External Affairs / Policy / Consultations Consultations
To: Rosalind.greenfield@homeoffice.gsi.gov.uk
Wednesday, February 25th 2004
Mrs Rosalind Greenfield
I refer to our telephone conversation and thank you for allowing
the Institute for Outdoor Learning to make a response in view of
the fact that we had not received the consultation document when
it was issued. I would be grateful if we could be put on your list
of consultees for any other further consultations by the Home Office.
The Institute, as a registered charity, was formed two years ago as the result of the convergence of six outdoor organisations. We represent probably the broadest spectrum across the industry of any existing organisation. Our members include employers and employees involved in walking, mountaineering, personal development, outdoor activities, watersports and field studies. Our members are present in outdoor centres, educational establishments, some small providers and they may work for charities, local authorities commercial enterprises or themselves. We have a permanent office at Penrith.
In view of the urgency I am responding by email.
Name: Brian Edward Lamb (Executive Member & Trustee
responsible for external consultations)
Organisation: Institute for Outdoor Learning (registered charity)
Address: Plumpton Old Hall, Plumpton, Cumbria CA11 9NP
Address for communications for this consultation: Greystone, Bere
Ferrers, Devon PL20 7JX
Umbrella body
Covers Education, Social and Personal Development and Adventurous
Activities
Voluntary Organisation
Other: National Organisation
Q(a)
Yes No comments
Q(b) (i) Identity Checking
Yes
(ii) Accurate completion of form
Yes
(iii) Payment on account
Yes
(iv) Publicising fees
Yes
(v) Compliance with Code of Practice
Yes
(vi) Inspection rights for CRB Staff
Yes but only with search warrant from Judiciary
(vii) Payment of annual fee
No
Annual fees produce more bureaucracy and costs and become self defeating.
However, if annual fee is to be charged then re-vetting of signatories
should be free.
The proposals will require more staff time and represent significant
extra costs for our member organisations. They seem to discourage
the registration of small organisations and to leave them no choice
but use umbrella bodies, for which charges are made with the potential
for delay and mistakes.
Q(c) Support intro of limit on countersignatories
Yes
Q(d) Do you agree with proposed limits
Yes
Q(e) Re-vetting of counter-signatories every 3 years
Yes
Comment: If annual fee charged it should included re-vetting of
counter signatories, streamlines operation on both sides. However,
you should seriously consider whether this is really required in
respect of Local Government and other major National Organisations
such as Outward Bound, Fairbridge etc. who have a very tight control
of staff
Q(f) Do you agree with cost, benefits and disadvantages of the proposed
regs. as et out in the partial R.I.A.?
No
Whilst the CRB may have to be financially self supporting, it should
not lose sight of its primary objective which is part of the protection
of vulnerable young people from the misfits of society. It would
seem that it is more concerned with bureaucratic processes and setting
up adjuncts to its main purpose. All of these at a cost to users!
It is obvious from recent reports on the qualification of its accounts
and proper control over debt management that cost efficiencies need
to be made instead of just opening the tap to further fee income!
The existing system is slow and suffers from inappropriately designed
forms for electronic application. It would then be possible for
on line data verification thereby ensuring correct completion which
would help the situation. Applicants could be issued with a pin
to authorise the disclosure without the need to verify their identity
beforehand.
Q(g) Our members report that there have been a number of issues,
related to 'learning the system', that have resulted ininaccurately
or incomplete forms being submitted. These should decline but how
many mistakes were made because of inappropriate form design?
For registered bodies who have 'mastered' the system there should
be no additional costs but those who consistently make mistakes
should perhaps be charged for the additional work. Economies of
Scale and the efficiencies that you have suggested should preclude
further increases above the rate of inflation.
Q(h) Have you any comments on the Disclosure fees to apply from
1st April 2004?
Yes
Fees continue to rise. Would you consider charging per application
based upon the cost of the CRB and then the costs would be pro rata.
Q(i) Do you support the proposed revised criteria for determining
which people qualify for an Enhanced Disclosure?
Yes
The 'further categories' paragraphs 14 and 15 should all be made
eligible. We suggest that employers should decide on the necessary
level of disclosure against minimum standards. In that way eligibility
is not an issue as ifthe employer considers it to be appropriate,
they can apply for an enhanced disclosure for a position that in
different circumstances may warrant a standard one. We understand
your thoughts that everybody should undertake enhanced disclosure
if he or she is on a site and can have lone access to young people.
Q(j) Are there other categories of employees or volunteers that
you consider should be eligible for an Enhanced Disclosure?
Yes
There are still significantly large groups not covered, especially
organisations involving foreign nationals, language schools and
private tutors. These not only need to be educational but sports
coaches who hire local halls and set up classes such as badminton
or judo. What is the control on these people? We understand and
support your suggestions that everybody should undertake enhanced
disclosure if he or she is on a 'site' and can have lone access
to young people
Please acknowledge YES
Thank you for the opportunity to be consulted
Brian Lamb, Member of Executive Committee, Institute for Outdoor
Learning