Memorandum by The Guide Association
CRIMINAL RECORDS BUREAU
1. Thank you for inviting comments from
The Guide Association who will be a potential major user of the
Criminal Records Bureau. As the UK's largest organisation for
girls and young women with more than 600,000 members aged between
5 and 25 years we take our responsibilities for safeguarding the
welfare of the membership very seriously. We have consistently
supported the principle of establishing the Bureau as this will
provide new access to information that can formally assist our
existing rigorous recruitment procedures.
2. There are more than 100,000 adult volunteers
in the Guide Association . We expect to need to access enhanced
disclosures for more than 40,000 volunteers per year.
3. The contribution of the work done by
the volunteer adults in the Guide Association is equivalent to
employing more than 5,000 full time youth workers. The Association
has given this service to local communities for 90 years free
of charge. It is difficult to accept we will have to find almost
£500,000 a year in order to continue to offer this opportunity
to girls and young women.
4. As a UK wide organisation it has become
clear that arrangements will be different for potential volunteers
in England and Wales than those for potential volunteers in Northern
Ireland, Scotland, Isle of Man, Channel Islands This may lead
to a different level of service and has certainly led to a different
level of equity as it is now clear that potential volunteers in
Scotland will not be charged for the disclosure and access to
PECS in Northern Ireland is also currently free of charge.
5. The Association is therefore faced with
policy and procedural issues which lead to a new layer of complexity
in the bureaucracy of the whole organisation. Changes in administrative
arrangements alone will cost the organisation tens of thousands
6. The government has repeatedly referred
to the fact that using the Bureau is optional for voluntary organisations.
However this is at least implicitly contradicted in the new criminal
offence which makes trustees and employers vulnerable if they
appoint someone whom they could have checked.
7. Expectations from Insurers and parents
who support their girls in joining the organisation will demand
that The Guide Association has to make use of this facility at
the enhanced level.
8. In the Regulatory Impact Assessment we indicated
that we would expect to need to check more than 40,000 volunteers
each year and around 50 new staff including many seasonal activity
instructors. Using the illustrative figure of £10 per person
this is an estimated annual cost of £450,000.
9. Guiding is carried out at a neighbourhood
level. It is also funded locally without any state grants or central
bursaries. Many units can only provide a service to girls and
young women in their area if the weekly fee is no more than 50
pence. The idea that additional funds need to be found to cover
the cost of the disclosure every time a new adult joins presents
a serious financial burden to the local unit.
10. One in three girls aged 8 in the UK
is a Brownie. We are not often associated with working with those
who are socially excluded but with this kind of percentage membership
we are surely taking care of a large number of girls and young
women who may become at risk of being socially excluded. There
does not seem to be any recognition of this as government funding
is directed to those at one extreme of the spectrum.
11. The Guide Association is committed to
working with the Bureau and once again urges the Home Secretary
to use his powers under the Police Act to waive the charges for
Mrs Terry Ryall, Chief Executive