Comparison to other similar systems

Braziledit

For decades, before 1990, there had been pressure from NGOs and children's organizations for protecting children battered by poverty and hunger and despised by sections of the community in Brazil. After this, became a chapter on the rights of children and adolescents in The Constitution of the Federative Republic of Brazil. In 1990, an even greater victory, when the Statute of the Child and Adolescent was approved by both houses of the National Congress, legally obligating the Government to protect child rights. This ensured a comprehensive child welfare system in Brazil. To ensure that the Statute's provisions are enforced, Councils for the Rights of the Child and Adolescent were set up at federal, state and local levels.

The National Council for the Rights of Children and Adolescents (CONANDA) is Federal Authority. The Councils of Guardianship are the Local Authorities and have duties and responsibilities towards children in their area. All work is based in STATUTE OF THE CHILD AND ADOLESCENT (Law No. 8,069, July 13, 1990).

Canadaedit

In Ontario, services are provided by independent Children's Aid Societies. The societies receive funding from, and are under the supervision of the Ontario Ministry of Children and Youth Services. However, they are regarded as a Non-governmental organization (NGO) which allows the CAS a large degree of autonomy from interference or direction in the day-to-day running of CAS by the Ministry. The Child and Family Services Review Board exists to investigate complaints against CAS and maintains authority to act against the societies.

The federal government passed Bill C-92 — officially known as An Act Respecting First Nations, Inuit and Métis Children, Youth and Families — in June 2019 coming into force on January 1, 2020. The new legislation creates national standards on how Indigenous children are to be treated. For example, when looking to place kids in foster care, authorities are to prioritize extended family and home communities. The law also allows Indigenous communities to create their own child welfare laws. Indigenous children make up seven per cent of Canada's population, but they represent about 50 per cent of youth in care.

Costa Ricaedit

The Patronato Nacional de la Infancia (PANI) is responsible for Child Protection in Costa Rica.

The agency was founded in 1930 by Dr. Luis Felipe Gonzalez Flores, a Costa Rican magnate at the time. It was founded to combat infant mortality, that at the time, was rampant in Costa Rica. The idea was to put infants up for adoption that the mother could not afford to support (abortion is a crime in Costa Rica).

In 1949, after the Costa Rican Civil War, a new constitution was written, it called for the agency to be an autonomous institution in the government, autonomous from any ministry.

Today the focus is on the UN Convention on the Rights of the Child. The agency still favors adoption, since abortion is illegal in Costa Rica.

United Kingdomedit

The United Kingdom has a comprehensive child welfare system under which local authorities have duties and responsibilities towards children in need in their area. This covers provision of advice and services, accommodation and care of children who become uncared for, and also the capacity to initiate proceedings for the removal of children from their parents care/care proceedings. The criteria for the latter is 'significant harm' which covers physical, sexual and emotional abuse and neglect. In appropriate cases the Care Plan before the Court will be for adoption. The Local Authorities also run adoption services both for children put up for adoption voluntarily and those becoming available for adoption through Court proceedings. The basic legal principle in all public and private proceedings concerning children, under the Children Act 1989, is that the welfare of the child is paramount. In recognition of attachment issues, social work good practice requires a minimal number of moves and the 1989 Children Act enshrines the principle that delay is inimical to a child's welfare. Care proceedings have a time frame of 26 weeks (although capable of extension under certain circumstances) and concurrent planning is required. The final Care Plan put forward by the Local Authority is required to provide a plan for permanence, whether with parents, family members, long-term foster parents or adopters. The Court routinely joins children as parties to their own Care proceedings, and their best interests are explored and advanced by Children's Guardians, independent Social Workers who specialise in representation of children in proceedings. It is a feature of Care proceedings that judges of all levels are expected to adhere to the recommendations of the Children's Guardian unless there are cogent reasons not to. Nevertheless, 'drift' and multiple placements still occur as many older children are difficult to place or maintain in placements. The role of Independent Visitor, a voluntary post, was created in the United Kingdom under the 1989 Children Act to befriend and assist children and young people in care.

In England, Wales and Scotland, there never has been a statutory obligation to report alleged child abuse to the Police. However both the Children Act 1989 and 2004 makes clear a statutory obligation on all professionals to report suspected child abuse.

The statutory guidance Working Together to Safeguard Children 2006 created the role of Local Authority Designated Officer, This officer is responsible for managing allegations of abuse against adults who work with children (Teachers, Social Workers, Church leaders, Youth Workers etc.).

Local Safeguarding Children Boards (LSCBs) are responsible ensuring agencies and professionals, in their area, effectively safeguard and promote the welfare of children. In the event of the death or serious injury of a child, LSCBs can initiate a 'Serious Case Review' aimed at identifying agency failings and improving future practice.

The planned ContactPoint database, under which information on children is shared between professionals, has been halted by the newly elected coalition government (May 2010). The database was aimed at improving information sharing across agencies. Lack of information sharing had been identified as a failing in numerous high-profile child death cases. Critics of the scheme claimed it was evidence of a 'big brother state' and too expensive to introduce.

Working Together to Safeguard Children 2006 (updated in 2010) and the subsequent 'The Protection of Children in England: A Progress Report' (Laming, 2009) continue to promote the sharing of data between those working with vulnerable children.

A child in suitable cases can be made a ward of court and no decisions about the child or changes in its life can be made without the leave of the High Court.

In England the Murder of Victoria Climbié was largely responsible for various changes in child protection in England, including the formation of the Every Child Matters programme in 2003. A similar programme – Getting it Right for Every Child – GIRFEC was established in Scotland in 2008.

A bill is beingwhen? debated in the UK parliament which many people and organisations fear will take away the statutory duty local authorities have to protect vulnerable children.