*NOW CLOSED* Respond to the Education Workforce Council (Wales) consultation

The ​‘New registration categories for the Education Workforce Council’ is a piece of legislation that will affect hundreds of churches across Wales if it passes in it’s current form. Welsh Government is looking to increase the number of youth workers who are registered for the Education Workforce Council, with youth workers in faith settings now being considered for registration also.

We at the Evangelical Alliance in Wales believe that church-based youth workers should be exempt from this registration, as there are complexities around how churches might implement standards of ​‘professionalism’, and also how transferrable the Council’s notion of teaching quality is for church-based youth groups. This proposal also raises important questions of religious freedom if churches are required to register youth workers with the government, and they are then additionally regulated according to standards set by the government. 

In this guide we have provided some suggested points to respond to the consultation which outlines our concerns and proposals. Do feel free to use the points provided and respond in your own words. Note also that we have not provided points for every question as not only is it not essential to do so, and we consider the primary questions for churches and Christian youth ministry organisations to respond to are Questions 8, 10 & 14.

*PLEASE NOTE THAT RESPONSES CLOSE ON THE 24^TH OF MAY 2022*

Questions 1 – 7 aren’t relevant to churches so therefore we’re choosing not to answer them. If you are interested in viewing these questions and have personal experience relating to its content, visit this page and click ​‘Download the respond form’. 

*PLEASE NOTE THAT RESPONSES CLOSE ON THE 24 OF MAY 2022*

Questions 1 – 7 aren’t relevant to churches so therefore we’re choosing not to answer them. If you are interested in viewing these questions and have personal experience relating to its content, visit this page and click ​‘Download the respond form’. 

Question 8 – Do you agree registration should be broadened to include all paid youth workers and youth support workers regardless of the setting they work in?

We suggest that you answer ​‘no’ to this question. 

In the section following which allows for supporting comments, some points you may wish to add include:

Due to the aims of the legislation covering such a broad group of people, it fails to appreciate the many nuances of different people’s contexts and environments.

Church-based youth work should continue to be exempt from the expanded registration, as the ​‘standards’ required in, for example, independent schools look completely different to those of a church-based youth worker, so any grouping of these settings in registration is unhelpful and unnecessary.

• On page 7 of the consultation document in paragraph 13 there are many points that are either not necessary to youth workers in churches, or mistakenly aims to group together church youth workers with those in contexts that contrast greatly.
• “Provide parity for those working in similar roles” (p.7). We do not consider it is appropriate to compare church based youth work to youth work in other settings.
• The content that a church-based youth worker would be teaching is based on biblical beliefs, so any assessment of ​“standards” (p.12) relating to the teaching will be either uninformed or lacking any relevance from a secular body.
• The assessment of content as a measure of regulating the work of church youth workers threatens to place the authority of the state over the freedom of churches to teach what they believe. 

Question 9 isn’t relevant to churches so therefore we’re choosing not to answer it. If you are interested in viewing this questions and have personal experience relating to its content, visit this page and click ​‘Download the respond form’.

Question 10 – Do you think people who are paid and delivering youth work, but who are not qualified, should register?

We suggest you answer ​‘no’ to this question.

In the section following which allows for supporting comments, some points you may wish to add include:

Similar to question 8, we believe that paid youth workers in church settings who are not qualified do not need to register for the Education Workforce Council.

• This expanded registration would affect hundreds of churches across the whole of Wales, placing a further burden on the already stretched resources of churches. It would also create a hurdle and act as a deterrent for an already incredibly limited pool of people hoping to become church-based youth workers.
• It is worth noting that it is already necessary, and which we wholly support, that church based youth workers, as with all youth workers, are checked with the Disclosure and Barring Service and that is up to date so as to ensure young people are safeguarded. 

Question 11 – 13 aren’t relevant to churches so therefore we’re choosing not to answer them. If you are interested in viewing these questions and have personal experience relating to its content, visit this page and click ​‘Download the respond form’. 

Question 14 – Please share with us any thoughts you may have on our future work on volunteers in the youth work sector.

The current proposals do not include volunteers in the categories of youth workers who would need to register, however, the Welsh Government are inviting views on this.

You may wish to make some of the following points in response to this question:

• Similarly to church-based youth workers, church-based volunteers should be protected from needing to register for the Education Workforce Council.
• The same concerns relating to the role of state authorities regulating church youth workers apply whether they are paid or unpaid. The state should have no role in regulating what is taught in church settings, or requiring those who do so to register with it. 
• Volunteers are non-contracted in their role, frequently help on an intermittent or occasional basis, and should not be viewed in the same category as paid and qualified youth workers. 
• Other than the obvious requirement for a DBS check when working with young people or children, registration of volunteers to the Education Workforce would be unnecessary and an excessive exercise.

Question 15 – 24 aren’t relevant to churches so therefore we’re choosing not to answer them. If you are interested in viewing these questions and have personal experience relating to its content, visit this page and click ​‘Download the respond form’.