Independent Safeguarding Board ISB Church of England Maggie Atkinson Martyn Percy
Church of England

The CofE ‘Independent Safeguarding Board’? A Review

Following a complaint brought Professor Martyn Percy to the Archbishops of Canterbury and York, the Independent Safeguarding Board (ISB) published Terms of Reference (ToR) for a ‘review’ to commence on 30th May. Dr. Percy’s complaint had detailed abuses (accidental and deliberate) in “weaponizing safeguarding concerns” perpetrated by:

• Lawyers (Winckworth Sherwood) working for the Church/Diocese who had been instructed to “act against the Dean” and had been doing so since the autumn of 2019;
• Luther Pendragon, a PR agency also working for the Church of England;
• Senior clergy and senior officers of the Diocese of Oxford;
• and staff on the National Safeguarding Team (NST).

The issues detailed in the complaint had taken place for more than two years, and Dr. Percy requested that an Independent Inquiry be initiated into these matters, led by a judge or QC. Since the allegations were extremely serious – and mindful of cases of clergy accused of abuse, and victims of abuse, who had suffered breakdowns or committed suicide – such misconduct by individuals or bodies could pose further risks if left unaddressed. Dr. Percy requested that this Independent Inquiry would address and examine:

• The involvement of church lawyers and its PR agency in the manufacture and curation of false and/or vexatious safeguarding allegations.
• Gaslighting – highly offensive proactive briefings to the public, media, police, etc..
• Gross incompetence in the carriage of safeguarding procedures (NST and Diocese).
• The potentially deliberate fabrication of unregulated and defamatory “Risk Assessments” designed to cause reputational, personal and financial harm.
• Claiming that “investigations” were “independent” when they engaged in conspiring to coordinate and intensify prosecution evidence, whilst at the same time tampering with, redacting and withholding important evidence for the defence.
• Refusing to engage with witnesses or evidence from the defence, and ensuring that the defendant had no legal support, and little personal-pastoral support (if any).
• Witness intimidation, and also presenting information in a manner intended to mislead others and deliberately malign the defendant.
• Collusion with deliberate misconduct, with buck-passing, cover-ups and denials of gross incompetence in delivering safeguarding processes.
• Core Groups unfairly and incompetently constituted and progressed.
• Failing to follow NST or Church of England safeguarding procedures.
• Briefings by the Bishop to the Diocese and media in a manner that was pejorative to a fair or balanced representation for a defendant.
• The use of unregulated, unaccountable and unlicensed “investigators” against clergy, with the investigator reporting to untrained, unaccountable, unregulated and unlicensed Core Groups, that could act and determine as they wished.
• Failure to manage conflicts of interest, or act in a manner that was accountable, transparent and fair.

The Archbishops and Archbishops’ Council did not agree to any such Independent Inquiry. Instead, with Bishop Croft, they commissioned Maggie Atkinson (ISB Chair) to conduct a ‘review’ (see; and see also: and

However, this proposed process really cannot be trusted, since the ISB:

1. Has no remit, powers or authority to conduct any such review. Neither General Synod or the Archbishops’ Council have approved such, and the ISB Chair confirmed this at the February meeting of General Synod (see: 1.37.33, where Maggie Atkinson states “You will know from Paragraph 6 of our report that we do not have a re-investigative, reviewing, instigating, insisting, sanctioning or directing role”.

2. Asserted and then imposed their ToR, which were neither negotiated or agreed. The respondents to the complaint commissioned this ‘independent review’. The ISB is accountable to the respondents, and relies upon their ongoing favour for funding.

3. Does not possess the necessary expertise and experience for such work. Has poor, inadequate or non-existent processes in place in respect of witness statements, conflicts of interest, equality, data-handling and assessing evidence.

4. Staff lack the qualifications and standing for conducting any Independent Inquiry. Ignored or redacted every aspect of Dr. Percy’s specific complaint in its ToR, and was not operating in a manner that could be construed as independent.

5. Failed to demonstrate accountability, transparency, fairness, reliability and integrity in process at every stage, with those leading the proposed process being unregulated, unaccountable, unlicensed and (mostly) inaccessible; and also subject to no Codes of Practice or any kind of Professional Standards regulating body.

6. Could not or would not address basic questions about its modus operandi, and were consistently unwilling to correct numerous basic errors of fact contained within their ToR; and then referred such legitimate questions and concerns to their lawyer.

7. Failed to demonstrate any kind of openness to legitimate claims, facts or corrections that contradicted the outlook already adopted and presented by the Archbishops and Bishop of Oxford, and who were the “commissioning agents” of this ISB ‘Review’.

In conclusion, the approach taken by both Archbishops is known by the acronym DARVO – which stands for “Deny, Attack, and Reverse Victim and Offender”. It refers to the reaction [that alleged] perpetrators of wrongdoing, often where there are real or false allegations of sexual misconduct, may display in response to being held accountable for their behaviour. Research indicates that DARVO is a common manipulation strategy of psychological abusers, whether individuals or institutions.

Typically, the alleged abuser (in the Percy case, this is the Diocese of Oxford and the NST) denies the abuse ever took place, attacks the person that alleged abuse (often the victim) for attempting to hold the alleged abuser accountable for their actions, and claims that he/she is actually the victim in the situation, thus reversing what may be the reality of the victim and the offender. It often involves not just ‘playing the victim’ but also victim blaming.

The acronym is based on the work of American psychologist Jennifer Freyd, who notes that the first stage of DARVO, denial, usually involves gaslighting:

“… I have observed that actual abusers threaten, bully and make a nightmare for anyone who holds them accountable or asks them to change their abusive behaviour. This attack, intended to chill and terrify, typically includes threats of law suits, overt and covert attacks on the whistle-blower’s credibility, and so on. The attack will often take the form of focusing on ridiculing the person who attempts to hold the offender accountable. … [T]he offender rapidly creates the impression that the abuser is the wronged one, while the victim or concerned observer is the offender. Figure and ground are completely reversed. … The offender is on the offense and the person attempting to hold the offender accountable is put on the defence…” (J. Freyd, ‘Violations of power, adaptive blindness, and betrayal trauma theory’, Feminism & Psychology. February 1997, II., 7, (1): 22–32.)

The only way for victims of abuse and false-vexatious allegations – ever – to obtain truth, justice and resolution – and perhaps some healing – is for completely independent regulation and robust open, legal, transparent, accountable and fair processes to be in place. The ISB lacks all of this, and it is hard to foresee any change in the shameful and shambolic culture of safeguarding until the CofE stops messing around with its DIY approach.

In the meantime, Prof. Percy is now a private citizen and no longer part of the CofE at all. This is on the grounds that the CofE continues to pose threats and dangers to him, which the Archbishops are not prepared to accept, despite the evidence within disclosures. Why would the ISB now weigh in with further judgments against a person who is no longer under their jurisdiction?

We believe the ISB lacks the necessary experience, independence and expertise for this work, and so cannot command the trust or confidence needed. Any conclusions that the ISB reaches in this process are bound to reflect their ToR, which from the outset excludes the very matters that necessitate a genuinely Independent Inquiry. The ToR go on to state that the alleged perpetrators will neither be named or blamed.

The ISB is poorly constituted, rendering any ‘review’ unsafe, and so likely to perpetrate further abuses. The ToR and manner of their manufacture – non-consensual, assertive and bullying – simply replicate the misconduct about which Prof. Percy first complained. The ISB has issued no public call for evidence which risks denying justice and impeding a fair outcome, and it has no accountable or regulated means for assessing evidence.

Moreover, the ISB failed to make ‘reasonable adjustments’ for witnesses, not produced any quality assurance documentation, nor identified a Data Controller for GDPR. Repeated representations to the ISB were waived away by ignoring or dismissing legitimate concerns. Finally, a lawyer for the ISB restated these bullying-assertive denials, in order to close down objections.

Prof. Percy requested an Independent Inquiry led by a Judge or QC to examine allegedly unsafe and corrupt safeguarding practices in the Diocese of Oxford and NST. Along with other advocates and activists for reform, he will continue to campaign for an authentically independent body with proper powers of investigation, regulation and policing within the CofE over its safeguarding practices – abiding by principles of fairness, transparency, accountability, integrity and equality. Manifestly, the ISB is no such thing. General Synod must address these matters when it meets in July.




Both Archbishops wrote to Prof. Percy on June 14th (their text is in italics):

We realise that we don’t have a common view about what ‘independent’ looks like…The ISB is still a new body and it is entirely appropriate that this matter is referred to it. As you know the ISB has drafted the terms of reference for the work it thinks is appropriate to do and, having discussed the matter on several occasions we really do think we need to afford them the space to do that work.

Comment: The ISB is absolutely not constituted or set up to do such work, and the ISB Chair, Maggie Atkinson, confirmed this at the February meeting of General Synod.

It is a source of continued disappointment to us that you don’t have confidence in this and are unwilling to participate…we both believe there are important questions to be asked and issues to be addressed. It is our belief that the ISB will do this and we have both worked hard towards its establishment and creation. Moreover, they have indicated that they will be able to report by the autumn this year. Why not then cooperate with the process, let them make their report, and then see where we are? How could this possibly be worse than the situation we are in at the moment?

Comment: The ToR speak for themselves, and do not even propose to name abusers or apportion blame for misconduct, corrupt practices or gross incompetence. Some of the alleged abusers are also close colleagues and/or friends of the Archbishops – and so the process being advocated represents a clear conflict of interest. Furthermore, the ISB-ToR states it will report next year (2023), not the autumn of 2022.

We have heard your concerns. We think there are things to look at, as we have said above. We have been part of a process that has referred this to the ISB. They have said that they will look at this and report back.

Comment: The ISB lacks the skills, experience and resources to undertake such a complex piece of work. It is entirely wise and appropriate not to trust persons or a new ‘board’ that has never attempted such work before.

…we invite you again to reconsider your opposition to cooperating with this process. Please think about giving her the space and time she needs. If it turns out you’re right, and the whole thing is a sham, and the ISB is in the pockets of those who are against you, then that will become clear. We, however, do not believe it for a moment. And, if we are honest, can’t quite understand why you have reached this conclusion, and wonder whether you have considered how others might interpret this?

Comment: The ISB ToR clearly evidences that this ‘review’ could not be independent. Their ToR exclude all reference to the primary complaint. The ISB is already a ‘sham’ and further proof of that is not required. It is hard to conceive of any Bishop or Archbishop agreeing to be a ‘guinea-pig’ for the ISB to cut its teeth on. In this case, Prof. Percy has been abused by all previous CofE/Diocesan/NST processes. Yet the CofE wants to inflict another ‘home-made’ process on him that is unregulated, unaccountable and lacks any reference to a professional code of conduct or standards.

Where someone’s health, future and reputation is at stake, what reason would one have to submit to yet another CofE process? Would it be wise to submit to more procedures, when previous church-led ones have been demonstrably abusive, inept and corrupt?

The Archbishops claimed they consistently “heard” the complainant’s “concerns”, listened and offered “pastoral care”. We note the “weaponization of safeguarding” is consistently dialed-down to “concerns”, “issues” or “things to look at”!

Is this the Archbishops’ response to disclosures of multiple types of abuse perpetrated by senior clergy, lawyers and a PR agency working for the CofE, and senior church officers? Do the Archbishops believe this is a sufficient and appropriate response to disclosures of abuse made by a victim?

Is the deliberate weaponization of safeguarding, with intention to cause harm, merely a “concern”? If so, how will any ISB-led process avoid perpetrating further abuse?

Prof. Percy requested an Independent Inquiry led by a QC or Judge, not an internal ‘DIY-review’ process entirely run and owned by the CofE, and accountable to nobody; nor subject to external scrutiny, quality assurance or standards.