Browne Jacobson - Education Law Conference 2016 - Workshop stream 2, Operational update

Workshop W1
Managing parents
The education law conference 2016
#BJEDC16

What we will cover
• Definitions of parent and parental
responsibility
• Implications
• Abusive parents
• Complaints

Who is a parent?
• DfE departmental guidance January 2016 –
“Understanding and dealing with issues relating to
parental responsibility”
• Section 576 Education Act 1996

Who is a parent?
• Section 576 – A parent for education purposes is:
- a natural parent or parents, whether married or not;
- any other person who has PR for the child (if not a
natural parent);
- any person who has care of the child (and is not a
natural parent).
• Care of child – lives with child and looks after them

What is parental responsibility?
• PR defined in section 3(1) Children Act 1989 – all
rights, duties, powers, responsibilities and
authority that a parent has in relation to child
• Applies to natural parents
• Other persons can obtain PR through a child
arrangements order, being appointed a guardian,
being named in an EPO, through adoption or via an
agreement with natural parent or a court or care
order

What is parental responsibility?
• Civil partners have similar powers to married couples
• Married parents will have PR for any child born after
marriage
• Father can obtain PR by registering the birth with
mother; subsequently marrying the mother or getting a
court order or PR agreement
• More than one person can hold PR for a child
• Those with PR can act independently of the other and
provide consent

Parental responsibility - disputes
• Court orders will determine disputes over the exercise
of PR and can limit exercise of PR
- Prohibited Steps Order
- Specific Issue Order
- Child Arrangements Order
• School need copies of orders in respect of child to
ensure it acts within relevant framework

Implications for schools
• Education legislation places requirements on
schools around parents not those with PR
• Unless there is a court order with express
contrary provisions – treat all parents equally
• Applies irrespective of whether Mother and
Father are separated – right to be involved in
child’s education

• Parents have right to:
- receive information – pupil reports
- participate in statutory activities – parent governor
elections
- to give consent to school activities
- be involved in meetings regarding the child at
parents evening, exclusions, SEN etc
- express preference for school to be attended
- use complaints policy.

• Parents also have responsibilities
• Ensure regular attendance at school (or face
criminal sanctions)
• Ensure attendance in the right uniform
• Parents cannot use their position to undermine
relationship with other natural parents i.e.
information sharing

Information sharing
• Parents have right to see “educational record”
under Pupil Information Regulations 2005
(maintained schools)
• Data Protection Act 1998 will apply for
information requests in academies or those
requests made by the pupil
• Note child is data subject and has rights under
the Data Protection Act 1998

Consent
• Usual practice to seek consent from resident parent
unless non-resident parent wants to be involved
• Where disagreement between parents, schools
should assume no consent but not get involved in
dispute
• Schools can act in medical emergencies – do what is
necessary to safeguard the child’s welfare. May be
necessary to take action or seek consent from one
parent/person without PR

Other issues
• Administration – get full details from all parents
including legal name and any “known as” names
• Change of surname – require evidence of
consent
• Parent elections must be open to all parents

Abusive parents
• Advice on school security: Access to, and
barring of individuals from, school premises
(DfE, December 2012)

Abusive parents
• Section 547 Education Act 1996 makes it a
criminal offence to cause a nuisance or
disturbance on school premises when the
person has no lawful reason for being there
• Final step in dealing with abusive parents

Abusive parents
• Schools are private property
• Parents have implied licence to come onto
school property at set times for certain
purposes – dropping off, picking up, meetings
• Schools can define context of licence
• Where there is poor behaviour exhibited by
parents, licence can be withdrawn

Abusive parents
• Case-law: (A v Wandsworth LBC) stated:
- Parents should be warned re: behaviour
- Barring/Banning should be provisional in first
instance and parent given right to make
representations
- Full ban may follow and be imposed for a
reasonable timescale and subject to regular
reviews by school

Context of letter
• Set out specifics of offence
• Explain school position on working with parents
but having duty of care to staff and children
• Explain proposed length of ban and right to
make representations
• Provide details of who to contact

Communications
• If parents become abusive, can limit channels
of communication to school
• Extreme cases – protection from harassment
and injunctions (Lawrence Sheriff School, Rugby
2015)
• Involve other agencies – Police etc

Increasing use of social media
• Consequences not considered
• One view taken as truth
• Escalation into abuse/intimidation
• Harm caused – quick and widespread
• Safeguarding issues

Options for school
• Social media policy/changes to Code of Conduct
for parents
• Query – can you really regulate parental
behaviour? – Is damage done once posted?

Options for school
• Speak to parents to obtain removal
• Report abuse to social media operators
• Legal action –
- Harrassment
- Malicious Communications Act
- Defamation
- Injunctions
- ASBO

Complaints
• All state funded schools must have a complaints
procedure
• Maintained – section 29 Education Act 2002
• Academies – Independent School Standards
Regulations 2014.

Complaints – basic requirements
• Must apply to parents as a minimum in academies and
all persons for maintained schools
• Set out clear timescales
• Informal and formal consideration
• Include a hearing before governors – one of whom must
be independent of the management and running of the
school (academy)
• Allow parent to be accompanied
• Allow panel to make and share findings with parent and
school

Talk to us…
Please note
The information contained in these notes is based on the position at
February 2016. It does, of course, only represent a summary of the
subject matter covered and is not intended to be a substitute for
detailed advice. If you would like to discuss any of the matters
covered in further detail, our team would be happy to do so.
© Browne Jacobson LLP 2016. Browne Jacobson LLP is a limited
liability partnership.

Victoria Hatton | +44 (0)1392 45 8744
victoria.hatton@brownejacobson.com
Richard Freeth | +44 (0) 121 237 3961
richard.freeth@brownejacobson.com
Hayley O’Sullivan | +44 (0)121 237 3994
hayley.o’sullivan@brownejacobson.com

Workshop W2
Social media and your staff
#BJEDC16

This session
Risk areas and concerns
Recent examples and common themes
Breach of trust offences
Policies to manage those risk areas

What are the risks?
Blurred boundaries
Inappropriate relationships
Reputational damage for your school

What are our concerns?
Mobile phone contact
Text contact
Social media contact
Social media exposure

Does it happen much?
Example from the last two years or so
• Jeremy Forrest One female student 15
• Salford Stallion Three female students 14+
• Phillip Barnwell One female student 15/16
• Emily Fox One female student 15

Example from the last two years or so (cont)
• Hayley Southwell One female student 15
• Kelly Burgess One male student 16/17
• Luke Atkinson One female student 17

• At least 959 allegations made between 2008 and 2013
• 254 led to criminal charges
• Numerous reported convictions in last three months

Breach of trust offences
S.16-21 Sexual Offences Act 2003
Any student under 18 at your school
Four different offences, all very
serious

Breach of trust – quick quiz
Four main offences based on relationships with
students. For the offence to apply:
• Do you need to have direct contact with the student?
• Do they need to be in your class?
• Is it enough simply for them to be a student at your
school?
• Does it have to involve a teacher or could it be wider
staff?

When does the offence apply?
The offence applies if:
• “A” looks after persons under 18 who are receiving
education at an educational institution and “B” is
receiving, and “A” is not receiving, education at that
institution
In other words:
• You are “A” and “B” is any student aged under 18 at
your school

What are the four offences
• Sexual touching of B by A (s.16)
• Causing or inciting B to engage is a sexual activity
(s.17)
• Engaging in sexual activity in front B (s.18)
• For the gratification of A, causing B to watch a sex act
(s.19)

What is the penalty?
• Prison
• Sex offenders register
• NCTL sanction
• Barred by the DBS from working with children

Underlying themes
In each of the cases discussed earlier, one or more of
the following were recurring themes:
• Over familiar teacher/student relationship
• Social networking contact
• Mobile phone and text contact
• School culture

What are the risks with social media and
mobile phone contact and how can we
mitigate them?

What are the risk areas?
• Social networking contact
• Mobile and text contact
• School:
• Over familiar teacher/ student relationships
• Whistle blowing polices
• Whistle blowing in practice
• Staff awareness and confidence

Social networking
• Staff profile pictures
• Staff posts
• Teacher student contact
• Open privacy settings
• Friending
• Photo sharing

What is your school’s approach?
• Do you have a policy that covers friending students?
– What does it say?
• Do you talk to you staff about being sensible with:
– Privacy setting?
– Profile picture?
– Posts?
Can you influence your staff in this respect?

Mobile and text contact
What is your policy for mobile phone contact?
• Sharing personal mobile phone numbers?
‐ Teachers sharing with students and vice versa
• Is it ever appropriate to exchange numbers?
• Is it appropriate to retain numbers in personal phones?

Mobile and text contact
• Is it appropriate to text students?
• Is it appropriate to text students from personal
mobiles?
• Photo sharing?
• Do you have school/pool mobiles?
• Is your policy/approach fit for purpose?
‐ What should it say?

School culture
• How does your school approach these risks?
• Can they be nipped in the bud?
• Does it always have to lead to criminal investigations or
can it be stopped sooner?
Strong culture required

What is your school’s culture?
Whistle blowing policy and practice
• Do you have a robust policy in place?
• How have you disseminated it and trained your staff?
• Do your staff feel comfortable enough to do it?
• Will they be believed and supported?

What is your policy on social media use?

What policies and what should they say?
• A policy to manage digital contact with students to
cover:
‐ social media, mobile phone and text
‐ email and instant messaging
• What do you want yours to say?
• Clarity and simplicity are key
• If you hit 100 words you have probably overdone it…

Policy wording example
“Staff must not have any contact with current students
or former students under 18 years of age online or
through any form of social media. Communication
with students should only be conducted through our
usual channels and should be related to school matters
only. Breach of this policy may result in disciplinary
action up to and including dismissal.”

2. Personal reputational damage

Let’s talk about your staff…
• Do they have an online presence?
• Do they understand the privacy
settings?
• Have they ever said something
online you/they wish they hadn’t?

What are the risks?
1. Student contact online and
allegations of inappropriate
relationship with student(s)
2. Personal reputational damage

Social networking
‐ What do they say about you?

Social networking
• Staff posts
‐ Do you think students search online for you and your
staff?
‐ What would they find if they did?

Social networking
• Staff posts
staff?
• Is there anything wrong with sorts of photo?

Social networking
• Staff posts
staff?
• Is there anything wrong with sorts of photo?
• Is that how you/your staff want students, parents and
colleagues to see them??

Social networking
• Staff posts

Social networking
• Staff posts
• Posting and tagging by friends

Social networking
• Staff posts
• Posting and tagging by friends
• Staff online comments

What can you do?
• Make no contact with students via social media,
text or phone
• Work with staff to ensure they actively manage
their profiles and privacy settings
• Get them to talk to friends about posting and
tagging
• Suggest they review their profile pictures and
conversations…

Dai Durbridge | +44 (0)161 300 8037
dai.durbridge@brownejacobson.com
Hayley O’Sullivan | +44 (0)121 237 3994
hayley.o’sullivan@brownejacobson.com

Workshop W3
Effectively managing local authority
relationships
#BJEDC16

The session’s focus
• In year admissions
• Fair access protocol
• Looked after children
• SEN admissions
• SEN funding

Key documents
• School Admissions Code 2014
• School Admissions Appeals Code 2012
• School Adjudicator decisions and annual report
• Case law
Rumours from DfE – consultation on new admissions
code is likely… watch this space

• No obligation to admit other than at the start of a term
unless parent has a good reason for wanting child to start
during a term
• Good reason must include illness or other issue outside
the parent’s control or where they lived outside the
school’s area and it was not reasonable to access the
school from the old address
• With good reason, may need to admit during term but it is
a matter for the admission authority to decide upon
taking account all the circumstances of the case
(paragraph 17 Keeping Pupil Registers)
When do I have to admit?

• Paragraph 2.8 “all maintained schools…that have
enough places available MUST offer a place to every
child who has applied for one…”
• Paragraph 3.12 “where a governing body does not wish
to admit a child with challenging behaviour outside the
normal admissions round, even though places are
available, it MUST refer the case to the LA for action
under the Fair Access Protocol. This will normally only
be appropriate where a school has a particularly high
proportion of children with challenging behaviour or
previously excluded children
Do I have to admit if under PAN?

• Use of Paragraph 3.12 will depend on local
circumstances and MUST be described in the LA’s Fair
Access Protocol
• Cannot refuse admission who is thought to be
potentially disruptive or who has challenging behaviour
just because they should be subject to statutory
assessment
Do I have to admit if under PAN?

• Drawn up by the LA and agreed with the majority of
schools in their area
• To ensure that outside the normal admissions round
unplaced children are offered a place at a suitable
school as soon as possible AND no one school takes a
disproportionate number of pupils who have been
excluded or who have challenging behaviour
• Protocol must include how the LA will provide for
children with needs that cannot currently be met in
mainstream education
Fair Access Protocol

• FAP takes place outside co-ordination and where the
parent of an eligible child has not secured a school
place under the usual in-year admission procedures
• All schools must participate in the FAP
• No duty to comply with parental preference under FAP
procedures
• FAP cannot require a school to operate a “1 in, 1 out”
policy if they permanently exclude
• FAP must set out arrangements for children who are
not ready for mainstream education

• Eligible children is for LA to determine but must
include:
- Children from criminal justice system or PRUs who
need to be reintegrated into mainstream education
- Children who have been out of education for two
months or more
- Children of Gypsy, Roma, Traveller, refugee or
asylum seeking families
- Children who are homeless

• Children with unsupportive family backgrounds
from whom a place has not been sought
• Children who are carers
• Children with SEN, disabilities or medical needs
(but without statements)

• Participation v blindly following
• It is possible to refuse to admit following a FAP referral
• Outcome will depend on nature of school – LA can
direct maintained schools to admit where all other
schools within a reasonable distance have refused
admission. Subject to consultation and school may refer
matter to Schools Adjudicator for determination
• LA cannot direct academies. May refer matter to DfE
for a direction to be made under Funding Agreement
FAP – challenging decisions

Challenge LA position on any relevant ground:
• FAP does not meet Code’s requirements
• FAP not subject to consultation/agreement
• Procedure followed was wrong/contrary to Code/unfair
• Unreasonable decision on suitability
• Discrimination towards school – too many children
through FAP
FAP – challenging decisions

In Year Fair Access
DfE guidance “Fair Access Protocols: Principles – Process”
November 2012
• Local solution preferable
• Schools should be treated fairly/equitably
• Application to DfE within 15 days
DfE to consider:
• whether protocol applied appropriately
• whether Academy is suitable - numbers taken already
under FAP compared to other schools

Looked after children
• Not covered by Fair Access Protocol
• Clear duties on LA to find suitable placement at same
time as care placement
• DfE guidance “Promoting the educational achievement
of looked after children” should be considered
• Emphasis on working together and grounds for refusal
should be based on serious prejudice to the school
• LA has right to refer matter to DfE but cannot direct
admission to academy on its own
• Request to direct admission

• DfE “Request to direct admission of a looked after
child”
• Consultation with academy
• Seven days response time
• Ground for refusal is serious prejudice to efficient
education
• On referral to DfE, academy notified and given seven
days to respond
• DfE decision based on LA acting appropriately and
whether serious/significant prejudice caused

Admission of looked after children
• LA must have regard to “Promoting achievements”
guidance (July 2014)
• Sets out principles which LA must follow
• Change of placement does not always mean change of
education setting
• Social care must minimise disruption especially at Key
Stage 4
• Where change is required, care and education
placement should be arranged simultaneously with VSH

• LA have 20 school days to find a placement
• Placement must be ‘best suited to child’s needs’
• No type of placement can be ruled out
• Placement should be full time
• Schools should be outstanding or good
• Take account of child’s wishes and a visit should
be arranged

• Failure to follow statutory guidance is potential
ground for challenge
• Evidence of LA not acting appropriately
• Consider process followed and decision over
suitability

Current position
• Children & Families Act 2014 – Royal Assent in Spring
2014, Implementation from September 2014
• SEND Code of Practice (April 2014) – published and
replaced by updated January 2015 version – in force
from 1 April 2015 (292 pages)
• Code of Practice is statutory guidance to which a
number of organisations including state funded schools
must ‘have regard’
• DfE has produced a range of other guidance on the new
SEN framework

Old framework
• Education Act 1996
• SEN Code of Practice (2001)
• Inclusive Schooling guidance (2001)
• Continues to apply to SEN statements by virtue
of transitional arrangements under 2014 Act
• Scope for confusion especially as 2014 Act
treats academies differently

Pre-September 2014
• Education Act 1996 – Section 9 and Schedule 27
• Same process to be followed for maintained
schools and independent schools (including
academies)
• Consultation with LA – 15 days
• Different tests to apply

Admissions – pre-September 2014
• Schedule 27 applied
• Maintained schools – only refuse to be named in
statement where they could prove admission would be
incompatible with the provision of efficient education
and no reasonable steps available to avoid
incompatibility
• Required evidence of more than just adverse impact
• Unsuitability not an issue for schools
• Weighted in favour of parental preference

Admissions – pre-September 2014
• Independent schools – LAs only required to have regard
to parental representations and take account of
problems caused to the provision of efficient
instruction and inefficient use of resources (Section 9)
• Much reduced obligation – consider parental wishes not
give effect to them
• Academies still needed to base case on incompatibility
due to funding agreement
• High profile issues – Mossbourne Academy.

Key points
• Paragraph 8.60 – parents may express a preference for
a maintained school…or make representations for a
placement in any other school
• Paragraph 8.60 – LAs must comply with parental
preference but only consider parental representations
• Academies treated as independent school – not
maintained.

Key points
• Paragraph 8.63 – LA must consult the preferred school
and must provide a copy of the proposed or amended
SEN statement, the amendment notice and the
appendices
• Make sure you have access to all required information.
SEN statement is only an LA summary of the evidence –
may be useful points to use in arguments against
placement.

Key points
• Paragraph 8.80 – LA must consult the governing body of
the school even if school is independent (8.84)
• Paragraph 8.80 – must respond within 15 working days
unless request made within school holiday of more than
two weeks
• Paragraph 8.80 – LA must carefully consider
representations from governing bodies.

Key points
• Paragraph 8.85 – LA should consider admission where
school is at or over PAN/operational capacity as
admitting over PAN might be incompatible with the
provision of efficient education or use of resources
• Paragraph 8.85 – must take account of issues from
physical space restrictions and comply with infant class
size legislation
• Paragraph 8.85 – must be carefully considered where LA
is not the admission authority
• Evidence of consideration?

Key points - incompatibility
• Inclusive Schooling guidance
• Efficient education means providing for each child a
suitable and appropriate education in terms of the child’s
age, ability, aptitude and SEN
• Other children means the children with whom the child
will directly come into contact with on a day to day basis
• Schools must show that there are no reasonable
adjustments to prevent the incompatibility
• Reasonable Adjustments – linked to disability
discrimination – use Equality Act guidance.

• Reasonable steps must be taken but without
compromising the efficient education of other children
• Incompatibility where behaviour systematically,
persistently and significantly threatens the safety of
others or impedes the learning of others
• Incompatible where teacher has to spend a
disproportionate amount of time with pupil compared
to rest of class even where TA is available to support.

Incompatibility – key question is whether the effect of the
child attending the school, and any adverse impact on the
efficient education of other children with whom they
would be educated, would be so great as to be
incompatible with the provision of efficient education
(R (Hampshire CC) v R (2009)

How to respond
• Review statement and evidence in appendices and
concentrate on the potential impact on current pupils
at the school
• Not about school being unsuitable for child but the
child being unsuitable for the school
• Use standard format.

How to respond
Set out:
• breaches of SEN Code or legislation
• Legal framework – S9 not Schedule 27 and impact
• Academy details – size, no on roll, resources available –
building, classroom usage, staffing and expertise, class/year
groups and sizes, approach to SEN and details of SEN
resource
• Comparison with other local schools
• Review of SEN statement and evidence with focus on
incompatibility
• If appropriate, set out estimated costs of provision

Post-September 2014 – EHC Plans
• On receipt of draft EHC plan, a parent may request
following types of school to be named:
- maintained nursery school
- maintained school or academy/free school
- non-maintained special school
- FE or 6th form college
- DfE approved independent or specialist school (s41)
• May make representations for other schools but LA has
limited duty to consider under s9 Educational Act 1996

Parental preference
• LA must comply with request unless:
- unsuitable for age, ability, aptitude or SEN of
child/young person; or
- attendance would be incompatible with the efficient
education of others with whom the child would be
educated with or the efficient use of resources
• Efficient education is provision of suitable and
appropriate education to their age and needs.

LA role
• Must send school/college copy of draft plan and allow
15 days as consultation period
• Supporting evidence to be sent as well?
• Must consider comments “very carefully” before
making a decision to name the school
• Where provision may be secured by direct payment
delivered on school premises must seek agreement of
school/college/nursery.

Reasonable steps
• Taken from Equality Act 2010 and defined in 9.91 of
SEND Code as number of factors to consider
• Reasonable steps may not always be available to the LA
or school – behaviour which systemically, persistently or
significantly threatens the safety and/or impedes the
learning of others
• Change from SEN Code 2001 – PAN/class size reference
omitted
• Not a simple decision to take – depends on
circumstances and requires consultation with parents
and young person.

Children & Families Act 2014
• Section 39 – consultation and decision making as a
result of parental preference. Will require consultation
– 15 days
• Guidance at paragraphs 9.78 – 9.87 of SEND Code 2015
• Section 40 – consultation where no parental preference
• Guidance at paragraphs 9.88 – 9.90
• Consultation responses must be carefully considered.

• Reasonable steps still required to be considered to
prevent incompatibility (9.91 – 9.92) but same
approach as in Education Act 1996
• Incompatibility – same test applies – includes behaviour
which systematically, persistently or significantly
threatens safety of others or impeding learning of
others (9.93)
• Decision must be based on circumstances of case (9.94)

• Need detailed response to object to placement
• Same format as before
- legal issues
- school information
- pupil issues arising from EHC plan and appendices
- focus on incompatibility.

What if the academy is named
• Admission – remember impact of Section 433 Education
Act 1996. Duty to admit but not until start of academic
term
• Complain to Secretary of State due to LA’s
unreasonable exercise of functions
• Legal action – judicial review decision
• Do nothing and await challenge.

High needs funding
• Cover SEN and AP
• New system brought in 2013
• Currently set out in DfE guidance “Schools receive
funding 2015 to 2016 – operational guide”
• Paragraphs 77 onwards deal with high needs funding

Principles
• Element 1 – AWPU/Pupil Funding
• Element 2 – SEND Notional Budget
• Element 3 – Top Up Funding
Element 1 and 2 = place funding

Element 1 – Pupil Funding
• Every pupil in school attracts an amount of
money. Not a standard sum across England
• Core budget for each school advised to make
general provision for all pupils in the school
including those with SEND.

Element 2 – SEND Notional Budget
• An additional amount within budget to meet children’s
SEND
• Based on LA formula
• Must be used to support SEND pupils up to threshold of
£6,000
• Can apply to LA for additional funding if threshold
exceeded
• Notional – no rules on how to use the money however
local offer should set out expectations.

Element 3 – top up funding
• If exceed threshold of £6,000 can approach LA for
additional funding to meet the cost of provision
• Top up funding is “that which is required over and
above place funding to enable a pupil with high needs
to participate in education…” (paragraph 83)
• Issue of evidence.

Link to SEND Code
• Schools have best endeavours duty to meet special
educational needs of pupils (s68 CAFA 2014)
• Paragraph 6.99 SEND Code makes it clear that do not
have to make all provision from within own resources –
should use top up
• LA has duty under s28/29 to co-operate with GB to
assist in exercise of functions

Top up funding
• Paragraph 90 of operational guide makes it clear
‐ where high needs pupil needs support which costs
over £6,000 threshold, LA should provide top-up
funding
‐ top up funding must be agreed with schools and
reflect the needs of pupil, the cost of meeting
those needs.

Top Up Funding
• Top Up Funding should also be paid where school has
disproportionate number of high needs pupils (93)
• Top Up Funding should ‘mainly reflect’ support costs
for individual student but also cost of any specialist
facilities on offer (residential accommodation)
(paragraph 125)

Top Up Funding
• No set way of dealing with top up funding – varies
between LAs
• Must relate to period of time the pupil is at school
(129)
• Must be subject to written agreement including duty to
make top up payments in a timely and regular fashion –
at least monthly (130)
• Breach of conditions of DSG if do not do so

Top Up Funding – what if it goes wrong
• Complain to LA
• Complain to DfE/EFA under Education Act 1996
• Exclude??

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