Safeguarding Self-audit Review Guide PDF

MEDIUM & HIGH-RISK GRANTEES How to interpret the filled safeguarding self-audit: the table headings We have added this column as we want We added this column for grantees to This box contains the expectations...

MEDIUM & HIGH-RISK GRANTEES How to interpret the filled safeguarding self-audit: the table headings We have added this column as we want We added this column for grantees to This box contains the expectations grantees to go and look -not just be able to see that even though they we have for an organisation’s We have an explanatory assume that they have it in place. Often don’t have things in place, we would safeguards. These build on the Oak column to help grantees the person filling in the self-audit is the like them to think about what they will Child Safeguarding Standards in understand why we are donor relations person or programme do to address this gap. This self-audit our policy (page 5) asking them to adhere to officer, not the safeguarding person. By can then be used as an action plan and this expectation/standard. adding this column, we make sure they to measure progress. need to consult with relevant colleagues. Expectation Why we ask about this Evidence Status (Where and in which document can (Met or not met? In progress? What this be found?) action is being taken? What are the timescales for any actions?) 1. Child protection matters can be complex with significant implications There is a policy statement that for an organisation. It is important to recognises that, when responding be child-focussed, and there needs to to child welfare and protection be a commitment to this from the issues, the child’s needs will the very top of the organisation. Even if paramount concern the organisation is not primarily concerned with working with children, concerns may still come to light. 1  MEDIUM & HIGH-RISK GRANTEES How to interpret the filled safeguarding self-audit: the findings The table below should help programme staff to interpret the organisation’s response and to highlight some potential warning signs that it might need further scrutiny by someone with greater knowledge of the topic. The table outlines the expectations in the same order as in the grantee self-audit tool and then explains what you as programme staff need to know about this expectation. It then gives you information about both good examples and possible shortcomings to look out for. Expectation What you need to know about this Positive signs Look out for expectation 1. When organisations do not usually work directly Policy statements that reflect Statements that focus on the with children, they can struggle to recognise the ways in which the organisation rather than the There is a policy and respond to safeguarding concerns when organisation might have contact child or which are defensive in statement that they arise. It is important, therefore, for them with children tone. recognises that, when to have a strong statement endorsed at a senior Recognising that children Statements that are not signed responding to child level to emphasise that children’s needs must remain children until they reach off by a suitably senior person welfare and protection come first. the age of 18 Statements that are not dated issues, the child’s needs Make it clear who will have or which have not been will the paramount responsibility for reviewing the reviewed on time concern. policy Clues that no proper review has been conducted e.g. references to out-of-date government guidance. 2  MEDIUM & HIGH-RISK GRANTEES Expectation What you need to know about this Positive signs Look out for expectation 2. The policy It is common for there to be some ambiguity Clarity that it applies to Indications that the policy makes it clear about who is expected to be familiar with the everyone working with the has not carefully considered that it will apply policy and bound by any procedures. In organisation in whatever how the organisation to anyone particular, where organisations are working in capacity operates and included working for or partnership with others or where they use Documents that acknowledge reference to all relevant with the contractors, this can lead to confusion. Trustees the way the organisation parties organisation and others in similar positions are also often not operates It is helpful to ask how the mentioned. Clarity about how the policy statement and any safeguarding processes will associated procedures are operate if they are working in disseminated to those who partnership with another need to be aware of its organisation contents if this is not covered in the document itself 3  MEDIUM & HIGH-RISK GRANTEES Expectation What you need to know about this Positive signs Look out for expectation 3. There is This is another issue that organisations with A designated person who truly No named person somebody of infrequent or indirect contact with children wants to do the job and The named person not having sufficient often neglect. The fact that safeguarding understands the issues sufficient seniority seniority with concerns are not a daily occurrence makes it Including responsibility for Not recognising both aspects of designated important that someone of sufficient seniority safeguarding in their job the role responsibility is named as having responsibility for the issue. description rather than it just The role not being defined for safeguarding This needs to cover both the operational being tagged on to someone’s matters* aspects (the person making decisions about role specific cases and concerns) and strategic concerns (how well the organisation is dealing with the issue to general, making appropriate arrangements, and resourcing it). These different responsibilities may be held by different people. 4  MEDIUM & HIGH-RISK GRANTEES Expectation What you need to know about this Positive signs Look out for expectation 4. Staff are This is often not prioritised in organisations with A willingness to acknowledge Lack of training on the subject supported to be little or no direct contact with children. the fact that they may be Staff working without adequate able to However, the adults they are working with and become aware of issues supervision recognise and supporting may well be parents or carers of affecting children A reluctance to acknowledge respond children. The issues that are the reason for the Time and resources allocated to responsibilities in this area or effectively to organisation’s involvement with somebody safeguarding an awareness of how concerns safeguarding often can create vulnerabilities or risks, and Effective supervision of staff might come to light concerns safeguarding is not only about protecting children from their parents. Staff need to be able to recognise when children’s wellbeing is at risk from whatever source, and to be supported in responding to that as a safeguarding concern. This support can be provided in many ways – training is one obvious one, but support and supervision from managers or simply having clear information and procedures is also important. 5  MEDIUM & HIGH-RISK GRANTEES Expectation What you need to know about this Positive signs Look out for expectation 5 Staff are able to This can be hard to discern from a policy Evidence that staff are able and A focus solely on responding to recognise document, but it is helpful if the documentation willing to recognise and direct disclosures of abuse safeguarding helps staff to recognise the various forms of respond to concerns even A focus solely on concerns concerns and abuse and how they might become aware of it where abuse is not clearly arising from one particular the different even if they do not have direct contact with the indicated, or the child is not source (usually either only ways in which child. their direct service user thinking about risks from staff they might arise Definitions of types of abuse and volunteers, or only about and types of safeguarding parents and carers. It may be concerns either and other young people Referral pathways for incidents can also present a risk) are included in policy document 6. Staff are able to Once again, staff working in organisations A detailed code of conduct No guidance on this topic respond that do not have direct or frequent dealing adapted to the work of the No guidance on when it is or appropriately to with children can struggle on the rare organisation isn’t appropriate to tell parents a child or an occasions where concerns do arise because Clarity about the limitations of and carers about the concerns adult who they have not been made aware of what to their role in responding (it is A lack of recognition of the makes them say or not to say. This guidance can come not their job to investigate) emotional impact of this kind aware of a through training, but it is helpful to have a balanced with a willingness to of situation on staff, and of the possible short list of ‘Dos and Don’ts’ within policy or engage appropriately (signs of need for appropriate support safeguarding procedures. concern should not be ignored, issue and children need to be listened to) 6  MEDIUM & HIGH-RISK GRANTEES Expectation What you need to know about this Positive signs Look out for expectation 7. All staff know It is essential that staff are clear about who to Indications that this is Lack of clarity about who to who in their inform. These arrangements need to take into communicated to all staff as contact and how organisation account the way in which the organisation soon as they join the No deputising arrangements in they should operates – the physical location of staff; the organisation place inform about numbers involved; the hours at which the Arrangements that reflect the Unrealistic arrangements e.g. 1 any organisation operates etc. Contact details practical way in which the person covering an safeguarding contained in policy documents or publicised organisation operates unreasonably large area or concern* elsewhere are important, as are the steps to be Named designated officers number of staff taken if that person is not immediately along with their contact details available. The procedures should make it clear that action should be taken as a matter of urgency. 7  MEDIUM & HIGH-RISK GRANTEES Expectation What you need to know about this Positive signs Look out for expectation 8. It is clear who has Once again this is a common failing of policy Information about referral Lack of clarity about who the responsibility to documents of organisations that do not expect pathways (e.g. contact details) makes the decision refer matters to the to have to deal with safeguarding concerns. It Recognising the different Lack of criteria for making a police or social care indicates that no real thought has been given as referral pathways when referral out agencies who have to how the organisation will respond in concerns are about the Evidence of deviation from a statutory duty to practice. This decision-making responsibility is behaviour of staff or volunteers stated procedure investigate such crucially important as it represents the point at Lack of timescales for action concerns* which control over what happens next passes to another organisation or agency. It is not uncommon in practice for organisations to ignore their own procedures in these circumstances with other senior managers over- riding or excluding the person with designated responsibility, particularly when the concerns are about the behaviour of a member of staff or volunteer. 8  MEDIUM & HIGH-RISK GRANTEES Expectation What you need to know about this Positive signs Look out for expectation 9. There is a process A common failing of policy and procedure even Provision of forms to be used to A lack of any systems for for recording for organisations that work directly with record/refer concerns managing such records concerns children and families, a lack of reference to this Information on how records will securely and confidentially confidentially and essential requirement often indicates a lack of be kept and for how long A lack of guidance to staff securely. understanding or consideration of the practical about what and how to record requirements of any response. Any potential A lack of clarity about record safeguarding issue clearly needs to be dealt retention and storage with confidentially and there has to be an A lack of understanding about accurate record of what was witnessed, what the principles of information action was taken and the reasoning behind any sharing (contained in decisions. This applies whether or not a referral government guidance) to another agency is made. Safeguarding concerns can have far reaching consequences, and the records about any incident may be examined by investigating agencies or indeed the courts. 9  MEDIUM & HIGH-RISK GRANTEES Expectation What you need to know about this Positive signs Look out for expectation 10. Appropriate and This is an area where organisations working Safer recruitment processes No mention about safer proportionate steps directly with children would be expected to that go beyond criminal record recruitment processes are taken during have much more robust processes in place, but checks, including safer A reliance on CVs rather than recruitment to for any organisation working with situations of recruitment training; application forms ensure those who vulnerability it is important to understand that a safeguarding statements, Lack of training on the topic for are employed are safer recruitment process goes beyond carrying including in adverts; use of self- staff involved in recruitment committed to out a criminal record check disclosure forms; overseas Evidence of people starting safeguarding criminal record checks where work before all the required children appropriate etc checks have been completed. Consistent application of those processes (no cutting corners when appointments are urgent or difficult to fulfil) 10  MEDIUM & HIGH-RISK GRANTEES Additional Expectation Sections Additional Question in What you need to know about this section Positive signs Look out for expectation risk- assessment tool Intermediary and 5 These additional questions have been The intermediary The intermediary re-granting included because the organisation has organisation has a organisation does not organisations indicated that they re-grant funding from safeguarding policy or have any policies or Oak. Although re-granting and intermediary associated policies on procedures that organisations rarely have contact with issues such as describe their children, we expect them to have harassment, equity, safeguarding safeguards in place. This is because many of whistleblowing. responsibilities them re-grant to smaller organisations that The intermediary Grant agreements do work or are in contact with children. As we organisation has a not include a mention believe that “safeguarding is everybody’s reporting framework in of safeguarding business”, this means that any regranting place for safeguarding Intermediary does not organisation needs to have policies and or other issues such as believe it to be their procedures that consider this. This is new to fraud, harassment, responsibility to many intermediaries, so do not be surprised bullying. consider safeguarding if you find low levels of understanding on This reporting the subject. framework includes grantee complaints The intermediary organisation discusses safeguarding with prospective grantees The intermediary organisation includes 11  MEDIUM & HIGH-RISK GRANTEES safeguarding clauses in their grant agreement Supervision These additional questions have been A policy on staff A lack of any regular or Arrangements 3 included because the organisation has supervision that planned contact with and Access to DSO indicated that their staff, consultants, acknowledges a focus managers volunteers or contractors operate in that goes beyond just No evidence of remote/rural locations away from the performance safeguarding being office. In those circumstances, it may be management. discussed difficult for them to access the support they Good records of DSO’s being asked to need when encountering safeguarding supervision cover unreasonably concerns, and it will be harder for their meetings/discussion large numbers of staff manager to assess their ability to respond that show that or geographical areas appropriately. This makes supervisory safeguarding is A lack of any arrangements of particular importance. adequately covered formalised deputising ‘Supervision’ in this context refers not only Information about who arrangements to a process to assess performance but one the DSO is and how to Inadequate covering of that also encompasses the member of contact them forming safeguarding staff’s development and support needs as part of induction, and arrangements as part well as ensuring their familiarity with the readily available of induction organisation’s policy and procedures in this through other means area. Deputising arrangements in place for when the DSO may not be available Record Retention These additional questions are included Consent forms that A lack of written policy and Storage 9a, b, or c because the organisation indicated that they make it clear what on this topic held personal information about children on information is being held A lack of understanding their records. This opens up an area of and why of the risks of the vulnerability for those children, as well as Secure storage information being questions about data protection legislation. arrangements covering misused Any identifying information about children both electronic and No timescales for can be used as part of a grooming process, paper records information to be 12  MEDIUM & HIGH-RISK GRANTEES and the organisation needs to have clear Demonstrating securely destroyed procedures ensure the security of that understanding that not once no longer needed information; specify for how long it will be all records should be No evidence of consent kept and for what purposes; to know who kept for the same length being obtained has access to that information; and to ensure of time. Conversely, no that this is happening with the informed Knowledge of and adequate records of consent of those concerned. compliance with safeguarding concerns government guidance being kept at all! and legislation on this topic Being able to say with confidence who has had access to what records Working in other These additional questions are required Knowledge and use of No evidence of staff countries and 1 or 2 because the organisation has indicated that the Keeping Children being made aware of where child their staff work in foreign countries or Safe standards local safeguarding protection countries where child protection processes Evidence of a arrangements processes are not may be unfamiliar and potentially less safeguarding focussed Practice that either well enforced rigorous. There are enormous differences in risk assessment process fails to acknowledge how each country approaches safeguarding when setting out to cultural sensitivities or and child protection. Structural and work in another country ignores child welfare legislative differences will reflect different Information and training concerns for fear of cultural interpretations and responses to being provided to staff being culturally issues of child welfare. Children may also face and volunteers insensitive different types of risk and vulnerability. An Lack of planning and organisation’s response to these variations preparation regarding needs to acknowledge and respect cultural safeguarding when differences whilst maintaining a focus on setting up projects in keeping the child’s needs as the paramount other countries. concern. The charity Keeping Children Safe has established a set of standards and principles for international safeguarding and 13  MEDIUM & HIGH-RISK GRANTEES these are an important resource to draw upon. These circumstances also make it essential that staff are adequately supported and trained to work in this context. Online These questions are included because the There are signs that A lack of interactions with 8d organisation has indicated that they interact online safety is taken as acknowledgement of children with children online as part of their activities. seriously as other types online risks It may be that the main type of interaction of risk Online safety does not with children and young people is online, or it Potential risks are feature in safeguarding may be peripheral or a later addition to the anticipated e.g. setting training or codes of way in which they deal with children. up official channels of conduct Problems are most often crop up when the online (and telephone) It is unclear how young online interaction is not the main way in interaction and insisting people could report which they encounter children, but there can that no personal concerns be a failure to consider safeguarding properly accounts or devices are even where online engagement has been used. anticipated from the start. There is strong and prompt moderation of online content and interaction Young people are made aware of the risks they might encounter and how to respond Photography These questions are included because the Well-structured consent A lack of understanding including children 10a or c organisation has indicated that they make forms that cover all the ways about how identifying use of photographs of children and/or in which a photograph might information can increase families as part of the communications. This be used. risk is a common cause of difficulty if appropriate The use of images with no steps are not taken to ensure consent and time frame for how long 14  MEDIUM & HIGH-RISK GRANTEES the safe use of such images. Any information An awareness of how they are permitted to used that can be used to identify a particular child identifying information can them being specified and increase their vulnerability which is why, increase vulnerability Images used for purposed if a photograph of a child is used, it should Pro-active steps being taken other than those specified not in most situations be accompanied by to control photography by on consent forms other information such as their name, 3rd parties at events location etc. Consent forms should specify Where external the purposes that the photographs may be photographers are used, used for and the period of time in which they clear expectations about may be used. how children’s safety and wellbeing will be ensured are communicated to them 15