Monday, 2 July 2018

Gruff's Response to the Draft EHE Guidelines Consultation


8  How effective are the current voluntary registration schemes run by some local authorities? What would be the advantages and disadvantages of mandatory registration of children educated at home, with duties on both local authorities and parents in this regard?
How many local authorities are going to maintain a register and have it remain just a register. Even if the guidelines settled on just a register, and not monitoring, it would not stay like that as local authorities already claim to have powers that they don't. This happens across the country on a regular basis. The disadvantage of any kind of register is just this. It will not remain just a register.
Another disadvantage of a register is that it would not achieve anything. There are already powers in place to make enquiries if concerns are raised, and this is just how it should be. What is a register going to add to that?

9  What information is needed for registration purposes, and what information is actually gathered by local authorities? Would it help the efficacy of these schemes, and the sharing of information between authorities, if there were a nationally agreed dataset or if data could be shared by national agencies, such as DWP or the NHS?
I do not think there should be a register at all, for the resaons stated above. In addition, it's completely unacceptable to suggest sharing my children's private data in this way, when there is absolutely no indication that they are at any risk of harm.

10  Does experience of flexi-schooling and similar arrangements suggest that it would be better if the scope of registration schemes included any children who do not attend a state-funded or registered independent school full-time? If so, do you think that local authorities should be able to confirm with both state-funded and independent schools whether a named child is attending that school full-time?

Flexischooled children are registered at a school already, so should no be involved in this guidance.

11  Would the sanction of issuing a school attendance order for parental non-compliance with registration be effective, or is there another sanction which would be more useful?
There should be no registration scheme. Furthermore, such a sanction for breach of a proposed registration scheme is shocking. The very suggestion that a child's education, which should be focused on their age, aptitude and ability, would instead be doled out as some sort of punishment to the parents, is unspeakably awful, and not what I would expect of this country.

12  What steps might help reduce the incidence of schools reportedly pressuring parents to remove children to educate them at home?
Schools should focus on the needs of the school-registered child, so they get the education they deserve, rather than palming them off to a practice they don't even believe in. Every aspect of that is unbelievably poor, and it's not home educators that are doing it. Support the schools to identify the underlying issues, which will include the lack of SEN funding, and then spend the money supporting them instead of hounding home educators.

14  How effective is local authority monitoring of provision made for children educated at home? Which current approaches by local authorities represent best practice?
There is no requirement for routine monitoring, so best practice is those local authorities who respect the members of the home education community in their area and don't intrude on their lives, and simply follow up concerns when they are raised.

15  If monitoring of suitability is not always effective, what changes should be made in the powers and duties of local authorities in this regard, and how could they best ensure that monitoring of suitability is proportionate?
The powers they have should not be changed, much less increased, as local authorities cannot even use the powers they have properly. The limits of their powers to intrude into the private lives of British citizens should be made clear to local authorities. They can ensure it is proporionate by having some respect for people and the law, and simply following up concerns when raised. Just think of all the money that would save, assuming people are fulfilling their lawful duties unless evidence says otherwise.

16  Should there be specific duties on parents to comply with local authorities carrying out monitoring if such LA powers and duties were created, and what sanctions should attach to non-compliance?
No. Non-compliance should be encouraged where measures, such as intruding into children's homes and lives without warrant, are disproportionate and unprecedented under British law.

17  Is it necessary to see the child and/or the education setting (whether that is the home or some other place), in order to assess fully the suitability of education, and if so, what level of interaction or observation is required to make this useful in assessing suitability?

There should be no requirement for local authorities to fully assess the suitability of provision unless concerns are raised. My children's education takes place in parks, museums, the supermarket, theatres, festivals, online, at the beach, and on farms, what would the benefit of coming into my home be?

18  What can be done to better ensure that the child’s own views on being educated at home, and on the suitability of the education provided, are known to the local authority?
Why should the local authority want to know this? Why would it be acceptable for them to try and know this? I am my child's advocate and protector. I support the most suitable education for them. I already know their views, and they want to be home educated, currently, and they also want to not have random strangers coming into our home to interfere with that.
You would think that if the government are concerned about getting the views of home educated children, they would be included on the drop down box at the start of this consultation.

19  What are the advantages and disadvantages of using settings which are not registered independent or state schools, to supplement home education? How can authorities reliably obtain information on the education provided to individual children whose education ‘otherwise than at school’ includes attendance at such settings as well as, or instead of, education at home?
How we educate our children is the concern of us and our children. The advantages and disadvantages of using settings that are not schools to achieve this will vary with each individual child, sometimes from day to day. Authorities should not be obtaining information on this about individual children as it is a massive intrusion into their privacy.

20  What are the advantages and disadvantages of using private tutors to supplement home education? How can authorities best obtain information on the education provided to individual children whose education at home includes private tuition, or whom attend tuition away from home?
Again, the advantages and disavantages of this will vary between children, with their interests, their aptitudes, their learning styles. The great things is, with home education, if it suits one of them this week, we can use a tutor. If it stops suiting them next week, we can stop.
Again, authorities should not be attempting to breach my children's privacy and obtain this kind of information.

22  What might be done to improve access to public examinations for children educated at home?
It would be good if local authorities made it easier for home educated children to access exam centres. However, if this came with any kind of strings attached we'll continue to organise and pay for it ourselves.

23  What good practice is there currently in local authority arrangements for supporting home-educating families? Should there be a duty on local authorities to provide advice and support, and if so how should such a duty be framed?
There should be no such duty, as their 'advice' may well come from their own lack of experience of home education and being required to then give this advice could have a bad effect on home educators and their children. A helpful and cheap option would be to signpost new home educating familes to local home education groups, who actually know things about home education.


24  Should there be a financial consequence for schools if a parent withdraws a child from the school roll to educate at home?
No
What would this achieve? Parents have the right and duty to be able to deregister, so putting any consequence in place for the school will just incentivise people in a position of power to pressure these parents to make decisions about their child's education based on things that are not whether the education is suitable for the child. Where is the focus on the child's needs in these guidelines?

25  Should there be any changes to the provision in Regulation 8(2) of the Education (Pupil Registration) (England) Regulations 2006 requiring local authority consent to the removal of a child’s name from the roll of a maintained special school if placed there under arrangements made by the local authority?
No parents should have to get permission to deregister. It puts a barrier in the way of them fulfilling their duty to provide a suitable education for their individual child.

27  What data are currently available on the numbers of children being educated at home in your local authority area?
I don't know. What data is there about the number of children who are vegetarian in my area? Why is it the local authority's business? What is the precedent for this level of intrusion into our privacy?

29  Comments on Section 1: What is elective home education?
What is elective home education?
:
Flexischooled children are on a school roll, so should not be in this guidance.

30  Comments on Section 2: Reasons for elective home education - why do parents choose to provide it?
The reasons for parents to home educate their children are as varied as the children. Why is this relevant? Putting any kind of list of this sort into guidance gives it legitimacy, and could influence people's thoughts of what are good and bad reasons, whereas the local authority wouldn't even know the child in order to know what might be a good reason for them personally.

31  Comments on Section 3: The starting point for local authorities
Suggesting that people wouldn't argue that parents should be able to exercise their right to home educate children with absolutely no independent oversight, is purely someone's opinion. I would argue exactly that. What is the point of Ofsted reports, the independent oversight for schools? They are to report the findings back to the parents of the children, as the parents are the service users. I don't need someone to report back to me about what I am doing, as I already know. People absolutely should be able to exercise their parental rights in their day to day lives without any independent oversight at all, whether that is feeding, clothing, entertaining or educating their child.

32  Comments on Section 4: How do local authorities know that a child is being educated at home?
Sharing my children's data is not lawful. I do not give consent. They do not give consent. Stick to the law which is to identify children who are not receiving an education. Mine are.

33  Comments on Section 5: Local authorities’ responsibilities for children who are, or appear to be, educated at home
We do not want annual contact with the local authority. We do not need annual contact with the local authority. It would cost a lot of money, achieve nothing, and be a huge and unprecedented invasion of our privacy.

34  Comments on Section 6: What should local authorities do when it is not clear that home education is suitable?
LA action when not clear if home education is suitable: Section 2.8 of the current guidelines makes it clear. This should be kept.

35  Comments on Section 7: Safeguarding: the interface with home education
It has been shown that home educated children are not at higher risk of abuse than schoolchildren. It would not be acceptable to target them in the way the Section 7 does. The repeated suggestion of such a risk drives a wedge between local authorities and home educating parents.

36  Comments on Section 8: Home-educated children with special educational needs (SEN)
SEN:

The same regulations should apply to all children who are home educated.

37  Comments on Section 9: What do the s.7 requirements mean?
Section 3.13 of the current guidelines should be kept in any new guidance, as it helps local authorities understand how different home education can look for individual children.

38  Comments on Section 10: Further information
Local authorities should not be being encouraged to have more oversight of home education than needed, as it shifts some liability onto them.

39  Comments on Section 1: What is elective home education (EHE)?

The requirement of an education being suitable to a child's age, aptitude, ability and special needs is the only thing that should be focused on. The law already
requires this, and so the focus is on the child's needs. Any stated aim to make a child's education 'world class' is taking the focus off the child and putting it onto some vague concept.

40  Comments on Section 2: What is the legal position of parents who wish to home educate children?
As already detailed, the focus of the suitability should remain on the child. Any attempt to impose a local authority's, school's or government's definition of this will take the focus off the child and make it much harder to continue fulfilling the suitability for their individual needs.

41  Comments on Section 3: So what do I need to think about before deciding to educate my child at home?
Children's needs change day to day, sometimes hour to hour. One of the huge advantages of home education is that we can adapt to this, unlike schools. Any suggestion that we should be planning detailed curricula in advance cuts off our ability to focus on our individual child's needs.


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