Safeguarding policy and procedure

Scope and relevance

The Centre for Crime and Justice Studies (hereafter the Centre) is committed to providing the most effective and appropriate safeguarding arrangements in order to protect vulnerable adults and children from abuse or neglect while taking part in activities organised by the Centre.

It is important to consider from the outset the scope and relevance of the policy, defining what is meant by activities organised by the Centre, who is to be protected, and the nature of the abuse and/or neglect that should be reported.

What are activities organised by the Centre?

These include:

• Providing information
• Conducting research
• Organising events and online discussions
• Working with members and volunteers
• Dealing with service contractors (building maintenance, designers, IT services, etc.)

The scope of this policy covers activities which the Centre organises, and for which it takes responsibility, which may include partnership activities conducted with the agreement of other organisations (such as prison research or joint events). In the latter case, the Centre will seek to work with partners in order to confirm the existence and relevance of their policies and to coordinate action wherever possible.

Types of abuse and neglect

In the context of activities organised by the Centre, this might include:

• physical abuse
• domestic violence
• sexual abuse
• psychological abuse
• financial or material abuse
• modern slavery
• discriminatory abuse
• organisational abuse

Who does this policy seek to protect?

In addition to all children, a wide range of adults are defined in law as vulnerable:

• those in the custody or under the supervision of a criminal justice organization;
• those looked after by the local authority or a private or voluntary sector organization;
• those receiving assessment, treatment or care for health needs;
• the homeless;
• those who lack mental capacity;
• victims of modern slavery and trafficking;
• the disabled or those having frailties associated with age (see Part 1. Care Act 2014; Modern Slavery Act 2015; S. 59 Safeguarding Vulnerable Groups Act 2006).[1]

(See the Glossary of Terms for more legal and statutory explanations)

Policy development and purpose

This policy is designed to target effectively the main risks that are anticipated as having the potential to occur, arising from the current work and commitments of the Centre.

The Centre will seek advice from experienced and informed experts when planning how it will ensure that all connected with it understand and carry out the policy.

It will be modified and amended as necessary when new work is planned, especially work that brings the Centre into more frequent contact with a greater range of vulnerable groups.

The purpose of the policy is to:

• Provide trustees, staff and volunteers with guidance on the procedures they should adopt in the event that they suspect a vulnerable adult or child or young person taking part in activities organised by the Centre may be experiencing, or be at risk of, abuse or neglect from anyone connected with the Centre;
• Provide carers, parents and external parties with guidance on the disclosure and complaints procedure and timescale for response in the event that they suspect a vulnerable adult or child or young person may be experiencing, or be at risk of abuse or neglect while taking part in activities organised by the Centre;
• Provide managers with guidance on statutory personnel checks, how to minimize risks and deal with potential complaints;
• Provide guidance on dissemination, monitoring, confidentiality, secure storage and information sharing procedures.
• Support programme participants to understand and feel confident in the Centre’s policy and practice.

Overview of risks and plans for prevention

Risks in relation to members or volunteers

These risks are considered to be low. Members have limited contact with staff and vice versa. They have few organised opportunities to mingle among themselves or have contact with volunteers. There are no plans to recruit volunteers who are known to be vulnerable adults or children.

Should vulnerable adults or children be recruited as volunteers in the future, it will be made clear that they will be supervised by a member of staff trained to identify signs of abuse or neglect. Members and volunteers, as well as carers and parents, will be informed about the complaints system which facilitates reporting.

Contractor risks

These risks are considered to be low. The main contractors operate remotely or visit the Centre office for pre-arranged periods of time, for example, working on the building.

To help manage their contacts with contractors, staff will be given guidance on the signs of modern slavery and trafficking. They will be trained in the reporting and complaints procedure.

Risks to attenders at events

These risks are considered to be low. There are no plans to hold events that are intended to involve vulnerable adults or children. Arrangements for events that may hold considerable interest for any vulnerable group (such as prisoners on licence, care-leavers or young people with special needs) will be reviewed, so that attenders can be specifically informed about our safeguarding procedures. All personal information about attenders is kept confidential.

Staff with access to personal information about attenders are trained to ensure they maintain proper boundaries in their communications and conduct.

Risks to subjects taking part in online activities

The responsibilities of the Centre for online safeguarding are exercised within the context of social media regulation, which is known to be weak and inconsistent. Where the Centre undertakes social media activity, online community guidelines should be identified and adhered to, and there should be full compliance with any procedures for dealing with abusive activity.

Risks to the general public who contact the Centre

These risks are considered to be very low. Enquiries are dealt with by phone or email. Regular contact with the Centre can be sustained through our online bulletins.

We will treat all concerns made known to us with attention and respect. Where possible, we will advise enquirers with concerns which do not relate to activities organised by Centre, to approach appropriate safeguarding bodies instead.  A list of bodies will be made known to staff.

Risks to research subjects

These risks are considered to be low. Current projects are focused on secondary data analysis from public or specialized sources. Where access to public data that can potentially identify individuals is sought, this is only possible subject to the strict protocols of the UK Data Service. Research staff are required to follow procedures for safe storage and to avoid disclosing research information to anyone unauthorized.

All plans to conduct research that involves the collection and storage of personal information will be designed with appropriate safeguarding protocols. In the case of vulnerable children and adults in other settings, there will be safeguarding policies in place among schools, prisons, etc. that should be prioritised in the planning and conduct of projects.  Plans for such research projects should be devised with full awareness of the policies of partner organisations, and preparations should be made to fulfil those requirements, which may involve Disclosure and Barring Services (DBS) checks and compliance with other conditions, before any contact, whether supervised or supervised, with children or vulnerable adults is allowed. All individuals who participate will be briefed in the course of seeking informed consent to the research about the safeguarding arrangements so that the boundaries of research confidentiality are fully understood and accepted. As an additional protection, the Centre will normally seek to have such research plans scrutinized by an independent body which can provide a full ethical assessment and recommend any necessary safeguarding changes.

Research staff will be expected to report concerns to the Safeguarding staff member (see below) who will liaise as necessary with an appropriate safeguarding body. Statutory checks on staff or any volunteers may be made through DBS when frequent contact with vulnerable adults or children is expected to be part of the research role.

Guidelines for handling indications of possible abuse or neglect

As someone working on behalf of the Centre, a staff member may be alerted in several ways to possible abuse or neglect of a vulnerable adult or child taking part in an activity organised by the Centre.

• A carer or parent discloses information.
• A vulnerable adult or child discloses information or the staff member see signs of possible abuse or neglect.
• Information comes from another source, another adult or another child, a brother/sister or friend of the person in question.
• The staff member witnesses an incident that gives cause for concern.

What must the staff member do in such situations:

• If information is disclosed to you, give reassurance i.e. "it's good that you told me".
• If information is disclosed to you, do not question the individual other than to clarify what he/she has said (this can contaminate possible evidence).
• If a child/adult tells you something, you should NOT promise to keep it a secret. Explain to the individual that you will need to share the information and who you will tell.
• Record what the individual has said as soon as possible in an email or written report to the Director.
• Follow any procedures for reporting the concern set out by the agency responsible for the adult or young person (e.g. prison or school) as soon as possible.
• Share the information with the Centre’s Director (unless they are the subject of an allegation, in which case the Chair of Trustees should be contacted).
• Be mindful of confidentiality at all times and share information on a need to know basis only, always remembering that the child’s or vulnerable adult’s wellbeing is the primary concern.
• Information should always be taken seriously, regardless of its source.

Ways for the public to report incidents or concerns are as follows

• Giving a sealed written report to a member of the Centre’s staff. This should be given, unopened, to the Director who will take appropriate action and store it securely. Alternatively, the report can be posted directly to the Director at: Centre for Crime and Justice Studies, 2 Langley Lane, SW8 1GB, and mark it ‘Confidential’. The report can also be emailed to the Director: richard.garside@crimeandjustice.org.uk. It is recommended, although not essential, that they use ‘Centre for Crime and Justice Studies Safeguarding Report’ form for this purpose.
• If the Director is the subject of an allegation, a sealed written report should be given, unopened, to the Chair of Trustees who will take appropriate action and store it securely. Alternatively, the report can be posted directly to the Chair of Trustees at: Centre for Crime and Justice Studies, 2 Langley Lane, SW8 1GB, and mark it ‘Confidential’. The report can also be emailed to the Chair of Trustees: charlotte.weinberg@crimeandjustice.org.uk. It is recommended, although not essential, that they use ‘Centre for Crime and Justice Studies Safeguarding Report’ form for this purpose.
• Speaking confidentially to a member of the Centre’s staff, who will make a written report of the incident on their behalf. They will pass this on to the Director, who will take appropriate action and store it securely, or the Chair of Trustees if the Director is the subject of the allegation.
• Speaking to an external authority. So as to be able to advise a member of the public, the Centre’s staff should ensure that they are aware of the contact details of safeguarding authorities for any areas in which they are working with children or vulnerable adults.

While the opportunity to report concerns anonymously may encourage individuals to give information about issues that would otherwise go unreported, it is important to stress that the more information that is given, the easier it is address the concern.

Whistle-blowing

Concerns about the behaviour of another staff member or individual associated with the Centre with regard to safeguarding vulnerable adults or children, should not be kept to oneself. This policy is designed to support those with concerns to share that information as efficiently and easily as possible. A written record of concerns should be made and shared immediately with the Centre’s Director, or the Chair of Trustees if the concern relates to the Director.

It is the Director’s responsibility to treat all such allegations with appropriate concern and seriousness. The Director should reassure the individual that their concerns will be appropriately dealt with and shared with a trusted safeguarding body, if they so wish. If the Director is the subject of a report, the Chair of Trustees should communicate with the individual in the same manner before having any contact with the Director to discuss the matter. Any staff member or individual about whom concerns have been voiced should have their contact with any vulnerable adult or children restricted until an investigation has been completed, and the appropriate outside authorities should be notified immediately about significant concerns , always keeping in mind the confidentiality and welfare of any adult or child involved.

Staff responsibilities

These reporting procedures are mandatory and failure to follow these procedures may result in disciplinary action. It is each individual’s responsibility to ensure that they are fully aware of the procedures as outlined in this policy and of the procedures of any external organisations with whom they are working.

The Director with HR oversight will be responsible for the Safeguarding policy. This is currently Roger Grimshaw.

It is their job to:

• Ensure that staff are aware of, and have access to, the Centre’s Safeguarding Policy.
• Ensure that the policy is updated annually and in line with any new recommendations or changes in legislation.
• Ensure that a list of appropriate safeguarding bodies is updated annually, and the Safe Guarding Staff Member and other staff have access to that information in a clear format

The Director of the Centre will be the designated Safeguarding staff member. This is currently Richard Garside.

It is their job to:

• Ensure that these procedures, and where necessary disciplinary action, are implemented
• Assess information promptly and thoroughly, clarifying by obtaining further information where appropriate
• Ensure that confidentiality is prioritized and all records stored securely
• Notify the relevant statutory bodies in the event of a concern or incident, when this has not already been undertaken by an external organisation with which the Centre is working.
• Ensure that where members of the public who have submitted a Safeguarding Report have given their contact details and their concern is acknowledged within 14 days.

Staff recruitment and checks

In cases where frequent contact with vulnerable adults or children is expected as part of the staff role, the appropriate statutory checks will be made after a job offer has been accepted or, if the staff member is already in place, at an appropriate stage before any such work is undertaken. We will not discriminate unfairly on the basis of past convictions that may be disclosed but instead consider all the relevant evidence as it affects safeguarding.

Photography and the use of images

There are no plans to carry out photographic activity with vulnerable adults or children. Any photographic activity with adults or children should be subject to the written consent of parents, carers and children, as appropriate. It should be conducted with awareness of legal obligations to avoid any intrusion and indecency. Website images will be monitored to ensure that they comply with these standards.

Any complaints or concerns about inappropriate or intrusive images should be recorded and reported in line with the procedure laid out in this policy.

Glossary of terms

Abuse

The Care and Support statutory guidance identifies ten types of abuse²[2], these are:

• Physical abuse
• Domestic violence or abuse
• Sexual abuse
• Psychological or emotional abuse
• Financial or material abuse
• Modern slavery
• Discriminatory abuse
• Organisational or institutional abuse
• Neglect or acts of omission
• Self-neglect

Children may be subject to:

• Physical abuse
• Emotional abuse
• Neglect
• Sexual abuse

Child sexual exploitation consists of offences set out in the Sexual Offences Act 2003 as amended by the Serious Crime Act 2015. Prohibited acts refer to specific sexual contacts and communications including abuse of a position of trust, as well as child prostitution and pornography. The Protection of Children Act 1978 and the Criminal Justice Act 1998 prohibit making and possessing indecent images of children.