What is student voice?
The view of the NASUWT
Student voice in practice: judging appropriateness
School councils/consulting pupils
Involving pupils in assessing their own work and setting future progress targets
Pupils supporting and working with one another
Lesson observations by pupils
Pupil involvement in staff recruitment
Pupils on interview panels
Pupils as associate governors
Advice
UNCRC Articles 3, 12, 28 and 29
 

What is student voice?

Policy approaches to student voice, particularly at national government level, have been influenced by the provisions of Article 12 of the United Nations Convention on the Rights of the Child (UNCRC). Article 12 of the UNCRC states that national governments shall:

‘assure to the child who is capable of forming his or her own views the right to express those views freely in all matters affecting the child, the views of the child being given due weight in accordance with the age and maturity of the child.’

The provisions of Article 12 have significant implications for schools, education and other services including family law and social and health care. The rationale for engaging in matters that affect them is that it helps pupils, both individually and collectively, to ensure that children’s and young people’s internationally recognised rights are respected and supports other important aspects of their physical, emotional, social and educational development. [1]

In England, Northern Ireland and Wales, the UNCRC is not incorporated into domestic law. However, the rights and obligations set out in the UNCRC are protected in these nations and must be taken into consideration when developing new policy and legislation.

The principles of the UNCRC therefore guide domestic law and practice and are often referred to by courts when interpreting obligations under human rights and other legislation.

Evidence confirms that education and children’s services policy makers and practitioners widely support the principle of student voice. [2]

The view of the NASUWT

The NASUWT is clear that pupils should play an active and constructive role in their own learning, the learning of peers and the development of their school communities. This does, however, need to be balanced with appropriateness, something that the worked examples in this guidance will look at in more detail.

Teachers have always sought to ensure that pupils are able to articulate their views and participate effectively in their learning, as well as the wider life of their school communities. This has been a long-standing position held even prior to the introduction of the UNCRC and is a fundamental element of teachers’ professional practice. It also recognises that teachers’ ability to motivate pupils to learn partly depends on the extent to which pupils can be supported to engage in and take responsibility for their own learning.

Protecting and enhancing the rights of children and young people to be heard and participate meaningfully in debates that affect their lives is a key duty of the state in a democratic society. It is therefore a particularly important principle in the context of the state’s responsibilities for ensuring universal access to a well-funded and high-quality education.

The NASUWT believes there are eight basic principles that should be reflected in the development of student voice policy and practice at school level to ensure that student voice is effective and supported by the whole school community.

Principle 1	Student voice activities should make a positive and demonstrable contribution to the life of the school
Principle 2	Student voice activities must not undermine teachers’ professional authority and must not compromise other fundamental rights of children and young people
Principle 3	Student voice and respect of the UNCRC is not and must never be mutually exclusive from a school’s ability to secure and maintain positive pupil behaviour
Principle 4	Student voice activities should be part of a system that values and respects the views of all members of the school community, including staff
Principle 5	Policies and practices on student voice must reflect the capacity of pupils to participate in particular activities and the extent to which they can reasonably be held to account for the results of their actions
Principle 6	Student voice activities and policies must be consistent with, and support work to promote, equality and diversity, while tackling discrimination and prejudice
Principle 7	Approaches to student voice must be inclusive and give all pupils an opportunity to participate
Principle 8	Student voice activities must not add to teacher and headteacher workload or school-level bureaucratic burdens

This guide will now explore each of these eight principles in more detail.

Principle 1 – Student voice activities should make a positive and demonstrable contribution to the life of the school

The NASUWT asserts that student voice is most effective where it encourages pupils to become involved in projects and activities that enable them to enact genuine change within their schools. This is also true of change in their communities, or the wider world.

Student voice activities should be viewed a holistic part of learning and developing, rather than simply an exercise which enables a school to comply with external requirements.

Examples of positive and meaningful student voice activities could therefore include:

• redeveloping school uniforms;

• setting up and running recycling initiatives;

• designation and redevelopment of physical equipment or recreational areas;

• involvement in community projects such as working with charities or organisations that support the most vulnerable in society;

• developing and maintaining global links.

Activities such as these enable students to take responsibility for their learning while developing important skills such as problem solving, negotiating, fundraising and project management. Through these initiatives, students recognise the symbiotic relationship between the rights they can exercise and the responsibilities that they have.

Where student voice activities allow students to see the positive impact of their actions, this links to the NASUWT’s long-standing view that effective curriculum, which includes student voice activities, should start from the needs of the child. It should address both their learning and development needs, while giving them a sense of agency.

Student voice activities that make a demonstrable contribution to the life of the school also help learners to become confident and successful, while equipping them to make a positive contribution to society.

This is explored more in the NASUWT’s ten fundamental principles of effective curricular provision.

Principle 2 – Student voice activities must not undermine teachers’ professional authority and must not compromise other fundamental rights of children and young people

The NASUWT indisputably recognises the absolute right of all children and young people, set out in Articles 28 and 29 of the UNCRC, to access educational provision that develops their personalities, talents, and mental and physical abilities to the fullest possible extent.

Securing this universal entitlement creates complex and wide-ranging responsibilities for schools for which they are legally accountable. If pupils’ educational rights and entitlements under the UNCRC are to be upheld in practice, the ways in which relationships between teachers and pupils are established and sustained are of critical importance.

Student voice and pupil participation must not impact on the ability of teachers and headteachers to discharge their responsibilities to secure the rights of pupils to a high-quality education. This aligns with the requirements set out in Article 3 of the UNCRC, that ‘in all actions concerning children…the best interests of the child shall be a primary consideration’.

Taking this into account, a key measure to assess the appropriateness and acceptability of any student voice initiative involves consideration of the extent to which teachers’ professional authority is supported or, inversely, undermined.

Any student voice practice that is used to make judgements about a teacher’s professionalism has the potential to undermine teachers’ professional authority and is therefore wholly unacceptable.

The NASUWT has received examples of schools using student voice to question teachers’ capabilities. Not only is this unacceptable employment practice, it is likely to create suspicion and resistance and undermine any benefits of student voice.

Principle 3 – Student voice and respect of the UNCRC is not and must never be mutually exclusive from a school’s ability to secure and maintain positive pupil behaviour

The relationship between professional and institutional authority and pupils’ rights is well recognised and was documented as far back as 1989 when it was explored in the Elton Report on Discipline in Schools [3]. Powers such as commissioning searches of pupils, to discipline, detain and exclude pupils, as well as the authority to restrain violent pupils, are founded upon the concept of professional and institutional authority.

The authority of teachers is important ‘for the purpose of securing [pupils’] education and well being and that of other pupils in the school and ensuring that they abide by the rules of conduct set by the school’ [4].

This view of authority is consistent with purposeful approaches to student voice and pupil participation that ensures the views and opinions of all pupils are heard and taken account of in decisions that affect their lives in schools, including their own and other pupils’ behaviour.

This concept is reflected in the NASUWT’s statement of principles for behaviour management. The primary purpose of behavioural policies and procedures should be to create and maintain a learning environment where all pupils and staff are respected, all pupils can achieve and succeed, and all teachers can teach effectively.

The NASUWT asserts that teachers cannot teach and pupils cannot learn in an environment where there is disruption and violence. Being in this environment will diminish a pupil’s right to a high-quality education and one which allows them to develop to their full potential, as set out in Articles 28 and 29 of the UNCRC.

Principle 4 – Student voice activities should be part of a system that values and respects the views of all members of the school community, including staff

Student voice can and should be an effective method of gathering feedback from pupils, including identifying their concerns and interests. Carried out correctly, it should offer opportunities for pupils to feel they are able to engage with and influence developments within their school and the wider school community.

Student voice must be part of a whole-school approach that values and encourages the contributions of all members of the school community, including teachers. The NASUWT believes that student voice can only be effective if a school develops and embeds mechanisms for ensuring all members of the school community are able to express their views and ideas. This has to be within an open and positive environment that welcomes constructive feedback.

While student voice activities should help a school to take better account of student views, the NASUWT has evidence of this feedback then being used to make judgements about the quality of teaching. This is a clear abuse of both staff and student trust. It highlights the need for schools to ensure that the relationship between the senior management team and the structures and activities to promote pupil participation is robust, clearly planned and transparent.

Principle 5 – Policies and practices on student voice must reflect the capacity of pupils to participate in particular activities and the extent to which they can reasonably be held to account for the results of their actions

Students should be encouraged to explore, develop and participate in school life as well as in the life of the wider school community. There is strong evidence that students who share a strong and positive affinity with their school are likely to be better motivated to learn [5]. For example, students may be encouraged to take on responsibilities such as being a school prefect or monitor.

While schools will want to encourage students to take greater ownership and responsibility for aspects of school life, there are a number of school-level roles, responsibilities and tasks that should not be undertaken by pupils. Article 12 of the UNCRC implies that students should not undertake activities that require professional skills and expertise. These should only be undertaken by qualified and skilled persons who are accountable for their decisions and actions through their status as employees or governors.

To apply this principle, a judgement has to be made about whether a specific activity or responsibility can be allocated to pupils. While this may require assessment of the factors relating to a specific case, the description of typical student voice activities explored later in this guidance may be applied to form a judgement about the appropriateness or otherwise of a particular practice.

Principle 6 – Student voice activities and policies must be consistent with, and support work to promote, equality and diversity, while tackling discrimination and prejudice

Schools have a legal duty to promote equality [6]. Tackling discrimination and prejudice, promoting equality and fostering good relations should therefore be embedded within all aspects of school life. This includes activities related to pupil participation and student voice. It is vital that approaches to student voice recognise and progress equality, anti-discrimination and inclusion within schools.

The NASUWT believes there must be an explicit expectation within school-level approaches to student voice and pupil participation that the expression of prejudiced or discriminatory views and opinions by pupils is neither acceptable nor tolerable and will be tackled proactively. Not only is this ethically, morally and legally correct, Articles 13 and 14 of the UNCRC infer that a child’s right to freedom of expression and freedom of thought, conscience and religion is subject to limitations prescribed by law to respect the rights and freedoms of others.

The Union cannot, and will not, support activities that purport to advance student voice but are potentially discriminatory.

There are many examples where student voice and equality policies work in synchronicity, with activities being used to challenge prejudice-related bullying and promote equality and diversity. These have included being alert in reporting incidents, peer mentoring, community action projects, and activities that foster a sense of teamwork and promote shared identity.

Principle 7 – Approaches to student voice must be inclusive and give all pupils an opportunity to participate

Student voice should enable students to respond to issues that can affect all students. It should also provide opportunities for students to take responsibility for themselves and others, develop an understanding of the relationship between rights and responsibilities, and develop skills in representing, negotiating and developing.

The NASUWT believes that all students should be encouraged to develop these skills as part of accessing a broad and balanced curriculum. Therefore, schools should develop strategies to encourage all students to become involved in student voice, rather than making activities available to a select few.

Research has identified the risk of poor practice where views that claim to be representative of the pupil population as a whole are, in effect, merely those expressed by a limited group of pupils who are willing or selected to engage in certain forms of student voice activity. [7] Such practice has the potential to be divisive and, in some instances, may lead to pupils becoming disengaged from learning or participating constructively in the wider life of the school.

Principle 8 – Student voice activities must not add to teacher and headteacher workload or school-level bureaucratic burdens

Approaches to student voice and pupil participation must not conflict with or work against efforts to address excessive teacher and headteacher workload and working hours. Where student voice policies are developed appropriately, they should contribute towards reducing bureaucratic burdens on teachers and headteachers and free them to focus on teaching and leading and managing teaching and learning.

Practices that are inconsistent with this key principle undermine the working conditions of teachers and headteachers. This threatens the provision of high-quality learning experiences for pupils given the distraction they can create from teachers' and headteachers’ core responsibilities.

Schools can utilise the services of outside organisations to support student voice activities. External expertise can enrich the quality of pupil participation while helping to ensure teachers and headteachers are able to concentrate on their core responsibilities.

Student voice in practice: judging appropriateness

There are a number of common approaches to the use of student voice in schools and the school community. The next section of this document outlines some of the ways the NASUWT understands student voice has been developed in schools. Each scenario is then tested against the eight principles.

School councils/consulting pupils

School councils are commonly the primary focus of student voice activities in schools. They can take a number of forms depending on the size of the school and the ages of the pupils involved. In some larger schools, they are often segmented by year group or class councils. They may also be through ad hoc ‘working groups’ of pupils to consider particular issues.

School councils can be an important means by which pupil participation can be secured. There is increasing evidence that they are able to play an important role in addressing key school-level issues. [8] This includes tackling bullying, poor behaviour and the improvement of facilities for pupils.

In addition, many schools engage pupils in consultation activities to explore matters affecting their learning in the classroom and on whole-school activities. They could also look at specific issues such as school transport and healthy eating. These consultations might include surveys, discussion groups, circle time sessions or interviews with pupils.

As with school councils, when undertaken appropriately, pupil consultation exercises can be an effective way to seek the views of pupils on issues that are affecting or concerning them.

The NASUWT believes that provided school councils and comparable approaches are developed in line with the guiding principles, they can be an effective method of engaging student voice.

Principles into practice - example 1

A primary school developed year action groups. Pupils were encouraged to get involved and could choose to participate or not. Each year group was given £200 to spend on recreational activities for their break times. A Year 6 action group decided to spend the money on football and netball equipment. The pupils are expected to take care of the equipment. Teachers have reported that pupils are using their break times more effectively, have taken pride in the choices they have made, and are acting responsibly with the equipment as they were involved in the purchasing decision.

The NASUWT is concerned that issues can and have developed in schools when the principles are not applied.

For example, issues have arisen over the extent to which pupils serving on school councils are able to reflect accurately the views of all their peers.

Similarly, if changes to school-level policies and practices are being contemplated as a result of the findings of a consultative exercise, these will be less valid and reliable if the sample of students does not reflect the whole student body. These clearly contradict the principles set out in this guidance.

Looking specifically at the principle of student voice activities not adding to teacher and headteacher workload, the management and administration of school councils or other pupil consultation exercises should be undertaken by appropriately qualified support staff rather than teachers.

Involving pupils in assessing their own work and setting future progress targets

The NASUWT and our members have seen a greater emphasis on approaches to teaching and learning that involve pupils more actively in assessing their own progress and setting future learning targets.

The NASUWT believes that such policies can only be effective if they involve embedding approaches to teaching and learning that encourage learners to take greater responsibility for their own progress and achievements. It is also important that this gives them the skills and experiences necessary to develop the ability to learn with greater independence.

Where pupils are engaged in setting their own learning goals and targets, approaches to pupil participation and student voice can often be a powerful and effective way of developing learner independence.

However, the NASUWT remains unequivocal in its stance that such practices should not be developed or implemented in a way that works against the ability of teachers to take effective decisions about appropriate teaching and learning strategies.

In addition, some approaches that seek to involve pupils more actively in the assessment of their progress and the setting of future targets may create unnecessary workload pressures. Schools must ensure that the development of such activities does not impact on the efforts to tackle teacher and headteacher workload and to reduce excessive working hours.

The example below is a positive illustration of how this can be put into practice, while adhering to the principles of student voice.

Principles into practice - example 2

Year 10 RE students were asked to complete a sample GCSE examination question following the end of a topic on Christian and Muslim views on the sanctity of life.

Students were then taken through the mark scheme for the questions, highlighting what they believe were the key indicators to gaining each grade. They were then asked to peer assess each other’s work, including two positive targets about the work and one suggestion for how the work could be improved in the future.

The students’ answers were then marked by the teacher, comparing the marks given by other students in the peer assessment. This allowed the teacher to consider whether students had understood the mark scheme effectively and could accurately assess the triggers for moving to a higher grade.

This lesson also provided students with an opportunity to understand more about examination techniques, as well as setting their own targets for future work.

Pupils supporting and working with one another

A powerful and effective way to develop pupil participation involves pupils supporting and working with other pupils. This can take the form of peer support, where older children support younger children. Activities could include listening to them read and the provision of informal pastoral care or more formalised peer mentoring and mediation where young people are properly trained to help other pupils to find positive solutions to disagreements and conflict.

When implemented sensitively and thoughtfully, pupil-to-pupil approaches to student voice have the potential to make a significant and positive impact on the quality of pupil behaviour. This approach can also positively influence social interaction within schools, while supporting and improving pupil wellbeing.

To make this truly effective, pupils must still be able to access and benefit from appropriate adult support where necessary.

Pupil-to-pupil input should be implemented in a way that is consistent with other whole-school policies, including behaviour and attendance policies, which seek to address similar concerns.

It is extremely important to consider the use of external sources of expertise and support to establish and develop pupil-to-pupil approaches to student voice. This can ensure teachers and headteachers are not allocated duties that other members of the wider children’s workforce are more suitably qualified and experienced and can focus on their core responsibilities.

Principles in practice - example 3

A secondary school set up a community action project. As part of this, a number of sixth-form students developed a series of performing arts activities for younger pupils. These were designed to tackle the positive perceptions that some children had about gang and knife-crime violence. This enabled students to develop their team-building skills and also offered younger students the opportunity to see positive older role models acting constructively. In addition, they developed an understanding about a key issue facing members of their community.

Lesson observations by pupils

The NASUWT has become aware of a number of schools using the observation of lessons by pupils as a means by which judgements can be made about the quality of teaching and learning. This is in regard to individual teachers, the engagement of other pupils, or more generally across the school. It would appear some schools have taken the step of offering training to individual pupils for this purpose.

The NASUWT is deeply concerned about this practice.

Lesson observations should only be undertaken by adults who are suitably qualified. Views about the quality of professional practice should only be made by teachers who have Qualified Teacher Status (QTS).

Inciting formal student observation of teachers’ practices undermines key elements of the relationship between teachers and pupils by legitimising criticism of teachers.

The use of a recognised mechanism for pupil assessment of the quality of teaching and learning through evaluations of performance that are not based on professional knowledge and expertise could work to undermine pupils’ confidence in teachers’ capacity and capability. This will ultimately damage the effective working relationship between a teacher and their students.

Some schools would argue that conditions are put in place to ensure the views of pupils and their evaluation of teachers’ practice remain confidential. However, pupils cannot be held accountable for violating any such provision, which means teachers cannot be assured that pupil reviewers’ opinions of individual teachers will not be communicated more widely.

This does not mean that feedback should not be sought from pupils. An individual teacher should feel comfortable if they wish to use their own professional mechanisms to seek feedback from pupils in the classes and groups they have responsibility for. This could be for the purposes of their own professional reflection and to inform future curriculum plans and priorities. It also should not prevent the help and support students can give as trained peer mentors and reviewers to other pupils.

Pupil involvement in staff recruitment

It is common practice and widely accepted that recruitment procedures for teachers and headteachers will involve some element of direct work with pupils. This has involved headteachers visiting an applicant teacher’s school to observe them or it may include inviting applicants to plan and teach a lesson to a typical class or group of pupils in the school they have applied to work in.

The NASUWT understands why this is a common element of recruitment procedures. However, the Union is concerned about the growing evidence of recruitment processes that involve pupils giving feedback on the perceived quality of the lesson that has been taught.

The NASUWT does not believe it is appropriate for interview arrangements to involve seeking the views of pupils on the relative merits of an applicant’s teaching and other professional skills to inform recruitment decisions. This could have serious implications for a school if this process does not comply with equalities legislation.

We have also been made aware of a number of cases where candidates for interview have been given a tour by pupils, with these students subsequently canvassed for their opinions on the suitability of the applicant as part of the overall recruitment procedure. This is poor practice and must not be perpetuated.

Not only is it inappropriate for pupils to be involved in the recruitment process, it is also impossible to define the criteria that these opinions could be based on.

If this type of tour does take place, the NASUWT believes it should be an opportunity for candidates to develop an understanding of the school, allowing them to decide whether they wish to remain a firm candidate.

Communication with pupils during a tour should therefore be an opportunity to seek pupils’ views on the strengths and weaknesses of a school. Candidates who feel they are being assessed during a tour may feel unable to ask the questions they wish to, which diminishes their opportunity to evaluate whether the school is a good fit for them.

Pupils on interview panels

Linked to the issues concerning staff recruitment, but perhaps even more troubling, are the cases of pupils participating on interview panels for teachers and headteachers, either as panel members or as ‘consultants’.

Under no circumstances does the NASUWT accept this as appropriate practice.

Membership of an appointment panel carries significant and legal responsibilities in terms of fairness, equality, safeguarding and child protection. It also must ensure the overall effectiveness of the school team.

The appointment of staff is a serious and important undertaking. It is vital that the school has the ability to appoint the best person for the job.

It is also important that all candidates are treated fairly and the person who is appointed to the post can be confident in their new role and given the best grounding to perform well. Part of this confidence will rely on the ability to establish an appropriate level of rapport with pupils and to feel empowered to act with authority. This could be placed in jeopardy if pupils are involved directly in the recruitment process and appointment decision.

It is good practice that all members of an appointment panel have been trained to undertake the role effectively and are accountable for the decisions they make. This is not only accountability to the school, but could potentially include a requirement to defend an appointment decision in court or an employment tribunal.

Taking this into account, it is not only inappropriate but also unfair to expect pupils to share this level of responsibility and accountability.

It is wholly unreasonable to place pupils in situations where they are given responsibilities that they may not be able to fully appreciate and could have serious implications if not undertaken effectively.

Pupils as associate governors

Contact between pupils and governors can form an effective part of student voice and pupil participation. For example, members of a school council may be asked or seek to attend a meeting of governors to give feedback on their activities or to discuss future plans. This could be a regular item on a governing body agenda.

In Wales, school councils are able to nominate up to two of their members from Years 11, 12 or 13 to serve on governing bodies as associate pupil governors. [9] In England, school governing bodies are able, if they choose, to nominate pupils to act as associate members. [10] Associate members may attend full governing body meetings, but they do not have a vote in governing body decisions.

There are potentially serious implications for both staff and pupils if the engagement of pupil governors in the activities of the governing body is not considered carefully and managed appropriately.

It is important to note that governing bodies may exclude pupil governors from any governing body discussion relating to issues such as:

• staff appointment, staff pay, staff discipline, performance management of staff, grievances submitted by staff, or dismissal of staff;

• admissions;

• individual pupil discipline;

• election, appointment and removal of governors;

• the budget and financial commitments of the governing body; or

• any other matter that the governing body believes should remain confidential to full members.

It is concerning that the governing body’s powers of exclusion are discretionary. The NASUWT feels there is a risk of involving pupils in the formulation of decisions by governing bodies that present a conflict of interest for the pupils concerned. For example, it would not be reasonable to expect some pupils to be impartial about individual pupils who may be the subject of a governing body determination, particularly if they have a personal history, friendship or conflict with them.

In regard to staffing issues, it may be that a pupil governor is not excluded from a discussion that could have a direct bearing on the terms and conditions of employment of individual staff members. This might involve the disclosure of information that could undermine the continuation of an appropriate and productive pedagogical relationship between pupils and teachers and other members of staff. This would be potentially highly problematic.

The NASUWT therefore believes that governing bodies should always use their powers to exclude pupil governors when the issues listed above are being discussed. Staff governors should ensure that pupil governors are not invited to attend sections of governing body meetings where issues of the type described above are being discussed.

Advice

The NASUWT would advise all school leader members to evaluate existing or new policies against the eight principles identified in this guidance.

Securing effective practice in student voice should involve consulting and seeking to agree student voice policies with the NASUWT and other school workforce trade unions.

NASUWT Workplace Representatives have a key role in seeking to ensure the eight key principles set out in this guidance are applied in the assessment of any student voice proposals. They should also ensure that appropriate representations are made to school management and governors or any proposed or existing systems.

Individual teachers will need to be vigilant in safeguarding their own professionalism. They should question and resist, with the support of the Union, practices that do not align with the NASUWT’s principles.

If you believe it is not possible to secure appropriate approaches to student voice or pupil participation activities at school that are consistent with the NASUWT principles, you should contact the union for advice and guidance.

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Footnotes
[1] https://www.unicef.org.uk/rights-respecting-schools/the-rrsa/what-is-a-rights-respecting-school
[2] Halsey, K, Murfield, J, Harland, J L and Lord, P (2006) The Voice of Young People: An Engine for Improvement? Scoping the Evidence. York: National Foundation for Educational Research (pdf)
[3] http://www.educationengland.org.uk/documents/elton/elton1989.html
[4] Department of Education and Science and the Welsh Office (1989) Discipline in Schools: Report of the Committee Enquiry chaired by Lord Elton
[5] Ferreira, M (2011):  Motivation and Relationship of the Student with the School as Factors Involved in the Perceived Learning (pdf)
[6] England, Scotland and Wales: Equality Act 2010. Northern Ireland, Northern Ireland Act 1998, Section 75
[7] Fielding and Rudduck (2006) Student Voice and the Perils of Popularity
[8] M Taylor and R Johnson, (2002): School Councils and their Role in Citizenship and Personal and Social Education
[9] The School Councils (Wales) Regulations 2005
[10] School Governance (Roles, Procedures and Allowances) (England) Regulations 2013