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DRAFT CHILDREN'S SERVICES (SCOTLAND) BILL

The UNISON Scotland Submission to the Scottish Executive consultation on the Draft Children's Services (Scotland) Bill.

March 2007

Executive Summary

  • UNISON is Scotland's largest trade union representing over 160,000 members working in the public sector, many of whom work with children.
  • UNISON Scotland welcomes the opportunity to respond to the Scottish Executive's consultation on the Draft Children's Services (Scotland) Bill. 
  • UNISON Scotland welcomes the Draft Bill's intentions to improve services for children and ensure they are provided in a more integrated way. The focus on early intervention is positive and its vision of agencies working together to support the child at the centre is laudable and builds on current policy.
  • However, we believe that the single biggest hindrance to children and their families receiving the services they need, when they need them, is a lack of resources. This is especially true at the early intervention stage.
  • We know that at present one of the key barriers to the effectiveness of the Children's Hearing System, and one of the major frustrations for social work and other Local Authority staff and for panel members, is the lack of resources of all kinds to meet the needs of children.
  • Unfortunately, when resources are mismatched with need, priorities dictate that they are directed towards offending behaviour, often the result of a lack of early intervention, rather than at early intervention itself. This further compounds the situation.
  • In addition, Scottish Executive ‘ring-fenced' funding initiatives are often targeted at the symptoms (e.g. anti-social behaviour) rather than the causes and at the expense of early intervention.
  • If the Bill is to lead to improvements in the well-being of all children, then considerable additional investment will be needed which is targeted at early intervention.
  • There will also be a need for multi-agency training in relation to the new requirements on agencies outlined in the Bill.
  • UNISON Scotland believes there should be more clarification in Section 19 of the Bill regarding Secure Accommodation. It is unclear at what point restrictions could be lifted or amended to allow reintegration of the child (which will always be necessary) and who would make that decision.
  • Secure accommodation is not a sentence and was never intended to be a sentence. It is a measure to offer protection to the child or others and was explicitly set up with the safeguard that it would only be used when necessary to effect that purpose and for only as long as is absolutely necessary.

 

Introduction

UNISON is Scotland's largest trade union representing over 160,000 members working in the public sector, many of whom work with children. We represent many social workers, who perform a wide range of duties in Children and Family services as well as members working for the Scottish Children's Reporters Association. We also have members working in schools as classroom assistants, support and administrative staff, cleaners, janitors and caterers; members working in early years establishments as nursery nurses, support workers within nurseries and crèches; and members across the NHS, working with children such as nurses, ancillary staff, cleaning and catering staff, etc.

UNISON Scotland welcomes the opportunity to respond to the Scottish Executive's consultation on the Draft Children's Services (Scotland) Bill.  

General Comments

UNISON Scotland welcomes the Draft Bill's intentions to improve services for children and ensure they are provided in a more integrated way. The focus on early intervention is positive and its vision of agencies working together to support the child at the centre is laudable and builds on current policy. The concern, however, is that the Bill seeks to do this by imposition without the consultation referring in any detail to the resources that will be required to deliver this effectively.

The proposals build from the clear research evidence and an acceptance in the 21st Review of Social Work, that early intervention on an integrated joint agency basis is the most effective way to ensure the "well-being" of children and this is welcomed. However, the references to resourcing these changes in the consultation document lack any detail and the implication made often is that the savings it anticipates will be made from some of the proposed changes can just be used to fund other proposed developments.

However, we believe that the single biggest hindrance to children and their families receiving the services they need, when they need them, is a lack of resources. This is especially true at the early intervention stage. Early intervention on an integrated joint-agency basis has been shown to be the best way to effect change and to improve the well-being and potential of children. Apart from the ‘Communities that Care' and various other research projects, this is also backed up by the fact that most children who are referred to the Reporter on offence grounds, have previously been referred on care grounds.

We know that at present one of the key barriers to the effectiveness of the Children's Hearing System, and one of the major frustrations for social work and other Local Authority staff and for panel members, is the lack of resources of all kinds to meet the needs of children.

Unfortunately, when resources are mismatched with need, priorities dictate that they are directed towards offending behaviour, often the result of a lack of early intervention, rather than at early intervention itself. This further compounds the situation. In addition, Scottish Executive ‘ring-fenced' funding initiatives are often targeted at the symptoms (e.g. anti-social behaviour) rather than the causes and at the expense of early intervention. This not only skews resources, it also diverts the limited pool of experienced staff, leaving gaps at the primary intervention level. If the Bill is to lead to improvements in the well-being of all children, then considerable additional investment will be needed which is targeted at early intervention.

The principles of ‘It's Everyone's Job To Make Sure I'm Alright' are reflected in parts of the Draft Bill but other sections seem to restrict the ‘relevant agencies' coming under the Bill's remit. It is important that all agencies and functions, universal and targeted services and broad community services, for example leisure and recreation, see the need to work together.

There will also be a need for multi-agency training in relation to the new requirements on agencies outlined in the Bill. As we understand it the Bill will place additional responsibilities on many of the agencies currently providing services to children and changes the focus of their involvement. Whilst good interagency working has developed across Scotland, this Bill will extend the responsibilities on all agencies, but particularly agencies other than local authority social work services who will be obliged to act to meet and promote the needs of children to a greater degree than they do now. Clear guidance will be needed on how this will work in practice alongside new procedures to ensure accountability and frameworks for information sharing.

Secure Accommodation - Section 19 of the Bill

One significant question is missing from the consultation regarding this Section which has important ramifications for children detained in secure accommodation. The deletion from the Principle Act of "during such period as the person in charge of that establishment, with the agreement of the chief social work officer of the relevant local authority considers necessary" removes an essential safeguard that ensures children are only detained in secure accommodation when it is absolutely required.

It is crucial that such a decision should have the level of independent scrutiny inherent in the requirement of agreement between the ‘internal unit manager and the ‘external' chief social work officer and that should remain.

The form of the deletion leaves no checks and balances as to what processes would be in place and at what level a decision would be made about the point a child who ‘shall be liable to be placed and kept in secure accommodation'. It is unclear at what point restrictions could be lifted or amended to allow reintegration of the child (which will always be necessary) and who would make that decision. It would be entirely unacceptable (and a recipe for disaster) for a child to be placed in secure accommodation without an exit plan to allow some form of transition.

Secure accommodation is not a sentence and was never intended to be a sentence. It is a measure to offer protection to the child or others and was explicitly set up with the safeguard that it would only be used when necessary to effect that purpose and for only as long as is absolutely necessary.

Additionally, there is a great emphasis in the consultation paper on ensuring consistency. While the wording of the proposed amendment to the Children (Scotland) Act leaves the condition that a child would only be ‘liable' to be detained in secure accommodation, it may be the intention that the actual decision about detention is to be taken by the Childrens Panel. If this is the case, the removal of the existing safeguard would place the responsibility to ensure consistency in respect of decisions about a child's need for secure care entirely with the panel members making the decision (three from a large number of panel members) rather than with a much smaller number of senior professionals. Many of our members who work with these children know that decision-making already lacks a level of consistency and have come across situations where decisions about secure care did not robustly meet the criteria laid down. This underlines the need for a level of independent scrutiny.

If the deletion is designed to address the fact that some orders cannot be implemented because of a lack of resources, it is that which should be addressed and not the important safeguard to ensure children are not unnecessarily locked up without a clear welfare purpose.

 

Questions for Consultation

Part 1: The Draft Bill

Q1. Do you think that the concept of well-being in relation to the duties on agencies set out in sections 1 and 2 of the draft Bill is helpful?

Overall, the concept of well-being is helpful, in particular the identification of unmet need. However, this needs to be matched with a resource strategy to meet the need.

Section 2 raises this issue of children who may pose a risk to the safety of other people. This needs careful consideration as to whether this would give fewer rights to a child than an adult. The issues of proof, right to defend allegations, etc., are addressed under Question 11. We are reassured that the Bill requires that action must still be directed towards the child in the same way as with a child with unmet care and protection needs, especially as we know that these are often the same children. However, it will be important to provide guidance which ensures a focus on meeting needs rather than just reacting to deeds.

The Children (Scotland) Act 1995 s93(4) defines a ‘child in need'. This includes specific reference to disability or being affected by the disability of another person in the family. The definition of well-being may have benefited from such a specific inclusion but so long as s93(A) of the Principle Act remains in force we would have no objection.

Q2. Do you feel that the duties on agencies proposed in sections 1 and 2 of the draft Bill will ensure that all relevant agencies can and will act so that children get the help they need when they need it?

UNISON Scotland welcomes these duties, but believes they will be restricted depending on which agencies are defined as ‘relevant'.

However, we find Sections 1 and 2 very general. They place general duties on relevant agencies but lack any detail as to what exactly this means in practice. For example, whilst the Bill requires agencies to undertake certain specified actions "as it considers appropriate" to meet the child's needs, there is no specific duty to assess the needs of the child. It is recognised that different agencies will be able to contribute differently to an assessment of a child's needs, but the Bill does not address this and prefers to deal in more generalised concepts such as "take action with a view to improving a child's situation." If this is to ensure that children get the help they need when they need it, in our view it will need to be underpinned by very robust guidance (including what constitutes a "relevant" agency) and multi-agency training.

Q3. In your view, do the proposals in sections 2(5) and 5 of the draft Bill for recording agency decisions and actions and for a multi-agency action plan provide enough of a framework to deliver effective planning across agencies for the child and their family?

UNISON Scotland welcomes the role of the ‘lead professional' implicit in 5.(1)(b) but believes that further guidance will be required on how this is operated, what the role and responsibilities of this person are and, crucially, where the accountability for decisions, implementation of plans and the provision of resources will lie. Support structures for the role will be required along with clarification of what powers the individual may have to ensure agencies collaborate.

This will also have training implications for many staff, especially those in local authority and other agencies who have not previously had to take on a "lead professional" role.

 

Q4. It is the intention that the proposals in sections 4 and 5 of the draft Bill for collaboration of agencies will provide a robust but simple framework for agencies to work together locally. In your opinion, do you think that the framework will enable this to happen?

The framework extends existing good practice and formalises in law the requirement on agencies to work together. Unfortunately this does not mean it will always happen in a child-centred way and there will continue to be many challenges. Furthermore, it is still not clear how this may be enforced. Also, the "as so far as appropriate" clause will need clarification and guidance. We need to know in what circumstances it may be "inappropriate" for agencies to co-operate with each other and what exactly "co-operation" will mean in practice.

The issue of sharing information is not sufficiently developed. Currently there are clear guidelines for sharing information where parental permission is given, or without such permission in terms of child protection. Concerns remain, however, about the sharing of information under anti-social behaviour initiatives and whether these fully comply with data protection requirements.

There is a need to ensure that information is shared in appropriate circumstances. However, there should not be a presumption that any child's personal information should be shared automatically. Children have a right to privacy. The commitment within the consultation paper to seek consent (from children and their families) to information sharing is welcomed and needs to be underpinned by clear guidance.

Different agencies have different arrangements for storing and sharing information. It is crucial that there are clear guidelines for all agencies about the use of that information. For example, health, social work and education records are assumed by children and their families to be confidential. These agencies have procedures for secure storage, sharing and allowing children access to their records. This will not necessarily be the case for some other agencies and functions. There are serious implications for agencies if someone other than the agency which gathered the information in the first place accidentally or otherwise discloses confidential information to third parties.

Several inquiries have highlighted the need for better information sharing. However, they have concentrated on situations where there is some reason to believe that the child's safety requires that information to be shared.

There needs to be explicit thresholds and criteria for sharing information (the Data Protection Act currently outlines those) to avoid an unjustified random and unregulated sharing (and possibly further dissemination) of personal information. To protect the individual's right to privacy and balance that with the need to share information to protect a child or others requires a clear ‘need to know' guideline.

Q5. Are you content with the definition of relevant agencies (including parts of the voluntary sector) in section 7?

No. Section 7(1) (a) restricts the functions of local authorities to social work, education and housing. In terms of corporate responsibility for the well-being of children, the principles of the Children (Scotland) Act 1995 and of "Its Everyone's Job To Make Sure I'm Alright", the whole of the local authority should be seen as a relevant agency. In particular, culture, leisure, recreation and other services have key roles in universal services to improve the well-being of children.

The Bill leaves it open for Scottish Ministers to define public or non-public bodies as relevant agencies. We would need clear indications of what this may involve. For example, some local authorities have passed their housing function to housing agencies. Clearly, this reality should have been recognised in the Bill.

Other examples include private fostering agencies, the number of voluntary sector or private providers in residential and home care, the arms-length provision of leisure services and ‘commissioned' services from the community and voluntary sector.

The intention of this section would be best served by listing a range of functions which, if provided by a public or non-public body, would designate that body as a relevant agency. The Scottish Ministers' powers would then only be required for exceptions or unforeseen eventualities.

Q6. With regards to section 11, do you agree that the Principal Reporter should not be a member of the Administration (the Board) of the Scottish Children's Reporter Administration?

We believe this would be a sensible separation of roles.

Q7. The new power in section 12 for the Principal Reporter to appoint a representative if certain criteria are met is meant to safeguard the rights of those children who need such representation. Are you content with the introduction of this new power?

It is relevant to note that this power is to appoint a "legal representative". This is not a measure to improve advocacy and general representation for a child.

While it is the case that children would benefit from independent advice at the stage when they are considering whether or not to accept the grounds of referral, once the grounds have been established the focus changes.

It is important here to recognise the key principle of a Childrens Hearing which is to put the child at the centre of its deliberations. Ideally, Hearings should be discussions which involve the child and the family in addressing an issue, with the best interests of the child taking centre stage.

It is important to recognise firstly, that this discussion takes place in the context of the grounds for referral having been upheld or accepted and, secondly, that the child is not on trial.

It is not the experience of our members that legal representatives at Childrens Hearings enable the participation of children or that they are always clear about their role. Some can be very good and are clearly aware of the legal issues that apply and have an ability to relate to children. Others seem unsure as to their role and end up participating very little, often leaving the child wondering what their purpose was.

The nature of legal representation is that it tends to create an adversarial situation rather than a ‘problem solving' approach and inhibits - or specifically advises against - the participation of the child.

We do believe, however, that children would benefit from this power in particular circumstances, for example where they are being presented with offence grounds. Whilst the Rehabilitation of Offenders Act still applies to children who come before a Children's Hearing, it is important, that they are provided with legal advice on the implications of accepting such grounds, before they do so, and if they do not accept the grounds, supported by their legal representative through the proof hearing. The issue of the Rehabilitation of Offenders Act and whether it should apply in the Children's Hearing System has unfortunately not been addressed in the Bill and we believe that this is a missed opportunity.

However, we do recognise that there are other occasions where a child may require specific advice and representation in situations where they do not believe their interests are being served or to help them to give their views. However, this is a role that may be better served by children's advocates or children's rights officers rather than legal representatives. It is very important that the appointment of a legal representative for a child does not take away their right to have a friend or representative of their choice as well. After all, the child is not given the choice as to whether or not to have a legal representative or of who is appointed. This power rests with the reporter.

It is important if the role of legal representation is to be extended in this way, that consideration is given to how such people are recruited and trained and that guidance is provided as to their role which is also available to the child, and therefore written in easily understood language.

Such appointments may address the problems that can arise when a family engages a solicitor to represent them or their child at Hearings. In these situations it is often not clear whether the legal representative is acting on the child's or the parents' behalf.

It is important to note under this question and the following question that the decision of the Hearing can be appealed to the Sheriff.

Q8. In section 12 the criteria for legal representation is expanded to include the appointment of a legal representative where a Children's Hearing is likely to make a movement restriction condition. Are you content with the introduction of this new criteria?

This seems appropriate given the possible restriction of liberty but should not exclude the child's right to have another advocate, e.g. children's rights officer.

In Questions 7 and 8, the additional pressure on local authority financial resources will have to be recognised.

Q9. Section 14 introduces new provision to withhold information about the child where disclosure would be significantly against the child's interests. Are you content with this new provision?

Yes. This used to be possible in the past until procedures changed. The requirement to pass all information to all relevant persons has caused considerable problems for some children and, in abuse cases in particular, has lead to important information not being communicated to the Reporter because of possible danger to the child if one or more of the ‘relevant persons' had access to that information.

Q10. Are you content with the proposals in section 15 of the draft Bill to change the grounds for referral to the reporter and the Children's Hearing to reflect the needs of a child and the need for compulsion?

The issue of compulsion exists in the current legislation in terms of s52 and s53 where the local authority has to refer if it believes a child may be in need of compulsory measures of supervision.

We broadly welcome the three measure test in Section 52A(2) of the Draft Bill but we are concerned about Section 52A(2)(c). If one of the tests is that ‘compulsory measures of supervision are (not may be) necessary', this appears to prejudge the role of the Childrens Hearing in deciding whether compulsion is necessary. If the grounds were upheld, it would put the position of the Childrens Hearing in an untenable position which could lead to the hearing being unable to discharge and disagree that compulsion was necessary.

We believe this drafting and its implications need to be closely examined.

Q11. The relevant situations in section 15 are intended to improve on the existing conditions in section 52(2) of the 1995 Act and to address possible gaps such as self-harm by a child and exposure to domestic abuse. Do you feel that the relevant situations are appropriate?

UNISON Scotland agrees that these are appropriate in general but are concerned that the way they are set out in the Bill puts the conditions which are based on the actions of the child first (i.e. offence grounds, truancy etc.), whilst the care and protection conditions are further down the list. We believe this should be reversed to fit with the underpinning welfare ethos of the Children's Hearing System.

We are also concerned about 52(B)(c) and what the test will be in terms of being ‘has caused, is causing, likely to cause another person to come to harm', etc. Our concern is that this may be widely interpreted on an ‘offence' basis with a much lesser burden of proof than the current ‘criminal proceedings' level which is required. Thus whilst it may prevent an offence being recorded on a child's record, the level of proof required if the ground is disputed, will be less that that required if an offence ground was to go to proof and would be based on the balance of probability rather than beyond reasonable doubt.

Q12. In your opinion, do the provisions in section 16 of the draft Bill to expedite the establishment of the situational condition where the relevant person accepts the condition but the child has not understood or is not able to understand provide adequate and appropriate protection for the rights of the child?

In terms of care and protection issues, the acceptance of the grounds of referral by the relevant person would be an acceptance of a lack of adequate care. As such, measures could be put in place to address the child's right to care and protection and in this case there is probably adequate protection for the child's rights.

In a referral for an offence, it would not be adequate protection of the child's rights if his/her parent accepted the grounds but the child was not able to understand. One would have thought that in these circumstances the child should have access to legal advice and the right to have the evidence heard. Subsection (5) grants this right but would not necessarily ensure that a child could exercise it.

Q13. In your opinion, do you feel that the proposals in section 17 for interim supervision requirements provide an appropriate additional option to a Children's Hearing when they are unable to dispose of a case?

Our understanding is that the interim supervision requirement would take the place of a warrant in some circumstances and allow the child to remain at home or with a relevant person until the Hearing was able to dispose of a case. We would support this measure on that basis.

Q14. In relation to section 18, it is intended that any agency which is taking, or is expected to take, action in accordance with a supervision requirement should have a duty to take such action. It is also intended that a Children's Hearing may impose specific duties on an agency. A formal enforcement process will apply to breach of duties, as is currently the case in relation to duties imposed on a local authority. The provisions in relation to duties set out in section 18, together with existing duties of a local authority, are intended to adequately and appropriately provide for duties to act in relation to a child subject to a supervision requirement. Do you think that they do so?

UNISON Scotland believes the provisions are clear in their intention to ensure that a required service is provided. However, this needs to be seen in the light of the resources being available to respond to unmet need. Current financial arrangements do not facilitate this. Subsection (8) makes it clear that no allowance will be made for the means available to the provider. This is unrealistic within the current funding regimes and could have a significant effect on the voluntary sector in particular.

It also runs the risk of forcing agencies to prioritise workloads on the basis of preventing enforcement rather than on the basis of their knowledge of competing priorities. This may well result in agencies diverting resources from the other care and protection cases or from the preventative multi-agency early intervention approach which the Bill purports to promote.

These provisions could also lead to the unintended result of reducing available services. Potential providers may be unwilling to involve themselves in some existing services for children because of the risk that they may have to provide something they do not have the means to provide.

We believe that the intention is good in terms of improving the effectiveness of the Children's Hearing System, which as was stated, has suffered from a lack of availability of all kinds of resources, but that the full implications of these provisions have not been properly considered. Unfortunately, unless additional resources are made available, these aspects of the Bill may well have the opposite effect to that intended.

Q15. In relation to section 20 on warrants, it is intended that section 66 will apply where there is an application to the sheriff under section 65. It is intended that section 69 will apply where the situational condition is accepted/established (and there is no current section 65 application). Section 45 and section 63 will continue to apply in their own particular circumstances. Further refinement to ensure this effect is intended. In your opinion or in the opinion of your organisation, will such an approach simplify warrant procedures?

We are unable to understand the implications of this question and are, therefore, unable to comment on it.

Part 2: Issues for consideration

Q16. The consultation document sets out a number of proposed changes to the Children (Scotland) Act 1995 arising from the Vulnerable Witnesses (Scotland) Act 2004. Are you content with these proposals?

Q17. For the small group of young people who continue to pose a risk to themselves or others, and who cannot or will not engage with services who are working to change their behaviour, we wish to explore further options to compel them to change their behaviour. To secure continued support and intervention for young people involved in offending we would like to hear your opinions on:

• How we can best ensure that children's services continue to support young people who offend to cease offending and make a successful transition into positive adulthood?

• How we could formalise systems to ensure that this happens?

• How we might respond to the concerns of our communities in the best way to deal with the problem of persistent offending by young people?

• What, if any, legislative requirements do you believe would be required to deliver this?

UNISON Scotland believes that the use of existing measures is often affected by the availability of resources, particularly in the case of 16-18 year olds. We would contend that it is possible to combine the criminal justice system and the children's hearing system through imaginative projects. There will always be situations where, for whatever reason, it is not possible to engage a young person and the criminal justice system will be the only option.

However, most of the inability to respond flexibly and intensively with this group of young people is due to restrictions on resources. Intensive projects are costly but tend to have reasonable success rates. They currently exist and the necessary funds should be made available for them before considering further legislation. UNISON believes is not the absence of legislation that is inhibiting progress in this area, it is the lack of funding.

Q18. The Scottish Executive is committed to promoting and supporting the rights of children and to reflecting the provisions of the UN Convention on the Rights of the Child in the development of policy and legislation. To ensure that we are effectively promoting and supporting the rights of children we would like your views on the following:

• The Bill as drafted is intended to improve children's rights in Scotland. Do you feel it will do so effectively?

• Should we also consider a general duty on agencies working to meet the needs of children to also promote and support the rights of children?

In many areas the Bill does improve children's rights to well-being and to access to services they may require. Many aspects of the Bill have a rights focus which should promote and support the rights of children if it is properly applied. This particularly includes the focus on the needs and well-being of children and the clear requirement to seek, record and take into account the child's views.

We believe the Bill should include the child's right to independent support and advocacy at each stage of the process of meeting a child's needs, and that additional resources should be committed to this, as we know that this can be key in ensuring the child's full participation.

However, we have concerns (as outlined above) about the possibility of current rights to a court hearing being removed which could undermine the ability to exercise the right to have a third party contest the situational grounds for referral on their behalf.

UNISON Scotland believes there should be a general duty on agencies to promote and support the rights of children.

Q20. We would be grateful for views on what further legislative provision for information sharing beyond that proposed in the Protection for Vulnerable Groups (Scotland) Bill may be necessary to deliver the Getting it right for every child agenda

Our comments above regarding information sharing also apply to this question. The issue of information sharing is constantly over-simplified and the implications for data protection and personal privacy and confidentiality have never been fully explored. The main inhibitor in sharing information is the apparent conflict in legislation or in the interpretation of that legislation. Professionals are very often unclear about what they can or should share and often have to juggle conflicting guidelines and ethical standards.

For those reasons, clear legal guidance with clear criteria for sharing information would benefit all those working with children. Within that, thresholds for sharing information would have to be specific and transparent and there would need to be definitive statements on the effect on other legislation (e.g. data protection, human rights etc). Such guidelines are also essential for the public to ensure they are aware of how and when personal information is shared and the limits of confidentiality in such situations.

Q21. Would amending the definition of a child ‘in need' in the Children (Scotland) Act 1995 be helpful to the aims of Getting it right for every child without causing unwanted consequences?

See response to Q1 above.

Q22. We would be grateful for informed comment on any or all of the matters discussed in the partial Regulatory Impact Assessment including views on any matters arising from the draft Bill which may (in your view) have cost implications

UNISON Scotland believes that the delivery of the principles of the Bill will require significant additional resources. The biggest single reason for not meeting children's needs at the time when it would be most effective is a lack of resources. Considerable investment in early intervention at the care stage is widely acknowledged to be key in reducing referrals on protection and offence grounds. To merely legislate and not address the evidenced resource gap will not deliver on the principles of the Bill.

 

For further information please contact:

Matt Smith, Scottish Secretary
UNISON Scotland
UNISON House
14, West Campbell Street,
Glasgow G2 6RX
Tel 0845 355 0845 Fax 0141 331 1203

Email matt.smith@unison.co.uk

 

 

 

 

 

 

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