Safeguarding Policy

Last updated: 13/08/2020

Safeguarding Children and Vulnerable Adults Policy Statement


1. The Policy

Construction Youth Trust (CYT) enables young people across England and Wales to access career opportunities in the construction industry, with a priority focus on young people facing significant barriers to employment. CYT raises awareness of construction careers among young people, provides basic construction training, connects young people with employers and offers one-to-one support to help them progress on the pathway into sustainable work or training including apprenticeships.
CYT is committed to safeguarding and promoting the welfare of children and vulnerable adults and to ensuring action is taken to support them if they are at risk of harm. CYT requires all staff, trustees, volunteers and those contracted to provide services to share this commitment.
CYT believes all children and vulnerable adults should have the same protection regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity. We are committed to anti-discriminatory practice and recognise the additional needs of children and vulnerable adults from minority ethnic groups and disabled children and the barriers they may face, especially around communication.
This policy should be read in conjunction with other supporting procedures and policies, including:
• E Safety
• Data Protection
• Volunteering
• Whistleblowing
• Bullying and Harassment

1.1 Purpose
The purpose of this policy is to:
• Provide a framework for the protection of children, young people and vulnerable adults with whom, or on behalf of whom, CYT works;
• Provide all staff, trustees and volunteers with guidance on how to respond to concerns they may have;
• Provide all staff, trustees and volunteers with guidance on how to report concerns;
• Ensure compatibility with other CYT polices which contribute to the overall safety of children and vulnerable adults
All staff and trustees receive a copy of this policy.

NB: CYT staff have no powers to investigate the external safeguarding issues of children or vulnerable adults, and it is not the responsibility of CYT to decide whether or not that there is an issue. It is, however, the responsibility of staff at CYT to act if there is cause for concern, in order that the appropriate agencies can investigate and take any action necessary to protect a child, young person or vulnerable young adult.

1.2 Policy Application
This policy applies to all employees, trustees, seconded staff, volunteers, students, freelance workers and suppliers of services working on behalf of CYT. For the purposes of this policy, the term ‘staff’ includes all those listed above.
CYT operates organisation-wide procedures including safeguarding protocols included in Appendix 3. Specific responsibilities for safeguarding will be clearly defined in job/role descriptions and person specifications.
 
1.3 Values
CYT believes that:
• All children, young people and vulnerable adults have the right to be protected, and should be listened to and have their views taken seriously.
• It has a duty of care to children, young people and vulnerable adults that it comes into contact with in the course of its business.
• It is always unacceptable for a child, young person or vulnerable adult to experience abuse of any kind.
• Staff should act immediately if they believe a child, young person or vulnerable adult is at risk of harm.
• Staff need to be aware of how issues of race, gender, disability, religion or belief, culture, sexuality and age impact on their understanding of and response to keeping children, young people and vulnerable adults safe.
• Joint working between agencies is essential for the protection of children, young people and vulnerable adults.
CYT is committed to:
• Supporting students to be confident and have good self-esteem.
• Listening and responding to students and valuing all forms of communication.
• Operating effective systems to enable students to communicate that they feel safe or unsafe.
• Ensuring its staff are aware of the possibility of a safeguarding issue and are supported to know how to address this.
• Having clear procedures for reporting and responding to allegations and concerns about a student’s safety.
• Working co-operatively with other agencies.
• Operating a Safeguarding Team to ensure decisions concerning complicated and sensitive issues are arrived at through informed discussion, whilst respecting confidentiality.
• Carrying out enhanced Disclosure and Barring Service (DBS) checks for all employees, freelancer staff and formal volunteers where they are likely to come in contact with children, young people and/or vulnerable adults and maintaining an internal DBS Single Central Record. An enhanced DBS check will only be required for one-off session volunteers (as defined below) if they have contact with young people at the same establishment for more 3 days within a 30 day period.
• Ensuring any safeguarding information that comes to light regarding students is incorporated into student information accessible only to staff who are supporting the student, whilst still ensuring confidentiality where applicable.
• Operating an E-Safety Policy

1.4 Definitions
Children & Young People
The Children’s Act, 1989 defines a child or young person as being up to the age of 18 years old. Extensions of this exist for children who have special needs and for those in local authority care settings. In legislation and for the purposes of this policy the term ‘child’ shall be used.
Vulnerable Adults
A vulnerable adult is a person who is 18 years of age or over, and who is, or may be, in need of community care services by reason of mental or physical disability, age or illness, including mental illness, and who is or may be unable to take care of him/herself, or unable to protect him/herself against significant harm or serious exploitation. This includes those with mental illness.
The Care Act 2014 provided a legal footing for adult safeguarding: it sets out a clear legal framework for how local authorities and other parts of the system should protect adults at risk of abuse or neglect. This is in addition to the Mental Capacity Act 2005 and Human Rights Act 1998.
Freelancer
CYT may at times employ an individual (whether as a sole trader or through their own company) to deliver CYT designed sessions or programmes. These individuals are defined as freelancers.
One-off Session Volunteers
Construction Youth Trust receives the support of a large number of organisations and companies who donate the time of their employees to assist in the delivery of ‘one-off’ sessions or projects to students.
One-off session volunteers will never be left alone with a child or group of children. One-off Session Volunteers will receive a briefing on child protection and safeguarding issues before sessions.
Third Party Providers
CYT may at times utilise the services of a third party business to use their employees to undertake sessions or programmes on behalf of CYT. There is no direct employment between CYT and the person who undertakes the delivery. Activities undertaken may have been designed by CYT or by the provider.
Trustee
A member of CYT’s Board of Trustees.
Formal Volunteers
When an individual, other than a trustee, is providing regular time and expertise to CYT which is over and above that of session volunteers they are considered to be a Formal Volunteer.

1.5 Legislation and Guidance
Over the last 10 years there has been a wealth of legislation and guidance relating to the protection of children, young people and vulnerable adults. CYT’s safeguarding policy is informed by the following published guidance documents:
• The Children’s Act 2004 places a duty on a range of organisations and individuals to have in place arrangements that safeguard and promote the Welfare of children.
• ‘Working Together to Safeguard Children – a guide to inter-agency working to safeguard and promote the welfare of children (2018)’ sets out the arrangements organisations should have in place to safeguard children
• Charities who operate within certain regulated sectors, are subject to guidance specific to them, such as Keeping Children Safe in Education (2016). CYT is not regulated like a college or school but could be if funded by Government.
• The Care Act 2014 sets out a legal framework for how local authorities and other parts of the system (includes voluntary sector) should protect adults at risk of abuse or neglect
• The Charity Commission has a regulatory role focused on the conduct of trustees. The Charity Commission has published its own guidance, which fall into two parts. First, a policy paper titled ‘Safeguarding Children and Young People (2014)’; and secondly a strategy document called ‘Strategy for Dealing with Safeguarding Vulnerable Groups including Children issues in Charities’ (2013).

1.6 Types of Abuse and Recognition
Abuse can take a number of forms:
Physical: causing physical harm to a child by hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or some other method. Physical harm can also be caused when a parent or carer fabricates the symptoms of or deliberately induces illness in a child.
Sexual: forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. Sexual abuse includes both physical contact and non-contact activities.
Emotional: the persistent emotional maltreatment of a child in a way likely to cause severe and persistent negative effects on the child's emotional development.
Neglect: the persistent failure to meet a child's basic physical and/or psychological needs, likely to result in the serious impairment of the child's health and/or development.
Staff may become aware of abuse in a number of ways:
• Disclosure by a child or vulnerable adult
• Disclosure or remarks made by another party (e.g. carer, other professional or member of the public)
• Discovery of bruising or marks on a student’s body
• Unexplained changes in behaviour or personality
• Evidence of disturbance or explicit detail in drawing, writing or play
• Evidence of neglect in terms of cleanliness, personal hygiene, failure to thrive or apparent exposure to unnecessary risks
• Persistent lateness, poor or irregular attendance or persistent absence from their training venue.
More information on different types of abuse can be found in Appendices 1 and 2.

1.7 Prevent Duty
The Trust recognises its public duty, as an organisation that works with young people, to have due regard for the need to prevent young people from being drawn into terrorism. This is to include both violent terrorism, as well as non-violent extremism which can create environments conducive to terrorism. Extremism is defined in the Prevent Strategy as ‘vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs’.
Staff are made aware what radicalisation means and why people may be vulnerable to being drawn into terrorism as a consequence of it. They understand the risk and signs of radicalisation. Any concern that a young person may be at-risk of radicalisation or being drawn into terrorism will be dealt under our safeguarding reporting procedure.
The Designated Safeguarding Lead and Deputy will be responsible for ensuring that staff members are aware of the Prevent duty and the steps to take if there is any concern for a young person. All staff and trustees are trained on their Prevent duty in their regular safeguarding training.

2. Roles and Responsibilities for Safeguarding Children and Vulnerable Adults
Safeguarding is everyone’s responsibility. CYT has a number of designated roles with safeguarding responsibilities. These are outlined below:

2.1 The Board of Trustees
The Board ensure that CYT
• Has a safeguarding policy and procedures in place that are consistent with any statutory requirements and guidance, reviewed and updated annually.
• Appoints the Designated Safeguarding Lead (DSL), Deputy Designated Safeguarding Lead and Trustee Safeguarding Lead.
• Ensures all staff, trustees and volunteers receive appropriate safeguarding training when recruited, refresher training annually and receive information on CYT’s safeguarding arrangements during their induction to the organisation
• Has procedures in place for dealing with allegations of abuse against children, young people or vulnerable adults whilst in the care of CYT.
• Follows recruitment procedures that include checks on staff, trustees and volunteers’ suitability to work with children, young people and vulnerable adults.
• Includes Safeguarding as an essential item on the organisation’s risk register.
• Trustees receive quarterly safeguarding monitoring reports from the DSL, taking action where appropriate.
CYT’s Trustee Lead Designated Person is: Russell Taylor

2.2 The Safeguarding Team
The Safeguarding Team is responsible for:
• Undertaking a regular meeting to discuss safeguarding, at least twice yearly or convened at any time when a potential risk has been identified or significant incident reported.
• Completing an annual review of the safeguarding policy and supporting procedures.
• Preparing and monitoring any Action Plan, monitoring and reporting progress against the implementation of actions.
• Providing advice and make recommendations to the CEO and trustees on the safeguarding of students across the organisation
• Coordinating safeguarding arrangements and providing support to staff on all matters to do with the application of the policy.
The Safeguarding Team is made up of the following members:
John Abbott, Trustee
Russell Taylor, Trustee
Carol Lynch, CEO
Pearl O’Keeffe, Senior Programme Manager
Emily Barnes, Schools & Programme Coordinator

2.3 Designated Safeguarding Lead (DSL)
The Designated Safeguarding Lead is responsible for:
• Ensuring all staff are aware of this policy and related documentation.
• Supporting staff involved in reporting incidents.
• Ensuring the Safeguarding Team are fully involved and supported in safeguarding decisions made.
• Ensuring all staff receive regular updates and information on all relevant safeguarding matters.
• Preparing timely safeguarding reports for the CEO and trustees, as and when required.
• Discussing safeguarding concerns and supporting colleagues to arrive at effective responses within the confidentiality of the Safeguarding Team.
• Liaising with the local authorities, local social services, police authorities and other agencies on individual cases of suspected or identified child abuse.
• Acting as the contact person/s within the organisation (this may be delegated to other members of the Safeguarding Team with the approval and supervision of the DSL).
• Liaising with staff on a 'need to know basis' so that children and vulnerable adults rights to confidentiality are ensured.
• Supporting the planning of any curricular or other learner provision.
• Representing the Trust at child protection meetings, if required.
• Ensuring that the Deputy DSL is fully briefed and equipped to carry out the role of DSL during any planned or unplanned absences
The Designated Safeguarding Lead with responsibility for Safeguarding is:
Pearl O’Keeffe, Senior Programme Manager
Address:
Bermondsey Campus, 37 Clements Road, London SE16 4EE
Telephone:
020 7467 9540
Mobile:
07943 068555
Email:
pearl.o’keeffe@constructionyouth.org.uk

2.4 The Deputy Designated Safeguarding Lead
The Deputy Designated Safeguarding Lead is trained to the same level of the Designated Safeguarding Lead and, in the absence of the Lead, carries out those responsibilities necessary to ensure the safety and protection of all students.
The Deputy Designated Safeguarding Lead with responsibility for Safeguarding is:
Emily Barnes, Schools & Programme Coordinator
Address: Bermondsey Campus, 37 Clements Road, London SE16 4EE
Telephone: 020 7467 9540
Mobile: 0750 799 4745
Email: emily.barnes@constructionyouth.org.uk

2.5 Staff
The safeguarding responsibilities of staff are to:
• Ensure the general safety and wellbeing of students and all those who come in to contact with them
• Ensure they are familiar with and adhere to all relevant safeguarding policies and procedures including those involved in recognising and reporting safeguarding incidents
• Report all concerns, without judgement about their significance, to the DSL or Deputy DSL
• Ensure that volunteers, freelancers and contractors are aware of CYTs safeguarding policy and know how to recognise any concerns and report them.
• Adhere to appropriate confidentiality
• Undertake appropriate training and refresher training annually
• Ensure no child is left unsupervised with a person who has not been DBS checked.

3. Safer Recruitment
Staff, volunteers and freelancers will be required to:
• Complete a standard application form
• Complete a declaration form to disclose previous spent/unspent convictions and disciplinary or capability procedures.
• Provide identity documents including photographic identity
• Provide proof of right to work in the UK
• Provide two referees, who will be asked to confirm that in their knowledge there is no reason why the individual should not be allowed to work with children and vulnerable adults.
• Provide qualification certificates if required for the role
Complete a Disclosure and Barring Service (DBS) if the role/place of work requires it i.e. if they are likely to come in contact with children, young people and/or vulnerable adults. All role descriptions contain information about safeguarding responsibilities.
Trustees
CYT checks the identity and suitability of all trustees and requires a Standard DBS check to be undertaken. An induction pack is provided and where possible an induction day arranged for new trustees which includes a session on safeguarding. All Trustees complete an annual Trustee Declaration as required by the Charity Commission.
Third Party Providers
Third party providers will be asked to confirm the following for their employees who are working on behalf of CYT
• That the individuals have been identity-checked and have permission to work in the UK as part of their recruitment process – in writing
• That a suitable and clear DBS check has been received within the last 3 years for the role their employee is to undertake and a copy to be provided to CYT.
• That the provider has Employer Liability insurance in place (CYT level £10M)
• That the provider has Public Liability Insurance in place of at least the minimum amount requested by CYT. (CYT level £10M)
• Third party providers will be required to adhere to any risk assessment provided by CYT where the provider is undertaking activities that have been designed by CYT. Where the provider is undertaking an activity they have designed the provider will be asked to provide a risk assessment to CYT. For activities with schools the risk assessment will be provided to the school for their consideration. No activity can commence without both CYT and the school confirming that the risk assessment meets their requirements.

4. Staff Training
It is important that all staff have training to enable them to recognise the possible signs of abuse and neglect and to know what to do if they have a concern.
New staff and trustees are expected to undertake on-line safeguarding awareness training as part of their induction to the organisation. This training is recorded in CYT’s central HR folder. Refresher training takes place annually.
In their first week of employment, new staff are given a copy of the CYT Safeguarding Policy, together with other related policies.
All those leading on CYT’s recruitment carry out Safer Recruitment training. There will always be at least one trained person involved in any recruitment and selection process.
The DSL and Deputy DSL undergo appropriate Designated Safeguarding Lead training.

5. Recording and Reporting
If a member of staff becomes aware of any safeguarding concerns, how that concern is handled is important for the protection of the child, young person or vulnerable adult as well as for the staff member involved. The following procedure should be followed:
• Wherever a member of staff suspects abuse, witnesses an incident that appears to be abuse, or has any safeguarding concerns, that member of staff will report it to the safeguarding team.
• The member of staff should record in writing the details of the incident/concern (including dates, times, venues and wherever possible using the actual words of the student) and input this into the incident report form found on the CRM, which will automatically send an alert email to the DSL and Deputy DSL. The reporting of the incident should not be left for more than 24 hours.
• If the incident/concern is reported by a volunteer or other third party, the CYT member of staff will ask the volunteer to record their concern in writing as above and they will then input into CRM system on their behalf.
• If the young person(s) in question is under the care of a school, college or other agency at the time, the member of staff will share their concern with their lead contact present. However, the incident/concern must still be recorded on the CYT CRM system, even if it has been resolved.
• If the member of staff believes the issue requires the immediate attention of the safeguarding team, they will make direct contact with the DSL (or Deputy DSL/CEO if DSL is not available) to ensure they are aware of incident. However, the incident/concern must still be recorded on the CYT CRM system, even if it has been resolved.
• The DSL/Deputy DSL will decide on the action to take within 24 hours, including consulting with school or other partner agency such as a youth offending team.
• CEO should be informed of serious incidents at the earliest opportunity by the DSL or Deputy DSL.
• At the next safeguarding working group meeting, a summary of all reports will be presented and there will be a discussion regarding any patterns of safeguarding issues that have been observed.
• Reports will be prepared for the Quarterly trustee meeting detailing patterns observed.
• All records relating to child and vulnerable adult welfare concerns will only be kept electronically, with access to it limited to the Safeguarding Lead, Deputy and CEO. A record will be kept and the CRM will be marked that there is confidential information available to staff who are to engage with the student with access to it sought via the Safeguarding Lead, Deputy or CEO.

5.2 Where a Criminal Offence is suspected
Wherever a criminal offence is alleged, or is suspected to have taken place, the police must be contacted. The DSL will consult with the school/college, partner agency, the Local Authority Designated Officer or Team of Designated Officers as appropriate to clarify who will contact the police. If it is agreed that a third party should contact the police, then the DSL will follow this up by making themselves known to the police and requesting confirmation as to whether the matter is being investigated.

5.3 Immediate Risk or Danger
If a learner is at immediate risk or in situations where there could be a requirement to collect forensic evidence, then the police and, if appropriate, other emergency services must be contacted immediately. In such cases the emergency services should be called before informing the DSL or a member of the Safeguarding Team.

5.4 Concerns about a CYT Colleague
CYT’s whistleblowing policy enables staff to raise concerns or allegations in confidence and for a sensitive investigation to take place.
If a member of staff has concerns about a colleague they should contact the DSL or Deputy DSL. They will decide whether the Local Authority Designated Officer or Team of Designated Officers need to be contacted. Any concerns about the behaviour of the Chief Executive Officer will be reported immediately to the Chair of the Board of Trustees by the DSL. Any concerns about the DSL or Deputy DSL should be reported to the CEO.
The Chief Executive Officer will inform the Disclosure and Barring Service if a member of staff, volunteer or trustee is removed or resigns from post due to safeguarding issues.
The Chief Executive Officer in liaison with trustees will decide whether to refer a safeguarding issue to the Charity Commission.
Reference should also be made to CYT’s Whistleblowing Policy if appropriate.

5.5 Requests for Assistance by Other Agencies
CYT will assist local authorities and the police service when they are making enquiries about the safety of children and vulnerable adults.
When telephone requests for information are received, staff will always maintain security by checking the telephone number listing and calling the person back on a telephone number that can be independently verified.
Requests for information about a safeguarding issue must be immediately referred to the DSL.
Requests for attendance at meetings about a young person or vulnerable adult must be notified to the DSL, who will consider the request before confirming the preparation of a report and attendance at the meeting.

5.6 Students Subject to a Child Protection Plan
CYT will ask the relevant agency, school or local authority whether a child in our care is subject to a Child Protection Plan for any particular issues that it should be aware of and how they should be addressed. CYT will take forward an appropriate risk assessment for the individual dependent upon issues that are divulged.
The name of the relevant contact e.g. social worker and/or care manager must be clearly recorded on the child's CRM record…
When a child is on a Child Protection Plan, CYT will discuss with the contact what information they want us to share.

5.7 How to respond if a child confides abuse to you
If a child or young person tells you that they are being abused, it is important that you know how to respond. Here are the universal principles regardless of the age of the child.
It is important you:
• stay calm and be patient.
• find a quiet place where your conversation will not be interrupted. Keep in mind CYT policy about not being alone with a child or young person but always within sight or earshot of another responsible adult.
• be welcoming, even if the time isn’t convenient for you. It may have taken a great deal of courage for them to approach you and they may not do so again.
• try to make the child or young person feel safe and secure. Reassure them that they have done nothing wrong in telling you.
• listen carefully and take it seriously.
• ask questions for clarification only.
• explain what you will do with the information and what will happen next.
• write down what you have been told as soon as possible. It should be dated, timed and signed. It should then be given to the DSL immediately.
It is important you do not:
• promise confidentiality
• ask leading questions
• look panicked, shocked or angry
• make the child or young person repeat their story
• interrupt
• give an opinion
• inform parents until you have had a discussion with your safeguarding lead.
If emergency help is required, do not delay getting it. If a child asks for confidentiality and they are told this cannot be guaranteed, and as a result they refuse to say anything further, make an immediate report to the organisation’s DSL.

6. Confidentiality and Sharing Information
All staff will understand that safeguarding issues warrant a high level of confidentiality to ensure that confidential information is not released into the public domain.
Staff should only discuss concerns with the DSL, or in their absence the Deputy DSL. It might also be appropriate to report directly to the Chief Executive Officer. The DSL will then decide who else needs to have the information and they will disseminate on a need to know basis.
All safeguarding information relating to concerns about a learner will be stored electronically and in line with the principles of the Data Protection Act 1998. There will be a flag on a student’s record that a safeguarding issue exists, but access will be restricted to the DSL, Deputy DSL or CEO. If necessary, confidential information will be made available to staff who are to engage with the learner but on a needs-to-know basis only.
If any member of staff receives a request from an agency or individual to see a learner’s safeguarding protection record or information relating to a safeguarding incident, they must refer the request to the DSL. The DSL will ensure they can identify who is requesting the information before sharing it and then record what has been shared, when, why and with whom.
For more information, please refer to CYT’s Data Protection policy:

7. E-Safety Policy
For further information, please refer to the following CYT policies:
• E-Safety policy

8. Risk Assessments
CYT has developed risk assessments designed to safeguard students the areas covered are:
1:1 Sessions with students including online work
Group online sessions
Visiting third party venue
Travel
School off site activities
Community referred programmes
School activities
Using third party providers
Visits to community groups
Practical sessions.

9. Review and Monitoring the Safeguarding Policy
It will be the responsibility of the Safeguarding Team to review and monitor CYT’s safeguarding policy and procedures.
The Board of Trustees are responsible for considering and agreeing changes to the policy and procedures as recommended by the Chief Executive Officer and Safeguarding Team.
The Senior Programme Managers, supported by the DSL, are responsible for ensuring the policy and procedures are implemented consistently across the organisation.

10. Useful Safeguarding Contacts
The table below contains useful contacts which can be used when seeking guidance on safeguarding issues. This list is not exhaustive and as CYT can operate training and education programmes across a number of areas it will be necessary to know where to locate the contact details of the appropriate Local Authority Designated Officer (usually searching on the internet under the county or borough name then LADO.
NSPCC Child Protection Helpline
www.nspcc.org.uk
help@nspcc.org.uk
0808 800 5000
Safe CIC
www.safecic.co.uk
01379 871091
Get Safe Online
www.getsafeonline.org/safeguarding-children

Appendices:
• Appendix 1: Definitions and Concepts of Child Protection and Protection of Vulnerable Adults
• Appendix 2: Types of Abuse Specific to Vulnerable Adults
• Appendix 3: Safeguarding Protocols

Appendix 1
Definitions and Concepts of Child Protection and Protection of Vulnerable Adults
There is a common agreement that clear definitions would be an enormous aid in child protection work. However, straightforward definitions are not easy to provide. To ensure consistency the concepts and categories outlined here are used in ‘Working Together to Safeguard Children: a guide to interagency working to safeguard and promote the welfare of children’ (2010), the national framework which guides agencies and professionals to work together to safeguard and promote the welfare of children and young people.
1. Children:
As per the Children Act 1989 and Children Act 2004, a child is anyone who has not reached his or her 18th Birthday.
Throughout this policy and procedure, reference is made to “children and young people”. This term is used to mean “those under the age of 18”. However, the governing body recognises that some vulnerable adults are also open to abuse and this policy also covers those adults. A ‘vulnerable adult’ is any person aged 18 or over who ‘is or may be in need of community care services by reason of mental or 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.’ (Department of Health, 2000). People with learning difficulties that make it difficult for them to protect themselves from harm will come within this definition. This policy and procedure has been developed to be pro-active in responding to Child and Vulnerable Adults Safeguarding Legislation.

2. Vulnerable Adult:
The Safeguarding Vulnerable Group Act 2006 defines a vulnerable adult as a person who is aged 18 years or older and:
• is living in residential accommodation, such as a care home or a residential special school;
• is living in sheltered housing;
• is receiving domiciliary care in his or her own home;
• is receiving any form of health care;
• is detained in a prison, remand centre, young offender institution, secure training centre or attendance centre or under the powers of the Immigration and Asylum Act 1999;
• is in contact with probation services;
• is receiving a welfare service of a description to be prescribed in regulations;
• is receiving a service or participating in an activity which is specifically targeted at people with age-related needs, disabilities or prescribed physical or mental health conditions or expectant or nursing mothers living in residential care (age-related needs includes needs associated with frailty, illness, disability or mental capacity);
• is receiving direct payments from a local authority/HSS body in lieu of social care services; or requires assistance in the conduct of his or her own affairs.

3. Safeguarding and promoting welfare:
Safeguarding and promoting welfare is defined as:
• Protecting children from maltreatment
• Preventing impairment of children’s health or development
• Ensuring that children are growing up in circumstances consistent with the provision of safe and effective care.
• undertaking that role so as to enable those children to have optimum life chances and to enter adulthood successfully

4. Child Protection:
This is a part of safeguarding and promoting welfare. It refers to activity that is undertaken to protect specific children who are suffering or are at risk of significant harm.
 
5. The concept of significant harm
This is an important concept which was introduced by the Children Act 1989.
Significant harm is the threshold, which justifies compulsory intervention in family life in the best interests of the child. The local authority is under a duty to make enquiries, or cause enquiries to be made, where it has reasonable cause to suspect that the child is suffering, or likely to suffer significant harm (section 47 of the Children’s Act 1989).
There are no absolute criteria on which to rely when judging what constitutes significant harm. Sometimes a single traumatic event may cause significant harm e.g. violent assault, suffocation, poisoning. More often however, it is the cumulative effect of incidents and/or behaviours over time which significantly impairs the child’s physical and psychological development.
Those wishing/needing to explore further the concept of significant should discuss this further training with their line manager.

6. What is child abuse?
Abuse and neglect are forms of maltreatment of a child. Child abuse is a multi-faceted, complex phenomenon. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. The categories of abuse most commonly used in child protection practice and procedures are: Physical abuse; sexual abuse; emotional abuse and neglect. It is recognised that these categories constitute a very narrow definition of abuse, excluding such phenomena as internet abuse. Here we will provide definitions for neglect; physical, sexual, emotional abuse but also abuse by discrimination.
Types of abuse (children and vulnerable adults):
Neglect
The persistent failure to meet a child’s basic needs both physical and or emotional/psychological. It may involve failure to provide clothes, shelter and food or failure to protect the child from physical harm or danger. It may also include neglect of, or unresponsiveness to, the child’s basic emotional needs.
Physical
Causing physical harm to the child or young person such as: Hitting, shaking, pushing, burning, poisoning, and drowning. Harm can also be caused when a parent or carer fabricates symptoms of ill health or causes actual ill health in a child or young person in their care.
Sexual
Involving, forcing or enticing a child or young person to engage in sexual activities, including prostitution, whether or not the child is aware of what is happening. These activities may involve physical contact including penetrative or none-penetrative acts. They may also include non-contact activities, such as involving children in creating or looking at pornographic material.
Emotional
Ill treatment of a child to cause severe and persistent adverse effects in their emotional development. It may involve telling a child they are worthless, unloved, unvalued. It may involve making unacceptable demands on the child in relation to their age and capabilities, or causing children frequently to feel frightened or in danger.
Any or all of these types of abuse may be perpetrated as the result of deliberate intent, negligence and ignorance. The abuse may be perpetrated by a wide range of people, including family members and relatives, people in positions of power and authority, volunteers, neighbours, friends and associates, as well as strangers.

7. Abuse of trust
There is particular concern when someone perpetrates abuse in power or authority or who uses his or her position to the detriment of the health, safety, welfare and general wellbeing of a vulnerable person. Employees should always be alert to situations where they may be witnessing ‘Abuse of trust’. This must also be brought to the attention of the safeguarding advisor and consultation should take place with the LADO.
When any of the above forms of abuse occur, emotional abuse will have occurred as well.

8. Recognising Abuse
Employees are not expected to be Child Protection experts. However, there are a number of circumstances under which staff might have concerns that a child, young person has been or is being abused:
• They may tell about the abuse they have experienced.
• A third party - a parent, relative, carer, another young person, other professionals, neighbour - may share concerns.
• Staff may also become concerned through observing:
• A bruising or injury, which is unusual for example on a part of the body which is not normally prone to such injuries, like the cheeks. *
• Injuries which require but have not received medical attention. *
• Cigarette burns or bite marks.
• Unexplained changes in behaviour either over time or suddenly for example becoming aggressive, quiet or withdrawn.
• Running away from home.
• Non-attendance at school, projects or activities.
• Reluctance to get changed or for example wearing long sleeves in hot weather *
• The young person appears not to trust certain adults for example parent, carer, staff member with whom you would usually expect them to have or once had a close relationship.
• The young person being discouraged or unable to make friends or from socialising with others.
• The young person becomes unusually dirty or unkempt.
• Changes to eating patterns.
• The young person developing a disturbed sleeping pattern.
• The young person self-harms or attempts to self-harm.
• Age inappropriate sexual knowledge.
• Sexually inappropriate behaviour.
This list is not exhaustive. *Note that these injuries may be signs of self-harm also.
Many children and young people will exhibit some of these indicators at some time and the presence of one or more should not be taken as proof that abuse is occurring. There may be other reasons for changes in behaviour such as a death in the family or other crisis. The staff’s knowledge of a young person over a period of time may help them to understand whether there is a cause for concern.

9. Barriers to reporting abuse
Experience in the child protection field over the years has shown that there are many barriers that individuals often have to overcome before raising a concern.
Some people have concerns about sharing confidential information. It would normally be good practice not to refer a child or young person to another agency without their knowledge and consent. However, this principle of confidentiality can be overridden when there are child protection concerns.

10. Race, Ethnicity and culture
Abuse can take place in any culture and all children have a right to grow up safe from harm. Staff need to be aware of and sensitive to differing family lifestyles and childrearing practices. Staff need to guard against myths and stereotypes, both positive and negative. At the same time fear of being accused of racism should not prevent necessary action being taken.

11. Gender
While a majority of child sexual abuse is carried out by men, it needs to be recognised females do commit sexual offences against children.

12. Disabled Children
Disabled children and young people are particularly vulnerable to abuse in any form. Safeguards for disabled are essentially the same as for non-disabled children. Staff must maintain high standards of practice remain vigilant to the possibility of a child being abused and minimise situations of risk. All staff working with disabled children must ensure that they (the children) know how to raise concerns, and have access to interpreters’/specialist workers and other aids to communication. Where there are concerns about the welfare of a disabled child, they must be acted upon in accordance with the procedures. The same thresholds for action apply. Where concerns are raised about a child who has communication difficulties, appropriate support, interpreting services and communication aids must be secured

Appendix 2
Types of Abuse Specific to Vulnerable Adults
These categories of abuse are in addition to those identified for safeguarding children and young people.
The following examples of abuse are not exhaustive:
Physical Abuse
• Hitting, slapping, pushing, kicking, inappropriate/careless handling and other forms of assault that may not leave visible signs of injury, but may cause pain or discomfort
• Beating (with or without an implement), punching, biting, deliberate burns, scalding, unnecessary restraint and other forms of assault that leave injuries
• Stabbing, strangulation, poisoning and wounding (breaking the skin) and other forms of assault that cause serious injuries or death
• Medical mistreatment such as withholding or inappropriately altering or administering medication or other treatments, and the inappropriate use of restraint or other sanction.
Sexual Abuse or Exploitation
Any of the following actions to which the individual has not consented, or could not consent to or was pressurised into consenting:
• Incest, rape
• Offensive or suggestive sexual language or action
• Touching, fondling, caressing, kissing, masturbation
• Oral sex on alleged victim, oral sex by alleged victim on perpetrator
• Sexual intercourse
• Involvement in prostitution or pornography
Psychological/Emotional Abuse
• Use of threats or fears to over-ride a person’s wishes
• Lack of privacy or choice
• Denial of dignity
• Deprivation of social contact or deliberate isolation
• Being made to feel worthless
• Threat(s) to withdraw care or support or contact with friends
• Humiliation, blaming
• Use of coercion
• Treating an adult as if they were a child
• Verbal abuse
Financial Abuse or Exploitation
• Stealing, theft of money or property
• Deceiving or manipulating a person out of money or property
• Withholding or misusing money or property
• Stripping the person of his or her assets
• Exploitation of dependence for personal gain
• Misuse of benefits by others
Neglect and Acts of Omission
• Lack of care
• Withholding food, drink or medication
• Deprivation of necessary personal care
• Failure to protect from harm
• Removal of aids to daily living
• Failure to give access to health and social care or educational services
• Failure to give information about sexual and reproductive health
Discriminatory Abuse
• Racist, sexist or homophobic abuse
• Abuse relating to age, illness or disability
• Acts or comments, including incitement of others to commit abuse

Appendix 3
Safeguarding protocols (For young people under 18 or vulnerable adults under 25)
Supervision protocols - Group work:
Default adult to young person ratio to be 1: 10 for 13 years and above; 1:8 for 12 years and below as per NSPCC guidelines. Exceptions:
• Groups evaluated as low risk (e.g. sixth formers with no particular risks identified by school), then ratio can be increased to 1: 15
• Ratio may be decreased if there are higher risk young people participating in the activities (e.g. young people with special educational needs; young people affected by violent crime)
Every group of young people will be supervised by at least one DBS verified member of the CYT team or trusted partner organisation (e.g. YOT, school, third party provider)
Groups of young people will not be supervised by a single adult working alone at any time unless the group is within sight/earshot of other adult(s) e.g. a trainer could work with a small group of young people in a separate area if there is an open door/window to other staff members
Unsupervised times:
The default position is that young people aged 16 and over have their lunch unsupervised and are allowed to leave the premises where we are working during the lunch break. Young people aged 16 and over will generally be free to walk unsupervised around the CYT building and other premises we are using, including to use the toilet facilities which will often be shared with staff and/or clients from other groups. This will all be covered in Parental Consent forms.
The exception would be if a group is evaluated as high risk, in which case extra precautions could be discussed with referral partners and put in place as appropriate e.g. supervised lunch.
Young people aged 15 and under will be supervised at all times. The only exception is Year 11 summer programmes where one or two young people may not have yet reached their 16th birthday. Our default position is that these will be run according to the 16+ protocols for all attendees but only if parental consent given.
There are times when young people come into CYT premises outside of organised activities to practise CSCS tests, for instance. Young people working within the building will be at all times within earshot/sight of responsible adult(s).
One-to-one work:
One-to-ones will be carried out only in CYT offices or on the premises of trusted partner organisation whose staff are aware in advance that CYT will be carrying out one-to-ones. One-to-ones will not be carried out in public places such as public cafes, restaurants etc.
One-to-one sessions to be held within sight/earshot of other responsible adults who are aware that the one-to-one is happening and the context of the meeting e.g. school interview room if open door/window to other adults, CYT space adjoining other occupied area with open door/window, in the corner of an otherwise open space such as a job shop.
Travel:
Only licensed travel companies to be used.
Ratios above apply with at least 2 adults with a travelling group at any time. Taxi/coach driver can act as second adult if necessary, as long as in sight of CYT staff at all times.
Young people to remain in sight of CYT staff at all times.
If young people are expected to make their own way to and from a venue/meeting point, this will be made clear in Parental consent forms.
First-aiders
All CYT delivery staff will be trained in basic emergency first aid at work.
Parental consent:
Parental consent will be sought for all activities involving young people under the age of 18 who are under the care of CYT. The parental consent form will detail:
• All activities to be undertaken
• Location of activities
• Travel arrangement
• Supervision arrangements including any unsupervised times and activities
• Description of who the young people are likely to interact with e.g. other students from their school, students from other schools, CYT staff, industry volunteers
• If and how CYT staff will communicate directly with young person
• Any likely interaction with members of public
• Food & refreshment arrangements if relevant
• Photo consent
Risk assessing individual learners and putting in place appropriate measures:
For young people who will be under the direct care of CYT, we will evaluate the risk of harm to themselves or to others according to the protocols below. This will include working with referral partners including schools to identify in advance where possible risks in any of the following areas and putting in place measure to control risks appropriately:
• Any relevant child protection or safeguarding issues relating to young person
• Significant health/medical issues
• Substance misuse issues
• Violent or aggressive behaviour
• Self-harming behaviour
• Criminal behaviour including gang involvement, sexual offences
CYT staff will review individual risk assessments regularly and will inform their line manager immediately if they have reason to believe the risk has changed so that risk assessment can be updated and measures continue to be appropriate.

1. Risk assessing learners from schools:
For group programmes, risk assessment will be carried out at group level initially by asking the school to inform us if there are any significant risk or issues that we should be aware of in relation to the young people in the particular group (referencing the list above) prior to undertaking any activity. This does not include activities where young people remain under the supervision of the school e.g. teacher present. If the school confirms there are no issues, we will deem each young person to be low risk.
For individual coaching programmes, schools will be asked to complete a full referral form for each young person including an assessment of the risk associated with that young person.
If the school identifies any potential issues, we will evaluate with the school whether the risk is low/medium/high risk. For medium/high risks, we will complete an individual risk assessment setting out the measures we will take to control the risk, in agreement with the school.

2. Risk assessing learners referred to us by our partners
All referral partners will be asked to complete our referral form to identify if there are significant risk or issues that we should be aware of in relation to the young person they are referring (referencing the list above). CYT staff will contact referral partner for a phonecall or meeting if information given is unclear or incomplete.
Referees will also be asked to help us assess the level of risk facing the young person, in terms of risk of harm to the young person themselves or risk of harm to others, so that appropriate support and precautions can be put in place. Referees will be asked whether they consider the risk associated with the individual young person is low/medium/high. For medium/high risk, we will contact the referral partner to agree an individual risk assessment setting out the measure we will need to take to control the risk.
We will also ask the referral partner to inform us in what capacity and for how long they have known the young person. If we deem this insufficient to make an informed risk assessment, we will ask the partner to provide an alternative referee. If still insufficient and of any doubts, we will follow the self-referral protocol below.

3. Risk-assessing learners who self-refer (or whose referral information is insufficient)
We will ask the young person if there is a professional who knows them and would be willing to refer them to our programme e.g. social worker, case worker, teacher etc. If yes, follow referral partner protocol above.
If not, the young person will be asked to complete the self-referral form and will then be invited for an informal interview. If the programme involves face-to-face engagement, this will be carried either in Bermondsey centre or in a partner’s premises with at least two responsible adults in attendance. Staff will be alert to the potential risk of an unknown individual and will put in place reasonable precautions. If the programme is online only, the interview can be carried out remotely online or by phone.
If there are worrying signs in evidence at any stage e.g. erratic behaviour, the individual will not be included on the programme unless a referee can vouch for the young person.
A risk assessment will be drawn up for the young person based on their self-referral form, erring on the side of caution until CYT has had the opportunity to get to know the young person better.
Risk assessing groups of individual learners and putting in place appropriate measures:
CYT staff will assess the risk of every group of young people, based on the risk assessment of the individuals involved, and will put in place appropriate additional measures for group activities where group deemed medium/high risk. This might include
• reducing the ratio of adults to young people
• arranging to have an induction prior to programme start
• supervising lunches
• supervising or managing access to toilet facilities
• reducing exposure to public
• Minimising travel outside of immediate area etc.
The risk level will reviewed on a regular basis to ensure control measures continue to be appropriate.