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Action Alert

Resist government inspection of Christian youth activities

'Out-of-school education settings': Respond by 11 January 2016

In light of its 'Counter-Extremism Strategy', the government has announced plans for the registration and regulation of 'out-of-school education settings'.

The proposals could see Christian youth activities inspected and punished. 

The government has issued a 'call for evidence'. Please respond, highlighting the problems with the government's approach. 
Your response must reach the Department for Education by 5.30pm on Monday 11 January 2016.

For brief guidance on responding,
please scroll down to the 'How do I respond?' and 'What should I say?' sections.
Download the response document
Respond online now

What is the government proposing?

The government is proposing registration and regulation of "intensive education" that takes place in an 'out-of-school' context.

The threshold for "intensive education" could be reached where a child attends a particular 'out-of-school' setting for more than 6 - 8 hours in a week, the government suggests.

The government proposes: 
  • Registration of settings that meet the criteria for "intensive education".
  • Inspection by Ofsted both on a routine basis (a certain proportion of registered settings inspected each year) and in response to specific complaints or concerns.
  • Sanctions including individuals being barred from working with children and the closure of premises.
Crucially, the proposals have implications for the content of what is taught in these settings. 

"Undesirable teaching, for example teaching which undermines or is incompatible with fundamental British values, or which promotes extremist views" would be prohibited under the proposals. 

These proposals are not about schools, colleges, childcare providers and other contexts that are already regulated

The proposals do not cover home schooling (although media reports before Christmas suggested that the government does plan to review home schooling).

The government says that the measures are not about "regulating religion", but the 'British values' approach used in the proposals does amount to regulation of Christian teaching and poses a huge challenge to Christian freedoms.

Many Christian children and youth activities (as well as vast numbers of other groups) are likely to fall within the scope of these proposals. Christian holiday clubs, camps and festivals could be included. If a child attends one church's events for more than a total of 6 hours during a week, then the church may be required to register.
Read the consultation document

What are the problems?

There are many problems with the proposals (e.g. a huge regulatory burden, failure to identify clearly the problem to be tackled) but a very damaging consequence is state regulation and censorship of Christian teaching, especially on central issues, such as the uniqueness of Jesus Christ, sexual ethics and the sanctity of human life. 

These proposals would introduce government registration and regulation into many Christian settings. 

The government claims that the proposals will protect children from:
  • "Emotional harm" (Para 2.1).
  • "Extremism" (Para 2.2).
  • Those who work in positions of trust and influence with children and young people who, "in expressing their individual beliefs, promote intolerance against others" (Para 2.4).
  • "Undesirable teaching, for example teaching which undermines or is incompatible with fundamental British values" (Para 3.19).
These ill-defined concepts are slippery and subjective. Decisions as to what constitutes "extremism", "British values", "undesirable teaching" or "emotional harm" would be wide open to abuse.

These proposals would hand huge power to public officials, without appropriate safeguards. They would provide a basis for state censorship of biblical teaching that is deemed undesirable.

Sadly, there are already people who claim that Christian teaching promotes "hate and fear". Public officials have already suggested that Christian teaching about marriage and homosexual practice could be considered 'extremist'. There are insufficient safeguards included within these proposals to protect them from these interpretations. 

These proposals are part of the government's broader 'Counter-Extremism Strategy' and suffer from the same fundamental flaws as that wider strategy. 

The strategy is very broad and is being rolled out across a number of areas, with dangerous consequences for Christians and churches (read more).

The government's definition of 'extremism' is vague and open-ended. In fact, it is both incoherent (it makes the government 'extremist' for countering 'extremism') and inconsistent (the government's definition has shifted, subtly but significantly).

The government sometimes presents the strategy as a response to right-wing and Islamic 'extremism'. However, its actual scope is much wider. The home secretary says that it is about defeating "extremism in all its forms" and addressing "hate and fear in all their forms". Christians (and others) will be caught in its net, given the loose definitions.

The entire strategy needs dramatic revision and tighter focus, if Christian belief and behaviour, which some people say is 'extremist', is not to be a target. 

Read more about the challenges of the government's 'Counter-Extremism Strategy'.
Read our response to the 'Counter-Extremism Strategy'

Who should respond?

  • Leaders of churches and Christian organisations, especially those that run activities for children or young people.
  • Leaders of Sunday schools, after-school clubs, youth groups, uniformed groups, festivals and holiday clubs and camps.
  • Parents and grandparents.
  • Children and teenagers (especially those who attend 'out-of-school' activities).
  • Church members.
  • Those involved in other 'out-of-school' activities for young people - e.g. sports clubs, reading clubs, Scouts and Guides, activity holidays.
You will be able to indicate the reason for your interest at the start of your response. If you don't fit into any of the categories given, just tick 'Other'.

You don't need to answer all the questions and your response needn't take more than a few minutes (although you can answer more questions if you wish). We suggest some key points to make below.

How should I respond?

There are three ways that you can respond to this consultation:
  1. Respond online: Use the link below. You may want to download the response document first, so that you can read the questions in advance.
  2. Respond by email: Download the response document using the link below, complete it and then email it to: 
  3. Respond by post: Download the response document using the link below and send your response to: Call for evidence: out-of-school settings, Department for Education, Fourth Floor, Sanctuary Buildings, Great Smith Street, London SW1P 3BT
Your response must reach the Department for Education by 5.30pm on Monday 11 January.
Respond online now
Download the response document

What should I say?

Please try to put your responses in your own words.

You don't have to answer all of the questions. If you don't have much time, we suggest that you focus on questions 15, 21 and 22d:

In answer to question 15:
  • Emphasise how many settings could be covered if the threshold is set at 6 - 8 hours.
  • Christian holiday clubs, summer camps, festivals and day conferences could be included, for example. Remember that the threshold is reached if a child attends a setting for more than the specified number of hours. So, if a teenager attends an after-school club, a Sunday morning service and an evening youth group for more than 6 hours in total across the week, the church could need to register.
  • Point out that it's not just Christian groups - a vast array of other activities could also be covered (e.g. sports and activity holidays, revision and educational courses).
  • Bear in mind that some individuals or organisations responding to the consultation may want the threshold lowered to even fewer hours than the government is proposing, so please highlight that the problems will be even greater if the threshold is lower still.
Question 21 is an opportunity to summarise the negative effect of the proposals, for example:
  • Penalises vast numbers of innocent groups and distracts resources from where they are needed. 
  • Places huge power in the hands of government inspectors: Coupled with the dangerously vague definitions of 'extremism' and 'British values', the proposed regulation will lead to censorship of beliefs and teaching that are not 'politically correct', such as the belief that marriage is between a man and a woman or that Jesus is the only Saviour and Lord.
  • Creates a chilling effect: The registration, inspection and sanction regime will deter groups and individuals from offering life-enriching activities to children and young people.
You could use question 22d to explain the problems with the government's approach to 'British values' and 'extremism':
  • If the government wishes to challenge certain Islamic beliefs or teaching, it should specify exactly what that belief or teaching is, so that proposals can be considered on that basis. If the problem is Islamic terrorism, this should be the clear and limited focus of these proposals.
  • It is confusing for the government to slip regulation of the content of teaching in amongst regulation of the context of teaching (e.g. unsafe premises, safeguarding checks to ensure that those convicted of certain offences don't have access to children).
  • The government's definitions of 'extremism' and 'British values' are dangerously vague, open-ended, incoherent and inconsistent. This hands huge power to government officials and to those who oppose Christian beliefs. The government's proposals could be used to prevent the teaching of mainstream Christian beliefs, just because some people claim that those beliefs are offensive or 'harmful'. Christian beliefs are already described as 'hateful' by some, and public officials have already suggested that opposition to homosexual practice could be considered 'extremist'. 
  • The term "undesirable teaching" used by the government is subjective and dangerously vague.

If you have a bit more time, please consider the following points: 

Characteristics (Questions 1 - 14):
  • You don't need to answer these questions, although question 12 gives you an opportunity to highlight the benefits / positive experiences of Christian 'out-of-school education settings'.
Thresholds (Questions 15 - 16):
  • See points in response to question 15 above.
  • In response to question 16, you can explain that Christian (and other) groups should be exempted because there is no reason to believe that they are doing anything to encourage violence or terrorism.
  • In answer to either or both questions, you can highlight how taking a blanket approach introduces a huge burden, at significant cost, that could largely be avoided by a more targeted approach. The blanket approach penalises the innocent and risks distracting resources from where investigation may be needed.
Inspection and registration (Questions 17 - 21):
  • You could use questions 17, 18 and 20, to reiterate why you believe that Christian settings (and many others) shouldn't be subject to burdensome state regulation (see previous section).
  • See points in response to question 21 above.
Prohibited activities (Questions 22 - 23):
  • You could use questions 22a, 22b and 22c to highlight how existing (or slightly amended) legislation or regulation of child safeguarding and health and safety could be used to meet these aims. 
  • See points in response to question 22d above.
Sanctions (Questions 24 - 25):
  • You could use question 25 to highlight that Christian belief is a protected characteristic under the Equality Act 2010, yet these proposals will be unnecessarily detrimental to Christian groups and could be used to challenge the free expression of mainstream Christian beliefs. 

Continuing challenge

Andrea Williams comments: 

"Thank you for taking action on this important issue. Unfortunately, since the approach of the government's 'Counter-Extremism Strategy' is fundamentally flawed, we can expect further dangerous proposals.

"We will keep you informed. Please continue to work with us as we challenge both the overall approach and the specific plans that flow from it."
You may also want to contact your MP to express your concern about the government's approach.

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