Guidance

Joint targeted area inspection of the multi-agency response to the criminal exploitation of children

Published 28 March 2022

Applies to England

1. This guidance is for inspectors carrying out a joint targeted area inspection (JTAI) of the multi-agency response to the criminal exploitation of children in a local authority area in England.

2. These JTAIs are carried out by inspectors from:

• Ofsted

• Care Quality Commission (CQC)

• His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS)

3. We carry out JTAIs under section 20 of the Children Act 2004.

4. We last updated this guidance on 28 March 2022.

5. For guidance on JTAIs that look at other topics, see the joint inspections of local area services collection.

Definition of child criminal exploitation

6. The Home Office defines child criminal exploitation as:

… where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or young person under the age of 18. The victim may have been criminally exploited even if the activity appears consensual. Child criminal exploitation does not always involve physical contact; it can also occur through the use of technology.

Criminal exploitation of children is broader than just county lines and includes for instance children forced to work on cannabis farms or to commit theft.

7. Currently there is no statutory definition of child criminal exploitation. However, perpetrators may be prosecuted under the Modern Slavery Act 2015, which sets out the offences of slavery, servitude and forced and compulsory labour in section 1, and human trafficking in section 2. Victims can be exploited in a number of ways, including sexual exploitation, forced labour, domestic servitude and criminal exploitation. Children may be forced to work in cannabis factories, move drugs, money or weapons across county lines or within their locality, launder money through their bank accounts or carry out crimes of theft or violence, particularly against other children.

8. One way in which children can be criminally exploited is through county lines activity. The government defines county lines in the following way:

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”.

9. Many children who are criminally exploited, including those exploited through county lines activity, are sexually exploited too. The government defines child sexual exploitation in the following way:

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.

10. A February 2022 report by IICSA, child sexual exploitation by organised networks, commented on the relationship between child criminal and child sexual exploitation:

The child criminal exploitation model covers all aspects of child exploitation, such as trafficking or county lines, including those which are particularly related to drug offending. The rationale for adoption of this model appears to be that it discourages a ‘silo’ mentality in relation to all aspects of child exploitation. This comes at the cost of making child sexual exploitation even more of a hidden problem and increasingly underestimated.

Scope of the inspection

11. The agencies within the scope of this inspection are the police, children’s social care, education and relevant health services.

12. The main focus of this JTAI is the multi-agency arrangements in relation to criminal exploitation, but we will also look at whether local agencies have a distinct and effective focus on identifying children at risk of or experiencing sexual exploitation. If a child is at risk of or experiencing both criminal and sexual exploitation, we will evaluate the holistic multi-agency response.

13. Inspectors will evaluate the multi-agency arrangements for:

• responding to all forms of child criminal exploitation at the point of identification

• assessment, planning and decision-making in response to notifications and referrals of children at risk of criminal exploitation, or who have been criminally exploited

• protecting, supporting and caring for children who are at risk or have been harmed by criminal exploitation, including the support and care of children looked after and/or care leavers

• preventing child criminal exploitation, including through awareness-raising and use of disruption activity (Disruption involves strategies and tactics designed by the police and other safeguarding partners to reduce risks to vulnerable children and interrupt the activity of those who are seeking to exploit them)

• identifying children at risk of sexual exploitation and the multi-agency response

14. Inspectors will also evaluate how effectively the local partnership, through its multi-agency safeguarding arrangements (MASA), monitors, promotes, coordinates and evaluates the work of the statutory partners.

15. The inspection will focus on recent practice. This is practice within the last 6 months. The inspection will evaluate how well current practice takes account of relevant history in children’s cases.

Evaluation criteria

16. Inspectors will evaluate evidence about the experiences and progress of children against the criteria set out below. The evaluation criteria (EC) numbers are a referencing system used by inspectors when recording their evidence.

EC number	Criteria
EC1	Agencies work together to identify children at risk or who are exploited, intervene to reduce risk and monitor effectively the impact of interventions so that risk is reduced.
EC2	Children who are at risk or are exploited experience a child-centred approach from all professionals. Practice is based on a good understanding of children’s experiences; their background and identity, including any barriers to them accessing help and support; and their needs and strengths.
EC3	Professionals understand the importance of building trusting relationships with children who have been exploited. Professionals work together to ensure that they are appropriately persistent in their efforts to engage with children and their families. Relationships are based on consistency, stability and respectful communication.
EC4	Assessments include contributions from all agencies. They are timely and consider contextual risks and protective factors, risks and strengths within the family, and risks online. The experience of the child is well understood and their views are clearly recorded and central to an effective multi-agency response.
EC5	Assessments and plans are dynamic and change in the light of emerging issues and risks.
EC6	Children are protected through effective multi-agency arrangements. Key participants attend multi-agency meetings. These meetings are effective forums for timely information-sharing, planning, decision-making and monitoring. Actions happen within agreed timescales and the help and protection provided reduce risk and meet need.
EC7	Children and their families can access a sufficient range of effective services that are well coordinated, including therapeutic help.
EC8	Professionals and support staff across agencies are well trained, confident and knowledgeable. They understand the impact of exploitation on children’s health and well-being. They are aware of the importance of avoiding victim-blaming language and approaches. This enables them to effectively identify how to help and protect children and to take action to do so.
EC9	Children at risk of exploitation who are missing receive a well-coordinated multi-agency response to prevent and reduce risk. This includes a discussion with the child when they return home. These discussions are of good quality and the information is shared appropriately. Agencies use the information at an individual and strategic level to reduce risk.
EC10	Agencies avoid the unnecessary criminalisation of children. Partners understand the experiences that can contribute to children exploiting other children. They reduce risks through appropriate support for all children involved.
EC11	Cases of children at risk of exploitation are investigated effectively.
EC12	Children and their families are listened to. Multi-agency practice focuses on their needs and experiences and is influenced by their wishes and feelings.
EC13	Schools/education providers have effective systems to identify children at risk of, or subject to, exploitation and children who are missing from school. They make timely referrals to early help or children’s social care, where appropriate. Schools and partner agencies work effectively together to ensure that children get the support they need.
EC14	Schools/education providers are supported by local safeguarding partners to contribute effectively to multi-agency working and to raise awareness and understanding of the risks of exploitation. They work together to support children to remain in education.
EC15	Leaders and managers across agencies share and analyse information effectively so that partners know and understand the: experiences of children at risk of or subject to exploitation; prevalence of exploitation in their area; localities where children may be at risk; demographics of adult perpetrators of exploitation; and demographics of victims of exploitation. This leads to effective multi-agency strategy, planning and action to meet children’s needs and improve the help and support for children and their families, including the commissioning of services to meet local need.
EC16	Multi-agency partners effectively combat and disrupt the exploitation of children, including by intervening in places where children are groomed and exploited.
EC17	Leaders and managers use their knowledge to challenge and support practice and promote continuous improvement in services for children at risk of exploitation.
EC18	Leaders in the local partnership, through the MASA, actively monitor and evaluate the work of the statutory partners effectively. The local partnership works closely with other strategic partnerships and local organisations to ensure that children and their families get the help and support they need. Arrangements for independent scrutiny of the MASA provide assurance of its effectiveness.
EC19	Multi-agency partners ensure that awareness-raising and preventative work is in place with the community, businesses, parents and children to alert them to the risk of child exploitation.
EC20	The local partnership, through the MASA, promotes multi-agency learning about the identification, assessment and response to exploitation effectively. Practice, planning and the design of services are informed and improved by feedback from children and families, as well as research and intelligence about effective multi-agency practice.

The inspection team

17. The inspection team will usually consist of:

• 3 social care inspectors from Ofsted – one will be the lead inspector

• 1 schools inspector from Ofsted

• 2 inspectors from HMICFRS

• 2 inspectors from CQC

18. A Senior His Majesty’s Inspector (HMI) from Ofsted will be the quality assurance manager.

19. CQC and HMICFRS may appoint additional quality assurance managers to the team if there are specific circumstances that require additional oversight.

Overview of the inspection

20. The JTAI will follow the structure set out below. The lead inspector will provide a detailed timeline when they notify the leaders in the local area of the inspection.

Activities in week 1

• Inspectors notify the local leaders of the inspection 10 working days before the fieldwork begins. This will usually be on a Monday but may happen earlier if a there is a bank holiday in week 1 or 2 of the inspection.

• Inspectors request information to support the inspection (this information is set out in Annex A of this guidance).

• Inspectors and local leaders hold a set-up discussion (inspectors are off site).

• Local agencies share information to support the inspection.

• Inspectors select some children and ask the local agencies to evaluate the children’s experiences through an audit.

• Inspectors carry out planning and pre-inspection analysis.

Activities in week 2

• The local area evaluates children’s experiences and provide audits to the inspection team.

• Local agencies share information to support the inspection.

• Inspectors carry out pre-inspection analysis and review the information set out in Annex A.

• Inspectors work with the local agencies to agree a fieldwork timetable.

• Inspectors may meet virtually with local leaders to discuss arrangements for the inspection and the local context.

Activities in week 3

• Fieldwork – inspectors gather evidence.

• Inspection findings fed back to the local partnership.

Pre-inspection activity

21. The inspectorates will share with each other an analysis of relevant information they hold about the local area.

22. An inspector from each of the inspectorates will review the information. They will meet to discuss arrangements for the inspection before they notify the local partners of the JTAI.

Week 1: notification, set-up and information request

Notification

23. On day 1 (10 working days before the fieldwork), inspectors will contact the relevant leaders in the local area to notify them of the inspection:

• Ofsted will contact the director of children’s services (DCS)

• CQC will notify the clinical commissioning group (CCG)’s chief executive and executive lead for safeguarding children

• HMICFRS will notify the chief constable and the force liaison officer

24. The Ofsted lead inspector will ask the DCS to notify the person with responsibility for independent scrutiny of the local MASA.

25. Inspectors will ask local leaders to arrange for the information set out in Annex A to be shared with inspectors. Inspectors will provide a timeline for this to happen.

Set-up discussion

26. Inspectors will arrange a multi-agency set-up discussion with local leaders and the person responsible for independent scrutiny of the local safeguarding arrangements. This is an opportunity for inspectors to explain the scope and methodology of the inspection, and the practical arrangements for ensuring that the inspection can be carried out smoothly. Local agencies can use this opportunity to ask questions about the inspection.

27. Inspectors will ask the local area to identify a link person to help arrange the inspection. The link person should have access to the senior leaders in the agencies and the authority to respond to the lead inspector’s requests.

28. Inspectors will ask whether there are any safeguarding incidents that they should be made aware of. This includes significant and current investigations, publication of serious case reviews, rapid reviews or child safeguarding practice reviews, or local issues of high media interest.

Information request (Annex A)

29. Annex A sets out the information inspectors will request and the timeline for the local agencies to share it. The information includes:

• child-level data, which inspectors will use to select the children whose experiences they will evaluate (inspectors will ask the local agencies to audit the experiences of some of these children)

• case records of the children whose experiences the local agencies have audited

• performance and management information that sets out how the local partnership works together

30. Inspectors may ask for additional information not set out in Annex A and may agree to look at additional information provided by the local partnership. The inspector/local agency must demonstrate that the additional information is:

• necessary for an accurate understanding of children’s experiences and the effectiveness of the local partnership in relation to the scope of the inspection

• not already available through the request in Annex A

Selecting cases to audit

31. By the end of week 1, inspectors will select between 5 and 7 children and ask the local agencies to audit these children’s experiences. Inspectors will use the child-level data set out in Annex A to select these children.

32. Inspectors will ask for some of the child-level data lists from Ofsted’s inspections of local authority children’s services (ILACS). We will ask the local authority to include some additional information in these lists (see Annex A for more information).

Week 2: children’s case audits, off-site analysis and creating a fieldwork timetable

Children’s case audits

33. Starting in week 2, the local agencies should audit the experiences of the children that the lead inspector selected at the end of week 1. Inspectors will also ask the agencies to share these children’s case records. They will ask the agencies to share the records electronically in week 2, if possible.

34. The local partnership should use its own methods to evaluate the children’s experiences, while taking the scope of the inspection into account. Inspectors will ask the local partners to submit single- and multi-agency audits for each child. If the local partnership has carried out a single- and/or multi-agency audit of any of these children’s experiences in the 3 months before the inspection, it may submit this as its evaluation for the inspection.

35. Inspectors will evaluate these cases and the local agencies’ audits. They will ask to meet with the practitioners involved in these children’s cases during the fieldwork week. At least 3 of these meetings will be multi-agency discussions. We refer to these activities collectively as case tracking.

Off-site analysis

36. In week 2, the local agencies should share the performance and management information set out in Annex A. Inspectors will refine their analysis based on the information that the local agencies share. Inspectors will also review audits of children’s cases carried out by the local agencies.

Off-site meetings with local agencies

37. Inspectors may meet remotely with local leaders, staff and stakeholders to discuss arrangements for the inspection and start gathering evidence in week 2. More information on who inspectors may speak to is set out in the ‘Interviews with practitioners, managers and leaders’ and ‘Meeting with representatives of the MASA, independent scrutineer and sub-groups’ sections.

Creating the fieldwork timetable

38. The Ofsted lead inspector will coordinate the creation of a fieldwork timetable. They will ask the lead inspectors from CQC and HMICFRS to liaise with their respective agencies to help create the timetable. This will include arrangements for meeting with practitioners, managers and leaders to discuss their work. Inspectors will also make arrangements for keep-in-touch (KIT) and feedback meetings to share inspectors’ findings.

39. Inspectors may also ask local agencies to arrange opportunities to meet with children and their families to discuss their experiences.

40. When creating the timetable, the Ofsted lead inspector will:

• consider which activities should be carried out in person and which by phone or video call

• include enough time for inspectors to travel between appointments

• include time for inspectors to review and analyse their evidence, individually and together

• ensure that the timetable is flexible enough to be changed in response to emerging findings

• agree arrangements for the local area to provide any additional support to facilitate communication with children, young people, parents and carers, when this is required (for example, by a social worker, advocate or family member)

• work with the link person in the local area to ensure that local leaders and practitioners are aware of the timetable and any changes to it

41. Inspectors will meet at the end of week 2 to discuss the plan for the inspection and any matters arising from their off-site analysis.

Week 3: inspection team meetings

42. Inspectors will meet when they arrive on site to review the arrangements for fieldwork.

43. Inspectors will meet regularly during fieldwork to discuss their findings. They may meet as a whole team or in smaller groups to consider findings from a particular part of the inspection scope. At these meetings, inspectors will:

• compare evidence from different inspectors and different parts of the inspection

• consider the impact of leaders, managers and the MASA on practice with children and families

• agree when the team has gathered enough evidence

• agree how best to gather further evidence in the time remaining

• ensure that the lead inspector has the information they need to coordinate the inspection effectively and keep the local agencies informed

44. Inspectors will meet at the end of fieldwork to review all the evidence they have gathered and agree provisional findings. Inspectors will review the evidence against the evaluation criteria and use their professional judgement to determine the weight and significance of their findings. They will identify any strengths, areas for improvement and areas for priority action.

Week 3: meetings with senior leaders

Initial on-site meeting with senior leaders

45. The lead inspector and a representative from each inspectorate will meet with senior leaders from the local agencies on the first day of fieldwork. At this meeting, attendees will review the matters discussed at the set-up discussion and inspectors will answer any questions the local leaders have.

46. This is also an opportunity for the local agencies to set out their local context. This can include any key strengths or challenges faced by the partnership and known issues of concern or public interest relating to the scope of the JTAI.

Keep-in-touch meetings

47. Inspectors will offer local senior leaders an opportunity to attend KIT meetings. KIT meetings are opportunities for senior leaders to hear emerging findings from the inspection. Leaders can use these meetings to ask questions about the findings and to help the lead inspector identify where further evidence is needed.

48. KIT meetings take place on the Wednesday and Thursday of the fieldwork week. They focus on the main findings arising from fieldwork. Inspectors may raise concerns about the help, protection or care of specific children for discussion at the meetings. They may ask the relevant local agencies to respond to these concerns in writing.

49. The lead inspector will chair these meetings. A representative from each inspectorate will usually attend. The lead inspector will ask the relevant local agencies to identify an appropriate senior leader from each agency to attend. Any additional attendees should be discussed with the lead inspector in advance.

50. Attendance at KIT meetings can be in person or by phone or video call. A local agency’s attendance at, or absence from, the meetings will not affect the inspection findings.

The feedback meeting

51. At the end of fieldwork, the lead inspector will invite all senior agency leaders and the person responsible for independent scrutiny of the MASA to meet inspectors to hear the provisional findings. The Ofsted lead inspector and at least one inspector from each inspectorate will attend. We will ask the local agencies to keep attendance to a minimum to help keep the discussions manageable and focused.

52. We encourage the local agencies to discuss the findings to help them:

• understand the evidence on which the findings are based

• understand any strengths, areas for improvement and areas for priority action

• build on their strengths and inform discussions about improvement

53. The lead inspector will set out the main findings and provide a summary of the evidence that demonstrates the local area’s strengths and areas for improvement.

54. If there are findings that may lead an inspectorate to take further action (for example, in its role as a regulator), the relevant inspectorate will offer to have a separate discussion with the relevant local agency.

55. The findings shared at this meeting are provisional pending quality assurance after the fieldwork has finished.

Week 3: gathering and evaluating evidence

56. Inspectors will prioritise gathering evidence about direct practice with children and families. They will gather evidence by:

• evaluating the experiences of children through case tracking, case sampling and observations of practice

• interviewing practitioners, managers, leaders and stakeholders

• evaluating the quality and impact of local multi-agency audits

• meeting with representatives of the MASA and relevant sub-groups

• reviewing documents about the local partnership’s work that are relevant to the scope of the inspection

57. Each of these methods is set out in more detail below.

58. When inspectors select the children whose experiences they will evaluate, they will take into account:

• the child’s age, sex and ethnicity, and whether the child is disabled

• children at different stages of involvement with the agencies being inspected

• issues specific to the local area that are relevant to the scope of the inspection

59. Inspectors will gather personal information that is necessary to help them evaluate local services. Our privacy notices set out what data we collect, what we do with it, how long we keep it for and people’s rights under the Data Protection Act 2018.

60. At all times, inspectors will focus on children’s experiences and how well practitioners have understood and taken account of their views in assessment, planning and intervention. Inspectors will evaluate how well leaders, managers and representatives of the MASA understand the experiences of children and families.

Hearing the views of children and their families

61. There are various ways for inspectors to hear the views of children and their families. These include:

• talking to children and their families directly, either in person or by phone or video call

• reading views recorded in case records and meeting minutes

• listening to views expressed by advocates on behalf of children

• listening to views expressed by practitioners based on their work with the child and their family

• analysing the responses to consultations with children, families and carers, particularly those the local partnership uses to evaluate and improve the help and protection it provides

62. The lead inspector may ask the local agencies to arrange for inspectors to talk to the children and their families and/or carers. This will usually be the children whose experiences inspectors have chosen to track. Inspectors will provide information to help children and their families/carers understand what their involvement in the inspection means. Children and their families/carers do not have to take part in the inspection if they do not want to. If a child, parent or carer does not want to speak to an inspector, the local agencies should inform the lead inspector of this. If there are reasons why the local agencies do not think it is appropriate for inspectors to speak to a particular child or their family, they should inform the lead inspector of the reasons.

63. In all activities involving children and their families, inspectors will ask the appropriate practitioner/s in the local area to speak to the child and their family and explain the inspection to them before the inspector speaks to the child/family or observes any work directly with them. Before proceeding with any discussions or observations, inspectors will always check with the child and family that they have understood what their involvement means. Inspectors should note this in their record of the discussion/observation.

Case tracking

64. Tracking is an in-depth look at a child’s experiences in relation to the scope of the inspection. Case tracking will usually include the following activities:

• reviewing children’s records (including case supervision notes)

• reviewing audits carried out by local agencies

• discussing children’s experiences with them and their parents/carers

• discussing children’s experiences with their social worker, health and education professionals and other practitioners involved with them

• observing the work of practitioners

• speaking to providers of commissioned services for children (when relevant)

Case sampling

65. Case sampling (also referred to as ‘dip sampling’) involves looking at the experiences of a larger number of children. It is not an evaluation of all the support provided to children and their families. Inspectors use sampling to focus on particular aspects of children’s experiences with local services. Inspectors use sampling to investigate areas of potentially strong and weak practice that they identify from other evidence gathered on the inspection. Inspectors may sample children’s cases alongside practitioners or by looking directly at case records.

66. The lead inspector may select some children’s cases for all inspectorates to sample (multi-agency sampling). Inspectors may also carry out single-agency sampling.

67. The lead inspector will decide when the inspection team has evaluated the experiences of a sufficient sample of children to arrive at clear inspection findings.

Observations of practice

68. Inspectors may gather evidence by observing meetings that are relevant to the scope of the inspection. These meetings could include:

• a strategy discussion/meeting

• a multi-agency panel

• an initial child protection conference

• a looked after children review, including a meeting when the child has been missing from care

• a child in need or other planning or review meeting

• any other meeting that is relevant to the scope of the inspection

69. If meetings relevant to the inspection are taking place in week 2, inspectors may join these by video call to observe local practice.

Interviews with practitioners, managers and leaders

70. Inspectors will speak to practitioners and/or managers about the children that they are responsible for, the learning and development of professionals, and the support and supervision they receive. They will ask them about their view of any strengths and areas for development relevant to the scope of the inspection.

71. Inspectors will usually meet with the service leaders listed below:

• DCS

• head of social care

• person responsible for independent scrutiny of the MASA

• police head of public protection or child protection and safeguarding

• police lead for the force or constabulary’s arrangements in relation to the scope of the inspection

• head of safeguarding and/or designated nurse for safeguarding children in CCG/integrated care system

If these individuals are not available, inspectors may talk to those who deputise for them. Where the local area has an alternative service model, inspectors will talk to the local equivalent of these service leaders.

72. Inspectors may speak to stakeholders who provide local services that are relevant to the scope of the inspection, such as providers of commissioned services or voluntary sector organisations. These discussions are to gather information about the effectiveness of the local safeguarding partners; they are not an inspection of the stakeholder.

Meeting with representatives of the MASA, the independent scrutineer and sub-groups

73. Inspectors will speak to representatives of the MASA by phone or video call in the week before fieldwork to find out how they support and enable local arrangements to safeguard and promote the welfare of children at risk of exploitation or who have been exploited. This includes how well they understand the strengths and areas for development in multi-agency practice and their impact on improvements in the multi-agency response to the criminal exploitation of children.

74. Inspectors will meet with the representatives of the MASA again during fieldwork to share our findings. This will be an opportunity to reflect on our findings and provide further evidence if appropriate.

75. The lead inspector will meet with the person responsible for independent scrutiny of the MASA (the independent scrutineer) during fieldwork to inform our understanding of the MASA’s effectiveness in relation to the scope of the inspection.

76. Inspectors may decide to meet with any sub-groups of the MASA that are relevant to the inspection.

Role of the schools HMI

77. The schools HMI will review children’s experiences for the cases that the local partnership is asked to audit. They will contact and meet with relevant schools/education providers that the children attend. They will evaluate whether schools contribute effectively to a well-coordinated multi-agency response to ensure that children get the right support, help and protection at the right time. They will meet with education representatives to evaluate how schools are working with others to ensure that preventative work is taking place and to evaluate the response to children missing education.

Issues of concern

78. Inspectors will notify a senior officer as soon as possible if they identify serious issues of concern during the inspection. Examples of these include a failure to follow child protection procedures or when a child is discovered to be at immediate risk of significant harm.

79. The lead inspector will provide a template for recording issues of concern and discuss the arrangements for managing this information at the set-up discussion. Inspectors will record their concerns on this template and ask the relevant senior officer(s) to provide a written response. The notifying inspector will inform the lead inspector, who will ensure that the response is received through the KIT meetings. The inspector who raised the concern and the lead inspector will evaluate the response and share their evaluation with the senior officer. The lead inspector and senior officer will sign this written record to confirm that they have seen the final version and that the process of review is complete.

Recording evidence

80. Each inspector will maintain a record of the evidence they gather. They should record the source of the evidence and the date and time they gathered it. This includes the date and time of any meetings, discussions and interviews. Each inspectorate will retain its individual inspectors’ evidence records in accordance with its retention policies.

81. Inspectors will record evaluative summaries of their evidence in the inspection team’s shared evidence record. The summaries will set out the inspector’s view about the quality of practice and the difference this makes for children. Two or more inspectors may coordinate their findings and agree for one of them to record an evaluative summary on their behalf. The shared record will include the notes of team meetings and KIT meetings with the local agencies. Ofsted will retain the shared record on behalf of the inspectorates.

82. Inspectors should complete all evidence records by the end of the fieldwork week. This is so an accurate record is available to support report writing and quality assurance.

83. The lead inspector will coordinate completion of the evidence record and will direct inspectors when further evidence is needed. All inspectors should review the shared evidence record regularly and advise the lead inspector when they identify gaps and when the team has gathered enough evidence.

84. When recording information about specific people, inspectors should use case reference numbers, people’s initials, dates of birth and job titles/roles. Inspectors should only record people’s names in the evidence record when this is necessary to accurately connect related evidence from across the local agencies. Inspectors should delete any names from the evidence record if they are no longer needed.

The letter of findings

85. The lead inspector will write up the inspection findings, drawing on the inspection team’s expertise as required. They will set out the findings in a letter addressed to the senior leaders in the local partnership and the independent scrutineer for the MASA.

86. The letter will set out any strengths, areas for improvement and areas for priority action. It will state the services, practice or arrangements that the findings relate to but will not state what action the local partnership should take in response to the findings.

Areas for priority action

87. Inspectors will include an area for priority action if they identify a serious weakness that is placing children at risk of inadequate protection or significant harm. Priority actions may result from particular or localised failings to protect children, as well as systemic failures or deficits. The inspectorates may take action individually after the inspection to respond to the areas for priority action they identified. For further information, see Annex B.

Quality assurance manager

88. A quality assurance manager will be assigned to the inspection to ensure that the inspection guidance, methodology and criteria are applied consistently and correctly, and that any concerns raised by the local agencies about the inspection are resolved. They will review the findings in the final letter to ensure that they link clearly to the evidence from the inspection.

Arrangements for publishing findings

89. The quality assurance manager will support the lead inspector throughout the writing process. Senior managers in all inspectorates will review and agree the findings presented in the letter.

90. We will share the draft letter with the DCS and ask them to coordinate a shared review of the factual accuracy of the letter and a response on behalf of the local partnership.

91. Inspectors will share a timeline for writing, reviewing and publishing the letter when they notify the local area of the inspection.

Activity	Timescales
Draft letter sent to local partnership to review factual accuracy	15 working days after fieldwork
DCS has 9 working days to coordinate the partnership’s comments	24 working days after fieldwork
Final version of the letter sent to the local partnership (pre-publication, under embargo)	31 working days after fieldwork
Letter published	34 working days after fieldwork

After the inspection

Post-inspection feedback survey

92. When we send the final letter of findings to the local partnership, we will ask the DCS to coordinate a response from the partnership to an evaluation questionnaire. The inspectorates will use the feedback to improve future inspections.

Action plan after the inspection

93. The Children Act 2004 (Joint Area Reviews) Regulations 2015 allow HMCI to require a written statement of proposed action that responds to the findings. Ofsted will decide whether to require a statement of action in consultation with CQC and HMICFRS. We will also decide which agency should lead and which agencies should cooperate in making the statement. We will include this decision in the letter of findings. The local partnership may choose to involve other partners in addition to those identified in the letter.

94. The local partnership must make the statement within 70 working days of receiving the final letter of findings.

95. The inspectorates will review the action plan and write a response to the local partnership. The purpose of the inspectorates’ review is to confirm whether the action plan shows that the local agencies have understood the findings. It is the partnership’s responsibility to agree the actions that it should take in response to the inspection findings.

Annex A: local information to support the inspection

96. This annex sets out the information that inspectors request when they notify the local partnership of the JTAI. It also sets out the arrangements for selecting the children’s cases that inspectors will ask the local agencies to audit. The flow chart below sets out the process and timeline for sharing this information.

97. Inspectors will provide details for accessing an online system that local agencies can use to share information. Ofsted has risk-assessed this system against the government’s Cloud Security Principles.

98. Inspectors will gather personal information that is necessary to help them evaluate local services. Our privacy notices set out what data we collect, what we do with it, how long we keep it for and people’s rights under the Data Protection Act 2018.

Week 1: selecting children’s cases to audit and evaluate

99. By 5pm on Tuesday in week 1, the local authority, working with partner agencies, should provide 3 lists of child-level data. These lists are similar to the information requested in Ofsted’s framework for the inspection of local authority children’s services. For a JTAI, these lists should include some additional fields of data, as set out in the table below.

List	ILACS list number	Additional fields
All those in receipt of services as a child in need at the point of inspection or in the 6 months before the inspection	List 6 (children in need)	- Is the child at risk of or subject to criminal exploitation? - Is the child at risk of or subject to sexual exploitation? - The number of episodes where the child has been missing from home or care in the last 6 months. - Is the child currently in receipt of full-time education?
All those who are the subject of a child protection plan at the point of inspection, including those who ceased to be the subject of a child protection plan in the 6 months before the inspection	List 7 (child protection)	- Is the child at risk of or subject to criminal exploitation? - Is the child at risk of or subject to sexual exploitation? - The number of episodes where the child has been missing from home or care in the last 6 months. - Is the child currently in receipt of full-time education?
All children in care at the point of inspection, including all those children who ceased to be looked after in the 6 months before the inspection	List 8 (children in care)	- Is the child at risk of or subject to criminal exploitation? - Is the child at risk of or subject to sexual exploitation? - Is the child currently in receipt of full-time education?

100. By 5pm on Tuesday of week 1, the local authority and partner agencies should also share separate lists of children, as set out in the bullet points below. For each child on these lists, the local authority should include the child’s unique ID; the agencies involved with the child and their family; and whether they are a child in need, on a child protection plan or a child in care. The lists should cover:

• up to 10 children for whom the local authority and partner agencies think that criminal and/or sexual exploitation is a current or significant factor and with whom at least two agencies are involved

• up to 10 children for whom the local authority and partner agencies think that criminal and/or sexual exploitation is a current or significant factor and believe that there has been positive engagement with the child and their family to improve outcomes for the child

• up to 10 children with whom the youth offending team and children’s services are involved and for whom criminal and/or sexual exploitation is a current or significant factor

101. By 5pm on Wednesday, the lead inspector will select 20 children from the lists provided and ask the local authority to provide additional information on these 20. By 5pm on Thursday, the local authority should provide the following information about each of the 20 children:

• is the child known to the police?

• are the child’s parents/carers known to the police?

• which health services has the child received support from (for example, school nurse, child and adolescent mental health services, contraceptive and sexual health (CASH) services and emergency department)?

• is the child known to the youth offending team?

102. By 11am on Friday in week one, the lead inspector will select 5 to 7 children from the 20. They will ask the local partnership to audit these children’s cases.

103. The lead inspector may phone the local authority to confirm that the cases selected include multi-agency involvement and current or recent work to address concerns about child exploitation. The lead inspector may ask the agencies to review the cases on the electronic recording system to ensure this.

Week 2: children’s case records

104. The list below sets out the information that inspectors will ask for about the children whose experiences the local agencies have been asked to audit. Whenever possible, the local agencies should share this information electronically by 5pm on Tuesday in week 2. If this is not possible, the local agencies should liaise with the relevant inspectorate to give access to this information during fieldwork.

The local authority should share:

• the initial referral/contact/notification (if applicable)

• the child’s most recent assessment, including a common or early help assessment

• the strategy or other multi-agency discussion or equivalent

• the section 47 investigation documentation/initial child protection conference minutes

• the child’s most recent plan and/or the most recent review of the plan, including any health care plans

• the latest return home interview and any subsequent risk assessments (if appropriate)

• the minutes of any multi-agency meetings about the child, such as multi-agency sexual exploitation meetings and/or multi-agency criminal exploitation meetings

• the most recent pre-sentence report about the child or any relevant adult (where applicable)

• a chronology of significant events in the 6 months before the inspection; these may include:

  • episodes of the child going missing from home, care or education
  • any contact that the child or relevant adults has had with the police – as either a victim or suspect – such as reported incidents, crimes and investigations, and reports of the child being missing or absent
  • information on events earlier than the 6 months before the inspection when this is necessary to understand the context of the child’s experience

The police force should share:

• incident logs

• crime/non-crime reports

• referral information

• missing children records

• custody records

Health services should share:

• assessments of need/risk and action taken

• analyses and evaluations of the impact of work undertaken

• referrals to multi-agency child exploitation (MACE) meetings

• follow-up of referrals and evidence of feedback

• evidence of information-sharing with and from other health and multi-agency partners

• evidence of health agencies contributions to decision-making, including at meetings (for example, initial child protection conferences)

• evidence of managers supervision/oversight of health practitioners work with the child

• evidence of escalation to multi-agency partners, including children’s social care, when there are professional disagreements about decision making

105. The specific health agencies that help each child will vary. CQC will determine which agencies to request information from.

Week 2: local partnership audits

106. The local agencies should provide their joint evaluations – and, if possible, individual agencies’ evaluations – of children’s experiences electronically by the end of Thursday in week 2.

107. Inspectors will ask to meet with the practitioners involved in these children’s cases during the fieldwork week for a discussion about their work. At least 3 of these meetings will be multi-agency discussions.

Week 1: other child-level lists and planned multi-agency meetings

108. By 5pm on Thursday in week 1, the local agencies should provide the lead inspector with details of the multi-agency meetings taking place during the fieldwork week, including: initial child protection conferences; review child protection conferences; looked after children reviews; strategy discussions; and other multi-agency meetings/panels relevant to the scope.

109. The local authority should also share the child-level data in list 4 (assessments) of the Ofsted ILACS framework: ‘All statutory assessment in accordance with section 17 or section 47 of the Children Act 1989 in the 6 months before the inspection’. The local authority should provide 2 additional fields for this list:

• if an assessment has been completed, has criminal exploitation been identified?

• if an assessment has been completed, has sexual exploitation been identified?

110. The local authority should also share:

• a list of children who have been missing within the last 12 months. The list should include for each child: their unique ID, current status (care leaver, looked after child, child protection, child in need or not receiving statutory service) and whether they were at risk of exploitation. (This list is similar to item 2.02 of Ofsted’s ILACS framework.)

• a report on children for whom the local authority is responsible, who are of school age and who are not receiving full-time education at the time of the inspection. (This list is similar to item 2.05 of Ofsted’s ILACS framework). For each child, this report should include the:

  • child’s unique ID or unique pupil number (UPN) and date of birth

  • type of education provision that they are receiving, including home tuition

  • number of hours of provision they are receiving per week (in particular, whether they are receiving more or less than 25 hours per week)

  • type of exclusion (if the child has been excluded)

  • date when alternative provision began

Week 2: performance and management information

111. By 5pm on Tuesday in week 2, the local agencies should provide the information set out below. Inspectors will use this information to understand how members of the local partnership work together.

112. The local partnership should not provide everything that it holds on each subject. The inspectors will want only the area’s best and most recent examples that relate to the scope of this inspection. Inspectors will not review information that they deem to fall outside the scope of the inspection, so the information provided must be relevant.

The local authority

Number	Item	Description
1.1	Local authority organisational structures	Organisational structures showing lines of reporting and accountability
1.2	Management information reports	Reports for those children within the scope of the inspection (all forms of exploitation and missing children), at both a local and agency level
1.3	Threshold criteria	Assessment and threshold criteria for helping families and protecting the identified children
1.4	Practice audits	Practice audits, including multi-agency audits, over the 12 months before the inspection relating to the theme of the inspection
1.5	Improvement plans	Improvement/action plans
1.6	Commissioned services	Details of any services in the area that have been commissioned from the community or voluntary sector for children who have been missing and for children who have been, or are, at risk of sexual or criminal exploitation
1.7	Needs analysis	Needs analysis, strategies and action plans relating to sexual and/or criminal exploitation and children missing, any success criteria and any analysis impact
1.8	Strategic meetings	Minutes of strategic multi-agency meetings relating to children who are missing and/or at risk of exploitation[footnote 1]
1.9	Multi-agency safeguarding hub	Terms of reference for the multi-agency safeguarding hub or local equivalent
1.10	Engagement with children	How the local authority seeks feedback from children about child exploitation and engages them in evaluating and improving services
1.11	Escalation policy	Any policy relating to escalation following disagreement between agencies

Multi-agency safeguarding arrangements

Number	Item	Description
2.1	MASA structure	Organisational structures showing lines of accountability and reporting
2.2	Management information reports	Management information reports: please inform the lead inspector if these are the same as the reports shared by the individual agencies
2.3	MASA meeting minutes	Minutes of the local safeguarding partners from the 12 months before the inspection (including executive board meetings where applicable)
2.4	Sub-group minutes	Sub-group minutes relevant to the scope of the inspection (requested by the lead inspector)
2.5	MASA audits	Any audits that are relevant to the scope of the inspection
2.6	MASA annual report	The most recent MASA annual report setting out the effectiveness of local arrangements
2.7	Reviews	Rapid reviews and practice reviews carried out in the 18 months before the inspection
2.8	Action plans	All relevant action plans, including those following rapid reviews, practice reviews and multi-agency audits
2.9	Engagement with children	Information about how the local partnership seeks feedback from children and engages them in evaluating and improving services for exploited children
2.10	Escalation policy	Any policy relating to escalation following disagreement between agencies about decisions

The police force

Number	Item	Description
3.1	Police organisational structure	Organisational structure showing lines of reporting and accountability
3.2	Learning and development	Learning and development regarding vulnerability, sexual exploitation, criminal exploitation and child protection
3.3	Referral document	Child protection referral document
3.4	Missing children	Policy and guidance on missing children
3.5	Strategies	Strategy, policies and guidance relating to child sexual exploitation and criminal exploitation
3.6	Problem profile	Problem profile relating to missing, and sexually exploited and criminally exploited children including any children referred to the national referral mechanism (NRM), plus a copy of the policy or description of the process for making such a referral
3.7	Minutes on strategic governance	Three most recent sets of minutes for any force strategic governance meetings related to children missing and sexually exploited and criminally exploited children
3.8	Audits and action plans	Any audits and action plan(s) relating to children who are or may be at risk of sexual and/or criminal exploitation or who are missing
3.9	Performance management	Performance management information/data for children who are or may be at risk of sexual and/or criminal exploitation or who are missing
3.10	Child-centred strategy	Child-centred policing strategy and associated delivery plan

Health partners

Number	Item	Description
4.1	CCG/provider organisational structure	Organisational structures of the CCG and provider organisations, showing lines of reporting and accountability, including details of local health commissioning and/or provider services and links between operational and safeguarding teams
4.2	Commissioning arrangements	CCG and provider services, with details of who is providing commissioned services, including emergency department, young people’s substance misuse service, and contraceptive and sexual health (CASH) services
4.3	Annual reports	Annual reports from CCG and provider services on safeguarding and child protection, including for children looked after
4.4	Provider policies	Provider policies relating to child sexual exploitation and children who are criminally exploited, including local primary care policies
4.5	Audits and action plans	Any commissioner or provider audits and action plans relating to child sexual exploitation and criminal exploitation of children
4.6	Referral data	Most recent data on health referrals to the multi-agency safeguarding hub (or equivalent) and MACE
4.7	Training	Level 3 safeguarding training data by service, including topics

Annex B: what the inspectorates will do if there is an area for priority action

If an area for priority action is relevant to more than one agency within the scope of the inspection or the MASA

113. The inspectorates will discuss how to coordinate their follow-up with individual agencies (as set out below). We will share the final letter of findings with the government departments before it is published. We may offer the departments a discussion to explain the findings so that they can coordinate any response they may take. The inspectorates will consider whether to carry out a JTAI with the same scope after the local partnership has had sufficient time to respond to the area for priority action.

If an area for priority action is relevant to the local authority

114. Ofsted will inform the Department for Education (DfE). The DfE may contact the local authority to discuss the findings. Ofsted will also follow the process set out in the inspection of local authority children’s services framework, including asking for an action plan.

If an area for priority action is relevant to a health service

115. The CQC inspection team will immediately notify their manager, and a management review meeting will be called. This meeting may be attended by representatives from the regulation team and other key individuals as deemed necessary.

116. At the management review meeting, the inspection team will present the issues, and a decision will be made as to whether regulatory action is required. The regulatory response may include arranging a meeting with providers, organising a further follow-up visit, and/or beginning enforcement activity according to CQC’s enforcement policy.

If an area for priority action is relevant to a police force

117. HMICFRS will report the area for priority action as a cause of concern. A cause of concern will always be accompanied by one or more recommendations. HMICFRS will recommend that the force(s) (and sometimes other bodies) make changes to alleviate or eradicate the concern. New and existing causes of concern are tracked through the force monitoring process.

118. There are 2 phases to the monitoring process: scan and engage. A force’s progress against a cause of concern is reviewed through the scan stage of the monitoring process. If a force is not responding to a cause of concern, or if it is not succeeding in managing, mitigating or eradicating the cause of concern, it will probably be moved to the engage phase.

119. At this stage, the HMI will meet with the chief constable and police and crime commissioner (or equivalent) to set out the causes of concern and identify actions that need to be taken. Based on these discussions, the chief constable will carry out a root cause analysis and use it to formulate an improvement plan. The level of improvement required to be ‘disengaged’ will be set out by the HMI. The HMI may also approach other organisations to organise support for the force.

120. HMICFRS may decide to revisit/re-inspect a particular area of activity. This would focus on the cause(s) of concern identified in the initial inspection.

Annex C: complaints about JTAIs

121. If concerns arise during an inspection, these should be raised with the lead inspector or quality assurance manager as soon as possible during the inspection. This provides an opportunity to resolve the matter before the inspection is completed.

122. If it has not been possible to resolve concerns, the local partnership can make a complaint. There is a different process for:

• complaints about the inspection process and/or the findings

• complaints about an inspector’s conduct

123. The local partnership can make a complaint from when it receives the final letter of findings (the pre-publication stage) to up to 10 working days after the inspection findings are published.

124. We will not usually withdraw findings that we have already published unless there are exceptional circumstances. The local partnership can ask us to withdraw the letter of findings when it submits its complaint. The request should set out any exceptional circumstances that may be relevant. Ofsted’s National Director (Regulation and Social Care) will decide whether to withdraw the published findings in discussion with the relevant Ofsted Regional Director and the other inspectorates. There may be circumstances when a decision needs to be made urgently and a discussion between the inspectorates is not possible. In these situations, Ofsted’s National Director will make the decision and advise the other inspectorates at the earliest opportunity.

Complaints about the inspection process and/or findings

125. Complaints relating to the inspection arrangements or findings should be submitted to Ofsted through our complaints form. Ofsted will appoint a lead investigator to coordinate an investigation with the other inspectorates. We will follow the timeline set out in the table below.

Milestone	Activity
From receiving the pre-publication report to 10 working days after the report is published	Local partnership submits complaint to Ofsted.
Within 5 working days of complaint being made	Ofsted sends an acknowledgement letter to the complainants, setting out the timeline for considering their complaint. The letter will confirm whether any request to withdraw the report has been agreed. Ofsted shares copies of the complaint with the other inspectorates.
Within 30 working days of complaint being made	The response letter will undergo final checks and sign-off in Ofsted. Ofsted will share the final response with all inspectorates before sending it to the complainant.

Complaints about inspectors’ conduct

126. Complaints about an inspector’s conduct should be submitted to the relevant inspectorate. The relevant inspectorate will use its own processes to investigate the complaint.

127. In order to maintain confidentiality, the details of the complaint and the outcome may not be shared across all inspectorates. However, inspectorates must share whether a complaint about an inspector’s conduct has been upheld so that any potential implications for the findings can be considered. The inspectorates have agreed the following milestones for keeping each other informed of the complaint progress.

Milestone	Activity
Within 5 working days of complaint being made	Acknowledgement letters will be sent to complainants and will confirm expected response deadlines; the letter will explain which inspectorate will carry out the investigation. All inspectorates will be informed that a complaint has been received.
Within 30 working days of complaint being made	All inspectorates will be informed of whether the complaint has been upheld. The relevant inspectorate will respond to the complainant.

Complaints about inspection process/findings and inspectors’ conduct

128. Complaints about both the inspection process/findings and inspectors’ conduct will be considered on a case-by-case basis. In some cases, it may be appropriate for queries about inspectors’ conduct to be included in a broader complaint investigation. In other cases, for reasons of confidentiality, complaints about conduct might be considered separately.

129. Where this occurs, it is important to consider whether the outcome of an investigation into a complaint about conduct might impact on the robustness of the inspection process itself or the inspection outcomes. The relevant inspectorates will be consulted in all such cases.

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1. The lead inspector will discuss with the local area the local arrangements for strategic meetings on children who are missing and/or at risk of exploitation and agree which minutes are required. ↩