Crystal Palace Community Trust (CPCT) believes it is always unacceptable for a child young person or vulnerable adult to experience abuse of any kind and recognises its responsibility to safeguard welfare by a commitment to practice which protects them. We recognise that the welfare of the child/young person & vulnerable adult is paramount and that everyone, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation, or identity, has the right to equal protection from all types of harm or abuse. Working in partnership with children, young people, their parents, carers and other agencies is essential in promoting people’s welfare.

The purpose of the policy is:

To provide protection for the children, young people & vulnerable Adults who receive CPCT’s services, including the children of adult members or users.
To provide staff and volunteers with guidance on procedures they should adopt if they suspect a child or young person may be experiencing/be at risk of harm.

This policy applies to all staff, senior managers and Trustees, paid staff, volunteers and sessional workers, agency staff, students or anyone working on behalf of CPCT

Crystal Palace Community Trust Safeguarding lead officers:

The Safeguarding Lead is Elaine Harrison, Trust Development Manager development@cpct.org.uk

The Deputy Safeguarding Lead is James Harrison-Sears, Youth Work Manager youth@cpct.org.uk

We will seek to safeguard children and young people by:

Valuing them, listening to and respecting them
Adopting child protection guidelines, procedures and a code of conduct for staff and volunteers
Providing early help by understanding risk factors
Considering risks outside the home (extra-familial harm)
Recruiting staff and volunteers safely, ensuring all necessary checks are made
Sharing information about child protection and good practice with children, parents, staff and volunteers
Sharing information about concerns with agencies who need to know and involving parents and children appropriately.
Developing and maintaining strong multi-agency relationships that can offer tailored support, collaborate and learn, and provide mutual challenge.
Providing effective management for staff and volunteers through supervision, support and training. Direct practice accordingly.

The Trust’s Safeguarding Policy draws upon the guidance contained in The Children’s Act 1989 & 2004 and “Working Together 2018”. The Care Act 2014 and the Safeguarding Disabled Children 2009. This policy will be subject to review according to legal modifications. Additionally, advice can be sought through the Local Authority Safeguarding Children Board. Furthermore, this policy is also underpinned by our confidentiality policy which lays out the general principles and operational issues regarding confidentiality.

We are committed to reviewing our policy and practice regularly.

Procedures

The role of all member agencies in safeguarding children & vulnerable adults who may require child protection & social services service is to identify who may be at risk and alert the appropriate service.

All staff in member agencies must ensure that they know the child protection procedures in force within the establishment and which staff member is responsible for child protection issues.

In some cases advice can be first sought from the Designated or Named person responsible for child protection support within CPCT, Elaine Harrison is the lead designated person and in her absence, James Harrison-Sears is the deputy. This should not preclude a direct referral to Children’s Social Care particularly if there is any element of immediate risk.

Referrals must always be made to the Social Services duty team if there are signs that a child under the age of 18 years, or an unborn baby (in the case of a teenage parent):

Is suffering or has suffered abuse and/or neglect, Is likely to suffer abuse and/or neglect (With agreement of a person with parental responsibility) would be likely to benefit from family support services.

The designated or named person in CPCT will support you in contacting the Social Services duty team. They will be familiar with the procedure and will be able to advise you. The timing of referrals must reflect the perceived risk and should normally be within one working day of recognition. If, for any reason, you cannot contact the designated or named person in your agency you should go ahead and contact Children’s Social Care.

When a referral is made to the Social Services duty team you must agree with them what the young person and parents will be told, by whom and when. Do not just leave messages. Always speak to someone. You must confirm verbal and telephone referrals in writing, within 48 hours. Any Common Assessment Framework (CAF) undertaken should be attached to the referral. Children’s Social Care should acknowledge your written referral within one working day of receiving it. Should you not have had a response within 3 working days, contact them again.

Under no circumstances should you speak to or confront the abuser. Do not share suspicions or information with any person other than your line manager, Social Services duty team or the police. Information given to Social Services or the Police will be taken seriously, handled sensitively and shared only on a ‘need to know’ basis wholly to protect the child. However, in order to ensure that children are safeguarded based on proper evidence, the source of the referral cannot be kept anonymous.

Acting on Concerns Regarding an Adult’s Behaviour

If you have any concerns about an adult’s behaviour towards children or young people (not an employee or volunteer working for the agency):

Do not ignore it – the service will take any concerns very seriously.
You must discuss your concerns with the designated person in your agency, who will support you in liaising with statutory agencies should any child protection matter arise.
Do not confront the adult – Seek the advice of the Designated person. If they are not available seek advice from your line manager or Children’s Social Care.

Dealing with Allegations or concerns against any Employee or Volunteer Working for your Agency

Concerns for the safety and well-being of children could arise in many different ways and in a range of settings.

It is essential to act quickly and effectively if an allegation is made, or if there is suspicion or concern about a professional or volunteer’s relationship with a child, young person or group of children/young people, particularly if they have:

Behaved in a way that has harmed, or may have harmed, a child;
Possibly committed a criminal offence against or related to, a child; or
Behaved towards a child/children in a way that indicates she/he is unsuitable
If an allegation is made, or a concern arises, about a member of staff or volunteer, ensure the Named person in your agency is informed immediately.

Records should be secured will be strictly limited to relevant staff and external professionals on a need-to-know basis.

The member of staff or volunteer should be treated fairly and honestly and helped to understand the concerns expressed, the process being followed and any outcomes.

Guidance in responding to a Disclosure.

If someone tells you that they, or someone they know, is being abused:

Believe what the person is saying and take it seriously.
Reassure the person who has made the disclosure they have done the right thing.
Give the child or adult time to talk and do not probe or ask leading questions. Investigation is not your responsibility.
Do not promise to keep secrets. All allegations of harm or potential harm must be acted upon.
Explain to the child or adult that you will share this information with a senior member of staff who will ensure the appropriate procedures will be followed.
E-mails or text messages received containing details of suspected abuse should be immediately responded to within 24 hours by contacting the young person by phone or face-to-face to obtain further information.
Record the event following member agency procedure.
All allegations, even those that appear less serious, need to be followed up and examined objectively by someone independent of the organisation concerned. All allegations will be considered by the Local Authority Designated Officer.
Advice on the storage of all documentation must be sought from your line manager who must ensure access is strictly limited to relevant staff and external professionals on a need-to-know basis. GDPR Information may be added here

Staff Conduct: SAFE WORKING PRACTICE

It is essential all staff, are conscious of how they conduct themselves to minimise the risk of finding themselves the subject of any child protection processes. All staff should be aware of the following things to do and not to do when working with children.

“DO’s”

Read and follow the child protection procedures
Report to the designated person any concerns about child welfare/safety
Report to the designated person any concerns about the conduct of other staff/volunteers/contractors
Record in writing all relevant incidents.
Work in an open and transparent way
Discuss and report any incidents of concern that might lead to concerns being raised about your conduct towards a child.
Report to the designated person any incidents that suggest a pupil (if this is a young person) may be infatuated with or taking an above-normal interest in you.
Dress appropriately for your role
Only use e-mail contact with pupils via any authorised system
Avoid unnecessary physical contact with children
Ensure you understand the rules concerning physical restraint
Where physical contact is essential for educational or safety reasons, gain permission for that contact wherever possible. Make sure someone else is present.
Allow children to change clothes with levels of respect and privacy appropriate to their age, gender, culture, and circumstances.
Avoid working in one-to-one situations with children
Avoid volunteering to house children overnight.
Ensure that during courses/activities run by CPCT or within Anerley Town Hall permission has been sought for photographs to be taken of children and young people for promotional purposes e.g. in social media and hard copy promotional materials. Be careful about recording images of children and do this only when an approved activity. You will need the child’s, and the parent's consent and need to make clear the purpose of the recording and how it will be stored
Fully co-operate with any investigation into child protection issues at CPCT.
Listen to pupils when they express concern (rumours) about the staff which might appear to be just and check facts v fiction

“DON’T’s”

Take any action that would lead a reasonable person to question your motivation and/or intentions
Misuse in any way your position of power and influence over children
Use any confidential information about a child to intimidate, humiliate or embarrass a child
Engage in activities outside of the workplace that might compromise your position with children or young people.
Establish or seek to establish social contact with pupils outside the workplace or setting
Accept regular gifts from children or give personal gifts to children
Communicate with pupils in inappropriate ways, including personal e-mails and mobile telephones.
Pass your home address, phone number, e-mail address or other personal details to children or young people.
Make physical contact secretive
Arrange to meet with pupils in closed rooms without other staff being made aware of this in advance.
Use physical punishment of any kind
Confer special attention to one child unless this is part of an agreed plan or policy
Transport pupils in your vehicle without prior management approval
Take, publish or share images of pupils or other children without their parents’ permission.
Access abuse images (sometimes referred to as child pornography) or other inappropriate material
Abuse your position of trust with children or young people
Allow boundaries to be unsafe in more informal settings such as trips out
Additional Help and Information
Early Help System Guide 2022
New Guidance on Safeguarding 2023:
Working Together to Safeguard Children

Appendix One:

Dealing with Concerns or Allegations against a Young person

Abuse by children and young people includes any abusive behaviour committed by a child or young person towards any other person, whether child or adult.
Work with young people who abuse should recognise that, whilst they may present a risk of Significant Harm to others, they are likely to have considerable needs themselves.
Such children are likely to be Children in Need and some will be at risk of, or suffering, Significant Harm.
Children and young people who abuse others should be held responsible for their abusive behaviour, whilst being responded to in a way that meets their needs as well as protects others.
It is possible that the child with the identified harmful behaviour may pose a significant risk of harm to their siblings, other children and/or adults.
This is a complex area of work where expert advice must be sought.
Reference should also be made to procedures for vulnerable adults if an adult has been abused by a child or young person.

If an allegation is made, or a concern arises about a young person

Ensure that the Named person in your agency is informed immediately. Followed by a written account of the concern.
Records should be secured and will be strictly limited to relevant staff and external professionals on a need-to-know basis.
The young person should be treated fairly and honestly and helped to understand the concerns expressed, the process being followed and any outcomes.

TYPES OF ABUSE ARE SIMILAR FOR YOUNG PEOPLE AS FOR ADULTS.

Additional Types of abuse or neglect

Particular issues for older people

Perpetrators of abuse or neglect are often people trusted and relied on by an older person, such as family members or care staff.

Safeguarding is not limited to situations where there is a breach of trust, it includes situations such as the risk of exposure to scams. It is important to be aware that anyone can commit abuse or neglect.

Financial abuse

Includes having money or property stolen, being defrauded or ‘scammed’, being put under pressure in relation to money or other property, or having money or other property misused. Things to look out for include changes in living conditions, lack of heating, clothing or food, inability to pay bills or unexplained money shortages. Other indicators include unexplained withdrawals from an account, unexplained loss of or misplaced financial documents, the recent addition of authorised signers on a signature card, or sudden or unexpected changes in a will or other financial documents.

There may, of course, be other explanations for any of these indicators.

If you are concerned about financial abuse by an attorney or a court-appointed deputy for someone who lacks mental capacity, contact the safeguarding team of the Office of the Public Guardian.

Psychological abuse

Includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, and harassment. Also includes verbal abuse, cyberbullying, isolation, and unreasonable and unjustified withdrawal of services or support networks.

Discriminatory abuse

Includes harassment, slurs or similar treatment because of race, gender and gender identity, age, disability, sexual orientation, or religion. These are ‘protected characteristics’ under the Equality Act 2010.

Modern slavery

Includes slavery, human trafficking, forced labour and domestic servitude.

Organisational abuse

Includes neglect and poor care practice within an institution or specific care setting or in relation to care provided in a person’s own home. This may range from one-off incidents to ongoing ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes and practices within an organisation.

Neglect and acts of omission

Includes ignoring medical, emotional or physical care needs; failing to provide access to appropriate health or care and support; or withholding the necessities of life, such as medication, nutrition and heating. Withholding access to assistive equipment like hearing aids, walking aids, or dentures may be neglect but can indicate coercive control.

Domestic abuse

Includes violence, psychological, sexual, financial, and emotional abuse and patterns of coercive and controlling behaviour during a relationship between intimate partners, former partners who still live together, or family members, and honour-based violence. Threats to family pets or other family members can be a form of domestic abuse.

Self-neglect

This covers a wide range of behaviours which shows that someone isn’t caring for their own personal hygiene, health or surroundings. It includes behaviour such as hoarding.

Unaccompanied Children in Public Settings

There will be situations when young children visit public settings unaccompanied by their parents or carers. Whilst not wishing to discourage children from visiting places such as libraries, information centres and play or educational facilities, staff need to take reasonable steps to ensure the safety of the child and to inform parents/carers of their responsibilities. The way in which staff deal with unaccompanied children must be based on awareness of the responsibility of the parent or the Loco Parentis Carer (i.e., the one taking the responsibility of the parent), and the duty of care the service to all children on the premises. In no instance would staff be expected to take on parental responsibilities for children in these settings.

A suitable notice should be clearly displayed, and staff should point to this poster when appropriate especially if parents/carers are about to leave their children on the premises. For example:

Try to establish if the child is allowed by the parent /carer to come and go alone.
If you are satisfied the child is allowed to come and go alone, allow the child to leave. If you gather this information only from the child, use your judgment to ascertain whether the child is competent to leave alone.

Relevant factors may be:

Whether the child exhibits signs of nervousness
Whether the child appears to clearly understand your questions
Whether the child seems physically capable
Whether the child appears to know clearly and readily where he or she lives
How far the journey is
Whether you know of any particular hazards on the journey
The child’s age and vulnerability

If you are in doubt, encourage the child to remain on the premises until you have been able to contact a parent or carer. Children under 10 years should not normally be allowed to leave alone unless you know that the parent/carer allows it.

Ask the child if s/he is expecting to be collected by an adult. Even if the child is expecting to be collected soon, do not wait until closing time before taking the next step. Try to contact the parent or carer. Ask the child for an address or telephone number.

Appendix two: Safer workforce

1) Training

All staff must ensure they attend child protection training in accordance with the requirements and standards of CPCT. Training will be organised and delivered in accordance with the requirements of 'Working Together to Safeguard Children (2018)'.

2) Safer Workforce & Recruitment and Selection

Advertisement of posts and application packs should make explicit reference to the commitment of the organisation to Safeguarding, including:

Compliance with Vetting & Barring regulations
Clear statements in the Job Description and Person Specification that explicitly reference the individual’s safeguarding responsibilities
Providing information about Safeguarding Policy and Practices to applicants.

The selection process should:

Comply with vetting & Barring regulations
Always use application forms (CVs should not be accepted)
A minimum of two people should check for any gaps in employment history and explore these gaps during the interview.
Ensure at least one reference is from a previous employer and specifically ask if there have been any concerns or allegations about the applicant's behaviour towards children; any disciplinary action; and confirmation of the applicant’s responsibilities.
Compare this information with that provided by the applicant. Any inconsistencies or concerns regarding the information provided in a personal reference must be followed up directly with the referee
Ensure that any concerns arising from the applicant’s medical references are followed up directly with the applicant and with the employing agency’s medical adviser. Seek to explore the applicant's attitudes towards children and young people, their motivation for pursuing the role, and managing boundaries, at the interview.
Always ensure that any other uncertainty or inconsistency about the information provided about the applicant is followed up and resolved.

If you need support with the process, seek advice on recruitment and selection from your HR advisors.

Confidentiality

CPCT recognises that colleagues (Employees, Volunteers, Trustees and Secondees) gain information about individuals and organisations during the course of their work or activities. In most cases, such information will not be stated as confidential, and colleagues may have to exercise common sense and discretion in identifying whether information is expected to be confidential.
Colleagues can share information with their line manager to discuss issues and seek advice.
Colleagues should avoid exchanging personal information or comments (gossip) about individuals with whom they have a professional relationship.
It is not appropriate to discuss a person’s sexuality (i.e. ‘outing’ a gay person) without their prior consent.
Colleagues should avoid talking about organisations or individuals in social settings.
Colleagues will not disclose to anyone, other than their line manager, any information considered sensitive, personal, financial or private without the knowledge or consent of the individual, or an officer, in the case of an organisation.

There may be circumstances where colleagues want to discuss difficult situations to gain a wider perspective on how to approach a problem. The organisation’s consent must be sought before discussing the situation unless the colleague is convinced beyond doubt that the organisation would not object to this. Alternatively, a discussion may take place with names or identifying information remaining confidential. Where there is a legal duty to disclose information, the person to whom the confidentiality is owed will be informed that disclosure has or will be made.

Appendix Three: Information sharing

The LADO (Local Authority Designated Officer) process is concerned with managing allegations of abuse. The LADO has the responsibility to manage and have oversight of allegations against people who work with children. The designated person will contact the LADO and a decision will be made as to whether a referral to the Police or Social Services should be made or whether a LADO safeguarding meeting should be held Any information shared with other professionals will adhere to the protocols within this process including only sharing information within closed meetings and ensuring any documentary information is password protected to prevent unauthorised access.

Relevant telephones numbers

Police: call 999 in an emergency, otherwise call Bromley Police Community Safety Unit: Telephone: 020 8284 8760
For older people or those with learning disabilities or physical disabilities If this is your first contact with Social Services OR you already receive services and your circumstances change OR there is an emergency your first point of contact will be the front-line contact service
(Bromley Social Services Direct) on 020 8461 7777 Minicom: 020 8464 7350. Assistance is available on this number from 8.30 am to 5.30 pm.
Adults under 65 with mental health problems Penge Telephone: 020 8659 2151
Out of Hours Contact Emergency Duty Social Worker: 020 8464 4848

Southwark Adult Social Care team on 020 7525 3324 (Lines are open Monday to Friday 9 am to 5 pm) For out-of-hours enquiries, call the council switchboard on 020 7525 5000 and choose the appropriate option.
Email the Access and Information team with your enquiry: ops@southwark.gov.uk London Borough of Southwark, 132 Queens Road, London

Commission for Social Care Inspection (CSCI)website (www.csci.org.uk)
Area Office Telephone: 020 8308 3520

Independent advocacy organisations:

Bromley Victim support: (www.victimsupport.org.uk) 020 8776 7071
Bexley and Bromley Advocacy (www.bbadvocacy.org) 020 8468 1096
Bromley Advocacy Alliance: 0345 310 1812
Bromley Age Concern: (www.acbromley.org.uk) 020 8315 1850
Action on Elder Abuse National Response Line: website (www.elderabuse.org.uk) 080 8808 8141
Carers Bromley: website (www.carersbromley.org.uk) 0800 0157700
Respond helpline for people with learning disabilities: website (www.respond.org.uk) 0808 808 0700

Please reference London Child Protection Procedures updated March 2019

Crystal Palace Community Trust Safeguarding Policy update – Zoom – April 2020

The restrictions put in place to manage the coronavirus outbreak have made Zoom an important tool for business continuity, and a sense of connection between members of staff.

It is important that CPCT responds to the restrictions in an agile way, and this may include the use of Zoom as the most effective tool to continue conversations and interactions with children and young people, and with staff who are categorised as vulnerable adults. Extra thought and appropriate procedures are in place to ensure the safeguarding of children and vulnerable adults whilst using Zoom as a tool for work at the Unicorn. A consent form or emailed consent should be acquired from a parent or guardian for a child to take part in a Zoom conversation. During the consent process, we will remind them that recording and screenshots are not permitted.

We cannot guarantee that other participants will not use other software or devices to record or screenshot. Reassure them that within Zoom, only the host can record the meeting, and they will not unless express permission has been obtained. They should consider what’s in the background of their frame – check there is no personal data visible, and choose a neutral background, ideally in a communal space in the home, with a parent or guardian sharing the space. Dress and manner should be reasonable and appropriate for a workplace conversation.

Meetings including children should only be hosted by CPCT staff members who are Zoom Licenced Users and who hold an Enhanced DBS check
Meeting invitations should only be sent via email, and not posted on social networks or other websites.
Meetings should need a password. If a participant manually enters the meeting/webinar ID, they will be prompted to enter the password (since early April, this has become a default setting on Zoom).
For any meeting including children or vulnerable adults, the following should be set by the host as the meeting begins:
The ability for participants to message privately should be disabled.
The ability for participants to rename their display names should be disabled. First names only should be used as display names.
Screensharing should be disabled.
The Waiting Room function should be enabled (any new participant trying to enter the meeting is assessed by the host).
The host should Lock the meeting once all expected attendees are present.
The host should know how to Remove Participants immediately.

Like many workplaces and educational environments, CPCT is learning about the interface between Safeguarding best practices and video conferencing as we go. The Safeguarding Lead has met with key staff to discuss best practices and agree on this update to CPCT’s Safeguarding Policy, but we understand this will need to come under regular review as we learn more about technologies, and the possible risks involved.

Appendix Four: Crystal Palace Community Trust Safeguarding Policy update – online

The restrictions put in place to manage the coronavirus outbreak have made online communications an important tool for business continuity, and a sense of connection between members of staff.

It is important that CPCT responds to the restrictions in an agile way, and this may include the use of online meetings as the most effective tool to continue conversations and interactions with children and young people, and with staff who are categorised as vulnerable adults. Extra thought and appropriate procedures are in place to ensure the safeguarding of children and vulnerable adults whilst using Zoom as a tool for work for CPCT.

A consent form or emailed consent should be acquired from a parent or guardian for a child to take part in an online conversation. During the consent process, we will remind them that:
Recording and screenshots are not permitted.
We cannot guarantee other participants will not use other software or devices to record or screenshot. Reassure them that within meetings, only the host can record the meeting, and they will not unless express permission has been obtained.
They should consider what’s in the background of their frame – check there is no personal data visible, and choose a neutral background, ideally in a communal space in the home, with a parent or guardian sharing the space.
Dress and manner should be reasonable and appropriate

Any meeting which includes children or vulnerable adults should not be recorded, except with the express consent of the parent or guardian of every child or vulnerable adult. This should be made clear to everyone taking part in the meeting, as other software or devices could be used by participants to record or screenshot the meeting. Zoom meetings are for group conversations with children and vulnerable adults. Zoom will not be used by CPCT for a one-to-one conversation between an adult and a child, or for one adult to speak to a group of children. As with in-person workshops, there should always be more than one responsible adult in the conversation. The children’s video can be on if they choose and have the facilities – this improves a sense of connection and balances the conversation between children and adults. Children are not engaging to be lectured at, and CPCT is not a schoolroom. We will encourage children and vulnerable adults to frame themselves with a neutral background, and check to see that no personal data is visible in their background. Children will be encouraged to join the conversation in a neutral, communal space (ideally not their bedroom), and parents/guardians will be encouraged to be in the same room. Meetings including children should only be hosted by CPCT staff members who are Licenced Users and who hold an Enhanced DBS check. Meeting invitations should only be sent via email, not posted on social networks/websites Meetings should need a password. If a participant manually enters the meeting/webinar ID, they will be prompted to enter the password For any meeting including children or vulnerable adults, the following should be set by the host as the meeting begins:

The ability for participants to message privately should be disabled.
The ability for participants to rename their display names should be disabled. First names only should be used as display names.
Screensharing should be disabled.
The Waiting Room function should be enabled (any new participant trying to enter the meeting is assessed by the host).
The host should Lock the meeting once all expected attendees are present.
The host should know how to Remove Participants immediately.