1) Policy Purpose
Our charitable activities include working with vulnerable people. The purpose of this policy is to protect children and vulnerable adults and provide stakeholders and the public with the overarching principles that guide our approach in undertaking our mission.
2) Safeguarding Principles
We believe that:
Nobody who is involved in our work should ever experience abuse, harm, neglect or exploitation.
We all have a responsibility to promote the welfare of all of our beneficiaries, staff and volunteers, to keep them safe and to work in a way that protects them.
We all have a collective responsibility for creating a culture in which our people not only feel safe, but also able to speak up, if they have any concerns.
3) Legal Framework
In developing this policy and any associated procedures and guidance, we have referred to key domestic legislation including The Charities Acts 2006 & 2011, the Children Act 1989 & 2004, the Protection of Children Act 1999 and the Safeguarding Vulnerable Groups Act 2006, the Care Act 2014, the Data Protection Act 2018, Public Interest Disclosure Act 1998, and the Equality Act 2010 and in light of the principles of the Mental Capacity Act 2005 and the Counter-Terrorism and Security Act 2015.
As a charity, we recognise our duties to safeguard and promote the welfare of children and adults at risk of harm affected by its work. Where we engage in such work, we will consider relevant statutory guidance including Keeping Children Safe in Education (2020), Working Together to Safeguard Children (2020), Care and support statutory guidance (2020) and Prevent Duty Guidance for England & Wales (2019). We shall consider this guidance proportionally in light of the organisation's unique nature and structure, and respecting the duties of statutory agencies to protect children and adults experiencing or at risk of harm.
4) Safeguarding Policy Applicability
This safeguarding policy applies to anyone working on our behalf, including our charity trustees and other volunteers.
Partner organisations will be required to have their own safeguarding procedures that must, as a minimum, include any additional legal or regulatory requirements specific to their work.
5) Types of Abuse
Abuse can take many forms, such as physical, psychological or emotional, financial, sexual or institutional abuse, including neglect and exploitation.
6) Reporting Safeguarding Concerns
If a crime is in progress, or an individual in immediate danger, call the police, as you would in any other circumstances.
If you are a beneficiary, or member of the public, make your concerns known to a member of our team, who will alert a senior member of the charity.
For members of the charity, make your concerns known to your supervisor. If you feel unable to do so, speak to a trustee.
The trustees are mindful of their reporting obligations to the Charity Commission
Information held by Project ReMake may need to be passed to the Children’s Services Department or the Police to assist any further enquiries and investigation.
It is the responsibility of the Designated Safeguarding Person to ensure that information is passed on to the relevant authorities as requested, and that is completed correctly.
We will record and keep information which:
· Allows for a chronology of what happened and when it happened
· Shows history of events and allows analysis of any patterns
· Allows for continuity in absence of a staff member
· Shows actions taken by staff
· Provides accountability
· Provides a basis for evidence in court
· Provides information for enquiry, statistics, research
· Highlights staff training and development needs
The recorded information would include:
· The nature of the allegation or concern
· A description of any visible bruising or other injuries
· The child’s account (using his/her own words)
· Any times, dates, or other relevant information
· Whether the parent, carer, child or adult is aware of the referral being made
· A clear distinction between what is fact, opinion and hearsay
· No jargon
· Clear recording of decisions reached with others
· Clearly signed, timed, and dated.
We will not:
· Delay reporting the matter by trying to obtain more information
· Destroy any handwritten notes made at the time of the incident
7) Trustee Safeguarding Responsibilities
Trustees. This safeguarding policy will be reviewed and approved by the Board annually.
Trustees are aware of and will comply with the Charity Commission guidance on safeguarding and protecting people and also, the10 actions trustee boards need to take to ensure good safeguarding governance.
The trustees have been given oversight of all aspects of safety and they have ultimate responsibility for safeguarding.
Planning programmes/activities to take into account potential safeguarding risks, to ensure these are adequately mitigated.
Ensuring that all appointments that require DBS clearance and safeguarding training are identified, including the level of DBS Creating a culture of respect, in which everyone feel safe and able to speak up.
An annual review of safety, with recommendations to the Board.
Receiving regular reports, to ensure this and related policies are being applied consistently.
Providing oversight of any lapses in safeguarding.
And ensuring that any issues are properly investigated and dealt with quickly, fairly and sensitively, and any reporting to the Police/statutory authorities is carried out.
Leading the organisation in way that makes everyone feels safe and able to speak up.
Ensuring safeguarding risk assessments are carried out and appropriate action taken to minimise these risks, as part of our risk management processes.
Ensuring that all relevant checks are carried out in recruiting staff and volunteers.
and any training required.
Ensuring that a central register is maintained and subject to regular monitoring to ensure that DBS clearances and training are kept up-to-date.
Ensuring that safeguarding requirements (e.g. DBS) and responsibilities are reflected in job descriptions, appraisal objectives and personal development plans, as appropriate.
Listening and engaging, beneficiaries, staff, volunteers and others and involving them as appropriate.
Responding to any concerns sensitively and acting quickly to address these.
Ensuring that personal data is stored and managed in a safe way that is compliant with data protection regulations, including valid consent to use any imagery or video.
Making staff, volunteers and others aware of:
Our safeguarding procedures and their specific safeguarding responsibilities on induction, with regular updates/reminders, as necessary.
The signs of potential abuse and how to report these.
The need to support staff/volunteers after they have shared their concerns about a child/vulnerable person
Everyone to be aware of our procedures, undertake any necessary training, be aware of the risks and signs of potential abuse and, if you have concerns, to report these immediately.
8) Policy development and purpose
This policy is designed to target effectively the main risks that are anticipated as having the potential to occur, arising from the current work and commitments of the Centre.
We will seek advice from experienced and informed experts when planning how it will ensure that all connected with it understand and carry out the policy.
It will be modified and amended as necessary when new work is planned, especially work that brings us into more frequent contact with a greater range of vulnerable groups.
The purpose of the policy is to:
Provide trustees, staff and volunteers with guidance on the procedures they should adopt in the event that they suspect a vulnerable adult or child or young person taking part in activities organised by the us may be experiencing, or be at risk of, abuse or neglect from anyone connected with Project Remake;
Provide carers, parents and external parties with guidance on the disclosure and complaints procedure and timescale for response in the event that they suspect a vulnerable adult or child or young person may be experiencing, or be at risk of abuse or neglect while taking part in activities organised by us;
Provide managers with guidance on statutory personnel checks, how to minimize risks and deal with potential complaints;
Provide guidance on dissemination, monitoring, confidentiality, secure storage and information sharing procedures.
Support programme participants to understand and feel confident in the Centre’s policy and practice.
9) Trustee Safeguarding Lead
Kameel Khan, a member of the Board of Trustees, is the Trustee Safeguarding Lead. His email address is: email@example.com.
10) Safeguarding and Fundraising
We will ensure that:
We comply with the Code of Fundraising Practice, including fundraising that involves children.
Staff and volunteers are made aware of the Institute of Fundraising guidance on keeping fundraising safe and the NCVO Guidance on vulnerable people and fundraising.
Our fundraising material is accessible, clear and ethical, including not placing any undue pressure on individuals to donate.
We do not either solicit nor accept donations from anyone whom we know or think may not be competent to make their own decisions.
We are sensitive to any particular need that a donor may have.
11) Charity Commission Guidance - Online Safeguarding
We will identify and manage online risks by ensuring:
Volunteers, staff, and trustees understand how to keep themselves safe online. You could use high privacy settings and password access to meetings to support this
The online services you provide are suitable for your users. For example, use age restrictions and offer password protection to help keep people safe
The services we use and/or provide are safe and in line with our code of conduct.
Protect people’s personal data and follow GDPR legislation.
We have permission to display any images on our website or social media accounts, including consent from an individual, parent, etc.
We clearly explain how users can report online concerns. Concerns may be reported using this policy, or direct to a social media provider using their reporting process. If you are unsure, you can contact one of these organisations, who will help you.
12) Overview of risks and plans for prevention
Risks in relation to volunteers
There are no plans to recruit volunteers who are known to be vulnerable adults or children.
Should vulnerable adults or children be recruited as volunteers in the future, it will be made clear that they will be supervised by a member of staff trained to identify signs of abuse or neglect. Volunteers will be informed about the complaints system which facilitates reporting.
Protecting people is everyone’s responsibility.
Board of trustees.
The board of trustees is ultimately responsible for safeguarding and for ensuring that staff and volunteers are competent to carry out their safeguarding responsibilities.
The trustees will take action to avoid any actual or potential conflicts of interest which could lead to Project Remake being compromised in any way in enforcing our safeguarding commitments.
We will review safeguarding reports and decide whether to report a serious incident to the Charity Commission or other relevant bodies
The trustees will review this Safeguarding Policy annually or (if sooner) when there are any material changes to safeguarding legislation or guidance, and in light of any safeguarding reports.
14) Reporting Safeguarding Concerns
If you witness a safeguarding incident, or if an incident has just taken place, and you believe someone is at imminent risk of significant harm, you should call the emergency services and then report the matter following the process below.
If you have a concern that someone may be experiencing, has experienced, or is at risk of experiencing, abuse, or exploitation you should make a report to the Safeguarding Lead Contact without delay. You should report a safeguarding concern, even if it relates to an incident that occurred some time ago.
When you make a report, it is helpful if you can provide details of your concerns including:
the name(s) of the people involved
a description of each incident
the dates, times and location of each incident Staff, consultants, interns and volunteers
If an allegation is made against you, you must inform the Safeguarding Lead Contact immediately and you will be asked to make a written record of the allegation. We will treat anyone who is accused with respect and all allegations will be treated confidentially.
We will treat all safeguarding reports as confidential and information will only be shared on a strictly ‘need to know’ basis. This may include sharing information with trustees.
Anyone who reports a genuine concern under this procedure will be protected against negative repercussions because of raising a safeguarding concern.
16) Responding to Safeguarding Concerns
Safeguarding reports may reach us through various routes, including telephone calls, text message, social media, face-to-face discussions, or rumours. All concerns must be taken seriously.
If someone raises a safeguarding concern with you, you should:
empathise with the person making the report
ask who, when, where, what, but not why
repeat what you have been told to check your understanding
reassure the person making the report that we will treat all safeguarding reports as confidential and that information will only be shared on a strictly ‘need to know’ basis
do not promise secrecy – if someone is in danger you will have to inform others
if the person making the report is a member of staff, ask them to limit discussions about the matter with other colleagues as far as possible in order to allow us to respond to their concern in line with this policy
(if the person receiving the report is not a Safeguarding Lead Contact) make a report to the Safeguarding Lead Contact without delay.
You must keep safeguarding reports confidential.
The Safeguarding Lead Contact will consider the report and will decide about how to take the matter forward. This could include:
conducting an internal investigation – when appointing someone to carry out an investigation we will take account of relevant experience, skills, cultural, linguistic and legal considerations, as well as potential conflicts of interest or loyalty. Support from external providers may be sought.
acting may include -
termination of consultancy agreements or bringing voluntary roles to an end
termination of partnership agreements or relationships with third parties
reporting to external agencies (see below) In reaching a decision, the Safeguarding Lead Contact will review all of the available information and, if necessary, discuss the matter further with the person who reported the concern and/or take external advice.
18) Reporting to the Board and to Regulators
The Safeguarding Lead Contact will inform the board of trustees that a safeguarding report has been received and the trustees will be responsible for deciding whether the matter should be reported as a serious incident to the Charity Commission, or to other relevant bodies in other jurisdictions if appropriate. The trustees may delegate authority to make a report to a manager or external agent (for example, a solicitor).
Unless a case is particularly serious, details of safeguarding concerns will not be shared with trustees. The board will only receive reports summarising the nature of issues raised and the outcomes.
19) Referrals to External Agencies
Where appropriate, Project Remake will refer safeguarding concerns to appropriate external agencies such as:
law enforcement authorities for criminal investigation
children’s social care services
the Disclosure and Barring Service (DBS)
other relevant bodies
The Safeguarding Lead Contact will undertake a risk assessment before making any report to an external agency. The risk assessment will take into consideration:
any risk of further harm to those affected by the alleged incident or incidents
whether those affected want the matter to be reported externally
whether external reporting risks disproportionate consequences for the accused
whether due process is guaranteed or likely (for example, where the incident occurs overseas).
Where applicable, the Safeguarding Lead Contact may decide to provide a limited description of safeguarding allegations, incidents or concerns to institutional donors and other third parties
20) Support for Complainants and Survivors
Project Remake adopts a person-led approach to safeguarding, and the safety and wellbeing of complainants and survivors is paramount
We actively seek feedback from complainants and survivors, if and wherever appropriate, to improve our safeguarding policies and processes.
Where appropriate, we will offer support to people involved in safeguarding incidents. All decisions on support will be led by the individual. Support could include (but is not limited to) referrals to, or covering the cost of:
protection or security assistance (for example being moved to a safe location)
21) Collaborating with Partners
We will ensure that agreements or contracts with third-party groups or organisations which involve contact with children or adults at risk include an obligation on the partner to have appropriate safeguarding policies and procedures in place and comply with its statutory and regulatory safeguarding obligations. The agreement or contract will also clearly outline safeguarding procedures including:
who has overall responsibility for safeguarding concerns.
who is responsible for reporting an investigating safeguarding concern; and
the procedure to be following for dealing with safeguarding concerns.
If we receive a safeguarding report about a partner organisation, we will contact the partner and expect them to respond quickly and appropriately. We will assist the partner and will require them to report on the outcome (as permitted under data protection laws).
If we have reason to believe that an allegation has not been dealt with appropriately by a partner organisation and/or if an investigation uncovers serious issues relating to the governance or management of a partner organisation, we will give serious consideration to ending the partnership.
22) Safer recruitment
We committed to the safe recruitment, selection and vetting of staff, trustees, and volunteers.
Appropriate checks will be carried out before a new trustee is appointed and all trustees must sign a declaration to confirm that the person is not disqualified under the Charity Commission’s automatic disqualification rules. Trustees in post will be asked to sign a fresh declaration every year.
As part of the recruitment process for all staff and volunteers, we will question gaps in employment and take up references for successful candidates. We will seek to have an open and measured discussion with applicants at interview about any criminal convictions, offences, or other matters that might be relevant to the position applied for. Failure to reveal information (including information about convictions and cautions) directly relevant to a position could lead to withdrawal of an offer of any employment, or termination where employment has already commenced.
We will carry out appropriate criminal records checks for anyone working with children and/or adults at risk.
23) Relationships at Work
This section applies to all Project Remake trustees, staff, consultants, interns and volunteers. Failure to comply will be treated as a disciplinary matter and could result in disciplinary action up to and including dismissal, or termination of your engagement with Project Remake
We respects everyone’s right to a private life. These guidelines are intended to provide a framework for managers to deal sensitively, consistently and fairly with personal relationships at work.
When we refer to relationships, we mean emotional or romantic relationships which go beyond the normally accepted boundaries of the professional sphere between colleagues. This will include formal, family relationships (e.g. where people are married or living together) as well as less formal situations (e.g. where people are “seeing each other” or “going out together”).
We prohibits relationships between colleagues and people who they line manage or supervise. Staff in the senior management team are prohibited from having relationships with any more junior staff. Such relationships may be based on inherently unequal power dynamics and could undermine the credibility and integrity of our work.
We do not prohibit relationships between colleagues outside of the unequal power dynamics but you must:
declare any relationship as soon as possible to your line manager, even if the relationship is at an early stage and may not continue
behave professionally and conduct the relationship in a way that does not impact on work or on other colleagues (e.g. being discrete in any discussions regarding your private life within the workplace, avoiding public displays of affection in the work sphere)
ensure you do not allow your relationship to influence your work decisions
ensure that your relationship does not lead to fraudulent or corrupt behaviour (e.g. choosing to travel at the same time as each other without having a valid business need and claiming expenses)
We will not tolerate any form of harassment of colleagues and will take all such allegations extremely seriously. You are reminded to consider your legal obligations towards colleagues, especially pertinent at the beginning or end of a relationship when professionalism and discretion will be particularly important.
24) UK Guidance
Charity Commission ‘Safeguarding and protecting people for charities and trustees’
Charity Commission ‘How to report a serious incident in your charity’
Charity Commission ‘Reporting a serious incident in your charity when it involves a partner’
Charity Commission ‘Automatic Disqualification: guidance for charities’
Institute of Fundraising ‘Treating Donors Fairly’
The Code of Fundraising Practice
16 November 2022.