Responses towards child abuse and neglect: comparing policies and practices between England, the Netherlands and Germany - Child protection across borders: comparing policy and systems

Objectives and methods: The objective of this study is to compare child protection policy and systems in England, Germany and the Netherlands. This analysis is based on a detailed review of national policies and statistics. ... [ view full abstract ]

Objectives and methods: The objective of this study is to compare child protection policy and systems in England, Germany and the Netherlands. This analysis is based on a detailed review of national policies and statistics.

Results: In all three countries ‘what counts’ as child maltreatment has undergone similar shifts since the 1960s. However there are differences in the way thresholds for intervention are conceptualised and in the degree to which the risk of harm, and the impact of actual harm on the child, are prioritised. There are also differences in the relation between the family and the state, with a greater emphasis on voluntary intervention in Germany and the Netherlands than in England. The relation between the family, the state and the market also varies, particularly in relation to the relative responsibilities of state and independent agencies.

All three countries are situated on a continuum between balancing children’s rights to protection with the rights of parents to freedom from intrusion by the state. A more child-centred approach is evident in England, where the law states that the welfare of the child must be the paramount consideration. While there is serious attention to protecting children from harm in both Germany and the Netherlands, policy in those countries suggests that the balance between a child-centred approach and a concern to protect families from unwarranted intrusion by the state tends towards a greater emphasis on the rights of parents, especially in Germany.

Conclusions: All three countries seek to balance a desire to keep children within their families and with a desire to protect them from serious harm. The balance achieved at any point in time has been influenced both by the force of circumstances, notably high profile child deaths, and by the legacy of historical child welfare regimes and attitudes to state intervention.