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Safeguarding Policy

Safeguarding Adults and Child Protection Policy


Gul Outdoor Therapy fully recognises its responsibilities for

safeguarding adults and child protection.


Key Safeguarding Personnel


Role: CEO

Name Dr Celia Grummitt

Tel. 01980 621 712  



Designated Safeguarding Lead (DSL)   As Above    

Deputy DSL(s) (DDSL) James Dwyer 

01980 621 712                   

Trustee responsible for safeguarding Eleanor Walters


Children’s Social Care referrals:   


Multi-Agency Safeguarding Hub (MASH): 0300 456 0108

Vulnerable Adults Social Care referrals: 0300 456 0111

Multi-Agency Safeguarding Hub (MASH): Out of hours: 0300 456 0100


If you believe a beneficiary is at immediate risk of significant harm or injury, you must call the police on 999.


God Unlimited Outdoor Therapy is committed to safeguarding and promoting the welfare of our beneficiaries. We will fulfil our local and national responsibilities as laid out in the following key documents:

  • Working Together to Safeguard Children (2018)

  • Keeping Children Safe in Education (new – Sept 2021) (statutory for Alternative Provision Schools)

  • The procedures of the Safeguarding Vulnerable People Partnership (SVPP)

  • Information sharing – Advice for practitioners providing safeguarding services to children, young people, parents and carers (2018)

  • Alternative Provision – Statutory guidance 2013


Under the 1989 and the 2004 Children Acts a child or young person is anyone under the age of 18. [accessed 05/05/22] [accessed 05/05/22]

The aim of this policy is to ensure:

  • all our beneficiaries are safe and protected from harm.

  • safeguarding procedures are in place to help beneficiaries to feel safe and learn to stay safe.

  • adults in the organisation’s community are aware of the expected behaviours and the organisation’s legal responsibilities in relation to safeguarding adults and child protection.


Safeguarding children is defined as:

  • ensuring that children grow up with the provision of safe and effective care

  • acting to enable all children to have the best life chances

  • preventing impairment of children’s mental or physical health or development and

  • protecting children from maltreatment.

Safeguarding adults means protecting a person’s right to live in safety, free from abuse and neglect.

Safeguarding covers a range of measures that includes child protection procedures. It encompasses a

preventative approach to keeping children and vulnerable adults safe that incorporates beneficiary health and safety; behaviour management and preventing bullying; supporting beneficiaries with medical conditions or disability; providing first air and site security as possible for an outdoor site.


Consequently, this policy is consistent with all other policies adopted by the trustees and should be read alongside the following policies relevant to the safety and welfare of our beneficiaries:


  • Behaviour policy·        

  • Staff Behaviour Policy

  • Health and Safety

  • Equality Statement

  • Whistleblowing policy

  • Confidentiality

  • Training


This policy applies to all staff in our organisation.


For the purposes of this policy:

  • Staff refers to all those working for or on behalf of the organisation full time or part time, in a paid or regular voluntary capacity.

  • A volunteer is a person who performs an activity that involves spending time, unpaid with our organisation (except for approved expenses).

  • Parent refers to birth parents and other adults who are in a parenting role, for example stepparents, foster carers and adoptive parents.

  • Child refers to all children attending our provision and any child under the age of 18 who encounters our organisation. This includes unborn babies.


Any safeguarding concerns or disclosures of abuse relating to a beneficiary at our provision or outside of operating hours are within the scope of this policy.



All staff are:

  • familiar with this safeguarding policy

  • alert to signs and indicators of possible abuse.

  • able to record and report concerns as set out in this policy.

  • able to deal with a disclosure of abuse from a beneficiary.

  • involved in the implementation of individual education programmes and safeguarding adult plans as required.



​As key vision setters for the organisation, the trustees will make sure that Gul’s policies and procedures are in line with national and local safeguarding requirements. Trustees will work with the senior managers to make sure the following safeguarding essentials are in place:


Internal Allegations Management

Our Chair of Trustees is responsible for liaising with the local authority Designated Officer for Allegations (DOfA) and other partner agencies in the event of an allegation of abuse being made against the CEO.  See also Managing allegations against adults.


The nominated Trustee for safeguarding liaises with the CEO and the D/DSL to complete an annual safeguarding audit return to the local authority.

Safer Recruitment

Our trustees monitor the organisation’s safer recruitment practice.

Safety Procedures

Safer recruitment

All staff are subject to safer recruitment processes and checks.


At Gul Outdoor Therapy all applications for paid or voluntary posts are scrutinised. We undertake interviews and make appropriate checks through the Disclosure and Barring Service (DBS). We maintain a single central record (SCR) of the essential checks that have been carried out and certificates obtained. The SCR applies to:

  • all staff who work at the organisation.

  • all Trustees

  • All volunteers


See also Training.

Staff Behaviour Policy (for safer working practice)

Gul Outdoor Therapy is committed to positive academic, social, and emotional outcomes for our beneficiaries underpinned by a strong safeguarding ethos. We are equally committed to the protection and welfare of our staff, who are expected to adhere to the highest standards of professional behaviour.

The Staff Behaviour Policy sets out staff behaviours that should be avoided, as well as those that constitute safe practice, and supports our commitment to safeguarding children.

Teaching staff are additionally expected to act within the guidance of the ‘personal and professional conduct’ section of the Teachers’ Standards.


All visitors complete a signing in/out form, and have available to them, safeguarding information including the contact details of safeguarding personnel in the organisation.

Scheduled visitors in a professional role (e.g., fire officer) are asked to provide evidence of their role and employment details (usually an identity badge) upon arrival at the setting.

If the visit is unscheduled and the visitor is unknown to the setting, we will not permit access to the site until the individual’s identity, has been confirmed if necessary.

Identifying the signs

All staff know how to recognise and are alert to the signs of neglect and abuse. Definitions of abuse set out in ‘ What to do if you’re worried a child is being abused – Advice for practitioners’ (2015) along with notes from Safeguarding training, are important reference documents for all staff, and which also includes supporting guidance about several specific safeguarding issues.

Responding to concerns/disclosures of abuse

Flowcharts provided by the SVPP that set out the required procedure for staff to follow when they have a safeguarding concern about a child are displayed. in the Office.

Staff adhere to the organisation’s safeguarding training requirements when concerned about abuse or when responding to a disclosure of abuse. Staff understand that they must NOT:

  • take photographs of any injuries.

  • postpone or delay the opportunity for the beneficiary to talk.

  • take notes while the beneficiary is speaking or ask the beneficiary to write an account.

  • try to investigate the allegation.

  • promise confidentiality e.g., say they will keep ‘the secret’.

  • approach or inform the alleged abuser.

All staff record any concern about or disclosure by a beneficiary of abuse or neglect and report this to the D/DSL. In the absence of the D/DSL, staff members know to speak directly to the Trustee for Safeguarding or another member of the Senior Management Team.  In some circumstances, the D/DSL, Safeguarding Trustee, or member of staff can seek advice by ringing the MASH for advice.


The voice of the beneficiary is central to our safeguarding practice and beneficiaries are encouraged to express and have their views given due weight in all matters affecting them.

Missing children and children missing education

Young people and children who do not attend Gul when expected are followed up through contact with their home or school. Gul may be involved in the close management of attendance but is not the lead in this.

The Gul staff member discusses any unauthorised/unexplained absence of Looked After Children with service commissioner/Virtual School when required.

A Gul staff member shares any unauthorised/unexplained absence of children who have an allocated social worker within 24 hours.

Beneficiaries with Special Education Needs and Disabilities (SEND)

Beneficiaries with additional needs face an increased risk of abuse and neglect. Staff take extra care to interpret correctly apparent signs of abuse or neglect. We never assume that behaviour, mood or injury relates to the beneficiary’s additional needs without further exploration. Staff understand that additional challenges can exist when recognising abuse and neglect in beneficiaries with SEND, including communication barriers. Staff recognise that beneficiaries with SEND are also at a higher risk of peer group isolation and can be disproportionately affected by bullying

Female Genital Mutilation (FGM)

FGM is illegal in the UK and a form of child abuse with long-lasting harmful consequences.  Staff will inform the D/DSL immediately if they suspect a girl is at risk of FGM.  We will report to the police any ‘known’ cases of FGM to the police as required by law.

Peer on Peer abuse

All beneficiaries have a right to attend Gul in a safe environment. All peer-on-peer abuse is unacceptable and will be taken seriously. Peer-on-peer abuse is not tolerated at Gul. It may need to be dealt with as a safeguarding issue and recorded as such with appropriate management.

Any beneficiary who may have been victimised and/or displayed such harmful behaviours, along with any other beneficiary affected by peer on peer abuse, will be supported at Gul and the efficacy of the support will be regularly reviewed.

Domestic abuse

Staff understand that domestic violence and abuse is any incident or pattern of incidents of controlling, coercive, 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. The abuse can encompass but is not limited to psychological; physical; sexual; financial; and emotional harm.

The Gul team liaises with any referring school if there is evidence or concern about a child or vulnerable adult. Gul is informed of concerns by schools too and takes note of Risks to the child or Young Person during the initial risk assessment and at reviews in longer-term placements.

Mental health

All staff are aware that mental health problems can be an indicator that a beneficiary has suffered or is at risk of suffering abuse, neglect or exploitation.

Staff understand that:

  • abuse and neglect, or other potentially traumatic adverse childhood experiences can have a lasting impact on beneficiaries’ mental health, behavior and education throughout childhood, adolescence and into adulthood.

  • they need to observe beneficiaries day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one.

If staff have a mental health concern about any child, they will ensure it is discussed with the Director of Therapy.

Preventing radicalisation

Protecting beneficiaries from the risk of radicalisation is part of organisation’s wider safeguarding duties and is similar in nature to protecting beneficiaries from other forms of harm and abuse.

Staff use their judgment in identifying beneficiaries who might be at risk of radicalisation and speak to the D/DSL if they are concerned about a beneficiary.

Serious violence

We are committed to success in learning for all our beneficiaries as one of the most powerful indicators in the prevention of youth crime.

Our curriculum includes teaching understanding risky situations to help our beneficiaries develop the social and emotional skills they need to thrive.

Staff are trained to recognise both the early warning signs that beneficiaries may be at risk of becoming involved in gangs as well as indicators that a beneficiary is involved in serious violent crime. They are also aware of the associated risks and know the measures put in place to minimise such risks.

Off site visits

We carry out a risk assessment prior to any off-site visit and designate the specific roles and responsibilities of each adult, whether employed or volunteers. Lone working is not encouraged during off site activities.

Exceptional operating circumstances

If the organisation is required to change the way we offer our provision to children and vulnerable adults due to unforeseen circumstances e.g., during a pandemic lockdown, staff responsibilities to remain alert to the signs and risks of abuse to children and vulnerable adults will continue to apply. In such circumstances:

We will ensure the therapy and activities we offer during such circumstances, continues to promote beneficiaries’ spiritual, moral, cultural, mental and physical development, and prepares them for the opportunities, responsibilities and experiences of life, as they may have changed as a result of the national/international events as they evolve.

Record keeping and information sharing

The organisation:

liaises with partner organisations (Schools, Wiltshire Council, NHS, services, Parents or other responsible commissioners) to ensure any safeguarding records for beneficiaries are shared on transition to the setting/organisation with responsibility for the education of the beneficiary.

  • keeps clear written records of all beneficiary safeguarding and any child protection concerns using a standard recording form, with a body map, including actions taken and outcomes as appropriate.

  • ensures all beneficiary safeguarding and child protection records are kept securely in a locked location.

  • ensures the records incorporate the wishes and views of the beneficiary.

The C.I.O. keeps records in line with its Retention of Documents policy which must meet the needs of healthcare referrers, insurers and educational establishments.

We are committed to work in partnership with parents and carers of children and of vulnerable adults (as appropriate). In most situations, we will discuss initial concerns with them. However, the D/DSL will not share information where there are concerns that if so doing would:

  • place a beneficiary at increased risk of significant harm

  • place any adult at increased risk of serious harm

  • prejudice the prevention, detection or prosecution of a serious crime

  • lead to an unjustified delay in making enquiries about allegations of significant harm to a child, or serious harm to an adult.

When we become aware that a child is being privately fostered, we remind the carer/parent of their legal duty to notify Wiltshire Children’s Social Care. We follow this up by contacting Children’s Social Care directly.

Escalation of concerns

Effective working together depends on an open approach and honest relationships between colleagues and between agencies.

Staff must be confident and able to disagree and challenge decision-making as an entirely legitimate activity; a part of their responsibility to promote the best safeguarding practice. Staff are encouraged to press for re-consideration if they believe a decision to act/not act in response to a concern raised about a beneficiary is wrong.

If we are on the receiving end of a professional challenge, we see this as an opportunity to reflect on our decision making.


All staff can raise concerns about poor or unsafe practice and potential failures in the organisation’s safeguarding regime. Our whistleblowing procedures, which are reflected in staff training and our Code of Conduct, are in place for such concerns to be raised with the team lead/Operations Director/CEO

If a staff member feels unable to raise an issue with any of the above or feels that their genuine concerns are not being addressed, other whistleblowing channels are open to them:

  • The NSPCC whistleblowing helpline

Staff can call: 0800 028 0285 from 08:00 to 20:00, Monday to Friday, or email

  • A member of the Board of Trustees: Jennifer Dixon-Clegg or the Board Chairman, Mr. Patrick Curry.

Managing allegations against adults

Gul Outdoor Therapy follows the procedure set out by the SVPP ‘Allegations against adults’ flowchart which is displayed in the office.

Where anyone in the organisation has a concern about the behaviour of an adult who works or volunteers at the setting, including supply staff, they must immediately consult the Senior Management Team. It may be that advice is sought from the Designated Officer for Allegations (DOFA).

Any concern or allegation against the CEO will be reported to the Chair of Trustees without informing the CEO.

All staff must remember that the welfare of a beneficiary is paramount and must not delay raising concerns by fear that any such reporting could jeopardise their colleague’s career.

Any allegation of abuse will be dealt with in a fair and consistent way that provides effective protection for the beneficiary and at the same time supports the person who is the subject of the allegation.




The welfare of all our beneficiaries is of paramount importance. All staff including proprietor/trustees and regular volunteers are informed of our safeguarding policy and procedures and Confidentiality at induction.

Our induction for staff also includes:

  • Plan of support for individuals appropriate to the role for which they have been hired

  • Confirmation of the conduct expected of staff within the organisation – our Staff Behaviour Policy

  • Opportunities for a new member of staff to discuss any issues or concerns about their role or responsibilities

  • Confirmation of the line management/mentor process whereby any general concerns or issues about the person’s ability or suitability will be addressed.


Safeguarding training

This training is for all staff and is updated every 3 years as a minimum to ensure staff understand their role in safeguarding. Any member of staff does not present at this whole team session will undertake this training requirement on their return.

Staff are required to be aware of the common presentations and situations in which abuse may be suspected including:

  • Disclosure by a child or young person

  • Physical signs and symptoms giving rise to suspicion of any category of abuse

  • A delay in seeking medical help

  • Extreme or worrying behaviour of a child, taking account of the developmental age of the child

  • Self-harm

  • Accumulation of incidents giving rise to a level of concern

  • Situations where parental factors such as mental health problems, alcohol, drug or substance misuse, learning difficulties, domestic abuse may impact on children and family life

  • Unexplained or suspicious injuries such as bruising, bites or burns, particularly if situated unusually on the body

  • The child says that she or he is being abused, or another person reports this

  • The child has an injury for which the explanation seems inconsistent, delayed presentation, or which has not been adequately treated or followed up

  • The child’s behaviour changes, either over time or quite suddenly, and he or she becomes quiet and withdrawn, or aggressive

  • Refusal to remove clothing for normal activities or keeping covered up in warm weather

  • The child appears not to trust adults, perhaps a parent or relative or other adult in regular contact

  • An inability to make close friends

  • Inappropriate sexual awareness or behaviour for the child’s age

  • Fear of going home or parents being contacted

  • Disclosure by an adult of abusive activities, including activities related to internet and social media use

  • Reluctance to accept medical help

  • Fear of changing clothes for activities


More guidance on how to recognise child abuse can be found in the NICE clinical Guidelines. Child Maltreatment: When to suspect maltreatment in under 18’s [CG89] published July 2009 [accessed 05/05/22]

Immediate Actions


  • Concerns should immediately be reported to the line manager or more senior manager in their absence.

  • Concerns should be discussed internally, and an action plan decided.

  • The action plan will depend if the child or young person is already known to Child Protection Services

  • The manager will make a decision whether to report the matter directly to a known Social Worker, the MASH, or Police for immediate place of safety. The School may also be contacted to discuss the incident or concern. The Lead Trustee may also be contacted to further discuss the best course of action.

  • If the suspicions relate to a member of staff or volunteer, there should be internal discussion with the safeguarding leads and a plan of action decided, the local Safeguarding Children team and / or social services should be contacted directly. Consideration should be made to involving the Local Area Designated Officer (LADO)

  • Suspicions should not be raised or discussed with third parties other than those named above

  • If the incident is that there appears to be a physical injury for which medical attention may be required parents will be asked to undertake this, however, if there is also concern for the child or young person’s safety the MASH or school will be informed.

  • Any individual staff member/volunteer must know how to make direct referrals to the child protection agencies and should be encouraged to do so if they have directly witnessed an abuse action; however, staff/volunteers are encouraged to use the route described here where possible. In the event that the reporting staff member or volunteer feels that the action taken is inadequate, untimely or inappropriate they should report the matter directly. Staff/volunteers taking this action in good faith will not be penalised

  • If urgent medical treatment is required either because of an incident at the site or because the child or young person arrived injured, and parents are not contactable to accompany the child an ambulance will be called and the child accompanied by a member of Gul staff until the situation is clearer.

  • If parents do not consent to medical care or to a social care referral and they fail to do so in situations of real concern the safeguarding lead will contact social services directly for advice

  • Where sexual abuse is suspected the safeguarding Leads will contact the MASH Team directly. The Leads will not speak to the parents if to do so might place the child at increased risk

  • Neither the safeguarding leads nor any other staff member or volunteer should carry out any investigation into the allegations or suspicions of sexual abuse in any circumstances. The safeguarding leads will collect exact details of the allegations or suspicion and provide this information to statutory child protection agencies: Social Care, the police or NSPCC, who have powers to investigate the matter under the Children Act 1989 [accessed 14/08/19]


What to do with allegations of abuse from a child


  • Keep calm

  • Reassure the child that they were right to tell you, and that they are not to blame and take what the child says seriously

  • Be careful not to lead the child or put words into the child’s mouth – ask questions sensitively

  • Do not promise confidentiality

  • Fully document the conversation on a word by word basis immediately following the conversation while the memory is fresh

  • Fully record dates and times of the events and when the record was made, and ensure that all notes are kept securely

  • Inform the child/ young person what you will do next

  • Refer to the safeguarding leads, or if neither are available, your line manager


Parental attitude may indicate cause for concern:

  • Unexpected delay in seeking treatment

  • Denial of injury, pain or ill-health

  • Incompatible explanations, different explanations or the child is said to have acted in a way that is inappropriate to his/her age and development

  • Reluctance to give information or failure to mention other known relevant injuries

  • Alcohol misuse or drug/substance misuse

  • Domestic Abuse or Violence between adults in the household

  • Appearance or symptoms displayed by siblings or other household members


In addition, all staff members receive safeguarding and child protection updates (for example, via email, e-bulletins, staff meetings) as necessary and at least annually. All roles at Gul have specified core competencies and the level of safeguarding training is included in all of these documents. All staff also receive training in online safety and this is updated as necessary.

Advanced training

The DSL has additional multi agency training which is updated every two years as a minimum. The DSL trains to Safeguarding level 3. Their knowledge and skills are refreshed at least annually e.g., via e-bulletins or safeguarding networking events.

Safer Recruitment

At least one person on any appointment panel has undertaken Safer Recruitment Training. This training is updated every five years as a minimum.

Preventing Radicalisation

All staff undertake Prevent awareness training.

Staff support

Due to the demanding, often distressing nature of child protection work, we support staff by providing

an opportunity to talk through the challenges of this aspect of their role with a senior leader and to seek

further support as appropriate.


As well as the organisation’s safeguarding induction programme, Trustees are encouraged to complete safeguarding and child protection training. In addition, Trustees may attend face training for Trustees provided by Wiltshire Council.


Monitoring and review


Trustees ensure that safeguarding is an agenda item on the for every full governing body meeting.

This policy is reviewed annually or earlier as required by changes to legislation or statutory guidance.

The nominated Trustee meets the DSL quarterly to monitor the effectiveness of this policy.

Appendix 1

Related legislation and key documents

Care Act 2014 The Care Act 2014 sets out a clear legal framework for how local authorities and other parts of the system should protect adults at risk of abuse or neglect.

Children Act 1989 (and 2004 update): The Children Act 1989 gives every child the right to protection from abuse and exploitation and the right to have enquires made to safeguard his or her welfare. The Act place duties on several agencies, including s, to assist Social Services departments acting on behalf of children and young people in need (s17) or enquiring into allegations of child abuse (s47).

Education Act 2002 – This requires organisations to make arrangements to safeguard and promote the welfare of children and to have regard to guidance issued by the Secretary of State for Education.

Sexual Offences Act 2003 – This act sets out an offence of ‘abuse of trust’ – a sexual or otherwise inappropriate relationship between an adult who is responsible for young people and a young person in his/her care.

Information Sharing – Department for Education (DfE) Advice for practitioners providing safeguarding services to children, young people, parents and carers 2018 This advice is for all frontline practitioners and senior managers working with children, young people, parents and carers who have to make decisions about sharing personal information on a case by case basis.

Counterterrorism and Security Act 2015 (the CTSA 2015), section 26 requires all organisations, 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.

Mental health and behaviour in schools (2018) advice to help schools to support pupils whose mental health problems manifest themselves in behaviour. It is also intended to be helpful to staff in alternative provision settings, although some of the legislation mentioned will only apply to those alternative provision settings that are legally classified as schools.

The Teachers’ Standards (2013) set a clear baseline of expectations for the professional practice and conduct of teachers and define the minimum level of practice expected of teachers in England.

Children Missing Education (2016) Statutory guidance for local authorities and advice for other groups on helping children who are missing education get back into it.

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