If you have questions regarding our Safeguarding Policy, please contact safeguarding@head-up.org. If your query relates to immediate concerns for someone’s welfare, please call our safeguarding team on 07542 003022. You can also get impartial advice via the NSPCC helpline: 0808 800 5000.

Head Up! Safeguarding and Whistleblowing Policies

October 2024

Contents

The Purpose and Scope of this Document 

Legal Framework 

Safeguarding Policies 

Child Protection & Safeguarding Policy Statement

Online Safety Policy Statement 

Role Description of the Nominated Child Protection Lead / Designated Safeguarding Lead 

Dealing with Disclosures and Concerns About a Child, Young Person or Vulnerable Adult

Managing Allegations Against Members of Staff / Volunteers 

Behaviour Code for Adults Working With Children, Young People and Vulnerable Adults

Zero-Tolerance Policy Statement 

Data Protection Policies 

Child Protection / Vulnerable Adult Records Retention and Storage Policy 

Whistleblowing Policy

Contact Details 

Review Schedule

The Purpose and Scope of this Document

The general aim and objective of Head Up! is to promote the interests of young people with disabilities, physical and/or mental health conditions, specific learning difficulties and neurodiversity; offering them practical advice and support concerning their education and welfare. This includes providing outreach information, advice and case studies in relation to overcoming health barriers to (higher) education, and providing mentoring sessions to young people and vulnerable adults over the age of 14.

This document contains the following policies and guidance:

• Child Protection & Safeguarding Policy Statement
• Online Safety Policy Statement
• Role Description of Child Protection Lead / Designated Safeguarding Lead
• Dealing with Disclosures and Concerns about a Child, Young Person or Vulnerable Adult
• Managing Allegations Against Members of Staff / Volunteers
• Behaviour Code for Adults Working with Children, Young People and Vulnerable Adults
• Zero-Tolerance Policy Statement
• Child Protection /Vulnerable Adult Records Retention and Storage Policy
• Whistleblowing

These policies and guidance apply to anyone working on behalf of Head Up! including the management team, staff, volunteers, trustees, and students, as well as children, young people, and vulnerable adults involved in Head Up!’s activities.

Legal Framework

As Head Up! works with children, young people and vulnerable adults from across the United Kingdom, this policy has been drawn up on the basis of legislation, policy and guidelines that seek to protect children, young people and vulnerable adults in England, Northern Ireland, Scotland and Wales.

These policies are written in accordance with the Childrens’ Act 2004/1989, Safeguarding Vulnerable Groups Act 2006, Equality Act 2010, Data Protection Act 2018, and Working Together to Safeguard Children Statutory Guidance 2023.

Summaries of key legislation and guidance are available on:

• Safeguarding children and child protection (learning.nspcc.org.uk/safeguarding-child-protection)
• Child abuse and neglect (learning.nspcc.org.uk/child-abuse-and-neglect)
• Child protection system in the UK (learning.nspcc.org.uk/child-protection-system)
• Online safety (learning.nspcc.org.uk/online-safety)
• Safer recruitment (learning.nspcc.org.uk/safeguarding-child-protection/safer-recruitment)
• Child protection definitions (learning.nspcc.org.uk/child-protection-system/child-protection-definitions)

Safeguarding Policies

Child Protection & Safeguarding Policy Statement

The purpose of this policy statement is:

• To protect children, young people and vulnerable adults who receive Head Up!’s services from harm.
• To provide the management team, staff and volunteers, as well as children and young people and their families, with the overarching principles that guide our approach to child protection.

We believe that:

• Children, young people and vulnerable adults should never experience abuse of any kind. This includes, but is not limited to:
  • Neglect
  • Physical abuse
  • Emotional abuse
  • Sexual abuse
  • Bullying
  • Domestic abuse
  • Modern slavery
  • Fabricated or induced illness (by proxy)
  • Female genital mutilation
• We have a responsibility to promote the welfare of all children, young people and vulnerable adults, to keep them safe and to practise in a way that protects them and enables them to achieve their full potential.

We recognise that:

• The welfare of children, young people and vulnerable adults is paramount in all the work we do.
  • Vulnerable adults (adults at risk) are defined as any person who is aged 18 years or over and at risk of abuse or neglect because of their need for care or support. They may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of themself, or unable to protect themself against significant harm or exploitation.
• In all the decisions we make, all children, young people and vulnerable adults, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation have an equal right to protection from all types of harm or abuse.
• Some children are additionally vulnerable because of the impact of previous experience, disabilities, their level of dependency, communication needs or other issues.
• Working in partnership with children, young people, vulnerable adults, their parents, carers and other agencies is essential in promoting young and vulnerable people’s welfare.

We will seek to keep children, young people and vulnerable adults safe by:

• Valuing, listening to and respecting them.
• Appointing a nominated child protection lead / designated safeguarding lead for children, young people and vulnerable adults and appointing a deputy.
• Adopting child protection and safeguarding best practices through our policies, procedures and code of conduct for staff, trustees, and volunteers.
• Developing and implementing an effective online safety policy and related procedures.
• Providing effective management for staff and volunteers through supervision, support, training and quality assurance measures so that all mentors, volunteers, and anyone else associated with Head Up! know about and follow our policies, procedures and behaviour codes confidently and competently.
  • All staff and volunteers are required to follow safeguarding policies and procedures, including a duty to report any safeguarding concern, as well as the volunteer code of conduct.
• Recruiting and selecting staff and volunteers safely, ensuring all necessary checks are made. Only those with an enhanced DBS check, satisfactory reference, and training will be allowed to work with children, young people, or vulnerable adults.
  • Where an applicant discloses or an enhanced DBS check shows a caution or conviction, but the applicant is not on the barred list, a risk assessment will be undertaken to ascertain whether the applicant is suitable to work with children and young people.
    • This will be done on a case-by-case basis to gather as much relevant information as possible before a final decision is made about the applicant’s suitability to work with children and young people at Head Up!.
    • Information that will be considered may include but is not limited to: the nature of the offence and its seriousness; the relevance of the offence to other staff, volunteers, children and their families; the length of time since the offence took place; the length of the sentence; whether the offence was an isolated incident or part of a pattern or history of reoffending; the circumstances which led to the offence being committed; whether these circumstances have changed and if these changes increase or reduce likelihood of similar offences happening in future; whether the individual has changed since the offence and whether this change reduces or increases the likelihood of them committing further offences; the level of remorse expressed by the applicant and any efforts to change; whether the new role provides opportunities to re-offend; any legal constraints relevant to the role.
  • Where the applicant discloses or an enhanced DBS check shows a caution or conviction that places the applicant on the barred list, their application will be rejected. We have a duty to notify the police of any applicant who applies to work with children when on the barred list.
  • Where an unsatisfactory reference is received (i.e. a reference that expresses concerns about the applicant’s suitability for working with children, is incomplete, or vague), the referee will be recontacted to provide further details in writing before a recruitment decision is made.
  • Head Up! requires all volunteers to undertake mandatory safeguarding and child protection training before commencing work with children, young people, and vulnerable adults. Any volunteer who does not attend training will not be matched with a young person (i.e. will not be allowed to begin volunteering).
  • Unsuccessful applicants will be able to ask for feedback on areas where they did not demonstrate suitability.
• Recording, storing and using information professionally and securely, in line with data protection legislation and guidance.
• Sharing information about safeguarding and good practice with children, young people, vulnerable adults and their families via our website (www.head-up.org), during mentoring sign-up and future sessions.
• Make sure that children, young people, vulnerable adults and their families (where appropriate) know where to go for help if they have a concern.
• Using our safeguarding and child protection procedures to share concerns and relevant information with agencies who need to know, and involving children, young people, vulnerable adults, parents, families and carers appropriately.
• Use our procedures to manage any allegations against staff and volunteers appropriately.
• Creating and maintaining an anti-bullying environment and ensuring that we have a policy and procedure to help us deal effectively with any bullying that may arise.
  • Our organisational structure means that children and young people who access Head Up! services do not come into contact with each other. Despite this, we still take allegations of bullying or child-on-child abuse amongst children or young people involved with Head Up! very seriously.
  • Online or offline bullying that originates externally to Head Up! spaces, as well as child-on-child bullying amongst children involved with Head Up! will be dealt with in accordance with our safeguarding reporting procedures.
• Ensuring we have effective complaints and whistleblowing measures in place.
• Ensuring that we provide a safe environment for children, young people, vulnerable adults, staff, trustees, and volunteers, by applying health and safety measures in accordance with the law and regulatory guidance.
• Building a safeguarding culture where staff, trustees, volunteers, children, young people, vulnerable adults and their families, treat each other with respect and are comfortable about sharing concerns.

Online Safety Policy Statement

This policy has been informed by the views of children and young people. The purpose of this policy statement is to:

• Ensure the safety of children, young people and vulnerable adults is paramount when (vulnerable) adults, young people or children are using the internet, social media or mobile devices.
• Provide staff, trustees, and volunteers with the overarching principles that guide our approach to online safety.
• Ensure that, as an organisation, we operate in line with our values and within the law in terms of how we use online devices, particularly social media.

We believe that:

• Children, young people and vulnerable adults should never experience abuse of any kind
• Children should be able to use the internet for education and personal development, but safeguards need to be in place to ensure they are kept safe at all times

We recognise that:

• The welfare of children, young people and adults is paramount in all the work we do
• In all the decisions we make, all children, young people and vulnerable adults, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation have an equal right to protection from all types of harm or abuse.
• The online world provides everyone with many opportunities; however it can also present risks and challenges
• We have a duty to ensure that all children, young people and adults involved in our organisation are protected from potential harm online
• We have a responsibility to help keep children, young people and vulnerable adults safe online, whether or not they are using Head Up!’s network and devices
• Working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare and in helping young people to be responsible in their approach to online safety.

We will seek to keep children, young people and vulnerable adults safe by:

• Appointing a nominated child protection lead / designated safeguarding lead who will take responsibility for online safety coordination.
• Providing clear and specific directions to staff and volunteers on how to behave online through our behaviour code for staff and volunteers. Specifically, online safety conduct is as follows:
  • Staff and volunteers working on behalf of Head Up! are prohibited from interacting with children, young people or vulnerable adults directly on personal social media accounts (including responding to comments, private messaging or becoming ‘friends’ with them online).
  • Responses to comments from children, young people or vulnerable adults on social media platforms must come from the official Head Up! social media accounts.
  • Communication with children, young people or vulnerable adults via email should only occur from official email accounts (that is, an @head-up.org account or a mentor’s registered email address).
  • Staff and volunteers who have access to @head-up.org accounts must not share passwords with any other party, and any requests for access must go through the administration team (which may be contacted at administrator@head-up.org). This allows us to protect any sensitive information.
  • No email contact from children, young people or vulnerable adults should be shared with anyone outside of Head Up! and if there are any concerns for safety of these individuals, the ‘Dealing with disclosures and concerns about a child, young person or vulnerable adults’ procedure should be followed, which includes, but is not limited to:
    • Contacting the designated safeguarding lead / named child protection lead as soon as possible (within 24 hours).
      • They will investigate the concern in a timely manner and report this to the relevant authorities if this is appropriate.
    • Informing the police via 999 if there is a genuine concern about immediate risk of harm for an individual.
  • Emails in @head-up.org accounts from children, young people or vulnerable adults must not be deleted by anyone other than the designated safeguarding lead, to ensure a record of interactions.
• Supporting and encouraging the young people using our service to use the internet, social media and mobile phones in a way that keeps them safe and shows respect for others
• Supporting and encouraging parents and carers to do what they can to keep their children safe online
• Developing an online safety agreement for use with young people and their parents/carers
• Developing clear and robust procedures to enable us to respond appropriately to any incidents of inappropriate online behaviour, whether by an adult or a child/young person
• Reviewing and updating the security of our information systems regularly
• Ensuring that usernames, logins, email accounts and passwords are used effectively
• Ensuring personal information about the adults and children who are involved in our organisation is held securely and shared only as appropriate
• Providing supervision, support and training for staff and volunteers about online safety
• Examining and risk assessing any social media platforms and new technologies before they are used within the organisation.

If online abuse occurs, we will respond to it by:

• Having clear and robust safeguarding procedures in place for responding to abuse (including online abuse)
• Providing support and training for all staff and volunteers on dealing with all forms of abuse, including bullying/cyberbullying, emotional abuse, sexting, sexual abuse and sexual exploitation
• Making sure our response takes the needs of the person experiencing abuse, any bystanders and our organisation as a whole into account
• Reviewing the plan developed to address online abuse at regular intervals, in order to ensure that any problems have been resolved in the long term.

Role Description of the Nominated Child Protection Lead / Designated Safeguarding Lead

Purpose of the role

The welfare of children, young people and vulnerable adults is paramount in all the work we do and in all the decisions we take. The Nominated Child Protection Lead / Designated Safeguarding Lead is an imperative role to keep the children, young people and vulnerable adults we work with and our volunteers safe. The identity and contact details of this individual must be made available to all volunteers and easy to access by members of the public.

Vulnerable adults (adults at risk) are defined as any person who is aged 18 years or over and at risk of abuse or neglect because of their need for care or support. They may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of themself, or unable to protect themself against significant harm or exploitation.

As specified by the Children’s Act 2004, the Designated Safeguarding Lead should take the lead in ensuring that appropriate arrangements are in place at Head Up! for keeping children, young people, and vulnerable adults safe, and promote the safety and welfare of children, young people and vulnerable adults involved in Head Up!’s activities at all times.

Duties and responsibilities

1. Take a lead role in developing and reviewing Head Up!’s safeguarding and child protection policies and procedures.
2. Take a lead role in implementing Head Up!’s safeguarding and child protection policies and procedures: ensuring all safeguarding and child protection issues concerning children, young people and vulnerable adults who take part in Head Up!’s activities are responded to appropriately.
3. Make sure that everyone working or volunteering with or for children, young people and vulnerable adults at Head Up!, including the management committee members and trustees, understands the safeguarding and child protection policy and procedures and knows what to do if they have concerns about a child’s welfare.
4. Make sure children, young people and vulnerable adults who are involved in activities at Head Up! and their parents know who they can talk to if they have a welfare concern and understand what action the organisation will take in response.
5. Receive and record information from anyone who has concerns about a child, young person or vulnerable adult who takes part in Head Up!’s activities.
6. Take the lead on responding to information that may constitute a child protection concern, including a concern that an adult involved with Head Up! may present a risk to children or young people. This includes:
   1. Assessing and clarifying the information
   2. Making referrals to statutory organisations as appropriate, in a timely manner.
      1. Here, a timely manner = within a maximum of 24 hours of receiving information from team members and as soon as possible if the risk of harm is immediate
   3. Consulting with and informing the relevant members of the organisation’s management
   4. Following the organisation’s safeguarding policy and procedures.
   5. Action steps include but are not limited to: speaking with the school/social worker/relevant organisation who initially contacted Head Up!, speaking with a mentor’s university, seeking advice from the NSPCC and contacting the UK police.
7. Take the lead on responding to information that may constitute a concern for the welfare of a vulnerable adult, including a concern that an adult involved with Head Up! may present a risk to vulnerable adults. This includes:
   1. Assessing and clarifying the information
   2. Making referrals to statutory organisations as appropriate, in a timely manner.
      1. Here, a timely manner = within a maximum of 24 hours of receiving information from team members and as soon as possible if the risk of harm is immediate
   3. Consulting with and informing the relevant members of the organisation’s management
   4. Following the organisation’s safeguarding policy and procedures.
   5. Action steps include but are not limited to: speaking with the school/social worker/relevant organisation who initially contacted Head Up!, speaking with a mentor’s university, seeking advice from the government website and contacting the UK police and/or local authority.
8. Liaise with, pass on information to and receive information from statutory child protection agencies such as:
   1. The local authority child protection services
   2. The police.

This includes making formal referrals to agencies when necessary.

1. Consult the NSPCC Helpline when support is needed, by calling 0808 800 5000 or emailing help@nspcc.org.uk.
2. Store and retain child protection records according to legal requirements and the organisation’s safeguarding and child protection policy and procedures.
3. Work closely with the management committee and other members of the safeguarding team to ensure they are kept up to date with safeguarding issues, where this is appropriate, and are fully informed of any concerns about organisational safeguarding and child protection practice.
4. Report regularly to the management committee on issues relating to safeguarding and child protection, to ensure that child protection is seen as an ongoing priority issue and that safeguarding and child protection requirements are being followed at all levels of the organisation.
5. Work with external agencies to ensure any particular vulnerabilities of children, young people or vulnerable adults are dealt with sensitively and will not be a barrier to receiving mentoring or support.
6. Be familiar with issues relating to child protection and abuse, and keep up to date with new developments in this area.
   1. This will be achieved by signing up to NSPCC update emails, including but not limited to the CASPAR, Safeguarding in Education Updates and Case Reviews Updates.
7. Attend regular training in issues relevant to child protection and share knowledge from that training with everyone who works or volunteers with or for children and young people at Head Up!.
   1. The Nominated Child Protection Lead / Designated Safeguarding Lead should, at a minimum engage in a refresher course at least every two years, however it is expected they should engage in regular continual professional development (CPD).
8. Attend team meetings, supervision sessions and management meetings as arranged.
9. Work flexibly as may be required and carry out any other reasonable duties.

The Child Protection Lead / Designated Safeguarding Lead must have received relevant safeguarding and child protection training that is specific to their role. This training should be refreshed regularly and they should keep up to date with any changes in safeguarding and child protection legislation and guidance.

Dealing with Disclosures and Concerns About a Child, Young Person or Vulnerable Adult

We believe that it is essential for disclosures and concerns to be dealt with efficiently and sensitively. The welfare of both the child, young person or vulnerable adult and the mentor, volunteer, or Head Up! associate are paramount.

Reporting procedure

1. If a mentor, volunteer, or anyone associated with Head Up! has a concern about the well-being of a child, young person, or vulnerable adult then they have a duty of care to report this to Head Up’s! Designated Safeguarding Lead / Nominated Child Protection Lead.
2. The reporter has a duty of confidentiality to not disclose details of their work with the child to anyone outside of Head Up!. The Designated Safeguarding Lead will be available to discuss any concerns about a child, young person or vulnerable adult’s wellbeing.
3. Concerns may include:
   1. The child, young person or vulnerable adult verbally disclosing information that may indicate that there is a risk to the individual’s physical or emotional safety.
   2. If the mentor/volunteer/team member observes something that may indicate that there is a risk to the child, young person or vulnerable adult’s physical or emotional safety.
   3. If the child, young person or vulnerable adult’s behaviour indicates that there is a risk to the child, young person or vulnerable adult’s physical or emotional safety.
   4. If the mentor/volunteer/team member is unable to obtain a reply from the child, young person or vulnerable adult for an extended period of time.
4. If there is an immediate risk to the child, young person or vulnerable adult, the mentor/volunteer/team member should encourage the individual to call the police via 999 immediately. If the mentee or other vulnerable party is not willing or not able to make this call, then the mentor/volunteer/team member should immediately contact the Designated Safeguarding Lead. In all circumstances, the Designated Safeguarding Lead should be updated as soon as possible after the incident.
5. If there are any concerns, but the risk is not immediate, the mentor/volunteer/team member will email the Designated Safeguarding Lead after the session ends. They should fully document their concerns, ensuring they note the time and date, and sign the information.
6. The Nominated Child Protection Lead (if the case involves a child or young person) and Designated Safeguarding Lead will then assess the severity of the concern and escalate accordingly.
   1. The Nominated Child Protection Lead / Designated Safeguarding Lead will contact the person who made the initial referral – with the mentor/volunteer/team member passing on all pertinent information.
   2. If the Nominated Child Protection Lead deems that the concern or disclosure requires immediate action (in regards to a child or young person) and cannot get hold of the referer, they will then contact the child or young person’s local child protection services (LADO).
   3. Child protection services may want to speak to the volunteer directly, in this case, we will contact the volunteer and pass on their information to the child protection services.
7. The Designated Safeguarding Lead (if the case involves a vulnerable adult) will then assess the severity of the concern and escalate accordingly.
   1. The Designated Safeguarding Lead will contact the person who made the initial referral – with the mentor/volunteer/team member passing on all pertinent information.
   2. If the Designated Safeguarding Lead deems that the concern or disclosure requires immediate action (in regards to a vulnerable adult) and cannot get hold of the referer, they will then contact the vulnerable adult’s local authority.
   3. The local authority may want to speak to the volunteer directly, in this case, we will contact the volunteer and pass on their information to the local authority.
8. If the mentor, volunteer, or anyone associated with Head Up! requires the opportunity to discuss any safeguarding incident in which they have been involved, they will contact the safeguarding team via the safeguarding@head-up.org email address. They will be provided with the opportunity to talk through the incident with the Designated Safeguarding Lead who will help to debrief and support the mentor. The NSPCC is also a helpline available.

Managing Allegations Against Members of Staff / Volunteers

We are aware that there is a potential for children, young people, vulnerable adults or other members of staff to make allegations against mentors, volunteers, or any other person associated with Head Up!. An allegation may relate to behaviour that has or may have harmed a child, committing a criminal offence against or related to children, and behaviour that poses a risk of harm to children or indicates unsuitability in working with children.

This policy aims to appropriately manage these allegations and protect both the children, young people and vulnerable adults engaged with the work of Head Up! and the staff.

Every service user and parent/carer/guardian can report allegations through the safeguarding email (safeguarding@head-up.org). All allegations will be investigated and taken seriously.

Reporting and investigation procedures

Our response to any allegations against mentors, volunteers, or any other person associated with Head Up! will be as follows:

1. As soon as the allegation is made, the Designated Safeguarding Lead will document the time, date and all information received about the incident, storing this in line with the data protection policy.
   1. Should an allegation be made against the Designated Safeguarding Lead, they will be suspended and a member of the Head Up! management team (ideally the Head Up! President or Deputy Safeguarding Lead) will perform these duties as Lead Investigator.
   2. It is prohibited for any member of the Head Up! team to investigate any concerns whilst they are undergoing an investigation themself.
2. The Lead Investigator will contact the child or young person’s Local Authority Designated Officer (LADO) within 24 hours of the allegation being received, as well as contact the Police if there is reason to believe that a crime has been committed. Any concerns for the immediate safety of a child, young person, or vulnerable adult will be reported to the police via 999 services.
   1. The Lead Investigator must keep a copy of the referral document (or screenshot for online portals) to be stored securely alongside the safeguarding report. Records should include times, dates, names of people, and roles of people contacted.
   2. Where the Lead Investigator is aware that the volunteer is due to meet with a child, young person, or vulnerable adult (e.g. a scheduled mentoring session), they should contact the LADO immediately before making a decision about suspension or other actions.
3. The Lead Investigator must wait for statutory services (e.g. the LADO) to authorise an internal investigation into the allegations before commencing a safeguarding investigation, so as not to compromise official investigations.
   1. They should discuss the nature, content, and context of the allegation with the local authority, and agree on a course of action.
   2. Should they deem it necessary, the Lead Investigator may seek external counsel (such as the NSPCC Helpline for safeguarding concerns on 0808 800 5000, or the National Council of Voluntary Organisations Helpdesk for non-safeguarding concerns on 020 7520 2552).
4. Once an internal investigation has been authorised by relevant authorities, the Lead Investigator will begin the investigation into the allegation following the agreed course of action.
   1. The volunteer will be suspended, taking into account the advice of external agencies such as the LADO/Police, where relevant. The suspension will last until both the local authority investigation and internal safeguarding investigation have concluded.
   2. The evidence provided by the person who has raised the concern will then be put to the member of staff. They will be asked for an explanation.
   3. This will be done in a way which prevents any further harm as the welfare of the child, young person or vulnerable adult is paramount.
5. The Lead Investigator will then appropriately determine the course of action. This may include the termination of the volunteer’s service and a report to the Disclosure and Barring Service (DBS) and a volunteer’s professional body or regulator if applicable.
6. The Lead Investigator will follow up on each allegation and ensure the service user is aware of the course of action and outcome of the internal investigation. They will also record the outcome/decision of the local authority investigation.

Behaviour Code for Adults Working With Children, Young People and Vulnerable Adults

This behaviour code outlines the conduct Head Up! expects from all our staff, trustees, and volunteers. This includes anyone who is undertaking duties for the organisation, whether paid or unpaid. The code helps us protect children, young people and vulnerable adults from abuse and reduce the possibility of unfounded allegations being made.

Head Up! is responsible for making sure everyone taking part in our services has seen, understood and agreed to follow the code of behaviour, and that they understand the consequences of inappropriate behaviour.

The role of staff and volunteers

In your role at Head Up! you are acting in a position of authority and have a duty of care towards the children, young people and vulnerable adults we work with. You are likely to be seen as a role model and are expected to act appropriately.

Responsibility

You are responsible for:

1. Prioritising the welfare of children, young people and vulnerable adults
2. Providing a safe environment for children, young people and vulnerable adults
   1. Ensuring equipment, including online platforms, is used safely and for its intended purpose
   2. Having good awareness of issues to do with safeguarding and child protection and taking action when appropriate.
3. Following our principles, policies and procedures
   1. This includes our policies and procedures for child protection/safeguarding, whistleblowing and online safety
4. Staying within the law at all times
5. Modelling good behaviour for children, young people and vulnerable adults to follow
6. Challenging all unacceptable behaviour and reporting any breaches of the behaviour code to the designated safeguarding officer on safeguarding@head-up.org
7. Reporting all concerns about abusive behaviour, following our safeguarding and child protection procedures
   1. This includes behaviour being displayed by an adult or child and directed at anybody of any age.

Rights

You should:

1. Treat children, young people and vulnerable adults fairly and without prejudice or discrimination
2. Understand that children, young people and vulnerable adults are individuals with individual needs
3. Respect differences in gender, sexual orientation, culture, race, ethnicity, disability and religious belief systems, and appreciate that all participants bring something valuable and different to the organisation
4. Challenge discrimination and prejudice
5. Encourage all individuals involved with Head Up! (be that staff or children, young people or vulnerable adults engaging with our programmes) to speak out about attitudes or behaviour that makes them uncomfortable.

Relationships

You should:

1. Promote relationships that are based on openness, honesty, trust and respect
2. Avoid favouritism
3. Be patient with others
4. Exercise caution when you are discussing sensitive issues with children, young people or vulnerable adults
5. Ensure your contact with children, young people and vulnerable adults is appropriate and relevant to the work of the project you are involved in
   1. This extends to email and social media contact with children, young people and vulnerable adults.
   2. You must ensure all contact is via official Head Up! social media accounts or @head-up.org email accounts, or your registered mentoring email address
      1. You are prohibited from deleting any contact, as these must be securely disposed of by a member of the safeguarding team to protect both yourself and children, young people or vulnerable adults from harm.

Respect

You should:

1. Listen to and respect children, young people and vulnerable adults at all times
2. Value and take children, young people and vulnerable adults’ contributions seriously, actively involving them in planning activities wherever possible
3. Respect a child, young person or vulnerable adult’s right to personal privacy as far as possible.
   1. If you need to break confidentiality in order to follow child protection procedures, it is important to explain this to the child, young person or vulnerable adult at the earliest opportunity.

Unacceptable behaviour

When working with children, young people and vulnerable adults, you must not:

1. Allow concerns or allegations to go unreported
2. Take unnecessary risks
3. Smoke, consume alcohol or use illegal substances
4. Develop inappropriate relationships with children, young people or vulnerable adults
5. Make inappropriate promises to children, young people or vulnerable adults
6. Engage in behaviour that is in any way abusive
   1. Including having any form of sexual contact with a child, young person or vulnerable adult
7. Let children, young people or vulnerable adults have your personal contact details (mobile number, email or postal address) or have contact with them via a personal social media account
8. Act in a way that can be perceived as threatening or intrusive
9. Patronise or belittle children, young people or vulnerable adults
10. Make sarcastic, insensitive, derogatory or sexually suggestive comments or gestures to or in front of children, young people or vulnerable adults

Upholding this code of behaviour

You should always follow this code of behaviour and never rely on your reputation or that of our organisation to protect you.

If you have behaved inappropriately you will be subject to our disciplinary procedures. Depending on the seriousness of the situation, you may be asked to leave Head Up!. We may also make a report to statutory agencies such as the police and/or the local authority child protection services.

If you become aware of any breaches of this code, you must report them to the designated safeguarding officer (Eleanor Bartram) on safeguarding@head-up.org. If necessary you should follow our whistleblowing procedure and safeguarding and child protection procedures.

Zero-Tolerance Policy Statement

The purpose of this policy statement is:

• To protect children, young people and vulnerable adults who receive Head Up!’s services from harm.
• To create an open and welcoming safe space for anyone receiving or taking part in Head Up!’s activities.

We Believe

• The welfare of children, young people and vulnerable adults is paramount in all the work we do.
  • Vulnerable adults (adults at risk) are defined as any person who is aged 18 years or over and at risk of abuse or neglect because of their need for care and/or support. They may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of themself, or unable to protect themself against significant harm or exploitation.
• We must create an open and welcoming environment that means team members and volunteer mentors feel safe, content and comfortable with providing services (such as mentoring, content production, and social media outreach) on behalf of Head Up!
• There is no place in Head Up! for prejudicial or discriminatory views or behaviour, including, but not limited to:
  • ableism;
  • racism;
  • sexism;
  • discrimination based on sexuality (including, but not limited to, homophobia and biphobia);
  • discrimination based on gender identity, transgender identity (including non-binary gender identity, gender diversity and gender nonconformity)
  • discrimination based on socio-cultural and/or socioeconomic background;
  • discrimination against any protected characteristic including age, religion, or perceived characteristics.

We Will

• Ensure that everyone is aware of our zero-tolerance policy and must adhere to this whether they are mentees, volunteer mentors, trustees, team members or anyone who interacts with Head Up!
• Should mentors, volunteers, or anyone associated with Head Up! use any prejudicial or discriminatory language, display any prejudicial or discriminatory behaviour, disseminate hate or make other members of the team or people who receive Head Up!’s services feel uncomfortable they will be suspended immediately.
  • Following this, an investigation will take place led by the Head Up! President and/or the Designated Safeguarding Lead, in a timely manner.
    • The severity of the allegation will be assessed by the Head Up! President and/or the Designated Safeguarding Lead, seeking external counsel as necessary (such as the NSPCC Helpline for safeguarding concerns on 0808 800 5000, or the National Council of Voluntary Organisations Helpdesk for non-safeguarding concerns on 020 7520 2552).
  • Depending on the results of the investigation, this will lead to either:
    • Instant dismissal
    • Retraining
  • The individual who has raised the concern will have the opportunity to input what they would like to happen, and should they feel unsafe or uncomfortable with the decision made, we will dismiss the team member or volunteer mentor unless this concern is found to be malicious in nature.
• Should mentees or those receiving the services of Head Up! use any prejudicial or discriminatory language, display any prejudicial or discriminatory behaviour, disseminate hate or make mentors or members of the Head Up! team feel uncomfortable, they will no longer be allowed to access our services.

Data Protection Policies

Child Protection / Vulnerable Adult Records Retention and Storage Policy

In working with children, young people and vulnerable adults, we must hold records about them including child protection records. These are records which relate to concerns about a child’s welfare and safety, and/or concerns about possible risks posed by people working or volunteering with children.

This policy outlines how Head Up! will appropriately collect, store, retain and dispose of concerns regarding both children and adults.

Principles of records management

According to Data Protection principles, records containing personal information should be:

1. Adequate, relevant and not excessive for the purpose(s) for which they are held
2. Accurate and up to date
3. Only kept for as long as is necessary

Staff working on behalf of Head Up! will:

1. Compile and label files carefully
2. Keep files containing sensitive or confidential data secure and allow access on a ‘need to know’ basis
   1. Child protection records will only be viewed and stored by members of the safeguarding team.
3. Keep a log of access to the confidential files, including which files have been accessed, by whom and on what date.
4. Assess how long we need to keep the records for.
5. Have a plan for how and when the records will be destroyed.
6. Only share information with relevant statutory bodies (such as the local authority or police) when there is deemed a requirement to make a referral for the purpose of safeguarding.
   1. Every effort will be made to gain consent from the parties involved
   2. However, if gaining consent is not appropriate due to a child, young person or vulnerable adult being at immediate risk of harm, or gaining consent may put them at risk of harm, this will be documented and records will be shared in the best interest of those involved.

Recording concerns about children, young people or vulnerable adult’s safety and wellbeing

If anyone in Head Up! has concerns about a child, young person or vulnerable adult’s welfare or safety, we will record all relevant details – regardless of whether the concerns are shared with the police or local authority.

We will keep an accurate, factual record of:

1. The date and time of the incident/disclosure
2. The date and time of the report
3. The name and role of the person to whom the concern was originally reported and their contact details
4. The name and role of the person making the report (if this is different to the above) and their contact details
5. The names of all parties who were involved in the incident, including any witnesses
6. The name, age and any other relevant information about the child who is the subject of the concern (including information about their parents or carers and any siblings)
7. What was said or done and by whom
8. Any action taken to look into the matter
9. Any further action taken (such as a referral being made)
10. The reasons why the organisation decided not to refer those concerns to a statutory agency (if relevant).

If any interpretation or inference is drawn from what was observed, said or alleged this will be clearly recorded as such. The record will be signed and dated by the person making the report.

Storage of child protection / vulnerable adult records

Head Up! will make child protection / vulnerable adult records that are electronic. These are required to be kept confidential and stored securely. This means:

• Electronic records will be stored on password-protected electronic accounts and stored on computers with protection against hackers and viruses.
• Information about child (and vulnerable adult) protection concerns and referrals will be kept in a separate individual protection file for each individual, rather than in one ‘concern log’. The file will be started as soon as the Head Up! Safeguarding team becomes aware of any concerns.
  • We will keep individual protection files separate from any general records.
  • An individual’s general records will be marked to indicate there is a separate individual protection record – although these may only be accessed by the safeguarding team.
• If we must share records (within Head Up! or externally), we will make sure they are kept confidential. We will do this by:
  • Using passwords and encryption when sharing electronic files.
  • As staff and volunteers will use their personal computers to make and store records, all individuals involved with making and storing records will be required to enter into an agreement to ensure the records are kept secure.
  • If the person responsible for managing Head Up!’s child protection / vulnerable adult records leaves the organisation, another member of the team will be appointed to take over the role and arrange a proper handover.

Retention periods: child protection records

As we are a member of the voluntary and community sector, records relating to child protection will be kept for 7 years after Head Up!’s last contact with the child and their family.

Recording concerns about adult behaviour

Although the team at Head Up! pride ourselves on supporting children, young people and vulnerable adults, sometimes concerns may be raised about an adult who works or volunteers with children. This could be because they have:

• Behaved in a way that has harmed, or may have harmed, a child, young person or vulnerable adult
• Committed a criminal offence against, or related to, a child, young person or vulnerable adult
• Behaved in a way that indicated they are unsuitable to work with young people.

Head Up! must therefore keep clear and comprehensive records of all allegations made against adults working or volunteering with children, including:

1. What the allegations were
2. How the allegations were followed up
3. How things were resolved
4. Any action taken
5. Decisions reached about the person’s suitability to work with children.

We will keep these records to enable us to give accurate information if we are ever asked for it. For example:

• In response to future requests for a reference
• If a future employer asks for clarification about information disclosed as part of a vetting and barring check
• If allegations resurface after a period of time.

Storing records relating to adults

Head Up! will store records relating to concerns about an adult’s behaviour in their confidential personnel file. This will only be accessed by members of the safeguarding or management team on a need to know basis. We will:

• Keep a log of access to these confidential files, including which files have been accessed, by whom and on what date.

Retention periods: concerns about adults

If concerns have been raised about an adult’s behaviour around children, we must keep the records in their personnel file either until they reach the age of 65 or for 10 years – whichever is longer (IRMS, 2016; Department for Education (DfE), 2020). This applies to both volunteers and paid staff.

• We must keep these records for the same amount of time regardless of whether the allegations were unfounded. An unfounded allegation is one that is not proven.
  • However, if the allegations are found to be malicious we will destroy the record immediately. A malicious allegation is one that is proven to be untrue and made in order to cause harm to the accused.
• Information must be kept for this length of time even if the person stops working or volunteering for Head Up!
  • In some cases, records should be kept for longer periods (see further section).

Exceptions

In some cases, records may be kept for longer periods of time. For example, if:

• The records provide information about a child’s personal history, which they might want to access at a later date
• The records have been maintained for the purposes of research
• The information in the records is relevant to legal action that has been started but not finished
• The records have been archived for historical purposes (for example if the records are relevant to legal proceedings involving the organisation).

Where there are legal proceedings Head Up! will seek legal advice about how long to retain our records.

Some records are subject to statutory requirements and have a specific retention period. This includes records relating to:

• Children who have been ‘looked after’ by the local authority
• Adopted children
• Registered foster carers
• Residential children’s homes.

When records are being kept for longer than the recommended period, files will be clearly marked with the reasons for the extension period.

Disclosure and Barring Service (DBS) checks

Head Up! will store an electronic copy of criminal records check certificates in order to demonstrate safer recruitment compliance and facilitate the auditing of safeguarding practices. These will be stored securely, and only accessible to designated members of the Head Up! team including the safeguarding officers and mentoring coordinators.

Electronic copies of criminal records check certificates will be deleted along with mentors’ personal information thirty-six months from the date a mentor informs us they no longer wish to mentor with Head Up!. If an individual has a safeguarding record on their personnel file (following concerns that have been raised) we are required to keep these records for longer. Please read the specific section on ‘Retention periods: concerns about adults’ and ‘Exceptions’ within this policy for further information.

Destruction of child protection records

When the retention period is finished, confidential records will be incinerated or shredded in the presence of a member of Head Up!. At the same time, any electronic versions of the record must be purged.

• If not shredded immediately, all confidential records must be held in a secured plastic bag, labelled as confidential and locked in a cupboard or other secure place; or placed in a confidential waste bin.
• If Head Up! is closed down, we will make arrangements for the ongoing management of records, which includes the review, retention and disposal of records.

For details of our general privacy policy (i.e. relating to issues besides safeguarding reports), please see our Privacy Policy.

Whistleblowing Policy

We, at Head Up! aim to conduct ourselves ethically, and with honesty and integrity. We expect the same high standards from all of our people – staff, trustees, and volunteers.

We do, however, recognise that there may be occasions when we – or our people – do not get this right. In these instances, you may feel that you need to raise your genuine and serious concerns through this whistleblowing policy.

The aims of this policy are to:

1. Provide an effective way for you to raise serious concerns
2. Ensure that you receive feedback on any action undertaken by us as a result of you raising serious concerns
3. Ensure that you will be supported and protected from reprisals or victimisation for having raised your concern in good faith
4. Signpost you to further options available to you if you are dissatisfied with our response, or if internal investigation is not appropriate
5. Allow Head Up! to take action against any employee who makes allegations in bad faith and/or publicly discloses information when it is unreasonable for them to do so.

Definition

‘Whistleblowing’ is a term used to refer to the internal or external disclosure of malpractice as well as illegal acts, or omissions, at work. It covers, for example, how we raise funds, how we commission work or make payments.

Protecting individuals using this policy

The Public Interest Disclosure Act 1998 amended the Employment Rights Act 1996 and it provides protection for individuals who raise legitimate concerns about specified matters, outlined below.

These are called qualifying disclosures. A qualifying disclosure is one made in good faith by an individual who has a reasonable belief that any of the following has occurred:

1. A criminal offence (including fraudulent and corrupt behaviour, e.g. theft, fraud or malpractice)
2. A miscarriage of justice
3. An act creating risk to health and safety
4. An act causing damage to the environment
5. A breach of any other legal obligation, or
6. Concealment of any of the above.

It is not necessary for you to have proof that such an act is being, has been, or is likely to be, committed. You do, however, need to hold a reasonable belief of such an action having been, being or likely to be carried out.

If you make such a protected disclosure, you have the right not to be dismissed, subjected to any other detriment, or victimised. This is the case even were it to materialise that you were genuinely mistaken. We will not tolerate any individual being subjected to a detriment as a result of their making a disclosure in good faith.

Under the law, volunteers are not afforded the same legal protection that is afforded to employees. At Head Up!, however, we want to promote and encourage an open and honest environment in which concerns can be freely raised. We will therefore, in so far as is possible, aim to treat all individuals making a disclosure in the spirit of the Public Interest Disclosure Act 1998.

Malicious disclosures

If it is found that you have maliciously raised a matter that you know to be untrue or you are involved in any way in the malpractice, wrongdoing or illegal acts or omissions, your behaviour may be addressed through the appropriate Head Up! policy.

Non-whistleblowing concerns

This policy is only to be used in the exceptional circumstances as outlined by the list of qualifying disclosures, above. There are a number of Head Up! policies that will be relevant in other circumstances.

This list includes but is not limited to:

• Safeguarding and child protection
• Online safety
• Managing Allegations Against Members of Staff / Volunteers

Raising a concern

You should raise your whistleblowing concern as soon as possible. This will make it easier to act and enable any problems to be resolved or reported quickly.

You can make your disclosure orally but written disclosures are preferable as these will make the process more efficient and effective. In your disclosure, you should:

• Provide any relevant context and background, including relevant dates, venues, names etc.
• State clearly the reason why the situation has causes for concern.

You must say that you are raising your concern using the whistleblowing policy and whether you wish your identity to be kept confidential. While we will make every effort to deal with your case confidentially, depending on the circumstances of the case this may not always be possible. Where this is the case, you will be informed of this and the reasons why it was not possible.

We will consider anonymous disclosures, but we do not encourage them as anonymity often makes it difficult to properly investigate concerns, protect staff or give feedback on outcomes.

Who should I raise it with?

You should look to raise the matter with a member of the Head Up! Management Team in the first instance. Ideally, this should be the President, Vice President or member of the safeguarding team.

Where this is not appropriate because they may be involved in the alleged malpractice, wrongdoing or illegal acts or omissions in some way, raise your concern with another member of the Head Up! Management Team or the Designated Safeguarding Trustee (Fenella Cannings-Jurd – whistleblowing@head-up.org).

If appropriate, the member of the Head Up! Management or Trustee Team may arrange for the concern to be investigated externally and independently of Head Up!, and for appropriate follow-up action to be taken.

What happens after I raise a concern?

Your disclosure will always be acknowledged within three working days.

It will be investigated by the Head Up! Management Team Member or Trustee that you raise your concern to.

They will arrange to meet you as soon as possible to enable you to explain your concern, as outlined above. We may not always be able to keep your details confidential but we will always let you know if it is not possible to do so.

You will be told either at the meeting or as soon as possible afterwards, what action will be taken to address the concern you have raised. Where action is not taken, you will be informed and given an explanation. The action taken in response to a disclosure will depend on the nature of the concern.

Typically, the matters raised may result in one or more of the following:

• No action required
• Action being taken under an alternative Head Up! policy or procedure
• An internal investigation under this policy
• A referral to the police or relevant statutory body
• An independent enquiry.

Any Head Up! Management Team Member or Trustee receiving a potential whistleblowing concern must notify the Head Up! President or Vice-President immediately that a concern has been raised and inform them of progress in resolving the concern, unless the concern involves the President or Vice-President themselves. In this instance, the most senior, but appropriate person must be informed.

Raising a concern externally

We strongly encourage you to exhaust the internal processes set out above in the first instance. In exceptional or urgent circumstances, however, or where, having made a disclosure, you are unhappy with the outcome, you may decide to make a disclosure to an external body. For whistleblowing concerns of a safeguarding nature, this may be the NSPCC Whistleblowing Helpline (0800 028 0285) and for whistleblowing concerns of a non-safeguarding nature, this may be the Protect Advice Line (020 3117 2520).

Similar to the rights and obligations of an employee, Head Up! reserves the right to make a referral to the above agencies without your consent.

Making a disclosure to the press / on social media

Disclosures to the press and posts on social media in a derogatory or inflammatory way in regards to Head Up! will not be considered reasonable and may constitute misconduct. As such, the matter might be treated as a disciplinary matter in accordance with our disciplinary and grievance policy and procedure.

Contact Details

Nominated child protection lead / designated safeguarding lead(s)

Name: Eleanor Bartram

Email: safeguarding@head-up.org

Phone number: 07542 003022

Head Up! President

Name: Holly Parrish

Email: lead@head-up.org

NSPCC Helpline 0808 800 5000

Review Schedule

These policies came into force on 23rd August 2020.

We are committed to reviewing our policy and good practice annually.

These policies and accompanying procedures were last reviewed on 3 November 2024.

Signed,

Holly Parrish, President