General Comments Respondent


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General Comments


Members of the Rotherham Safeguarding Children Board met to review the Working Together Consultation document, and provide constructive feedback to assist the process.
As well as completing the Consultation Response Form which was posted to DCSF on 27th January, Rotherham Safeguarding Children Board would also like to submit the following comments for review.
Chapter 1
1.21 The statement currently uses the word 'maybe', this needs to be strengthened to 'should'.
1.31 Refers to children committing acts of sexual abuse, the definition given is 'usually defined where there is a significant age difference of 3 years or more' . Rotherham Safeguarding Children Board feel this should be removed as it can be misleading.
Chapter 2
This chapter makes reference to integrated services, however the remainder of the document uses the term co-located. Both terms have different meanings, direction is needed on which is preferred.
2.170 This section is not up to date.  The Connexions Partnership in South Yorkshire disbanded in April 2007 and became the individual responsibility of each of the 4 local authorities.  I am aware other sub regions also are in the same situation.

2.215 There is a danger when using lists that people often mistake them as being exhaustive rather than inclusive. If lists are to be used there should be consistency, this is not the case in this point. Some of the contact details can be found in a box where others are in paragraph format.

Chapter 3
3.58 It would be helpful to expand on this point and clarify what is actually being said.
Chapter 4
Generally chapter 4 is more detailed, there is additional information regarding support for staff , and emphasis is placed on multi agency working and training.
4.26 Is a welcome addition, defining the degree of contact with children.
The common core of skills and knowledge for the children's workforce is less bewildering.
4.7 The increase in time to carry out the induction process from 3months to 6 is greatly appreciated.

Rotherham Safeguarding Children Board would like to see clarity on how the relationship between Children's Trust and Safeguarding Board would work.

Chapter 5
5.37 The extension from 7 to 10 working days to complete the initial assessment is a welcome amendment for some, however others felt it should remain at 7 days, as every day is a day too long for a vulnerable child.
5.83 Confirmation that professionals who are unable to attend conference should send a well briefed representative is most helpful.
5.90 The additional detail on the information a report should contain is very helpful.

Chapter 6

6.33 Refers to appendix 5, however this is appendix 5 in the previous edition of Working Together and should read appendix 4 in the new edition.
Chapter 7
7.10 Further clarification regarding information shared to parents, how this achieved, in what timescales and the most appropriate method.
7.81 More detailed information concerning the purpose of the visit and the expected follow up from local authorities and public health.
Chapter 9
The chapter refers heavily to domestic violence. Suggest the word violence is changed to abuse.
When commenting on domestic abuse the chapter refers to women being the victims, there should be some mention that domestic abuse can be suffered by men, it can occur in same sex relationships, and children abusing children.

    1. There is no reference in here to the role of MARACs where children are involved.  This is not explained until 12.26.  There are different sections on DV and is confusing.  All thematic areas need to come together.

Chapter 10
Points 10.14 to 10.26 are good additions.
Chapter 11
A welcome inclusion that the document recognises children missing from education.
11.105 One paragraph relating to migrant children is minimal. It would be helpful if this could be expanded, with additional information on baby brokering and the multitude of issues with migrant children.

Information regarding hospital shoppers, people who go from hospital to hospital to avoid being detected, would be a useful addition .

Chapter 12
The section on MARAC is new, would this be better located in the chapter referring to domestic abuse? The information needs to be more about victims than perpetrators.

Rotherham Metropolitan Borough Council

It would be very helpful to have an index as well as contents. Frequently the user wants to look up a particular problem and it is often quicker to look in the index, for example; refugee, sexual abuse. Many things are referred to in different contexts throughout the document.
Chapter 1.

This is a very positive start to the guidance and I think another sentence adding that the aim of this guidance is to help the professional support children and families to achieve the five outcomes would help.


It is important to mention the cultural differences but within these variations, children must still be safe. Reference: United Nations Right of the Child, article 24 that protects all children from maltreatment, independently of their cultural background and the family belief system.


Expand and add that parents not only deserve support but also respect for the difficult task they are doing and add that most parents are ‘good enough’ parents.


Add another bullet point, discussing ‘protective factors’ and explain that a child in a situation of high risk can do better if he or she is resilient and there are sufficient protective factors in contrast to a vulnerable child who has little innate resilience.


Safeguarding and promoting the welfare of children is defined as

  • Protecting children from maltreatment, ‘but not reaching threshold for significant harm’

The title is promoting but it is not expanded upon in the text below within 1.15 . Add something about promoting.


This paragraph is not clear. The CAF is used as a tool to help the team around the child coordinate the care of a given vulnerable child, or one with complex needs.

A sentence is needed to explain the universal services or give a reference to them or a footnote.

Cross-reference this to 1.18 for clarity.


Add the family strengths and ability to support, but also the child’s response to this which is determined by their resilience/vulnerability.


There needs to be more emphasis on the fact that children are usually abused by family members, followed by smaller numbers and less often the extended family and also those known to them.


This definition includes the age and gender of the perpetrator. If this is to be included in definitions it must be included in all definitions and not just for sexual abuse.

Chapter 2.


There are 14 bullet points. Not all health professionals should be expected to do all of the points contained in each of the 14 bullet points. The 6th, 7th, 9th and 14th bullet point are done by particular/designated/named health professionals and it is important that other/all health professionals know to whom a child should be referred or who in a given area would carry out these tasks in bullet points 6,7,9, &14.


Re: Forensic Examinations – if local arrangements do not have the necessary equipment it is acceptable for local services to access the forensic service within a network of several local services. The development of networks within a Paediatric service for safeguarding children is being developed by the Royal College of Paediatrics and Child Health.

These arrangements should avoid repeated examinations. However, it is important that professionals in other agencies realise that repeated examinations can be done when indicated by a consultant paediatrician with the necessary expertise. Depending on the context and the co-existence of an underlying medical condition they may be necessary and not abusive.

SARCs will be set up around the country and each must have a dedicated service for the assessment of children under 13 who have been sexually assaulted in the previous 3 days. The paediatrician must be part of the service. Paediatricians need to contribute to the assessment of such children which is, known from the literature, a very rare occurrence within a borough. Most children are sexually abused within their families over time and do not disclose for many weeks/months or even years later or never.


As far as possible a note needs to be made in the PCHR (Parent Child Health Record)/ Red Book.


Add where that child between the age of 5 & 16 years is not in school, the local education authority must be notified and also social care.


In addition to identifying in the records children who are subject to child protection plan, it would be good practice to identify:

  • Children in need

  • The name of the social worker


This paragraph should also include the general practitioner who is providing a universal service when carrying out child health promotion as many general practitioners do.


Include the identification of those with problems and in particular those mothers/families/children at risk.


There needs to be close liaison between adult mental health services and children social care. It is an opportunity here to add that adult mental health must liaise not only with social care but also with other health providers, such as health visitors and general practitioners.


In this section there needs to be more about the role of the paediatrician not only when they come into contact with child abuse in the course of their work but also children who are referred to them because of concerns. For example: the teacher, social worker, health visitor etc. may notice that the child is neglected/failing to thrive/has alleged sexual abuse etc. these children are, in most parts of the country referred to the community paediatric service where there is an on-call team of doctors who see the child. Each borough needs to have a clear referral pathway for this paediatric assessment when there is a suspicion of abuse or neglect of a child or young person or an allegation of maltreatment. The service should be set up so that both children with acute difficulties and those with chronic difficulties are seen by an appropriately trained paediatrician in an appropriate place. This local pathway should be part of a larger network of several boroughs so that expertise and further advice can be sought when needed in particular in complex cases such as child sexual abuse.


In this paragraph is it important to emphasise that we all need to be able to listen to children as the teacher may be the first person to whom an allegation is made. Such allegations often occur following PHSE.


It is important either in these paragraphs or in other parts of the guide to point out that there is sometimes a tension between multi- faith/religious teachings and safeguarding children in England in 2010.

Chapter 3.


In this paragraph, children who are excluded from school need to be included in the guidelines. Such children are often from families who are unable to look after them and school may be their only ‘safe’ place.


Include the impact of learning disabilities in this paragraph.


Serious case reviews need to be cost effective. It is my opinion that over the years the lessons learnt are similar and the money needs to be spent on implanting these lessons rather than discovering them ‘again and again’ in each serious case review.

In addition a serious case review needs to be a learning opportunity for all those involved in the case and there are other ways of looking at serious case reviews, such as an interactive half day facilitated seminar to discuss what happened with all those involved in the case.


The following sentence could be added: “As long as the advantages and disadvantages of a chair who is working in that borough are discussed annually and minuted by the board without the chair present, the safeguarding board members can decide if that chair should continue or if a new independent chair should be appointed.”

In my opinion there are advantages and disadvantages of an independent chair. A good chair who is working within the borough is a huge advantage in knowing the local demographics and also the personnel working in all the agencies. Either way, there must be a mechanism by which the board can discuss the appropriateness of the chair on a regular basis.
Also consideration needs to be given to the costs of an independent chair.
QUESTION: is there a link between the independent chair and children being safer? What the evidence an independent chair is always better

Include designated manager.


LSCB’s need to ensure that size does not preclude effective workings. Other groups may be formed and represented on sub-committees of the safeguarding children’s board – this is mentioned in 3.90.

Chapter 5.


For example; early years staff etc. it is important to add doctors or GP’s and Paediatricians.

Accident and Emergency is a place and this list contains staff. It is important to list staff /professionals or places, where a vulnerable child or an abused child maybe recognised. I favour listing the staff groups and then the places, such as accident and emergency, hospital in-patients, hospital out-patients, primary care, other community settings.

Add learning difficulties to the list and also adults who are in hospital with acute or chronic illness.


Add - send by email or fax.


It is important to determine whether there should be a paediatric assessment of the child.


Strategy discussion involves social care and police, but it is very important to add health, particularly in cases where there is a suspicion of child sexual abuse or in complex cases, such as with a child with a disability. It would be best practice to consult or to include health in all strategy discussions.


Paediatrician needs to be included. If it is more efficient, there can be a three way phone conversation which can be done on any phone with a ‘recall’ button. In other cases, a conference call can be organised if more than three people need to speak together. This practice includes efficiency, as travelling time is not needed.


Add there needs to be an honest explanation of the process. A copy of written information should be given to the parents if they would like it. One of the aims should be to include a positive outcome for the child and parent, even if there is abuse and neglect.


There needs to be consideration to the number of professionals attending each child protection conference. It is important to ensure that the key professionals for that child are given priority and attend the conference. The conference may have to be moved to a suitable time and place to accommodate such professionals.


It is a priority to give clear guidance to the parents as to what they must do for the child, for example, attend school with the aim for 95% attendance.

If the child is ill he/she should go to the general practitioner and get a note for the school or the social worker in cases where there are concerns about the maltreatment of the child. Part of the child protection plan should include that all absences must be authorized. An arrangement could be made with the GP who should be able to see such a child. Each general practice at any one point in time, out of the children on their list would only have 2 or 3 children with a child protection plan.

In a set time from the date of the conference, the chid is not attending school, without authorized absences then urgent action needs to take place. For the child a place of respite/safety would be nursery or school. It is up to the professionals to ensure that the vulnerable/abused child attends especially those in nursery and primary school they cannot get there themselves.

Chapter 6.


Fabricated or induced illness is now thought of as a spectrum from the highly anxious parents, who consult the doctor very frequently and request hospital appointments to those who deliberately fabricate or induce illness in their child. This spectrum needs to be mentioned here, as it is in the guidelines produced by the Royal College of Paediatrics and Child Health, which should be added as a footnote.


Add a sentence to alert practitioners to girl children of mothers who have had FGM. Such girls are at risk of having FGM and a prevention plan needs to be in place.

Chapter 10.


Surely multi-racial and multi-cultural is a more descriptive and better term than black and minority ethnic people. The experience in Australia and New Zealand is that multi-cultural is now the preferred term.


Add every school should have an anti-bullying policy available to staff, parents and children.


Mixed race children living with one parent, may very well live within a ‘white environment –community and family’. This leaves the mixed-race child very vulnerable to racism not only from the community but also from their family, particularly if they have very little contact with the other parent.

Doctor, Camden, London.

1.1 All children have the right to achieve their full potential. In 2003, the Government published the Every Child Matters Green Paper alongside the formal response to the report into the death of Victoria Climbié...

1.2 The Children Act 2004 subsequently became law and set out these outcomes in statute, as well as the Government’s approach to the well-being of children and young people from birth to age 19. The publication of the Children’s Plan in 2007, which was developed having regard to the principles and articles of the UN Convention on the Rights of the Child, further set out the role of Government and a wide range of agencies and professionals in improving children’s lives.

To achieve the Every Child Matters outcomes, children need to feel loved and valued, and be supported by a network of reliable and affectionate relationships. They need to feel they are respected and understood as individual people and to have their wishes and feelings consistently taken into account. If they are denied the opportunity and support they need to achieve these outcomes, children are at increased risk not only of an impoverished childhood, but also of disadvantage and social exclusion in adulthood. Abuse and neglect pose particular problems.

Parenting, family life and services

1.3 Patterns of family life vary and there is no one, perfect way to bring up children. Good parenting involves caring for children’s basic needs, keeping them safe and protected, being attentive and showing them warmth and love, encouraging them to express their views and consistently taking these views into account, and providing the stimulation needed for their development and to help them achieve their potential, within a stable environment where they experience consistent guidance and boundaries without the use or threat of violence.

1.4 Parenting can be challenging. Parents themselves require and have the right to support. Asking for help should be seen as a sign of responsibility rather than as a parenting failure.

1.5 A wide range of services and professionals provide support to families in bringing up children. Sometimes children will seek out and ask for help and advice themselves. However, in the great majority of cases, it will be the decision of parents when to ask for help and advice on their children’s care and upbringing. As well as being responsive to children’s direct requests for help and advice, professionals also need to engage parents early when to do so may prevent problems or difficulties becoming worse...

1.10 Effective measures to safeguard children are those that also promote their welfare. They should not be seen in isolation from the wider range of support and services already provided and available to meet the needs of children and families:

● enquiries under section 47 of the Children Act 1989 may reveal significant unmet needs for support and services among children and families. These should always be explicitly considered, even where concerns are not substantiated about significant harm to a child, if the child and/or their family so wishes; and
● if processes for managing concerns about individual children are to result in improved outcomes for children, then effective plans for safeguarding and promoting children’s welfare should be based on a wide-ranging assessment of the needs of the child, including the child’s wishes and feelings, whether they are suffering or likely to suffer significant harm, parental capacity and their family circumstances.

1.13 For those children who are suffering, or at risk of suffering, significant harm, joint working is essential, to safeguard and promote the welfare of the children) and, where necessary, to help bring to justice the perpetrators of crimes against children. All agencies and professionals should:

● prioritise direct communication and positive and respectful relationships with children, ensuring the child’s wishes and feelings underpin assessments and any safeguarding activities;
● be alert to potential indicators of abuse or neglect; ...

I would add in new section at the beginning, to complement the emphasis on an integrated approach and a shared responsibility:

The child in focus

Lord Laming reiterated the importance of frontline professionals getting to know children as individual people and, as a matter of routine, considering how their situation feels to them. Ofsted’s evaluation of 50 serious case reviews conducted between 1 April 2007 and 31 March 2008 highlighted ‘the failure of all professionals to see the situation from the child’s perspective and experience; to see and speak to the children; to listen to what they said, to observe how they were and to take serious account of their views in supporting their needs’ as probably the single most consistent failure in safeguarding work with children.

Since 2005, local authorities have been under a duty to ascertain and give due consideration to the child’s ascertainable wishes and feelings (having regard to the child’s age and understanding) before providing services under Section 17 of the Children Act 1989, and before making decisions about action to be taken to protect individual children under Section 47 of the Children Act 1989. These new duties complement existing requirements relating to the wishes and feelings of children who are, or may be, looked after (Section 22(4) Children Act 1989), those being provided accommodation (Section 20(6) Children Act 1989) and children taken into police protection (Section 46(3)(d)).  

The “wishes and feelings” duties in the Children Act 1989 must be carried out as far as is reasonably practicable and consistent with the child’s welfare. There will be occasions when it is not possible to ascertain the child’s wishes and feelings and / or possible to give them due consideration. However, this will be exception rather than the rule and, in these circumstances, professionals should record in writing why it was not reasonably practicable or consistent with the child’s welfare to elicit and / or take into account his or her wishes and feelings.

Domestic law duties are strengthened by the UK’s obligations under Article 12 of the UN Convention on the Rights of the Child, which grants every child the right to express their views freely, and for these views to be given due weight in accordance with the child’s age and maturity. In particular, the child must be given the opportunity to be heard in any judicial or administrative proceeding affecting him or her, either directly or through a representative. Effective ongoing action to keep the child in focus includes:

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