Change Please Safeguarding Policy – January 2022
- General Policy
Change Please Foundation (Change Please) is firmly committed to the belief that all children and vulnerable adults have a fundamental right to be protected from harm and fully recognises its responsibility for child and adult protection. The safety and protection of all vulnerable people that Change Please supports is paramount and has priority over all other interests, unless life is at imminent risk.
There are five main elements to the policy:
- ensuring that CHANGE PLEASE practices safe recruitment in checking the suitability of staff and volunteers to work with young people and vulnerable adults;
- raising awareness of child protection and vulnerable adult issues amongst all paid and unpaid staff;
- developing and implementing procedures for identifying and reporting cases or suspected cases, of child or adult abuse;
- supporting the child or adult who has been abused;
- establishing a safe environment in which children and adults can develop and grow, where they are able to talk and be listened to.
The following definitions apply throughout the Safeguarding Policy and associated procedures:
Child or Children
The Children Act 1989 defines a child as a person under eighteen, for most purposes.
Vulnerable Adult or Adults
The Protection of Vulnerable Adults Scheme (PoVA 2004) defined a vulnerable adult as a person aged 18 or over who has a condition of the following type:
- A substantial learning or physical disability;
- A physical or mental illness or mental disorder, chronic or otherwise, including addiction to alcohol or drugs;
- A significant reduction in physical or mental capacity.
The term young person will include those aged between 5 and 24 years. For the purposes of this policy, a young person aged under 18 years is regarded as a child and a vulnerable adult includes all people aged 18 and over subject to the criteria of the POVA Scheme.
2.2 Forms of abuse
The Children Act 1989 defines four types of abuse: physical, emotional, sexual and neglect. These categories of abuse apply and will be relevant to vulnerable adults as well as to children who CHANGE PLEASE has contact with as part of its activities and social care role with people of all ages.
Physical abuse may take many forms e.g. hitting, shaking, throwing, poisoning, burning or scalding, drowning or suffocating.
It may also be caused when a parent or carer feigns the symptoms of, or deliberately causes, ill health to a child or vulnerable adult. This unusual and potentially dangerous form of abuse is now described as fabricated or induced illness.
Emotional abuse is continual emotional ill treatment causing severe and persistent effects on the child or vulnerable adult’s emotional development and may involve:
- conveying the message that they are worthless or unloved, inadequate, or valued only in so far as they meet the needs of another person;
- imposing developmentally inappropriate expectations;
- causing the child or vulnerable adult to feel frightened or in danger – e.g. witnessing domestic violence;
- exploitation or corruption of children, young people or vulnerable adults.
Some level of emotional abuse is involved in most types of ill treatment, although emotional abuse may occur alone.
Sexual abuse involves forcing or enticing a child or vulnerable adult to take part in sexual activities, whether or not they are aware of what is happening and includes penetrative (i.e. vaginal or anal rape or buggery) and non-penetrative acts.
It may also include non-contact activities such as looking at, or being involved in, the production of pornographic materials, watching sexual activities or encouraging children or vulnerable adults to behave in sexually inappropriate ways.
Neglect involves the persistent failure to meet basic physical and/or psychological needs, which is likely to result in serious impairment of the neglected person’s health and development. It may involve failure to provide adequate food, shelter or clothing, failure to protect from physical harm or danger or failure to ensure access to appropriate medical care or treatment. It may also include neglect of basic emotional needs.
Staff should also be aware of other factors which influence these forms of abuse such as racial or homophobic abuse.
2.3 Status of Policy
This policy forms part of the Terms and Conditions of Employment and applies to all employees, trustees and volunteers. Its purpose is to protect the personal safety of all children, young people and vulnerable adults using the facilities, resources and activities provided by [Name of Organisation] actively promoting awareness, good practice and sound procedures.
All employees, trustees and volunteers are required to provide references that CHANGE PLEASE deems appropriate, which are always verified.
All paid and unpaid staff involved in regulated or intensive contact with vulnerable people as part of their work for CHANGE PLEASE will be required to have a DBS check
No new employees, trustees or volunteers should start employment/work until references have been verified and DBS checks received. If this is not possible then new employees, trustees and volunteers must not have contact with vulnerable people until references and DBS checks are completed. Details of the checks to be carried out are set out in Part 5.
All employees, trustees and volunteers will receive, and will be required to read and sign, the Children and Vulnerable Adults Safeguarding Policy. All employees, trustees and volunteers will receive regular support in their work with children and vulnerable adults.
Please see part 6 for details of the Vetting and Barring Scheme.
All employees, trustees and volunteers working on behalf of CHANGE PLEASE have a responsibility for the welfare of the children and vulnerable adults that they work with, in relation to their employment.
All employees, trustees and volunteers have a duty to ensure that any suspected incident, allegation or other manifestation relating to child and vulnerable adult protection is reported using the reporting procedures detailed in this policy.
CHANGE PLEASE has a Designated Safeguarding Officer and a nominated deputy. The Manager, for whom the Administrator will act as deputy in his or her absence, must also be informed of issues which arise under this policy. The Designated Safeguarding Officer and Deputy Safeguarding Officer are responsible for child protection and the implementation of this policy. It is the responsibility of the Designated Safeguarding Officer to take appropriate action following any expression of concern and make referrals to the appropriate agency.
3.2.1 Designated Safeguarding Officer
The Designated Safeguarding Officer will attend training as appropriate and make referrals to external agencies. Other aspects of their role include:
- obtaining information from staff, volunteers, children, parents or carers who have concerns relating to the protection of children or vulnerable adults and to record this information;
- assessing information quickly and carefully and asking for further information where appropriate;
- consulting with statutory child and vulnerable protection agencies e.g. the local social services department and police, to clarify doubts or worries;
- making referrals to Social Services, the Independent Safeguarding Authority or the police, without delay.
All employees will be made aware of the named Designated Safeguarding Officer and how to contact them. Contact details also appear in Part 12 of this policy. The Designated Safeguarding Officer has contact telephone numbers for the local Area Safeguarding Board and other statutory agencies.
3.3 Reporting Procedures: What to do if you suspect someone is being abused
All staff, volunteers and others working in direct or indirect contact with vulnerable people as part of the organisation’s activities, or as part of the environment where the activities take place, must be alert to the signs of abuse. Anyone who suspects that abuse is taking place in this environment or to whom a child or vulnerable adult discloses issues relating to safeguarding should contact the Designated Safeguarding Officer immediately.
Any suspicion or allegation must be reported as soon as possible on the day of the occurrence to the Designated Safeguarding Officer. Disclosure or evidence for concern may occur in a number of ways including a comment made by a child or adult, physical evidence such as bruising, a change in behaviour, or inappropriate behaviour or knowledge.
It is the responsibility of the Designated Safeguarding Officer to liaise with other relevant agencies where necessary and seek clarification from the Safeguarding and Protection Unit of the local Constabulary if there is any concern about the validity of any allegation.
Any suspicion or allegation of abuse must be recorded by the observer/s on the appropriate incident reporting form. This form must be kept strictly confidential and stored securely following the Data Protection Procedures. All employees and volunteers are instructed to report the disclosure or discovery of abuse or alleged abuse directly to their Line Manager who will inform the Designated Safeguarding Officer.
All trustees will report such incidents directly to the Manager, or his/her deputy as the Designated Safeguarding Officers.
All stages of the reporting procedure must be documented, marked CONFIDENTIAL and stored securely following the procedures laid out in the Data Protection Policy.
3.4 Allegations against employees, trustees or volunteers
When any form of complaint is made against an employee or volunteer, it must be taken seriously and the complaint should initially be dealt with by the most senior staff member on site at the time the complaint is made. The senior staff member must report the complaint to the Manager or his/her nominated deputy immediately, giving details of the circumstances.
The Manager or his/her nominated deputy will attend the site of the allegation to gain an initial account of what has occurred from all relevant parties, including the person against whom the allegation has been made. If this is not possible, contact will be made by telephone.
The Manager or his/her nominated deputy will have the right to suspend from duty and/or the premises, any person who is a party to the allegation until a full investigation has been made in line with CHANGE PLEASE’s Disciplinary Procedures or the Code of Conduct.
This action does not imply in any way that the person suspended is responsible for, or is to blame for, any action leading up to the complaint. The purpose of any such suspension is to enable a full and proper investigation to be carried out in a totally professional manner.
It is the responsibility of the Manager or his/her nominated deputy to make the decision as to whether to inform Social Services, NHS Community Mental Health Team (CMHT) and/or the Safeguarding Unit of the local Constabulary, depending on the nature of the allegation.
CHANGE PLEASE will co-operate fully with the Police, Social Services, the NHS and all other parties involved.
The Manager or his/her nominated deputy will ensure that the Chair of CHANGE PLEASE or in his/her absence the Secretary or Treasurer, is fully briefed. An agreed statement will be prepared for the purpose of accurate communication with external sources and for the protection of the legal position of all parties involved.
The Manager or his/her nominated deputy will make a full written report of the incident and the actions taken. This report will be stored securely following the procedures detailed in the Data Protection Policy.
If, during the course of an investigation relating to safeguarding, an employee tenders his or her resignation, or ceases to provide their services, CHANGE PLEASE is not prevented from following up an allegation in accordance with these procedures. Every effort will be made to reach a conclusion in cases relating to the welfare of children or vulnerable adults, including those where the person concerned refuses to co-operate with the process
Staff Code of Conduct
All employees and volunteers must work under the principle that confidentiality is extremely important and plays a large part in much of the work carried out with children and young people. However, under no circumstances will any individual in the employment of CHANGE PLEASE, or acting as a volunteer, keep confidential any information that raises concerns about the safety and welfare of a child or vulnerable person. This statement relating to confidentiality is made known to all who access any provision of CHANGE PLEASE.
- Safe recruitment of staff
CHANGE PLEASE undertakes to ensure that its paid and unpaid staff are suitable to work in an environment where they will encounter children and vulnerable adults as part of the Organisation's work. It also reserves the right to refuse to employ staff or volunteers whom it has a reasonable belief may pose a risk to vulnerable people.
CHANGE PLEASE has systems in place to prevent unsuitable people from working with children or vulnerable adults and to promote safe practice. These systems apply to all new staff and volunteers and require the following checks to be made on appointment:
- A minimum of two references, satisfactory to CHANGE PLEASE, one of which should be from a previous employer;
- Documentary evidence checks of identity, nationality, residency and “right to work” status;
- DBS Check;
- Documentary evidence of qualifications;
- Satisfactory completion of the probationary period.
- Vetting and Barring
The Safeguarding Vulnerable Groups Act 2006 places a duty on CHANGE PLEASE to undertake an Enhanced Criminal Records Bureau Disclosure for all staff and volunteers supervising or in intensive or frequent contact with children or vulnerable adults. When the coalition government came to power they halted the Vetting and Barring Scheme. As such, registration with the Independent Safeguarding Authority is not currently required. The Organisation may however check the barred lists held by the ISA before offering employment or a volunteer position.
CHANGE PLEASE carries out Standard Disclosure checks on all staff whose jobs involve some contact with children or vulnerable adults. Positions which fall into this category include administration staff, where unsupervised access to children or vulnerable adults is not a large part of the job.
An Enhanced Disclosure is required for staff and volunteers who regularly care for, supervise, train or are in sole charge of children or vulnerable adults. Positions which fall into this category include managers, youth workers and administration staff in positions where unsupervised access to children or vulnerable adults forms a large part of the job e.g. programme administrators. For individuals who have lived outside of the UK further checks are carried out, where appropriate, if a DBS Check is not felt to be sufficient to establish suitability to work with children, young people or vulnerable adults.
See also [Health and Safety Policy and Procedures] and Incident Reporting (part 7).
- Reporting cases to the Independent Safeguarding Authority
CHANGE PLEASE has a statutory duty to make reports and provide relevant information to the Independent Safeguarding Authority (ISA) where there are grounds for believing, following an investigation, that an individual is unsuitable to work with children or vulnerable adults, or may have committed misconduct. The responsibility for reporting cases to the ISA lies with the Designated Safeguarding Officer.
The Independent Safeguarding Authority make barring decisions for Section 142 of the Education Act (formally known as List 99), The Protection of Children Act List (PoCA) and the Protection of Vulnerable Adults List (PoVA). This has now been combined as part of the Vetting and Barring Procedures of the Independent Safeguarding Authority
- Support for Staff
All staff and workers who come into direct contact with learners must undertake training on the subject of safeguarding. The Children and Vulnerable Adults Safeguarding Policy will be issued to all new staff as part of their induction.
See also CHANGE PLEASE’s Induction Procedure
CHANGE PLEASE is aware that safeguarding cases can be distressing and that both paid and unpaid staff who have been involved may find it helpful to talk about their experiences, in confidence, with the Designated Safeguarding Officer or with a trained counsellor. Staff wishing to be referred for counselling should contact their line manager or the Designated Safeguarding Officer.
- Equality of Opportunities
As part of the community served by CHANGE PLEASE all children and vulnerable adults have the right to be safeguarded from harm and exploitation whatever their race, religion, gender, sexuality, age or disability. This policy relates to the Organisation’s legal obligation to protect children who are suffering forms of abuse as defined in the Children Act 1989 and is therefore in line with CHANGE PLEASE’s equality and diversity policies.
Disability Equality Scheme
Equal Opportunities Policy statement
Recruitment of Ex-Offenders
Employment and Recruitment Policy
10.1 The use of cameras, videos, or camera mobile phones
CHANGE PLEASE may take photographs of children and young people participating in activities and events. At all times written permission from parents will be obtained before photographs are taken.
CHANGE PLEASE reserves the right to prohibit the use of cameras, videos and mobile telephones with picture taking capacity on its land and within any of its properties or at events it promotes.
Used security videos will be kept in a secure place and when no longer needed shall be destroyed.
10.2 Employee Ratios
The ratio of employees/volunteers to children will be one to eight for those aged 8 years and under and one to ten for those aged 10 years or over as laid down by guidance issued under the Children Act (1989).
Where a Governing Body or Government guidelines require a higher ratio of employees/volunteers to the number of children and vulnerable adults this ratio will override the minimum ratios set above.
Outdoor adventure activities will always have a minimum of 2 appropriately trained adults, one of which must be an employee of CHANGE PLEASE who will hold a First Aid at Work qualification.
There will always be two employees present when transporting children and vulnerable adults in a minibus or other forms of public and private transport. The ratio of employees/volunteers working with children and vulnerable adults with special needs will be as laid down under CHANGE PLEASE’s Special Needs Policy (see Part 11).
10.3 Signing in and out
All children aged 14 and under and vulnerable adults attending a CHANGE PLEASE organised activity with a duration of less than one hour will be checked against a register. All children and vulnerable adults attending a CHANGE PLEASE organised activity that lasts longer than one hour must be signed in/out by a parent/guardian. This applies to all CHANGE PLEASE organised activities, regardless of their location.
10.4 Outside Organisations
Any club, society, organisation or individual undertaking activities on CHANGE PLEASE’s behalf involving children aged 14 and under and vulnerable adults will be required to either adopt CHANGE PLEASE’s Children and Adults Safeguarding Policies or show proof that they have their own robust policies.
Any club, society, organisation or individual undertaking any activity that has been sanctioned by CHANGE PLEASE which involves children aged 14 years and under on CHANGE PLEASE’s land or in its premises will be required to adopt CHANGE PLEASE’s signing in and signing out procedures.
Any club, society, organisation or individual working with children and vulnerable adults who refuse to adopt CHANGE PLEASE’s policies, signing in and signing out procedures or adopt their own policies and procedures will not be permitted to use CHANGE PLEASE facilities.
Any club, society, organisation or individual working with children and vulnerable adults will be subject to random spot checks periodically by CHANGE PLEASE employees to ensure policies and procedures are in place and being implemented.
- Special Needs Policy
All CHANGE PLEASE’s employees, volunteers and contractors are required to comply with the procedures contained within this policy.
This Special Needs Policy works in support of CHANGE PLEASE’s established Children and Vulnerable Adults Safeguarding Policy which requires all employees, trustees and volunteers to be checked through the Criminal Records Bureau before coming into contact with any child or vulnerable adults taking part in CHANGE PLEASE organised activities.
Screening must take place prior to the commencement of activities and will complement CHANGE PLEASE’s booking procedures. Screening will include illnesses, medication, health, emergency numbers and, in certain cases, special reference to asthma sufferers and inhalers and whether the child is able to administer their own medicines. Screening must include a medication sheet for children and vulnerable adults with individual medical requirements e.g. dosage, symptoms, times to be administered, Doctor’s surgery numbers etc.
CHANGE PLEASE is within its rights to turn away a child or vulnerable adult with a medical condition which a parent has neglected to inform CHANGE PLEASE about during the screening process.
11.1.2 Contagious illness
The screening form will indicate that CHANGE PLEASE will not accept any child suffering from a contagious illness and they will be turned away.
11.1.3 Three to Five Years
For activities where 3 – 5 year olds are left in the sole care of CHANGE PLEASE and where medication needs to be administered, parents will be required to return to administer the medication at the appropriate time. Where a child needs help to administer an inhaler, employees must first be given written consent from parents.
11.1.4 Six Plus
Parents will be asked to leave written consent in order for any medicines to be given or overseen. It is the parent’s responsibility to inform employees or volunteers whether their child has an inhaler and where it is kept. It should be clearly labelled with the child’s name and, where the child may need assistance in taking an inhaler, written consent must be given first.
11.1.5 A child over 5 requiring Injections
It is not CHANGE PLEASE’s responsibility to assist a child in the administering of injections. A child must either be able to administer and control their condition or be supervised by a parent or guardian. If a child needs to, or may need to, inject them during an activity, employees must be advised during the screening process.
11.1.6 Dietary requirements
Parents or carers must inform employees or volunteers if a child or vulnerable adult has specific dietary requirements that need to be adhered to.
Employees and volunteers will be responsible for the safekeeping of any medicines. Children and vulnerable adults will be given the option of leaving inhalers in safekeeping or in their bags. All medicines must be clearly marked with the child or vulnerable person’s name.
Should a child or vulnerable adult become ill during an activity CHANGE PLEASE employees will request the parent or carer to collect the child at the earliest opportunity.
11.1.9 Nut Allergies
Where nut allergies have been made known to CHANGE PLEASE, the organisation will be responsible for writing to all parents/carers with children and vulnerable adults attending the same activity to request that parents refrain from giving their children and vulnerable adults nut products in their lunch boxes.
11.1.10 Dangers of the Sun
It will be CHANGE PLEASE’s responsibility to inform parents/carers about the dangers of sunburn and to request that parents/carers provide children and vulnerable adults with suntan cream and appropriate headwear.
11.2 Other Special Needs
11.2.1 Clinically diagnosed Behavioural Problems
CHANGE PLEASE will require parents/carers to inform CHANGE PLEASE employees during the screening process prior to the activity if their child has any known behavioural problems.
11.2.2 Additional Conditions
CHANGE PLEASE will take all reasonable steps to accommodate children and vulnerable adults with conditions that have been made known to employees.
11.2.3 Disabled Children and Vulnerable Adults
Children and vulnerable adults who are wheelchair users will be actively encouraged to participate in activities. However, where the safety of other children and vulnerable adults may be compromised, such as contact sports, certain disabled children and vulnerable adults may be turned away and encouraged to seek out more suitable activities for their disability.
11.3 Unacceptable Behaviour
CHANGE PLEASE expects a reasonable standard of behaviour from the children and vulnerable adults in its care and reserves the right to remove a vulnerable person from the activity. Where other children and vulnerable adults’ safety and enjoyment are compromised by bad behaviour CHANGE PLEASE will have total discretion whether to remove the child or vulnerable adult from the activity. Where this has to be done then a full incident report will be required to be completed and kept on file.
- The Designated Safeguarding Officer
Name: Laurence Higgens
Tel: 07546 767779
All paid and unpaid staff who are not the Designated Safeguarding Officer, but who are approached with concerns about a child or vulnerable adult, must bring the concerns raised to the attention of the Designated Safeguarding Officer, his/her deputy or their line manager immediately.
All staff to whom a vulnerable person discloses issues that may be related to safeguarding must keep written notes of concerns. The staff member must also complete an Incident Form immediately after the issues have been noted by them or reported to them.
- Review and Maintenance of Policy
CHANGE PLEASE shall undertake to review this policy, its implementation and effectiveness annually. The views of all employees and volunteers shall be sought where necessary and reflected in the review process.
Any new legislation or developments in existing legislation will be considered as and when required and the policy will be updated to reflect these developments.
All employees and volunteers will receive training in child and vulnerable adult protection procedures and the training will be reviewed as and when required.