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Chamber and committees

Education Committee, 22 Dec 2004

Meeting date: Wednesday, December 22, 2004


Contents


Protection of Children (Scotland) Act 2003

The Convener (Robert Brown):

Good morning. I welcome members to this meeting of the Education Committee. As always, when we are in public session, people should make sure that their mobile phones and pagers are turned off.

We move to agenda item 1 and resume discussion of the arrangements proposed by the Scottish Executive for the implementation of some provisions of the Protection of Children (Scotland) Act 2003, which is scheduled to come into force on 10 January.

We heard evidence from officials last week, and I am pleased to welcome to the committee Euan Robson, the Deputy Minister for Education and Young People. Since the committee's meeting last week the minister has had discussions with representatives of some of the voluntary sector groups. I invite Euan Robson to make an opening statement about where we are on this complicated matter.

The Deputy Minister for Education and Young People (Euan Robson):

Thank you for meeting today; I welcome the opportunity to be here. As you say, I have had discussions with the voluntary sector.

I will set out briefly how I think we should proceed. I appreciate the fact that the voluntary sector organisations have been available at short notice to discuss the act. I also appreciate the informal input of the convener and members of the committee.

As members will recall, the aim of Parliament in introducing the Protection of Children (Scotland) Act 2003 was to ensure that the most effective protection was available for children. I welcome a number of the statements made by voluntary organisations this week, saying that they are fully committed to that principle. I am sure that we all are. The act strengthens that protection and in doing so creates a number of new offences, as we know from when the act went through during the previous parliamentary session.

The Executive is keen to give effect as soon as possible to the additional protections for children that Parliament has agreed are necessary. Because of the concerns expressed by the voluntary sector during the passage of the bill about the need to allow them time to prepare, we agreed not to implement the act for at least a year. We undertook not to implement it before spring 2004, but by 31 December 2004. Since laying the commencement order on 1 December 2004 to bring the act into force on 10 January 2005, 14 months after the passage of the act, we have listened to the concerns of some voluntary sector organisations that they need a further period of time to get ready for implementation. We have also listened to the concerns of MSPs and members of the Education Committee about the position of some voluntary sector organisations.

As the convener said, I met representatives of the voluntary sector on Monday afternoon and Tuesday morning. I understand from those discussions that the key concern is that some voluntary sector organisations are unaware of the requirement to check new appointees for the wide range of positions that are covered by the act. Was it the intention of Parliament that the act should be wide enough in scope to cover the voluntary sector? I believe that the former Education Committee took that view particularly strongly. However, we understand that there are some who are not aware of the implications of the requirement.

We therefore looked at the act in relation to that particular offence and proposed that we defer the offence element for three months only. In so doing, we want to ensure that the maximum protection available to children under the act is in place from the commencement date of 10 January. Under that proposal, from that date, individuals will commit an offence if they are on the list of those disqualified from working with children and they continue to work or seek work with children. The voluntary sector representatives were fully in agreement with that.

From 10 January, organisations will be required to make a referral to the list of those disqualified from working with children if they dismiss an individual or move them from a child care position because they have caused harm to a child or placed a child at risk of harm. All other requirements to refer will also apply from that date, for example, to those who the organisation would have dismissed or moved if they had not resigned before that could be done. Again, none of the voluntary sector organisations raised with me any particular difficulty with that.

All organisations that need to will be able to make checks against the list from 10 January, although they will not be at risk of committing an offence if they do not do so until the three-month preparation period is concluded. That is the key point that voluntary organisations made to me in discussions in the past few days. Although the offence element is deferred, we know that many organisations are fully aware of the act and are ready to deal with its provisions, so it is not a uniform picture that we have discovered in the past few days. We expect that those organisations that are aware of the new requirement will check all new appointments from 10 January. Organisations will be able to make referrals retrospectively from any dismissals or moves made before the act entered into force if they wish to do so. There is no duty to make retrospective referrals, but it is open to organisations to do so if they consider it necessary.

The technical means to achieve deferral of the offence element are relatively simple. We would need to make one amendment to the commencement order to bring section 11(3)(a) of the 2003 act into force from 11 April. I understand that that is the day we return from the Easter recess and schools go back. In effect, there is a complete term before section 11(3)(a) comes into force. That gives a further three months for preparation. However, I emphasise that there will be no further change from that date and I hope that the committee will support that position. No date has yet been fixed for the implementation of section 11(3)(b) of the 2003 act, which would trigger the need for retrospective checking of existing staff or volunteers. As I have tried to make clear, that requirement will be subject to further consideration of how its implementation might best be managed. There was some discussion that that might be in April, but April would have been the earliest date that we could have considered. There is no date for the retrospective checking that will be brought about by section 11(3)(b).

The Protection of Children (Scotland) Act 2003 Determination Regulations 2004 (SSI 2004/523), which are the technical regulations that are currently subject to scrutiny, would remain as they are and enter into force on 10 January. They are needed from that date in order to set out the procedures under which the decisions and referrals will be made.

In summary, I hope that we have met the concerns that were expressed to me by the voluntary organisations in our two meetings and those that have been expressed to MSPs.

We have had some discussion about guidance. There are four parts to the guidance. Some 10,000 copies of the guide, the contents of which I have in this folder, are being printed and 6,500 will be distributed initially. There is to be some addition to that, but a summary will be produced and distributed. A voluntary sector leaflet has been finalised and has gone to the printers. There will be some additional guidance—two pages long—to help people make an initial assessment of whether a position is covered and needs to be checked. That will be the subject of discussion with the sector during January. There will be a framework meeting on 25 January during which organisations will be able to raise their concerns again. I will continue dialogue with anyone who has further concerns, but I hope and think that we have now arrived at a situation in which, in practical terms, we can proceed to implement the act that Parliament passed.

The Convener:

I would like to clear up one or two preliminary aspects. You have said that the retrospective checks are not coming in at the moment, but the committee has longer-term concerns about that because of the sheer numbers of people involved. Could you undertake to discuss the matter with the committee before the commencement order is laid?

It is clear that we are going to have to have considerable discussion about retrospective checks. I intend to come back to the committee to explain what is eventually agreed.

The Convener:

Can you share with us the names of the organisations that you met recently? In last week's evidence, an issue was raised about the appropriateness of some of the organisations in terms of how representative they were of the interest groups involved.

Euan Robson:

On Tuesday, I met the Scottish Council of Voluntary Organisations. On Monday, I talked to a representative group comprising Mr Duffy from the Scout Association, Mr Thomson from Volunteer Development Scotland, a lady from YouthLink and two other groups—

Maureen Verrall (Scottish Executive Education Department):

Children in Scotland and sportscotland.

That group was as representative as we could make it, given that it was brought together at relatively short notice. However, the representatives brought with them the concerns of others.

The Convener:

If I understand correctly the evidence that we have heard, the substance of the matter falls into two bits. As you rightly say, there was a concern that everything should be in place so that the organisations on the ground and the headquarters offices had all the information. It was also felt to be important to ensure that account was taken of any organisations that do not fit into clear categories. That is helpful. However, questions were raised about whether the information would be adequate and whether the guidance would be appropriate in relation to such issues as working under supervision pending disclosure and so on. Can you give us a clear indication, on the question of guidance in particular, of the position regarding agreement with the voluntary groups on all of that? Is the voluntary sector pack in a finalised form?

Euan Robson:

I tried to summarise the position at the end of my statement. Deferring section 11(3)(a) of the 2003 act until 11 April 2005 will help us to ensure the physical distribution of appropriate material. For example, a summary document will be prepared for the major training pack, which I believe all committee members have received. Therefore, rather than have to read the whole pack—it took me about an hour and a quarter to do so and I found it to be a particularly good document—people will be able to read the summary quickly.

I can leave a copy of the leaflet that is specifically for the voluntary sector with the committee for members to look at. The leaflet was prepared by the voluntary organisations themselves and is at the printers as we speak. About 70,000 copies will be available and more will be printed if necessary. There will also be additional guidance—an issue that the voluntary groups raised with me during my discussions with them on Monday and Tuesday—on roughly two sides of A4, but members should not hold me to that description. The guidance will help people to make an initial self-assessment of whether they are covered by the terms of the act.

The Convener:

I want to press you on the key points for guidance. The two main issues that emerged in discussion at last week's meeting—and in private discussion with voluntary sector groups—were working under supervision and normal contact with children. One appreciates the variability of the circumstances for which additional guidance and help is required, particularly for small groups.

Euan Robson:

Absolutely. That guidance issue is, as you say, a cause for concern. We intend, with voluntary sector colleagues, to ensure that guidance is incorporated in the two-page guide so that there will be a clear statement of how one should proceed in the circumstances under question. The issue was, as you said, raised by the voluntary sector groups. We will discuss it with them to ensure that we get the appropriate advice and information across.

For the avoidance of doubt, can we be clear that those particular matters are to be discussed further and that the terms of the guidance are yet to be agreed?

Yes. As I said, the two-page leaflet has not yet been produced, but it will be. It is a response to the points that were made in the two meetings to which you referred.

I have a couple of further questions, but I have rather dominated questions so far. Therefore, I invite other members to ask their questions first.

Dr Elaine Murray (Dumfries) (Lab):

I am sure that the committee is pleased to hear that progress has been made on the concerns that were raised during last week's meeting. Maureen Verrall advised me during that meeting that it would be necessary either to defer the whole act or not to defer it at all. Has the position shifted in terms of what is now possible?

Euan Robson:

Yes. Having discussed with the voluntary sector its concerns, we have found the means of taking out until 11 April the element in the act that they found most difficult. We are, in effect, striking a balance between those groups' concerns, the desire of organisations that are ready to proceed to do so, and our wish to commence the act, given that it is now 14 months since the act was passed. It was Parliament's intention that we do so. Therefore, by means of an amending order, we will take out section 11(3)(a) until 11 April. That will take out the element that gave most cause for concern to the voluntary sector. When speaking to them about whether that would be a way forward, we found that they welcomed the proposal, which we now intend to implement.

I also want to ask you about guidance. We were told last week that a separate set of general guidance was being produced for everybody. It was supposed to be on the Executive's website by the end of the week. Is that guidance there?

It is there.

Dr Murray:

We met representatives of Disclosure Scotland on 27 October, and we discussed guidance in respect of the Police Act 1997. It appeared that there was fairly little guidance about who needed to be disclosure checked and under what circumstances. It is clear that many authorities and other bodies are erring on the side of caution, owing to the lack of guidance. Brian Gorman told us:

"With the introduction of the Protection of Children (Scotland) Act 2003, some form of guidance to authorities and voluntary groups may well be provided."—[Official Report, Education Committee, 27 October 2004; c 1661.]

Is the guidance that is likely to be provided going to include guidance on the Police Act 1997 and on disclosure in particular? We have heard about issues involving people wanting to help out with a school disco or with walking buses and so on. At the moment, there seems to be a very strict application of disclosure provisions. Will the guidance that you intend to distribute include guidance on when disclosure is appropriate and when it is not?

Disclosure Scotland has been in regular contact with the Education Department, and has confirmed that it is in a position to proceed. For the purposes of accuracy, I will ask Maureen Verrall to give you some more detail.

Maureen Verrall:

The guidance that we are producing and the question of which positions need to be checked relate to the interaction between the Protection of Children (Scotland) Act 2003 and the Police Act 1997. The 1997 act effectively gives us the power to set aside the Rehabilitation of Offenders Act 1974 for certain positions in order to disclose information about spent convictions under certain circumstances.

The 1997 act provides the technical means to enable the checks to be done; it is the 2003 act that requires the checks to be done. The 2003 act makes it an offence to employ anybody in a child care position who is on the list, and it is the definition of that child care position about which we understand that some people are being extremely pure, in that they are saying that anybody who works in an organisation that has anything to do with children must be checked, even if they themselves never come into contact with children. The legislation does not say that.

The two-page guidance that we are working on will tell people that there is a connection between different parts of the 2003 act. First, it must be asked whether an organisation is likely to be covered, and examples may be given of the sort of organisations that would be caught under the legislation. Secondly, it must be asked whether the organisation is employing somebody in a child care position, as defined under the act. A detailed description of child care positions is provided under schedule 2. We need to make it clear that the positions falling under that schedule are the kinds of posts that organisations need to consider. If the answer to those two questions is yes or highly probable, the organisations concerned need more detail and specific guidance on the posts in question. I reiterate that it is the Protection of Children (Scotland) Act 2003 rather than the Police Act 1997 that contains the requirement for checking.

Dr Murray:

I appreciate that, although people have been getting disclosure checked for some years now. The 2003 act brings in additional concerns, because there is a new criminal offence involved. The procedure for checks has been in place for some time, however, and there has been a fairly rigorous application of disclosure checks in some parts of the country. It is that additional anxiety, on top of people's experience of disclosure, that has created a problem.

Maureen Verrall:

The Police Act 1997 does not require anybody to be checked; it enables checks to be done if people consider that necessary. It is not the regulations under the 1997 act that define the positions that need to be checked; it is the 2003 act that does that.

So why have people been getting disclosure checked for several years?

Maureen Verrall:

There are of course some requirements under the Police Act 1997. However, in relation to the concerns that members are raising, the guidance that needs to be issued relates to the definition of child care positions under the 2003 act. It is the 2003 act that is relevant for people who are asking whether, when the act enters into force, they will have to check, for example, everybody organising walking buses, every member of a parent-teacher association—even if they never come into contact with children in that capacity—every member of a scout group or anyone who runs a disco at a school youth club, even if they are just there as a disc jockey, for example. As I understand it, what is being asked for is the guidance relating to the 2003 act coming into effect. The two acts are connected but I am not sure that separate guidance on the Police Act 1997 is what is required.

Dr Murray:

What I am proposing is general guidance for the lay person about when they need to be disclosure checked, and that the guidance should be in a relatively simple form so that people know if they need to be disclosure checked, whether they are in a local authority or a voluntary group or whether they are people such as councillors and MSPs who go to talk to children about their jobs. People are asking for a clear and simple form of guidance that indicates what needs to be done and when it might be a criminal offence not to have a disclosure check done. If that sort of guidance could be made available to everyone, it could prevent some of the rather ridiculous stories that we are hearing at the moment about people not being allowed to do things.

Euan Robson:

Indeed, and it is precisely that type of point that a number of the voluntary bodies have raised with me in the past three or four days. The purpose of producing what I characterise as two-page guidance is that that will be one of the objectives that the guidance will cover.

There will have to be discussion about the precise detail of the guidance. We will have to have those discussions with the voluntary organisations in early January. If it is helpful to the committee, we can keep it informed by letter or, if you want me to come back, we can have further discussions so that you can see the process as it develops into the eventual end product. We have to start that work and that is the undertaking that I have given to the voluntary sector organisations that I have met.

Dr Murray:

In the lift on the way up to this meeting, one of our colleagues told me and Wendy Alexander about a constituent who had a knife in his car when it was serviced, and now he is not allowed to go into his children's school. That is the type of thing I am talking about; people are getting over-anxious because they do not understand how the legislation should work. It is a crazy situation.

Indeed. There have been some headline-grabbing stories—some of which have involved Santa Claus—and we are well aware of those.

Lord James Douglas-Hamilton (Lothians) (Con):

I have two questions for the minister. First, he will be aware that there is no motion to annul the order before the committee this morning, as far as I know. Does he accept that, in the past, ministers have often refused to interpret the law, saying that that is a matter for the courts? However because this is such a sensitive matter, does the minister accept that there is a case not just for guidance, but for guidance as to best practice? The danger is that local authorities, charities and voluntary bodies might be inconsistent in how they interpret the law. They might interpret it in several different ways. If guidance can be given as to best practice, that might be of considerable assistance.

Euan Robson:

I entirely agree with Lord James. Ultimately, it is up to the courts to decide as to scope and who is covered. However, I reassure him that we are talking to the Convention of Scottish Local Authorities directly about interpretation and we will address the points that he makes. We seek to ensure that the eventual guidance will point to how to proceed and, of course, to best practice. That must be the objective. Lord James is correct that it is up to the courts. In any legislation, it is the courts that will make the final decisions as to scope.

Lord James Douglas-Hamilton:

I thank the minister for his response.

Secondly, in light of the great concern expressed by local authorities, voluntary bodies and charities, could he review, in due course and in light of experience, what has happened and, if necessary, come back with revised guidance or a revised order?

Euan Robson:

Part of what we must do, moving ahead, is keep in close contact with all those organisations and their representatives, as we tried to do previously. The engagement will need to continue because of the retrospective checks and how we implement the will of Parliament in that regard. You can be assured that there will be development over the course of the next year.

On the point about COSLA, we are trying to get information from that organisation about what local authorities are doing in a number of instances. The discussion with COSLA will continue after we have gained a more clear understanding of different interpretations that are currently being applied.

There will be on-going dialogue and on-going developments. You can be assured that we will keep the committee closely informed in relation to that.

Ms Rosemary Byrne (South of Scotland) (SSP):

I appreciate the minister's efforts to meet the voluntary organisations and discuss the issue, but I am sure that I am not the only member who has been contacted by volunteer centres that have concerns that I do not think are being answered. I will raise a couple with you.

Do adults who work in charity shops in which there are young volunteers have to go through this process? People do not know and are concerned about their legal position. I am also told that there is confusion about who to risk assess and who not to. Apparently, officials have told organisations that it will be up to groups to determine who they should assess. It seems that it has been left to individual organisations to interpret complex legislation.

The legislation is extremely complex. I started to feel hopeful when you were talking about delaying implementation of section 11(3)(a) of the 2003 act until 11 April. However, as happened last week, I felt my heart sink at the thought of the sheer confusion that exists around this matter.

The situation that some voluntary organisations are being placed in concerns me. I do not think that I am hearing anything that reassures me in that regard.

What is your question, Rosemary?

My question is: what do I say to the organisations who come to me? What guidance do I point them to? What reassurances can I give them?

Euan Robson:

At the outset, I should say that we all value the immense contribution that the voluntary sector makes. The examples that you give are important and we would want there to be continuing clarity about how to proceed. That is why, at the request of the voluntary organisations, we have agreed the action that we are about to take—to suspend section 11(3)(a), to provide a three-month period in which there is no offence. Equally, that will give time for the leaflet that the voluntary sector has prepared to be distributed. It will also give time for the training pack to be distributed. Further, it will enable us to send out the additional leaflet that will assist people to make the initial assessment as to whether people are covered by the act.

Many voluntary sector organisations have told me that they need more time and I have accepted that. When they have had the chance to read the packs, leaflets and so on, I think that some of the confusion will disappear. Clearly, that must be the objective.

The other thing that came out of the discussions with voluntary organisations was that some of them felt that they had not had enough opportunity to discuss matters with what you might describe as their local branches. Some have managed to obtain the information, digest it and talk to their regional organisations, but they have not yet had time to talk to their local branches.

We do not want there to be difficulty and confusion for volunteers: we value the work they do. That is why we are taking the actions that we are proposing this morning.

The Convener:

The substance of Rosemary Byrne's point goes a bit further than that. The letter that I have had from the Volunteer Centre Edinburgh, which I think is the one Rosemary was referring to, says specifically that the centre is concerned about taking on young volunteers to help in the charity shop.

The general idea, I suppose, is that those young volunteers might work a morning a week or a Saturday. The fear is that if those volunteers have to be disclosed as well, such organisations might feel that it is not worth their while getting into this complex morass and they will not take on volunteers aged under 18. It may be that you are bound by the act in that regard—it does sound as if there is regular contact as part of the normal job—but are you or your officials able to give specific guidance to us on that kind of general situation, which is fairly common?

We are bound by what the act says, and it is my understanding that the act would cover that particular situation.

Is there anything we can do to have further discussions with people and to help them understand the situation? We could speak to representatives from YouthLink Scotland, for example, which is not one of the usual organisations.

I am happy to meet it early in the new year and to work on the way forward. However, you must understand that Parliament passed the act and that the Executive must implement the intention of Parliament.

Fiona Hyslop (Lothians) (SNP):

I am stunned by the complacency that is being exhibited here and by the fact that the meeting that was hastily arranged in the past few days has resulted in a change that we were told only last week was legally and technically impossible.

Can you confirm that the advice that we were given last week—that it was an all-or-nothing implementation—was wrong? Can you also address the question where that leaves children? We now find ourselves in the worst of all worlds: delay in legislation that is meant to protect children and confusion in the voluntary sector about what is required. We are in limbo, which is creating a great deal of confusion. We need to bring some common sense to bear.

The guidance that we were told would also cover the Police Act 1997 is not ready yet. It needs to be made ready. What will you do differently, having made a mess of the implementation of the legislation over the past two years? When are we likely to see progress? What will you do differently to ensure that the concerns of front-line volunteers who have been caught up with that problem are addressed—rather than have hastily arranged meetings to come up with a fix to something that should have been sorted months ago?

Euan Robson:

I reject a number of the points that you have made. The first and most important thing is that officials, in all good faith, gave you advice and evidence last week. In fact, a way was found to address the specific concerns that were raised with us. That required some detailed work, research and legal advice, which was sought after last week's committee meeting and after the discussion with the voluntary sector. I would like to make it clear, as I did before, that a number of voluntary sector organisations—indeed, a number of organisations overall—are ready for 10 January. We have been able to achieve implementation of the act from 10 January, but with a suspension of the criminal offence element under section 11(3)(a). That is a simple, straightforward means of addressing some of the voluntary organisations' main concerns.

There has been a period of some 14 months since the passage of the act. There have been detailed and on-going discussions with the voluntary sector over that time. Indeed, the voluntary sector helped to produce the pack. All that took time. There are obviously some general lessons to be learnt, not only by the Executive but by other organisations, about how to address a new piece of legislation. We shall pick those up, take them forward and use them throughout the Executive in future.

What lessons have you learned?

Euan Robson:

We have now reached a position where we will achieve implementation of the act from 10 January. We have addressed the concerns of some voluntary organisations, found a way forward and understood how we need better to engage with the voluntary sector, just as the voluntary sector needs to engage better with the process of implementing the legislation.

Fiona Hyslop:

What specific lessons have you learned, minister? In particular, concerns were raised last week that volunteer-led organisations seemed to be missing from some of the debate and consultations that you have been having. Bearing in mind that we have been told by Disclosure Scotland that it anticipates one Scot in eight being caught by retrospective checks, the scale of our current concerns will be as nothing compared with what you have put off with regard to retrospective checking. So we need to—

Euan Robson:

Forgive me, but I am not quite clear about your line of argument. Is your proposal that we should not do what we have done and that we should implement the whole thing, including retrospective checks, from 10 January? What is your suggestion? I think that we have taken a sensible way forward. As I said, given what Parliament passed, the retrospective checks will be the subject of considerable further work. We have undertaken to do that with the voluntary sector. We always knew that some further discussion would be necessary. We also have to take on board the recommendations of Sir Michael Bichard. We shall need to factor those in as far as retrospective checks are concerned, and we intend to do that. I think that the way forward that we have come to is one that has commanded widespread support from the Scout Association, youth clubs and Girlguiding Scotland—those who are represented around the table.

I do not want to drift too much into the retrospective checks, to which we shall return on a future occasion, but I take the point that has been made.

Mr Kenneth Macintosh (Eastwood) (Lab):

I am pleased with the actions that the Executive is taking this week. In fact, I think it is slightly unfair of members to criticise the Executive for doing exactly what we have asked it to do, to try to cut through the confusion and ease some of the anxiety. Given that the Executive has shown some movement, I think that it should be congratulated rather than condemned. However, we are obviously in a difficult situation, and I and other members of the committee are worried about the anxiety and concerns that have been created. It is a difficult task that the Executive is engaged in. The act introduces a series of potentially severe penalties on the voluntary sector. We are trying to put those protections in place while not putting off volunteers from their efforts. There is undoubtedly a tension there.

I am trying to explore whether there are a number of things that we can do, apart from the steps that the minister has already taken. Last week, we heard Maureen Verrall's evidence about who in the voluntary sector would be penalised and bear the brunt of a criminal prosecution or conviction if they were found to be in breach of the law. I think that that should be spelt out, because there is obviously huge anxiety among small groups—we have heard one or two examples of that this morning—about who exactly would be punished and criminalised.

Elaine Murray expanded on the point, which we developed in committee at a much earlier stage, about the need for further guidance on implementation of the Police Act 1997. In other words, although there is guidance, which will obviously help all those in the voluntary sector, the whole sector is concerned about who needs a disclosure and under what circumstances. I am not saying that it will be an easy task; we have heard the example this morning of the Volunteer Centre Edinburgh. The example of young people in further education colleges has also come up before. There are several grey areas. Nobody wants an overly bureaucratic and, in the end, slightly meaningless exercise that does not offer the protection it is supposed to offer.

We definitely need to work on guidance. To do that, I think the Executive should work directly in consultation with the voluntary sector. I would like to hear that the Executive will develop guidance and that it will do so through the formal basis of the joint working group, or perhaps through other mechanisms that allow the smaller, more individualised and more compartmentalised parts of the voluntary sector to make their contribution.

I do not want to ask too many questions all at once, but I have one final question. It is difficult to produce guidance without knowing exactly what the impact of the Police Act 1997 and of the Protection of Children (Scotland) Act 2003 has been. We talked about whether the committee could carry out an inquiry in that area, but I would certainly like to hear that the Executive is exploring that issue. We need evidence on whether the disclosures that are being carried out under the Police Act 1997 are putting off volunteers. There is a general anxiety that what we are doing to try to offer protection, guidance and support to the voluntary sector is actually having the opposite effect and is putting off adults and young people from being active citizens. The only way in which we can address that is by having some hard, empirical evidence that we can use to inform our guidance. I would like to hear that the Executive has got some work under way on that, or is willing to undertake such work, because only the Executive can really do that in a thorough way.

Euan Robson:

There were a number of points in that question, and I shall try to cover them all. Volunteer Development Scotland reports in a recent survey that 83 per cent of people surveyed would not be put off by the need for the checks. I understand that the total number of volunteers actually went up last year, and that must be borne in mind. However, we will clearly look at the effects of the legislation. As I said to another member, the Executive fully values, as we all do, the immense contribution that volunteers and the voluntary sector make, so we will clearly have regard to on-going work to check the impact on volunteering numbers.

As to what might be described as further suggestions for incorporation into the guidance, I shall take away the points that Ken Macintosh and Elaine Murray have made about interaction with the Police Act 1997 to see how that can be covered appropriately within the short guidance that is being prepared. Equally, if further issues emerge that no one had foreseen, you can be assured that we shall look at those further issues and work with the voluntary sector, as we have been doing in relation to the training pack and in discussions over some considerable length of time. We shall continue to do that and to pick up new issues as they arise.

I think that I have covered the main themes of what you said, but if you have any specific questions I am happy to answer them.

I had a point about who is penalised.

Euan Robson:

That is covered by section 20 of the act. I am advised that offences by bodies corporate, not by individuals, are covered and would be affected. However, because this is a legal matter, Mr McNicoll may be able to help us out on that specific point about section 20.

Gordon McNicoll (Scottish Executive Legal and Parliamentary Services):

If an offence appears to be committed by a body corporate, section 20 of the act specifies who within that organisation is responsible for the offence. If the body is a local authority, partnership or association, the act sets out in each case which individual would be held responsible for the actions of the organisation. That is laid out in the act, it has clearly been determined by Parliament and is not open for change by way of regulations.

For the avoidance of doubt, could we be clear about what a body corporate is in that respect? It does not sound like the voluntary sector, although I am sure it is included in some shape or other. What is a body corporate?

Gordon McNicoll:

The voluntary sector would be covered by the unincorporated associations. The section tries to cover every organisation that could conceivably be covered, and it starts off with a body corporate. However, you are quite correct to say that the provisions relating to unincorporated associations are probably the ones that are most applicable to the voluntary sector. Again, the act sets out who is responsible when an offence is committed by that association.

Mr Macintosh:

The point I was trying to get at is that there is a role for the Executive in sending out a message that, although it is a serious matter and the act creates a serious offence, the act is not aimed at penalising or criminalising members of the voluntary sector or volunteers who give up their time to work with young people or others. It is a difficult task to do, but I feel that there is room for guidance there. People who give up their time to volunteer do not have the energy to look through the legislation in detail and they may be slightly scared by the fact that they are getting themselves into deep water or unfamiliar territory, and they could fall foul inadvertently—because ignorance is no excuse before the law—of a very serious offence. There is room for the Executive to produce guidance that encourages people to volunteer and suggests to them that, although it is a serious matter, it is not looking to prosecute them for doing a very good job. I shall leave that point there.

I am pleased that the Executive is going to develop the guidance further, particularly to look at the balance of risk and to produce a guide, if it is at all possible, to what is beyond the pale and what is not a risk to children. The example that we have heard several times is that of the walking bus. As Judith Gillespie of the Scottish Parent Teacher Council suggested, there is more danger of a child being run over by a car than of being abused by the person leading the walking bus. We need to get that idea of proportion into the guidance.

Finally, I would like the minister not only to look at the impact of the legislation but to confirm that he will undertake a scoping exercise to find out what kind of impact assessment or research could be done to give us the firm, empirical evidence that we need to see to establish whether the disclosures are putting off volunteers. You have given us some encouraging figures, minister, showing that the number of volunteers has gone up and that 83 per cent of people, when asked, said that they would not let those disclosures put them off, but we would obviously like to have further work done. If it is possible, could you go away and consider the sort of research that could be carried out, either by the Executive or by independent academics?

Euan Robson:

That final point is an important one. In essence, it is the kind of concept that was put to me by the Scottish Council for Voluntary Organisations. I told the SCVO's chief executive that we could look at that kind of point in discussion with that organisation, and that we would then be better placed to carry out the sort of exercise that you are postulating. I would like to discuss with the voluntary sector in more detail the sort of concepts that are at issue and the practicality behind that. If it is helpful, convener, I could write to the committee or come back to report on our progress in the new year when I have had those discussions. One of the lessons that we can learn from all this would be about having a good process or template for future legislation. The SCVO is well placed to do that.

I have one technical point. The amendment that you are introducing to defer section 11(3)(a) is very welcome, but does it actually have to appear before us as a piece of subordinate legislation?

Euan Robson:

It is a commencement order, which any minister can sign. I believe that it is in draft form, and it has not been signed because I wished to come to the committee first to explain the proposal to you before any signature was applied to any piece of paper. It will be done either later today or tomorrow.

The Convener:

Before we leave the research point, I would like to be clear about what is being suggested. The committee had in mind some in-depth research of its own, but I think that we would be keen to encourage the Executive to undertake not just general research of the kind that shows that 83 per cent of volunteers hold a certain view, but in-depth research that involves discussion with parent-teacher groups, youth organisations and the like, to find out whether there have been examples on the ground of the different sorts of situations in which people might be put off. Charity shops have been mentioned this morning: that, too, is an area that could also be important.

Euan Robson:

Forgive me. I was not trying to pre-empt any work that the committee wanted to do. Nor did I want to pre-empt discussions with the SCVO. However, if the committee would like to involve a couple of members in that discussion, I am sure that the SCVO would be happy to include them.

It is actually the other way round. We were wondering whether the Executive proposes to do that kind of research at its own hand. You are better equipped than we are for that sort of process, and it clearly has to be done.

I have an open mind on that. I would like to have an initial discussion with the SCVO and then come back to you, either by letter or in person, to discuss that specific point.

Ms Wendy Alexander (Paisley North) (Lab):

Like other members, I welcome the delay, which will offer welcome relief to the brown owl who, among other things that she is meant to do tomorrow, will no doubt have to go to a post office to pick up a copy of the details, but at least she will discover that it does not have to be implemented before we return from our Christmas holidays.

I turn to the substance of things. We are all aware that guidelines are the mechanism whereby we implement legislation in a way that does not have adverse consequences for those working at the coalface. In the spirit of the season, I wonder whether you might be willing to acknowledge that it was deeply unfortunate that not a single volunteer-led organisation was in the group that drew up the guidelines and that that sent an unfortunate signal about the value that the Executive places on the activities of such groups. What assurances can you offer us that that will not happen again?

Euan Robson:

Just so that we can be clear, YouthLink Scotland, Volunteer Development Scotland, the SCVO, Children in Scotland and the Scout Association were involved, and we felt that that was a fair cross-section. I take the point that you make. Hindsight is a perfect science. There was no intent to exclude or to downgrade the efforts of the voluntary sector. It was simply a process whereby people were available who represented national bodies, and one hopes that they represent—I am sure that they do—the broad interests around the table, but there was no intent to exclude anybody from that process. I take the point, and in future discussion others are welcome to be included if they wish to be included. If you have specific suggestions and feel that certain people have been excluded, please let me know.

Ms Alexander:

The issue was that there should be a volunteer-led organisation. We heard last week that sportscotland, a non-departmental public body, was on the committee. We were just looking for an assurance that, in future, given the anxieties that have been expressed and the purpose of guidelines, a volunteer-led organisation would have a place in those discussions.

I think the person from sportscotland volunteered their services and others assented to that. I do not know; I was not party to the detail of that. However, your point is well made and completely taken.

Ms Alexander:

I am happy to let that rest.

I move to the substance of the matter, on which I have two questions. You and your officials have properly stressed that the act is the will of Parliament. That is true, but it is also a tautology, in the sense that it applies to everything that we consider at this stage. I want to try to get to the essence of our objectives. Political leadership is about persisting only if you believe that legislation both is fit for purpose and does not have unacceptable unanticipated consequences. My question, therefore, is this. Over the past year, have you or your officials, in attempting to implement the act, and in full knowledge of the experience of the Police Act 1997, ever reached the conclusion that any aspect of the legislation either is unfit for purpose or has unacceptable unanticipated consequences?

Euan Robson:

No. If we had, I think that we would have come to the Parliament or to this committee, or we would have sought a means of doing so through the appropriate channels. As we go forward in the light of experience, in circumstances that are as yet unforeseen it is always possible that we may choose to take an opportunity to do that. The committee itself could also recommend changes to Parliament.

The answer is no, but I do not say that it will always, in all circumstances, continue to be no.

Thank you. I shall leave it at that.

Lord James Douglas-Hamilton:

I would like to ask the minister a quick question, to which I do not necessarily expect an answer this morning. Will he consider the possibility of establishing the equivalent of a helpline for local authorities, charities and voluntary bodies, so that, in cases where there is doubt as to the most appropriate way forward, effective guidance on best practice can and will be given?

I am happy to say that there is a helpline, and I can give you the number: 01786 849777. There is also an e-mail address, which is on the leaflet. I shall leave the proof with the clerk and we shall distribute copies in due course.

The Convener:

We received this morning from the Scottish Parent Teacher Council a bundle of correspondence between Judith Gillespie and a number of local authorities. It is quite varied, but the issue of gold bottoming the legislation appears to arise out of it. The legislation is one thing, but what councils do in terms of allowing council lets, their attitude to boards and what they advise organisations to do is another matter.

I would like to read out one or two quotations. For example, East Dunbartonshire Council says that the position applies to

"Parent volunteer helpers in schools … Parents and co-opted members of school boards … Parent members of local parent-teacher associations … Any other individual working in a voluntary ‘childcare' position",

which is fine. It goes on to state:

"The EDC draft policy points towards occasions where the voluntary helpers duties involve unsupervised contact with children."

That does not suggest the regularity that we hear about in the act.

North Ayrshire Council's letter states:

"many of our Head Teachers are currently seeking checks on any helper involved in extra-curricular events, so that maximum flexibility is available in emergencies, such as a child having to be taken home or a child feeling unwell."

Again, I do not think that the element of regularity comes through that.

There are a number of similar letters. Dumfries and Galloway Council states:

"we do ask that parental volunteers should be Disclosure Scotland checked where they are undertaking activities on behalf of the school … (e.g. transporting groups of children)."

Again, there is a difference with regard to regularity.

East Renfrewshire Council stated:

"I have to say though, if asked about a Hallowe'en or any other party in East Renfrewshire, ‘I would say yes.'"

We are getting into the Santa Claus situation a little bit with some of these advice things. I can understand where the councils are coming from, but it seems to me that the broad issue that arises is that different approaches are being taken by different local authorities.

Indeed.

The Convener:

You mentioned a discussion with COSLA and I wonder whether there is any way of resolving the issue in a way that is compliant with the terms of the act, that gives due recognition to the duties of councils, such as they are—I do not think that they have duties under the act in that context—and that allows sensible decisions to be made by groups such as parent-teacher associations.

Euan Robson:

You quoted a number of examples and I am advised that we are also aware of those examples. In the areas that you mentioned, some local authorities are not taking the line that is suggested. As I said, we are trying to establish a map across the 32 authorities that can tell us precisely who is doing what. We are in discussion with COSLA about that and we will develop those discussions to try to iron out some of the particular procedures that are in place and some of the formulations that certain authorities have placed on the way in which they need to proceed. That work with COSLA is developing to try to ensure greater consistency of approach.

The Convener:

I am a great believer in local authorities' discretion and independence, but in the context that we are discussing it seems ludicrous that there should be major differences of approach in different parts of Scotland. Does the Executive have the power to give instruction or guidance to local authorities on the matter? If you cannot enforce the approach and make it happen, there will be on-going difficulties.

Euan Robson:

I am pretty sure that we do not have powers to enforce, but I need to give that a bit more consideration. The discussion with COSLA will focus on exactly what you suggest and try to ensure that there is consistency of approach across the 32 local authorities. It is obvious that there is currently no such consistency and I want to ensure that there is, because inconsistency of approach will cause confusion, as you said.

The Convener:

The Scottish Parent Teacher Council might usefully be involved in the discussions. There are quite a lot of organisations that do not provide children's services in the way that the Scout Association or other youth groups do, which should nevertheless probably be involved.

Fiona Hyslop:

Will the minister explore insurance and include insurance companies in the discussions? Organisations that seek lets from local authorities or other bodies are concerned about what is happening on the ground. Regardless of the legislation, organisations cannot secure insurance for what they do, because insurance companies' interpretations are tighter in practice than is required by the law. That is another barrier to progress on volunteering.

Euan Robson:

Issues to do with insurance obviously involve commercial decisions. I think that the matter has been raised with Executive colleagues outside the context of the 2003 act. The matter has certainly been raised with the Department of Trade and Industry, because insurance is a reserved matter. As you suggest, there have been rather strange examples—in one instance, a Santa Claus needed insurance and Disclosure Scotland checks. If it would help to have discussions with the insurance industry, we can talk to the Association of British Insurers—I knew the association's chairman, although I do not know whether he is still in post. I would be happy to engage with the current Scottish chairman if that is helpful. Ultimately, we cannot intrude into commercial decisions, but your point is well made and we will see what we can do.

The Convener:

Thank you for your evidence. In fairness, I should say that the agenda item has again generated somewhat lengthy and involved investigation by the committee. I do not think that anyone doubts that the issue is tricky. On one hand we are faced with the implementation of the 2003 act, which was passed in the first session of the Parliament and must be taken as the starting point for such matters. On the other hand, there is genuine concern in the committee about the implications of the act and its possible detrimental effects on volunteering and voluntary organisations in the youth field. The committee wants to leave you with the message that anything that can be done to reassure people, avoid unnecessary hassle and simplify the situation—we did not consider multiple checks this morning—would be extremely welcome. Thank you for the efforts that you have made on the matter and for your attendance. I also thank your officials, Maureen Verrall and Gordon McNicoll, for coming.

Euan Robson:

Thank you for giving me the opportunity to speak to the committee. I welcome our helpful discussions. For the purposes of accuracy, I should say that the deferment of section 11(3)(a) of the 2003 act would apply not just to the voluntary sector but to all sectors.

The Convener:

Under the next agenda item, the committee will continue its consideration of the Protection of Children (Scotland) Act 2003 Determination Regulations 2004 (SSI 2004/523), which we considered at last week's meeting, and consider another relevant instrument. Do members want to take further action as a result of the evidence that we heard this morning? We have received an assurance from the minister that various things will happen in relation to discussions on guidance and that he will come back to the committee to discuss the provisions on retrospective checks before they are implemented. We will have an opportunity then to take up particular issues. We could consider the matter at our meeting on 12 January, which is technically the final day on which we could deal with the subordinate legislation. However, the committee might think that we have had a good exploration of the issues today and at our previous meeting and that we could defer consideration until the minister reports back to us on retrospective checks and further guidance. Is that approach acceptable to members?

Fiona Hyslop:

That would be an appropriate approach. The issue is not the content of the regulations but the process and management of the implementation of the 2003 act and the commencement order that we discussed at our meeting last week. The Executive has now offered an alternative route.

The Convener:

It might be sensible to put the matter on the agenda of one of our meetings in January or February, before the February recess, so that we can ascertain what has happened. Euan Robson promised to report to us on the provision of guidance, which might provide a useful opportunity for us to review the situation on what is a difficult issue.

Ms Alexander:

The minister seemed to leave his options open on a number of areas—I think that any one of us would have done the same thing in the circumstances. Will the clerks take a careful look at his evidence and note for us, as an aide-mémoire, the issues on which the minister said that he would reflect or come back to us? I note that he said that the 2003 act is fit for purpose in all respects and will have no unanticipated consequences. At the root of the matter is the fact that large parts of the voluntary sector do not share that understanding, but at least the Executive's position is clear on that as well as on a variety of other matters. A brief aide-mémoire compiled from the Official Report would be enormously helpful.

I presume that the Official Report of the meeting will be available at some point during the Christmas recess, so we will be able to consider it in detail.

Dr Murray:

Your suggestion that we put the matter on our agenda is a good one, because otherwise such matters can slip. We should make a commitment to come back and consider the guidance.

The minister pointed out that the 2003 act is an act of the Scottish Parliament, which was guided to some extent by the opinions of the Education, Culture and Sport Committee in the first session of the Parliament. I do not suggest that the act is unworkable, but if it would have unintended consequences or deter adults or young people from becoming active citizens, this committee has the responsibility to reconsider it and recommend amendments.

The Convener:

That would be appropriate, but it might best be done in the context of the potential research that we or the Executive carry out, whereby we can drill down into the issues. Euan Robson said that 83 per cent of people said that they were not put off volunteering by the act—

That means that one in six people is put off.

The Convener:

Quite. We should drill down behind the figures, but we must have more than just anecdotal evidence and we should seek evidence at a later stage, when implementation has begun and we can see where we are going. If there have to be amendments to the act, the process will take a little time.

Some committees carry out post-legislative scrutiny.

The Convener:

Absolutely. I am just suggesting the context of our consideration of the 2003 act, which would fit in, first, with the minister's report to us and secondly and perhaps more relevant, with the research that we propose to undertake—under one heading or another—to give us material with which we can work. We are all struggling with the implications of the act.

All sorts of different situations have emerged from the woodwork, some of which I confess I had not thought about before we received letters about them. The legislation is complex and interrelates with other legislation and situations that are happening in England. We need to get the full flavour of the situation. There are no two ways about it: we have to return to the subject, which will remain on our agenda for some time to come.

For the time being, let us agree to look at the matter again before the February recess when we have enough information to make it worth our while. That would give us six weeks before the April date to iron out any of the problems that will emerge and to look at the retrospective checks again with the minister, in the context of the research. I think that it was suggested that those checks would not come in before April at the earliest, although unless I am very much mistaken in the impression that I got today, it will happen much later than April.

I hope that the proceedings of the committee this week and last have been of some help to the voluntary sector and to those who will be involved with the legislation. I echo what Ken Macintosh said before in that I hope that the voluntary sector will be encouraged by some of the evidence that we have heard to work its way round some of the difficulties and to ensure that that aspect of caring for children is not damaged—and is in fact enhanced—by the legislation. It is intended to protect volunteers and children in the way in which the volunteers go about their duties.