Back in September, I asked the Independent Safeguarding Authority how it had arrived at the figure of 11.3 million adults who would need to be vetted before they could be allowed regular access to children (their own excluded, naturally).

My question was how was it calculated, what sources were used and whether there was a document anywhere that explains the process.
 
On September 18 a woman from the Vetting and Barring Scheme Information Team - I've got her name but it seems invidious to name her - said she had passed my query to somebody who knew the answer and promised a reply within ten working days. No sign of one yet, though.
 
Now the NHS has begun to look for answers, too. From November employers will be legally required to check whether staff are registered with the Independent Safeguarding Authority. But, reports Health Service Journal today, NHS managers simply don’t know when they will be expected to refer people to the ISA and how any information they provide will be interpreted.
 
Sian Thomas, director of NHS Employers, told HSJ: “There’s huge scope for confusion about what the actual purpose is, how it fits with regulation generally and how it fits with an overall strategy for public protection.”
 
Draft guidance from the ISA being circulated says employees should be referred if there is any presence of “an impulsive, chaotic, unstable lifestyle,” if a person has “elective links with antisocial peers and/or associates,” suffers “severe emotional loneliness,” or has “poor emotional arousal management skills”, whatever that means. Given the NHS employs 1.3 million people, you can see why Ms Thomas is worried.
 
There must be tens of thousands among them who could meet these elastic criteria: indeed, many artists, writers, scientists and musicians of the past would clearly need vetting if they were alive today and planned to visit any children or vulnerable adults. And plenty of doctors and teachers, too.
 
Harry Cayton, chief executive of the Council for Healthcare Regulatory Excellence, said: “Regulation should be proportionate and targeted. It should be transparent and fair. The general feeling is that ISA is none of those things ... how did we get ourselves into creating a new quango with this level of interference into people’s lives?”
 
Mr Cayton is worried because the ISA has the capacity to trump regulatory bodies such as the General Medical Council or the Nursing and Midwifery Council, for which he has responsibility. They may decide a transgression by a doctor or nurse does not justify striking off, only to find that the ISA disagrees and bars the individual concerned from working.
 
Dr Peter Carter, the chief executive of the Royal College of Nursing, told The Daily Telegraph earlier this month: “You’re talking about people’s livelihoods, people’s careers, and this is a paper-based exercise. Appeals can only be made on a point of fact or law.
 
“We can’t think of any other situation where someone could lose their livelihood and not have any right of representation. We think it’s contrary to the spirit of natural justice, and we do believe that it could be a breach of the European Convention on Human Rights.”
 
The actual statistics of this issue, and discovering how the ISA calculated its 11.3 million figure (now reduced to 9 million, according to press reports) are relatively minor considerations. But the fact that it is unable to answer the question is symptomatic of an ill thought-out scheme.