We have reviewed the Corporations current Child Protection Policy. It’s value is extremely limited. Child Protection at the BBC, as with every institution (and ‘Regulated Activities’) is grounded on ‘discretionary reporting,’ not mandatory reporting.
Here is the BBC’s child protection policy and our review. The areas of particular concern are highlighted in yellow.
- Little has changed to ensure reports reach the Local Authority or the authorities since Savile and Hall were doing their worst.
- There are multiple reporting lines within the child protection policy which are unclear; there is no description of when a child welfare concern will be referred to the Local Authority; there are no named designated child protection officers or contact details.
- Currently there is no law that requires adults working with children to report child abuse. It is a ‘discretionary’ report in the control of the institution. The Corporation is at liberty to strengthen its policy beyond the statutory minimums, but has chosen not to.
- Child protection at the BBC is grounded on the hope that adults who have a concern about the welfare of a child will do the right thing and whistle blow, which can risk their career. Staff who have spoken out at the BBC seem not to last long which has been noticed by all employees at the corporation. This can easily reduce the likelihood of reports being made in future.
No one at the BBC is required to report concerns/ allegations either by statutory law or, we understand, by terms and conditions within BBC employment contracts. There are multiple reporting lines which are unclear; no explanation of the point at which a concern is referred to the Local Authority; no named designated child protection officers or contact details. These points are highlighted in our analysis of clauses – 7.0, 8.2, 8.3, 8.4, 8.5, 8.7, 8.10, 9.3, 9.4, 10.1 and the flowchart on P23.
The BBC adheres to ‘statutory guidance’ (confirmed by BBC in email below) which relies on a behavioural expectation that ‘people will do the right thing,’ when Serious Case Reviews have repeatedly demonstrated this assumption cannot be relied upon. Reporting a concern is entirely discretionary at the BBC and most other places. Should an employee do the right thing and report, they are a ‘whistle blower’ and as we have seen in matters related to Savile (See yellow highlights P9, clause 7 analysis), whistleblowers seem not to last long at the BBC. In real structural terms child protection at the Corporation has changed little since Savile and Hall were doing their worst. Child protection at the BBC is grounded on the hope that adults who have a concern will be courageous enough do the right thing, blow the whistle, and potentially risk their career.
The BBC seems to have overlooked that it is free to create a credible policy that exceeds the very undemanding ‘statutory guidance’ (an oxymoron) created by the Department for Education. Sadly its ‘follower’ approach to ‘guidance’ has produced another poor child protection policy which fails children and staff alike.
Last evening (20/1/16) Mandate Now was forwarded this email from the BBC which attempts to justify its inadequate child protection arrangements.
Here is what 9.4 says and our review in yellow – decide for yourself.
The BBC is itself deciding whether or not to refer the allegation to the LADO for independent assessment.
In our experience the two child protection NGOs mentioned in the BBC’s email, which contributed to the new child protection policy, are disinclined to step beyond government ‘guidance’ which simply cannot, on its own, produce a credible policy. Furthermore, both charities focus principally on other areas of child protection rather than abuse perpetrated within institutional settings which, like CSE and trafficking, is a specialism. While child protection charities believe their interests are best served by slavishly supporting the failed ‘statutory guidance’ (and Government policy no matter how poor it is), errors such at this latest BBC child protection policy will perpetuate. It is impossible to deliver an effective child protection culture in any institutional setting when the legislative ingredients deposited on a naive public by the Department for Education are so inadequate. Here’s another example: Southbank International School (SCR published 20/1/16) demonstrates similar shortcomings when attempting to magic an effective child protection culture from missing legislative ingredients.