Safeguarding Policy

Etgar is a charity registered in England and Wales (with no. 1157569) and a company (no. 08669613), located at The Wohl Campus for Jewish Education, 44a Albert Road, London NW4 2SJ.

Etgar works through its staff and with volunteers to run activities for children, including:

inter-school quizzes attended by school pupils (who are accompanied by school staff);
Etgar assessments carried out in schools
Visits to schools to observe/participate in lessons;
Using volunteers, including vulnerable adults or those potentially at risk (‘adult at risk’), to help with preparations for Etgar activities.

Tolerance, respect, understanding and the welfare of those with whom we engage are key to our ethos and to our approach to everything we do and all those with whom we interact. This policy has been devised to reflect those values and to provide practical guidance to ensure that Etgar is compliant with its legal responsibilities for the welfare and safeguarding of any child or any adult at risk of any form of abuse with whom we may come into contact.

In line with our commitment to safeguarding, we expect any organisations with which we work or partner to have similarly robust policies in place and reserve the right to request and retain on file copies of such policies.

The purpose of this Policy
Our Safeguarding Policy
What constitutes abusive behaviour?
What we expect from our staff and volunteers
What to do if you are concerned about a child or adult at risk

1. The purpose of this Policy

This Safeguarding Policy explains the procedures and systems we have implemented to protect vulnerable individuals, whether children or adults at risk, that we may come into contact with. Its purpose is to ensure that no individual is subjected to any abusive behaviour by anyone associated with Etgar and also to ensure that any concerns about an individual’s welfare, from whatever source, are listened to, dealt with sensitively and effectively and are recorded and reported in line with best practice and all legal requirements. The Policy is founded on the three pillars of prevention, reporting and response.

Our staff and volunteers are committed to taking all reasonable steps to safeguard vulnerable individuals, both through their own actions and by providing a means for such individuals to report abuse. We expect them all to be familiar with this Policy and committed to behave in accordance with it.

This Policy should be read in conjunction with any other relevant policies referred to herein or otherwise produced by Etgar from time to time including, but not limited to, our Anti-bullying Policy, Whistleblowing Policy, Equality and Diversity Policy and Privacy Policy (relating to the use of personal data).

2. Our Safeguarding Policy

Through this Policy we commit to the following principles and actions:

Every individual, without exception, should be treated with respect and is entitled to live, work and study free from abuse of any kind, and has the right to protection from abuse regardless of gender, ethnicity, disability, sexuality or beliefs;
The welfare of a child or adult at risk is paramount;
No such individual or group of individuals may be treated any less favourably than others in being able to access services which meet their particular needs;
This Policy applies to our staff, volunteers and any other persons working on behalf of Etgar, whether paid or unpaid and in any capacity;
This Policy will be made available on request to anyone who wishes to see it;
All concerns, and allegations of abuse will be taken seriously by staff and volunteers and responded to appropriately. This may require a referral to a partner organisation with which a particular activity takes place, if the person to whom the concerns relate fall within their duty of care, as well as to children’s social care services, the independent Local Authority Designated Officer (LADO) for allegations against staff or volunteers and, in emergencies, the police;
Safe recruitment through scrupulous selection, vetting, induction and ongoing training procedures;
Proper reference to all of the principles, legislation and guidance that underpin the Policy;

This Policy is reviewed, approved and endorsed by our Trustees annually or when legislation or guidance changes. The current legislative framework and relevant guidance is set out in Appendix A, at the end of this Policy.

3. What constitutes abusive behaviour?

Abuse can take many forms and maybe be carried out by any person against anyone else; including by one child against another or by an adult against a child or another adult. This can be a parent, relative other carer or by a work colleague or someone in authority such as a teacher or police officer.

Children are those under the age of 18 years.

Adults at risk are persons aged 18 years and over who are or may be in need of community care services by reason of mental health issues, learning or physical disability, sensory impairment, age or illness and who is or may be unable to take care of him/herself or unable to protect him/herself against significant harm or serious exploitation. Since mental health challenges can affect anyone and may not always be apparent to an observer, no assumptions should be concerning the mental health or emotional resilience of any individual.

Actions may constitute abuse whether or not they are directed at vulnerable persons and accordingly may also result in a range of responses or sanctions.

Abuse may include, but is not limited to:

Sexual abuse or inappropriate touching or comments of any kind, whether or not there was, or was perceived by any person, to have been consent to such behaviour
Bullying, threatening, abusive or disparaging or mocking acts or words, including acts of actual or threatened violence or that cause emotional, physical or psychological harm;
Using undue influence and/or doing acts that cause an individual to feel compelled to act in a particular way or to do something against their will or which they do not have the legal, mental or emotional capacity to consent to doing;
Acts or omissions that result in neglect or a lack of care;
The sending by any means of material, whether in words, in pictures or otherwise, that results in abuse or exploitation of the kinds mentioned above.

4. What we expect from our staff and volunteers

Our Code of Conduct

The safety and welfare of those with whom we come into contact is paramount and we take great care to ensure that the people working for or on behalf of Etgar are properly recruited and vetted, are fully aware of their responsibilities and subscribe to this Code of Conduct, which states that they must:

Treat all individuals equally, and with respect and dignity;
Always put the care, welfare and safety needs of a child or adult at risk first;
Design and implement activities in such a way as to promote and protect the welfare vulnerable individuals;
Take all reasonable steps to avoid being alone with a child or adult at risk unless without express permission and all necessary clearances (including, but not limited to an appropriate Disclosure and Barring Service certification), and otherwise work in an open environment, avoiding unobserved situations;
At schools and at Etgar Challenge events, separate toilets are provided for children and must not be used by adults;
Never form inappropriate emotional or physical relationships with a child or adult at risk;
Never engage in rough, physical or sexually provocative games;
Never allow or engage in any form of inappropriate touching;
Never arrange to see or communicate in any way with a child or adult at risk away from the location in which an Etgar activity has been designated to take place. This includes contacting, ‘friending’, ‘following’, ‘liking’ or otherwise commenting or engaging through any form of social media;
Never make sexually suggestive comments to a child or adult at risk, even in fun;
Never do things of a personal nature for a child or adult at risk, that they can do themselves;
Take all reported concerns seriously and never allow allegations made by or about a child or adult at risk to go unrecorded or not acted upon;
Report immediately any suspicion that a child or adult at risk could be at risk of harm or abuse (see section 5, below);
Fully cooperate with any investigation of suspected or alleged abuse and work in partnership with all others involved in such a process;
In the case of trustees and staff in particular, ensure that they keep themselves informed of current legislation and guidelines and that all staff and volunteers are provided with vetting, monitoring and training appropriate to their roles and level of contact with vulnerable individuals, and the means to report actual or suspected abuse. Breaches of this code may lead to disciplinary action and the termination of the working relationship between Etgar and the person involved. Where necessary, incidents may be reported to the appropriate authorities.

Recruitment

Anyone (1) working for Etgar (whether paid or otherwise) who will or may come into unsupervised contact with a child or adult at risk, will first be subject to a rigorous recruitment and vetting process in accordance with the NSPCC’s Standard 1(2) which will include as a minimum, and as is appropriate to their role:

At least one face to face interview with at least two interviewers.
At least two written references providing detail about the person’s character and workplace record, and disclosing any concerns relating to their working with children or adults at risk.
A Disclosure and Barring Service (‘DBS’) check, where appropriate, including in every case where an individual visits schools and will or may work unaccompanied with children.
- NB: The DBS decides who is unsuitable to work or volunteer with vulnerable persons and it is illegal for a barred person to apply for such work (paid or voluntary), or for a charity to employ a barred person in such work. It is also a legal requirement for employers to refer someone to the DBS if they:
  - Dismissed them because they harmed a child or adult.
  - Dismissed them because they might have harmed a child or adult otherwise.
  - Were planning to dismiss them for either of these reasons, but the person resigned first.
  - An induction and training programme, and ongoing training as deemed appropriate by Etgar.

5. What to do if you are concerned about a child or adult at risk

Etgar has designated the following persons as our Principal and Deputy safeguarding officers:

Principal Safeguarding Officer: Atarah Ruback 0203 905 6977 or atarah@etgar.co.uk
Deputy Safeguarding Officer: Sarah Martin 0203 905 6977 or sarah@etgar.co.uk

If you are concerned about an individual either because of something done or said by them or someone else, or because of something else that you observe, you must:

Immediately make known your concerns to the class teacher and the designated Child Protection or Safeguarding Officer at the school (or organisation in which you are working, if they have a duty of care to that individual); AND
Immediately make known your concerns the Principal or the Deputy Safeguarding Officer at Etgar; AND
Make an immediate and accurate factual note of the circumstances giving rise to your concerns. This note is an important record for your future reference and for Etgar’s own records. You will need to fill in a safeguarding incident report form, provided by the Etgar Safeguarding Officer, but do not delay making a contemporaneous note in the meantime.
Not give assurances to the individual that the information disclosed by them to you won’t be disclosed to other responsible persons, including those mentioned above. A child or young person (under 18) cannot refuse for this referral to occur if they have made an allegation of abuse – their welfare is paramount.
Subject to the above, comply with regulations relating to confidentiality and data protection, including Etgar’s Privacy Policy and any related policies, and accordingly only share personal information on a need-to-know basis.

The Safeguarding Officer at Etgar will then report the matter as appropriate to the relevant authorities, which may include Children’s Services, the police, the Local Authority Designated Officer (LADO) and Child Exploitation Online Protection Centre (CEOP) for e-safety concerns. They will also retain records of the alleged incident or concerns in a secure place for future reference, in compliance with all relevant safeguarding, data protection and other regulations and guidance.

No one should feel in any way constrained from making known to an appropriate person genuine concerns, even if they cannot immediately be substantiated. The law affords particular protection to those who make known such concerns in good faith (3) and Etgar operates its own Whistleblowing Policy, to which you are referred.

Updated: June 2022

Appendix A: Legislation and guidance

The Children Act 1989 provides the legislative framework for child protection in England. Key principles established by the Act include:

the paramount nature of the child’s welfare
the expectations and requirements around duties of care to children.

This is strengthened by the Children Act 2004, which encourages partnerships between agencies and creates more accountability, by:

placing a duty on local authorities to appoint children’s services members who are ultimately accountable for the delivery of services
placing a duty on local authorities and their partners to co-operate in safeguarding and promoting the wellbeing of children and young people.

Both of these acts are amended by the Children and Social Work Act 2017. Key provisions include:

the Child Safeguarding Practice Review Panel was established to review and report on serious child protection cases that are complex or of national importance (Sections 12 to 15).
the previous model of Local Safeguarding Children’s Boards (LSCBs) has been replaced by local safeguarding partners who will publish reports on local safeguarding practice reviews (Section 17).
child death review partners are required to review each death of a child normally resident in their area and identify matters that are relevant to public health and safety and children locally (Section 24).
local authorities must appoint personal advisers for care leavers up to the age of 25 (Section 3).
Social Work England is created as a regulatory body for the social work profession in England (Section 36).
relationships education will be provided to primary school children and relationships and sex education will be provided (instead of sex education) in secondary schools (Section 34).

Policy and guidance

Working together to safeguard children (Department for Education, 2018)

The Department for Education (DfE) published an updated version of the key statutory guidance for anyone working with children in England in July 2018. It sets out how organisations and individuals should work together and how practitioners should conduct the assessment of children.

The main changes are:

three safeguarding partners (chief officers of police, clinical commissioning groups and local authorities) replace local safeguarding children boards (LSCBs), working together with relevant agencies to protect the welfare of children in their area (Chapter 3)
child death review partners are required to make provisions to review child deaths, replacing the previous requirement on LSCBs (Chapter 5, Section 6)
responsibility for overseeing lessons learned from serious child safeguarding incidents lies with the
Child Safeguarding Practice Review Panel at a national level, and with the safeguarding partners at a local level (Chapter 4, Section 5)
early years providers are required to have policies and procedures to safeguard children in place (Chapter 2, Section 14). This relates to children from birth up to 1st September following the date on which they turn 5-years-old.

Other amendments include:

clinical commissioning groups should employ or contract the expertise of designated health professionals for safeguarding children
children’s homes must follow the Guide to the Children’s Homes Regulations, including the quality standards (Department for Education, 2015)
multi-Agency Public Protection Arrangements (MAPPA), including governing bodies of maintained schools, police, prison and probation services, should work closely with other relevant agencies to manage the risks posed by violent and sexual offenders within the community.

• What to do if you’re worried a child is being abused: advice for practitioners (Department for Education, 2015)

This describes the indicators of abuse and neglect and the actions to take if you think a child is being abused or neglected. It’s relevant for anyone who comes into contact with children and families while working and applies to the statutory, voluntary and independent sectors.

(1) Other than volunteers engaged solely to assist at Challenge or other single events, during which time children are always accompanied by teachers and volunteers are never in unsupervised contact with them.

(2) NSPCC ‘Safeguarding Standards and Guidance for the Voluntary and Community Sector Working with Children’ (2017).

(3) Employment Rights Act 1996 (as amended by the Public Interest Disclosure Act 1998)