is integral to and embedded in all we do.
To help illustrate the value of our greater focus on preventing problems before they occur, we talk more clearly about the need to get ahead of the curve. This helps us to explain how acting to reduce risk and prevent harm is in the interests of the public and the profession, enhancing public protection and increasing public confidence in the profession. This is fundamental to the prevention and impact strategic theme.
We listened carefully to feedback about our public profile and the wider understanding of our role as regulator, the requirements on social workers as part of a regulated profession, and how these can combine positively. The new objective 1, to ‘Build trust and confidence in the social work profession, and in regulation, by strengthening our relationship with the sector’ directly addresses this. To complement this engagement, our new objective 2 commits us to ‘Share the data and insight we hold about the social work profession and our regulation.’
Objective 3 says we will ‘Collaborate with other sector leaders to develop a clear and shared understanding of risks to the public and agree how to manage those risks.’ We have started to do this with early exploratory discussions involving educators, employers and others, and we will develop plans over the coming strategic period. This will also address some of the consultation responses that wanted us to be more visible and impactful on the challenges facing the profession in practicing whilst keeping people safe. Recognising the importance of education in properly preparing students to start their career, objective 4 says we will ‘Ensure all social work students receive comprehensive and consistent education and training, in a supportive and inclusive learning environment to prepare them for practice.’
Our requirements on CPD are fundamental to renewal of registration and demonstrating how social workers remain capable of safe and effective practice. They are also central to our ongoing relationship with the profession. We will continue to explore ways we can maximise CPD as impactful, meaningful, relevant and sustained. In response, the strategy commits us in objective 5 to ‘Ensure that our registration processes are fair, responsive and efficient', where will be exploring whether changes to our guidance, engagement and digital delivery are needed.
As part of our future fitness to practise work, there was support for addressing more concerns locally, where appropriate to do so. However, there was also concern about how this could safely and fairly be delivered in practice. Our new objective 7, ‘Develop our work with employers and the public to resolve more concerns locally (where it is safe and appropriate to do so)’ commits us to this, but also acknowledges these concerns, and emphasises the need for careful management of this approach to be safe and provide confidence to all involved.
The strategy also emphasises the importance of evaluation and data in understanding our impact and influencing our plans. Evaluation is core to how we operate, how we improve and how we are held to account for our activities and the public money we are spending.
Equality impact
The majority of respondents did not express a view or did not feel they could give an opinion on the impact of our proposed strategy on any persons with a protected characteristic. Of those that did provide feedback (around a quarter), the overall view was that the impact would be positive, protective and/or supportive.
The strategy makes clear the values as an organisation we will exhibit and how much importance we give to doing things in a respectful and transparent way. The section ‘How We Approach Our Work’ makes clear that we value meaningful co-production and engagement in all our work and how we develop and understand change. This section also sets out how equality, diversity and inclusion is at the heart of all we do: our dedication to tackling discrimination and disproportionality in all matters equality, diversity and inclusion. We believe these are mutually supportive – as one consultation respondent said: “Ongoing collaboration and co-production will strengthen the voice, support and impact on persons with protected characteristics.”
The strategy offers a new direction as a regulator: greater focus on identifying potential public protection risks at a system level and showing leadership to work, across the sector, to address these. This should reduce the level of harm incurred and in turn concerns raised, benefiting both members of the public who use and rely on social work services and social workers themselves.
The strategy does not, however, propose detailed plans and approaches for how this activity will be delivered. It is not therefore possible to conduct an equalities impact assessment on the operational details. When business and operational plans are developed, over the life of this strategy, equality impact assessments will be undertaken at the appropriate time. These will be grounded in data and insight to challenge our activities and processes, identify any concerns and address them. For example, now that we have data on the demographic make-up of the profession, work can be undertaken to interrogate any disproportionality in the fitness to practise process. Again, where specific changes are proposed, an equality impact assessment will be undertaken at the appropriate time.