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Archived Transcript for 13 December 2001:
Pages 151 to 200
151
1 MR GARNHAM: And you were not getting one?
2 MS GRAHAM: And I did not achieve it in that meeting.
3 MR GARNHAM: Go on to 264 in that same bundle, please. From
4 you to Anne Bristow:
5 "Anne, this follows on from a suspension of B."
6 Then a message "refer to" from you to Carol Wilson
7 addressed to "Dear Dave and Carol":
8 "I have given some more thought to the proposal put
9 forward by Angella and Rose yesterday and would like to
10 include another section to their document. This section
11 is about the relationship between Rose, Angella and the
12 CPAs/ROs ... I would like to discuss the following.
13 "1. That Team Managers and Practice Managers will
14 continue to make case management decisions but raise all
15 serious child protection issues/concerns with [you].
16 "2. The advice given by ROs/CPAs is taken."
17 MS GRAHAM: Would it be all right for me to interrupt you?
18 MR GARNHAM: Please.
19 MS GRAHAM: This is dated 19th of July and this is me
20 setting --
21 MR GARNHAM: I am so sorry --
22 MS GRAHAM: -- setting the ground.
23 MR GARNHAM: You are quite right. I am glad you did,
24 because although this is a memo dated 1st December, it
25 is quoting a much earlier memo.

152
1 MS GRAHAM: That is right.
2 MR GARNHAM: Thank you. 255 in this bundle, please. This
3 is the Prince report.
4 MS GRAHAM: I will just go to the front to see which Prince
5 report.
6 MR GARNHAM: Yes. Interim report on investigation into
7 Hornsey DIAT.
8 MS GRAHAM: Yes.
9 MR GARNHAM: Page 255, "Child Protection Advisers". Let us
10 check the date of this.
11 I do not see any date on the report but there is
12 a covering letter at page 250 from Mr Prince which is
13 dated 11th January 2001:
14 "Currently and certainly recently, there appears to
15 have been a number of structural problems between the
16 child protection advisers and the operational teams.
17 "The 'advisers' have been seen as such, rather than
18 as managers. Yet they are graded as team managers.
19 This means that their 'advice' on cases can be ignored
20 or overruled, even if it is sought. As chairs of child
21 protection conferences they commented that some team
22 managers ignored or changed formal protection plans
23 without consultation. This is unacceptable and
24 potentially a disciplinary matter. Child
25 protection conferences are convened ..."

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1 That is explained. Then in paragraph 3:
2 "The managerial status of the advisers should be
3 re-emphasised and protocols developed as to how best
4 they can work with the teams. Equally, their advice,
5 when put on file, carries a management authority which
6 should be recognised."
7 So although I was wrong to rely on that memo of
8 December 2000 as showing that this problem was
9 continuing, it appears from Mr Prince's report that by
10 January 2001 the problem was still persisting.
11 MS GRAHAM: This report was commissioned following the
12 March 2000 audit and so it relates more to that time.
13 It is closer -- it relates more closely to that time
14 than it does to 2001 but when I was the Acting Assistant
15 Director I had not seen the outcome of this report.
16 I think you know who it relates to and so I had asked
17 for it. So it is not describing the situation in
18 January 2001, although that could have been the
19 situation.
20 MR GARNHAM: That was my next question. Was it the
21 situation or was this problem about the status of CP
22 advice settled?
23 MS GRAHAM: By now I was the Acting Assistant Director and
24 so I had not yet put anything different in writing but
25 as the Assistant Director it certainly was the protocol.

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1 MR GARNHAM: Do you know whether Angella Mairs now accepted
2 the position?
3 MS GRAHAM: In January we had -- it was a difficult time,
4 you understand, and shortly after that Angella was
5 suspended.
6 MR GARNHAM: Did she, before suspension, ever sign up to the
7 process whereby CP advice was to be accepted?
8 MS GRAHAM: Following the memo to Carol Wilson -- I do not
9 know if Dave was copied into it but it did go to Dave.
10 Dave did -- the feedback from me to Dave was to issue
11 the protocol. It was accepted.
12 MR GARNHAM: I see. While we are looking at this report can
13 you just go back to page 253, please, to a section of
14 the Prince report headed "A Failure to Manage" and
15 remind ourselves that this is addressed to Hornsey:
16 "It would seem that problems concerning the Duty
17 system were known of for a considerable time. My
18 previous report in 1997 ..."
19 Sir, I will be corrected if I am wrong but I do not
20 think we have seen that and if we have I not wonder if
21 we could have it.
22 "My previous report in 1997 had highlighted some of
23 the difficulties faced on the Duty system. These were
24 caused by various social workers behaving in an
25 inappropriate fashion. Whilst the problems and the

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1 individuals concerned were known to the management team,
2 little if any proactive action seems to have taken
3 place. Duty and its problems were a constant item on
4 the management team meeting's agenda. This extended
5 over a number of years, yet no resolution appears to
6 have been reached, nor apparently were individual
7 delinquent workers challenged by their own supervisors
8 in a manner which precipitated change.
9 "It appears that the individual managers of
10 particular workers failed to take control over their
11 behaviour concerning Duty and that the management team
12 failed corporately."
13 Is that an analysis you accepted?
14 MS GRAHAM: (Nods).
15 MR GARNHAM: You are nodding.
16 MS GRAHAM: I am trying to think back and to take it in at
17 the same time but I think, yes.
18 MR GARNHAM: We have already seen evidence of a viewed-from
19 outcomes of a position in which you have agreed was
20 appalling in Hornsey. We are now looking at the
21 position from input and it is plain where the problem
22 lies, is it not: a failure of management, failing to
23 prevent delinquent workers misbehaving in the way they
24 went about their work, yes?
25 MS GRAHAM: Yes.

156
1 MR GARNHAM: Can I turn now to ask you a little about the
2 role of the link officer, please.
3 You were the link officer between Haringey
4 Social Services and the NMH between 1992 and 1998,
5 I think.
6 MS GRAHAM: Yes.
7 MR GARNHAM: You were then succeeded by Petra Kitchman.
8 MS GRAHAM: Yes.
9 MR GARNHAM: When you were the link worker, what did you
10 understand to be the purpose of the post?
11 MS GRAHAM: I understood the purpose was to meet with the
12 hospital doctors, Dr Rossiter and Dr Naidoo, to exchange
13 information between the agencies, to focus on practice
14 developments and to focus on cases that may have arisen.
15 That basically was the purpose. Next to that was the
16 link similarly with the hospital social workers.
17 MR GARNHAM: So both of those were functions held by the
18 link worker, were they?
19 MS GRAHAM: Yes.
20 MR GARNHAM: Petra Kitchman succeeds you. By the time she
21 does that, is there in place a written agreement between
22 Haringey Social Services and the NMH setting out the
23 duties of the link worker?
24 MS GRAHAM: In part there is the Hospital/Social Work
25 Agreement and I do not think it names the liaison

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1 officer, so I would have to say no.
2 MR GARNHAM: Any internal protocol which Petra Kitchman
3 could have resorted to to understand what she is doing?
4 MS GRAHAM: We discussed the role many times, not just in
5 relation to Petra but in relation to other advisers, and
6 so it was understood, in my view, but I am not able to
7 get a written document to support that view. We did
8 have a meeting with the Enfield social worker setting
9 out clearly that role but neither Enfield nor myself
10 have been able to get a hold of a copy.
11 MR GARNHAM: When you say "that", we are talking about that
12 aspect of the job which relates to a relationship
13 between Enfield social workers and Haringey
14 Social Services?
15 MS GRAHAM: To the liaison role.
16 MR GARNHAM: So both elements of it?
17 MS GRAHAM: Yes.
18 MR GARNHAM: So you say that was discussed in a meeting with
19 Enfield?
20 MS GRAHAM: With the hospital social workers, yes, and it
21 would have been discussed at a meeting with Dr Rossiter
22 and Naidoo as well.
23 MR GARNHAM: It would have been?
24 MS GRAHAM: It definitely was.
25 MR GARNHAM: When? Before Kitchman took on the post or

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1 afterwards?
2 MS GRAHAM: I took Petra to the meetings and we discussed
3 her role so we met with Dr Rossiter, Dr Naidoo and
4 others that may have been there and I handed over -- we
5 discussed her role and when I met with the hospital
6 social workers I remember that one very clearly, because
7 I did not always meet with all of them and all the
8 hospital social workers were there, even those for
9 adults and elders.
10 MR GARNHAM: So this would have been soon after Kitchman
11 took over from you?
12 MS GRAHAM: Yes, I have the dates in my statement somewhere.
13 MR GARNHAM: I probably missed it but we can find it. Did
14 you provide Ms Kitchman with any written guidelines for
15 her job as a link person?
16 MS GRAHAM: Her Performance Development and Review sheet, we
17 looked at her role overall and on that is the outline of
18 my expectation.
19 MR GARNHAM: I think that says she is to attend bimonthly
20 meetings.
21 MS GRAHAM: Yes.
22 MR GARNHAM: Anything else?
23 MS GRAHAM: Umm.
24 MR GARNHAM: We will look at it in a moment.
25 MS GRAHAM: It is not detailed.

159
1 MR GARNHAM: Except what she could pick up when you took her
2 along to introduce her at these meetings, was there any
3 guidance given to her about how she should go about her
4 role?
5 MS GRAHAM: Yes. It was more than just picking up. Petra
6 and I would have discussed the role at length not
7 just -- before we went to the meeting I would have
8 introduced Petra to the meeting and went through her
9 role. And certainly at the hospital meeting, went
10 through it in great detail because there were others
11 there who also did not know.
12 MR GARNHAM: Let us identify what the elements of her role
13 were. Firstly, to attend this bimonthly meeting?
14 MS GRAHAM: Yes.
15 MR GARNHAM: What would she to do while she was there? What
16 was she to do while she was there?
17 MS GRAHAM: To adhere to the agenda that had been set and
18 the basis for the agenda --
19 MR GARNHAM: So any matters arising so to speak she would
20 address?
21 MS GRAHAM: The basis for the agenda would have been, as
22 I said earlier, the new developments between the
23 hospital and Haringey, about --
24 MR GARNHAM: Presumably this meeting discussed structural
25 matters, did it?

160
1 MS GRAHAM: Yes.
2 MR GARNHAM: Or would it discuss individual cases?
3 MS GRAHAM: Both.
4 MR GARNHAM: What was Petra Kitchman to understand she was
5 to do on receipt of information from the doctors during
6 the course of such meetings?
7 MS GRAHAM: To respond to it as a child protection adviser.
8 MR GARNHAM: So providing advice?
9 MS GRAHAM: Or whatever else was required in the role of an
10 adviser.
11 MR GARNHAM: I am trying to understand what was required in
12 the role of an adviser.
13 MS GRAHAM: It would be to note the concern and then to
14 follow that through. So if the concern --
15 MR GARNHAM: How would she do that?
16 MS GRAHAM: She would note the concern from Dr Rossiter or
17 Dr Naidoo and make contact back with the district. She
18 would either contact the appropriate person --
19 MR GARNHAM: So for example Dr Rossiter would be correct to
20 regard her as the person with whom she should speak if
21 she wanted to express concerns about a particular case?
22 MS GRAHAM: It was twofold.
23 MR GARNHAM: Just answer that bit first if you would. Was
24 Dr Rossiter right to see Petra Kitchman as the person to
25 whom she should speak if we wanted to pass on concerns

161
1 about an individual case?
2 MS GRAHAM: No. Well it was twofold, I have to give you
3 that as my answer, in that if Dr Rossiter was aware of
4 the social worker she could make direct contact. If
5 Dr Rossiter felt that cases were not being progressed as
6 she should then Petra then came in as the link.
7 MR GARNHAM: How was Dr Rossiter to know that that was to be
8 the process?
9 MS GRAHAM: I do accept that I could have put things in
10 writing and that I should have, and certainly I do see
11 that as a weakness in that liaison function. I fully
12 accept that.
13 MR GARNHAM: Because the problem is obvious, is it not?
14 MS GRAHAM: It is.
15 MR GARNHAM: Rossiter thinks she is dealing with the matter
16 by raising it with Kitchman and Kitchman thinks that
17 Rossiter, if she had a problem, would deal with it
18 direct to the social worker.
19 MS GRAHAM: I had worked for many years with Dr Rossiter and
20 it is my view that we had clarities to my function as
21 the liaison officer and therefore Petra's and other
22 matters, but I understand that I have not got that in
23 writing and that that is a weakness.
24 MR GARNHAM: Did either the Purple Book or "Working
25 Together", two documents to which you refer in this

162
1 context, describe in any detail this link role?
2 MS GRAHAM: No they did not.
3 MR GARNHAM: So it is a matter, is it, of us accepting from
4 you your belief that Rossiter knew what the correct
5 procedure ought to be?
6 MS GRAHAM: Yes. I can understand how this matter has
7 arisen.
8 MR GARNHAM: Yes. Has that now been addressed so that
9 people are all clear as to what is to be the means of
10 contact between the hospital and your department?
11 MS GRAHAM: Matters have progressed such that now we have
12 hospital social workers in the hospitals and so with
13 some further work as -- to sort out Petra's link with
14 them. But, for the time being, that has not been fully
15 resolved.
16 MR GARNHAM: It still has not been fully resolved?
17 MS GRAHAM: In as much as that Petra has not been at work
18 and Petra has reduced her hours to part-time.
19 MR GARNHAM: Who is Dr Rossiter meant to communicate with
20 now?
21 MS GRAHAM: She contacts me, so she contacts me as Head of
22 Service.
23 MR GARNHAM: She does that in respect of concerns she has on
24 a particular case, does she?
25 MS GRAHAM: She would write to me if she felt that was the

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1 need but I have been -- it is my error and I own that
2 and I have been trying to pick up a few bits of work,
3 and I know that the hospital social workers have just
4 recently got into the hospital. I do not mean that in
5 that way. They are recently in post and have taken up
6 post so we need to sort out those roles and
7 relationships. I have not as yet got to that stage.
8 I do know that David Derbyshire is in discussion with
9 Enfield, but I have not joined him yet to be party to
10 those discussions.
11 MR GARNHAM: It is over two years since precisely this sort
12 of contact went wrong in Victoria's case, is it not?
13 MS GRAHAM: It is.
14 MR GARNHAM: So how is it that it is still not resolved?
15 MS GRAHAM: I think the full extent of that miscommunication
16 has more recently become apparent to me and I do
17 apologise for that.
18 MR GARNHAM: You tell us in paragraph 8 of your second
19 statement that the link role was raised in each
20 supervision you had with Kitchman.
21 MS GRAHAM: That is right.
22 MR GARNHAM: Were you giving her directions about the way
23 she should do this role during the course of those
24 supervisions?
25 MS GRAHAM: It is my view that we understood what her role

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1 was and so we were discussing matters that would have
2 arisen and I was just checking.
3 MR GARNHAM: Can we then have a look at those supervision
4 notes, 29A, please. Page 019. This, I think, is your
5 notes of your supervisions with Petra Kitchman and the
6 first one is 25th June 1999. Just point to me, will you
7 please, where this is discussed?
8 MS GRAHAM: You will see on the left-hand it has Petra's
9 name. If you go to the next column, if you go four
10 points down it says "North Mid".
11 MR GARNHAM: Is that paragraph 7 on the next page? Oh
12 I see, that is in the agenda, yes. Then if we go to
13 point 7.
14 MS GRAHAM: Yes, I had not turned over the page.
15 MR GARNHAM: "Petra attend meeting. All going. NAI meeting
16 Tuesday. Sharon Johnson is link. Attending hospital
17 team meetings. Threat of cuts".
18 MS GRAHAM: That is right.
19 MR GARNHAM: So that was the reference to the role there.
20 That sounds as if it is an updating; you being updated
21 by Kitchman on the state of play at the time.
22 MS GRAHAM: She was passing information back to me, she was
23 updating me.
24 MR GARNHAM: No obvious direction by you as to how she
25 should carry out her role there?

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1 MS GRAHAM: What I would say is that because we had got to
2 the position with Sharon Johnson there had been previous
3 discussion as to direction. The NAI meetings became an
4 obvious gap so we had discussed a direction previously
5 and this was an update as to that.
6 MR GARNHAM: I will come back to ask you a bit about the NAI
7 in a moment. Can we go to the next one, please.
8 Page 22. There is a mention in the agenda of hospital
9 social worker. Any other discussion on this liaison
10 role?
11 MS GRAHAM: If you go to page 024 there is a reference
12 there.
13 MR GARNHAM: You will have to help me with that. Is that
14 number 10?
15 MS GRAHAM: It is number 10.
16 MR GARNHAM: What does it say?
17 MS GRAHAM: "Hospital meeting", HSP, and "team meeting of
18 social workers."
19 MR GARNHAM: Then beside it there is a mention of somebody
20 being pregnant and something about a book.
21 MS GRAHAM: Under "team meeting of social workers" it is to
22 book another time so the meeting perhaps had not gone
23 ahead.
24 MR GARNHAM: The next one, page 26. Anything there?
25 MS GRAHAM: There is a tick against number 8 and that is

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1 Dr Lloyd and hospital link and the purpose of that was
2 Dr Lloyd was a local GP who I had met at Dr Rossiter's
3 training course who discussed with me in meetings that
4 he had in the community -- he is a doctor closely linked
5 to North Tottenham office and we had wanted to attend
6 his meetings but we were not able to between Petra
7 and I.
8 MR GARNHAM: Page 28, the next one. The next and I think
9 the last.
10 MS GRAHAM: On page 029 it says "North Tottenham meetings".
11 MR GARNHAM: Yes.
12 MS GRAHAM: And under "Discussion": "Enfield cuts may affect
13 social work posts".
14 MR GARNHAM: Yes. That is a reference to the hospital
15 social work post, is it?
16 MS GRAHAM: I will just re-read that. (Pause). I think it
17 is, because we have very few links with Enfield social
18 workers otherwise.
19 MR GARNHAM: What appears to emerge from those supervision
20 minutes is that there is no identification of any
21 problem of the -- in the nature of the work being
22 carried out by Kitchman in this role and no evidence of
23 any direction by you as to how she should go about the
24 work. Is that fair?
25 MS GRAHAM: Not entirely. I think that they are notes of

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1 our supervision discussions and so if -- so I was aware
2 of some problems, such as the absence of a hospital
3 social worker. Is that what you are --
4 MR GARNHAM: I am wondering whether there is any sense in
5 which she is being given directions by you, during the
6 course of this supervision, as to how to carry out this
7 job. It appears much more as if she is simply reporting
8 back to you on where she has got to.
9 MS GRAHAM: I think by now she would have been settled in
10 that role so that may be the case, that she is reporting
11 back, and there are no further developments that she
12 needs direction as to by now.
13 MR GARNHAM: You mentioned a moment ago the attendance by
14 social workers at the NAI meetings.
15 MS GRAHAM: Yes.
16 MR GARNHAM: You mention this in paragraph 14 of your second
17 statement. June 1998 you say there was an oral request
18 from Rossiter for a link person from Social Services to
19 attend the NAI forums.
20 MS GRAHAM: Paragraph?
21 MR GARNHAM: 14, second statement.
22 MS GRAHAM: Yes.
23 MR GARNHAM: "Request from Rossiter for link person from
24 Social Services to attend the NAI forums at the NMH."
25 MS GRAHAM: Yes.

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1 MR GARNHAM: You say Sharon Johnson allocated.
2 MS GRAHAM: Yes.
3 MR GARNHAM: Anyone else?
4 MS GRAHAM: I heard Petra's evidence and she was initially
5 keen to attend those meetings and we agreed she should
6 attend.
7 MR GARNHAM: How often did the two of them attend?
8 MS GRAHAM: Petra was not able to attend very much at all.
9 MR GARNHAM: One she told us.
10 MS GRAHAM: Yes, it could have been that.
11 MR GARNHAM: Johnson?
12 MS GRAHAM: I am not sure how often Sharon attended.
13 MR GARNHAM: Zero according to Kitchman.
14 MS GRAHAM: Right.
15 MR GARNHAM: So that the result of Rossiter's request for
16 a social work presence at the NAI meetings was that
17 Kitchman turns up once.
18 MS GRAHAM: Dr Rossiter certainly did request that somebody
19 attend and I was not able to meet that need.
20 MR GARNHAM: Why do you not tell us that in your statement?
21 MS GRAHAM: Sorry.
22 MR GARNHAM: You tell us of the request and you tell us of
23 the fact that Johnson was assigned to do this. There is
24 no mention of the fact that as it turned out you were
25 unable to meet that request.

169
1 MS GRAHAM: I am sorry, I could have put it in and I did
2 not.
3 MR GARNHAM: It is slightly misleading to omit it, is it
4 not?
5 MS GRAHAM: I do not think so, no. I would not agree with
6 that.
7 MR GARNHAM: Well one reads your statement and comes away if
8 one does not press with the impression that this request
9 was met. And it plainly was not.
10 MS GRAHAM: In 1998 I took Carol Wilson to a meeting at the
11 hospital, for other reasons, and at that meeting there
12 was a request for a district link and that -- and that
13 was followed through and Sharon Johnson became the named
14 person. Petra was also a link but I would not see Petra
15 as the main link to those meetings.
16 MR GARNHAM: No, but neither of them turned up except on one
17 occasion.
18 MS GRAHAM: I fully accept neither of them did, but I accept
19 that was passed on to the districts.
20 MR GARNHAM: So you might have done but that does not take
21 things much forward, does it?
22 MS GRAHAM: For Dr Rossiter, no. I accept that.
23 MR GARNHAM: Why was it that Dr Rossiter's request for
24 a representative from Haringey Social Services at the
25 NAI forums was not met properly?

170
1 MS GRAHAM: I was aware that Petra was not attending. We
2 had passed the link on to Sharon but I did not supervise
3 Sharon and so I was not aware that she was not attending
4 for some while.
5 MR GARNHAM: So you cannot help us with why it was that this
6 request of Rossiter's was not complied with?
7 MS GRAHAM: No. It was accepted by Dave and Sharon that
8 Sharon should be the lead -- the link, rather and should
9 attend.
10 MR GARNHAM: This question of communication between the
11 hospital on the one hand and Haringey Social Services on
12 the other is important, is it not?
13 MS GRAHAM: It is important, yes.
14 MR GARNHAM: You tell us that responsibility for the system
15 of communication was not part of your job description.
16 Paragraph 10 of your second statement:
17 "Responsibility for systems for the communication
18 concerns between hospital medical and nursing staff and
19 social services is not formally part of my job
20 description."
21 MS GRAHAM: What I mean by that is that if the nursing staff
22 wanted to -- the system with which they should
23 communicate from within the hospital was not part of my
24 personal responsibility.
25 MR GARNHAM: I understand. So you are addressing in that

171
1 paragraph only the mechanics for communication between
2 nurses and Haringey Social Services?
3 MS GRAHAM: Yes. We had the ACPC handbook and that was the
4 process through which we would communicate with each
5 other and then Petra was the link if there was a concern
6 about that through Dr Rossiter. I did not see --
7 MR GARNHAM: Was Petra Kitchman not there to facilitate the
8 proper communication of information between nursing
9 staff or doctors and social services?
10 MS GRAHAM: I saw that more as -- that if they were to make
11 communication with her, yes. If they were to contact
12 her. But I did not see that Petra's role was to work
13 directly with the nurses or doctors in the hospital.
14 I saw her link as being with Dr Rossiter.
15 MR GARNHAM: And so the nurses ought to be communicating
16 with you through the Enfield hospital social worker, do
17 they?
18 MS GRAHAM: That is how I understood it, or Dr Rossiter.
19 MR GARNHAM: You tell us that you say the ACPC handbook
20 would make clear to anyone at NMH what procedures should
21 be followed with regard to passing concerns. So you
22 expect the NMH staff to be familiar with the ACPC
23 handbook?
24 MS GRAHAM: Yes.
25 MR GARNHAM: Even though your staff are not?

172
1 MS GRAHAM: Sorry, what I meant there was the hospital
2 guidelines, that they should be familiar with them.
3 MR GARNHAM: Ah, not the ACPC which is what you say in
4 paragraph 11.
5 MS GRAHAM: Sorry.
6 MR GARNHAM: So we should delete your reference in the third
7 sentence in paragraph 11 to the ACPC handbook which you
8 exhibit?
9 MS GRAHAM: I should have included them both as opposed to
10 delete one or the other. Dr Rossiter regularly updated
11 her hospital guidelines and I know the hospital --
12 hospital social workers made clear that she did and on
13 top of that we were to all work to the ACPC handbook.
14 MR GARNHAM: Let me pursue a little bit further the extent
15 of communication between you and NMH. You have told us
16 how nursing staff ought to communicate with you, your
17 department. You have told us that in fact there was,
18 with one exception, no attendance by your department to
19 the NAI forums although you have not disagreed with me
20 about that.
21 MS GRAHAM: I also know it was Dr Rossiter who said in her
22 evidence that she would invite social workers to those
23 meetings. I might be wrong. No, I have that wrong.
24 I think it might be the Monday meetings.
25 MR GARNHAM: I think it was.

173
1 MS GRAHAM: That is my mistake.
2 MR GARNHAM: So at the moment we have virtually no
3 attendance at the NAI forum. How did it come about that
4 there were no social workers attending the Monday
5 psychosocial meetings on the wards at the NMH?
6 MS GRAHAM: This was something I was not aware of. I did
7 think that the Enfield hospital social workers were
8 attending those meetings.
9 MR GARNHAM: So you did not know that they were not?
10 MS GRAHAM: I did not know that they were not.
11 MR GARNHAM: Dr Rossiter tells us that she complained long
12 and hard, my words not hers, about the fact that
13 Haringey had no resident social worker at the NMH and
14 you say that has now been resolved as a problem?
15 MS GRAHAM: Yes it has.
16 MR GARNHAM: But for some time there was no such resident
17 social worker and you were dependent on the arrangement
18 you had with Enfield.
19 MS GRAHAM: That is right.
20 MR GARNHAM: You tell us in paragraph 15 of your second
21 statement that Enfield were funded for that dual role.
22 MS GRAHAM: That is what I was told, yes.
23 MR GARNHAM: The implication being, am I right, that
24 Haringey were not going to accede to the NMH's request
25 to have resident social workers at that time?

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1 MS GRAHAM: Yes.
2 MR GARNHAM: Could you have volume 26B, please.
3 Sir, I wonder whether this might be a convenient
4 moment for a break. I think the witness could rather
5 acutely do with one.
6 MS GRAHAM: Thank you, yes.
7 THE CHAIRMAN: Well Mr Garnham, of course. That would be
8 fine.
9 You understand that you are not allowed to discuss
10 with others while on the break. 3.25.
11 MR GARNHAM: Thank you, sir.
12 (3.15 pm)
13 (A short break)
14 (3.25 pm)
15 MR GARNHAM: Miss Graham I was asking you to look at
16 volume 26B please at page 239.
17 You were telling us before we broke that you did not
18 know about the non-attendance of social workers at the
19 Monday ward rounds and I think it is right that none of
20 the attendees at this meeting are from Haringey.
21 MS GRAHAM: That is right.
22 MR GARNHAM: I just wanted to ask you about the penultimate
23 paragraph which reads:
24 "There are a lot of problems with North Tottenham
25 District Office and referring to them (which is done by

175
1 the clinical staff in some circumstances). This causes
2 negative feelings about Social Services in general which
3 can be unjustified. It was felt that there is a need
4 for paediatric social work input from Haringey."
5 Then these words:
6 "It was stated that Enfield Social Services do work
7 with Haringey clients, carrying out checks et cetera and
8 do not always refuse to liaise on behalf of ward staff."
9 The implication of that as I read it is that on
10 occasions Enfield Social Services do refuse to liaise on
11 behalf of ward staff.
12 MS GRAHAM: Yes.
13 MR GARNHAM: If that is right it is a pretty unhappy
14 picture, is it not?
15 MS GRAHAM: Yes it is.
16 MR GARNHAM: And suggests that the arrangement that you
17 believe was in place with Enfield was not working?
18 MS GRAHAM: Not all of the time. It would suggest that.
19 MR GARNHAM: So we have non-attendance of Haringey social
20 workers at NAI forums, no hospital social worker from
21 Haringey and question mark about how well the
22 arrangement with Enfield is working. I think you have
23 already agreed with me that strategy meetings which
24 ought to be held in hospital were on occasions not held
25 in hospital.

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1 MS GRAHAM: Yes.
2 MR GARNHAM: And the consequence of that is that on those
3 occasions there was less chance of getting doctors and
4 nurses present.
5 MS GRAHAM: Yes.
6 MR GARNHAM: That paints, taken together, a pretty unhappy
7 picture, does it not? Strategy meetings happening in
8 North Tottenham District Office when they should be
9 happening at the hospital, nobody turning up at Monday
10 psychosocial meetings, no representatives on the NAI, no
11 residential social worker from Haringey and query the
12 effectiveness of the Enfield social worker in that
13 regard; the, if I can put it this way, imprecision of
14 the role that the link worker is performing given the
15 absence of any written guidelines. Would it be fair to
16 say that that adds up to the absence of any decent
17 system in place to ensure that Haringey Social Services
18 liaise properly with NMH, at least so far as Haringey
19 are concerned?
20 MS GRAHAM: I think it shows that an agreement that was put
21 in place between Haringey and Enfield was not being
22 adhered to and I think that it does show that the system
23 was not as strong as it could be.
24 MR GARNHAM: It hardly has an element left standing, does
25 it? You are not turning up at the NAI, you or your

177
1 representatives not turning up at ward social meetings.
2 Strategy meetings held in your department when they
3 ought to be held in the hospital. Where exactly is the
4 structure for communication?
5 MS GRAHAM: I did not know that Enfield social workers were
6 not attending the Monday meetings and I cannot say that
7 I was aware at that time that Sharon Johnson -- I do not
8 know that she was linked at this time, was not attending
9 the NAI meetings. I cannot say when I became aware of
10 that and I do accept that the clarity of role for Petra
11 and Dr Rossiter was not as strong as that could be.
12 MR GARNHAM: Looking back on it now, then, and using your
13 experience to make a judgment, that is a very unhappy
14 state of affairs, is it not?
15 MS GRAHAM: It is not a position that ensures that all
16 children receive a service.
17 MR GARNHAM: That will do, thank you. And the fault -- let
18 us be clear -- the fault for that lies on the Haringey
19 side of the equation, not the NMH, does it not?
20 MS GRAHAM: The Enfield social workers do not attend Monday
21 meetings, the psychosocial meetings, I am not sure is
22 the responsibility of Haringey.
23 MR GARNHAM: The rest? It is not the NMH's fault, is it?
24 MS GRAHAM: No, it is not.
25 MR GARNHAM: We have talked about hospitals contacting

178
1 social workers. How should social workers contact
2 hospitals? Is there a procedure or do they just ring up
3 the doctor they need to speak to?
4 MS GRAHAM: They would ring up the doctor she wanted to
5 speak to.
6 MR GARNHAM: So Lisa Arthurworrey uncertain of a medical
7 diagnosis for example could ring up Rossiter direct?
8 MS GRAHAM: Yes.
9 MR GARNHAM: And that is what she should do, is it?
10 MS GRAHAM: Yes.
11 MR GARNHAM: Thank you. Can I turn to the use of family
12 centres. Paragraph 47 of your first statement, please.
13 MS GRAHAM: My first statement has been taken away.
14 MR GARNHAM: Yes, you need it back. Could we see if it has
15 gone back into volume 3 of the green files please. I am
16 told it is volume 2, I am sorry. Page 159.
17 Paragraph 47.
18 MS GRAHAM: I have that as well.
19 MR GARNHAM: You tell us that social workers should be aware
20 of the existence and role of the Family Centre, the
21 Psychology Service and the NSPCC.
22 MS GRAHAM: I do, yes.
23 MR GARNHAM: You then go on to describe the use of the Maya
24 Angelou Family Centre.
25 MS GRAHAM: Yes.

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1 MR GARNHAM: That was not used in Victoria's case, was it,
2 that centre?
3 MS GRAHAM: No it was not.
4 MR GARNHAM: Instead Barry Almedia referred her case in
5 August to the Moira Close Centre.
6 MS GRAHAM: Yes.
7 MR GARNHAM: He did so direct.
8 MS GRAHAM: Yes he did.
9 MR GARNHAM: Given the review you conducted of this case
10 after Victoria's death, do you regard the reference of
11 Victoria's case to the Moira Close Centre as
12 appropriate? Is that where it should have gone?
13 MS GRAHAM: No, it should not have gone there.
14 MR GARNHAM: Should it have gone to either centre?
15 MS GRAHAM: I think that an assessment needed to have taken
16 place and an agreement as to which centre it should have
17 gone to.
18 MR GARNHAM: So it should not have gone anywhere before the
19 assessment, it should have stayed with Haringey?
20 MS GRAHAM: I would have expected it to -- unless Barry made
21 reference to an environmental health assessment so it
22 could be that part of the assessment would be
23 commissioned out, so to speak.
24 MR GARNHAM: But the handling of the whole case should not
25 go off to the Moira Close Centre?

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1 MS GRAHAM: I would not have thought so, no. Not as we
2 understand it now.
3 MR GARNHAM: Once an assessment had been done was this an
4 appropriate case for the Maya Angelou Centre?
5 MS GRAHAM: Not with the information we have now.
6 MR GARNHAM: It was not an appropriate ... not with the
7 information you have now, it was never a suitable case
8 for that centre?
9 MS GRAHAM: That is my view.
10 MR GARNHAM: Never a suitable case for either centre?
11 MS GRAHAM: Sorry, just to come back to the Moira Close.
12 Unless there was an element of the assessment that we
13 wanted Moira Close to take up. But the whole case as we
14 understand it now would not have been an appropriate
15 referral.
16 MR GARNHAM: In any event, before reference to either centre
17 it should have gone through the Children's Services
18 Family Support Panel?
19 MS GRAHAM: Yes. If it had been identified as a child
20 protection case that was the agreement.
21 MR GARNHAM: And Mr Almedia should have been aware of those
22 processes?
23 MS GRAHAM: Yes.
24 MR GARNHAM: It is right I think that you were previously
25 a chair of the Family Support Panel?

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1 MS GRAHAM: That is right.
2 MR GARNHAM: Were terms of reference ever established for
3 that panel?
4 MS GRAHAM: Yes I think so. I took over the chairing from
5 another chair and so they do not stand out in my mind
6 because I did not write them but I am sure they were.
7 MR GARNHAM: What was the role of the chair?
8 MS GRAHAM: The chair was to oversee the distribution of
9 work.
10 MR GARNHAM: Was there any conflict of interest in that role
11 between you as chair given that you were -- sorry. Any
12 conflict of interest given that you were both chair and
13 also a representative of Haringey?
14 MS GRAHAM: No, I think there would have been a protocol in
15 agreement as to how we worked together and the Moira
16 Close took cases from Haringey Social Services.
17 MR GARNHAM: Whose responsibility was it to refer cases to
18 the panel?
19 MS GRAHAM: Cases would be referred by social workers in the
20 first instance.
21 MR GARNHAM: So by the allocated social worker?
22 MS GRAHAM: Yes or the Duty social worker. The case had not
23 yet been allocated.
24 MR GARNHAM: The instance of Mr Almedia referring a case
25 direct to a centre, was that a single instance or did

182
1 that happen on occasions?
2 MS GRAHAM: It did happen on occasions.
3 MR GARNHAM: What action did you take as chair to ensure
4 social workers did as they were supposed to and referred
5 cases to the panel?
6 MS GRAHAM: Two actions. One was to remind people to inform
7 them again of the proper route to the panel and the
8 second was to --
9 MR GARNHAM: The route to the centre?
10 MS GRAHAM: To the panel are we talking about? Route to the
11 panel.
12 MR GARNHAM: What matters is you ensure the route taken, get
13 a case referred to the centre via the panel?
14 MS GRAHAM: That was the second point I was coming to, that
15 Moira Close was not to accept cases unless they had come
16 through the proper route.
17 MR GARNHAM: I see. Were statistics kept as to how many
18 cases were allocated through the panel and how many went
19 direct?
20 MS GRAHAM: Yes there were.
21 MR GARNHAM: What did they show?
22 MS GRAHAM: I do not have an analysis of those to hand.
23 MR GARNHAM: Was it a significant number going direct?
24 MS GRAHAM: Sorry, the cases going direct to?
25 MR GARNHAM: Yes.

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1 MS GRAHAM: No, no statistics as far as I knew. I only knew
2 about the child protection ones. Sorry, I misheard
3 that.
4 MR GARNHAM: The panel eventually stopped meeting I think.
5 MS GRAHAM: The panel did stop meeting in the sense that
6 panel representatives from Maya Angelou, they never
7 attended -- Moira Close did not attend along with
8 Red Gables; that is correct.
9 MR GARNHAM: When did that happen?
10 MS GRAHAM: It was some time in 1999 and I think it was the
11 latter part of 1999.
12 MR GARNHAM: What happened after the people stopped
13 attending?
14 MS GRAHAM: I did not always chair the panel. I delegated
15 that responsibility to Dawn Cardis and Dawn Cardis --
16 that was one of her projects so to speak, one of her
17 pieces of work, and so the panel worked such that Dawn
18 would prior to the panel meet with a team manager from
19 each of the district offices to go through the cases and
20 once they had gone through the cases the panel would
21 then meet and distribute work. Because I think Moira
22 Close closed its waiting list at some point and then
23 began to close as a centre, we were left with referrals
24 to Red Gables and so there was not a lot of point in
25 meeting because around the same time two team managers

184
1 moved post. So Dawn may have met with the manager of
2 Red Gables from time to time but there was not a formal
3 panel any more.
4 MR GARNHAM: I see. Were social workers and practice
5 managers aware of the difference in the sort of work
6 that was done by the two centres?
7 MS GRAHAM: Between Moira Close and Red Gables?
8 MR GARNHAM: No. I knew I was going have to say it again.
9 The Angelou Centre.
10 MS GRAHAM: Angelou and Moira Close?
11 MR GARNHAM: Yes.
12 MS GRAHAM: Yes, I would have expected them to be, yes.
13 MR GARNHAM: Were you aware of any preference among social
14 workers for one centre or the other?
15 MS GRAHAM: No, I could not say because they did different
16 work.
17 MR GARNHAM: Thank you. Can we now go back to paragraph 54
18 of your statement. This is the paragraph you were
19 anxious to take me through earlier and I have some of
20 your answers but I wanted to make sure I have understood
21 it all. There you set out the thirteen relevant
22 policies, procedures and guidance that you say was
23 applicable. Can I just run through them and make sure
24 I understand them?
25 Paragraph (a), Haringey Child Protection Guidelines.

185
1 Applicable but at least in Victoria's case breached in
2 some respects?
3 MS GRAHAM: Yes.
4 MR GARNHAM: (b) Haringey Child in Need policy. Relevant to
5 Victoria's case?
6 MS GRAHAM: It would form part of the Child Protection
7 Guidelines.
8 MR GARNHAM: Yes.
9 MS GRAHAM: It was a policy as to how we work with children.
10 That is -- there is a policy also in the part of the
11 Child Protection Guidelines.
12 MR GARNHAM: (c) Haringey Case Recording policy. Ignored as
13 far as Victoria's case goes?
14 MS GRAHAM: It was not complied with.
15 MR GARNHAM: Is my phraseology not the accurate one,
16 ignored, because at least some of the managers did not
17 follow it at all?
18 MS GRAHAM: Do they not come to the same thing?
19 MR GARNHAM: Well they might do and it is late in the
20 afternoon and I am not going to split semantic hairs
21 with you.
22 MS GRAHAM: Thank you.
23 MR GARNHAM: (d) Haringey supervision policy. At least one
24 of the managers, one of your staff I should say, did not
25 have a copy of it, namely Ms Kitchman.

186
1 MS GRAHAM: But she would have had the Performance
2 Development and Review procedure which included
3 a supervision policy.
4 MR GARNHAM: Do you know whether either of those two
5 supervision policies were applied with regard to the
6 supervision given to those responsible for Victoria's
7 case?
8 MS GRAHAM: I would not know.
9 MR GARNHAM: Both of them required a manager to have some
10 familiarity with the files, did they not?
11 MS GRAHAM: Yes. The Performance Development and Review
12 procedures is something that all Haringey employees are
13 to follow, so in that sense I understand we are all to
14 follow it but in those particular instances I do not
15 know whether they did or whether they did not.
16 MR GARNHAM: If they, as we understand to be the position,
17 did not read any of the files, they would be in breach
18 of those, would they not?
19 MS GRAHAM: Yes.
20 MR GARNHAM: (f) Working Together under the Children Act
21 1989. That is what most of this Inquiry has been about.
22 (g), the 1999 version, not relevant most of the time
23 Victoria was in Haringey?
24 MS GRAHAM: That is right.
25 MR GARNHAM: (h) Framework for the Assessment of Children in

187
1 Need did not come out until after she had died?
2 MS GRAHAM: That is right.
3 MR GARNHAM: Not really relevant.
4 (i) Looked After Children Procedures, not relevant.
5 (j) ACPC Child Protection Procedures Handbook.
6 Well we have discussed that and we know that some of
7 the managers and senior practitioners concerned were not
8 aware of it.
9 MS GRAHAM: (Nods).
10 MR GARNHAM: (k) Haringey Equal Opportunities Policy. Not
11 directly relevant here.
12 MS GRAHAM: No. Well, yes.
13 MR GARNHAM: In a sense that there was no evidence she was
14 treated differently from someone of another race or
15 background it was applied, but it was not that the
16 detailed provisions of that policy did not become of
17 importance in Victoria's case?
18 MS GRAHAM: I think the policy is a more general one than
19 that, I do not think it is case specific.
20 MR GARNHAM: Thank you.
21 (l) Protocols for joint investigation between the
22 police and Social Services. Applied in this case?
23 MS GRAHAM: In part.
24 MR GARNHAM: (m) Haringey Child Protection investigations
25 where more than one authority is involved. Not

188
1 relevant?
2 MS GRAHAM: No, it is not relevant.
3 MR GARNHAM: So of your 13 policies which you suggest are
4 relevant and in operation at the time of Victoria's case
5 we have to knock out quite a few as being either
6 irrelevant, breached, not applied.
7 MS GRAHAM: To Victoria's case?
8 MR GARNHAM: Yes.
9 MS GRAHAM: Yes, they may not be specific to her case.
10 MR GARNHAM: Thank you. Can I ask you about your role after
11 Victoria's death, please.
12 We know that after Victoria had died instructions
13 were issued to Dawn Green to collect the file from North
14 Tottenham District Office.
15 MS GRAHAM: That is right.
16 MR GARNHAM: Who issued that instruction? Was that you?
17 MS GRAHAM: I did tell Dawn to go to North Tottenham to get
18 it.
19 MR GARNHAM: It did not originate with you, the instruction?
20 MS GRAHAM: I am not sure that it did.
21 MR GARNHAM: Carol Wilson?
22 MS GRAHAM: I think so.
23 MR GARNHAM: Did Dawn Green telephone you from North
24 Tottenham District Office during the course of her
25 attempts to obtain that file?

189
1 MS GRAHAM: She did.
2 MR GARNHAM: What did she say?
3 MS GRAHAM: I do not remember her exact words but she did
4 let me know she was having difficulty getting hold of
5 the file.
6 MR GARNHAM: Did she explain to you what that difficulty
7 was?
8 MS GRAHAM: That Angella was photocopying it.
9 MR GARNHAM: What did you say to her?
10 MS GRAHAM: I do not remember my exact words but I --
11 MR GARNHAM: The gist?
12 MS GRAHAM: I was very unhappy.
13 MR GARNHAM: Because?
14 MS GRAHAM: For two reasons: that a member of my team should
15 be treated in that way. Dawn let me know that Angella
16 had been quite rude to her. Secondly, I was very
17 concerned that the file was being treated in that way at
18 that time.
19 MR GARNHAM: In what way?
20 MS GRAHAM: It is right that we do photocopy files but it is
21 my understanding that it is after a discussion and
22 agreement because this was not a family file that people
23 were working on, because often when there are concerns
24 to a child when there are serious injuries to a child
25 there are other children to safeguard and that was not

190
1 the case here.
2 MR GARNHAM: No, and the only child about whom that file had
3 been prepared was Victoria and she was dead?
4 MS GRAHAM: That is right.
5 MR GARNHAM: So there was no reason, was there, for
6 photocopying it at all?
7 MS GRAHAM: There may have been a reason that people had but
8 there was to be a discussion about that in my view.
9 MR GARNHAM: Did you ever discover what the reason for the
10 photocopying was?
11 MS GRAHAM: I think the reason was that there was still some
12 ongoing work to do. But I did not --
13 MR GARNHAM: In respect of a child who has died?
14 MS GRAHAM: I did not sit down and speak with Angella as to
15 why she was photocopying the file.
16 MR GARNHAM: What is the position now? What do you
17 understand to be the reason why that file was being
18 photocopied? Can you think of one?
19 MS GRAHAM: I am not clear as to why she was photocopying
20 the file.
21 MR GARNHAM: Can you imagine any reason that could obtain in
22 these circumstances?
23 MS GRAHAM: The file should have been secured. The file --
24 MR GARNHAM: Can you think of any reason why it should be
25 photocopied?

191
1 MS GRAHAM: No.
2 MR GARNHAM: You also told us that it should have been
3 secured, that means taken in its state as it was when
4 last worked Monday and brought back to the manager's
5 office?
6 MS GRAHAM: Yes.
7 MR GARNHAM: So as to eliminate any possibility of it being
8 interfered with?
9 MS GRAHAM: Yes.
10 MR GARNHAM: Miss Mairs' conduct was contrary to that
11 because she was dismantling it, having it photocopied or
12 photocopying it herself and then reassembling it?
13 MS GRAHAM: Yes, I have heard about this custom and practice
14 but as I say that has related to children who come
15 from -- who have siblings. But again my view of that is
16 that is not a blanket position. But having secured
17 files myself, it is not a task that we do often enough
18 in my view to have come to --
19 MR GARNHAM: Much of a custom or much of a practice?
20 MS GRAHAM: But I understand Angella was given permission to
21 do this so I am not sure how that came about.
22 MR GARNHAM: After you had been told of Miss Mairs'
23 allegedly rude remark to Ms Kitchman about the file --
24 MS GRAHAM: Miss Green just to --
25 MR GARNHAM: What did I say?

192
1 MS GRAHAM: Kitchman.
2 MR GARNHAM: So sorry, Green. You told her that you were
3 very unhappy with that?
4 MS GRAHAM: Yes.
5 MR GARNHAM: What did you tell her she should do?
6 MS GRAHAM: We discussed the way forward and that I would
7 speak with Dave. So I think I made two phone calls, the
8 first to speak with Dave and the second to speak with
9 Carol. So it could be that I informed Carol but
10 I cannot be certain as to that but certainly we were
11 negotiating the strategy meeting and the premeeting
12 before the strategy meeting so I know I called her.
13 I cannot be certain I told Carol about that.
14 MR GARNHAM: Did you speak to Dave Duncan?
15 MS GRAHAM: Yes.
16 MR GARNHAM: And said what?
17 MS GRAHAM: That we wanted the file, to have the file.
18 MR GARNHAM: Do you know why it still took some little time
19 before it was handed over? Half an hour plus, according
20 to Green.
21 MS GRAHAM: Again I would not want to split minutes with you
22 but I think it was 20. But nonetheless --
23 MR GARNHAM: I think you are right. It was half an hour she
24 was kept waiting initially and then another 20 minutes,
25 was it not?

193
1 MS GRAHAM: Yes. I do not know what Dave did after I phoned
2 him.
3 MR GARNHAM: Two last subjects, you will be sorry to know.
4 First of all I want to ask you just a little more about
5 case recording. Could you have volume 43 for this,
6 please. Page 9. We ought to identify this document by
7 looking at --
8 MS GRAHAM: I have to get my glasses. Do you mind?
9 MR GARNHAM: Yes, you will certainly need them.
10 A magnifying glass might help as well. This is
11 Haringey's Quality Protects MAP 3 which is I think
12 Management Action Plan, is it not?
13 MS GRAHAM: Yes.
14 MR GARNHAM: You had responsibility for that as we can see
15 from that first page.
16 MS GRAHAM: Yes.
17 MR GARNHAM: Can you go to page 9, please.
18 MS GRAHAM: I am on page 9, yes.
19 MR GARNHAM: Letter B. Plans 2001-2 and beyond set out what
20 you will achieve for children under this objective in
21 2001-2 and beyond and how you will achieve it.
22 Can you then go to three lines from the bottom:
23 "All allocated files forwarded for closure will be
24 signed by a Team Manager agreeing the assessment as
25 complete. Also provision reports on child protection

194
1 cases will be made available to the Commissioning
2 Manager to ensure appropriate levels and quality of
3 supervision are taking place."
4 Was that a description of circumstances as existed
5 at the time you made this report or was this a hope for
6 the future?
7 MS GRAHAM: I think the first sentence, "All allocated files
8 forwarded for closure ..." was in existence -- was going
9 on at the time.
10 MR GARNHAM: When had that been put in place?
11 MS GRAHAM: I cannot say.
12 MR GARNHAM: After Victoria's death?
13 MS GRAHAM: No, I think that was beforehand. Sorry, I will
14 read it again. (Pause). I think Dave Duncan would be
15 better to help you here than myself.
16 MR GARNHAM: Next sentence:
17 "All supervision reports on child protection cases
18 be made available to the Commissioning Manager."
19 A statement of present practice or hope for the
20 future?
21 MS GRAHAM: I think we have not achieved this as yet but
22 I would have to speak to the current Commissioning
23 Manager.
24 MR GARNHAM: Thank you. The next page:
25 "Systems and resources will be introduced [so this

195
1 is plainly for the future] to ensure that team managers
2 can read all child protection files on a rota basis."
3 What does that mean?
4 MS GRAHAM: This is happening. It is the intention that
5 managers read files on a systematic basis so a team
6 manager may have within their team, say, for argument's
7 sake, 100 files and so it is intended they will get
8 through each of the files and not -- over a given
9 period.
10 MR GARNHAM: This is a reviewing mechanism, is it?
11 MS GRAHAM: Yes. It is a case reading mechanism and in
12 reviewing in that sense -- yes, sorry, file reading.
13 MR GARNHAM: Does this describe the only circumstances in
14 which team managers are to read files or is this an
15 additional circumstance?
16 MS GRAHAM: This is additional.
17 MR GARNHAM: How frequently does this mean that files get
18 read?
19 MS GRAHAM: A monthly list goes out to managers from the
20 centre saying that these are the files they are to read
21 and to audit, basically.
22 MR GARNHAM: By sample or is the intention that all files
23 will be so read?
24 MS GRAHAM: It is by sample but I am sure the files are not
25 sampled twice if you know what I mean.

196
1 MR GARNHAM: Yes. So the idea is that each month by rota
2 18 managers are asked to read a selection of case files
3 for the purpose of ensuring that the work is done
4 adequately?
5 MS GRAHAM: Yes. This is the document I was referring to
6 earlier and so it may work differently for team managers
7 and for commissioning managers but the intention is that
8 managers will read files. So I think for team managers
9 they will read -- it works that people read files and
10 they are selected randomly.
11 MR GARNHAM: Did you say that is already going?
12 MS GRAHAM: Yes.
13 MR GARNHAM: When was it introduced?
14 MS GRAHAM: It was the earlier part of this year, the first
15 quarter I think, or thereabouts.
16 MR GARNHAM: Thank you. The last topic, although the one we
17 have just dealt with, is also relevant to this but
18 I want to look at the current position of the Duty
19 teams.
20 January of this year you were Acting Director of --
21 MS GRAHAM: Acting Assistant Director.
22 MR GARNHAM: Acting Assistant Director of Children's
23 Services. Could you be given volume 45A, please.
24 Page 142.
25 This is a paper prepared by David Duncan on

197
1 21st January of this year. Presumably a paper you have
2 seen before.
3 MS GRAHAM: Yes, I have seen this before. I have not seen
4 it recently.
5 MR GARNHAM: It might be described as something of a crie de
6 coeur from Duncan, setting out his concerns about
7 staffing, unallocated cases, managers' morale, staff
8 feedback, support. Do you know to whom this was
9 addressed?
10 MS GRAHAM: I cannot say, sorry.
11 MR GARNHAM: Did it come to your attention at the time?
12 MS GRAHAM: It could possibly have. It does not ring any
13 bells to me, not immediately, that it was -- a lot of
14 communication went to Anne Bristow and I was copied in
15 to it, so it could have been that was the way round.
16 MR GARNHAM: Thank you. Look at just one or two points
17 please. "Staffing":
18 "The staffing levels are acutely worrying because of
19 the numbers of very inexperienced temporary staff, the
20 numbers of unallocated cases, the levels of work and the
21 low morale."
22 Were you aware of those concerns?
23 MS GRAHAM: Yes, I was.
24 MR GARNHAM: Over the page, "Unallocated" is the heading:
25 "Unallocated numbers in Hornsey are under control,

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1 but will increase due to imminent departures. However
2 the staff group remaining is experienced.
3 "The number of cases unallocated in Tottenham is now
4 100."
5 Aware of that?
6 MS GRAHAM: Yes.
7 MR GARNHAM: "Managers":
8 "Although we are only one manager down, three
9 managers are under management investigation following
10 Anna's [as she is called] death. Our emotions following
11 her death and the worry of the investigation must be
12 having a major impact on our ability to carry out the
13 job and to maintain the morale of staff and to move the
14 office forward."
15 Aware of that?
16 MS GRAHAM: Yes.
17 MR GARNHAM: "Morale":
18 "Morale at the Tottenham office is extremely low and
19 will eventually have a detrimental impact on
20 performance."
21 Aware of that?
22 MS GRAHAM: Yes.
23 MR GARNHAM: Do you know what was done in response to this
24 paper?
25 MS GRAHAM: Yes. A number of things were done. Meetings

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1 took place attended by Anne Bristow, myself and later
2 the Chief Executive and there were attempts to rectify
3 this position through the funding of --
4 MR GARNHAM: How?
5 MS GRAHAM: Through the funding of additional social
6 workers.
7 MR GARNHAM: Successfully?
8 MS GRAHAM: Yes, we did successfully recruit. We reduced
9 the number of unallocated cases through a holding team.
10 We attempted to address morale through -- I am not sure
11 it would have been immediately -- well it happened while
12 I was acting up. Workers in Hornsey and Tottenham were
13 given a sum of money. The office in Tottenham was
14 certainly refurbished and so an improvement plan was put
15 in place.
16 MR GARNHAM: It is fair to say the position described by
17 Mr Duncan in that paper is pretty dire, is it not?
18 MS GRAHAM: It is not good.
19 MR GARNHAM: Could you now go to page 150.501 in that
20 bundle.
21 MS GRAHAM: Yes.
22 MR GARNHAM: A memo from Rose Kozinos to Anne Bristow, copy
23 to you amongst others.
24 MS GRAHAM: Yes.
25 MR GARNHAM: Setting out her concerns at the position she

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1 finds herself in about five months after Duncan's memo.
2 MS GRAHAM: Yes.
3 MR GARNHAM: A not dissimilar picture being painted.
4 MS GRAHAM: That is right.
5 MR GARNHAM: So that at least from her point of view the
6 same sort of concerns were still remaining?
7 MS GRAHAM: Yes.
8 MR GARNHAM: I think it is right to say that that resulted
9 in a response, did it not?
10 MS GRAHAM: Yes.
11 MR GARNHAM: From whom?
12 MS GRAHAM: I think it was following this and another report
13 that Ben Brown was asked by Anne Bristow to go down to
14 North Tottenham office.
15 MR GARNHAM: Yes. He produced a paper as a result.
16 MS GRAHAM: Yes.
17 MR GARNHAM: In your view, was the picture painted by
18 Rose Kozinos in that memo an accurate one of the state
19 of play at the time?
20 MS GRAHAM: I have not seen this for some time so I would
21 have to go through it but certainly towards the early
22 part of the year I was very worried about the state of
23 play in North Tottenham. Morale was low.
24 MR GARNHAM: Practice safe?
25 MS GRAHAM: Practice was concerning because we had

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