Speaking at the annual conference of the Headteachers' Association of Scotland in Dalmahoy, outside Edinburgh, Sohail Faruqi, who moved earlier this year from England to become director of education in Aberdeenshire, said the English system already had a greater focus on structures than standards. The white paper's proposals for trust schools and independent management were a further development of this.
The Government south of the border also exercised a greater centralised control over what goes on in schools compared to the Scottish Executive's pedagogical approach, according to Mr Faruqi, who formerly worked for the Office of the Deputy Prime Minister and was director of lifelong learning in Plymouth.
In England, schools were isolated; in Scotland there was more partnership working. England was institution-focused; Scotland was community-focused.
In England, the focus was on attainment; in Scotland, it was on achievement. In England, the emphasis was on parent choice; in Scotland, it was on pupil choice.
However, Mr Faruqi acknowledged that the English structure had allowed confident and self-evaluating schools to develop, and that integrated services were working together to look after children and families. "The challenge for Scotland is to extend the role of the school as the hub of the community," he said.
With less than six months' experience north of the border and, as he himself described it, "superficial contact" with the Scottish system, Mr Faruqi suggested Scotland would benefit from a greater focus on early years education and learning through play; a greater focus on understanding how learners learn; better progression throughout the system; and development of paraprofessionals such as support staff and classroom assistants.
The conference also heard from John Dunford, general secretary of the Secondary Heads' Association (SHA), who said he was glad his members did not have to grapple with the problems posed by the 35-hour week for teachers set out by their national agreement.
But Dr Dunford did say that leadership teams in English schools now included more administrative, finance and support staff and fewer qualified teachers in the form of deputy heads.
The white paper in England did not contain the kinds of freedoms for headteachers that were being widely hyped in the media. These freedoms existed only in the minds of the Prime Minister's speech-writers, he said.
"The white paper is just more change for the sake of it," Dr Dunford said.
"In England, we have more pilots than British Airways. Schools are suffering this year from the biggest overload I have ever seen since the time I have been involved in SHA.
"In England, where schools have been driven apart for many years by Government through competition, more needs to be done to encourage partnership and collaboration. Only by working together can weaker schools be supported and stronger schools have some of their weaker departments supported."
Dr Dunford added: "I am very suspicious about new categories of schools being introduced. Before we know it, we will have a two-tier and a multi-tier system being introduced in the name of diversity. The English have a genius for turning diversity into hierarchy."