CRAM: the Met helps with home educators’ enquiries

In the wake of revelations that “home educated”, “disability” and “privately fostered” are listed as risk factors by the Metropolitan Police Service in its operational policy known as CRAM (Child Risk Assessment Matrix), alongside “co-sleeping”, “substance abuse”, “sexualised behaviour” and various other alleged indicators, some of our members decided to invite the police to help them with their enquiries by asking for evidence of the stated risks in respect of some of these named groups.

One HEF member, who complained directly to the Met about the inclusion of home education within CRAM, was left unimpressed by the response he received, which cited high profile abuse cases, including Victoria Climbie, Baby P and Khyra Ishaq (none of whom was home educated) as justification for their finger pointing at our own particular minority.

He was advised that the development of CRAM was informed by “internal and external consultation and focus groups” (were any home education groups consulted?), academic research, serious case reviews and “other relevant material”.  He was also assured that “the CRAM process is not applied to children in families or households where there is no referral to police in relation to substantial child protection or abuse concerns”, which will be of scant comfort to home educators and other minority groups who have been the subject of malicious referrals.

Although the Met may not recognise it as such, prejudice seeps through each and every sentence.

“In mainstream education there has been a requirement for school staff to be trained and comply with Every Child Matters (ECM) safeguarding and child protection procedures. Additionally, guidance and procedure has been in place in relation to recruitment and safeguarding children such as access to criminal records bureau checks (CRB). Children in home educated circumstances are often away from this environment and this isolation may increase the risk to them.”

There we have it: parents, most especially home educating parents, have no recognised role in keeping their children safe and only professionals can be trusted to do so. We would beg to differ!

We have, of course, heard these claims about the “safety net” of schools before, almost always from those with a vested interest in the school system or the child abuse industry. So where is all the evidence to demonstrate that schools are effective safeguarding institutions?

Leaving aside evidence of the many reported cases of bullycide, one forum member helpfully reminded us of this extract from Noticing and Helping the Neglected Child Literatrure Review, which observes:

“There was a striking absence of rigorous studies into the role of schools and teachers in recognising early signs of neglect. Many studies allude to the importance of schools and teachers; many studies allude to the severe impact of neglect upon cognitive development, but we found very little empirical research on neglected children and the ways in which they engage or not with schools and education.”

Returning to the Met letter, the author goes on to ice the CRAM cake thus:

“You will be aware that there have been cases where children in home educated situations have been subjected to serious child abuse and in a few cases have even died. A recent situation in Birmingham (Khyra Ishaq) in which a serious case review was actually published is one example.”

Has the Met not read or understood the findings of the Ishaq serious case review? For those who may have been fooled by diversionary tactics and spin, may we again take the liberty of bursting some Ballsian bubbles and point out that the judge in this criminal case stated that (a) home education was not a contributory factor, and (b) Brimingham Social Services and West Midlands Police both had ample grounds and powers to intervene, yet chose not to do so?

When it comes to home education, we have been unable to find any peer reviewed research that demonstrates it to be a disproportionate risk factor. Indeed we can only produce findings that point to it being much less of a risk factor.

Another of our forum members was sufficiently concerned by the discriminatory elements manifest within CRAM that he submitted a FOI request to the Met via the What Do They Know website so that the eventual response would be a matter of public record. His questions were crafted with equalities legislation in mind and related to the Equality Impact Assessment (a legal requirement for public bodies), specific definitions of the named risk groups and the evidence bases used to inform their inclusion.

Although it first appeared that the Met was seeking to engage sections 30 and 31 exemptions under the FOI Act, to their credit they did eventually provide a fulsome response to the questions posed.

The salient points were as follows:

No Equality Impact Assessment was undertaken in respect of CRAM prior to its adoption. According to the Met: “The EIA has been agreed to and is to be commissioned in the near future. Therefore no information is held at the moment.” Since an EIA is a legal requirement, this omission is troubling.

With reference to the request for the definitions of “disability”, “home educated” and “privately fostered”, all of which were identified as risk factors within CRAM, the Met confirmed that “no specific definition” was used in respect of the first two, only “the concept/designation in its widest generic understanding”. “Private fostering” was, however, defined as “an arrangement where a child or young person under the age of 16  (or 18 if they are disabled) is looked after full time for more than 28 consecutive days by an adult who is not their legal guardian, grandparent, brother or sister, aunt or uncle”.

As we understand it, there are specifically defined models of disability as one of the protected characteristics within the equalities legislation, and so failure to consult with relevant groups, pay due regard to the nature of the disability, or publish the findings of an EIA represents a breach of a public sector equality duty.

With reference to the request for details of the evidence bases used to justify the inclusion of “disability”, “home educated” and “privately fostered” as risk factors within CRAM, the responses were honestly provided, although far from reassuring.

On “disability”:

“The MPS through its own experience and participation in multi-agency training is aware that on occasions children with disability can be more vulnerable to abuse. This has been identified in some serious case reviews and associated studies such as those published by the Department of Children School and Family on a biennial basis. No single or particular evidence was used to justify this risk factor. Please note that the DCSF has now changed their name to Department of Education.”

On “home educated”:

“A number of children throughout England and Wales have suffered from neglect in circumstances where they are home educated. These cases have attracted both local and national comment and some have been the subject to serious case reviews. The absence of a child from a conventional school environment where staff are routinely trained in safeguarding responsibilities can in some circumstances lead to that child being in a more vulnerable situation and at a higher risk of neglect or abuse. No specific individual case evidence has been relied upon for the inclusion of this category.”

On “privately fostered”:

“Children in private fostering arrangements are recognised by Government as being in a potentially vulnerable situation. There is a requirement in law for private fostering arrangements to be registered and inspected by the local authority in which the arrangement exists. Local authorities and LSCB’s have identified a low registration rate. Amongst some communities there is a practice of sending children to the UK in non familial or extended kinship placements and on occasions elements of child exploitation are present.”

So there we have it. The Met has relied on no specific case evidence – and, arguably, in the case of private fostering, prejudice against communities where kinship care is a cultural norm – in order to attach disproportionate risk labels to minority groups, thereby perpetuating the discrimination they already experience on a routine basis.

As home educators, we make no apology for harking back once again to AHEd’s exposure of the discredited statistics contained within Badman’s report of the so called independent review of elective home education in England. The Met should also take note of the unsubstantiated allegations made by the London Safeguarding Network (LSN) in relation to home education, which were deliberately “cascaded” to local authorities, presumably to perpetuate prejudice against those who had dared to queer the pitch of vested interests.

Given the LSN’s admission to AHEd that they did not “actually hold any information about specific cases”, the Met should certainly not be relying on assertions made in an official LSN submission that they were aware of serious cases pointing to child protection concerns for home educated children. To quickly recap, they were unable to provide details of any such cases; moreover, no details could be found in the minutes of the meeting in which these serious cases were allegedly discussed.

We can only surmise that the Met has failed to examine and test all the available “evidence” and has chosen to convict home educators on hearsay alone. It is therefore not inconceivable that the other minority groups which have been singled out in CRAM may also have been labelled as posing a disproportionate risk to children on the basis of a few common characteristics (some of them protected by law) and highly questionable evidence sources.

More questions will be asked. They need to be.

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