Prepared June 2023
The Building Centre Group Limited and The Built Environment Trust (“the Organisation”) operates out of premises at 26 Store Street, which consists of public spaces as well as private offices, and runs activities including exhibitions, workshops and meetings.
The Organisation acknowledges a duty of care to safeguard and promote the welfare and safety of children and adults at risk. We are committed to ensuring safeguarding practice which reflects statutory responsibilities, government guidance and Charity Commission Guidance. The purpose of this policy is:
We aim to ensure that all children and adults at risk have a positive and enjoyable experience of our organisation in a safe environment.
We recognise that:
We will work to ensure that children and adults at risk are protected from harm when they are participating in our activities, whether our activities are delivered online, off‐site or on our premises.
This policy applies to anybody working for or on behalf of the organisation regardless of whether they receive payment or not. For ease, everybody in this group will be referred to as a ‘worker’ throughout this policy.
For the purpose of this policy:
Children in this policy refers to a person under the age of 18.
An adult at risk is somebody who is aged 18 or over and who is in, or may need, community care services for reasons including a mental health condition, cognitive or physical disability, sensory impairment, age or illness and is therefore unable to care for themselves or not able to protect themselves against harm or risk of harm, such as abuse or neglect.
A responsible adult refers to the person who is responsible for the welfare of the child or adult at risk during their visit or participation in one of our activities. This might be a teacher, group leader, parent or friend.
A legal guardian is the person with legal authority and responsibility for a child or an adult at risk. This can be a birth parent or somebody appointed by the courts.
This policy is based on the law and guidance that seeks to protect children and adults at risk in England and Wales.
Government guidance (such as Working Together to Safeguard Children, published in 2018) makes it explicitly clear that private sector, voluntary and religious bodies which work with children must have rigorous arrangements in place to reflect the importance of safeguarding and promoting the welfare of children.
Other relevant legislation is contained in:
The person named below takes responsibility for providing safeguarding support and advice to workers and for ensuring that safeguarding is a priority in the work of our organisation.
To report a concern or incident relating to a child:
Camden Children & Families Contact Services (office hours): 020 7974 3317
Camden Children & Families Contact Services (out of office hours): 020 7974 4444 (option 1)
Children & Families Contact Services: LBCMASHadmin@camden.gov.uk or
To report a concern or incident relating to an adult
Telephone number Camden Adult Social Care: 020 77974 4000
Email address for Camden Adult Social Care: email@example.com
Or call the Police: 999
Principles we apply to keep children and adults at risk safe include:
If this organisation removes an individual or an individual leaves from work because of safeguarding issues, then we will make a report to the Government’s Disclosure and Barring Service liaising as necessary with the Local Authority Children’s Services department and police. We will involve parents and children appropriately.
Roles and Responsibilities
We take the safeguarding of children and adults at risk very seriously. Operationally Head of Learning is responsible for the implementation of, and compliance with, this policy. Day‐to‐day it is the responsibility of line managers or key contacts to ensure that workers understand and are working in accordance with this policy; this could be through observations, testing knowledge in one‐to‐one meetings or identifying workers for further training.
Compliance and Training
All employees, Trustees and long‐term freelancers are given a copy of this policy prior to their start date. They must read, sign and return this document prior to their start date to confirm that they have read and understood its content.
The Organisation will carry out Disclosure & Barring Service ‘DBS’ checks on all workers who are responsible for planning and implementing programmes attended by children and adults at risk. If there is a gap in service of more than one year a new DBS will be carried out.
Partners and third‐party consultants are expected to follow the same safeguarding procedures as staff and volunteers. Their contact is responsible for ensuring that all groups comply and that they read the policy prior to commencing any work.
We will provide training on safeguarding to all new staff and volunteers who work with children and adults at risk, as part of their mandatory induction programmes.
Photographs, films or sound recordings in which children or adults at risk can be identified must not be taken without obtaining written permission. This applies to all photographs, film or sound recordings that may be used in any form of publication or broadcast including leaflets, brochures, websites, social media, film etc.
Where photographs, films or sound recordings of large‐scale events or public areas are required and it is not feasible to obtain consent because of the number of people involved, or where people are too distant to be recognisable, a notice should be prominently displayed in advance of and during the photography/filming/recording informing attendees that photographs/films/recordings will be taking in that area. Standard working for generic notices should read:
‘Photography and filming may take place at this activity/in the area/at this event. If you do not wish to be included, please let the photographer know.’
In case of groups, consent from the child’ parent or legal guardian will be required and this should be requested via the school or group leader in advance of the activity. Where a school has an all‐inclusive photo consent for all children, we will ask to see a copy of the form. If this is not possible, we will ask the school to confirm in writing that this includes third party partners such as BET.
The Mental Capacity Act (2005) states that for adults at risk, written permission should be obtained from the adult themselves in a way that is accessible to them – their responsible adult should be consulted about the best way to do this, but this might include using images or easy read language. If this is not possible because the adult at risk does not have the capacity to give their permission, photographs, films or sound recordings which can identify the person should not be taken.
Any information which could be used to identify or trace a child or adult at risk should be withheld (e.g. names of individuals, schools, groups or institutions). Crests, badges and uniforms should not be shown‐ or the names should be digitally obscured. Where providing the name of an individual, school etc. it is important (e.g. when celebrating an achievement, competition winners etc.) written permission is needed.
Consent can be withdrawn at any time. If there is a need to verify the identity of the person in the photograph or the person requesting the withdrawal, the image will be withdrawn whilst this is happening.
Though there is no specific timescale for expiry of consent, it is good practice to not use photographs or video that are more than five years old, unless there is a specific reason for doing so, such as a history talk or anniversary.
All photographs, videos and sound recordings will be stored digitally in a folder with restricted access. This folder will be titled with the date and name of the event at which the photograph, video or sound recording was taken. Scans of completed photo consent forms corresponding to the event will be kept in a separate folder, this folder will also have restricted access. All paper copies of consent forms will be shredded.
Digital and online
When this policy refers to digital or online activities, it means somebody using a device to gain access to the internet. How somebody accesses the internet or ‘gets online’ will vary massively especially as technology is changing so rapidly, it might include using their own smartphones or tablets/computers provided by the BET. When using an online platform or service (Zoom, Instagram etc.) all accounts should be set up in the organisation’s name and be purely for professional purposes. We look to limit the use of workers using personal equipment when engaging with children and adults at risk but understand this might not always be possible. Where this isn’t possible, we ask the person to let us know.
We will not provide content for or target children under 13 using social media.
When there are concerns about the welfare of a person, which have occurred during a digital engagement, we will follow safeguarding procedures as outlined in this policy to respond to these. The context of the abuse / harm occurring online is no different to other situations where there is a concern about a person’s welfare.
It is important to remember it is not the technology itself that is the source of harm but rather the behaviour of another person that causes harm whilst online. Removing particular device or stopping an activity is therefore not an appropriate response to safeguarding anybody from harm online. Our response to harm / potential harm experience online should be the same as the response to harm experience by a person in the ‘real world’.
If an incident occurs involving a child or an adult at risk, there are two types of reporting procedures to follow depending on the type and seriousness of the incident. The type of incident is either a Category A or a Category B Incident. All reporting should be a fact‐finding, neutral process, without judgement and should not amount to an investigation of the incident. See Appendix A for reporting Digital or Online Safeguarding Incidents to external organisations.
A Category A Incident is an incident that meets the threshold of harm / risk of harm and is an allegation of which the Safeguarding Lead should notify the Children and Family Services or Adult Social Care Services in the relevant borough.
This is when somebody has:
Examples are witnessing or disclosure of physical, sexual or emotional abuse; witnessing or disclosure of radicalisation; or anything of a serious nature that would require the involvement of a third party such as the police or a local authority.
In addition, these procedures should be applied when there is an allegation that any person who works with a child or adult at risk has:
A potential Category A Incident must be reported to the relevant Safeguarding Lead immediately using the Safeguarding Incident Report Form. If the Safeguarding Lead is absent, it should be reported to the Senior Safeguarding Lead. When informed of a concern or allegation, the designated Safeguarding Lead should not investigate the matter, but they should continue to gather information regarding the incident and ensure any evidence is preserved.
If it is decided that the incident meets the threshold of harm / risk of harm and therefore is an allegation and a Category A Incident, the Safeguarding Lead should notify the appropriate Children and Family Services or the Adult Social Care Services within one working day. If appropriate, the police should also be notified within on working day – or immediately if necessary.
If it is decided that the incident does not meet the threshold for harm / risk of harm and is a concern only it should be classed as a Category B Incident.
If the designated Safeguarding Lead is unclear whether the incident meets the threshold of harm / risk of harm they may wish to seek advice from the Children & Family or Adult Social Care Services.
A Category B Incident is an incident that can be dealt with internally. It might include:
All Category B Incidents must be recorded on the Safeguarding Incident Report Form and passed to the relevant Safeguarding Lead who will review and store the forms securely. They will also take steps to ensure all relevant workers are informed and procedures put in place or updated to minimise any further incidents.
Some incidents may initially be a Category B and become a Category A Incident if the details of the incident change, e.g., a lost adult at risk is initially a Category B Incident but will become a Category A Incident if the responsible adult is unable to be located.
For all incidents which have taken place online, using a digital platform, the relevant Safeguarding Lead should contact the relevant organisations if appropriate and as listed in Appendix A.
Information Requests: Workers must not give anyone (except for emergency services and social services) information about children or adults at risk, regardless of who the person claims to be. Any request for information, including whether the child or adult at risk is in our building and where, should be dealt with by contacting the child or adult at risk’s responsible adult who should take the decision whether to provide the information.
Physical Contact: Physical contact between workers and children or adults at risk is strongly discouraged and workers should never initiate physical contact. It is acknowledged that some children or enthusiastic adults at risk may make spontaneous contact with workers and that this is unavoidable. In case for a First Aid incident the procedures below will be followed.
Unaccompanied Children or Adults at Risk: The Organisation encourages and welcomes people of all ages and abilities to participate in our programmes. Responsible adults or carers should remain with their children or person they care for throughout the session. All activities for unaccompanied children or adults at risk are risk assessed to identify any risks to the children, adults at risk or workers, but it is our stance that under no circumstances should workers be alone with children or adults at risk and should avoid situations where they cannot be clearly seen. Workers should never take children or adults at risk to the toilets, either as individuals or in a group or run one‐to‐one digital sessions without parent/carer’s consent.
First Aid Incidents: In emergency situations, First Aiders may administer first aid as required without contacting the person’s parent/carer. However, after the emergency comes to an end or the emergency services are called and have arrived, they should be contacted immediately. Workers who are not qualified first aiders should not provide anyone with access to first aid equipment or provide first aid. Workers should not give a child or adult at risk medication or help them take medication. All first aid training for workers should include a section on safeguarding.
In the event of a non‐urgent first aid incident involving an unaccompanied child suspected of being under 16 or an adult at risk who is judged incapable of making an informed decision and requires first aid, a worker should contact the person’s parent/carer before first aid is administered. Children aged 16 or over or adults at risk judged competent to decide will be offered first aid only by a qualified first aider (where possible the qualified first aider should be a teacher or group leader) and asked whether they would like their parent/carer to be contacted. Where possible and appropriate two workers should be present whilst first aid is being administered.
Lost Children or Adults at Risk: If a child or adult at risk becomes separated or lost from their group or responsible adult, they should be brought to the Reception Desk. Security will contact a member of staff to see if they have been reported missing, if not, then Security will try to locate their group or adult. At no point should a single worker take the person to a non‐public area, such as the toilet or the staff room. If the person needs the toilet, they should be accompanied by two workers who wait outside.
If a responsible adult becomes separated from their child or adult at risk and they approach a worker, the worker should take the adult to the Reception Desk where they will be asked for a description of the child or adult at risk and a member of the Organisation will then search the building. The responsible adult will be asked to wait at the Reception Desk.
If the person or their group cannot be found, then the situation needs to be escalated and social services or police called as it will become a Category A Incident.
In both instances details about the child or adult at risk should not be broadcasted publicly.
Where to report Digital and Online Safeguarding Incidents.
Possible indicators of abuse to help workers identify harm or risk of harm. Evidence of any one indicator from the following lists should not be taken on its own as proof that abuse is occurring. The lists of possible indicators and examples of behaviour are not exhaustive and people may be subject to a number of abuse types at the same time.
Physical – injuries involving softer tissue and in areas that are harder to damage through slips, trips falls and other accidents, for example: upper arm, chest, abdomen or face.
Sexual – Sexual abuse may take place either in person or online or offline. Possible indicators include non age-appropriate behaviours (actions or language), self-harming or reluctance to be alone with a particular person.
Emotional – Some level of emotional abuse is present in all types of abuse or neglect, though it may also appear alone. Possible indicators include concerning interactions between parent or career and the child (e.g. overly critical or lack of affection), signs of distress (tearfulness or anger) or lack of empathy shown to others (including cruelty to animals).
Neglect – Neglect is a persistent failure to meet basic needs (physical or emotional. Possible indicators include excessive hunger, poor personal or dental hygiene or untreated medical issues.
Physical – no explanation for injuries or inconsistency with the account of what happened, signs of malnutrition, bruising, cuts, welts, burns/and or marks on the body or loss of hair in clumps.
Domestic violence – Domestic violence and abuse includes any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been, intimate partners or family members regardless of gender or sexuality. It also includes so called 'honour’ -based violence, female genital mutilation and forced marriage. Possible indicators are verbal abuse or humiliation in front of others, limited access to money, feeling that
the abuse is their fault when it is not.
Sexual – bleeding, pain or itching in the genital area, pregnancy in a woman who is unable to consent to sexual intercourse, self-harming or reluctance to be alone with a particular person.
Emotional – an air of silence when a particular person is present, low self-esteem or uncooperative and aggressive behaviour.
Financial – missing personal possessions, unexplained lack of money or inability to maintain lifestyle or disparity between the person’s living conditions and their financial resources, e.g. insufficient food in the house.
Discriminatory – Unequal treatment based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex or sexual orientation (knows as ‘protected characteristics’ under the Equality Act 2010. Possible indicators are person appears withdrawn and isolated or expression of anger, frustration, fear or anxiety.
Organisational or institutional abuse – poor standard of care, public discussion of personal matters, unnecessary exposure during bath or using the toilet or lack of personal clothing and possessions and communal use of personal items.
Modern slavery – signs of physical or emotional abuse, appearing to be malnourished, unkempt or ithdrawn, lack of personal effects or identification documents or avoidance of eye contact, appearing frightened or hesitant to talk to strangers.
Neglect – poor physical condition and/or personal hygiene, untreated injuries and medical problems or inappropriate or inadequate clothing.
Self-neglect – very poor personal hygiene, unkempt appearance, lack of essential food, clothing or shelter or inability or unwillingness to take medication or treat illness or injury.