Safeguarding Children and Young People Policy

1. Policy Statement

1.1 TRAIN believes:

• That children and young people should never experience harm or abuse of any kind.
• We have responsibility to promote the welfare of all children and young people and to keep them safe.
• Operating in a way that protects all children and young people is critical. Any disclosures be they regarding conduct outside of TRAIN or within TRAIN premises and/or programmes will be taken seriously and dealt with in line with this policy.

1.2 TRAIN recognises that:

• The welfare of the child and young person is paramount, as stated in the Children Act 2004. This Policy is based on the legal and statutory definitions of a child (defined as being up to 18 years old). Therefore, “a child or young person” means anyone under the age of 18 years.
• The term Safeguarding means that we will take all reasonable measures to ensure that the risk of harm to child’s and young person’s welfare and development is minimised.
• This policy has been developed in accordance with Working Together to Safeguard Children 2026 (DfE, March 2026), the current statutory guidance on multi-agency working to help, protect and promote the welfare of children in England, and should be read alongside it.
• All children and young people, regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion, belief, sex, and sexual orientation, have a right to equal protection from any type of harm or abuse.
• Safeguarding children and young people is the responsibility of every individual working for TRAIN, irrespective of their role.
• Working in partnership with children and young people, their parents, carers, and other agencies is essential in promoting children and young people’s welfare and preventing abuse.
• It is essential that everyone is clear on how to report a concern about the safety of children and young people. A timely and appropriate response will be given to all suspicions, allegations of abuse, or poor practice.

1.3 The purpose of this policy

• Protect children and young people who access any provision from TRAIN.
• Provide staff and volunteers with the framework and principles that guide our approach to safeguarding and child protection.

1.4 Types of abuse

Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. The main categories are:

• Physical abuse
• Emotional abuse
• Sexual abuse
• Neglect

1.5 Specific safeguarding issues

TRAIN recognises that safeguarding concerns may relate to a range of specific harm types. These include but are not limited to:

• Child sexual exploitation (CSE): where a child is manipulated or coerced into sexual activity, often in exchange for something they need or want.
• Child criminal exploitation (CCE): where a child is manipulated or coerced into criminal activity, including county lines drug distribution.
• Extra-familial and contextual harm: harm occurring outside the home, including in community settings, public spaces, or through peer relationships.
• Online harm: abuse, exploitation, or grooming facilitated through the internet or digital technology.
• Peer-on-peer abuse: harm caused by one young person to another, including bullying, sexual harassment, and coercive behaviour.
• Radicalisation and extremism: the process by which a young person is drawn towards terrorist or extremist ideology (see also the Prevent duty).
• Female genital mutilation (FGM): a form of child abuse and a criminal offence in the UK.
• Honour-based abuse: abuse committed in the name of so-called “honour,” including forced marriage.
• Domestic abuse: as a contextual risk factor significantly affecting children’s welfare and safety.

2. Organisation and Responsibilities

TRAIN seeks to provide an environment where all children and young people are safe, secure, valued, respected, happy and listened to.

2.1 The CEO shall:

• Ensure all staff and volunteers have access to, are familiar with, and know their responsibilities as set out by this Policy.
• Appoint a Designated Safeguarding Lead (DSL) and ensure a clear line of accountability with regards to safeguarding concerns.
• Always follow safe recruitment procedures for staff and volunteers, as laid out in P12 Safe Recruitment Policy.
• Ensure that all staff and volunteers complete an OSCP Generalist Safeguarding course prior to working with young people, and refreshed every two years thereafter. Employed youth work staff must complete OSCP Advanced Safeguarding training, also refreshed every two years. The DSL must complete DSL-level safeguarding training, refreshed every two years. Trustees must complete awareness-level training covering their legal safeguarding responsibilities.
• Ensure all members of staff and volunteers read and adhere to this Policy and know whom to contact if a safeguarding disclosure is made.
• Ensure all staff and volunteers undertake the appropriate safeguarding training to keep children and young people safe from harm.

2.2 The Board of Trustees shall:

• Set a culture of safeguarding being a core priority, creating a safe and open environment where concerns are taken seriously.
• Ensure all safeguarding policies are up to date and reviewed annually in line with UK legislation.
• Be ultimately accountable for ensuring settings are safe and the CEO and DSL are delivering against their responsibilities.
• Be responsible for reviewing safeguarding reports on a quarterly basis, monitoring any trends and if any safeguarding cases exceed thresholds, as per Section 4.1 of this policy. Ensuring lessons are learnt and processes adhered to.
• Appoint a Board Safeguarding Champion to take a lead role in supporting, advising and guiding the Board on safeguarding matters. The appointment of a Board Safeguarding Champion does not reduce the collective responsibility of all trustees for safeguarding governance.

2.3 All staff and volunteers shall:

• Ensure that the children and young people know they can approach any of the members of TRAIN if they are worried about something, or have any concerns, and they will receive a consistent, supportive response set out in this Policy.
• Keep accurate written records of all concerns and reports for a child and young person in line with the Data Protection Policy.
• Must refer any concerns or allegations to TRAIN’s DSL, who will then report to internal and external parties appropriately.
• Commit to taking appropriate action to address any concerns by working in full partnership with other agencies.
• Not, under any circumstances, use their own personal devices such as a mobile phone, tablet or computer to contact a young person, on their personal number, social media, email address or other personal means or hold any personal information of young people or their parents on their personal devices.
• Will not share personal contact details with young people unless strictly agreed to with permission from the CEO with a reasonable explanation.
• Must not photograph or film children or young people using personal devices. All photography and filming must use TRAIN equipment only, with consent obtained in accordance with TRAIN’s media consent policy and processes.
• Must not connect with or follow children or young people on personal social media accounts. Any social media communication with young people must be through TRAIN’s official accounts only.

2.4 The Designated Safeguarding Lead (DSL) shall:

• Be aware of any children and young people who are subject to a child protection plan and communicate all implications to relevant staff members.
• Respond in a timely manner to any safeguarding concerns.
• Keep an accurate record of all safeguarding concerns, safeguarding allegations and low-level concerns reported.
• Record, store, and use information confidentially and securely, in line with data protection legislation and guidance.
• Refer allegations to Social Services or to an appropriate agency quickly and effectively where necessary, and certainly within 24 hours. These agencies could include the Multiagency Safeguarding Hub, Locality Community Support Service or Local Authority Designated Officer (LADO) for advice or guidance.
• In the absence of the DSL, the CEO or another Deputy DSL will assume DSL responsibilities. In the unlikely event that no deputy DSLs are available, staff should contact the Chair of Trustees in the first instance. Contact details are listed in Section 6 of this policy. In no circumstances should a safeguarding concern be left unaddressed pending the availability of the DSL.

3. Safeguarding Thresholds

If you are unsure whether a concern meets any of the thresholds below, report it to the DSL without delay. When in doubt, always report.

3.1 Safeguarding concern

A safeguarding concern is any concern that a child or young person is, or may be, at risk of harm, abuse or neglect. This includes harm occurring inside or outside the home, in the community, online, or through exploitation. A safeguarding concern requires prompt reporting to the DSL. Staff and volunteers must not attempt to investigate concerns themselves. A safeguarding concern may lead to a range of responses. The DSL will assess the information and determine the appropriate course of action.

Examples include:

• A disclosure of abuse or neglect by a child or young person
• Signs or indicators of harm, abuse or neglect
• Concerns arising from something a young person has said, done or presented
• Historic disclosures, including those relating to events before the young person’s involvement with TRAIN

3.2 Safeguarding allegation

A safeguarding allegation is a concern that an adult working with children, including staff, volunteers, trustees or contractors, has:

• behaved in a way that has harmed, or may have harmed, a child or young person
• possibly committed a criminal offence against or related to a child
• behaved towards a child in a way that indicates they may pose a risk of harm
• behaved in a way that suggests they may not be suitable to work with children, including conduct outside of work

Allegations must be reported immediately to the DSL. If the allegation concerns the DSL, it must be reported to the CEO or Chair of Trustees.

3.3 Low-level concern

A low-level concern is a concern about an adult’s behaviour towards or around children that does not meet the threshold of a safeguarding allegation, but is inconsistent with TRAIN’s expected standards of conduct. Low-level concerns relate to adult behaviour only. They are not a lesser version of a concern about a child’s welfare.

Examples include:

• Inappropriate comments or language in the presence of young people
• Minor boundary breaches such as favouritism or overly familiar conduct
• Behaviour that feels uncomfortable or out of place but cannot yet be defined as harmful

All low-level concerns must be recorded and reported to the DSL. They will be reviewed to identify patterns or emerging risk. Reporting low-level concerns is an essential part of maintaining a safe culture and will always be taken seriously. Multiple low-level concerns, when considered together, may meet the threshold of a safeguarding allegation.

4. Reporting a Disclosure

All safeguarding concerns must be reported to the DSL without delay. All safeguarding allegations must be reported to the DSL immediately, or to the CEO or Chair of Trustees if the allegation concerns the DSL. Safeguarding concerns and allegations will be escalated beyond the DSL in the following circumstances:

• To CEO / trustees where:
  • The concern involves a member of staff, volunteer or trustee
  • There are serious concerns, repeated low-level concerns, or safeguarding allegations indicating organisational risk
  • The DSL requires additional oversight or support
• To external agencies (e.g. children’s social care or police) where:
  • A child or young person is at risk of, or experiencing, significant harm
  • A criminal offence may have been committed
  • Immediate protection is required

Where there is uncertainty about thresholds, the DSL will seek advice from the local safeguarding partnership or relevant statutory agencies.

All staff and volunteers should be aware that they can make a direct referral to external agencies if they believe a child is at immediate risk of harm and should inform the DSL as soon as possible.

Procedure

At the point of disclosure, listen to what the child or young person is saying without interruption and without asking leading questions. Respect the child’s/young person’s right to privacy but do not promise confidentiality, explain that it may be necessary to consult a senior colleague. Reassure the child/young person that they have done the right thing in talking about any concerns.

Report what has been disclosed to the DSL as soon as practical.

1. Record in writing, as soon as practicable, what was said using the child’s/young person’s actual words.
2. Sign and date the record and store as soon as possible on the child’s/young person’s file.
3. The DSL will:
   1. Assess any urgent medical needs of the child/young person.
   2. Consider whether the child/young person has suffered, or is likely to suffer significant harm.
   3. Check whether the child/young person is currently subject to a Child Protection Plan or has been previously subject to a Plan.
   4. Confirm whether any previous concerns have been raised by staff or volunteers.
   5. Consider whether the matter should be discussed with the child’s/young person’s parents or carers or whether to do so may put the child/young person at further risk of harm because of delay or the parent’s possible actions or reactions.
   6. Seek advice if unsure that a child protection referral should be made.
   7. Complete a full written record of concern and any action taken.

5. Reporting Safeguarding Allegations Against a Member of Staff, Volunteer or Trustee

Where a safeguarding allegation is made against any member of staff, volunteer or trustee, a written report must be made to the DSL as soon as practical. This must use the child’s/young person’s actual words and any further relevant observations and details. The DSL will inform the Local Authority Designated Officer (LADO) at Oxfordshire County Council. If the complaints/allegations relate to the DSL, then concerns should be reported to the CEO or Chair of Trustees as appropriate.

In emergencies, or cases of immediate danger, safeguarding concerns must be reported to the police (via 999) or other relevant authorities immediately.

5.1 If safeguarding allegation thresholds have been met: CEO and Board responsibilities

• The parent/carer of the child or young person will be contacted as soon as possible, following advice from statutory agencies.
• The CEO and Chair of Trustees will be notified, who will then be responsible to inform the Charity Commission, where required, in line with the Serious Incident Report process covered in P01.
• Additional referrals (e.g. DBS, funders) in line with suitable threshold information.
• If the complaints raise serious safeguarding concerns, TRAIN shall consider the following actions:
  1. Apply appropriate disciplinary measures to any staff, volunteers or members found in breach of this Policy. This may include suspending the individual, taking into account the risks to other children/young people and the staff/volunteer concerned, until the matter is formally resolved. This could lead to dismissal and/or further action being taken against the staff member/volunteer.
  2. Provide appropriate support to the child or young person and victims of safeguarding incidents. If the allegation involves a young person/young volunteer, TRAIN will contact their parent/guardian/carer to advise them of the process and support available to them.

5.2 If safeguarding allegation thresholds are not met

• If the complaints/allegations are deemed by the DSL as low-level and do not meet the safeguarding threshold, the report should be kept on file to ensure patterns can be monitored.
• TRAIN will also consider any wider lessons that can be learned.
• If the complaint is found to be unsubstantiated, no action shall be taken against the person alleged to have breached the safeguarding policy.
• The DSL will inform the complainant of the outcome of the investigation and any actions taken as a result. This will be done within 7 working days of the conclusion of the investigation. However, where this impacts TRAIN’s duty to protect the confidentiality and safety of others, the DSL may limit the information that will be provided to the complainant.

5. Confidentiality

TRAIN operates under a policy of confidentiality, and it is essential that confidentiality is maintained at all stages of the process when dealing with safeguarding concerns. However, information that raises concerns about the safety and welfare of a child/young person must be disclosed.

Information relating to the concern and subsequent case management should be shared on a need-to-know basis only and kept secure at all times. All information must be treated confidentially and in accordance with the relevant data protection law.

6. Associated Policies

This Policy should be read in conjunction with the other associated policies, such as the Whistleblowing Policy, Code of Conduct, Adult Safeguarding Policy, and Safe Recruitment Policy.

6. Contact Details

For safeguarding, suspicions, concerns or disclosure, contact TRAIN’s DSL:

If the complaints/allegations relate to the DSL, or actions taken in response to a safeguarding concern being raised, contact the Chair of Trustees.

In the event that DSL or CEO cannot be contacted, staff should contact:

Children’s social care Multiagency Safeguarding Hub (MASH) at: 0345 050 7666, for any safeguarding incidents concerning young people.

OR

Thames Valley Police at: 999, for support from the police, in cases where a child is at immediate risk of harm.