Bantani Cymru (BC) Child Protection and Safeguarding Policy

Document Child Protection and Safeguarding Policy 

Date of original document September 2023 

Original document author Morgan Jones 

Latest document revisions 

Revised by  

Approved by Hazel Israel 

Next review date November 2024

Introduction

Everyone who participates in training and projects organised by BC is entitled to do so in an enjoyable and safe environment. BC has a moral and legal obligation to ensure that, when given responsibility for children, young people and vulnerable adults, all staff and volunteers provide them with the highest possible standard of care. 

BC is committed to devising and implementing policies to ensure that all staff and volunteers understand and accept their responsibilities to safeguard children, young people and vulnerable adults from harm and abuse. This means to follow procedures to protect children, young people and vulnerable adults and report any concerns about their welfare to appropriate authorities. 

The aim of the policy is to promote good practice, providing children, young people and vulnerable adults with appropriate safety and protection whilst in the care of BC’s trade skills mentors and to allow staff and volunteers to make informed and confident responses to specific protection safeguarding issues. 

NB1: A child/young person is defined as a person under the age of 18 (Children’s Act 1989). 

Policy statement

BC is committed to the following: 

  • The welfare of participating children, young people and vulnerable adults is paramount. 
  • All children, young people and vulnerable adults, whatever their age, culture, ability, gender, disability, language, racial origin, religious belief and/or sexual identity, should be able to participate in an enjoyable and safe environment. 
  • Taking all reasonable steps to protect children, young people and vulnerable adults from harm, discrimination and degrading treatment and to respect their rights, wishes and feelings. 
  • All suspicions and allegations of poor practice or abuse will be taken seriously and responded to swiftly and appropriately.
  • All BC employees and volunteers who work with children, young people and vulnerable adults will be recruited with regard to their suitability for that responsibility, and will be provided with guidance and/or training in good practice and child protection procedures, in accordance with all pertinent regulation, including the Safeguarding Vulnerable Groups Act (SVGA) 2006 and ISA Registration & Disclosure and Barring Service (DBS).
  • Working in partnership with parents/guardians/care workers is essential for the protection of children, young people and vulnerable adults.

Monitoring and reviewing the policy and procedures 

The implementation of these procedures will be regularly monitored and reviewed. The Senior Designated Person will regularly report progress, challenges, difficulties, achievements gaps and areas where changes are required. 

This policy will be reviewed every six months or whenever there is a major change in BC personnel or in relevant legislation.

Promoting good practice 

Introduction 

To provide children, young people and vulnerable adults with the best possible experience and opportunities all BC staff and volunteers must operate within an accepted ethical framework (e.g. Every Child Matters). 

It is not always easy to distinguish poor practice from abuse. It is therefore not the responsibility of employees or participants within BC to make judgements about whether or not abuse is taking place. It is however their responsibility to identify poor practice and possible abuse and act if they have concerns about the welfare of the child, young person or vulnerable adult, as explained below. 

This section helps identify what is meant by good practice and poor practice. 

Good practice 

All BC staff and volunteers should adhere to the following principles and action: 

  • Always work in an open environment (e.g. avoiding private or unobserved situations and encouraging open communication with no secrets) 
  • Make the experience fun and enjoyable: promote fairness and confront and deal with bullying 
  • Treat all children, young people and vulnerable adults equally and with respect and dignity 
  • Always put the welfare of the child, young person or vulnerable adult first 
  • Maintain a safe and appropriate distance (e.g. it is not appropriate for staff or volunteers to have an intimate relationship with a child, young person or vulnerable adult) 
  • Avoid unnecessary physical contact with children, young people or vulnerable adults. 

Where any form of physical support is required it should be provided openly and with the consent of the child, young person or vulnerable adult. Physical contact can be appropriate so long as it is neither intrusive nor disturbing and the participant’s consent has been given 

  • Involve parents/guardians/care workers/youth workers wherever possible, e.g. where children, young people or vulnerable adults need to be supervised, encourage parents/guardians/care workers to take responsibility for their own ‘charge’. If groups have to be supervised in changing rooms always ensure parents, guardians, care workers, coaches, etc, work in pairs 
  • Request written consent if staff or volunteers are required to transport young people in their cars 
  • Gain written consent for any significant travel arrangements (e.g. overnight stays) 
  • Ensure that if mixed gender participants are taken away, they should always be accompanied by a male and female member of staff/volunteer where possible 
  • Be an excellent role model. This includes not smoking or drinking alcohol in the company of children, young people or vulnerable adults 
  • Always give enthusiastic and constructive feedback rather than negative criticism 
  • Recognise the developmental needs and capacity of the child, young person or vulnerable adult 
  • Secure written consent for the project /club to act in loco parentis, to give permission for the administration of emergency first aid or other medical treatment if the need arises 
  • Keep a written record of any injury that occurs, along with details of any treatment given 

Poor practice 

The following are regarded as poor practice and should be avoided by all staff and volunteers: 

  • Unnecessarily spending excessive amounts of time alone with children, young people and vulnerable adults away from others 
  • Taking children, young people and vulnerable adults alone in a car on journeys, however short 
  • Taking children, young people or vulnerable adults to your home where they will be alone with you 
  • Sharing a room with a child, young person or vulnerable adult 
  • Engaging in rough, physical or sexually provocative games, including horseplay 
  • Allow or engage in inappropriate touching of any form 
  • Allowing children, young people or vulnerable adults to use inappropriate language unchallenged 
  • Making sexually suggestive comments to a child, young person or vulnerable adult, even in fun 
  • Reducing a child, young person or vulnerable adult to tears as a form of control 
  • Allow allegations made by a child, young person or vulnerable adult to go unchallenged, unrecorded or not acted upon 
  • Do things of a personal nature that the child, young person or vulnerable adult can do for themselves 

When a case arises where it is impractical/impossible to avoid certain situation e.g. transporting a participant in your car, the tasks should only be carried out with the full understanding and consent of the parent/guardian/care worker and the child, young person or vulnerable adult involved. 

If during your care you accidentally hurt a participant, the child, young person or vulnerable adult seems distressed in any manner, appears to be sexually aroused by your actions and/or if the participant misunderstands or misinterprets something you have done, report any such incidents as soon as possible to the Senior Designated Person and make a written note of it. Parents/guardians/care workers should also be informed of the incident.

Defining abuse 

Introduction

Abuse is any form of physical, emotional or sexual mistreatment or lack of care that leads to injury or harm. It commonly occurs within a relationship of trust or responsibility and is an abuse of power or a breach of trust. 

There are four main types of abuse: physical abuse, sexual abuse, emotional abuse and neglect.

The abuser may be a family member, someone the child, young person or vulnerable adult encounters in residential care or in the community, including sports and leisure activities. 

Any individual may abuse or neglect a child, young person or vulnerable adult directly, or may be responsible for abuse because they fail to prevent another person harming the child, young person or vulnerable adult. 

Abuse in all of its forms can affect children, young people and vulnerable adults at any age. 

The effects can be so damaging that if not treated may follow the individual into adulthood. 

Children and young people with disabilities may be at increased risk of abuse through various factors such as stereotyping, prejudice, discrimination, isolation and a powerlessness to protect themselves or adequately communicate that abuse had occurred. 

Types of abuse 

  • Physical abuse: where adults physically hurt or injure a child, young person or vulnerable adult, e.g. hitting, shaking, throwing, poisoning, burning, biting, scalding, suffocating, drowning. Giving children, young people or vulnerable adults alcohol or inappropriate drugs would also constitute abuse. This category of abuse can also include when a parent/guardian/care worker reports non-existent symptoms or illness, or deliberately causes ill health in a child, young person or vulnerable adult they are looking after. 
  • Emotional abuse: the persistent emotional ill treatment of a child, young person or vulnerable adult, likely to cause severe and lasting adverse effects on the individual’s emotional development. It may involve telling the individual they are useless, worthless, unloved, inadequate or valued in terms of only meeting the needs of another person. It may feature expectations of children, young people or vulnerable adults that are not appropriate to their age or development. It may cause an individual to be frightened or in danger by being constantly shouted at, threatened or taunted which may make the child, young person or vulnerable adult frightened or withdrawn. The ill treatment of children, young people and vulnerable adults, whatever form it takes, will always feature a degree of emotional abuse. 
  • Bullying may come from another participant or an adult. Bullying is defined as deliberate hurtful behaviour, usually repeated over a period of time, where it is difficult for those bullied to defend themselves. There are four main types of bullying. It may be physical (e.g. hitting, kicking, slapping), verbal (e.g. racist or homophobic remarks, name calling, graffiti, threats, abusive text, email or chat room messages), emotional (e.g. tormenting, ridiculing, humiliating, ignoring, isolating from the group), or sexual (e.g. unwanted physical contact or abusive comments). 
  • Neglect occurs when an adult fails to meet the child, young person or vulnerable adult’s basic physical and/or psychological needs, to an extent that is likely to result in serious impairment of their health or development. For example, failing to provide adequate food, shelter and clothing, failing to protect from physical harm or danger, or failing to ensure access to appropriate medical care or treatment. 
  • Sexual abuse occurs when adults (male and female) use children, young people or vulnerable adults to meet their own sexual needs. Siblings and family members can be the abuser. This could include full sexual intercourse, masturbation, oral sex, anal intercourse and fondling. Showing individuals pornography or talking to them in a sexually explicit manner are also forms of sexual abuse. NB: Issues and abuse for children and young people are not always the same as vulnerable adults. In addition to the list above, the following types of abuse may apply specifically for vulnerable adults: 
  • Financial or material abuse can involve the theft or misuse of a person’s funds and assets, obtaining property and funds without his/her knowledge, or in the case of an elderly person who is not competent, not in his/her best interest. 
  • Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals. It can be the feature of any form of abuse of an adult, but can be motivated because of age, gender, sexuality, disability, religion, class, culture, language, race or ethnic origin. 
  • Institutional abuse is the maltreatment of a person from a system of power, which occurs within care facilities such as retirement homes. 

Indicators of abuse 

Even for those experienced in working with abuse, it is not always easy to recognise a situation where abuse may occur or has already taken place. Most people are not experts in such recognition, but indications that a child, young person or vulnerable adult is being abused may include one or more of the following: 

  • Unexplained or suspicious injuries such as bruising, cuts or burns, particularly if situated on a part of the body not normally prone to such injuries 
  • An injury for which an explanation seems inconsistent 
  • The child, young person or vulnerable adult describes what appears to be an abusive act involving them 
  • Another participant or adult expresses concern about the welfare of a child, young person or vulnerable adult 
  • Unexplained changes in a child, young person or vulnerable adult’s behaviour (e.g. becoming very upset, quiet, withdrawn or displaying sudden outbursts of temper) 
  • Inappropriate sexual awareness 
  • Engaging in sexually explicit behaviour 
  • Distrust of adult’s, particularly those whom a close relationship would normally be expected 
  • Difficulty in making friends 
  • Being prevented from socialising with others 
  • Displaying variations in eating patterns including over eating or loss of appetite 
  • Losing weight for no apparent reason 
  • Becoming increasingly dirty or unkempt 

Signs of bullying include: 

  • Behavioural changes such as reduced concentration and/or becoming withdrawn, clingy, depressed, tearful, emotionally up and down, reluctance to go training or competitions 
  • An unexplained drop-off in performance 
  • Physical signs such as stomach aches, headaches, difficulty in sleeping, bed wetting, scratching and bruising, damaged clothes, binge consumption (e.g. of food, alcohol or cigarettes) 
  • A shortage of money or frequents loss of possessions 

It must be recognised that the above list is not exhaustive, but also that the presence of one or more of the indications is not proof that abuse is taking place. It is not the responsibility of those working for BC to decide that abuse is occurring. It is their responsibility to act on any concerns.

Use of photographic/filming equipment at project activities/events 

There is evidence that some people have used community-based activities and events as an opportunity to take inappropriate photographs or film footage of children, young people and vulnerable adults. BC staff and volunteers should be vigilant and any concerns should be reported to the Senior Designated Person. 

To safeguard children, young people and vulnerable adults, as well as the privacy of all participants in general, BC has a strict ‘no photography or filming’ policy in all sessions where children, young people or vulnerable adults are present unless written consent of participants and/or their parents/guardians/carers has been requested and received.

Responding to suspicions and allegations 

Introduction 

It is not the responsibility of anyone working in BC in a paid or unpaid capacity to decide whether or not abuse has taken place. However, there is a responsibility to act on any concerns through contact with the appropriate authorities so that they can then make inquiries and take necessary action to protect the child, young person or vulnerable adult. This applies both to allegations/suspicions of abuse occurring within BC and to allegations/suspicions that abuse is taking place elsewhere. 

Receiving evidence of possible abuse 

We may become aware of possible abuse in various ways. We may see it happening, we may suspect it happening because of signs such as those listed above, it may be reported to us by someone else or directly by the child, young person or vulnerable adult affected. 

In the last of these cases, it is particularly important to respond appropriately. If a child, young person or vulnerable adult says or indicates that they are being abused, you should: 

  • Stay calm so as not to frighten the child, young person or vulnerable adult 
  • Reassure them that they are not to blame and that it was right to tell 
  • Listen to them, showing that you are taking them seriously 
  • Keep questions to a minimum so that there is a clear and accurate understanding of what has been said. The law is very strict and abuse cases have been dismissed where it is felt that the child, young person or vulnerable adult has been led or words and ideas have been suggested during questioning. Only ask questions to clarify.
  • Inform the child, young person or vulnerable adult that you have to inform other people about what they have told you. Tell the child, young person or vulnerable adult that this is to help stop the abuse continuing
  • Safety of the child, young person or vulnerable adult is paramount. If the participant needs urgent medical attention call an ambulance, inform the doctors of the concern and ensure they are made aware that this is a child protection issue 
  • Record all information 
  • Report the incident to the Senior Designated Person 
  • When working on site in another organisation (such as a school, nursery, youth centre or sports club) and you become aware of possible abuse, you must immediately ask to speak to the Senior Designated Person on site

Recording information 

To ensure that information is as helpful as possible, a detailed record should always be made at the time of the disclosure/concern. In recording you should confine yourself to the facts and distinguish what is your personal knowledge and what others have told you. Do not include your own opinions. 

Information should include the following: 

  • The participant’s name, age and date of birth 
  • The participant’s home address and telephone number 
  • Whether or not the person making the report is expressing their concern or someone else’s 
  • The nature of the allegation, including dates, times and any other relevant information 
  • A description of any visible bruising or injury, location, size etc. Also any indirect signs, such as behavioural changes 
  • Details of witnesses to the incidents 
  • The participant’s account, if it can be given, of what has happened and how any bruising/injuries occurred 
  • Has a parents/guardian/care worker been contacted? If so, what has been said? 
  • Has anyone else been consulted? If so, record details 
  • Has anyone been alleged to be the abuser? If so, record detail 

Reporting the concern 

All suspicions and allegations must be reported appropriately. It is recognised that strong emotions can be aroused particularly in cases where sexual abuse is suspected or where there is misplaced loyalty to a colleague. It is important to understand these feelings but not allow them to interfere with your judgement about any action to take. 

BC expects its staff and volunteers to discuss any concerns they may have about the welfare of a child, young person or vulnerable adult immediately with the Senior Designated Person and subsequently to check that appropriate action has been taken. 

Your Senior Designated Person is: Hazel Israel, Bantani Cymru Director Contact: hazel@bantani.com

If the Senior Designated Person is not available you should take responsibility and seek advice from local services (NB: contact details/phone numbers must be provided for these local services to all BC staff and volunteers working with children, young people and vulnerable adults on BC projects): 

If you need urgent help or a crime has been committed you should contact the police. If it is an emergency you should call 999 or 112. 

Where there is a complaint against an employee or volunteer, there may be three types of investigation: 

  • Criminal: in which case the police are immediately involved 
  • Child protection: in which case the social care team (and possibly) the police will be involved 
  • Disciplinary or misconduct: in which case BC will be involved 

As mentioned previously in this document, BC staff and volunteers are not child protection experts and it is not their responsibility to determine whether or not abuse has taken place. 

All suspicions and allegations must be shared with the appropriate professional agencies. 

NB: If there is any doubt, you must report the incident: it may be just one of a series of other incidences which together cause concern. 

Any suspicion that a child, young person or vulnerable adult has been abused by an employee or a volunteer should be reported to the Senior Designated Person, who will take appropriate steps to ensure the safety of the child, young person or vulnerable adult in question and any other individuals who may be at risk. Any suspicions regarding the Senior Designated Person should be reported immediately to the appropriate agency. Please see the above section for up to date contact details. 

Allegations of abuse can be made sometime after the event. Where such an allegation is made, you should follow the same procedures and have the matter reported to the appropriate services. This is because other children, young people or vulnerable adults may be at risk from the alleged abuser. Anyone who has a previous conviction for offences related to abuse against children, young people or vulnerable adults is automatically excluded from working/volunteering on BC; Safeguarding Vulnerable Groups Act (SVGA) 2006 and ISA Registration & DBS. 

Concerns outside the immediate environment (e.g. a parent, guardian or care worker) 

  • Report your concerns to the Senior Designated Person 
  • If the Senior Designated Person is not available, the person being told or discovering the abuse should contact their local social care team or the police immediately 
  • The social care team and Senior Designated Officer will decide how to inform the parents/guardians/care workers 
  • Maintain confidentiality on a ‘need to know’ basis 

Confidentiality 

Every effort should be made to ensure that confidentiality is maintained for all concerned. 

Information should be handled and disseminated on a ‘need to know’ basis only. This includes the following people: 

  • The Senior Designated Officer 
  • The parents/guardian/care worker responsible for the child, young person or vulnerable adult 
  • The person making the allegation 
  • Social care team/police 
  • The alleged abuser (and parent/guardian/care worker if the alleged abuser is a child) 

Seek advice from the social care team on who should approach the alleged abuser. 

Internal inquiries and suspension 

  • BC’s Senior Designated Person will make an immediate decision about whether any individual accused of abuse should be temporarily suspended pending further police and social care team inquiries in line with the Safeguarding Vulnerable Groups Act (SVGA) 2006 and ISA Registration & DBS 
  • Irrespective of the findings of the social care team or police inquiries BC’s Disciplinary Committee (made up of company Directors) will assess all individual cases to decide whether a member of staff or volunteer can be reinstated and how this can be sensitively handled. This may be a difficult decision; especially where there is insufficient evidence to uphold any action by the police. In such cases BC’s Disciplinary Committee must reach a decision based upon the available information which could suggest that on the balance of probability, it is more likely than not that the allegation is true. The welfare of children, young people and vulnerable adults will remain of paramount importance throughout. 

Recruiting and selecting personnel working/volunteering with children, young people and vulnerable adults 

Introduction 

It is important that all reasonable steps are taken to prevent unsuitable people from working with children, young people or vulnerable adults. This applies equally to paid staff and volunteers, both full and part-time. To ensure unsuitable people are prevented from working with children and vulnerable adults the following steps will be taken by BC when recruiting. 

Controlling access to children, young people and vulnerable adults 

  • All staff and volunteers will complete an application form. The application form will elicit information about the applicants past and a self disclosure about any criminal record 
  • Consent will be obtained from the applicant to seek information from the Disclosure and Barring Service (DBS) 
  • Two confidential references, including one regarding previous work with children, young people or vulnerable adults will be obtained. These references must be taken up and confirmed through telephone contact and to check identity 
  • Evidence of identity and the right to work in this country must be checked. This evidence must be photo ID (passport or driving licence with photo) 

Interview and induction 

All employees and volunteers will be required to undertake an interview carried out to acceptable protocol and recommendations. All employees and volunteers will receive formal or informal induction during which: 

  • A check will be made that the application form has been completed in full, including sections on criminal records and self disclosures 
  • Their qualifications will be substantiated 
  • The job requirements and responsibilities will be clarified 
  • They will sign up to BC’s Code of Ethics and Conduct 
  • Child Protection and Safeguarding Procedures will be explained and training needs identified 

Training 

In addition to pre-selection checks, the safeguarding process includes training after recruitment to help staff and volunteers to: 

  • Analyse their own practice against what is deemed good practice, and to ensure their practice is likely to protect them from false allegations 
  • Recognise their responsibilities and report any concerns about suspected poor practice and/or abuse 
  • Respond to concerns expressed by a child, young person or vulnerable adult 
  • Work safely and effectively with children, young people and vulnerable adults 

BC requires: 

  • All staff and volunteers who have access to children to undergo a DBS check 
  • All staff and volunteers to undertake relevant safeguarding training or undertake a form of home study, to ensure their practice is exemplary and to facilitate the development of positive culture towards good practice and child protection 
  • All staff and volunteers to receive advisory information outlining good/poor practice and informing them what to do if they have concerns about the behaviour of an adult towards a young person or vulnerable adult.