The Rehabilitation of Offenders Act

 

 was passed in 1974.

It was reviewed in 2002.

It does not work.

No action has been taken by HMG to make it work.

This failure actively discourages reform and rehabilitation.

Action is required Now.

 

Click Here To read the full Review Report “Breaking the Circle”

 

Click here to contact the author

The self same moment I could pray;

And from my neck so free

The Albatross fell off my neck., and sank

Like lead into the sea.

 

Review of the Rehabilitation of Offenders Act (1974) (the ROA)

 

The Existing Law and Situation

 

The ROA was passed in 1974 and is still in force.  Its principal purpose is set out in Section 4. – (1) of the Act and states:

 

“… a person who has become a rehabilitated person for the purposes of this Act in respect of a conviction shall be treated for all purposes in law as a person who has not committed or been charged with or prosecuted for or convicted of or sentenced for the offence or offences which were the subject of that conviction; and notwithstanding the provisions of any other enactment or rule to the contrary, but subject to the aforesaid”

 

The ROA Section 9 states that:

 

“Any person guilty of an offence under subsection (4) above shall be liable on summary conviction to a fine not exceeding £400 or to imprisonment for a term not exceeding six months, or both.

 

This means that any one who keeps the official criminal records commits a criminal offence if he or she discloses details of those offences to anyone, except the offender, if those offences are “Spent”.

 

The Police and Courts may keep and use all criminal records indefinitely provided they are used exclusively for police investigations or to inform a judge or magistrate after conviction of a subsequent offence.

 

Keepers of UK criminal records may not divulge details of Spent sentences anyone at all,  be they: employers, foreign police forces, immigration authorities, or issuers of visas and work permits.  This has been recently confirmed by the Home Office Minister, Baroness Scotland who said on 12 Jan 06: “It will therefore, with very limited exceptions, remain an offence to disclose details of spent convictions and this provision will continue to apply equally to information held by immigration officials.”[1]

 

Not everyone can earn a Spent sentence.  It is restricted to those sentenced to 30 months in prison or less. In 1975 an Order called the ROA (1974) (Exceptions) Order 1975 was issued.  This listed “relevant offences” against certain professions and occupations which, to certain extent, were excepted from the provisions of the ROA.  The object being to allow disclosure of relevant Spent sentences for employment with vulnerable people, positions of special trust and national security.  Over time this list has been added to extensively and now even includes traffic wardens.  However these exceptions are not absolute; to be excepted the offence has to be relevant to the profession, office, employment, occupation, license, certificate or permit.

 

The ROA defines the periods it takes to Spend a sentence.  These vary according to the sentences and the age of the offender.  Expenditure starts from the date of conviction and not the date of sentence or release from prison or the end of the sentence.  The most common period is 10 years.  If the person is convicted of any offence during this period, then he or she has to start again.

 

Spent sentences can only be obtained by those sentenced to 2 ½  years or less provided  they commit no offences for 10 years after date of conviction, and thus demonstrate that they have reformed.

 

At this point it is worth pointing out that the ROA uses, in my opinion, the word “rehabilitation” incorrectly.  Reform is the process by which a person decides not to commit further offences. Rehabilitation is the process by which a reformed person is assisted to re-enter society as a law-abiding person. Reform always precedes rehabilitation and in most cases is something that need not happen at all, because the offender is not really a bad person at all; he or she just did a “bad thing” once.

 

It can be seen that the whole purpose of the ROA is to give a reformed person “a clean sheet” so that he or she can then rehabilitate themselves.  This takes the form of an extract of the person’s criminal record and is called a Disclosure.  There are three grades: Enhanced, Standard and Basic.

 

  • An Enhanced Disclosure is required by employers who need to know if the applicant has committed a crime relevant to certain employment, usually involving children or vulnerable people, e.g. a school needs to know if the applicant has a conviction for an offence against children.  Enhanced Disclosures will reveal relevant Spent sentences.

 

  • A Standard Disclosure is required when the job involves special trust and these disclosures will reveal relevant Spent sentences, e.g.: fraud

 

  • A Basic Disclosure conceals all Spent sentences.  The biggest demand is for Basic Disclosures.

 

It is against the law for third parties to be given Disclosures.  However the ROA has never really worked properly because successive governments have failed to provide a system which will produce Disclosures on demand to the individual that meet the requirements of concealment of Spent sentences.

 

Individuals can apply to their local police for a “Subject Access Request”.  This provides them with a complete extract of their record, taken from Police Records. The police can, under Police Rule 5.4,[2] weed their records, but they are not allowed to weed any custodial sentence exceeding six months or any convictions for drugs, violence or of a sexual nature or any offences against the vulnerable. So the Police Records do, in the main, always include Spent sentences and never constitute a “clean sheet”. They are useless for anyone who needs a Disclosure and has a record.  More than one quarter of the working population of the UK does have a criminal record.[3]

 

In March 2002 the government set up an agency in Liverpool called the Criminal Records Bureau (CRB) which serves England and Wales.  There is a similar one for Scotland.  So far this agency is tasked with providing Enhanced and Standard Disclosures to UK employers. An unreasonable number of jobs now require Enhanced and Standard Disclosures, because the Excepted list is so long.  The CRB can barely cope with this load.  It has never worked efficiently and very long delays and frequent errors are made.

 

Crucially the English and Welsh CRB has never been tasked with producing Basic Disclosures, which are the clean sheets that most ex offenders need, deserve and are entitled to have under the law.  This is a very grave failing.  About 93,000 people are released from prison each year.  Of these it is estimated that that about  38% reform and are entitled to Spend their sentences.  This means that every 10 years 372,000 ex-prisoners and many more who have not suffered custodial sentences cannot obtain their clean sheets and are being hindered from becoming rehabilitated, because the government is failing under its duty in law. 

 

The Government admitted in March this year that the launch of the CRB’s Basic Disclosure service was initially postponed due to concerns over the impact of the Standard and Enhanced Disclosure service, but that a feasibility study is currently being undertaken into its launch.[4].

 

It is scarcely surprising that, after a continuing delay of 32 years, recidivism rates are so high and that on 24 March 2006 there were 77,004 people in prison, which are 2,603 more than the year before.[5]

 

The Reform of the ROA – Breaking the Circle (BtC)

 

In 2000 the Home Office commissioned a review of the ROA, because it was realised that it was not helping the reformed to rehabilitate themselves.  A wide-ranging investigation by experts, including public consultation, was conducted over two years and their report “Breaking the Circle” (BtC) was published on 17 July 2002.  All the recommendations were accepted by the Government in April 2003.  These called for a radical reform of the ROA and an improvement in the delivery of Disclosures.  .  Baroness Scotland, the Home Office Minister explained on 5 Dec 05[6] that delays may have been influenced by the Bichard Reports recommendations, which arose after the Soham murders, but that “The situation remains that the Government accepts the majority of the review’s recommendation.”

 

However, the fact remains that four years later nothing has been done to bring these recommendations into force by amendment of the ROA.

 

The BtC observed, inter alia, that:

 

  • Over a quarter of the working-age population has a previous conviction.
  • The annual cost of crime is [was then] £60 billion.
  • Employment can reduce re-offending by between a third and a half.
  • A criminal record can seriously diminish employment opportunities.

 

The main changes to the ROA by the BtC changes are:

 

  • Certain posts etc should continue to be excepted from the disclosure scheme: vulnerable people, national security and posts of particular trust [but not others].

 

  • The requirement to disclose, [and therefore conceal spent sentences] should be explained as part of the sentence.

 

  • Employers should be encouraged to develop a code of practice to govern the informed use of disclosures during recruitment processes and should be sanctioned [prosecuted] if they failed to comply [broke the law].

 

  • The disclosure scheme should be on fixed periods based on sentence with different period for non-custodial sentences.

 

  • These periods should comprise the length of sentence plus a buffer period of two years (less or zero for young offenders, minor offences, cautions etc).

 

  • The scheme should apply to all offenders, not just those with sentences of 30 months or less.

 

  • The changes should be retrospective and enacted without delay.

 

Note:  This is a very brief summary.  This is easily misunderstood.  It is very important that the detail and implications be read an understood by reading the entire  95 page report.[7]

 

 

One important finding was that the longer a person is sentenced the more likely he is to reform  People with short sentences of say 6 months or a year, are much more likely to re-offend than those with longer sentences.  This led to the fundamental recommendation that all those who reform should be allowed to achieve a Spent sentence and not just those with sentences of 30 months or less.

 

The huge change that this excellent report envisages is that every offender, except those who commit offences against vulnerable people, state security and particular  positions of trust,  can Spend his or her sentence and then obtain promptly, as of right  a “Clean Sheet” which conceals Spent sentences.  This expenditure is, usually achieved by adding the “buffer period” of two years of the sentence. During this entire period the person must not re-offend.

 

 Some  imagined examples might be:

 

  • Thief -  sentenced 2 ½  years  -  Released from prison after 15 months. Sentence ends after 30 months. Sentence Spent after 4 ½ years.

 

  • Murderer -  sentenced to Life Imprisonment – Released from prison after 8 years.  Sentence ends on death. Sentence Spent  two years after death.

 

  • Dog fouling owner -  cautioned. No penal imposition.  Sentence Spent immediately.

 

  • Paedophile sentenced for assaulting a child.  Sentenced to 10 years in prison.  Released after 5 years.  Sentence Spent after 12 years, but never for any relevant Excepted profession or Purpose.

 

  • 20 year old student,  who has shared [supplied]  his drug only with adult friends -  sentenced to 18 months in prison – released after 9 months – sentence Spent after 3 ½  years.  Applies for a job as a primary school teacher and obtains an Enhanced Disclosure which does conceal his sentence, because his crime was not relevant to the employment.

 

 

The following two examples are problematic, but reveal the complexities of the ROA and the reforms.  The questions and answers are of supreme and fundamental importance and may need testing in court:

 

  • Man commits terror offence against NATO base on UK soil.  Sentenced to 8 years.  Released after 4 years.  Sentence Spent after 6 years.  Then applies for Working Visa in USA.  USA authorities apply for an enhanced disclosure.  Request refused (disclosures can never be given to third parties).  He then applies for a Disclosure.  Enhanced Disclosure given to him which does reveal his sentence because the offence involved the National security of the UK, which is in NATO.

 

  • Man convicted of supply heroin (to adults) in London.  Sentenced to 4 years in prison.  Released after 2 years.  Sentence spent after 6 years.  Applies for working Visa in USA for which the US authorities demand an Enhanced Disclosure.  Issued with an Enhanced Disclosure which conceals his offence because the requirements of the US authorities, whatever they may be, are not relevant to his UK offence.

 

 

 

Other Reforms and Administrative Measures

 

A long time has passed since July 2002 and even more since 1974.  Much has changed and  BtC  had no remit, or did not envisage, other very important aspects.

 

With the increasing fear of child abuse, terrorism and other ‘high-profile’ offences, employers offering the most run-of-the-mill jobs and nearly all foreign immigration authorities are now demanding disclosures as a matter of course.  As a result a whole spectrum of Agencies has sprung up whose job it is to obtain these documents on behalf of the employers.  Even the CRB will not issue Disclosures to individuals; individuals have to apply through, and pay fees to, these agencies, who work for the employers and others that are seeking the information.  This acts against the interests of the individual even though he must pay the CRB’s fees.

 

In the vast majority of cases these agencies obtain Subject Access Requests from the police for ordinary jobs.  These are complete extracts of the Police Criminal records and will be blank if no crime has ever been committed.  But if any offence has ever been committed, including Spent sentences, they will appear.  This is fine if the person applies himself, but if the agency applies, both agency and the police have probably unwittingly conspired to break the criminal law.  This is being done all the time at the moment because no authority is capable of issuing Basic Disclosures.  No one has yet been prosecuted. 

 

The increasing use of data on IT systems means that either direct or indirect access is possible to many officials.  There is a very real danger that criminal record data might be easily accessible by employers or, even worse, by foreign police or immigration authorities, because of some agreement, regulation or treaty that somehow assumes it by-passes the ROA.  There is a particular risk with the National ID card, which although it may not contain direct access to the criminal records, could easily enable any official, with suitable access, to do so.  This is completely illegal because no new law or regulation may supersede the ROA, which is quite specific on this point when says: “notwithstanding the provisions of any other enactment or rule to the contrary[8]

 

It is completely unacceptable that the CRB cannot issue Basic Disclosures promptly on demand to individuals.  It is a national disgrace that this fundamental right has never been achieved in 32 years, even though that was the primary purpose of this law.  This aspect is only assumed and implied in the BtC.  It is the most important administrative measure that must be achieved immediately,  because it possibly adversely affects, as the summary of the BtC says, one quarter of the working population of this country or 15 million people.

 

Some effort has been made to encourage employers to employ ex-offenders and to educate them about rehabilitation, such as the Corporate Alliance for Reducing Re-offending, sponsored by the National Offenders Management Service (NOMs). Charities such as NACRO also exist to help ex-offenders.  However the fact remains that most employers tend to use low grade administrators who tend to weed out any one with a “black mark” at the initial stage.  Overwhelming “Daily Mail” prejudice is deeply rooted in the public conscience.  There is a pressing need for protection under the law.

 

 

 

 

 

Conclusions

 

  • All these reforms are achievable.  HMG has approved them and few, but the ill informed, will oppose them.

 

  • There is no good reason to delay reform.  The Bichard report is irrelevant, because the people affected are already Excepted.

 

  • The reforms only benefit those who have really reformed.  It protects the vulnerable, our national security and those people and institutions which we must trust.

 

  • The reforms enable people, who have reformed, to rehabilitate themselves.  It  improves both their lot and society as a whole.

 

  • Reforms will reduce the unacceptable und unaffordable prison population.

 

  • Reforms will protect the human rights and freedoms of all individuals.

 

Recommendations

 

  1. That MPs press for the reform of the ROA as set out in the BtC.

 

  1. That Basic Disclosures be made available on demand to all individuals.

 

  1. That the illegal disclosure of police and criminal records to agencies and other third parties be investigated stopped, and, where appropriate, prosecuted as the current Law requires.

 

 



[1] Letter to Jeremy Browne, MP dated 12 Jan 2005

[2] Chief Constable Manchester letter 25 Oct 05

[3]  Breaking the Circle 2002

[4]  Andy Burnham, MP PUS Home Office letter to Jeremy Browne dated 27 Mar 06

[5] Bromley Briefings April 2006 – overview.

[6] Letter to Jeremy Browne dated 5 Dec 05

[7]  Home office Breaking the Circle, July 2002

[8] ROA Section 4. (1)