1. Policy Statement
The Greater Manchester Trust for Recreation known as Greater Manchester Youth Federation (“GMYF ”) is a registered charity in England and Wales number 521234. We are a charitable trust. GMYF works with children and young adults as part of its activities. Our mission statement is:
“Our aim is to deliver a year-round programme of recreational and educational opportunities to young people, volunteers and leaders within our affiliated clubs that encourages them to reach their full potential.”
This policy applies to anyone working on behalf of GMYF, whether paid or unpaid, including its trustees, staff and volunteers. It will be widely promoted and is mandatory for everyone involved in GMYF. Failure to comply with it will be addressed without delay and may ultimately result in dismissal/exclusion from the organisation.
1.1 The purpose of this policy is to:
- protect children and young people who take part in our activities
- make available to GMYF staff and volunteers, affiliated clubs and parents/carers the principles that guide our approach to safeguarding
We believe that children and young people should never experience abuse of any kind. We have a responsibility to promote the welfare of all children and young people, to keep them safe and to carry out our activities in a way that protects them.
1.2 We recognise that:
- the welfare of the child is paramount
- regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation all children have a right to equal protection from all types of harm or abuse whilst participating in our activities or outside of them
- some children, including disabled children and young people or those from ethnic minority backgrounds, can be particularly vulnerable to abuse and we accept the responsibility to take reasonable and appropriate steps to ensure their welfare
- working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare
1.3 We will seek to keep children and young people safe by:
- valuing, listening to and respecting them
- appointing a nominated safeguarding lead, a deputy safeguarding lead and a lead trustee for safeguarding
- ensuring everyone in the organisation understands their roles and responsibilities in respect of safeguarding and is provided with appropriate learning opportunities to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children and young people
- ensuring robust child protection and safeguarding policies and procedures are in operation
- using our safeguarding procedures to share concerns and relevant information with agencies who need to know, and involving children, young people, parents and carers appropriately
- using our procedures to manage any allegations against staff and volunteers appropriately
- recruiting staff and volunteers safely, ensuring all necessary checks are made
- implementing a code of conduct for staff and volunteers
- ensuring that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored
1.4 Related policies and procedures
This policy should be read alongside GMYF’s policies and procedures including:
Safer recruitment procedure
Safeguarding Information Sharing Guidance
Safer Activities Procedure
Anti-bullying Policy Statement
Online safety Policy Statement
Child protection records retention and storage policy Whistleblowing policy
1.5 Legislation and Government Guidance
There is a considerable body of legislation designed to ensure that children and young people are protected. The main acts include:
- Legislative Framework and Rationale Section 21 of the Counter-Terrorism and Security Act 2015
- Children Act 1989
- Working Together to Safeguard Children 2013
- Framework for the Assessment of Children in Need and their Families
- The Children (Protection from Offenders) (Miscellaneous Amendments) Regulations 1997
- The United Nations Convention on the Rights of the Child
- Rehabilitation of Offenders Act 1974
- The Legal Aid, Sentencing and Punishment of Offenders Act 2012
- Health and Safety at Work Act 1974
- Youth Justice and Criminal Evidence Act 1999
- Safeguarding Vulnerable Groups Act 2006
- The Sexual Offences (Amendments) Act 2000
- Children and Young Persons Act 2008
Other factors guiding the policy include:
- NSPCC guidance, particularly ‘Safe sport events, activities and competitions’
- Safe Network guidelines
- The Charity Commission guidelines
- The National College for Teaching and Leadership Safer Recruitment Guidelines
2. Designated Safeguarding Lead
The role of the DSL is to take the lead in ensuring that appropriate arrangements for keeping children and young people safe are in place and to promote the safety and welfare of children and young people involved in GMYF’s activities at all times.
Overall responsibility for safeguarding within the organisation lies with Karen Wilson. In their absence, Lisa Hall will fulfil the duties of the role. The Trustee with responsibility for safeguarding is Gavin Evans.
The role of the Designated Safeguarding Person includes:
- Ensuring that all staff are aware of what they should do and who they should go to if they have a concern about the safety and welfare of a child.
- Ensuring that any concerns are acted on, clearly recorded, referred on where necessary and, followed up to ensure the issues are addressed.
- Recording any reported incidents, concerns or breaches of Safeguarding policies and procedures. This will be kept in a secure place and its contents will be confidential.
Designated Safeguarding Lead
A full description of the role of the Designated Safeguarding Lead is available.
3. Definition of a Child
A child is anyone who has not yet reached their 18th birthday. The fact that a child has reached 16 years of age, is living independently or is in further education, is a member of the armed forces, is in hospital or in custody does not change their status as a child or entitlement to protection. In this procedure ‘children’ therefore means ‘children and young people’ throughout. If a concern arises about someone who is aged 18 or older it should be reported as per the procedures below, the DSL will act accordingly
4. Code of Conduct and Good Practice
4.1 The role of staff and volunteers
For the purposes of this policy the term ‘staff’ is used to encompass any adult working for or on behalf of GMYF be they paid staff, volunteers, trustees or other. When working with or for children staff are acting in a position of trust, are likely to be seen as a role model and must act appropriately. All staff should promote relationships that are based on openness, honesty, trust and respect.
4.2 Staff and volunteers are responsible for:
- prioritising the welfare of children above all else including winning and or achieving goals
- providing a safe environment for children which includes ensuring equipment and venue is used safely and for its intended purpose
- reading and following the safeguarding policies and procedures and undertaking safeguarding training
- modelling good behaviour
- challenging unacceptable behaviour and reporting any concerns about the behaviour of staff
- reporting all safeguarding concerns following the reporting procedures. This includes abusive behaviour being directed by an adult or child and directed at anybody of any age.
Children are individuals, within individual needs and rights. All staff should treat children fairly, with respect and without prejudice or discrimination regardless of gender, sexual orientation, culture, race, ethnicity, disability and religious beliefs. Everyone should be encouraged to speak out about attitudes or behaviour that makes them uncomfortable. Everyone should be listened to, and their contributions valued.
4.3 Promoting good practice means:
- avoiding favouritism
- being patient with others
- ensuring contact with children is appropriate and relevant to the project
- working in an open environment and avoiding unobserved or private situations with only one adult present
- personal care only being provided by staff for whom it is a part of their role and have received appropriate training.
All staff should respect others’ rights to privacy and their personal details etc. should not be shared. Should a safeguarding concern arise, the reporting of that concern overrides any concerns about breaking confidentiality and if appropriate and possible that should be explained to those concerned.
4.4 Unacceptable Behaviour
When working with children staff must not:
- allow concerns or allegations to go unreported
- take unnecessary risks
- smoke, consume alcohol or use illegal substances develop inappropriate relationships with children
- engage in behaviour that is in any way abusive which includes having any form of sexual contact with a child
- let children have your personal contact details (mobile number, email address) or have contact with them via a personal social media account
- act in a way that can be perceived as threatening or intrusive
- patronise or belittle anyone else.
5. Safeguarding Procedures
The purpose of the following is to offer guidance to staff on how to keep children safe and what to do should a safeguarding concern arise. Alongside these procedures GMYF encourages all staff to trust their instincts and contact the DSL should they have any concerns, questions or queries relating to safeguarding.
Disclosure is the process by which children and young people share their experiences with others. This can be a full description of abuse or just a small part of the picture, it can happen all at once or over a long period of time. Disclosures can be about recent events or something that happened many years ago. Regardless, all disclosures should be taken seriously. Further information on disclosure is available on the NSPCC web site.
It is important that staff create an environment where everyone feels comfortable speaking out if anything is worrying or concerning them. Staff and volunteers to whom a child chooses to make a disclosure need to listen and respond appropriately so the child gets the help, support and protection they need.
Children and young people may disclose abuse in a variety of ways including:
- directly – making specific verbal statements about what’s happened to them.
- indirectly – making ambiguous verbal statements which suggest something is wrong
- behaviourally – displaying behaviour that signals something is wrong (this may or may not be deliberate)
- non-verbally – writing letters, drawing pictures or trying to communicate in other ways.
When a disclosure is made:
- listen carefully to the child, give them your full attention and state that you will take them seriously
- keep your body language open and encouraging
- be compassionate and re-assuring, let them know they are doing the right thing and that what has happened to them is not their fault
- do not to show shock or judgement
- respect pauses and do not interrupt – let them go at their own pace
- NEVER confront the alleged abuser, doing so could make the situation a lot worse
- do not promise a child that you will keep the things they are telling you a secret – instead explain that
- you will not share it with lots of people, only those who will be able to help
- do not press a child for information, ask leading questions or cross-examine the child
If possible, make notes when talking to the child (including their exact words) which you should write up as soon as possible using the GMYF incident reporting form (see Appendix). The original notes along with the completed form should be given to the DSL as soon as possible.
When recording information you should be as factual as possible. If you need to give an opinion, make sure that it is clearly differentiated from fact and identify whose opinion is being given. Should further conversations occur, the same procedures should be followed.
5.3 Signs of abuse
Many of the signs that a child is being abused are the same regardless of the type of abuse and staff need to be able to spot the signs that a child might be at risk of harm. Waiting for a child to disclose their experiences could mean that abuse carries on and that they, or others, are put at risk of further physical or mental harm. Information on the different types of abuse can be found on the NSPCC website however staff are encouraged to trust their instincts and to report concerns regardless of the type of abuse that might be indicated.
Behaviours that may be a cause for concern include a child:
- being afraid of particular places or making excuses to avoid particular people
- knowing about or being involved in ‘adult issues’ which are inappropriate for their age or stage of development, for example alcohol, drugs and/or sexual behaviour 7
- having angry outbursts or behaving aggressively towards others
- becoming withdrawn or appearing anxious, clingy or depressed
- self-harming or having thoughts about suicide
- showing changes in eating habits or developing eating disorders
- regularly experiencing nightmares or sleep problems
- regularly wetting the bed or soiling their clothes
- running away or regularly going missing from home or care
- not receiving adequate medical attention after injuries.
It is important to note that this list is not exhaustive but also that these signs do not necessarily mean a child is being abused. There may well be other reasons for changes in a child’s behaviour however if you have any concerns about a child’s wellbeing, they should be reported.
5.4 Other concerns
Any concerns about the behaviour of a staff member, either by commission or omission, that has or has potential to put a child at risk of harm should be reported to the DSL immediately. The Incident Report Form is to be completed. If the person who is the subject of the concern is the DSL, the matter should be reported to the trustee responsible for safeguarding.
If it is inappropriate to report an incident within GMYF it can be reported to the police or the local child protection services.
If a child is in immediate danger the police should be called.
All information regarding any allegations made against staff will be taken seriously and treated confidentially in line with the relevant safeguarding, health and safety and HR policies.
All safeguarding concerns and incidents should be reported to the DSL as a matter of urgency, the DSL may ask for an incident reporting form to be completed which should be done as soon as possible. Should the DSL or their deputy not be available and the concern is pressing, the relevant local authority safeguarding team should be contacted (see Appendix). Should a child be at immediate risk of harm staff should dial 999.
5.6 Confidentiality and information sharing
Every effort should be made to ensure that confidentiality is maintained for all concerned when discussing or reporting safeguarding concerns. Information should be handled and disseminated on a strict ‘need to know’ basis. However, concerns about privacy or data protection should not prevent staff from raising concerns with the DSL or contacting the relevant agency / police if an immediate risk of harm is apparent.
“Where there are concerns about the safety of a child, the sharing of information in a timely and effective manner between organisations can improve decision-making so that actions taken are in the best interests of the child. The GDPR and Data Protection Act 2018 place duties on organisations and individuals to process personal information fairly and lawfully; they are not a barrier to sharing information, where the failure to do so would cause the safety or well-being of a child to be compromised. Similarly, human rights concerns, such as respecting the right to a private and family life would not prevent sharing where there are real safeguarding concerns.” (Information Sharing advice from HM Government, 2018)
Decisions about information sharing outside of the organisation will be taken by the DSL in consultation with other safeguarding specialists within the organisation and the NSPCC helpline if necessary and in line with the Information Sharing Policy and Procedures.
6. Photography and Filming
Children will be kept safe by:
- asking for written consent from a child and a parent/carer before taking and using images of an individual child or of smaller groups in which their child would easily be recognisable
- on occasion we may wish to take wide-angle, more general images (photographs and video) of an event or competition, the site and opening or closing ceremonies for use on our web site, in social media and in printed promotional material to report on the event/competition and to publicise our activities. These more general images will be taken and used even if consent has not been given. General images used will not include any identifying features (e.g., Faces) of the children.
- changing the names of children whose images are being used in our published material whenever possible (and only using first names if we do need to identify them)
- never publishing personal information about individual children
- making sure children and their parent/carer understand how images of children will be securely stored and for how long (including how we will control access to the images and their associated information)
The risk of images being copied and used inappropriately will be reduced by:
- only using images of children in appropriate clothing (including safety wear if necessary)
- avoiding full face and body shots of children taking part in activities such as swimming where there may be a heightened risk of images being misused
- using images that positively reflect young people’s involvement in the activity.
Should the abuse or misuse of images of children come to light, it should be reported to the DSL immediately.
6.2 Photography and/or filming for personal use
When children themselves, parents/carers or spectators are taking photographs or filming at our events and the images are for personal use, guidance about image sharing will be published in the event programmes and/or announce details of our photography policy before the start of the event.
- reminding parents/carers and children that they need to give consent for GMYF to take and use images of children
- asking people to gain permission from children and their parents/carers before sharing photographs and videos that include them
- informing parents/carers and children of areas where photography is not permitted for example toilets, changing rooms and first aid areas
- recommending that people check the privacy settings of their social media to understand who else will be able to view any images they share
- reminding children, parents and carers who they can talk to if they have any concerns about images being shared.
6.3 Photography and/or filming for GMYF’s use
We recognise that organisations may use photography and/or filming as an aid in activities. Children and their parents/carers must be made aware that this is part of the programme and give written consent, if consent is not given this must be respected – see below.
If a photographer is hired for an event, children will be kept safe by:
- providing the photographer with a clear brief about appropriate content and behaviour and detailing the areas where all photography is prohibited (for example toilets, changing rooms, first aid areas)
- ensuring the photographer wears identification at all times
- informing children and parents/carers that a photographer will be at the event and ensuring they give written consent to images which feature their child being taken and shared
- informing the photographer about how to identify and avoid taking images without the required
- parental consent for photography
- not allowing the photographer to have unsupervised access to children
- not allowing the photographer to carry out sessions outside the event or at a child’s home reporting concerns regarding inappropriate or intrusive photography to the DSL.
6.4 Photography and/or filming for wider use
If people such as local journalists, professional photographers (not hired by GMYF) or students wish to record one of our events and share the images professionally or in the wider world, permission should be sought advance.
The photographer should provide:
- the name and address of the person using the camera
- the names of children they wish to take images of (if possible)
- the reason for taking the images and/or what the images will be used for
- a signed declaration that the information provided is valid and that the images will only be used for the reasons given.
GMYF will verify these details and decide whether to grant permission for photographs/films to be taken. Appropriate consents will be sought, and the photographer will be informed of anyone who has not given consent.
At the event, children and parents/carers will be informed that an external photographer is present. The photographer must be easily identifiable, for example by issuing them with a coloured identification badge.
If GMYF is concerned that someone unknown to the organisation is using sessions for photography or filming purposes, that person will be asked to leave and (depending on the nature of the concerns) reported to the DSL.
6.5 If consent to take photographs is not given
If children and/or parents/carers do not consent to photographs being taken, their wishes must be respected. It should be agreed in advance how they would like to be identified so any photographer knows not to take pictures of them and ensure this is done in a way that does not single out the child or make them feel isolated. A child should never be excluded from an activity because of a lack of consent to take their photograph.
6.6 Storing images
Photographs and videos of children will be stored securely, in accordance with the relevant policies and data protection law. Hard copies of images will be kept in a locked drawer and electronic images in a protected folder with restricted access. Images will be stored for a period of 3 years.
Images of children should never be stored on unencrypted portable equipment such as laptops, memory sticks and mobile phones. GMYF does not permit staff to use any personal equipment to take photos and recordings of children. Only cameras or devices belonging to GMYF should be used.