Safeguarding in Wales: our concerns, our actions and where next

Context and definitions

In Wales, we have guidance in place to support the safeguarding of children and young people, as set out in the All-Wales Safeguarding Procedures.

Child Practice Reviews (CPRs): These reviews are undertaken in circumstances of a significant incident where abuse or neglect of a child is known or suspected.

Regional Safeguarding Boards (RSBs): There are six boards in Wales. These Boards have a statutory responsibility to undertake multi-agency Child Practice Reviews and for instigating SUSRs.

National Safeguarding Board (NISB): this is described as an advisory board that advises Welsh Ministers on safeguarding people in Wales and works alongside RSBs to secure consistent improvements in safeguarding policy and practice throughout Wales.

Single Unified Safeguarding Reviews (SUSRs): this came into effect in 1 October 2024; here is the guidance from Welsh Government. This process brings together Child Practice Reviews, Adult Practice Reviews, Domestic Homicide Reviews and Mental Health Homicide Reviews under one umbrella.

Timelines

Our office was a UK-first, established to protect and promote the rights and welfare of children in Wales. As such, the issue of safeguarding children has been a central focus of our influencing work since this organisation was established in 2001. Here’s a summary of key milestones (not an exhaustive list):

June 2004: Publication of Clywch, the first Inquiry held in accordance with the Commissioner’s powers. The Inquiry’s final report contained 31 recommendations; 16 of which fell within the direct responsibility of Welsh Assembly Government (as it was then known), together with a further six in which they had substantial involvement in developing associated guidance or in a sponsorship role. Government accepted and implemented these recommendations.

2012: Following a damning joint inspection report about Pembrokeshire’s child protection procedures, the then Children’s Commissioner undertook an audit of local authorities’ implementation of the Clywch recommendations, indicating a good or reasonable level of compliance with many of the recommendations.

2020: The then Commissioner undertook a review of Welsh Government’s response to Dylan Seabridge’s death in 2011 and the Child Practice Review published in 2016. It highlighted deficiencies in the procedures for sharing and learning from CPRs and recommended a substantive update of the CPR guidance.

2020: The then Commissioner gave evidence to the Independent Inquiry into Child Sexual Abuse (IICSA).

Below we have outlined key milestones during Rocio Cifuentes’s term as Children’s Commissioner. It is not an exhaustive list but provides an insight into key pillars of work relating to children’s safeguarding.

October 2022: Commissioner called for the WG to coordinate and publish a Welsh Implementation Plan, showing how the Government and other public bodies in Wales will implement the recommendations contained in the Independent Inquiry into Child Sexual abuse (IICSA) Inquiry Report. This Inquiry Report included a recommendation that Wales should have a new body – a Child Protection Authority – to look at the ways that activity groups, clubs, and religious organisations keep children safe.

Following the tragic death of Logan Mwangi in 2021, recommendations were made in a CPR about how safeguarding should be strengthened on a national level to better protect children at risk of harm and abuse

May 2022: we wrote to the then Deputy Minister setting out concerns about the governance and accountability arrangements surrounding learning from CPRs, and sought Welsh Government’s views on the effectiveness of Wales’ safeguarding governance methods and structures. The Commissioner also met with the independent Chair of the Logan Mwangi Review and the CYSUR Mid and West Wales safeguarding board regarding the Kaylea Titford Review

Following the publication of the Cwm Taf Morgannwg Child Practice Review, the Commissioner spoke out about ongoing concerns. We wrote again to Welsh Government to share these concerns and urged for this area of safeguarding to feature in any review the WG undertakes to build confidence that we have robust governance and accountability structures in place. Officers also met with Care Inspectorate Wales to help shape their Rapid Review of Child Protection Arrangements.

December 2022: met with WG officials to learn more about the Single Unified Safeguarding Review (SUSR) process

May 2023: SUSR process went out for public consultation by WG; we responded and make it clear that whilst the proposals will have greater oversight of recommendations emanating from reviews, dissemination of learning and monitoring of the implementation of the recommendations still relies on existing structures. We were not confident that the SUSR will go far enough in addressing our concerns.

2023: key pieces of work published, including renewed National Action Plan on Preventing Child Sexual Abuse; Welsh Government’s response to the SUSR; thematic review of CPRs commissioned by the National Independent Safeguarding Board

81% of respondents to the public consultation on the proposed SUSR guidance raised concerns in relation to governance.

We followed up concerns with Ministers and officials throughout the year, as well as discussing the matter with the National Independent Safeguarding Board and at various working groups and workshops. Our concerns were about:

Lessons from Reviews are shared and actions are identified on an all-Wales basis, and who will be responsible for achieving this;

Action plans that are intended to implement recommendations from Reviews are taken forward and achieved, and who will have oversight of this; and

Recommendations from Reviews are suitably famed so that they don’t just apply to the regional area undertaking the Review; whether / how individual boards can direct others across Wales in this regard.

2024: saw the publication of various CPRs, including Kaylea Titford and Lola James – in response to those damning Reviews, we raised time and again publicly and in meetings our concerns around the adequacy of governance structures.

2024: the new SUSR process was due to come into force in April 2024 – it did not. The changes we had suggested to WG to strengthen the governance and processes to ensure lessons are adequately learned from CPRs have not been made, despite our consultation response, follow-up meetings and correspondence with the Deputy Minister. The effectiveness of the new roles and structures under the SUSR remain to be seen, but we were not assured that the system would be suitable to ensure all practitioners across a range of agencies will hear about and address practice issues arising from Reviews. We were also concerned at the lack of mechanism external to Government as part of the new governance arrangements.

October 2024: SUSR process came into effect. We sit on the Ministerial Board and the Strategy Group for this work. Our suggested changes to the process were not accepted by WG. The effectiveness of the new roles and structures under the SUSR remain to be seen, but we were not suitably assured that the system will be suitable; there was no mechanism external to Government as part of the new governance arrangements and we had no access to the new Repository, which is to house all reports and actions plans, despite sitting on the Strategy Group convened by WG.

November 2024: We wrote to the Cabinet Secretary about Government’s School Complaints Procedures Guidance, following a request from our office for information from all 22 local authorities on how that guidance is being implemented. We initiated this work, based on our concerns, emerging from our casework, about educational complaints, the role of school governors within that process, and the inadequacy of the current guidance. Following this representation, Welsh Government agreed to review its guidance.

July 2024: Sentencing of headteacher, Neil Foden, for multiple sexual offences at Ysgol Friars, Gwynedd.

January 2025: hosted a roundtable with Wales’ inspectorates and Welsh Government to discuss ongoing safeguarding concerns resulting from the Foden case (Commissioner wrote to Gwynedd LA when Foden was arrested in September 2023 and requested a meeting, which was declined until trial concluded. Since July 2024, Commissioner had regular contact with senior local authority officials, including the CEO, to discuss its Response Plan)

March 2025: Commissioner and team accepted invite by Gwynedd Council to be active observer members on its Response Plan Programme Board, established to steer the authority’s response plan, adopted by Cyngor Gwynedd in January 2025 to collate all support, reviews, audits and other work streams responding to Foden’s crimes.

2025: Published blog looking at Welsh Government’s progress against the six recommendations from IICSA that apply to the devolved government. We met with Senedd members, Government Ministers and officials related to the topic as well as some faith-based organisations, safeguarding boards and the National Independent Safeguarding Board.

September 2025: In our ‘Manifesto for Children and Young People’, we set out the commitments we want political parties standing in the 2026 Senedd elections to make for children and young people. Within this document we highlighted yet again as a key priority, our concern that without more oversight, when recommendations emerging from CPRs or SUSRs are made to keep children safe, nobody will know if these have been achieved. Our asks of political parties were as follows:

The IICSA recommendation to establish a Child Protection Authority needs to be delivered

New legislation is needed to close safeguarding loopholes to enable independent oversight of religious organisations, and non-affiliated sports clubs.

October 2025: Welsh Government announces a review of governance and accountability mechanisms for safeguarding children and adults in Wales, which will examine:

The roles and responsibilities of the NISB and RSBs

Interface between these bodies and the inspectorates

Overall effectiveness of those arrangements in protecting people from harm

Recommendations to further strengthen safeguarding governance in Wales

October 2025: Welsh Government announces a review of school governing bodies, which will examine: structure and roles, effectiveness and impact, support and training, accountability and oversight, recruitment and retention, best practice and innovation.

November 2025: Commissioner responds to the publication of the Foden CPR. The harrowing report emphasised the sheer number of opportunities that were missed to stop Foden’s abuse of children. Time and time again, children were not listened to; they were failed by people who should have acted and by institutions that should have protected them. These are not new themes. These themes are consistent with what we, and others, have highlighted and impressed on Welsh Government and others to change.

Recommendations by us and others

In 2023, the UN Committee on the Rights of the Child published concluding observations on the UK’s implementation of the UN Convention on the Rights of the Child, issuing nearly 200 recommendations for improvement. Below is a summary of those recommendations related to this work, and relevant to our devolved Welsh Government:

Strengthen measures aimed at tackling violence against children, including implementing the recommendations of the independent inquiry into child sexual abuse (IICSA)

Ensure the systematic collection and analysis of data on child protection issues and violence against children to inform the implementation of national strategies on violence and child sexual abuse

The need to ensure that child protection systems take a child rights-based approach to preventing and addressing cases of abuse and neglect

Here is a summary of pertinent recommendations we’ve addressed to Welsh Government in successive annual reports:

2022/23 Annual Report

Welsh Government should confirm how the SUSR proposals will adequately ensure learning emanating from child practice reviews will be implemented and monitored

2023/24 Annual Report

Welsh Government must ensure that SUSR guidance addresses the significant concerns that we have raised about Review recommendations being implemented comprehensively across Wales. This includes:

Specify how lessons from all Reviews will be shared across all Boards and that relevant agencies in Wales, and whose role it will be to do this on a proactive basis

Clarifying who within WG will have oversight of the action plans that are intended to implement recommendations from Reviews, to make sure that they are taken forward and achieved not just in the Board area responsible for that Review but, where relevant, across Wales, and

Setting out whether WG officials and/or the National Independent Safeguarding Board will advise on the wording of the recommendations from Reviews, to ensure that they are suitably framed to make sure that they are targeted at the right body or bodies, so that they don’t just apply to the regional area undertaking the Review. This includes recommendations that apply on a national basis, so some further independent oversight or input is likely to be required.

2024/25 Annual Report

Welsh Government must swiftly undertake a review of the current safeguarding landscape, and its governance and accountability mechanism in Wales to ensure that identified gaps are being addressed through new actions, with legislative change to underpin this as required

The Year One review of the SUSR process needs to be in place swiftly so that the findings are available to be accepted and implemented prior to the Senedd election in 2026

Further work to improve accountability and governance around safeguarding reviews is required to ensure all those working with children in Wales are aware of and are implementing lessons learned through Reviews. This has to start with broader access to the Repository and Dashboard tools as a matter of priority

The road ahead

This is a crucial moment for child safeguarding in Wales.

The Neil Foden CPR is clear that, despite the changes to legislation that were introduced initially in response to the Clywch Inquiry, children were let down by institutions there to protect them. Local implementation of some of these guidelines and procedures is not good enough; the oversight of the implementation of these guidelines and procedures is not good enough.

There can be no more missed opportunities. The recently announced Welsh Government reviews must get underway at pace. We have also urged Welsh Government to ensure the reviews’ respective terms of reference are mutually reinforcing rather than overlapping.

Given our statutory remit to promote and protect children’s rights and welfare, I urge the Welsh Government to ensure my office is formally and consistently involved in both reviews.