SECTION 1: Introduction and Legal Background
Q1 Is this Section of the draft guidance clear? If not which issues need to be clarified?
This section is well presented and provides comprehensive information. We have one comment to make:Paragraph 1.4 In relation to the requirements of School Governing bodies, there is opportunity here in the guidance to make clear that in relation to school uniforms “promoting high standards of educational achievement” can and should always be achieved by maintaining school uniform codes and policies that are reasonable in practical and financial terms for parents on low incomes.
SECTION 2: Equality Issues
Q2 Does this Section make clear to school governing bodies how its school uniform could be discriminatory? Are there any other issues you feel should be included? If so please specify them.
In relation to the Welsh Assembly Government’s policies, there is clear scope here in the guidance to refer to the principles of the UN Convention of the Rights of the Child (UNRC), which has been formally adopted by the WAG as the underpinning principles for children and youth services. In particular, reference to equal learning opportunities, emotional health, recognition of race, faith and cultural identity and ensuring that all children and young people are not disadvantaged by child poverty could be listed as elements that a minimum set of standards of support to obtain a decent school uniform would address.We very much welcome the inclusion of this section on Equality Issues and also the information on discrimination awareness in Section 1 as these elements form a crucial part of our service aims. Each Citizens Advice Bureau is independent and provides free, confidential, impartial advice to everybody regardless of race, gender, religion, sexuality or disability. The Citizens Advice Service aims:“to ensure that individuals do not suffer through lack of knowledge of their rights and responsibilities or of the services available to them, or through an inability to express their needs effectively, and equally; to exercise a responsible influence on the development of social policies and services both locally and nationally”.Our Action Guide for Bureaux entitled Bridging Communities (which was produced for following the policy agreement in the Citizens Advice AGM in 2001) initiated our work on building relationships between the between Citizens Advice Bureaux and BME groups within their communities and in being proactive in helping victims of racist incidents. Although geared towards Bureaux activities, the guide could also, potentially, act as reference to other organisations or establishments, who wish to develop community links with and pursue active work on anti-racism. Citizens Advice is in the position to monitor any incoming evidence of racist incidents or bullying as a result of discrimination within schools and could utilise proactive work done to date in relation to Bridging Communities in order to engage with schools on raising awareness of this topic. The Equalities Working Group of the Citizens Advice Cymru Committee will be considering how to develop activities already undertaken by Bureaux in responding to the Bridging Communities Action Guide. Amongst the proactive work noted on Bureaux activities in this field has been involvement with racist incident monitoring groups.Citizens Advice Cymru would welcome engaging with the WAG, strategically and with LEAs locally to discuss how this work could be developed in relation to schools.
SECTION 3: Practical Issues to Consider in Adopting or Changing School Uniform Policies.
Q3 Do you consider that the draft guidance relating to cost and practicalities is clear, comprehensive and practical? Are there any other issues you would like to see included? If so please specify them.
We would suggest that this section’s heading be changed to ‘Practical issues for adopting or evaluating school uniform policies’. This section should not only focus on adopting and changing. School governors and teachers should be encouraged to evaluate their policies to determine whether they fit into the practical and equality considerations as well as financial implications. If they don’t, they should consider revising them.In paragraph 3.2:Bullet point 1 could be amended to include ‘dry clean only items should be avoided’. This could instead refer to ease of washing and mention colour and dry cleaning.Bullet point 3: it would be helpful to take consideration of variations in “style” as well as “colour” for different year groups. This would take into account individual school policies that might include style requirements that would potentially bring an additional financial burden.Paragraph 3.8:It would be beneficial to add a paragraph saying that where a P.E. item is only required for part of the school year it is important that the kit list indicates the period when it is required. This both prevents the likelihood of the child outgrowing the item before it is even needed, thus having to buy the item twice, and enables them to budget by spreading the costs over the year.
SECTION 4: Information, Consultation and Complaints
Q4 Section 4.2 of the draft guidance recommends that schools should consult with pupils and parents on matters relating to school uniform. Do you agree or disagree with this view?
We agree with this view. Giving parents and pupils a sense of ownership can also encourage an appreciation and better understanding by these groups of, for example, the inequalities that exist and stigmatisation of peers that might arise or currently exist. This could also bring a different perspective on practical considerations and can give pupils a sense of responsibility over their school affairs.
Q5 Are Sections 4.4 - 4.5 of the draft guidance relating to non-compliance clear and understandable? Are there any other issues, which need to be covered?
We gather that this refers to sections 4.5-4.6Paragraph 4.6: We welcome the recognition given to the importance of first establishing why a pupil is not complying with the uniform policy and the acknowledgment that the family may be facing financial difficulties.It does not seem necessary to detail the types of discipline that are appropriate in the cases of persistent defiance. In this case it might be more appropriate to suggest that the school would want to take action in line with its general discipline policy.
Q6 Is Section 4 in general clear and comprehensive? Are there any other issues you consider should be included?
Paragraph 4.1: We believe it important to add the following sentence: ‘Alongside the information regarding the school’s uniform requirements should be brief reference to cost considerations. This might be by giving reference to the fact that cost considerations have been taken into account in drawing it up and/or by including reference to any assistance that is available from the school or the LEA or other sources.’ Reference to financial considerations should also be included on websites and any other place where there’s reference to the uniform requirements. This both serves to answer any question that the parent might have but feel too awkward to ask but also by addressing it, takes the stigma out of the issue and makes it much easier for a parent to ask or raise a concern. A number of school websites refer to what assistance is available together with the kit-list. However, one Welsh Authority’s (Wrexham) website has a Q & A page but under the question ‘How do I get a school uniform grant?’ it simply says ‘the authority does not provide grants for school uniform’ without giving any further information about help that might be available elsewhere.
SECTION 5: Financial Assistance
Q7 Are there any other forms of financial help available to parents that you are aware of that could be included in Section 5.6? If so please give details.
Paragraph 5.6:· Under Section 17 of the Children Act 1989, each Local Authority has the power to provide assistance in cash, or in kind, to families in order to meet its duties under the Act. The family must have a child who has been assessed as being “in need”, as defined by the Act. The payment must be appropriate for the child's needs and, if cash is provided, the circumstances must be exceptional. It is important to note that there are no guidelines on what constitutes exceptional circumstances for cash payments. ‘Clothing’ is listed as an example of what Section 17 payments may cover. Financial assistance can be a cash payment, a loan or a payment in kind. Most payments will be in the form of a loan. However, if the client is receiving income support or income-based jobseeker's allowance, s/he will not have to repay the assistance given. The WAG may wish to obtain the Local Authority's policy and procedure on financial assistance under the Children’s Act to be included as part of the Guidance. This information is detailed on the Citizens Advice Electronic Information Service (EIS) and is often referred to by Welfare Benefit caseworkers and specialists in Wales.· It would also be helpful to include a separate point on the giving away of second hand clothing to families in financial difficulty.
Q8 Are there any other examples of good practice by schools in relation to financial assistance for school uniform that could be included in Section 5.7? If so please specify them.
As previously listed, other examples of good practice are: · Indicating on school kit lists when items are required by so that parents are not requested to buy all items at once. Some items such as sports kits are seasonal and not required until some time later in the year· Making reference to financial assistance where uniform requirements are listed. This may be in letters informing about kit lists, school prospectuses, websites and in consultations about changes to uniforms. For example: A school in East London planned to change its uniform policy in September 2002 to include a blazer for all pupils. In its correspondence with the parents the school recognised the extra cost of this and potential difficulties this could raise for some families. They gave details of the grant help available from the LEA and offered discretionary assistance for those not eligible to LEA assistance. In addition the blazer would not be made compulsory for pupils moving into the top two years in September 2002 as they would have limited wear and hence reduced value for money from it.
Q9 Please provide any information you have on what support with school uniform costs is available currently and what it costs. LEAs are invited to provide copies of their present schemes. Please express your views on what would be appropriate and realistic for the future.
Paragraphs 5.8 and 5.9:We very much welcome the recognition of the Welsh Assembly Government of the financial hardship some parents face in purchasing school uniform for their children. Citizens Advice conducted a review of all grant schemes in Wales to accompany the CAB evidence briefing paper ‘Help with school clothing costs’ (August 2002). We contacted all LEA’s again in February 2004 and have updated the data (See Annex 1 – Bold Italics). It is encouraging to see that none of the LEAs have lost existing schemes and a new scheme has been introduced by Wrexham to bring the total schemes offered to 17 out of 22 LEAs. However, the inconsistencies in the eligibility criteria, amounts awarded and payment methods that still exist, uphold the case for a minimum set of standards of financial support. The case remains that the WAG cannot depend on LEAs administering discretionary funds. The following case illustrates the hardship faced by some families where a specified scheme does not exist which would apply in Wales and England: A Kettering CAB client was a lone parent on income support. She contacted the bureau in search of help with the costs of uniform for her three children. She had already contacted the school, but they could only help with certain items. The LEA advised that they could offer to assistance with the costs. The client was going to find it difficult to buy the essential items of uniform for her children to return to school. (August 03)Paragraph 5.10:The minimum standards we recommend are listed in Section 7 of Uniform Failure (2001) whose information that this Guidance has drawn upon: However, in line with new evidence we have received, Eligibility criteria needs to reflect the new tax credits:· Eligibility criteria should not be limited to IS IB/JSA. We suggest it should include all families in receipt of Child Tax Credit (CTC) above the family element i.e. for 2003/4 higher than £545. This would include many families on working tax credit and it parallels criteria for sure start maternity grant and other schemes such as help with legal costs. Families on WTC should not be automatically excluded, as some of these families will not necessarily have incomes any higher than families on income support.There have been problems with the introduction of Child Tax Credit and the implications for passported benefits. A couple from Ynys Môn lost their entitlement to Income Support after claiming CTC, as their income was increased to a level £10 higher than the threshold. As a result, the clients lost their entitlement to school uniform grants for their three children. They are worse off as a result. · Grant levels need to be adequateMiddlesbrough’s client, a lone parent with two children, applied for a grant towards the cost of uniform for her child starting secondary school and received £15. However, the estimated cost of the uniform for a child in this position is £200. The help given by the LEA is totally inadequate for a family living on benefit when costs are this high. · Comprehensive information and publicityEven when there are grants available, LEAs sometimes do not make parents aware of this. Sedgefield and District’s CAB have reported over a hundred of cases of families struggling to meet the costs of school uniforms. The LEA did in fact provide a one-off grant of £25 towards meeting these costs, but many of the families in need of this assistance were unaware of its existence. The bureau put an advert in the local paper and had over 100 people come in to request help applying for a grant.· Applications should be accepted for each child at any time in the school year. High Wycombe CAB reported their client on income support and higher rate disability living allowance applied for a school clothing grant for his twins who were due to start school. However, the LEA turned down his application as he had received a grant the previous September for his older child, who had transferred to secondary school. He was concerned that the twins were suffering at school because they were not wearing the uniform and he had received two phonecalls from the head teacher requesting that they wear it.· Grants should be available for all children of statutory school age.Consideration should also be given to children in nurseries in mainstream schools. Even if uniform is not compulsory, where it is worn by the majority, financial constraints should not give cause to a child not having the uniform. Hull City Centre CAB recorded a case of a client with a three year-old daughter in a ‘foundation’ year at a local primary school. The school recommends that pupils wear uniform, but the client is on Income Support and unable to afford this. She applied for a grant from her LEA, but was told that they only awarded grants to pupils of compulsory school age. · How the grant is administered: a) It is important that schools uniform policies are monitored for their compliance with the guidance. The DfES issued guidance to English schools in 2002 but CAB evidence demonstrates that many schools do not adhere to them. For example: In February 2003 a CAB in Somerset (Keighley and District) reported a client whose son was sent home from school for not wearing his blazer. The school have advised that he must wear the full school uniform or he cannot attend even though the client has promised that he will purchase a blazer as soon as he can afford one. Two bureaux in Somerset report problems experienced by their clients as a result of Somerset LEA not providing a grant for help with school clothing costs. (Following the publication of Uniform Failure the LEA wrote to advise that they had no knowledge of any difficulties experienced by parents). Such action would not comply with the spirit of paragraph 4.6 of this document and it would be important that systems either within the LEA or the WAG were established to ensure that any future guidance was followed. It might be judged that this monitoring of compliance sat most comfortably with the body responsible for administering the grant scheme and this might influence the decision over who is best to provide the grant scheme. It may well provide a strong argument for the administration of the grant to be via the LEAs as it is likely to be easier for them to monitor the uniform policies of the schools in their area. b) It is also important that school clothing grants are administered efficiently A bureau in the North West reported that their client had applied for a uniform grant in the middle of April for his child starting secondary school in September. However by the end of September they had heard nothing. They chased it up to find that it had yet to be processed. Three months after the start of the school term it still had not been received. After lots of chasing round the Local Authority trying to find the right person the bureau were eventually told it would be issued within two weeks. (Dec 03)c) Particular schemes should be clearly advertised and easily accessible to parents on low incomeA Bargoed CAB client who was on Income Support had always been able to purchase her son’s uniform from his school in two or three payments. She was concerned therefore when she was informed that the school would be no longer supplying uniform but that it would be available from a sports shop in a town 9 miles away. Whilst she was told she would still be able to pay for it in instalments, the uniform would be more expensive and she would in addition have to pay for the travel costs of using the train or the bus, neither of which ran a good service. The bureau wrote to the school asking why the service has been stopped and asking if there could be a day when a rep from the shop could pay a visit. (May 02)d) LEAs must be fully aware of the status of benefits in relation to income calculations when deciding on awards:Neath CAB reported a 46 year-old parent with 8 dependents, one of which was disabled. The parent was refused a school uniform grant on the basis that there was too much household income. Further investigations revealed that the child’s disability premium, included as part of Income Support, was counted as income in the local authorities’ calculations. The client was forced to purchase the school uniform out of the disability money. This money should have been used for other necessary support for the disabled child (September 2003).
GENERAL
Q10 Does your school have any good practice ideas regarding school uniform that can be shared with other schools? Please give details.
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