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NSPCC responses to government consultations 2007

Our government consultation responses and key briefings on legislation and policy

The NSPCC Policy team responds to government Green Papers and influences the development of policies and laws that affect children and young people - especially those designed to end cruelty to children. Below are the government consultations we responded to in 2007.


Children's Charities' Coalition for Internet Safety (CHIS) response to the Byron review (PDF, 60KB)
November 2007. As a leading partner in the Children's Coalition on Internet Safety the NSPCC has submitted evidence to Dr Tanya Byron's independent review of the risks to children from exposure to potentially harmful or inappropriate material on the internet and in video games. Dr Byron was appointed to undertake this review by the Prime Minister. When she makes her report in March 2008, she hopes to identify measures that will help all parents feel confident that their children are using new technologies and are playing video games in a way that is appropriate for their age and development.

NSPCC submission to the Independent Asylum Commission’s review of the asylum process (PDF, 68KB)
October 2007. The NSPCC submission has examined the asylum process and challenged its ability to meet the needs of separated children. We have looked in detail at the need for separated children to be afforded the same rights and protections as other children. We have identified child protection issues and child rights issues throughout the asylum process. In addition we raise concern about the treatment of families and call for the end of detention of children in immigration removal centres.

NSPCC response to Staying safe (DCSF, 2007) (PDF, 340KB)
October 2007. We welcome the government's statement that keeping children and young people safe is a top priority to make the most of their talents and new opportunities to fulfil their potential. In order for all cruelty to be prevented, it is vital that all children, whatever their needs, have a range of services that are flexible and offer them support and protection. Although significant steps have been made to improve the safety and protection of children, many children are not respected and treated as equal citizens with rights of their own, but as adjuncts of their parents. The Every Child Matters (ECM) programme and the UN Convention on the Rights of the Child (UNCRC) should provide the basis for the development of the Children's Plan and the Staying Safe strategy.
NSPCC summary of recommendations in response to Staying safe (DCSF, 2007) (PDF, 52KB)

NSPCC response to the Children’s Plan: Time to Talk (DCSF) (PDF, 104KB)
October 2007.  In drawing together this response, we have consulted with a wide range of practitioners who directly provide services and support to children and young people.  We have also consulted with children and young people through There4me.com which is a website for 12-16 year olds who are worried about something and need help.

NSPCC Memorandum of Evidence to the Home Affairs Committee inquiry into domestic violence (PDF, 76KB)
October 2007.  We are pleased to be able to contribute evidence to the inquiry on the effectiveness of existing legislation and whether greater support is being provided for victims of domestic violence.  Our evidence focuses on the needs of children who witness domestic violence and makes a number of recommendations in this area. 

NSPCC response to Improving the criminal trial process for young witnesses (PDF, 104KB)
October 2007.

NSPCC response to the Safeguarding Vulnerable Groups Act 2006 / the Safeguarding Vulnerable Groups (Northern Ireland) Order 2007 Barring consultation document (PDF, 48KB)
September 2007. This Barring Consultation document published by the Home Office, DoH and DFES (now DCSF) in conjunction with the Northern Ireland Executive relates to both the Safeguarding Vulnerable Groups Act 2006 and equivalent legislation in Northern Ireland. Our response represents the NSPCC's response from jurisdictions of England, Wales and Northern Ireland.

NSPCC response to the consultation on the review of Section 58 of Children Act 2004 (DCSF) (PDF, 96KB)
August 2007. We do not consider that section 58 has improved legal protection for children. The NSPCC urges the government to remove the defence of reasonable punishment, and give children equal protection under the law on assault. There is no other just and safe way to remedy the current situation. Seeking to issue guidance to clarify precisely how children can be hit is repugnant on moral grounds and fantastical on rational grounds as it is not possible to define the subjective concept of 'reasonableness' in an objective way.

Our accompanying submission of Children and young people’s voices on physical punishment (PDF, 156KB)  was produced by children and young people working with the NSPCC and the Children's Rights Alliance for England (CRAE) between 2005 and 2006. More details on the NSPCC's broad view of equal protection for children is available through our pages on key policy areas .

NSPCC response to Education and training for young people in the youth justice system (DCSF) (PDF, 56KB)
July 2007. Our response calls for Personal Sexual Health and Economic Education (PSHEE) to be a core part of education in the Youth Justice System (YJS). We also make it clear that teachers must be adequately trained in delivering PSHEE and that safeguarding procedures are followed in their recruitment. Finally, the NSPCC recommends that all young people in the YJS have access to counselling services.

NSPCC response to the consultation on draft guidance for ContactPoint (DfES) (PDF, 100KB)
July 2007. Our response covers issues of accuracy of data, unauthorised access and misuse, subject access requests, complaints procedures, shielding, contents and purpose of the system, supporting practitioners, implementation and user groups.

The Children's Charities Coalition on Internet Safety (CHIS) response to the consultation on the possession of non-photographic visual depictions of child sexual abuse (Home Office) (PDF, 29KB)
June 2007. CHIS (of which the NSPCC is a member) consider that it is right to make non-photographic visual depictions of child sexual abuse illegal. Our view is based on two principal considerations: (1) Our research has shown us that non-photographic depictions of child sexual abuse appears to becoming part of the ecology of child abusive material. In our view, the extent that it remains legal suggests a degree of acceptance or tolerance of depictions of sexually abusive material involving children; (2) Advances in technology have made it possible to create materials which are entirely artificial but which, in turn, are indistinguishable from photographs or videos of real events.

NSPCC response to Planning better outcomes and support for unaccompanied asylum seeking children (Home Office) (PDF, 195KB)
May 2007. Our response states the fact that separated children must be safeguarded and have their welfare promoted. We also discuss: assessing and meeting needs and providing adequate care; presumption of a temporary stay; dispersal; and, inappropriate accommodation.

NSPCC response to DfES draft guidance for local authorities on securing sufficient childcare (PDF, 31KB)
May 2007. The NSPCC welcomes guidance for local authorities to fulfil their duties under Section 6 of the Childcare Act 2006 to secure, so far as is reasonably practicable, sufficient childcare in their area. We particularly welcome some of the provisions in the guidance which set out safeguarding standards in childcare which will provide the assurance and confidence that is needed on service standards and quality for parents when deciding which childcare provider to choose.

NSPCC response to the consultation on the secondary curriculum review (Qualifications and Curriculum Authority 2007) (PDF, 73KB)
April 2007. We recommend that Personal, Social, Health and Economic Education (PSHEE) should be a statutory requirement in the national curriculum for all key stages, to ensure that children learn about appropriate behaviour and how to stay safe in relationships from an early age.

NSPCC response to the consultation on exemption from the Ofsted Childcare Register (Department for Education and Skills 2007) (PDF, 54KB)
April 2007. The NSPCC strongly supports reforms to the regulation and inspection regime for childcare, though we have a number of concerns, especially concerning: paramountcy of children's best interests and their right to protection; childcare providers to be registered on a compulsory rather than voluntary basis; all children to be afforded the same level of protection regardless of age; the need to avoid presenting the Safeguarding Vulnerable Groups Act 2006 as a panacea. The childcare register should be focused on safeguarding children rather than on costs and financial efficiency.

NSPCC response to the Social Exclusion Task Force Families At-Risk Review (PDF, 196KB)
April 2007. We respond to the 'Whole Family' approaches to delivery of services for at-risk families, specialist areas of adults' services expertise and offer details of research and good practice.

NSPCC response to the Statutory Guidance on Section 6 Education and Inspections Act - Positive Activities for Young People (DfES) (PDF, 84KB)
March 2007. We highlight the need for the guidance to include a chapter on safeguarding, the absence of which is of great concern. We also offer suggestions for how to enhance the provisions for accessibility and inclusiveness of the activities.

NSPCC response to Working together to safeguard children: safeguarding children from abuse linked to a belief in spirit possession and witchcraft (PDF, 85KB)
March 2007. We welcome the Department for Education and Skills guidance, which is a useful and much-needed supplement to Working Together to Safeguard Children. Improvements must be made however, and we are particularly concerned that the draft guidance lacks detail about the increased vulnerability of a child with a difference as a trigger for a belief that they are possessed with a spirit or a witch.

NSPCC response to the Chief Medical Officer's report on medical expert witnesses: public consultation on proposals for change (PDF, 144KB)
February 2007. Our consultation response focuses upon the credentials of Medical Expert Witnesses in court proceedings, the Multi-disciplinary Specialist Assessment Model and expert evidence in the court.

NSPCC response to the Strengthening powers to tackle anti-social behaviour consultation (PDF, 87KB)
February 2007. In whatever work is being done to support children, it is important to see them as children first, and then to consider their behaviour. Our consultation response introduces a coalition of organisations who are calling for changes to juvenile justice procedures and shows the link between maltreatment and anti-social and offending behaviour. Other topics addressed are additional powers for front-line police and the Deferred Penalty Notice for Disorder.

NSPCC response to the Conservative Party Childcare Consultation (PDF, 68KB)
February 2007. A summary of our position on childcare. Some of the information included in this response is based on the outcome of a joint research project by the NSPCC, York University and the Frank Buttle Trust which sought to increase understanding of the complex relationships between poverty, parenting and children's well-being in diverse social circumstances.

NSPCC response to the DfES consultation paper Care Matters: Transforming the lives of children and young people in care (PDF, 214KB)
January 2007. The NSPCC supports the principle of shifting the balance between care and prevention and believe the aspirations of the "Care Matters" paper can be fulfilled, but not without significant additional investment. Our experience indicates that there will always be a need for a state co-ordinated care system. The comments in this consultation document are based on our broad expertise in safeguarding children and promoting their welfare and we have also spoken to children and young people in care, practitioners delivering NSPCC services and foster carers.

NSPCC response to Bullying in schools: a review of the current complaints system and a discussion of options for change (Office of the Children’s Commissioner) (PDF, 72KB)
January 2007. Despite initiatives from government, and efforts on the part of many teachers and schools, bullying remains a serious problem for many children. The NSPCC study of the prevalence of abuse and neglect, which surveyed the childhood experiences of almost 2,900 young adults, showed that bullying and discrimination by young people, especially in school, is one of the most common forms of harmful aggression experienced by children and young people. A quarter of those bullied by other young people (1 in 10 of all respondents) reported that they had suffered long-term harmful effects from being bullied.


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