Safeguarding Policy
This policy sets out the statutory requirements for the Office of the Police and Crime Commissioner for Hampshire, Isle of Wight, Portsmouth and Southampton (OPCC) in discharging its responsibility to safeguard children, young people and adults at risk of harm. This policy should be read alongside the OPCC’s Whistleblowing Policy.
Purpose
The purpose of this policy is to set out the expectations and key principles that all staff working in the OPCC should be aware of with regard to safeguarding children, young people and adults at risk of harm or abuse. The OPCC recognises the welfare of children, young people and vulnerable adults form part of its responsibility to monitor the effectiveness of safeguarding in the Hampshire policing area. This policy ensures any services the Police and Crime Commissioner (PCC) commissions from third parties are compliant with the legal duty to safeguard and promote the welfare of children [Children’s Act 2004 & Care Act 2014].
Additionally it outlines the safeguarding responsibility the OPCC has to its volunteers whilst in our care.
Scope
This policy applies to all employees of the OPCC, including temporary employees, agency staff, contractors and volunteers. Hereafter for reference, all employees will be uniformly referred to as “staff” in this document.
- The aim of the policy is to increase staff awareness around the expectations placed on them in relation to safeguarding, along with clear information around processes which should be adopted and best
- OPCC staff have a clear responsibility to take action when they suspect or recognise that a child, young person or vulnerable adult may be a victim of harm or abuse
- The policy recognises the needs of children and vulnerable adults from minority ethnic groups and disabled children and vulnerable adults and the barriers they may face, especially around
- The policy allows OPCC staff to safely voice any concerns through an established
- All reports of abuse or potential abuse are dealt with in a serious and effective manner.
- There is a clear process, efficient recording and monitoring system in place.
- Employees receive appropriate
- Robust ‘safer’ recruitment procedures are in
- Demonstrates the welfare of children, young people and vulnerable adults is paramount
- Mitigates the risk to staff
- Creates clear boundaries between personal and professional interactions
- While employees, volunteers and contract staff are likely to have varied levels of contact or exposure to potential safeguarding issues including contacts and correspondence with children, young people and vulnerable adults as part of their duties and responsibilities for the OPCC, everyone should be aware of the potential indicators of abuse and neglect and be clear about what to do if they have concerns. Responsibilities are limited and it is important to remember the following:
IT IS NOT THE RESPONSIBILITY OF ANY OPCC EMPLOYEE TO DETERMINE WHETHER ABUSE IS ACTUALLY TAKING PLACE
Legal Framework
This policy has been drawn up on the basis of law and guidance that seeks to protect children, young people and vulnerable adults,
- Children’s Act 1989 and 2004
- The Human Rights Act 1998
- Data Protection Act 1998
- Police Reform and Social Responsibility Act 2011 [s1(8)(h) PRSRA11 – The PCC to hold the Chief Constable to account in relation to the safeguarding of children and the promotion of child welfare that are imposed on the Chief Constable by sections 10 and 11 of the Children’s Act 2004]
- Care Act 2014
- Working Together to Safeguard Children 2015 – statutory guidance
- Promoting the Health and Wellbeing of Looked After Children – statutory guidance
- Care and Support – statutory guidance (Chapter 14 – Safeguarding) Definitions:
A child is defined as anyone under the age of 18.
A vulnerable adult is described as a person aged 18 years or over, who is in receipt of or may be in need of community care services by reason of mental or other disability, age or illness and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation [This definition is taken from Bedfordshire Police], such as:
- Physical abuse
- Sexual abuse including exploitation
- Psychological / Emotional abuse
- Neglect of failure to help or support them
- Discrimination
- Financial abuse
- Institutional abuse
Detailed definitions and examples of child and adult abuse can be found under Appendix A.
What is Safeguarding?
- Protecting children and vulnerable adults from maltreatment
- Preventing impairment of children and vulnerable adults’ health or development
- Ensuring that children and vulnerable adults are growing up in circumstances consistent with the provision of safe and effective care
- Taking action to enable all children, young people and vulnerable adults to have the best outcome
- The action we take to promote the welfare of children and vulnerable adults and protect them from harm – is everyone’s responsibility. Everyone who comes into contact with children, vulnerable adults and families has a role to
Situations where concern may be raised:
- A child or vulnerable adult may tell you about something or someone that has upset or harmed them
- Someone else might report that a child or vulnerable adult has told them, or that they believe that a child or vulnerable adult has been or is being harmed
- A child or vulnerable adult might show signs of physical injury for which there appears to be no explanation
- A child or vulnerable adult’s behaviour may suggest he or she is being abused
- The behaviour or attitude of one of the workers towards a child or vulnerable adult worries you
- You witness worrying behaviour from one child or vulnerable adult to another.
- A child or vulnerable adult demonstrates worrying behaviour towards other children or vulnerable
- The situations where staff have contact with the public but not direct work with children or vulnerable adults could include PCC summer events, meetings, out and about days, surgeries, contact correspondence
Good practice guidelines for staff working with volunteers: Social media
Staff should only be ‘friends’ with volunteers on social networking sites via a designated and approved work account for business purposes. See Appendix B, guidelines for using social networking with young people.
Personal details
Staff should not divulge details such as their home address, personal phone numbers and email addresses to volunteers.
Role modelling
Staff should be an excellent role model, this includes not smoking or drinking in front of volunteers. Staff should never allow a young person to drink or use drugs when working or attending events. Staff should promote healthier lifestyles, be appropriately dressed and work in a respectful manner e.g. not use obscene language. Staff should never make sexually suggestive comments to a young person/vulnerable adult, even in jest.
Staff should not socialise with, or invite a volunteer to their home and never enter into inappropriate relationships (i.e. relationships of an intensely personal or sexual nature), even though some volunteers are over the age of consent.
Gifts
Staff should not give, or loan, money, presents or items to volunteers. Gifts given to OPCC staff should fall within the OPCC staff policy.
Touch
Staff need to maintain a safe and appropriate distance, and work in an open environment, ideally with another worker present. Avoid unnecessary physical contact including rough, physical or sexually provocative games. Where any form of manual/physical support is required it should be provided openly and with the consent of the volunteer. Physical contact can be appropriate so long as it is neither intrusive nor disturbing and the person’s consent has been given
Spending time alone
If for any reason a member of staff is supervising a volunteer on a one to one basis, this should ideally be done in a public area. It is accepted that this will not always be possible, and in such cases the door to the room should be kept open. If possible, another member of staff should be made aware that such one to one supervision is taking place.
It is inappropriate for a member of staff to share a bedroom with a volunteer.
It is recognised that occasionally staff members may be required to take a volunteer in their vehicle. In this case the staff member should advise a colleague of the time they leave, where they are going, with who and what time they are due to finish that journey. The staff member should then confirm with that colleague that the journey has been completed and the volunteer is safely at their destination.
If the volunteer is under 16 years of age they should take a registered and pre-booked taxi with parental consent.
Personal values
Staff should work in an inclusive and respectful manner. Staff should refrain from discussing internal issues in front of volunteers, who may misconstrue information received or which may present the office, or PCC in a negative light. Equally staff should never show disrespect for a person’s culture, religion or personal choices.
Photography
Photos taken with volunteers are for use on official channels only.
Safeguarding Roles and Responsibilities
The Chief Executive and the Senior Management Team are responsible for ensuring that this policy and related procedures are implemented, monitored and consistently reviewed. The Chief Executive is the Safeguarding Champion within the OPCC and is responsible for dealing with reports or concerns about the protection of children, young people and vulnerable adults appropriately. The Senior Management Team are responsible for ensuring the implementation, consistent monitoring and improvements of this Safeguarding policy.
All employees must bring safeguarding concerns to the attention of the Safeguarding Champion
Everyone has a responsibility:
- For safeguarding children, young people and vulnerable adults;
- To recognise the welfare of the child and vulnerable adult as our primary consideration in everything we do;
- To ensure everyone understands their roles and responsibilities in respect of safeguarding and is provided with appropriate training to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children, young people and vulnerable adults;
- To ensure appropriate action is taken in the event of incidents/concerns of abuse and that support is provided to the individual(s) who raise or disclose the concern;
- To ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored;
- To prevent the employment/deployment of unsuitable individuals;
- To ensure robust safeguarding arrangements and procedures are in
The procedure for staff and volunteers to manage safeguarding concerns can be found at Appendix C.
Safeguarding Impact On:
Recruitment:
Recruiting managers will seek guidance from HR, to determine the level of DBS (formerly CRB) check required for any role to be recruited to within the OPCC, particularly for any role which involves regular or substantial unsupervised contact with children, young people or vulnerable adults. The manager will ensure clearance is obtained before the applicant commences employment
The name of any member of staff considered not suitable to work with children, young people and vulnerable adults will be referred to the Disclosure and Barring Service (DBS) with the advice and support of the HR Services.
Training:
All OPCC staff will receive training in relation to safeguarding and their responsibilities in upholding this policy as part of their induction programme and this should be refreshed every three years.
Commissioning:
As a commissioner of services, the OPCC has a responsibility to ensure safeguarding responsibilities are detailed in all contracts and grants awarded. The OPCC will work with providers to ensure that they understand their responsibilities and are adhered to in line with best practice arrangements and ensure this is monitored through the contract / grant management process by way of a checklist see Appendix D.
Monitoring:
Compliance with and effectiveness of this policy will be reviewed every three years or in the following circumstances:
- Changes in legislation and or government guidance
- As a result of any other significant change or event
Appendices
Appendix A: Definition of abuse
Physical Abuse
Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
Emotional Abuse
Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to children that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond the child’s development capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill treatment of another. It may involve serious bullying, causing children frequently to feel frightened or in danger, or the exploitation or corruption of children of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
Sexual Abuse
Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, including prostitution, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (e.g. rape, buggery or oral sex) or non-penetrative acts. They may include non-contact activities, such as involving children in the looking at, or in the production of, sexual online images, watching sexual activities or encouraging children to behave in sexually inappropriate ways.
Neglect
Neglect is the persistent failure to meet a child’s basic physical and / or psychological needs, likely to result in serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:
- Provide adequate food, clothing and shelter (including exclusion from home or abandonment);
- Protect a child from physical and emotional harm or danger;
- Ensure adequate supervision (including the use of inadequate care- givers); or
- Ensure access to appropriate medical care or treatment.
It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
Staff need to be aware of vulnerable groups such as those with disabilities, children living away from home, asylum seekers, children and young people in hospital, children in contact with the youth justice system, victims of domestic abuse and those vulnerable due to religion, ethnicity etc. and those who may be exposed to violent extremism.
Definition of adults at risk of harm or abuse
Living a life that is free from harm and abuse, is a fundamental human right for every person and an essential requirement for health and well-being.
Safeguarding adults is about safety and well-being but providing additional measures for those least able to protect themselves from harm or abuse.
Physical
Examples of physical abuse are assault, rough handling, hitting, pushing, pinching, shaking, misusing medication, scalding, inappropriate sanctions and exposure to excessive heat or cold. Unlawful or inappropriate use of restraint or physical interventions and / or deprivation of liberty are also physical abuse.
Sexual and Sexual Exploitation
Some examples of sexual abuse / assault include the direct or indirect involvement of the adult at risk in sexual activity or relationships which:
- They do not want or have not consented to;
- They cannot understand and lack the mental capacity to be able to give consent to;
- They have been coerced into because the other person is in a position of trust, power or authority, for example, a care worker; or
- Required to watch sexual activity.
Psychological/ Emotional
This is behaviour that has a harmful effect on the person’s emotional health and development or any form of mental cruelty that results in:
- Mental distress;
- The denial of basic human and civil rights such as self-expression, privacy and dignity;
- Negating the right of the adult at risk to make choices and undermining their self-esteem;
- Isolation and over-dependence that has a harmful effect on the person’s emotional health, development or well-being;
- Bullying;
- Verbal Attacks; or
- Intimidation.
Neglect
A person’s well-being is impaired and care needs not met. Behaviour that can lead to neglect includes ignoring medical or physical needs, failing to allow access to appropriate health, social care and educational services, and withholding the necessities of life such as medication, adequate nutrition, hydration or heating.
Neglect can be intentional or unintentional. Intentional neglect would result from:
- Wilfully failing to provide care;
- Wilfully preventing the adult at risk from getting the care they needed; or
- Being reckless about the consequences of the person not getting the care they need.
Unintentional neglect could result from a carer failing to meet the needs of the adult at risk because they do not understand the needs of the individual, they may not know about services that are available or because their own needs prevent them from being able to give the care the person needs. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Discrimination
Discriminatory abuse exists when values, beliefs or culture result in a misuse of power that denies opportunity to some groups or individuals and this results in harm.
Psychological abuse that is racist, sexist or linked to a person’s sexuality, disability, religion, ethnic origin, gender, culture or age.
Institutional
Observed lack of dignity and respect in the care setting, rigid routine, processes / tasks organised to meet staff needs, disrespectful language and attitudes.
Domestic violence and self-harm need to be considered as possible indicators of abuse and / or contributory factors.
Financial
It is the use of a person’s property, assets, income, funds or any resources without their informed consent or authorisation. It includes:
- Theft;
- Fraud;
- Exploitation;
- Undue pressure in connection with wills, property, inheritance or financial transactions;
- The misuse or misappropriation of property, possessions or benefits; or
- The misuse of an enduring power of attorney or a lasting power of attorney, or appointee ship.
Appendix B: Guidelines for Using Social Networking with Young People
Use of Messages & Communication with Individuals
All social networks allow private messaging to take place between ‘friends’. There are times when one-to-one communication is appropriate however it is strongly recommended that any one-to-one communication using social media is kept to a minimum and that it is done via a platform that keeps a record of these messages (i.e. Facebook messenger) and is done using a specific work account.
When using social networks to communicate with young people you should:
- Use a separate, designated Facebook account for the purposes of the organisation. This account may be examined by your line manager and used for business purposes only and not as a workers personal account.
- Any communication using this Facebook account should be kept public or kept logged. Messages should be saved and kept (both incoming and outgoing).
- All contact with young people using Facebook should be kept appropriate and not use abbreviations/language that could be misunderstood by a parent or guardian (e.g. LOL (laugh out loud, IDK (I don’t know).
Young people regularly use kisses in their messages, however they should not be reciprocated. - It is recommended that staff do not use this account after 10pm in order to maintain a safe boundary between work and personal life.
- All communication with young people on social media should be done with parental consent.
Specific Site Guidelines
Young people are only to be added to a specific work Facebook account with parental consent. This can be done by adding a tick box to your regular consent form. Facebook has a function that allows you to download an archive of your profile. We recommend doing this periodically to enable you to have a local copy.
Messaging on Facebook is typically logged which means a record of individual and group messages are automatically kept. When using group messages best practice would be that another adult is also part of this message. In all communication with young people using social networking sites it is advisable to not use abbreviations (for example: lol) as these can often be misinterpreted by parents.
If you are concerned about a young person from their posts or late night/ emotional messages on a social media network then you should seek alert and ask for further advice from the Child Protection lead and consult the safeguarding policy. These should not be responded to but should be logged and discussed and if necessary shared with parent/guardian/key workers.
WhatsApp can be a great tool for creating group messages between young people however when doing this make sure you have sought parental permission first.
Best practice recommends that at least 2 adults are part of a WhatsApp group chat. When using WhatsApp group chats you should be aware that adding people to the group discloses their mobile number to the rest of the group.
WhatsApp allows you to back up your chats and we highly recommend doing this.
The public nature of the majority of twitter profiles means that young people can freely choose to ‘follow’ you on the platform. It also means you can freely choose to ‘follow’ them back. If you use a public twitter account or one specifically for work you should make sure that your content is appropriate and only reply to young people when absolutely necessary.
Twitter recommend using public communication as much as possible, as the direct message feature isn’t easy to back up or keep a log of.
We recommend using Instagram for the purpose of sharing photos only rather than using messaging features as these are difficult to keep a backup of. Make sure you have permission from parents before sharing photos of young people.
Snapchat
The nature of Snapchat makes it completely inappropriate for use with young people as messages disappear after a designated amount of time. If you use Snapchat as an individual please ensure that you have to give permission for people to follow you and that you do not and any young people.
Appendix C: Managing Safeguarding Concerns – procedure for staff and volunteers
When a child, young person or vulnerable adult makes an allegation of abuse, you should:
- Listen carefully to what is said and allow the person to talk at their own pace, being careful not to compromise potential.
Find an appropriate opportunity to explain it is likely that certain information will need to be shared with other responsible people, do not promise to keep secrets. - Where possible, seek the support of another colleague before continuing the conversation, if it does not compromise the situation. Ask permission of the person making the disclosure if they are ok for an additional person to join the conversation.
- Only ask questions for clarification, the use of open questions e.g. what, where, when, who? is advisable, do not ask leading questions (that suggest certain answers as this could compromise evidence)
- Reassure the child, young person or vulnerable adult that they have done the right thing in telling you.
- Tell them what you will do next and who you will
- If you believe the person is ‘at risk’ of immediate significant harm, which includes situations which any employee would reasonably believe requires the emergency services, then you must contact the relevant emergency
- At the earliest opportunity, make a note of the conversation. All allegations of abuse / concern regarding children, young people and vulnerable adults must be recorded without delay, to ensure there is an accurate record of key written information and details are passed onto appropriate individuals / organisations. If a concern / allegation is raised, employees should complete the Safeguarding concerns / allegations form as soon as practicable (see Appendix E).
- Any allegation against staff that indicate that they may have:
- Behaved in a way that has harmed a child or vulnerable adult, or may have harmed a child or vulnerable adult;
- Possibly committed a criminal offence against or related to a child or vulnerable adult; or
- Behaved towards a child, children or vulnerable adult in a way that indicates s/he is unsuitable to work with children and vulnerable
Should be reported immediately to the Safeguarding Champion or another member of the Senior Management Team.
If the allegation made to a member of staff concerns the Safeguarding Champion, the person receiving the allegation will immediately inform a member of the Senior Management Team.
Referrals
If you believe the child, young person or vulnerable adult is at immediate risk then you should contact the police on 999.
If the threat is not imminent, follow the Child Protection Procedures for the four Local Safeguarding Children’s Boards (Hampshire, Isle of Wight, Portsmouth and Southampton)
Adult Safeguarding contacts
- Hampshire Adult Services on 0300 555 1386
- Southampton Adult Social Care on 02380 833003
- Portsmouth Adult Social Care on 02392 680810
- Isle of Wight Adults First Response Team on 01983 814980
Appendix D: Safeguarding checklist for PCC grants
Safeguarding
All staff and volunteers who are involved in the direct delivery of services to children / young people and vulnerable adults should understand and recognise issues relating to safeguarding in line with legislation and best practice.
| Question | Evidence |
|---|---|
| Does your organisation have a safeguarding policy either for children / young people or vulnerable adults? (delete as appropriate) | Copy of safeguarding policy |
| Does your organisation have a safeguard lead? | Details of safeguarding lead (s) |
| Do all your staff and volunteers (if applicable) know who the safeguarding lead is and how to contact them? | Evidence staff / volunteers know who safeguarding lead (s) is / are and how to
contact them |
| Are staff and volunteers
aware of their safeguarding responsibilities? |
Details of staff / volunteer training |
| Are staff and volunteers aware of procedures to report concerns, disclosure or allegations from children / young people and vulnerable adults? | Details of staff / volunteer training |
Recruitment
Your organisation should have in place arrangements for safer recruitment and supervision of staff and volunteers, together with arrangements for the continuing skills development and training of staff and volunteers.
| Question | Evidence |
|---|---|
| Do you undertake and maintain current Disclosure Barring System (DBS) checks on staff / volunteers
/ contractors who will be delivering frontline services with either children / young people or vulnerable adults? |
Details of DBS checks are undertaken and maintained |
| Are new and existing staff provided with safeguarding training (including refresher training)? | Details of safeguarding training |
Data handling
Does the nature of the work you are undertaking with children, young people or vulnerable adults mean that you will have to manage information that contains sensitive personal details?
| Question | Evidence | |
|---|---|---|
| Does your organisation comply with the principles of the Data Protection Act 2018? | Yes/no | |
| Does your organisation have policies and procedures in place that secure against the inappropriate loss or destruction of personal information supplied via the grant application and/or grant agreement, including a secure means of transferring information in and out of organisations? | Copy of data protection policy | |
| Is data disposed of as prescribed within the Data Protection Act? | Yes/no | |
Safeguarding Concerns / Allegations Recording Form
The form records the following details:
- Person completing the report
- Source of information
- Name of vulnerable adult (s) / child(ren)
- Name and role of employee (if allegation is made against an employee)
- Date & location of incident(s)
- Nature of concern / allegation
- Concern / allegation raised with
- Outcomes of discussion
- Action agreed
- Signature of person completing the report, dated
- Actions resolved or details passed onto another agency
- Signature of personal resolving the actions, dated