During the course of the affiliation process over the summer, it became apparent that a number of coaches had never been made subject to a police check by their clubs, or whose checks had been allowed to lapse without a renewal being in progress.
Any coach, manager, or assistant who is working in grassroots youth football without an 'Accepted' FA/Criminal Records Check is in breach of both the law and FA regulations.
Of greater significance is the fact that these people may potentially be banned from working with, or pose a risk to, children.
The legal responsibility for compliance lies with both the individual and the club. However, Lancashire FA also has a moral duty to ensure that eligible volunteers have been safely recruited.
As some of you may be aware, this resulted in a delay in the affiliation process of some clubs whilst compliance was gradually achieved. In some cases, this led to fixtures being postponed - which is clearly not in anybody’s interest, least of all our young players.
In order to prevent a recurrence next summer, we wish to work as closely as possible with all of our club welfare officers to ensure they are effectively managing the ongoing renewal process.
We have created a guidance document which should allow our CWOs to navigate around their area of the Whole Game System.
CRCs are 'traffic-lighted,' which gives an instant view of any volunteers whose checks have already expired, or are due to run out shortly. Our very strong advice to CWOs is to begin the renewal process three months before the original check expires, to allow an overlap and constant compliance.
If you are using the GBG Disclosures system to manage CRCs for your club, it is important to be aware of when an application is complete. Full compliance is only achieved when the CRC shows as 'Accepted' on the FA database.
Just because an application shows as complete on the GBG Disclosures system, does not mean the volunteer in question is fully compliant at that stage. In cases where there is some form of historic criminal content, the application becomes subject to a risk assessment - hence there is an inevitable delay between the application showing completed and then 'Accepted.'
Unsupervised access to children cannot be sanctioned until the latter stage is reached.
Of course, the FA/CRC is only one element of a wider safe recruitment policy. Lancashire FA want to ensure that anybody who wishes to volunteer in football goes through the same process as one would, for example, in the case of a childminder.
There have been coaches in the past with a clear 'Accepted' CRC who were not suitable role models for children and whose behaviour fell short of the standards we require.
In order to assist clubs in this area, Lancashire FA has drawn up guidelines on safe recruitment, and would urge clubs to consider adopting it as a standard policy and procedure.