As Peter Drucker famously remarked, “culture eats strategy for breakfast”.  It is therefore no use the Church of England running its own systems for safeguarding investigations and inquiries.  Church of England culture remains mired in fear and shame.  The primary purpose of its safeguarding enterprise remains cosmetic, reputational and financial.  

This ‘culture’ consumes process, fairness, justice, truth, transparency and integrity at every turn.  If the Church of England wants to remain as a religious, civic and unrestricted body that can serve the nation – and that is an “if” – then it needs to behave like a morally responsible public body.  

Some medieval theologians viewed anxiety and shame as close relatives of fear.  They argued that fear tended to over-regard evil, producing frenetic activity and inertia in equal measure. The Church of England’s proactive, reactive, slow and sloppy work in safeguarding fits this paradigm. Fear is key. The response of the Church – in person, in role in process and as institution – is fright, fight and flight.  The CofE leadership is lost in their own hormonal maelstrom.

The behavioural paradigm of the Church of England can be traced within the classic psychotherapeutic drama-triangle model. Starting off with good intentions, the Church sees itself as the Rescuer of the Victim, and against the Perpetrator.  But the processes are unable to cope with the raw fury and persistent anger of a Victim. The Church is not equipped to manage this (e.g., “…can we get you some more pastoral care?”, etc.).  Financial liability, potential reputational damage and lack of resources mean that the Victim can be heard, but then has to shut up.

The Rescuer role is a long-term, demanding and complex responsibility. No Diocese employs such a person. Nobody who is abused is ever going to be rescued by six free sessions of counselling. Or more “pastoral care”.

The Victim then finds that the Rescuer is slow, unhelpful, evasive and also wary.  The Rescuer wants to help, but is hampered by the institution, its opaque processes, and its lack of transparency and accountability.  The Victim turns on the Rescuer (i.e., the Church). At this point the Church will claim that the demands made upon it are unreasonable.  In the mind of the Church/Bishop, the Victim is now persecuting the Rescuer.  Victim-blaming begins.

The Church, in turn, fights back against the complainant, becoming another chapter in the persecution true Victims experience. In this way, the Church of England oscillates wildly across the passive-aggressive spectrum. It wants to appear to be caring and compassionate.  But if the institution is simultaneously being held responsible and blamed for the abuse, then the Church resorts to self-defence – and especially reputational and financial safeguarding.

The opacity of the Church of England on safeguarding is also, probably, a form of subconscious institutional self-defence.  Take the definition of ‘vulnerable adult’ in the 2016 Care Act. The Church pays regard to this, but then expands its ambit in a way that is both dangerous and indefensible.  

Is a bereaved person a ‘vulnerable adult’? According to many Safeguarding Officers in the Church, the answer is “yes”, since the grief-stricken are distressed.  Should a funeral visit be risk-assessed with the Safeguarding Officer first? Again, yes, because the person “might be vulnerable at this time”. 

The Church of England regards everyone as a “potentially vulnerable adult”, and so subject to “safeguarding concerns”.  There are just two exceptions to this rule.  The accused who is the respondent. And the angry, persistent, mendacious victims who keep complaining and may have significant mental health and trauma issues.  These two categories are habitually denied any ‘vulnerable adult’ status.  The CofE determines who counts – and who doesn’t. 

The Church of England would position itself better in the public domain if it made itself subject to Nolan Principles that govern public life.  This may include adopting equality legislation that addresses gender and sexuality, ending the ‘opt out’ clauses permitting the Church to discriminate in the name of theology or to protect dissenting (minority) ecclesial traditions.

The Church of England needs to place itself under a new Independent Safeguarding Regulation Authority. One that was free from paying homage to ecclesial patronage and deferring to episcopal authority.  Such a regulator could firmly bind the Church to principles of law and justice first, be thoroughly forensic with its investigative powers, and have the authority to call the Church to account.  (The CofE will resist all of this).

This would be far better for many denominations. And perhaps specially the Church of England, as they are, instead, (inevitably) always trying to read cases of sexual abuse, harassment and safeguarding in a bifurcating and binocular way, with one lens always firmly trained on reputational risk.  

Good models exist in other professions. The General Medical Council, or Solicitor’s Regulation Authority, to name but two.  The Church of England must find a way to disgorge itself from the partial, political, weaponised, uneven, amateur, corrupted, under-resourced, over-anxious, conscious and subconscious actions that cause people to become ill, self-harm and even commit suicide over safeguarding allegations and concerns.  

Currently, the Church serves none of the stakeholders well. Respondents and Claimants alike frequently cite the conduct of Core Groups, Bishops and Safeguarding Officers (DSA’s) as further abuses and trauma.  Core Groups lack basic conflicts of interest policies. If they exist, they are frequently ignored or forgotten.  Mostly, they don’t exist.

Significant numbers of DSA’s neither know or own the policies of the National Safeguarding Team (NST), which in any case are pretty fudgy. No ‘Lessons Learned’ are ever learnt.  Reports and Reviews are seldom seen. Core Groups lack legal training, representation and expertise.  

Actually, they lack training: full-stop. Core Groups are mostly populated by persons representing communication/press (i.e., reputational management) and the Bishop (i.e., more reputational management). Minutes of meetings are not taken. If they are, Respondents and Claimants may not be allowed to see them. Neither the Respondents or Claimants are allowed representation at a Core Group.  

Core Groups have no mechanism for fact-checking, and no system of triage. Intense and unbounded pastoral gossip sessions need proper scrutiny, checks and balance.  Otherwise this trains of thought have no braking mechanism. 

The basics of ‘confirmation bias training’ have never seen the light of day in the Church of England. Why? Because at a Core Group, uninformed opinion and un-evidenced alarmist concerns will be understood as an urgent pastoral matter or spiritual discernment, and once vocalised, will be affirmed as insightful.

Without a proper legal basis for Core Groups, Respondents and Claimants alike are doomed.  That is what they all experience too – opaque, tortured, unaccountable and non-transparent ‘verdicts’. Against which there is no appeal. The investigators appointed by the NST are unlicensed, unregulated, unaccountable and can be untrained (or self-appointed).  These individuals can investigate any clergyperson on any matter, and without boundaries or any kind of mechanism for appeal.  

Clergy, let us remember, are licensed, regulated, accountable, trained and generally not self-appointed.  Can the Church of England think of any other profession where this kind of imbalance in power, authority, employment and human rights would be permitted? The premise of process is inherently abusive.

In the midst of this, all the Church of England offers Respondents and Complainants is “pastoral care during this difficult time” or “some counselling” (perhaps). But Respondents and Claimants share the same problem here under the Church of England’s safeguarding.  They have no rights, little information, poor process, and no advocacy.

Liberation Theology teaches us that in the face of abuse and oppression, pastoral care without advocacy is no better than tea and sympathy.  Just like the prayers and good wishes of the Levite and Pharisee in the Parable of the Good Samaritan. If all the Church of England can offer to Respondents and Claimants is a rationed portion of some thin gruel of pastoral care, sentiments and sympathy, it is time to stop pretending that we can deliver safeguarding at all, and admit defeat.

With safeguarding allegations, the experience of Respondents and Claimants is overwhelmingly negative at the hands of the Church of England.  It is time to face this, and separate out the functions, roles and callings the Church can manage.  Faithfulness is not always holding fast. It is also letting go, and trusting God.  God may bless the courage that confesses inadequacy.  

It is time for the Church of England to divest itself of safeguarding responsibility.  The Church needs to be placed under a genuinely Independent Regulatory Authority that would command trust and confidence. Then Complainants and Respondents alike might trust such people and processes who submit to external authority, are made accountable, open to scrutiny and subject to transparency. Meanwhile, our self-regulation lacks competency, and can even be corrupt.

By letting go of functions that it plainly cannot manage, and having the courage and humility to publicly admit this, the Church of England might actually get some of the support it really needs. My concern is that pride, fear, shame and anxiety will continue determine the culture of our episcopal leadership.  That means real change only ever consists of empty promises and cheap cosmetic procedures.  Complainants about abuse will also be relieved not to get threatening letters from lawyers on instructions from Bishops, because the Bishop does not like being held up to public scrutiny or any accountability.  I have been writing to both Archbishops for over a year to complain about:

“the corruption, partiality, incompetence, conflicts of interest, cover-ups, misconduct and malfeasance riddling the oversight and practice of safeguarding in the CofE and NST. It is not safe, and the current structures permit and licence the deliberate ‘weaponisation of safeguarding’ with intent to cause harm to individuals”.

I have carefully explained the personal, reputational and financial damage this caused me.  I have described this treatment as “abuse”, and I have made repeated and detailed disclosures, with supporting written evidence, to them both.  The Bishop of Oxford has had all the same information for over two years.

Their response to this is to tell me that “on legal advice they do not consider me a victim of abuse”.  Yet I had sent them their own guidelines on this (see: section 3 of [2018] ‘Types of Abuse Factsheet’ at I had described the impact of the deliberate “project-managed persecution” perpetrated by church lawyers, church officers, clergy, the NST and the Bishop of Oxford. The Lead Bishop for Safeguarding returns every email with an “out of office reply”, so there is no point in making a disclosure: they are never there. The season for hand-wringing Bishops, Diocesan or NST reassurances on safeguarding from our leaders is over.  Trust and confidence in the Church of England has gone.  We need a total revolution. Yes, total revolution.

The Very Revd. Professor, Martyn Percy, Oxford

Note: For ToR drafted by retired lawyers on behalf of the Dean, requesting a thorough Independent Inquiry are referred to at:  You can also read the ToR from the ISB at the same address.  Please note, the ISB took instructions from the respondents to complaints.  Who in turn, made sure the complaint was turned against the complainant, and “weaponized”. Let us hope that other complainants do not receive threatening letters from the Bishop of Oxford’s lawyers, as others have done.  We will let you know if we do.