Safeguarding Policy

Children, Young People and Vulnerable Adults Safeguarding Policy

1.0 Introduction

Action for Race Equality (ARE) is a national charity whose mission is to end racial inequality. We believe that the contribution of all communities makes a nation, builds dynamic local communities, generates wealth and improves wellbeing.

We champion fairness, challenge discrimination and pioneer innovative solutions to empower Black, Asian and Mixed Heritage people through education, employment and enterprise. Our activities involve working with Government, business, public services, Black-led organisations and the media.

As a national organisation ARE want to maximise our work with central government departments by connecting more directly with local Black and Minority Ethnic organisations and mainstream activities aimed at closing racial inequalities.

We strongly believe that race inequalities will persist and in some areas such as unemployment, take generations to close unless we start to inspire local BME individuals and organisations to get actively involved in local decision-making processes.

1.01 Safeguarding Statement

At ARE, we maintain a zero-tolerance approach to all forms of abuse, particularly when it involves children, young people, or vulnerable adults. We are committed to helping our members and service users protect themselves from abuse and neglect. Safeguarding is everyone’s responsibility — all staff, volunteers, trustees, members, and service users must be able to identify, prevent, and act upon concerns of abuse or neglect.

Our safeguarding practices are rooted in person-centred principles, meaning we prioritise the best interests — and, where possible, the wishes — of the individuals we support. We ensure that all members and service users are aware of our Safeguarding Policy and Procedures, and we promote transparency and accountability throughout the organisation.

Safeguarding is a thorough process and handling safeguarding complaints can be complex. We recommend all staff and Trustees review this policy annually. We want all staff and Trustees to think about safeguarding at key moments such as recruitment, event planning, working with or funding new partner organisations and whenever dealing with children or vulnerable adults even if those activities are being led by a partner organisation such as a school.

We also recommend that if an incident is reported all those involved, please read this policy thoroughly at the time they are made aware of the incident and carefully follow the approach and advice within. This is especially important in terms of listening to complainants/victims and accurately taking information in a sensitive manner.

Anyone involved with ARE — including trustees, staff, volunteers, members, and service users — must report safeguarding concerns to the Senior Designated Safeguarding Lead (DSL) or the Chief Executive Officer (CEO). In their absence, concerns should be escalated to a manager or trustee.

This policy applies to everyone involved in ARE’s work, including senior managers, trustees, employees, volunteers, contractors, agency staff, session workers, and placement students.

This policy aligns with other ARE policies, including:

Equity, Diversity, and Inclusion
Health and Safety
GDPR and Data Protection
Risk Management

Our safeguarding practices are informed by key legislation and guidance, including:

The Children Acts 1989 and 2004
The Care Act 2014 (formerly “No Secrets”)
The Education Act 2002
Every Child Matters (2003)
Working Together to Safeguard Children (2018)
GDPR (2018)

Our Commitments

The welfare and wellbeing of children, young people, and vulnerable adults is our top priority.
Everyone, regardless of age, ability, gender, racial or cultural heritage, religious belief, sexual orientation, or gender identity, has the right to protection from abuse.
We work in partnership with individuals, families, carers, and external agencies to promote well-being and safety.
Everyone at ARE has a duty to report suspected abuse; however, statutory investigations are carried out by the relevant social care and/or police services.
All allegations or concerns about misconduct, poor practice, or abuse will be taken seriously and addressed promptly.
Personal data will be processed in line with GDPR requirements to ensure confidentiality and protection of information.

1.02

This Safeguarding Policy forms an integral part of ARE’s Terms and Conditions of service. It applies to all staff, volunteers, and representatives, regardless of whether their role involves direct contact with children, young people under the age of 18, or vulnerable adults.

Safeguarding responsibilities extend beyond direct contact. All personnel may come into possession of confidential or sensitive information relating to individuals who could be at risk. As such, everyone has a duty to act responsibly and in accordance with this policy to protect the safety and well-being of children, young people, and vulnerable adults.

2.0 The purpose of the policy

This policy applies to all individuals working with or on behalf of ARE, including permanent, temporary, seconded staff, contractors, and volunteers.

The purpose of this policy is to:

Define what constitutes abuse and raise awareness of the different forms it can take.
Support staff and volunteers in recognising the signs of abuse and understanding their responsibility in responding appropriately.
Reduce the risk of abuse or neglect occurring within the organisation or through its services.

Specifically, the policy aims to:

Protect children, young people, and vulnerable adults who engage with ARE’s services from all forms of abuse and exploitation.
Provide clear guidance for staff and volunteers on the policies and procedures to follow when working with these groups.
Safeguard the confidentiality and personal data of service users — including the appropriate storage and sharing of photographs and images of children, young people, and vulnerable adults — in line with data protection legislation.

2.01 Safeguarding Actions

ARE is committed to safeguarding the welfare of children, young people, vulnerable adults, and volunteers by taking the following actions:

Valuing, listening to, and respecting all individuals, ensuring they feel heard and respected.
Adopting clear child protection guidelines and a robust code of conduct for staff and volunteers, which includes policies on bullying and online abuse.
Recruiting staff and volunteers safely, ensuring all necessary background checks are conducted in accordance with safer recruitment practices, including DBS checks.
Sharing information on child protection and best practices with children, parents, staff, and volunteers to promote awareness and understanding.
Respecting confidentiality while ensuring that information regarding safeguarding concerns is shared on a need-to-know basis with the relevant authorities or agencies.
Providing effective management and support for staff and volunteers through induction, ongoing supervision, professional support, and comprehensive training.
Reviewing and updating this policy, our procedures, and best practices regularly (at least annually) to ensure they remain relevant and effective.

3.0 Safeguarding Vulnerable Adults/Adults at Risk

(See Appendix 2 for definitions)

ARE is committed to ensuring that vulnerable adults and adults at risk are protected from abuse and exploitation. We actively work to implement practices that minimise the risk of harm.

Right to Live Free from Harm
Every individual has the fundamental right to live free from harm and abuse. As a society, it is our collective responsibility to act as good citizens, looking out for one another and preventing isolation that can often lead to vulnerable adults being exposed to abusive situations.

Collaboration with Statutory and Local Bodies
ARE is committed to working alongside statutory bodies, including local councils, the police, NHS organisations, and other local voluntary organisations, to promote safer communities. Our aim is to prevent harm and abuse, and to effectively respond to suspected or actual cases of abuse. In all our work, we prioritise the safety, dignity, and human rights of adults at risk.

Working Within a Multi-Agency Framework
ARE operates in line with the Islington Safeguarding Adults Board (SAB) and the Social Care Institute for Excellence (SCIE) multi-agency policy and procedures. This framework helps us:

Improve interagency collaboration
Ensure no individual falls through gaps in services
Reduce duplication of efforts across agencies
Foster a shared understanding of safeguarding among all stakeholders
Align the language and approaches used across different agencies

The Role of Staff and Volunteers
All ARE staff and volunteers — regardless of their role or setting — are on the frontline of safeguarding. They are integral in preventing harm and abuse, and in empowering individuals at risk to take action when concerns arise. Every member of the organisation has a responsibility to be vigilant, act swiftly, and ensure that any safeguarding concerns are raised appropriately.

4.0 Keeping Children and Young People Safe

(See Appendix 1 for definitions)

ARE is committed to safeguarding the welfare of children and young people, informed by key legislation and guidance, including:

The Children Act 1989 & 2004
The Care Act 2014 (No Secrets)
The Children and Education Act 2002
Every Child Matters (ECM) 2003
Keeping Children Safe in Education (KCSIE) 2024
Working Together to Safeguard Children 2018

ARE is dedicated to creating and maintaining the safest environment possible for children and young people. Safeguarding is everyone’s responsibility, and all individuals who come into contact with children and young people have a role to play. When working with young people, ARE will:

Recognise the right of every child to be free from abuse and harm.
Ensure that all staff and volunteers are carefully recruited, with relevant qualifications and experience, and take responsibility for helping to prevent the abuse of children in their care.
Respond promptly and appropriately to all suspicions or allegations of abuse, following our established safeguarding procedures.
Provide opportunities for children, young people, and parents/carers to voice concerns they may have, ensuring these concerns are taken seriously.
Adopt non-violent, non-humiliating disciplinary measures, ensuring that any sanctions used are respectful of the child’s dignity.
Appoint a designated Child Protection Officer (currently the Head of Education and Youth Programmes), who is responsible for overseeing the safety, protection, and well-being of children and young people.
Review this policy and safeguarding procedures annually to ensure they remain effective and up-to-date.
Collaborate with external organisations, including statutory bodies, to ensure that children and young people are adequately protected.
Take a firm stance against bullying — all bullying incidents will be investigated seriously, and appropriate action will be taken to stop bullying.

ARE works closely with the Islington Safeguarding Partnership (www.islingtonscp.org.uk) and follows the London Safeguarding Children Procedures and Guidance (www.londonsafeguardingchildrenprocedures.co.uk). These procedures apply to children under the age of 18.

Responding to a Disclosure of Abuse from a Child or Young Person

If a child or young person discloses abuse, it is essential to follow these steps to ensure their safety and well-being:

React calmly — This will help the child or young person feel supported and not frightened.
Listen carefully without interrupting and take the disclosure seriously.
Ask questions for clarification only. Avoid leading questions or suggesting answers.
Allow the child/young person to share their experience at their own pace without interruption.
Acknowledge the difficulty of disclosure and reassure them that they have done the right thing.
Reassure the child/young person that they are not to blame for the abuse.
Do not promise secrecy. Explain that you must report the information to someone in authority to keep them safe. Let them know there are others who can help.
Explain next steps: Inform them of what will happen next and who the information will be shared with.
Ensure the immediate safety of the child or young person, prioritising their protection.
Record the disclosure as soon as possible, using the child’s exact words. Include the date, time, setting, names mentioned, to whom the information was given, and any other relevant details. Sign and date the record.
Document any follow-up actions or events related to the disclosure.

It is not the responsibility of the person receiving the disclosure to determine whether abuse has occurred. All concerns or disclosures must be raised with the Senior Designated Person (SDP) — currently the Head of Education and Youth Programmes — who will follow through with the appropriate steps.

Handling Past Disclosures

If a child recalls past abuse in a safe environment, even if there is no immediate threat, the disclosure must still be reported to the Senior Designated Person and handled according to the safeguarding procedures.

Raising Concerns About a Child’s Welfare

If there are concerns about a child’s welfare, even without a formal disclosure or allegation, these concerns should be raised with the Senior Designated Person to ensure they are investigated and managed in the best interests of the child.

5.0 Designated Officer(s)

All staff working in ARE – whether paid or volunteer – are required to report instances of actual or suspected child abuse or neglect to the Designated Person with responsibility for child protection. The designated officers are;

The Senior Designated Persons (SDP): Brianna Cyrus, ARE Head of Education and Youth Programmes, brianna@actionforraceequality.org.uk Tel: 07735908195
The Designated Person (DP): Femi Bola MBE (ARE Trustee) f.bola@outlook.com Tel: 07917 162 492

5.01

The Senior Designated Person is the first point of contact for external agencies that are pursuing Child Protection investigations and will coordinate ARE’s responses at any Child Protection Conferences that may be called, where ARE’s presence is required. In all instances the SDP will liaise with the DP, who will have the ultimate responsibility for signing off all CP related issues on behalf of the Board of Trustees.

6.0 Implementation

The Senior Designated Person (SDP) will be responsible for all aspects of child protection awareness and implementation of the policy.

Responsibilities of the Senior Designated Person (SDP)

The Senior Designated Person (SDP) will be accountable to the Board of Trustees for the following responsibilities:

Ensuring Policy Implementation: Overseeing the effective implementation of the safeguarding policy throughout the organisation, ensuring that all staff, volunteers, and stakeholders are aware of and adhere to it.
Coordinating Safeguarding Procedures: Ensuring that all necessary child protection and safeguarding inquiries, procedures, and investigations are carried out in collaboration with relevant statutory agencies (e.g., social services, police).
Confidentiality and Record-Keeping: Reporting the outcomes of safeguarding inquiries while maintaining “need-to-know” levels of confidentiality. Ensuring that confidential records related to child protection or safeguarding concerns are securely stored and access is appropriately managed.
Staff Support and Awareness: Informing, educating, and supporting staff and volunteers to ensure they understand their roles and responsibilities in relation to safeguarding and the implementation of this policy.
Liaising with External Agencies: Engaging with social services, police, and other relevant agencies on both formal and informal levels, ensuring appropriate communication and collaboration on safeguarding concerns when necessary.
Monitoring Policy Implementation: Continuously monitoring the application of the safeguarding policy across the organisation, addressing any emerging issues or challenges. Regularly reporting on safeguarding matters and the status of the policy to the Board of Trustees.
Reporting Allegations: Ensuring that any allegations or suspicions of abuse are reported to the appropriate authorities, following established safeguarding procedures.
Staff Induction and Training: Ensuring that all staff and volunteers receive adequate induction and ongoing training on child protection and safeguarding, empowering them to handle concerns appropriately.
Ensuring Safeguarding Best Practices in Activities: Ensuring that all ARE activities, particularly those involving children, young people, and vulnerable adults, are conducted in a manner that upholds safeguarding standards with respect to personnel, practices, and premises.
Incident Report Review and Referrals: Reviewing and countersigning all incident reports submitted by staff and volunteers. Making referrals to relevant agencies or authorities as necessary, based on the information provided in the reports.

The SDP shall ensure active compliance with this policy by all staff working in ARE and shall work closely with the DP to ensure this, affording the DP every support to carry out this function. All other officers, staff and voluntary workers within ARE will be expected to apply and implement this policy.

7.0 Pre-employment Checks

ARE is committed to ensuring that all individuals — whether paid or voluntary — who work with children, young people, and vulnerable adults in ARE’s activities are appropriately vetted and as safe as possible in terms of safeguarding.

The Designated Person (SDP) will ensure that the following checks are carried out on all volunteers whose roles may involve substantial access to children, young people, and vulnerable adults:

Disclosure and Barring Service (DBS) Check: An Enhanced DBS check will be completed for all relevant staff and volunteers. This check helps identify any criminal convictions, cautions, warnings, or reprimands that might indicate potential safeguarding risks.
Personal Reference: A personal reference will be required from a nominated individual who is not related to the applicant and ideally has knowledge of the applicant’s character, trustworthiness, and experience working with children, young people, or vulnerable adults.
Mandatory DBS Consent: Consent to undergo a DBS check is a mandatory part of the application process. If the applicant refuses to consent, the application will be withdrawn. If the applicant is not selected for the role, the completed form will be returned unopened.
Start Date Contingency: No individual will begin working with children, young people, or vulnerable adults — or have access to confidential or personal information — until DBS clearance and satisfactory references have been received.
Regular Rechecks: All Trustees, staff, and volunteers will be rechecked every three years. This will be managed by the Senior Designated Person (SDP).
Disclosure of Changes in Circumstances: It is the responsibility of all trustees, staff, and volunteers to disclose any conviction, caution, bind-over, probation order, pending prosecution, or change in personal circumstances that could present a conflict of interest or risk to safeguarding, whether this occurs before or during their engagement with ARE.
Proof of Identity: The applicant must provide proof of identity, ideally through photographic documentation such as a passport or driver’s license, along with verification of their right to work and reside in the country. All documents will be securely maintained in the applicant’s personnel file.
Investigation of Discrepancies: If any discrepancies arise from the checks, they will be thoroughly investigated by the DP and SDP, especially regarding dates of residence, employment, voluntary work, and any past offences or convictions. The applicant will be advised on the procedures to challenge any inaccuracies in references or checks.
Break in Volunteering: If a volunteer takes a break from volunteering and later returns, they will be required to undergo the same vetting procedures again, including updated DBS checks and references.

8.0 Personnel Records

8.01 Record Maintenance for Safeguarding
In addition to the standard personnel records maintained in line with the Personnel Policy, each volunteer and staff member will have additional records relating to child protection and safeguarding considerations, which will be kept in compliance with GDPR. These records will include:

Copies of all forms, consents, and replies related to safeguarding checks (as outlined in section 5.02 above).
A progress check form documenting the status of checks and responses.
Notes for the file: If the Designated Person (DP) receives verbal or other non-written communication, the key details will be recorded and filed as part of the applicant’s records.

8.02 Retention and Destruction of Records
In line with GDPR requirements:

The files of unsuccessful applicants will be retained for six months and then safely destroyed by the DP.
The files of staff who leave ARE’s employment will be kept open for 12 months from their last day of employment, regardless of the length of employment. After 12 months, these files will be securely archived or destroyed, depending on the nature of the records.

8.03 Right to Access Records
Anyone working with ARE has the right to inspect their own confidential records, including those related to safeguarding. Access to these records can be requested by the individual from the Senior Designated Person (SDP). The SDP will not unreasonably withhold consent and will aim to provide access within five working days of the request.

However, the SDP may refuse access to these records in certain circumstances, including:

If granting access would jeopardise the operations of ARE.
If it would impede ongoing police or social services investigations into safeguarding matters.
If access could potentially compromise the welfare or safety of a child, young person, or vulnerable adult.

In cases where access is withheld, the SDP is not required to provide specific reasons for the decision. However, the SDP will report to the Board of Trustees that a request was made but refused, purely because it relates to the welfare and protection of children, young people, or vulnerable adults.

9. Activities

9.01 Pre-Activity Safeguarding Measures
Before any activity, site, or programme begins, the Senior Designated Person (SDP) will ensure that all necessary child protection and safeguarding measures are in place. This includes confirming that relevant staff and volunteers are briefed on their safeguarding responsibilities and that safeguarding protocols are clearly outlined for the activity.

9.02 Risk Assessments
In consultation with the partner organisation, the SDP will ensure that a comprehensive risk assessment is conducted. This assessment should include:

The layout of premises or activity sites to ensure safe environments for children, young people, and vulnerable adults.
The number of volunteers and the level of supervision required to guarantee adequate personal safety.
Identifying and addressing any potential problems related to supervision of volunteers or communication issues due to extended sites or off-site activities.

The risk assessment will be used to identify any safeguarding concerns and ensure that appropriate measures are taken to mitigate risks.

9.03 Awareness of External Risks
Staff and volunteers should remain mindful that abuse may be prevalent outside of the programme. A disclosure of abuse or signs of abuse may arise during the activity, or children, young people, or vulnerable adults may be present who have not yet disclosed that they are being abused. Therefore, it is essential that the environment created for activities fosters an atmosphere of safety, where individuals feel comfortable disclosing any concerns they may have. The SDP will ensure that mechanisms are in place for participants to report concerns confidentially.

9.04 Guidance on Physical Contact
In line with best safeguarding practice, staff and volunteers are instructed to avoid initiating any inappropriate physical contact with children, young people, and vulnerable adults. Any necessary physical contact should be appropriate, brief, and with clear consent. Staff should adhere to clear, professional boundaries always.

9.05 Responding to Safety Threats
If at any point staff, volunteers, or participants feel that their safety is being threatened or compromised, they must remove themselves from the situation immediately. They should inform the SDP or another designated safeguarding lead of the incident as soon as possible, so that appropriate action can be taken.

10. Reporting Concerns and Dealing with Disclosures

10.01 Duty to Report Concerns
Staff and volunteers working with children, young people, and vulnerable adults have a responsibility to immediately report any concerns, incidents, allegations, or other manifestations relating to child protection or safeguarding. This includes both direct disclosures and indirect signs of abuse, neglect, or inappropriate behavior.

10.02 Potential Signs of Abuse or Harm
Concerns can arise in various forms, including:

Verbal disclosures from children, young people, or vulnerable adults.
Written materials, online communication, or behavioral changes indicating distress or harm.
Physical signs, such as bruising, self-harm, or marks, including signs of bullying, child exploitation, or online abuse.
Emotional signs, like withdrawal, depression, or unusual fearfulness, which might indicate abuse or exploitation.

Staff and volunteers should remain vigilant for any changes in behaviour, appearance, or speech that could indicate underlying issues of harm.

10.03 Documentation of Concerns
It is vital that all incidents, observations, or concerns, no matter how minor, are documented immediately. The observer(s) must log the incident in the appropriate accident and incident report book or forms. The details should be brought to the attention of the Senior Designated Person (SDP) without delay.

10.04 Reporting Procedure
Staff and volunteers are required to provide both a verbal and written report as soon as a concern arises. This report should be:

Signed and dated within 24 hours of the incident.
Countersigned by the SDP, who will review it and add any relevant comments or recommendations, then pass it on to the Designated Person (DP) for further review and countersignature.

10.05 Multiple Observers
If multiple staff or volunteers witness the same incident, each individual must submit a separate report. These reports should then be cross-referenced by the SDP to ensure that all perspectives are considered and dealt with as a single case.

10.06 Volunteer Discussions
After the session ends, the SDP should ensure that volunteers have an opportunity to discuss concerns. This discussion allows the volunteer to express any worries or questions they may have. The SDP will take notes during the meeting and ensure that any relevant actions are followed up.

10.07 Escalation of Serious Concerns
If, after discussing with volunteers, it is determined that the concern is serious enough, the SDP will consult with the DP. If necessary, the DP will attend a meeting or arrange to meet relevant parties as soon as possible. If the concern involves a serious level of abuse or risk of harm, the DP must be involved to ensure an appropriate response. A formal investigation may be necessary in these cases.

10.08 Reviewing Concerns
At the meeting with the SDP, the concern or disclosure will be reviewed thoroughly. The SDP will:

Chair the meeting and take minutes.
Assess all evidence and consider previous related incidents.
Consult with the DP to determine the next course of action.
Document the decision and file it in the appropriate restricted file for safeguarding records.

10.09 Escalation for Immediate Action
If the concern indicates immediate risk of harm or abuse, the SDP is authorized to:

Immediately report to the Duty Officer at the Local Safeguarding Children’s Board (LSCB), Social Services, and/or Police.
If a Duty Social Worker cannot be located, the Police should be contacted to help secure immediate protection for the child, young person, or vulnerable adult.
No protocol should prevent this action when there is a genuine concern for safety.

In cases where immediate intervention is not required, the SDP will raise the concern informally with a liaison contact at Social Services or the LSCB, as appropriate. This informal approach ensures that ongoing concerns are discussed with the relevant authorities regularly, even if a formal investigation is not immediately warranted.

If there are concerns but insufficient hard evidence to trigger an urgent formal referral, the SDP should still raise the issue informally with Social Services or the LSCB for further assessment. This ensures that concerns are not ignored and that appropriate monitoring and follow-up occur.

11. Feedback and Reporting

11.01 Assurance and Feedback to Staff and Volunteers
Staff and volunteers who report concerns will be reassured that appropriate action is being taken in response to their report. The Senior Designated Person (SDP) and Designated Person (DP) should provide feedback when possible, within the bounds of confidentiality and safeguarding protocols. While the DP may not always have full information, especially after a report is made to Social Services, they should seek to ascertain the specific actions taken—on a need-to-know basis—such as whether the police have been informed or whether further actions are being pursued.

11.02 Principles of Information Sharing
In providing feedback to staff and volunteers, the SDP will follow strict principles of information sharing. This feedback will be shared on a “need-to-know” basis to maintain confidentiality and the integrity of any ongoing investigations or procedures.

For example, the volunteer who made the initial report can be told whether any referrals have been made to agencies such as the DBS, Social Services, the police, or any other relevant authority. However, sensitive details, such as the identities of those involved or the specifics of an ongoing investigation, will not be shared unless it is essential for the staff or volunteer to know.

11.03 Board of Trustees Reporting
The SDP will provide a regular report on child protection matters during scheduled Board of Trustees meetings. This will be an ongoing standing item on the agenda to ensure that child protection and safeguarding are always a priority at the leadership level. The SDP‘s report will include:

The results of police and other background checks on new applicants. The report will include the name of the applicant and whether the checks were satisfactory, but without revealing specific details regarding the outcome.
Any formal reports made to the Police or Duty Social Worker, ensuring that the names of children and families are omitted to protect confidentiality.
Any informal discussions or reports made by the DP to Social Services through liaison arrangements, with appropriate care to omit sensitive information.
An update on child protection training and the level of staff awareness regarding safeguarding matters, to ensure that all staff are consistently trained and informed about their safeguarding responsibilities.

12. Allegations Against Board of Trustees, Staff Team, or Volunteers

12.01 Procedure Following an Allegation Against a Staff Member or Volunteer
If an allegation is made against a staff member, volunteer, or a member of the Board of Trustees, the following procedure will be followed:

The person receiving the allegation must immediately contact the Senior Designated Person (SDP).
Upon receipt of the complaint, the SDP will contact Social Services to inform them of the situation. In the case of a criminal allegation, the SDP will initiate formal contact with the Duty Social Worker and the police.
The SDP should inform the person against whom the allegation has been made as soon as possible, unless notifying them might prejudice a criminal investigation. This decision must be made in consultation with the police.

12.02 Course of Action Based on the Nature of the Allegation

Criminal Allegations (e.g., sexual abuse, physical assault, inappropriate behaviour):
- The SDP will activate the Disciplinary Procedure, suspend the individual from any activity involving children or vulnerable adults within ARE, pending investigation.
- The suspension will be on full pay (for staff members) and will remain in place until police and/or Social Services confirm the allegations are unfounded. An incident report will be made and treated confidentially.
- The matter will be immediately reported to the police and Local Safeguarding Children Board (LSCB) or Social Services.
Non-Criminal Allegations:
- The SDP will collect as much information as possible, examining available reports or other information. However, the SDP should not interview the child (or others) if the situation involves a criminal allegation—this is the responsibility of the authorities.
- The SDP will assess whether there is a child protection/safeguarding concern and whether the worker should be suspended. The SDP will advise the Board of Trustees regarding any possible suspension and make recommendations as appropriate. This may include situations where non-criminal behaviour could still constitute gross misconduct.
Decisions and Reporting to the Board of Trustees:
- The SDP will report to the Board of Trustees on the outcome of the investigation and will recommend whether:
  - The matter should be treated as a disciplinary issue (misconduct or gross misconduct), with the associated right of appeal.
  - The allegations should be dismissed as unfounded, or if appropriate, make non-disciplinary recommendations.
  - The person under investigation should be given the opportunity to respond to the allegations during an interview conducted by the SDP, which will be minuted.

12.03 Suspension and Disciplinary Action in Case of Serious Allegations

Criminal Allegations:
- If the Disciplinary Committee believes that the misconduct is serious enough to justify immediate dismissal, the individual will be suspended until the investigation is complete.
- The individual under suspension must maintain communication with the Designated Person (DP) regarding matters related to their employment during suspension, and the terms of communication (whether in-person or by phone) will be clearly defined.
Post-Investigation Action:
- If the investigation results in a conviction for a serious offence involving a child, young person, or vulnerable adult, the SDP will consider the police report and make recommendations to the Board of Trustees, which could include instant dismissal.
- If no conviction occurs but there is evidence of misconduct, the disciplinary process will proceed, as outlined in section 12.02.

12.04 Lesser Forms of Misconduct
If the allegation involves a lesser form of misconduct, such as inappropriate behaviour that does not rise to the level of a criminal act but still poses a risk to children’s welfare, it will be reported under the Misconduct provisions of the Disciplinary Procedure.

If deemed necessary, Social Services will be informed, and they may advise on the person’s suitability to continue working with children or vulnerable adults.
The SDP will liaise with Social Services and make a report with recommendations to the Board of Trustees.

12.05 Duty to Report to LSCB/DBS
In the event of a dismissal arising from misconduct related to child protection/safeguarding, ARE has a duty to inform the Local Safeguarding Children Board (LSCB) and the Disclosure and Barring Service (DBS).

12.06 Prohibition of Contact During Suspension
Under no circumstances will an individual under suspension be allowed to re-enter the project, property, or participate in any activities related to ARE while under suspension. This restriction applies even if there are no children or young people present.

13. Induction, Training and Awareness Raising

13.01 The Senior Designated Person shall ensure that there is adequate and appropriate induction and ongoing training and information to all voluntary workers concerning child protection/safeguarding matters. All Trustees, employees and voluntary workers shall be required to undergo a period of probation, a period of induction and child protection/safeguarding training. On appointment, the following shall apply to all Trustees, staff and volunteers:

(a) Induction

Introduction to policies and procedures.
Understanding of expectations and duties.

(b) Training

Protecting children, young people and vulnerable adults from all forms of abuse including bullying, online (cyber bullying), child exploitation and child sexual exploitation.
Working effectively with children, young people and vulnerable adults (including presentation skills, developing child and vulnerable adult friendly resources and activities).
Any other identified training needs.

NSPCC	– NSPCC Learning homepage – safeguarding training and resources	Help for adults concerned about a child Call us on 0808 800 5000 Help for children and young people Call Childline on 0800 1111
Anna Croft Trust	https://www.anncrafttrust.org/resources/	0115 951 5400
London Safeguarding Children’s partnership	https://www.londonsafeguardingchildrenprocedures.co.uk/ These procedures apply to children under the age of 18. Link to wider directory of national contacts tri.x National Contacts (proceduresonline.com)
Childline	https://www.childline.org.uk/	0800 1111 (24 hours)
NHS England – Safeguarding Adults	NHS England » Safeguarding

14.01 Regular Monitoring and Review

This policy will be monitored and reviewed annually to ensure that it remains effective and in line with current legislation, guidance, and ARE’s operational needs. The policy will be reviewed under the following circumstances:

Legislative and Guidance Changes: Any changes in national legislation, government guidance, or relevant best practices concerning the protection of children, young people, and vulnerable adults.
Issues or Concerns: Following any issues, incidents, or concerns raised regarding the protection of children, young people, or vulnerable adults in the course of delivering services or activities within ARE. This includes feedback from staff, volunteers, or external agencies.
Other Relevant Changes: In cases where external audits, internal evaluations, or other changes to the operational structure or activities of ARE require an update to the policy.

14.02 Engagement in Review Process
The review process will involve the Board of Trustees, Senior Designated Person (SDP), Designated Person (DP), and any relevant stakeholders, including safeguarding advisors, legal professionals, and local safeguarding boards. The purpose of the review is to:

Ensure that the policy continues to meet the safeguarding and child protection needs of the individuals and communities served by ARE.
Assess the effectiveness of the safeguarding measures in practice, taking into account incidents or feedback that have arisen during the previous year.

14.03 Updating the Policy
Where necessary, updates will be made to the policy to ensure ARE’s ongoing compliance with the law and best safeguarding practices. Any amendments will be communicated to staff and volunteers, and appropriate training will be provided to ensure they are aware of any updates or changes to the policy.

14.04 Reporting the Outcome of Reviews
The results of the policy review will be reported to the Board of Trustees at the earliest opportunity, outlining any updates or changes made to the policy, and the rationale behind those changes.

Accountability for the Implementation and Review of the Policy: Senior Designated Person

APPENDIX

Appendix 1: Child Protection and Safeguarding Concerns

What is Abuse?

Abuse can take many forms, including:

Physical Abuse: The use of force resulting in injury or pain, including non-accidental harm like hitting, shaking, or poisoning.
Sexual Abuse: Involvement of an adult or peer in sexual activities without consent, including physical or non-physical acts like exploitation or grooming.
Emotional & Psychological Abuse: Harmful behaviour that affects emotional health, such as verbal abuse, manipulation, and denial of rights.
Institutional Abuse: Mistreatment within a system or care setting that disregards dignity and human rights.
Discriminatory Abuse: Abuse caused by misuse of power based on values, beliefs, or culture, leading to inequality.
Financial & Material Abuse: Misuse of a person’s assets or resources without consent, including theft, fraud, or exploitation.

What is Abuse of Children?

Children may experience:

Physical Abuse: Hitting, shaking, poisoning, or causing injury.
Sexual Abuse: Involvement in sexual activities or exposure to sexual content without understanding or consent.
Emotional Abuse: Constant criticism, isolation, bullying, or preventing social interaction.
Neglect: Failing to meet basic needs like food, shelter, protection, and supervision.
Child Exploitation: This includes any situation where a child is manipulated or coerced into engaging in activities for someone else’s benefit, such as forced labour, illegal activities, or exploitation through pornography. Online spaces, particularly through social media, online gaming, and messaging apps, can be used to exploit children for illegal activities.
Child Sexual Exploitation (CSE): This involves manipulating or coercing children into engaging in sexual activities for the benefit of the perpetrator. It can occur in both physical spaces and online spaces. With the rise of online platforms, there are increasing cases where children are groomed or exploited online for sexual purposes.

Bullying is also a form of abuse, which can be verbal, physical, or emotional. It includes cyberbullying through digital platforms.

Signs of Abuse/Neglect in Children:

Verbal/Behavioural Cues: Information from the child, sudden mood changes (e.g., becoming withdrawn or aggressive), and unexplained weight loss.
Physical Signs: Unexplained bruising, self-harm, and injuries.
Changes in Eating Habits: Loss of appetite or overeating.

Actions for Staff and Volunteers:

Prohibited Actions:
- Do not exchange money, goods, or services for sexual activity.
- Avoid engaging in any sexual relationships with beneficiaries.
Required Actions:
- Contribute to creating a safeguarding-friendly environment.
- Report any safeguarding concerns or suspicions to the appropriate staff member immediately.

Appendix 2: Definitions of Vulnerable Adults

A vulnerable adult is defined as a person aged 18 or over who:

Is or may need community care services due to mental or physical disability, illness, or other conditions.
Is or may be unable to care for themselves or protect themselves from significant harm or exploitation.

This definition, outlined in the Law Commission’s ‘Making Decisions’ (Lord Chancellor’s Department, 1999), includes individuals who may be at risk due to factors such as disabilities, mental health conditions, immigration status, or difficulties accessing necessary services.

Definition of Abuse

Abuse involves the harm or mistreatment of an individual by someone in a position of power, trust, or authority. This harm may be:

Physical (e.g., hitting, neglect)
Psychological or emotional (e.g., manipulation, coercion)
Exploitation of the individual’s vulnerability, including neglect or financial abuse.

Appendix 5: Recording pro forma to be used in relation to disclosures and/or incidents of safeguarding concerns.

Date
Time
Name of person making disclosure
DOB
Address
Tel number
Name(s)/address of parents/guardian (if different from above) Contact details (T/M/E)
Name of the member of staff making the report
Position/role
Contact number (s)
Brief summary of disclosure
Line Manager’s comments
Staff signature (reporting)

This page has been updated as of 11/11/2025.