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This bill currently before Parliament, is set to have a major impact on safeguarding.

Every major Christian denomination has already expressed its deep concerns about key parts of the Protection of Freedoms Bill to the Parliamentary Under-Secretary of State for the Home Office responsible for the legislation, Lynn Featherstone.

If you wish to bring your views about it to the attention of your MP, you may obtain his or her contact details from the web link at the end of this page.  


The Protection of Freedoms Bill, which is making steady progress through Parliament, includes provisions to replace the proposed Vetting and Barring Scheme and current Criminal Records regime.

Following a final debate in the House of Lords it will return to the House of Commons to give MPs a last opportunity to accept or reject any amendments made by the Lords.

Once both Houses have agreed the Bill, it will receive Royal Assent - probably in May this year. 

Two key aspects of the Bill which may concern you are:

Single Certificate

The government proposes to remove the Registered Body Copy of the disclosure certificate. This means that organisations will have to rely on the applicant producing their copy, thereby delaying the recruitment process.

It also means that CCPAS will not be able to inform you of any certificates being sent to you with serious concerns, as we will be unaware of them. Some concessions may be made on the E-Bulk system and tracking the certificate’s progress online - but details are not yet clear.

What is very obvious, however, is that you will only be able to gain access to a blemished disclosure via the applicant’s own copy, as it will not be issued to you in a paper format.

This is set to place a major bureaucratic burden on churches and other organisations. In addition, recruiters will need to be trained not only how to recognise fraudulent certificates but also to understand any conviction information. Currently CCPAS is responsible for examining certificates, and we contact you immediately if we have any concerns. The drawback is that an important safety net will disappear and the responsibility will be placed firmly on Recruiters.

Receiving blemished disclosures can often place a church or similar organisation in a difficult position, because of important issues such as forgiveness and redemption. It can be difficult for leaders to make objective decisions about such disclosures, since the individuals concerned are known to them personally. Many therefore welcome the independent, professional help CCPAS provides in such circumstances. But under the terms of the proposed legislation we will be precluded from doing so in future.

Regulated Activity

CCPAS is also extremely concerned about the proposal that adults who work with children or vulnerable adults will be deemed not in "regulated activity" if they are “supervised”. This demonstrates a lack of understanding, both of how churches operate and the perspective of a child or vulnerable adult.

Long experience has shown that "supervised" people could encounter children and/or vulnerable adults outside formal supervised church activities. These could include weekday Bible studies, coffee after Sunday services, Saturday social clubs and so on.  


Much of the bad press about the CRB system arose because some organisations were not following standard procedures correctly or were asking for checks to be made on ineligible people, for example flower arrangers in churches or local authority administrative staff. It also proved unpopular when checks took too long to process, but this has been rectified by E-Bulk and the revamp of the Police system for soft information.

Rechecks and renewals were not popular either but we are pleased that the Bill has addressed this. Full details will follow once is has been enacted.

Should you wish to lobby your MP about any part of the Protection of Freedoms Bill, using all or part of this document if you wish, you may follow the link below to the House of Commons website.

Please feel free to forward this information to anyone you think may be interested.

Simon Bass

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. CCPAS - Company Registered in England No: 2646487, Charity No: 1004490 Scottish Charity No: SCO40578