Our safeguarding policy

Statement of Purpose

1. The purpose of this Policy is to protect people, particularly children, young people and adults at risk, from any harm that may be caused due to their coming into contact with the3million. This includes harm arising from:

a) The conduct of Members of the Personnel.

b) The design and implementation of the Organisation’s programs, activities and campaigns.

2. The Policy lays out the commitments made by the3million and informs Members of the Personnel of their responsibilities in relation to Safeguarding.

3. Any questions in relation to this Policy should be referred to the Chief Executive Officer (CEO).

Our Safeguarding Commitment

4. the3million (“the Organisation”, “we”, “our” or “us”) is committed to preventing and responding to harm and risks of harm and promoting the welfare of all children and adults at risk that come into contact with Members of the Personnel. Individuals who engage with activities organised by the3million are referred to as “Community Members” in this Safeguarding Policy.

5. We recognise the importance of this commitment to safety and welfare and, further, are committed to safeguarding all Community Members without discrimination due to an individual's age, disability, ethnic origin, religion or belief, sex, gender reassignment, pregnancy or maternity leave status, marriage or civil partnership status, or sexual orientation.

6. The Organisation commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.

7. No Member of the Personnel is currently involved in regulated activity for or on behalf of the Organisation. In a majority of activities, Members of the Personnel do not come into direct contact with Community Members towards whom we have a legal duty of care (i.e. children, young people and adults at risk). Any contact with children, young people and adults at risk would be in a public or private event or workshop setting, where the aim is for them to be in the presence of a responsible adult.

Definitions

8. Abuse and harm can take many forms and include:

a. Physical abuse and harm, this may involve hitting, slapping, pushing, kicking, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, misuse of medication, inflicting inappropriate physical sanctions, or otherwise causing physical harm, including fabricating the symptoms of, or deliberately causing the individual ill health (The Department for Education and Employment (DfE) 2014, Department of Health (DoH) 2000)

b. Emotional/Psychological abuse, this is the persistent emotional ill-treatment of a child, young person or vulnerable adult such as to cause severe and persistent adverse effects on their emotional development. Threats of harm or abandonment; humiliation; blaming; intimidation; coercion; harassment; verbal abuse, bullying (including cyberbullying) and being prevented from receiving services or support are all forms of emotional abuse (DoH 2000).

c. Sexual abuse – including rape and sexual assault or sexual acts to which

• the adult at risk has not consented or could not consent or was pressured
• into consenting, indecent exposure, sexual harassment, inappropriate
• looking or touching, sexual teasing or innuendo, sexual photography,
• subjection to pornography, witnessing sexual acts or indecent exposure.

d. Discriminatory abuse, including forms of harassment, slurs or similar treatment because of race, gender and gender identity, age, disability, sexual orientation or religion.

9. Adults at risk are individuals 18 years old or over:

a) who have care and/or support needs and who are, because of these needs, unable to protect themselves from harm due to:

- illness, including physical and mental illness, and substance misuse

- disability, including physical, sensory, and cognitive impairment and learning disability.

This need not be on a permanent basis.

b) who are subject to abuse including domestic violence and modern slavery.

10. Children and young persons are individuals younger than 18 years old.

11. Community Members are individuals who engage with activities organised by the3million.

12. Members of the Personnel are all individuals working for or acting on behalf of the3million at all levels, including full-time, part-time, permanent and fixed term employees, trainees and interns, external and agency personnel, directors, officers and volunteers.

13. Safeguarding is a term that refers to practices and procedures aimed at preventing or responding to harm or risks of harm posed to vulnerable individuals, and at promoting these individuals' wider welfare. Safeguarding is particularly important for children and adults at risk. Most safeguarding legal obligations relate to the care of these groups, and these are the groups to whom the protections set out in this Policy apply.

14. Safeguarding Concern is any conduct or situation that is reported to, known, reasonably suspected or witnessed by a Member of the Personnel or another party that risks violating the safeguarding commitments set out above. A Safeguarding Concern also relates to the possibility of harm or exploitation. Safety Concerns while engaging Community Members might include:

a) description of abuse being inflicted upon them or another individual (disclosure)

b) physical signs or symptoms that may be indicative of abuse (emotional, sexual, physical or neglect)

c) witnessing abuse

d) third parties reporting information related to suspected abuse

e) concerns about the possibility of abuse

f) exposure to potential risk of harm.

15. Safeguarding Officers, the Lead Safeguarding Officer and Deputy Safeguarding Officer, are Members of the Personnel to whom Safeguarding Concerns regarding Community Members are reported.

16. Vulnerable People for safeguarding purposes is a child, young person or an adult at risk.

Schedule of Responsibilities

17. The Organisation is responsible for:

a) Publishing and promoting this Policy to all Members of the Personnel, through induction and/or training.     

b) Reviewing the Policy annually or when the nature of the Organisation’s work changes (whichever is sooner) and will be revised if any Members of the Personnel is involved in regulated activity for or on behalf of the3million.

c) Ensuring that all Members of the Personnel understand their roles and responsibilities in respect of safeguarding and is provided with the necessary information, and support on safeguarding matters.

d) Ensuring that all Members of the Personnel receive training on safeguarding at a level commensurate with their role in the organisation.

e) Implementing and maintaining comprehensive, accessible, fair and efficient procedures for Members of the Personnel to use when reporting on and dealing with Safeguarding Concerns or abuse. These procedures will be made known and easily accessible to all Members of the Personnel.

f) Ensuring that any Member of the Personnel is encouraged to report any abuse or Safeguarding Concerns that they identify.

g) Ensuring that any Member of the Personnel reporting concerns or complaints through formal whistleblowing channels (or if they request it) will be protected by the Organisation’s Whistleblowing Policy

h) Appointing Safeguarding Officers.

i) Following appropriate recruitment processes when recruiting Members of the Personnel. This includes:

- Conducting Disclosure and Barring Service (DBS) criminal record checks for management, director roles and where appropriate:

▪ Candidates will be informed before any checks are carried out and relevant identification will be requested.

▪ The Organisation will cover the costs of DBS checks

- Ensuring new Members of the Personnel take part in, and understand the content of, all necessary safeguarding training before having any contact with the3million's Community Members.

- Following the3million's policies and procedures on hiring and recruitment.

18. Company’s Directors are responsible for:

a) Reviewing and ratifying the Safeguarding Policy.

b) Having an awareness of the issues relating to Community Members.

c) Reviewing written reports following an investigation of abuse.

19. CEO & Senior Managers are responsible for:

a) Creating and reviewing the Safeguarding Policy.

b) Enforcing the policy and procedures.

c) Assessing the safety of services.

20. Safeguarding Officers are responsible for:

a) Ensuring that all reported Safeguarding Concerns are dealt with by appropriate individuals and in accordance with the3million's relevant procedures.

b) Sharing appropriate information with external agencies (e.g. the police, the ambulance service, a mental health crisis line, other assistance line or social services) during the course of and following an investigation of abuse.

c) Monitoring and authorising any actions resulting from an investigation.

d) Producing a written report following an investigation for company’s directors together with any recommendations for action.

21. All Members of the Personnel are responsible for:

a) Promoting the safety and wellbeing of Community Members and following the Organisation’s policies and procedures relevant to safeguarding at all times.

b) Participating actively in all safeguarding training they are assigned, and raising to the CEO or a Safeguarding Officer any aspects of their training they do not understand.

c) Recording and reporting any Safeguarding Concerns they have regarding Community Members, regardless of whether the concerns relate to potential wrongdoing of other Members of the Personnel, other Community Members, or external parties (e.g. parents, teachers, other organisations, or members of the public).

In addition, Members of the Personnel must not:

d) actively risk the safety or wellbeing of any of the3million's Community Members.

e) Subjecting children, young people or adults at risk to or facilitating abuse of any sort.

f) Engage in any sexual activity with anybody under the age of 18.

g) Participate in or facilitate any activities that may commercially exploit Community Members (e.g. failing to report suspected child labour or trafficking).

Lead and Deputy Safeguarding Officers

22. Our Lead Safeguarding Officer (LSO) is:

Name: Andreea Dumitrache, Chief Executive Officer

Contact details:

Email: [email protected]  

23. Our Deputy Safeguarding Officer (DSO) is:

Name: Lara Parizotto, Chair of the Board of Directors 

Contact details:

Email: [email protected] 

24. The Deputy should be available to support or cover for the Lead. They will also handle any complaints or allegations against the Lead Safeguarding Officer if appropriate. If the Member of the Personnel does not feel comfortable reporting to the LSO (for example if they feel that the report will not be taken seriously) they may report to the Deputy Safeguarding Officer (DSO).

Initial Response and Support Guideline

25. When a safeguarding concern is disclosed, witnessed or identified, the Member of the Personnel must follow these steps and guideline:

Step 1: Immediate Response and Active Listening

1) Take immediate action to ensure the safety and medical welfare of the individual.

2) Follow these key principles:

- Do’s:

• Remain calm and non-judgmental, try not to show shock
• Listen carefully, remain attentive and treat the information seriously
• Remain sympathetic

Appropriate responses include:

• "I am glad you told me"
• "I am sorry this happened"
• "We can do something about this together, what would you like to happen?"

▪ Be aware of the possibility of medical evidence

▪ Give reassurance but do not make promises.

- Don’ts:

▪ Do not assume someone else will act or already knows

▪ Do not interrupt or ask leading questions (e.g., "did your partner/parent do that to you?")

▪ Do not promise to keep secrets

▪ Do not make promises you cannot keep (e.g. "this will never happen to you again")

▪ Do not press the person for more details

▪ Do not contact the alleged abuser

▪ Do not express disbelief in what you are being told

▪ Do not judge or shame the individual (e.g., "why didn't you mention this before?")

▪ Do not discuss the incident with other Members of the Personnel not directly involved, except the Safeguarding Officer (the LSO or DSO).

Step 2: Information Gathering and Consent

1) Explain confidentiality limitations regarding alleged or suspected abuse.

2) Inform that the Safeguarding Officer must be notified.

3) Seek consent for information sharing.

4) Clarify and summarise the main facts.

5) Maintain sensitivity throughout the process.

6) Consider issues of capacity, consent, best interest and public protection.

7) Offer ongoing support from yourself or the Safeguarding Officer.

Step 3: Safety and Evidence

1) Ensure the individual is not in immediate danger of further harm.

2) Take appropriate steps to preserve any evidence.

Step 4: Inform The Lead Safeguarding Officer

1) Verbally report the incident or Safeguarding Concern to the LSO.

2) Report the incident or Safeguarding Concern to the LSO in writing by filling out the Reporting Form in appendix of the Policy.

Reporting and Record Keeping Requirements

26. The Safety Concern or incident must be reported by the Member of the Personnel who the incident or concern has been disclosed to, or witnessed by, was most directly involved or who provided first aid.

27. The Member of the Personnel should report the Safety Concern or incident within 12 hours of becoming aware of the incident or concern by filling the Reporting Form in appendix of the Policy.

28. The Member of the Personnel must describe the circumstances in which the concern came about and what action they took and/or advice they gave. It is important to distinguish between facts and opinions to ensure that information is as accurate as possible. If the Member of the Personnel is reporting about disclosure of the harm or abuse, they must use the words the disclosing person themselves used. If someone has written to the Member of the Personnel (including by email, message) a copy must be included in the report.

29. If more than one Member of the Personnel observes the same incident, a separate report is to be made by each member.

30. The report must be reviewed by the Safeguarding Officer within 24 hours.

31. Any report of Safeguarding Concern or Incident by a Member of the Personnel or an external party should include: the date of becoming aware of Safeguarding Concern or abuse, name of person who raised the concern, the description of the Safeguarding Concern or abuse, name and contact of the vulnerable person and/or parent/carer, the outcome the person wants, action taken and by whom.

32. For investigation and monitoring purposes records of any part of a procedure carried out to alert or investigate whether unsubstantiated or not must be kept. These records are also important in the identification of abuse where it may be necessary to build up a picture from fragments of relevant information over time by recalling information of previous alerting. Involved Members of the Personnel should hold this information confidentially.

Investigation and Response to Safeguarding Concerns Raised Against a Member of The Personnel

33. Any Member of the Personnel is required to report any concerns about another member to the Lead Safeguarding Officer. The Safeguarding Officer will inform the person against whom an allegation has been made unless there appears to be a case that this might prejudice a criminal investigation. The Safeguarding Officer will also consider whether suspension of the accused person is advisable whilst the allegation is being investigated. The Safeguarding Officer will gather as much detail from available sources as possible, by way of investigation. He or she will notify the company’s directors.

34. The Lead Safeguarding Officer will recommend whether the circumstances constitute grounds either:

a) to treat the matter as a disciplinary issue, either as misconduct or gross misconduct, with associated rights of appeal; or

b) to make such other non-disciplinary recommendations as are appropriate; or

c) to dismiss the allegations as unfounded.

35. The person against whom such non-criminal allegations are made should have an opportunity to give an explanation or answer to any allegation at an interview conducted and minuted by the LSO.

36. If a criminal allegation is made, e.g. of sexual abuse and impropriety, or physical assault, or inappropriate behaviour, the matter will be reported immediately to the police. The Safeguarding Officer will suspend the person from any activity in the project under the heading of alleged Gross Misconduct. If it is warranted, this may be without pay, should the evidence appear strong enough to justify the matter.

37. If the safeguarding concern is raised against a Non-Executive Director, it must be reported directly to the Deputy Safeguarding Officer/Chair, or if they are implicated, to another Non-Executive Director. The Organisation will conduct an investigation. The Board of Directors will first decide whether the circumstances constitute grounds either:

a) to temporarily suspend the Non-Executive Director while the matter is being reviewed; or

b) to make such other recommendations as appropriate; or

c) to dismiss the allegations as unfounded. 

38. The Organisation will ensure that the process is conducted fairly, in line with relevant legal and regulatory requirements, and with due consideration for confidentiality and the welfare of all involved. If the concern is substantiated, appropriate actions will be taken, which may include removal from the Board of Directors, reporting to relevant regulatory bodies, or legal action as necessary.

39. The Organisation will offer support to survivors of harm inflicted by any Member of the Personnel, regardless of whether a formal internal response is carried out (such as an internal investigation).

40. If a Member of the Personnel is involved in an incident that could give rise to a concern, including the potential for misinterpretation by others, the Member of the Personnel is strongly advised to self-report the incident directly to the Lead Safeguarding Officer. The Safeguarding Officer will then handle the matter in a fair, neutral, and timely manner.

41. Concerns related to the conduct towards children, young people or adults at risk by members of the personnel of delivery partner organisations should also be raised accordingly, following the policies of the delivery partner (either with an executive or the Lead Safeguarding Officer of the delivery partner).

Confidentiality

42. It is essential that confidentiality is maintained at all stages of the process when dealing with Safeguarding Concerns or incidents. Information should be shared on a need-to-know basis only and should always be kept secure.

Supporting Documents and Other Protections

43. This Safeguarding Policy does not cover all of the3million's commitments relevant to protecting its Community Members. We also have other policies in place that protect our Community Members, Members of the Personnel, and/or others. These include:

a) An Anti-Harassment and Bullying Policy

b) A Whistleblowing Policy

c) An Equal Opportunities Policy

d) A Disciplinary Procedure