SSS Learning March 2024 e-bulletin

Sam Preston 6 March 2024 5 min read

Welcome to the SSS Learning March 24 e-bulletin. All future Safeguarding E-bulletins will be published on the first Wednesday of every month, so you'll know when to expect your safeguarding news.

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In the news

  • New Intimate Abuse Image Laws
  • Compulsory reporting of child sexual abuse
  • Met child exploitation investigations rated inadequate
  • Sexual abuse cases increase as child protection plans fall
  • Doxing

New Intimate Abuse Image Laws

Under the reforms introduced under the Online Safety Act, enacted new intimate image abuse laws for England and Wales came into force this year from 31st January. Under the reforms prosecutions no longer have to prove intent to cause distress when non-consensual sharing of sexual images or films occurs.

The reforms significantly broaden the scope of offences, including a ‘base’ offence of sharing an intimate image without consent or reasonable belief in consent, where perpetrators could face a maximum of 6 months imprisonment.

The new laws also strengthen the offence of threatening to share an intimate image without consent, regardless of whether the image exists. Perpetrators of such threats could receive a maximum of two years imprisonment.

If an intimate image is shared with the intent to cause alarm, distress, or humiliation, perpetrators could face a maximum of two years imprisonment. In addition, sharing an intimate image without consent, or a reasonable belief of consent, to obtain sexual gratification could result in the perpetrator also being made subject to the sex offenders register.

The new legislation also provides more support and protection for victims by ensuring lifelong anonymity and eligibility for special measures during the trial process.

Laws are also to be updated to expand the nature of what is considered an intimate image, to include any images that show, or appear to show, sexual acts, nudity, or partial nudity.

This includes Deepfakes, that is intimate images made or altered with computer graphics to replace the likeness of one person with another. Now under an amendment to the Sexual Offences Act 2003 contents anyone sharing or threatening to share digitally altered intimate images without consent can be convicted.

Northern Ireland and Scotland have separate legislation for intimate image abuse.

Compulsory reporting of child sexual abuse

In response to a recommendation made by the Independent Inquiry into Child Sexual Abuse (IICSA), HM Government have announced plans to introduce a new mandatory duty to report child sexual abuse. The proposed legislative requirement will apply to anyone working with children in a ‘regulated activity’ capacity and will introduce penalties for non-compliance including being barred from working with children and, if it is deemed that someone has actively protected an abuser they may face a penalty of up to seven years imprisonment.

In addition, under the proposed plans law enforcement will also be given greater powers to stop registered sex offenders from changing their name if they think they still pose a risk.

Announcing the plans, Secretary of State for the Home Department James Cleverley, stated:

‘Having listened to the voices of victims and survivors and reviewed the work of the IICSA, we are working at pace to get a mandatory reporting duty for child sexual abuse onto the statute book. We’re also going further, equipping the police with more powers to prevent those who have committed abhorrent sexual crimes in the past from evading the police by changing their name.’

However, children's services leaders and education unions have raised concerns about the proposals.

In response to the announcement, Paul Whiteman, NAHT General Secretary warned that schools rely on a wide range of other services when reporting concerns stating:

‘We are concerned about the current capacity of services like children’s social care and the police to provide children with the help they need should mandatory reporting lead to an increase in referrals being made. It’s vital the government provides these services with sufficient funding to ensure they can cope with demand and are not forced to raise thresholds for intervention.’

President of the Association of Directors of Children's Services, John Pearce stated:

‘A rushed, poorly scoped and under-resourced policy could adversely affect the very children it seeks to protect if services become overwhelmed and support is not available for children when they need.’

Met child exploitation investigations rated inadequate

Following an inspection led by HM Inspectorate of Constabulary and Fire and Rescue Services (HMICFRS), more than 50% of London police force investigations into child exploitation have been rated as inadequate. Of the 244 investigations, only 43 were rated ‘good’, leading to the report stating that:

‘The force can’t fully understand the nature and scale of child exploitation in London’.

The report also found that:

‘the force often uses officers and staff to investigate child exploitation who don’t have the necessary skills or knowledge to do this effectively’ with ‘missed opportunities to identify suspects and disrupt their activity, and to carry out evidence-led prosecutions’.

It also stated that:

‘many officers and staff in the force fail to identify exploitation or understand the links between missing children and exploitation’ and that priority was given to ‘the likelihood of a successful prosecution rather than safeguarding children and promoting their welfare’.

Whilst recognising the ‘good work to protect children’ of the Metropolitan Police Service’s online child sexual abuse and exploitation teams, the report found concerning evidence. This included delays in action being taken, lines of enquiry not being followed, poor supervision of investigations, victim-blaming language and unlinked IT systems.

The inspection found that many Met officers and staff were committed to providing a better service, but they were frustrated by having too much work to complete. The report has recommended key actions to address the failings.

In response to the findings, Commander Kevin Southworth, lead for Public Protection at the Met, stated:

‘I’m deeply sorry to the children and families we have let down and want to reassure our communities that we are already taking significant steps to address these recommendations. We are putting more police resource into this area and retraining officers to have a better understanding of the complexities of child exploitation so we can continue our work to win back the trust of Londoners.’

Sexual abuse cases increase as child protection plans fall

According to a statement made by children’s charity Barnardos, one in ten children will experience child sexual abuse, yet thousands of those children are then being left alone to cope without proper support.

Worryingly, research published by the Centre of Expertise on child sexual abuse (CSA) has shown that the number of plans put in place by Local Authorities to protect children from sexual abuse has dropped, despite an increase in the number of recorded cases.

According to the CSA report, 105,286 child sexual abuse offences were recorded in 2022/23, a rise of two per cent on the previous year and the number of defendants in child sexual abuse offences has increased by six per cent to 8,024 people in the 12 months to December 2022.

However, the number of child protection plans put in place due to sexual abuse has dropped to the lowest level in 14 years. Analysis of statistics for 2022/23 has revealed a nine per cent drop in sexual abuse focused protection plans compared to the previous year.

CSA analysis of official figures found that only 2,290 children were being supported by specific plans to protect them from sexual abuse.

The CSA report also raises a concern that, despite the increase in sexual abuse cases being recorded by police, there has been a one per cent fall in Local Authorities recording concerns about abuse. Although the CSA ‘conservatively estimates’ that at least 1,223 children ‘in even the smallest’ Local Authority area will experience sexual abuse each year, four authorities in England identified no children at risk of child sexual abuse across the entire year.

This apparent discrepancy has revealed that, whilst identification and reporting are essential to enable intervention and support for children who may have experienced sexual abuse the protection, more detailed official data from Local Authorities and other agencies is needed to examine the support levels on offer after concerns have been raised.


‘Doxing’ is the term used to describe the online abuse of publishing private information about a person on the internet without their consent with the intent to cause harm and distress.

As part of safeguarding practice, it is essential that staff and pupils are aware of this term, measures to protect against it happening and what to do if their personal information is shared without consent.

All safeguarding policies and procedures for online safety should include details on ‘doxing’, and the measures your organisation is taking to safeguard staff and children.

Useful guidance on doxing has been produced by the SWGfl.

SSS Learning news:

Our latest course designed to support those undertaking the role of Designated Teacher for Looked-After Children is now live.

Our new Emergency Strategies for Schools and Colleges course to assist with your emergency planning procedures is in the final stages of production and is due for release shortly.

We have also almost completed our redesign of our certificate management and admin home screen to make management of your training even easier. Look out in the next few weeks for the update. We'll let you know when it's arrived!

Please do let us know what you think of the e-Bulletin:

Sam Preston

SSS Learning Safeguarding Director

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