Thinking Anglicans

Publication of Bishop George Bell independent review

Updated to include press reports published after release of the report – more added Saturday morning and evening

The Bishop George Bell independent review (the “Carlile Report”) has been published today together with the press release below.

Scroll down for links to the report and its annexes, and for press reports.

Publication of Bishop George Bell independent review

15/12/2017

The Church of England’s National Safeguarding Team (NST,) has today published the key findings and recommendations, along with the full report, from the independent review into the processes used in the Bishop George Bell case.

The review, commissioned by the NST on the recommendation of the Bishop of Chichester, was carried out by Lord Carlile of Berriew. As he writes in the introduction, his purpose was not to determine the truthfulness of the woman referred to as Carol in the report, nor the guilt or innocence of Bishop Bell, but to examine the procedures followed by the Church of England. The objectives of the review included “ensuring that survivors are listened to and taken seriously”, and that recommendations are made to help the Church embed best practice in safeguarding in the future.

The report made 15 recommendations and concluded that the Church acted throughout in good faith while highlighting that the process was deficient in a number of respects.

Bishop Peter Hancock, the Church of England’s lead safeguarding bishop, has responded on behalf of the Church:

“We are enormously grateful to Lord Carlile for this ‘lessons learned’ review which examines how the Church handled the allegations made by Carol in the 1990s, and more recently. Lord Carlile makes a number of considered points as to how to handle such cases in future and we accept the main thrust of his recommendations.

“In responding to the report, we first want to acknowledge and publicly apologise again for the Church’s lamentable failure, as noted by Lord Carlile, to handle the case properly in 1995.

“At the heart of this case was a judgement, on the balance of probabilities, as to whether, in the event that her claim for compensation reached trial, a court would have concluded that Carol was abused by Bishop Bell. The Church decided to compensate Carol, to apologise and to be open about the case.

“Lord Carlile states that ‘where as in this case the settlement is without admission of liability, the settlement generally should be with a confidentiality provision” but respectfully, we differ from that judgement. The Church is committed to transparency. We would look at each case on its merits but generally would seek to avoid confidentiality clauses.

“It is clear from the report, however, that our processes were deficient in a number of respects, in particular the process for seeking to establish what may have happened. For that we apologise. Lessons can and have been learnt about how we could have managed the process better.

“The Bishop Bell case is a complex one and it is clear from the report and minutes of Core Group meetings that much professional care and discussion were taken over both agreeing the settlement with Carol and the decision to make this public. As Lord Carlile’s report makes clear, we acted in good faith throughout with no calculated intention to damage George Bell’s reputation.

“The Church has always affirmed and treasured Bishop Bell’s principled stand in the Second World War and his contribution to peace remains extraordinary. At same time, we have a duty and commitment to listen to those reporting abuse, to guard their confidentiality, and to protect their interests.

“We recognise that Carol has suffered pain, as have surviving relatives of Bishop Bell. We are sorry that the Church has added to that pain through its handling of this case.”

Statement from Bishop of Chichester, Martin Warner

“Lord Carlile’s Independent Review is a demonstration of the Church of England’s commitment to equality of justice and transparency in our safeguarding practice. The diocese of Chichester requested this “lessons learned” Review.

“We welcome Lord Carlile’s assessment of our processes, and apologise for failures in the work of the Core Group of national and diocesan officers and its inadequate attention to the rights of those who are dead. We also accept the Report’s recognition that we acted in good faith, and improvements to Core Group protocols are already in place. Further work on them is in hand.

“The Report demands further consideration of the complexities of this case, such as what boundaries can be set to the principle of transparency. Lord Carlile rightly draws our attention to public perception. The emotive principle of innocent until proven guilty is a standard by which our actions are judged and we have to ensure as best we can that justice is seen to be done. Irrespective of whether she is technically a complainant, survivor, or victim, ‘Carol’ emerges from this report as a person of dignity and integrity. It is essential that her right to privacy continues to be fully respected.

“The good deeds that Bishop George Bell did were recognised internationally. They will stand the test of time. In every other respect, we have all been diminished by the case that Lord Carlile has reviewed.”

Statement from Archbishop of Canterbury, Justin Welby

“Bishop George Bell is one of the great Anglican heroes of the 20th century. The decision to publish his name was taken with immense reluctance, and all involved recognised the deep tragedy involved. However we have to differ from Lord Carlile’s point that ‘where as in this case the settlement is without admission of liability, the settlement generally should be with a confidentiality provision”. The C of E is committed to transparency and therefore we would take a different approach.

“Lord Carlile does not seek to say whether George Bell was in fact responsible for the acts about which the complaint was made. He does make significant comments on our processes, and we accept that improvement is necessary, in all cases including those where the person complained about is dead. We are utterly committed to seeking to ensure just outcomes for all. We apologise for the failures of the process.

“The complaint about Bishop Bell does not diminish the importance of his great achievement. We realise that a significant cloud is left over his name. Let us therefore remember his defence of Jewish victims of persecution, his moral stand against indiscriminate bombing, his personal risks in the cause of supporting the anti Hitler resistance, and his long service in the Diocese of Chichester. No human being is entirely good or bad. Bishop Bell was in many ways a hero. He is also accused of great wickedness. Good acts do not diminish evil ones, nor do evil ones make it right to forget the good. Whatever is thought about the accusations, the whole person and whole life should be kept in mind.”

Documents

Carlile Review
Annexes to the Review

Press reports

(published before the release of the report)

BBC News Church apology over Bishop George Bell abuse inquiry

Harriet Sherwood The Guardian Church of England to apologise over George Bell abuse allegations

Robert Mendick The Telegraph Church of England accused of ruining reputation of Bishop George Bell over sex abuse claims 50 years ago

James Macintyre Christian Today Church of England apologises over ‘deficient processes’ and ‘pain’ in its handling of George Bell ‘abuse’ claim

(published after release of the report)

Tim Wyatt Church Times Traducing George Bell’s name was ‘just wrong’ says Carlile review

Harriet Sherwood The Guardian Anglican church ‘rushed to judgment’ in George Bell child abuse case

Olivia Rudgard The Telegraph Archbishop criticised for refusing to clear bishop besmirched by the Church

Joel Adams The Argus Victim: ‘He can say Bishop Bell wouldn’t be found guilty, it doesn’t change the facts’

Charles Moore The Telegraph Archbishop Welby’s response to 
the George Bell inquiry is shocking

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Simon D
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Simon D

Am I alone in being somewhat nauseated by the three statements in response to the report. It seems that those responsible still have no qualms about attacking those unable to defend themselves and the weasel words trying to add balance leave me cold

Jeremy
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Jeremy

Report published on a Friday afternoon, as predicted?

James Byron
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James Byron

Wow.

So, after being told in no uncertain terms that the accusations had been thoroughly investigated, that Bell was probably guilty, and that to question this was to increase the complaint’s suffering, it turns out that there wasn’t even sufficient evidence to lay charges.

And the official response to this finding? Mealy-mouthed half-apologies and a refusal to accept that Bell should never have been publicly named. I can’t even pretend to be surprised.

I hope that all those who told me, with equal force, that I was wrong not to trust the diocese will now reconsider that position.

Stanley Monkhouse
Guest

In other walks of life, resignations would follow. Or dismissals.

Michael Mulhern
Guest
Michael Mulhern

What baffles me is that, having commissioned this report from Lord Carlile, no attempt has been made to take the next logical step and weigh the possibility of guilt. Martyn Percy’s recent piece about the failure to consult Bishop Bell’s diaries (he was allegedly out of the country on one of the dates given by Carol), or to talk to surviving relatives and colleagues, means that the scope of the Carlile report has, in effective, left Bishop Bell guilty until proved innocent. As for transparency and naming, if this had happened in Ireland, or most other European states, the C… Read more »

Alan Marsh
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Alan Marsh

Despite a clear message from the foremost legal expert in the country, the church authorities are still in effect insisting that Bell was guilty – in other words they are not willing to apologise for their grotesque error of judgement. Sadly Lord Carlile’s work is wasted on such people. Let’s have some “transparency” now about the Iwerne case. And what about the Dame Heather Steel review, still unpublished?

Marc S
Guest
Marc S

No, Simon D, you are not alone – nauseated sums up my reaction too. Welby’s response does not surprise me, sadly, but I would have expected better from Warner, who quotes the presumption of innocence principle, then seems to wave it airily aside. I hope the George Bell Group feel suitably proud of their campaign defending the late bishop against this abuse of process.

Malcolm Dixon
Guest
Malcolm Dixon

No, you are not alone, Simon D. I find the responses so shocking in their cold lack of apology or compassion for the family, that I think some people should be considering their position, starting at the top.

Jeremy
Guest
Jeremy

No, Simon D, you are not alone. As for why not, just look at Bishop Peter Hancock’s sentence that begins “At the heart of this case.” In that entire sentence there is only one word casting doubt–“whether”–and that word is quite distant, in the sentence, from its very judgmental conclusion. To pile insult on injury, Bishop Martin Warner then adds, “[i]rrespective of whether [Carol] is technically a complainant, survivor, or victim….” In other words, the Bishop is ignoring one of Lord Carlile’s key recommendations. It appears that the CofE will continue to use language that assumes that a complaint is… Read more »

Alan Marsh
Guest
Alan Marsh

Are there any instances where the CofE has named living people against whom accusations have been made? Or does it only do “transparency” when someone is dead, and can’t sue?

Kate
Guest
Kate

I still maintain there is a difference between an appropriate legal / secular response to the allegations, and a Christian one. Lord Carlile has produced a report which defines the former and outlines that the Church didn’t follow it. For once I find myself in agreement with the Archbishop of Canterbury and support his decision not to apologise for the emphasis placed on supporting Carol, an emphasis I still believe is the correct, Christian response.

Bill Broadhead
Guest
Bill Broadhead

Yes, the response from the top IS shocking; but it is hardly surprising. This is all-of-a-piece with the ‘Hire them and Fire Them’ culture at Lambeth. Only it seems as if it is all one-way traffic. I doubt that we will see an archiepiscopal resignation over this one – and the refusal to accept Lord Carlile’s admonition is astonishing in its arrogance. To be fair to Martin Warner, his statement will have had to have been approved by Pyongyang, and there can be no dissent from what the Beloved Leader has decreed. Absolutely sickening. Who will now do the proper… Read more »

Michael Skliros
Guest
Michael Skliros

My contribution to this is minuscule, though slightly relevant historically. In 1950, I told my vicar, that I wanted to “go into the church”, as the saying was in those days. So I was duly interviewed by a kindly old buffer who saw right through me and out the other side but nevertheless reckoned I’d be OK as a clergyman (the term “priest” wasn’t used generally then). It wasn’t until years later that I realised I’d had 15 minutes with the legendary Bp George Bell. I can’t remember a word he said, but what does stand out in my memory… Read more »

David Chillman
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David Chillman

One aspect of this that has not been mentioned at all (as far as I can see) is the question of what will happen to the buildings etc that were previously named after Bishop Bell and were to be renamed. Is that still going ahead? If so, is not the C of E in effect still passing a judgement of guilty on Bishop Bell? The responses so far by Welby, Warner and Hancock are utterly inadequate, which is remarkable given how long they have had to read the report and plan what to say. They (and others) seriously messed up… Read more »

Marian Birch
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Marian Birch

What I find intolerable in the Archbishop of Canterbury’s comments is the remark ‘He is also accused of great wickedness’. Having read through thoroughly from beginning to end the Carlile report I find it incredible that that bald statement can still be made. At the very least the tense of the verb should have been changed.

Simon R
Guest
Simon R

Welby’s commitment to transparency is truly remarkable. So remarkable that the decision was made to release Alex Carlile’s report the day AFTER Radio 4’s Today programme was invited in to Lambeth Palace. Welby so values transparency that he decisively and deliberately manipulated the release of this report to avoid having to answer questions from an experienced journalist like Nick Robinson. This must be an example of what Welby means when he talks so easily about ‘faithfulness to Jesus Christ.’ Truly remarkable.

Rod Gillis
Guest
Rod Gillis

Re Marian Birch, “What I find intolerable in the Archbishop of Canterbury’s comments is the remark ‘He is also accused of great wickedness’. “ Consistency and attempts to stay on message are hallmarks of modern public relations. Notice that the ABC’s comment ( who knows who may have drafted it for him) attempts to set the findings of the report alongside the original accusations. This is an attempt to change the channel back from the Carlile report’s findings on the church’s mishandling of events to the allegations themselves. Notice the tense of the verb, ” is accused”. This is correct.… Read more »

Jeremy
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Jeremy

As for the conduct in the matter of the current Archbishop of Canterbury, see Lord Carlile’s report at pages 67-68, paras 262-68. Of course this assessment comes very near the end of a report that was released on a Friday. Fortunately The Times was not fooled. Their headline is “Welby criticised over handling of historic child abuse case”. In this regard, note especially paragraph 265: “Once the Bishop Bell decision was made, he [the Archbishop of Canterbury] felt passionately that the Church should be transparent.” I wonder whether the Archbishop would have “felt” so “passionately” about “transparen[cy]” had the accused… Read more »

RevDave
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RevDave

For once we all seem to agree!

Father Ron Smith
Guest

Bishop Bell’s case is not too different from many in which the Church has taken complaints against clergy as being proof – of themselves – of culpability – preferring to trust the words of the complainant against that of the accused. This happens in other Churches of the Anglican Communion (and, I’m sure, in other Churches). The sadness, in this case, is that Bishop Bell – an otherwise exemplary model of Christian virtue – has been maligned without the opportunity to speak in his own defence. Surely, without actual proof of culpability, this is immoral & unjust? Mind our Blessed… Read more »

Jo
Guest
Jo

I think some commentators are underestimating the difficulty of balancing conflicting imperatives in this case. Certainly there is rightly a desire not to see a good man defamed, but there is also rightly a desire to ensure that survivors of abuse can have the confidence to come forward knowing that they will be believed. Too often people making accusations of abuse against the powerful have been dismissed as liars or fantasists. A lot of people here are quick to condemn the ABC’s handling (and you’ll not often see me rushing to his defence) but in doing so seem to be… Read more »

Chead
Guest
Chead

What an utterly repugnant statement by Justin Welby. In response to a report that specifically doesn’t deal with the guilt or innocence of Bishop Bell, Welby goes out of his way to muddy the waters by dwelling on the accusations. Rather than deal with the CofE’s failures, (and his own), he chooses to focus on the original accusations, to try to shift the attention onto alleged actions of others, rather than the actual failures of the organisation he purports to lead. A new low for the lack of moral authority of the current Ab of C?

Susannah Clark
Guest

“For once we all seem to agree!” Hmmm, I’m not sure the comments so far quite do it for me. I agree with the issue of deeply damaging process. However, no mention or concern at all seems to have been expressed for the poor woman who is the “object” of this case – the woman who may have been abused and whose life may have been deeply harmed. I use the term ‘may’. Same as we would have used it about Savile until evidence was provided and the case made clear. We have gone to great lengths here to defend… Read more »

Richard Ashby
Guest
Richard Ashby

It’s clear from reading the report that the accusations were badly handled from the beginning and that once the accusations were in the hands of the ‘core group’, members not only lacked commitment to prioritise their participation but they lamentably failed in their duty to determine the facts. Clearly the whole exercise has been a tragic incompetent farce, made worse by the obstinacy of the Archbishop of Canterbury’s continuing stubbornness in appearing to insist that Bishop Bell was, in fact, guilty, when in the end there is still only the testimony of one person with no corroborating evidence. The curious… Read more »

Richard Ashby
Guest
Richard Ashby

Of course, what this whole episode also shows is that the Church remains unable to competently investigate complaints made against its clergy and others and that the only way forward is independent enquiry into all such allegations. Only then can justice be seen to be done.

Jeremy
Guest
Jeremy

Father Ron, to my mind “proof” connotes liability.

The testimony of a complainant is usually evidence.

Whether in this case Carol’s testimony would amount to proof is the question that the Core Group mishandled, and that was not in Lord Carlile’s remit.

In this case we may never know the answer to the question of guilt or innocence. We do have Lord Carlile’s conclusions as to process.

Jill Armstead
Guest
Jill Armstead

[the Church of England] would only be reverting to the principle upon which justice is based – that a person is innocent unless proved guilty. It says it accepts the report’s finding that its procedures were wrong. In morality and logic, it must concede that its decision to destroy Bell was wrong too. This, I had expected, was what Archbishop Welby would now do. He is a brave man and I know, from conversations with him, that he is deeply anguished both by child abuse and by false accusations of child abuse. He tries harder than most princes of the… Read more »

Victoriana
Guest
Victoriana

In other — not totally unrelated — news, the Royal Commission into Institutional Responses to Child Sexual Abuse has given its final report to the Governor General of Australia. The RC has been a very thorough five years of steady investigation into institutions caring for children that will no doubt interest readers concerned with the state of affairs around the handling of matters around Bishop Bell. The final report is voluminous at seventeen volumes. But it is practically required reading for anyone interested in institutional failures over sexual abuse instanced in some very important Anglican institutions in Australia. I append… Read more »

Alan Marsh
Guest
Alan Marsh

Charles Moore in today’s Telegraph (Saturday 16 December) is not impressed by the Church’s response to the Carlile Report. I don’t imagine Peter Hitchens will be too impressed either. Or any of those who campaigned for the Report to take place. The ABC may think his spin machine has got him off the hook, but he has succeeded only in making matters worse.

James Byron
Guest
James Byron

“This shambles has turned her case into a circus and that possibly really puts off other men and women from coming forward when they may have suffered disgusting abuse.” Absolutely right, Susannah. “Carol” was subjected to this scrutiny by the decision to publicly condemn Bell after the church took it upon itself to run a cold case investigation: a decision fueled, it appears, by Welby’s feelings. Bell should never have been named; and, as I’ve said previously, “Carol” should’ve been compensated for the bungled handling of her complaint in the ’90s and later. Here, justice for Bell would also have… Read more »

Simon Butler
Guest
Simon Butler

As an elected Officer of the General Synod, this is a disturbing and important report. The Church of England has to face up to its failings and, without being mealy-mouthed, needs to learn lessons. What matters here is not so much the reputation of a much-loved, heroic bishop – such a person must be judged by the same standard as the most incompetent, unpopular clergy person the Church of England chooses to ordain. They won’t have media clergy, outraged journalists and pro bono lawyers rushing to defend them. But they are entitled to the same robust process as George Bell… Read more »

Jo
Guest
Jo

Correction: my previous post should of course read “choose the former” rather than “choose the latter”.

Jeremy
Guest
Jeremy

To Jo and Susannah I would say that the law already encourages complainants to come forward because it permits them to remain anonymous. I believe that in this regard, UK law is quite unusual. There was a different news report yesterday of a rape prosecution that “fell apart” because the police failed to give the prosecutor exculpatory evidence. Perhaps, rather than risk innocent people being defamed, we should consider what that young man went through? As for what Bishop Bell would have thought, I’m fairly certain he would have sided with the innocent–both the victim and the wrongly accused. Of… Read more »

Ex Revd
Guest
Ex Revd

The supporters of Bomber Harris and Lord Portal *still* trying to pull down a saintly person?

James Byron
Guest
James Byron

Simon, naming the accused without proof is the last way to encourage complainants to come forward: as happened here, the accused’s supporters rally around, and subject the complaint to forensic scrutiny.

Complainants are far likelier to feel supported by the CoE listening sensitively, investigating thoroughly, and giving prompt compensation in proven cases of abuse.

Denying justice to any party only goes to ensure injustice for all.

James Byron
Guest
James Byron

Simon, naming the accused without proof is the last way to encourage complainants to come forward: as happened here, the accused’s supporters rally around, and subject the complaint to forensic scrutiny.

Complainants are far likelier to feel supported by the CoE listening sensitively, investigating thoroughly, and giving prompt compensation in proven cases of abuse.

Denying justice to any party only goes to ensure injustice for all.

Judith Maltby
Guest
Judith Maltby

Reading the Carlisle report today, the thing that struck me most powerfully is that it MUST be read alongside Dame Moira Gibb’s report on Peter Ball (June 2017). The failures (the most charitable word) of Eric Kemp in the early 1990s described in Gibb are mirrored in Carlisle (80-96): the failure to disclose, poor record keeping, making judgements on reputational grounds, investigating the complainant rather than addressing the complaint – just as with Ball – so too in this case. Taking the two reports together, I was struck by what they say about privileging reputations, first from Carlisle: (56) On… Read more »

Jo
Guest
Jo

Jeremy: all the child protection training I’ve ever had has emphasised that one of the biggest fears that prevents reporting of abuse is that of not being believed (a well-founded fear, historically).

T Pott
Guest
T Pott

So, is anybody actually going to investigate this? In a post-truth world are we invited to imagine the truth is whatever we prefer? At the least those schools etc renamed away from Bell should be renamed back . Ultimately, I fear, it will be Hollywood who decide what is truth.

Jeremy
Guest
Jeremy

Jo — I am sure that what you say is true. But that does not justify credulousness, or naming the accused publicly without a rigorous process to justify that. Which seems to be the point that Lord Carlile made in his report and at the press conference. Like it or not, false or unfounded accusations have been made in the past and will be made again. This too is a “well-founded fear, historically.” We who care about proper safeguarding, and civil justice for wrongdoers, do ourselves no favors by suggesting that our cause requires risking the reputations of people who… Read more »

Jo
Guest
Jo

Believe me, I live with the fear of false allegations every day, working in a profession where I have regular contact with children. My only point that IF, IF the cost of preserving his posthumous reputation was deterring survivors of abuse from coming forward then I took George Bell to be the sort of man who might consider that a price worth paying. It is not a call we can make on behalf of someone else. False accusations can ruin lives even if the accused is innocent, even if the charges are dropped for lack of evidence or a court… Read more »

James Byron
Guest
James Byron

If truth’s considered expendable, then, as seen by innumerable witch hunts, we can be sure that the spectre of unfounded accusations won’t stay confined to the dead.

Besides, even on a raw utilitarian level, Bell’s horrifically botched case has done nothing to encourage complainants to come forward: just the opposite.

This isn’t a dilemma about which we must wring (then wash) our hands: the case for truth and due process is overwhelming, not just for the accused’s sake, but for that of accusers. Presenting it as anything else offers a false choice.

Stevie
Guest
Stevie

Lord Carlile made it clear in his report that the Church of England’s overriding priority was protecting the Church of England, a fact which Justin Welby amply confirmed by his statement on the report published, in true spin doctor style, on Friday. In doing so he made it obvious that nothing has really changed, and that is profoundly worrying for everyone who hoped that the Church would ask itself the hard questions about what it exists for. We are left with an institution which simply exists to perpetuate itself by whatever means necessary; it is unsurprising that people are turning… Read more »

Peter Knowles
Guest
Peter Knowles

Judith Maltby’s juxtaposition of Gibb and Carlile is instructive. There is, however, a significant difference. In the Peter Ball case there was more than one complainant; and once events became public, other complainants came forward. According to Alex Carlile, once it became public that he was investigating George Bell, not one additional person came forward to make a complaint. That makes the two cases significantly different.

Jeremy
Guest
Jeremy

Was publication of the Carlile report delayed until Friday so that the subject could be changed with the announcement today of the new Bishop of London?

Alan Jesson
Guest
Alan Jesson

In all this one thing in particular worries me. The botched (or at least incomplete) “investigation”, and Archbishop Welby’s “Good acts do not diminish evil ones, nor do evil ones make it right to forget the good” hides the fact that if Bishop Bell is innocent then somebody else is guilty (if Carol’s story is true) and that person has avoided any consequences of their actions.

In all fairness a more competent, thorough investigation into the truth of the matter must be held.

Rachel Evans
Guest
Rachel Evans

Peter Knowles’ point is rather affected by the difference in time. Ball’s abuses were committed in the 70s and 80s, and on into the early 90s. The great difficulty in the Bell case is the lapse of time. “Carol” is now an elderly woman and was a small child at the relevant time. If the allegations were true, it is entirely possible that there were other complainants who have died or are in no fit state to give evidence. I’m not sure we can draw the conclusion that Peter Knowles implies. There is a separate and wider question about whether… Read more »

Jeremy
Guest
Jeremy

“Is no-one else troubled by the suggestion that the Church should have settled with a confidentiality agreement?”

Are you suggesting that the alleged perpetrator be named, in the absence of any civil or criminal finding of liability, and where (per Carlile) the case is “weak”?

It seems to me an excellent way to cause the Church to be sued for defamation.

James Byron
Guest
James Byron

Excellent point, Alan: I’ve long suspected that this may be the case; and it’s the kinda thing that a real investigation, conducted by trained professionals, could’ve uncovered. Yet another example of how due process benefits all parties.

Rachel Evans
Guest
Rachel Evans

To say there should not be a confidentiality agreement as a condition of a settlement is not the same as saying that the name of the alleged perpetrator should always, or even often, be published. Imposing a confidentiality agreement in a safeguarding case silences the victim. (Defamation is not realistically an issue – if the individual is alive and denies the allegation, there is likely to be a trial of some kind, or a CDM hearing if a cleric is in question. And the dead cannot be defamed as a matter of law.)