So the Church of England’s Independent Safeguarding Board has announced that they are going to launch a Review into events at Christ Church Oxford as early as next week !
An original copy of the ISB’s Terms of Reference as published by the Church of England can be downloaded from here
These have been reviewed by Victims, Supporters and Legal Specialists who have expressed deep concern about their contents. We have set out the annotated contents underneath for your information.
Comments are printed in red.
We have no confidence in the independence, expertise, competence and integrity of the Independent Safeguarding Board (ISB), or its staff. The Terms of Reference drafted by the Chair, Maggie Atkinson, were imposed without any proper process for agreement, and they lack legal proficiency throughout.
Ms. Atkinson’s Terms of Reference are designed to hide, protect and absolve the perpetrators of serious abuse from the outset, and in no way address the corruption and incompetence that lies at the heart of this case and other cases. There can be no confidence in Ms. Atkinson’s work, or in the remit of the ISB.
The complaint put to the Archbishops and Archbishops’ Council provided evidence of corruption, partiality, gross incompetence, conflicts of interest, cover-ups, misconduct and malfeasance riddling the oversight and practice of safeguarding in the Church of England and NST. The Archbishops’ attention was drawn to the dangerous and deliberate ‘weaponization of safeguarding’ perpetrated by lawyers, PR agents, clergy and church officers, and aided and abetted by the Bishop of Oxford and NST staff.
We are astonished that the ISB are undertaking this ‘Review’ since in their report as part of GS2244 at February 22nd 2022 meeting of the Church of England’s General Synod, para 6, Ms. Atkinson stated: “The ISB is not a re-investigation body. It does not have powers to sanction, direct, regulate, inspect or insist. Its authority is moral, members having no connection to the CofE”. This must also presumably limit its powers to obtain any documents or compel any testimony.
This also means that its report will have little or no probative value if, at the end of this, anyone harmed in the process wishes to seek compensation via legal action. For the ISB to undertake this task represents a clear departure from their official terms of reference. As Children’s Commissioner, Ms. Atkinson exercised her powers under the Children Act 2004 to look into School Exclusions under the term “Inquiry”, where she reported the work was performed by a team supported by “an expert panel”.
There are no other indications that she has ever chaired any Board of Enquiry, and she patently lacks the experience to deal with these complex matters. We are extremely concerned about the very limited in-person reading period proposed and how they will deal with disputes about evidence.
We are concerned that Ms. Atkinson seems to lack the skills, experience, powers and resources to undertake this proposed ‘review’. At every level her Terms of Reference fail to demonstrate the required independence for such an Inquiry at this level. Victims would be glad to engage in an Independent Inquiry that has some serious and proper standing. Regrettably, the ISB’s work would not be able to reach the required standard that could command confidence and trust. We believe that Ms. Atkinson should now consider her position, and withdraw from work she is plainly unfit to undertake.
Section 1 Introductory remarks and context
- The ISB will undertake and report on a forensic review of the quality of previous investigations and reports undertaken into safeguarding issues at Christ Church Oxford.
- The review was requested and is jointly commissioned by the Archbishop’s Council (AC) and the Diocese of Oxford. The three members agreed to undertake this work as described in these Terms of Reference.
- Its findings will be presented in a published ISB report.
- The period under consideration begins in early March 2020 and ends in March 2022. The longstanding dispute between the then-Dean and the College authorities is outside the scope of this review.
- The ISB will examine individuals’ and organisations’ roles and involvement, and will review reports or judgements already written on the case. It is not within scope to undertake a review of the primary sources of evidence relied upon in earlier reports and investigations.
- Whilst a C of E review process under the remit of the NST commenced a review, due to issues in relation to issues raised about the constitution of that core group the LLR was placed on hold. This will now allow the ISB to complete its review.
Comments on Section 1:
- These Terms of Reference have not been competently or legally drafted.
- There is a current review of Christ Church safeguarding being conducted by Ineqe.
- Previous “investigations” at Christ Church were weaponized by the lawyers for the diocese/college. In view of this, “quality” (1.1) is hardly the issue.
- The Dean first raised safeguarding concerns in 2017, and this marked the beginning of the campaign to remove him, as safeguarding was not being undertaken in the College, which was a failing of statutory obligations.
- Clergy opposed to the Dean then weaponized a charge of “immoral, scandalous and disgraceful conduct” against the Dean, and began gas-lighting. This was the spring/summer of 2018.
- The Bishop was informed of this, and in 2019 he received the Smith Tribunal judgment that showed he had been lied to by those clergy. He declined to act.
- In February 2020, Luther Pendragon and Winckworth Sherwood were contacting media organisations and the NST, planting manufactured “safeguarding concerns” relating to the Dean.
- We cannot understand why Ms. Atkinson thinks this review only commences from March 2020 to the present (1.4). Can she explain her time-frame?
- Clause 1.5 contradicts 1.1 – a “forensic review” of “previous investigations and reports” is promised (1.1). Yet 1.5 states: “it is not within scope to undertake a review of the primary sources of evidence relied upon in earlier reports and investigations”. Which is it?
- Clause 1.6 – the conduct of the Core Group, the conflicts of interest, its gross incompetence and breaches of its own codes of practice are also a subject for review. Nobody has any faith in an Lessons Learned Review.
Section 2 – The ISB’s review
- The ISB is not a judicial or quasi-judicial body. This being the case, whilst the ISB will complete an independent review and make recommendations arising from its findings, it will then be for others to determine which recommendations are then adopted and implemented, and how any such implementation will be undertaken.
- The purpose of an ISB review is to ensure that alleged or proven abusive behaviours or failures in safeguarding and/or its leadership, along with their attendant damage to reputations, relationships, practice and governance in any institution, might in future be prevented.. This part of the ISB remit is particularly relevant given the complex issues this case has raised. The NST’s work is therefore central to, but it is not the only body whose work will be considered during, this Review
- The NST having been involved in this case under its remit for acting on the conduct of senior clergy in safeguarding matters, it will provide the ISB with all relevant paperwork. This is covered by an information sharing agreement (ISA) between the ISB and the Archbishops’ Council (AC.) The ISA will also be used to give assurance on GDPR compliance in necessary exchanges of information between all those involved in this review.
- The ISB is not a primary review body, but a scrutiny and assurance one. It was established to scrutinise, and publicly to report on, how well the NST’s remit is undertaken, including in casework; and to advise the wider Church on safeguarding development and important lessons to be learned.
- The ISB’s remit reaches beyond its scrutiny of the NST’s work. It reports on church-wide safeguarding development and advises on ways of achieving continued improvement, including in future ways of guaranteeing independence in safeguarding scrutiny and oversight. The ISB advises the Church of England on changes needed to ensure safeguarding is central to all activities. The lessons drawn from this review will contribute to the fulfilment of this part of its remit. The review will include an index of all the evidence considered that forms part of the investigation.
- The review will report on the quality, completeness and robustness of what C of E bodies have done in work already undertaken, commencing in March 2020 and closing in March 2022. The report will present recommendations on future actions for diocesan and national church bodies to undertake as a result of what it concludes.
- The review will serve the purpose of a LLR, as well as extending beyond into making recommendations on work undertaken by the NST, the Diocese of Oxford and Christ Church.
- All earlier reviews and their reports will be reviewed. These will include but will not be limited to previous reviews commissioned by the NST and the Diocese of Oxford. Materials from the Clergy Disciplinary Measure (CDM) process evidence will also be considered. However, no previous process will be reopened by the ISB.
- The materials which key bodies or individuals already hold that relates to, or records of previous engagement with those most affected by this case, will be reviewed by the ISB. The report will present an objective view of how well such previous work was done.
- The ISB’s report will centre on:
- How well or badly safeguarding responsibilities have been fulfilled;
- How well the NST has undertaken its work, or commissioned others to undertake it;
- Presenting clear findings and recommendations to the parties concerned in Oxford, the leadership of the C of E, and the wider church.
- The review will be managed, and the report will be written, by the ISB’s three members. They will agree and the ISB will publish the closing report. Editorial control will be the ISB’s throughout. Parties involved will see the final report in strict confidence a maximum of 24 hours ahead of publication. Whilst they may comment on factual accuracy they will not have authorial or editorial rights.
- The ISB is supported by independent legal advisors who have no connection with the C of E and were appointed following a procurement exercise to support ISB.
- As part of the scope of the review those who have submitted previous reports or evidence, and to whom ISB could usefully speak as part of this review, will be invited to be interviewed. If they accept, their interviews will be recorded.
- No participant will be named in the report, which will use either pseudonyms or initials. That some involved are publicly known and could be identified by some readers is not disputed. However, not everybody concerned is so known, and the ISB will adhere to generally accepted good practice in safeguarding by striving to maintain their anonymity.
Comments on Section 2:
This section repeats the contradictions from the previous section. For example:
Clause 2.8: “All earlier reviews and their reports will be reviewed. These will include but will not be limited to previous reviews commissioned by the NST and the Diocese of Oxford. Materials from the Clergy Disciplinary Measure (CDM) process evidence will also be considered. However, no previous process will be reopened by the ISB”.
This is a plain contradiction of 1.5.. This section further evidences shoddy drafting, and a failure to engage legal expertise in drafting these Terms of Reference. There is no reason to place any trust or confidence in this work.
Section 3 – The ISB’s way of undertaking this work
- The ISB’s remit requires that its work is objective. It is not part of the C of E’s complaints systems, but an independent body. The funding that supports it comes from the Archbishops’ Council (AC) acting as a commissioner of this specific piece of work. The AC cannot direct the ISB’s work. It can ask for consideration of topics including reviews such as this one, but the ISB does not have to take them up. If it does so, how the work is done is determined by the ISB.
- The ISB does not reopen from scratch, or reinvestigate as if from a blank page, any case covered by others that may then come to it for a review. The ISB calls out, in public and where necessary through the media, issues it judges have been poorly addressed. It holds to account those responsible for ensuring improvement, and reports on success and failure in achieving it.
- The report will comment on good practice where relevant, as well as reporting on clear failings in practice, leadership or management. The ISB will also comment on the timeliness, completeness and appropriateness of responses by C of E bodies and NCIs to how this case was handled, and to C of E wide concerns this case raises.
Comments on Section 3:
The ISB is funded by and accountable to the Archbishops’ Council. It has already stated that it will not receive complaints from individuals. As the funding and accountability for the ISB lies with the very bodies that should be under investigation, the assertions in this section are misleading and untrue.
The ISB is not independent. It has no powers to “ask” for anything (3.1).
Under 3.2, we again see flat contradictions of 1.5 and 2.8. The only conclusion to reach is that the person drafting these Terms of Reference lacks the skill, expertise and experience for doing so. Ms. Atkinson has been asked to provide evidence that she has undertaken such work before. She has declined to do so, and therefore the improvised and amateurish nature of the Terms of Reference are hardly a surprise.
Section 4 – Practicalities: Timing, those contributing, outcomes sought
- The Review will commence on Monday 30 May 2022 .
- On that date, a call for the submission of written evidence will be issued directly to those already acknowledged as having such evidence to contribute:
- The complainant who brought safeguarding allegations
- The former Dean
- Members of the clergy and staff at Christ Church
- The Archbishops of Canterbury and York, their staffs and both their internal and external advisers
- The Diocesan Bishop and Diocesan Secretary, Oxford Diocese
- The Oxford Diocesan Safeguarding Panel (DSAP) and its Chair
- The Oxford Diocesan Safeguarding Adviser
- Members of the casework team and the Interim Director at the National Safeguarding Team (NST)
- The members of the Archbishops’ Council who investigated a complaint made in the summer of 2020, and
- The members of staff against whom that complaint was made.
Comments on Section 4:
The ISB demonstrates its complete lack of comprehension, viz:
Clause 4.2.1 – “complainant”? There were seven complaints made against the Dean, and the “complainant” in these is a combination of Winckworth Sherwood, Luther Pendragon, some clergy of Christ Church and church officers of the Diocese. Complicity in this was provided by the NST, Bishop and others.
Clause 4.2.5 – Diocese of Oxford’s internal/external advisers missing – why? Director of Communications missing, as is Bishop of Reading and others. Why?
In the case of the 7th (safeguarding?) allegation, the alleged ‘victim’ categorically stated on the record that they are not a ‘vulnerable adult’, so this is therefore not a safeguarding matter. In June 2021 the NST confirmed that this was not a safeguarding matter, and the Core Group disbanded. The Bishop of Oxford disputes this.
In view of this, the “complainant” referred to in 4.2.1 can only be the Dean. He is the one complaining about the “weaponization of safeguarding” perpetrated by the lawyers for the Diocese, their PR agents and others. Winckworth Sherwood kept pressing the NST on how the 7th allegation and earlier ones could be and to “[made] safeguarding”, and Luther Pendragon extensively briefed the media on the “allegations” before the Dean had been informed. This is “weaponization”.
Missing from this section is any mention of Winckworth Sherwood, Luther Pendragon and other agents of abuse complained about (e.g., Diocesan staff, clergy and officers, the Archbishops’ Council also removed). Can the ISB explain why those organisations and individuals have continued to be removed from every single draft of the Terms of Reference? Is this a decision by the “commissioners” of the ISB’s work? If so, the ISB is not independent. If not, the ISB is plainly incompetent (see conclusion).
The ISB will take NO further written materials that are not presented following this single call for evidence and adhering to its deadline.
- The call for evidence will close on Friday 01 July 2022. An email address will be supplied for electronic submissions, which will be the preferred means of submitting materials. Evidence should be presented in chronological order and where necessary should include signposting to other materials, which should be included as appendices in the paperwork concerned.
- The ISB Chair will seek updates from the reader/analyst throughout their work, which will focus on reading, making detailed notes, helping to frame a narrative and recommending key lines of enquiry (KLOEs).
- This portion of the work should be completed by 30 September 2022, with the reader/analyst concluding by giving the ISB the lines of enquiry generated, key questions, and likely direction of travel for the review.
- Those submitting evidence who in addition are prepared to be interviewed, will be seen as soon after the end of September as possible. Evidence from interviews will be added to the files mentioned above.
- As appropriate and necessary, the ISB will issue updates on the progress of this review to the commissioning bodies and interested parties.
- The ISB will present a polished draft report by the end of 2022. This draft will be issued in strict confidence, for read and comments on factual accuracy only. Recipients will be limited to those to whom the call for evidence was issued.
- One month will be allowed for comments on the text, editorial control of which will remain with the ISB. The report will be published by the end of January 2023. If readers cannot agree at this final stage, the ISB will publish with their disagreement noted in the text.
- The ISB has complied with all the necessary statutory frameworks to ensure data and information is securely and appropriately shared.
- The report will be written and published by the ISB’s 3 members, who have complete editorial control.
Conclusion:
The ISB Terms of Reference are extremely shoddy, and there is no basis for trust and confidence in the document, the person drafting it, and those purporting to undertake the work. The ISB emerges as an internal complaints body, lacking the experience, expertise, skills and resources to undertake a serious piece of work. The ISB has no external accountability, and is not following Nolan Principles for conduct in public life. As a body, its existence is owed to its sponsors, who have inherent conflicts of interest, and vested interests in ensuring that there is never any proper scrutiny of the malfeasance, misconduct, gross incompetence, partiality and conflicts of interest that riddle the NST and CofE safeguarding.
There can be no confidence in the ISB conducting this work, given its Chair told General Synod only a few months ago that:
“The ISB is not a re-investigation body. It does not have powers to sanction, direct, regulate, inspect or insist. Its authority is moral, members having no connection to the CofE”.
Furthermore, the ISB will be trespassing on current investigations, including the Charity Commission and the Solicitors’ Regulation Authority both of whom are now three years into their investigations of Christ Church and Winckworth Sherwood over their alleged misconduct. This includes:
- Weaponization of Safeguarding, including rigged investigations against the Dean and bogus risk assessments approved by the Bishop and Diocesan staff.
- Being party to serious financial irregularities.
- Abuses of CofE, safeguarding and employment protocols.
- Deliberate misuse of charitable funds to pursue vendettas.
The deliberate perpetration of extensive “weaponizing safeguarding” against the former Dean and others is wholly neglected in Ms. Atkinson’s Terms of Reference. The commissioners of the proposed review are party to the perpetration of the abuses, and it is inherently dishonest of them to direct terms and conditions for such an exercise, and claim it is “independent”. The ISB should know this. If they don’t, they are not fit for purpose. If they do know this, they are part of the very corruption that needs serious independent (external) judicial investigation.
APPENDIX: Further Notes – comments in Bold Italic
Independent Safeguarding Board (ISB) Review: Christ Church Oxford
Introductory remarks and context [1]
- The ISB will undertake and report on a forensic review (surely “will undertake a forensic review and report”) of the quality of previous investigations and reports undertaken into safeguarding issues at Christ Church Oxford.
- The review was requested and is jointly commissioned by the Archbishop’s (Spelling) Council (AC) and the Diocese of Oxford (No mention of MP, Christ Church?). The three members agreed to undertake this work as described in these Terms of Reference.
- Its (clumsy, surely “The Review’s findings….”) findings will be presented in a published ISB report.
- The period under consideration begins in early March 2020 and ends in March 2022. The longstanding dispute between the then-Dean and the College authorities is outside the scope of this review. [Were NST, Bishop and the CofE not involved before then?]
- The ISB will examine individuals’ and organisations’ roles and involvement, and will review reports or judgements already written on the case. It is not within scope to undertake a review of the primary sources of evidence relied upon in earlier reports and investigations. [though surely will address whether statements/claims/evidence were properly obtained and reported, and that might require addressing some of the source evidence]
- Whilst a C of E review process under the remit of the NST commenced a review, due to issues in relation to issues raised about the constitution of that core group the LLR was placed on hold. [What a ghastly sentence, multiple use of “issues”, “Review”] [does not define LRR, just assumed it is known] This [what ?] will now allow the ISB to complete its review.
The ISB’s review [2]
- The ISB is not a judicial or quasi-judicial body. This being the case, whilst the ISB will complete an independent review and make recommendations arising from its findings, it will then be for others to determine which recommendations are then adopted and implemented, and how any such implementation will be undertaken. [So, toothless…?]
- The purpose of an ISB review is to ensure that alleged or proven abusive behaviours or failures in safeguarding and/or its leadership, along with their attendant damage to reputations, relationships, practice and governance in any institution, might in future be prevented.. [floating full stop; surely the purpose of an ISB review does not relate just to “abusive” behaviours/failures: in fact, this is the first and only definition of what an ISB Review might look like. Are these Reviews actually discussed anywhere else, in the original discussion about the ISB ? Or is this ISB Review “made up” for the purposes of Christ Church/Diocese/NST?] This part of the ISB remit is particularly relevant given the complex issues this case has raised. The NST’s work is therefore central to, but it is not the only body whose work will be considered during, this Review.
- The NST having been involved in this case under its remit for acting on the conduct of [clunky] senior clergy in safeguarding matters, it will provide the ISB with all relevant paperwork. This is covered by an information sharing agreement (ISA) between the ISB and the Archbishops’ Council (AC.) [Defined elsewhere as AC] The ISA will also be used to give assurance on GDPR compliance in necessary exchanges of information between all those involved in this review. [But it has just said that the ISA is between just AC and ISB. What about other parties, including NST, Diocese and the College ? There needs to be a watertight data protection agreement available for all parties. Participants (MP needs to be sure there are appropriate “walls” between the ISB and all investigated]
- [floating 2.4. Did no one proofread this at all……?] The ISB is not a primary review body, but a scrutiny and assurance one. It was established to scrutinise, and publicly to report on, how well the NST’s remit is undertaken, including in casework; and to advise the wider Church on safeguarding development and important lessons to be learned.
- The ISB’s remit reaches beyond its scrutiny of the NST’s work. It reports on church-wide safeguarding development and advises on ways of achieving continued improvement, including in future ways of guaranteeing independence in safeguarding scrutiny and oversight. The ISB advises the Church of England on changes needed to ensure safeguarding is central to all activities. The lessons drawn from this review will contribute to the fulfilment of this part of its remit. The review will include an index of all the evidence considered that forms part of the investigation. [2.5 and 2.6 are sudden declarations of what ISB thinks it is for? Why here?]
- [formatting??] The review will report on the quality, completeness and robustness of what C of E bodies have done in work already undertaken, commencing in March 2020 and closing in March 2022. The report will present recommendations on future actions for diocesan and national church bodies to undertake as a result of what it concludes.
- The review will serve the purpose of a LLR [as above, not defined. If it is an LLR, should not it spell out the limitations of LLRs and not address that; LRRs are flawed anyway], as well as extending beyond into making recommendations on work undertaken by the NST, the Diocese of Oxford and Christ Church.
- All earlier reviews and their reports will be reviewed. These will include but will not be limited to previous reviews commissioned by the NST and the Diocese of Oxford. Materials from the Clergy Disciplinary Measure (CDM) process evidence will also be considered. However, no previous process will be reopened by the ISB.
- The materials which key bodies or individuals already hold that relates to, or records of previous engagement with those most affected by this case, will be reviewed by the ISB.[just not English] The report will present an objective view [what is that?] of how well such previous work was done.
- The ISB’s report will centre on:
- How well or badly safeguarding responsibilities have been fulfilled;
- How well the NST has undertaken its work, or commissioned others to undertake it;
- [this makes NST the main target, whereas all the other parties, whether Diocese, their lawyers, Christ Church and clergy: should be listed here]
- Presenting clear findings and recommendations to the parties concerned in Oxford, the leadership of the C of E, and the wider church.
- The review will be managed, and the report will be written, by the ISB’s three members.[How ??? This is absurd !! How on earth can they resource this ? Who has writing or investigative skills ? What previous, serious, high profile, Reviews have any of them undertaken ? Done properly, the Review could be 200-400 pages. As with Makin, etc, a little thought might say this will take two people, full time, one year] They will agree and the ISB will publish the closing report. Editorial control will be the ISB’s throughout. Parties involved will see the final report in strict confidence a maximum of 24 hours ahead of publication [farcical, and probably unlawful. What will they do if mistakes are found, and they need to go back to sources, or re-Maxwellise? What they describe here is not “representations” but just “prior viewing” And they do not define “Parties”….who will get to see it?………..see 4.8 below]. Whilst they may comment on factual accuracy they will not have authorial or editorial rights.
- The ISB is supported by independent legal advisors who have no connection with the C of E and were appointed following a procurement exercise to support ISB. [what does “supported” mean?]
- As part of the scope of the review those who have submitted previous reports or evidence, and to whom ISB could usefully speak as part of this review, will be invited to be interviewed. If they accept, their interviews will be recorded. [and presumably transcribed, and interviewees allowed to sign off on the transcripts as being accurate]
- No participant will be named in the report, which will use either pseudonyms or initials. That some involved are publicly known and could be identified by some readers is not disputed. However, not everybody concerned is so known, and the ISB will adhere to generally accepted good practice in safeguarding by striving to maintain their anonymity. [Why is this being suggested, and who is advocating it, given these ToR’s already go to great lengths not to name individuals and organisations?}
- The ISB’s way of undertaking this work
- The ISB’s remit requires that its work is objective.[be pretty odd if this was not the case !!] It is not part of the C of E’s complaints systems, but an independent body. The funding that supports it comes from the Archbishops’ Council (AC) acting as a commissioner of this specific piece of work. The AC cannot direct the ISB’s work. It can ask for consideration of topics including reviews such as this one, but the ISB does not have to take them up. If it does so, how the work is done is determined by the ISB. [Nolan principles, natural justice and the law….??]
- The ISB does not reopen from scratch [hardly a legal phrase] , or reinvestigate as if from a blank page, any case covered by others that may then come to it for a review. The ISB calls out [Does it? How does this tally with an “objective” review?], in public and where necessary through the media, issues it judges have been poorly addressed. It holds to account those responsible for ensuring improvement, and reports on success and failure in achieving it.
- The report will comment on good practice where relevant, as well as reporting on clear failings in practice, leadership or management.[this is so repetitive, and rambling. The scope and role of the ISB is referred to and defined in about ten places] The ISB will also comment on the timeliness, completeness and appropriateness of responses by C of E bodies and NCIs [not defined] to how this case was handled, and to C of E wide concerns this case raises.
- Practicalities: Timing, those contributing, outcomes sought
- The Review will commence on Monday 30 May 2022 . [Who will this actually be?]
- On that date, a call for the submission of written evidence will be issued directly to those already acknowledged as having such evidence to contribute:
- The complainant who brought safeguarding allegations
- The former Dean
- Members of the clergy and staff at Christ Church
- The Archbishops of Canterbury and York, their staffs and both their internal and external advisers
- The Diocesan Bishop and Diocesan Secretary, Oxford Diocese
- The Oxford Diocesan Safeguarding Panel (DSAP) and its Chair
- The Oxford Diocesan Safeguarding Adviser
- Members of the casework team and the Interim Director at the National Safeguarding Team (NST)
- The members of the Archbishops’ Council who investigated a complaint made in the summer of 2020, and
- The members of staff against whom that complaint was made.
- [why so many missing individuals and organisations here…..?]
The ISB will take NO further written materials that are not presented following this single call for evidence and adhering to its deadline. [Just 25 working days…..farcical. And no serious Review would exclude important evidence received after that]
- The call for evidence will close on Friday 01 July 2022. An email address will be supplied for electronic submissions, which will be the preferred means of submitting materials. Evidence should be presented in chronological order and where necessary should include signposting to other materials, which should be included as appendices in the paperwork concerned.
- The ISB Chair will seek updates from the reader/analyst [first mention? who?] throughout their work, which will focus on reading, making detailed notes, helping to frame a narrative and recommending key lines of enquiry (KLOEs). [jargon]
- This portion of the work should be completed by 30 September 2022, with the reader/analyst concluding by giving the ISB the lines of enquiry generated, key questions, and likely direction of travel […suppose they see it as a “journey”] for the review.
- Those submitting evidence who in addition are prepared to be interviewed, will be seen as soon after the end of September as possible. Evidence from interviews will be added to the files mentioned above. [Personal evidence could amount to over a weeks’ worth of testimony?]
- As appropriate and necessary, the ISB will issue updates on the progress of this review to the commissioning bodies and interested parties.
- The ISB will present a polished [NOT a legal term !!] draft report by the end of 2022. This draft will be issued in strict confidence, for read and comments on factual accuracy only. Recipients will be limited to those to whom the call for evidence was issued.
- One month will be allowed for comments on the text, editorial control of which will remain with the ISB. The report will be published by the end of January 2023. If readers cannot agree at this final stage, the ISB will publish with their disagreement noted in the text.
- The ISB has complied with all the necessary statutory frameworks to ensure data and information is securely and appropriately shared. [Seriously? Where is the draft Data Notice? Where is the information sharing protocol? Where are the draft consent forms? A Conflicts of Interest policy?]
- The report will be written and published by the ISB’s 3 members, who have complete editorial control. [repetition…….]
Overarching comment: under what part of its constitution (which does not yet exist) does the ISB have the remit or powers to undertake this Review? What makes them a “competent” body to undertake the work? What will be the legal status of a Review by an un-constituted body? This has made the ISB a quasi-judicial body, apparently able to comment, criticise and recommend? Yet, by Maggie’s own admission at Synod, they have no such powers.