1.4.16 Complex (Organised or Multiple) Abuse

1. Definition

Complex (organised or multiple) abuse may be defined as abuse involving one or more abusers and a number of children (related or non-related).

The abusers concerned may be acting in concert to abuse a child or children or may act in isolation. One or more of the adults may be using an institutional framework or position of authority to recruit children for abuse.

It reflects, to a greater or lesser extent, an element of organisation on the part of the adult(s) involved and may involve:

Aspects of ritual to aid or conceal the abuse of children;
Child Sexual abuse networks where adults plan and develop social contacts with children for the purpose of gaining access to them in order to abuse them;
Abusive images of children;
abuse in residential homes, boarding schools or other institutions;
Adult(s) who seek contact with children with the intention to harm through leisure or welfare organisations.

Complex abuse investigations will encompass not only the reporting of current abuse on children, but also the reporting of childhood abuse by adults, often referred to as non-recent abuse. A report of abuse made to the police may be identified as non-recent if the offences occurred a considerable period of time before they were reported and recorded as a crime. However, the term non-recent is not universally applied and will be dependent on individual reports and the circumstances in which the abuse has taken place.

These procedures also reflect the fact that whilst some investigations fall within the definition of complex abuse, they are not in general of the same scale or complexity as some larger investigations.

Consequently, some investigations may be defined as 'complicated' rather than 'complex'. In general terms, these will be cases where agencies will need to work closely together, probably as part of a specialist team for the investigation under the direction of an Investigation Management Group (IMG), but not requiring the management and resources that would necessitate a Strategic Management Group (SMG). See Section 6, The Strategic Management Group (SMG) and Section 7, The Investigation Management Group (IMG).

Any decision relating to whether a case is complicated or not will be made at the scoping meeting.

2. General Principles

Cases of organised abuse are often highly complex because of the number of children involved, the very serious nature of the allegations of abuse, the need for therapeutic input and the complex and time consuming nature of any consequent legal proceedings.

Each investigation is different and complex abuse may occur in day care, in families and in other provisions such as youth services, sports clubs and voluntary groups. The emergence of cases of children being abused by the use of the Internet is also a form of complex abuse - see also: Child Abuse and Information Communication Technology Procedure.

Complex abuse investigations require thorough planning and may require the formation of dedicated teams of professionals from both the Police and Children's Social Care for the purpose of the investigation.

It is recognised those who commit offences against children often operate across geographical and operational boundaries and the offending may necessitate the involvement of more than one local authority - see Section 11, Crossing Geographical and Operational Boundaries.

Where an allegation involves a post holder who has a specified role within these procedures, the referral must be reported to an alternative (more senior) manager.

In all investigations of organised abuse, it is essential that staff involved maintain a high level of confidentiality in relation to the information in their possession without jeopardising the investigation or the welfare of the children involved.

Information generated throughout the investigation should only be shared where immediate safeguarding concerns are identified.

These procedures must be implemented in conjunction with the procedures on allegations against carers, staff, and volunteers where appropriate.

See: Allegations Against Persons who Work with Children Procedure.

3. Response

Where there is a suspicion of complex or organised abuse, the social worker or police officer receiving the referral should immediately inform their line manager. Further advice is available from second tier managers. If managers agree that the information gained constitutes a complex abuse allegation, the appropriate Children’s Social Care Manager will be informed. They will make the appropriate arrangements for the Police to be informed and consulted.

Investigations of complex abuse will be carried out under the auspices of the safeguarding partnership, which should be kept informed of its progress.

4. Scoping Strategy Discussion

In order to assist the decision-making about whether a complex abuse investigation is commenced, there should be a 'scoping' meeting involving the:

Senior Manager who has a service lead in respect of Complex Abuse, Children's Social Care or their nominee;
Police Detective Chief Inspector, Safeguarding Investigations Unit or their nominee;
Operational managers from three safeguarding statutory partners (Children’s Social Care, police and health representatives) and from any other agency with information to assist in determining the scale of the enquiry, including the referring agency.

The meeting needs to take account of the likely impact on the victim(s), the suspected offender(s) and the community in deciding whether the investigation or any course of action, is proportionate to the aim. Factors to be considered include the:

Extent or seriousness of the abuse (potential and actual numbers involved; the complexity of the circumstances; seriousness of injury or abuse; strength of public concern / feeling; the affect upon the community);
Context in which the abuse occurred (degree of organisation; ritual; paedophile ring; access to children; employer / volunteer; school, nursery or other institution).

The scoping meeting must:

Assess the information known to date;
Decide what further information is required at this stage and make arrangements to gather this;
Establish whether, and to what extent, complex abuse has been uncovered;
Undertake an initial mapping exercise to determine the scale of the investigation and possible individuals implicated;
Consider process for identifying any further potential victims or suspects;
Consider any immediate protective action required;
Consider a plan for the investigation to be presented to the Strategic Management Group (SMG), including resource implications, if a complex investigation is initiated.

If the meeting decides that the case is likely to be sufficiently complex and resource intensive, then a full meeting of the SMG needs be convened within a maximum of 10 working days.

If the meeting decides the case does not meet this threshold but does need a specific and focused operational response, an Investigation Management Group (IMG) should be convened to identify and deploy the necessary resources to manage and complete any resulting investigation.

Once formed, the IMG should operate as outlined within Section 7, The Investigation Management Group (IMG) and consider as appropriate the issues listed within Section 6, The Strategic Management Group (SMG) and continue to comply with the general principles of these procedures.

If, after further enquiries are made, it becomes clear that the situation is more complex, the scoping meeting should be re-convened and consideration given to defining the investigation as complex and convening a SMG.

As in all circumstances (including complex abuse), where children are deemed to be or are likely to be at risk of significant harm, Strategy Discussions/Meetings and Section 47 Enquiries should be convened as soon as practically possible as per standard procedures. See: Strategy Discussions/Meetings Procedure and Child Protection Enquiries - Section 47 Children Act 1989 Procedure. A Scoping Strategy Discussion should not delay or interfere with this process.

If it is found that the case does not meet the threshold regarding complexity, then the investigation will be managed under the normal arrangements described in the Child Protection Enquiries - Section 47 Children Act 1989 Procedure.

Where the extent of the complexity is unclear, there should be a further scoping meeting arranged to review the progress of the case. In some cases it may be useful to put in place an IMG where it would be helpful to the process.

If, after further enquiries are made, it becomes clear that the situation is more complex, the scoping meeting should be re-convened.

5. Professionals who need to be Informed

Once the decision has been taken at the scoping meeting to initiate a complex investigation, a Serious Incident Notification must be completed and inform the Safeguarding Children Partnership Manager.

6. The Strategic Management Group (SMG)

To ensure a coordinated response, a Strategic Management Group (SMG) meeting, chaired by either Children's Social Care or the Police, must be convened as early as possible. At this point, the lead agency should be identified and they will be the responsible agency for providing administrative support.

The membership of the SMG should comprise senior staff able to commit resources and will normally include the following:

Lead officer for Children's Social Care or nominee;
Assistant Chief Police Officer or nominee;
Police Senior Investigating Officer (SIO);
Senior child protection manager or nominee (Head of Service);
Senior legal adviser (local authority);
Crown Prosecution Service;
Assistant Director, Education or nominee;
Senior health representative;
Press officer;
Other individuals and agencies as appropriate.

Line managers of any staff implicated in the allegations of abuse must not be included in the SMG or the investigation team.

The Terms of Reference of the SMG should be recorded at the first meeting. All subsequent meetings held in accordance with this procedure must be recorded, the minutes classified as 'confidential’ and all copies individually numbered. Any copying of minutes should be agreed with the chair.

The minutes should be arranged in the following format:

Time, date, location of the meeting;
Persons present;
Apologies;
Details of all individuals subject of the enquiry (genogram);
Facts and circumstances known to date;
Identified actions;
Parameters of investigation;
Terms of Reference;
Resources and management issues;
Media issues;
Miscellaneous;
Exit strategy;
Date of next meeting.

Investigative decisions and rationale should be recorded in a policy book; a document used by the Senior Investigating Officer to record strategic and tactical decisions. An action matrix to assist monitoring purposes should be considered.

The meeting must consider a wide range of issues and agree a plan that includes:

A decision on the scale of the investigation and the staff required for a joint IMG - see: Section 7, The Investigation Management Group (IMG);
The focus of the investigation: protection versus prosecution and what will and what will not be investigated;
If a referral to the LADO is necessary;
Any cross boundary issues and planning of appropriate liaison and sharing of resources;
Identification of staff to manage the investigative process (usually the Police Safeguarding Investigations Unit and Children’s Social Care);
Identification of sufficient trained staff for the investigation - see: Section 8, Investigation Team;
Organisation of adequate accommodation including a dedicated major incident room and facilities for interviewing and recording interviews;
Arrangements for medical staff to conduct assessments;
Arrangements for sufficient administrative staff and information technology resources to support the investigation;
Proper legal advice including consultation with the Crown Prosecution Service, litigation and any other legal implications;
Sufficient resources to ensure that children are protected from further abuse and that their welfare remains paramount (this should include appropriate foster, day-care or residential placements, medical, therapeutic, educational and practical services);
Victim care;
Child witness support, if relevant;
Sufficient support, supervision and de-briefing of staff involved;
Availability of expert advice where necessary;
Liaison arrangements for inter-agency working;
Time scales for the stages of the investigation;
Allocation of specific tasks to personnel involved in the investigation together with line management responsibilities;
Management of public relations and media interest in the case;
Management of political arena;
Confidentiality / need to know arrangements;
Disclosure policy / information sharing, Memorandum of Understanding (MOU);
Professional association interest (e.g. Trades Unions);
Free phone application - helpline for victims / information line;
Issues around financial compensation for victims;
Exit strategy;
Safety / security of records and appointment of disclosure officer.

The SMG must ensure that any current risks to children are acted upon immediately, whenever they emerge during the investigation and should consider developing a risk management protocol.

The SMG must make arrangements to convene regularly during the investigation to:

Monitor the progress, quality and integrity of the investigation;
Review risk indicators for the children involved;
Consider resource requirements;
Consider the appropriate timing of the termination of the investigation;
Plan a de-brief meeting with the IMG to identify lessons learnt.

The SMG should remain in existence at least until the Crown Prosecution Service has made a decision about the alleged perpetrators.

The SMG must inform the safeguarding partnership of the investigation and consideration given to the need for a child safeguarding practice review.

7. The Investigation Management Group (IMG)

This group led by the police Senior Investigating Officer or their deputy needs to include representatives of Children's Social Care, education, health and local authority legal services. The chair would be an identified Children’s Social Care Manager from the Local Authority. Other agencies should be invited as appropriate.

The role of this group will vary, but should include:

A forum for the exchange of information, tactics and strategy, and to monitor the progress of the investigation;
Ensuring consistent strategy for interviewing victims;
Updating the SMG of the progress of the investigation;
Updating the SMG on any resource shortages;
Ensuring consistent support for victims and their families;
Maintaining support for investigation team staff;
Sharing information with agencies not represented on the SMG;
Ensuring compliance by the investigation team of policy and parameters set with regard to information sharing and confidentiality;
Ensuring cross-flow of intelligence between agencies and the police major incident room;
Setting policy.

8. Investigation Team

The SMG should identify individuals within and outside their organisation with the required expertise. This may include experience of investigating allegations of abuse, compiling profiles, understanding methods of abusers, child protection processes, disciplinary proceedings and working with victims, survivors and their families.

In selecting staff, consideration should be given to requirements arising from the individual needs of the relevant child(ren) - e.g. gender, culture, race, language, and where relevant, disability.

The team members must be trustworthy and display sensitivity, honesty, empathy and personal maturity. They must all be wholly independent from any of the parties that are the subjects of the investigation.

Personnel seconded to the Investigation Team should be dedicated to the investigation and have no other responsibility.

The location of the team must take account, both geographically and organisationally, of the need to maintain confidentiality, especially crucial where the investigation concerns staff or carers.

Appropriate facilities must be available for video interviews and paediatric assessment.

Administrative support, information technology and accommodation requirements must be addressed at the outset, including the storage of confidential records.

9. Access to Records

One of the most difficult issues in complex abuse investigations relates to the tracing, use, management and disclosure of documentary information relevant to the investigation. The Investigation Team should consider what information is required and where it is likely to be and take immediate steps to secure it within each agency.

A vast range of documentary information will exist on personal files, personnel files, e-mails, general establishment records and registers. Clear protocols and procedures for investigative access to this material will need to be established at an early stage. An information sharing MOU should be considered for all agencies.

Where vital information may have been lost, damaged or destroyed over a period of time, consideration should be given to the establishment of a database containing details of known or potential witnesses and victims.

10. Information Sharing

Complex abuse investigations rely critically on sensitive or highly confidential information being made available, including any information known about alleged perpetrators identified in the investigation.

The principles set out in Information Sharing and Confidentiality should be applied to all complex abuse investigations and team members should be familiar with its provisions.

The need to maintain the integrity of shared information is vital, and all investigative staff must be aware and comply with the principle of a 'need to know basis'. Consideration should be given to the use of confidentiality agreements with regard to individuals employed to undertake the investigation. In addition to the issues regarding access to files and information sharing, consideration must be given for the need to share information about any known or suspected offender identified in the investigation.

Whenever a statement of complaint is received in respect of an alleged perpetrator, a risk assessment must be immediately undertaken with regard to what current risk that person may pose to other young children.

Members of the Investigation Team should not undertake this task but ensure that the appropriate information is shared with the multi agency risk panel situated in the area where it is believed the perpetrator is currently residing.

11. Cross Geographical and Operational Boundaries

It may be recognised at the outset, or during the investigation, that there are suspected or potential victims in more than one geographical area.

At the outset, the responsibility for coordinating the investigation lies with Children's Social Care where the abuse is alleged to have occurred/ where the alleged perpetrator(s) are alleged to operate.

Once it is recognised that there are suspected or potential victims in other areas a joint approach should be made by the SMG to the appropriate police and Children's Social Care.

The initiating IMG and Investigation Team should undertake the investigation on behalf of the other geographical areas. A senior manager from each area should join the initiating SMG to discuss this and agree any resource implications involved.

If the number of victims outside the geographical boundaries of the original joint Investigation Team increases to the extent that it cannot respond, then an IMG and / or an Investigation Team in the new geographic area should be established.

It is essential that there is a joint SMG to provide overall planning. If it is necessary to have more than one Investigation Team, there must be close working between coordinators and processes for full information sharing.

12. Closure

There must be a clearly defined exit strategy not only in relation to the closure of the investigation, but also with regard to the victims and witnesses, who may require on-going support at the conclusion of any trial or investigation.

Staff involved directly in the investigation as well as other operational staff who have kept day to day services running where colleagues have been seconded into the investigation team, need to be thoroughly debriefed.

At the conclusion of the investigation each agency should undertake a review, with a view to identifying any changes to policy, practice or disciplinary processes that may be necessary. Such a review will complement any safeguarding practice review that may be concurrent or have been completed.

The SMG should have a final meeting where concluding information and debriefing can be shared. An overview report should be compiled and presented to the Safeguarding Children Partnership.

Consideration must also be given to the storage and security of the files relating to the investigation. Access to such records may well be necessary in relation to any on-going appeals, civil proceedings or applications for compensation.

The records will be stored on the relevant child’s file unless there are issues of confidentiality; where this is the case other arrangements will be agreed. Best practice is for the files to be centrally archived at a single location and retained for a minimum period in line with agencies case file retention policies.

Further Information

Risk and associated investigations (College of Policing)