Safeguarding Policy

system · 6 July 2022 13:01

1. General

1.1 Introduction

The Ferret (TF) carries out activities that may bring our staff into limited contact with children or vulnerable adults. TF is committed to creating and maintaining the safest possible environment for any children and vulnerable adults we work with as journalists and ensuring all reasonable steps are taken to prevent them from harm.

This policy applies to all members of staff whose duties bring them into contact with children or vulnerable adults. The term ‘staff’ in this policy relates to all employees, freelancers, contract and seasonal staff, volunteers, mentors and students involved in The Ferret in any capacity and in any setting. Failure to comply with this policy may result in disciplinary action for employees and termination of their employment contract.

1.2 Legal considerations

TF will take into consideration all current and future legislation applying to this area and update this policy as needed.

1.3 Definitions

A “child” is a person who is yet to reach their 18th birthday. A “vulnerable adult” is a person aged 18 years or over who is unable to take care of themselves or to protect themselves from exploitation and may include the elderly or frail, those with learning disabilities, people who suffer from mental illness, people who have a physical disability, a substance misuser, people who are homeless or in an abusive relationship. An adult may become vulnerable, or stop being vulnerable, during the time in which they are involved with The Ferret.

1.4 Confidentiality

All information regarding children or vulnerable adults is highly confidential and should be treated as such at all times. Any relevant information that needs to be kept on file will be securely stored with access limited and should be shared only within appropriate professional contexts and in accordance with law. Please refer to TF’s Privacy Policy for further guidance.

1.5 Staff Training

All staff at The Ferret will be made aware of this policy. The Ferret also recognises its responsibility to invest in training for staff that work with children and vulnerable adults on a regular basis to give them the confidence and skills to safeguard children and vulnerable adults. Where appropriate, disclosure checks will be undertaken before commencing any at risk activities.

1.6 Designated Safeguarding Leads

The Designated Safeguarding Lead has responsibility for:

Acting as the main contact within TF for the protection of children and vulnerable adults.
Providing information and advice to TF staff on the protection of children and vulnerable adults.
Supporting and raising awareness of this policy and related procedures.
Ensuring all relevant information under this Policy is communicated to all relevant people.
Keeping abreast of developments and understanding the latest information on data protection, confidentiality and other legal issues that impact on the protection of children and vulnerable adults.
Where necessary, establishing and maintaining contact with local statutory agencies including the police and social services.
Working to maintain confidential records of reported cases and actions taken, and liaising with the relevant statutory agencies to ensure they have access to all necessary information.
Taking the lead with specific allegations where there are suspicions of abuse, harm or neglect of a child or vulnerable adult.

Designated Safeguarding Lead Contact Details

Craig Campbell

Tel: 07915 557837

Email: craig@theferret.scot

2. Induction & Responsibility of Directors

2.1 Induction

Newly appointed staff should be made aware of TF’s Safeguarding Policy. They should also be made aware of the members of staff with safeguarding responsibilities.

2.2 Directors

Directors have a collective responsibility to ensure that safeguarding is prioritised within the organisation. Directors must maintain a risk register which includes safeguarding risks and actions taken to mitigate those risks as far as reasonably possible. The risk register should form a standing item at each directors’ meeting.

3. Code of Behaviour

This behaviour code outlines the conduct expected of staff from The Ferret and staff from other organisations who engage with children and young people through The Ferret and its activities.

3.1 Purpose

Following this code will help protect children and vulnerable adults from abuse and inappropriate behaviour. It will also help staff maintain the standard of behaviour expected of them and will reduce the possibility of unfounded allegations of abuse being made against them.

3.2 Upholding this code of behaviour

All staff are expected to report any breaches of this code to the Designated Safeguarding Lead under the whistle-blowing procedure.

Staff who breach this code of behaviour may be subject to disciplinary procedures. Any breach of the code involving a volunteer or member of staff from another agency may result in them being asked to cease working with The Ferret.

Serious breaches may also result in a referral being made to a statutory agency such as the police, the local authority children’s social care department and/or the Independent Safeguarding Authority.

3.3 The role of staff

When working with children and vulnerable adults for The Ferret, all staff are acting in a position of trust. It is important that staff are aware that they may be seen as role models by children, young people and vulnerable adults, and must act in an appropriate manner at all times.

3.4 Communication

Communication with children and young people is vital in establishing relationships built on trust. Those working with children and vulnerable adults should listen to what they are saying, and respond appropriately. Children and vulnerable adults are entitled to the same respect as staff. TF encourages staff to demonstrate the standards of communication listed below:

Listen to and respect children and vulnerable adults at all times
Avoid favouritism
Treat everyone fairly without prejudice or discrimination. Refer to TF’s Equality & Diversity Policy for further guidance.
Value and take participants’ contributions seriously, actively involve children and vulnerable adults in planning activities wherever possible
Always ensure language is appropriate and not offensive or discriminatory
Provide examples of good conduct
Recognise that special caution is required when discussing sensitive issues with children or vulnerable adults

Staff members must not:

Patronise or treat children and vulnerable adults as if they are silly.
Cause distress by shouting or using derogatory names.
Make sarcastic, insensitive, derogatory or sexually suggestive comments or gestures to or in front of children and vulnerable adults.
Make inappropriate promises to children and vulnerable adults, particularly in relation to confidentiality.
Act in a way that can be perceived as threatening or intrusive.
Smoke, drink alcohol or use offensive language directly in the presence of a child or vulnerable adult.
Discuss inappropriate aspects of their personal life.

3.5 Contact outside of work

Contact should not be made with any of the children or vulnerable adults with whom TF is working for any reason unrelated to the particular project and social or other non-work related arrangements should not be entered into with them.

3.6 Social Networking and e-safety

TF recognises that its staff use the Internet outside of the work environment for various reasons and would like to remind staff of how to promote e-safety by:

Supporting and encouraging everyone to use the opportunities offered by mobile phone technology and the Internet in a way that keeps themselves safe and shows respect for others.
Ensuring that user names, logins and passwords are used appropriately and safely.
Using only official email accounts and phone numbers provided via The Ferret, and monitoring these as necessary.
Personal contact details should never be provided to children aged under 18 – only work contact details should be used.
When emailing a child aged under 18, ensure that another staff member is also copied into the email, and that the parent or carer of the child under 18 is aware that this communication is taking place.
When phoning or conducting a digital meeting with a child under 18, ensure that someone else is always present in the same room.
Ensuring that images of children, young people and families are used only after their written permission has been obtained, and only for the purpose for which consent has been given. No details which could identify a child aged under 18 should be included when images or videos are shared publicly (e.g. only their first name and not surname should be used).
If someone shares content on their private personal social media account, this should not be shared more widely without the consent of the individual and (if they are a child aged under 18) their parent or carer.
Not engaging on any social media platform with somebody who does not meet the age requirement for that particular platform.
Staff should use their professional judgment in assessing the suitability of social media tools to be used in the course of TF’s work with children and vulnerable adults.
If Internet access is required as part of the work, staff are asked to ensure that steps are taken to protect children from accessing inappropriate web content,
Not initiating contact with a child or vulnerable adult using social media
Not sharing personal information with children or vulnerable adults through webcam, photographs, blogs etc.
Not encouraging or pressuring others into sharing images, videos, or details online, whether as a private message or publicly.
Not sharing inappropriate material (e.g. pornography) and being careful when sharing material which discusses sensitive topics or could be perceived as offensive, harmful, or discriminatory.
Not sharing or asking for personal financial information unless it is through a secure channel for a necessary purpose such as claiming expenses.
When conducting remote meetings digitally (e.g. using Zoom), the same principles should be applied as detailed throughout this Policy, e.g. conducting the meeting in an appropriate space, not smoking or drinking alcohol on camera.

TF will deal firmly, fairly and decisively with any examples of inappropriate ICT use, complaints or allegations, whether by an adult or a child/vulnerable adult (this may include breaches of filtering, illegal use, cyberbullying, or use of ICT to groom a child or to perpetrate abuse).

3.7 Confidential information

Anyone who is likely to have access to confidential material regarding children, young people or vulnerable adults, or any of the agencies or organisations on behalf of whom The Ferret is working, is reminded that they have signed a non-disclosure agreement as part of their contract of employment.

4. Procedure for children and vulnerable adults at possible risk of abuse

This procedure applies to any member of staff who may be concerned about the safety and protection of a child or vulnerable adult.

4.1 Purpose

We aim to ensure that children or vulnerable adults who our journalists come into contact with receive the protection and support they need if they are at risk of abuse.

4.2 Dealing with incidents and suspicions of abuse

Staff members should report, record and inform the Designated Safeguarding Lead if the following occurs:

A child or vulnerable adult makes an abuse/harm/neglect disclosure (in this case refer to and inform the Designated Safeguarding Lead by telephone as soon as possible ensuring it is on the same day – see section 4.3 Dealing with abuse).
A staff member/another learner accidentally or deliberately hurts a child or vulnerable adult.
First aid is performed on a child or vulnerable adult.
A child or vulnerable adult seems very distressed.
A child or vulnerable adult significantly misunderstands or misinterprets something that a staff member/another child or vulnerable adult has said.
A child or vulnerable adult/staff member/volunteer is/appears to be sexually aroused by a staff member/volunteer/child or vulnerable adult.
A child or vulnerable adult is restrained in self-defence.

A full record should be made using the prescribed cause for concern form and reported to the Designated Safeguarding Lead. This should include information relating to the date, time and place where the incident happened, the staff member’s name and the names of any others present, the name of the complainant and where different the name of the child or vulnerable adult who has been involved in the incident, the nature of the incident and a description of any injuries observed.

It is NOT TF’s responsibility to investigate suspicions or decide whether abuse has taken place. TF’s role is to act if there is a cause for concern and to report it to the appropriate authority to investigate and take any necessary action.

Any allegations of abuse made against anyone working for The Ferret will be thoroughly investigated and dealt with through its disciplinary procedure. Serious breaches may lead to dismissal.

The Designated Safeguarding Lead will appropriately record an allegation or reported incident. He/she will be responsible for contacting the statutory child protection agency such as the Local Safeguarding Children Board or the police if necessary.

4.3 Dealing with Abuse

The 4 R’s are Recognise, Respond, Record and Refer. Whether the abuse occurs on The Ferret premises, in the home, or in any other setting (including digitally), the 4 R’s should be followed when dealing with the suspected abuse of children or vulnerable adults.

Recognise

The ability to recognise signs that might indicate abuse is of fundamental importance. Staff members should contact the Designated Safeguarding Lead immediately if they have any concerns about the following:

Excessive tiredness
Aggressive behaviour
Nervous behaviour
Bite or burn marks
Lack of confidence
Stealing food
Fear of making mistakes
Self-harm
Flinching
Sudden behaviour changes
Frequent absences
Sexualised language
Hinting at secrets
Fear of a specific individual

Respond

No report or concern about possible abuse should ever be ignored. In order to determine the most appropriate response, the context of the disclosure must be determined.

Information received about a child or vulnerable adult might fall into one of the categories below:

Suspicion/allegation of abuse, harm or neglect where an TF member of staff is the alleged perpetrator.
Suspicion/allegation of abuse, harm or neglect where a child, young person or vulnerable adult is the alleged perpetrator.
Suspicion or allegation of abuse, harm or neglect where a third party is the alleged perpetrator.
Suspicion/allegation of inappropriate conduct.

It is vital to listen carefully to any information that a child, young person or vulnerable adult discloses with reference to abuse, harm or neglect. If a child, young person or vulnerable adult chooses to disclose this information to a staff member, the staff member must make them aware that if it is concerning something which puts either the child, young person or vulnerable adult at harm or in danger, the staff member will have to tell the appropriate person.

Whilst listening, the following good practice is essential:

During the disclosure:

React calmly, try not to show disbelief or project other emotional reactions.
Demonstrate you are listening by demonstrating attentiveness and concern.
Don’t ask leading questions; instead ask by repeating back what the person has said in their own words.
Take all information given from the person seriously.
Tell the person that they are never to blame for abuse and that they have the right to tell somebody.
Reassure the person they have done the right thing in reporting their concerns, and state you will do everything you can to support them.

Do not:

Make unrealistic promises
Introduce personal information from your own experiences
Apportion blame or pass judgement
Guarantee confidentiality
Tell the person that ‘everything will be alright’

After the disclosure:

Tell the person sharing the disclosure the concern they have raised will be recorded and passed onto a limited ‘need-to-know’ basis.
Inform a Designated Safeguarding Lead immediately.
Make a full record of what has been said, heard or seen (please see the Record section below) – you can also conduct this while the disclosure is being made if appropriate and possible.
Ensure that the complainant and the subject of the allegation are treated in line with this policy.

Do not:

Verbally speculate about what might have happened, with anyone.
Approach an alleged abuser or make comments about him/her to the child or vulnerable adult.

Record

The staff member should report their concerns to the Designated Safeguarding Lead that working day. In the event this is not possible, they should report their concerns to their line manager. In all cases, the recipient of the report should, without delay and having carefully recorded the information, report this him/herself to the Designated Safeguarding Lead.

Once the staff member has reported concerns about the abuse to any of the colleagues mentioned above, the responsibility for taking any further decisions and/or actions resides with them. It is their responsibility to make further decisions. Once the staff member has spoken to a Designated Safeguarding Lead, they should make notes using the cause for concern form in Appendix 1.

Refer

This is the responsibility of a Designated Safeguarding Lead only – or of a member of the board in extenuating circumstances.

Please note: concerns should be discussed with the family unless:

The view is that a family member might be responsible for abusing a child or vulnerable adult.
Someone may be put in danger by the parents or carers being informed.
Informing the family might interfere with a criminal investigation.

If any of these circumstances apply, consult with the local authority children’s social care department, or adult services in the case of a vulnerable adult, to decide whether or not discussions with the family should take place.

The only agencies that can investigate child protection cases are the police, social services and the NSPCC.

4.4 Different Types of Abuse

Children and vulnerable adults may be vulnerable to neglect and abuse or exploitation from within their family and from individuals they come across in their day-to-day lives. These threats can take a variety of different forms, including: sexual, physical and emotional abuse; neglect; exploitation by criminal gangs and organised crime groups; trafficking; online abuse; sexual exploitation and the influences of extremism leading to radicalisation. Whatever the form of abuse or neglect, practitioners should put the needs of children first when determining what action to take.

The Ferret views the following as being the main categories of abuse:

Physical abuse

Is violence causing injury or occurring regularly. It happens when:

A child or vulnerable adult is hurt or injured by being hit, shaken, squeezed, thrown, burned, scalded, bitten or cut.
Someone tries to drown or suffocate a child or vulnerable adult.
Someone gives a child or vulnerable adult poison, alcohol or inappropriate drugs.
Someone fabricates the symptoms of, or deliberately induces, illness in a child or vulnerable adult.

In some cases the injuries will be caused deliberately. In others they may be accidental but caused by the child or vulnerable adult being at risk.

Sexual abuse

Occurs when someone uses power or control to involve a child or vulnerable adult in sexual activity in order to gratify the abuser’s own sexual, emotional or financial needs or desires. It may include:

Forcing or enticing a child or vulnerable adult to take part in sexual activities, whether or not the child or vulnerable adult is aware of what is happening.
Encouraging children or vulnerable adults to behave in sexually inappropriate ways.
Showing children or vulnerable adults pornographic material or involving them in the production of such material.
Involving children or vulnerable adults in watching other people’s sexual activity or in inappropriate discussions about sexual matters.

Emotional abuse

Is persistent or severe emotional ill-treatment of a child or vulnerable adult that is likely to cause serious harm to his/her development. It may include:

Persistently denying the child or vulnerable adult love and affection.
Regularly making the child or vulnerable adult feel frightened by shouts, threats or any other means.
Hurting another person or a pet in order to distress a child or vulnerable adult.
Being so overprotective towards the child or vulnerable adult that he/she is unable to develop or lead a normal life.
Exploiting or corrupting a child or vulnerable adult, e.g. by involving him/her in illegal behaviour.
Conveying to a child or vulnerable adult the message that he/she is worthless, unlovable, inadequate, or his/her only value is to meet the needs of another person. This may or may not include racist, homophobic or other forms of abuse.

Neglect

Involves persistently failing to meet a child’s or vulnerable adult’s physical, psychological or emotional needs. It may include:

Failing to ensure that a child’s or vulnerable adult’s basic needs for food, shelter, clothing, health care, hygiene and education are met.
Failing to provide appropriate supervision to keep a child or vulnerable adult out of danger. This includes lack of supervision of particular activities or leaving a child alone in the house.

4.5 Relationships and Sexual Abuse

The age of consent (the legal age to have sex) in the UK is 16 years old. The laws are there to protect children. They are not there to prosecute under-16s who have mutually consenting sexual activity but will be used if there is abuse or exploitation involved.

To help protect younger children, the law says anyone under the age of 13 can never legally give consent. This means that anyone engaging in sexual activity with a child who is 12 or younger will be subject to penalties set out under the Sexual Offences Act 2003.

The law also gives extra protection to young people who are 16 to 17 years old. It is illegal to:

Take, show or distribute indecent photographs.
Pay for or arrange sexual services.
For a person in a position of trust (for example TF staff) to engage in sexual activity with anyone under the age of 18.

Conducting a sexual relationship with a child or vulnerable adult or indulging in any form of sexual contact with a child or vulnerable adult using the services of The Ferret represents a serious breach of trust on the part of the staff member and is not acceptable under any circumstances.

If a child or vulnerable adult makes a comment about you being good-looking or seems to be expressing intent to initiate a relationship with you, immediately explain that this is an inappropriate conversation due to professional boundaries. Then inform your line manager/Designated Safeguarding Lead.
Be alert to the possibility of children or vulnerable adults being romantically/sexually attracted to you, and to your words and actions being misinterpreted.
If a child or vulnerable adult who is a friend or relative, or with whom you are in a romantic relationship, is due to join TF, inform your line manager or HR or a Designated Safeguarding Lead.

Members of staff must not:

Rely on their reputation or that of the organisation to protect them.
Develop inappropriate relationships such as contact with children or vulnerable adults that is not a part of the work of TF or agreed with the manager or leader of a youth organisation.
Allow or engage in inappropriate touching of any kind.
Allow or engage in sexually suggestive behaviour within a person’s sight or hearing, or make suggestive remarks to or within earshot.
Give or show anything that could be construed as pornographic.
Buy gifts which could be in any way considered as a bribe or inducement.
Socialise with or develop friendships with children or vulnerable adults.
Initiate romantic, sexual or emotionally dependent relationships with children or vulnerable adults.

5. Implementation, monitoring and review of this policy

The Ferret’s Chief Operating Officer and Chairperson has overall responsibility for implementing and monitoring this policy, which will be reviewed on a regular basis following its implementation and specifically whenever there are relevant changes in legislation or to TF’s working practices. Any queries or comments about this policy should be addressed to the Chief Operating Officer or Chairperson.

Exceptional Public Interest

This policy should be read as complementary to the Impress Standards Code, particularly clauses 3 and 4. The Impress Standards documents contain additional guidelines Ferret journalists must work to when working on stories that involve children or vulnerable adults. The Impress Standards code can be found at Standards | IMPRESS

These clauses attract an exceptional public interest qualification. Where it is considered that there is an overwhelming public interest in the act or publication then The Ferret will consider this against the harm any publication may cause. Any subsequent publication must be agreed by The Ferret’s Editorial Committee and one non-journalist director or the Chief Operating Officer.