Independent review

Trowler review into youth custody safeguarding

34 recommendations · government responded 7 Jul 2026

Chaired by Isabelle Trowler · Published 7 Jul 2026 · Commissioned by MoJ

Government response

The government responded to the review on 7 July 2026.

Summary written by Accountability Index from the government's response. It is not the government's own words.

The government says it accepts the principle of all 34 recommendations, with some far-reaching ones needing further scoping and longer-term ambitions "subject to the outcome of the next Spending Review".

  • On counter corruption (recommendations 1 to 3), Heads of Safeguarding will be involved in case management meetings and will inform the LADO of abuse of trust allegations involving children, in place "From September 2026" across all YOIs, the Secure School, the STC and SCHs.
  • On independent inspection of counter corruption practice (recommendation 4), the government notes the HMPPS unit is not a law enforcement body, so HMPPS is reviewing options for "stronger independent assurance and scrutiny arrangements".
  • On looked after status for all children in custody (recommendation 30), the government supports the principle, but says delivery requires consultation with partners and primary legislation "when parliamentary time allows".
  • On professional registration of staff (recommendation 27), the government says it will consider external registration "in the round" and set out its position in the Youth Custody Transformation Plan in the Autumn.

Read the government's response ↗ Report an error

About this review

Summary written by this site
Rapid review of safeguarding in youth custody, carried out by Isabelle Trowler, Chief Social Worker for England, for the Ministry of Justice and published on 7 July 2026.

Recommendations 34

Recommendation 1
HMPPS should ensure that all counter corruption allegations involving children are notified to the LADO in line with the statutory guidance Working Together to Safeguard Children.

Link to recommendation 1

Recommendation 2
HMPPS should ensure that statutory child protection advanced expertise and advice is integral to counter corruption decision-making and planning of their investigations involving harm to a child.

Link to recommendation 2

Recommendation 3
HMPPS should make it a requirement that Governors of the YOIs and the STC should ensure that their counter corruption teams are always included in safeguarding meetings where there is suspected abuse of trust, or other corruption, to assist in planning investigations from their earliest point.

Link to recommendation 3

Recommendation 4
The Ministry of Justice should ensure that there is independent inspection of HMPPS counter corruption practice similar to that undertaken by His Majesty’s Inspectorate of Constabulary and Fire and Rescue Services.

Link to recommendation 4

Recommendation 5
HMPPS should ensure that all YCS sites have ready access to social workers with extensive statutory child protection investigation expertise, routinely involved in triage discussions and decisions with the Head of Safeguarding or Registered Manager, so there is optimum planning for any subsequent investigation. HMPPS contracts for commissioned custody placements should make this a key condition.

Link to recommendation 5

Recommendation 6
HMPPS Heads of Safeguarding should have a social work qualification and solid expertise in statutory child protection investigations. Where that is not the case, they should receive an extensive professional development programme on appointment, focused on child protection practice and, specifically, investigations.

Link to recommendation 6

Recommendation 7
All Heads of Safeguarding should receive frequent external professional supervision from the host Multi Agency Child Protection Team. This should be resourced by the relevant YCS site.

Link to recommendation 7

Recommendation 8
The Department for Education (DfE) should review Working Together to Safeguard Children to ensure that statutory guidance regarding the role and responsibilities of the LADO is clarified for the next edition due in 2027.

Link to recommendation 8

Recommendation 9
Host local authorities and the YCS National Team should introduce case review arrangements, so that referrals and consequent decision-making between YCS sites and the LADOs across England and Wales is moderated, with learning and best practice shared.

Link to recommendation 9

Recommendation 10
HMPPS should ensure there are robust arrangements in place for independent and expert scrutiny of restraint, based on their own guidance on ‘Use of Force, Restraint and Restrictive Practices in the Children and Young People’s Secure Estate’, across all commissioned custody placements and that an overview of system health in relation to restraint is reported to the new YCS Safeguarding Governance Board by the YCS Central Unit Head of Safeguarding every 6 months.

Link to recommendation 10

Recommendation 11
The Department for Education should update Working Together to Safeguard Children in the next edition due in 2027 to clarify expectations for host Local Safeguarding Children’s Partnerships (LSCP) in overseeing the independent review of restraint in youth custody and associated reporting responsibilities. Detailed guidance, including on the knowledge and skills required for those undertaking such reviews, should be developed by the relevant departments.

Link to recommendation 11

12In taking forward the recommendation from Dame Lynne Owen’s report to consider establishing an equivalent body to the Independent Office for Police Conduct in the prisons sector, and the suitability of the Prisons and Probation Ombudsman to undertake this role, HMPPS should specifically set out the applicability and functions of any such body to the youth estate.
HMPPS should reconfigure the management of allegations against HMPPS youth custody staff, ensuring that the principle of independence from the relevant YCS site is applied to all investigations regarding allegations against staff concerning harm to a child which, if proven, could result in dismissal (and, in some cases, referral to the Disclosure and Barring Service). HMPPS contracts for commissioned custody placements should include this expectation.

Link to recommendation 12

13HMPPS should ensure that all outstanding enhanced DBS checks across the YCS workforce are completed without further delay. YCS commissioning arrangements should include a standard expectation that enhanced DBS checks are undertaken every 3 years across all YCS sites.
HMPPS Human Resources should report to the YCS Safeguarding Governance Board, and in turn to the Ministerial Youth Custody Performance Board, at the earliest opportunity and no later than September 2026, to confirm all sites are operating in line with the policy. HMPPS should ensure that arrangements are in place to audit compliance with HMPPS policy on DBS checks, across all YCS sites, including SCHs, the STC and the Secure School.

Link to recommendation 13

Recommendation 14
HMPPS should ensure that that all disciplinary matters are satisfactorily concluded even when the person under investigation resigns during the process, and ensure that where the threshold is met, referrals are made to DBS with sufficient evidence to secure inclusion on the barring list.

Link to recommendation 14

Recommendation 15
The Home Office should work with the Disclosure and Barring Service to consider together the introduction of outcome notifications and appeal rights for employers, as well as the provision of external scrutiny of DBS decision-making, from which all partners can learn and develop their understanding of safeguarding practice and suitability to work with children.

Link to recommendation 15

Recommendation 16
HMPPS should review the YCS National Unit to identify its key functions and to ensure it has sufficient resources and the skill necessary to deliver at pace and to quality. This includes day-to-day operations and additional resource to successfully implement any major new change programmes.

Link to recommendation 16

Recommendation 17
A comprehensive central record of all allegations against staff concerning harm to a child should be maintained by the YCS National Unit so that patterns of concern can be readily recognised and acted upon.

Link to recommendation 17

Recommendation 18
A regular audit of allegations against staff concerning harm to a child, including those resulting in no further action and those referred out to host authorities, should be conducted by the YCS National Unit across all youth custody sites to provide a check and balance on decision-making. This should be done in partnership with the host local authority.

Link to recommendation 18

Recommendation 19
The YCS National Unit should establish a formal process for learning from serious incidents and high-profile events with effective mechanisms for learning embedded across all YCS sites.

Link to recommendation 19

Recommendation 20
The proposed new YCS Safeguarding Governance Board should be established with sufficient resource as soon as possible to oversee the development of new systems for data collection, analysis, and audit activity to ensure safeguarding arrangements are working well. It should report to the Ministerial Youth Custody Performance Board at least quarterly.

Link to recommendation 20

Recommendation 21
The Ministerial Youth Custody Performance Board, in addition to its existing brief, should routinely seek assurance from the YCS Safeguarding Governance Board about the quality of decision-making regarding allegations against staff concerning harm to a child, safer recruitment & vetting, DBS referrals and renewals, and local authority and YOT compliance with statutory duties, to ensure strategic oversight of safeguarding the welfare of children in custody.

Link to recommendation 21

22HMPPS should introduce a single National Practice Framework for Youth Custody which clearly sets out the core purpose of youth custody, key principles of practice, core outcomes to be achieved for children in custody, key enablers necessary to achieve those outcomes including specific knowledge and skills for all grades, the evidence underpinning preferred practice methodology, and clarity about the expectations of practitioners and leaders.
HMPPS should ensure that this National Framework forms the core of all performance and contract monitoring, the basis for induction and professional development, and the design of support to staff.

Link to recommendation 22

Recommendation 23
HMPPS should develop a knowledge and skills framework underpinned by evidence-based methodology, and an aligned curriculum and assessment methodology which includes a comprehensive focus on knowledge of child development, enduring relationships with family and community, the impact of trauma on behaviour, skills for building trusted relationships, positive behaviour management, restraint as last resort and effective resettlement.

Link to recommendation 23

Recommendation 24
HMPPS should introduce a second stage recruitment and redeployment process to ensure suitability and aptitude for working with vulnerable children in youth custody.

Link to recommendation 24

Recommendation 25
HMPPS should introduce a supported management and leadership pathway for those without a prisons background to form an expanded pool of talent for future YOI Governor and other management roles.

Link to recommendation 25

Recommendation 26
HMPPS should work with YOI Governors to identify policies that do not sufficiently address key differences when working with children and ensure these are amended in line with children’s best interests. Priority attention should be given to those covering performance management and disciplinary action.

Link to recommendation 26

Recommendation 27
HMPPS should work towards introducing professional registration for YCS staff by an independent body in line with the IICSA recommendation.

Link to recommendation 27

Recommendation 28
HMPPS complaints framework should be amended to allow trusted adults to raise formal complaints on behalf of children, with their full involvement at every stage. Commissioned custody placements should be contracted on the basis that similar arrangements are in place.

Link to recommendation 28

Recommendation 29
HMPPS should ensure that induction materials and processes across all YCS settings should be reviewed and redesigned to be accessible to children with low literacy levels, neurodiverse needs, and communication differences. Information about rights, complaints, and safeguarding should be reinforced through regular touchpoints throughout a child's placement.

Link to recommendation 29

Recommendation 30
To maximise opportunities for safeguarding in custody, the facilitation and strengthening of family relationships and resettlement plans, all children in youth custody should be considered “looked after” by the home local authority.

Link to recommendation 30

Recommendation 31
Independent routine safeguarding enquiry should be introduced as a structured, routine, sensitive, private enquiry undertaken by the home local authority social worker as a distinct part of their duties towards children looked after by virtue of their custodial sentence.

Link to recommendation 31

32HMPPS should establish systems to track when children are visited, by whom and whether this is in line with statutory expectations of the home local authority. Reasons for visits not taking place should also be recorded.
HMPPS should establish the key barriers to scheduled visits going ahead as planned and resolve systemic causes in particular sites and across the secure estate.

Link to recommendation 32

Recommendation 33
The Ministry of Justice should introduce a new statutory notification system where local authorities and Youth Justice Services are not meeting their statutory duties to visit children. These notifications should be sent to the local authority and the Youth Justice Service for urgent action, and to HMIP and Ofsted for consideration in their respective inspections.

Link to recommendation 33

Recommendation 34
HMPPS should fund a dedicated service to help rebuild and repair fractured family relationships for all children in custody where this is not already being undertaken by the home local authority as an excellent and leading example of corporate parenting responsibilities as defined in the new Children and Wellbeing Act 2026.

Link to recommendation 34

All text above is the review's.