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Archived Transcript for 13 December 2001:
Pages 201 to 235
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1 inexperienced workers, we had a high turnover, people
2 were coming in, they were going. So I could not be
3 assured that practice was safe in all cases.
4 MR GARNHAM: We were told that following the SSI inspection
5 in 1999 managers felt they were able to sleep at night.
6 Did you feel able to sleep at night, having received
7 this paper?
8 MS GRAHAM: It was a very difficult time overall and I think
9 that a lot of efforts were put right -- were -- a lot of
10 people were trying to put right the situation that we
11 had and by the time June came around I am certainly sure
12 that all children were -- I do not have the figures to
13 hand but we did not have 100 children unallocated.
14 MR GARNHAM: But numbers were still high of unallocated
15 cases?
16 MS GRAHAM: I would have to look at the performance
17 indicators. We did work hard to ensure all children
18 were allocated and I think we probably get to that point
19 about now.
20 MR GARNHAM: So speaking metaphorically at least you were
21 not sleeping at night in January but you were sleeping
22 a little better by June?
23 MS GRAHAM: Mr Garnham I am not sure what my sleeping
24 patterns were.
25 MR GARNHAM: That is why I said I am speaking

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1 metaphorically.
2 MS GRAHAM: Perhaps you could choose a different metaphor.
3 MR GARNHAM: Were you able to rest easy about the
4 circumstances in the North Tottenham District Office in
5 January and in June now, 2001?
6 MS GRAHAM: In January I became very concerned.
7 MR GARNHAM: Volume 29A, please. Page 4. Notes of
8 a supervision. It says simply at the bottom:
9 "Anne Bristow notes for supervision 21 March 2001."
10 Is that a supervision with you?
11 MS GRAHAM: Yes.
12 MR GARNHAM: It is?
13 MS GRAHAM: Yes.
14 MR GARNHAM: Bristow supervising you?
15 MS GRAHAM: Yes, I was to have a supervision session with
16 Anne Bristow and I prepared this for that meeting.
17 MR GARNHAM: Would you look at paragraph 4 on page 5.
18 MS GRAHAM: Yes.
19 MR GARNHAM: "District restructuring":
20 "The district teams were restructured at the end of
21 1999. Although there has been support for the model in
22 place I do think we have to review it urgently. The
23 problems are (1) too few team managers such that we are
24 unable to cover absences effectively. (2) Practice
25 managers who do not appear to be undertaking the

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1 intended role. This is because of the unstable staffing
2 situation, the high number of allocated cases. (3) no
3 training and/or time for all managers to implement the
4 change effectively."
5 Were those your views on the effect of restructuring
6 by the time we get to March 2001?
7 MS GRAHAM: Yes, this is what I wrote to Anne Bristow.
8 MR GARNHAM: Do those remain your concerns?
9 MS GRAHAM: No but the position has shifted slightly.
10 MR GARNHAM: In what way?
11 MS GRAHAM: Certainly now we have two Commissioning Managers
12 instead of one. We -- I am no longer the Assistant
13 Director as I made clear at the very beginning of today
14 and so the staffing position, those statistics are
15 produced and I should have a copy so it is my fault that
16 I am not able to tell you what the current staffing
17 position is, but certainly as I left post we were short
18 by I think one and a half bottoms on seats so to speak,
19 although we still did have a number of agency workers
20 and I am not sure of that position now.
21 MR GARNHAM: Yes, thank you. The last matter, I think.
22 Volume 45D. Have you got 45D? Nor have I. The speed
23 at which we are trying to keep up with the documents,
24 these are amongst the new documents coming in and
25 obviously although I saw them this morning they have not

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1 been filtered through to everybody. Sir I will leave it
2 there and make an inquiry about the missing document
3 over the next few minutes.
4 THE CHAIRMAN: Thank you very much Mr Garnham. I will not
5 say that it is an illustration of the problem -- but
6 I will say that, sorry. Miss Lawson.
7 MISS LAWSON: Ms Graham I would just like to take you back
8 if I may to your first witness statement. It is the
9 green volume 2 at page 178. Do you have paragraph 54 of
10 your witness statement?
11 MS GRAHAM: What page did you say?
12 MISS LAWSON: Page 170.
13 MS GRAHAM: I have the wrong witness statement in front of
14 me but I have my own here.
15 MISS LAWSON: It is paragraph 54 of your first witness
16 statement.
17 MS GRAHAM: Yes, I have it.
18 MISS LAWSON: Do you remember this is the list of systems
19 which you had indicated were in place and wanted to say
20 some more about? Mr Garnham took you back to it and
21 asked you specific questions about the list. Can I just
22 ask you about one matter in the list and that is the
23 framework for the assessment of children in need and
24 their families, sometimes called just to confuse things
25 the Lilac Book compared with the Purple Book.

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1 Mr Garnham dismissed this on the basis that as it
2 was the year 2000 it could not have been in application,
3 and it is true that is when it came in but what was the
4 position so far as the use of that document and the
5 training for it was concerned?
6 MS GRAHAM: We had quite a lot of training in Haringey,
7 a process similar to the case recording booklet. My
8 team took the lead in the training and jointly with
9 Dave Duncan and his team the implementation of systems,
10 so we worked alongside the draft because we knew there
11 was not going to be too many changes and we briefed all
12 social workers and we worked with them individually as
13 teams on the assessment framework.
14 There was also a multi-agency aspect to the training
15 we did but primarily our focus in relation to today was
16 with teams.
17 MISS LAWSON: Now the Inquiry is aware that Haringey had its
18 own forms in place to deal with assessment, prior to the
19 introduction of this new framework. I would just like
20 to know what the position was. Were those forms amended
21 at the time we are talking about or did they supersede
22 the previous forms or what actually happened about that
23 side of it in relation to the new framework for children
24 in need?
25 MS GRAHAM: The framework for the assessment of children in

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1 need and their families came with their own forms, came
2 with an initial assessment form and with the core
3 assessment forms and we, like other boroughs, took
4 account of the initial assessment form and combined that
5 with our own. I think it turned out that they were much
6 the same but we expanded our to include a few other
7 bits.
8 MISS LAWSON: You wanted when you were originally asked
9 about it to say something about the interrelationship
10 between these various bits of the system and I just
11 wanted to make sure that you had said all you wanted to
12 about that aspect of it.
13 MS GRAHAM: Yes, I think Mr Garnham's point if I remember
14 rightly was that it would be helpful to have one
15 document, one procedural document and I was pointing out
16 that although I have 13, that does not mean that all 13
17 were used all of the time. I think I was able to
18 highlight the cross-referencing of some of them.
19 MISS LAWSON: Could I take you back, please, to your role in
20 the Part 8 review. Can I just get you to confirm the
21 way in which that was prepared was as a result of
22 various people within the different agencies preparing
23 a report on their agency's involvement?
24 MS GRAHAM: That is right yes.
25 MISS LAWSON: That was your task?

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1 MS GRAHAM: Yes, that it had been agreed that we would have
2 an independent chair -- an independent panel, sorry, of
3 the Part 8 review and we were asked as agency leads to
4 prepare a document for that purpose.
5 MISS LAWSON: So at the time that you prepared this report,
6 what documents did you have access to?
7 MS GRAHAM: It was quite limited. I had the case file and
8 as I had already met and spoke with Petra Kitchman I had
9 that first initial meeting with her. It was agreed that
10 the panel, the Part 8 panel would do the investigation
11 so to speak, and so my documents were quite limited.
12 MISS LAWSON: So far as for example what might have been
13 happening during Victoria's stay in the North Middlesex
14 Hospital for example, you had no information other than
15 what came on to the Social Services file?
16 MS GRAHAM: That is right.
17 MISS LAWSON: Just for the sake of completeness, could I ask
18 you to have volume 2, please, of the document. That is
19 the black volume 2. Page 172. That is the document you
20 looked at earlier with Mr Garnham which is the report
21 that you prepared for that but I would just like to ask
22 you if you would to go forward in that to the same
23 volume but page 232.
24 MS GRAHAM: Yes, I am there.
25 MISS LAWSON: This as you see from the top is a briefing for

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1 the Chief Executive from Carol Wilson and I think it is
2 prepared at the end of February 2000.
3 MS GRAHAM: Yes.
4 MISS LAWSON: Without wishing to take you through it in
5 detail there seems to be a very close similarity between
6 the text of that document and what is certainly in the
7 historical part of your Part 8 report. I just wondered
8 who compiled the first one or what the interrelationship
9 between the two is.
10 MS GRAHAM: The first one was not put together by me.
11 I think this was the one that was put together when Dawn
12 and Carol met.
13 MISS LAWSON: After the file was eventually obtained?
14 MS GRAHAM: Yes. And then I was asked to prepare a document
15 for the case review. I am not sure of the dates but
16 I did not feel I had enough time and I was not quite
17 sure how to achieve the task I thought I had to complete
18 without speaking to people. And so I did not reinvent
19 the wheel, I started from an existing document.
20 MISS LAWSON: So far as the report that was eventually
21 prepared by the independent chair and the team, that we
22 also have in the bundle but you have read it, have you
23 not?
24 MS GRAHAM: Yes, the first Part 8.
25 MISS LAWSON: Is it right to say that everybody is

209
1 anonymised in that report in terms of identifying who
2 they are?
3 MS GRAHAM: Yes.
4 MISS LAWSON: Can I ask you about another aspect of it that
5 you were asked about a lot? You do not need anything
6 more in that file, it is all right. You were asked
7 quite a bit about the relationship between Haringey and
8 the North Middlesex Hospital.
9 MS GRAHAM: (Nods).
10 MISS LAWSON: I would like if I may to put that in context
11 because obviously this case is being looked at because
12 it was one which came from the hospital and particularly
13 from that hospital. I would like, if I may, with your
14 assistance, to look at it in the context of how big that
15 is in the overall picture. To begin with, is it the
16 only hospital in Haringey's area that deals with
17 children's cases?
18 MS GRAHAM: No, we deal with another hospital quite a lot as
19 well.
20 MISS LAWSON: Which is that?
21 MS GRAHAM: The Whittington.
22 MISS LAWSON: Is there the same problem over the absence of
23 social work presence?
24 MS GRAHAM: None at all.
25 MISS LAWSON: Is there a social work presence at the

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1 Whittington?
2 MS GRAHAM: There is a social work presence.
3 MISS LAWSON: Is the Whittington within Haringey itself or
4 how does it work?
5 MS GRAHAM: The Whittington is as I understand it in
6 Islington but I think it is actually on the borders
7 again as is the North Mid with Haringey and there is
8 a social work department there that has been there for
9 many years and they undertake assessments on behalf of
10 children who enter the hospital regardless of residence,
11 and we have had none of the issues we have had with the
12 North Middlesex.
13 MISS LAWSON: Can I ask you, please, to look in volume 12A.
14 Page 186. These are, as you will see, the children
15 strategy board performance indicators. Would you go
16 forward to page 188.
17 MS GRAHAM: Yes.
18 MISS LAWSON: This is dealing with the Children's Services
19 and we see there the referral origins by client group in
20 relation to the different types of child referral.
21 MS GRAHAM: Yes.
22 MISS LAWSON: You see those. If one looks at the top column
23 which is Child Protection, we see during the period
24 covered by these indicators, which is April to June of
25 1999, that the number of referrals from Health during

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1 that period is, apart from the unknown ones, the
2 smallest of all child protection referrals amounting to
3 eight in all.
4 MS GRAHAM: Yes, that is right.
5 MISS LAWSON: Would that include not only referrals from the
6 North Middlesex Hospital but also from the Whittington?
7 MS GRAHAM: Yes.
8 MISS LAWSON: And also via other health professionals?
9 MS GRAHAM: Yes.
10 MISS LAWSON: If you go forward, please, to page 251, we
11 find the same document for October to December of 1999.
12 I do not think June to September is in here and I have
13 not found where it is, so that is not a deliberate
14 omission because I think they are everywhere else. If
15 you go to page 251, please.
16 MS GRAHAM: Yes, I have page 251.
17 MISS LAWSON: We see there again the same picture. This
18 time there are only four.
19 MS GRAHAM: Yes, that is half the number of the previous
20 quarter that you mentioned.
21 MISS LAWSON: But were actually during a period of six
22 months looking at a total of 12 referrals from all the
23 health professionals?
24 MS GRAHAM: Yes.
25 MISS LAWSON: In relation to child protection?

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1 MS GRAHAM: Yes.
2 MISS LAWSON: Yes, thank you. So in terms of attendance,
3 for example at the health meetings, the meetings in the
4 hospital on Tuesdays, the NAI meetings that you were
5 asked about, are you able to help at all as to what sort
6 of numbers of cases would actually involve Haringey
7 during this period?
8 MS GRAHAM: From these figures it is not likely to be a very
9 high number.
10 MISS LAWSON: No, indeed.
11 MS GRAHAM: So I suppose it breaks down from the October to
12 December figures at just over one point something
13 a month.
14 MISS LAWSON: You also went on to describe the fact that
15 there are now arrangements for Haringey social workers
16 to be in post in North Middlesex Hospital. How many did
17 you say there were?
18 MS GRAHAM: There are two social workers.
19 MISS LAWSON: Can we assume they do things other than simply
20 deal with child protection cases?
21 MS GRAHAM: I think that might be an assumption that I would
22 agree with.
23 MISS LAWSON: I would like to ask you about one or two
24 points arising in relation to relationships with other
25 agencies. Could you have volume 2, page 165. Can

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1 I just explain to you what this document is, Ms Graham.
2 This is part of the Part 8 review done in Enfield
3 following Victoria's death and it is, I think, the only
4 place where we find any indication of the protocol to
5 which you referred between Haringey and Enfield. Under
6 the heading in the middle "Haringey Child Protection
7 Cases" we have a summary of what the protocol appears to
8 be.
9 MS GRAHAM: Yes, I have not read it.
10 MISS LAWSON: No, well have a look at it now.
11 MS GRAHAM: I have read the first paragraph. Do I need to
12 read further?
13 MISS LAWSON: No, I think that is probably -- it goes on to
14 describe the Child Protection Guidelines and I assume
15 from your earlier evidence that you are familiar with
16 the hospital's Child Protection Guidelines and what they
17 say about contacting the social worker.
18 MS GRAHAM: (Nods).
19 MISS LAWSON: Does that first paragraph correspond
20 substantially with your understanding of the position
21 and the role undertaken by Enfield on Haringey's behalf?
22 MS GRAHAM: Yes.
23 MISS LAWSON: Did you at any time receive any concerns from
24 Enfield about the way in which this arrangement worked
25 in individual cases?

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1 MS GRAHAM: Yes, I did. When I was an adviser there were
2 concerns as to the liaison role and I think that
3 although the agreement was accepted they wanted to --
4 there was I think a desire to come out of it and for
5 Haringey to fund a social worker.
6 MISS LAWSON: There were those sorts of problems?
7 MS GRAHAM: Yes.
8 MISS LAWSON: I was asking whether it caused any problems
9 that you were aware of in relation to the management of
10 individual cases; in other words --
11 MS GRAHAM: Sorry I misunderstood. No it did not.
12 MISS LAWSON: In other words Enfield were not complaining
13 about the fact that they had difficulties getting
14 Haringey to respond or anything of that sort?
15 MS GRAHAM: No.
16 MISS LAWSON: Indeed Miss Johns told us it was her
17 experience that there were not any problems over that on
18 the ground, certainly not in child protection cases.
19 MS GRAHAM: Yes.
20 MISS LAWSON: And are you aware of any problems caused by
21 that arrangement in relation to Victoria's case?
22 MS GRAHAM: No.
23 MISS LAWSON: Thank you. You were also asked some questions
24 about the relationships with the police.
25 MS GRAHAM: Yes.

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1 MISS LAWSON: You spoke about one particular case that you
2 were aware of where there had been some concern.
3 I wonder whether you could have volume 45B, please, at
4 page 176. This is actually a memorandum from
5 Dave Duncan to Carol Wilson in response obviously to
6 a letter that the police had sent in March of 2000 and
7 I am just wondering whether that is the same case that
8 you were referring to or whether it is a different one?
9 MS GRAHAM: That is the one I am referring to.
10 MISS LAWSON: That is the one. Thank you. I think other
11 people can read that so I do not think there is any need
12 for me to take you through it.
13 You were asked a number of questions about the ACPC
14 guidelines.
15 MS GRAHAM: Yes.
16 MISS LAWSON: Both in relation to Haringey and in relation
17 to the North Middlesex Hospital.
18 MS GRAHAM: Yes.
19 MISS LAWSON: You said that there was in fact considerable
20 overlap between both sets of guidelines.
21 MS GRAHAM: Yes.
22 MISS LAWSON: Dr Rossiter told us that she had in effect
23 prepared the hospital guidelines in both documents, in
24 other words she had done the hospital guidelines and she
25 had also dealt with the hospital bit of the ACPC

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1 guidelines.
2 MS GRAHAM: Yes.
3 MISS LAWSON: I would just like to ask you -- you have told
4 us of your role in the preparation of Haringey
5 guidelines -- did you have any role in the preparation
6 of the ACPC guidelines so far as Haringey was concerned?
7 MS GRAHAM: No, I did not.
8 MISS LAWSON: You did not?
9 MS GRAHAM: No.
10 MISS LAWSON: When you were drawing up your guidelines did
11 you pay attention to what the ACPC guidelines were?
12 MS GRAHAM: If I can put that differently. I was slightly
13 hasty in that a colleague of mine would have been --
14 would have taken the lead for Social Services for the
15 ACPC handbook and I would have been consulted through
16 that process but I was not the author of them.
17 MISS LAWSON: Right. Were those -- remind me -- were those
18 prepared before the revisions of the Haringey
19 guidelines?
20 MS GRAHAM: It is the other way around. 1996 is the Purple
21 Book, 1997 is the handbook.
22 MISS LAWSON: So they would have been prepared with
23 knowledge of Haringey's Child Protection Procedures?
24 MS GRAHAM: Definitely.
25 MISS LAWSON: You were asked a number of questions about

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1 strategy meetings and in particular about reviews of
2 strategy meetings.
3 MS GRAHAM: Yes.
4 MISS LAWSON: And about the decision being necessary to
5 decide whether to have such a review.
6 MS GRAHAM: Yes.
7 MISS LAWSON: I would like to ask you a little bit more
8 about that in the context of child protection because
9 after all the strategy meetings developed to deal with
10 primarily the Section 47 investigation.
11 MS GRAHAM: Yes.
12 MISS LAWSON: In cases where that uncovers evidence to
13 substantiate either some form of proceedings or gives
14 rise to child protection concerns, the next stage would
15 be either the issue of the proceedings or the call of
16 a case conference.
17 MS GRAHAM: That is right, yes.
18 MISS LAWSON: In other words the piece of work done by the
19 strategy meeting would be finished.
20 MS GRAHAM: Yes.
21 MISS LAWSON: And the group which would look at the outcome
22 of that would either be the court or the child
23 protection?
24 MS GRAHAM: Yes, that is the sort of -- the case where I was
25 trying to indicate there would be discussion between

218
1 those involved as opposed to a sit-down meeting.
2 MISS LAWSON: It would not necessarily be the case, would
3 it, that the strategy meeting at the time it was coming
4 together would know which of the two was appropriate?
5 MS GRAHAM: That is right. It is possible.
6 MISS LAWSON: Finally, Mr Garnham asked you a number of
7 questions looking at the situation in the North
8 Tottenham District Office --
9 MS GRAHAM: Yes.
10 MISS LAWSON: -- after the trial and the way in which the
11 social workers were treated in the aftermath of it and
12 the problems that it had in terms of the office and
13 morale generally.
14 MS GRAHAM: Yes.
15 MISS LAWSON: And you were taken to Rose Kozinos's memo in
16 June and asked about that too as to whether or not
17 things had improved.
18 MS GRAHAM: Yes.
19 MISS LAWSON: Are you able to help at all about the present
20 position in terms of either numbers of social workers
21 or -- that is not something that you can help with?
22 MS GRAHAM: Not really. Not with any confidence.
23 MISS LAWSON: That is fair enough. Are you able to help us
24 on the state of the morale since this Inquiry started?
25 MS GRAHAM: Since the Inquiry started?

219
1 MISS LAWSON: Yes.
2 MS GRAHAM: Well morale is not at its best to put it
3 politely.
4 MISS LAWSON: That is what I thought. Thank you.
5 THE CHAIRMAN: Well, I understand that.
6 Ms Graham just a few questions from me, please. It
7 fits in very nicely where Miss Lawson ended up.
8 If you can have a look at volume 29A again, please.
9 Just so you know what this is, this is the notes of your
10 supervision session that you prepared on 21st March. If
11 I may say, very well prepared, which presumably is an
12 indication of the seriousness of the issues that you
13 wanted to discuss during your supervision session.
14 MS GRAHAM: Yes.
15 THE CHAIRMAN: You did not like the metaphor that Mr Garnham
16 used. I guess it is an indication of my inadequacy that
17 I have been prone to lose sleep during my career and not
18 little during this Inquiry.
19 MS GRAHAM: I have got here 29A/022. Is that what you want
20 me to look at?
21 THE CHAIRMAN: Yes. If you go to 005.
22 MS GRAHAM: I am on the right page now.
23 THE CHAIRMAN: This is the 21st March this year.
24 MS GRAHAM: Yes.
25 THE CHAIRMAN: More than a year after Victoria died and

220
1 a couple of months after this Inquiry was at least
2 announced. If I can just highlight a couple of points
3 that you highlighted yourself.
4 "North Tottenham has the highest number of
5 unallocated cases and appears the most inexperienced
6 workforce."
7 A couple of paragraphs further down your assessment:
8 "This situation leaves districts in a very dangerous
9 and unsafe position."
10 Then overleaf under 6:
11 "Only one of the three remaining child protection
12 advisers is in work, the other two are on maternity
13 leave."
14 It may not have kept you awake at night but would
15 you agree with me that this represented a serious
16 situation?
17 MS GRAHAM: It was a serious situation. I do agree.
18 THE CHAIRMAN: Going back to paragraph 35 of your first
19 statement, you refer to the Children Act. Mr Garnham
20 asked you about this. I want to be clear exactly what
21 is meant in the second line about the Children Act or
22 the issues being complex. Was it your --
23 MS GRAHAM: Sorry. It is my fault. Which paragraph?
24 THE CHAIRMAN: 35, sorry. I am sure it is me, my
25 unfortunate accent. I was not sure in paragraph 35

221
1 whether you were saying that the Children Act is
2 complicated -- this is for clarification, that is not
3 a criticism -- the Children Act is complicated or
4 Haringey's handling of the Children Act is complicated.
5 MS GRAHAM: I do not think it is either of those. What
6 I was trying to say is that the systems and processes
7 themselves are complicated. Although I know this
8 Inquiry is focusing on Social Services I did not want to
9 just think that -- I did not want to write in my
10 statement that was the only way in which children are
11 considered so I go back to the example of mental health.
12 Mental health social workers do come across children and
13 children in distress and so those routes into
14 social services are significant. And I just wanted to
15 try and illustrate -- I have obviously done it very
16 badly -- how complicated working with children in need
17 is. It was not a reference at all to the Children Act.
18 THE CHAIRMAN: Or to Haringey?
19 MS GRAHAM: Or to Haringey.
20 THE CHAIRMAN: All right, thank you. You have been asked
21 about the ACPC. Could you just tell me roughly, you may
22 not have the numbers immediately to hand but roughly,
23 how many people legitimately could attend the ACPC? Are
24 we talking about 10, 20, 30, 40, 50?
25 MS GRAHAM: I do not think there is a limit as to the

222
1 numbers.
2 THE CHAIRMAN: It was not a public meeting I assume.
3 MS GRAHAM: No, we would have agency representatives so the
4 core agencies are, as you know --
5 THE CHAIRMAN: What I am really trying -- all right, how
6 many turned up at these meetings? Was it a big meeting
7 or a small meeting?
8 MS GRAHAM: I think my sense for the ACPC main meeting would
9 be about 12-15 or 20. It could be as little as eight.
10 It was in those regions.
11 THE CHAIRMAN: Eight to 20.
12 MS GRAHAM: If we were going to have a particular
13 presentation we would have more numbers, the crowds
14 would come. If it was a regular meeting then you would
15 have those whose job it was to come and I think at an
16 ACPC I would expect maybe about eight.
17 THE CHAIRMAN: It is just it was described earlier in the
18 Inquiry to us as being a very large, rather unwieldy
19 type of meeting and eight seems to me to be a fairly
20 manageable meeting.
21 MS GRAHAM: Yes. It was a big room and we were spread out.
22 THE CHAIRMAN: I see. There is a big distance between
23 people, all right.
24 MS GRAHAM: Our working relationships were good.
25 THE CHAIRMAN: It sounds intimate.

223
1 MS GRAHAM: Can I just read paragraph 35? Shall I read it
2 and then I will answer you properly?
3 THE CHAIRMAN: Well I think that I have got your
4 understanding of 35.
5 MS GRAHAM: Okay.
6 THE CHAIRMAN: Which is that -- so you want to read it
7 again?
8 MS GRAHAM: No --
9 THE CHAIRMAN: I took it from you that that statement was
10 not intended to reflect anything on either the Children
11 Act or Haringey.
12 MS GRAHAM: That is right, sorry.
13 THE CHAIRMAN: It was something more general, let us say.
14 MS GRAHAM: Yes.
15 THE CHAIRMAN: I just want to ask you a few details really
16 just for my own clarification. The first is about
17 securing files. How many times in your career have you
18 had to secure a file, roughly? I do not mean precisely.
19 MS GRAHAM: I would say maybe five times.
20 THE CHAIRMAN: My understanding of securing a file is one
21 kind of action and I want to make sure that my
22 understanding of it is the same as your understanding of
23 it. Securing a file in my terms is making sure that the
24 document is secured as it is and that nobody else has
25 any means of contact with that document until it is

224
1 actually in the place where it has to be which is with
2 senior management. Is that your understanding?
3 MS GRAHAM: Yes.
4 THE CHAIRMAN: It certainly did not work this time.
5 MS GRAHAM: No.
6 THE CHAIRMAN: Mr Garnham asked you a number of questions
7 about your statement and the style of it and the content
8 and I think it is fair to say, and I guess you would
9 accept this, that in all organisations or at least most
10 organisations there tends to be a gap between what
11 management believes is happening and what the reality is
12 on the ground.
13 MS GRAHAM: I would agree.
14 THE CHAIRMAN: And part of the task of management is to
15 actually narrow that gap.
16 MS GRAHAM: Yes.
17 THE CHAIRMAN: From the evidence we have had so far it seems
18 there was a positive chasm between what management was
19 describing in Haringey and the people who have been with
20 us so far who have actually been doing the job day by
21 day. Would you agree with my assessment of that?
22 MS GRAHAM: I think through the course of the Inquiry and
23 reading transcripts that there was a big gap, a big gap.
24 THE CHAIRMAN: I notice your precision with words and if you
25 cannot be tempted to acknowledge a chasm I will take it

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1 as some considerable acknowledgment from you if we say
2 a big gap.
3 MS GRAHAM: Thank you.
4 THE CHAIRMAN: No, it is very tough to secure some
5 understanding of the English language in these matters.
6 Okay.
7 You said several times in your answers to questions
8 that because you were not the line manager you could not
9 actually say what happened. And of course you were not
10 the line manager in a lot of day by day practice
11 arrangements. What do you think that says about the
12 kind of post that you occupied, in terms of utility?
13 MS GRAHAM: I do have a sense -- I do not remember the
14 question specifically. I do have a sense of practice
15 but I think that I was asked specifics as to cases and
16 I would not know what happened within a supervision
17 session. As now there are two commissioning managers.
18 I would not expect one commissioning manager in one area
19 to know precisely what was going on in another and
20 I would expect them to have a sense in relation to the
21 role that they held. I think I would have a sense but
22 I would expect my advisers to have an even stronger
23 sense.
24 THE CHAIRMAN: Yes, that might be so. I would be glad for
25 your professional guidance or your opinion on the role

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1 of your advisers because I am a fairly sort of simple
2 fellow and I like to know what people are accountable
3 for and I find it hard to understand -- I understand the
4 tension, that you were reluctant -- there was tension
5 this morning between team managers and child protection
6 advisers. If a team manager is accountable for their
7 team, does it not create some kind of complication, or
8 have I misunderstood it, if somebody else, however
9 skilful they may be, and helpful, parachutes in and
10 gives advice and parachutes out, if you can parachute
11 out?
12 MS GRAHAM: Yes, and that is part of the basis for the
13 tension if it is viewed that way. If it is not viewed
14 that way, if it is seen as embracing, then the tension
15 is not there.
16 THE CHAIRMAN: The link role with the North Middlesex
17 Hospital, you did it --
18 MS GRAHAM: Yes, I did.
19 THE CHAIRMAN: And you supervised your successor?
20 MS GRAHAM: Yes.
21 THE CHAIRMAN: It comes across to me, and maybe I have this
22 wrong so I need to you help me, it comes across to me
23 that role was perceived as being a link with
24 Dr Rossiter.
25 MS GRAHAM: That is right because Dr Naidoo had her own link

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1 but it was not seen as a link with the wider hospital.
2 Is that your --
3 THE CHAIRMAN: Yes.
4 MS GRAHAM: It was not seen as a link with the wider
5 hospital.
6 THE CHAIRMAN: And yet I suspect the hospital is like --
7 I am not familiar with that hospital but some hospitals
8 I am familiar with. The majority of children that are
9 seen in Accident and Emergency do not end up admitted to
10 hospital. So what was the link between Accident and
11 Emergency in Haringey, children who may be real,
12 genuine, and understand there were concerns about?
13 MS GRAHAM: That would be through the hospital social
14 workers. The hospital social workers would work with
15 A&E and any concerns would be passed through to
16 Haringey.
17 THE CHAIRMAN: So the link worker, the link job that you did
18 and your successor did was essentially a link between
19 Haringey and Dr Rossiter?
20 MS GRAHAM: Yes. I never had any contact with anyone in A&E
21 in the time that I did that role. It was with
22 Dr Rossiter and with the hospital social workers.
23 THE CHAIRMAN: Thank you very much indeed. You supervised
24 Petra Kitchman?
25 MS GRAHAM: Yes.

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1 THE CHAIRMAN: What was your professional assessment of her
2 work?
3 MS GRAHAM: I think it is true to say Petra was the least
4 experienced of the advisers and she -- I have looked
5 back and I think that she has needed support in areas.
6 She needed guidance such as with the role at North Mid
7 and with policy work. So she has been developed and
8 I think in some areas she does very, very well. I have
9 read her transcript and I did not have concerns -- while
10 I supervised Petra I did not have concerns as to her
11 functioning while at the time she -- the significant
12 period or the relevant period, rather.
13 THE CHAIRMAN: But you do now?
14 MS GRAHAM: The contact that she had with Dr Rossiter and
15 with Lisa, I am concerned about that. I did not have
16 concerns about her practice in any significant way or in
17 any way, really, before she gave evidence and so I am
18 concerned about what happened there.
19 THE CHAIRMAN: The truth is that you probably did not have
20 a very good picture about her performance.
21 MS GRAHAM: I am not sure about that. I think I did have
22 a good picture about her performance. I suppose it is
23 the depth to the picture, really. I would own that
24 I did not have the depth which I saw -- I had not
25 unpicked the communication channels between her and Lisa

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1 and Dr Rossiter. I did not see that. I had seen that
2 letter but I had not unpicked it in that way. I had not
3 spoken to Petra, as I say, about it in any great depth
4 because of the Part 8 and the way that went and I had
5 not spoken to Lisa. That degree of investigation I had
6 not done.
7 THE CHAIRMAN: I do not want to quibble about numbers
8 because I am not in a position to argue with you but
9 I do not see how you could understand what she was doing
10 or the quality of work she was doing if her supervision
11 was about nine times in 20 months.
12 MS GRAHAM: As I said at the early part, I know we have said
13 it for the relevant period but it is my view I met with
14 Petra and discussed cases with Petra a lot more than
15 that, but I would have to go back and check. But for
16 that period, Mr Garnham and I did go through and were
17 able to account as to why.
18 THE CHAIRMAN: I am not disputing that there might be good
19 reasons. What I am trying to reach agreement with you
20 is that whatever the circumstances, whatever the things
21 were that intervened, it would be difficult for anyone,
22 even a very remarkable person, to understand the quality
23 of somebody's work if you only see them something like
24 nine times in 20 months.
25 MS GRAHAM: Yes, I would have to go back and confirm it is

230
1 nine.
2 THE CHAIRMAN: As I say I am not going to quibble but
3 I think you were acknowledging with Mr Garnham that
4 there were long periods when you could not have had time
5 to look at Petra Kitchman's work.
6 MS GRAHAM: Yes. I am not going to ...
7 THE CHAIRMAN: All right. I will come to my final point and
8 that is this: you portray to me on paper a system in
9 Haringey which is, on paper, comprehensive and
10 satisfactory; some would say substantially above
11 satisfactory. But the reality is that Victoria died in
12 terrible circumstances. How can I reconcile what
13 happened to Victoria with the system that you describe?
14 MS GRAHAM: It is difficult.
15 THE CHAIRMAN: Well we have talked about words. Can I put
16 it to you it is impossible?
17 MS GRAHAM: I would not want to attempt to justify it.
18 THE CHAIRMAN: Thank you. Mr Garnham?
19 MR GARNHAM: Sir, while Miss Lawson was on her feet
20 documents that I wanted to ask this witness about were
21 circulated and I am sorry that it was not done before
22 and it may be, sir, that you will want to ask
23 Miss Lawson if she has any questions arising out of what
24 I now ask.
25 We have here an addition to our bundle system which

231
1 is apparently to go in volumes 45D and 45E. I want to
2 ask you about these as they describe the position as it
3 was during the present year.
4 First of all the memo to Anne Bristow copied to you
5 of 9th February 2001 which is the first document. Do
6 you see that?
7 MS GRAHAM: Yes.
8 MR GARNHAM: From a number of people who I do not know. Who
9 are Denise Cuffy and the others?
10 MS GRAHAM: Denise Cuffy is a social worker.
11 MR GARNHAM: Where?
12 MS GRAHAM: She is at the North Tottenham District Office.
13 Elaine Noel is a social worker also of the same --
14 MR GARNHAM: Are they all North Tottenham District Office?
15 MS GRAHAM: I think so. The third person along I am not
16 familiar with.
17 MR GARNHAM: I am only trying to understand which office
18 this comes from.
19 MS GRAHAM: Okay.
20 MR GARNHAM: They write 9th February, "Duty Crisis":
21 "Due to the ongoing crisis with Duty at the NTDO,
22 the situation has escalated to what can only be
23 described as a major crisis with the current Duty
24 system.
25 "Mary Rice's team has gone on an away day leaving

232
1 four remaining workers to cover Duty - although they
2 have already done their Duty and shadow Duty for the
3 week.
4 "At present with the situation as it is social
5 workers are feeling highly demoralised and unable to
6 carry out duties on allocated cases. Consequently we
7 are falling further behind with our child protection
8 cases thus further putting our clients at risk.
9 "In light of the above, we require a response today
10 as to how the matter can be resolved.
11 "We are not prepared to continue working under these
12 stressful conditions which has adverse effects on our
13 health."
14 Over the page:
15 "We are concerned that we are being put in this
16 position of informing you of our concerns through a
17 memo~...
18 "Therefore we have made the decision that we will
19 not be covering Duty on 9th February 2001 and presume
20 that you will be taking appropriate action to address
21 the issue."
22 Do you know what happened as a result of that?
23 MS GRAHAM: I do know that Dave Duncan responded but
24 I cannot -- it does not spring to mind immediately what
25 the response was.

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1 MR GARNHAM: In writing or orally?
2 MS GRAHAM: I think we -- I cannot say. I do not know if we
3 wrote.
4 MR GARNHAM: Did that memo accurately represent the position
5 as it was on 9th February this year?
6 MS GRAHAM: Yes -- well, I do not know. If they have
7 written it as such I would agree with it.
8 MR GARNHAM: Thank you. The next document, 45E, a letter
9 from Mary Rossiter, North Middlesex to Shirley Dunn, CPA
10 office at Hornsey. Is she another one of your team?
11 MS GRAHAM: She was covering my absent post as she was
12 acting as the Commissioning Manager.
13 MR GARNHAM: Thank you. Third paragraph:
14 "I need to tell you that two strategy meetings have
15 been held in the community this week with regard to
16 children who are in-patients at North Middlesex
17 Hospital."
18 Then she gives details.
19 "We have plenty of large rooms for strategy meetings
20 and Ann Graham agrees that these should be held on
21 hospital premises when paediatric patients are still in
22 the hospital."
23 It looks as if despite your concerns that problem is
24 still happening, at least in May 2001.
25 MS GRAHAM: Yes, as written here.

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1 MR GARNHAM: So that has still not been addressed?
2 MS GRAHAM: It has been addressed inasmuch as that people
3 have been informed that that should happen.
4 MR GARNHAM: But it does not happen?
5 MS GRAHAM: Dr Rossiter has written here to say that it has
6 not happened.
7 MR GARNHAM: Do you know whether that is still happening?
8 MS GRAHAM: I do not think that is the current position.
9 I think that meetings do take place in the hospital.
10 MR GARNHAM: Thank you. The last point is a question I am
11 asked to put to you. The NAI forum, is it right that it
12 is not just used for in-patients or NHS referrals, it is
13 used for others who are believed to be the victim of
14 non-accidental injury?
15 MS GRAHAM: I think it is a forum where children who come to
16 the attention of the hospital are discussed.
17 MR GARNHAM: Not necessarily in-patients?
18 MS GRAHAM: Not necessarily in-patients.
19 MR GARNHAM: Yes, thank you very much.
20 THE CHAIRMAN: Miss Lawson?
21 MISS LAWSON: No, nothing sir.
22 THE CHAIRMAN: Thank you very much indeed for your evidence
23 today, Ms Graham. Mr Garnham.
24 MR GARNHAM: Sir that completes our business. I am sorry it
25 is rather late today. I ask you to adjourn until 9.30

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1 tomorrow morning.
2 THE CHAIRMAN: Indeed. Tomorrow being Friday, ladies and
3 gentlemen, we will adjourn until 9.30. Thank you very
4 much indeed.
5 (4.55 pm)
6 (Hearing adjourned until 9.30 am the following day)
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