NHS Volunteering Guidance – Response from Attend

Dear NHS England Team

Thank you for sharing the draft guidance on volunteering partnerships within the NHS. We appreciate the work that has gone into producing a document that aims to support safe, effective and meaningful involvement of volunteers across health and care.

The feedback below is offered in the spirit of supporting the development of a concise, trusted document which is not overly onerous or prescriptive and also empowers independent volunteering organisations as partners. The feedback is specifically around “specific elements that are unclear or ambiguous”.

We write from the perspective of an independent network that has partnered with the NHS since its beginning. Our experience is that volunteering partnerships are one important expression of the wider relationship between the NHS and the communities it serves. This guidance therefore has an opportunity not only to support volunteering safely and effectively, but also to strengthen that wider relationship. Such partnerships succeed when they combine the complementary strengths of NHS services and independent organisations, and when the conditions for trust, mutuality and shared purpose are clearly established.

In our experience, local NHS organisations can sometimes misunderstand central guidance, or interpret it in ways that lead to a 'one size fits all' approach. Greater clarity in the guidance would help reduce these misunderstandings and avoid unnecessary barriers for independent volunteering organisations and local Friends groups specifically.

The message we received from Friends groups is that they can feel increasing attempts to control them by the host organisations, and a sense there is an underlying lack of trust and cynicism from hospital management, which can show little respect for all their loyalty and efforts over the decades.

Also, the perspective we give seeks to strengthen the guidance and bring it into closer alignment with the NHS Constitution’s principle that “the NHS belongs to the people.”

A further principle underpins our response. Long-established NHS indemnity and risk management guidance has recognised that effective partnership with independent organisations depends upon maintaining clear organisational responsibilities, governance and indemnity arrangements.

Partnership is strengthened not by blurring organisational boundaries, but by ensuring that each organisation remains accountable for its own governance, insurance and legal responsibilities while working collaboratively towards shared objectives. We believe this principle could be more clearly reflected throughout the draft guidance.

1. Definition and Scope of a Volunteer

There needs to be some clarity here.

There is a difference between the definition provided in section 1.3 of the guidance, and the reality of volunteering within independent volunteering groups and other un-paid placements. We have found this frequently causes misunderstandings, potentially resulting in upset and unnecessary blockages to community engagement with our member Friends groups.

Other unpaid contributors need to be acknowledged if this guidance is seeking to capture volunteering within the NHS rather than NHS organisations’ own centrally managed volunteering approaches and programmes. Examples include, fundraisers, supporters, Friends, students undertaking placements.

2. The current draft begins from governance rather than partnership

The draft is technically competent, but its early emphasis on governance, risk, liability, screening, supervision and escalation creates an atmosphere in which partnership is framed primarily as a matter of NHS assurance and control. The cumulative effect is to suggest that partnership is conditional on alignment with NHS governance and policy priorities, rather than beginning with recognition that independent organisations bring their own legitimate governance, experience and community relationships to a shared endeavour.

This is not a question of removing governance, but of where it sits. Effective partnership begins with shared purpose, identity, relationship, and conditions, and governance then becomes the structure that supports those relationships rather than defines them.
One possible sequence for effective partnership is:

• Purpose – Why are we here together?
• Identity – Who are we?
• Relationship – How will we work together?
• Conditions – What helps this partnership thrive?
• Governance – How do we hold it safely?
• Learning – How do we keep it alive?

Currently, beginning halfway down this sequence subtly communicates that partnership is something to be managed rather than something that creates value.
 
3. Independence needs explicit recognition

Independent organisations – particularly those in the VCSE sector – are not extensions of the NHS. They are independent institutions with their own charitable purposes, governance, accountabilities and relationships with the communities they serve. Their strengths often arise precisely from that independence.

Independent volunteering organisations are often highly experienced in managing volunteers, safeguarding, governance and risk in their own right. Effective partnerships recognise and build on this capability rather than assuming that all responsibility must sit with NHS organisations.

Maintaining this independence is also an important element of good governance. Effective partnerships rely on clear organisational boundaries, with each organisation retaining responsibility for its own governance, legal duties, insurance, volunteer management and decision-making. Blurring these boundaries can create unnecessary uncertainty over accountability, liability and risk, rather than strengthening assurance.

Partnership should therefore begin from an assumption of mutual legitimacy, rather than an assumption that independent organisations need to be incorporated into NHS governance arrangements before they can be trusted to contribute.

Partnership should therefore begin from an assumption of mutual legitimacy, rather than an assumption that independent organisations need to be incorporated into NHS governance arrangements before they can be trusted to contribute.

Friends groups are full of people who have been involved for many years. In fact, ‘decades’ would be more accurate. The Friends Voices website offers insight and many varied examples of this contribution https://friendsvoices.co.uk/

Friends groups represent a continuity of community memory that NHS organisations can find difficult to sustain. These trusted local relationships bring a sense of lived experience, adaptability, belonging and mutuality. The draft does not yet name these strengths clearly. Without this recognition, partnership risks being framed as alignment rather than complementarity.

A sentence would shift the philosophy:

The most effective partnerships do not seek to make organisations the same, or operate in the same way. They create the conditions in which different organisations can contribute their distinct strengths towards a shared purpose.

This sentence is faithful to the NHS Constitution, and it reflects the lived reality of volunteering partnerships across the country.

This also reflects long-established NHS indemnity principles. Effective partnership depends upon maintaining clear organisational boundaries, with each organisation retaining responsibility for its own governance, liabilities, insurance and volunteer management arrangements. Partnership agreements should define how organisations work together, rather than inadvertently transferring responsibilities that properly belong to one organisation or the other.
 
4. Proportionality should be strengthened

The draft mentions proportionality, but it could be used more deliberately. Independent organisations may legitimately prepare and support volunteers in different ways. The key question is whether arrangements are proportionate to the nature of the activity.

A clearer statement would help avoid unnecessary friction:

NHS organisations should satisfy themselves that arrangements are proportionate to the role and foreseeable risks, recognising that independent organisations may use different approaches to governance, organisational structures, volunteer management and risk assurance, including maintaining their own policies, insurance and risk registers.

This clarification would prevent many avoidable discussions.

For context, discussions we have been aware of, and asked to mediate in include:

(i) Insisting volunteers who support Friends groups in the community are DBS checked in case they enter hospital premises, when they are just helpers at a fête in a local community centre.

(ii) Friends group volunteers being asked to sign the host NHS organisation’s Code of Conduct and agree to be managed according to the central volunteering policies (including grievance and termination arrangement) before being allowed to volunteer in a Friends led-and-run service in the hospital. The Friends group clearly had their own Code of Conduct and relevant volunteering policies, as required by an independent charity

(iii) Who the independent volunteers technically volunteer for and what insurance they are covered by. This is where NHS management have taken on responsibility for recruiting, placing and supporting Friends group volunteers, for example.

(iv) The associated data management challenges relating to point (iii) above, where the Friends group had been asked to sign a data agreement to meet the hospital’s data management requirements, where in reality the arrangement should have been the other way around, and the hospital needed to demonstrate their own data management compliance to safeguard the Friends group volunteers’ personal data.

(v) Memorandums of Understanding being ‘imposed’ on Friends groups that do not reflect the legal and operational realities of how volunteering works in that setting.

(vi) Time hospitals take to resolve issues: Frequently it can be years, during which time Friend groups are forced to ‘hibernate’.

5. Trust, mutuality and shared purpose should be named

Volunteer partnerships work because of trust, openness and shared purpose. Rather than being “soft” concepts; they are operational strengths. The draft lists processes but does not yet name the relational qualities that make those processes effective.

A short addition would rebalance the tone:

Effective partnerships are built on mutual trust, openness and respect. Strong governance supports these relationships but does not replace them. It is important to apply governance with precision to avoid undermining them.

6. Community participation is broader than volunteering

Given the NHS Constitution, the guidance should acknowledge that volunteering partnerships are one of the ways people and communities participate in the NHS. They are important, but they sit within a broader ecology of community contribution.

As noted earlier, independent organisations and Friends groups are not simply providers of volunteers. They are independent community institutions that contribute to the NHS in a wide variety of ways. Alongside involving volunteers, they raise funds, advocate for services, represent local voices, preserve local heritage, convene community support, and build long-term relationships that strengthen trust between the NHS and the communities it serves. These wider roles are often closely interconnected and should not be separated artificially.

A suggested addition:

Volunteering partnerships are one of the ways people and communities participate in the NHS. Alongside fundraising, advocacy, community engagement and other forms of community contribution, they help ensure that the NHS remains connected to the communities it serves, reflecting the principle that the NHS belongs to the people.

7. A revised structure would create a more accessible and partnership-oriented document

Reordering the section would make the guidance more recognisably partnership based:

1. Shared purpose

2. Respecting independence

3. How we work together

4. Supporting volunteers

5. Proportionate governance

6. Learning together

This structure holds governance firmly, but within a climate of partnership rather than control.

Conclusion

The draft guidance is technically robust and addresses many important aspects of volunteering practice. However, its current structure places early emphasis on governance, assurance and alignment with NHS systems. While these are essential elements of successful partnerships, they are most effective when situated within a wider framework of shared purpose, mutual trust and respect for organisational independence.

We believe the guidance would be strengthened by:

• Clarifying the definition and scope of volunteering and recognising the wider range of unpaid contributors who support the NHS.

• Explicitly recognising the independence, expertise and legitimacy of voluntary, community and Friends organisations as partners in their own right.

• Strengthening the principle of proportionality so that governance and assurance arrangements reflect the nature and risks of the activity involved.

• Making trust, mutuality and shared purpose visible as foundational characteristics of effective partnerships.

• Acknowledging volunteering as one part of a broader ecosystem of community participation that helps realise the NHS Constitution's principle that the NHS belongs to the people.

• Reflecting more clearly the importance of maintaining distinct organisational responsibilities, governance arrangements, insurance and liabilities while working collaboratively towards shared objectives.

• Drawing on and signposting to established NHS Resolution guidance and longstanding NHS indemnity principles relating to partnership working with independent organisations, voluntary bodies and charities, ensuring the guidance builds on existing good practice and maintains clarity over accountability, governance and liability.

These adjustments would not weaken governance. Rather, they would help ensure that governance operates in service of strong partnerships, enabling NHS organisations and independent community partners to contribute their respective strengths safely, effectively and with mutual confidence.

Most importantly, they would reinforce a vision of volunteering partnerships that recognises independent organisations not simply as delivery mechanisms for volunteers, but as valued community institutions whose relationships, experience and local knowledge help strengthen the enduring connection between the NHS and the communities it serves.

We hope these reflections are helpful as the guidance is refined and would welcome the opportunity to discuss any of these points further.

Yours faithfully

David M Wood OBE BA AKC PCC CharteredFCPID MIWFM MCIOF
Chief Executive, Attend