Analysis Of Responses To The Consultation On Draft Statutory Guidance For Parts 4, 5 & 18 (Section 96) Of The Children And Young People (Scotland) Act 2014

7 The Named Person Service: Considerations relating to different groups

7.1 Sections 5 and 6 of the statutory guidance covered the Named Person service in relation to different groups of children (pre-school children, not pre-school children, children who leave school before their 18^th birthday, children of gypsies / travellers, children who are home educated, and children where there is more than one Named Person involved with a family). This guidance relates to Part 4 (Sections 20 and 21) of the Act.

7.2 The consultation asked six questions (Questions 10-15) about Sections 20 and 21. The views of respondents in relation to each of these questions are discussed below.

Q10: Named Person service for pre-school children

7.3 Question 10 asked: 'Section 20 of the draft guidance outlines arrangements for making the Named Person service available for pre-school children. Do you think it provides clarity?' Table 7.1 shows that 84% of organisations and 21% of individuals agreed, while 16% of organisations and 79% of individuals disagreed.

Table 7.1: Question 10

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	15	(94%)	1	(6%)	16	(100%)
Health organisations	15	(100%)	0	(0%)	15	(100%)
Partnership bodies and joint responses	11	(92%)	1	(8%)	12	(100%)
Other national public sector bodies	3	(100%)	0	(0%)	3	(100%)
Third sector organisations	12	(63%)	7	(37%)	19	(100%)
Professional groups	7	(88%)	1	(13%)	8	(100%)
Other organisational respondents	4	(57%)	3	(43%)	7	(100%)
Total organisations*	67	(84%)	13	(16%)	80	(100%)
Individual respondents	6	(21%)	22	(79%)	28	(100%)

* One respondent ticked both 'yes' and 'no'. This response is not included in the table.

Percentages do not all total 100% due to rounding.

7.4 In general, organisational groups said the guidance was clear in relation to pre-school children. However, third sector organisations and those from 'other organisations' were least likely to say that the guidance was clear.

7.5 Altogether, 77 respondents (67 organisations and 10 individuals) made comments at Question 10.

Aspects of guidance respondents found helpful

7.6 Respondents from all organisational subgroups, but particularly those from the partnership and third sectors, commented that the guidance was clear. In particular, respondents thought the arrangements to identify a Named Person pre-birth had been well addressed and provided clarity.

7.7 However, respondents also often went on to highlight issues which they thought needed clarification or additional guidance.

Issues requiring clarification or additional guidance

7.8 There was a wide range of specific requests for further clarification of the guidance; these were often raised by a single respondent. Some of these requests related to the use of terms which it was thought were too vague (e.g. 'reasonably practicable', 'exceptional circumstances'). Other requests for clarification related to the provision of timescales for some of the processes identified (e.g. notification of a newborn outwith normal residence, the timeframe for storage of information about decisions).

7.9 There were requests for clarification as to who the Named Person would be in specific circumstances and how the Named Person would relate to other professionals. In particular:

• It should be made clearer that the health visitor is (usually) the Named Person for this group; it was said that currently some people believe midwives are the first Named Person. What is the role of the midwife and what is the relationship with the Named Person (especially pre-birth)?
• Who is the Named Person if a child does not register for school, or if the family drops out of the Family Nurse Partnership, or if the health visitor is not the Named Person?
• How can the Family Nurse Partnership provide the Named Person when this contradicts the requirement of universalism?
• Why is the health visitor the Named Person when the child has more contact with early learning and childcare providers?
• How will the liaison between the Named Person and nurseries work?

7.10 Other requests for clarification related to information sharing, in the context of geographic transitions (e.g. children moving between Health Board areas) and life-course transitions (e.g. children moving from pre-school to education).

7.11 There were also requests for clarification in respect of children seeking asylum in Scotland, and children whose parents also have a Named Person.

Duties / training / skills of the Named Person

7.12 Points were often made about the duties, training and skills of the Named Person. It was thought that the Named Person must be able to: communicate effectively with this group of children; discuss screening with pregnant mothers; and be trained to ensure fathers are not excluded. It was also thought their duties should include managing the transition to school.

Other issues / suggestions / more general comments

7.13 Issues were raised in relation to Question 10 which are reported in detail elsewhere. In particular respondents commented on the importance of continuity in relation to the Named Person role, and that the distinction between the Named Person and the Lead Professional roles does not reflect accepted practice. Points were also made about linkage with existing child protection procedures.

7.14 Respondents asked about the legal position regarding non-engagement. In particular, when can parents legitimately be excluded from discussions about a child's wellbeing? There were also questions about what should happen if the relationship between a Named Person and a child / parent broke down.

Views from individual respondents

7.15 Some individual respondents made comments in relation to the topics already discussed above (about the need for greater clarity, issues relating to the training and skills of the Named Person, etc.). In addition, some individuals commented that they were opposed to the Act as a whole.

Q11: Named Person service for children who are not pre-school children

7.16 Question 11 focused on paragraphs 6.1.1 - 6.1.8 of the guidance and asked: 'Section 21 of the draft guidance outlines arrangements for making the Named Person service available for children who are not pre-school children. Do you think it provides clarity?' Table 7.2 shows that 71% of organisations and 18% of individuals agreed, while 29% of organisations and 82% of individuals disagreed.

Table 7.2: Question 11

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	15	(94%)	1	(6%)	16	(100%)
Health organisations	10	(67%)	5	(33%)	15	(100%)
Partnership bodies and joint responses	11	(79%)	3	(21%)	14	(100%)
Other national public sector bodies	2	(67%)	1	(33%)	3	(100%)
Third sector organisations	12	(71%)	5	(29%)	17	(100%)
Professional groups	3	(38%)	5	(63%)	8	(100%)
Other organisational respondents	4	(57%)	3	(43%)	7	(100%)
Total organisations	57	(71%)	23	(29%)	80	(100%)
Individual respondents	5	(18%)	23	(82%)	28	(100%)

Percentages do not all total 100% due to rounding.

7.17 A substantial majority of respondents from almost all organisational subgroups (and 94% of local authority respondents) said they thought the guidance was clear. The only exception to this pattern was professional groups, where only 38% thought the guidance was clear.

7.18 Altogether, 73 respondents (63 organisations and 10 individuals) made comments in relation to Question 11.

Aspects of the guidance respondents found helpful

7.19 In general, respondents thought the guidance provided a clear and comprehensive description of the Named Person service for this group, with appropriate flexibility. The inclusion of guidance relating to children excluded from school was particularly welcomed.

7.20 Nevertheless, respondents often went on to highlight issues which they thought needed clarification or additional guidance.

Issues requiring clarification or additional guidance

7.21 Respondents requested further clarification of some of the terms used in the guidance (e.g. 'readily identifiable', 'easily accessible', 'clear and easy access to the Named Person'). It was also thought that the title of this section in the guidance should be reworded to make clear it applies to all children and young people beyond pre-school up to age 18.

Who should be the Named Person?

7.22 There was uncertainty about who the Named Person should be, especially for children not in a state school, children who leave school before they are 18, and children who are in residential / foster care outwith their home authority. It was also not clear when 'joint contact' should be offered.

7.23 Respondents suggested that where an individual was not in education, employment or training, the Named Person should not come from the education sector.

Children excluded from school (6.1.8)

7.24 There were widespread requests for more guidance in relation to exclusion (6.1.8). More guidance was required about how access to the Named Person would be arranged and managed, and what the role of the Named Person would be during this time. These requests were often mentioned in the context of children with disabilities, who were more likely to be excluded.

7.25 It was noted that exclusion from school should only be used in extreme circumstances. It was also suggested that the school may not be the best point of contact at a time of exclusion, and (the appointment of) a 'new' Named Person may be appropriate.

Other issues / suggestions / more general comments

7.26 It was suggested that guidance needed to be developed for groups of children not currently explicitly identified; specifically those at risk of poverty, those who are homeless, those in the criminal justice system, those never enrolled in educational provision, looked-after and accommodated children, those who have complex needs, and other vulnerable groups.

7.27 Respondents also requested guidance about where the working relationship between the Named Person and the parent / child is difficult or has broken down. It was suggested that a dispute resolution process was required.

7.28 Continuity of the Named Person, a single point of contact, and efficient transfer of information about who the Named Person was, were all thought to be important. Respondents also wanted to know what the relationship was between this guidance and local guidance and processes.

7.29 Some respondents asked for examples of good practice to be included in relation to how the Named Person communicated with parents and children. Others focused on the importance of consistency of practice across different areas, and ensuring that Named Persons had appropriate training to be able to communicate with children and young people.

Views from individual respondents

7.30 All the individuals who commented at Question 11 ticked 'no' in the closed part of the question. Many of these were opposed to the Act in principle.

7.31 Those who offered comments in relation to the specific proposals thought that: it was unclear how access to the Named Person by parents would be achieved; it was unclear who the Named Person was for children not in state school; a clear explanation of the circumstances in which parents could be legitimately excluded from discussions about a child's wellbeing was required; and the Named Person in a secondary school should be a member of the Senior Management Team.

Q12: Named Person service for children who leave school before their 18^th birthday

7.32 Question 12 related to paragraphs 6.1.9 - 6.1.25 of the guidance. It asked, 'Does the draft guidance make clear arrangements for providing the Named Person service for children who leave school before their 18th birthday?' Table 7.3 shows that 48% of organisations and 15% of individuals agreed, while 52% of organisations and 85% of individuals disagreed.

Table 7.3: Question 12

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	8	(53%)	7	(47%)	15	(100%)
Health organisations	9	(64%)	5	(36%)	14	(100%)
Partnership bodies and joint responses	5	(33%)	10	(67%)	15	(100%)
Other national public sector bodies	2	(50%)	2	(50%)	4	(100%)
Third sector organisations	11	(56%)	13	(54%)	24	(100%)
Professional groups	4	(44%)	5	(56%)	9	(100%)
Other organisational respondents	3	(50%)	3	(50%)	6	(100%)
Total organisations*	42	(48%)	45	(52%)	87	(100%)
Individual respondents	4	(15%)	23	(85%)	27	(100%)

* Two respondents ticked both 'yes' and 'no'. These responses are not included in the table.

Percentages do not all total 100% due to rounding.

7.33 As the table shows, organisational respondents were generally divided in their views on this question. Health organisations were more likely than other organisational respondents to say the guidance was clear. However, partnership bodies were more likely to say that it was not.

7.34 Altogether, 95 respondents (82 organisations and 13 individuals) made comments at Question 12.

Aspects of the guidance that respondents found helpful

7.35 Respondents from each organisational sector commented that the guidance was clear. Some of these provided a general comment that the guidance was clear overall and did not elaborate further. Others focused on specific aspects including: a) welcoming the focus on children with communication difficulties; b) confirming that the local authority's responsibility for those leaving school at 16 or 17 had been clearly set out; and c) affirming the levels of flexibility and local variation allowed within the guidance.

7.36 Respondents often highlighted issues which they thought needed clarification or additional guidance. In addition, some respondents raised wider points which they wished to be considered.

Issues requiring clarification or additional guidance

7.37 There was widespread comment that the issues in relation to this group were complex and challenging. Respondents repeatedly made the point that keeping track of those who leave school was not straightforward, and it was not clear how contact could be maintained with those who were no longer registered on a school roll. In particular it was not clear 'where and to whom' a concern would be raised for children not moving on to higher education.

7.38 Overall, the guidance for this group (out of the six groups discussed in this chapter) attracted the most concern. Respondents often made comments to the effect that this part of the guidance was 'generally unclear', 'not as clear as the guidance for other groups' or 'in need of greater clarity and specification'. It was felt that the guidance spelled out what was required, but not how it could be achieved. Implementing this requirement was thought to represent a major challenge for local authorities.

7.39 It was also felt that leaving the responsibility for identifying the Named Person for this group to local authorities was likely to lead to a high degree of inconsistency. More specific guidance, and a minimum defined national standard was requested. Respondents thought that examples to illustrate the range of circumstances and possible responses might help. This should also cover the responsibility for awareness raising (6.1.22) and a statement of how proactive local authorities are expected to be.

Who should be the Named Person for this group?

7.40 A range of respondents questioned the merit of allocating school leavers a Named Person who held a promoted post in the field of education. It was suggested that a wider range of professionals might be more appropriate, especially for those who were not in education (e.g. a youth or community worker, a careers guidance professional, or a voluntary sector worker).

Transition to adult services / Interface with adult services

7.41 Respondents often asked for more clarity in relation to the transition to adult services for this group. It was noted that there were specific requirements for young people making this transition, and the Named Person service would be critical to support this. There was a concern that adult services would not be aware of the Act and the accompanying guidance.

7.42 The comments about improving transitions to adult services were often made in the context of children with learning difficulties or disabilities, and children with complex needs. It was emphasised that it would be important for the arrangements to dovetail with other legislation (e.g. Additional Support for Learning Act, Self-directed Support Act). There was also comment that there needed to be clear guidance around the links to adult support and adult protection services.

Linkages to further and higher education establishments

7.43 Respondents asked for clarification of the links with further and higher education establishments, including how these organisations will communicate with Named Persons.

Specific subgroups where more clarity is required

7.44 More clarity about the arrangements was required for a range of groups including: those not moving on to higher education; those who were young parents; those moving from one area to another; those returning from the armed forces; those with communication problems; the chronically ill and homeless; those excluded from school; looked-after children placed out of the local authority area. In this last case it was thought confusing that the placing authority would be responsible for aftercare, and the social worker would be elsewhere, but the home authority would have to provide the Named Person.

Other issues where more clarity is required

7.45 Other issues which required more clarity were: the arrangements for continuity, cover at holiday times, and the training of the Named Person.

Other issues / suggestions / more general comments

7.46 Respondents raised the issue of the importance of balancing the rights and wishes of this age group. This covered: a) the right of a young person over the age of 16 to choose not to engage or to refuse consent for the Named Person to hold or share information; and b) the role of the young person in preparing, and in any decision to prepare, a Child's Plan.

7.47 Respondents thought there were potentially large logistical difficulties in ensuring that these young people - who might be in apprenticeships, or in a workplace or educational establishment - knew who their Named Person was. To work successfully, the systems would require young people and families themselves to navigate them; the realism of this was questioned.

7.48 Finally, the arrangements for information sharing were questioned. More well- defined protocols for information sharing were thought to be required.

Views from individual respondents

7.49 Most of the individuals who made comments at Question 12, were against the Act as a whole. Of those who engaged with the question, there was a view that the guidance in relation to this age group was not practical.

Q13: Named Person service for gypsies / travellers

7.50 Question 13 focused on paragraphs 6.1.25 - 6.1.31 of the guidance and asked, 'Does the draft guidance make clear arrangements for providing the Named Person service for children of Gypsy / travellers?' Table 7.4 shows that 70% of organisations and 24% of individuals agreed, while 30% of organisations and 76% of individuals disagreed.

Table 7.4: Question 13

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	12	(80%)	3	(20%)	15	(100%)
Health organisations	10	(83%)	2	(17%)	12	(100%)
Partnership bodies and joint responses	7	(54%)	6	(46%)	13	(100%)
Other national public sector bodies	2	(50%)	2	(50%)	4	(100%)
Third sector organisations	11	(79%)	3	(21%)	14	(100%)
Professional groups	5	(56%)	4	(44%)	9	(100%)
Other organisational respondents	3	(75%)	1	(25%)	4	(100%)
Total organisations*	50	(70%)	21	(30%)	71	(100%)
Individual respondents	6	(24%)	19	(76%)	25	(100%)

* One respondent ticked both 'yes' and 'no'. This response is not included in the table.

Percentages do not all total 100% due to rounding.

7.51 Partnership bodies, other national public sector bodies, and professional groups were less likely than other organisational respondents to say the guidance was clear.

7.52 Altogether, 72 respondents (63 organisations and 9 individuals) made comments at Question 13.

Aspects of the guidance respondents found helpful

7.53 Those offering positive comments included respondents from professional, local authority, health and third sector subgroups. Specific aspects which were welcomed or thought to be clear included: a) the recognition that there are different types of gypsies / travellers, who have different needs; b) that the guidance was realistic, flexible, and not unduly intrusive; and c) that there was a commitment to overcoming any cultural, language, literacy or other barriers.

7.54 Nevertheless, respondents often highlighted issues which they thought needed clarification or additional guidance. In addition, some respondents raised wider points which they wished to be considered.

Issues requiring clarification or additional guidance

7.55 It was recognised that the provision of a Named Person service to gypsies / travellers was complex and challenging. This was especially the case for those with less predictable patterns of residence, or those who were frequently on the move. Respondents wanted to know how proactive the Named Person service should be in seeking out these children.

7.56 There were requests for more clarity in relation to the Named Person's role with gypsies / travellers, especially for those children not attending school. Respondents asked how, without regular contact, the Named Person could identify any wellbeing needs.

Sharing of information

7.57 The sharing and / or transfer of information was highlighted as requiring clear guidance when a traveller moves between a Scottish school and an English one, and during a period of temporary residency when no registration with a GP occurs.

Wellbeing concerns

7.58 There was a range of comments about how the Named Person service could or should operate if there was a wellbeing concern. It should be made clearer that the decision about who the relevant agency was, depended on the age of the child. Respondents queried what should happen if:

• A family had only recently arrived and it is unclear if they had sought the support of the Named Person service. Will any wellbeing concerns be shared with the Named Person in the current residence area?
• There are wellbeing concerns but not child protection issues for children with less predictable travelling patterns.

Other issues

7.59 Respondents raised a range of other specific issues / queries in relation to this part of the guidance including:

• Which organisation should lead when a family arrives in a new area with a range of children of varying needs / ages?
• Would a promoted staff member within a school be the Named Person if a family was resident in an area for a significant part of the year?
• It would be unwise not to transfer the Named Person role to the child / family's new area, no matter how temporary.
• It is unclear how schools would manage any transfers, given the nature of this group and their relationship with the local authority in some cases.

Other issues / suggestions / more general comments

7.60 There were broader comments made in relation to the cultural aspects in relation to this group. Some respondents highlighted that it was unlikely that gypsies / travellers would wish to engage with the Named Person service, and they questioned the assumptions underpinning the guidance that this group would wish to engage. A range of respondents thought that seeking to know the family's whereabouts could be viewed as an infringement of cultural rights.

7.61 The issues of coordination and tracking meant some respondents called for 'a national approach' or 'a separate national service' with 'a single point of contact' or 'designated person' in relation to this group. Otherwise it was thought that there were risks of confusion, inequality of service provision from one area to another, and overall a lower level of support as compared with that available to non-travelling families.

7.62 It was thought that some examples would help to make the guidance clearer.

Views from individual respondents

7.63 One respondent made strongly positive comments about this guidance, whilst others pointed out the challenging nature of providing the Named Person service to this group. Other individuals made comments which focused on their lack of support for the Act as a whole.

Q14: Named Person service for those who are home educated

7.64 Question 14 focused on paragraphs 6.1.32 - 6.1.39 of the guidance and asked: 'Does the draft guidance make clear arrangements for providing the Named Person service for children who are home educated?' Table 7.5 shows that 77% of organisations and 8% of individuals agreed, while 23% of organisations and 92% of individuals disagreed.

Table 7.5: Question 14

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	11	(69%)	5	(31%)	16	(100%)
Health organisations	14	(93%)	1	(7%)	15	(100%)
Partnership bodies and joint responses	8	(57%)	6	(43%)	14	(100%)
Other national public sector bodies	4	(100%)	0	(0%)	4	(100%)
Third sector organisations	10	(77%)	3	(23%)	13	(100%)
Professional groups	7	(88%)	1	(13%)	8	(100%)
Other organisational respondents	4	(80%)	1	(20%)	5	(100%)
Total organisations	58	(77%)	17	(23%)	75	(100%)
Individual respondents	2	(8%)	23	(92%)	25	(100%)

Percentages do not all total 100% due to rounding.

7.65 Partnership bodies were less likely than other organisational respondents to say this section of the guidance was clear.

7.66 Altogether, 65 respondents (55 organisations and 10 individuals) made comments at Question 14.

Aspects of the guidance that respondents found helpful

7.67 Positive comments on the clarity of the guidance were made by respondents from across all organisational subgroups. Specific aspects which were welcomed or thought to be clear included: a) the role of the local authority in providing the Named Person service; b) the liaison arrangements between health and education and particularly the role of the health visitor in informing the local authority of all school age children; and c) the arrangements for sharing / transferring information.

7.68 Despite these positive comments respondents often went on to highlight issues which they thought needed clarification or additional guidance. In addition, some respondents raised wider points for consideration.

Issues requiring clarification or additional guidance

7.69 There was a widespread view that this was a challenging group in relation to the establishment of a Named Person service. Respondents repeatedly raised questions which indicated there was a concern that local authorities would not necessarily be aware of home educated children in all cases; those who had never registered with a GP and those who were 'missing in education' were specifically mentioned. As with gypsies / travellers, a 'national approach' was advocated for this group.

Communication - responsibilities and timescales

7.70 Respondents had a range of queries in relation to communication:

• Whose responsibility is it to inform the local authority about a child who is transitioning from the Named Person in the Health Board (often the health visitor)? The health visitor? Or the parent?
• What is the timescale for the notification?
• Do home educators have a legal responsibility to make contact with the Named Person?
• How proactive should the local authority be in contacting / meeting parents and offering support?
• If a child is withdrawn from a local authority school it needs to be made clearer that the Named Person who previously had responsibility, no longer has responsibility.
• Is it to be left to the parents' discretion whether to contact the service?

Wellbeing concerns

7.71 Respondents commented that it was not clear how the Named Person would become aware of wellbeing concerns in this group of children. Moreover, more guidance was required on how the Named Person will assess information on wellbeing and under what conditions / circumstances this will be explored with the child and their parents.

Other issues

7.72 Respondents requested more clarity in relation to:

• The participation of the child / parent in the selection of a Named Person
• How a dispute resolution process would be developed / implemented
• How the Named Person will be identified and how variations in the choice of the Named Person will be minimised
• Whether the Named Person can / will help with the transition to post-school life
• Whether parents may choose to opt out.

Other issues / suggestions / more general comments

7.73 A range of broader issues was raised by respondents. It was suggested that the draft guidance misrepresents the current situation on home education, as parents (and others with parental rights and responsibilities) do not require 'permission' to home educate.

7.74 The reliance on the health sector to provide full information was highlighted; local authorities / partnership bodies were not always confident that this would be forthcoming, and asked that a process for this was developed.

Views from individual respondents

7.75 Individuals often made comments which indicated that they did not think the Act could or should be implemented amongst this group of children. These individuals saw the Named Person service as an unwelcome and unnecessary imposition. A smaller group of individuals made more detailed points concerning who could act as Named Person for a home-schooled child, and the responsibility of the parent to make contact with the Named Person.

Q15: Named Person service for families with more than one Named Person

7.76 Question 15 concerned paragraphs 6.1.41 - 6.1.43 of the guidance and asked: 'Does the draft guidance make clear arrangements for providing the Named Person service for those families with more than one Named Person?' Table 7.6 shows that 81% of organisations and 16% of individuals agreed, while 19% of organisations and 84% of individuals disagreed.

Table 7.6: Question 15

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	13	(87%)	2	(13%)	15	(100%)
Health organisations	12	(86%)	2	(14%)	14	(100%)
Partnership bodies and joint responses	12	(80%)	3	(20%)	15	(100%)
Other national public sector bodies	4	(80%)	1	(20%)	5	(100%)
Third sector organisations	9	(64%)	5	(36%)	14	(100%)
Professional groups	10	(91%)	1	(9%)	11	(100%)
Other organisational respondents	4	(80%)	1	(20%)	5	(100%)
Total organisations*	64	(81%)	15	(19%)	79	(100%)
Individual respondents	4	(16%)	21	(84%)	25	(100%)

* One respondent ticked both 'yes' and 'no'. This response is not included in the table.

Percentages do not all total 100% due to rounding.

7.77 In general, organisational respondents thought this part of the guidance was clear. However, third sector organisations were least likely to say this.

7.78 Altogether, 69 respondents (61 organisations and 8 individuals) made comments in relation to Question 15.

Aspects of the guidance that respondents found helpful

7.79 A few respondents specifically commented that they thought the guidance was clear. Specific aspects which were welcomed or thought to be clear were the need for dialogue and communication, and the requirement to share relevant information between different Named Persons.

7.80 Respondents nevertheless often highlighted issues which they thought needed clarification or additional guidance. In addition, some respondents raised wider points for consideration.

Issues requiring clarification or additional guidance

7.81 Respondents often referred in their comments to the complexity of the situations where more than one Named Person was involved. These were thought to be some of the most vulnerable families, and the guidance was not thought to be sufficiently clear to handle complex arrangements. There were many requests for detailed practice guidance which would complement and elaborate the current guidance, as well as a request for a firmer statement of what is required to meet the statutory duties.

Communication and dialogue

7.82 Respondents emphasised the importance of good communication and dialogue. They thought that this was a necessity, and the guidance should be amended to reflect this.

Accountability arrangements

7.83 The difficulties of ensuring clear accountability arrangements where multiple Named Persons were involved was mentioned repeatedly. Respondents wished to know who had responsibility for co-ordinating the arrangements between the Named Persons, who would take overall / lead responsibility, and whether (and how) an overarching plan would be developed. The point was made that families want one point of contact. Moreover, part of the rationale behind GIRFEC was to ensure families did not have to deal with a wide range of professionals with potentially conflicting points of view.

Information sharing

7.84 Points were often made about the complexities and the importance of developing clear information-sharing protocols to cover the situation where more than one Named Person was involved. Respondents made specific requests for more clarity in relation to:

• Situations where there are children within one family who do not all reside in Scotland
• Whether one Named Person could share information with another Named Person of a child in the same family
• How one Named Person will know that another Named Person is involved with the family
• How receptive parents would be to information being shared regarding other children's school attendance or professional contact
• Ensuring that if information is shared it is given to the correct individual.

7.85 Finally, more detail was requested about what was meant by 'all information which the outgoing service provider holds which is likely to be relevant to the Named Person function'. It was suggested that core data should be defined and listed (e.g. numbers and names of siblings).

Other issues / suggestions / more general comments

7.86 Some respondents asked for 'a national approach' to be adopted with this group. It was also suggested that there was the potential to learn from the progress made nationally in the field of child protection.

7.87 As mentioned earlier, respondents thought that the current guidance runs contrary to the GIRFEC Practice Model whereby service providers should be limiting (not increasing) the number of people involved with the family.

Views from individual respondents

7.88 Some individuals who made comments at Question 15 felt the guidance lacked clarity, or was too general. More often, respondents were not in favour of the Act.