Sample report · Harebell Primary Academy and Brindle Heath Learning Trust are fictional. All findings, quotes and figures are illustrative.
Report + Policy Drafts

Harebell Primary Academy

Statutory Compliance Review
Prepared for Ms Priya Raman, Headteacher, and the Local Governing Board, on behalf of Brindle Heath Learning Trust
14th July 2026
First edition

Method: every document Harebell Primary Academy publishes was read in full against rubrics built from the current statutory sources, not pattern-matched on titles or keywords. Every finding quotes the passage of the school's own policy it rests on, names the duty it is measured against, and states what to change. Website and data-protection checks were run against the live site on the report date.

14
Documents reviewed
11 statutory policies + 3 website-level checks
9/12
Must-publish items found
3 not located: appeals timetable, equality objectives, phonics
11
Must-level failures
4
Currency failures
Documents out of date against their own review cycle
7
Ready-to-adopt drafts included

Executive summary

Harebell Primary Academy is a well-run 4 to 11 academy of around 210 pupils, and its published policy set reflects that: the safeguarding policy is substantial and school-specific, the SEND information report is written in plain language for parents, and the complaints policy exists and is easy to find. Nothing in this review suggests a school that is unaware of its duties. What the review does find is a set of eleven must-level gaps that are precise, well understood and, in most cases, correctable in an afternoon with wording we have drafted for you. Three of the twelve items a primary academy must publish were not located at all, and four published documents have fallen behind their own review cycle. The pattern is administrative drift rather than weak governance, and it is exactly the kind of drift that shows up in an Ofsted website check or a parental complaint.

Strength to acknowledge

The Safeguarding and Child Protection Policy is genuinely strong on substance: low-level concerns, allegations against staff, filtering and monitoring, and the local authority designated officer route are all covered properly, and Mrs Helen Doyle is named as DSL with a direct contact route. The SEND Information Report is one of the clearest we have read at this size of school. The fixes below are about currency and completeness, not about rebuilding the policy set.

The four themes

Each theme names the documents it affects. Full evidence sits in the per-policy sections below.

  1. 1Citation currency. The safeguarding policy is built on Keeping Children Safe in Education 2024 and cites it as the current edition throughout, including in the staff declaration at Annex A. KCSIE 2025 has been in force since 1st September 2025. The content is not far off, but a governor, an inspector or a parent reading the front page sees a policy anchored to a superseded edition. The accessibility plan (Equality Act 2010 Schedule 10) covers 2021 to 2024 and has now lapsed. Both are wording changes, not policy rewrites.
  2. 2Missing statutory wording inside otherwise good policies. The RSE policy does not state the parental right to withdraw from sex education, which is the single element the RSE Regulations 2019 and the accompanying statutory guidance require a primary policy to address explicitly. The complaints policy stops at stage 2 and gives no timescales, where the Education (Independent School Standards) Regulations expect a three-stage process with a panel including an independent member and published deadlines. The SEND information report does not set out the arrangements for consulting parents of pupils with SEND, one of the specific items required by the SEN Information Regulations under Children and Families Act 2014 s.69. In each case the surrounding policy is sound and the gap is a clause.
  3. 3Funding statements that do not evidence the money. The pupil premium strategy statement on the site is the 2024/25 statement and carries no figures at all in the funding overview. The PE and sport premium report gives spend but omits the three swimming and water safety percentages that the conditions of grant require every primary to publish. Both are the statements most likely to be read by someone checking whether public money was accounted for.
  4. 4Three items not published, and a website that leaks data. The admission appeals timetable, the equality objectives and the phonics scheme statement were not located anywhere on the site. Separately, the site loads Google Analytics before any consent is sought and no cookie banner exists, no privacy notice could be found, and the accessibility statement omits its compliance status and the enforcement wording. This is the area with the widest exposure relative to the effort needed to fix it.

Prioritised recommendations

1
Adopt the drafted RSE right-to-withdraw clause and the drafted complaints timescales and stage 3 panel section. These two gaps carry the clearest route from a parental dispute to a formal escalation, and both drafts are included in this pack ready to paste.
Owner: Ms Priya Raman Timeframe: Before the autumn term
2
Turn off Google Analytics or place a compliant consent banner in front of it, and publish a privacy notice. Analytics cookies set before consent engage PECR regulation 6 and the UK GDPR transparency duties, and this is live on the site today.
Owner: Trust data protection officer Timeframe: This month
3
Republish the safeguarding policy against KCSIE 2025, including the Annex A staff declaration and Part 1 references, and name a deputy DSL with a contact route. Mrs Helen Doyle is currently the only named safeguarding contact in the document.
Owner: Mrs Helen Doyle Timeframe: Before 1st September 2026
4
Publish the 2025/26 pupil premium strategy statement with the funding allocation and per-strand amounts stated, and add the three swimming and water safety percentages to the PE and sport premium report.
Owner: Ms Priya Raman Timeframe: By 31st December 2026
5
Publish the three missing items: the admission appeals timetable, a refreshed set of equality objectives with the date they were agreed, and the phonics scheme statement. Drafts for all three are included.
Owner: Mr Alan Whitcombe Timeframe: Next full governing board
6
Refresh the accessibility plan for 2026 to 2029 and add the arrangements for consulting parents of pupils with SEND to the SEND information report.
Owner: SENCO and Ms Priya Raman Timeframe: This academic year

Statutory publishing checklist

The twelve items a primary academy must publish on its website. This is the same ground the free automated scan covers, reproduced here so the board can see presence and absence at a glance. Everything after this section is content review, which the free scan does not attempt. Links are inert in this sample; in the real report each links to the school's own published document.

ItemStatutory sourceStatusPublished documentNote
Admission arrangements School Admissions Code FOUND harebellprimary.org.uk/policies/admissions-2026-27.pdf Determined arrangements for 2026/27 published with the oversubscription criteria and the PAN of 30. Current.
Admission appeals timetable School Admissions Appeals Code NOT FOUND Not located No appeals timetable published. As its own admission authority the academy must publish one by 28th February each year.
Safeguarding and child protection KCSIE 2025 FOUND, ISSUES harebellprimary.org.uk/policies/safeguarding.pdf Published and substantial. Cites KCSIE 2024 as current; no deputy DSL named. See deep dive.
Relationships education (RSE/RSHE) RSE Regulations 2019 FOUND, ISSUES harebellprimary.org.uk/policies/rshe-policy.pdf Policy exists and is school-specific, but carries no right-to-withdraw statement. See deep dive.
Phonics scheme statement What academies must publish online NOT FOUND Not located The curriculum page names the scheme in passing within a Year 1 overview, but no phonics statement is published as a discrete item.
SEND information report Children and Families Act 2014 s.69 FOUND, ISSUES harebellprimary.org.uk/send/information-report.pdf Clear and recent. Missing the arrangements for consulting parents. See deep dive.
Accessibility plan Equality Act 2010 Sch 10 FOUND, EXPIRED harebellprimary.org.uk/policies/accessibility-plan-2021-24.pdf Covers 2021 to 2024. The plan has lapsed and must be reviewed at least every three years.
Equality objectives Equality Act 2010 specific duties NOT FOUND Not located An equality statement is published, but no specific and measurable objectives with the date they were agreed. Objectives must be republished at least every four years.
Pupil premium strategy statement Funding agreement / DfE conditions FOUND, ISSUES harebellprimary.org.uk/key-info/pupil-premium-2024-25.pdf Last academic year, and no amounts stated. See deep dive.
PE and sport premium PE & sport premium conditions of grant FOUND, ISSUES harebellprimary.org.uk/key-info/pe-sport-premium-2025-26.pdf Current year and gives amounts, but omits the three swimming and water safety percentages.
Complaints procedure Independent School Standards FOUND, ISSUES harebellprimary.org.uk/policies/complaints.pdf Published and easy to find, but no timescales and no stage 3 panel. See deep dive.
Attendance policy Working together to improve school attendance (Aug 2024) FOUND harebellprimary.org.uk/policies/attendance.pdf Adopted September 2025 and correctly built on the August 2024 guidance, including the support-first expectations and the attendance and absence codes.

Found: 9 of 12. The three not located are the admission appeals timetable, the equality objectives and the phonics scheme statement. A drafted starting point for each is included in the drafts pack below.

Per-policy deep dive

This is the part a title-matching scan cannot do. Each policy below was read end to end against a rubric built from the statutory source named on it. Every finding quotes the passage it rests on, so that a governor can check our reading against the document in front of them. Verdicts are PRESENT, PARTIAL or ABSENT, and severity is either MUST (a statutory requirement) or SHOULD (expected practice, including currency of citations).

Safeguarding and Child Protection Policy Reviewed against KCSIE 2025 · harebellprimary.org.uk/policies/safeguarding.pdf Must failures: 3 · Currency failures: 2

Safeguarding and Child Protection Policy REVIEWED

14 of 19 must elements present

A 41-page, school-specific policy approved by the local governing board in October 2025. It is well above the standard we usually see at this size of school: low-level concerns, allegations against staff, the local authority designated officer route, filtering and monitoring, and children who are absent from education are all covered with real detail rather than template text. Two things let it down. It is built on, and repeatedly cites, Keeping Children Safe in Education 2024, which was superseded on 1st September 2025. And although Mrs Helen Doyle is named as DSL with a direct contact route, no deputy DSL is named anywhere in the document, so the policy does not say who acts when she is off site.

Risk flags raised
  • For review with your governance/legal adviser The policy names KCSIE 2024 as the guidance it is written against, including in the Annex A declaration staff sign. Worth confirming whether staff have been asked to acknowledge the 2025 edition, since Part 1 is the part the declaration covers.
  • For review with your governance/legal adviser With no deputy DSL named, cover arrangements rest on custom rather than on the published policy. KCSIE expects the deputy arrangements to be set out in the policy itself.
Element / checkVerdictEvidenceNote
The policy is written against the current edition of Keeping Children Safe in Education and cites it accurately MUST ABSENT
“This policy has regard to the statutory guidance Keeping Children Safe in Education (September 2024) and should be read alongside it.”
KCSIE 2024 is cited as current in the opening statement and at eleven further points, including the Annex A staff declaration. KCSIE 2025 has applied since 1st September 2025. Replace every citation and re-issue the declaration.
The designated safeguarding lead is named, with a contact route MUST PRESENT
“The Designated Safeguarding Lead at Harebell Primary Academy is Mrs Helen Doyle, who can be contacted in person at the school office or by telephone during the school day.”
Named clearly on page 4 and repeated in the contacts annex. This is done well.
One or more deputy DSLs are named, and the policy sets out who acts in the DSL's absence MUST ABSENT
“In the absence of the DSL, concerns should be raised with a member of the senior leadership team without delay.”
No deputy DSL is named anywhere in the policy or the contacts annex. Pointing at the senior leadership team as a group does not tell staff or parents who holds the role. Name at least one trained deputy and give a contact route.
The policy states that all staff read Part 1 of KCSIE and that the school keeps a record of that MUST PARTIAL
“All staff are required to read Part One of the guidance on induction and annually thereafter.”
The requirement is stated, but the policy does not say the school records who has read it, and given the edition is cited as 2024 the annual acknowledgement now points at superseded text.
The policy covers additional barriers to recognising abuse in children with SEND and commits the DSL and SENCO to close liaison MUST PRESENT
“Children with special educational needs or disabilities can face additional safeguarding challenges, and the DSL and SENCO meet each half term to review concerns for these pupils.”
Handled properly, with a named cadence rather than a general aspiration.
The policy sets out the procedure for allegations and low-level concerns about adults working in the school MUST PRESENT
“Any concern about an adult which does not meet the harm threshold is recorded as a low-level concern and reviewed by the Headteacher for patterns over time.”
Both the harm-threshold route to the local authority designated officer and the low-level concerns route are described, with the pattern review made explicit. Strong.
The policy is reviewed and approved at least annually by the governing board, with the date shown SHOULD · currency PRESENT
“Approved by the Local Governing Board on 8 October 2025. Next review due: October 2026.”
Within cycle. The approval date is on the cover, which makes the 2024 citation more conspicuous rather than less.
Where an edition year is cited for supporting guidance, it reflects the current edition HIGH · currency ABSENT
“Staff should also refer to Working Together to Safeguard Children (2023) for the multi-agency framework.”
A superseded edition of the multi-agency guidance is cited as current. Refresh alongside the KCSIE citations so the whole reference set moves at once.
RSE / RSHE Policy Reviewed against RSE Regulations 2019 · harebellprimary.org.uk/policies/rshe-policy.pdf Must failures: 2 · Currency failures: 1

Relationships and Health Education Policy REVIEWED

9 of 12 must elements present

A readable, school-specific policy with a proper curriculum map by year group and a clear statement of how the school works with parents. The gap is a serious one for a document of this kind: the policy does not tell parents that they may request their child is withdrawn from sex education. For a primary school this is the element the statutory guidance is most explicit about, and it is the element parents look for. The policy also sets out its position on the year 2019 guidance without acknowledging the July 2025 update, which becomes mandatory from 1st September 2026.

Risk flags raised
  • For review with your governance/legal adviser With no right-to-withdraw statement published, a parent who wanted to exercise that right would have no route described to them. Worth confirming with your adviser how requests have been handled in practice, since practice and policy should say the same thing.
  • For review with your governance/legal adviser The policy is silent on the July 2025 RSHE guidance and the 1st September 2026 changeover. Worth putting the adoption date in the governance calendar now.
Element / checkVerdictEvidenceNote
The policy states the parental right to request withdrawal from sex education, and describes how to make the request MUST ABSENT
“We are confident that our programme is appropriate for all our families, and we encourage parents with any concerns to speak to the class teacher in the first instance.”
This is the closest the policy comes, and it is not a withdrawal statement. The policy must state that parents may request withdrawal from sex education other than that within the national curriculum for science, that the request is made in writing to the headteacher, and that a discussion follows. A drafted clause is included in the drafts pack.
The policy makes clear that there is no right to withdraw from relationships education or health education MUST ABSENT No passage on withdrawal was located in the document. The boundary matters as much as the right itself. Without it, a withdrawal request can be made and understood far more broadly than the law allows. The drafted clause covers both halves.
The policy is published and available free of charge to anyone who asks MUST PRESENT
“This policy is published on the school website and a paper copy is available from the school office on request, free of charge.”
Correct wording, correctly placed on page 2.
The policy describes how the school consulted parents in developing it, and how it will consult on review MUST PARTIAL
“Parents were invited to a curriculum evening in the spring term and were able to view the resources used in each year group.”
A real consultation event is described, which is more than most policies manage, but the policy does not say how parents will be consulted at the next review or how their views feed into the decision.
The policy sets out the content taught, by year group or phase MUST PRESENT
“Appendix 2 sets out, for each year group from Reception to Year 6, the units taught each half term and the key vocabulary introduced.”
Appendix 2 is genuinely good and is the reason parents can engage with this policy at all. Keep it when the policy is refreshed.
The policy reflects the edition of the DfE RSHE statutory guidance currently in force, and shows awareness of the July 2025 edition mandatory from 1st September 2026 HIGH · currency ABSENT
“This policy has been written in line with the DfE guidance Relationships Education, Relationships and Sex Education and Health Education (2019).”
The policy rests entirely on the 2019 edition, with no reference to the July 2025 update or the 1st September 2026 changeover. The refresh and the withdrawal clause should be done as one piece of work.
SEND Information Report Reviewed against Children and Families Act 2014 s.69 · harebellprimary.org.uk/send/information-report.pdf Must failures: 2 · Currency failures: 0

SEND Information Report REVIEWED

11 of 14 must elements present

Updated in September 2025 and written for parents rather than for inspectors, which is rarer than it should be. The identification process, the graduated approach and the support available are all described concretely, with named staff. Two required items are missing: the arrangements for consulting parents of pupils with SEND about the provision made for their children, and the route for complaints about SEND provision specifically. The local offer link is present and resolved correctly when checked on the report date.

Risk flags raised
  • For review with your governance/legal adviser The SEN Information Regulations require the report to set out the arrangements for consulting parents of children with SEND and for involving them in their child's education. This is absent, and it is the item most often raised when a SEND dispute escalates.
Element / checkVerdictEvidenceNote
The report sets out the arrangements for consulting parents of pupils with SEND and involving them in their child's education MUST ABSENT
“Parents are welcome to contact the SENCO at any point during the year to discuss their child's progress.”
An open-door statement is not the same as arrangements. The report should describe the structured points at which parents are consulted, for example the termly review meeting and the contribution parents make to the support plan, and who leads each. A drafted section is included.
The report sets out the arrangements for handling complaints from parents about SEND provision MUST ABSENT No SEND-specific complaints route was located in the report. The report should name the SEND complaints route and cross-refer to the school's complaints procedure, and give the local information, advice and support service contact. This connects to the complaints policy findings below.
The report names the SENCO and gives a contact route SHOULD PRESENT
“Our SENCO holds the National Award for SEN Coordination and can be contacted through the school office or by email.”
Present with the qualification stated. Adding the postholder's name would make it stronger.
The report describes how pupils with SEND are identified and assessed MUST PRESENT
“Where a pupil is making less progress than expected, we begin the assess, plan, do, review cycle with the class teacher and the SENCO, and we tell parents at the point the cycle starts.”
The graduated approach is described properly, and the commitment to tell parents at the start of the cycle is good practice.
The report links to the local authority local offer MUST PRESENT
“Information about the Lincolnshire local offer for children and young people with SEND is available on the county council website.”
Link present and resolved correctly when checked on 14th July 2026. Broken local offer links are one of the most common failures we find, so this is worth noting as a positive.
The report is reviewed at least annually, with the review date shown SHOULD · currency PRESENT
“Reviewed September 2025. Next review: September 2026.”
Within cycle and clearly dated.
Pupil Premium Strategy Statement Reviewed against the funding agreement and DfE conditions · harebellprimary.org.uk/key-info/pupil-premium-2024-25.pdf Must failures: 2 · Currency failures: 1

Pupil Premium Strategy Statement REVIEWED

6 of 10 must elements present

The statement published on the site is the 2024/25 one, and the 2025/26 statement was due by 31st December 2025. The strategy itself is thoughtful, and the challenges it identifies for disadvantaged pupils are specific to Harebell rather than lifted from a template. But the funding overview carries no figures at all, so a reader cannot see the allocation, what it was spent on, or whether the strands add up. Publishing amounts is the point of the statement.

Risk flags raised
  • For review with your governance/legal adviser A statement for the previous academic year is the live published version six months after the deadline for the current one. Worth confirming whether a 2025/26 statement exists internally and has simply not been uploaded.
  • For review with your governance/legal adviser With no amounts published, the statement does not evidence how the grant was used. This is the disclosure the conditions of grant exist to secure.
Element / checkVerdictEvidenceNote
The published statement covers the current academic year MUST ABSENT
“Pupil Premium Strategy Statement: Harebell Primary Academy. Academic year: 2024 to 2025.”
The 2025/26 statement was due by 31st December 2025 and no version for that year is published. Upload the current statement and archive this one rather than replacing it, so the three-year strategy history stays visible.
The statement states the pupil premium funding allocation for the year MUST ABSENT
“Pupil premium funding allocation this academic year: to be confirmed following the October census.”
The placeholder was never replaced, so the published statement gives no allocation. State the allocation figure and the number of eligible pupils.
The statement states the amount budgeted against each strand of activity MUST ABSENT
“Teaching priorities, targeted academic support and wider strategies are set out below with the intended outcomes for each.”
Each strand describes the activity and the intended outcome but carries no cost, so the strands cannot be reconciled to a total. Add a budgeted amount to each of the three strands and check they sum to the allocation.
The statement sets out the challenges faced by disadvantaged pupils at this school MUST PRESENT
“Challenge 3: attendance for our disadvantaged pupils was 3.1 percentage points below that of their peers across the previous two years, with lateness concentrated in two year groups.”
Specific, quantified and clearly about Harebell. This is the strongest part of the statement and should survive into the 2025/26 version.
The statement reviews the outcomes of the previous year's strategy SHOULD PARTIAL
“Our review of last year's strategy showed that the small-group phonics catch-up had the strongest effect on outcomes for our disadvantaged readers.”
A narrative review is given, but without figures against the outcomes originally stated, so the reader cannot tell whether the intended targets were met.
The statement is signed off and dated by the governing board SHOULD · currency PARTIAL
“Statement authorised by: the Local Governing Board. Date: December 2024.”
Dated but not attributed to a named signatory. Adding the chair's name and the meeting date makes the sign-off auditable.
Complaints Policy Reviewed against the Independent School Standards · harebellprimary.org.uk/policies/complaints.pdf Must failures: 2 · Currency failures: 0

Complaints Policy REVIEWED

7 of 11 must elements present

Published, easy to find from the homepage, and written in a tone that would not put a parent off using it. As a procedure, though, it stops short. It describes an informal stage and a formal stage to the headteacher and then ends, with no third stage before a panel and no deadlines anywhere in the document. The Education (Independent School Standards) Regulations, which apply to academies through the funding agreement, expect a three-stage procedure, a panel including a member independent of the management and running of the school, and published timescales at each stage. This is the most common single failure we see in academy complaints policies, and it is also the easiest to fix.

Risk flags raised
  • For review with your governance/legal adviser With no stage 3 panel described, a complainant who is dissatisfied at stage 2 has no published route inside the school, and would escalate to the trust or the Department for Education instead. Worth reviewing with your adviser whether the trust's model policy should be adopted here.
  • For review with your governance/legal adviser No timescales are stated at any stage, so the school cannot demonstrate that a complaint was handled promptly and a complainant cannot know when to expect a reply.
Element / checkVerdictEvidenceNote
The procedure sets out timescales for each stage, for both the complainant and the school MUST ABSENT
“The Headteacher will investigate the complaint and respond to you as soon as is reasonably practicable.”
No deadline is given at any stage of the procedure, and this is the only wording resembling one. The policy must state the period within which a complaint may be raised and the period within which the school will respond at each stage. A drafted timescales section is included.
The procedure includes a stage before a panel, with at least one panel member independent of the management and running of the school MUST ABSENT
“If you remain unhappy after the Headteacher has responded, you may write to the Chair of Governors, whose decision is final.”
The procedure ends with a single individual rather than a panel, and no independent member is contemplated. Add a stage 3 panel of three, including one member independent of the management and running of the school. A drafted section is included.
The procedure states that complaints are handled confidentially, with a stated exception for legal or inspection requirements MUST PRESENT
“Correspondence, statements and records relating to individual complaints are kept confidential except where access is requested by the Secretary of State or under inspection legislation.”
Correctly worded and correctly scoped.
The procedure states that a written record is kept of all complaints, including the stage reached and whether they were upheld MUST PARTIAL
“A record of formal complaints is maintained by the school office.”
The record is committed to, but the policy does not say that it captures the stage reached or the outcome, which is what the record is required to show.
The procedure is published on the school website MUST PRESENT
“This procedure is published on our website and a copy is available from the school office on request.”
Published and reachable in two clicks from the homepage, which is better than most.
The procedure distinguishes a concern raised informally from a formal complaint SHOULD PRESENT
“Most concerns are resolved quickly by speaking to the class teacher, and we would always encourage you to start there.”
Warm and clear. Keep this framing when the later stages are added.

Website compliance

A paid-tier section. The free scan tells you whether a document exists; this section is about the website that carries them, checked live on 14th July 2026. Two of these findings sit outside education law and inside data protection law, which is where the sharper exposure usually is.

Cookies and analytics ACTION NEEDED

0 of 3 checks passed

Google Analytics loads on every page of the site, including the homepage and the policies pages, and sets its cookies before any consent is requested. No cookie consent banner or preference control exists anywhere on the site. Under PECR regulation 6, non-essential cookies require consent before they are set, and analytics cookies are not exempt as strictly necessary. The transparency duties in the UK GDPR then require you to tell visitors what is collected and why, which brings us to the second finding.

Risk flags raised
  • PECR reg. 6 / UK GDPR Analytics cookies set on page load with no prior consent and no means of refusing them. The quickest compliant fix is to remove the analytics tag; the fuller fix is a consent banner that blocks the tag until consent is given. Both are within reach this month.
  • UK GDPR Art. 13 No privacy notice could be located anywhere on the site, including on the pages carrying the contact and admissions forms. Visitors submitting those forms are given no information about who controls their data, why it is collected, how long it is kept, or how to complain to the Information Commissioner's Office.

Accessibility statement PRESENT, INCOMPLETE

3 of 6 required elements present

A statement is published, which already puts Harebell ahead of many schools, and it correctly names the site it covers and gives a route for reporting problems. It stops short of the two things the statement exists to deliver: a compliance status, and the enforcement route. Note that this is the website accessibility statement, and is a different document from the Accessibility Plan required under Equality Act 2010 Schedule 10, which is covered in the checklist above and has lapsed.

Element / checkVerdictEvidenceNote
The statement gives a compliance status against WCAG 2.2 AA MUST ABSENT
“We want as many people as possible to be able to use this website, and we are working to make it as accessible as we can.”
An intention, not a status. The statement must say whether the site is fully compliant, partially compliant or non-compliant, and list the known non-accessible content.
The statement names the enforcement route to the Equality and Human Rights Commission and the Equality Advisory and Support Service MUST ABSENT No enforcement or escalation wording was located in the statement. The statement must tell a user who is unhappy with the school's response that they can contact the Equality Advisory and Support Service, and that the Equality and Human Rights Commission enforces the accessibility regulations. Drafted wording is included.
The statement gives a contact route for reporting accessibility problems MUST PRESENT
“If you find any problems or think we are not meeting accessibility requirements, please contact the school office and we will respond.”
Present and usable. Adding a response timescale would strengthen it.
The statement says when it was prepared and last reviewed SHOULD · currency PARTIAL
“This statement was prepared in March 2024.”
Prepared date given, no review date. Statements should be reviewed and the review date shown.

Technical accessibility basics PARTIAL

4 of 7 checks passed

A sample of eight pages was checked against the WCAG 2.2 AA basics that are cheap to fix and disproportionately affect keyboard and screen reader users. Colour contrast passed throughout and the policy PDFs carry document titles, which is more than we usually find. Three issues recur.

CheckVerdictDetailNote
Skip-to-content link present SHOULD ABSENT Not present on any of the 8 pages sampled. A keyboard user must tab through the full navigation on every page before reaching the content. One line of markup fixes this site-wide.
Every page has exactly one H1 SHOULD PARTIAL 3 of 8 pages sampled have no H1: the policies index, the key information page and the contact page. Screen reader users navigate by heading. Pages with no H1 give them no anchor. The pages affected are the ones carrying the statutory documents.
Images carry meaningful alternative text SHOULD PARTIAL 11 of 46 images sampled have empty or filename alt text. Mostly decorative gallery images, where empty alt text is correct. Four are informational, including the term-dates graphic, and need real descriptions.
Colour contrast meets AA SHOULD PASS No failures found across the sampled pages. Body text and link colours pass comfortably. No action.

Ready-to-adopt drafts

This is what the paid tier actually buys. For every must-level gap above we have drafted the wording that closes it, written against the statutory source named in the finding and in Harebell's own register rather than in template language. The drafts are yours to paste, edit and adopt. They are a starting point for your governance decision, not legal advice, and the board should read them before adoption in the ordinary way.

DraftClosesStatutory sourceLength
RSE right-to-withdraw clause 2 must failures in the RSHE policy RSE Regulations 2019 1 page, drop-in section
Complaints timescales and stage 3 panel 2 must failures in the complaints policy Independent School Standards 3 pages, replaces sections 4 to 6
Safeguarding citation and deputy DSL refresh 3 must failures in the safeguarding policy KCSIE 2025 Marked-up citation list plus a drafted deputy DSL section
SEND parental consultation arrangements 2 must failures in the SEND information report Children and Families Act 2014 s.69 1 page, drop-in section
Admission appeals timetable 1 not-published item School Admissions Appeals Code 1 page, dated for 2026/27
Equality objectives 1 not-published item Equality Act 2010 specific duties 2 pages, 4 drafted objectives to review
Accessibility statement completion 2 must failures on the website Accessibility regulations, EHRC and EASS route Compliance status and enforcement wording

Excerpt: RSE right-to-withdraw clause

Reproduced in full so you can see the standard of the drafting. Fill-in fields are shown in the form [SCHOOL NAME] and are pre-populated in the pack you receive. This clause closes both RSE must failures at once: it states the right, and it states its limits.

Section 9. Parental right to withdraw

At [SCHOOL NAME] we teach relationships education, health education and, as part of our wider curriculum, a small number of age-appropriate sex education lessons in [YEAR GROUP(S)]. We know that parents and carers hold the primary role in teaching their children about relationships and growing up, and this section explains your rights.

9.1 What you may withdraw your child from

You have the right to request that your child is withdrawn from some or all of the sex education delivered as part of our relationships and sex education programme, other than the elements that form part of the national curriculum for science. The science curriculum includes, for example, the life cycles of humans and animals and the changes experienced in puberty, and there is no right of withdrawal from those lessons.

9.2 What you may not withdraw your child from

There is no right to withdraw your child from relationships education or from health education. These subjects are compulsory for all primary-aged pupils and cover the friendships, families, respect, online safety and physical and mental wellbeing content that we consider essential to keeping our children safe and well.

9.3 How to make a request

A request should be made in writing to the Headteacher, [HEADTEACHER NAME], at [SCHOOL EMAIL], and should name your child, their class, and the lessons you wish them to be withdrawn from. Before the request is granted, the Headteacher will invite you to a meeting to discuss it. The purpose of the meeting is not to persuade you to change your mind. It is to make sure you have seen the materials we use, to understand what you would like your child to learn instead, and to talk through any effect withdrawal may have, including on your child's sense of inclusion among their classmates.

Except in exceptional circumstances, [SCHOOL NAME] will respect your request and will grant it for the relevant lessons up to the end of your child's time at this school, unless you tell us otherwise. Where a child is withdrawn, we will provide purposeful alternative work and appropriate supervision for the duration of those lessons.

9.4 Records

A written record of the request, the discussion held and the decision made will be kept in the child's file, and the class teacher will be told which lessons the child is not attending. The record is reviewed at the start of each academic year.

9.5 Who to contact

If you would like to discuss any part of this policy or to see the materials we use before deciding, please contact [RSHE LEAD NAME] at [SCHOOL EMAIL] or through the school office. Copies of the resources used in every year group are available to view by arrangement at any point in the year.

Drafted against: the Relationships Education, Relationships and Sex Education and Health Education (England) Regulations 2019 and the accompanying DfE statutory guidance. Replaces: nothing (the current policy has no withdrawal section). Recommended adoption route: local governing board, with the wider RSHE refresh for the July 2025 guidance, before 1st September 2026. This draft is a starting point for your governance decision and is not legal advice.

Excerpt: complaints timescales

A shorter extract from the second draft, showing the deadlines the current policy lacks. The full draft also supplies the stage 3 panel constitution and the independent member requirement.

Section 5. Timescales

We aim to resolve every concern as quickly as we can, and the deadlines below tell you what to expect at each stage. Where we cannot meet a deadline, we will write to you before it passes, explain why, and give you a new date.

Raising a complaint. A formal complaint should normally be raised within three months of the event complained about, or within three months of the last of a series of connected events. We may consider a complaint raised later than this where there is a good reason, and we will tell you in writing if we decide not to.

Stage 1, informal. The member of staff you contact will respond within five school days.

Stage 2, formal, to the Headteacher. Write to [HEADTEACHER NAME] at [SCHOOL EMAIL]. We will acknowledge your complaint within five school days and send you a written outcome within fifteen school days of the acknowledgement.

Stage 3, panel hearing. If you are dissatisfied with the stage 2 outcome, write to the Clerk within ten school days of receiving it. The Clerk will acknowledge within five school days and convene a panel hearing within twenty school days of your request. The panel will include three members, at least one of whom is independent of the management and running of [SCHOOL NAME]. You may attend and be accompanied. The panel's findings and recommendations will be sent to you in writing within ten school days of the hearing, and a copy will be available for inspection on the school premises by the proprietor and the Headteacher.

Drafted against: the Education (Independent School Standards) Regulations, which apply to [SCHOOL NAME] through its funding agreement. Replaces: sections 4 to 6 of the current Complaints Policy and Procedure. Recommended adoption route: local governing board, this term. This draft is a starting point for your governance decision and is not legal advice.

What happens next

Nothing in this report requires a crisis meeting. It requires an afternoon, a governing board agenda item, and someone to press publish. Here is the order we suggest.

1
Read the drafts. Every must-level gap in this report has a drafted answer in the pack. Ms Priya Raman and Mrs Helen Doyle between them can review all seven in a single session.
Timeframe: This week
2
Take the two data-protection items straight to the trust. The analytics tag and the missing privacy notice sit with Brindle Heath Learning Trust's data protection officer rather than with the school, and they are live today. They do not need to wait for a board meeting.
Timeframe: This month
3
Put the RSHE policy, the complaints policy and the equality objectives on the next local governing board agenda for adoption. Mr Alan Whitcombe can take all three as one item, since the drafts are ready and the findings explain what changed and why.
Timeframe: Next full governing board
4
Diarise the two deadlines that are fixed rather than advisory: the 2025/26 pupil premium strategy statement, and the RSHE refresh against the July 2025 guidance which becomes mandatory on 1st September 2026.
Timeframe: Today
5
Re-run the review once the drafts are published. A second edition re-reads every document and shows the board what moved, which is the evidence trail an inspector or a trust audit committee actually wants.
Timeframe: After adoption
What is in the pack you receive
This report
The full statutory compliance review, as a web page and as a PDF for the board pack, with every finding evidenced and linked to the school's own published document.
Seven drafts
Editable documents, one per must-level gap, drafted against the statutory source named in the finding, with fill-in fields pre-populated from your school's register entry.
The checklist
The twelve must-publish items with their current status, as a one-page governance summary for the board.
Website findings
The cookies, privacy notice, accessibility statement and WCAG findings, written so they can be passed to a website supplier without translation.

Harebell Primary Academy is not an outlier. The gaps in this report are the gaps we find in most primary academies of this size, because they are administrative rather than cultural: a citation that moved, a clause that was never added, a statement that was never re-uploaded. What separates schools is not whether the gaps exist but whether anyone has read the documents closely enough to name them. That is the whole of what this report does, and the drafts are the part that makes the reading worth something.