Safeguarding Policy

Safeguarding describes the actions we take to ensure the safety and wellbeing of customers accessing the Charity’s services.

Abuse is a form of maltreatment. Somebody may abuse or neglect by inflicting harm or by failing to act to prevent harm. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children.

Physical

Actual or likely physical harm and/or failure to prevent physical injury (or suffering), including fabricated or induced illness (FII).    

Sexual

Involves forcing or enticing a child, young person or vulnerable adult to take part in sexual activities, not necessarily involving a high level of violence, whether or not they are aware of what is happening.

Emotional

Persistent emotional maltreatment of a child, young person or vulnerable adult which may cause severe and adverse effects on their the child’s emotional development.

Bullying and Harrassment

Bullying and harassment is behaviour that makes someone feel intimidated or offended. Bullying and harassment can happen face-to-face, online, by email or by phone. Harassment is against the law when unwanted behaviour relates to a protected characteristic included but not limited to age, sex, disability, race, religion or belief, gender identity or sexual orientation.

Neglect

Persistent failure to meet a child’s, young person or vulnerable adult’s basic physical and/or psychological needs, likely to result in the serious impairment of their the child’s mental and physical health or development. It may also include neglect of, or unresponsiveness to, a child’s, young person or vulnerable adult’s basic emotional needs.

Harm

The ill treatment or impairment of health or development, including impairment suffered from seeing or hearing the ill-treatment of another.

Child Sexual Exploitation and Child Criminal Exploitation

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact, it can also occur through the use of technology. Like all forms of child sex abuse, child sexual exploitation: 

• can affect any child or young person (male or female) under the age of 18 years, including 16 and 17 year olds who can legally consent to have sex; 
• can still be abuse even if the sexual activity appears consensual; 
• can include both contact (penetrative and non-penetrative acts) and noncontact sexual activity; 
• can take place in person or via technology, or a combination of both; 
• can involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence; 
• may occur without the child or young person’s immediate knowledge (e.g. through others copying videos or images they have created and posted on social media); 
• can be perpetrated by individuals or groups, and children or adults, regardless of gender identity. The abuse can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse; and 
• is typified by some form of power imbalance in favour of those perpetrating the abuse. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources.

Sexual violence and abuse

Sexual violence and abuse is where any behaviour thought to be of a sexual nature is unwanted and takes place without consent. Sexual violence and abuse can be physical, psychological, verbal or online. Any behaviour of a sexual nature that causes distress is considered sexual violence or abuse.

Sexual Violence is physical sexual acts without the consent of the other person or when the other person is unable to give consent

Harmful Sexual Behaviour

Children’s sexual behaviour exists on a wide continuum, ranging from normal and developmentally expected to inappropriate, problematic, abusive and violent. Problematic, abusive and violent sexual behaviour is developmentally inappropriate and may cause developmental damage. The term “harmful sexual behaviour” (HSB) is used to describe this. HSB can occur online and/or face-to-face and can also occur simultaneously between the two.

Domestic Abuse

Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners, family members, or part of shared households, regardless of gender or sexuality. The abuse can encompass, but is not limited to:  

• psychological; 
• physical; 
• sexual; 
• financial 
• emotional 

Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on children and adults affected. In some cases, a child or adult may blame themselves for the abuse or may have had to leave the family home as a result. Domestic abuse affecting young people can also occur within their personal relationships, as well as in the context of their home life.

Female Genital Mutilation

Female Genital Mutilation (FGM) comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long-lasting harmful consequences. There is a statutory duty to report to the police where FGM appears to have been carried out on a girl under 18 (either through disclosure by the victim or visual evidence).

So-called ‘honour-based’ abuse

So-called ‘honour-based’ violence (HBV) encompasses incidents or crimes which have been committed to protect or defend the honour of the family and/or the community, including female genital mutilation (FGM), forced marriage, and practices such as breast ironing. Abuse committed in the context of preserving “honour” often involves a wider network of family or community pressure and can include multiple perpetrators. It is important to be aware of this dynamic and additional risk factors when deciding what form of safeguarding action to take. All forms of HBV are abuse (regardless of the motivation) and should be handled and escalated as such. 

Forced Marriage

Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical, financial or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some communities use religion and culture as a way to coerce a person into marriage. Schools and colleges can play an important role in safeguarding children and young adults from forced marriage.

Child on Child Abuse

Children can abuse other children, young people, and adults. This is generally referred to as child on child abuse and can take many forms. This can include (but is not limited to) bullying (including cyberbullying); sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, upskirting or otherwise causing physical harm; sexting and initiating/hazing type violence and rituals.

Serious Violent Crime

Unexplained gifts/new possessions – these can indicate children, young people and vulnerable adults have been approached by/involved with individuals associated with criminal networks/gangs, increased absence from school/ college, change in friendship/relationships with others/groups, significant decline in performance, signs of self-harm/significant change in wellbeing, signs of assault/unexplained injuries.

Cuckooing

Cuckooing is a practice where people take over a person’s home and use the property to facilitate exploitation. There are different types of cuckooing:

• Using the property to deal, store or take drugs
• Using the property for sex work
• Taking over the property as a place for them to live
• Taking over the property to financially abuse the tenant.

The most common form of cuckooing is where drug dealer/gangs take over a person’s home through intimidation and use it to store or distribute drugs.

County Lines

County Lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs into one or more importing areas [within the UK], using dedicated mobile phone lines or other forms of “deal line”. A common feature in county lines drug supply is the exploitation of young and vulnerable people. The dealers will frequently target children and adults – often with mental health or addiction problems – to act as drug runners or move cash so they can stay under the radar of law enforcement.

Sexual Consent

Consent is an agreement between participants to engage in sexual activity. Consent should be clearly and freely communicated. A verbal and affirmative expression of consent can help both partners to understand and respect each other’s boundaries. It should happen every time for every type of activity. Consenting to one activity, one time, does not mean someone gives consent for other activities or for the same activity on other occasions.

• Consent cannot be given by individuals who are underage, intoxicated or incapacitated by drugs or alcohol, or asleep or unconscious. If someone agrees to an activity under pressure of intimidation or threat, that isn’t considered consent because it was not given freely.
• Unequal power dynamics, such as engaging in sexual activity with an employee or student, also means that consent cannot be freely given due to social perception

On-line abuse

Online abuse is any type of abuse that happens on the internet. It can happen across any device that’s connected to the web, like computers, tablets and mobile phones. And it can happen anywhere online, including, text messages and messaging apps, social media, emails, online chats, online gaming and live streaming sites. Children, young people and adults can be at risk of online abuse from people they know or from strangers. It might be part of other abuse which is taking place offline, like bullying or grooming. Or the abuse might only happen online. Children, young people and vulnerable adults may experience different types of online abuse such as; cyberbullying, emotional abuse, grooming, sexting, sexual abuse, sexual exploitation, with the signs being very much the same.

Abuse can occur in a family, institutional or community setting by someone they know, or more rarely, by a stranger, for example via the internet. The following can be signs of abuse: 

Physical

Unexplained (or repeated) bruises, burns, fractures, lacerations or abrasions, swollen areas, a general deterioration well-being, a variation in eating habits (e.g., overeating, loss of appetite), weight loss for no apparent reason, personal hygiene issues, evidence of delayed or inappropriate treatment for injuries, a lack of adult supervision on a daily basis, difficulty walking or sitting.

Sexual

Pre-occupation with sexual matters, sexual activity through words, play or drawings, severe sleep disturbances with fears and phobias, being sexually provocative with adults (in the case of children and young people). Pain or itching in the genital area, bruising or bleeding near genital area, sexually transmitted disease, stomach pains, discomfort when walking or sitting down.

Emotional

Regression in behaviour, nervousness, sudden under-achievement, inappropriate relationships with peers/adults, attention seeking, running away/stealing/lying, looking uncared-for. Neurotic behaviour, e.g. sulking, hair twisting, rocking, being unable to play/interact, fear of making mistakes, sudden speech disorders, self-harm, delay in emotional development.

Harm

The physical signs of neglect may include: constant hunger, sometimes stealing food from others; being constantly dirty or ‘smelly’; loss of weight, or being constantly underweight; inappropriate clothing for the conditions. Changes in behaviour can also indicate neglect.

Child Sexual Exploitation and Child Criminal Exploitation

Appearing with unexplained money gifts or new possessions, associating with other young people involved in exploitation, having older friends boyfriends or girlfriends, suffering from sexually transmitted infections or getting pregnant, changes in emotional well-being, misuse of drugs and alcohol, receiving lots of messages, or calls, missing for periods of time or regularly come home late and regularly missing school or education or do not take part in education.

* clarification that being absent, as well as missing, from education or home can be warning sign of a range of safeguarding concerns, including sexual abuse, sexual exploitation or child criminal exploitation

Children are classed as anyone who has not yet reached their 18th birthday. The fact that a child has reached 16 years of age, is living independently or is in further education, is a member of the armed forces, is in hospital or in custody in the secure estate, does not change his/her status or entitlements to services or protection.

A child in need is defined under the Children Act 1989 as a child who is unlikely to achieve or maintain a reasonable level of health or development, or whose health and development is likely to be significantly or further impaired, without the provision of services; or a child who is disabled. Local authorities are required to provide services for children in need for the purposes of safeguarding and promoting their welfare. 

Local authorities, with the help of other organisations as appropriate, have a duty to make enquires under section 47 of the Children Act 1989 if they have reasonable cause to suspect that a child is suffering, or is likely to suffer, significant harm. Such enquiries enable them to decide whether they should take any action to safeguard and promote the child’s welfare and must be initiated where there are concerns about maltreatment, including all forms of abuse and neglect, female genital mutilation or other so-called honour based violence, and extra-familial threats like radicalisation and sexual exploitation.

The policy helps to ensure the Charity is able to protect learners and apprentices that are studying with the Charity. It highlights key signs and symptoms to staff, volunteers and employers to reduce the risk and protect against abuse towards learners and apprentices. To support learners and apprentices there is a published process detailing how to report concerns and/or seek advice and guidance.

The purpose of adult safeguarding is to prevent harm and reduce the risk of abuse or neglect to adults with care and support needs. The statutory framework introduced under the Care Act applies to any person aged 18 or above who:

• Has needs for care and support (regardless of the level of need and whether or not the local authority is meeting any of those needs); 
• Is experiencing, or is at risk of abuse or neglect; and 
• As a result of those needs, is unable to protect themselves against the abuse or neglect or the risk of it.

Training on safeguarding and online safety is delivered to all staff, volunteers and self-employed contractors. Bespoke training is delivered to Trustees aligned to their leadership responsibilities.  

Ongoing support is provided to ensure staff are informed and confident to take appropriate preventative and responsive steps. Information, advice and guidance for staff is available and regularly updated through briefings at staff meetings and training interventions.

Training and support is delivered to support the correct reporting and response to reported harmful sexual behaviours. Training ensures that all safeguarding staff are aware of the guidance found in part 5 ‘Child-on-child sexual violence and sexual harassment’ of Keeping Children Safe in Education.

Learners and apprentices are surveyed annually and asked to comment on how safe they feel and if they understand how to report any concerns. Responses help to inform improvements in our guidance and practice.        

4.1 eLearning Modules

All employees, self-employed contractors and volunteers who engage with the Charity are required to successfully complete the Charity’s mandatory Safeguarding and Prevent eLearning modules on an annual basis. 

New members of staff, volunteers or self-employed contractors will receive this training as part of their induction.

Line managers are also required to successfully complete the Safer Recruitment in Education eLearning modules. Full details on the Charity’s Safer Recruitment procedures can be found in the Recruitment Policy and Disclosure and Barring Service Policy, on the Charity’s intranet.

4.2 Face to Face Training

In addition to the eLearning modules, those who work in a regulated activity, specifically people within our Education and Training operations and those working with children, young people and adults at risk at the Club will be required to undergo face to face training at a local level.  

This face to face training will be carried out by local Safeguarding Officers and will be appropriate to each specific business area

Regular safeguarding updates will also be provided to support the face-to-face training.

4.3 Designated Safeguarding Leads and Local Safeguarding Officers

Designated Safeguarding Leads (DSLs) attend an external Level 3 training course, and ensure this knowledge is refreshed every two years as a minimum.

The local Safeguarding Leads and Officers (DSL’s and DSO’s) also attend regular training and networking events with local authorities relating to safeguarding issues. Records of staff attendance are held individually on CPD logs.

Designated Safeguarding Leads and Officers must be aware of and communicate any low-level concerns about staff through the correct channels to ensure the continued safeguarding of all stakeholders.

Central YMCA has procedures in place to manage any safeguarding concerns about staff members and volunteers.

If any staff member has safeguarding concerns or an allegation is made about another staff member or volunteer posing a risk of harm to children, or vulnerable adults, the staff member should be referred to a Designated Safeguarding Lead immediately.

Where there are concerns/allegations about a manager or Designated Safeguarding Lead, this should be referred to the Charity’s Chief Executive or Chair of the Board and Named Trustee (Trustee Lead), in accordance with the Charity’s Whistleblowing Policy. You can contact the NSPCC’s Whistleblowing Advice Line for confidential independent advice.

In the event the concerns or allegation relates to the Charity’s Chief Executive or Chair of the Board, or where there is a conflict of interest in reporting the matter to the Chief Executive or Chair, this should be reported directly to the local authority designated officer(s) (LADOs). Contact details for the appropriate LADOs can be found on each local authority website.

During any investigation involving staff, staff may be suspended and access to systems may be temporarily suspended until the investigation has concluded.

Where a concern is raised by a customer or staff member about another staff members’ professional conduct, managers will work alongside HR and the Designated Safeguarding Lead to decide on whether harm thresholds have been met. When harm thresholds have not been met and therefore involvement of the Local Authority Designated Officer (LADO) is not required, a low-level concern will be reported.

A low-level concern is any concern that a staff member has acted in a way that is inconsistent with the staff code of conduct, including inappropriate conduct outside of work and does not meet the harm threshold or is otherwise not serious enough to consider a referral to the LADO.

Mobile phones are not permitted to be used during any of the Charity’s programmes which include regulated activity with pre-16 children. 

This applies to all staff and volunteers except for emergencies. 

All staff and volunteers are responsible for ensuring this procedure is adhered to by parents and children when regulated activity is taking place. Local procedures will be detailed in specific operational policies at local level.