Safeguarding Children, Young People and Vulnerable Adults Policy

This policy applies to all the students enrolled on a BCT NI C.I.C programme.

1. Purpose

We are committed in ensuring to safeguard the interests of the individual students and ensure that all students experience an inclusive, enjoyable and safe environment, in which they feel respected and valued. We all share an objective to keep children, young people and vulnerable adults safe. All Children and Young People have a fundamental right to be safeguarded from harm.

The purpose of this Policy and related procedures is to:

• promote the welfare of children, young people and vulnerable adults and protect them from harm.
• prevent harm occurring through early identification of risk and appropriate timely intervention.
• identify staff responsibilities in dealing with reports or suspicions of abuse.
• provide clear and robust guidance on how to handle these concerns.
• encourage good practice in all aspects of promotion and protection of children, young people and vulnerable adults.

2. Context

We will carry out our responsibilities under all relevant legislation, regulations and professional guidelines which include the following:

• Children Northern Ireland Order 1995
• Children’s Services Co-operation Act (Northern Ireland) 2015
• Co-operating to Safeguard Children and Young people in Northern Ireland (HSSPS – March 2016) Human Rights Act 1998
• Safeguarding Vulnerable Groups (Northern Ireland) Order 2007
• United Nations Convention on the Rights of the Child

3. Scope

This Policy and related procedures deal with the safeguarding and protection of children and vulnerable adults from abuse, as defined below.

Child: A person under the age of 18,as defined in the Children Northern Ireland Order 1995.

Vulnerable Adult: A person aged 18 or over, who is or may be in need of community care services by reason of mental or other disability, age or illness and who is, or may be unable to take care of him or herself or unable to protect him or herself against significant harm or exploitation (DoH No Secrets 2002)

Abuse: Defining abuse is complex and rests on many factors. The term “abuse” can be widely interpreted. However, “abuse” is defined in the Department of Health No Secrets guidance as the “violation of an individual’s human and civil rights by any other person or persons.” Abuse may happen as the result of deliberate intent, negligence or ignorance.

Here are some examples of abuse:

• Physical abuse
  This includes hitting, slapping, pushing, kicking, misuse of medical/chemical restraint or inappropriate sanctions.
• Sexual abuse
  This includes rape and sexual assault or sexual acts to which the child/vulnerable adult has not, or could not, consent and/or was pressured into consenting.
• Psychological/emotional abuse
  This includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, verbal or racial abuse, forced marriage, isolation or withdrawal of services or supportive networks.
• Financial or material abuse
  This includes theft, fraud, exploitation; pressure in connection with wills, property, inheritance or financial transactions; or the misuses or misappropriation of property, possessions or benefits.
• Neglect and acts of omission
  This includes ignoring medical or physical care needs; failure to provide access to appropriate health, social care or educational services; the withholding of the necessities of life, such as medication, adequate nutrition and heating.
• Institutional abuse
  This is repeated instances of poor care of individuals or groups of individuals. It can be through neglect or poor professional practice as a result of structures, policies, processes and practices within an organisation. While this in no way condones the abusive practice on the part of individuals, it recognises the powerful influence that organisational culture has on individual behaviour.

The above should not be considered an exclusive or even exhaustive list of the types of abuse which can be experienced by children/vulnerable adults.

4. General Principles

This policy and related procedures are based on the following principles:

• We seek to provide and promote a safe learning environment for all users.
• We recognise that anyone can be the subject of abuse and that all allegations of abuse will be taken seriously and treated in accordance with the BCT NI C.I.C procedures.
• This Policy and related procedures will be reviewed annually to ensure they reflect current legislation and best practice.
• We will use best practice in its safe recruitment of staff by undertaking the appropriate checks.
• We reserve the right to refuse to employ any person who has a conviction for the abuse of a child, young person or a vulnerable adult. BCT  NI C.I.C  staff working with Students will be subject to background checks.
• We must follow criminal disclosure risk assessment procedures, before enrolling any person who has a conviction for the abuse of a child, young person or a vulnerable adult.
• Our staff will listen, record and report all concerns, disclosures and allegations of abuse in accordance with current procedures in an empathic, prompt and secure manner.
• We will NOT investigate instances of abuse as this is the role of other statutory agencies e.g. social services, PSNI and NSPCC.
• We are committed to supporting, resourcing and training those who work with, or come in contact with children, young people and vulnerable adults and to provide appropriate supervision.

The policy will be implemented in the following ways:

• All staff are required to follow the staff code of behaviour for Child and Vulnerable Adult Safeguarding
  • All staff must refer all concerns, allegations or suspicions to a Designated Safeguarding member of staff promptly using the appropriate recording methods
  • Designated Safeguarding members of staff will report these concerns, allegations or suspicions to the Designated Safeguarding Manager
  • The Designated Safeguarding Manager will undertake to contact external agencies when and where appropriate.

5. Responsibilities

All staff

It is the responsibility of all staff working in BCT NI C.I.C  to follow the guidance provided in this policy and related policies and to record and report abuse and incidents of concern. This responsibility extends to all staff, not just those specifically working with children, young people and vulnerable adults.

Therefore, it is the responsibility of all staff to:

• Report an immediate concern about the safety or welfare of a child or young person by contacting the police.
• Report a concern about the safety or welfare of a child or young person in circumstances other than an emergency by completing a safeguarding record form and forwarding It on immediately to the designated safeguarding officer.
• Adopt child protection and vulnerable adult guidelines including the code of behaviour for staff.
• Act upon any concern, no matter how small or trivial it may seem, in accordance with BCT C.I.C NI procedures.
• Promote safe practice and challenge poor and unsafe behaviour.
• Ensure all health and safety procedures are adhered to.

The Designated Senior Manager /lead officer is Chris Bailie. We have appointed a Designation Senior Manager who is assigned to act upon child, young people and vulnerable protection concerns.

This person’s responsibilities are:

• Ensuring that BCT C.I.C NI has procedures and policies which are consistent with the requirements for safeguarding students and reviewed regularly.
• Promoting the welfare of children and vulnerable adults.
• Ensure staff (paid and unpaid) have access to appropriate training/information.
• Advise staff on protection policy, procedures and record keeping.
• Receive information from any staff, volunteers, children, parents or carers who have safeguarding concerns and record it.
• Receive staff concerns about safeguarding and respond to all seriously, swiftly and appropriately.
• Store all information and recording in a secure manner and in accordance with Data Protection Act 1998.
• Keep up to date with local arrangements for safeguarding and DBS.
• Develop and maintain effective links with relevant agencies. To report concerns to PSNI/Social Services in the absence/unavailability of the DSM (or if the allegation is against the DSM) or in the instance of an immediate threat to a person(s) safety or welfare.

6. Confidentiality

Confidentiality and trust should be maintained as far as possible, but staff must act on the basis that the safety and welfare of the child/vulnerable adult is the overriding concern. The degree of confidentiality will be governed by the need to protect the individual and therefore complete confidentiality cannot be guaranteed. In general the following guidelines should be used:

• The individual should be informed at the earliest possible stage of the disclosure that the information may be passed on and where possible their permission to disclose sought.
• All conversation regarding a safeguarding concern should always be held in a person sensitive environment. Staff must not discuss the case with anyone other than those involved in the case.
• If staff have any concerns about the progress of the case or have any other concerns these must be discussed with the DSM dealing with the case.
• In all cases the main restrictions on disclosure of information are:

We comply with the requirements of the Data Protection Act 1998, which allows for disclosure of personal data where this is necessary to protect their vital interests. Other statutory provisions may also be relevant, but in general, legislation does not prevent sharing of information if:

• those likely to be affected consent; or
  • the public interest in safeguarding the person’s welfare overrides the need to keep the information confidential; or
  • it is considered the person is a danger to themselves or others; or
  • disclosure is required under court or other legal obligation

7. Professional boundaries

We expect staff to protect the professional integrity of themselves and the organisation.

The following professional boundaries must be adhered to:

Giving and receiving gifts from clients: BCT C.I.C NI does not allow paid or unpaid staff to give gifts to or receive gifts from clients. However, gifts may be provided by the organisation as part of a planned activity’.

Staff contact with Children and /or Vulnerable adults.

• ‘Personal relationships between a member of staff (paid or unpaid) and a client who is a current service user is prohibited. This includes relationships through social networking site such as Facebook. It is also prohibited to enter into a personal relationship with a person who has been a service user over the past 12 months’.
• Staff should not spend excessive amounts of time alone with children or vulnerable adults.
• Staff should also not take students home or be alone in a car journey no matter how short.

When it is unavoidable that these things do happen, they should only occur with the full knowledge and consent of the Line Manager and the young person’s parent /person with parental responsibility where appropriate.

Staff should never:

• engage in rough physical games including horseplay – apart from structured sports activities

[and only with children and/or vulnerable adults over age 16years].

• engage in sexually provocative games;
• allow or engage in inappropriate touching of any form;
• allow young people to use inappropriate language unchallenged;
• make sexually suggestive comments about or to a young person even in fun;
• let allegations in respect of a young person go unchallenged or unrecorded;
• do things of a personal nature for young people that the young person can do themselves.

It may sometimes be necessary for staff to do things of a personal nature for young people or vulnerable adults, particularly if they have disabilities. If this is the case, these tasks should be clearly described and should only be carried out with the full understanding and written consent of the parent / person with parental responsibility.

In an emergency situation which requires help of a personal nature, parents / those with parental responsibility should be fully informed, as soon as reasonably possible that it was necessary to provide such assistance. In such situations, it is important that all staff are sensitive to the individual and undertake personal care tasks with the utmost discretion. Whenever possible a second member of staff should be informed in advance of, or as soon as practically possible thereafter, of the need to perform an assisting task of a personal nature. A record should be maintained to this effect.

Staff should be particularly careful when supervising students in a residential setting, or in approved out-of-hours activities, where more informal relationships tend to be usual.

Academic staff should avoid teaching materials, the choice of which might be misinterpreted and reflect upon the motives for the choice. If in doubt about the appropriateness of a particular teaching method, the academic should consult with their line manager before using it.

In all circumstances, employees’ professional judgement will be exercised and for most this code of conduct will only serve to confirm what they have always done. However, inappropriate actions in relation to any of the above may lead to staff disciplinary procedures being implemented.

If the professional boundaries and/or policies are breached this could result in disciplinary procedures or enactment of the allegation management procedures.

8. How to Respond to a Disclosure, Suspicion or Allegation

If a young person, or a vulnerable adult, indicates that they have been or are being abused in some way or you are otherwise informed of possible abuse you must:

• React calmly – What you are told may be very shocking but it is important that you do not rush into inappropriate action and give the person some stability;
• Reassure the young person that they are not to blame and that they did the right thing to tell someone about the incident/s,
• Recognise that this may be difficult for the student, therefore you should take the young person seriously and listen carefully to them. 
• Only ask questions which help to clarify the situation. The law is very strict when it suspects a young person has been led or ideas have been suggested;
• Try not to make the young person repeat their account unnecessarily;
• Do not make promises you cannot keep.
• Explain that you may have to tell other people in order to stop what is happening but that you will endeavour to keep the incident as confidential as possible; and
• Make a full record of what has been said, heard or seen as soon as possible.

• Recording Information

Information that is passed on to the Social Services and/or PSNI must be as helpful as possible.

Hence there is a necessity for making as detailed record as possible. Any incidents should be records on an incident form and should include the following information:

• The nature of the incident;
• Dates when the incident was raised with you and steps you have taken.
• A description of any visible injuries / demeanour;
• The young person’s account;
• Times, dates or other relevant information, eg in the case of sexual abuse of young persons, supply details of younger siblings (if known).

1. Reporting

When raising and reporting safeguarding concerns you should:

1. Communicate your concerns with your immediate manager
2. Seek medical attention for the vulnerable person if needed
3. Discuss with parents of child or with vulnerable person. Obtain permission to make referral if safe and appropriate
4. Contact the relevant third-party organisations (PSNI and Social Services) and submit the relevant information.

If the immediate manager is implicated, then refer to their line manager or peer.

We recognise its duty to report concerns or allegations against its staff (paid or unpaid) within the organisation or by a professional from another organisation.

The process for raising and dealing with allegations is as follows:

Step 1 – Any member of staff (paid or unpaid) is required to report any concerns in the first instance to report the concern or allegations to their line manager/ safeguarding manager/ peer. A written record of the concern should be taken by your line manager /safeguarding manager /peer.

Step 2 – contact local authority for advice.

Step 3 – follow the advice provided

1. Monitoring

We will monitor the following Safeguarding aspects:

• Safe recruitment practices
• Security checks undertaken
• References applied for new staff
• Records made and kept of supervision sessions
• Training – register/ record of staff training on child/ vulnerable adult protection
• Monitoring whether concerns are being reported and actioned
• Checking that policies are up to date and relevant
• Reviewing the current reporting procedure in place

1. Communicating and reviewing the policy

BCT C.I.C NI will make the policy available to all clients at the start of their agreement for services and advise them of any updates during their contract.

This policy will be reviewed every annually and when there are changes in legislation.