This paper examines perceptions of time and institutional support for decision making and staff confidence in the ultimate decisions made—examining differences and similarities between and within the service-oriented Nordic countries (represented by Norway and Finland) and the risk-oriented Anglo-American countries (represented by England and California). The study identifies a high degree of work pressure across all the countries, lines of predominantly vertical institutional support and relatively high confidence in decisions. Finland stands out with higher perceived work pressure and with a horizontal support line, whereas England stands out with workers having a lower degree of confidence in their own and others’ decisions.

This paper examines whether and how the views of professional decision makers in public agencies and courts in four child protection jurisdictions align with the views of the public. Democratic states are built on the foundation that state polices are accountable to, and represent, the citizens’ will. The extent to which this is the case in child protection is largely unknown. This study draws on survey vignette data collected from three samples (citizens, child protection staff and judiciary decision makers) representing society at large, the child welfare agency, and judicial systems in four jurisdictions - England, Finland, Norway, and the U.S. (California). Findings from this study suggest that there is a high degree of similarity across countries in the public's views about children's need for services, and the poor outcomes that may result absent a service response. Views between child protection professionals and the public diverge the most when considering if the child is suffering from neglect and the use of intrusive state interventions. Child protection staff and judges’ perspectives within each country are in general alignment and show the impact of the established systems on considerations. Our results may have implications for the design of social policy in the area of child protection internationally.

This international comparative paper examines how child protection workers in four countries, England, Finland, Norway, USA (CA), involve children in decision making regarding involuntary child removal. The analysis is based on 772 workers' responses to a vignette describing preparations for care order proceedings. We examine children's involvement along three dimensions including information given to the child, information gathered from the child, and opportunities for their perspectives and interests to be considered. Results show that child protection workers weigh children's involvement differently based upon age. Staff in the four countries were more likely to talk with an older child, to provide information, to gather information, and to include in relevant decision making if the child were 11 compared to five in our vignette. Although the Nordic countries and England provide policy guidance regarding children's role in child protection decision making, we did not see consistently higher indicators of children's involvement from the respondents in these countries. Using child protection system frames to analyze the findings did not produce consistent differences between the family service systems and child protection systems included in this study. Findings highlight the wide range in practices concerning children's involvement in decision making, and the wide space for professional discretion in implementing practice with children at the local level.

This paper compares how frontline staff in four national child welfare systems and policy contexts – Finland, Norway, England and the USA (specifically, California) – respond to questions about a scenario of possible harm to children. The countries have different child welfare systems that we anticipated would be reflected in the workers' responses (n = 1027). The analysis shows differences and similarities between the systems, although often not in line with system expectations. There is also variation within the country samples. The study shows the complex interactions of individual and agency characteristics in addition to the role of proceduralised decision-making systems and professional discretion. ‘Compares how frontline staff in four national child welfare systems and policy contexts.. respond to.. a scenario of possible harm to children’. Key Practitioner Messages: Professional discretion differs. Proceduralised and high threshold systems result in less variation between workers' responses. System categories do not seem to capture the nuances of frontline decision-making.

This article examines parents' involvement in care order decision-making in four countries at one particular point in the care order process, namely, when the child protection worker discusses with the parents his or her considerations regarding child removal. The countries represent different child welfare systems with Norway and Finland categorized as ‘family service systems’ and the USA as a ‘child protection system’, with England somewhere in between. The focus is on whether the forms and intensity of involvement are different in these four countries and whether the system orientation towards family services or child protection influences practice in the social welfare agencies with parents. Involvement is studied in terms of providing information to parents, collecting information from parents and ensuring inclusion in the decision-making processes. A vignette method is employed in a survey with 768 responses from child protection workers in four countries. The findings do not show a consistent pattern of difference regarding parental involvement in care order preparations that align with the type of child welfare system in which staff work. The goal in each child welfare system is to include parents, but the precise ways in which it is carried out (or not) vary. Methodological suggestions are given for further studies.

This paper presents the views of judicial decision-makers (n = 1794) in four child protection jurisdictions (England, Finland, Norway, and the USA (California)), about whether parents and children are provided with appropriate opportunities to participate in proceedings in their countries. Overall, the study found a high degree of agreement within and between the countries as regards the important conditions for parents’ and children´s involvement, although the four systems themselves are very different. There was less agreement about children’s involvement than parents’, and the court decision-makers from Norway and Finland were more likely to express doubts about this. Nevertheless, the main message from the judicial decision-makers is that they are relatively satisfied as to how parents’ and children´s involvement is handled in their countries. Whether or not this confidence is justified, the emphasis on achieving effective involvement of children and parents in court proceedings is likely to grow, with major implications for the workers, decision-makers and agencies involved.

This article compares blank care order application templates used in four countries (England, Finland, Norway, and USA (California)), treating them as a vital part of the ‘institutional scripts’ that shape practice, and embody state principles of child protection. The templates are used when child protection agencies apply to court for a care order, usually to remove a child from the family home. The templates prescribe and shape the type of information and analysis that is required justify such an extreme level of state intervention in family life. They are a mechanism and a manifestation of the principles and the legislation of each child welfare system, and are able to cast light on issues that might otherwise remain unseen or unnoticed in cross-country comparisons. The analysis of the documents compares the language and form of the four blank templates, their inter-textuality, their readership, and authors. The analysis highlights the discretionary space allocated to social workers across countries and the state frameworks within which child protection efforts are embedded.

Care orders within the child protection system are some of the most invasive interventions a state can make. This article examines the discretionary space governments set out for child protection workers when they prepare care orders. We analyse the formalized framework for these decisions in England, Finland, Norway and the United States. We focus on knowledge, timelines, how children and parents are involved and accountability. We find that Norway and Finland have highly de-regulated systems with wide discretionary space, whereas England and the United States are highly regulated systems with narrow discretionary space. The United States differentiates itself with relatively little parent and/or child involvement in decision-making. England and Finland do not have defined deadlines for terminating the process, and Norway has few directives on what information to collect. Such differences will influence the quality of decisions as well as the principles of the rule of law.

Child friendly justice and access to justice for children are explicit concerns for the European Union, the Committee on the Rights of the Child, the Council of Europe and the Child Rights International Network. This study examines court systems as child-responsive by eliciting the views of judicial decision makers on child protection cases (n = 1,479) in four legal systems (England, Finland, Norway and the usa (represented by California)), based on an online survey. In this paper, we asked judicial officials who have the authority to make care order decisions how they view the child-friendliness of the courts. We presented them with six statements representing standard features of child responsive courts. Findings show that there is considerable room for improving both structure and practice of the court proceedings, for example the use of child friendly language and child-sensitive time frames. There were variations across states, and some variation across type of decision maker. Implications for the development of education and training about the opportunities for children's engagement are considered.

The authors regret: On page 4, line number 47 it now reads “Ninety-eight (38%)…”, but is should read “One hundred and one (38%)…”. On page 4, line 48–50 it now reads “Of the total 1,020 informants …. 367 from Norway, 208 from Finland, 102 from England, and 84 from the US.”, but it should read “Of the total 1,027 informants …. 370 from Norway, 209 from Finland, 103 from England, and 90 from the US.” On page 6, table 1, there is an error in the title of the columns. It now is in the following order “Finland – Norway – England – US”, but the titles should have the following order “Finland – England – Norway – US”.  The authors would like to apologise for any inconvenience caused.