Safeguarding children policy

The Macular Society is committed to safeguarding in line with national legislation and relevant national and local guidelines and best practice. The safeguarding policies and procedures are reviewed on a yearly basis and whenever there are changes in relevant legislation and/or government guidance as required by the Local Safeguarding Board, or as a result of any other significant change or event.

The policy below is regarding Safeguarding children, please also see our Safeguarding adults policy.

Safeguarding themes

Please note that below is not an exhaustive list.

Abuse and neglect

Abuse and neglect takes many forms and can be caused by single or repeated acts or a failure to act by any other person or persons, or in the case of self-neglect, the victim themselves. The circumstances of each individual case will be considered as to not limit what constitutes abuse or neglect.  The Macular Society will treat as a safeguarding concern where a child is suspected to be involved in either of the following:

Neglect

Includes the persistent failure to meet a child’s basic physical and/or psychological needs, likely the result in serious impairment of the child’s health or development.

Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

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

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

Possible indicators:

• excessive hunger
• poor personal hygiene
• frequent tiredness
• inadequate clothing
• frequent lateness or non-attendance at school
• untreated medical problems
• not brought to appointments
• poor relationships with peers
• compulsive stealing and scavenging
• rocking, hair twisting and thumb sucking
• running away
• loss of weight or being constantly underweight (the same applies to weight gain, or being excessively overweight
• low self esteem
• poor dental hygiene

Physical abuse

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

Possible indicators:

• physical signs that do not tally with the given account of occurrence,
• conflicting or unrealistic explanations of causer
• repeated injuries
• delay in reporting or seeking medical advice.

Sexual abuse

Includes: forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening.

The activities may involve physical contact, including assault by penetration (for example, rape or oral sex); or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing.

They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet).

Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.

Possible indicators:

• Changes in:
  • behaviour
  • language
  • social interaction
  • physical wellbeing
• It is important to recognise there may be no signs.

Emotional abuse

Includes: The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child's emotional development.

It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or 'making fun' of what they say or how they communicate.

It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child's developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction

It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children.

Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.

Possible indicators:

• lack of self-confidence/esteem
• sudden speech disorders
• self-harming (including eating disorders)
• drug, alcohol, solvent abuse
• lack of empathy (including cruelty to animals)
• concerning interactions between parent/carer and the child (e.g. excessive criticism of the child or a lack of boundaries)

Child Sexual Exploitation (CSE)

Includes: Child sexual exploitation is a form of child sexual abuse.

It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator.

The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.

Possible indicators:

• going missing from school/home/care placement
• associating with older people/adults
• isolation from family/friends/peer group
• physical symptoms including bruising/STI’s
• substance misuse
• mental health problems
• unexplained possessions, goods and/or money

Other type of abuse you should be aware of:

County lines

County lines exploitation describes how criminals from large urban areas supply drugs to suburban and rural locations, using vulnerable children and young people to courier drugs and money.

Typically, criminals use mobile phone lines to facilitate drug orders and supply to users. They also use local property as a base. These often belong to a vulnerable adult and are obtained through force or coercion. (This exploitation is sometimes referred to as ‘cuckooing’.)

It also finds that the age of those involved is getting younger, with children as young as 12 being targeted. Criminals ‘recruit’ through deception, intimidation, violence, debt bondage and/or grooming into drug use and/or child sexual exploitation.

While there has been an increased awareness of the use of children and young people in county line markets, more needs to be done, as it cuts across a number of issues such as drug dealing, violence, child sexual exploitation, safeguarding, modern slavery and missing persons.

Domestic abuse

Defined as:

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. This can encompass but is not limited to the following types of abuse: psychological, physical, sexual, financial or emotional. (Home Office, 2013)

Forced marriage

A forced marriage (FM) is a marriage conducted without the valid consent of one or both parties and where duress is a factor. Forced marriage is now a specific offence under section 121 of the Anti-Social Behaviour, Crime and Policing Act 2014.

FM is very different to an arranged marriage where both parties give consent.

Modern slavery and human trafficking

Modern slavery can take many forms including the trafficking of people, forced labour, servitude and slavery. Victims can include adults and children and come from all walks of life and backgrounds. A quarter of all victims are children.

The Modern Slavery Act 2015 places a duty on specified public authorities to report details of suspected cases of modern slavery to the National Crime Agency.

Indicators of Modern Slavery can include:

• lack of access to legal documents (e.g. passports)
• appearance (malnourished, unkempt, etc.)
• untreated or unexplained injuries
• attitude (withdrawn, frightened, unable to speak for themselves)
• indebtedness or in a situation of dependence
• frequent changes of location or restrictions on movement

Female genital mutilation

Female genital mutilation (FGM), sometimes referred to as female circumcision, refers to procedures that intentionally alter or cause injury to the female genital organs for non-medical reasons. The practice is illegal in the UK.

There are no health benefits to FGM. It is carried out for cultural and social reasons within families and communities. The procedure is traditionally carried out by an older woman with no medical training. Anesthetics and antiseptic treatment are not generally used and the practice is usually carried out using basic tools such as knives, scissors, scalpels, pieces of glass and razor blades.

Self-harm

Self-harm refers to an intentional act of self-poisoning or self-injury, irrespective of the motivation or apparent purpose of the act, and is an expression of emotional distress.

Self-harm can involve:

• Cutting, burning, biting
• Substance misuse
• Head banging and hitting
• Taking personal risk
• Picking and scratching
• Self-neglect
• Pulling out hair
• Disordered eating
• Overdosing and self-poisoning

Indicators of self-harm may include:

• changes in eating/sleeping habits
• Increased social isolation
• unexplained cuts, bruises or cigarette burns, usually on wrists, arms, thighs and chest
• keeping fully covered at all times, even in hot weather
• signs of depression, such as low mood, tearfulness or a lack of motivation or interest in anything
• self-loathing and expressing a wish to punish themselves
• not wanting to go on and wishing to end it all
• becoming very withdrawn and not speaking to others
• signs of low self-esteem, such as blaming themselves for any problems or thinking they're not good enough for something
• signs they have been pulling out their hair

People who self-harm can seriously hurt themselves, so it’s important that they speak to a GP about the underlying issue and request treatment or therapy that could help them.

Prevent - Extremism

From 1 July 2015 all schools, registered early years childcare providers and registered later years childcare providers are subject to a duty under section 26 of the Counter-Terrorism and Security Act 2015, in the exercise of their functions, to have “due regard to the need to prevent people from being drawn into terrorism”. This duty is known as the Prevent duty.

Settings subject to the Prevent Duty will be expected to demonstrate activity in the following areas:

• Assessing the risk of children being drawn into terrorism
• Demonstrate that they are protecting children and young people from being drawn into terrorism by having robust safeguarding policies.
• Ensure that their safeguarding arrangements take into account the policies and procedures of the Local Safeguarding Children Board.
• Make sure that staff have training that gives them the knowledge and confidence to identify children at risk of being drawn into terrorism, and to challenge extremist ideas which can be used to legitimise terrorism.
• Ensure children are safe from terrorist and extremist material when accessing the internet in the setting.

Preventing vulnerable adults and children from being drawn into extremism is a safeguarding concern. It is essential that frontline staff are able to spot the signs and make a safeguarding referral.

Indicators may include:

• Withdrawing from usual activities
• Accessing extremist literature/websites
• Expressing ‘us and them’ thinking
• Expressing feelings of anger, grievance or injustice.

Roles and Responsibilities

All staff and volunteers must:

• Understand the different types of abuse and recognise the possible indicators.
• Understand their responsibility to report any concerns that a child or adults is being, or is at risk of being, abused or neglected. This includes reporting any concern they may have regarding another staff member or volunteer’s behaviour towards a child or adult.
• If appropriate, liaise with other agencies, contribute to safeguarding assessments and attend multi agency safeguarding meetings.
• Record and store information legally, professionally and securely in line with organisational policies and procedures.
• Undertake the required level of training for their role in line.
• Understand the line of accountability for reporting safeguarding concerns, and be fully aware of the organisation’s Designated Safeguarding Leads and their role within the organisation.

Trustee Safeguarding Lead has overall responsibility for safeguarding. The Board of Trustees is ultimately accountable for ensuring the safety of all services provided by the Macular Society, including the implementation of effective safeguarding procedures. A designated Trustee provides a link between the Designated Safeguarding Lead and the Board. Safeguarding is an agenda item at every Board meeting. In addition the Trustee Safeguarding Lead will:

• receive and disseminate safeguarding reports to the Board.
• ensure that any concerns are cross-referenced with the risk register and will review any actions taken.
• be notified immediately when significant safeguarding issues arise

Designated Safeguarding Lead (DSL) is responsible for overall safeguarding oversight.

• This includes GDPR compliance, oversight of all safeguarding and risk escalation processes, referrals, ensuring all policies, procedures and practice guidance are adhered to. Reviews of these will take place annually.
• They will report regularly to the CEO and Trustee Safeguarding Lead or in the event of a safeguarding referral or a criminal investigation.
• They are the individual management review author for cases of domestic homicide and/or mental health reviews.
• They will monitor and review staff and volunteer training and induction.
• Triaging safeguarding concerns when they arise
• Ensuring that safeguarding actions are established, recorded and completed
• Overseeing that safeguarding concerns are appropriately referred to the Children Safeguarding Board
• Maintaining detailed and accurate written records of safeguarding and protection concerns
• Supported staff with debriefing after safeguarding concerns are raised.
• Working with others within the organisation to create a culture of safeguarding within the organisation.
• Coordinate the dissemination of the safeguarding children policy, procedures and resources throughout the organisation.
  Advise on the organisation’s training needs and the development of its training strategy.
• Liaise and escalate cases to the Case Management Team for review to determine if the concern is a safeguarding children concern and action to be taken.
• Receive reports of and manage cases of poor practice and abuse reported to the organisation – including an appropriate recording system.
  Support the chair to co-ordinate the case management process.
• Create a central point of contact for internal and external individuals and agencies concerned about the safety of children in contact with the organisation.
• Provide advice and support and play a lead role in the Macular Society’s training of safeguarding children.
• Represent the organisation at external meetings related to safeguarding along with the Case Management Team.

Emma Malcolm, Safeguarding Lead
Tel 07796 015 342, emma.malcolm@macularsociety.org

Hannah Keegan, Safeguarding Lead
Tel 01264 560 201, hannah.keegan@macularsociety.org

What to do if you are concerned about a child

You may become concerned about the safety or welfare of a child in a number of ways:

• The person may tell you
• The person may say something that worries you
• A third party may voice concerns
• You may see something – an incident or an injury or other sign.

If a safeguarding concern is suspected:

• Emergency situations: Where an immediate police or medical response is required e.g. if the person at risk is in immediate danger of harm/injury, emergency services 999 should be immediately contacted and the Designated Safeguarding Lead is then contacted at the earliest opportunity once it is safe to do so.
• For all other safeguarding concerns, the safeguarding concern must be reported to a Designated Safeguarding Lead. The Designated Safeguarding Lead will triage the safeguarding concern and lead on ensuring follow up actions are assigned, documented and completed.
• Observations, conversations or concerns will be recorded which should:
  • Include details of the concern and nature of risk
  • Be factual (who, what, where, when, how)
  • Be supported by available evidence e.g. a summary of what has been disclosed
  • Provide details of all actions taken

Include a detailed outline of outcomes and follow up actions required

Receiving a disclosure

Receive

Stop and listen if someone wants to tell you about suspicions of abuse. Listen quietly and actively, giving your undivided attention. Allow silences when needed. Do not show shock or disbelief and take what is said seriously.

Reassure

Stay calm and give reassurance to the person. Explain to them that they have done the right thing by telling you and that what has happened is not their fault. Never promise confidentiality but provide assurance that they have done the right thing.

React

Establish the facts of what has happened but do not ask leading questions. Keep questioning open, e.g. ‘Is there anything else you want to say?’ or ‘Can you tell me more about that?’ Ask “Who”, “What”, “When”, “Where”, and “How” questions. Do not criticise the perpetrator. Explain to the person what you will do next, e.g. you will need to pass this information to the Designated Safeguarding Lead. Make it clear that you be seeking advice/support/action Ask them how they would like information to be shared but do not make any promises. It is almost impossible to say what might happen in specific cases if there is a disclosure, so focus on exploring and mitigating fears, and being reflective and supportive.

Record

If possible, make brief notes about what the person is telling you as they are speaking. If this is not appropriate, write down what was said, as soon as possible. Record the date, time, place, your name and role and what was said (rather than your interpretation of it). Use the person’s language wherever possible. Note: In most cases it is more appropriate to listen and record immediately afterwards.

Notes should include:

• The date, time and method of contact (ie, telephone, in person, etc);
• Any allegations recorded using the client’s own words. Reflect the language and vocabulary of the young person. Include who, what where, when, how.
• The rationale behind any professional decision-making and actions. Clear recording of decisions is the basis of accountable practice.

If any other professionals across agencies are contacted to discuss safeguarding concern relating to the disclosure, then it is important to keep records of the following:

• Date
• Who spoke and their job title
• The reason that you spoke to the professional
• Whether this was a consultation where you did or did not name the client
• What information was shared and what the key points of the discussion were
• What actions you agreed on the basis of the discussion, along with timescales and responsibilities attached to these
• Any decisions or plans to discuss/not discuss any further safeguarding actions with the person
• Whether it has been necessary for the conversation to occur without the client’s knowledge or consent
• Any follow up to actions.

Report

Report the incident to your Designated Safeguarding Lead as soon as possible. If the matter is regarded as critical it should be referred to Emergency Services 999.

Recording and information sharing

With regards to information sharing, the child’s need for protection must always be the primary concern.

1. Decisions to inform the child and parent/carer about any referral will be informed by local inter-agency protocols; an assessment of any increased risk of harm to the child; and the possibility of prejudicing any subsequent police investigation. If in doubt about the decision and timing of informing a child and their family, seek advice from your line manager or local child protection services. In any event you must speak to your line manager as soon as possible and definitely on the same day.
2. Following consideration of the above, if you assess there is a risk, tell the child, as appropriate to their age and understanding, and parent/carer, that the referral will be made.
3. Contact must be made with the appropriate Child Protection services or Police, following local inter-agency procedures.
4. Share with Child Protection services any other relevant information or known risks about the child and family within the context of their wider family and environment.
5. Agree with Child Protection Services what the child and parents/carers will be told about the next steps, by whom and when and the actions which are required to be taken.
6. Referrals of suspected child abuse must always be confirmed by encrypted email or recorded delivery, using local referral protocols to the MASH/Duty Team/local child protection service/Gateway Services/etc within 24 hours.

Northern Ireland This should be done using a UNOCINI form.

Scotland If Child Protection Services do not make contact within five working days you must contact them for an update .

Wales In Wales, there are national safeguarding procedures that detail the essential roles and responsibilities for practitioners to ensure the safeguarding of children and adults who are at risk of abuse and neglect. The procedure helps practitioners to apply the legislation and statutory guidance for practice, and the pathway for the safeguarding referral criteria have been reduced to ‘a child at risk of harm’ under the SSWBA, 2014. The definition of a “child at risk” is a child who:

• Is experiencing or is at risk of abuse, neglect or other kinds of harm, and;
• Has needs for care and support (whether or not the Local Authority is meeting any of those needs).

There is a new duty for relevant partners of a local authority to report children at risk. If a partner has reasonable cause to suspect a child is at risk, it must inform the local authority of that fact.

When a child has been reported under Section 130 of the SSWBA 2014, the local authority shall make enquiries to enable them to decide whether they should take action to safeguard or promote the child’s welfare under section 47 of the Children Act 1989 i.e. practitioners will still need to use the Children Act 1989, section 47 in the same way as they do now when responding to safeguarding referrals. 

7. Ensure you inform your line manager as soon as possible and certainly on the same day and record all actions, decisions, risk assessments, and contact.

8. For regulated services and Family Placement services, ensure that you inform the relevant inspectorate within designated timeline.

9. If you become concerned that the situation has escalated and it seems that the child or young person is at increased risk of significant harm you must immediately contact the police on 999 and local child protection services to seek guidance on what to do.

10. If you are not satisfied that the child protection service’s response adequately safeguards the child then you must inform the DSL/Lead Trustee for Safeguarding for escalation.

All charity organisation must comply with the Data Protection Act (DPA) and the General Data Protection Regulations (GDPR). 

Information about concerns of abuse includes personal data.  It is therefore important to be clear as to the grounds for processing and sharing information about concerns of abuse.

Processing information includes record keeping. Records relating to safeguarding concerns must be accurate and relevant.  They must be stored confidentially with access only to those with a need to know
Sharing information with the right people, is central to good practice in safeguarding children. However, information sharing must only ever be with those with a ‘need to know’.

The purpose of data protection legislation is not to prevent information sharing but to ensure personal information is only shared appropriately. Data protection legislation allows information sharing within an organisation. For example:

• Anyone who has a concern about harm can make a report to an appropriate person within the same organisation
• Case management meetings can take place to agree to co-ordinate actions by the organization

Any decision to share or not to share information with an external person or organisation must be recorded together with the reasons to share or not share information.

Multi-agency working

The Macular Society may need to cooperate with the local authority and the police including to:

• Provide more information about the concern you have raised.
• Attend safeguarding meetings.
• Coordinate internal investigations (e.g. complaints, disciplinary) with investigations by the police or other agencies.
• Share information about the outcomes of internal investigations.

Whistle blowing

If a member of staff suspects that children or vulnerable adults are being abused by another member of the Macular Society’s staff, they should immediately speak to their Designated Safeguarding Lead. Where there is a failure to respond appropriately to allegations of abuse, or where staff have concerns that a colleague or superior is responsible for the abuse, staff must follow the Whistleblowing Policy. The Public Interest Disclosure Act (1998) protects workers from detrimental treatment or victimisation from their employer if they blow the whistle on wrongdoing, such as the abuse of customers. Staff who whistle blow can remain anonymous. However, this cannot necessarily be guaranteed if it results in a criminal investigation. Please see the Whistle Blowing Policy for more information.

Allegations against staff/volunteers

If any allegation is made or suspicions emerge regarding any member of staff/volunteer of the organisation, this should be reported to the Designated Safeguarding Lead. The concern must also be reported to the staff member’s line manager, who should take advice from the Safeguarding lead and HR.

All allegations made against staff/volunteer must be reported to via local social care routes for allegations against staff/volunteers. within 24 hours.

If an allegation concerns the Designated Safeguarding Lead, the report should be made to the CEO.

If an allegation concerns the CEO, the report should be made to the Designated Safeguarding Lead on the Macular Society’s Trustee Board.

Safer recruitment

Safe recruitment is central to the safeguarding of children and adults. All organisations which employ staff or volunteers to work with children and/or vulnerable adults have a duty to safeguard and promote their welfare. This includes ensuring that the organisation adopts safe recruitment and selection procedures which prevent unsuitable persons from gaining access to children and/or vulnerable adults. All staff who are involved with recruitment must receive Safer Recruitment training.

Information provided by applicants and referees will be scrutinised where applicable by:

• Taking up and satisfactorily resolving any discrepancies or anomalies
• At least two references being taken for successful candidates; references are followed up and verified.
• All interview panel member with up to date safer recruitment training
• Making an application for a Disclosure and Barring Service, with or without barring list check
• Conducting an overseas criminal record check (where appropriate)
• Conducting a prohibition order check (where appropriate).

Appendix 1 - Case Management Team

The Case Management Team can be ‘standing committees’ who meet regularly or can be brought together as the need arises. Depending on the safeguarding case and specifically for cases directly involving staff or volunteers they could comprise of a Senior Trustee Member, CEO, HR, the appropriate Director and Safeguarding Leads and where necessary could be Co-opted independent safeguarding expertise (e.g. from another charity or relevant profession such as the police or social services), they will have the knowledge and experience of safeguarding adults within the organisation.

Case Management Team - Terms of Reference

The Macular Society has a responsibility to safeguard, protect and promote the welfare of adults in accordance with “The CARE Act 2014”.

The Case Management Team is responsible for ensuring that all allegations, incidents or referrals related to the safeguarding of adults both internal and externally are dealt with fairly and equitably within appropriate timescales. This includes criminal records disclosure information being considered and decided on a consistent and equitable basis.

In particular and without limiting that responsibility, the Case Management Group shall:

• Inform the appropriate statutory agency (the police and/or the Local Adult Authority) where a report is made relating to concerns about suspected or actual abuse of an adult, and to comply with any directions or requirements they may make regarding the case.
• Give direction where appropriate to the Designated Safeguarding Lead as to the level of cases - as high risk, medium risk or low risk.
• Give direction where appropriate as to the level at which a case is to be managed.
• Determine where appropriate which cases the Case Management Group need to be directly involved with and advising on what level of investigation should be undertaken.
• Analyse any reports commissioned and determine whether any further actions are required.
• Make initial decisions regarding risk from the information received and determine how such risks are to be managed.
• Monitor and review the progress on all cases and identify any trends emerging, which may require a review of current policies and procedures.
• Consider medium and low risk cases and decide whether to issue any conditions regarding changes to policy and procedures.
• The Case Management Team should consider any criminal records disclosure information, which contain “non-conviction information”.
• Advise generally on matters of safeguarding policy, strategy and procedure, and to approve appropriate protocols.
• Advise on referrals of individuals to the Disclosure and Barring Service, AccessNI or Disclosure Scotland.

Case Management Team roles include:

• to ratify any actions already taken by the Designated Safeguarding Lead.
• to initially assess and agree immediate response to a safeguarding case (does there appear to be a case to answer?).
• to identify appropriate ‘route’ for case (e.g. internal/ disciplinary action alone or referral to statutory agencies plus internal/ disciplinary action).
• to decide the level (from local to national) at which the organisation will deal with the concern.
• to consider the need for temporary/ interim suspension order.
• to review progress of case(s).
• to identify/ communicate learning from cases.

Approved by: Macular Society Trustees
Date: June 2024
Review: June 2026