SAFEGUARDING POLICY STATEMENT
Introduction
This policy includes:
Details of the policies and procedures CRC London has in place to protect children and adults at risk
The details of our Designated Safeguarding Officers
The process followed when a concern or allegation is raised in relation to a child or adult at risk.
Please note that all CRC London Group Leaders, and all volunteers involved with kids, youth or adults at risk, are required to complete the following prior to volunteering:
-
An application including reference checks
-
External online safeguarding training
-
A DBS check
-
A Volunteer Agreement detailing the expectations and restrictions for volunteering.
CRC London is a member of thirtyone:eight (thirtyoneeight.org), an independent Christian charity that provides guidance and advice on safeguarding, through which all staff and key volunteers have immediate access to safeguarding advice in the event of any concern, disclosure or incident.
All concerns, disclosures and incidents reported via email or MyConcern, including the advice received from thirtyone:eight and the subsequent actions taken, are internally reported, recorded and followed up by the Designated Safeguarding Officers.
For urgent matters, please contact safeguarding@crclondon.com
For concerns or allegations that do not relate to children or adults at risk please contact safeguarding@crclondon.com.
This policy (“The Safeguarding Policy”) includes the procedures for the safety and protection of children, young people, and adults at risk, as well as the staff and volunteers of CRC London, UK. This Policy applies to all staff and volunteers at all UK Campuses and Start-ups of CRC London, UK, including all related services as well as the other ministries (altogether “CRC London”).
The Safeguarding Policy is to be read alongside the CRC London Kids Policy and the CRC London Youth Policy, which define the procedures and requirements for the provision of CRC
London Kids and Youth activities. References to “Children” herein refers to both children and young people. The Safeguarding Policy sets out the procedures to:
-
Ensure the protection, safety and wellbeing of all the Children in the care of the staff and volunteers of CRC London
-
Safeguard Children and adults at risk from any danger of abuse
-
Safeguard the staff and volunteers from allegations that can arise from careless and unwise behaviour
-
Define how staff and volunteers must act if there is any concern for a Child or adult at risk.
Adults at Risk are defined under the Care Act 2014 as individuals aged 18 years and over who:
-
Have needs for care and support (whether or not a local authority is meeting any of those needs); and
-
Are experiencing, or at risk of, abuse or neglect; and
-
As a result of those care of support needs are unable to protect themselves from either the risk of, or the experience of abuse of neglect.
​
Safety and Protection Mission Statement
CRC London is committed to the protection, safety and well-being of all Children in its care and all adults at risk with whom we work.
CRC London fully accepts its responsibility under relevant UK legislation, including the Care Act 2014, and endeavours to do everything possible to prevent all forms of harm and abuse and to be an agent of love, encouragement, care, healing and justice.
CRC London is therefore committed to:
-
Stopping, preventing, and reducing the risk of harm, abuse or neglect wherever possible;
-
Safeguarding and nurturing the Children within our community;
-
Safeguarding the adults at risk in our community in a way that supports them in making choices and having control about how they want to live;
-
Promoting an approach that concentrates on improving life for the adults at risk concerned; Viewing the welfare of children as paramount to our community;
-
Carefully selecting and training staff and volunteers who work with Children and adults at risk and using appropriate background checks on each person;
-
Responding appropriately and without delay to any allegations, reports or suspicions of abuse;
-
Cooperating fully with any statutory agencies during the course of any investigation into allegations concerning a member of our church community;
-
Offering informed pastoral care to any Child or adult at risk who has suffered abuse, and using the appropriate external channels as necessary.
Duties
Duties of CRC London:
-
To ensure that all staff and volunteers are familiar with this Policy and associated policies and procedures;
-
To be linked with Parliament, government departments, statutory agencies and church partners in promoting the safeguarding of Children and adults at risk, and make a safeguarding adults referral to the Local Authority as appropriate;
-
To put into place appropriate systems of accountability and supervision at all levels of the Church’s life, and ensuring that employment (staff and volunteer) procedures are robust enough to manage risk;
-
To appoint a suitably qualified staff member to act as Designated Safeguarding Officer, directly accountable for all matters relating to the protection of Children and adults at risk;
-
To ensure that all staff and volunteers in direct contact with such persons are properly trained and equipped to confidently undertake their responsibilities;
-
To provide access to the Disclosure and Barring Service (“DBS”) for staff and volunteers who require disclosures, and to pay the necessary fees for using this service;
-
To work within the current legal framework for referring staff or volunteers to the DBS who have harmed or pose a risk to Children and/or adults at risk;
-
To endeavour to keep up to date with national developments relating to preventing abuse and welfare of Children and adults at risk.
Duties of the Designated Safeguarding Officer and Deputy Designated Safeguarding Officer
-
To accept the prime duty of care for the Children and adults at risk in the Church community;
-
To undertake suitable training for the position and update this training every two (2) years;
-
To implement policies and procedures in relation to Children and adults at risk where appropriate;
-
To be responsible for conducting background checks on trustees, staff and volunteers wishing to work with Children and adults at risk within church;
-
To be responsible for the training and equipping of staff and volunteers so they are able to confidently undertake their responsibilities, and are aware of what they should do and who they should go to if they have concerns that a Child or adult at risk may be experiencing, or has experienced, abuse or neglect;
-
To ensure that appropriate health and safety policies and procedures are in place and adhered to where Children and adults at risk are concerned;
-
To ensure that those who may cause a threat to Children and/or adults at risk in our church are effectively and sensitively monitored and managed;
-
-
To receive, report and monitor any concerns involving the safety of Children and adults at risk in our church, and to follow up any such referrals to ensure the issues have been addressed;
-
To receive, report and monitor any allegations regarding staff or volunteers causing or potentially causing harm to the Children and adults at risk in our church;
-
To reinforce the need for confidentiality and to ensure that staff and volunteers are adhering to the CRC London policies and procedures with regard to confidentiality and security, being aware that when a person starts to challenge abuse there is a resulting risk of increasing intensity of abuse.
The Designated Safeguarding Officer is Pastor Anton Snyman.
The Deputy Designated Safeguarding Officers for Children and Young People is Hettie Gava.
The Deputy Designated Safeguarding Officer for Adults at Risk is Hettie Gava.
First point of contact at each CRC London campus:
-
Elam - Laraya Coetzee
-
Sevenoaks - Hettie Gava
-
Southfields - Jackie McCarthy
-
Sawbridgeworth - Tania Faro
-
East Barnett - Ps Anton Snyman
​
Duties of a Responsible Person
A Responsible Person is any staff member or volunteer who is entrusted with supervising, caring for, or working with a child or adult at risk. This is typically, but not limited to, Campus Pastors. Whilst CRC London does not own, operate or manage adult day or residential care facilities, from time to time staff and/or volunteers are invited to attend such facilities or visit adults at risk in their homes for the purpose of Home Cells. In the event any matters of concern arise out of such visits they must be brought to the attention of the Designated Safeguarding Officer or a Deputy Designated Safeguarding Officer for Adults at Risk.
Responsible Persons must:
-
Comply with background checks and procedures at the instruction of a Designated Safeguarding Officer;
-
Comply with the CRC London Safeguarding Policy in its fullness at all times; and
-
Complete the online Safeguarding training course.
Notwithstanding our legal and ethical responsibilities for the Children in our care, and the adults at risk with whom we work, parents and legal care-givers are not bound by this Policy.
Definition of Abuse
Abuse has many forms and CRC London will not be limited in its view of what constitutes abuse or neglect; the circumstances of an individual case will always be considered.
Abuse may occur in a family or in an institutional or community setting by those known to the individual or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults, or by a child or children. Abuse may be carried out deliberately or unknowingly. Abuse may be a single act or repeated acts.
Abuse includes:
Discriminatory
Including forms of harassment, bullying, slurs, isolation, neglect, denial of access to services or similar treatment; because of race, gender or gender identity, sexual orientation, age, disability or religion. This includes racism, sexism, ageism, homophobia or any other form of hate incident or crime.
Domestic abuse or violence
Including an incident or a pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse, by someone who is, or has been, an intimate partner or family member regardless of gender or sexual orientation. This includes psychological/emotional, physical, sexual, financial abuse; so called ‘honour’ based violence, forced marriage or Female Genital Mutation (FGM).
Financial or material
Including theft, fraud, internet scamming, exploitation, coercion in relation to an adult’s financial affairs or arrangements, including coercion with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.
Modern slavery
Encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.
Neglect and acts of omission
Including ignoring medical, emotional or physical care needs, failure to access appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating. In Children, the persistent failure to meet basic physical and/or psychological needs is likely to result in the serious impairment of the Child’s health or development.
Organisational (sometimes referred to as institutional)
Including neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example, or in relation to care provided in a person’s own home. This may range from one off incidents to ongoing ill treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes and practices within an organisation.
Physical
Including assault, hitting, shaking, throwing, poisoning, slapping, pushing, burning or scalding, drowning, suffocating, misuse of medication, restraint or inappropriate physical sanctions.
Psychological (sometimes referred to as emotional)
Including threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyber-bullying, isolation or unreasonable and unjustified withdrawal of services or support networks. Persistent emotional ill- treatment of a Child may cause severe and persistent adverse effects on the Child’s emotional development. It may involve conveying to Children that they are worthless or unloved, inadequate, or valued only so far as they meet the other person’s needs. It may feature age or developmentally inappropriate expectations being imposed on Children.
Sexual
Involves forcing or enticing a Child or adult at risk to take part in sexual activities, not necessarily involving a high level of violence, whether or not the Child or adult at risk is aware of what is happening. Includes rape, indecent exposure, sexual assault, sexual acts, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts. It also includes sexual exploitation such as exploitative situations, contexts and relationships where the person receives “something” (eg food, accommodation, drugs, alcohol, mobile phones, gifts, money) or perceived friendship/relationship as a result of them performing, and/or another or others performing sexual acts.
Self-neglect
Includes a person neglecting to care for their personal hygiene, health, or surroundings; or an inability to provide essential food, clothing, shelter or medical care necessary to maintain their physical and mental health, emotional wellbeing and general safety. It includes behaviour such as hoarding.
Possible Signs of Abuse
A Child or adult at risk may indicate that something is wrong in three ways: visual indicators, behavioural indicators, verbal indicators, or a combination of these.
Examples of Indicators:
-
Injuries that cannot be explained
-
Untreated or inadequately treated injuries
-
Bruising which looks like hand or finger marks
-
Cigarette burns
-
Human bites
-
Scalds and burns
-
Stomach pains or discomfort when walking or sitting
-
Pain, itching, bruising or bleeding in the genital or anal areas
-
Frequently hungry, dirty or inadequately dressed
-
Constantly ‘put down’, insulted, sworn at or humiliated
-
Becoming sad, withdrawn or depressed
-
Having trouble sleeping
-
Behaving aggressively or being disruptive
-
Showing fear of certain adults
-
Showing lack of confidence and low self-esteem
-
Using drugs or alcohol
-
A marked change in general behaviour
-
Refusal of a Child to attend school, or difficulty in concentrating so that their school work is affected
-
Using sexually explicit behaviour or language, particularly if the behaviour or language is not appropriate for their age
-
May describe receiving special attention from a particular adult, or refer to a new, ‘secret’ friendship with an adult or child.
Many adults at risk may not realise that they are being abused. For instance, an elderly person, accepting that they are dependent on their family, may feel that they must tolerate losing control of their finances or their physical environment. They may be reluctant to assert themselves for fear of upsetting their carers or making the situation worse.
Recruitment of Staff and Volunteers
People joining CRC London as a staff member or volunteer with a view to being in the position of a Responsible Person must have the prior approval of a Campus Pastor or Department Heads of CRC London and have undergone a pastoral screening process.
Conditions of recruitment
1. Disclosure and Barring Service (DBS) disclosure:
It is a criminal offence to offer paid or unpaid work with children to someone who is disqualified from working with children, or to allow them to continue doing such work. CRC London requests an Enhanced DBS Disclosure with Barred Check List from each person applying to work as a Responsible Person with Children or adults at risk.
Suitability Assessment
In the case of the DBS returning a Disclosure Form with prior convictions, cautions or warnings, it is the responsibility of the Designated Safeguarding Officer to assess the impact these will have on the Responsible Person performing their duty. The Designated Safeguarding Officer should take into consideration the severity and frequency of the record, and the time lapsed since recording.
The Designated Safeguarding Officer may choose to follow further references to aid their decision, or may ask the person to serve in another area of church for a period of time first. In all cases, the well-being of the Children and adults at risk takes precedence over the well-being of the applicant.
The legal requirement of CRC London to the DBS and policing authorities
CRC London has a legal and moral obligation to inform other professional practitioners, those directly working in child or adult service. This is solely the duty of the Designated Safeguarding Officer with the agreement of church leadership.
Ground for mandatory refusal
A person shall be immediately and irrevocably denied status as a Responsible Person and from any activity with Children and/or adults at risk, in the event of any disclosure indicating a person is on the list of individuals unsuitable for working with children and adults.
In these circumstances, the relevant authorities shall be notified that such a person has attempted to gain paid/unpaid work with Children and/or adults at risk. The Designated Safeguarding Officer shall be informed and will give guidance on receiving and supporting the person as a part of the wider church community.
Storage and access to Disclosure Forms
Disclosure Forms are completed by the applicant electronically through an agency designated by the Church and only on request, checked by the church for completion, before lodgement. Access to such forms is only permitted to Designated or Deputy Designated Safeguarding Officer and authorised delegated staff.
The agency will contact the applicant in the event a matter is disclosed and inform the Church of that fact. In that event the applicant for clearance has the option to withdraw the application or authorise disclosure to the Church.
Save for disclosures requiring mandatory refusal, any disclosure will be referred to the Designated Safeguarding Officer for assessment and final decision as to whether an individual may be appointed to staff, appointed as a Responsible Person or be involved in any volunteer activity with children or adults at risk.
Disclosure information shall be retained in accordance with our Privacy Policy (CRC London.com/privacy) and the CRC London Church London Data Retention Schedule and Policy. This will be for no longer than is necessary to make an appropriate decision of suitability. This should usually be less than six months. The only record kept on CRC London files will be that an application for DBS clearance was lodged and the date clearance was received OR in the event of a disclosure, the decision of the Designated Safeguarding Officer following any assessment, or the fact of Mandatory Refusal.
2. Interview (face to face) and two character references:
Part A: In the interview the person will be asked questions such as:
-
What experience do they have of working with Children / adults at risk?
-
What do they understand about the safety and protection of Children and adults at risk?
-
Do they know what to do if they receive a disclosure of abuse?
-
They will be asked if they have ever been convicted or accused of any untoward acts of molestation or abuse. [If the answer is ‘yes’ these people are unable to participate in ministry towards Children or adults at risk].
Notes: there is a specific set of questions that are assigned to the interviewer by CRC London which will be completed online and any concerns noted sensitively.
Part B: Each candidate is required to provide two character references in the application process. Referees must be Pastors or Key Leaders (not related to the applicant) who have a definite knowledge of the applicant's character and suitability to work with Children.
The character reference comments must be logged into the application tracking system on SharePoint. If for any reason a character reference rejects the candidate or highlights concerns, the information must be recorded and not told to the candidate until agreed upon by CRC London designated leadership.
Part C: Probationary Period: A three-month probationary period will be given at which point the volunteer or staff member may be required to be interviewed by a senior member of staff regarding their performance.
4. Safeguarding Training:
All new members to team in a position as a Responsible Person are required to complete the online Safeguarding Training Course. All people who work in any area of church involving Children and/or adults at risk will be required to receive a copy of the Policy and agree to abide by its procedures before they commence their work/volunteering. Failure to do so will disqualify the person from any form of contact or work with the Children or adults at risk.
5. Data Protection Training and Privacy:
All new members to the team are required to sign a Volunteer/Confidentiality Agreement and complete the online Data Protection Training and Test (with pass mark of 80%).
​
​
Procedure for Reporting Suspected Abuse
CRC London recognises that it has a duty to act on reports, or suspicions of abuse or neglect. It is the responsibility of all staff and volunteers to report suspected abuse to the proper authority; not withstanding a person’s right to make a direct report. In most cases it will be proper to report suspicions to a Responsible Person, Deputy Designated Safeguarding Officer or the Designated Safeguarding Officer.
Nothing in this Policy prevents a person speaking to or reporting such issues directly to the Senior Pastor, a Campus Pastor, Children’s Pastor or Youth Pastor, unless they are the subject of an allegation.
Nothing in this Policy prevents a person directly or immediately contacting the police or other emergency services in the event of risk of serious injury or harm to any person.
Where a local authority has a Multi-Agency Safeguarding Hub (MASH) this will be the initial point of contact for emerging concerns about the safety of a Child or adult (including an adult at risk).
Immediate responses
-
On receiving an allegation, the Responsible Person must:
-
Reassure the person concerned
-
Listen to what they are saying
-
Record what has been told/witnessed as soon as possible
-
Remain calm and do not show shock or disbelief
-
Tell them that the information will be treated seriously
-
Do not start to investigate or ask detailed or probing questions
-
Do not promise to keep it a secret.
On witnessing abuse, or if abuse has just taken place, the priorities for the Responsible Person will be to:
-
Call an ambulance if required
-
Call the Police if a crime has been committed
-
Preserve evidence
-
Keep yourself and others safe
-
Inform the Designated Safeguarding Officer
-
Record what happened through the Reporting Procedure - MyConcern
-
Where an allegation is in relation to a Child The Responsible Person:
-
Must report the concern immediately to the Campus Pastor AND the Designated Safeguarding Officer or a Deputy Designated Safeguarding Officer.
-
Must not ask a child to repeat a story or ask for any more information than the child is willing to give.
-
Should not ask ‘leading’ questions, make assumptions, or attempt to investigate the situation themselves.
-
Must not speak directly to the person against whom the allegations were made.
-
Will treat the issue as confidential, and relay on a ‘need-to-know’ basis only.
-
Will inform the Child immediately that, for the Child’s safety, they will need to speak to someone in church who can help them. No ‘secrets’ are kept between a Child and a Responsible Person.
The Deputy / Designated Safeguarding Officer will:
-
Immediately contact Children’s Social Care in the case of a concern for the Child’s safety if they should return to their parent or caregiver.
-
Seek medical help if needed, advising a doctor of the concerns.
-
Make careful notes of conversations and or concerns.
-
Contact the relevant MASH when applicable.
-
Refer the concerns to Children’s Social Care.
-
Assist all relevant agencies involved in dealing with the referral and conducting an enquiry.
-
Reassess the Safeguarding Policy and associated procedures as a result of the enquiry.
Where an allegation is in relation to an adult at risk The Responsible Person:
-
Must report the concern immediately to the Campus Pastor AND the Designated Safeguarding Officer or a Deputy Designated Safeguarding Officer.
-
Should not ask ‘leading’ questions, make assumptions, or attempt to investigate the situation themselves.
-
Must not speak directly to the person against whom the allegations were made.
-
Will treat the issue as confidential, and relay on a ‘need-to-know’ basis only.
The Deputy / Designated Safeguarding Officer will:
-
Contact the relevant MASH when applicable.
-
Immediately contact any Case or Social worker for the adult at risk.
-
Contact the Local Council in the case of an immediate concern for someone not being treated properly in a care home or someone being mistreated by a carer.
-
Contact an NHS hospital, GP or clinic if you’re worried about someone.
-
Make careful notes of conversations and or concerns.
-
Seek views from the adult (or an appropriate representative) about what they would like to happen as a result of the concern.
-
Refer the concerns to the adult safeguarding contact at the relevant local council. Consent from the individual is required for the referral, unless there is a good reason to override consent, such as risk to others, or if the individual does not have the mental capacity to consent to a referral. Assist all relevant agencies involved in dealing with the referral and conducting an enquiry.
-
Reassess the Safeguarding Policy and associated procedures as a result of the enquiry.
Allegations against CRC London staff or volunteers
CRC London will ensure that any allegations made against staff or volunteers will be dealt with swiftly.
If an allegation is made that a staff member or volunteer of CRC London has committed physical or sexual abuse towards a Child (whether part of the church community or not), or towards an adult at risk, the church will report the matter immediately to the police, other relevant authorities and to the Trustees of the church.
That person shall be immediately withdrawn from contact with Children or such adults until the findings of an investigation are made.
If an allegation is made that a staff member or volunteer of CRC London has committed an act of neglect or emotional abuse towards a child (whether part of the church community or not), or towards an adult at risk, the matter shall be referred to the Designated Safeguarding Officer, who shall take appropriate steps.
Incident Report Forms
In the event of an incident where first aid, medical, or extended disciplinary measures are taken, the involved Responsible Person must complete an Incident Report Form on the MyConcern App or webpage with their personal login with details of the situation. Parents/carers of the Child or adult at risk must be informed verbally on the same day that an Incident Report Form has been completed, and the parents/carer should be given full information of the event.
Access to Children’s Activities
Access to children’s activities will be subject to and in accordance with the CRC London Kids Policy and the CRC London Youth Policy.
During children’s activities, children must be supervised at all times by an appropriate choice of Responsible Persons.
Parents and caregivers will be given full information about the program including starting and finishing times. Staff and or volunteers will cooperate with the parents/caregivers to ensure the child is picked up safely.
While in the care of CRC Kids children will not be allowed to play in an unsupervised manner.
At all times, parents and caregivers will have access to their children. While they are not usually encouraged to stay during the activities, they must have full and uninterrupted access with the option to remove their children as they wish.
Privacy
All staff are required to sign and adhere to the CRC London Church London Staff Confidentiality Agreement and all volunteers are required to sign and adhere to the CRC London Church London Volunteer Agreement. All personal information is held in accordance with the CRC London Privacy Policy (CRC London.com/privacy) for the period defined in the Data Retention Schedule. In the event of any incident or allegation, data may be held indefinitely and will not be subject to the right of erasure under the Law. If you are unclear as to what is expected in any situation or need clarification on any issue raised, contact the Data Protection Office of CRC London Church London.
Risk Management Policy Review
​
This policy was reviewed in November 2023 by Anton Snyman, Designated Safeguarding Officer.