Durell Barnes explores how the inspection framework has raised levels of risk consciousness

The language of risk has become familiar in all schools with the advent of the current framework. There is more awareness of ‘risk assessment’, ‘risk management’, ‘risk appetite’ and ‘risk awareness’. I’d like to coin another term –‘risk conscious’ – to encapsulate the way in which governors, leaders, managers, teachers, support staff and even parents and pupils look at aspects of school life with a constant consciousness of risk. This is an almost entirely beneficial development, although it also raises some important questions.

From the inception of the current framework, the chief inspector emphasised the central roles of governance and leadership in school improvement. Guidance indicates that risk management, focused on pupil wellbeing, should be at the heart of school culture, constantly reviewed by self-evaluation in a process of dynamic quality assurance. The Independent Schools Inspectorate (ISI) Inspection Framework paragraph 45 states: “The proprietor must ensure that leaders and managers have the skills, knowledge and understanding to actively promote the wellbeing of all pupils through taking a strategic, comprehensive and inclusive approach to identifying and managing the risk of harm to pupils’ wellbeing. As a result, leadership must safeguard and promote the wellbeing of pupils through effectively identifying risk of harm and take appropriate action to reduce risks that are identified. Pupils’… health needs must be met, and their physical and emotional wellbeing actively promoted.”

Prior to the implementation of the framework, there were some concerns about the three level approach to school culture as outlined in the Handbook. This referred to level 1, where all appears well on the surface, and level 2 where there are some ripples under that surface, but essentially things are gong well. It also identified level 3, which might be more concerning.  The ISI Handbook paragraph 16 states: “Some members of the school community (and this may be a small number) are impacted by negative and damaging behaviours and attitudes such as racism, misogyny and bullying. Experience may be ‘secret and separate’ and evidence may be harder to see. This aspect of school life may be hidden from view and requires very effective mechanisms in place for hearing from pupils and staff. Evidence may be located in the safeguarding, behaviour, bullying and complaints logs… in the small negative percentages in questionnaires and negative comments included among a larger number of positive comments. Deep listening and noticing are required to access this level.”

Some feared that this approach might mean that inspectors would be easily distracted from excellent provision in a school by negative feedback from very small minorities or individuals. I don’t think the ISI should apologise for bearing in mind the wellbeing of schools’ most vulnerable pupils. There has been some evidence of fairly dogged pursuit of evidence when concerns arise on inspection, but reports don’t, on the whole, indicate that desperately unhappy children are present in most of our schools. We would know more about this if the inspectorate published the rich seam of data which it possesses in terms of the statistical returns to pre-inspection questionnaires completed by pupils, parents and staff. Nonetheless, this aspect of inspection is having a beneficial effect in the sense of reinforcing that a school’s priority, the efforts of its leaders and the monitoring and oversight of its governors should be focused on the wellbeing of all pupils, not many or most or nearly all. And this has a significant impact on risk management.

Analysing reports, we can see that there are layers of risk, and some are not new as such, but have perhaps new prominence and new expectations around them. There are those associated especially with health and safety in particular places and activities on and off the premises. Effective risk assessment includes lessons from near misses and things which might have gone wrong. Schools which are adept in this area have constant review processes in place to ensure that after an activity, trip or visit, the risk assessment is checked to see if it covered every eventuality and if anything was learnt, and it is updated accordingly before future use.

More prominent now are wellbeing risks associated particularly with vulnerable pupils, who must be considered as part of any risk assessment (what are the particular issues pertaining to them which must be borne in mind in organising this activity/visit/trip or safeguarding this location, etc?). There also have to be generic risk assessments for their needs more generally, as well as in particular instances. There is no fixed list of who these might be, it will depend on the school’s context, and risk assessment – like safeguarding – must be contextual. One report commends a school because “leaders have a comprehensive understanding of the contextual risk of the school” and another states “leaders liaise effectively with local agencies to monitor risks in the locality”. The vulnerable are likely to include groups who come under the Equality Act, people who might be in a minority, for example in terms of their culture, race, ethnic origin, gender, sexuality or any special educational need or disabilities, etc.

A new area of focus is new situations, not just new arrangements for boarding, or supervision, or something of that kind, but also more sophisticated things. For example, one school was commended for thinking about the risks for some vulnerable pupils associated with the school’s new focus on oracy. In another, a school was castigated for not assessing the risk of appointing new staff to a boarding house.

Inspection reports also draw attention to the need for risk assessments to consider unintended consequences, an area where many schools could benefit from scenario planning. Sometimes this can be quite subtle as in the school where it feared potential problems arising from an expanded co-curricular programme: “Leaders ensure that activities are widely available to pupils and regularly check for any unintended consequences of the programme by ensuring that pupils maintain a healthy balance between their work and other activities.”

And one school is commended for its awareness of pupils who might be difficult to reach: “Leaders constantly assess and mitigate risk to pupils’ education and wellbeing. They have a sharp awareness of the need to identify pupils who have unrecognised anxieties or concerns.”

The consequences of failure in this area can be starkly described in reports: “Risk assessments are insufficiently detailed and systematic risk management and review [are] not established. Staff are not consistently trained in the completion of risk assessments… Some aspects of risk management and safeguarding are not efficiently overseen by [governors] and leaders do not discharge their responsibilities in relation to those.”

The potential reputational and financial risks of such reports is likely to concern governors. They may take comfort from reports which indicate how the responsibilities are carried out, as in this example: “Governors appropriately challenge and support leaders through the effective scrutiny of policy and the oversight of procedures. Governors are known by staff and are a visible presence through their joint learning walks with senior staff and frequent visits. They work closely with leaders to identify and mitigate risk, review policies and procedures and evaluate the performance of the school to ensure that the standards are met.”

We see increasing references in reports to “a strategic approach to risk” and “strategic risk assessment” and this reflects developments in schools. It’s not absolutely clear, however, what is meant by this. This report commends the approach: “Leaders take a strategic and measured approach to identifying and managing risk. Staff with responsibility for risk assessment have appropriate training. They write detailed and thorough risk assessments for the premises and for school trips and activities that clearly identify potential hazards. The risk register is updated regularly.”

Here we have an assertion about strategy, a description of efficient risk management and reference to the risk register. Risk assessment and the risk register are very different things and in the limited space available in an inspection report can assume a false connectivity.

Now that the inspection framework has played its part in increasing proactive risk consciousness in schools it is important for the sector to develop a clear understanding of what constitutes strategic risk assessment. The inspectorate could assist further with this by sharing any training available to team inspectors about making judgements about layers of risk (health and safety focus, wellbeing focus and strategic focus) or by making it a focus of the Additional Inspector scheme which is due to be introduced. This could be a further benefit of the peer review element of inspection which, properly applied, can help embed risk consciousness in our schools.

Durell Barnes is head of governance at RSAcademics and chair of the Independent Schools’​ Bursars Association inspections oversight committee.

Durell Barnes