Safeguarding Children, Young People, and Adults at Risk policy and procedure

Introduction

Purpose

The purpose of this policy is to protect people, particularly children and at risk adults, from any harm that may be caused due to their coming into contact with Play Included C.I.C (“Play Included”). This includes harm arising from the conduct of Play Included’s employees, Directors, consultants, and volunteers.

The policy lays out the commitments made by Play Included, and informs employees, Directors, consultants and volunteers of their responsibilities in relation to safeguarding.

Certain sections of this policy will also be applicable to Play Included's trainers, mentors and Brick Club facilitators. Trainers, mentors and facilitators must familiarise themselves with this policy as part of their contractual obligations in affiliating themselves with Play Included and delivering Brick Clubs. A section specific to trainers, mentors and facilitators can be found at the end of this policy.

This policy does not cover:

• Sexual harassment in the workplace – this is dealt with under Play Included’s (employee) Grievance Policy; and

• Safeguarding concerns in the wider community not perpetrated by Play Included or its employees, Directors, consultants, volunteers, trainers, mentors and facilitators.

What is safeguarding?

Safeguarding means protecting peoples' health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect. Play Included understands it to mean protecting people, including children and at-risk adults, from harm that arises from coming into contact with our activities.

Further definitions relating to safeguarding are provided in the glossary (see annex 1).

Scope

The policies and procedures apply to all of Play Included’s employees, Directors, consultants, visitors and volunteers. Where expressly provided, these shall also apply to Play Included's trainers, mentors and facilitators.

Policy Statement

Play Included believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm, abuse, neglect and exploitation. Play Included will not tolerate abuse and exploitation by its employees, Directors, consultants, volunteers trainers, mentors and facilitators. This policy will address the following areas of safeguarding as appropriate: child safeguarding, adult safeguarding, and protection from sexual exploitation and abuse. These key areas of safeguarding may have different policies and procedures associated with them (see Associated Policies). Play Included commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.

Prevention

Play Included's responsibilities

Play Included will:

• Ensure all employees, Directors, consultants and volunteers have access to, are familiar with, and know their responsibilities within this policy;

• Design and undertake all its programmes and activities in a way that protects people from any risk of harm that may arise from their coming into contact with Play Included. This includes the way in which information about individuals in our programmes is gathered and communicated;

• Implement stringent safeguarding procedures when recruiting, managing and deploying employees, Directors, consultants and volunteers;

• Ensure employees receive training on safeguarding at a level commensurate with their role in the company;

• Follow up on reports of safeguarding concerns promptly and according to due process; and

• Commit to the safe recruitment, selection and vetting of those performing their duties for, or on behalf of, Play Included that includes direct contact with children and at-risk adults. This includes a criminal record check from the Disclosure and Barring Service in England and Wales for each employee, Director, consultant and volunteer.

Responsibilities of employees, Directors, consultants and volunteers

Child safeguarding

Play Included’s employees, Directors, consultants and volunteers must not:

• Engage in sexual activity with a child;

• Have inappropriate contact with a child – physical, verbal or electronic;

• Subject a child to physical, emotional or psychological abuse, or neglect;

• Engage in any commercially exploitative activities with children including child labour or trafficking;

• Engage with a child in an unobserved and unaccompanied environment, and whenever practical or possible must ensure that another adult is present when working in the proximity of a child;

• Provide personal contact details to any child or contact them via social media;

• Record any sessions and store this on a personal device; and/or

• Take photographs or videos of a child without the express permission of their school, parents or guardians.

Adult safeguarding

Play Included’s employees, Directors, consultants and volunteers must not:

• Sexually abuse or exploit at risk adults;

• Subject an at risk adult to physical, emotional or psychological abuse, or neglect; and/or

• Engage with an at risk adult an unobserved and unaccompanied environment, and whenever practical or possible must ensure that another adult is present when working in the proximity of an at risk adult.

Protection from sexual exploitation and abuse

Play Included’s employees, Directors, consultants and volunteers must not:

• Exchange money, employment, goods or services for sexual activity; and/or

• Engage in any sexual relationships with any beneficiary of assistance since they are based on inherently unequal power dynamics.

Additionally, Play Included’s employees, Directors, consultants and volunteers are obliged to:

• Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of this Safeguarding Policy; and

• Report any concerns or suspicions regarding safeguarding violations by an employee, Director, consultant and volunteer to Dr Gina Gómez de la Cuesta and/or Dr Elinor Brett.

Reporting

Reporting of concerns or complaints

Play Included will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to employees, Directors, consultants and volunteers as well as the communities we work with.

Any employee reporting concerns or complaints through formal whistleblowing channels (or if they request it) will be protected by Play Included’s Whistleblowing Policy.

Play Included will also accept complaints from external sources such as members of the public, partners and official bodies.

How to report a safeguarding concern

Employees, Directors, consultants and volunteers who have a complaint or concern relating to safeguarding should report it immediately to either of the joint Safeguarding Officers:

• Dr Gina Gómez de la Cuesta, by email: gina@playincluded.com; and/or

• Dr Elinor Brett, by email: elinor@playincluded.com.

As the best interests of the child or at-risk adult are paramount, any safeguarding concern must only be shared on a need to know basis to ensure confidentiality.

Record keeping

All complaints or concerns relating to safeguarding must be recorded and stored safely on Play Included’s network for 7 years. Dr Gina Gómez de la Cuesta and Dr Elinor Brett are collectively responsible for these records.

Response

The Board’s responsibilities

Play Included’s Board will:

• Follow up safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations (see Procedures for reporting and response to safeguarding concerns in Associated Policies);

• Apply appropriate disciplinary measures to an employee found in breach of this policy;

• Terminate the company’s engagement with any consultant found in breach of this policy;

• Where possible and appropriate, offer support to survivors of harm caused by an employee, Director, consultant and volunteer, regardless of whether a formal internal response is carried out (such as an internal investigation). Decisions regarding the nature of such support will be led by the survivor; and/or

• decide whether the report should be dealt with by any or all of the agencies and authorities listed at Annex 2.

Confidentiality

It is essential that confidentiality in maintained at all stages of the process when dealing with safeguarding concerns. Information relating to the concern and subsequent case management should be shared on a need to know basis only, and should be kept secure at all times.

Procedure

Safeguarding Officer’s Actions

Where the Safeguarding Officer has been notified, or otherwise has reason to believe there is risk of harm to any individual coming into contact with Play Included, including but not limited to Play Included’s beneficiaries, volunteers or employees, the Safeguarding Officer has the power to act as necessary and, in particular, as follows:

• log all conversations regarding the issue

• sign and request signatures on reports and statements

• confidentially seek advice from expert sources – Cambridgeshire & Peterborough Safeguarding Board (safeguardingcambspeterborough.org.uk)

• share concerns (with consent where required and appropriate) internally with senior staff / Chair of the Board of Directors

• share concerns and make referrals to external agencies such as social services or the police, as appropriate to the circumstances. For referral forms please see Cambridgeshire & Peterborough Safeguarding Board (safeguardingcambspeterborough.org.uk) or the relevant agency in your area.

• make a referral to the DBS regarding employees or volunteers engaged in Regulated Activity whose conduct is harmful to Play Included’s beneficiaries and refer them to DBS when they are removed from such Regulated Activity.

Trainers, Mentors and Facilitators

Play Included will:

• Ensure all trainers, mentors and facilitators are appropriately signposted to access this policy and are made aware of their obligations for compliance with this policy as part of their separate contractual arrangements with Play Included.

Trainers, mentors and facilitators will:

• Be responsible for familiarising themselves with this policy, and in the case of trainers and mentors, ensuring compliance at an organisational and individual level for those licensed to deliver facilitator training or mentoring;

• Comply with the Responsibilities of employees, Directors, consultants ad volunteers section of this policy in addition to any safeguarding policies of their employer or other relevant regulator;

• Comply with the Code of Conduct;

• Provide accurate information on their ability to work with children and/or at risk adults in good faith to Play Included as part of all eligibility checks.

Suspected or confirmed breaches of this policy committed by a trainer, mentor or facilitator should be notified to Play Included in accordance with the How to report a safeguarding concern section.

Where Play Included is notified of any breach of the Responsibilities of employees, Directors, consultants ad volunteers section of this policy committed by a trainer, mentor or facilitator, Play Included reserves the right to:

• Terminate the licence of any trainer or mentor found in breach of this policy;

• Terminate the membership of any facilitator found in breach of this policy.

Associated employee policies

Grievance policy

Disciplinary policy

Whistleblowing policy

Annex 1: Glossary of Terms

Beneficiary of Assistance

Someone who directly receives goods or services from Play Included’s programme. Note that misuse of power can also apply to the wider community that Play Included serves, and also can include exploitation by giving the perception of being in a position of power.

Child

A person under the age of 18, as defined in section 105(1) of the Children Act 1989.

Harm

Psychological, physical and any other infringement of an individual’s rights.

Psychological harm

Emotional or psychological abuse, including (but not limited to) humiliating and degrading treatment such as bad name calling, constant criticism, belittling, persistent shaming, solitary confinement and isolation.

Protection from Sexual Exploitation and Abuse (PSEA)

The term used by the humanitarian and development community to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel. The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13)

Safeguarding

In the UK, safeguarding means protecting peoples' health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect.

We understand it to mean protecting people, including children and at risk adults, from harm that arises from coming into contact with our staff or programmes. One definition is as follows:

Safeguarding means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur.

This definition draws from our values and principles and shapes our culture. It pays specific attention to preventing and responding to harm from any potential, actual or attempted abuse of power, trust, or vulnerability, especially for sexual purposes.

Safeguarding applies consistently and without exception across our programmes, partners and staff. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and having mature, accountable and transparent systems for response, reporting and learning when risks materialise. Those systems must be survivor-centred and also protect those accused until proven guilty.

Safeguarding puts beneficiaries and affected persons at the centre of all we do.

Sexual abuse

The term ‘sexual abuse’ means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual exploitation

The term ‘sexual exploitation’ means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. This definition incudes human trafficking and modern slavery.

Survivor

The person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive, however it is the individual’s choice how they wish to identify themselves.

At risk adult

Sometimes also referred to as vulnerable adult. Adults at risk are defined by the Care Act 2014 as individuals aged over 18 who:

• have needs for care and support (whether or not the local authority is meeting any of those needs), and

• is experiencing, or at risk of, abuse or neglect, and

• as a result of those care and support needs, is unable to protect themselves from either the risk of, or the experience of abuse or neglect.

Annex 2: contact details of relevant bodies and authorities

NSPCC (if you are worried about a child, but unsure)

0808 800 5000

Cambridgeshire Police

01480 456111

(If a child or an at risk adult is in immediate danger call 999)

Cambridgeshire Local Authority Designated Officer (LADO)

01223 727967

Cambridgeshire and Peterborough MASH (Multi-Agency Safeguarding Hub) 01733 863744 safeguardingboards@cambridgeshire.gov.uk

Child Exploitation and Online Protection Command (CEOP)

They can be contacted through their website

Up-to-date contact details for all UK Safeguarding Adult Board Links can be found here: Safeguarding Adults Board Links (safecic.co.uk)