This Model Policy has been drawn up to help managements of children's and young people's play and leisure organisations when they are considering the detail of a Child Protection Policy. It is a Model, not a prescriptive instruction, so the idea is that it can be adapted to suit local needs and circumstances.
We welcome comments, suggestions, criticisms of this Model, so we can improve it.
In this Model Policy, the word "Project" can be subsituted by e.g. Charity, Association etc. The word "Management" can be "Executive Committee", "Board of Directors/Trustees" etc.
CONTENTS: [click on subjects below]
1.1 This Policy forms part of the Terms and Conditions of service, and applies to all activities of the Project where children and young people under 18 years of age are present, and to all working in such activities, whether as an employee, volunteer, management representative or otherwise.
2.1 The Objective of the Project's Child Protection Policy is to contribute to the personal safety of all children using the facilities and resources of the Project, through actively promoting awareness, good practice and sound procedures.
3.1 The Management shall appoint one of their number as Responsible Officer (RO) for all aspects of child protection awareness and implementation of this policy.
3.2 The RO will be responsible to the Management for:
a. ensuring that this policy is implemented throughout the Project's activities;
b. ensuring all necessary child protection-related enquiries, procedures and investigations are carried out;
c. reporting results of screening enquiries and for preserving a "need to know" levels of confidentiality and access to secure records;
d. ensuring secure and confidential records relating to child protection matters;
e. liaison with the senior staff member and session leaders to ensure implementation of the policy by all staff and volunteers;
f. liaison with social services at a formal and informal level on child protection matters, likewise with the police;
g. the reporting to all meetings of the Management on the implementation of this policy;
h. the reporting of allegations and suspicion of abuse to the appropriate authorities;
i. ensuring there is adequate induction and training relating to child protection matters;
j. ensuring that each activity carried out by the Project is sound in terms of child protection as regards personnel, practices, premises.
k. checking all incident reports made by staff and volunteers, countersigning them, and making such reference to authority as is appropriate, after consultation with the senior staff member etc as detailed below.
3.3 The Senior Staff Member (SSM) of the Project shall ensure active compliance with this policy by all working in the Project, and shall work closely with the RO to ensure this, affording the RO every assistance to this end. All other officers, staff and voluntary workers of the Project will actively endeavour to implement this policy.
4.1 The Project's aim is to ensure as far as is possible that anyone, paid or voluntary, who seeks to work with children and young people through the Project's activities and who gains substantial access to them thereby (whether within activity hours and/or beyond) is as safe to do so in child protection terms as can be guaranteed.
4.2 Therefore the RO will ensure that the following checks are carried out on all prospective directors, staff and volunteers whose work may create a situation of substantial access to children and young people:
a. criminal records check at enhanced level [via Fair Play for Children or other approved agency route] [give route];
b. questionnaire to the officer appointed by the local authority Social Services, in the approved format [if this route is available];
c. General Practitioner of the applicant;
d. personal referee, nominated by the applicant - a person who is not related to the applicant and who preferably knows of the applicant's character, trustworthiness, any previous experience of working with/looking after children and young people
4.3 The forms and formats to be used shall be in the general form as attached, and the written consent of the applicant must be obtained to enable such enquiries to be made. No application may proceed unless such consent is given by the applicant.
4.4 The enquiry forms and authorities will be completed at an interview with the applicant, by the RO in consultation with the SSM. The applicant may request this be done in confidence with only the RO present.
4.5 At the interview stage, the RO shall give to the applicant, and get the applicant to give written confirmation of receipt a letter/notice stating the checks are required as a condition of working in Project activities with children and young people.
4.6 No applicant may start sessions unsupervised without the above enquiries being completed, but the SSM may, in consultation with the RO, authorise an applicant to commence supervised (one-to-one basis) work where it is absolutely clear there will be no problems arising from the checks.
4.7 The RO shall be responsible for sending the enquiries to their destinations, under a strictly confidential heading in all cases, and shall ensure security of records.
4.8 The Project's policy is to recheck all trustees, staff and volunteers after three years service, in terms of police and social services. This will be undertaken by the RO in consultation with the SSM.
4.9 At all times the onus is on the applicant/employee/volunteer to reveal any conviction, caution, bind-over, probation order, or pending prosecution, whether imposed prior to or within the period the applicant works on Project activities.
4.10 The applicant shall produce proof of identity, preferably passport or photographic, and of residence, which checks the RO shall note as having been undertaken in the applicant's records.
4.11 The RO will not accept any previous reference, police check, social services endorsement etc provided by an applicant in substitution for the above enquiry process. At all times the initiative must lie with the Project to make its own, completely independent enquiries.
5.1 The RO will indicate to the SSM whether an applicant is suitable to work on Project activities, as revealed by the results of the checks at 4.2 a-d above.
5.2 Where a Schedule One offence is indicated by the above process, the RO must rule an applicant unsuitable, and that person must not undertake any form of work or help with the Project. If such an attempt is made by a convicted Schedule One Offender or by any person prohibited under legislation from working with children and young people or from being in proximity to places where they may gather etc, the RO shall immediately inform Social Services and the Police.
5.3 The RO will recommend at each meeting of the Management on the acceptance or otherwise of applicants. No details other than an applicant was accepted or otherwise shall be given or minuted. The SSM may indicate an opinion on any application at this stage, in child protection terms. The Management shall consider the RO's recommendation and their decision shall be recorded in the minutes.
5.4 On receipt of all replies to enquiries, the applicant shall be invited to attend an interview with the RO and the SSM. The RO will show the applicant all replies received. The SSM will also read these, to ensure fair play, and non-bias/collusion etc.
5.5 Any discrepancies revealed between the applicant's statements and the replies must be investigated thoroughly with the applicant by the RO and the SSM, especially as regards dates of residence, employment, voluntary work, past offences and convictions. In particular, the applicant should be advised as to the necessary procedures s/he can take if s/he queries the accuracy of a reference or check. The replies given may be taken into account by the RO, in consultation with the SSM, in making a recommendation to the Management as at 5.3.
5.6 Where an applicant declines to attend such an interview as at 5.4, the RO shall write to the applicant to inform him/her that their application has not been successful.
5.7 The RO shall be authorised to undertake any additional enquiries as sanctioned by the applicant as may assist the making of a recommendation to the Management.
6.1 The RO shall maintain a confidential file on each applicant in which shall be kept:
a. copies of all forms, consents and replies as in paragraph 4.2 above;
b. a progress check form indicating progress of the checks and replies;
c. notes for file - where the RO receives a phone call or other non-written communication, the main points shall be recorded and filed with the applicant's records.
6.2 The file of an unsuccessful applicant shall be kept for six months and then safely destroyed by the RO - likewise for a successful applicant who declines to commence with the Project - this period will be increased to 12 months from the date of leaving the Project's service for any successful applicant who commences work with the Project.
6.3 Anyone working with the Project has the right to inspect their own confidential records as at 6.1 above, and may do so on request to the RO who shall not withhold consent unreasonably and will do so within one working day. The RO may only withhold such agreement and access if to do so might jeopardise a Project or police or social services investigation relating to child protection matters or might lead to a child's welfare and safety being compromised. The RO need give no reason for such withholding of consent. S/he will report such a situation to the Management, purely on the lines that a request was made and refused for reasons relating to the welfare of children.
6.4 The SSM may have access to such records as kept at 6.1 above, with the caveat at 6.3 above applying.
7.1 Prior to any activity/site/programme being commenced, the RO shall ensure that adequate child protection procedures are in place.
7.2 In consultation with the SSM, the RO shall ensure a site audit is undertaken to ascertain the layout of premises/site, helpers and supervision required to achieve adequate personal safety of children and young people. The audit shall be undertaken with a view to recognising any problems in terms of e.g. supervision of helpers, extended sites creating communications concerns etc. There may be a need to audit an existing site etc if, in the opinion of the RO and/or the SSM there have been significant changes since the last use of that site.
7.3 As a basic principle, no helper should work with less than three children on their own for any period longer than 10 minutes, and where possible each room should have two or more helpers and/or regular visits, at not less than 5 minute intervals. The Project's regulations as regards helper:child ratios shall be observed.
7.4 All sessions shall be conducted with the provisions, aims and objective of this policy in mind.
7.5 Every activity shall be undertaken with the possibility in mind that a child may be suffering abuse outside the project, that a disclosure or symptom relating to this may become apparent within a Project activity, or that there will be children present who have not as yet revealed they are being abused. It is important that the environment created for Project activity is as conducive to support of a child in such a situation as is possible.
7.6 For their own protection, but mainly as good practice and good manners, helpers are advised that children should initiate physical contact with helpers - this will not apply e.g. where a child needs to be removed from a situation threatening its or others' safety.
8.1 Those working on Project activities have a duty to ensure that any suspicion, incident, allegation or other manifestation relating to child protection is reported as provided below.
8.2 Disclosure or evidence for concern may occur in any number of ways. This may be by what a child says, about itself or another child or children. It may be through interception of a written item, or through observation of activity or behaviour giving cause for concern. It may be through changes in behaviour or attitude. There may be physical, emotional pointers such as bruising, staining, inappropriate behaviour or knowledge. These and many other signs can be picked up by workers.
8.3 IT IS VITAL FOR THE SUCCESSFUL OPERATION OF THIS POLICY THAT ALL INCIDENTS, OBSERVATIONS, HOWEVER INSIGNIFICANT-SEEMING, ARE LOGGED BY THE OBSERVER(S) IN THE APPROPRIATE ACCIDENT AND INCIDENT REPORT BOOK/FORMS.
8.4 The observing worker, paid and voluntary, will make a verbal report to the session leader, and also will make a written report outlining in adequate detail what was heard, seen, reported, alleged etc. Verbatim quotes from a child are important, as is the retention of anything which gave cause for concern such as a drawing, painting, writing etc. The worker will sign and date the report. The session leader will countersign the report and at the end of the session or, at the latest, the next working morning, will draw the attention of the SSM to the report. The SSM will read and countersign the report, with any comments/ recommendations, and pass it to the Responsible Officer who also will read and countersign, completing the form with comments etc as appropriate.
8.5 If more than one worker has an observation on the same incident on the day in question, a separate report is to be made by each worker and treated as above. The session leader will ensure the reports are cross-referenced and dealt with as one.
8.6 At the same time, after the session's completion, the session leader will afford worker[s] opportunity to discuss the matter and will note any matters which should be taken forward from the discussion. The session leader MUST bring in the SSM to such a feedback discussion if an allegation has been made, or if there is serious concern evident or raised by workers. Workers should not feel constrained in expressing their concerns on any such matter in such a discussion - THE BASIC PRINCIPLE IS THAT THERE CANNOT BE TOO MUCH DETAIL OR DISCUSSION WHERE THE PROTECTION OF CHILDREN IS CONCERNED.
8.7 Many reports will be purely minor in nature. It is important to treat them with due seriousness, however, in case there already exists information within the Project concerning a child or e.g. a related child.
8.8 The SSM will ensure the Responsible Officer has as much background, supplementary detail about a child or an incident as possible. The RO will keep records in such a way as will enable appropriate cross-referencing of reports. The object is that any persistent pattern is identified as soon as possible.
8.9 After discussion with workers as in 8.6 above, where the matter is serious enough to warrant the SSM being brought in, the SSM will contact the RO who will either attend the meeting or make arrangements to meet the relevant people together as soon as possible. The RO MUST attend if there is a serious level of allegation or evidence of abuse which may endanger a child or children.
8.10 At such a meeting which the RO will chair and the SSM minute (or have minuted), the evidence and concerns will be reviewed and the RO will consult in making a decision on action. Any previous records relevant will be also consulted by the RO. The RO will record his/her decision by a memorandum, copy to the SSM and copy filed in the appropriate restricted files.
8.11 The RO will take an appropriate course of action as follows:
a. Immediate Report to Duty Officer at Social Services and/or Police: this covers any situation where, in the judgement of the RO, after due consultation with workers involved, session leader and SSM, there is perceived to be an immediate danger to a child or detection of criminal offences against a child or other form of obvious, ongoing/future/recent serious harm. [If the Project has a current liaison with e.g. the senior child welfare social worker in the Social Services Area Office, this person can be contacted during office hours in lieu of the Duty Social Worker]. Where the Duty Social Worker cannot be located, the Police should be informed and told of this problem in locating the Social Services officer. Where a child seems at imminent harm of danger/ injury or worse, then the RO is authorised to make a complaint to the Police in order to secure immediate action and protection of a child. NO PROTOCOL SHOULD EVER INHIBIT THIS COURSE OF ACTION IF IT IS TRULY WARRANTED.
b. In exceptional cases, where action under a. above seems unable to guarantee a child's welfare which appears to be under serious and imminent threat, the RO, consulting with the SSM and the Officers of the Project as they can be quickly located, should consider direct action through obtaining of a suitable order through the Court.
c. Most situations will not require reference as in a. or b. above. It will be more appropriate for the RO to raise them informally with a designated liaison contact at Social Services, provided that social worker is dealing with child-related matters in the course of their duties. The RO will always strive to ensure that there is such an informal liaison arrangement so that concerns can be discussed informally and on a regular basis. It will be appropriate at such informal meetings for all recent reports to be copied to the liaison person. The SSM's attendance at such informal liaison meetings is seen as desirable for the detailed information this can afford.
d. There may quite often be situations arising from the reporting process which will not require the urgent formal reporting of a. or b. above but where it will not be appropriate to wait until a liaison meeting as in c. In such circumstances the RO should never hesitate to contact the Social Services liaison person on an informal basis as soon as possible. Such situations may arise e.g. where there is insufficient hard evidence or facts to warrant a complaint/ urgent formal referral, but there may be enough in terms of e.g. previous reports to justify referral of concerns in an informal manner.
8.12 The point of making informal reports as in 8.11 above should not be under-estimated. It may well be that, from a child protection viewpoint, the information given to social services in a piecemeal manner, informally, is potentially a major way of picking up issues as they develop. Our piece of information may be one part of a jigsaw - it may even be the first piece. It may complete "a puzzle".
8.13 The RO, and all workers, should bear in mind that in this Project we may not be privy to all or indeed much information about a given child's situation, as held by Social Services - but our item of information may assist in promoting a child's welfare.
9.1 Workers will always wish to be assured that, having made a report, appropriate action has been taken. The RO and the SSM should always attempt to give such feedback from a reporting situation as is appropriate. The RO him/herself may be short on information once a report has been made to Social Services, who for reasons of confidentiality may be unable to give specific details. However the RO should press for a description about progress from the Social Services end, usually through the liaison machinery but if necessary by direct action as high as may be warranted if a serious matter has been reported. The RO is entitled to ask what specific action has been taken so far, whether the police have been informed etc.
9.2 In giving any feedback to workers, the RO has to bear in mind "need to know" and confidentiality. So, the worker who made a report can be told what action has been taken by the RO including any representations that e.g. the police should be brought in etc. This will usually take place via the SSM through whom such liaison will occur.
9.3 In regular reports on child protection matters to the Project's Management, the RO will report:
- all new applicant's results of police and other checks: the person's name and whether the checks were satisfactory or not (but without giving detail) and the SSM will confirm this information. The Management will then decide upon each recommendation and their decisions will be recorded in the minutes as to whether agreed or not.
- any formal report to the Police or the Duty Social Worker, omitting children's and families' names; also any informal report made by the RO to Social Services via our liaison with them.
10.1 If a child or parent makes allegations to the Project against any person working for the Project, whether paid or unpaid, or a member of the management, the following procedure will come into force - incident reports will be made at all stages as appropriate:
a. The person receiving the complaint will contact the SSM who will at once contact the Chairman, or his deputy. The Chairman will contact the RO. On receipt of the complaint, the RO will contact Social Services to appraise them of the situation. Normally this will be by informal channels but if there is a criminal allegation, the contact will be formal to the duty social worker and also to the police.
b. The Chairman should inform the person against whom an allegation has been made as soon as possible UNLESS THERE APPEARS TO BE A CASE THAT THIS MIGHT PREJUDICE A CRIMINAL INVESTIGATION. This will require consultation with the police to ascertain.
10.2 The course of action to be taken from thereon will be decided by the nature of the allegation(s).
a If a criminal allegation e.g. of sexual abuse and impropriety is made, or physical assault, or inappropriate behaviour, the Chairman will activate the Disciplinary Procedure and suspend the person from any activity in the Project under the heading of alleged Gross Misconduct. If it is warranted, this may be without pay, should the evidence appear strong enough to justify the matter. For example, a worker discovered in a situation of actual wrongful behaviour. The matter must then be reported immediately to the police and duty social worker. The suspension will remain in force unless and until the police and/or social services confirm there was no substance to the report. An incident report will be made and treated as confidential.
b If there is no criminal allegation the RO will gather as much detail from available sources of information as possible, by way of investigation, but not including seeking to interview any child if there is a criminal allegation (which is a matter for the authorities). The RO should examine to see if there is any company report relating to a child protection matter concerning any involved child. This is most important. Where appropriate, the RO should consider whether suspension of the worker is advisable and recommend accordingly to the Chairman. This may include a situation which, though non-criminal, could lead to a decision of gross misconduct.
c The RO will report to the Chairman on the outcome of such an investigation and will recommend whether the circumstances constitute grounds either:
A. to treat the matter as a disciplinary issue, either as misconduct or gross misconduct, with associated rights of appeal
or B. to dismiss the allegations as unfounded, or to make such other non-disciplinary recommendations as are appropriate. The Chairman shall consider such recommendations and report to the next meeting of the Management of action taken.
The person against whom such non-criminal allegations are made should have opportunity to give an explanation or answer to any allegation at an interview conducted by the RO and the course of such an interview should be minuted by the SSM who should be present.
d. In the case of 10.2 b above the suspension will remain in force on completion of the RO's enquiries if the Chairman is of the view that the misconduct is so serious as to constitute grounds for immediate termination of employment or voluntary service until the dismissal procedure has been implemented. The person suspended should be advised by the Chairman of a person in the Project with whom s/he can communicate during the period of suspension on matters relating to their employment, and the person so appointed should be told clearly, as should the person suspended the address to which any communication should be made, whether or not communication includes personal contact, and the hours/times of contact.
e. In the situation of 10.2 a above, if legal proceedings result in the conviction of the person for a serious offence involving a child, the Chairman shall consider any report or information from the police and /or social services and shall recommend to the directors the appropriate course of action up to and including instant dismissal. If the proceedings to not result in a conviction but there is evidence to suggest misconduct, the procedure in 10.2 b may be invoked.
f. In the situation of 10.2 b above the Chairman shall write to the person concerned to inform them of the outcome of the investigation and will inform the person of any decision to terminate employment or of the date and conditions, if any, of a return to duties, where a disciplinary offence has been committed but is not of a nature as to warrant immediate dismissal.
h. Under no circumstances is any person suspended to re-enter Project premises or property or attend a session site whilst under suspension. This prohibition includes activities where there are no children/ young persons present.
i. In appropriate circumstances, in consultation with the SSM, and with other Officers as available, the Chairman may effect an instant dismissal if the evidence warrants it. For example, someone caught in the act of committing an offence involving a child on Project property. This will be reported in the manner detailed above, and the RO will make the appropriate reference to Social Services, or, if appropriate the Police (remembering to report to Social Services). The personal file of such a worker will have the necessary note of action taken entered in it.
j. Lesser forms of misconduct involving a worker in a child protection incident where the worker's actions or behaviour are inconsistent with children's welfare should be reported and dealt with under the ordinary Misconduct provisions of the Disciplinary Procedure, with appropriate records made in the person's file. Social Services should be informed if the matter is related to child protection, and it is possible they may express a view on the person's suitability to continue to work in the Project. Each case will be individual, judged on its own merits. The RO and the Chairman will liaise on such issues, with the SSM, and a report with recommendations made if necessary to the Management next meeting.
k. Where the Police are called in, the provisions of Terms and Conditions as regards e.g. interviews with workers etc and children apply.
11.1 The Project shall ensure that there is adequate and appropriate induction and ongoing training and information to all employed staff and voluntary workers concerning child protection matters, which shall be the responsibility of the SSM to devise and implement, in consultation and liaison with the RO. All directors, employees and voluntary workers shall have this policy drawn to their attention on joining the Project and it shall be the duty of the SSM, in consultation with the RO, to ensure that such persons are fully aware of how and where to access the full policy statement, and that the SSM is the person through whom they should route queries concerning the policy.
12.1 The Management shall review this policy, its effectiveness and regarding its implementation every two years and the RO shall ensure with the SSM that the views of all workers, paid and voluntary, are sought and reflected in such a review process, and that any statutory authority input is sought as appropriate.