Section 1. Summary on providing a credible plan to improve the regime for each child. Designated units for separated children were not organised well enough to provide them with an acceptable regime, including education and meaningful interaction with staff and peers. Senior management oversight at a national level lacked challenge, and we were surprised that in 2018–19 every one of the 346 requests to keep children separated for longer than 21 days was granted by the prison group director. 1.10 A basic requirement of leadership and management of separation is to understand what is being delivered on the ground, and to support staff in improving outcomes for separated children. This was undermined by a lack of accurate information locally and nationally; no accurate data were collated on how many children were separated, where they were separated, for how long, and how long they spent in their cell. This made it impossible for national leaders to monitor trends and act to improve practice. The lack of data also meant it was not possible to monitor disproportionality across any of the protected characteristics.2 1.11 We found many children in YOIs who were subject to unacceptably impoverished regimes. There was too little appreciation among staff at all levels of the negative effects of spending long periods locked in a cell without meaningful human interaction. As a consequence, too little was done too late to reintegrate children into a normal regime. The planning that did take place was undermined by poor delivery, particularly on normal residential units. 1.12 Many staff, managers and national leaders accepted the minimum entitlement of a regime for children – less than an hour out of their cell a day – despite this leaving little time for interaction with staff and peers, outside exercise, showering or phone calls. The current system of daily and weekly visits by managers, nurses and chaplains created an illusion of meaningful interaction and oversight, but in reality these checks were cursory and often did not happen at all. More importantly, despite significant investment of time and resources, the current system of rule 49 reviews, checks and safeguards had failed to prevent children receiving a harmful regime. 1.13 The current system of separation, with its roots in the adult estate, is unsuited to meeting the needs of children. We found there were fundamental flaws in leadership at a local and national level. There was no shared understanding of the aims of separation, how often it occurred and what support separated children should receive for the intervention to achieve these aims. Key safeguards, including health care, chaplaincy and prison group director authorisations, did not always take place, and most separated children did not have any opportunity for meaningful interaction with staff or other children. Key concern and recommendation to the Secretary of State for Justice 1.14 2 8 Key concern: The current arrangements for separating children in YOIs do not safeguard children’s well-being. Local and national leaders and managers have failed to prevent children from being subject to harmful regimes for extended periods of time. Oversight arrangements do not enable managers to know how many children are separated or for how long, or what interactions, education or health care input they have received. Safeguards for separated children involve a large number of cursory checks rather than meaningful and dynamic management. The grounds upon which discrimination is unlawful (Equality and Human Rights Commission, 2010). Separation of children in young offender institutions