Line of Duty - County Lines

3 September 2019

Teachers are placed on the front line every day. How do you support your staff in their duties to identify and support vulnerable students who may be targeted as part of county lines operations?

The UK Government definition:

"County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs into one or more importing areas within the UK, using dedicated mobile phone lines or other form of “deal line”. They are likely to exploit children and vulnerable adults to move and store the drugs and money and they will often use coercion, intimidation, violence (including sexual violence) and weapons."[1]

If you look at your current student body, how many are certainly involved? How many more might be involved? Although the most commonly targeted age range is 15-17 years, 12 year old children and younger have reportedly been victims of county lines exploitation.

What are your duties?

  1. To safeguard the children and young people in the school’s care.

    This duty stems from the Children Act 1989 and you will have systems, policies and processes in place, which are reviewed annually, in line with best practice. Staff training will also be routine, but should focus on changes made to ensure that policies are implemented in practice.

    In terms of other resources or lines of support that staff can refer to for guidance or assistance:

    - ensure that you are aware of the local arrangements in your area and how any updates are made available;

    - the guidance from the Safer Recruitment Consortium was updated in May 2019[2] and has some practical guidance regarding implementation of a number of safeguarding measures; and

    - include signposting information in your policies to specialist practitioners that can advise on issues such as mental ill-health.

  2. To work with the new local safeguarding arrangements (LSAs).

    Local Safeguarding Children’s Boards (LSCBs) are being replaced with LSAs. The deadline for each Local Authority to publish its intended arrangements was June 2019, with an implementation deadline of September 2019. Statutory responsibility for safeguarding is now shared between the three safeguarding partners: Local Authority, Police and Clinical Commissioning Group (CCG).

  3. To co-operate with the police.

    There are now bespoke teams within police forces dedicated to investigating and tackling the criminal activity behind county lines gangs. Schools need to be pro-active as well as reactive to what is sadly, a very real problem that requires the involvement of the police, National Crime Agency and a wide range of Government departments.

    The DfE guidance on county lines states:

    "Any practitioner working with a vulnerable person who they think may be at risk of county lines exploitation should follow their local safeguarding guidance and share this information with local authority social services. If you believe a person is in immediate risk of harm, you should contact the police."

    Concerns should be reported in the usual way and information should be shared, as appropriate. The provision of information to the police is unlikely to breach your duties under the GDPR and Data Protection Act 2018. However, always liaise with the person in your organisation with responsibility for data protection; if personal data is involved, you may need to balance the different rights of data subjects and also consider (and document) the lawful basis on which you will rely in the circumstances. Having a paper trail to evidence why information is provided in full, in part, in redacted form or not at all will be important, particularly if you receive subsequent queries and subject access requests from either the students involved or their parents.

  4. To conduct internal investigations once police enquiries have concluded.

    Outside of London, arrests relating to class A drugs offences are reported to have increased by 45%, including possession with intent to supply. This duty to deal with the issues on the ground can be complicated, as schools have a number of considerations to balance:

    - Pastoral policies need to be implemented. With internal investigations, the standard of proof in relation to dealing with allegations of misconduct is not the criminal standard of proof “beyond reasonable doubt”, but the civil standard of proof “on the balance of probabilities”.

    - The School also has a range of sanctions, but also lines of support available for pupils that should more frequently be considered victims and not just as perpetrators.

    - Fair implementation of the School’s Behaviour and sanctions Policy with your duties to keep children safe. Poor behaviour can be used as a tactic if exclusion is the student’s main aim. The School will have less contact with the individual and their family during a period of exclusion, leaving them even more vulnerable to exploitation.

    - The action that you take must be lawful and in accordance with the rules of natural justice, without having an impact on the rest of the student body. It should also support your teaching staff in their day to day roles of teaching and managing classroom behaviour, without undermining their authority to issue sanctions. This is no mean feat.

  5. To keep Governors updated.

    Governors have ultimate responsibility for safeguarding. The Chair should be kept regularly updated and you should consider how much information needs to be provided to the rest of the board. Other Governors may need to remain independent and impartial enough to be able to sit on a future disciplinary panel or parental complaint panel, if required.

  6. Sharing information with “those who need to know”.

    Sometimes a Head will take the view that safeguarding information should not be shared beyond the remit of the Senior Leadership Team. In complying with your safeguarding duties and your duties owed to the pupils involved, their identities are not usually confirmed to the wider teaching staff.

    If a member of staff becomes increasingly concerned about certain pupils that they teach, it might be appropriate to consider additional measures, such as involvement of the child or young person’s tutor for additional monitoring and support. Each case must be considered in the specific circumstances and a plan tailored to support the child or young person concerned.

  7. To respond to any social media or press issues.

    In managing negative or unwanted publicity, schools should consider how best to respond, if a response is required at all. What and how much you say may be limited or determined by the police, if there is an on-going investigation. If other agencies are involved, it is advisable to seek their agreement before publishing a response. The Chair should also be kept informed of any media strategy adopted by the School.

  8. To report to regulatory bodies.

    Schools may have a duty to report allegations or incidents of this nature to the DfE, Charity Commission (if your school is a registered charity) and/or the ICO (if matters concern data protection breaches).

    The Charity Commission has published a table of examples to assist in determining whether a Serious Incident Report should be made:

    “Routine inspections by a sector regulator e.g. Ofsted, CQC… do not need to be reported to the Commission unless there are adverse findings that place the future of the charity in doubt, relate to other categories of serious incidents or are likely to attract negative media attention.”[3]

    Your response will need to be tailored to the specific circumstances and it is advisable to record your decisions and reasoning as the matter progresses.

With county lines cases, there is a cycle of children being targeted, tested and then trapped. More action is needed to identify those that are targeted at an early stage. It is hoped that this general guidance will be of assistance if you find yourself dealing with a similar situation. We should all aim to develop a shared language across services to ensure the efficient implementation of new local safeguarding arrangements. Schools continue to play a vital role and going forwards, multi-agency training will be invaluable to ensure that each relevant partner understands the role of other partners and relevant agencies.

For further information or to discuss a specific matter, please contact Vicky Wilson or your usual Wilsons contact.

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