This Policy covers the Club’s approach to protecting children and adults at risk who use the Club’s services.
1. The Club is committed to creating a safe, secure culture for children and adults at risk to participate in a broad spectrum of activities relating to football. Unfortunately, children and adults at risk (“vulnerable groups”) may be subject to abuse of various kinds in a number of environments, including the Club, as sport provides easy access for someone who wants to harm them. Many of our staff members will have contact with vulnerable groups or will have access to their personal information in the course of their employment or involvement with the Club, and many of those staff members will have a position of trust in relation to those individuals by virtue of their work. As such the Club has a duty of care towards those vulnerable groups to provide a safe environment during any involvement with the Club.
2.The primary aim of this Policy is to provide a framework for guidance to staff both during the staff recruitment process and whilst acting on our behalf to promote issues relating to safeguarding children and adults at risk.
3. This Policy does not form part of your contract of employment and it may be amended at any time. We may also vary any parts of this Policy, including any time limits, as appropriate in any case.
This Policy applies to any individual working with or around vulnerable groups on behalf of the Club including the
4. Club’s directors, officers and employees (whether full-time, part-time, temporary or seasonal) and agency workers, consultants, volunteers or self-employed contractors (referred to in this Policy as “staff”).
5. Failure to comply with the Policy may lead to disciplinary action by the Club under the Club’s Disciplinary Policy, up to and including summary dismissal. Where non-compliance is alleged and it relates to an agency worker, volunteer, consultant or self employed contractor then the Club’s Disclosure Panel will review the circumstances and decide on the appropriate course of action.
6. If you have any queries in relation to the Policy, please contact the Club’s Safeguarding Services Manager or the Club’s Head of HR and Training.
7. Safeguarding is essentially about keeping children and adults at risk safe from abuse and our role in promoting and protecting the welfare of vulnerable groups.
8. The term child or children applies to any person under the age of 18 years.
9. The term adult at risk applies to any person over the age of 18 years and who is:
An adult at risk may be vulnerable at some times and not others; has the right to self determination and may not wish to have others intervene to safeguard them, unlike children where there is a statutory duty to protect their well being.
10. Abuse covers any deliberate act towards a child or adult at risk, or a failure to act, which results in them being injured, put at risk of injury or damaged in such a way that they fail to meet their potential. On occasion, adults at risk may consent to activities which are not in their best interests but, as adults, they are entitled to do so. Abuse can take many forms: physical abuse, emotional abuse, neglect and sexual abuse (collectively referred to in this Policy as “abuse”).
11. Abuse is a very emotive and difficult subject. It is important to understand the feelings involved but not to allow them to interfere with our judgement about any action to be taken. It is also important that abuse and safeguarding are openly discussed as this helps create an environment where people are more aware of the issues and sensitive to the needs of children and adults at risk.
12. Definitions of abuse:
13. Some common misconceptions:
14. A safeguarding issue may come to your attention in various ways. The most common are where a child or adult at risk:-
15. If you have any concerns about a child’s or an adult’s behaviour, you should contact the Club’s Safeguarding Services Manager or the Head of HR and Training immediately.
16. There is no definitive list to cover all indicators of abuse and not all indicators will apply to all vulnerable groups suffering abuse. There could be indicators other than set out below which give you cause for concern. By themselves, the following indicators do not prove abuse or neglect, but they do tell us that we need to know more about the child’s or adult at risk’s circumstances.
17. If you have any concerns relating to a child or adult at risk, whether it is because you believe that there are one or more indicators or for another reason, you should immediately contact the Club’s Safeguarding Services Manager or the Head of HR and Training for advice. It is always better to report your concerns than to do nothing (see below What to do if abuse is suspected).
What to do if abuse is disclosed to you
18. There are four simple steps to take in the event that a child discloses abuse:
- LISTEN to what the child or adult at risk is telling you, do not probe or ask questions. A person who is freely recalling significant events should not be interrupted.
- REASSURE the person calmly and gently that they have done a good thing in telling you what is happening. Tell him or her what will happen next.
- REPORT what you have been told promptly to the Club’s Safeguarding Services Manager or the Head of HR and Training for them to manage. Do not discuss the matter with anyone else including the parent, carer or the alleged perpetrator.
- RECORD what the person has told you straight away while it is fresh in your mind. The actual words spoken by the person should be used as much as possible rather than an interpretation of what was said. Specific facts relating to named people, dates, places etc. should always be recorded accurately along with any details of injuries i.e. where they are and what they look like and pass a copy to the Club’s Safeguarding Services Manager or the Head of HR and Training. Do not under any circumstances undress the person or adjust clothing to view any injuries or bruising.
Do not promise to keep what the person has told you a secret. You must inform the Club’s Safeguarding Services Manager or the Head of HR and Training immediately.
What to do if abuse is suspected
19. If abuse is suspected:
- REPORT any concerns to the Club’s Safeguarding Services Manager or the Head of HR and Training immediately. You must not investigate the alleged abuse. Prompt action is paramount; doing nothing is not an option when any kind of abuse is suspected.
- RECORD all details which support your suspicions. You should sign, date and keep these records and pass a copy onto the Club’s Safeguarding Services Manager or the Head of HR and Training.
Allegation of abuse or poor practice against a member of staff
20. If an allegation of abuse or poor practice is made against a member of staff the Club will treat this very seriously. The matter will be dealt with under the Club’s Disciplinary Policy. If an allegation is made against an agency worker, volunteer, consultant or self employed contractor then the Club’s Disclosure Panel will review the circumstances and decide on the appropriate course of action.
On-going responsibilities and what happens next
21. The Club’s Safeguarding Services Manager will take responsibility for any ongoing involvement with any investigation and will keep you updated on what further expectations, if any, there may be of you e.g. to provide a police statement or to attend external safeguarding strategy discussions. The Club’s Safeguarding Services Manager will liaise with the Head of HR and Training and will ensure that allegations of abuse and the outcome of any investigation by the Protection Agencies are dealt with appropriately.
22. You must maintain confidentiality at all times and must not discuss your involvement in proceedings with any one, whether it is someone internal or external to the Club, your family, a friend or a colleague.
23. You should contact the Safeguarding Services Manager immediately if you are contacted by the Police, Crown Prosecution Service or if you are asked to attend a Local Authority Forum or a Protection Conference.
Recruitment and selection
24. The Club has procedures in place to ensure that all reasonable checks are made before appointing an individual to a position of trust, in order to prevent those who pose a risk to vulnerable groups from working within or representing the Club. It is, however, important that everyone remains vigilant to indicators that individuals are acting in an unacceptable manner.
25. It is a requirement that those seeking employment to work with or around vulnerable groups will need to disclose any current involvement with protection agencies (i.e. if you have ever been the subject of an investigation) and the outcome of that involvement, or stage it is currently at, before employment can be offered.
26. If you are already in the Club’s employment and become involved with a protection agency (i.e. you become the subject of an investigation) you must disclose that involvement as soon as it commences and you should immediately contact the Head of HR and Training or the Safeguarding Services Manager for support.
Criminal Records Disclosure
27. The Club has a Criminal Records Policy in relation to:-
- undertaking criminal record checks of current and prospective staff members (a “Disclosure”);
- making enquiries into the offending history of contractors and their suitability to work within certain defined roles at the Club;
- employing people with a criminal record; and
- ensuring the secure storage, handling, use, retention and disposal of documentation relating to criminal records checks.
28. The Club’s Head of HR and Training, Safeguarding Services Manager and Head of Legal (the “Disclosure Panel”) are jointly responsible for ensuring compliance with the Criminal Records Policy Any questions or concerns about the interpretation or operation of the Criminal Records Policy should be taken up, in the first instance, with a member of the Disclosure Panel.
Criminal Records Policy Statement
29. The Club complies fully with the Disclosure & Barring Service (“DBS”) Code of Practice.
30. A copy of the Club’s Criminal Records Policy is available to all staff or applicants for roles within the Club upon request and which should be referred to for further information.
Roles subject to Criminal Records disclosure
31. The Club requires that any staff member who works for or on its behalf in either a paid or unpaid capacity in a regulated activity, must have a current, relevant DBS Check (and Barred List check when appropriate) which is acceptable to the Club’s Disclosure Panel.
32. At recruitment stage, the post will be identified as to whether it is a regulated activity or not. If it is, the Club will ask applicants about any offences that are not “protected” as defined by the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended 2013), and at offer stage will obtain a relevant DBS / Barred List check before employment commences.
33. Heads of Department, when recruiting, are responsible for considering the responsibilities that the person holding that role will have, the safeguarding risks inherent in such a role and the appropriateness of a criminal record check and providing this information to the Disclosure Panel.
Safeguarding Code of Conduct
34. The Club has a number of Codes of Conduct which are applicable to Club activities. You must read and comply with the Safeguarding General Code of Conduct in Appendix 1 at all times.
35. In addition, there are roles and activities which carry their own specific Code of Conduct (as set out below) and should be used in conjunction with the Safeguarding General Code of Conduct. You must ensure that you receive, read and comply with the Code of Conduct for the activity you are engaged in prior to commencing that role or activity:-
- Club Mascots (Hercules, Bella & Chip);
- Mascot Co-ordinator;
- Dedicated Drivers for Children;
- First Team Players;
- Media and Communications Personnel;
- Health and Medical Personnel;
- Host Families
Appendix 1 – Safeguarding General Code of Conduct
1. All Staff must have a working knowledge of the Club’s Safeguarding Vulnerable Groups policy and follow this Code of Conduct.
2. This Code of Conduct applies to all activities that operate under the auspices of the Club at any site.
3. There are roles and activities which carry their own specific Code of Conduct and should be used in conjunction with the Safeguarding General Code of Conduct. All staff must ensure that they receive, read and comply with the Code of Conduct for the activity they are engaged in prior to commencing that role or activity.
4. The aim of each code of conduct is to provide guidance on best practice which should:
- safeguard children or adults at risk attending or participating in an event
- safeguard staff involved in that event
Code of Conduct
1. Do not allow yourself to be in a situation alone with a child or adult at risk; ensure that you can be observed by another adult at all times.
2. Do not divulge personal details, contact telephone numbers or details about your personal life to any child or adult at risk known to you through your role at the Club.
3. Do not go into a toilet with a child who is or appears to be under the age of 18 or an adult at risk. If asked by a mother to escort her son to the toilet you must refuse, but assist that mother to use a disabled toilet so that she may supervise the child or adult at risk directly herself. This applies equally if a father with a daughter asks. It is reasonable for you to assume the adult is the parent or designated person without checking. However, if there is anything about the child’s or adult at risk’s behaviour that suggests they do not know the adult or that they are distressed in any way, ask them if everything is all right.
4. Report a negative or worrying response to your Supervisor straight away or depending on the context of the situation report the matter directly to the Safeguarding Services Manager or another Senior Officer at the site the incident is on.
5. If you see conduct, hear comments or are in any way alerted to concerns about an individual in contact with a child or adult at risk, then you should raise this with the Safeguarding Services Manager for further guidance in the first instance. If you consider that a child is in immediate and direct danger then seek protection and advice from the police immediately, then contact the Club’s Safeguarding Services Manager straight away. However, if you consider that an adult at risk is in immediate and direct danger then seek their consent to call the police immediately, then contact the Club’s Safeguarding Services Manager straight away.
6. Do not detain an individual by physical means. You may ask them to wait with you whilst a colleague meets up with you.
7. Where a safeguarding incident occurs or is suspected ensure that at least one member of staff attending is the same gender as the child or adult at risk.
8. In the event that you discover a child under the influence of alcohol or other substance report this to your Supervisor.
9. Do not give sweets or gifts, however small or insignificant to you, to any child or adult at risk you have contact with whilst acting for the Club. Your actions could be misunderstood and you are not helping the child or vulnerable adult to develop a healthy awareness of individuals not known to them.
10. If a child or adult at risk becomes tactile with you (e.g. holds your hand, tries to sit on your lap or cuddle you,) in the gentlest manner possible ask them not to. It is acceptable to say something along the lines of ‘we don’t know one another well enough to be that friendly’ or ‘it is important for you to stay with your daddy/mummy’ or ‘I’d rather you sit next to me than on my lap then we can both see what the others are doing’. When greeting a child or adult at risk for the first time it is acceptable to shake their hand.
11. If a child or adult at risk is distressed, crying or frightened it is important not to try to cuddle or draw them to your body. You may be trying to comfort as you would your own family, but they are not and you do not know what your action will mean to them. Approach and ask them quietly but audibly, if they can tell you what is wrong, as you want to help. Should they lean in to you or attempt to cuddle you then squat down to their level, ask if you can put one arm around the top of their shoulders (not across their back) as they seem very sad. Do not place the other arm across the front in a full embrace. Care must be taken not to impose the supporting adult’s need to comfort and make them feel better. In all circumstances, situations of this nature must be reported to a Manager and the Safeguarding Services Manager in order that a record can be kept.
12. You must not accept social invitations to any event from a child, adult at risk or their family where you have met them through your role with the Club. In some rare situations this might be appropriate, but, in all circumstances this must have been agreed with the Safeguarding Services Manager prior to the contact taking place.
13. You must not take photographs and/or use images for personal use of any child, adult at risk or their family where you have met them through your role with the Club. If asked by the family to take a photograph of them with their camera then this is permitted.
14. You should not encourage children or adults at risk to tell you their secrets, nor must you tell them any – even nice ones about parties or presents.
15. You should not attempt to engage children or adults at risk in conversation about their feelings e.g. whether they have a boy/girlfriend (irrespective of their age or for fun) and do not whisper things that any adult within close proximity could not hear.
16. You should not promise to get access to or an autograph from a player, manager or other prominent figure. If the opportunity presents itself for a child or adult at risk to be given appropriate access to such an individual then it should be encouraged but no personal credit should be taken for it actually happening.
17. You must not accept gifts from children, adults at risk or their designated carer (this includes money). If they want to show their appreciation of the time you have given them then ask them to send you a picture they have drawn or a painting of the Club’s mascot. Should you receive any such token then make the Safeguarding Services Manager aware so this can be noted and should reference in the future be made to it, it will be deemed to be common knowledge.
18. Be aware of the language, tone and manner of delivery of instructions being given. At no time should you use language that could be considered offensive, obscene or profane around children or adults at risk. Remember that some ‘common usage’ words are inappropriate around vulnerable groups. Also, bear in mind religious and cultural sensitivities. If you do use such language then you should apologise immediately for it and explain that adults should not speak like that. If an adult confronts you, having heard you using poor language, you should accept that you did, adopting the same approach by way of apology.
19. Should you become annoyed, angry or in any way disgruntled you must ensure that this is not evident to a child or adult at risk in your vicinity, whether they have contributed to your state or not. You must distance yourself from the cause of your ill feeling and regain composure as quickly as possible. If taking this action would mean leaving a colleague alone with a child or adult at risk you should instead move to the periphery of the group / individuals to compose yourself.
20. If you see a colleague beginning to become unsettled, and you are not the cause of this, you should suggest they take time out. You must ensure this does not mean you are left alone with any child or adult at risk. Commenting that they seem disgruntled can restore the equilibrium. If you are in some way the cause for their feelings then seek the intervention of a supervisor or third party to assist you both.
21. You must never physically or verbally chastise a child or adult at risk. You must engage the parent/guardian or designated carer who is responsible for them and request they take suitable action for the behaviour that has occurred. In doing so, you should not suggest or permit physical chastisement and, wherever possible, you should promote them discussing the problem that has arisen and its appropriate resolution in private away from the main group. Should the designated adult become verbally or physically aggressive with you, the child or adult at risk then immediate assistance should be sought. In all circumstances you must do everything possible to prevent the child or adult at risk being hurt.
22. If the activity you are engaged in involves changing clothing, then the supervision of changing must be with the assistance of their parent, guardian or designated carer and never with your direct involvement. A private area must be available for them to change in privacy; children and adults at risk should not be made to change en mass in an area not designated for changing. You must not be present in the private area used for changing. No other adult, including individual parents or carers, should be in this general area whilst changing occurs unless a specific individual requires that level of attention. The removal of tracksuits pitch side is exempt from this protocol.
23. If the activity you are involved in requires climbing on to equipment or some similar action, you should not handle a child or adult at risk without first ascertaining they want/need your assistance or that the designated carer cannot undertake the task and has asked you or verbalised they are happy for you to do so.
24. Physical contact with children or adults at risk should be avoided. If this cannot be avoided and they have to be lifted then have as little physical contact with their body as possible. Place your hands as carefully as possible on the outside part of the torso, well below the armpits at a line with the waist. If it is a female then you must take particular care not to place any part of your hand near or on the chest area.
25. You must not arrive for work under the influence of alcohol or any other substance and do not consume alcohol or use any other illegal substance during your shift.
26. Ensure that you know how to contact your Supervisor in an emergency including reporting a missing/lost child or adult at risk.
27. You must wear your Club uniform where one has been provided and any identification that you have been issued with at all times.