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Archived Transcript for 30 November 2001:
Pages 1 to 50
1
1 Friday, 30th November 2001
2 (9.30 am)
3 MR GARNHAM: Good morning sir.
4 THE CHAIRMAN: Good morning.
5 MR GARNHAM: I wonder if we could have Ms Green back to the
6 witness chair, please. Sir, you will remember that
7 yesterday evening I had completed my examination and we
8 were about to move to Miss Lawson. Overnight I have
9 been given another question from one of the interested
10 parties. You might think it more convenient for me to
11 put it now because that will give Miss Lawson a chance
12 to deal with it.
13 THE CHAIRMAN: I think that would be fair, thank you.
14 MS DAWN GREEN (continued)
15 MR GARNHAM: Good morning Ms Green.
16 MS GREEN: Morning.
17 MR GARNHAM: You told us during yesterday's proceedings of
18 the audit that you carried out or helped to carry out on
19 the instructions of the Leader of the Council following
20 Victoria's death.
21 MS GREEN: Yes.
22 MR GARNHAM: We went through that in a little detail. Since
23 March or April of 2000 have you revisited the I&A Teams
24 to repeat that audit to see how things have changed?
25 MS GREEN: I have been on maternity leave from March 2001 so
2
1 I am not sure whether that --
2 MR GARNHAM: What about the year between March 2000
3 and March 2001?
4 MS GREEN: No, not to my knowledge.
5 MR GARNHAM: Do you know whether since March 2001 a similar
6 audit has been carried out?
7 MS GREEN: I do not know.
8 MR GARNHAM: Given the seriousness of the matters revealed
9 by the March 2000 audit, why was there no follow-up in
10 the year that followed?
11 MS GREEN: My understanding was that very shortly following
12 the audit report the SSI came in to do an inspection and
13 there were a number of action points coming out of the
14 SSI inspection, because they found very similar things
15 to the audit report, so if you like I suppose there was
16 follow-up in the sense of the SSI. Following that audit
17 report, following the SSI report, my understanding was
18 that Haringey implemented a lot of, or began to
19 implement a lot of the suggestions that the SSI made in
20 that April 2000 SSI report.
21 MR GARNHAM: Thank you very much. Thank you sir.
22 THE CHAIRMAN: Thank you Mr Garnham. Miss Lawson.
23 MISS LAWSON: I would just like to pick up on a number of
24 matters that you dealt with in your evidence yesterday.
25 First of all, you mentioned at one stage in relation to
3
1 the securing of the file after Victoria's death that
2 that was not exclusively your responsibility because the
3 Child Protection Guidelines said that that was also the
4 responsibility of the team manager to secure the file.
5 Can I just get you to confirm it is volume 24 page 108,
6 please?
7 MS GREEN: Yes, that is right.
8 MISS LAWSON: That is the particular point that you had in
9 mind?
10 MS GREEN: That is the point that I had in mind.
11 MISS LAWSON: Can I just ask, had you been responsible for
12 securing files before, following the death or --
13 MS GREEN: On one other occasion I was responsible for
14 securing a file, yes.
15 MISS LAWSON: Were you aware of any previous suggestion of
16 a file being tampered with in those circumstances?
17 MS GREEN: No, I was not.
18 MISS LAWSON: You were asked also by Mr Garnham about your
19 historical role in relation to improving practice and
20 maintaining a high standard of quality control in
21 relation to child protection matters in Haringey. Can
22 I ask you to look at volume 27, page 164, please. This
23 is in relation to the first of the two audits you looked
24 at yesterday, Ms Green, the one about case recording and
25 the audit that you carried out in relation to that.
4
1 These are Haringey's case recording guidelines, which we
2 can see by looking at them were produced in 1998.
3 I just wondered whether you or your team had made any
4 input into those.
5 MS GREEN: I did not personally but certainly people in our
6 team were responsible for this as well.
7 MISS LAWSON: Thank you. Now, as far as the case recording
8 guidelines are concerned, and the extent to which you
9 were auditing the way that files were maintained, you
10 found in the report that you were taken to, and the
11 parts that Mr Garnham highlighted, some discrepancies,
12 areas of poor recording, which you highlighted. Is it
13 a difficulty to relate poor recording to poor outcome,
14 as far as the children are concerned?
15 MS GREEN: Say that again please.
16 MISS LAWSON: There is the question of whether or not a file
17 is properly maintained and recorded and there are all
18 sorts of reasons, perfectly obvious, why within social
19 services it is important that files should be properly
20 maintained and recorded, and every single inquiry that
21 there ever is comments on this, and supervision and
22 failures of communication, and no doubt there are one or
23 two, but as far as the question -- there are two points.
24 There is first of all the question of the recording
25 itself and the importance of doing that. Now, some
5
1 people are much better at recording than others, are
2 they not?
3 MS GREEN: Yes.
4 MISS LAWSON: The ability to record things accurately is not
5 necessarily related to the quality of the work that an
6 individual may be doing on the case?
7 MS GREEN: Yes.
8 MISS LAWSON: Is that your experience, or ...?
9 MS GREEN: That is my experience. Obviously for continuity
10 and for other people picking up the file people do need
11 to keep as good as possible records but I have known
12 people who are excellent practitioners who hate all the
13 paperwork and do it very grudgingly.
14 MISS LAWSON: And perhaps even the other way around, people
15 who are ace at recording everything but not necessarily
16 the most able practitioners.
17 MS GREEN: Absolutely.
18 MISS LAWSON: So I bring you back to my poorly phrased
19 question which is that the question of looking at the
20 case recording is monitoring performance but is not
21 necessarily related to the outcome for the children in
22 each individual case.
23 MS GREEN: Yes, that is true.
24 MISS LAWSON: And when we come to look at the audit that you
25 did after Victoria's case, the position as far as North
6
1 Tottenham was concerned was, as Mr Garnham indicated to
2 you yesterday, nothing like as bad as the picture you
3 found in Hornsey and I think I am right in saying that
4 he did not highlight any particular horror stories that
5 you had found in the records in North Tottenham.
6 MS GREEN: That is true.
7 MISS LAWSON: Analogous to what you found here, that he was
8 highlighting matters such as cases being allowed to
9 drift and the question of whether the planning was
10 really what you would hope to see. One of the points
11 that Mr Garnham put to you was that it is a problem that
12 there are within the social services office people of
13 different levels of ability and it is tough if you get
14 one of the ones who is not as good dealing with your
15 particular case. One can see the force of that.
16 I would like to suggest to you that that is not
17 something which is really just confined to social
18 services, that any service which is provided by
19 individuals is bound to contain that variation and that
20 when an inquiry like this is looking at how to improve
21 the situation, a failure to recognise that will not
22 produce workable recommendations.
23 I would like you therefore if you can to help us in
24 this way. When you are trying to improve the practice
25 in your capacity as child protection adviser, what are
7
1 the things in your view that actually stop that
2 happening? Is it ill will? Do people not want to
3 improve? Are they totally resistant? You know, if we
4 are going to move this area forward what actually would
5 make a difference, do you think?
6 MS GREEN: My own personal belief is that if you have
7 so-called people who know something about child
8 protection employed by the local authority then their
9 advice should be taken, and if people do not follow that
10 advice then there should be sanctions in place to deal
11 with that as a misdemeanour, following the disciplinary
12 or competency codes I would suggest.
13 MISS LAWSON: Is that in relation to individual cases or
14 generally?
15 MS GREEN: I think generally. I think if you give a dictate
16 that child protection advisers' advice should be
17 followed at all times then when people's advice is not
18 followed then something needs to happen as a consequence
19 of that. I think that is one way that you can ensure --
20 I mean I think the other thing, and one of the things
21 that we have tried to do is to put together a service
22 level agreement with the districts, suggesting that we
23 should be involved in certain cases, and we have
24 indicated what those cases might be.
25 MISS LAWSON: That is also in the Child Protection
8
1 Guidelines.
2 MS GREEN: Yes.
3 MISS LAWSON: There are certain cases where the child
4 protection advisers have to be involved.
5 MS GREEN: That we should always be involved in those cases.
6 I mean I think it is also fair to say that because of
7 our chairing and because of the team, I think as a team
8 we were fairly well aware of the practice in the
9 districts overall as an encompassing view, but I think
10 when we are giving individual consultations or when we
11 are chairing and making care plans, that workers do need
12 to be mindful, and I think senior management too, that
13 advice should be followed if they are employing people
14 to discharge that responsibility.
15 MISS LAWSON: I see, thank you. You were asked about the
16 relationships between child protection advisers and the
17 team managers and you gave some indication of why there
18 might be problems there. Was that your actual
19 experience of most of the team managers or was it --
20 MS GREEN: Most of the team managers wanted our help and
21 advice and used us on a regular basis.
22 MISS LAWSON: And you have been giving us some instances of
23 that in your evidence. One of the matters that
24 Mr Garnham put to you was that if the audit which was
25 carried out after Victoria's death in relation to
9
1 North Tottenham had been carried out in November of
2 1999, Victoria might well still be here, and you said,
3 "It is possible." I wondered what you had in mind when
4 you said that, what it was that you saw highlighted in
5 the audit which had it been done earlier might have
6 saved Victoria's life.
7 MS GREEN: As I said, especially in relation to Hornsey, we
8 went through files systematically, so we were looking at
9 things like were all the forms that are on files
10 generally properly filled in? Were the index checks
11 done? Was information in the right order? Were
12 confidential parts of the file filed correctly, that is
13 in the confidential part of the file? So that we were
14 doing a full audit of the file as it stood.
15 Now, it may be that reading that file through may
16 have given us an indication that the drift of this had
17 not followed through from the Section 47 to the actual
18 investigation, you know, from the strategy meeting
19 through to the investigation. So it is possible that we
20 may have picked it up and taken it back and said, "This
21 is one of the cases that we are worried about, team
22 managers may need to have a look at", if that case had
23 been -- there is a lot of ifs and buts -- and if that
24 case had been looked at by a team manager.
25 MISS LAWSON: We are talking about looking at it before the
10
1 child dies, not looking at it in the knowledge that she
2 has died subsequently.
3 MS GREEN: If you look at the strategy meeting
4 recommendations, and I have seen the file on the day
5 that I went to Carol Wilson's office, there is no very
6 clear indication on that file that those things that
7 were requested in the strategy meeting were actually
8 carried out. So if that had been picked up in an audit
9 that might have meant that it may have raised that issue
10 with the team manager, who may have put it back on
11 course in a child protection sense, who may have called
12 a case conference, et cetera et cetera. There are a lot
13 of mays.
14 MISS LAWSON: Exactly. One final matter. You were asked
15 about your involvement with the NSPCC and you explained
16 that your involvement was primarily with the
17 Maya Angelou Centre but you described the panel which
18 met to consider which statutory cases should go to the
19 NSPCC Family Centre. You mentioned that the panel had
20 ceased to meet when the two managers from east and west
21 got different jobs and you were not able to remember
22 when that was.
23 MS GREEN: Not exactly, no.
24 MISS LAWSON: If I was to suggest to you that it was May
25 1999, would that seem about right?
11
1 MS GREEN: Yes.
2 MISS LAWSON: Thank you.
3 THE CHAIRMAN: Thank you Miss Lawson. Just a few points if
4 I may for clarification Ms Green. Am I right in
5 thinking that you have been in Haringey since 1991?
6 MS GREEN: That is right.
7 THE CHAIRMAN: So you are very experienced in childcare
8 work?
9 MS GREEN: I think so, yes.
10 THE CHAIRMAN: I would like to just take forward a little
11 more a question that Miss Lawson just put to you. In
12 your evidence you said yesterday that there is a natural
13 tension, you said, a natural tension between team
14 managers and child protection advisers. I think I have
15 got some idea what that is but that is not good enough.
16 I need to have your evidence as to what it is. So what
17 is this natural tension?
18 MS GREEN: I think that because a team manager is managing
19 a team and therefore has case responsibility, that
20 anyone coming in offering advice could be viewed as
21 undermining their case responsibility.
22 THE CHAIRMAN: Is that it?
23 MS GREEN: I think so, that is the main thrust of what I had
24 in mind.
25 THE CHAIRMAN: Does that mean that it blurs the
12
1 accountability for who actually at the end of the day is
2 responsible for delivering quality service?
3 MS GREEN: My own personal view is that the delivering of
4 a quality service does not just rest with the districts
5 and does not just rest with the team manager and that
6 actually as a quality assurance, quality control worker
7 I would expect that my input would enhance the quality
8 and the input into that case.
9 THE CHAIRMAN: Yes, so what you are saying is that it is an
10 organisational responsibility rather than an individual
11 responsibility?
12 MS GREEN: Absolutely.
13 THE CHAIRMAN: You chair a lot of case conferences.
14 MS GREEN: I do.
15 THE CHAIRMAN: No doubt you are very good at it. What
16 I would like to ask you about is whether or not you have
17 any information about the strategy meetings that are
18 taking place. Do you actually know how many strategy
19 meetings, what kind of cases, what are the issues that
20 are being raised by strategy meetings, or is it that you
21 do not know anything about the case until it actually
22 comes to a case conference?
23 MS GREEN: There are two things. I mean historically we did
24 not know anything about cases until they came to case
25 conference and then more recently there were concerns
13
1 about the strategy meetings, so that all strategy
2 meeting forms were sent to us as a team to have a look
3 at and I was one of the people responsible for going
4 through strategy meeting minutes, to check that what
5 should have been done had been done.
6 THE CHAIRMAN: That did not happen when Victoria was --
7 MS GREEN: No, it was after that.
8 THE CHAIRMAN: Because you may know that there were two
9 strategy meetings held for Victoria, the first to decide
10 that there should not be a case conference and the
11 second decided there should be a case conference but it
12 never happened.
13 MS GREEN: I know, yes. Yes, we were not involved. I had
14 no knowledge, I was not invited and I would not be
15 normally and really that was the District's
16 responsibility because really the strategy meeting was
17 there to plan the investigation, to decide who was on
18 a very practical basis going to do what and within what
19 time scales, so that was the purpose of the strategy
20 meeting, so that that was very much bread and butter
21 work of the Districts.
22 THE CHAIRMAN: Yes, I understand. You have described in
23 your evidence about the audits that you were involved
24 in. Who actually saw these audits apart from you and
25 your line manager?
14
1 MS GREEN: They went up to assistant director and maybe
2 director level, I do not know, the manager would have
3 taken them to the management meetings and they would
4 certainly have been -- and also there was feedback to
5 the Districts of course in terms of the outcome, so that
6 there was a lot of consultation and feedback involved in
7 the audits. There was a lot of work.
8 THE CHAIRMAN: Could you say for certainty, and please do
9 not if you cannot say, that the Director of Social
10 Services would have read the audit that you described
11 yesterday?
12 MS GREEN: I would be incredibly surprised if she had not
13 but I mean I was not there so I cannot say that she did.
14 THE CHAIRMAN: You said quite rightly that you were not the
15 link person for the Moira Close Family Centre. Could
16 you say who was?
17 MS GREEN: I do not believe there was one.
18 THE CHAIRMAN: Were you aware of any concerns that the
19 police had in working with Haringey Social Services
20 Department on child protection?
21 MS GREEN: Not especially.
22 THE CHAIRMAN: Pretty good relationship, was it?
23 MS GREEN: I would say on the whole it was a pretty good
24 relationship. We were certainly used if there were any
25 problems, but I would have said on the whole, out of all
15
1 the agencies, probably the police less so.
2 THE CHAIRMAN: You got this call from Dr Rossiter.
3 MS GREEN: Yes.
4 THE CHAIRMAN: Was it by chance that it came to you, or ...?
5 MS GREEN: Yes.
6 THE CHAIRMAN: I mean, tell me, why did it come to you
7 rather than to Petra Kitchman?
8 MS GREEN: Petra was not there, that might be one reason.
9 I was unlucky I picked up the phone. I was in the
10 office at the time.
11 THE CHAIRMAN: Such is life. You tried to contact a senior
12 manager, three I think.
13 MS GREEN: Yes I did.
14 THE CHAIRMAN: And not one was available. Where were they,
15 why were they not available?
16 MS GREEN: I think it was the half term week when a lot of
17 children are off school so I would think that a lot of
18 them had taken time off to be with their children. I am
19 assuming. I think Carol Wilson was on some kind of
20 residential training exercise so she was not available.
21 I mean Lisa did tell me that she had phoned everybody
22 and that I was -- I would not be lucky if you know what
23 I mean, but I still felt that it was important as my
24 responsibility to actually ensure that that was done.
25 That was -- I felt that that was one of my
16
1 responsibilities, which is why I did the ringing round
2 again, so I was not all that surprised because I knew my
3 manager was not in, so I did phone Dave and Carol.
4 THE CHAIRMAN: So when children were away from school there
5 are no senior managers available in Haringey?
6 MS GREEN: I would not say that is always the case. I would
7 say that was unusual. I was shocked there was nobody
8 else there but there was cover, and that cover was in
9 the form of Jean Croot.
10 THE CHAIRMAN: I can understand you being shocked. Did you
11 try to contact the Director of Social Services?
12 MS GREEN: No, I did not.
13 THE CHAIRMAN: If a child dies -- well, it does not have to
14 be in these circumstances but particularly in these
15 circumstances, would it not be normal for the Director
16 of Social Services to be amongst the first people to be
17 informed?
18 MS GREEN: Yes, I would have suggested -- I mean at the time
19 I took the phone call Victoria was seriously ill, that
20 is true, but she had not died at that point.
21 THE CHAIRMAN: You are quite right. Thank you for
22 correcting that. Carry on.
23 MS GREEN: I felt that it was my responsibility to confer
24 with Jean, who would have been seen as a senior manager
25 covering, and it was her view at that time that there
17
1 was no need to involve anyone else at that moment in
2 time.
3 THE CHAIRMAN: Was that her decision?
4 MS GREEN: Yes.
5 THE CHAIRMAN: She said, "We do not need to bother the
6 Director of Social Services"?
7 MS GREEN: No, not as clearly as that, no.
8 THE CHAIRMAN: I do not know anything about her, all I know
9 is her title. Her title is not child protection, that
10 is for sure.
11 MS GREEN: She was in child protection before.
12 THE CHAIRMAN: So she knew what she was talking about, did
13 she?
14 MS GREEN: Yes, she had been a social worker and a team
15 manager in the Children and Families Team.
16 THE CHAIRMAN: That is helpful, thank you for that. Who
17 told the North Tottenham office that you were coming to
18 get the file?
19 MS GREEN: I do not know that. I do not know. What I did,
20 I mean it was quite a busy time. I was told to go and
21 do something so I went off and did my thing and other
22 people were phoning round. My understanding was, and
23 I may be wrong because I was not there, but that
24 Ann Graham was trying to arrange the multiagency
25 strategy meeting and getting everybody to that meeting.
18
1 So it was obviously a very stressful and busy time.
2 I went over to do my own thing so I was away from the
3 office for the rest of the day in actual fact, so
4 whatever was going on in the office at that time I was
5 not aware of. I was only aware to go and get the file
6 and things, other things would be being done while I was
7 doing that.
8 THE CHAIRMAN: Do you have 24/108 in front of you? It is
9 the point that Miss Lawson made. I just want to be
10 clear. I want to be clear what this page is because my
11 reading of this page was this is what the social worker
12 should do in such circumstances.
13 MS GREEN: Yes, these guidelines are really for social
14 workers.
15 THE CHAIRMAN: Right. This does not deal with how the
16 organisation secures a file?
17 MS GREEN: No, it does not. There is nothing there about
18 the procedure for securing a file other than this.
19 THE CHAIRMAN: You described yesterday what happened when
20 you went to the office in fairly clear -- well, very
21 clear and quite vivid terms. Your irritation, if I can
22 put it mildly, came across. You strike me as quite
23 a determined and confident person.
24 MS GREEN: I will take that as a compliment. Yes, I think
25 I am.
19
1 THE CHAIRMAN: Entirely intended as a compliment Ms Green.
2 Well, let me put it more directly then. You do not come
3 across as a shrinking violet.
4 MS GREEN: That is true.
5 THE CHAIRMAN: You did not go there as Ms Green, Child
6 Protection Adviser; you went there with the authority of
7 a more senior person behind you.
8 MS GREEN: Yes.
9 THE CHAIRMAN: I mean, put another way, and I do not mean
10 this at all offensively, you were actually a messenger.
11 MS GREEN: Yes.
12 THE CHAIRMAN: So why was it not possible to say, "I need
13 the file now. If there is a photocopy needed we will
14 photocopy it at headquarters and return a photocopy to
15 you"? There was no other child involved.
16 MS GREEN: It is a fair point. I mean I suppose, thinking
17 about it now, I was unsure about what I would be taking
18 if I gathered everything up in a bundle as it was,
19 because of the process of it being halfway through. And
20 I thought because I had to meet Carol at 12 I had the
21 time to allow them to complete a task that they had
22 already begun, so I thought on the balance it was most
23 sensible to give them a short period of time in order to
24 complete the task that they had already begun before
25 I had arrived, in order for me to take what I could have
20
1 been sure they were giving me was the complete version
2 of the file.
3 Otherwise I could never be sure that a piece of
4 paper had not gone under the photocopying machine or,
5 you know, I could not take responsibility for that
6 process because I had not been there from the beginning
7 of it, so I thought at the time that the most sensible
8 thing was to allow them to finish that process and then
9 for me to take the file as I also had the time
10 available. I mean, I think if Carol Wilson had said,
11 "Get the file to me by 10 o'clock", I would have gone in
12 there and taken it as it was, so I think that was the
13 other factor that guided my thinking on that day.
14 THE CHAIRMAN: If by chance you are unlucky and answer the
15 phone again and your boss says, "Secure a file", what
16 would you do next time?
17 MS GREEN: Ask someone else! No, I would go down there and
18 take the file in whatever state it was.
19 THE CHAIRMAN: Because it exposes everybody to the dangers
20 that have already been --
21 MS GREEN: I do understand that. I think in fairness to
22 myself I think the photocopying, if people were going to
23 tamper with it, to be fair, they had had a lot of
24 opportunity in order to do so and that was also
25 something that was in my mind, so that in terms of
21
1 protecting other people that position had passed by the
2 time I arrived on the scene.
3 THE CHAIRMAN: Because of the gap that existed?
4 MS GREEN: Because of the gap.
5 THE CHAIRMAN: Yes, I take that as an entirely fair point
6 and I am grateful to you. Mr Garnham.
7 MR GARNHAM: Sir, just one question arising from what has
8 been said so far.
9 The call that Haringey received on 25th February was
10 that from Dr Rossiter or from a Dr Alsford, who we have
11 heard from in this Inquiry, who says she made the call;
12 do you know?
13 MS GREEN: It was definitely Dr Rossiter.
14 MR GARNHAM: Because you know her?
15 MS GREEN: I know her voice, yes.
16 MR GARNHAM: That is the only point. Thank you very much.
17 THE CHAIRMAN: Ms Green, thank you for the way you have
18 given your evidence.
19 (The witness withdrew)
20 MR GARNHAM: Sir, I regret to say I need to ask you and your
21 colleagues to rise for a few minutes. I do so for two
22 reasons. First, Miss Lawson has handed me this morning
23 three documents. She did so during the course of the
24 evidence we have just been hearing. They are of central
25 importance to the evidence we are going to hear from
22
1 Ms Kozinos.
2 The first of the documents I think I have seen
3 before although I will check that. The second and the
4 third I have not. The second is very short and I have
5 read it while the evidence was going on. The third is
6 a document that runs to 19 pages. It is of central
7 importance to the evidence of the next witness. I do
8 not think I can do either the Inquiry or Ms Kozinos
9 justice without my reading it properly and for that
10 reason I would ask your indulgence for time to do so.
11 It may also give the interested parties time to consider
12 one other matter.
13 You will be aware, sir, that the Solicitor to the
14 Inquiry circulated to the interested parties on two
15 occasions details of a connection that one of your
16 assessors, Mrs Kinnair, has discovered she has with
17 a member of Haringey Social Services. We, the Inquiry,
18 have done that pursuant to our continuing obligation to
19 ensure that any connection we discover as matters
20 progress is brought to the attention of everybody
21 concerned.
22 There has been some suggestion that that may prompt
23 some form of application from some party or another.
24 Given that we are now moving on to hear the evidence of
25 Ms Kozinos, I would invite any interested party who
23
1 wishes to say anything about that matter to do so now
2 because otherwise the matter cannot be dealt with
3 sensibly, given that we are about to proceed with
4 a central witness dealing with Haringey's involvement in
5 this matter. It is of course not a matter for me but
6 a matter for those representing interested parties, but
7 I would urge them if anything is going to be made of
8 this point to do so now rather than to save it up.
9 So for each of those reasons I wonder if I could ask
10 you to rise. It is going to take me, even with my
11 recent speed reading course, 15 minutes to read this
12 19-page document.
13 THE CHAIRMAN: Thank you Mr Garnham. I am very anxious that
14 we do it well and therefore it is important that you
15 have time to read this document. That being so, if you
16 think 15 minutes is the right time we will rise until
17 20 past 10.
18 MR GARNHAM: I am getting indications. It occurs to me that
19 it may also be necessary to have this copied. I do not
20 yet know what is in it but I imagine that others will --
21 I am certain others will need to see it eventually, they
22 may well need to see it before I start with Ms Kozinos
23 and certainly Ms Kozinos's counsel will need to see it.
24 So building in the time to photocopy it and issue it, we
25 probably ought to say until half past 10.
24
1 THE CHAIRMAN: Absolutely. Let us do it properly and well,
2 and I do not want anybody to be disadvantaged in any way
3 and so let us rise until 10.30. We will adjourn until
4 10.30.
5 (10.05 am)
6 (A short break)
7 (10.35 am)
8 THE CHAIRMAN: Ladies and gentlemen, there were two points
9 that Mr Garnham made before we adjourned. One was about
10 these documents and the other one was about any
11 application. If there is going to be an application of
12 any kind could we deal with it now please.
13 MISS LAWSON: Sir, I do not know whether anybody else is
14 proposing to make an application but I would be grateful
15 if you would allow me to make a statement on Haringey's
16 behalf. It is not an application but I want to avoid
17 any suggestion that Haringey is trying to seek some
18 advantage by not making public its reasons for not
19 making any application in relation to the matters.
20 THE CHAIRMAN: Right Miss Lawson.
21 MISS LAWSON: Sir, Haringey was unaware of any connection
22 between any member of its staff and Miss Kinnair prior
23 to 23rd November. We made enquiries as soon as we
24 received the name on Tuesday 27th November and passed
25 the information to the Inquiry on the same day.
25
1 Haringey accepts the account given by Miss Kinnair of
2 her limited contact with her second cousin who is
3 employed by Haringey Council.
4 No doubt had it been known prior to the start of the
5 Inquiry that Miss Kinnair's cousin was employed at the
6 relevant time in the Tottenham Duty Intake and
7 Assessment Team, this would have been taken into account
8 when the Panel was selected. However, given that the
9 Inquiry has already heard considerable evidence,
10 Haringey is content for Miss Kinnair to continue, as we
11 have no doubt that she will discharge her
12 responsibilities to the Inquiry in a professional
13 manner.
14 THE CHAIRMAN: Thank you Miss Lawson. I suspect that I am
15 not the only person in the room who does not know the
16 definition of a second cousin. I suspect that there are
17 other people elsewhere that would have a certain
18 sympathy with me if I said I do not know how many second
19 cousins I have or what jobs they do, but there is one
20 thing I am absolutely clear about, and that is my
21 absolute, total and complete confidence in Mrs Kinnair,
22 her professional integrity, and I am glad the matter is
23 settled in that way. Now, Mr Garnham.
24 MR GARNHAM: I too. I will just look around the room to
25 make sure nobody else wants to make any application in
26
1 relation to this. I see nobody does, so perhaps we can
2 proceed.
3 The second reason for the short adjournment we have
4 taken was the delivery to me during the course of this
5 morning's proceedings of three documents from Haringey
6 Council. One of those documents was a memo from
7 Rose Kozinos, the next witness we are to call. That,
8 sir, was already in our bundles, for your note at 45A,
9 page 150.501.
10 THE CHAIRMAN: Thank you.
11 MR GARNHAM: The other two documents were not. The first of
12 them is a reply from Ms Bristow, the Director, to
13 Ms Kozinos, dated 7th June of this year, and quite why
14 that was not provided to the Inquiry before, I am
15 uncertain. The second document was a lengthy report
16 commissioned as a result of the memorandum sent by
17 Kozinos to Bristow, commissioned on 7th June. It is
18 undated so we do not know when it was obtained but it
19 would be surprising in the extreme if it had taken four
20 months to produce.
21 The implication must be, therefore, that it has been
22 in Ms Bristow's or Haringey Council's hands for some
23 time. Quite why it was not disclosed to us until the
24 59th minute of the 11th hour I do not know and it may be
25 that is something that Miss Lawson in a moment can
27
1 assist with. It puts us in considerable difficulties.
2 We for our part finds it frankly astonishing that
3 this material should come so late. We had occasion to
4 raise with you on an earlier occasion another London
5 borough who I suggested were dripfeeding material to us.
6 I asked for the assurance of other interested parties
7 that that would be avoided in the future and I received
8 that assurance from those concerned. I fear that we are
9 being dripfed information again. It is not only the
10 problem of trying to deal with a document of this length
11 at this short notice, a few moments before the witness
12 concerned is being called, it is also trying to fit it
13 in with any sensible plan for the way this Inquiry is to
14 be run.
15 It cannot conceivably be said that this document is
16 irrelevant since it plainly goes to the question of the
17 lessons which Haringey have learned or have not learned
18 as a result of the death of Victoria Climbie. The
19 problem multiplies because this document in turn refers
20 to four more documents which we do not appear to have
21 received. They are a report written on 25th May 2001
22 after an audit was carried out by members of the Child
23 Protection Review Service, a report dated 1st June 2001
24 by the Acting Commissioning Manager for North Tottenham,
25 Terry Burns, an urgent memorandum to the Commissioning
28
1 Manager Dave Duncan dated 25th May 2001 and finally the
2 plan of actions which the final paragraph of this report
3 promises, which presumably has been taken forward.
4 Sir, this Inquiry is not a game. We are about
5 serious matters and we are trying to ascertain what
6 happened to a child and whether that is likely to happen
7 again. To be provided the material in this way, which
8 makes it impossible properly to conduct
9 cross-examination, is in my respectful submission
10 intolerable.
11 We have now the problem of whether to adjourn
12 today's proceedings in their entirety so that we can be
13 provided with this material or whether to try and limp
14 on, taking such of Ms Kozinos's evidence as we can and
15 then reviewing the position over the weekend. Because
16 I do not want us, sir, to lose the remainder of today it
17 seems to me that the latter of those courses is
18 preferable, though it does mean I fear that we will
19 certainly not finish Ms Kozinos today because I want to
20 look at this material over the weekend.
21 It also means that I must invite Haringey now to
22 provide us with those documents that I have just
23 referred to and any others of a similar character that
24 they have. There are two ways in which that might be
25 done. The first is for Haringey simply to volunteer
29
1 that material and get it to us promptly. The second,
2 sir, is for you to issue a summons under your powers
3 under the Local Government Act and require the Director
4 of Social Services to attend at 9 o'clock on Monday
5 morning to produce all the files relating to this
6 matter.
7 Sir, I am in your hands and would be interested to
8 know Haringey's reaction to those two possibilities but
9 in my respectful submission the current situation is one
10 that is simply not sensible to continue with. It may be
11 you want to hear from Miss Lawson on this.
12 THE CHAIRMAN: Sure, I do want to hear from Miss Lawson and
13 what Miss Lawson says will give me some help in deciding
14 whether to act upon that last suggestion. So
15 Miss Lawson please.
16 MISS LAWSON: Sir, I can only agree with Mr Garnham.
17 I acknowledge that these documents should have been
18 placed before the Inquiry before. I have ensured that
19 they were placed before the Inquiry at the earliest
20 opportunity when they became available to me.
21 I acknowledge and we are already searching for the other
22 documents which are listed and which Mr Garnham has
23 called for.
24 I was not entirely sure, because you may or may not
25 be aware that we have been responding to numerous
30
1 requests for a wide range of documents which we have
2 been trying to trace down and put before the Inquiry,
3 whether or not any of these documents had been included
4 in that recent disclosure. I had hoped that they were.
5 If they were not and I am unable myself to assist you
6 about that, then again I can only apologise on the
7 Council's behalf.
8 THE CHAIRMAN: Thank you Miss Lawson. Miss Lawson I wonder
9 if you are able to help me with one thing though, and
10 that is that this document which I have just seen now,
11 just put before me, which is headed "Report of Visit to
12 North Tottenham Children and Families Area Office", my
13 copy is undated. Do you have an idea when this was
14 produced?
15 MISS LAWSON: I think it is June or July is the best we can
16 do at the moment. Again we will try and get clear
17 exactly when it was completed and passed to us but just
18 at the moment that is the best we can do.
19 THE CHAIRMAN: Sorry, I notice it was commissioned in June.
20 What I was wondering was when it was submitted to the
21 Director of Social Services.
22 MISS LAWSON: We think it is later in June or early July but
23 we are not absolutely certain at the moment.
24 I know what he is going to say.
25 MR GARNHAM: Sir, it is so obvious I will not say it.
31
1 THE CHAIRMAN: Say it for my benefit.
2 MR GARNHAM: If it has been available that long it should
3 have been disclosed long before this morning. I have
4 also been passed a note which it seems to me compounds
5 the position. I am told in this note, and doubtless
6 counsel can speak to it if that is necessary, that
7 Rose Kozinos has been asking for a copy of this report
8 since the summer and it has never been disclosed to her.
9 Sir, you will make of that what you will.
10 It seems to me in my respectful submission in the
11 light of the way that Miss Lawson puts it that the only
12 proper course is for you, sir, to issue a summons. The
13 advantage of issuing a summons is that if that is not
14 complied with then the sanctions that are set out in
15 Section 250 of the Local Government Act will be
16 available to you, sir. That will include supplying of
17 information. We cannot proceed in this manner, in my
18 respectful submission, in the future.
19 THE CHAIRMAN: Thank you very much. I think I would like
20 just a moment to think about how I am going to express
21 myself and I will try and do it judiciously.
22 Well, ladies and gentlemen, I will try and express
23 myself judiciously but you will understand that it is
24 not entirely easy for me to do that because of the
25 circumstances in which I now find myself in in chairing
32
1 this Inquiry.
2 I think that it is deeply disturbing that this
3 material comes to the Inquiry in this form at this time
4 and certainly I find it disturbing that it gets put in
5 front of me just this minute, a document, at least one,
6 which is obviously important to the Inquiry, and which
7 refers to other documents, as I understand it, although
8 I have not had a chance to read that yet.
9 I feel particularly aggrieved about this because we
10 have had earlier, to put it nicely, discussions with
11 Haringey, who I did not think used the same judicious
12 language that I am using when they referred earlier to
13 the Inquiry being preoccupied with a paperchase rather
14 than the real issues. I took exception to that and
15 I take even more exception to it now in the light of
16 this material that has been produced this morning.
17 It is just not good enough. In fact, more than
18 that, it is totally unacceptable. This is an important
19 Inquiry, it is a difficult Inquiry to conduct and it is
20 an Inquiry which is of immense importance, not just in
21 respect of previous practice but in learning the lessons
22 for the future. I know that the Government attaches
23 considerable importance to this Inquiry being conducted
24 thoroughly and correctly and I and my colleagues are
25 working hard to achieve that.
33
1 In the circumstances in which I now find myself I do
2 not think that I have any alternative but to issue the
3 summons to the Director of Social Services of Haringey
4 and that will be done today.
5 MR GARNHAM: Thank you sir.
6 MR MASON: Sir, as we are on the subject of disclosing
7 documents, could I say something about the NHS position
8 given that there is this outstanding stuff that we are
9 doing at the moment? I have tried to keep Mr Garnham
10 informed about that. At the end of Dr Rossiter's
11 evidence Haringey asked for disclosure of any
12 documentary evidence from Dr Rossiter about complaints
13 that she had concerning Haringey.
14 THE CHAIRMAN: Indeed.
15 MR MASON: We have been trying to get that all together and
16 I have been keeping Mr Garnham informed as best I can.
17 We have difficulty, there are a number of individual
18 cases, post Victoria cases, where concerns have been
19 raised by Dr Rossiter about the service from Haringey.
20 There is also some more generic documentation relating
21 to concerns in relation to failure to provide hospital
22 social workers that were mentioned in the NHS evidence
23 in Dr Rossiter's statements.
24 THE CHAIRMAN: I recall.
25 MR MASON: I am also trying to make sure, because of the
34
1 position acting for the health community in that area,
2 that I get any documentation held by the Health
3 Authority and the Primary Care Trust and its predecessor
4 Community Trust together in one piece.
5 The way forward suggested by Mr Garnham, which
6 I think is very sensible, is to put the information all
7 together in one statement which could probably be from
8 the North Middlesex Medical Director Dr Yasmin Drabu.
9 I am doing my best to get it all together. Some of it
10 I know you already have.
11 I have not had time to read every single file of the
12 85 volumes but I noticed the other day there are some
13 letters from Haringey in the Haringey documentation to
14 the Inquiry to North Middlesex Hospital. The letters to
15 the North Middlesex prompting these replies are not in
16 the bundle so I am going to be doubly careful to make
17 sure that you, sir, have everything we can possibly
18 find. I am sorry it is taking longer than I would have
19 liked and I am sure that you would have liked but
20 I thought I had better make the position clear now as we
21 are discussing disclosure of documentation and I do not
22 want to find myself dripfeeding the Inquiry.
23 THE CHAIRMAN: I am grateful to you. Could you give any
24 idea and, if it is not possible, to get an idea --
25 I operate on the basis of no surprises in this life and
35
1 sadly it does not always work in that way, so if you
2 could give me some idea I would appreciate it.
3 MR MASON: A number of people are running round frantically,
4 I have the Chief Executive of the Health Authority being
5 very helpful with me today. Can I say next week?
6 THE CHAIRMAN: Mr Garnham?
7 MR GARNHAM: Mr Mason has indeed kept me informed of the
8 efforts to obtain this and we are grateful for his
9 assistance.
10 While that discussion was going on Ms Kozinos's
11 counsel has whispered in my ear her view on the position
12 in which she and we now find ourselves. It seems to me
13 entirely reasonable that she should say as she does that
14 while she is perfectly content to go ahead with her
15 evidence, she does not feel that she would be in
16 a position to respond to the report that was produced
17 this morning were I to ask her questions about it.
18 I will need to ask her questions about it but what
19 I propose to do is to simply leave that, those
20 questions, until Monday morning. We will deal with it
21 then.
22 THE CHAIRMAN: I think that is entirely fair. Mr Wilkinson.
23 MR WILKINSON: Can I just impose one caveat on that? The
24 likelihood is that Rose will be midway through her
25 evidence and I would like the opportunity to speak to my
36
1 client about the report over the course of the weekend.
2 THE CHAIRMAN: Well, as this is new material, unless
3 Mr Garnham thinks otherwise that seems to me to be an
4 entirely proper arrangement.
5 MR GARNHAM: I agree. I will call Rosemarie Kozinos please.
6 MS ROSEMARIE KOZINOS (affirmed)
7 MR GARNHAM: Good morning Ms Kozinos.
8 MS KOZINOS: Good morning.
9 MR GARNHAM: Would you give the Inquiry your full name.
10 MS KOZINOS: Rosemarie Kozinos.
11 MR GARNHAM: I am sorry that you have had to wait so long
12 before we started this morning. I think it is right
13 that you have provided the Inquiry with a statement,
14 a copy of which is now being put in front of you. Sir,
15 it is volume 2, page 202.401.
16 Would you now look through that and confirm to me
17 that you have signed it and that its contents are true.
18 If you wish to make any amendments to it can you
19 indicate that please.
20 MS KOZINOS: Yes I have signed it and I wish to make some
21 amendments.
22 MR GARNHAM: Subject to the amendments you want to make, is
23 it true?
24 MS KOZINOS: Yes, I would like to make some amendments.
25 MR GARNHAM: Let us work through the amendments then. Do
37
1 you have a list of them?
2 MS KOZINOS: Yes, I do. On page 3, paragraph 3, four lines
3 down, it says "1995"; it should be "1994".
4 MR GARNHAM: That is October 1994 instead of 1995 when you
5 commenced the work at Haringey?
6 MS KOZINOS: That is right.
7 MR GARNHAM: Thank you.
8 MS KOZINOS: Also page 4, paragraph 4, last line, it should
9 be "Acting Team Manager".
10 MR GARNHAM: "... a copy of the job description for Acting
11 Team Manager"?
12 MS KOZINOS: That is right.
13 MR GARNHAM: Thank you. Any more?
14 MS KOZINOS: Yes, sorry. Page 9, midway down, it is "no
15 medical reports", not "no written information".
16 MR GARNHAM: That is about --
17 MS KOZINOS: It starts midway.
18 MR GARNHAM: -- nine lines from the bottom:
19 "However in the event she had brought no", delete
20 "written information" and put "medical reports"?
21 MS KOZINOS: Yes. And the rest is, well, grammar. Three
22 lines --
23 MR GARNHAM: I think we can probably survive without
24 corrections to the grammar. If we started correcting
25 them this Inquiry might double in time.
38
1 MS KOZINOS: Page 10, please. It is from the second line
2 down "had" to be crossed out until "day". That was
3 based on incorrect information I was given at the party.
4 Where it says "had".
5 MR GARNHAM: "Had I known that a Police Protection Order was
6 in place ..."
7 MS KOZINOS: None of that is relevant until it ends up
8 "...~the same day", which is three lines up from the
9 bottom of that paragraph.
10 MR GARNHAM: Thank you.
11 MS KOZINOS: I think that is it.
12 MR GARNHAM: With those corrections, are you now content
13 with this statement as being a true account of your
14 evidence?
15 MS KOZINOS: Yes, I think that is it.
16 MR GARNHAM: Thank you very much.
17 THE CHAIRMAN: That is the removal of the whole of the third
18 sentence on page 10?
19 MR GARNHAM: No, it is rather more than that. It is the
20 removal of lines 3, 4, 5, 6, 7, 8, 9, 10, 11 and the
21 first half of 12.
22 MS KOZINOS: Yes.
23 THE CHAIRMAN: Right.
24 MS KOZINOS: I responded to information that was --
25 MR GARNHAM: I will ask you about that change in a little
39
1 while. I think it is right you also made one statement
2 for the Crown Prosecution Service.
3 MS KOZINOS: Yes.
4 MR GARNHAM: Sir, for your note that is in volume 46 at
5 page 135.601.
6 MS KOZINOS: Thank you.
7 MR GARNHAM: You qualified as a social worker in 1994?
8 MS KOZINOS: That is right.
9 MR GARNHAM: You began work at Haringey in October 1995?
10 MS KOZINOS: 1994, I corrected it.
11 MR GARNHAM: I am sorry. You then moved to the North
12 Tottenham District Office in the I&A Team in February
13 1996?
14 MS KOZINOS: That is right.
15 MR GARNHAM: February 1997 you became Acting Senior
16 Practitioner?
17 MS KOZINOS: That is right.
18 MR GARNHAM: And you remained in that position until
19 24th December when you became Practice Manager?
20 MS KOZINOS: Yes.
21 MR GARNHAM: In July 2000 you became Acting Team Manager?
22 MS KOZINOS: Yes.
23 MR GARNHAM: You do not mention this in your statement
24 because of its relatively recent events, but I think it
25 is right that you resigned on 18th June 2001?
40
1 MS KOZINOS: That is right.
2 MR GARNHAM: That was your letter of resignation. You in
3 fact went on sick leave on 6th July and formally your
4 last day of service was 8th August of this year?
5 MS KOZINOS: 2nd.
6 MR GARNHAM: Thank you. For the reason you now know about
7 I will not discuss with you the response to this memo
8 but I want to take you first please to a memorandum that
9 you wrote to Anne Bristow 12 days before you left
10 Haringey Social Services, volume 45A please. Page
11 150.501. Do you have that?
12 MS KOZINOS: Yes, I do.
13 MR GARNHAM: I would like you to use the copy from the
14 Inquiry's bundle so we can be sure we all have the same
15 page references. That is a copy of the memorandum.
16 Before I ask you about that do you have some other
17 documents in front of you on the table?
18 MS KOZINOS: Yes, my statement.
19 MR GARNHAM: You have your statement and are there some
20 other documents there?
21 MS KOZINOS: A copy of the memorandum.
22 MR GARNHAM: Can I ask you to put those other documents to
23 one side. If you want to refer to them please simply
24 ask and we will deal with it.
25 MS KOZINOS: Okay.
41
1 MR GARNHAM: But it is important that we know what you are
2 looking at. In the memorandum of 6th June you set out
3 concerns you had in June of this year about staffing,
4 recruitment and the quality of practice in Haringey
5 I think.
6 MS KOZINOS: Yes, that is right.
7 MR GARNHAM: I need to ask you to reply because if you nod
8 it does not go on the transcript.
9 MS KOZINOS: Sorry, yes.
10 MR GARNHAM: I will ask you about that in a moment. Can you
11 go to page 504, which is the end of that.
12 MS KOZINOS: Yes.
13 MR GARNHAM: The first paragraph on that page reads:
14 "This situation is untenable and there appears to be
15 no improvement in sight. This current climate, if not
16 worse, is the mirror image of the working environment
17 when Victoria Climbie died."
18 To what extent was it the mirror image? In all the
19 regards that you mentioned or in some of them?
20 MS KOZINOS: I just need to refer back. It is in regards to
21 the staffing levels, in terms of trying to retain staff,
22 the recruitment and retention of staff and because of
23 that the quality of staff, hence the practice issues.
24 MR GARNHAM: Thank you. So, at least in general terms, in
25 all three of the respects that you deal with in that
42
1 memo you say the situation was the mirror image of the
2 situation that existed when Victoria died?
3 MS KOZINOS: I said actually it is worse than when Victoria
4 died.
5 MR GARNHAM: I want to know that about that then please. In
6 which of those three regards or one of them or more has
7 the situation -- had the situation worsened by the time
8 you wrote this memo?
9 MS KOZINOS: Staff vacancies.
10 MR GARNHAM: Staff vacancies you say had worsened.
11 MS KOZINOS: Much worse. The lack of resources put to the
12 front line.
13 MR GARNHAM: Yes.
14 MS KOZINOS: The high turnover of staff and also the quality
15 of staff, we relied heavily on agency workers and newly
16 qualified staff, which means they were very
17 inexperienced in child protection and the matters we
18 dealt a lot mainly in Duty.
19 MR GARNHAM: And the quality of practice, same, better,
20 worse?
21 MS KOZINOS: Worse, in my opinion.
22 MR GARNHAM: To what extent, then, were there concerns on
23 each of those three headings at the time of Victoria's
24 death? Let us deal with them in turn. At the time of
25 Victoria's death what was the extent of the problem with
43
1 regard to staffing?
2 MS KOZINOS: Again there was a high turnover, due to
3 restructuring, morale was quite low. This obviously had
4 an impact on how in terms of the Team Manager's post in
5 terms of the Practice Manager's post there was a lot of
6 permanent workers that had left and we were trying to
7 recruit into the Duty Investigation and Assessment Team.
8 MR GARNHAM: Were you up to complement, up to establishment?
9 MS KOZINOS: Not that I can remember.
10 MR GARNHAM: Practice, quality of practice?
11 MS KOZINOS: Sorry, what is the question? Was it worse?
12 MR GARNHAM: In what respects -- I think you have told us
13 that you think it is worsened since Victoria died.
14 MS KOZINOS: That is right.
15 MR GARNHAM: In what respects was it the subject of concern
16 when Victoria died?
17 MS KOZINOS: In terms of the vacancies, in terms of the
18 workers, in terms of the agency workers we were getting
19 that were very inexperienced in the front line and newly
20 qualified workers it attracted.
21 MR GARNHAM: What effect did that have on the quality of
22 their work?
23 MS KOZINOS: It meant extra pressure on managers who had to
24 supervise them. It meant a lot of extra training and
25 a lot of additional time had to be put in.
44
1 MR GARNHAM: What effect did all that have on the end
2 product, how they were looking after children?
3 MS KOZINOS: Delays, work having to be duplicated, where
4 workers would go out on assessments and because of their
5 inexperience you would have to send them out again to
6 get further information to complete a full investigation
7 that that an experienced worker would have been able to
8 do from one visit.
9 MR GARNHAM: When they eventually got to do the work, in
10 those circumstances, was it of an adequate quality in
11 your view?
12 MS KOZINOS: It meant extra guidance, it had an additional
13 pressure on the people that had to supervise them.
14 MR GARNHAM: But in the end was the work up to standard?
15 MS KOZINOS: Yes, to a reasonable standard.
16 MR GARNHAM: Thank you. One of the issues this Inquiry has
17 to address is whether agencies have learned lessons from
18 Victoria's case. So let me ask you therefore what the
19 position was at the time you left Haringey.
20 I appreciate you address this in your memo and it is
21 that I want to ask you about. When you left, or in June
22 of this year, what was the problem with regard to
23 staffing?
24 MS KOZINOS: In terms of my problem?
25 MR GARNHAM: Yes, what were your concerns about staffing?
45
1 MS KOZINOS: Again the high vacancy factor. We were not
2 attracting workers into the I&A Team. The quality of
3 work was poor.
4 MR GARNHAM: At that stage what was your job?
5 MS KOZINOS: I was Acting Team Manager.
6 MR GARNHAM: Responsible for how many?
7 MS KOZINOS: For the team, I was responsible for the overall
8 team.
9 MR GARNHAM: How many were in that team?
10 MS KOZINOS: I have to refer, sorry, I left quite a while
11 ago.
12 MR GARNHAM: Who was the next rank down from you, was it
13 Senior Practitioner?
14 MS KOZINOS: Practice managers.
15 MR GARNHAM: How many of them?
16 MS KOZINOS: Three.
17 MR GARNHAM: And how many social workers beneath them?
18 MS KOZINOS: Without referring, 16 roughly, I cannot
19 remember.
20 MR GARNHAM: Roughly 16, thank you. Is that the
21 establishment figure or is that the actual figure?
22 MS KOZINOS: I think that was the actual figure. I need to
23 refer back to my notes.
24 MR GARNHAM: What I am trying to get to understand --
25 MS KOZINOS: There were vacancies.
46
1 MR GARNHAM: How many were you short?
2 MS KOZINOS: I would need to refer back to my memo. I do
3 not know this information off the top of my head.
4 MR GARNHAM: Have a look at your memo.
5 MS KOZINOS: Thank you. It seems nine social workers from
6 16 posts.
7 MR GARNHAM: You take that from the memo?
8 MS KOZINOS: Yes.
9 MR GARNHAM: Because you now cannot remember clearly?
10 MS KOZINOS: No, and I was not expecting to be talking about
11 this today.
12 MR GARNHAM: I do not guarantee you will be expecting to
13 talk about everything I ask you.
14 MS KOZINOS: I know.
15 MR GARNHAM: Were the team able to cope?
16 MS KOZINOS: No, they were struggling.
17 MR GARNHAM: Were they able to cope?
18 MS KOZINOS: It depends what you mean by cope.
19 MR GARNHAM: Were they able to manage the job?
20 MS KOZINOS: I had concerns about some of the workers.
21 MR GARNHAM: You say in the second paragraph on page 502:
22 "The increasing vacancies put added pressures on
23 remaining staff, practice managers and the team
24 managers. It is apparent that the team cannot cope with
25 the volume of work."
47
1 What did you mean by that?
2 MS KOZINOS: Because of the vacancies and the workers were
3 inexperienced it meant the practice managers and myself
4 were actually doing a lot of the work we expected social
5 workers to do, yes, in terms of carrying out our risk
6 assessments, which means our managerial tasks were done
7 and we would often, the majority of time were done in
8 the evening, the majority of paperwork was done at
9 weekends and obviously that had a great impact.
10 Also at the time we were also or I was also involved
11 in this matter, so there was a time taken away from my
12 working duties in terms of the police investigation, the
13 management investigation, and also having to work with
14 the Inquiry.
15 MR GARNHAM: When you say it is apparent that the team
16 cannot cope with the volume of work, that might be read
17 as meaning that you were not doing the work as it came
18 in.
19 MS KOZINOS: No, not at all. We were very busy, we were
20 very stretched, we did not have the resources to manage
21 all that work and it relied very much on the managers at
22 the time to fill in the existing gaps.
23 MR GARNHAM: So what we are to understand you to mean by
24 that expression is that the volume of work and the
25 staffing difficulties you have described meant that
48
1 managers were under greater pressure?
2 MS KOZINOS: Considerably, and so were the workers.
3 MR GARNHAM: People working longer hours?
4 MS KOZINOS: That is right.
5 MR GARNHAM: And work was taking longer to complete?
6 MS KOZINOS: That is right.
7 MR GARNHAM: But you are not saying that work was simply not
8 done?
9 MS KOZINOS: No, it was taking longer.
10 MR GARNHAM: Were you able to provide cover within the Duty
11 Team as a whole? Were you able to cover all the jobs?
12 MS KOZINOS: No, we struggled.
13 MR GARNHAM: Struggling though you were, did you cover it?
14 MS KOZINOS: Yes, the practice managers and myself.
15 MR GARNHAM: How easy was it to recruit staff into the Duty
16 Investigation and Assessment Team at this time?
17 MS KOZINOS: It was incredibly difficult.
18 MR GARNHAM: Why?
19 MS KOZINOS: After the publicity in December Haringey seemed
20 a less attractive option, I suppose, from the outside.
21 Also there was issues in terms of pay. We would lose
22 agency staff to other boroughs who were paying more.
23 The work itself is quite demanding. And it is not
24 something that every social worker would prefer, working
25 in terms of crisis.
49
1 MR GARNHAM: So three reasons for difficulty in recruiting.
2 1 the adverse publicity following the trial of Kouao and
3 Manning, 2 the terms and conditions of employment being
4 offered and 3 the nature of the work in this office.
5 MS KOZINOS: That is right.
6 MR GARNHAM: You quote a manager called Chris Sandercombe at
7 page 503, saying that if managers drifted away the
8 situation will totally collapse.
9 MS KOZINOS: Yes, that is from a memorandum that he wrote
10 to --
11 MR GARNHAM: I understand where you get the quote from. You
12 left shortly after this, you left shortly after writing
13 this memo?
14 MS KOZINOS: That is right, sorry, yes.
15 MR GARNHAM: So you were one of the managers who might be
16 said to have been drifting away?
17 MS KOZINOS: One of a few that had resigned also very
18 shortly after.
19 MR GARNHAM: Before you left had anybody been recruited to
20 take your place?
21 MS KOZINOS: No.
22 MR GARNHAM: So do you know who was to cover your work after
23 you left?
24 MS KOZINOS: No, I have no idea.
25 MR GARNHAM: Again on that page you say that there was very
50
1 little evidence that your concerns had been addressed by
2 the Directorate.
3 MS KOZINOS: That is how it felt to me, yes.
4 MR GARNHAM: What efforts had you made to draw to the
5 Directorate's attention your concerns prior to this
6 memo?
7 MS KOZINOS: We have had a meeting, we have had a meeting
8 with the Assistant Director.
9 MR GARNHAM: When?
10 MS KOZINOS: Sorry, I do not remember.
11 MR GARNHAM: How long before you left? A week, a month,
12 a year?
13 MS KOZINOS: No, it would have been between February
14 and June.
15 MR GARNHAM: Who was the person you had the meeting with?
16 MS KOZINOS: Anne Bristow and the managers at North
17 Tottenham and also with Ann Graham the Assistant
18 Director at the time.
19 MR GARNHAM: Was that meeting minuted? Did anybody take
20 notes of it?
21 MS KOZINOS: I am not sure, I am not 100 per cent sure.
22 MR GARNHAM: Were the concerns you raised in that meeting
23 different from the concerns you raise in this memo?
24 MS KOZINOS: Not much different but it involved the other
25 managers of the Long Term Teams.
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