While both England and Finland are states within the European Union (EU), they demonstrate distinct and differing approaches to the adoption of children. In Finland along with other countries in Scandinavia, child adoption and the permanent transfer of parental rights is less of a central a concern, or worry than currently so in England where child adoption is featured prominently across a range of professional, political and popular discourses. In terms of social work practice the involvement of children and families, coupled with certain factors of the adoption process have been handled in a distinctly different way between the two countries. This can be seen where in Finland adult adoptees were allowed to gain access to records regarding their adoption or their birth parents far earlier than their English counterparts where this was not permissible until much later earlier through the Children Act 1975 (Triseliotis, 1973, p. 1).

According to Lowe (2000) in the late-nineteenth century attempts were made to introduce adoption, but it was not until 1927, subsequent to the Adoption of Children Act 1926, that child adoption became legally recognised in England. Since then many factors including; reports, legislation and case law have all had an impact, this has resulted in refined policy and changes in social work practice. More recently media attention has illustrated social workers’ alleged shortcomings in relation to child adoption processes.

In recent years, adoption policy has been influenced by a number of socio-cultural and political factors. During the Conservative government of the 1990s politicians and policy makers made attempts ineffectively to restructure what were viewed as unsatisfactory adoption procedures (see PIU, 2000, p. 31). These services were impaired because social workers were driven by ‘political correctness’ (Hopton, 1997). The white paper Adoption: The Future was published In November 1993, representing a ‘common sense’ approach to adoption (Department of Health, 1993). In 1996, the DoH published a Draft Bill with an emphasis placed on child adoption as an alternative to single parenthood during the consultation period. The Bill failed to progress any further due to the General Election in May 1997. With a change in government, the then Prime Minister’s (Tony Blair) Review of Adoption was published in 2000 (PIU, 2000). Followed by a White Paper, Adoption: A New Approach (Department of Health, 2000), which was followed by the publication of the Adoption and Children Bill in 2001. The Bill failed to materialise due to the General Election later in the same year. It was however re-introduced in October 2001 and the Adoption and Children Act received royal assent in November 2002.

The first Adoption of Children Act in Finland was in 1925, a year earlier than the English equivalent. The present Finnish Adoption Act stems from 1985 followed by an additional Adoption ruling in 1997 which dealt specifically with adoption counselling and inter-country adoptions. Specific to Finnish adoption system is the role of Save the Children originally created in 1945 following the merging of two previous organisations (Homes for Homeless Children which were practicing adoption since 1922 and Save Finland’s Children, which was set up after the Second World War in an attempt to help orphaned children). This organisation is now part of the International Save the Children. Save the Children has had an influential position as a provider of adoption services in Finland. In addition to civic welfare bodies, Save the Children is still the only private child welfare organisation in Finland licensed to provide adoption counselling (Pylkkanen 1995)

In Finland, adoptions have dramatically changed during the last 30 years, in 1970, 243 Finnish children were adopted through ‘Save the Children’. Over the last few years this has decreased to less than fifty. Partly as abortion became more freely available following the Abortion Act of 1970; the number of unplanned children born to young single mothers fell. (Garrett, 2003 p.21). England too has seen a decrease in adoptions, (PIU, 2000, p.10) This may be attributed to the rise in use of the contraceptive pill and the acceptance of single mothers. According to Lowe (2000) The largest decline is in respect of babies (children under the age of 12 months) put up for adoption; in 1968, 12,641 babies were adopted (51% of all adoptions), but only 195 babies were adopted in 1998 (only 4% of all adoptions) According to Bennett (2009)” Only 4,637 children were adopted in 2007, the lowest number since 1999.”

In both states, adoption is far more likely to involve children in public care-or ‘looked after’ children (In England under the Children Act 1989) who are older, are child protection concerns, or have disabilities (DoH, 1998). This is in part due to the fact that there are very few ‘healthy’ babies ‘available’ for adoption. In England there are approximately 60,000 children ‘looked after’. (Department for Children, Schools and Families (DCSF), 2007). 62% of these children were removed, on a compulsory basis, from their family. Approximately 1% of all children under 18 years live in foster care, with about 48% in family foster care, 40% are in ‘children’s’ homes’, and the remaining 12% in new formats of family professional care (Kalland & Sinkkonen, 2001). In July of this year these statistics were even worse according to sources obtained by Bennett (2009) who claimed that this figure was now almost three quarters of all adoptions, she agrees with the reasoning behind the removal of children form their families stating “The increase in alcohol and drug abuse among parents is also a growing factor in care proceedings, with parents often being given several chances to break their habit before children are removed.”

It may possibly be argued that many of those children in long-term placements should and probably could be adopted, but this is not the overriding view of Finnish society, indeed the dominant view is that of family preservation. Several contributors share the opinion that children’s best interests are met when every effort is made to keep the family together. If foster care is needed, it should always be of limited duration (Garrett, 2003). These views echo FOX HARDING CHECK WHICH PERSPECTIVE AND MENTION

Many of these Finnish children in long-term foster care could have been adopted if they lived in England. Evidently, foster care makes it possible for children to keep some contact with their birth family. Unfortunately, this is not always advantageous for the child because of the severe difficulties including both psychological and behavioural of some parents (Quinton et al., 1997). The placement faces the risk of breakdown where the birth parents have sufficiently dealt or recovered from their difficulties, and desire to be a complete family with the return of their child. This may be successful, but may also be short-lived resulting in endless short-term placements. This will have an adverse effect destroying the child’s ability to form any meaningful attachments in adulthood. Adoption would offer the child an opportunity to form a stable relationship but this would cut the connections with the birth family. In Finland adoption against the will of the natural parents is far from the norm. As a result, there are very few ‘contested’ adoptions. According to the Finnish Adoption Act, the consent of both biological parents is needed before the adoption can take place. It should be noted that there are two exceptions to this; firstly, adoption can be granted if it is believed that the adoption is definitely in the best interests of the child and the refusal of consent of the parents is not suitably justified, secondly, the parents cannot logically express their will due to illness or disability, or if their whereabouts are unknown. Additionally the mother’s consent is only accepted after she has recovered from the birth (no earlier than eight weeks). In Finland the feelings and desires of the child are taken into account, this is according to the age and level of maturity. If the child is 12 or older, their opinions must be taken into account.

In recent years England has evolved a degree of openness in the adoption process (DoH, 1999, Ch. 5). This is because traditionally in England, the adoption of children resulted in the ‘cutting off’ of the relationship with the birth mother and birth family. The developments in this area have been provoked through professionals whose opinion that ‘openness’ is important for the mental health and ‘identity needs of adoptees’ (Kirton, 2000, p. 108). The ability for English adoptees and their family to gain access to records is relatively recent, in fact as recent as 1973 Scotland and Finland were “the only countries in the Western world where an adopted person could obtain information from official records that could help them trace their original parents” Triseliotis (1973, p. 1). The move away from high levels of secrecy can also be attributed to adoptees who wanted to find birth relatives (Campbell et al., 1991), birth mothers also campaigned for larger levels of openness in adoption in England (Logan, 1996). These actions coupled with the ‘Natural Parents Support Group’, an organisation of birth mothers, who lobbied the UK parliament for a public inquiry into the injustices which occurred through the mass adoption in the 1950s and 1960s (Rickford, 2000, Fink, 2000). The Children Act 1975 gave adopted people over the age of 18 years the right to apply for access to their original birth certificates. The recent ‘openness’ has enabled in some instances, ‘contact arrangements’ between the child and birth family after the adoption has taken place (Lowe, 2000, p. 326-329). The Adoption Act 1976 amended by the Children Act 1989, made it compulsory for the Registrar General to set up an ‘Adoption Contact Register’ in an attempt to make it possible for adopted people to contact their birth parents and other birth relatives. It the opinion of Hughes & Logan (1995) that these measures are in part due to the increasing awareness of the importance of post-adoption services. The view in Finland however has been far more open indeed; Save the Children has mediated between the adopted child and biological parents since the 1960s. It should be mentioned that large proportions of adopted people in Finland still do not wish to seek contact with their original families, usually those that felt disappointment about being adopted inn the first instance (Garrett 2003). This all means that while the recent drive toward adoption being more ‘open’ is obviously important, it must be recognised that ‘openness’ is not simple or straightforward.

Kalland et al. (2001) shows that mortality rates in Finland for both sexes on the ‘child welfare registry’ are in excess compared with the general population. Another Finnish study showed aggressive behaviour, delinquency and attention problems were associated with children and adolescents in children’s homes and that children may also be at risk of sexual abuse in these homes with the person responsible for the act often being an older adolescent (Hukkanen et al., 1999). What is important though is, none of these negative instances can be entirely attributed to poor quality or damaging care that children get whilst in public care. Numerous children arrive in these institutions already suffering from been highly traumatised in some cases due to parental addictions. In short, it is not simply the ‘looked-after’ experience which leads to poor outcomes.

Whereas in contrast concerns about the ‘poor outcomes’ of children who are ‘looked after’ (Parker et al., 1991) in England such as; ineffective health provision available for ‘looked after’ children (Butler & Payne, 1997), poor levels of educational achievement (Aldgate et al., 1993, Fletcher-Campbell, 1998), the bullying that takes place in ‘care’ settings, the high pregnancy rates amongst teenagers in ‘care’ in 2007 there were 360 mothers aged 12 and over who were ‘looked after’, an increase of 15 per cent from the previous year, (Corlyn & McGuire, 1998, DCSF, 2007), the disappointingly high number of moves from ‘care’ environment to ‘care’ environment (Sone, 1997), and the lack of preparation for those ‘leaving care’, and poor after-care support (Biehal et al. , 1995) has led to the English adoption system making wholesale reform

In July 2000 the then Prime Minister, Tony Blair published the governments ‘Review of Adoption’ which contained over 80 recommendations. Four of these recommendations focused on plans to; develop and implement a “National Adoption Register”, drawing up of new “National Standards” for local authorities to follow, the setting up of an “Adoption and Permanency Taskforce” to promote best practice and challenge poor performance, and conducting a “rapid scrutiny” of the ‘backlog’ of children that were waiting to be adopted (PIU, 2000, p.4).This was followed in December 2000, with the White Paper, ‘Adoption-A New Approach’. The aim of establishing a National Adoption Register and an Adoption and Permanency Taskforce were again set out. A national target was to be set with the aim of increasing the number of ‘looked after’ children adopted. Other processes highlighted in the consultation paper integrated within the plan were to introduce new National Standards for councils and adoption agencies. To enforce these standards, powers were put in place ’emergency inspections’ and ‘special measures’ to deal with problematic service providers. Other plans included, timescales for children enabling a ‘sound plan’ for their permanent future, this would be made within six months of their starting to be continuously ‘looked after. When the decision was made that adoption was to take place, a ‘new family’ should be found within a further six months. In an attempt to aid adoptive parents new plans to support them were briefly set out. Other significant measures included: a new legislative option, called ‘special guardianship’, this would provide a sense of stability for the child, but fall short of legal separation from their birth parents.

Unlike England there is no National Adoption Register and there are no plans to develop and implement one in Finland, a National Register however, could possibly help in advancing research and practice in a Finnish framework. Likewise an Adoption and Permanency Taskforce similar to that of England would be welcomed by many in Finland.

Finland’s parliament however, have this year voted to give people in same-sex couples who are registered in an official partnership the legal right to adopt the naturally-born child of their partner.(Finnsson, 2009) No further plans to speed up adoptions of ‘looked after’ children are planned. This is, perhaps, because as suggested earlier of the dominant position Fox Harding again which places an emphasis on family preservation services. There are very few Finnish waiting to be adopted. There are however in contrast, hundreds of couples waiting to adopt a child. There has been some discussion in the media about the intense frustration of these couples. It may take four or five years to have a child adopted. This has raised the notion of an adoption industry which is fed by the child protection system, “Regrettably, in many cases, the emphasis has changed from the desire to provide a needy child with a home to that of providing a needy parent with a child. As a result, a whole industry has grown, generating millions of dollars of revenues each year, seeking babies for adoption and charging prospective parents enormous fees to process paperwork.”(Pragnell, 2008) It is also his view that the interests of the child are now the cause of “atrocities committed against children and parents by well-meaning and well-intentioned employees of state and related agencies but whose acts are leading to immense suffering for children.”