Introduction
Child protection is everybody’s business. However, until very recently Irish law and policy lacked clear guidelines and obligations to report instances of harm and abuse concerning children. Mandatory reporting, enacted under the Children First Act 2015, is one such recent development. It provides that specific, scheduled, ‘Mandated Persons’ shall report concerns of harm to children to the State child protection services, Tusla (The Child and Family Agency). This paper examines the current standing and operation of mandatory reporting in Ireland. A recent court decision pertaining to the interpretation of the operation of these reporting obligations in circumstances where adult disclosures of childhood experiences are received by Mandated Persons, has further ignited debates around what must be reported. The paper takes a particular focus on this court decision and its impact on understanding current legislative and policy contexts, and the influence these may have on adult victims and survivors’ retrospective disclosures of childhood sexual abuse. A retrospective disclosure is a disclosure made by an adult of abuse they experienced as a child. The paper does not specifically focus on the process of assessment of such reports and aims to synopsise the current legal and policy development in this area, in the context of the development of reporting obligations in Ireland.
Mandated Reporting: A brief origin story
Mandatory reporting, as we now know it internationally, had its origins in a study by Kempe, Silverman, Steele, Droegemueller and Silver in the United States in 1962 (Kempe et al., 1962). The study focussed on 302 children in 71 hospitals who were shown to have been intentionally injured by their parents. The study led to the concept of ‘battered child syndrome’ and prompted the federal government in the United States to sponsor a conference aimed at tackling the challenges posed by child abuse. This conference featured the presentation of proposals for mandatory reporting laws in relation to child abuse and, as a consequence, the first Mandatory Reporting laws were introduced in the US in 1963 (Hutchinson, 1993). By 1967, all fifty states in the US had adopted mandatory reporting legislation and, in the ten years following this, every region in Canada and Australia, with the exception of Western Australia, had also adopted versions of mandatory reporting into their laws.
We say ‘versions’ here as while the underlying principles were shared, the manner in which mandatory reporting was adopted in each jurisdiction, and in some instances in each State, varied. The legislation across these jurisdictions in general contained provisions dealing with the category of person required to report and the type of abuse which would trigger a reporting obligation. The original US legislation limited the obligation to requiring medical professionals to report instances of physical abuse inflicted by a parent or caregiver (Matthews and Kenny, 2008). This was subsequently amended to various degrees in different jurisdictions with both the type of the abuse attracting a report, and the category of reporter, expanding. Some jurisdictions, for example, require all members of the public to report concerns where they have a reasonable suspicion or, in some cases, a belief that abuse or neglect has occurred.
A potential concern in relation to mandatory reporting is that specifying certain forms of abuse that must be reported, automatically delineates certain forms of harm that do not need to be reported. A case in point is psychological harm, also sometimes known as emotional abuse, which due to difficulties in detection and definition, does not lend itself easily to legislative provision. This, however, does not and should not take away from the serious effects it may have on a child and should not hinder the seeking of services on that child’s behalf (Matthews and Kenny, 2008). It should also be remembered that emotional harm cannot be neatly disaggregated from other forms of harm and abuse.
Finally, legislation in this area generally provides for some form of punishment in the case where no report is made. However, this is usually framed in such a way as to encourage reporting of child abuse and neglect and not to specifically penalise individuals who have not reported. In most jurisdictions, in fact, the legislation either includes or is paired with another piece of legislation that provides for immunity from suit for a reporter in specific circumstances. In Ireland, the Protection of Persons Reporting Abuse Act 1998 pre-dated the commencement of mandatory reporting laws, which were commenced much later in 2017.
The law surrounding the protection of children in Ireland has developed considerably in the last decade. From April 2012, the Oireachtas began unveiling a ‘suite of legislation’, essentially consisting of three different pieces of legislation aimed at copper-fastening child protection in Ireland. These laws were the culmination of a series of inquiries, scandals and tragedies all of which appeared to lay blame at the same two key downfalls in our society. Firstly, inter-agency cooperation is regarded as a critical necessity in an efficient child protection system, it is “vital to the …effective protection of children at immediate risk of harm” (Kilkelly, 2008, p291). The concern was that inter-agency cooperation needed to be improved, and this was as valid in 2012 as it was some 20 years prior when it was first cited as a concern in the Kilkenny Incest Investigation (McGuinness, 1993; RTÉ, 2017). The second, and perhaps more troubling contributing factor to the culture of abuse that was permitted to prevail for so many years, was the utter failure of so many adults to report relevant information when a child was in danger. A culture of silence and unaccountability permitted the continued suffering of the most vulnerable in our society (Holohan, 2011; Conroy, 2017).
Mandatory Reporting in Ireland: A chronology of policy and legal developments
Ireland did not begin its debates on mandatory reporting as early as our colleagues in the United States, however the country was by no means immune from abuses and adversity. The Kilkenny Incest Inquiry Report, delivered in May 1993, was one of the first formal calls for a scheme of mandated reporting in Ireland (McGuinness, 1993, p99-101). The inquiry examined abuse and neglect in a familial setting spanning several years, and specifically the failures in communication and collaboration between State agencies and functions. In that report, Catherine McGuinness, then a Senior Counsel, called for the inclusion of “doctors, nurses, social workers, psychologists, community welfare officers, childcare workers, teachers, probation officers and other professionals responsible for the care of children” (p100) in such a scheme. Shortly after the Kilkenny Inquiry, in 1999, the Children First national guidelines for the protection of children, were published by the Department of Health and Children (1999). These guidelines highlighted a broad duty on those engaged with children to report concerns related to abuse or harm, albeit not supported by legislation. This was also the first national policy to recognise adult retrospective disclosure of abuse and to include them as matters which fall under the remit of the State child protection services (at the time the role of the Health Boards and currently Tusla).
While this paper deals with the development of our current scheme of mandated reporting in Ireland, it would be remiss not to note that other reporting obligations, and legislative protections, are in existence that pre-date the Children First Act 2015 and the later commencement of mandatory reporting in December 2017. The Criminal Justice Withholding of Information Against Children and Vulnerable Adults Act 2012 obliges any person to report information related to a scheduled crime against a child or vulnerable adult to An Garda Sίochána. The impact of this Act is much more extensive than people realise. While professionals working with children are specifically tasked with reporting concerns pursuant to other legislation, here the Act does not provide any such limits or specifics. The Act applies to all persons who fail to disclose information about a scheduled offence to An Garda Sίochána, not just a person who occupies a position of authority or is a mandated professional. It is also worth noting that in terms of section 14(12) of the Children First Act, the obligation to disclose to An Garda Sίochána is in addition to, and not in substitution for, any other obligation to disclose. Thus, a mandated person might be required to report concerns of harm to State child protection agencies and then also be obliged report the same incident, where it amounts to information about a scheduled offence, to An Garda Sίochána. In that instance, failure to make two separate reports to two State agents, would amount to a breach of one or other of the legal requirements.
Likewise, the offence of reckless endangerment, under section 176 of the Criminal Justice Act 2006, creates an offence whereby anyone who, having authority or control over a child or abuser, intentionally or recklessly places a child in a situation that creates a substantial risk of their becoming a victim of serious physical harm or sexual abuse. The offence also applies where a person in authority intentionally or recklessly fails to take reasonable steps to protect a child from such risk, knowing that the child is in such a situation. A person found guilty of the offence of reckless endangerment is liable on conviction on indictment, to a fine or to imprisonment for a term not exceeding 10 years or both. Finally, the Protections for Persons Reporting Child Abuse Act 1998 provides a defence for persons reporting to the relevant civil authorities their opinion that a child is at risk, unless it is proved that they have not acted reasonably and in good faith.
While mandatory reporting had been flagged as far back as the early 1990s, the debate had developed a certain inertia. The allegations of clerical sexual abuse outlined in the Cloyne report in 2010 were important in reigniting these debates, for two reasons. Firstly, the majority of the allegations related to reports made after the commencement of Children First National Guidelines in 1999, after national reporting obligations had been rolled out. Secondly, in the case of some of the allegations, information had been shared between clergy in the confessional. The main opposition by the church at the time was whether or not mandated reporting would seek to breach the confessional (McDonald, 2011). These debates led to public outrage and the State’s first full Minister for Children, Francis Fitzgerald (a former social worker) signalling a commitment to pursue the legislative implementation of mandated reporting in Ireland.
The initial steps included a revision of the Children First National Guidelines and the insertion of a new opening preamble that stipulated that the policy now applied to all persons; a civic duty to report (Department of Children and Youth Affairs, 2011, p2). The revision came alongside the specific commitment to place a version of these reporting obligations on a statutory footing and, with this, the preparations for the Children First Bill and a national scheme of mandated reporting began. The Children First: National Guidance for the Protection and Welfare of Children 2017 is now the third iteration of these guidelines and they were published alongside a suite of resources for mandated professionals. The new guidelines include guidance on how to report concerns of abuse and neglect, and emphasise inter-agency cooperation between State agencies. Disclosures by adults remain within the current remit of Tusla under these most recent guidelines (Department of Children and Youth Affairs, 2017, p23). Mandated reports currently account for 34% of all referrals to the Child and Family Agency (Q1 2024; Child and Family Agency, 2024, p14).
The Children First Act 2015
The Children First Act 2015 was much lauded as heralding an era where the statutory responsibility for children who required protection would now spread beyond state agencies, by obliging certain mandated professionals to report concerns of harm. Notably, the initial draft of the Bill had contained criminal sanctions for failing to report a concern or allegation of abuse to the state agency. Where a concern was brought to the attention of such a mandated professional, while in the course of their employment, and without a reasonable excuse the professional failed to make a report, that person could be found guilty of a crime. However these criminal sanctions did not survive the enactment of the law and instead, sanctions for non-compliance arise more in terms of professional sanctions, employment issues and potentially consequences arising within Garda vetting.
The threshold for reporting concerns is higher for those scheduled mandated professionals than the more general obligations laid down in the Children First National Guidelines. The threshold is specifically set out in section 14(1) which provides that mandatory reporting is required:
“where a mandated person knows, believes or has reasonable grounds to suspect, on the basis of information that he or she has received, acquired or becomes aware of in the course of his or her employment or profession as such a mandated person that a child has been harmed, is being harmed or is at risk of being harmed he or she shall, as soon as practicable, report that knowledge, belief or suspicion to the Agency- being the Child and Family Agency”.
Harm is defined in the Act as assault, ill-treatment, neglect of a child in a manner that seriously affects or is likely to seriously affect the child’s health, development or welfare, or the sexual abuse of a child. Section 14(8) further requires certain named professionals to complete a standardised and comprehensive referral form which comprises part of an initial assessment. The process requires mandated professionals to describe their concerns in accordance with the level of risk to the child. However, this leaves professionals somewhat adrift when attempting to discern the applicable risk levels where a risk of harm to a child might be swayed by the historic nature of a disclosure, by the unknown status of the potential abuser, and by the lack of clarity around reporting obligations. This tension is further heightened where an adult does not consent to a report being made to Tusla; highlighting the level of complexity that arises where professionals attempt to navigate the legal obligations arising from retrospective disclosures of childhood abuse.
Adult Disclosures and Mandated Reporting: Impossible Tensions
Mandatory reporting, as implemented in Ireland, has had a specific impact on adults who have experienced abuse in childhood. Under the Children First National Guidelines 1999, adult retrospective disclosures of abuse were first recognised as matters which fall under the remit of the child protection services. ‘This places adults, sometimes in the later years of their lives, in the position of referring abuse to a system designed to engage with and protect children’ (Mooney, 2018, p247). The rationale, as outlined in the policy, related to the potential risk that may be posed by any perpetrator identified in such allegations. When mandatory reporting was enacted such disclosures were therefore drawn into the pool of ‘relevant information’ that was subjected to reporting requirements. This is activated, for example, when an adult who had experienced abuse as a child engages with a counsellor or psychotherapist for help and support. In circumstances where professionals are scheduled as mandated reporters under the Act, a legal duty is therefore triggered.
Given the often sensitive nature of the therapeutic relationship, especially for those impacted by child sexual abuse, concerns have been raised regarding the potential harm this process can cause to such adults (Schwab-Reese et al., 2023; O’Moráin, 2024). Some have raised the concern that many individuals may forgo seeking help in order to avoid mandated reporting. For example, Pellegrini et al. (2022) evidenced these concerns in respect of psychologists’ interactions with mandated reporting. That study aimed to gather Irish psychologists’ experiences as mandated reporters under the Children First Act. Via three focus groups across 18 participants, they found that psychologists believed adults engaged in a process of ‘self-policing’ (p11) to avoid revealing or discussing content that could result in a reporting obligation. They suggest a worrying reality that “As clients became aware of the limits of confidentiality many chose to disengage from therapy altogether” (p11). Similar concerns about the impact on professional relationships have been raised in respect of the teaching profession also (Bourke and Maunsell, 2015; Nohilly and Treacy 2022)
Previous research in this area by Mooney (2021a; 2021b) has shown that adults’ experiences of engaging with child protection services regarding their disclosures of childhood sexual abuse can lead to risks of re-traumatisation, confusion, and distress. These studies highlighted that the system itself can act as a barrier for those wishing to come forward (2021a), and more specifically that some adults were not advised that their personal data, and specifically details of their disclosure, would be shared; or information about with whom their information would be shared (2021b; see also Data Protection Commission, 2020). Mooney (2021b) has stated that “We need to avoid what appears to be a slow drift towards treating adults who come forward to make retrospective disclosures of childhood abuse as mere suppliers of information” (2021b, p41).
Furthermore, Mooney (2023) in a critical analysis of this process, that takes place once an adult engages with child protection services, highlighted some of the possible reasons for this reticence on the part of those adults coming forward. Using the analogy of Michél Foucault’s ‘confessional’, Mooney compared the current system to a form of ‘harvesting’, whereby adult disclosures are gathered via a system of mandated reporting, processed via the child protection system, to determine the presence of evidence of any risk to current or future children, and taking any required actions on this basis. Thus, the disclosing adult is left as secondary to this process, which is in stark contrast with the ethos of trauma-informed practices. To date, mandatory reporting has acted as a catapult system, propelling adults who disclose their childhood experiences towards the child protection system; complicating the underpinning ethos of mandated reporting.
Legal Developments
Recent legal developments have thrown into question the issue of when a retrospective disclosure of abuse ought to be disclosed to the Authorities by a counsellor and in what circumstances (Daly, 2024; O’Moráín, 2024). This issue has particular importance where the adult making the disclosure may not consent to any onward sharing of this information. A recent Court of Appeal decision provides much needed clarity to professionals working with adults who may make disclosures of childhood abuse, particularly in the medical and psychology services.
In McGrath-v-HSE, the Appellant (a director of a counselling service) and the Respondent (the HSE) were in disagreement as to the scope of section 14(1)(a) of the Children First Act. The Appellant contended that the word ‘child’, as used within that section, refers only to a person who is a ‘child’ as defined in the Act, at the time that the mandated person referred to in section 14(1) receives, acquires, or becomes aware of the information referred to in that section. The Respondent argued that the statutory definition of child should be properly construed within the context of the statute as a whole and within the objectives of the legislation: that the word ‘child’ includes any person who has been harmed when a child, even though that person may now be an adult. This disagreement between the parties as to the scope of section 14(1)(a) came to a head following the publication by the respondent (the HSE), on 14 November 2019, of a document entitled HSE Child Protection and Welfare Policy. Following issues arising from this, a further clarifying document – an interim standard operating procedure (the SOP) – was circulated by the respondent in 2021.
The Applicant sought leave to issue judicial review proceedings seeking an order of certiorari quashing both the policy and the 2021 interim operating procedure. In 2022, the High Court had held that section 14(1)(a) of the Act required mandated persons to notify the Child and Family Agency (Tusla) where an adult disclosed retrospective harm suffered as a child, where that harm reached the threshold as set down in section 2 of the 2015 Act. The court also provided that section 14(1)(a) did not require the consent of the person disclosing this harm, prior to making the notification to Tusla. Instead, the mandated person had an obligation to ensure that the person was informed of the counsellor’s mandatory reporting obligations, including the limitations on the counsellor’s duty of confidentiality. This judicial interpretation of the Act meant that a report must be sent to Tusla even where the client is now an adult, where there is no information relating to the current risk of harm to a child, and where the alleged perpetrator is not identifiable or even deceased. The High Court had determined a mandatory reporting obligation was created under s.14(1)(a) Children First Act 2015 (the Act) in respect of disclosures made by adults of their own childhood experiences of abuse. This interpretation informed HSE Policy as regards mandatory reporting of retrospective disclosures of abuse to Tusla. Ultimately, the High Court finding was appealed to the Court of Appeal in 2024, and the result was a more practical and equitable resolution.
The Court of Appeal held that the High Court fell into error in failing to place sufficient emphasis on the statutory definition of ‘child’, and also its interpretation in concluding that the use of the past tense in section 14(1)(a) indicated an intention to include those who had suffered harm in the past, but who had since passed into adulthood. The court held that there is no ambiguity about who is a ‘child’: it refers only to a person who, at the time that the mandated person receives or acquires or becomes aware of the information referred to in the section, is a child as defined in the 1991 act and cannot, in any circumstances, include persons over the age of 18 years.
It was further held that the trial judge “fell into error” in concluding that section 14(1)(a) requires mandated persons to notify the Child and Family Agency where an adult discloses past harm suffered as a child, where that harm falls within the definition of ‘harm’, as set out in section 2 of the 2015 act. The court said that this interpretation of section 14(1)(a) “is consistent with the 2015 act as a whole, [and] does not give rise to any anomaly or absurdity and nor is it undermining of the legislative intention to protect children”. Moreover, this interpretation does not obviate the obligation of mandated persons to report any reasonably held suspicions that a child is at risk of harm – an obligation which pre-dates mandated reporting and applies to all persons, under the Children First National Guidelines, alongside some other statutory duties, as discussed.
This clarification from the Court of Appeal is a welcome one. A key concern arising from the original interpretation of the Act was the view that fewer adults would avail of counselling services (Pelligrini et al., 2022) and this, in turn, would inevitably reduce the extent of existing reporting of childhood abuse to Tusla rather than increase it. Moreover, it is clear that the active participation of the person making the disclosure is a vital component of mandatory reporting, as regards any decision to share this information with Tusla. The High Court had emphasised the importance of informed consent in counselling services in circumstances where counsellors are subject to mandatory counselling requirements. The disclosure of past harm is long recognised ‘by clinicians as important aspects of healing’ (Sarsoli et al., 2008, p333) and creating therapeutic and safe spaces where those who have experienced abuse feel they can come forward is essential to a healthy and healing society.
Conclusion
This Court of Appeal decision provides valuable clarification regarding the legislative definition of a ‘child’ when assessing whether adults’ retrospective disclosures of abuse fall within the remit of section 14 of the Children First Act. Moreover, the decision appears to provide increased reassurance to clinicians when faced with difficult questions around disclosure in the face of a client’s reliance on the duty of confidentiality. The question to be assessed in real terms is whether a child is at risk of being harmed. If that answer is in the affirmative, then a report must always be made. A service user should always be made aware of the limitations impinging on a counsellor’s duty of confidentiality, particularly where a child-protection concern arises.
The rights to privacy and confidentiality, due to an adult who is disclosing, can still fall second place to the urgent need to ensure a child is not at risk of harm. Hence the requirements remain, that where an adult discloser of abuse reveals an abuser who, it appears, is still in contact with children or indeed still capable of being in contact with children, that the obligation to report the disclosure persists. This decision provides very necessary clarification to practitioners working at the coalface of this quandary, hopefully offering some comfort to those seeking counselling services and ultimately bringing us a step closer to making child protection everyone’s business.
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