Prevention of Future Deaths reports · 2024

Elizabeth McCann

Regulation 28 report to prevent future deaths, reference 2024-0288, written 29 May 2024. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report29 May 2024
Reference2024-0288
DeceasedElizabeth McCann
CoronerAlison Mutch
Coroner areaManchester South
CategoryOther related deaths
Sourcejudiciary.uk record · original PDF
Responses published5

The report

Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.

REGULATION 28:  REPORT TO PREVENT FUTURE DEATHS 

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

THIS REPORT IS BEING SENT TO:  1) Ministry of Justice 2) Home 
Office 3) Greater Manchester Police 4) Department of Health and Social 
Care 5) Pennine Care NHS Foundation Trust 

1  CORONER 

I am Alison Mutch, Senior Coroner, for the coroner area of South 
Manchester 

2  CORONER’S LEGAL POWERS 

I make this report under paragraph 7, Schedule 5, of the Coroners and 
Justice Act 2009 and regulations 28 and 29 of the Coroners 
(Investigations) Regulations 2013 

3 

INVESTIGATION and INQUEST 

On 26th  August 2022 I commenced an investigation into the death of 
Elizabeth Sarah Jayne McCann. The investigation concluded on the 19th 
April 2024 and the conclusion was one of unlawful killing. The medical 
cause of death was 1a) Ligature strangulation. 

4  CIRCUMSTANCES OF THE DEATH 

Elizabeth Sarah Jayne McCann was raped and murdered on 25th  August 
2022 at the home address of her murderer, 91 Manchester Road, Ashton-
under-Lyne. Her murderer was on a life licence at the time and on the 
Sex Offenders Register as a consequence of his convictions in 2009 for 
rape, sexual assault and Section 20 assault. 

He had met Elizabeth through the Health and Wellbeing College run by 
Pennine Care. Whilst he was on licence, he had been signposted by 
Probation to the Wellbeing College run by Pennine Care NHS Foundation 
Trust. The College and Probation had previously agreed the college 
would accept some Probation clients. 

There was a failure by the college and Probation to set up a clear, 
documented system for how this would work and how risk would be 
managed. Within the college there was a failure to ensure that there was 
a system for how this information from Probation would be received and 

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 scrutinised effectively. There was a failure by the college to set up a risk 
management system for attendees such as him. As a consequence of 
these failures her murderer joined the college without any risk 
assessment having been undertaken and without the college recognising 
the risk he posed. It is probable that had there been an effective system 
in operation that: either he would not have been accepted at the college 
at all or would not have been accepted without a stringent plan to 
manage his risk, these failures by the college and Probation probably 
contributed to Elizabeth's death. 

It was known to Greater Manchester Police (GMP) and Probation that he 
posed a risk in certain circumstances. The areas of focus for an increase 
in risk were alcohol use, lone females, intimacy and rejection. Whilst he 
was being supervised under licence and in accordance with the Sex 
Offenders Register management, both his Probation Officer and Police 
Offender Manager had caseloads far in excess of what were safely 
manageable. This was because Greater Manchester Police had failed 
over a period of years to adequately staff the Sexual Offender 
Management Unit and the Probation service did not have sufficient 
probation officers available due to recruitment challenges. 

Whilst managing him in March 2022, he disclosed to his Police Offender 
Manager that he had recently had a small relapse with alcohol but 
Change Grow Live had declined to assist him. That information was not 
shared with Probation and not investigated further probably due to the 
excessive workload of the Police unit. 

On 6th  April he disclosed to Probation that he had met a woman and 
believed it would develop into an intimate relationship. The information 
was shared that day with Greater Manchester Police. There was a failure 
by Greater Manchester Police and Probation to action that information. In 
addition, the officer working for Greater Manchester Police who was 
spoken to failed to appropriately record the information. This was 
probably due to the excessive workload in the unit against the staff 
numbers. 

On 12th  April when it was indicated that the woman had decided not to 
pursue the relationship with him, Police and Probation failed to exhibit 
any professional curiosity as to whether the relationship was as described 
and in particular failed to speak to the woman; and failed to recognise 
that the basis on which his risk had been assessed was changing. There 
was a failure to consider if additional work needed to be undertaken with 
him. It is probable that the large caseloads contributed to the lack of 

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 professional curiosity as it meant there was little time available to 
consider the emerging picture. It is possible that this lack of action by 
Greater Manchester Police and Probation contributed to Elizabeth's 
death. 

In July 2022 he approached a woman he had met at college at a public 
house in Ashton. He was under the influence of alcohol. He touched her 
and tried to kiss her without her consent. She reported the incident to the 
college Senior Management team because she was very concerned 
about the incident. The college Senior Manager failed to recognise it was 
a safeguarding issue and spoke to him informally. 

On 18th  August 2022 she made it clear to him that she did not want a 
relationship with him. Had there not been a failure by the college and 
Probation to set up an effective referral system and had there not been a 
failure by the college to set up a system for dealing with emails from 
Probation then it is probable the college would have known his status and 
have escalated the event to Probation and recognised it as high risk in 
relation to his behaviour. It is probable that the college would have taken 
action that would have prevented him from accessing the college after the 
reported incident. It is probable that Probation would have recognised this 
was a deteriorating situation, reassessed risk and taken steps to reduce 
the risk he posed to the public and in particular to women. None of these 
actions happened as a consequence of the failure to have an effective 
system in place to manage high risk referrals such as him. As a 
consequence, he continued at the college and Probation were unaware of 
these events and no action was taken by them. 

It is probable that had there not been a failure to share the July 2022 
incident which was caused by the previous failures Elizabeth McCann 
would not have died on the day she did. 

5 

CORONER’S CONCERNS 

During the course of the inquest the evidence revealed matters giving rise 
to concern. In my opinion there is a risk that future deaths will occur 
unless action is taken. In the circumstances it is my statutory duty to 
report to you. 

The MATTERS OF CONCERN are as follows.  – 

1.  The inquest heard evidence that the probation staff were carrying 
significant caseloads. This was due to challenges in recruiting 
sufficient staff. The evidence was that there is still a national 

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 shortage of probation officers. Steps have been taken to recruit 
and train further probation officers which provides some assistance 
but means that overall, a significant number of probation officers 
are young in service and experience. 

2.  The evidence before the inquest was that it was important that 
newly qualified probation staff were closely supervised and 
supported by their managers. Without that supervision 
performance issues identified by the trackers were not being 
tackled. Ensuring this had been and was challenging as the 
number of staff line managed by senior probation officers had 
been too high. This was being addressed but was only achievable 
if sufficient senior staff were retained. 

3.  Evidence before the inquest was that if probation referred clients 
under supervision to places such as the Health and Wellbeing 
College this would, if not implemented effectively pose a significant 
risk to vulnerable users of such institutions. If referrals were made 
without a protocol being in place that dealt with managing risk then 
the risk posed increased further. 

4.  Clear Information Sharing protocols between Probation and such 
groups as drug and alcohol services were limited. Without clear 
agreements understood by both sides there was a significant risk 
that crucial information that impacted risk assessments would not 
be shared. 

5.  The inquest was told that nationally a significant number of police 
forces were struggling to adequately staff their Sexual Offender 
Management Units. As a consequence, the level of supervision of 
sex offenders in the community was being risk managed posing a 
risk to communities. 

6.  In the case of Greater Manchester Police, the staffing issues had 
been known by senior managers for a number of years (many 
years before Covid) and a decision taken to risk mange far below 
the appropriate staffing numbers taken. The consequence was that 
the staff in the unit could not effectively manage their caseloads 
that were far in excess of the recommended level. The numbers in 
the unit were increasing but the caseloads were still high. 

7.  The GMP investigation into their role in relation to Elizabeth’s 
death was poor in quality and there was no evidence that any 

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 senior officer had considered the report. The inquest was told that 
the quality and lack of referral upwards of a report was not unique 
to Elizabeth’s case. 

8.  There was no evidence before the inquest of any professional 
curiosity by senior GMP officers as to the role of GMP and if 
lessons could be learnt. It was unclear as to why senior officers 
were unsighted. 

9.  It was accepted that there needed to be a level of professional 
curiosity by staff dealing with high-risk offenders such as in this 
case and that training for probation officers and police staff needed 
to reinforce that. 

10. The inquest was told that Health and Well Being Colleges could 
provide effective support for the communities they served. They 
were a national model. However, if they were to be open to all it 
was essential that they were structured in such a way that risk was 
effectively managed with clear, documented protocols understood 
by all in place. There was also a need for effective information 
sharing protocols and effective well understood safeguarding 
provisions. 

11. The Health and Wellbeing College in Tameside served 5 boroughs 
of Greater Manchester and was run by the Mental Health Trust. It 
was accepted by the Trust that the investigation report was of poor 
quality and an opportunity to learn lessons missed. This included 
the management structure, oversight, lack of an information 
sharing protocol with probation, the systems in the college for 
managing risk and sharing information and compliance with 
GDPR. 

6  ACTION SHOULD BE TAKEN 

In my opinion action should be taken to prevent future deaths and I 
believe you have the power to take such action. 

7  YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the date 
of this report, namely by 24th  July 2024. I, the coroner, may extend the 
period. 

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 Your response must contain details of action taken or proposed to be 
taken, setting out the timetable for action. Otherwise you must explain 
why no action is proposed. 

8  COPIES and PUBLICATION 

I have sent a copy of my report to the Chief Coroner and to the following 
Interested Persons namely 1) 
 on behalf of the family and 
2) Tameside Metropolitan Borough Council, who may find it useful or of 
interest. 

I am also under a duty to send the Chief Coroner a copy of your 
response. 

The Chief Coroner may publish either or both in a complete or redacted 
or summary form. He may send a copy of this report to any person who 
he believes may find it useful or of interest. You may make 
representations to me, the coroner, at the time of your response, about 
the release or the publication of your response by the Chief Coroner. 

9  Alison Mutch 

HM Senior Coroner 

29.05.2024 

6

Responses

5 responses published against this report on judiciary.uk. A response is a body's written reply to the coroner's concerns; publication is at the discretion of the Chief Coroner's office, so an absent response does not mean nobody replied.

Response from Dhsc (PDF)
From Baroness Gillian Merron  
Parliamentary Under-Secretary of State for  
Patient Safety, Women’s Health and Mental Health 

39 Victoria Street  
London  
SW1H 0EU 

5th August 2024 

Our Ref: 

Alison Mutch 
Senior Coroner 
Coroner's Court 
1 Mount Tabor Street 
Stockport 
SK1 3AG 

By email: 

Dear Alison, 

Thank you for your Regulation 28 report to prevent future deaths dated 29 May 2024 
about  the  death  of  Elizabeth  Sarah  Jayne  McCann  and  I’d  like  to  thank  you  for 
agreeing  an  extension.    I  am  replying  as  the  newly-appointed  Minister  with 
responsibility for mental health and patient safety.      

Firstly,  I  would  like  to  say  how  saddened  I  was  to  read  of  the  circumstances  of 
Elizabeth’s death and I offer my sincere condolences to  her family and loved ones. 
The circumstances your report describes are concerning and I am grateful to you for 
bringing these matters to my attention.  

Most of the concerns you have raised are matters for the Ministry of Justice, Home 
Office and Greater Manchester Police and I understand that these organisations will 
be responding to your report. 

You have also raised concerns about health and wellbeing colleges and, in preparing 
this  response,  Departmental  officials  have  made  enquiries  with  NHS  England  and 
Pennine Care NHS Foundation Trust. I understand that the Trust is also in the process 
of responding to you directly.  

The  Health  and  Wellbeing  College  in  Tameside  is  based  on  the  ‘recovery  college’ 
model  which  takes  an  educational  approach  to  developing  people’s  strengths  to 
enable them to understand their own challenges, become experts in their own self-
care and develop the skills and confidence to manage their own recovery.  Courses 
are  co-produced,  co-delivered  and  co-received  by  people  with  personal  and 
professional experience of mental health problems. 

In  this  instance,  it  is  clear  that  information  sharing  protocols  and  safeguarding 
provisions within the College were not effective or well enough understood. 

A15 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 I  have  been  informed  that  prior  to  your  report  being  issued,  the Trust had  already 
commissioned  an  external  review  of  the  Health  and  Wellbeing  College,  which  is 
currently  ongoing. 
  The  Network  Director  of Quality,  Nursing  and  Health 
Professionals for the South Network is working with the team there in relation to risk 
management systems and processes. 

The Trust recognises that, at the time of the incident the College did not have a clear 
written protocol in place to manage risk. As an educational establishment the College 
did not have plans or processes in place to communicate effectively with other teams 
within the Trust such as the clinical teams or externally to organisations such as the 
Probation Service about the risk of harm occurring to others.  The College is bound by 
Trust policies in relation to safeguarding and the College team did have access to and 
used Trust internal incident reporting systems. 

Since  the  incident  occurred,  the  College  has  developed  a  standard  operating 
procedure outlining  steps  and  processes 
leads  and 
administrators in  relation  to information  required  by  the  College  for  every student's 
successful  enrolment  to  commence. These  checks  include  self-disclosure  by 
prospective  students relating  to  activity  and  engagement  with  other  agencies  in 
addition to checks against internal clinical systems.  

required  by  College 

Any  student  with  an  open  referral  to  another  agency  will  be  requested  to  give 
permission to contact and explore issues of risk with that agency as appropriate. For 
any student with open and ongoing engagement with a clinical team, College leads 
will have full access to the Trust's patient record systems to enable a review of  any 
risks associated with the student. College leads are required to liaise with the clinical 
team for a position on whether enrolment is appropriate for the individual. 

It  is  expected  that  the  ongoing  review will  analyse  these  new  risk  management 
protocols and provide the Trust with assurance or recommendations.   

The  Trust's  safeguarding  leads  have  supported  College  leads  in  developing 
more robust safeguarding policy for enrolees at the College.  The safeguarding team 
has provided additional learning sessions to college staff and volunteers and there is 
a  rolling  programme  of  support  in  place.  College  leads  report  compliance  with 
safeguarding  training  through  newly  established governance  systems  and  are  also 
receiving support to access and utilise core governance processes such as reporting 
and management of risk in accordance with the expectations within the organisation.    

Following your inquest, a review of the process followed in this case was requested 
by the Trust’s Executive Director of Quality, Nursing and Healthcare Professionals to 
identify  learning. This  review  made  recommendations in  relation  to  strengthening 
triggers for an investigation, more robust systems for the recording of decisions made 
in  relation  to  commissioning  investigations, agreement  of  scope  and  terms  of 
reference and 
beyond 
arrangements already in place. It was also recommended that the quality assurance 
process for the presentation and ratification of investigation findings could be reviewed 
and strengthened.  

ensuring training 

investigators 

and skills 

of 

A16 
 
 
 
 
 
 
 In response, the Executive Director of Quality, Nursing and Health Professionals has 
introduced new  governance  processes  including  a  Central  Safety  Summit  with  an 
approved  scope  and  purpose  agreed  at  Board  level  with  reporting  into  the  Trust’s 
for  continuous  oversight  at  a  Non-Executive Director 
Quality  Committee 
level. Progress in relation to the embedding of these new structures will form part of 
the  Trust’s  regular discussions  with  integrated  care  board  colleagues  and  reporting 
within the quarterly compliance schedule. 

I hope this response is helpful. Thank you for bringing these concerns to my attention.  

All good wishes, 

BARONESS GILLIAN MERRON 

A17
Response from Gmp (PDF)
%

GREATER MANCHESTER

Stephen Watson QPM
Chief Constable

Alison Mutch

HM Senior Coroner
Coroner's Court

1 Mont Tabor Street
Stockport

SK1 3AG

19" July 2024

Dear Ms Mutch,

Thank you for your report dated 29" May 2024 in respect of the tragic unlawful killing of
Elizabeth Sarah Jayne McCann pursuant to Regulations 28 and 29 of the Coroner's
(Investigations) Regulations 2013 and Paragraph 7, Schedule 5 of the Coroners and Justice
Act 2009.

The findings evidenced within your report are most regrettable and speaks to the failure of
Greater Manchester Police and various agencies to pull together to do the right thing.

Having carefully considered your concerns and the evidence provided at the inquest | make
the following observations to address the matters you have raised. | will address points 1-4 as
one:

1. The inquest heard evidence that probation staff were carrying significant caseloads.
This was due to challenges in recruiting sufficient staff. The evidence was that there is
still a national shortage of probation officers. Steps have been taken to recruit and train
further probation officers which provides some assistance but means that overall, a
significant number of probation officers are young in service and experience.

2. The evidence before the inquest was that it was important that newly qualified
probation staff were closely supervised and supported by their managers. Without that
supervision performance issues identified by the trackers were not being tackled.
Ensuring this had been and was challenging as the number of staff line managed by
senior probation officers had been too high. This was being addressed but was only
achievable if sufficient senior staff were retained.

3. Evidence before the inquest was that if probation referred clients under supervision
to places such as the Health and Wellbeing College this would, if not implemented
effectively pose a significant risk to vulnerable users of such institutions. If referrals
were made without a protocol being in place that dealt with managing risk, then the risk
posed increased further.

AQ

4. Clear Information Sharing protocols between Probation and such groups as drug and
alcohol services were limited. Without clear agreements understood by both sides there
was a significant risk that crucial information that impacted risk assessments would not
be shared.

These four matters are primarily for the Ministry of Justice to reply to on behalf of the Probation
Service, however, to promote effective communication between agencies and improve
awareness of any challenges, the Head of Public Protection at Greater Manchester Police and
the Head of Public Protection at Greater Manchester Probation service commenced monthly
meetings in 2023.

5. The inquest was told that nationally a significant number of police forces were
struggling to adequately staff their Sexual Offender Management Units. As a
consequence, the level of supervision of sex offenders in the community was being risk
managed posing a risk to communities.

This is primarily a matter for reply by the Home Office on behalf of all police forces, however,
it is worth noting that the provenance for the evidence presented at inquest is the Independent
Review into the Police-led Management of Registered Sex Offenders in the Community,
authored by Mick Creedon QPM which was published in 2022. In particular, paragraphs 26 to
28 outline the implications on policing of volume changes, the proliferation of the internet,
increased societal and criminal justice awareness around sexual offending and the introduction
of new offences.

6. In the case of Greater Manchester Police, the staffing issues had been known by
senior managers for a number of years (many years before Covid) and a decision taken
to risk manage far below the appropriate staffing numbers taken. The consequence was
that the staff in the unit could not effectively manage their caseloads that were far in
excess of the recommended level. The numbers in the unit were increasing but the
caseloads were still high.

The Sex Offender Management Unit (SOMU) sits within GMPs Public Protection Division and
is responsible for centrally managing all registered sex offenders (RSOs) within the community.

In 2018, due to increasing RSO to Offender Manager ratios, Chief Officers made a policy
decision to only visit and conduct Active Risk Management System (ARMS) assessments for
high and very high-risk cases, which resulted in an accumulation of overdue visits and ARMS
assessments for medium and low risk offenders.

In April 2023, following changes to the Chief Officer team this policy was reversed resulting in
the formulation of a recovery plan, Operation Madeira. The Gold Strategy was set by Assistant
Chief Constable ]jwho made a significant investment of force resources, reducing RSO
to Offender Manager ratios from 1:85 to 1:56.

Furthermore, in January 2024 ACC] commissioned a business analysis ‘sprint’ by our
Change & Transformation Branch to assess the potential strategic changes required to reduce
inefficiencies, improve performance, and restructure the department as a means of ensuring
we build in sustainable service delivery over the next 3 to 5 years.

is)

A10

As of April 2024, there were 5,666 RSOs in Greater Manchester, of which 3,309 were in the
community requiring active management and our Offender Manager establishment had
increased to 76, thereby further reducing RSO to Offender Manager ratios to 1:43 when at full
establishment, which is under the recommended level of 1:50.

However, as GMPs sex offender register is forecasted to increase by 7-10% annually in line
with national predictions, Chief Officers have taken the decision to further increase the
establishment of the SOMU by 18 full time equivalent staff, representing an investment of
c.£1m of additional resources. This will not only increase the number of Offender Managers
from 76 to 80 to maintain effective ratios as the register grows but will also formally establish
a dedicated criminal investigation team and a pro-active intelligence function to significantly
enhance the support to Offender Managers with their retained workloads.

A review and redistribution of caseloads is now complete. This has been a beneficial process
as it has re-balanced risk levels across teams i.e., all Offender Managers now carry a similar
percentage profile of Very High and High Risk RSOs in their caseload, and balanced caseloads
now take priority over tight geographical boundaries. This exercise will be repeated on a
regular basis, including when vacancies arise, to ensure there is fluidity in moving resources
around to respond to changing demand and risk.

Investment has also been made into increasing the Specialist Offender Manager team
responsible for RSOs held on remand in prisons and hospitals. This will take away significant
proportions of largely administrative workload meaning Offender Managers can focus on those
who need more active management, risk assessments and visits in the community.

7. The GMP investigation into their role in relation to Elizabeth’s death was poor in
quality and there was no evidence that any senior officer had considered the report. The
inquest was told that the quality and lack of referral upwards of a report was not unique
to Elizabeth’s case.

Following Elizabeth McCann’s murder, on 26" August 2022 the District Commander for
Tameside briefed Assistant Chief Constable J and chaired a silver review meeting with
representation from both the SOMU and Greater Manchester Probation Service.

Due to there being no prior direct or indirect police contact with Elizabeth McCann the case
did not meet the criteria for referral to the Professional Standards Directorate for consideration
for referral to the Independent Office for Police Conduct (IOPC) as a ‘death or serious injury’
in accordance with the Police Reform Act 2002, Schedule 3, paragraphs 4(1)(a), 13(1)(a) and
13C(1) as amended by the Serious Organised Crime and Police Act 2005, Schedule 12.

On 30" August 2022, GMPs Investigation and Safeguarding Review Team made a referral to
the Tameside Community Safety Partnership for consideration of commissioning a Domestic
Homicide Review (DHR).

On the same date, notification of a Serious Further Offence (SFO) being committed by a RSO
was made to the Multi-Agency Public Protection Arrangements (MAPPA) coordinator, in
accordance with the MAPPA framework, for onward consideration by the Chair of the Greater
Manchester MAPPA Strategic Management Board (Detective Chief Superintendent) whether
to commission a MAPPA Serious Case Review (SCR). This decision was deferred pending a
decision on the DHR.

All

On the 5" October it was determined the case did not meet the criteria fora DHR as there was
no evidence of a relationship between Elizabeth McCann and and it was
recommended the case was referred for consideration as to a Safeguarding Adults Review
(SAR).

On the 7"" October the case was referred and on 27" October it was determined the case did
not meet the criteria for a SAR as Elizabeth McCann did not have care and support needs as
defined by the Care Act 2014.

Due to J being managed at MAPPA Level 1, the Deputy Chair of the MAPPA Strategic
Management Board (Detective Superintendent) determined the case did not meet the criteria
for a mandatory SCR. Consideration was given to commissioning a discretionary SCR,
however, owing to tandem Police and Probation Internal Management Reviews (PIMRs) being
commissioned it was determined that a discretionary SCR would not add additional value to
the findings of the PIMR as outlined in national MAPPA guidance (paragraph 20.5).

On the 19" January 2023 a Police Internal Management Review (PIMR) was completed by a
Detective Inspector. This report should have been considered by a senior officer in accordance
with Authorised Professional Practice (APP) which directs review by the force public protection
lead (Superintendent or above) to establish whether there is any learning, good practice,
performance or disciplinary matters, or other issues impacting on performance such as
workloads, support, and guidance.

The Detective Inspector no longer works for GMP and the senior leadership in post at the time
have since retired or left GMP. Had they remained in post, and this had been assessed by the
Head of Public Protection together with colleagues from the Professional Standards
Directorate, it is likely that the officer would have been developed by way of reflective practice
with a member of the senior leadership team.

Following leadership changes within the Public Protection Division the PIMR process has been
fully revised by the new Head of SOMU to comply with APP. All Detective Inspectors have
been briefed on their responsibilities in relation to timeliness and the quality of PIMRs and
compliance with review has been reinforced with the senior leadership team and is tracked by
the Head of Public Protection.

Furthermore, the specifics of this case and the learning from it have been discussed with all
SOMU staff and added to the initial training for Offender Managers and ongoing continuous
professional development inputs.

8. There was no evidence before the inquest of any professional curiosity by senior
GMP officers as to the role of GMP and if lessons could be learnt. It was unclear as to
why senior officers were unsighted.

As described above, there was a degree of professional curiosity exhibited by senior GMP
officers both in the immediacy after Elizabeth McCann’s murder and subsequently through
referrals in line with established processes and it is with regret that the PIMR process was not
followed.

Al2

The new Head of SOMU has introduced a daily management meeting which tracks any further
offences committed by RSOs in order to identify any learning opportunities, ensure effective
information sharing and revise risk management plans. Where a serious further offence has
been committed a senior officer (Chief Inspector or above) now chairs a silver review meeting
and commissions PIMRs as required. Compliance with APP, including senior officer oversight,
is then tracked via the branch’s monthly performance meeting, which is chaired by the Head
of Public Protection.

The PIMR process has also been further strengthened via independent quality assurance by
the force Investigation and Safeguarding Review Team, which in turn provides better
connectivity to the Strategic Organisational Learning Board.

9. It was accepted that there needed to be a level of professional curiosity by staff
dealing with high-risk offenders such as in this case and that training for probation
officers and police staff needed to reinforce that.

The need for professional curiosity and the learning from this case have been further
embedded into the completely refreshed training delivered to all new staff, along with portfolio
completion. Refresher CPD training on PIMRs has been delivered to existing staff.

The training includes discussions around the difference between information sharing and multi-
agency working, along with the need to challenge and sense check information given by RSOs
with other agencies that are working with them, to ensure the validity of the information being
given by an RSO.

Plenary discussions explore what constitutes a ‘significant change’ to prompt a new ARMS
assessment and fully considers underlying triggers for re-offending and whether the
significance of this even if it doesn't relate to sexual offending, actually prompts an increase in
risk, €.g., consumption of alcohol or controlled substances.

The learning has also been incorporated into the curriculum item re MAPPA, which is given to
new and existing staff as CPD.

10. The inquest was told that Health and Well Being Colleges could provide effective
support for the communities they served. They were a national model. However, if they
were to be open to all it was essential that they were structured in such a way that risk
was effectively managed with clear, documented protocols understood by all in place.
There was also a need for effective information sharing protocols and effective well
understood safeguarding provisions.

This is a matter for the Department of Health and Social Care to reply on behalf of the Pennine
Care NHS Foundation Trust.

11. The Health and Wellbeing College in Tameside served 5 boroughs of Greater
Manchester and was run by the Mental Health Trust. It was accepted by the Trust that
the investigation report was of poor quality and an opportunity to learn lessons missed.
This included the management structure, oversight, lack of an information sharing
protocol with probation, the systems in the college for managing risk and sharing
information and compliance with GDPR.

This is a matter for the Department of Health and Social Care to reply on behalf of the Pennine
Care NHS Foundation Trust.

Al3

It remains a source of profound regret that we cannot turn back the clock and undo the damage
done in this tragic case. However, | trust this response demonstrates that pivotal lessons have
been learned and are solidly baked into today’s practice following significant changes to our
current practices and working arrangements.

| am confident that GMP has the organisational learning capability to dynamically reflect and
adapt our approach to maintain our drive to build the trust and confidence of our communities
and deliver policing to the highest professional standards.

Yours si

Chief Constable
Greater Manchester Police

Al4
Response from Hmpps (PDF)
Director General of Prisons 
HM Prison and Probation Service 
8th Floor Ministry of Justice 
102 Petty France 
London SW1H 9AJ 

Email:

31st October 2024 

Ms Alison Mutch,  
Senior Coroner,  
South Manchester Area 
1 Mount Tabor Street 
Stockport. 

By email only to: 

Dear Madam, 

Inquest Touching the Death of Elizabeth Sarah Jayne McCann 

Thank you for your Regulation 28 Report of the 29th May 2024, following the conclusion of 
this Inquest and thank you also for extending the timescale for this response which is being 
issued on behalf of the Ministry of Justice.  

I know that you will share a copy of this response with the family, and I would like to take 
this opportunity to express my sincere condolences for their loss.  

In  your  Report,  you  raised  the  following  concerns  specifically  in  relation  to  the  Probation 
Service which are responded to below.  

The  Inquest  heard  evidence  that  the  probation  staff  were  carrying  significant 
caseloads.    This  was  due  to  challenges  in  recruiting  sufficient  staff.    The  evidence 
was  that  there  is  still  a  national  shortage  of  probation  officers.    Steps  have  been 
taken to recruit and train further probation officers which provides some assistance 
but  means  that  overall,  a  significant  number  of  probation  officers  are  young  in 
service and experience.   

It  was  important  that  newly  qualified  probation  staff  were  closely  supervised  and 
supported  by  their  managers.    Without  that  supervision  performance  issues 
identified  by  the  trackers  were  not  being  tackled.    Ensuring  this  had  been  and  was 
challenging  as  the  number  of  staff  line  managed  by  senior  probation  officers  had 
been too high.  This was being addressed but was only achievable if sufficient senior 
staff were retained.   

Whilst  at  a  national  level,  the  staffing  position  of  the  Probation  Service  is  improving,  it 
remains  the  case  that  raising  staffing  in  some  Probation  Delivery  Units  (PDU)  to  a  full 
complement  remains  a  significant  challenge.  Until  such  time  as  the  situation  improves,  in 
PDUs with acute pressure remaining, staff will follow a Prioritisation Framework which was 

A24 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 first  implemented  in  January  2022.  Those  PDUs  will  also  benefit  from  wider  national 
workload relief through Probation Reset as reflected in a refreshed Prioritisation Framework 
published in May 2024.  

We continue to prioritise recruitment to put the Service on a sustainable footing and secure 
sufficient Probation Practitioner staffing (Probation Officers and Probation Service Officers). 
As  of  30  June  2024,  the  staffing  level  of  Probation  Officers  working  across  the  Probation 
Service  was  70%,  with  5,136  Full  Time  Equivalent  (FTE)  Probation  Officers  in  post.  This 
number  shows  a  considerable  increase  relative  to  June  2021  (when  Community 
Rehabilitation Companies were dissolved, and the Probation Service was unified) when we 
had  4,517  FTE  Probation  Officers  in  post.    Across  HMPPS,  4,582  new  Trainee  Probation 
Officers have started their training since April 2020 (1,007 in 2020/21, 1,518 in 2021/2022, 
1,514  in  2022/23  and  543  in  2023/24).  Many  of  these  trainees  have  already  qualified  and 
taken  up  Probation  Officer  posts,  and  we  expect  the  remainder  to  qualify  by  the  end  of 
2025,  taking  on  Probation  Officer  caseloads.  We  are  beginning  to  see  large  numbers  of 
newly qualified officers coming through and continue to run national recruitment for Trainee 
Probation  Officers  to  meet  the  Lord  Chancellor’s  commitment to  bringing  in  at  least  1,000 
new  Trainee  Probation  Officers  by  the  end  of  March  2025  so  that  we  continue  to  have  a 
pipeline of qualified Probation Officers.  

HMPPS  also  recognises  the  pressure  placed  upon  Senior  Probation  Officers  (SPOs)  and 
how this can affect their supervision of junior staff. The number of SPOs has increased by 
249  nationally  since  June  2022,  whilst  initiatives  continue  to  strengthen  the  SPO  role, 
including  a  review  of  the  Management  Oversight  Policy  Framework  and  roll  out  of  the 
revised Management Oversight model by December 2024, to ensure the approach to staff 
supervision is consistent and effective. HMPPS has invested in a suite of capability options 
for SPOs to further develop their skills by way of continuing professional development, and 
additional  support  from  dedicated  case  administration  officers  to  reduce  the  demand  on 
SPOs in relation to administrative tasks. 

Clear Information Sharing protocols between Probation and such groups as drug and 
alcohol  services  were  limited.    Without  clear  agreements  understood  by  both  sides 
there was  a  significant  risk that  crucial information  that  impacted  risk  assessments 
would not be shared  

The HMPPS Information Sharing Policy Framework sets out clearly the steps to be taken to 
share  information  in  addition  to  the  various  statutory  frameworks  for  the  sharing  of  risk 
information.  This includes guidance on the preparation of Information Sharing Agreements  
in  the  absence  of  a  contractual  arrangement  with  a  partner  agency  which  will  include 
information sharing protocols. 

As  well  as  improving  information  sharing  protocols,  we  are  committed  to  improving 
professional standards of practice and have introduced mandatory professional registration 
for  Probation  Officers,  which  aims  to  sharpen 
focus  on  Continuous  Professional 
Development and drive improved performance and personal accountability to deliver public 
protection.  The  professional  standards  will,  alongside  increased  staffing levels  ensure that 
Probation  Officers  do  all  that  is  required  of  them,  including  the  sharing  of  risk  information 
with partner agencies, whose contribution is vital to the efficacy of risk management plans.  

Effective  risk  assessment  and  management  is  a  clear  HMPPS  priority  and  is  assured  at 
both  local  and  national  levels.  Locally,  risk  assessment  and  management  practice  is 
assured within teams and PDUs using the approved case audit tool. Nationally, the HMPPS 

A25 
 
 
 
 
 
 internal  Performance  Assurance  and  Risk  Group  (PARG)  undertakes  an  annual  sentence 
management  audit,  a  key  component  of  which  is  the  quality  of  risk management  practice. 
The  results  of  this  audit  are  shared  with  regions  and  recommendations  given,  which  are 
incorporated into their local improvement plans.  

It  was  accepted  that  there  needed  to  be  a  level  of  professional  curiosity  by  staff 
dealing with high risk offenders such as in this case and that training for probation 
officers and police staff needed to reinforce that  

Professional  curiosity  in  the  Probation  Service  is  an  essential  part  of  the  assessment  and 
management  of  risk  and  is  a  golden  thread  throughout  the  recently  updated  risk  training 
material  available  to  all  probation  practitioners.  It  will  also  be  incorporated  into  the  new 
Continuing  Professional  Development  risk  learning  product,  which  is  currently  being 
developed  by  HMPPS  in  conjunction  with  subject  matter  experts.  This  will  be  piloted  with 
probation  practitioners  towards  the  end  of  this  year  before  being  launched  from  February 
2025.  

The  need  to  demonstrate  professional  curiosity  is  also  woven  into  several  other  learning 
products,  most  notably  Skills  for  Effective  Engagement  Development  and  Supervision 
(SEEDS2)  for  practitioners  and  middle  managers.  In  recognition  of  the  importance  of 
SEEDS2,  this  been  identified  as  a  strategic  learning  priority  for  2024-2025  with  Probation 
Officers  required  to  complete  the  learning  by  September  2025  as  part  of  their  Continuing 
Professional Development requirement.  

Reflective Practice supervision (a key aspect of the SEEDS2 approach) plays a crucial role 
in fostering professional curiosity by creating a supportive environment where practitioners 
reflect  on  casework  and  practice  issues  by  critically  analysing  and  evaluating  their 
experiences.  It  encourages  practitioners  to  question  their  own  practice,  assumptions  and 
decisions with their line manager, who provides feedback based on observations and other 
sources of information.  

Probation  Practitioners  also  have  access  to  the  HM  Inspectorate  of  Probation  Effective 
Practice  Guide  on  Professional  Curiosity,  published  in October  2022,  and  are  encouraged 
to  use  this  as  a  reference  document  to  support  continuous  professional  development  and 
apply professional curiosity in their practice. 

Thank  you  again  for  bringing  your  concerns  to  our  attention.  I  trust  that  this  response 
provides assurance that action is being taken to address these concerns. 

Yours sincerely, 

Director General Operations  
HM Prison & Probation Service  

A26
Response from Home Office (PDF)
Yvette Cooper MP 
                                                                                                                                    Home Secretary 

                                                                                                                                                   2 Marsham Street 
                                                                                                                                                      London SW1P 4DF 

www.gov.uk/home-office 

His Majesty’s Coroner Ms Alison Mutch 
Senior Coroner for the Coroner Area of South Manchester 
Coroner’s Court  
1 Mount Tabor Street  
Stockport  
SK1 3AG 

Dear Ms Mutch, 

16 September 2024 

RESPONSE TO REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

Thank you for Report to Prevent Future Deaths on 29 May 2024 regarding the 
unlawful killing of Elizabeth Sarah Jayne McCann.  

Thank you for your conduct of the inquest and for your identification of a number of 
matters of concern, which are set out in the Report.  These failings are shocking and 
I am clear that the lessons must be learned across Government and beyond.  In 
providing this response to the Coroner’s Report, the Home Office wishes to repeat 
the offering of its sincere condolences to Elizabeth’s family, and we emphasise our 
commitment to addressing the matters of concerns raised.  

Tackling violence against women and girls is a top priority for this Government and 
we will treat it as a national emergency.  Our mission is to halve levels of violence 
against women and girls using every lever available to us.  This means reforming the 
police response to these crimes, strengthening the criminal justice system, and 
empowering victims by providing access to specialist support when they need it.  
The Home Office is working closely with other departments and stakeholders in 
developing plans to achieve this mission.  

We will build on the existing work I outline below, ensuring that wholesale systematic 
changes are made in response to the findings from your report. Making these 
changes will take time as we must guarantee they are delivered effectively, and that 
we are getting it right. Too often piecemeal changes have failed to deliver effective 
and lasting improvements. We are determined not to make the same mistakes. 

A18 
 
 
 
 
 
 
 
 
 
 
 The Home Office’s response to your report focuses on two matters of concern 
raised, specifically concerns five and nine. 

Matter of concern five 

The inquest was told that nationally a significant number of police forces were 
struggling to adequately staff their Sexual Offender Management Units.  As a 
consequence, the level of supervision of sex offenders in the community was being 
risk managed posing a risk to communities. 

Increasing police capacity  

Decisions on how funding and resources are utilised is a matter for chief constables 
and elected police and crime commissioners (including mayors with Police and 
Crime Commissioner (PCC) functions).  However, it is vitally important that every 
police force has the specialist officers and other resources necessary to support 
victims of rape and sexual violence, bring perpetrators to justice and manage the 
risks they pose.  

The total number of officers nationally is 149,769 (headcount).  Funding has 
previously been provided to forces to support the maintenance of officer numbers.  In 
2024/25 the police funding settlement provides funding of up to £18.5 billion for 
policing in England and Wales.  Overall police funding available to PCCs will 
increase by up to £965.4 million.  The Home Office will also provide additional 
Government grant funding of £175 million to policing in 2024/25, to support the costs 
of the 2024 police pay award. 

On 31 March 2024, there were 8,189 police officers in Greater Manchester Police. 
Greater Manchester Police’s funding will be up to £815.6m in 2024-25, an increase 
of up to £56.4m when compared to 2023/24.  

However, I recognise your concerns regarding the lack of sufficient staffing amongst 
sexual offender management units and the impact that this has in ensuring sex 
offenders are being effectively managed in communities. I am committed to making 
our streets safer.  As part of our mission to halve violence against women and girls in 
a decade, we will ask the police to relentlessly pursue those perpetrators who pose 
the greatest risk to women and use all the tools at their disposal to protect victims 
and get dangerous offenders off the streets. We are currently working at pace to look 
at our national expectations on the management of the highest-risk offenders. 

A19 
 
 
 
 
 
 
 
 
 
 I also recognise that visible neighbourhood policing has been the cornerstone of the 
British consent-based model.  In too many areas it has been eroded, leaving the 
police a reactive service focused on crisis response, rather than preventing crime. 

This Government will introduce a new Neighbourhood Policing Guarantee, restoring 
patrols to our town centres by recruiting thousands of new police officers, police and 
community support officers, and special constables.  Communities and residents will 
have a named officer to turn to when things go wrong. 

Enhancing policing capability 

In addition to providing the police with sufficient capacity to improve its response to 
violence against women and girls, we will ensure the police has the necessary tools 
and capabilities. 

The regime for managing registered sex offenders and those who pose a risk was 
reformed under the previous Government through the Police, Crime and Sentencing 
Courts Act 2022 (“the Act”).  Sexual harm prevention orders and sexual risk orders 
were amended to specify that the court should apply the lower civil standard of proof 
(balance of probabilities) when deciding an application for these civil orders.  In 
addition, the Act enables the courts to impose positive obligations (in addition to 
restrictions) via these orders where appropriate, for example, requiring an individual 
to engage in a behaviour change programme or substance misuse services. 

Violence against women and girls has been included in the Strategic Policing 
Requirement since 2023.  All police forces in England and Wales are implementing a 
new National Operating Model for the investigation of rape, developed through 
Operation Soteria.  The aim is to ensure forces have the right specialist capability 
and use all available levers to respond to sexual offending effectively.   

Section 325 of the Criminal Justice Act 2003 requires the police, probation and 
prison services in each local Criminal Justice Board area to work together to manage 
the risk posed by sexual and other offenders.  These multi-agency public protection 
arrangements (MAPPA) provide a common framework for the identification, 
assessment and management of violent and sex offenders living in the community.  

Your report is clear that more must be done to enhance the police’s capability to 
sufficiently manage sex offender in the community, and I agree that is the case. To 
make sure that the police, prisons, probation service and others have the right 
systems in place to do this and share pertinent information on registered sex 
offenders and other dangerous individuals, the Home Office is developing a new 

A20 
 
 
 
 
 
 
 
 
 multi-agency public protection system (MAPPS) which will provide improved 
functionality that will better meet the future needs of frontline offender managers.  It 
will enable more effective and efficient offender and risk management, improve data 
sharing between frontline agencies and the management of additional cohorts of 
offenders.  

In April 2023, the Home Office published an independent review of the police’s 
management of sex offenders undertaken by former chief constable Mick Creedon. 
Chief Constable Creedon recommended that PCCs include MAPPA/sex offender 
management within their police and crime plans to ensure they are able to 
appropriately hold chief constables to account and provide them with the opportunity 
to inform the public of realistic expectations for sex offender management within the 
community.  

The Government welcomes primacy being given to offender management in police 
and crime plans. Offender management is the mechanism that prevents reoffending 
and revictimization.  Placing an emphasis on it in police and crime plans will raise 
awareness of the important preventative work that police offender managers do, 
which will in turn increase the level of informed accountability that police offender 
managers are subjected to. 

I would like to assure you that I will be reviewing this as we develop our plans to 
halve the levels of violence against women and girls in the next decade. We will 
monitor closely and robustly if these systems are working. 

Matter of concern 9  

It was accepted that there needed to be a level of professional curiosity by staff 
dealing with high-risk offenders such as in this case and that training for probation 
officers and police staff needed to reinforce that. 

I would also like to respond to your concerns relating to the lack of professional 
curiosity by staff dealing with high-risk offenders. This is – to my mind – perhaps the 
most concerning finding that you make given the significance of the task and the 
responsibilities that are conferred upon every individual involved in offender 
management.  

I recognise that it is crucial that offender managers understand the importance of 
their role; how to interrogate the data and information they hold about offenders and 
when and how to act to protect the public from harm.  

We must deliver better protection for the public and outcomes for victims. The 
Government will be working closely with the College of Policing and NPCC to 
improve training for officers. 

A21 
 
 
 
 
 
 
 
 Chief officers are encouraged to create and promote opportunities for officers and 
staff to enhance their subject matter knowledge and skills relating to vulnerability. 
This can be achieved through various mechanisms, for example, briefing, policy, 
continuing professional development (CPD) and training.  

The College of Policing’s evidence-based guidelines on vulnerability and risk aim to 
support officers to spot the signs of vulnerability and create a safe, trusting 
environment to identify risk, encourage the disclosure of harm and elicit information 
required to inform appropriate actions to keep people safe.  

One of the core elements of the Vulnerability and Risk guidelines from the College of 
Policing for police responders includes ‘Curiosity’, which outlines core components 
for officers and staff to consider as part of exercising professional curiosity to identify 
and respond to vulnerability. Another product produced by the College of Policing 
includes a one-day vulnerability training package which encourages frontline officers 
and staff to look beyond the obvious and feel empowered to use their professional 
curiosity when dealing with those who are vulnerable.  

In addition, the College of Policing’s Authorised Professional Practice (APP) is an up-
to-date source of policing practice which police officers and staff are expected to 
have regard to in discharging their responsibilities. The APP module on identifying, 
assessing and managing risk sets out a range of information and intelligence that 
police officers and staff should draw on to consider risk for the purpose of public 
protection. This includes reviewing a range of historical and dynamic factors, such as 
offending history, biographical and relationship factors, access and proximity to 
victims and other criminogenic factors. 

The College of Policing also has a Managing Sexual and Violent Offenders 
(MOSOVO) learning package which is designed to prevent sex offenders from 
reoffending. The learning package trains offender managers in conducting an active 
risk management assessment to identify risk factors that may increase the 
propensity of a given offender to reoffend. There is a specific module within that 
learning package that focuses on understanding offenders’ motivation and what 
works in deterring offenders and encouraging desistance. The College reviews the 
course continually based on feedback from trainers and trainees as well as changes 
to the operating environment. Lastly, the Home Office currently funds the 
Vulnerability Knowledge and Practice Programme (VKPP), which works with the 
National Police Chiefs’ Council’s Violence and Public Protection and Violence 
Against Women and Girls portfolios. The VKPP engages with forces and key 
partners to identify promising practice and share knowledge to shape future 
responses to serious crime that exploits vulnerability. This is with a view to improving 
policing's overall response, reducing threat and harm, bringing more offenders to 
justice and improving outcomes for victims.  

A22 
 
 The VKPP has a workstream to consolidate learning from case reviews into death 
and serious harm, which analyses and draws together police learning across several 
types of reviews, including Child Safeguarding Practice Reviews (CSPRs) 
(previously Serious Case Reviews); Safeguarding Adult Reviews (SARs); and 
Domestic Homicide Reviews (DHRs). I acknowledge that this work is only the 
beginning, but I will use every tool available to target perpetrators and address the 
root causes of abuse and violence. For too long, violence against women and girls 
has been ignored. Our landmark mission to halve violence against women and girls 
in a decade will require a step change in our approach to it nationally.  

That starts with tougher enforcement and protection. Under this Government, we will 
be introducing specialist rape and sexual offences teams in every police force. The 
most prolific and harmful perpetrators will be relentlessly targeted, using tactics 
normally reserved for terrorists and organised crime.  

Once again, we would like to take the opportunity to thank you for highlighting these 
matters of concern, and for giving us the opportunity to respond. We will continue to 
work with police forces to make sure we continue to improve the effectiveness and 
efficiency of the system that supports policing to manage sex offenders and prevent 
them from committing further harm. 

Rt Hon Yvette Cooper MP 
Home Secretary 

A23
Response from Pennine Care (PDF)
Corporate Legal Services 
Trust Headquarters 
225 Old Street 
Ashton Under Lyne 
Lancashire 
OL6 7SF 

Telephone: 

19th July 2024 

Private & Confidential 
Alison Mutch 
HM Senior Coroner 
Coroner’s Court 
1 Mount Tabor Street 
Stockport 
SK1 3AG 

Dear Ms Mutch, 

RE: Inquest touching on the death of Elizabeth McCann 

I set out below the Trust’s response to your letter to Pennine Care NHS Foundation 
Trust  and  the  issuing  of  a  Prevention  of  Future  Deaths  Notice  (Regulation  28), 
arising from the inquest into the death of Elizabeth McCann. 

May I take this opportunity to extend my own condolences to the family of Elizabeth 
and apologise that you had to raise concerns relating to the services she accessed 
prior to her sad death.  

Prior to receipt of the Regulation 28 notice, the Executive team here commissioned 
an  external  review  of  the  College.  This  is  currently  concluding  with  the  outcome 
anticipated before 31 July 2024. The Network Director of Quality, Nursing and Health 
Professionals  for  our  South  Network  (
)  is  working  with  the  team  at  the 
College in relation to all of the issues highlighted by the internal investigation report, 
the evidence heard at Inquest and from the early findings of the external review. 

I  would  also  like  to  take  this  opportunity  to  assure  you  that  the  College  has  no 
partnership  arrangement  with 
the 
understanding  that  the  Probation  Service  has  developed  an  in-house  recovery 
model. 

the  Probation  Service.  The  Trust 

is  of 

The Trust sets out its response to the specific points below: 

3. Evidence before the inquest was that if probation referred clients under 
supervision  to  places  such  as  the  Health  and  Wellbeing  College  this 
would,  if  not  implemented  effectively  pose  a  significant  risk  to 
vulnerable  users  of  such  institutions.  If  referrals  were  made  without  a 
protocol  being  in  place  that  dealt  with  managing  risk  then  the  risk 
posed increased further.  

A1 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Trust Response: 

The College has a new Standard Operating Procedure within which there is a clearly 
articulated  protocol  for  the  referral  and  enrolment  process  for  any  member  of  the 
public,  referring  agency  or  clinical  team  referral.  This  protocol  has  a  stepped 
approach to risk management and includes cross-reference checks with Trust clinical 
systems  (PARIS  our  Electronic  Patient  Record  system  and  incident  reporting 
systems). Any referral by an external agency, such as the probation or service [e.g., 
third sector] will be required to share risk information that is known about the person.  

As  a  condition  of  enrolment,  students  agree  to  the  sharing  or  disclosure  of 
information to professionals/other agencies regarding concerns to their own or others 
safety by agreeing to the student charter on enrolment. 

The College leads will also perform a PARIS ‘look up’ to check for flags against any 
new enrolling students. During this time, they will also check new enrolment forms to 
ascertain if any students have answered ‘yes’ to the below question: 

‘Do you have any current or recent (within the last 12 months) police or court 
involvement, or have you been released from prison or been under any other 
court mandated orders within the last 12 months? 

If yes, please provide the name of the police or probation officer you are/were 
involved with, as we will need to contact them.’ 

If a student has answered ‘yes’ to the above question on the student enrolment form, 
the  details  will  be  clarified  with  police/probation  and  the  question  asked  as  to 
whether  this  person’s  current  level  of  risk  can  be  managed  within  the  Health  and 
Wellbeing College environment. 

No  enrolment  to  the  College  is  permissible  until  there  is  sufficient  assurance 
gathered from internal and external systems. A student’s application to enrol will be 
kept  on  hold  until  a  manager  is  able  to  either  authorise  or  decline  the  person’s 
application based on this information. 

If enrolment for a student is unsuccessful due to an evaluation that there is a risk to 
other students, then a standard letter of ‘Unsuccessful enrolment’ is issued. 

If enrolment for a student is successful, then the College will manage the day-to-day 
presence of a student on site as follows: 

Once a student has had their enrolment authorised: 

• 

If  there  are  any  risk  concerns  during  a  student’s  time  at  the  Health  and 
Wellbeing College: 

1.  Discuss the concern with the Health and Wellbeing College lead(s) who 

will agree next steps. 

A2 
 
 2.  Record any conversations or discussions regarding the above, in the 

student’s individual paper file on the notes sheet. This should be signed 
and dated, with the time of the note entry recorded. 

3.  If it is decided that a student or other person (e.g. key 

professional/emergency contact/safeguarding) should be contacted, 
this must be recorded on the student’s individual paper file on the notes 
sheet, along with any conversations and outcomes. Additionally, any 
emails or letters etc, relating to this must be printed, and attached to 
the notes sheet in the student’s individual file. 

•  Teaching  staff  will  check  each  student  file  against  the  class  register  for  any 
class they are teaching that day, to ensure they are aware of any risk updates 
or changes or new information. 

•  Teaching  staff  will  ensure  that  the  online  register  is  open,  checked  and 
completed  before  the  class  starts/as  students  enter  the  classroom.  This 
ensures that only those students who have enrolled and booked on a course 
are present. 

The  risk  management  checks  protocol  is  set  out  within  the  College’s  standard 
operating procedure at appendix 11. 

The  Trust’s  respective  Head  of  Quality  will  ensure  that  the  risk  management 
protocols for the college are kept under review and discussed regularly.  

It  is  anticipated  that  the  independent  review  of  the  College  will  provide  additional 
assurance  as  to  the  effectiveness  of  the  current  risk  management  processes,  or 
opportunities for further development as a result of this process. 

4.  Clear  Information  Sharing  protocols  between  Probation  and  such 
groups  as  drug  and  alcohol  services  were  limited.  Without  clear 
agreements understood by both sides there was a significant risk that 
crucial  information  that  impacted  risk  assessments  would  not  be 
shared. 

Trust Response: 

As  outlined  in  our  earlier  response,  since  Elizabeth’s  death,  the  College  has 
developed  a  standard  operating  procedure  that  outlines  the  steps  and  processes 
required  by  College  leads  and  administrators  in  relation  to  information  received  by 
the  College  and  the  steps  required  for  every  student’s  successful  enrolment  to 
commence. These checks include self-disclosure by students relating to activity and 
engagement  with  other  agencies  in  addition  to  checks  against  internal  clinical 
systems.  

Any  student  with  an  open  referral  to  another  agency  will  be  requested  to  give 
permission to contact and explore issues of risk with that agency as appropriate. For  

A3 
 
 any student with an open and ongoing engagement with a clinical team, the College 
leads have full access to the Trust’s patient record systems to enable a review of the 
risks  associated  with  the  student.  The  College  leads  are  required  to  liaise  with  the 
clinical  team  for  a  position  on  whether  or  not  enrolment  is  appropriate  for  the 
individual.  

Alongside  the  community  focus,  the  service  works  in  partnership  with  both  internal 
partners  and  external  organisations  to  co-produce  and  co-deliver  wellbeing  and 
recovery  focussed  courses,  in  line  with  the  recovery  college  fidelity  criteria  and 
standards. All partners will agree to and sign a partnership agreement.  

The partnership agreement exists to support the safety and wellbeing of all College 
students and sets out clear expectations relating to information sharing.  

The College’s nominated partners are: 

•  Tameside Libraries 

•  PCFT Volunteer Service 

•  PCFT Chaplaincy and Spiritual Care Service 

•  Aminas Art and Design 

•  Heathfield House, Rehabilitation and High Support Hub PCFT 

•  My Mirror Loves Me 

•  Bury Community Mental Health Team 

•  Acorn Recovery, Stockport Early Intervention and Recovery Service 

•  Tameside Macmillan Unit 

Any Partner seeking to engage with the Trust’s Health and Wellbeing College must 
enter into a contract and engage in a workshop that outlines amongst others, a clear 
understanding of the structures, processes and working protocols of the Health and 
Wellbeing College in relation to risk and safeguarding. 

The College no longer has a working partnership with any probation service.  

The College team have worked closely with the Trust’s Information Governance Lead 
who  has  supported  them  to  ensure  compliance  with  the  General  Data  Protection 
Rules. 

The  College  team  have  worked  to  develop  and  share  protocols  in  relation  to 
information governance with the staff group. These include the creation of a generic 
email account, access to the generic email account, standardised out of office for the 
account  and  escalation  processes  in  relation  to  information  received  to  the  generic 
email account, an extract of which is provided here for assurance: 

“Protocol for Dealing with emails to the Generic Health and Wellbeing College 
Inbox. 

A4 
 
 The  generic  e  mail  account 
following staff only: 

is  accessible  by  the 

•  Health and Wellbeing College Administrator 
•  Health and Wellbeing College Leads 
•  Health and Wellbeing College Band 5 Practitioner 

General  email  enquiries  regarding  opening  times;  enrolment  process;  courses; 
general  college  information;  room  bookings;  web  site  queries;  basic  IT  issues; 
ordering and invoicing; visits etc, can be dealt with by the College Administrator. It is 
the  College Administrator’s  responsibility  to  check  and  action  the  in  box  on  a  daily 
basis. In the absence of the college administrator, the in-box will be checked by the 
band 5 practitioner or the College Leads, as decided. 

Signposting  information  or  enquiries  regarding  student  welfare  or  wellbeing, 
or information from any internal team or external agency regarding a student, must 
be forwarded to the College Leads. 

Any  enquiries  about  risk  from  any  internal  or  external  team  or  agencies,  must  be 
forwarded to the Health and Wellbeing College Leads, and will be dealt with as per 
the risk protocol. 

In  the  absence  of  the  College  Leads,  the Administrator  should  escalate  any  urgent 
information  to  the  band  5  practitioner,  and  if  necessary,  the  band  5  practitioner  will 
escalate this to the service line manager.” 

Working with the Information Governance Leads the College has established regular 
sessions  with  all  staff  and  volunteers  at  the  College  to  remind  them  of  the 
importance  of  the  General  Data  Protection  Regulation  rules  when  information  is 
shared from other agencies.  

Information Governance Lunch and Learn Sessions – Termly: 

•  14/8/24 – Classroom 3 HWC 
•  10/12/24 – Classroom 3 HWC 
•  17/4/25 – Classroom 3 HWC 

The  Trust  and  College  acknowledge  that  in  order  to  provide  a  safe  and  effective 
learning  environment  for  all  students  to  access  courses  to  enable  growth  and 
recovery,  they  must  be  supported  and  enabled  to  do  so  through  systems  and 
processes that keep them safe.  

A5 
 
 
 
 
 
 
 10. The inquest was told that Health and Well Being Colleges could provide 
effective  support  for  the  communities  they  served.  They  were  a  national 
model.  However,  if  they  were  to  be  open  to  all  it  was  essential  that  they 
were structured in such a way that risk was effectively managed with clear, 
documented  protocols  understood  by  all  in  place.  There  was  also  a  need 
for  effective  information  sharing  protocols  and  effective  well  understood 
safeguarding provisions.  

Trust Response: 

The  new  Standard  Operating  Procedures  for  the  College  were  shared  through  a 
briefing note e-mail of 17th April 2024 regarding the updated version of the Standard 
Operating  Procedure  (SOP)  and  the  reminder  noted  in  the  team  brief  notes  on  3rd 
July  2024.  This  is  stored  within  the  shared  electronic  folder  which  all  staff  can 
access, with a hard copy on file in the office for reference.   

The  College  shares  information  within  the  staff  group  and  operates  2  x  10-minute 
briefings each day, at the following times: 

•  09.20 – 09.30 (Team brief) 
•  13.20 – 13.30 (Team brief) 

This provides an opportunity to clarify the courses for the day, teaching staff and any 
issues  for  staff  that  day  to  be  aware  of.  There  is  an  expectation  that  all  team 
members present attend, participate fully and share information in a respectful, open, 
constructive, and supportive way. A termly Health and Wellbeing College meeting is 
held, and all staff are encouraged to attend. 

All  staff  working  within  the  Health  and  Wellbeing  College  are  up  to  date  with  their 
safeguarding training - level 2 (College management – level 3). This is monitored by 
the Health and Wellbeing College Leads, in liaison with the Volunteering Team and 
the Temporary Staffing Team. All staff compliance will be checked before the start of 
the September term.  

The  College  will  report  quarterly  compliance  data  for  safeguarding  through  the 
Trust’s established governance systems. 

The Trust has set dates for the safeguarding sessions quarterly on: 14th August 2024 
and 10th December 2024 as ‘lunch and learn’ sessions for all staff. As these become 
embedded, they will be scheduled once each term (3 times per academic year) with 
the Trust’s Safeguarding Team as an additional way of ensuring that Safeguarding is 
kept as a living and conscious statutory duty by all working within the College. 

If there is an occasion when that the College staff and / or Leads become aware of 
information or behaviours that give rise to serious and significant concerns about the 
potential risk of harm to other individuals at the College, then steps should be taken 

A6 
 
 
 
 to  establish  if  the  individual  has  a  forensic  history  that  may  give  rise  to  their 
unsuitability to being a student at the college. This approach should be made via any 
clinical  team  involved  with  the  student  (for  example  if  they  were  open  to  a 
Community Mental Health Team) in the first instance. If no clinical team is involved, 
then  an  approach  should  be  made  to  the  Trust’s  Security  Lead  &  Police  Liaison 
Officer, who will liaise with criminal justice agencies. 

The College leads must ensure the health, safety and welfare of all students and this 
may necessitate a temporary suspension of a current student or the temporary halt 
on the intended enrolment of a student, pending further enquiries. 

If  any  safeguarding  concerns  arise,  these  should  be  reported  to  a  College  Lead 
immediately,  who  will  act  accordingly.  If  necessary,  guidance/further  advice  will  be 
sought from the Trust safeguarding team.  

The  College  and  the  Trust’s  Head  of  Safeguarding  have  developed  a  clear  policy 
that covers students enrolled at the College, should the leads or staff become aware 
of a concern or incident that gives rise to a safeguarding concern.  

11.  The  Health  and  Wellbeing  College  in  Tameside  served  5  boroughs 
of  Greater  Manchester  and  was  run  by  the  Mental  Health  Trust.  It  was 
accepted by the Trust that the investigation report was of poor quality 
and  an  opportunity  to  learn  lessons  missed.  This  included  the 
management  structure,  oversight,  lack  of  an  information  sharing 
protocol  with  probation,  the  systems  in  the  college  for  managing  risk 
and sharing information and compliance with GDPR. 

Trust Response: 

As part of the reflections immediately post inquest, a tabletop review of the process 
followed in this case was requested by the Executive Director of Quality, Nursing and 
Healthcare  Professionals,  who  had  taken  up  his  post  in  the  weeks  before  the 
inquest.  This  review  was  led  by  a  member  of  the  Director  team  and  identified 
learning. 

This  made  recommendations  in  relation  to  strengthening  the  triggers  for  an 
investigation, more robust systems for the recording of decisions made in relation to 
commissioning  of  investigations,  for  the  agreement  of  the  scope  and  terms  of 
reference,  and  for  ensuring  the  training  and  skills  of  investigators  beyond 
arrangements already in place. In addition to this, it was also recommended that the 
quality  assurance  process  for  the  presentation  and  ratification  of  investigation 
findings could also be reviewed and strengthened.  

These findings were received and accepted by our new Executive Director of Quality, 
Nursing  and  Health  Professionals  who  is  being  supported  by  the  Interim  Head  of 
Patient Safety and Clinical Effectiveness to dovetail these recommendations into our 
broader change in organisational approach to investigations as part of the nationally 
mandated work to implement the Patient Safety Incident Response Framework  

A7 
 
 (PSIRF).  As part of this, we are also commissioning a training programme that will 
provide attendees with enhanced skills in reviewing and learning from patient safety 
incidents. This is intended to build on the existing offer available to staff, to create a 
robust system and pool of those able to undertake this responsibility effectively and 
efficiently.  

In order to facilitate the recommendations, the Executive Director of Quality, Nursing 
and  Health  Professionals  has  also  introduced  new  governance  processes  into  our 
agreed structure which should support a more robust process for the most significant 
patient  safety  investigations.  One  of  these  is  a  Central  Safety  Summit,  with  an 
approved  scope  and  purpose  agreed  at  Trust  Board  level,  with  reporting  into  our 
Quality Committee to ensure continuous oversight at a Non-Executive Director level.  

Progress  in  relation  to  the  embedding  of  these  new  structures  will  form  part  of  our 
reporting  to  Trust  Board  in  relation  to  quality,  safety,  experience  and  effectiveness, 
supported  by  an  established  report  provided  within  the  private  part  of  the  Board 
meeting,  which  is  focused  on  incident  investigations,  including  performance  and 
learning  and  inquest  activity.  This  will  also  inform  regular  discussions  with  ICB 
colleagues and reporting within the quarterly quality compliance schedule, which is in 
place, as well as our established engagement mechanisms with our regulator, Care 
Quality Commission on a bi-monthly basis.  

I hope that the information within this response has provided you with the assurance 
that you were seeking in relation to learning from these events. Should you require 
any  further  information  or  clarification  on  the  details  within  this  letter, please do  not 
hesitate to get in touch with me again.  

Yours sincerely 

Chief Executive  

A8

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