National guidance for child protection 2021: consultation report

Advice and Accessibility

Q1: Advice and Accessibility – This guidance seeks to provide advice to local partnerships and agencies to inform the development of local guidance, and has been structured in sections that are intended to be standalone and accessible to practitioners seeking advice on particular aspects of practice

In your view, does the guidance fulfil these objectives?

Stakeholder Event Themes

The main themes raised at the stakeholder events were:

The guidance is comprehensive and thorough, but this inevitably means it is a long and relatively complex document.

Some parts of the document are more detailed and/or appear more prescriptive than others (in particular Part 3). This was welcomed by some, but not all.

The addition of Part 4 was generally welcomed, although some felt it was not clear how it relates to other parts of the guidance.

The multi-agency focus and partnership working ethos could be more explicitly stated.

Online publication, including the use of hyperlinks, will help readers navigate the document.

Developing tailored/accessible versions for key groups – such as children and families – will be important.

A small majority of respondents (52% of those answering the question) thought that the guidance fulfils its advice and accessibility objectives to some extent.

Around 100 respondents made a further comment at Question 1.

Overall assessment

In their initial comments, a number of respondents welcomed the revision of the guidance, sometimes also commenting that keeping a degree of consistency with the previous version, particularly in terms of overall structure, is helpful.

Very much reflecting the answers to the closed question, the overall balance of opinion was that guidance fulfils the objectives of providing information in structured, standalone sections which are accessible. It was described as well laid out, well-structure, well-written and easy to read.

A frequently made comment was that the guidance is comprehensive and detailed, and while this was welcomed, that it does inevitably mean it is also lengthy. Some respondents thought the guidance is too long, and that this will affect its accessibility and useability.

Other concerns raised about the length and complexity of the guidance included that:

• It will potentially be daunting for some practitioners and other stakeholders. This may apply especially to those who do not work directly in the frontline services of Social Work, Education, Police and Health.
• It could result in fewer practitioners reading and using the document.
• There may be a risk that some key elements become lost in the volume of material.

An associated concern, and one which spoke to some of the issues about policy and principles covered at Question 2, was that the intention to promote cultural change could be lost in those sections that are, by necessity, more prescriptive than others. It was suggested that significant shifts in practice, along with the reason behind these shifts, could be set out in the early stages of the guidance and an Executive Summary could emphasise the wider cultural changes to which Scotland aspires.

Also, in relation to the length and complexity, it was suggested that the current draft:

• Contains some irrelevant information. Examples given were that the section on the definition of a child also discusses adult protection and the coverage of the Children (Scotland) Act 1995 goes beyond the scope of the guidance.
• Contains unnecessary repetition. Further comments included that this is particularly the case in Parts 2 and 4. Repetition between Part 1 and Appendix A was also highlighted.
• Goes beyond guidance, weaving procedure with research and information, which affects its accessibility in some parts.
• At times reads like regulations associated with legislation.
• Blurs into procedural elements at times.

Audience for the guidance

As noted in the question, the national guidance seeks to provide advice to local partnerships and agencies to inform the development of local guidance. It was suggested that local partnerships and agencies are likely to find it to be a helpful source document for shaping local guidance. Related comments included that:

• The intended audience should be clearly specified at the very start of the publication.
• It would be helpful to suggest that local multiagency partnerships and organisations should be clear about their reasons should they decide not to follow the guidance.

However, not all respondents agreed with the focus on local partnerships and agencies, and it was suggested that the scope of the guidance should be expanded to take the needs of other organisations and the general public into account.

Other comments included that the intended audience for the guidance is not clear. It was suggested that it is currently presented as a mixture of strategic and operational guidance for partnerships, services, agencies and in parts for practitioners and managers respectively. Meeting the needs of a very wide audience was acknowledged as challenging, including because it may mean at times that the document cannot be too specific or prescriptive. This, in turn, was seen as highlighting the need for robust local implementation.

Respondents identified particular audiences or groups that may find the guidance helpful, sometimes also commenting on particular aspects that may be helpful to them:

• Newly qualified Social Workers may find the structure particularly helpful.
• Individual aspects are designed in a way that will assist and enable accessibility for all healthcare staff, partnerships and agencies.

However, it was also suggested that a particular weakness of the draft is that, unlike the 2010 and 2014 versions, it no longer provides a reference point for children, young people, families or their representatives or advocates. Suggestions for providing accessible materials for a range of audiences are covered further below.

Tone and language

Some respondents commented on the tone of the guidance document, including with reference to the type of language used. The changes in language used relative to previous versions were welcomed, including as a way of supporting the development of increasingly relationship focused, strengths-based and inclusive practice. Support for what was described as a shift to a much more prescriptive tone was also welcomed.

Acknowledging the changes of tone and terminology at the start of the guidance was suggested, as was setting out the rationale for the changes. Child Protection Case Conference being replaced with Child Protection Planning Meeting was given as an example of the type of change that could helpfully be explained.

Other observations included that, although some sections are an easy read, some of the language used is complex, academic or overly complicated. There was a concern that the document may not be accessible to all partners and agencies due to the complex and, in some places, technical language used. It was suggested that a plain English review should be carried out.

There were also comments on the use of particular terms or phrases, which included that:

• As discussed at Question 11, the use of the term 'disabled children' as opposed to 'children with disabilities', is outdated. However, it was also reported that the term disabled people has its roots in the disabled people's movement. Consulting relevant Disabled People's Organisations, as well as children and young people with learning/intellectual disabilities themselves, on the best language to be used was recommended.
• The term ICT is used in the document which could be confusing for practitioners as the term that is now used is digital literacy.

Finally, it was noted that the national guidance will (understandably) use terminology that does not always reflect local processes and procedures and that an element of 'translation' will be required, limiting its immediate application to practice.

Structure and layout

General observations about the structure were that it is well structured and easy to navigate, including for practitioners who may be less familiar with an area of practice. Specifically, it was suggested that the standalone sections will support practitioners in seeking advice on particular aspects of practice.

However, there was also a view that using the sections as stand-alone relative to other sections of the guidance could present difficulties. In particular, it was thought that a thorough reading of the whole guidance would be required to understand key terminology, such as harm, significant harm and risk of significant harm and to inform a proper consideration of underpinning factors such as poverty, disability, trauma and discrimination.

More broadly, it was suggested that the guidance does not read as a stand-alone document in its own right, but instead reads as a follow on from the 2014 guidance. Further comments included that the draft text makes repeated reference to the 2014 guidance and at times assumes prior knowledge of existing guidance, policy and practice frameworks. The associated concern was that this has the potential to create inconsistencies in the development of local guidance and may make the new guidance less accessible to newly qualified practitioners or workers taking on new roles with added responsibility for child protection.

In relation to other aspects of the structure, elements which respondents thought worked particularly well included:

• Practitioners can clearly see the different issues and can navigate to their particular area of interest.
• The addition of visuals such as flowcharts.

Areas for possible improvement identified included:

• Making the guidance elements more prominent and easier to extract from the research and reference elements.
• Giving more attention to presenting information in a way that aids the learning and understanding of those using it.
• Including a better index and more comprehensive contents page.
• Numbering paragraphs consecutively from the beginning to the end of the guidance document.
• Ensuring that the layout and formatting is consistent, for example in the use of headings, sub-headings and bullets, presentation of hyperlinks, accuracy and consistency of referencing and the use of bold text or text box shading.
• Colour coding of sections.
• More use of diagrams.
• Including a summary, highlighting the main points covered, at the end of each section.
• Links to resources opening in a second window rather than taking the reader out of the documents as at present.
• Including a search function.

Comments about different parts of the document (other than in relation to their specific content, which is covered at subsequent questions), included:

• The more procedural approach taken in Part 3, including relative to the previous version of the guidance, is broadly welcome. The possible advantages of the more procedural approach identified included supporting the development of local procedures and protocols. However, there was also a concern that Part 3, and the more procedural approach, may be overly prescriptive and potentially lead to confusion for staff if the guidance differs from local procedures.
• There is reference to the sections standing alone, however this does not seem to be the case for Part 4 - Specific Concerns. The purpose of this section and how it relates to practice is not clear.

Publication approach

Amongst those who commented, there was broad agreement that the most effective way to publish the guidance would be online, including because it will mitigate the impact of the size of the document to some extent. Among the advantages of the online approach identified were that it will:

• Help with functionality and navigability, including through the use of navigation links and links to sources of information.
• Ensure that the guidance can be updated quickly should legislation change, or policy develop. This was seen as particularly important given the changes in legislation which are expected in the coming year, with reflecting these in the guidance providing a national approach making sure the workforce is aware of them.

Practical aspects highlighted as needing to be taken into account included:

• Providing the document on an app platform for ease of access, perhaps something similar to the SSSC app for adult protection.
• Ensuring the guidance is readily accessible from various IT platforms / devices.

However, it was also noted that consideration will need to be given to the needs of those who do not have online access.

In addition to commenting on the online publication, other points raised included that:

• It will be important to ensure that this resource is widely available 24/7 and accessible to all staff working across the public, private and third sectors, some of whom may not always have easy and unrestricted access to web-based resources. There may be occasions when staff need to access and print off key sections / webpages; there should be a full print facility option, supported by very good search, indexing, referencing and navigation functionality.
• Availability of the guidance in word format is welcome as this makes the documents accessible with screen reading software and magnification.
• The guidance should be version controlled.
• A designated keeper of the resource should be clearly identified.

Other ways to maximise accessibility

Respondents also suggested a range of ways in which they thought that the guidance could be made as accessible as possible. Reflecting some of the comments above regarding the audience for the guidance, these included developing a suite of supporting resources for different audiences, including for:

• Children and young people.
• Families, parents and carers.
• Those with lived experience.
• Chief Officer Groups.
• Frontline practitioners.
• Professional groups who have less direct experience of Child Protection processes.
• Sports bodies.

Suggestions relating to the type of resources that could be helpful included:

• An app.
• Easy read versions.
• Abbreviated versions or executive summaries.
• Briefings, specifically 7 minute briefings.

These suggestions sometimes came together around an app for use by frontline practitioners and an easy read version of the guidance for children and families.

It was also suggested that practitioners should be asked to test the planned practice notes to ensure they are clear.

In terms of language or translations, suggestions included that materials should be available in:

• Gaelic.
• British Sign Language.
• Braille, large print, and accessible electronic formats for the benefit of those with vision impairment.

Other comments addressed how the guidance could be promoted and shared, including how practitioners could be supported to become familiar with, and make good use of, the guidance. Suggestions were sometimes similar to those made at Question 12 (concerning implementation), and included:

• Having the guidance and associated information and links all in the one place online, for example housed within one website that is searchable by topic.
• Introducing the guidance through training sessions or conversation cafés.

Review and revision

Both at Question 1 and elsewhere, a number of respondents highlighted the importance of the guidance being subject to regular review and revision.

In terms of the current draft and associated materials, it was suggested that:

• The guidance needs to be island-proofed. An Island Communities Impact Assessment being undertaken was welcomed. As highlighted at Question 11, it would be beneficial for the final document to more explicitly reference issues relating to remote and rural life, such as challenges associated with delivering the range of services and approaches suggested within the guidance.
• The document should be subject to an independent review and edit, to remove repetition, ensure plain English is used and rectify any grammatical or punctuation errors.