Safeguarding Children Policy

Safeguarding Children Policy and Procedure

SWIFT Appropriate Adult Service C.I.C. (SWIFT) regards the health, safety and welfare of all beneficiaries’ as one of its highest priorities. The organisation recognises and fully accepts its moral and statutory duty to safeguard and promote the welfare of children, young people and vulnerable adults and its duty to protect staff from unfounded allegations of abuse.

This policy applies to all staff and volunteers working on behalf of SWIFT.

Principles of Safeguarding at SWIFT Appropriate Adult Service:

We will ensure:

  • A safe and trusted environment for all clients, staff and volunteers.

  • Those suffering or at risk of suffering significant harm or abuse are identified and referred to the necessary agencies as appropriate.

  • All staff and volunteers learn about safeguarding, the organisation’s policies and procedures and how to keep themselves and others safe.

We will do this by:

  • Appointing a Designated Safeguarding Lead (DSL) and a Safeguarding Team to lead on all safeguarding matters.

  • Following safe recruitment procedures which ensure that staff are carefully selected, vetted and have relevant qualifications and experience.

  • Raising awareness of issues relating to the welfare and safeguarding of children, young people and vulnerable adults.

  • Promoting a safe and trusted environment.

  • Engaging with safeguarding partners to ensure their commitment to safeguarding.

  • Ensuring staff and volunteers recognise the signs of abuse or that an individual maybe at risk of significant harm.

  • Working with other agencies as appropriate (e.g. Police, Children’s’ Services, Safeguarding Partners) where an individual is being, or at risk of being, significantly harmed.

  • Providing a framework for reporting and dealing with concerns and disclosures.

  • Establishing clear procedures for the reporting and handling of allegations of abuse against staff or volunteers.

  • Requiring staff and volunteers to undertake safeguarding training as appropriate.

Legislative Frameworks

The legislative frameworks around our policy are:

  • Children’s Act 2014, which is fundamental to people working with children and young adults in the UK.

  • Children & Social Work Act 2017 which made a number of changes to child protection, child welfare and safeguarding.

  • Working Together to Safeguard Children (2018) reaffirms safeguarding as everyone’s responsibility and the sharing of information between agencies.

  • Sexual Offences Act 2003 makes it is an offence for a person over 18 to have a sexual relationship with a child under 18 where that person is in a position of trust in respect of that child, even if the relationship is consensual.

  • Safeguarding Vulnerable Groups Act 2006 sets out the type of activity in relation to children and adults at risk for which employers and individuals will be subject.

  • Protection of Freedoms Act 2012 which changed the definition of Regulated Activity including who is eligible for a barred list check.

  • Keeping Children Safe in Education (2020) requires all staff to read and understand their responsibilities if engaged in ‘regulated’ activities with young people.

  • The Prevent Duty 2015 - to have due regard to preventing people being drawn into terrorism.

  • Data Protection Act (1998) – to protect personal data stored on computers or in an organised paper filing system.

  • Modern Slavery Act (2015) – designed to combat modern slavery in the UK and consolidates previous legislation relating to trafficking and slavery.

  • SEND Code of Practice 0-25 years (2014) – statutory guidance for organisations that work with and support children, young people and vulnerable adults with special educational needs and disabilities.

Other legislation which are worth noting and have prompted changes in Safeguarding practices over time are:

  • GDPR and the Data Protection Act 2018.

  • Information Sharing: Advice for Practitioners 2018.

  • Sexual Violence and Sexual Harassment Between Children in Schools and Colleges (guidance document) 2018.

  • Childcare (Early Years Provision Free of Charge)(Amendment) Regulations 2018.

  •  Childcare Act 2006 (as amended in 2018).

Definitions of Abuse

The following are recognised as definitions of abuse, although any act which harms a child, young person or vulnerable adult should also be considered:

  • Physical Abuse - may involve hitting, shaking, throwing, poisoning, burning, scalding, drowning or suffocating. It may be done deliberately or recklessly, or be the result of a deliberate failure to prevent an injury occurring.

  • Neglect - the persistent or severe failure to meet a child’s, young person’s or vulnerable adult’s physical and/or psychological needs, which may result in serious impairment of their health or development.

  • Sexual Abuse involves a child, young person or vulnerable adult being forced or coerced into participating in or watching sexual activity of any kind. Any apparent consent or awareness is irrelevant.

  • Emotional Abuse – persistent emotional ill treatment or rejection; includes abusive or offensive electronic communications. This causes severe and adverse effects on behaviour and emotional development, resulting in low self-esteem. Some degree of emotional abuse is present in all forms of abuse.

  • Financial Abuse - in intimate or parental relationships is a way of controlling a person’s ability to acquire, use, and maintain their own money and financial resources.

  • Significant Harm – The Children’s Act introduced the concept of significant harm as the threshold that justifies compulsory intervention in family life in the best interest of the children. Some children may be in need of help because they are suffering or likely to suffer significant harm.

  • Extremism and Radicalisation – Extremism is defined as ‘vocal or active opposition’ to fundamental British values; democracy, the rule of law, individual liberty and mutual respect for and tolerance of those with different faiths and beliefs and for those without faith. Radicalisation is defined as ‘the way in which a person comes to support terrorism and encourages other people to believe in views that support terrorism’.

  • Criminal Exploitation – is a form of modern slavery that sees victims being forced to work under the control of highly organised criminals in activities such as drug dealing, forced begging, shoplifting and financial exploitation.

  • Female Genital Mutilation - all procedures involving partial or total removal of the external female genitalia for non-medical reasons. FGM is illegal in England and Wales under the FGM Act 2003.

  • Forced Marriage - as distinct from a consensual arranged one, is a marriage conducted without the full consent of both parties and where duress is a factor. Duress cannot be justified on religious or cultural grounds. A child who is being forced into marriage is at risk of significant harm through physical, sexual and emotional abuse.

Other Definitions

  • Safeguarding – protecting children, young people and vulnerable adults from maltreatment, preventing impairment of their health or development and ensuring they are growing up in circumstances consistent with the provision of safe and effective care.

  • Child Protection – any activity that is undertaken to protect specific children who are suffering, or are likely to suffer, significant harm.

  • Child/Young Person – anyone under the age of 18.

  • Regulated Activity - Those working in specified activities will be classed as engaging in regulated activity. Put simply, this is anyone who is teaching, training, instructing, coaching, caring for or supervising children or providing personal care, healthcare, social work, assistance with household matters and personal affairs, and transportation to vulnerable adults.

Roles & Responsibilities

Safeguarding is everyone’s responsibility and all staff and volunteers involved in the organisation’s activities have a role to play. SWIFT will ensure that staff and volunteers undergo safeguarding training at induction, advanced training (as appropriate) and will take part in the annual CPD programme where safeguarding updates/refreshers will be programmed.

Designated Safeguarding Lead (DSL)

The DSL is David Hill – Company Director. The DSL will be responsible for:

  • Managing the referral of cases of suspected abuse or allegations to the relevant agencies.

  • Providing advice and support to staff and volunteers who have made referrals to other agencies.

  • Maintaining secure and accurate records of any safeguarding concern, referral, complaint or allegation.

  • Attending case conferences and review meetings as appropriate.

  • Communication of the policy and arrangements to all relevant parties including but not limited to children, young people and vulnerable adults, their parents and families, staff and volunteers.

  • Engaging with local authorities and other agencies as appropriate.

  • Ensuring that staff and volunteers receive safeguarding training appropriate to their roles and update this annually.

  • Maintaining accurate and up to date employment records of all staff and volunteers including DBS checks.

  • Maintaining safeguarding training records.

  • Safety of all clients, including when a young person or vulnerable adult is absent or missing, without explanation.

  • Providing periodic reports to the board about safeguarding incidents or referrals as well as policy implementation.

  • Act as a source of support, advice and expertise for staff and volunteers.

Dealing with Concerns and Disclosures

If any member of staff or volunteer is concerned about the welfare or safety of a child, young person or vulnerable adult, they must report their concerns to the DSL as soon as practicably possible. Staff and volunteers will receive training on how to deal with disclosures made by a child, young person or vulnerable adult. Written notes of the disclosure will be made by the member of staff or volunteer and these will be held in a secure location and shared with the relevant agencies as appropriate.

Staff and Volunteers

Safer Recruitment

SWIFT operates safer recruitment and employment practices. Staff checks and critical process undertaken include:

  • Enhanced Disclosure and Barring Service (DBS) check where the member of staff, trustee or volunteer is involved or likely to be involved in ‘regulated’ activity. Where this is not the case a standard DBS check will be made.

  • Where a conviction is recorded, the DSL will carry out a risk assessment and decide whether to confirm or reject the individual’s appointment. (Anyone that is barred from working with children will NOT be appointed)

  • Two employment/education references including the most recent employment.

  • Check on gaps in work history.

  • Evidence of identity is obtained, including the right to work in the UK.

  • Qualifications are checked and verified with original certificates.

  • Areas of concern in the CV or application will be addressed during the interview.

  • Applicants sign the application form to declare the information they have provided is true.

Allegations against Staff or Volunteers

The primary concern in the event of an allegation is to ensure the safety of the child or young person. In all cases, action will be taken quickly, confidentially and professionally, with all parties clear that suspension is not an indicator of guilt, but a required part of a process.

Where an allegation is made, the DSL will liaise with the Local Area Designated Officer (LADO) to discuss the required action. In order that a full and fair investigation can be carried out, consideration must be given to suspending the member of staff or volunteer.

Where it is clear that a criminal offence may have occurred, the matter must be reported to the police. Any subsequent dismissal and/or must be reported to the Disclosure and Barring Service.

In the event that a member of staff or volunteer suspects any other member of staff or volunteer of abusing a child, young person or vulnerable adult, it is their responsibility to report these concerns to the Designated Safeguarding Lead. If the allegation is against the DSL, a member of the Safeguarding Team must escalate the matter to the organisation director and take advice regarding further action.

The SWIFT Designated Safeguarding Lead is David Hill.

Safeguarding Children Procedure

Process to follow if you suspect that a child is at risk of harm:

We have a statutory duty to notify agencies if we have a concern about a child’s safety or welfare (Working Together to Safeguard Children 2018). Where there is a concern about a child’s welfare or wellbeing or a concern that a child is in need of protection, this should be recorded on the concern form and then passed on to the DSL or a member of the Safeguarding Team (or if unavailable then seek advice from Children’s Services).

These running records should be kept securely in the child’s file. All staff and volunteers are aware that they must report concerns immediately. All records of concerns, emails, notes of phone conversations and actions are filed confidentially and securely in the child’s file. Staff know that when they have concerns about a child’s welfare they need to:

  • Focus on the needs of the child – their physical and emotional welfare.

  • Be sensitive.

  • Talk it over with one of the Designated Members of Staff.

This Safeguarding Policy is accessible to all staff.

Managing a ‘Disclosure’

Staff should:

  • Stay calm and listen to the child.

  • Ask questions for clarification only. Avoid asking leading questions that suggest a particular answer.

  • Consider how to explain to the child about our policies and procedures so that they know what is going to happen.

  • Tell them who you are going to tell so that they can be made safe – children may fear that what they have said will be passed on to everyone and they need to know that this will not be the case.

  • Control expressions of panic or shock.

  • Use the child’s language or vocabulary.

  • Offer comfort bearing in mind the age and needs of the child.

  • If the child has disclosed sexual abuse, ask them when it happened but nothing more.

  • Whether a child is asked this question will depend upon the child’s age and understanding.

  • Tell them that they were right to tell you and it was not their fault and that they have not done anything wrong.

  • Do not be tempted to give false reassurances to the child but tell them that you will do your best to protect or help them.

  • As soon as possible take care to record in writing what was said using the child’s own words.

  • Record the date, time, setting, any names mentioned, to whom the information was given and other people present. Sign and date the record.

  • Record any subsequent events and actions.

  • It is not your responsibility to decide if a child has been abused. Any disclosure must be raised with the Designated Safeguarding Lead.

Recording and Reporting

Recording is a tool of professional accountability and is central to safeguarding and protecting children. It is not always possible to know whether a small or vague concern held today may increase as the days or weeks pass and later form the substance of a child protection referral.

For this reason, it is vital that concerns are recorded accurately so that they can be monitored, and emerging patterns noticed.

Inappropriate behaviour by Staff

All staff must be vigilant in relation to inappropriate behaviour displayed by members of staff, or any other person working with the children. Examples include inappropriate sexual comments; excessive one-to-one attention beyond the requirements of their usual roles and responsibilities; or inappropriate sharing of images. 

Training

All members of staff will regularly access appropriate safeguarding training (depending on their level of responsibility) as advised by Local Authority Safeguarding Partners and ensure their knowledge is up to date on safeguarding issues. SWIFT will ensure that the training made available will enable staff to identify signs of possible abuse and neglect at the earliest opportunity, and to respond in a timely and appropriate way.

Safer Recruitment

Safe recruitment and selection practice is vital to safeguarding and protecting children. Staff must give management details of any incident, order, determination, conviction or any other possible issue which may impact on their suitability to work with children. Please refer to the ‘Safer Recruitment Policy and Procedure’ for more detailed information.

Responding to allegations made against a member of staff/volunteer

Any allegation made against a professional must be shared with the DSL immediately. Staff members will follow SWIFT's ‘Allegations Against Staff Policy and Procedure’ The DSL will liaise with the Local Authority Designated Officer (LADO) who will manage any allegation in line with relevant local authority policies.

Children harming other children (Peer on Peer Abuse)

It is part of our duty of care that we make sure children are protected from harm from other children. Please refer to the Behaviour Policy for managing these incidents. If you think that a child is targeting another child it is important to raise this with the Management Team immediately. In recording and reporting incidents it is important that the identity of the child that did the hurting is not disclosed. This is part of our duty of confidentiality to all children and families. If a parent asks who has hurt their child, show understanding of their upset, anger or pain but explain that we are not able to share this information.

E-safety and use of digital devices

Our aim is to:

  • Protect children and young people who receive SWIFT's services and who make use of information technology (such as mobile phones, games consoles and the internet) as part of their involvement with us.

  • Provide staff and volunteers with the principles that guide our approach to e-safety.

  • Protect professionals.

  • Ensure that, as an organisation, we operate in line with our values and within the law in terms of how we use information technology.

We recognise that:

• The welfare of the children/young people who come into contact with our services is paramount and governs our approach to the use and management of information communications technologies.

• Mobile phones and digital devices can present a number of problems when not used appropriately.

• Phones and personal devices can allow internet access and bypass the security settings and filtering.

• Mobile phones with integrated cameras could lead to child protection, bullying and data protection issues with regard to inappropriate capture, use or distribution of images of children or staff.

Cameras

It is not the intention to prevent parents/carers from taking pictures, but to ensure that photographic practices are monitored and to reduce the risks of inappropriate photography/filming. No one is permitted to photograph or record images whilst undertaking duties on behalf of SWIFT:

Mobile Phones

• Staff are not permitted to use their personal mobile phones for contacting anyone outside the setting in a professional capacity.

• The SWIFT office number should be used for staff expecting a personal call or as an emergency contact.

Useful Numbers:

  • NSPCC (National Society for the Prevention of Cruelty to Children) Child Trafficking Advice and Information Line (CTAIL) Tel 0800 107-7057

  • ECPAT (End Child Prostitution and Trafficking) Tel 020 7233-9887 Visit www.ecpat.org.uk

  • Barnardo’s Young Women’s Project & Trafficking Service PO Box 34727, London N7 8YQ Tel 020 7700 2253

  • UKHTC (United Kingdom Human Trafficking Centre) Tel 0114 252-3891 Visit www.ukhtc.org

  • CEOP (Child Exploitation and Online Protection) Centre Tel 0870 000-3344 Visit www.ceop.gov.uk UK Border Agency Tel 020 7147 5554

  • FGM helpline if you're worried a child is at risk of, or has had, FGM 0800 028 3550

  • Forced Marriage Unit Tel 020 7008 0151