Safeguarding & Welfare Policy

Introduction

Innate Change enables diversity, inclusion and equity through education, coaching and facilitation. In practice, this means working with individuals, families and organisations across Great Britain, including neurodiverse children and adults. Innate Change is fully committed to safeguarding the wellbeing and protection of all those with whom it works. From hereon, the people with whom we work will be referred to as ‘clients’.

We recognise the responsibility to promote safe practice and to protect people from harm, abuse and exploitation. Everyone, regardless of disability, age, gender, gender reassignment, race, religion or belief, sex and sexual orientation or socio-economic status, has the right to protection from all forms of harm and abuse. This policy sets out how all staff (paid or unpaid) and volunteers should recognise and respond to allegations or concerns of abuse, exploitation or neglect. It will also outline safeguarding procedures that will keep clients safe. Whilst local authorities play a lead role in safeguarding children and adults by protecting them from harm, it is everyone’s responsibility.

Policy Statement

Innate Change will:

• Promote the health and wellbeing of clients by providing opportunities for them to take part in its activities safely.
• Respect and promote the rights, wishes and feelings of clients.
• Provide, promote and implement appropriate procedures to safeguard the wellbeing of clients and protect them from abuse.
• Follow safer recruitment practice when employing staff and volunteers, such as DBS checks, obtaining at least two references and checking gaps in work history for relevant roles.
• Require employees and volunteers to adopt and abide by this Safeguarding and Welfare Policy and all associated procedures.
• Respond to any allegations of misconduct or abuse of clients in line with this Policy and these procedures as well as implementing, where appropriate, the relevant disciplinary and appeals procedures.
• Observe and adhere to relevant legislation guidelines issued by local safeguarding Committees.
• To maintain a robust recording system for any safeguarding concern and the storage of information.
• Regularly monitor and evaluate the implementation of this Policy and all associated procedures.
• Ensure all volunteers, contractors, stakeholders, partners working with or for Innate Change will be required to operate within the ethos and parameters of the safeguarding policy and its procedures.

Definitions and Role Descriptions

Innate Change strives to ensure that clients are protected and kept safe from harm whilst participating in Innate Change activity. We will endeavour to promote high standards of care for all participants. For the purpose of this policy and associated guidelines, the following definitions and role descriptions will apply:

• The Chief Executive Officer acts as the Safeguarding Lead and is responsible for organisational compliance with Safeguarding Policies and Procedures and also ensuring there is promotion of a positive culture of safeguarding across the organisation.
• Member of staff means anyone in the paid employment of Innate Change. This can include coaches, mentors, trainers and administrative staff.
• Board means the whole Board of Directors of Innate Change.
• Client means any Child or Adult who takes part in the activities of Innate Change
  Regulated Activity is broken down into two separate groups ‘Activity with Children’ and ‘Activity with Adults’ (formerly termed Vulnerable Adults).
• Safeguarding means the proactive policies and procedures in place for the benefit of all clients of Innate Change.
• Child Protection is one aspect of the safeguarding umbrella specific to children who are considered to be at risk of, or suffering significant harm.
• Child is someone who is under the of 18 years old.
• Adult at risk is someone who is 18 years old or older, who has care and support needs, is experiencing or at risk of experiencing abuse or neglect and due to their support needs cannot protect themselves from the abuse.

Recognising Abuse

To ensure that all clients are protected from harm, staff and volunteers at Innate Change need to understand what types of behaviour constitute abuse and neglect. Innate Change recognises that abuse can take many different forms and staff and volunteers will receive training and information in regard to safeguarding issues and procedures. Abuse of children and adults at risk can occur in any environment, including the home, at school, in a sports or recreation club, although children and adults at risk are more likely to be abused by people they know and trust. Therefore, it is vital that those who have regular contact with our clients recognise the signs and indicators that they may be being abused and know the appropriate steps to take to report these concerns. Coaches and facilitators may be best placed to help in identifying concerns and/or indicators of possible abuse or neglect at an early stage, and referring those concerns to the CEO and the appropriate statutory organisation, usually the Local Area Designated Officer (LADO).

Abuse can take many forms, as follows:

Sexual Abuse – involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. This can also be non-physical, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline abuse.

Emotional/Psychological Abuse – the persistent emotional maltreatment of a child or adult at risk such as to cause severe and adverse effects on the child’s or adult’s emotional development. It may involve conveying to the child or adult that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person.

Neglect – this is the persistent failure to meet basic physical and/or psychological needs, likely to result in the serious impairment of the child’s or adult’s health or development. Neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect them from physical and emotional harm or danger; ensure adequate supervision, or ensure access to appropriate medical care or treatment.

Physical Abuse – a form of abuse which involves hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child or adult at risk.

Financial or Material Abuse – 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.

Organisational Abuse – not offering flexibility and choice, having poor standards of care, lack of inadequate procedures. Poor record keeping or lack of management overview and support. Insufficient staffing, abusive or disrespectful attitudes towards the child or adult at risk, not offering choice or promoting independence, misuse of medication. Failure to respond to abuse properly.

Self-Neglect – the inability (intentional or non-intentional) to maintain a socially and culturally accepted standard of self-care with the potential for serious consequences to the health and well-being of the individual and potentially to their neighbours and the community.

Discriminatory Abuse – includes any type of abuse aimed at a child or adult at risk because of disability, age, gender reassignment, race, religion or belief, sex, sexual orientation, marriage and civil partnership and pregnancy and maternity. For example, ignoring spiritual or religious beliefs, comments or jokes about a person’s disability, age, race, sexual orientation, or gender/gender identity, ignoring cultural needs, for example diet or clothing.

Modern Slavery – which encompasses: slavery; human trafficking; forced labour; domestic servitude; and where traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.

Domestic Abuse/Domestic Violence – Any incident or pattern of incidents of controlling, coercive or 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. This can encompass but is not limited to the following types of abuse: psychological; physical, sexual, financial and emotional.

Increased vulnerabilities of children

Children can be identified as having increased vulnerability in a variety of settings and under a number of different circumstances, as follows:

• Children with disabilities (seen and hidden).
• Children in a hospital setting, hospice or a children’s home
• Children in families where domestic abuse/violence is present
• Children in families where drug/alcohol use is affecting parenting
• Children in families where parents/guardians/carers have mental health issues learning difficulties/disabilities causing problems coping with parenthood
• Children growing up with parents in prison
• Children in families where the child is a “young carer” for a parent/guardian/carer who is physically/mentally ill or disabled
• Children who are primary carers of younger children
• Looked after children
• Children living in un-registered private fostering arrangements
• Children who are bullied
• Children of young/unsupported parents
• Children living in poverty/poor housing

Online safety

At Innate Change we recognise that:

• The online world provides everyone with many opportunities; however, it can also present risks and challenges.
• We have a duty to ensure that all clients involved in Innate Change online are protected from potential harm.
• We have a responsibility to help keep clients safe online, whether or not they are using our network and devices
• We will work in partnership with clients, their families and other agencies to promote welfare and to support them to be responsible in their approach to online safety.

We will seek to keep clients safe by:

• Providing clear and specific directions to staff and volunteers on how to behave online through our code of conduct.
• Providing support and training for all staff and volunteers on dealing with all forms of abuse, including bullying/cyberbullying, emotional abuse, sexting, sexual abuse and sexual exploitation.
• Supporting and encouraging clients to use the internet, social media and mobile phones in a way that keeps them safe and shows respect for others.
• Developing clear and robust procedures to enable us to respond appropriately to any incidents of inappropriate online behaviour, whether by a client, volunteer or member of staff.

Responding to Concerns

Our procedure for responding to a safeguarding and welfare concern about a client makes sure that everyone is clear on what action to take in the event of a concern being raised. The procedure is based on four steps: Respond, Record, Report, Refer. The following principles underpin the procedure:

• The wellbeing of the client is the paramount consideration.
• Parents/carers have the primary responsibility for the safety and wellbeing of their children and, where possible, Innate Change should work in partnership with parents /carers when there are concerns.
• Clients have the right to say what they think in all matters affecting them and to have their views taken seriously (Making Safeguarding Personal – Care Act 2014). It is important, therefore, to seek the views of the individual, where relevant and appropriate, and to seek their consent for further reporting of the concern.
• Where the concern about an individual’s wellbeing suggests that they are in need of protection, the information must be passed on to police/social care with or without the individual’s consent for the purposes of their protection.

Allegations of abuse must always be taken seriously. No member of Innate Change shall investigate allegations of abuse or decide whether an individual has been abused.

Volunteers and staff may become aware in different ways with regards to details of a concern. This may be:

• A direct disclosure by an individual
• Through observation of an individual, demonstrated by a change in their behaviour, appearance or nature
• Information that is shared from another individual or organisation

RESPOND

When there is an allegation or suspicion of abuse, everyone must be clear about their role. All staff and volunteers (paid or unpaid) need to act impartially, not as “friends” of the client or if applicable, their parents. It is essential that all staff and volunteers follow these procedures.

• Ensure the immediate safety of the client and any others (where appropriate, call 999 for emergency services if there is a medical emergency, other danger to life or risk of imminent injury, or if a crime is in progress).
• React calmly so as not to frighten the individual.
• Consider what requirements an individual may need to communicate effectively (e.g. what support needs do they have, what is the nature of any neurodiversity, do they use sign language, is English their first language etc.)
• Listen to the individual and take what they say seriously. Do not show disbelief. Reassure them that they are not to blame and were right to tell someone.
• Avoid asking any questions. If necessary, only ask enough questions to gain basic information to establish the possibility that abuse may have occurred. Only use open-ended, non-leading questions e.g. Who? What? Where? When?
• It is important to explain to the individual who you may need to share information with and why. Do not promise to keep information a secret.
• Do not introduce personal information from either your own experiences or those of others.
• Pass on the information to the Safeguarding Lead without delay. The Safeguarding Lead will advise on next steps in terms of reporting to the LADO and/or the police.
• Write up your record of the disclosure/concern as soon as possible, including the date and time the matter was raised and any details that were given to you. Make it clear in your records what you have observed or heard yourself and what you have been told by others (hearsay).
• If the person who has been accused is known to you or Innate Change it is not your job to tell them that they have been accused of abuse or neglect. You must avoid “alerting” the person accused.

Any safeguarding concern about a client should be considered in line with the relevant wellbeing indicators and the Safeguarding Lead may discuss the matter with parents/carers as long as doing so does not put the client at further risk of harm. Common sense is advised in these situations and the best interests of the individual will be considered as to what is the best support for each individual. Clients will be asked who they feel is suitable to be informed and where relevant and possible, consent should be gained.

Innate Change does not undertake Child protection investigations (Section 47 Children Act 1989) or section 42 Inquiries (Care Act 2014) – Statutory agencies (police, social care, and the NSPCC) undertake this role. Therefore, you must NOT investigate an allegation of abuse.

RECORD

Make a written record of the information as soon as possible using the Safeguarding and Welfare Incident Report Form, completing as much of the form as possible. Records made must:

• Be factual – only record what you have been told or have observed. Do not record how you feel or what you think might have happened.
• Be clear – the report could be used in further investigations, so it needs to be clear and easy to understand.
• Detailed – include as much detail as you can remember from the disclosure including details about the alleged perpetrator, the client’s presentation, were they crying, withdrawn, shaking etc. Also include things like location, context (build up), any potential witnesses to the alleged abuse.
• If someone has been hurt in the incident, include a description of any physical marks (including the site) or any visible bruising or injuries – use the forms body map to record this. DO NOT remove any clothing or take any photos.
• Include any actions taken by yourself and/or others – e.g. were emergency services called, who have you informed.

REPORT

• Inform the Safeguarding Lead as quickly as possible. This should not be delayed by gathering information to complete all sections of the form. The information in the form will help the Safeguarding Lead decide what action to take next.
• If the Safeguarding Lead is not available and you believe that the client is in immediate danger, you are responsible for reporting the concern to the LADO. You should speak to Julia Gaskell julia@innatechange.co.uk for support and advice on this decision.

Sharing Concerns with Parents/Carers Where there are concerns that the parents/carers may be responsible for, or have knowledge of, the abuse, sharing concerns with the parents/carers may place the individual at further risk. In such cases advice must always firstly be sought from the LADO, Safeguarding Lead or police as to when and who should inform the parents/carers.

REFER

If abuse has taken place or there is a suspicion of abuse, then this must be referred to the appropriate local authority services, see below on how to find your local service:

England and Wales

Children: https://www.gov.uk/report-child-abuse-to-local-council

Adults: https://www.gov.uk/report-abuse-of-older-person

Scotland

Children: https://www.mygov.scot/report-child-abuse/

Adults: http://www.actagainstharm.org/getting-help/find-your-local-contact

Staff and Volunteers should ordinarily follow the reporting procedures outlined in this policy. However, any staff member can refer their concerns directly to Children’s/Adults Social Care and/or the Police if:

• the situation is an emergency and the Safeguarding Lead is unavailable;
• they are convinced that a direct report is the only way to ensure the client’s safety; or
• for any other reason they make a judgement that a direct referral is in the best interests of the client.

Allegations against staff/volunteers

When an allegation is made against a member of staff or volunteer, they have the right to have their case dealt with fairly, quickly and consistently and to be kept informed of its progress. Where a member of staff or volunteer feels that there are poor or unsafe practices and potential failures then they should raise them with the Board of Directors. Any member of staff or volunteer who receives an allegation about another member of staff or volunteer from a client will follow the guidelines for dealing with disclosure.

All allegations against a staff member or volunteer will be assessed by the Safeguarding Lead or Board of Directors if the Safeguarding Lead is the subject of the allegation. In order to assess the allegations against a member of staff, it will be judged against the relevant criteria highlighted below. This applies to all cases in which it is alleged that an individual who works or volunteers with clients has:

• Behaved in a way that has harmed a client or may have harmed a client;
• Possibly committed a criminal offence against or related to a client; or
• Behaved towards a client in a way that indicates they may pose a risk.

England and Wales

The Safeguarding Lead or Board of Directors will inform the Local Authority Designated Officer (LADO) within 1 working day of receiving the allegation about a staff member or volunteer if the case meets the relevant criteria. Where the cases may not appear to meet the relevant criteria fully but still gives rise to concerns about the risk an individual poses to clients through their work, the Safeguarding Lead or Board of Directors will seek advice from the (LADO) for the most appropriate course of action.

Suspension of a member of staff or volunteer is a neutral act and is not the default option; alternatives to suspension will always be considered. Where relevant conditions are met a referral may also be made to the Disclosure and Barring Service (DBS).

Relevant criteria in relation to conduct towards children:

• endangers a child or is likely to endanger a child.
• if repeated against or in relation to a child would endanger the child or be likely to endanger the child.
• involves sexual material relating to children (including possession of such material).
• involves sexually explicit images depicting violence against human beings (including possession of such images).
• is of a sexual nature involving a child.

A person’s conduct endangers a child if they:

• harm a child
• cause a child to be harmed
• put a child at risk of harm
• attempt to harm a child
• incite another to harm a child

Relevant criteria in relation to conduct towards adults:

• endangers an adult at risk or is likely to endanger an adult.
• involves sexual material relating to children (including possession of such material).
• involves sexually explicit images depicting violence against human beings (including possession of such images).
• is of a sexual nature involving an adult.

A person’s conduct endangers an adult if they:

• harm an adult.
• cause an adult to be harmed.
• put an adult at risk of harm.
• attempt to harm an adult.
• incite another to harm an adult. 

Scotland

Referrals to the Children’s List or the Protected Adults List

Where Innate Change takes disciplinary action to remove a member of staff/volunteer from regulated work as a result of harmful behaviour towards a client, then they have a duty to refer the member of staff/volunteer to Volunteer Scotland so that consideration can be given to whether that individual should be barred from any kind of regulated work with children and/or protected adults. The Protection of Vulnerable Groups (Scotland) Act 2007 stipulates that organisations must refer to Volunteer Scotland the case of any member of staff/volunteer who (in the course of their role within the organisation) has:

• Harmed a child or protected adult;
• Placed a child or protected adult at risk of harm;
• Engaged in inappropriate conduct involving pornography;
• Engaged in inappropriate conduct of a sexual nature involving a child or protected adult;
• Given inappropriate medical treatment to a child or protected adult;

AND as a result:

• Innate Change has dismissed the member of staff/volunteer;
• The member of staff/volunteer would have been dismissed as a result of the incident had they not resigned, retired or been made redundant;
• Innate Change has transferred the member of staff/volunteer to a position in Innate Change which is NOT regulated work with children or protected adults;
• The member of staff/volunteer would have been dismissed or considered for dismissal where employment or volunteer role was not due to end at the expiry of a fixed term contract; or
• The member of staff would have been dismissed or considered for dismissal had the contract not expired.

Innate Change will also refer the case of a member of staff/volunteer where information becomes available after the member of staff/volunteer has:

• Been dismissed by Innate Change;
• Resigned, retired or been made redundant;
• Been transferred to another position in Innate Change which is not regulated work with children or protected adults; and
• Where Innate Change receives information that a member of staff/volunteer who holds a position of regulated work has been listed on the Children’s List or the Protected Adult list, the member of staff/volunteer will be removed from the regulated work with children or protected adults post.

In some cases, however, a member of staff may be suspended where this is deemed to be the best way to ensure that allegations are investigated fairly, quickly and consistently and that all parties are protected. In the event of suspension, Innate Change will provide support and a named contact for the member of staff or volunteer.

Organisational Reporting and Accountability

All safeguarding reports whether externally referred or not must be shared with the Safeguarding Lead within 24 hours of being completed. The data in these reports will be analysed and used to drive improvement in good practice throughout the organisation. They will inform training needs, resources and updates to procedures. An annual safeguarding report highlighting the types of abuse reported, actions taken, training provided and recommendations for improvement across the organisation will be created and presented to the Board of Directors by the Safeguarding Lead. These reports will also look at safeguarding policies, procedures and practices and will review these to ensure that is our safeguarding framework is effective and robust in protecting everyone at Innate Change.

Communication and Security of Documents

No document, once completed, which contains the personal information of an individual (e.g. significant incident form, self-declaration form) will be transmitted by email except where such file is either password protected and/or encrypted. Where password protection is enabled, such password must be sent to recipients of these documents by separate email or other electronic means. Where information is kept as a computer record, the information will be kept on an encrypted memory stick or on properly secured cloud storage (SharePoint) and only accessed by those authorised to see it in the course of their duties. Any printed document, once completed, relating to safeguarding will be kept in a secure place and treated as confidential.

Information Sharing

Staff and volunteers must be informed about how their personal information will be used. For the purposes of Safeguarding and Welfare matters Innate Change may share information about an individual where they have been alerted to circumstances that might affect their suitability to carry out the regulated work role for which they have applied/been appointed or already doing. Additionally, Innate Change may be required to share information with other statutory or regulatory authorities where an individual member is believed to be under criminal investigation for matters pertaining to Safeguarding and Welfare. Such organisations include the Health & Safety Executive, Disclosure and Barring Service, Disclosure Scotland and the Police for the purposes of safeguarding children and adults at risk and reporting on any accidents or incidents leading to serious injury or death.

Recording Form for Safeguarding Concerns

Staff, volunteers and regular visitors are required to complete this form and pass it to the Safeguarding Lead if they have a safeguarding concern about a client at risk.

Download the form here