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The Children’s
Information Sharing (IS) Index
The Government has drafted regulations that will
allow them to set up a national database of all children – the Information
Sharing (or ‘IS’) Index. It is seeking views on these draft regulations until
December 14th 2006, and will then produce the final regulations to go
before Parliament early in 2007.
MPs and Peers will have to pass a resolution to approve
the regulations. If Parliament does approves them, work will begin on building
the IS Index straight away.
The Government plans to have all children entered on the
IS index by 2008. It will be a single, national index partitioned into 150 local
authority sections. Each local authority will be responsible for running its own
section.
The Information-Sharing Index will track all children
from birth.
The draft regulations to operate the Index can be found
here.
In summary, this is what they say:
Each child’s entry on the Information Sharing Index
will show:
Ø
The child’s name, gender, date of birth and address
Ø
An identification number for the child
Ø
Parents’ names and addresses (or of person with parental responsibility)
Ø
Details of child’s doctor, health visitor, midwife and/or school nurse
Ø
Details of child’s school/college (or of education they are receiving if
not at school)
Ø
Details of all services* a child uses + dates when service started and
ended
*It will also show if a child is receiving a ‘sensitive
service’ but the details won’t be displayed. A ‘sensitive service’ is: mental
health, sexual health or substance abuse treatment. Individual practitioners in
these services will normally need the consent of their client/patient before
putting details on the IS Index. Once they have been put on the Index, the local
authority will decide who can have access to this information.
Any practitioner working with a child must indicate when
they have:
Ø
Information to share
Ø
Taken any action in relation to the child
Ø
Completed an assessment under the Common Assessment Framework
The following people/bodies must supply
information to the Information Sharing Index:
Ø
Local Authority – which includes all LA services in education, social
care etc
Ø
Health Authorities, NHS Trust, Primary Care Trust – all health workers
Ø
Learning and Skills Council
Ø
Connexions
Ø
School, special school and college governors
Ø
Proprietor of an independent school
Ø
Police
Ø
Probation & Youth Offending Team
Ø
Prison governor
Ø
Registrar General (births, deaths and marriages)
Ø
CAFCASS
The following may supply information to the
Information Sharing Index:
Ø
Childminders, playgroups & nurseries
Ø
Voluntary organisations
Ø
HM Revenue and Customs
Ø
Registered social landlord
Ø
Fire and rescue authorities
Ø
Doctors, dentists, opticians, osteopaths, chiropractors, nurses,
midwives, health visitors, pharmacists, paramedics, any other practitioner who
is liable to regulation under section 25(3) of the National Health Service
Reform and Health Care Professions Act 2002
Each local authority will decide who may access the IS
index.
Any person given access to the index must undergo training
and have a CRB check, and must be in one of the categories given in paragraph 6
of the draft regulations. Broadly speaking, these are:
Ø
LA services in education, social care etc
Ø
Health care professionals
Ø
Connexions employee
Ø
Head teacher; deputy head teacher; school administrator; a head of year
or teacher with pastoral or child protection responsibilities; SEN teacher; SEN
coordinator
Ø
Proprietor of an independent school
Ø
Police officer
Ø
Probation officer
Ø
Youth Offending Team member
Ø
Prison governor
ARCH is extremely concerned about the planned Information
Sharing Index for the following reasons:
- Although the
government says that the IS Index will contain only ‘basic details’, it will
actually create a log of every service a child receives. That’s a lot of
information. For example, even giving ‘basic’ school details can show a
child’s religion, and also whether they have disabilities or special needs.
Contact details of parents show whether parents are separated or single.
- The purpose of the
IS Index is to allow practitioners to link up with each other to exchange
information. There are already a large number of databases in education,
social care, youth justice and the police, each of them holding detailed
information about children. Some are used to try to ‘predict’ which children
may become criminals, even though the evidence about the accuracy of these
‘predictions’ is by no means clear.
- Although government
guidance says that further information known to individual practitioners
(beyond what is required to build the IS Index) should not normally be
exchanged without consent, this is a very grey area. For example, the Youth
Justice Board believes that consent is not necessary when practitioners are
trying to identify a child who may become an offender. Many practitioners
believe that information can be shared under wide legal powers such as
‘preventing crime’ or ‘improving the local area’. There is also the question
of whether a young person can give lawful consent in his/her own right, and
whether people may feel under pressure to give consent, especially as the new
children’s policy identifies sharing more information as the key to improving
services. In the case of child protection concerns, practitioners will
continue with the current policy of sharing information without consent.
- The government has
given the impression that the IS Index is about ‘child protection’, but this
is simply not true. Ministers have repeatedly talked about Victoria Climbie
and used words like ‘at risk’, but the usual meaning of ‘at risk’ has in fact
been changed. The government has re-defined it as being ‘at risk’ of
committing crime, of failing at school, of becoming pregnant in one’s teens,
or of becoming ‘socially excluded’. It no longer means ‘at risk’ of abuse or
neglect. The IS Index would not have helped Victoria Climbie. Her death came
about because several practitioners failed to interpret correctly the
information they already had.
- Many experts have
argued that the IS Index will make it less likely that a child at risk
of abuse will be noticed because the warning signs won’t be noticed when there
is so much other, trivial information being logged and monitored.
- Government IT
projects have an appalling record of failure and breakdown. If practitioners
are dependent on a database to alert them to signs of neglect or abuse, a
breakdown could place vulnerable children at even greater risk. Similarly,
families who need services are likely to experience serious delays in getting
what they need.
- The IS Index will
show whether an assessment has been carried out under the Common Assessment
Framework (CAF). The CAF will collect details on every aspect of a child’s
life, including assessment of his/her mental health and the capabilities of
parents. The CAF can be carried out by any practitioner who believes a child
needs more services – the government estimates that around 1 in 3 children
come into this category. The CAF will be held on a parallel database: the eCAF.
The government says that a CAF should only be carried out and shared with
consent, but the comments we have made above about consent apply also to the
CAF. There is anecdotal evidence from the pilot projects that consent is being
sought as a condition of receiving a service.
- The government says
that it will cost £224m to set up the IS Index, and another £41m per year to
run it. This is a major database project and, so far, all of the government’s
major IT projects have cost far more than was predicted. The £41m running
costs appear very optimistic: this amounts to £270,000 per local authority.
Bearing in mind the extra staff that will be needed, the training costs
whenever a new practitioner is given access, the system maintenance and
upgrade costs, it is difficult to see how it will only cost £41m per year.
Will the additional costs have to be borne by local councils?
- Local authorities
have to pay for the eCAF system themselves. They also have to pay for another
new system: the Integrated Children’s System (ICS), a database that will store
every child’s social services record. The government’s own Society of
Information Technology Management estimates that installing an
ICS system will cost each local authority £1m and that government grants offered to
local authorities are only a fraction of the true cost. Local authorities are
meant to install eCAF and ICS without increasing council tax, which means that
other services have to be cut.
- We believe it would
be better to spend all of this money on services. At the moment 11% of social
work posts have not been filled, and around half of all local authorities have
‘unallocated’ child protection cases because they are short-staffed. If the
government is really concerned about child protection, they should be putting
the money into staffing, training and supervision of social workers. It would
also be better if money were made available for equipment and services for
families that need them – for example where a child has disabilities. At the
moment, many families are finding that they can’t get basic equipment like
wheelchairs or bath-aids, or respite care, because of cuts in local authority
budgets.
- There is no such
thing as a secure database system. The Government has already indicated that
‘celebrity’ children or families escaping domestic violence will not have
their details visible on the Index. If the system were completely secure, they
wouldn’t need to do this.
- The greatest danger
comes from people with access to the Index. Sometimes they are careless about
security, leaving files open on their computer, or giving their password to
someone else. Sometimes, ‘insiders’ will sell information. Earlier this year
the Information Commissioner published a report: ‘What
Price Privacy?’ in which he set out the going rate for different types of
confidential information held on government databases.
WHAT YOU CAN DO
If you are
concerned about the Information Sharing Index, contact your MP as soon as
possible. The regulations to allow the Index to go ahead must be approved by
Parliament, and they will be asked to do this early in the New Year.
Tell your MP why you object to the database, and that you
don’t want him/her to vote in favour of the regulations.
You can also respond to the Government’s consultation on
the regulations – details of how to do this are
here
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