There have been a number of articles published in The Ringing World regarding requirement for CRB (Criminal Record Bureau) checks for bell ringing activities based on current legislation (the Safeguarding Vulnerable Groups Act 2006) and guidance issued by the Church of England. There remain, however, diverse interpretations at local level which has given rise to problems for ringers, the most common being attempts to insist that all adult ringers in a team be CRB checked. This note has been prepared to clarify the position as it exists at February 2012.

A legal requirement for CRB check derives from the 2006 Act and relates to “regular” close work with those under 18 years of age (or vulnerable adults). Such activity is referred to as a “regulated” activity. In respect of ringers this has been accepted by both Government and Church to be those who teach or train those under 18 and further that this is interpreted as face to face teaching of handling. It does not include ringing as part of a team, standing behind or giving verbal advice “on the bench”. A fuller explanation is given on the Central Council website under Tower Stewardship – Guidance Note No. 3 Protecting Children in Towers.

The Church of England position is set out in three related documents:

Protecting All God’s Children – 4th edition November 2010

This booklet sets out the principles by which the Church operates and specifically under Section 5.34 states in regard to mixed age activities including bell ringing that “It is not possible to request CRB checks or ISA registration for adults in those groups unless they have specific responsibilities for children”.

Safer Recruitment Guidelines – January 2011

This booklet sets out procedures for using paid and volunteer workers and in Appendix 1 identifies those roles within the church which “usually require CRB checks”. In this context the expectation is that “All tower captains and (other) adult ringers who teach/train children under 16” should be CRB checked it goes on to say that “ where all children are in the age group 16-18, then checks are not mandatory but desirable”.

Briefing from Church of England Safeguarding Adviser – May 2011

This document reiterates that “The only reason that churches are entitled to seek enhanced CRB disclosures about people in paid or volunteer positions, is if that person will be working closely with children (under 18s) or vulnerable adults”. Reference is made to the Safer Recruitment document and goes on to say that “churches should ensure they are compliant with those policies … if churches are not compliant, then urgent steps should be taken to secure compliance”.

Illegality of certain checks

In an earlier briefing on the Vetting and Barring Scheme, the Safeguarding Adviser specifically warned that churches could be acting illegally if unwarranted CRB checks were sought with PCC and Incumbent becoming liable.

To explain this position the Code of Practice of the Records Bureau requires that CRB checks are only sought for bona fide purposes and the form of request includes a statement of purpose to which a Parish and, as the processing body, the Diocese are signatories. A CRB check requested for other than an acceptable purpose conforming to the role guidance given by the Church itself could be regarded as a false statement. Not only could the CRB turn back such a request but there could be repercussions for both the original requester and the processer. Persistent improper requests by a Diocese could lead to it being taken off the list of Registered Bodies for whom the CRB will process checks.

Key Consideration

Quite apart from the defined roles which might require CRB checks, one of the key criteria is the nature of the activity and NOT the mere presence of children. So an adult involved in teaching minors to ring should be checked but another adult merely present should not. It even goes further that there is a general acceptance that if a tower captain and say deputy have been CRB checked , then adults assisting are regarded as a peer group under the direct supervision of the CRB checked leaders.

Vulnerable Adults

Although we might all be “vulnerable” at times, provisions for CRB checking relate solely to those adults over 18 who are in receipt of specific help in social matters. It is a legal definition and for practical purposes does not involve ringers.

Adult only bands

Strictly speaking there is no legal or church need to CRB check adults ringing where there is no teaching of under 18s. However, it is not illegal to request a CRB check for someone who anticipates that they might be involved with minors at a future date. In this respect it would not be unreasonable for a church to expect at least the Tower Captain to be CRB checked as a leader and role model within the church.

Protection of Freedoms Bill

This Bill was introduced into Parliament as a result of concern and criticism of the 2006 Safeguarding legislation, much of which has not in the event been implemented. The PoF Bill has now gone through both the House of Commons and House of Lords and is likely to become law in May 2012. Amongst its provisions are

  • Scrapping the requirement for ISA registration
  • Reducing the scope of regulated activities and thereby CRB checks
  • Provision for portability of CRB checks between activities
  • Formal recognition of working under supervision of CRB checked leaders

Dealing with Problems

Initial problems should be dealt with by discussion with the bodies concerned with reference to the guidelines and briefs issued by the Church of England itself as mentioned above. Further advice and assistance can be obtained through the CCCBR Tower Stewardship Committee or direct to myself as under:

Chris Mew,
TSC member
Tel: 01926 402273
New email: mewsofwarwick@btinternet.com

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CC
Central Council of Church Bell Ringers