Review to demand excluded pupils count in schools’ results – Friday 15 February 2019

This week I report on the review of exclusions expected to be published before Easter which would require excluded pupils to count in school’s results and the DfE has announced it’s expectation that schools fund a 2% cost of living teacher pay rise in 2019/20.

Timpson review to demand excluded pupils count in schools’ results
A landmark review of exclusions will demand the Government revives plans to make schools retain responsibility for the results of pupils they exclude. According to leaked documents seen by Schools Week the Timpson review will call for a “significant shift” for schools, alternative provision settings and councils, demanding that ministers “remove the potential” for Headteachers to game the system by “permanently excluding children at the most crucial time in their education”.

Edward Timpson, a former children’s minister who was commissioned to look into the practices around exclusions last year, was supposed to publish his report by the end of December. It was later widened to look at the illegal off-rolling of pupils, with ministers promising it will be published before Easter.

In extracts of the draft, seen by Schools Week, Timpson said the Department for Education should make heads “continue to be responsible for children who have been permanently excluded, including for commissioning high-quality and safe alternative provision where this is needed and remaining accountable for the educational outcomes of this”.  In practice, that means the performance of excluded pupils would count towards the school’s league table position.

Publication of evidence to support the School Teachers’ Review Body (STRB) consideration of the 2019 pay award
The Secretary of State wrote to the STRB on 21 November, asking for their recommendations on the September 2019 teachers pay award. The letter stressed the importance of focusing on how the pay award can best address recruitment and retention challenges, while taking account of affordability across the school system.

The DfE has now published evidence to support the STRB’s consideration of the 2019 pay award and concluded that a pay increase for teachers of 2% (in line with forecast inflation) is affordable within the overall funding available to schools for 2019 to 2020, without placing further pressure on school budgets. This is supported by the Government’s proposals to fund increases in teachers’ pension contributions from September 2019.

New vision for character and resilience – Friday 8 February 2019

This week I report on the Education Secretary’s five foundations for character education, a series of trials testing different approaches to supporting young people’s mental health and an EEF trial of an English mastery programme at Key Stage 3.

Vision for character and resilience
This week the Education Secretary, Damian Hinds laid out the 5 Foundations for Building Character and pledged to work with schools and external organisations, including membership bodies and charities, to help every child access activities within each of those foundations. The foundations are:

  • Sport – which includes competitive sport and activities such as running, martial arts, swimming and purposeful recreational activities, such as rock climbing, hiking, orienteering, gym programmes, yoga or learning to ride a bike.
  • Creativity – this involves all creative activities from coding, arts and crafts, writing, graphic design, film making and music composition.
  • Performing – activities could include dance, theatre and drama, musical performance, choir, debating or public speaking.
  • Volunteering & Membership – brings together teams for practical action in the service of others or groups, such as volunteering, litter-picking, fundraising, any structured youth programmes or uniformed groups like Beavers, Brownies, Cubs, Guides, Scouts, Cadets and Duke of Edinburgh.
  • World of work – practical experience of the world of work, work experience or entrepreneurship. For primary age children, this may involve opportunities to meet role models from different jobs.

To help to make this happen the Education Secretary announced:

  • Plans for an audit of the availability of out of school activities across the country, to help understand where more focus is needed to increase access and choice.
  • A call on businesses and charities to offer more work experience and volunteer placements to young people.
  • Relaunching the Department for Education’s Character Awards, which highlight innovative or outstanding programmes that develop a wide variety of character traits.
  • A new advisory group will develop a new framework to help teachers and school leaders identify the types of opportunities that will help support their pupils to build character. The framework will also provide a self-assessment tool for schools to check how well they are doing.

Mental Health trials launched in 370 schools
To mark Children’s Mental Health Week (4-10 February), the Education Secretary Damian Hinds has announced that up to 370 schools in England will take part in a series of trials testing different approaches to supporting young people’s mental health.

Children will benefit from mindfulness exercises, relaxation techniques and breathing exercises to help them regulate their emotions, alongside pupil sessions with mental health experts. The study will run until 2021 and aims to give schools new, robust evidence about what works best for their students’ mental health and wellbeing.

Mr Hinds also confirmed the nine areas across the country that will trial new high-quality mental health assessments for young people entering care, helping them get the support they need to meet their individual needs at a time when they are more vulnerable.

English mastery programme trial by the EEF
A Key Stage 3 English mastery programme has been selected for a trial by the Education Endowment Foundation (EEF). The EEF will test the approach, which is supported by Ark Ventures, an arm of Ark Schools, in 110 schools over two years to find out if it will boost pupil progress. Around 700 teachers and 40,000 pupils are expected to be involved.
Ark recently announced that it is developing a school curriculum programme covering “all the major subjects” that it plans to sell to other schools. It comes as Ofsted’s new framework shifts its focus from exam results to how schools deliver curriculum.

The new trial is one of five unveiled today by the EEF, which exists to test approaches that “break the link between family income and educational achievement”. Other successful projects include a scheme to improve access to glasses, and programmes for struggling readers.

New teacher Recruitment and Retention strategy – Friday 1 February 2019

This week I highlight the launch of the new teacher Recruitment and Retention strategy, a consultation on making it easier to identify schools that could benefit from support to improve performance, an online energy switching service added to the DfE’s new deals service for schools and publication of advice to schools in the event of a no deal Brexit.

Launch of a new teacher Recruitment and Retention strategy
Earlier this week the Education Secretary, Damian Hinds, launched the new teacher Recruitment and Retention strategy. It includes plans for an early career framework which will fund schools to provide an extra year of induction for new teachers, including a 5% off-timetable requirement.  Working with Ofsted to simplify the accountability system and reduce any unnecessary pressure it places on teachers.  Launch a new job-share service to help those interested find opportunities and provide free timetabling tools to make it easier for schools to manage.  As well as simplifying the application process by introducing a new ‘one-stop’ system for initial teacher training.

Consultation on making it easier to identify schools that would benefit from support to improve their performance
The consultation seeks views on proposals for a clearer, simpler approach to identifying schools that may benefit from an offer of support to help improve a school’s educational performance.

The proposal is that all schools judged as ‘Requires improvement’ by Ofsted will be eligible for support, and that schools with two consecutive ‘Requires improvement’ judgements will be eligible for more intensive support.  To simplify accountability it also proposes removing floor and coasting data standards.

Deals for Schools
The DfE’s Schools Commercial Team provides information on the national deals available to schools to help them save money on some of the things they buy regularly. The deals are assessed for compliance with procurement regulations, ease of use, suitability and value for money. An online energy switching services has just been added.

Advice to schools on preparing for the possibility of the UK leaving the EU without a deal
Yesterday the DfE published advice to schools in England on how to prepare in the event that the UK leaves the EU without a deal. This relates to the EU Settlement scheme, school places, recognition of teaching qualifications, travel to the EU, school meals and the supply of food and the Erasmus programme.

Secondary performance tables published – Friday 25 January 2019

This week I report on the publication of the secondary performance tables and revised guidance explaining how the secondary school accountability measures are calculated, as well as the Education Secretary’s speech calling for the technology industry and educators to work in partnership to transform education, cut teacher workload and improve pupil outcomes.

Secondary accountability measures and the publication of performance tables
A new secondary school accountability system was introduced in 2016. The DfE has published revised guidance explaining how the measures are calculated and further clarification on the support available to schools falling below the floor or coasting standards, following the Education Secretary’s speech in May 2018, on his vision for a clearer school accountability system. It also follows publication of the Government’s response to the Workload Advisory Group’s recent report Making Data Work.

This week the secondary school performance tables were published and show:

  • attainment results for pupils at the end of Key Stage 4
  • the progress made by pupils between the end of primary school to the end of secondary school
  • data on the performance of disadvantaged pupils
  •  differences in the performance of:
    • pupils who had low attainment at the end of primary school
    • pupils who had high attainment at the end of primary school
    • pupils who were at the expected level at the end of primary school

There is also data about school income and expenditure, the workforce, pupil characteristics and absence.

Education Secretary speech on the technology industry and educators to work in partnership to transform education, cut workload and improve pupil outcomes
On Wednesday, Damian Hinds the Education Secretary, addressed more than 800 of the world’s leading tech companies and start-ups, as well as school representatives and international education ministers, at the Bett Show in London. He told teachers and school leaders to make smarter use of technology, both inside and outside of the classroom, to make sure that it does not add to teachers’ responsibilities. He suggested teachers should not have to email outside of office hours and should instead embrace innovative technology such as AI to help to reduce their workload.

Mr Hinds also outlined his plans to launch an EdTech strategy later this year to harness the power of technology in schools, strengthening the training teachers receive, reducing their workload, and unleashing young people’s potential – backed by a £10 million fund to support innovative uses of tech in schools and colleges across England.

Consultation on draft inspection framework opens – Friday 18 January 2019

This week I report on the opening of the consultation on the draft inspection framework and the changes this will mean for schools and governors as well as the publication of updated guidance for maintained schools about setting up or reviewing complaints procedures.

Consultation on draft inspection framework
Earlier this week Ofsted opened its consultation on the draft education inspection framework to be implemented from September 2019. The framework sets out how it proposes to inspect schools, further education and skills provision and registered early years settings. Alongside the framework Ofsted also published draft inspection handbooks and a reports on its research. The consultation is open until 5 April 2019 and if you would like to submit a response you can do so by responding online or via email at inspection.consultation@ofsted.gov.uk.

Key Headlines

  • Increased curriculum focus – shift from scrutiny of pupil data to more discussion of curriculum structure, coherence and sequencing.
  • Continued importance of assessment – published pupil performance data will continue to figure strongly in future inspections under “Curriculum Impact”. However, it’s unclear how much weighting the inspectorate will give to this factor in forming an overall judgement.
  • Pause on full implementation – following concerns around the timetable for implementation Ofsted has inserted a significant caveat on the new curriculum criteria to ensure ‘inspectors will evaluate ‘intent’ favourably’. However, the language surrounding this is vague and open to interpretation.
  • No-notice inspections – Ofsted has proposed that the lead inspector will arrive at the school within hours of notifying the school of inspection but has termed this “on-site preparation” rather than the beginning of an inspection. The scope of activities covered on this first half-day is minimal.
  • Longer short inspections – Section 8 inspections of good schools would double in length to two days, the same length as full inspections, to allow inspectors to cover more ground within an expanded framework. The original intention of short inspections, as a check with conversion to full inspection when inspectors identify problems, appears to have been discarded.

How this affects governance
Inspectors will make judgements on the following:

  • overall effectiveness

and the four key judgements:

  • the quality of education
  • behaviour and attitudes
  • personal development
  • leadership and management

The role that governors and trustees play in the school’s performance is evaluated as part of the judgement on the effectiveness of leadership and management, and each report will contain a separate paragraph that addresses the governance of the school.

The framework references the Governance Handbook indicating it sets out the purpose of governance, which is to provide confident, strategic leadership and to create robust accountability, oversight and assurance for educational and financial performance.

In addition, those with governance/oversight are responsible for ensuring that the school fulfils its statutory duties, for example under the Equalities Act 2010, and other duties, for example in relation to the ‘Prevent’ duty and safeguarding. Inspectors will explore how governors carry out this responsibility. The framework notes that inspectors are not expected to construct or review a list of duties.

The draft inspection handbook for maintained schools and academies provides a section on applying the Education Inspection Framework in different contexts such as junior and middle schools, special schools and pupil referral units.

Updated DfE guidance on school complaints procedures
This week the DfE also published updated guidance for school complaints procedures for maintained schools. There are key additions to the original guidance as follows:

  • Establishing a complaints procedure – the DfE has clarified that responsibility for establishing procedures for handling complaints lies with the governing board. The board must have regard to any guidance from the Secretary of State when establishing and publishing its complaints procedures but that doesn’t mean that schools must adhere to every detail in the DfE’s guidance.
  • Publishing a complaints procedure – where a school deems it necessary or reasonable to deviate from its published complaints procedure this deviation should be documented.
  • Stages in the procedure – though the decision still lies with schools, the DfE now recommends implementing a complaints procedure that consists of two stages.
  • Complaints about the Headteacher or the whole governing board – the guidance confirms that a school’s complaints procedure must also outline the steps to follow if the subject of the complaint is the entire governing board. When a complaint is made against the whole governing board, they need to be made aware of the allegations made against them and respond to any independent investigation. Complaints against the headteacher should be dealt with by a suitably skilled member of the governing board at stage 1 of the complaints process, then by a committee of members of the governing board at stage 2.
  • Managing serial or persistent complaints – schools should establish a policy for managing serial and unreasonable complaints and this should be included in the published complaints procedure. Where a decision to enforce a bar on an individual due to poor behaviour has been confirmed, the individual will be notified in writing, explaining how long the bar will be in place and when the decision will be reviewed.
  • Legal representation – where a complaint progresses to a committee of members of the school governors, it is recommended that neither the complainant or the school brings legal representation. The DfE does, however, recognise that there will be occasions where legal representation may be appropriate.
  • Mediation – including a mediation stage in a complaints procedure can be useful in helping schools and complainants to reach an agreement and move forward; however, there may be occasions where this is not an appropriate course of action.
  • Complying with the GDPR – before disclosing information regarding a complaint to a third party, schools must obtain written consent from the complainant. Notes of meetings and telephone calls should be kept securely and encrypted, where possible, to prevent any later challenge or disagreement over what was said. Recording meetings – consent must be obtained from all involved parties before conversations or meetings are recorded. Audio and video evidence – the DfE may accept independently notarised transcriptions of recordings and may ask for the written consent of all recorded parties. Schools will be supported should they choose to refuse to accept recordings of conversations that were obtained without the informed consent of all parties being recorded as evidence.
  • Communicating the outcome – schools should inform the complainant of the conclusion and reasons for any decisions in writing and any further rights of appeal. Copies of minutes should be issued to the complainant, as failure to do so could lead to further complaint.  The guidance clarifies that when responding to a complaint, schools should advise the complainant of any escalation options at each stage of the procedure, e.g. when communicating the outcome of the stage 1 process, the details of the stage 2 process should be included.

I will review our current Complaints procedures and will bring a revised version, if that is required, to this term’s Governing body meetings for discussion and adoption.

Proposal for children to learn life-saving skills in schools – Friday 11 January 2019

This week I report on the DfE’s plans for children to learn life-saving skills as part of health, sex and relationships education, the publication of an activity passport for primary school children to inspire and boost resilience, the Education Secretary’s request for schools to lead the way in reducing plastic waste and the announcement of the first modern foreign languages centre for excellence.

Plans for children to learn life-saving skills
To ensure the next generation knows what to do in an emergency, the Government is planning to make health education compulsory in all state-funded schools. Under the proposed new guidance, by the end of secondary school pupils will be taught how to administer CPR, the purpose of defibrillators, and basic treatments for common injuries.

The proposals are part of the Department for Education’s plans to strengthen teaching of health, sex and relationships education – building on free resources already available for schools to teach first aid including those provided by the Every Child a Lifesaver Coalition, made up of the British Heart Foundation, St John Ambulance and the British Red Cross.

Activity ‘passport’ to inspire children and boost resilience
Early in the new year the Education Secretary launched a ‘Passport’ of activities to enrich children’s experiences and skills, backed by the Scouts, Girlguiding and National Trust.

The ‘My Activity Passport’ list is part of the Education Secretary’s vision for every child to have the opportunity to enjoy new and varied experiences, no matter their background, comprising of key areas:

  • drive and tenacity;
  • sticking at the task at hand;
  • understanding how to work towards long term goals when reward might be a long way off in the future; and
  • being able to pick yourself up and bounce back from life’s challenges.

Schools urged to ban single-use plastic
The Education Secretary, Damian Hinds, has urged schools to “lead by example” in the Government’s drive to reduce plastic waste. This would involve avoiding the use of plastic bags, straws and bottles in favour of sustainable alternatives, and talking to pupils about the detrimental long-term effects that discarded plastic has on the environment.

No additional funding has been allocated to assist schools with the changes; however, Mr Hinds has said that his department will “increase communication” with the school supply chain over plastic packaging of “day to day” supplies for schools, but his “ambition” is for schools to work with suppliers to make the changes themselves.

New centre for excellence to boost modern foreign language skills
The School Standards Minister, Nick Gibb, announced yesterday that the University of York was England’s first modern foreign languages centre for excellence.  The centre, which will be known as the Centre for Excellence for Languages Pedagogy, will work with schools to help more young people learn foreign languages.

The university will now co-ordinate the work of nine modern foreign languages hubs – leading schools that are working with other schools and sharing best practice to boost the teaching of Spanish, French and German.

New funding to support children with SEND – Friday 21 December 2018

In the final week of this term I report on new funding to help local authorities support pupils with SEND, the launch of a £9 million Government programme to deliver holiday clubs for pupils eligible for free school meals during the summer break next year and the publication of a new guide for governing bodies from the NGA on careers guidance.

New funding to support children with special educational needs
The Education Secretary Damien Hinds has announced extra funding to help local councils support pupils with SEND. LAs will receive an extra £125 million this year and a further £125 million in 2019/2020 to top up high needs budgets for maintained schools and academies.

The Government has been under increasing pressure over the lack of funding available to schools for supporting pupils with SEND. Mr Hinds said: “We recognise that the high needs budget faces significant pressures and this additional investment will help local councils to manage those pressures, whilst being able to invest to provide more support.”

The Government has also confirmed an expansion of the funding to train more educational psychologists, who are responsible for assessing children’s needs and providing tailored support as part of the Education, Health and Care needs assessment process.

Extra support for disadvantaged children during school holidays
This morning the Children and Families Minister Nadhim Zahawi has confirmed that more disadvantaged children will benefit from free meals and activities during the school holidays, under a £9 million Government programme.

Organisations from across the country have been invited to bid for a share of the multi-million-pound Government investment to deliver holiday clubs for pupils eligible for free school meals during the 2019 summer break.

The scheme follows a successful £2 million programme in the summer of 2018, which saw charities and community groups provide meals and activities such as football, play sessions and cooking classes for more than 18,000 children across the country.

Launch of NGA Careers guidance: the role of the governing board
The National Governance Association has written a new guide for governing boards on careers guidance with support from the Careers & Enterprise Company, the Gatsby Foundation and Education & Employers.

The new guide sets out the duties of the governing boards of primary and secondary schools in the context of the broader aims of the government’s careers strategy, alongside the key resources, sources of information and data to consider when monitoring the provision and quality of careers guidance.

 

Replacement for Parent View – Friday 14 December 2018

This week I report on a replacement for Parent View, publication of research suggesting the removal of assessment levels in primary schools had led to some confusion between schools and publication of the 2018 primary performance tables.

Replacement for Parent View
Her Majesty’s Chief Inspector, Amanda Spielman has written to the Public Accounts Committee advising that Parents View (the dedicated website used by Ofsted to collect the views of individual parents and particularly used during inspection) would be replaced with a new service, which would better meet parents’ needs. The new system was being specifically designed to increase the volume, quality and diversity of views that Ofsted collects from parents both during and outside of inspection. This includes considering different platforms, ways of gathering and presenting data and the questions parents are asked.

Ofsted has conducted a series of focus groups with parents across the country to better understand how they would like to share their views, how they would like to see the views of others and what they would like to provide views on. After this initial exploration Ofsted will develop options for what this new service could look like. It will test these with parents and inspectors so that they can learn what does and doesn’t work, and once the best option is identified it will be tested and piloted before launching the final, live product.

Scrapping assessment levels has led to some confusion between schools
This week the National Foundation for Educational Research has published its research looking at whether the removal of national curriculum levels in primary schools in 2014 has had the intended effect in schools, such as allowing more time for in-depth teaching and increasing pupil engagement.

But teachers and leaders from 42 primary and secondary schools who were interviewed last year warned the “diversity” of approaches to testing that has replaced levels “makes it difficult to understand” the information they receive about pupils who move, or when moderating work in other schools. Because of this confusion, “schools would welcome a form of national standardisation for non-statutory assessment guided by annotated exemplars of pupils’ work” rather than the current item bank of questions available to schools now, the research suggested.

Publication of the 2018 primary performance tables
The 2018 primary performance tables have been published and show attainment has gone up for each subject nationally compared to 2017, with no changes to the headline figures published in the provisional data in September.

Board of Opportunity North East announced – Friday 7 December 2018

This week I highlight the announcement of the Board of education and business experts that will help to implement the Government’s £24 million investment in a region-led North East Opportunity area and the publication of Ofsted’s Annual Report for 2018.

Opportunity North East Board announced
At the beginning of the week Lord Agnew confirmed the board of education and business experts to help implement £24 million investment to raise school standards and aspirations in the North East. The expert board will help to run the Opportunity North East programme to build a coalition of schools, colleges, local authorities, businesses and higher education institutions to tackle the issues holding back young people in the region.

The group of twelve, which includes the Chair of the North East Local Enterprise Partnership, the Director of Schools North East, the Regional Schools Commissioner, the Chief Innovations Officer and Company Secretary of ATOM Bank, the Chief Executive of Tyne Coast College and the Pro Vice-Chancellor, Learning and Teaching at Newcastle University, met for the first time on the 3 December.

Opportunity North East will help young people in the North East to reach their potential through secondary education and beyond by:

  • building on good primary school performance to ensure more children continue to achieve at secondary school;
  • unlocking the potential of key secondary schools in the region by encouraging collaboration with schools, high performing academy trusts and local authorities;
  • working with partners such as Teach First to ensure there are more great teachers where they are needed most. The North East will be the first region in England to implement more support for newly-qualified teachers to encourage them to stay in the classroom, with £12 million for early roll-out of the Government’s improved offer from September 2020;
  • raising aspirations and tackling the barriers that prevent young people in the North East from realising their full potential, including accessing high-quality technical education and attending the best universities; and
  • making the most of young people’s skills and talents in the North East through harnessing the pioneering work of local enterprise partnerships to help them find a rewarding, secure job.

Publication of Ofsted’s Annual Report for 2018
This week Ofsted published its 2018 Annual Report and listed below are six key findings:

  1. There are too many children in ‘stuck’ schools – Chief inspector Amanda Spielman said that although inner-city sink schools have become largely a thing of the past there were too many pupils in “stuck schools”. Ofsted has identified 490 schools which have not been rated as good since 2005.
  2. The number of good and outstanding schools fell slightly this year – at the end of August this year 86% of schools were good or outstanding at their last inspection, compared with 87% of schools in August 2017. Outcomes are highest for special schools with 92% rated as good or outstanding, compared to 87% of primaries and 75% of secondaries. Of the 2,470 full inspections this year 7% were judged to be outstanding, 47% were judged to be good, 37% were judged to require improvement and 9% were found to be inadequate.
  3. Stark regional variation in children’s ability to read – Ms Spielman warned that children failing to learn properly created a cycle which meant they would not be able to read to their own children. She highlighted a regional imbalance in pupils from disadvantaged backgrounds performance in the phonics check with areas such as Newham and Newcastle performing well while disadvantaged children in more affluent areas like West Berkshire lagging behind.
  4. Assessing multi-academy trusts – Ofsted is continuing to push the DfE to allow it to make full inspections of multi-academy trusts (MATs) arguing that this is “one area where our inspection powers have not kept pace with changes in education”. In the meantime the inspectorate plans to continue to get round this with its batch inspections of schools in the same MAT., but these will now take place over the course of one or two terms rather than a single week.
  5. More scrutiny for schools suspected of off-rolling – Ofsted has found that 19,000 pupils were taken off school rolls between 2016 and 2017 with around half not appearing at other schools. Sean Harford, the inspectorate’s national director of education said around 300 schools had been identified with high numbers of pupil movement. He said these would be subjected to extra scrutiny and added that Ofsted is already highlighting off-rolling in inspection reports. Ofsted also said the new inspection framework it is launching next year will allow inspectors to better report on schools which off roll pupils.
  6. There is a shortage of good MATs – Ofsted has said that unless more good multi academy trusts are found the Government’s plan to deliver system wide school improvement through the academies programme will not be realised. The report says the halfway house approach to academisation is not working and the matching of schools to is “not happening anywhere near as quickly as the inspectorate would hope”. Ofsted said more outstanding schools and school leaders are needed to step up to the challenge of providing system leadership.

Research indicates more support is required for teachers mental health – Friday 30 November 2018

This week I highlight new research on the growing need for schools to support staff wellbeing and a DfE consultation on new school security guidance.

Call for schools to do more for teachers mental health
Three-quarters of teachers say their mental health is not being monitored at work, according to new research that highlights the growing need for schools to support staff wellbeing. The study by the Anna Freud National Centre for Children and Families offers examples of techniques and practices to help schools prioritise the mental wellbeing of their staff and pupils.

The research, released on Wednesday, underlines how British schools are facing a growing tide of mental health problems among both staff and students. Fifty five percent of those surveyed by the Anna Freud centre said staff at their school were not encouraged to speak openly about their mental wellbeing.

Proposed new school security guidance
The DfE is seeking views on proposals for new school security guidance. It’s intended the non statutory guidance will help schools to put in place proportionate and sensible security policies and plans that reflect their individual circumstances. The consultation closes at 11:59pm on 18 February 2019.