Dear NRCSE members,
I hope you submitted your response to the Department for Education’s consultation on out of school hours education/supplementary schools; if they don’t hear people’s concerns they can’t address them. If you would like a full copy of NRCSE’s response please email us and we’ll send it.
Many people have spoken to me of their fears that any new regulation/registration will bring a massive additional burden on community groups that are already stretched very thin.
In terms of increased bureaucracy, the policies and procedures that are being proposed would appear to be those basic documents that any organisation working with children should have in place to ensure they are running safely and not putting children at risk of harm. The Bronze Quality Framework Management File would provide evidence enough that procedures are in place to ensure activities do not fall into the four areas of prohibition detailed in the consultation (and below).
3.19 […]Prohibited activities would be focused around the following areas designed to keep children safe and promote their welfare:
- Failure to adequately ensure the safety of the children in their care, for example, failing to maintain basic records and emergency contact details for the children in attendance.
- Appointing unsuitable staff. Teaching, if not supervised, falls within the definition of ‘regulated activity’ (This is defined in the Safeguarding Vulnerable Groups Act 2006. Broadly speaking, regulated activity relating to children is considered to be: teaching, training, instruction, care or supervision of children […] For example, it is an offence to knowingly permit individuals who are barred from working with children to engage in regulated activity, or to work in regulated activity while barred.
- Accommodating children in premises that are unsafe and pose a threat to their safety or welfare.
- Corporal punishment. We propose to ensure that corporal punishment is not a practice adopted in out-of-school settings, regardless of the number of hours which children attend the setting.
Of course only an actual visit to the classes in action can evidence that procedures are being implemented. Again, the Bronze Quality Framework Award is evidence that such a visit has taken place and that an independent recommendation has been made that the setting is running safely and effectively.
The prohibition of:
- Undesirable teaching, for example teaching which undermines or is incompatible with fundamental British values, or which promotes extremist views.
is less clearly defined and more detail is needed on how any agency (whether Ofsted or the local authority or someone else) would determine whether ‘undesirable teaching’ takes place. NRCSE has raised concerns that without much clearer guidelines this prohibition appears divisive and discriminatory and will not protect children at all. On the contrary it will damage community relationships, make it harder for supplementary schools to build partnerships with mainstream education, lead to even more negative press and promote xenophobia, racism and Islamophobia.
NRCSE has recommended that supplementary schools and their teaching staff be supported, with subsidised teacher training opportunities, appropriate guidance in curriculum development if requested by the school, opportunities to share good practice with their peers, etc. Exactly the kind of training and support that LCST, ANSS, Westway Trust, UKFCS, Milton Keynes EMAT, Camden, Barnet, Brent,Harrow, Leeds, Manchester, Suffolk Councils, Macierz Szkolna and NRCSE provide but for all settings and with a clear strategy for how it will be funded.
Executive director NRCSE
NOTE/ If you have concerns and you DIDN’T respond to the consultation, you still can write to the DfE.
The deadline for responding has passed, but we continue to welcome contributions from individuals and organisations to inform our wider understanding of the supplementary schools sector and will consider any concerns raised over our proposals. Contributions received after the deadline will not form part of the official report summarising our findings, however.
Head of Regulatory Framework Unit