I am delighted to have been asked to make this presentation on behalf of Early Childhood Ireland.
Early Childhood Ireland welcomes the heads of the Children First Bill 2012 and values this opportunity to make a submission at this early stage. As a membership-based organisation with 3,200 affiliates providing care and education across pre-schools, playgroups and in full day care and after-school settings to nearly 70,000 children daily, we wish to help shape the legislation and to ensure that it is robust, fit-for-purpose and provides children and adults with a responsive and dependable system that will create a climate of confidence.
The organisation came about as a result of the recent merger of the Irish Preschool Play Association, IPPA, and the National Children's Nurseries Association, NCNA. It has long advocated for a greater visibility of children within the Constitution and for access to training and supports for those adults who work with children and families. The legacy of failure in protecting children highlights issues of capability and credibility. The proposed Children First Bill offers an opportunity to regain confidence in the system and to ensure a child's right to protection.
Our written submission contains many factors that have been outlined in full and today I will offer a quick snapshot or profile of the sector. While acknowledging the heads of the Bill we must take into consideration the context in which early childhood care and education services operate. The current context is challenging and demanding. The formal early childhood care and education sector comprises 4,600 services that are notified to the HSE, of whom 70% are affiliated to my organisation. These services provide private and community services, full day care and sessional services, such as Montessori and playgroups, from birth up to 12 years.
At present our members work within the system to process Garda vetting for each of their employees or volunteers, as appropriate. They notify the HSE of their operations and are subject to inspections by the HSE, NERA and Pobal. Whether operating in a private or community setting, there are significant policy and legislative requirements placed on these small services and small businesses. Senior managers undertake an additional 12 hours per week at least, and outside of their daily contact with children, to do their administrative work. It revolves around funding schemes, human resources and finance and they have no additional remuneration for that work. Our members have emphasised the frustration that service providers experience in trying to access Children First training for staff. In total, 52% of the respondents to our survey last year indicated that they were unable to access Children First training in the previous year. Practitioners and services work to maintain and centralise the best interests of the child but they require training and support.
I would like to locate the child. Fundamental to our work in Early Childhood Ireland services are the views and images that adults hold about children. There are many ways of depicting children and childhood and they all have political implications for children in any society. In the past we, as a society, believed to our detriment that children should be seen and not heard, to spare the rod would spoil a child and that the pain of childhood would be forgotten in adulthood. This deficit stance portrayed the child as dependent, needy, voiceless and passive. Children were viewed as less than human. It is important and essential that our new policies and legislation reflect a more contemporary view of children. It is imperative that children are viewed as rich in potential, strong, powerful, competent and most of all connected to adults and other children. These values must underpin all relations with children and child protection work.
Early Children Ireland places the child at its centre and it is the child that informs our thinking. That is the first strong point that we want to make and it is contained in our written submission. I do not know whether I should read them all to the committee but we strongly recommend that future policies and legislation that emerge from this consultative process should position the child at its centre. The committee should feel it, see it, hear it and read that in the legislation. I do not know if we have managed to take on board a contemporary view of children. I have not seen it in the legislation but I would like to. I want to see a more holistic view of the children.
The position of the adult is also important. Relationships are crucial and vital to understanding and is perhaps the most attractive aspect of the caring and learning process that we are engaged in. The adult who engages with the child as a volunteer or in a paid capacity, regardless of the setting, is absolutely key to providing a safe and secure environment - safe child, safe adult; secure child, secure adult. They work hand in hand. The child learns and develops within and through relationships; in other words, the child needs the secure and consistent presence of adults. Learning to be in healthy relationships provides a lifelong benchmark for young children in recognising healthy and unhealthy contexts. In being picked up and cuddled, in sitting on an adult's lap listening to a story, in being helped to self-manage in toilet and washing, the child experiences care and education, a sense of trust and of being valued. To provide secure environments, adults must be confident in their practices and secure in the ways they respond to and work with young children. Early Childhood Ireland recognises that work with young children must be underpinned by qualifications, training and access to support and continuing professional development.
With regard to constructing the system in which we work, the Bill provides a tangible opportunity to build a connected system. Under the weight of scandals, reports and insufficient investment, our current system of child protection lacks credibility and reliability. Like scaffolding, a system of child protection must be robust and secure; capable of dealing with volume; provide coverage so that it is inclusive; connected in that all bodies and agencies are linked and listening; and provide some flexibility without interfering with the integrity of the structure of daily life.
The birth rate is increasing, and the number of children eligible for the early childhood care and education scheme, which covers the three to four year old age group, is also increasing. The number of children coming into our services is definitely increasing . A recent article in The Irish Times by Helen Buckley suggested that where reporting legislation has been implemented, one in every four or five children in the population is reported. When this is applied across the number of children in the services, it would equate to over 13,000 being reported to the services. We need a world class system to deal with that. In our written submission, I have outlined how that system might look.
A number of issues arise from the heads of the Children First Bill. On policy alignment, we would urge clarity in the use of language. Emotional abuse, for example, is categorised in one document but not in another, while ways of reporting are stated to be by telephone in one document but in writing in another. The role of the designated officer must be clearer because there is confusion between documents, and there is strong overlap and duplication of information required. We propose that the new system must ensure that the child care regulations of 2006, the forthcoming Garda vetting bureau Bill, the Children First national guidance of 2011, the Data Protection Acts and the Children First Bill must be coherent and speak uniformly across all documents.
On the scope of the Bill, the protection must be for all children. Childminding is a very important part of the Irish early childhood care and education sector. Figures from the Central Statistics Office identify the most prevalent form of child care for preschool children as being crèche, Montessori or playgroup at 19%, with childminders, au pairs or nannies at 12%. They must be included, but the Bill has omitted them. While the numbers attending childminders remained static in the period 2002 to 2007, it is assumed that the levels of childminding have increased in recent times. At our conference in April 2012, Dr. Jan Peeters from the University of Ghent talked about the situation in Belgium. As in Ireland, childminding is a huge informal sector. From research he conducted with his colleagues, Dr. Peeters found that life patterns are changing and that childminders are becoming a more transient group, staying in the sector for fewer years than previously. There is greater turnover of childminders. Belgium requires 1,000 new childminders annually to replace those who are leaving. This larger turnover rate has resulted in a significant increase of child protection issues. This is coming down the track for us as well. We must take note of these things because all children need protection.
School age and out-of-school services currently operate outside of regulation. To better understand their scope and remit, data are currently being collated on numbers and patterns of usage on a county by county basis. Parents rely on out-of-school services for peace of mind to participate in the labour force. The Bill is a wonderful opportunity to take out-of-school services into consideration. All children deserve protection and we have no option but to include all those working directly with young children and youth under the remit of the Bill.
With regard to staff, the Bill includes preschool or full day care staff with a HETAC level 7 award as mandated professionals in Schedule I. The purpose of this inclusion is unclear. We have tried to figure out what it means. HETAC level 7 is not currently a required or uniform qualification across senior posts within schools and crèches. The FETAC level 5 is the most common qualification in the sector. We suggest that this category should be renamed or reclassified as "early childhood care and education professionals, not covered under Schedule I".
The definition of "organisation" places a significant weight of responsibility and consequences for failing to meet the requirements across all organisational types, irrespective of their size or capacity. I have already spoken about the demands and challenges within the sector on owners, managers and supervisors. This would mean additional pressure and extra work for services. Under the proposed draft heads of the Bill, the organisation - frequently this person will also be the designated officer - will now have an additional role with significant responsibilities carrying penalties for failures to comply. A small preschool service with four staff members, for example, will now be required to provide training for employees and volunteers without any additional resources, carry out annual audits and establish an internal audit committee. This will be difficult. The definition of "organisation" could be reorganised to allow for a body such as Early Childhood Ireland to be the designated organisation. The definition should be broadened and there should be systems of support in place.
The designated officer is conceptualised as the most senior person in the organisation. Many of these small services are run by the owners and they tend to be the most senior person, so the organisation and designated officer will be the same person. Approximately 15% of our services are run by voluntary boards of management. I mention this to discuss the penalties. Without supports, these services will be criminalised for failure to meet the requirements. This is about thinking about the role of dedicated officer and the support that designated officers and others working with children need to implement the regulations. A national, established and creditable organisation such as ours which provides training from levels 4 to 8 will be able to support people in some of the new functions they will be expected to carry out. Although there is much to be welcomed in the proposed Bill, we can think further about the protection and safeguarding of children.
