Procedure for dealing with Safeguarding Reports
Purpose and scope
The purpose of this document is to provide procedures for dealing with reports of breach of Standing Start Solutions Safeguarding Policy, where the safeguarding violation is:
- Against personnel or a participant.
- Perpetrated by personnel or participant.
1. Report is received
1.1 Reports can reach the organisation through various routes. This may be in a structured format such as a letter, e-mail, text or message on social media. It may also be in the form of informal discussion or rumour. If an associated person hears something in an informal discussion or chat that they think is a safeguarding concern, they should report this to James Cooke.
1.2 If a safeguarding concern is disclosed directly to a member of personnel, the person receiving the report should bear the following in mind:
- Listen and empathise with the person
- Ask who, when, where, what but not why
- Repeat/ check your understanding of the situation
- Report to the appropriate personnel member (see below)
1.3 The person receiving the report should then document the following information, using an Incident Report Form
- Name of person making report
- Name(s) of alleged survivor(s) of safeguarding incident(s) if different from above
- Name(s) of alleged perpetrator(s)
- Description of incident(s)
- Dates(s), times(s) and location(s) of incident
1.4 The person receiving the report should then forward this information to James Cooke.
1.5 Due to the sensitive nature of safeguarding concerns, confidentiality will be maintained during all stages of the reporting process, and information shared on a limited ‘need to know’ basis only.
1.6 If the reporting person is not satisfied that the organisation is appropriately addressing the report, they have a right to escalate the report, either up the management line, to the Board (or other governance structure), or to an external statutory body. The personnel member will be protected against any negative repercussions as a result of this report.
2. Assess how to proceed with the report
2.1 Appoint a Decision Maker for handling this report
2.2 Determine whether it is possible to take this report forward
- Does the reported incident(s) represent a breach of safeguarding policy?
- Is there sufficient information to follow up this report?
2.3 If the reported incident does not represent a breach of Standing Start Solutions Safeguarding Policy, but represents a safeguarding risk to others, the report should be referred through the appropriate channels (e.g. local authorities) if it is safe to do so.
2.4 If there is insufficient information to follow up the report, and no way to ascertain this information (for example if the person making the report did not leave contact details), the report should be filed in case it can be of use in the future, and look at any wider lesson learning we can take forward.
2.5 If the decision is made to take the report forward, ensure that you have the relevant expertise and capacity to manage a safeguarding case. If you do not have this expertise in-house, seek immediate assistance, through external capacity if necessary.
2.6 Clarify what, how and with whom information will be shared relating to this case. Confidentiality should be maintained at all times, and information shared on a need-to-know basis only. Decide which information needs to be shared with which stakeholder – information needs may be different.
2.7 Check your obligations on informing relevant bodies when you receive a safeguarding report. These include (but are not limited to):
- Funding organisations
- Umbrella bodies/networks
- Statutory bodies (such as the Charity Commission in the UK)
Some of these may require you to inform them when you receive a report, others may require information on completion of the case, or annual top-line information on cases. When submitting information to any of these bodies, think through the confidentiality implications very carefully.
3. Appoint roles and responsibilities for case management
3.1 The Decision Maker should be a senior personnel member, not implicated or involved in the case in any way.
3.2 If the report alleges a serious safeguarding violation, you may wish to hold a case conference. This should include:
- Decision Maker
- Person who received the report
- Safeguarding adviser (or equivalent)
The case conference should decide the next steps to take, including any protection concerns and support needs for the survivor and other stakeholders (see below).
4. Provide support to survivor where needed/requested
- 4.1 Provide appropriate support to survivor(s) of safeguarding incidents. Nb. this should be provided as a duty of care even if the report has not yet been investigated. Support could include (but its not limited to)
- Psychosocial care or counseling
- Medical assistance
- Protection or security assistance (for example being moved to a safe location)
- 4.2 All decision making on support should be led by the survivor.
5. Assess any protection or security risks to stakeholders
- 5.1 For reports relating to serious incidents: undertake an immediate risk assessment to determine whether there are any current or potential risks to any stakeholders involved in the case and develop a mitigation plan if required.
- 5.2 Continue to update the risk assessment and plan on a regular basis throughout and after the case as required.
6. Decide on next steps
- 6.1 The Decision Maker decides the next steps. These could be (but are not limited to)
- No further action (for example if there is insufficient information to follow up, or the report refers to incidents outside the organisation’s remit)
- Investigation is required to gather further information
- Immediate disciplinary action if no further information needed
- Referral to relevant authorities
- 6.2 Although associated personnel are not personnel members, we have a duty of care to protect anyone who comes into contact with any aspect of our programme from harm. We cannot follow disciplinary processes with individuals outside our organisation, however decisions may be made for example to terminate a contract with a supplier based on the actions of their personnel.
- 6.3 If an investigation is required and the organisation does not have internal capacity, identify resources to conduct the investigation. Determine which budget this will be covered by.
7. Manage investigation if required
- 7.1 Refer to the organisation’s procedures for investigating breaches of policy.
8. Make decision on outcome of investigation report
- 8.1 The Decision Maker makes a decision based on the information provided in the investigation report. Decisions relating to the Subject of Concern should be made in accordance with existing policies and procedures for personnel misconduct.
- 8.2 If at this or any stage in the process criminal activity is suspected, the case should be referred to the relevant authorities unless this may pose a risk to anyone involved in the case. In this case, the Decision Maker together with other senior personnel will need to decide to decide how to proceed. This decision should be made bearing in mind a risk assessment of potential protection risks to all concerned, including the survivor and the Subject of Concern.
9. Conclude the case
- 9.1 Document all decisions made resulting from the case clearly and confidentially.
- 9.2 Store all information relating to the case confidentially, and in accordance with Standing Start Solutions policy and local data protection law.
- 9.3 Record anonymised data relating to the case to feed into organisaitonal reporting requirements (e.g. serious incident reporting to Board, safeguarding reporting to donors), and to feed into learning for dealing with future cases.