Safeguarding Children and Young People Policy consultation

Policy Statement

Freebridge believe that safeguarding children is everyone’s responsibility and that everyone who encounters children and families has a role to play to protect children and young people under the ages of 18 from abuse or neglect. Freebridge shall effectively work with statutory and partner agencies to proactively prevent abuse and/or neglect and ensure that any such abuse is responded to promptly and effectively.

Freebridge is committed to taking all reasonable measures to safeguard children and young people under the ages of 18 who live in our accommodation from abuse and neglect. We are not an investigative or intervention agency; however, our staff and contractors are in regular contact with children and young people and can therefore potentially observe signs of abuse and to alert the appropriate agencies.

Role of the Organisation in Safeguarding Children and Young People

The organisation recognises that statutory responsibility for safeguarding children rests with local authorities under the Children Act 1989 and Children Act 2004.

However, as a provider of social housing the organisation has an important role in safeguarding children and young people who live in or visit our homes.

Our role includes:

• identifying potential safeguarding concerns
• recognising signs of abuse, neglect or exploitation
• accurately recording concerns
• reporting concerns promptly to the relevant statutory agencies
• working in partnership with local authorities, police and other agencies
• supporting families to access appropriate services where concerns arise
  
  

Staff are not expected to investigate allegations of abuse themselves. Their responsibility is to identify and report concerns so that statutory safeguarding authorities can assess and respond appropriately.

Staff are expected to exercise professional curiosity where concerns arise, meaning they should respectfully question, observe and verify information where necessary to ensure the safety and wellbeing of children.

Where safeguarding concerns arise alongside housing issues such as tenancy breaches or anti-social behaviour, the organisation may act through its housing management powers while statutory safeguarding investigations are carried out.

Safeguarding responsibilities apply to all staff, contractors and volunteers who meet residents in the course of their work.

Policy Detail

For the purposes of this policy, a child is defined as anyone who has not yet reached their 18th birthday, in accordance with the definition set out in Working Together to Safeguard Children (2023) and the Children Act 1989. Safeguarding concerns may also arise in relation to unborn children where there are risks during pregnancy.

General Responsibilities

It is the responsibility of:

• Every member of customer-facing staff to be aware, and have a clear understanding, to remain alert, and respond appropriately, to indications of possible abuse and neglect
• the Director of Operations, acting as Freebridge’s Designated Safeguarding Officer, with the Assistant Director of Customer Experience, and Head of Housing acting as deputies, for the implementation of this policy
• The Designated Officers to maintain an up-to-date awareness and understanding of good practise, and the legislative & regulatory requirements which may impact this policy and the service provided; and
• Members of Leadership Team to maintain an overview of safeguarding practices, and an awareness of the operation of the policy

 
What is Safeguarding and promoting the welfare of children & young people?

 Safeguarding and promoting the welfare of children is defined in Working Together to Safeguard Children (2023) as:

• Protecting children from maltreatment
• Preventing impairment of children’s mental and physical health or development
• Ensuring that children grow up in circumstances consistent with the provision of safe and effective care
• Taking action to enable all children to have the best outcomes

(Source: Working Together to Safeguard Children 2023)

What is Child Protection?

Child protection is part of safeguarding and promoting welfare. It is an activity undertaken to protect specific children who are suffering, or are likely to suffer, significant harm.

What is abuse?

Abuse is a form of maltreatment of a child; someone may abuse or neglect a child by in inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or an institutional or community setting by those known to them, or more rarely, by others (e.g. via the internet). They may be abused by an adult or adults, or another child or children.

Abuse can take many forms please refer to Appendix 1.

What is neglect?

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy because of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

• Provide adequate food, clothing and shelter (including exclusion from home or abandonment).
• Protect a child from physical and emotional harm or danger.
• Ensure adequate supervision (including the use of inadequate care-givers).
• Ensure access to appropriate medical care or treatment.

It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Our commitment 

Our safeguarding practice is guided by the following principles:

• The welfare of the child is paramount.
• We take a child-centred approach.
• Safeguarding is everyone’s responsibility.
• Children should be listened to and their views taken seriously.
• Early identification and intervention are essential to protect children from harm.
• Effective safeguarding requires partnership working between agencies.
• We embrace the good practise principle of professional challenge, in ensuring the safety and wellbeing of children.
• We work in the spirit of the principles of the ‘Signs of Safety’ framework, through an open, coaching approach to conversations with families that we are concerned about.

Recruitment

We will take appropriate legal advice to determine what level of Disclosure and Barring Service checks apply to all roles across the organisation. The requirement for a DBS check is clearly stated in any job advertisement, and all applicants are required to complete a rehabilitation of offenders form which is reviewed prior to job offers being made. More information on our recruitment and selection procedures, relating to DBS, can be found under section 8 of our recruitment policy.

Roles that meet the legal eligibility criteria will be subject to an appropriate Disclosure and Barring Service check.  Any volunteers working with us will be required to consent to the same level of check, deemed appropriate for the position they are volunteering for, that a paid member of staff would be.

We will also undertake quarterly reviews of staffing and job role changes within the organisation, to ensure that all post holders continue to have the relevant level Service check.

We require staff to keep us informed of any changes to their circumstances which could affect their Disclosure and Barring Service check results. Where DBS checks are required, the organisation will determine rechecking frequency based on role risk and may use the DBS Update Service as appropriate. Our Employee Handbook provides more information.

Training

We shall:

• Brief all newly appointed customer-facing staff on safeguarding awareness & our own procedures within 3 months;
• Provide appropriate refresher training every three years for all customer-facing staff in all relevant aspects of safeguarding

Contractors

We will:

• Require contractors working on our behalf to have their own policies and procedures in place (or agree to comply with ours).
• Provide information to support their staff to report any concerns they have directly to our Designated Officers.
• Require contractors to evidence that they have appropriate procedures in place to assess the need for Disclosure and Barring Service checks of their own staff, and to carry out those checks if determined necessary.

Awareness

In promoting and raising awareness of safeguarding, we will work with residents to ensure that they are aware of how to report any concerns they have, through regular promotion in tenants’ newsletters etc. and ongoing campaigns.

Working with Partners and the Local Safeguarding Children Partnership

In promoting and raising awareness of safeguarding, we shall:

Participate in Multi Agency Public Protection Arrangements and Multi Agency Risk Assessment Conferencing case conferences as appropriate, where they involve concerns for a child or young person that we are working with, as well as engaging with Child Protection Conference arrangements where new concerns arise.

Ensure all relevant staff have an awareness of, and work in accordance with the principles for professionals working with children & families in West Norfolk, as determined by the Norfolk Safeguarding Children Partnership

Recognise Norfolk Safeguarding Children Partnership as the primary source of best practise advice, and

Maintain our membership to the Safer Programme to ensure that our practises remain current.

Assist in preventing difficulties in family life escalating which may subsequently lead to the abuse, neglect or the significant harm of a child if not resolved.

Be alert to identifying any emerging problems and potential unmet needs for individual children and families through our involvement with them and actively participate in the provision of early help interventions, such as through the Family Support Process Model.

Recording Safeguarding Concerns

Accurate and timely recording of safeguarding concerns is essential to ensure that appropriate action can be taken and that statutory agencies have the information required to assess risk.

Where safeguarding concerns arise, staff must:

• record the concern as soon as possible
• ensure the record is clear, factual and accurate
• distinguish between facts, observations and professional opinion
• include the date, time and location of the concern
• record the names of any individuals involved or present
  
  

Where possible, staff should record the exact words used by the child or adult when disclosing information.

Safeguarding records should also include:

• actions taken by staff
• advice sought from managers or safeguarding leads
• referrals made to external agencies
• outcomes or follow-up actions
  
  

Safeguarding records will be stored securely in accordance with the organisation’s data protection procedures and will only be accessible to authorised staff.

All safeguarding concerns must be reported internally in line with the organisation’s safeguarding procedures, even where staff are uncertain whether abuse has occurred.

Staff are not expected to investigate safeguarding concerns, but they must ensure concerns are recorded and reported promptly so that appropriate agencies can assess and respond.

Reporting

Where concerns do exist regarding possible abuse, neglect or risk of significant harm to children;

we shall:

• Work closely with the statutory agencies, the Children’s Advice and Duty Service, and in cases of immediate risk to life or on suspicion of a criminal offence, with Norfolk Constabulary, to ensure their statutory involvement with the child at risk.

Support staff to take a child centred approach in listening, accurately recording and reporting all concerns, seeking professional advice from the Children’s Advice and Duty Service when in doubt.

Maintain comprehensive and easily accessible procedures for all customer-facing staff to support them in making referrals to the Children’s Advice and Duty Service via the following process CADS Flowchart.pdf (fch.local)

Our Director of Operations is the organisation’s Designated Safeguarding Officer, with the Assistant Director of Customer Experience, and Head of Housing acting as deputies, responsible for:

Providing advice and guidance to staff in relation to potential safeguarding concerns.

Liaising with the Children’s Advice and Duty Service and Social Care Teams to ensure that referrals are dealt with robustly and that communication between organisations is effective.

Promoting safeguarding awareness across the organisation, and that procedures and current knowledge remain up to date and relevant.

The Designated Officers are also responsible for:

• Reporting any allegations promptly to the Local Authority’s Designated Officer Team (within one working day); and ensuring cooperation with any subsequent investigation should any concerns arise regarding the conduct of staff or contractors that have:
• Behaved in a way that has harmed a child, or may have harmed a child;
• Possibly committed a criminal offence against or related to a child; or
• Behaved towards a child or children in a way that indicates they may pose a risk of harm to children.
  
  

Freebridge is committed to maintaining a culture where safeguarding concerns can be raised openly and without fear. Staff can also raise their own concerns directly via our Whistleblowing Policy. We understand that raising concerns can be difficult for staff and will also signpost to the Whistleblowing Charity – Protect (formerly Public Concern at Work) – for further advice and support.

We also understand that involvement in cases of abuse and neglect can be distressing for staff, and will provide all appropriate support throughout their involvement, including access to our Employee Assistance Programme.

Information Sharing

Freebridge recognises that effective safeguarding relies on appropriate and timely information sharing between agencies.

Where safeguarding concerns arise, information will be shared with relevant agencies where this is necessary to protect a child or adult at risk from harm.

Information sharing will be carried out in accordance with:

• the Data Protection Act 2018
• the UK General Data Protection Regulation
• the Information Sharing Advice for Safeguarding Practitioners
• the organisation’s Data Protection Policy

The organisation understands that data protection legislation does not prevent the sharing of safeguarding information where there is a lawful basis to do so.

Where appropriate and safe to do so, staff will:

• seek consent before sharing information
• explain why information may need to be shared
• involve individuals and families in safeguarding discussions
  
  

However, information may be shared without consent where:

• a child or adult is at risk of significant harm
• seeking consent would place someone at greater risk
• a serious crime may have been committed
• a statutory safeguarding duty applies
  
  

In all cases, staff will ensure that information shared is:

• necessary and proportionate
• relevant and accurate
• shared only with appropriate agencies
• recorded appropriately
  
  

Safeguarding Governance and Assurance

Safeguarding Governance

Freebridge recognises that safeguarding is a key responsibility and requires effective oversight at all levels of the organisation.

Overall responsibility for safeguarding governance sits with the Board, which provides strategic oversight and ensures that appropriate safeguarding policies, procedures and resources are in place.

Operational responsibility for safeguarding sits with the Director of Operations acting as the organisation’s Designated Safeguarding Lead, who is responsible for:

• overseeing safeguarding practice across the organisation
• ensuring safeguarding policies and procedures remain up to date
• providing advice and guidance to staff
• monitoring safeguarding referrals and outcomes
• liaising with external safeguarding agencies where appropriate
  
  

Senior managers will ensure that safeguarding responsibilities are embedded across all relevant services including housing management, neighbourhood services and customer-facing roles.

Monitoring and Assurance

The organisation will monitor safeguarding practice to ensure that safeguarding responsibilities are being carried out effectively.

This may include:

• monitoring safeguarding referrals and outcomes
• reviewing safeguarding incidents or case reviews
• identifying learning from safeguarding cases
• reviewing staff training compliance
• ensuring safeguarding procedures are followed consistently
• Where appropriate, learning from safeguarding incidents will be shared internally to improve safeguarding practice

Policy Review

This policy will be reviewed at least every year, or sooner if required due to:

• legislative changes
• updated safeguarding guidance
• learning from safeguarding incidents or reviews.
  
  

Updates may also be made following changes to relevant guidance including  **Working Together to Safeguard Children 2023 and other national safeguarding frameworks.

Appendix One – Definitions

Child

For the purposes of this policy, a child is defined as anyone who has not yet reached their 18th birthday, in accordance with the Children Act 1989 and Working Together to Safeguard Children 2023. Safeguarding concerns may also arise in relation to unborn children where there are risks identified during pregnancy.

Young Person 

The term young person may be used interchangeably with “child” within safeguarding guidance and refers to individuals under the age of 18.

Adult

An adult is defined as a person aged 18 years or over. Concerns relating to adults who may have care and support needs are addressed through the organisation’s Safeguarding Adults Policy, which operates under the framework of the Care Act 2014.

Abuse can take many forms including, but not limited to:

Physical abuse

which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.

Emotional abuse

is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber 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

involving forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Adult males do not solely perpetrate sexual abuse. Women can also commit acts of sexual abuse, as can other children.

Child Sexual Exploitation (CSE)

Child Sexual Exploitation occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity.

The child may receive something in return such as:

• money
• gifts
• accommodation
• affection or status
  
  

The exploitation may involve physical contact or may occur online. Children may be exploited by individuals known to them, by peers, or by organised groups.

Possible indicators include:

• unexplained gifts, money or new possessions
• frequent missing episodes
• relationships with significantly older individuals
• use of sexualised language inappropriate to age
  
  

Child Criminal Exploitation (CCE)

Child Criminal Exploitation occurs where children are manipulated, coerced or pressured into committing criminal activity for the benefit of others.

This may include:

• transporting or selling drugs
• theft or other criminal offences
• storing drugs, money or weapons
  
  

Children may be targeted due to vulnerability, including poverty, family difficulties, or social isolation.

County Lines Exploitation

County lines refer to criminal networks that exploit children and vulnerable people to transport and sell drugs.

Children may be:

• groomed or manipulated by criminal groups
• threatened or coerced into participating
• required to travel outside their local area.
• Children involved in county lines activity should be treated as victims of exploitation rather than offenders
  
  

Online Abuse

Children may be exposed to abuse through digital technologies including social media, gaming platforms and messaging services.

Online abuse may include:

• grooming for sexual exploitation
• sharing of indecent images
• cyberbullying
• coercion or harassment
• Staff should recognise that online abuse can occur without direct physical contact
  
  

Radicalisation and Extremism

Radicalisation occurs when a child is influenced to support extremist ideologies, groups or causes.

Children may be vulnerable to radicalisation through:

• online content
• peer groups
• community influences
  
  

Concerns regarding radicalisation should be reported in line with safeguarding procedures and may involve referral through the Prevent programme.

Modern Slavery and Human Trafficking

Children may be trafficked or exploited for criminal activity, domestic labour or sexual exploitation.

Indicators may include:

• restricted freedom of movement
• signs of coercion or control
• unexplained travel patterns
  
  

All suspected cases should be treated as safeguarding concerns and referred to appropriate agencies.

Safeguarding Adults at Risk of Abuse or Neglect Policy and Safeguarding Children & Young People Policy:

Freebridge is committed to helping keep residents safe.

Safeguarding means protecting people from abuse, neglect or exploitation and making sure that people who may be vulnerable receive the support they need.

As a housing provider, we may sometimes become aware that someone living in or visiting our homes may be at risk of harm. 

This could include:

• abuse or neglect of a vulnerable adult
• domestic abuse
• financial exploitation or scams
• criminal activity targeting vulnerable residents
• concerns about the safety or wellbeing of children

While we are not responsible for investigating safeguarding concerns ourselves, we work closely with the relevant agencies such as local authorities, social care services and the police to make sure concerns are reported and addressed.

Our staff are trained to recognise signs that someone may be at risk and to report concerns so that appropriate support can be provided.

Residents can also raise safeguarding concerns with us if they are worried about someone’s safety.

If we believe someone may be at risk of serious harm, we may need to share information with safeguarding agencies so that appropriate action can be taken.

Our safeguarding policies set out:

• how staff identify and report safeguarding concerns
• how we work with safeguarding agencies
• how we support residents where safeguarding concerns arise.