Safeguarding and Participant Safety

1 Purpose

This policy establishes the public safeguarding standards applied by BE(YOU)FULL CIC across its programmes, mentoring, education, workshops, events, research, partnerships, communications and digital activity.

Its purpose is to prevent avoidable harm, support early identification of concerns and ensure that concerns are reported and addressed through appropriate safeguarding channels.

2 Who the policy protects

This policy applies to the safety and welfare of:

• children and young people under the age of 18;
• adults who may have care and support needs and may be unable to protect themselves from abuse or neglect;
• programme applicants and participants;
• parents, guardians and family members involved in an activity; and
• other people affected by BE(YOU)FULL CIC activity.

3 Who must follow the policy

This policy applies to:

• directors and workers;
• mentors, coaches and facilitators;
• contractors and consultants;
• volunteers and placement participants;
• researchers and evaluators;
• delivery partners; and
• anyone representing BE(YOU)FULL CIC or participating in delivery on its behalf.

4 Safeguarding principles

• The welfare, dignity and best interests of participants are central to decision-making.
• Children and adults at risk should be listened to and taken seriously.
• Safeguarding is everyone’s responsibility.
• Concerns should be identified and reported promptly.
• Responses should be proportionate, lawful and centred on the person at risk.
• Discrimination, victimisation and retaliation are not tolerated.
• Information should be shared when necessary and lawful to prevent or respond to harm.

5 Safeguarding leadership

BE(YOU)FULL CIC maintains safeguarding oversight through its directors and an appointed Safeguarding Lead.

The Safeguarding Lead is responsible for:

• receiving and reviewing safeguarding concerns;
• determining whether external advice or referral is required;
• maintaining secure safeguarding records;
• supporting workers and delivery partners;
• monitoring training and procedural compliance;
• reviewing incidents, patterns and lessons; and
• escalating concerns to directors or external authorities where appropriate.

6 Safer recruitment and suitability

BE(YOU)FULL CIC applies proportionate recruitment and suitability measures according to the responsibilities, contact and risk associated with each role.

Measures may include:

• clear role descriptions and safeguarding expectations;
• identity and eligibility checks;
• interviews and relevant references;
• role-appropriate Disclosure and Barring Service checks where the role is legally eligible;
• barred-list checks where the legal conditions apply;
• verification of qualifications or professional status;
• safeguarding induction and continuing training; and
• probation, supervision and performance review.

7 Training and conduct

People involved in delivery must receive safeguarding information appropriate to their role and know:

• how to recognise possible abuse or neglect;
• how to respond to a disclosure;
• how and when to report a concern;
• how to maintain appropriate boundaries;
• how safeguarding records must be handled;
• what to do where the concern relates to another worker; and
• when emergency or statutory services must be contacted.

8 Partnerships and commissioned activity

Before delivering work with another organisation, the parties should establish:

• the applicable safeguarding policy and lead contacts;
• who receives and manages concerns;
• the referral and emergency arrangements;
• recruitment and suitability responsibilities;
• consent and participation arrangements;
• information-sharing responsibilities;
• venue, online and activity risk controls; and
• responsibility for allegations involving workers or volunteers.

When operating in a school, college or other regulated setting, BE(YOU)FULL personnel must also follow the host organisation’s safeguarding procedures.

9 Professional boundaries

Workers, mentors, facilitators and volunteers must maintain clear and appropriate professional boundaries.

They must not:

• establish secret, exploitative, sexual or inappropriate relationships with participants;
• use a position of trust for personal, financial, political or commercial advantage;
• engage in discriminatory, humiliating, threatening or degrading conduct;
• connect privately with children through personal social media accounts;
• communicate through concealed or unauthorised channels;
• promise absolute confidentiality;
• provide therapy, medical care or regulated advice unless specifically qualified and authorised; or
• invite a participant into a private personal arrangement outside the agreed programme.

10 One-to-one mentoring

One-to-one work must be planned and delivered through agreed organisational arrangements.

• Sessions should take place in an approved physical venue or authorised digital environment.
• The date, time, facilitator and intended purpose should be recorded.
• Appropriate parental, guardian, school or commissioning arrangements should be established where required.
• A responsible organisation or contact should know when the session is taking place.
• Communication should use approved professional channels.
• Concerns arising during a session must be recorded and reported.

11 Online activity

Online mentoring, workshops and meetings should use appropriate platforms, privacy settings and participant controls.

Depending on the activity, safeguards may include:

• approved organisational accounts;
• passwords, waiting rooms or controlled access;
• clear rules about recording and screenshots;
• appropriate involvement of a school, parent or responsible organisation;
• secure handling of chat, attendance or session records;
• procedures for disruption, harmful conduct or an online disclosure; and
• avoiding unnecessary display of personal surroundings or identifying information.

12 Photography, recording and public stories

Photographs, video, audio, testimonials and participant stories must not be captured or published without an appropriate lawful basis and the necessary permissions.

Participation in publicity should be voluntary. Refusal should not disadvantage a participant.

Images or stories must not reveal sensitive, unnecessary or identifying information that could expose a participant to avoidable risk.

13 Venues, travel and off-site activity

Activities should be subject to proportionate planning and risk assessment. Considerations may include:

• accessibility and participant support;
• supervision and staffing;
• arrival, departure and collection arrangements;
• emergency contacts and medical information;
• first aid and incident response;
• toilets, changing and private spaces;
• transport and insurance arrangements; and
• local or partner safeguarding and emergency procedures.

Workers must not provide private transport or make unapproved home visits without written authority, appropriate safeguards and agreed organisational arrangements.

14 Forms of harm

A safeguarding concern may relate to actual, suspected or emerging:

• physical abuse;
• sexual abuse, harassment or exploitation;
• emotional or psychological abuse;
• neglect or acts of omission;
• domestic abuse;
• online abuse or technology-facilitated harm;
• bullying, intimidation or discriminatory abuse;
• criminal or sexual exploitation;
• trafficking or modern slavery;
• radicalisation or extremist exploitation;
• financial or material abuse;
• organisational abuse;
• self-neglect;
• harmful practices; or
• conduct by a person in a position of trust that may place someone at risk.

A concern may arise from a disclosure, observation, behaviour, injury, communication, pattern of absence, online activity or information received from another person.

15 Responding to a disclosure

When a participant discloses a concern, the person receiving it should:

• remain calm and listen carefully;
• take the concern seriously;
• avoid expressing disbelief or blame;
• avoid leading questions, interrogation or investigating;
• explain that relevant information may need to be shared to help keep someone safe;
• record what was said accurately, using the person’s own words where possible;
• record the date, time, context and people present;
• report the matter promptly to the Safeguarding Lead; and
• contact emergency or statutory services directly where delay would increase risk.

16 Reporting and escalation

Concerns should be reported to the BE(YOU)FULL CIC Safeguarding Lead as soon as possible.

Depending on the circumstances, a referral or consultation may be made with:

• children’s social care;
• adult safeguarding services;
• a school or partner safeguarding lead;
• the police or emergency services;
• a Local Authority Designated Officer;
• the Disclosure and Barring Service;
• a regulator, commissioner or funder; or
• another authority with a lawful safeguarding role.

A person should escalate the concern externally where the internal route is unavailable, inappropriate, compromised or has not resulted in an adequate response.

17 Confidentiality

Safeguarding information is confidential, but confidentiality is not absolute.

Relevant information may be shared without consent where this is necessary and lawful to protect a child or adult at risk, prevent harm, comply with a legal obligation or support an authorised safeguarding process.

Information should be shared on a need-to-know basis with appropriate people. The reasons for sharing, or for deciding not to share, should be recorded.

18 Allegations and conduct concerns

A concern must be reported where a worker, mentor, facilitator, contractor, volunteer, director or other representative may have:

• harmed a child or adult at risk;
• possibly committed a criminal offence;
• behaved in a way indicating that they may pose a risk of harm;
• breached professional boundaries or the code of conduct;
• exploited a relationship of trust; or
• acted in a way that may make them unsuitable for relevant work.

The immediate priority is the safety and welfare of the participant. The concern should not be investigated informally by colleagues.

19 Reporting concerns about a worker

Report the matter immediately to the BE(YOU)FULL CIC Safeguarding Lead or the responsible senior person.

Where the concern relates to the Safeguarding Lead, a director or the person who normally receives reports, do not send the concern to that person. Contact an uninvolved director, the relevant partner organisation, children’s social care, adult safeguarding service, police or Local Authority Designated Officer as appropriate.

Allegations involving work with children may require prompt consultation or referral to the Local Authority Designated Officer for the authority in which the organisation or activity is based.

20 Fair process and protective action

Safeguarding concerns will be taken seriously while recognising the need for a fair, proportionate and confidential process.

Protective measures may include changes to duties, supervision, restricted contact, suspension or removal from activity while advice or investigation is obtained. Such action is precautionary and does not, by itself, determine guilt.

External reporting, regulatory notification or a DBS referral will be made where the applicable legal conditions are met.

21 Whistleblowing and retaliation

Workers, participants and partners should be able to raise a genuine safeguarding concern without intimidation, obstruction or retaliation.

Deliberately concealing a safeguarding concern, pressuring someone not to report, destroying relevant information or retaliating against a person who raises a concern may result in disciplinary, contractual or legal action.

22 Safeguarding records

Safeguarding records should be accurate, factual, dated, attributable and created as soon as reasonably possible after the concern or disclosure.

Records may include:

• the nature and source of the concern;
• the participant’s own words where relevant;
• observations distinguished from opinion;
• the people informed;
• decisions and the reasons for them;
• external advice, referrals or notifications;
• protective action taken; and
• follow-up and outcome information.

Safeguarding records should be kept securely, separately from routine programme notes where appropriate, and accessible only to authorised people.

23 Data protection and information sharing

Personal information used for safeguarding must be handled lawfully, fairly, securely and proportionately.

Data protection law does not prevent necessary safeguarding information sharing. Consent is not always the appropriate lawful basis and is not required in every safeguarding situation.

Decisions should consider:

• the purpose and urgency of sharing;
• the risk to the child or adult;
• the lawful basis and any additional condition;
• what information is relevant and necessary;
• who needs to receive it;
• the security of the transfer;
• whether the person can safely be informed about the sharing; and
• how the decision will be recorded.

Further information is provided in the BE(YOU)FULL CIC Privacy Notice .

24 Monitoring and learning

BE(YOU)FULL CIC will review safeguarding practice through appropriate monitoring of:

• incidents, concerns and referrals;
• complaints and allegations;
• training and recruitment records;
• programme and partnership feedback;
• risk assessments and delivery arrangements;
• changes in law and statutory guidance; and
• lessons arising from internal or external reviews.

Identifiable safeguarding information should not be used in public impact reporting unless there is a lawful basis and appropriate protection.

25 Policy review

This policy will be reviewed at least annually and earlier where required by:

• a safeguarding incident or learning review;
• a material change in programme delivery;
• a new partnership or participant group;
• a change in law or statutory guidance;
• a change in safeguarding leadership; or
• a significant organisational or technological change.

26 Contact

Contact the BE(YOU)FULL CIC Safeguarding Lead to report a concern or ask about this policy.