SPCs Quality and Inclusion

Summary

A request was made for information regarding the management structure, quality assurance, and inclusion policies of Specialist Provision Centres (SPCs). The Department of Education disclosed details on reporting lines and responsibilities but withheld the quality assurance framework citing a policy formulation exemption.

Key Facts

• Headteachers are responsible for the management structure of SPCs within their school settings.
• SPC Managers may report directly to the Headteacher or to a designated representative such as a Deputy Head or SENCo.
• The SPC Manager holds line management and appraisal responsibilities for staff within the centre.
• The quality assurance framework governing SPC assessments was withheld from disclosure.
• The request was received on 1 October 2024 and the outcome was issued on 28 October 2024.

Data Disclosed

• 2024-10-01
• 2024-10-28
• 4160205
• 5
• 1
• Level 2
• Level 3
• Section 34(1)(b)(i)

Exemptions Cited

• Section 34(1)(b)(i) - Formulation of Policy

Original Request

I am writing to request information under the Freedom of Information Act regarding Specialist Provision Centres (SPCs). Could you please provide the following information: 1. Management Reporting Structure of SPCs Please provide copies of the current management reporting structure for SPCs. 2. Quality Assurance Framework Please provide a copy of the quality assurance framework that governs the assessment of SPCs. Additionally, could you confirm whether the engagement with "Tribal" for external validation extends to SPC settings and provide copies of the criteria? 3. Inclusion Policies and Responsibility Please provide information on who holds responsibility for the inclusion of pupils within the Island's Specialist Provision Centres. Additionally, please provide copies of any related policies concerning pupil inclusion, as well as any equality impact assessments associated with these policies derived centrally by the department and how these are monitored for effectiveness. 4. Equality Impact Assessments for External Curriculum Contributors When external visitors or contributors, such as Young Engineers or Junior Achievement, visit schools to deliver curriculum input, please provide a copy of the equality impact assessment or any other demonstrative method that shows how these programmes are made accessible or adapted for children accessing SPCs or how the department provides equitable access. Thank you for your time and assistance. Yours faithfully

Data Tables (1)

Full Response Text

Policy, Strategy and Governance Division Department of Education, Sport and Culture Thie Slieau Whallian Foxdale Road St Johns IM4 3AS

Telephone: (01624) 685808 Website: www.gov.im/dec Email: dec@foi.gov.im

Our ref: 4160205 28 October 2024

Dear ###

We write further to your request, received 1 October 2024, which states:

"I am writing to request information under the Freedom of Information Act regarding Specialist Provision Centres (SPCs). Could you please provide the following information:

1. Management Reporting Structure of SPCs

Please provide copies of the current management reporting structure for SPCs.

1. Quality Assurance Framework

Please provide a copy of the quality assurance framework that governs the assessment of SPCs. Additionally, could you confirm whether the engagement with "Tribal" for external validation extends to SPC settings and provide copies of the criteria?

1. Inclusion Policies and Responsibility

Please provide information on who holds responsibility for the inclusion of pupils within the Island's Specialist Provision Centres. Additionally, please provide copies of any related policies concerning pupil inclusion, as well as any equality impact assessments associated with these policies derived centrally by the department and how these are monitored for effectiveness.

1. Equality Impact Assessments for External Curriculum Contributors

When external visitors or contributors, such as Young Engineers or Junior Achievement, visit schools to deliver curriculum input, please provide a copy of the equality impact assessment or any other demonstrative method that shows how these programmes are made accessible or adapted for children accessing SPCs or how the department provides equitable access."

Our response to your request is as follows:

1. Management Reporting Structure of SPCs

Please provide copies of the current management reporting structure for SPCs.

The respective Headteacher is responsible for the management structure of the Specialist Provision Centre (SPC) within their school setting.  Some Headteacher’s, particularly in secondary settings, may delegate the line management of the SPC Manager to a Deputy Head Teacher, Assistant Head Teacher, SENCo or Inclusion Manager whilst other SPC Managers report directly to the Headteacher.

The SPC Manager job description states:

The line manager for the post will be the Headteacher or their designated representative. The Headteacher will be responsible for all aspects of your management including health and safety in the workplace and attendance at work.

Line management and appraisal responsibilities of the SPC Manager:
• Take on all aspects of line management and appraisal for staff working within and sometimes beyond the Specialist Provision Centre
• Line management of any SPC teachers
• Performance management of any SPC teachers
• Line management and performance management of Education Support Officers at Level 2 and 3 in line with the school’s organisation of such.

SPC teacher and support staff:
• The Headteacher is responsible for all aspects of their management including health and safety in the workplace and attendance at work.
• The SPC Manager or their designated representative is responsible for the line management and appraisal/performance management of staff working within the Specialist Provision Centre.

1. Quality Assurance Framework

Please provide a copy of the quality assurance framework that governs the assessment of SPCs.

Section 34(1)(b)(i) Formulation of Policy
While our aim is to provide information whenever possible, in this instance the information is exempt from disclosure under section 34(1)(b)(i) of the Act as it is held by the Department, and it relates to the formulation or development of government policy. As section 34 is a qualified exemption, it is subject to a public interest test. The public interest must be something that is of serious concern and benefit to the public at large.

Factors in favour of disclosure: • There’s public interest in disclosing factual information used to provide an informed background to decision taking.

• Public participation in the policy is appropriate, in the sense of permitting people to contribute to policy prior to a final decision. Information disclosed prior to a decision being taken will facilitate more informed public debate.

Factors in favour of withholding • The pilot process of the new Quality Assurance model is live • Could result in information being disclosed which isn’t accurate therefore misleading the public • To protect the deliberative process and provide a safe space to protect information in the early stages of policy formulation and development • The need to maintain the quality of government policy making by facilitating free and frank exchanges between civil servants (“the chilling effect” and the thorough consideration of all policy options, however extreme, without including the need to defend them (“safe space”)

In taking these factors into account the Department of Education, Sport and Culture determined that the factors in favour of maintaining the exemption outweigh the factors in favour of disclosing the information.

Additionally, could you confirm whether the engagement with "Tribal" for external validation extends to SPC settings and provide copies of the criteria? The Department of Education, Sport and Culture can confirm that where an SPC setting is present within either a primary or secondary school, the SPC setting will be included within the external validation process, the same quality assurance framework that is used to support schools, supports SPC settings too.

1. Inclusion Policies and Responsibility

Please provide information on who holds responsibility for the inclusion of pupils within the Island's Specialist Provision Centres.

Headteacher’s hold overall responsibility for all children attending their school setting and are required to consider the educational needs of all pupils to plan and deliver a broad and balanced curriculum. However, the day-to-day management of SPCs, including teaching and learning responsibilities, timetables etc. are the responsibility of the SPC Manager. They will liaise with senior leaders and teaching staff in school along with external providers to develop and facilitate opportunities for inclusive practice, where this is appropriate to the individual needs of children attending the SPC.

Additionally, please provide copies of any related policies concerning pupil inclusion, as well as any equality impact assessments associated with these policies derived centrally by the department and how these are monitored for effectiveness.

DESC Policies:
Section 20 Information Accessible to Applicant by other means While our aim is to provide information whenever possible, under section 20 of the Act, we are not required to provide information in response to a request if it is already

reasonably accessible to you, whether free of charge or on payment of a fee. Most of the information that you have requested is available from:

• SEN Policy: https://www.gov.im/media/1371987/special-educational-needs- policy-final-formatted-november-2019.pdf

• Transport of Pupils with Special Educational Needs: https://www.gov.im/media/203066/policy-on-transportation-of-pupils-with- special-educational-needs-july-2018.pdf

• Inclusion Policy: https://www.gov.im/media/1386094/inclusive-education- policy-october-221024-v10_compressed.pdf

School Policies:
• Individual schools may have SEN and/or inclusion policies published on their website.

Equality Impact Assessments

While our aim is to provide information whenever possible, in this instance the public authority does not hold or cannot, after taking reasonable steps to do so, find some of the information that you have requested.

1. Equality Impact Assessments for External Curriculum Contributors

When external visitors or contributors, such as Young Engineers or Junior Achievement, visit schools to deliver curriculum input, please provide a copy of the equality impact assessment or any other demonstrative method that shows how these programmes are made accessible or adapted for children accessing SPCs or how the department provides equitable access.

While our aim is to provide information whenever possible, in this instance the public authority does not hold or cannot, after taking reasonable steps to do so, find some of the information that you have requested.

By way of advice and assistance external visitors or contributors are ordinarily organised by individual schools. They are aware of the needs of the cohort attending their provision, and for example, activities may have a whole school focus or be targeted at a specific year group such as Young Engineers or Junior Achievement.
Dependent on the programme offered, where possible materials will be adapted to meet the individual needs of all children attending including those children from SPCs.

Please quote the reference number 4160205 in any future communications.

Your right to request a review

If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.

If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested.
In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.