__WIP___
Author: LEVELS SLT
Date of Issue: 23/3/25
Next Review Date: 01/09/26
Version 1
Policy Review
This policy will be reviewed in full by Levels on an annual basis.
Policy reviewed and agreed by Levels on <1/8/25>
Due for review in <1/9/26>
1. Our Safeguarding Policy
This Policy applies to all staff, including senior managers, paid staff, seasonal workers, volunteers, chaperones, students or anyone working on behalf of Levels.
The purpose of this policy:
- To protect children and young people who access Levels services.
- To provide staff and volunteers with the overarching principles that guide our approach to safeguarding and child protection.
Levels believes that a child or young person should never experience abuse of any kind. We have a responsibility to promote the welfare of all children and young people and to keep them safe. We are committed to practice in a way that protects them.
1.1 Legal Framework
This policy has been drawn up based on law and guidance that seeks to protect children and young people, namely:
- Rehabilitation of Offenders Act 1974
- The Mental Health Act 1983
- Children’s Act 1989
- NHS and Community Care Act 1990
- The Police Act 1997
- Data Protection Act 1998
- Human Rights Act 1998
- Care Standards Act 2002
- The Adoption and Children Act 2002
- Sexual Offences Act 2003
- Children’s Act 2004
- Safeguarding Vulnerable Groups Act 2006
- The Equality Act 2010
- Protection of Freedoms Act 2012
- Children’s and Families Act 2014
- Care Act 2014
- Special Educational need and disability (SEND) code of practice: 0 to 25 years – statutory guidance for organisations who work with and support children and young people who have special educational needs or disabilities: HM Government 2014
- The Child (Performances and Activities) (England) Regulations 2014
- Information Sharing: Advice for practitioners providing safeguarding services to children and young people; HM Government 2015
- Working together to safeguard children; a guide to inter-agency working to safeguard and promote the welfare of children: HM Government 2015
- Working together to Safeguard Children 2018
This policy should be read alongside our policies and procedures on:
- Safer Recruitment, induction and training
- Recording and Information sharing
- Code of conduct for staff and volunteers
- E- Safety
- Anti-bullying
- Complaints
- Whistleblowing
- Health and Safety
- Training, supervision and support
- Quality Assurance
1.2 We recognise that:
- The welfare of the Child is paramount, as enshrined in the Children’s Act 1989
- All children regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have an equal right to protection from all types of harm and abuse
- Some children are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues
- Working in partnership with children, young people, carer’s and other agencies is essential in promoting young peoples’ welfare
1.3 We will seek to keep children and young people safe by:
- Valuing them, listening to them and respecting them
- Appointing a Strategic Designated Safeguarding Officer (DSO) and Operational Designated Safeguarding Officer for children and young people
- Adopting child protection and safeguarding practices through procedures and a code of conduct for staff and volunteers
- Developing and implementing an effective e-safety policy and related procedures
- Providing effective management for staff and volunteers through supervision, support, training and quality assurance measures
- Recruiting staff and volunteers safely, ensuring all necessary checks are made
- Recording and storing information professionally and securely.
- Using our safeguarding procedures to share concerns and relevant information with agencies that need to know, and involving children, young people, parents, families and carers appropriately
- Using our procedures to manage allegations against staff or volunteers appropriately
- Creating and maintaining an anti-bullying environment and ensuring that we have a policy and procedure to help us deal effectively with any bullying that occurs
- Ensuring that we have effective complaints and whistleblowing measures in place
- Ensuring that we provide a safe physical environment for our children, young people, staff and volunteers, by applying health and safety measures in accordance with the law and regulatory guidance.
- Inform each child who the appropriate person or people are to speak to if they have any questions, problems or concerns
- Recognise the individual needs of the child e.g. recognising when a child may be tired and need a break
- Ensure that all staff and crew who don’t necessarily have close contact with children but who are assisting in the production are aware of their conduct around children
2. Safeguarding Structure
- Strategic Designated Safeguarding Officer: <Placeholder>
- Operational Designated Safeguarding Officer: <Placeholder>
2.1 Role and Responsibility of the Operational DSO’s
- First point of contact for all staff and volunteers to go to for advice if they are concerned about a child or young person.
- To ensure that they comply with safe recruitment procedures for new staff members and their induction
- Ensures that the safeguarding policy is adhered to
- Identify and challenge poor practice
- Sharing appropriate information with relevant people
- Consulting strategic DSO and local safeguarding children board procedures for additional information and guidance if needed
- Ensuring that all staff having contact with children and young people have received appropriate safeguarding and child protection training
2.2 Role and Responsibility of the Strategic DSO
- Provide support for Operational DSO’s
- Drawing up, updating and enforcing the company’s safeguarding policy
- Ensure operational DSO’s are following safeguarding policy and procedure within their individual schools
- Ensure concerns are logged and stored securely
- Leading the way for promoting a safe environment for children and young people
3. Code of Conduct: safeguarding behaviours offline and online
All staff are encouraged to demonstrate exemplary behaviour when working with children and/or adults and this code of conduct sets out clearly the expectations of Levels with respect to this. The purpose of the code is not to stifle creativity or prevent building rapport and good working relationships rather it’s to clarify expectations and avoid the possibility of misunderstanding or misinterpretations of behaviour. By following this code of behaviour staff will be promoting the welfare of the children and adults with whom they work and will be preserving both their own professional reputation and that of the company.
3.1 Permitted behaviours
- Always work in an open environment wherever possible
- Treat all children and adults equally, and with respect and dignity
- Always put the welfare of each child, young person or adult first, before achieving goals
- Give enthusiastic and constructive feedback rather than negative criticism.
- Report any incidents or concerns that cause them to believe that a child or an adult is at risk, or is likely to be at risk of significant harm in line with our safeguarding procedures and this includes any safeguarding allegations against any colleagues too
- Co-operate with any vetting and recruitment requirements appropriate to your role and responsibilities
- Ensure that whenever possible there is more than one adult supervising during activities with children, or at least you are within sight or hearing of others. Unless the reason for this has been firmly established and agreed in advance with your manager/commissioner
3.2 Non-permissible behaviours
The following behaviours are not allowed (and in some instances, may be unlawful) for any person to:
- Use their position to intimidate, bully, threaten, injure, discriminate against, coerce or undermine any child or adult
- Allow bullying between participants to be tolerated
- Use their status or position to form or promote relationships with any child or adult participants either face to face or online, which are of a sexual nature, or which may become so
- Make sexually suggestive or derogatory remarks or gestures to, or in the presence of a child or adult participants
- Engage in rough, physical or sexually provocative games, including horseplay
- Allow children or adults to use inappropriate language without discussion about it
- Encourage or assist others to break the law in any way
- Smoke/vape, drink alcohol or taking drugs in the company of children or adult participants during outreach projects
- Invite a child or adult participant that you have met through your employment, performance or teaching into your home
- Engage in, or attempt to engage in a sexual or inappropriate relationship with child or adult participants
- Possess indecent images of children or unauthorised images of participants
- Put yourself in a position where you are alone with children or adults at risk away from organisational premises, such as taking them out on trips unaccompanied by other adults or transporting them alone, unless the reason for this is part of a work plan authorised by the Manager and with the consent of parents/carers where required
- Breach confidentiality or seek information to which you have no right of access
- Reduce a child or adult participant to tears as a form of control
- Provide intimate or medical care for any participant
- Give out personal contact details, including social networking sites and accounts, to participants
- Transport a child or adult participant to and from an event or activity unless pre-planned or in an emergency and with parent/carers knowledge
- Change clothes in a public area or enter a room where children may be changing their clothes
3.3 Appropriate physical contact
- Do not encourage physical contact (i.e. touch) between staff/freelancers and participants
- Only use touch when it is necessary in relation to the activity. Demonstration is far safer to do and avoids any misunderstanding
- Explain and then seek the agreement of the child or adult participant prior to initiating any physical contact with them if it is necessary during teaching or other activities
- Ensure disabled participants are informed of and comfortable with any necessary physical contact to support their full participation and learning
- If participants initiate touch themselves, such as a hug, then manage this carefully so that your own position is not compromised.
3.4 Abuse of a position of trust
When working with children and adults on behalf of Levels staff and freelancers are acting in a position of trust. Broadly speaking, a relationship of trust can be described as one in which one party is in a position of power or influence over the other by their work or the nature of their activity. It is vital for all those in positions of trust to understand the power this can give them over those they care for and the responsibility they must exercise because of this relationship.
Young people of 16 or 17 can legally consent to sexual activity but they may still be relatively immature emotionally. It is essential that those who may be in a position of trust recognise this vulnerability and ensure it is not exploited.
Where a person aged 18 or over is in a specified position of trust with a young person under 18, it is an offence in certain circumstances for that person to engage in sexual activity with or in the presence of that young person, or to cause or incite that young person to engage in or watch sexual activity even if the young person appears to consent. Therefore, given this principle, Levels expects:
- Any behaviour, which might allow a sexual relationship to develop between the person in a position of trust and the child or adult participants, must be avoided.
- Any sexual relationship within a position of trust relationship is not permitted so long as the relationship of trust continues.
3.5 Relationships between adults
If a member of staff or freelancer intends to have a romantic, as opposed to professional, relationship with an adult participant (i.e. aged 18 or over) then they must inform the DSO to determine and agree how to manage that situation for all parties concerned. Levels will not permit a personal relationship between someone tutoring, teaching, mentoring or coaching an adult participant and in such circumstances alternative arrangements must be made.
3.6 Communicating with child or adult participants
The following sections of the code of conduct are about expected behaviour when communicating with children and adults by phones, mobile devices, email, social media and apps:
3.6.1 Phone Contact
- Participants should only be called in relation to Levels related activities
- Staff should only use Levels landlines or work mobile phones;
3.6.2 E-safety code of conduct – communication with children via all mobile devices, on social media and apps
The term e- safety is defined here as the process of limiting the risks to children, our staff/freelancers when communicating via the internet, digital and mobile devices and using social media. Social media includes blogs, Wikis, online communities, and social networking sites such as Facebook and Twitter.
There is a wide range of ways with which to communicate with children and this is a rapidly changing environment as new technologies, applications and social media sites merge. No code of conduct for e-safety can cover these separately. However, there are broad behaviours that we expect all staff / volunteers to adhere to safeguard children and adults and themselves in respect of using all these forms of media, devices, apps and social networking sites.
3.6.3 Content
- When communicating with child or adult participants online you should observe the same rules of behaviour as if speaking with them in person that is by being professional – polite, respectful, not swearing or saying anything (using the written word, images or icons) that could be regarded as sexual innuendo, bullying or discrimination.
- Ask yourself whether the content of the message could be misunderstood or misinterpreted by someone else.
- Don’t use any text speak abbreviations or symbols/emoticons even if you ordinarily use these in your personal life. The exception to this is when working with those with educational needs (SEND) where symbols are a normal part of their communication mode.
- Never disclose non-public and confidential information about Levels and its staff/freelancers or the people with whom we are working.
- Do not say anything or re-tweet any posts that could be deemed offensive, controversial, bullying or socially inappropriate in any way.
- Contact with children and adult’s participants online should only be for Levels purposes only.
- Do not send any illegal or inappropriate content (written, images or icons) including sexting which is illegal.
- Do not use social media to view or distribute indecent images of children. Taking, making, sharing and possessing indecent images and pseudo photographs of people under 18 is illegal.
3.6.4 Openness and scrutiny
- Always communicate with children and adult participants in a way that is open to others to see if necessary.
- Do not use private messaging facilities on social networks or apps rather if it needs to be private then do this by email exchange or phone and note the conversation afterwards.
- Ensure there is always a record of such conversations that would be open to others to check if necessary.
- It should always be clear who the communication is from when x is communicating with a participant.
- There should be no use of anonymous apps – that is where the sender can remain anonymous.
3.6.5 Recording
Only use social media and apps where there is a permanent record of what’s been said and sent thereby being open to scrutiny e.g. the use of Snapchat is not appropriate. Do not use any personal devices to take pictures or film child or adult participants.
3.6.6 Use of equipment
Levels IT equipment (including computers, laptops, mobile phones, notebooks, etc.) must not be used to view, download, create or share (with colleagues or others) illegal content including abusive images of children or young people).
3.6.7 Act on concerns
If anyone identifies online concerns – be they about illegal online content or suspicious behaviour by another adult online then they must follow the Levels procedures for reporting on those concerns see (Section 5).
In respect of any child or adult participant met through work for or on behalf of Levels staff and freelancers must not:
- share personal contact details. This includes mobile phone numbers, home address, social networking accounts, personal website/blog URLs, online image storage sites, passwords etc.;
- ask to become an online friend/contact of a child or adult to follow them or add/allow a child or adult to join your contacts/friends list on personal social networking profiles;
- share work photographs or films on any personal social media sites including Facebook and Twitter;
- play online games with any child or adult participants unless part of official Levels business using professional accounts and devices;
- seek to befriend a child or adult or their family online whom you have met through work for any purpose whatsoever including for developing a personal and/or sexual relationship;
- use your personal mobile phone to communicate with child or adult participants (applicable to staff only).
3.6.8 Text messaging other messaging services
The use of text messaging to communicate with individual participants increases the vulnerability of both the person and (typically) the member of staff/freelancer. However, there may be circumstances in which it is justified, subject to appropriate safeguarding considerations. In these circumstances, the following guidelines will apply:
- The decision to use text messaging should not be made by a staff/freelancer in isolation and should be discussed and agreed with the relevant line manager;
- Only those approved to send bulk or individual messages are permitted to do so;
- Staff should only send individual text messages to a participant in response to a specific question or immediate request; staff should not engage in general conversation with young people via text message;
- Child or adult participants’ mobile phone numbers should be kept secure via passcode locks on phones and computers. The mobile phone numbers should not be shared with anyone else and should only be used for the purposes of the specific activity;
- The content should relate solely to Levels activity;
- All bulk text messages sent to children or adults should also be sent through an Levels device.
3.7 Breaches of the code of conduct
If anyone has concerns that someone is breaching the code of behaviour then s/he should contact either the Manager or head strategic DSO. That person will then determine the necessary course of action according to the seriousness of the breach.
Any breaches of the code of conduct will be taken seriously and acted upon as necessary. In some instances, this may result in disciplinary action or the initiation of the safeguarding allegation process.
Levels wants everyone to feel confident about coming forward if they do have concerns about breaches. Hierarchy, status or prestige of the person who has breached the code must not prevent this from happening.
4. Definitions of Abuse and neglect
4.1 In respect of children
Child abuse is any action by another person – adult or child – that causes significant harm to a child. It can be physical, sexual or emotional, but can just as often be about a lack of love, care and attention. We know that neglect, whatever form it takes, can be just as damaging to a child as physical abuse.
An abused child will often experience more than one type of abuse, as well as other difficulties in their lives. It often happens over a period, rather than being a one-off event. And it can increasingly happen online.
Types of child abuse:
- Domestic abuse: Witnessing domestic abuse is child abuse, and teenagers can suffer domestic abuse in their relationships.
- Sexual abuse: A child is sexually abused when they are forced or persuaded to take part in sexual activities. This doesn’t have to be physical contact, and it can happen online. It may be non- contact activities such as involving children looking at pornographic material, watching sexual activities or encouraging children to behave in sexually inappropriate ways
- Neglect: Neglect is the ongoing failure to meet a child’s basic needs. It’s dangerous and children can suffer serious and long-term harm. It can be physical or psychological needs that are being failed. These are likely to result in the serious impairment of the child’s health or development. It may involve a parent failing to provide adequate food, shelter and clothing, failure to protect a child from physical harm or danger or failure to ensure access to appropriate care and treatment. It may also include unresponsiveness to a child’s basic emotional needs
- Online abuse: Online abuse is any type of abuse that happens on the web, whether through social networks, playing online games or using mobile phones.
- Physical abuse: Physical abuse is deliberately hurting a child causing injuries such as bruises, broken bones, burns or cuts. May involve hitting, shaking, throwing, poisoning, burning or scalding. Physical harm may also be caused when a parent or carer fabricates or induces illness in a child whom they are looking after
- Emotional abuse: Children who are emotionally abused suffer emotional maltreatment or neglect. It’s sometimes called psychological abuse and can cause children serious harm. The persistent emotional ill treatment of a child such as to cause severe and persistent adverse effects on a child’s emotional and behavioural development. It may involve conveying to the child that they are worthless or unloved, inadequate or valued only in so far as they meet the needs of another person.
- Child sexual exploitation: Child sexual exploitation is a type of sexual abuse in which children are sexually exploited for money, power or status.
- Female genital mutilation (FGM): Female genital mutilation (FGM) is the partial or total removal of external female genitalia for non-medical reasons.
- Bullying and cyberbullying: Bullying can happen anywhere – at school, at home or online. It’s usually repeated over a long period of time and can hurt a child both physically and emotionally.
- Child trafficking: Child trafficking is a type of abuse where children are recruited, moved or transported and then exploited, forced to work or sold.
- Grooming: Children and young people can be groomed online or in the real world, by a stranger or by someone they know – for example a family member, friend or professional.
- Harmful sexual behaviour: Children and young people who develop harmful sexual behaviour harm themselves and others.
4.2 In Respect of Adults
Abuse can be either an act or an omission. Abuse may consist of single or repeated acts or omissions and can be carried out by anyone, in any setting. It may result in significant harm to or exploitation of, the individual.
Abuse can include one or more of the following:
- Physical Abuse: This includes hitting, pinching, deliberately giving too much medication or physically restraining someone in an inappropriate way – for example, being locked in or force-fed.
- Financial Abuse: This includes taking another person’s money or possessions – for example, having money or property stolen, being pressured into giving people money or changing a will, misuse of benefits, not being allowed access to money.
- Sexual Abuse: This includes any sexual act to which the vulnerable adult has not consented and may not understand. For example, being touched or kissed when it is not wanted, being made to touch or kiss someone else, being raped, being made to listen to sexual comments or forced to look at sexual acts or materials
- Psychological Abuse: This can happen where someone is isolated, verbally abused or threatened.
- Discrimination: This includes racism, sexism or acts based on a person’s disability, age or sexual orientation. It also includes other forms of harassment, slurs or similar treatment such as disability hate crime.
- Organisational: Neglect and poor care practice within a care setting such as a hospital or care home or in relation to care provided in someone’s own home ranging from one off incidents to ongoing ill-treatment. It can be neglect or poor practice because of the structure, policies, processes and practices within a care setting.
- Neglect and Acts of Omission: This includes ignoring or withholding physical or medical care needs. Examples are failing to provide appropriate food, shelter, heating, clothing, medical care, hygiene, personal care; inappropriate use of medication or over-medication.
- Self-neglect: Self-neglect covers a wide range of behaviour including neglecting to care for one’s personal hygiene, health or surroundings and behaviour such as hoarding.
- Abuse of Individual Rights/discriminatory abuse/racial abuse: Abuse of individual rights is a violation of human and civil rights by any other person or persons. Discriminatory abuse consists of abusive or derisive attitudes or behaviour based on a person’s sex, sexuality, ethnic origin, race, culture, age, disability or any other discriminatory abuse – this includes hate crime. Forced marriage is also an abuse of human rights and falls within the definition of adult abuse.
- Professional Abuse: Professional abuse is the misuse of therapeutic power and abuse of trust by professionals, the failure of professionals to act on suspected abuse/crimes, poor care practice or neglect in services, resource shortfalls or service pressures that lead to service failure and culpability because of poor management systems/structures. Examples of behaviour: entering a sexual relationship with a patient/client.
- Domestic Abuse: The government defines domestic violence and abuse as ‘any incidents 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 or family members regardless of gender or sexuality. The abuse can encompass, but is not limited to psychological, sexual, financial or emotional abuse’. In addition, the Serious Crime Act 2015 includes a new offence of coercive and controlling behaviour which can impose a maximum sentence of 5 years imprisonment, a fine or both.
- Modern Slavery: Encompasses slavery, human trafficking, forced labour and domestic servitude of the adult at risk.
- Hate and Mate Crime: Hate crime is where a crime is committed against a person specifically because of their gender, ethnicity, disability, religious belief or sexual orientation. If an adult at risk is specifically targeted as a victim of crime this is a hate crime.
- Mate Crime is where someone befriends an adult at risk with the intention of exploiting or abusing them. The person often believes they are their ‘friend’ but will go on to be abused e.g. financially, physically or psychologically.
- Forced Marriage: Forced Marriage is where one or both people do not or cannot consent to the marriage and pressure or abuse is used to make sure the marriage takes place. Under the Anti-Social Behaviour, Crime and Policing Act 2014 Forced Marriage is now a criminal offence to force someone to marry; therefore, the Police must always be contacted as quickly as possible.
- Honour Based Violence: Honour Based Violence is a crime; therefore, if it is suspected or the person discloses abuse, the Police must always be contacted as quickly as possible. Honour Based Violence (or killing) is used by people who want to defend the reputation of their family or community. It can also include enforced isolation from their community.
- FGM (Female Genital Mutilation): FGM involves procedures that involve total or partial removal of the female external genitalia or other injury to the female genitalia for non-medical reasons. Predominantly carried out on young girls, it is considered child abuse and is illegal in the UK.
- Coercive Control: Coercive control is when a person with whom you are personally connected, repeatedly behaves in a way which makes you feel controlled, dependent, isolated or scared.
The following types of behaviour are common examples of coercive control:
- isolating you from your friends and family
- controlling how much money you have and how you spend it
- monitoring your activities and your movements
- repeatedly putting you down, calling you names or telling you that you are worthless
- threatening to harm or kill you or your child
- threatening to publish information about you or to report you to the police or the authorities
- damaging your property or household goods
- forcing you to take part in criminal activity or child abuse
4.3 Groups more vulnerable to abuse
Certain individuals or groups of children may be more vulnerable to abuse or neglect because of risk factors in their family or environment, or because of the way they are perceived by their carers.
Recognising these vulnerable groups may enable the staff team to take steps to promote and safeguard the well-being of such children and to respond appropriately to concerns.
It is important, however, not to stigmatize families because of the presence of particular risk factors; whilst the risks of maltreatment may be higher, the majority of children within these vulnerable groups are loved and cared for and do not experience abuse.
- Parental factors: Young or single parents, parents with learning difficulties, those who themselves have experienced adverse childhoods and those with any mental health problems, including problems of drug or alcohol abuse, and those who live with intimate partner violence and abuse are all more at risk of abusing or neglecting their children. They may often need extra support in meeting their children’s needs and may be more vulnerable to the stresses inherent in parenting.
- Social factors: Families living in adverse social environments, for example due to poverty, social isolation or poor housing may also find it both materially and socially harder to care for their children. Where such issues are affecting a child’s care, it may be possible to intervene to support the family at an early stage before the child suffers harm.
- Child factors: Age plays an important role in the patterns of child abuse. Younger children are much more vulnerable to physical abuse and neglect, with at least 10% of all abuse involving children under the age of 1. In contrast, sexual abuse more often (though not exclusively) involves older children, particularly girls.
Children with disabilities are much more at risk of experiencing abuse of all kinds A wide variety of factors may contribute to that risk including sometimes greater dependence on carers, increased stresses on the carers and difficulties for the young person to communicate concerns. It is also well documented that people with disabilities face barriers when accessing health services. Attention should therefore be given to supporting the needs, including the dental needs, of children with disabilities and being alert to signs, symptoms and behavioural indicators that may indicate abuse or neglect.
5. Procedures – concerns regarding children
5.1 Responding to an emergency/accident involving a child
Levels is committed to promoting good health and to dealing efficiently and effectively with illnesses and emergencies that may arise and relate to both children and staff.
We request that parents/carers sign their Child Medical Record consent form to give permission for their child to receive treatment in the event of accident, illness, incident or emergency at Levels and in the event of a major incident for the child to be removed to hospital.
Levels always have a trained first-aider on duty and a first aid box on site.
All accidents, incidents, illnesses and emergencies will be recorded in detail in the Accident/Incident book for parents/carers to read and sign and have a copy.
5.1.1 Minor Accident. Illness or Incident or Emergency.
- A first aider will make an appropriate decision on any action or non-action required. If the child does not need hospital treatment the child will be treated at Levels, returned to classes but be kept under supervision for the remainder of the session.
- The event will be logged in the Accident & Incident book for the parent/carer to sign with details of any treatment given.
- If the injury/illness is such that first aid treatment seems inappropriate but the condition does not warrant hospitalisation, the parent/carer will be contacted immediately and asked to collect their child. Until they arrive, the child will be kept under supervision and as comfortable as possible. The event will be logged in the Accident & Incident book for parent/carer to sign.
5.1.2 Major Accident, Illness or Incident Emergency
- A first aider will make an appropriate decision on any action or non-action required. He/she will assess whether the child needs to go straight to hospital or whether they can safely wait for their parent/carer to arrive.
- If the child needs to go to hospital, an ambulance will be called and the parent/carer will be contacted. A member of staff will accompany the child to hospital and will consent to medical treatment being given only if the Childs Emergency Medical Record consent form has been completed and signed by the parent/ Carer.
- If the child does not need to go to hospital but needs to go home the parent/carer will be contacted to collect their child.
5.2 Responding to a safeguarding concern about a child
What should you do if a child comes to you and tells you that they are being abused? It’s normal to feel overwhelmed and confused in this situation. Child abuse is a difficult subject that can be hard to accept and even harder to talk about. Children who are abused are often threatened by the perpetrators to keep the abuse a secret. Thus, telling an adult takes a great amount of courage. Children have to grapple with a lot of issues, including the fear that no one will believe them. So, care must be taken to remain calm and to show support to the child throughout the disclosure phase. The following guidelines will help lessen the risk of causing more trauma to the child and/or compromising a criminal investigation during the disclosure phase.
- Receive: Listen to what is being said without displaying shock or disbelief. A common reaction to news as unpleasant and shocking as child abuse is denial. However, if you display denial to a child, or show shock or disgust at what they are saying, the child may be afraid to continue and will shut down. Accept what is being said without judgement. Take it seriously.
- Reassure: Reassure the child, but only so far as is honest and reliable. Don’t make promises that you can’t be sure to keep, e.g. “everything will be all right now”. Reassure the child that they did nothing wrong and that you take what is said seriously. Don’t promise confidentiality – never agree to keep secrets. You have a duty to report your concerns. Tell the child that you will need to tell some people, but only those whose job it is to protect children. Acknowledge how difficult it must have been to talk. It takes a lot for a child to come forward about abuse.
- React: Listen quietly, carefully and patiently. Do not assume anything – don’t speculate or jump to conclusions. Do not investigate, interrogate or decide if the child is telling the truth. Remember that an allegation of child abuse may lead to a criminal investigation, so don’t do anything that may jeopardise a police investigation. Let the child explain to you in his or her own words what happened, but don’t ask leading questions. Do ask open questions like “Is there anything else that you want to tell me?” Communicate with the child in a way that is appropriate to their age, understanding and preference. This is especially important for children with disabilities and for children whose preferred language is not English. Do not ask the child to repeat what they have told you to another member of staff. Explain what you must do next and whom you must talk to. Refer directly to the Operational DSO. Do not discuss the case with anyone outside the child protection team.
- Record: Make some very brief notes at the time and write them up in detail as soon as possible. Do not destroy your original notes in case they are required by Court. Record the date, time, place, words used by the child and how the child appeared to you – be specific. Record the actual words used; including any swear words or slang. Record statements and observable things, not your interpretations or assumptions – keep it factual.
The Operational DSO must report the concern in a timely manner:
- If the child is in immediate of harm call the local safeguarding officer or if out of hours the police on 999
- If the child isn’t at immediate risk call the local safeguarding officer straight away or if out of hours first thing in the morning.
- Operational DSO’s must also report to the Strategic DSO immediately
5.3 Responding to child welfare type concerns
If you’re worried that a child or young person is at risk or is being abused contact the children’s social care team at their local council.
You’ll be asked for your details, but you can choose not to share them.
Call 999 if the child is at immediate risk, or call the police on 101 if you think a crime has been committed.
You don’t need to be sure that a child or young person has been abused – it’s OK to report a suspicion.
What happens when you report it?
The person who answers your call will decide what to do. For example, they might:
- gather more information
- ask a social worker to look into it
- contact the police, if they think the child is at immediate risk or a crime has been committed
The children’s social care team will tell you what happens next, but they won’t be able to give you any confidential information.
5.4 Lost or Missing Children
Missing / Lost Child Even when all precautions are properly observed, emergencies can still arise. Therefore, staff will undertake periodic head counts, especially at the transition points between sessions (in addition to the registration procedures set out in the Arrival and Departures policy). If for any reason a member of staff cannot account for a child’s whereabouts during a session at Levels, the following procedure will be activated:
- The member of staff in question will inform both the Manager and the rest of the staff team that the child is missing and a thorough search of the entire premises will commence. Staff will be careful not to create an atmosphere of panic and to ensure that the other children remain safe and adequately supervised.
- The Manager will nominate a member of staff to search the area surrounding the premises. All staff will be extra vigilant to any potentially suspicious behaviour or persons in and around the Club.
- If after 15 minutes of thorough searching the child is still missing, the Manager will inform the police and then the child’s parent/carer.
- While waiting for the police and the parent/carer to arrive, searches for the child will continue. During this period, staff will maintain as normal a routine as is possible for the rest of the children.
- The Manager will be responsible for meeting the police and the missing child’s parent/carer. The Manager will co-ordinate any actions instructed by the police, and do all she/he can to comfort and reassure the parents/carers.
- All incidents of children going missing from the Club will be recorded in the Incident Record Book, and head office informed.
6 Procedures- safeguarding allegations against staff or volunteers
The procedures should be applied when there is an allegation that a person who works with children has:
- Behaved in a way which has harmed a child, or may have harmed a child;
- Possibly committed a criminal offence against or related to a child;
- Behaved towards a child or children in a way which indicates that he/she is unsuitable to work with children
There may be up to 3 strands in considering a concern or an allegation:
- A Police investigation of a criminal offence;
- Enquiries and assessment by the Children’s Services Trust to ascertain whether a child or young person needs protection or needs services;
- Consideration by Manager of disciplinary action in respect of the individual.
The person to whom an allegation or concern is reported should not question the child or investigate the matter further and should:
- Treat the matter seriously;
- Avoid asking leading questions and keep an open mind;
- Communicate with the child (if the complainant) in a way that is appropriate to the child’s age, understanding and preferred language or communication style;
- Make a written record of the information (where possible in the child’s own words), including:
- When the alleged incident took place (time and date);
- Who was present;
- What was said to have happened.
- Sign and date the written record;
- Report the matter immediately to the Manager or deputy in his/her absence or where the Manager is the subject of the allegation.
The Manager should not investigate the matter by interviewing the accused person, the child or potential witnesses, but should only gather sufficient information to establish whether there is enough credible information to proceed further (this is known as a ‘fact find’):
- Obtain written details of the allegation, signed and dated by the person receiving the complaint, or allegation and any other relevant person at the point the allegation has been made;
- Countersign and date the written details;
- Record discussions about the child and/or member of staff, any decisions made, and the reasons for those decisions;
- Decide whether any immediate action needs to be taken to safeguard any child or whether an urgent referral needs to be made to either the Children’s Services Trust and/or the Police;
- The accused adult must not be informed of the allegations before consideration has been given to the implications this may have on any subsequent investigation.
If the allegation meets any of the criteria the Manager should report it to head office and the local safeguarding board within 1 working day.
Referral should not be delayed to gather information.
If a concern or an allegation requiring immediate attention is received outside normal office hours the Manager should consult straight away with the Children’s Services Trust Emergency Duty Team.
6.1 Referral to DBS/Disclosure Scotland
Refer someone to DBS
Guidance for making barring referrals to the DBS:
Contact the barring helpline for help referring someone to DBS.
DBS barring helpline
Telephone: 03000 200 190
Managers must refer someone to DBS if they:
- sacked them because they harmed someone
- sacked them or removed them from working in regulated activity because they might have harmed someone
- were planning to sack them for either of these reasons, but they resigned first
You’re breaking the law if you don’t refer someone to DBS when you should.
When to make a referral to Disclosure Scotland
The Manager must make a referral to Disclosure Scotland explaining what’s happened. This only must be done if the harmful behaviour meant that the person involved:
- was dismissed as a result
- would have been dismissed but left before they could be
- was transferred permanently away from work with children or protected adults
How to send a referral
If an employee or volunteer has been permanently removed from work for harmful behaviour towards a child or protected adult, the employer or organisation must send an employer referral form to Disclosure Scotland.
The form asks for:
- proof of the person’s identity (name, address, date of birth, national insurance number)
- details of the type of regulated work they’re employed to do
- the person’s PVG scheme number
- information on the harmful behaviour
- details and documentation relevant to the employer’s investigation and outcome
Guidance on making a disclosure to Disclosure Scotland:
7 Procedures – recording, information sharing, escalation and working with partners
7.1 Information sharing and confidentiality
It’s important to ensure a child or young person understands their personal information will be treated respectfully and confidentially. This provides a safe space for them to be open and honest with the people caring for them. Establishing this form of trust is fundamental for the provision of safe and effective care. But when working with children and young people, it’s important to keep in mind two essential factors:
- Timely information sharing is key to safeguarding and promoting the welfare of children. It enables intervention that crucially tackles problems at an early stage
- If a child is at risk or suffering significant harm, the law supports you to share information without consent.
Get help on deciding what to do – talk to your Manager or the person in your organisation who has a lead role for safeguarding children. Ensure the outcome of your discussion is recorded. Never assume someone else will pass on information about a child, a parent or other adult that may be critical to keeping a child safe.
Ask for consent to share confidential information unless:
- Asking for consent may increase the risk of significant harm to the child or young person
- A delay in sharing information may increase the risk of harm to the child or young person.
You can get consent either verbally or in writing although it’s better to get written consent. This is to avoid any future dispute. A person can withdraw consent at any time. If a child doesn’t have the capacity to understand and make their own decisions, ask a person with parental responsibility. Be open and honest. Ensure the person you’re asking for consent understands what information will be shared and why it needs to be shared. Tell them who will see the information and what they will use it for. It’s important to respect the wishes of a child or any person who doesn’t consent to share confidential information. If you’re not given consent to share information, you may still lawfully go ahead if it can be justified to be in the public interest
If you share information without consent you’ll need to explain to the child or adult you’re going to do this and why, unless doing this will put the child at risk of significant harm.
You may need to share information about a child or about a parent or other adult to protect the child. Decide what is appropriate to share and who it will be shared with. Identify how much information to share. Think about the purpose for sharing information and share only what you judge is relevant and necessary to fulfil this.
Ensure the information you’re sharing for protecting a child is relevant to that purpose and is accurate, unbiased and up-to-date.
Share information securely and only with the relevant staff in the organisation who need to have it.
Keep a written record of your decision to share information and the reasons why.
Keep a record of who you have shared information with, what the information was, and why it was shared
7.2 Record Keeping, storage, retention and destruction
It is the policy of Levels to ensure that documents and data are retained for the time required by the law. Even where information is not covered by the Act, the Data Protection Act principles suggest that information should be adequate, relevant, not excessive, accurate, up to date and not kept for longer than is necessary.
| Information/document type | Retention Period |
| Trust deeds, governing documents | Indefinitely |
| Minutes of board meetings and AGM | Indefinitely |
| Health and safety assessments | Indefinitely |
| Insurance certificates | 40 years |
| Finance and salaries records | 7 years |
| Team Meetings | 5 years |
| Minutes and papers of meetings with external partners | 1 year |
| Personnel Records | 7 years after employee leaves (reduce to information required for references only) |
| Contracts | 6 years |
| Disciplinary Records | 6 months – 2 years depending on provisions of disciplinary policy |
| Employee time sheets | 2 years |
| Job application forms for unsuccessful candidates, interview notes | 1 year |
| Accident Book | 3 years after last entry |
Any other information kept by staff should be in line with the Data Protection Act and manual and computer records not listed above should be kept for no more than one year. Information listed above which contains personal information should be kept securely and disposed of by shredding or some way which does not breach confidentiality.
All data and personal information (e.g. names and addresses, banks details etc.) should be kept confidentially and securely:
- Data in electronic form – in password protected areas and in encrypted form
- Data in hard copy form – locked up Only those staff that need access to this data for their duties should be given passwords or access to it. Keep records of passwords in a secure place
APPENDICES
Appendix 1 – Child abuse in specific circumstances
Abuse by peers. Young people, particularly those living away from home, are vulnerable to physical, sexual and emotional bullying and abuse by their peers. Such abuse should always be taken as seriously as abuse perpetrated by an adult. It is subject to the same safeguarding children procedures as apply in respect of any young person who is suffering or at risk of suffering significant harm from an adverse source. A significant proportion of sexual offences are committed by teenagers. Staff should not dismiss some abusive sexual behaviour as “normal” between young people.
Child abuse linked to belief in “spirit possession” or “witchcraft”. The belief in “possession” and “witchcraft” is widespread in some communities. It is not confined to countries, cultures or religions. The number of known cases of child abuse linked to accusations of “possession” or “witchcraft” is small, but young people involved can suffer damage to their physical and mental health, capacity to learn, ability to form relationships and self-esteem due to extreme physical and emotional abuse that may be wrongly justified on the basis of spirit possession or witchcraft.
Child abuse and social media. The internet has become a significant tool in the distribution of abusive images of children. Social media is used as a means of contacting young people with a view to grooming them for inappropriate or abusive relationships. Contacts made initially in a chat room can be carried on via email, instant messaging services, mobile phones or text messaging. Cyberbullying, including sexting (which is illegal), is now widespread and can be very harmful to young people. Further advice and guidance on this topic are on the websites of the NSPCC, CEOP, Internet Watch Foundation and the UK Safer Internet Centre.
Child trafficking. Child trafficking is child abuse. This is where children are recruited, moved or transported and then exploited e.g. for the purpose of sexual exploitation or domestic servitude. They are often subject to multiple forms of abuse. Children may be trafficked into the UK from abroad but can also be trafficked from one part of the UK to another. Advice can be sought from the Child Trafficking Advice Centre (CTAC) on: 0808 800 5000.
Disabled children. Disabled young people are three times more likely than non-disabled children to experience abuse due to a number of factors:
- have fewer outside contacts than other young people;
- may receive personal care, possibly from a number of carers, which may both increase the risk of exposure to abusive behaviour and make it more difficult to set and maintain physical boundaries;
- have an impaired capacity to resist or avoid abuse;
- have communication difficulties that may make it difficult to tell others what is happening or to be believed;
- be inhibited about complaining because of a fear of losing services;
- be especially vulnerable to bullying and intimidation and /or, abuse by their peers.
Domestic violence. Young people living in families where they are exposed to domestic violence have been shown to be at risk of behavioural, emotional, physical and long term developmental problems. Everyone working with young people and families should be alert to the frequent inter-relationship between domestic violence and the abuse and neglect of young people.
Female genital mutilation (FGM). (also known as ‘female genital cutting’ or ‘female circumcision’.) Communities tend to use local names for referring to this practice including “sunna”. Some FGM-practicing families do not see it as an act of abuse; however, FGM has significant physical and mental health consequences both in the short and long term and, therefore, must not be excused, condoned or accepted. FGM cannot be left to personal preference or cultural custom as it is an extremely harmful practice that violates basic human rights. Girls are at particular risk of FGM during school summer holidays. This is the time when families may take their children abroad for the procedure. Many girls may not be aware that they may be at risk of undergoing FGM. FGM is illegal in the UK and where it is suspected it must be referred onto children’s social care.
Forced marriage. A forced marriage is a marriage conducted without the full consent of both parties and where duress is a factor. It is an entirely different from an arranged marriage, and the two should not be confused. In an arranged or assisted marriage, the families take a role in choosing and introducing the marriage partners but the marriage is entered into freely by both people, without pressure. In a forced marriage, this consent does not exist. If this form of harm is suspected, advice should be sought from the Forced Marriage Unit prior to any discussion with the young person or family on 0207 008 0151 or out of office hours contact: 0207 008 1500 (ask for Global Response Centre).
Parental adversity. Parental drug misuse can and can cause harm from conception to adulthood, including physical and emotional abuse and neglect. Where drug misuse co exists with domestic violence and mental illness the risk of harm to a child is even greater.
Race and racism. Children from black and minority ethnic groups may have experienced harassment, racial discrimination and institutional racism. The experience of racism is likely to affect the responses of the young person and parents/carers to other intervention in their lives. There is also a danger that people working with children and young people may not intervene soon enough for fear of being seen as racist and in so doing, offer the child less protection.
Unaccompanied asylum-seeking children (UASC). A UASC is an asylum-seeking child under the age of 18 who is not living with their parent, relative or guardian in the UK. They can be more vulnerable to abuse and exploitation because they lack the necessary support networks, protection and communication skills.
Safeguarding adolescents
The nature of abuse and neglect for teenagers is different from that of younger children. Behaviours by parents/adults that might be deemed abusive or neglectful for a very young child may be considered appropriate for teenagers. Additionally they may face a wider range of risks due to the relationships they have, social media that they use, lifestyles that they lead and with their increasing independence. Risk taking and experimentation is a normal part of growing up but also can place young people in harm’s way.
Young people whose behaviour indicates a lack of parental control. When young people are brought to the attention of the police or wider community because of their behaviour, this may be an indication of vulnerability, poor supervision, abuse or neglect in its wider sense. It is important to consider whether these are young people in need of protection and/or support services and not to view them as only an offender as they may well be also victims themselves.
Young people and gang activity. Overall, young people can be particularly vulnerable to suffering harm in the gang context are those who are:
- not involved in gangs, but living in an area where gangs are active, which can have a negative impact on their ability to be safe;
- not involved in gangs, but at risk of becoming victims of gangs;
- not involved in gangs but at risk of becoming drawn in, for example,
siblings or children of known gang members; or
- gang-involved and at risk of harm through their gang-related activities e.g. drug supply, weapon use, sexual exploitation and risk of attack from own or rival gang members.
Young carers. A young carer is a person under 18 who provides or intends to provide care for another person (of any age with the exception of where that care is provided for payment or as voluntary work). Young carers may require support services either for them or for the person they care for in order to ensure that their health and welfare does not suffer. In some instances young carers may also be in need of protection due to the adverse circumstances they may be experiencing or where the behaviour of the person that they are caring for is abusive.
Radicalisation and violent extremism. Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism leading to terrorism. Extremism is defined by the Government in the 2011 Prevent Strategy as: Vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. It also includes calls for death of members of the armed forces, whether in this country or overseas.
There is no such thing as a “typical extremist”: those who become involved in extremist actions come from a range of backgrounds and experiences, and most individuals, even those who hold radical views, do not become involved in violent extremist activity.
Children or adults may become susceptible to radicalisation through a range of social, personal and environmental factors – it is known that violent extremists exploit vulnerabilities in individuals.
Indicators of vulnerability include:
- Identity crisis – the young person is distanced from their cultural/religious heritage and experiences discomfort about their place in society;
- Personal crisis – the young person may be experiencing family tensions; a sense of isolation; and low self-esteem; they may have dissociated from their existing friendship group and become involved with a new and different group of friends; they may be searching for answers to questions about identity, faith and belonging;
- Personal circumstances – migration; local community tensions; and events affecting the student’s country or region of origin may contribute to a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy;
- Unmet aspirations – the young person may have perceptions of injustice; a feeling of failure; rejection of civic life;
- Experiences of criminality – which may include involvement with criminal groups, imprisonment, and poor resettlement/reintegration;
- Special educational needs – young person may experience difficulties with social interaction, empathy with others, understanding the consequences of their actions and awareness of the motivations of others.
However, this list is not exhaustive, nor does it mean that all young people experiencing the above are at risk of radicalisation for the purposes of violent extremism.
Indicators of radicalisation and violent extremism may include:
- showing sympathy for extremist causes
- contact with extremist recruiters;
- justifying the use of violence to solve societal issues;
- joining or seeking to join extremist organisations;
- glorifying violence, especially to other faiths or cultures
- making remarks or comments about being at extremist events or rallies
- possessing illegal or extremist literature
- advocating messages similar to illegal organisations or other extremist groups
- out of character changes in dress, behaviour and peer relationships secretive behaviour
- online searches or sharing extremist messages or social profiles
- intolerance of difference, including faith, culture, gender, race or sexuality
- graffiti, art work or writing that displays extremist themes
- attempts to impose extremist views or practices on others
- verbalising anti-Western or anti-British views
Children or adults who are showing signs of radicalisation and violent extremism will need to be considered as at risk of harm to themselves or others and therefore such concerns should be acted upon by following safeguarding procedures.
Appendix 2 – Child Protection and Safeguarding Contacts List
| Name and job title | Safeguarding Role | Contact details | ||||
| Ian Irving | Designated Safeguarding Lead (DSL) | Manager will contact directly | ||||
| Manager of each school | Designated Safeguarding Officer | Individual Manager will provide this to staff | ||||
| NSPCC Helpline | 24 hour helpline for advice on child protection matters | 0808 800 5000 | ||||
| ChildLine | 24 hour helpline for children and young people | 0800 1111 | ||||
| Whistle blowing advice line (external) | Advice can be sought from NSPCC if using the internal whistleblowing procedure has not resolved the concern | 0800 028 0285 | ||||
| The UK Safer Internet Centre | Provides advice for professionals and responds to reports about sexual abuse images of children online | 0344 381 4772 | ||||
| Child Exploitation and Online Protection Centre(CEOP) | Investigates inappropriate online behaviour such as grooming online or sexual exploitation | 0870 000 3344 https://www.ceop.police.uk/safety-centre/ | ||||
| Internet Watch Foundation | Remove images of child sexual abuse content and criminally obscene content online | 01223 203030 https://www.iwf.org.uk/ | ||||
| Disclosure and Barring Service (DBS) | Advice line for criminal records checks | 03000 200 190 | ||||
| The Mix | Helpline offering support and advice for those under 25 years | 0808 808 4994 | ||||
| Local authority children’s social care | Use the following website to find out the details: https://www.gov.uk/report-child-abuse-to-local-council | |||||
Appendix 3 – Safeguarding Incident Report Form
Complete as much detail as you are able. Don’t delay making a referral if there is information missing.
| Part 1 – Details of the Child/ren or adult at risk: | ||
| Name of Children or adult at risk: | ||
| Gender: | Age: | Date of Birth: |
| Religion | Ethnicity | Any additional needs (e.g. disability, language spoken, interpreter required) |
| Parent’s/Carer’s name(s): | ||
| Home address of children or adult at risk: | ||
| Legal status of Children/ adult at risk : | ||
| Is child or adult at risk subject to any of the following e.g. child protection plan/on a child protection register/a care order/child in need plan/adult protection order or other? | ||
| Part 2 – Details of a safeguarding allegation against staff/ volunteer/ musician | ||
| Name and role of person: | ||
| Age and/or Date of Birth: | ||
| Home address: | ||
| Part 3 – Your Details | ||
| Your Name: | Your Position: | Your contact details |
| Part 4 – Report | |
| Are you reporting your own concerns or responding to concerns raised by someone else? | |
| □ Responding to my own concerns □ Responding to concerns raised by someone else | If responding to concerns raised by someone else, please provide their name, role and contact details (if known): |
| Please provide details of the concerns you have for the child’s or adult at risk safety and/or welfare, including times, dates or other relevant information (describe any injuries, whether fact, opinion or hearsay). Please add any other relevant information known about the family/child/adult at risk circumstances. If you are reporting on concerns about a safeguarding allegation against a staff member/volunteer or musician please provide full details here | |
| The child’s or adult at risk account of what happened (e.g. of any incident, injury, disclosure, behaviour): | |
| Please provide details of the person alleged to have caused the incident/injury if known (e.g. names(s) /address/ incident address /relationship to child or adult at risk etc.): | |
| Please provide details (name, role contact details if known) of any witnesses to the incident/concerns: | |
| Part 5 – Actions Taken | |
| State any risk of immediate danger: | |
| Identify any action taken already e.g. contact with police, manager, children’s or adult social care services etc. | |
| Is the child/children/adult at risk or family/carer or accused person aware that a report has been made: | |
| Any known previous history of concerns or abuse or allegations: | |
| Any further information or comments: |
Date and time of report being submitted……………………………………………………………………………
| Part 6 – Immediate action and decisions by DSO |
Child Protection and Safeguarding Recording Log
| Date & time | Name | Notes |
Appendix 4 – Use of images in media, online and publications
Images (still and moving) are taken and used for a variety of purposes including publications, social media, marketing and PR activity. Levels must act responsibly in its use of taking and managing the use of these images.
Consent
- Managers must seek consent from children and their parents/carers of those up to the age of 16 years when it intends to capture any images (still and moving) of a child or adult at risk on a camera or any other electronic device. Young people aged 16-18 and adults with mental capacity may give consent themselves.
- The Photography and Film Consent Form should be signed either before enrolment or when it is apparent that images will be taken and used.
- Consent forms should be stored by the relevant Manager in a password protected project folder.
- Those giving consent must be informed about how the images will be used e.g. once only for a specific publication or multiple use or, as part of the Levels image library for future use.
- Where images are taken for any marketing material, the relevant manager should check that the consent form has been completed prior to taking any images or film of a child or adult at risk or before using existing ones.
- Images should be stored separately from consent forms and those for which there is no consent should either be deleted or labelled as such
- Giving children stickers so it’s clear who can’t be photographed and/or position them at the end of rows can be helpful
- Use back of head shots if necessary
- The Manager should brief any appointed photographer in advance about consents
- Display signage to declare if images will be taken during an activity/event
Equipment used to capture images
Levels staff working will only use Levels equipment for capturing images. No photographs should be taken if there is no Levels staff present.
Use of images
The names of children must normally not be published with the image of the child unless it is needed to give meaning to the article, case study, press release etc. for which it is being used. If names are used, the publisher should think carefully whether the first and surname are needed and only use a surname where it is absolutely necessary.
Sharing images
Once the images have been captured Levels may get requests from other individuals or organisations to use those images. If the request is from somebody included in the image then they will normally be entitled to a copy (having due regard for other people included in the picture) as they would with any other request for personal information. If, however, it is somebody external, such as a media organisation, Levels will need to consider whether the consent covers this or if it needs to seek further consent.
Storage, retention and destruction of images
- Images must be stored securely
- Only those individuals at Levels who need to use the images should have access to them.
- Timescales for keeping the images need to be specified on the consent form.
- Data protection legislation states that personal information (including images of identifiable people) should not be kept longer than necessary. The Manager is responsible for ensuring images are securely stored and destroyed. The destruction period will be dependent on whether there are any exemptions within the consent given ex: if someone doesn’t want images archived for historic purposes then they will need to be destroyed after they have been used for the stated purpose.
Existing photographs
If the existing photographs are going to be used for another other purpose than that they were originally taken for, the holder is responsible for making reasonable contact with the subject to gain consent. When there is uncertainty, a risk assessment should be undertaken to determine what is reasonable.
Large crowds
When taking images at an event attended by large crowds, this is regarded as a public area and so permission is not required from everyone in a crowd shot.
Appendix 5 – Confirmation of Reading
I confirm that I have been made fully aware of, and understand the contents of, the Safeguarding Policy and Procedures for Levels.
Please complete the details below and return this completed for to <Ian Irving, ian@levelswhitehaven.co.uk>
| Name:_______________________________________ | Signature:____________________________________ |
| Date:_________________ |

