"SENAC cannot support the implementation of this draft policy for a number of reasons and as a consequence we disagree with each point in the pro forma response.
Our main concerns are:
- The absence of any comprehensive reason for the need to draft this policy and to propose change. This is the fundamental expectation of any reform of policy or practice. The document does not outline what issue it is addressing or why is it needed.
- There is no research, data or statistics to help inform consul tees as to the justification or need for this policy. Without this it is unreasonable to expect any positive agreement to any change in procedures and monitoring of home education.
- The legal duty of the Education and Library Boards in relation to home education has not been demonstrated satisfactorily. There is no legal duty quoted in the document that justifies the nature of monitoring proposed and inspection of the home in relation to home education.
- Concerns expressed that this policy will compromise and undermine many aspects of the UN and European Conventions relating to family life, freedom of choice and right to privacy.
- The policy outlines what could be perceived as intrusive powers and seems in contrast to those within other UK jurisdictions. No reason is presented to warrant the level of monitoring proposed comparable to other parts of the UK and no sound basis in law has been outlined for such a practice.
- The failure to demonstrate in the policy that the Education and Library Boards have the legislative power to act in the way they propose.
- The policy does not adequately recognise the right of parents to choose to home educate their child. It presents a perception that education is best when accessed within the state school system and makes no attempt to recognise or value parental or family choices or the individuality and wishes of a child and that for some children the state school system is not the environment that they need or want.
- The policy fails to demonstrate that the relationship between the education authorities and parents who choose home education should be founded in respect, support and positive communication.
- The absence of statistics and data relating to home education for example educational outcomes /attainment etc and breakdown of characteristics of this group of children, gender, disability etc."
Read the full document in the pdf below