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Safeguarding Policy

Purpose

Our charitable activities include working with vulnerable people.  The purpose of this policy is to protect them and provide stakeholders and the public with the overarching principles that guide our approach in doing so. 

Lead Trustee

A lead trustee will be appointed to provide oversight of safeguarding and to lead on any incident investigation and reporting.

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Applicability

This policy applies to anyone working on our behalf, including our trustees and other volunteers. We will ensure that it is:
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  • Put into practice

  • Responsive to change

  • Reviewed as necessary, always following a serious incident and at least once a year

  • Available to the public

  • Compliant with all relevant legislation

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We will make all trustees, staff, volunteers, partners and beneficiaries aware of our policies and that they know how to apply them.
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Partner organisations will be required to have their own safeguarding procedures that must, as a minimum, meet the standards outlined below, and include any additional legal or regulatory requirements specific to their work.  These include, but are not limited to other UK regulators, if applicable.

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Safeguarding should be appropriately reflected in other relevant policies and procedures. 

Principles

We believe that:​

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  • 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. 

Types of Abuse

Abuse can take many forms, such as physical, psychological or emotional, financial, sexual or institutional abuse, including neglect and exploitation.  Signs that may indicate the different types of abuse are at Appendix 1.

Reporting 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 CIC.

For members of the CIC, 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 in respect of Serious Incident Reporting and, if applicable, other regulator.  They are aware of the Government guidance on handling safeguarding allegations.

Responsibilities

Trustees.  This safeguarding policy will be reviewed and approved by the Board annually.​

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Trustees are aware of and will comply with the Charity Commission guidance on safeguarding and protecting people and also the 10 actions trustee boards need to take to ensure good safeguarding governance.

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A lead trustee/committee with be given responsibility for the oversight of all aspects of safety, including whistleblowing and H&SW.  This will include:

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  • Creating a culture of respect, in which everyone feels 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.

  • 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 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 (eg 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.

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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 (see above).

Fundraising

We will ensure that:

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  • 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.

Online Safety

We will identify and manage online risks by ensuring:

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  • Volunteers, staff and trustees understand how to keep themselves safe online. We may use high privacy settings and password access to meetings to support this.

  • The online services we provide are suitable for our 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.

  • We protect people’s personal data and follow data protection 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.

  • We have adopted and comply with the Charity AI Ethics & Governance Framework.

Working With Other Organisations

In working with other organisations, including any grant making, we will comply with Charity Commission guidance by carrying out relevant due diligence and having a written agreement that sets out:

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  • Our relationship.

  • The role of each organisation.

  • Monitoring and reporting arrangements.

Version Control - Approval and Review

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This policy will be reviewed as part of any safeguarding incident investigation, to test that it has been complied with and to see if any improvements might realistically be made to it. 

Statutory Guidance

  • Gov.UK – The role of other agencies in safeguarding

  • Disclosure and Barring Service (DBS) – DBS Guidance

  • CC: Infographic; 10 actions trustees need to take.

  • CC: Safeguarding duties of charity trustees

  • CC: Safeguarding - policies and procedures

  • CC: How to protect vulnerable groups

  • CC: Managing online risk.

Useful Links

  • NCVO: Online safeguarding resources.

  • NSPCC: Writing a safeguarding policy

Overseas Safeguarding

  • Developing and modelling a positive safeguarding culture: A tool for leaders.

  • Misconduct Disclosure Scheme.

Appendix 1 - Types of Risks and Harm

Harm and risks you must be alert to, whether online or in person, include:

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  • Sexual harassment, abuse and exploitation.

  • Criminal exploitation.

  • A charity’s culture, which may allow poor behaviour and poor accountability.

  • People abusing a position of trust they hold within a charity.

  • Bullying or harassment.

  • Health and safety.

  • Commercial exploitation.

  • Cyber abuse.

  • Discrimination on any of the grounds in the Equality Act 2010.

  • People targeting your charity.

  • Data breaches, including those under General Data Protection Regulations (GDPR).

  • Negligent treatment.

  • Domestic abuse.

  • Self-neglect.

  • Physical or emotional abuse.

  • Extremism and radicalisation.

  • Forced marriage.

  • Modern slavery.

  • Human trafficking.

  • Female genital mutilation.

Appendix 2 - Signs of Abuse

Physical Abuse.

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  • Bruises, black eyes, welts, lacerations, and rope marks.

  • Broken bones.

  • Open wounds, cuts, punctures, untreated injuries in various stages of healing.

  • Broken eyeglasses/frames, or any physical signs of being punished or restrained.

  • Laboratory findings of either an overdose or under dose medications.

  • Individual's report being hit, slapped, kicked, or mistreated.

  • Vulnerable adult's sudden change in behaviour.

  • The caregiver's refusal to allow visitors to see a vulnerable adult alone.

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Sexual Abuse.

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  • Bruises around the breasts or genital area.

  • Unexplained venereal disease or genital infections.

  • Unexplained vaginal or anal bleeding.

  • Torn, stained, or bloody underclothing.

  • An individual's report of being sexually assaulted or raped.

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Mental Mistreatment/Emotional Abuse.

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  • Being emotionally upset or agitated.

  • Being extremely withdrawn and non-communicative or non-responsive.

  • Nervousness around certain people.

  • An individual's report of being verbally or mentally mistreated.

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Neglect.

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  • Dehydration, malnutrition, untreated bed sores and poor personal hygiene.

  • Unattended or untreated health problems.

  • Hazardous or unsafe living condition (e.g., improper wiring, no heat or running water).

  • Unsanitary and unclean living conditions (e.g., dirt, fleas, lice on person, soiled bedding, faecal/urine smell, inadequate clothing).

  • An individual's report of being mistreated.

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Self-Neglect.

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  • Dehydration, malnutrition, untreated or improperly attended medical conditions, and poor personal hygiene.

  • Hazardous or unsafe living conditions.

  • Unsanitary or unclean living quarters (e.g., animal/insect infestation, no functioning toilet, faecal or urine smell).

  • Inappropriate and/or inadequate clothing, lack of the necessary medical aids.

  • Grossly inadequate housing or homelessness.

  • Inadequate medical care, not taking prescribed medications properly.

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Exploitation.

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  • Sudden changes in bank account or banking practice, including an unexplained withdrawal of large sums of money.

  • Adding additional names on bank signature cards.

  • Unauthorized withdrawal of funds using an ATM card.

  • Abrupt changes in a will or other financial documents.

  • Unexplained disappearance of funds or valuable possessions.

  • Bills unpaid despite the money being available to pay them.

  • Forging a signature on financial transactions or for the titles of possessions.

  • Sudden appearance of previously uninvolved relatives claiming rights to a vulnerable adult’s possessions.

  • Unexplained sudden transfer of assets to a family member or someone outside the family.

  • Providing services that are not necessary.

  • Individual's report of exploitation.

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