ECDP Safeguarding Policy

Read/download a PDF version of this policy here: ECDP Safeguarding Policy (PDF 192kb)

Contents

• Safeguarding Officers
• Policy Statement
• Definitions
• Legal Framework
• Recruitment and Training
• Definitions of ‘Abuse’
• Procedures for In-person Activity
• Procedures for Online Activity
• Film, Audio and Photography
• Disclosure and Reporting
• Policy Change Record
• APPENDIX ONE: Safeguarding Incident Report Form

Safeguarding Officers

ECDP Trustee Safeguarding Officer:
Jo Webb | ECDP Trustee | jowebb@essex.ac.uk

ECDP Lead Safeguarding Officer:
Indi Sandhu | ECDP CEO and Creative Director | indi.sandhu@essexcdp.com

ECDP Online Safeguarding Officer:
Jo Nancarrow | ECDP Digital and Admin Lead (Freelance) | jo@essexcdp.com | 07952 563451

Policy Statement

Essex Cultural Diversity Project is committed to creating and maintaining safe environments and accepts its responsibility to safeguard the welfare of all children, young people and vulnerable adults we work with. ECDP believes that everyone, regardless of age, culture, disability, gender, language, racial origin, religious belief and/or sexual identity has at all times in all situations a right to feel safe and protected from any situation or practice which results in them being physically or psychologically damaged.

This policy applies to anyone working on behalf of ECDP including Trustees, employees, freelancers and volunteers, who have a duty of care to safeguard from harm all children, young people and vulnerable adults that access the activities we deliver.

The purpose of this Policy is to:

a) protect children, young people and vulnerable adults we work with from harm.
b) provide ECDP Trustees, employees, freelancers and volunteers with the overarching principles and procedures that guide our approach to safeguarding.

ECDP will meet its commitment to safeguard children, young people and vulnerable adults through the following means:

• Awareness Ensuring all Trustees, employees, freelancers and volunteers are aware of the problem of abuse and risks to children, young people and vulnerable adults
• Prevention Ensuring, through awareness and good practice, that staff and others minimise the risk to children, young people and vulnerable adults
• Reporting Ensuring that Trustees, employees, freelancers and volunteers are clear what steps to take where concerns arise regarding the safety of children, young people and vulnerable adults
• Responding Ensuring that Trustees, employees, freelancers and volunteers are clear what steps to take where concerns arise regarding the safety of children, young people and vulnerable adults

For all ECDP activities, risk assessments will be written for individual projects or events where appropriate, which will include all risks related to Safeguarding children, young people and vulnerable adults, and ways in which ECDP will mitigate the risks.

Definitions

For the purpose of this policy and these procedures:

Children and Young People are any persons under the age of 18 years

Adult is anyone over the age of 18 years

Vulnerable adult is an individual aged 18 years or over who is considered at risk or vulnerable who

a) has need of community care and support because of mental or physical disability, age or illness
b) is experiencing, or is at risk of, abuse and/or neglect
c) as a result of those care and support needs, is unable to protect themselves from either the risk of, or the experience of, abuse and/or neglect

ECDP Activity: As part of its regular programme, ECDP provides in-person and online activities for various audiences, which often includes children, young people and vulnerable adults. Such activity is:

a) organised and coordinated by employees/freelancers contracted by ECDP
b) organised and coordinated by ECDP’s programming partners and creative collaborators
c) facilitated by external freelance creative practitioners who have been invited or contracted by ECDP to deliver a commission, project or event, as part of its programme

Legal Framework

This policy is underpinned and informed by the following legislation, policy, resources and guidance:

NSPCC: Guide to Child Protection in England
https://learning.nspcc.org.uk/child-protection-system/england

Recruitment and Training

ECDP will appoint individuals with the appropriate experience and skills to provide a safe and positive experience for children, young people and vulnerable adults with whom it is working. ECDP has recruitment procedures which:

• Require identity checks and Enhanced Disclosure and Barring Service (DBS) checks for all employees and freelancers in the core team before they are appointed to undertake unsupervised work with children, young people and vulnerable adults
• Review the employee / freelancer / creative practitioner’s experience, training and qualifications to make sure it is adequate and relevant.

Trustees, employees, freelancers working with us regularly will receive guidance and training to ensure they are aware of their professional responsibilities when working with children, young people and vulnerable adults, and are familiar with the procedures they need to take to create and maintain safe working environments, as well as inform them of the appropriate and relevant disclosure and reporting procedures.

Definitions of ‘Abuse’

‘Abuse’ can be defined as any form of physical, emotional or sexual mistreatment or lack of care that can lead to injury or harm. It commonly occurs within relationships of trust or responsibility and represents an abuse of power and/or a breach of trust. Abuse can happen to a child, young person or vulnerable adult regardless of their age, gender, disability or race.

Physical Abuse
This can involve hitting, spitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm. It also includes Munchausen Syndrome by proxy, whereby a parent/ carer feigns the symptoms of, or deliberately causes, ill health in a child/vulnerable adult.

Emotional Abuse
Persistent emotional maltreatment, which is likely to cause serious severe and persistent adverse effects on a child’s emotional development or harm and distress to a vulnerable adult. It may involve conveying to an individual that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond the child’s developmental, as well as overprotection or limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the maltreatment of another. It may involve serious bullying causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.

Sexual Abuse
This involves forcing or enticing a child/vulnerable adult to take part in sexual activities, whether or not they are aware of what is happening. It may involve physical contact, penetrative or non-penetrative acts. It may also involve non-contact activities, such as involving children or vulnerable adults in looking at, or in the production of, pornographic material or watching sexual activities, or encouraging children or vulnerable adults to behave in sexually inappropriate ways.

Physical and Emotional Neglect
The persistent failure to meet basic physical and/or physiological needs, which is likely to result in serious impairment to health or development. This may include the failure of the parent/carer to supply food, shelter or clothing or a failure to protect from physical or emotional harm and danger, or allow access to medical care or treatment. It may also include neglect of, or unresponsiveness to basic emotional needs.

Signs and Indicators of Abuse

a) Unexplained or untreated bruising or injuries
b) Suffering continual stomach pains or other physical ailments without any medical explanation
c) Aggressive or withdrawn behaviour and refusal to talk about injuries
d) Unexpected fear of an adult and flinching when touched
e) Sexually explicit behaviour and language
f) Unaccounted for sources of money
g) Fear of going home to parents or carers or of them being contacted
h) Changes over time in manner and appearance such as losing weight, becoming dirty and dishevelled, being constantly tired and always hungry
i) Telling staff about being asked to ‘keep a secret’ or dropping other hints or clues about abuse

Bullying

For the purposes of all ECDP activities and this policy, we regard bullying as exposing any person, regardless of age or background, to repeated negative actions on the part of one or more persons. Any interaction that is of a negative nature is unwelcome and will be treated as bullying, and investigated and addressed as such.

ECDP is fully committed to opposing oppressive, abusive or inappropriate behaviour, regardless of whether it is incidental or intentional. Any ‘bullying’ behaviour, however casual and minimal it may be, will be challenged by ECDP staff and may result in disciplinary action.

Bullying can include:
a) teasing and name calling
b) threats and physical violence
c) damage to property
d) leaving someone out of social activities deliberately
e) spreading rumours
f) upsetting mobile phone, email or internet messages / comments

Procedures for In-person Activity

Below are some guidelines for Trustees, employees, freelancers and volunteers undertaking work with children, young people and vulnerable adults, in-person and face-to-face (i.e. live events rather than online activity).

Duty of care:

a) All activities are planned in close consultation with the host venue, taking their safeguarding policies and procedures into account, whether this is a school, college, arts venue, museum, theatre, community venue, hired or other space.
b) When working in schools or community venues, a support worker, teacher or supervisor must be present and available for support at all times.
c) For public events, i.e. those outside of a school, college or community venue, all children and young people must be accompanied by a parent or guardian. This should be a stipulation upon booking, or for drop in events, made clear to all when they join the activity.
d) When supervising an activity, event organisers and facilitators must ensure that the activity, equipment, and working environment is safe and appropriate for the group.
e) Children, young people and vulnerable adults will not use mobile phones or the internet during sessions without appropriate supervision and guidance. In the event that internet use is required, it must be closely supervised.
f) In the event of a child, young person or vulnerable adult absenting themselves or wandering off during a session, you should immediately notify the relevant person in authority at the school, college or community venue, or the parent or guardian accompanying the child, young person or vulnerable adult.

Openness

a) Avoid situations where you are working alone with a child, young person or vulnerable adult, completely unobserved.
b) Always ensure that the relevant school workers, teachers, supervisors, parent or guardian are present throughout your session, and ensure this is communicated to them at the planning stages and/or at the start and throughout of the activity.
c) Do not share any personal contact details with a child, young person or vulnerable adult.

Physical Contact

a) Any form of physical punishment of a child, young person or vulnerable adult is strictly forbidden.
b) Do not engage in unnecessary physical contact, especially that which could be open to misinterpretation.
c) If physical contact is absolutely necessary (such as physically directing an individual in a drama, art or dance session) where possible you should explain your actions and the reasons for the actions before any contact is made. Permission must also be obtained from the individual before any contact is made.

Personal Care

a) If a child, young person or vulnerable adult requires help with toileting, do not offer or undertake this yourself under any circumstances, instead request the assistance of the relevant person who cares for their personal needs – i.e. teacher, supervisor, support worker, parent or guardian.
b) ECDP workers and facilitators should use the staff/visitor toilet facilities when working in schools or colleges. If this is not possible they should ensure that children and young people are not present.

Behaviour and code of conduct

a) Positive behaviour should be praised and criticism should always be constructive.
b) Be a positive role model with regards to friendliness, care, courtesy and valuing others.
c) Do not make sexually suggestive comments.
d) If a child, young person or vulnerable adult makes an approach towards you of a sexual or provocative nature during your work, then sensitively discourage this action. Report any instances to the relevant person in authority at the school, college, community venue or host organisation, and discuss this with your line manager or designated member of staff, who will report the concern to one of the named Safeguarding Officers listed at the start of this document.
e) If you accidently hurt, distress or offend a young person or vulnerable adult, notify the relevant person in authority at the school, college, community venue or host organisation, complete an incident form, and notify your line manager, designated member of staff, who will report the concern to one of the named Safeguarding Officers listed at the start of this document.

Procedures for Online Activity

We believe and recognise that online activity can provide many opportunities and benefits; positive connectivity can create and strengthen a sense of community, allow people to share their achievements with others, and access mutual support that can improve mental health and wellbeing. However, we acknowledge that it can also present risks and challenges, and we have a responsibility to help keep children, young people and vulnerable adults safe online, whether or not they are using ECDP’s networks and devices.

Online risks include (but are not limited to): cyber bullying, exposure to inappropriate and/or explicit content, security breaches which could result in personal data being shared, contact with and/or grooming by those wishing to physically or psychologically harm, abuse or bully the child, young person or vulnerable adult.

Anyone involved in organising and running ECDP’s activities has a responsibility to ensure the safety and wellbeing of children, young people and vulnerable adults when using the internet, social media, mobile devices or participating in online events. Below are some guidelines for Trustees, employees, freelancers and volunteers undertaking work online with children, young people and vulnerable adults.

General Guidelines

a) ECDP will designate at least one member of their Trustee/employee/freelance team as an Online Safety Coordinator, named at the start of this document, who has access to all ECDP online platforms
b) All ECDP Trustees, employees and freelancers will review and update the security of their IT equipment, communications, information and filing systems regularly to avoid security breaches, such as keeping anti-virus software up-to-date, and downloading the latest Zoom updates, especially those with improved safety features
c) Usernames, logins, and passwords must be kept secure and used effectively
d) All personal information, especially about those participating in our activity, should only be collected, processed and stored with the data subject’s consent, stored securely, and used only for the purpose for which the consent has been given
e) ECDP will examine and risk assess any social media platforms, software and new technologies before they are used within the organisation
f) All ECDP Trustees, employees and freelancers will regularly review content on ECDP’s social media platforms, and remove any content, comments or posts which they deem inappropriate, offensive or harmful to others, either directly or via the Online Safety Coordinator.

Behaviour and code of conduct
All Trustees, employees, freelancers and volunteers should:

a) be aware of their digital footprint; funders, creative, and community partners, participants and audiences – which includes children, young people and vulnerable adults – may look up the personal social media accounts of those representing the organisation. Publicly available information about you should be accurate and appropriate, and social media accounts should be free of inappropriate, potentially offensive or harmful content, and not provide any personal information such as personal email addresses or phone numbers
b) remember online conversations may be referred to as ‘chat’ but should be treated as public shareable content and in some cases written documents
c) not accept friend requests on their personal social media accounts from children, young people, vulnerable adults and families they have met at work, or work / have worked with
d) not use personal email accounts to communicate with children, young people, vulnerable adults and families they have met at work, or work / have worked with
e) not give any personal information to participants – this includes personal websites or social networking accounts

Online meetings and events

a) if a person under the age of 18 participates in an online meeting and/or event, ECDP will ensure that their camera and microphone are kept off, and that there is a parent/guardian supervising them at their end
b) If a person under the age of 18 needs to be seen, heard and/or recorded during an online meeting or event – i.e. as a workshop participant or a guest speaker – ECDP will seek written permission from their parent/guardian
c) Any ECDP Trustees, employees, freelancers and volunteers organising an online meeting or event involving children, young people or vulnerable adults, must consult with the Online Safeguarding Officer in advance (i.e. before scheduling and promoting the event), to assess risks, received advice and guidance re safeguarding, and to run through procedures for running safe events online.

Online activity at in-person activities and events

a) children, young people and vulnerable adults will be expected to turn off mobile phones when participating in in-person ECDP activity
b) any computer or online based activities will be supervised closely by staff and volunteers
c) participants will not use social media sites without supervision during sessions, work experience or other interactions, and any incidents of cyberbullying or inappropriate content will be discussed with the person and their parent/guardian.

Film, Audio and Photography

Documentation and recording through photography, audio and film are a major part of ECDP’s activity, such as the recording of commissions, workshops, projects and events, and programmes in the ECDP TV and ECDP Radio series. All Trustees, employees, freelancers and volunteers should follow the following guidelines – this applies to internal film, audio and photography undertaken by core staff, as well as freelancers contracted by ECDP, and applies to informal as well as formal film, audio and photography.

a) All audiences and participants will be informed that the activity is being recorded, and of how the recording will be used. Notices should be clearly written and placed in highly visible locations. Where possible notice should also be given in advance on booking or on agreeing to participate (such as for workshops or events with reserved spaces); and verbally by the event host / speakers (such as at meetings, presentations and seminars, on and offline).
b) Where possible, activity organisers and facilitators will introduce the photographer(s) / filmmaker(s) / audio recorder to the entire group and explain their role.
c) All audiences and participants will be given the option to opt out of being recorded, and any requests to not be recorded will be strictly adhered to.
d) Full parental/guardian written consent must be sought for any photographic, audio or film work which includes the images and/or voice of children, young people and vulnerable adults. Vulnerable adults may be able to sign their own consent form. This will be reviewed on an individual basis.
e) Any external photographers/filmmakers/audio recorders or invited press must be clear about ECDP expectations of them in relation to safeguarding. When contracting external filmmakers, audio recorders and photographers, ECDP will provide a clear brief, and will include what is considered appropriate in terms of content and behaviour, including a copy of this Safeguarding Policy.
f) ECDP will not allow unsupervised access to participants or one-to-one unsupervised photo/film sessions.
g) Photographic and recording equipment including mobile phones is forbidden under all circumstances in any private, changing or toilet areas.
h) ECDP will not publicly use personal information – such as the full name and an address where an individual could be found – in a film, photograph, audio recording or other recording, including film credits, unless agreed with the individual.
i) ECDP will only use images of participants in suitable dress to reduce the risk of inappropriate use.
j) Photographic, audio or video material will be securely stored.
k) ECDP Trustees, employees, freelancers, volunteers and contractors will not use their personal cameras or mobile phones to film, record or photograph children, young people or vulnerable adults taking part in ECDP’s activities.
l) ECDP Trustees, employees, freelancers, volunteers will not post any film, audio recording or photography containing children, young people or vulnerable adults taking part in ECDP’s activities to personal online accounts, including personal social media accounts or websites.

Disclosure and Reporting

If a Trustee, employee, freelancer or volunteer has any concerns about safeguarding, they need to discuss their concern either with one of the Safeguarding Officers listed at the start of this Policy, or with their line manager or designated member of staff, who will report the incident to the Safeguarding Officer. This can be done verbally, or via a Safeguarding Incident Report Form (see Appendix One).

The Safeguarding Officer(s) will investigate and appraise the matter to determine what steps should be taken, following the guidelines as laid out by Essex County Council at https://www.essex.gov.uk/report-a-concern-about-a-child

What to do if you have concerns about a child, young person or vulnerable adult in your care and/or attending an ECDP activity:

It is not your responsibility to investigate or decide whether or not a child, young person or vulnerable adult has been abused. It is, however, everyone’s responsibility to respond to and report concerns.

You may have concerns about a child, young person or vulnerable adult because of something you have seen or heard, or they may choose to disclose something to you. If they disclose information to you, you should follow the following guidelines:

a) Agree to help the person who wants to share the information with you.
b) Do not promise confidentiality, you have a duty to share this information with the appropriate Officers and/or authorities.
c) Listen to what is being said, without displaying shock, anger, panic or disbelief. Do not make judgements.
d) Accept what is said.
e) Reassure the person that you are pleased that they shared this with you.
f) Reassure the child, but only as far as is honest, don’t make promises you may not be able to keep eg: ‘Everything will be alright now’, ‘You’ll never have to see that person again’.
g) Do reassure and alleviate guilt, if the child refers to it. For example, you could say, ‘You’re not to blame’.
h) Do not interrogate the child; it is not your responsibility to investigate.
i) Do not ask leading questions (eg: Did he touch your private parts?), ask open questions such as ‘Anything else to tell me?’
j) Do not ask the child to repeat the information for another member of staff.
k) Explain what you have to do next and who you have to talk to.
l) Take notes if possible or write up your conversation as soon as possible afterwards.
m) Record the date, time, place any non-verbal behaviour and the words used by the child (do not paraphrase).
n) Record statements and observable things rather than interpretations or assumptions.
o) If the alleged abuse has taken place during the ECDP activity, remove the alleged person from activity immediately. Reassure them that this removal does not imply any guilt, but it is to protect them as much as the person making the allegation.

Whatever the nature of your concerns, discuss and report them immediately with the relevant responsible adult at the host venue, to your line manager or to a designated member of staff, who will report the concern to one of the named Safeguarding Officers listed at the start of this document.

If you are concerned someone is in immediate danger, contact the police on 999 straight away. Where you suspect that a crime is being committed, you must involve the police.

Allegations Involving an ECDP employee or representative

When working unsupervised with children, young people and vulnerable adults, ECDP is committed to having effective recruitment and human resources procedures, including checking all Trustees, employees, freelancers and volunteers to make sure they are safe to work with children, young people and vulnerable adults in. However, there may still be occasions when there is an allegation against a Trustee, employee, freelancer or volunteer. Allegations against those who work with children, young people and vulnerable adults, whether in a paid or unpaid capacity, cover a wide range of circumstances.

All allegations of abuse must be taken seriously. All reports of allegations must be submitted within one working day to one of ECDP’s Safeguarding Officer(s), either verbally or using the Safeguarding Incident Report Form (see Appendix One).

The following procedure should be applied in all situations where it is alleged that a person who has:

a) Behaved in a way which has or may have harmed a child, young person or vulnerable adult.
b) Possibly committed a criminal offence against or related to a child, young person or vulnerable adult.
c) Behaved in a way which indicates that he/she/they are unsuitable to work with children, young person or vulnerable adult.

The allegations may relate to the person’s behaviour at work, at home or in another setting. The Safeguarding Officer will investigate and appraise the matter to determine what steps should be taken and where necessary obtain further details of the allegation and the circumstances in which it was made. The discussion should also consider whether there is evidence/information that establishes that the allegation is false or unfounded, whether a referral to Essex County Council’s Safeguarding Team is required and/or whether disciplinary action is appropriate.

Some allegations will be so serious as to require immediate referral to the Local Authority and the Police, but common sense and judgement must be applied in reaching a decision about what action to take.

If the allegation is not patently false and there is cause to suspect that a child, young person or vulnerable adult is suffering or is likely to suffer significant harm, the Safeguarding Officer will immediately refer the matter to the Local Authority.

Some allegations may be less serious and at first sight might not seem to warrant consideration of a police investigation or enquiries by the Local Authority. However, it is important to ensure that even apparently less serious allegations are followed up and examined objectively by someone independent of the organisation. Consequently the Safeguarding Officer should be informed of all allegations that come to ECDP’s attention and appear to come within the scope of this procedure so that he or she can consult Police and any social care colleagues as appropriate.

Where such allegations are made, consideration will given to the following three strands:

a) The police investigation of a possible criminal offence;
b) Enquiries and assessment by the Local Authority as to whether the child or young person is need of protection or in need of services;
c) Consideration by an employer of disciplinary action in respect of the individual.

Policy Change Record

• March 2022 – Drafted to replace original ECDP Safeguarding Policy
• May 2022 – Discussed with key members in Core Team and ECDP Trustees
• May 2022 – Approved by ECDP Trustees at ECDP AGM

APPENDIX ONE: Safeguarding Incident Report Form

A copy of this document will be help by ECDP but the Lead Safeguarding Officer in a secure and confidential file.

Read/download a PDF version of this policy here: ECDP Safeguarding Policy (PDF 192kb)