1. Introduction

This policy sets out OneRichmond’s approach to safeguarding. OneRichmond was established by the Richmond Foundation and Hampton Fund to address inequality and hardship across the borough. By encouraging people who live locally, to give locally, we increase the amount of grant funding available to local organisations, and ensure projects and services are available where they are needed most.

Safeguarding aims to ensure that everyone connected with our charity is safe and protected from abuse and exploitation. It includes actions to prevent abuse and mitigate the risks of it occurring, as well as actions to ensure any allegations of abuse are taken seriously and anyone experiencing abuse is protected and their welfare promoted.

Safeguarding is a priority for OneRichmond. By prioritising safeguarding within our internal practices and integrating safeguarding into our overall approach to funding, OneRichmond plays an important role in promoting practices and organisational cultures which keep people safe.

This policy reflects relevant legislation and statutory guidance on safeguarding within England (see Appendix A). This policy should be read in conjunction with OneRichmond’s Employee Handbook, Trustee Handbook, Acceptance and Refusal of Donations Policy, Complaints Policy, Social Media Policy and Data Protection Policy.

This policy is reviewed on an annual basis to ensure policies and procedures reflect current legislation and best practice and take into account any changes within OneRichmond. The revised policy is approved by Trustees.

2. Principles

• OneRichmond is committed to safeguarding all those connected with our work. In particular, OneRichmond believes that the welfare of a child or adult at risk is of paramount importance.

• Within the parameters of its roles as a funder and a fundraiser, OneRichmond is committed to safeguarding children and adults at risk by ensuring OneRichmond and the organisations we work with and/or fund have appropriate safeguarding mechanisms in place.

• OneRichmond believes all allegations of harm and abuse must be taken seriously. It has procedures in place to ensure any concern or allegation of abuse is listened to and responded to swiftly and appropriately.

• OneRichmond aims to promote a healthy safeguarding culture and we encourage a culture of learning to continuously improve our approach to safeguarding.

3. Scope

This policy applies to anyone working on behalf of OneRichmond including employees, trustees and volunteers.

This policy includes the work funded by OneRichmond and we will make funded partners (grant-holders) aware of our policy and the expectations that we have in relation to safeguarding. However, it is the responsibility of the organisations funded by OneRichmond to ensure that their safeguarding policies and procedures are fit for purpose and are implemented.

4. Definitions

Safeguarding children means:

• Protecting children from maltreatment, whether the risk of harm comes from within the child’s family and/or outside (from the wider community), including online.

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

• Ensuring that children are growing up in circumstances consistent with the provision of safe and effective care

• Taking action to enable all children to have the best outcomes

The definition of a ‘child’ is anyone who has not yet reached their 18th birthday. The fact, for example, that a child may have become 16 years of age, be living independently, in further education, in the armed forces, in hospital, or in a Youth Offender’s Institution does not change their status, their entitlement to services, or their protection under the Children Act 1989.

Safeguarding adults at risk means:

• Protecting their right to live in safety and free from abuse and neglect

The definition of an ‘adult at risk’, from the Care Act 2014, is any person aged 18 years and over who is or may be in need of care and support (whether or not those needs are being met), who is experiencing or at risk of abuse or neglect, and because of those needs is unable to protect themselves against the abuse or neglect or the risk of it. An adult at risk of abuse may: have an illness affecting their mental or physical health; have a learning disability; have drug or alcohol problems; and/or be frail.

The Care Act 2014 defines ten types of abuse as: physical abuse, domestic violence or abuse, sexual abuse, psychological or emotional abuse, financial or material abuse, modern slavery, discriminatory abuse, organisational or institutional abuse, neglect or acts of omission, self-neglect.

5. Roles and Responsibilities

Safeguarding is the responsibility of everyone at OneRichmond. All employees, volunteers and trustees are expected to read and follow the guidance set out in this policy.

Trustees have ultimate responsibility for safeguarding within OneRichmond.

 

Our Trustees are responsible for:

• Approving OneRichmond’s Safeguarding Policy and overseeing its implementation and effectiveness, and ensuring this is reviewed on an annual basis

• Ensuring OneRichmond is compliant with Charity Commission regulations and that all serious incidents are reported to the Charity Commission

• Appointing a Safeguarding Lead who is responsible for championing safeguarding at Board level and providing oversight on high-risk safeguarding concerns. The Trustee Safeguarding Lead is Sarah Wilkins [email protected]

 

The Director has responsibility for:

• Ensuring the safeguarding measures outlined in this policy are implemented

• Ensuring employees, volunteers and trustees have access to appropriate training and support to enable them to fulfil their safeguarding responsibilities.

• Reporting promptly any complaint which is safeguarding-related to the Trustees Safeguarding Lead and the Chair, and informing the Board of Trustees of the complaint at the next Trustee meeting.

• Keeping the Board of Trustees informed on progress and any concerns in relation to safeguarding

• Deputising for the Safeguarding Lead Officer

• OneRichmond’s Safeguarding Lead Officer is: the Director, Sue Martineau ([email protected]).

 

The Safeguarding Lead Officer is responsible for:

• Acting as the first point of contact for any safeguarding concern and ensuring appropriate action is taken

• Reporting promptly any complaints which are safeguarding-related to the Director and the Trustee Safeguarding Lead

• Ensuring OneRichmond’s Safeguarding Policy is reviewed on an annual basis

• Undertaking an annual review of safeguarding incidents and submission of an anonymised report to the Board of Trustees identifying trends and key learning

• Ensuring employees have access to advice and training to help them fulfil their safeguarding responsibilities, including access to external safeguarding expertise where necessary.

6. Safe People

6.1 Safe Recruitment

When recruiting new employees and volunteers, recruitment checks are undertaken to ensure the suitability of all potential candidates. For staff this includes ensuring that:

• A job description and person specification is created for all roles

• Candidates are interviewed to check their suitability against the person specification and job requirements

• Offers of employment will be dependent upon receipt of two satisfactory references and evidence of right to work in the UK

For volunteers this includes:

• A role description

• An informal chat

• Two references

OneRichmond requires a basic Disclosure and Barring Services (DBS) checks for the Director. If, in the future, OneRichmond creates new positions, whether paid or voluntary, which require regular contact with children or adults at risk, the OneRichmond Safeguarding Lead will use the government online tool to check whether a DBS check is required https://www.gov.uk/find-out-dbs-check DBS checks are renewed every 3 years.

6.2 Handling DBS Disclosures

DBS check disclosures are handled with confidentiality, compliance, and fairness. All disclosures are securely stored and accessed only by authorised personnel. The information disclosed is used solely for assessing an individual’s suitability for their role, following relevant legal guidelines. Any disclosed convictions or concerns are assessed in the context of the role’s requirements, ensuring a balanced and non discriminatory approach. Disclosure findings are discussed confidentially with the individual, allowing them an opportunity to provide context or clarification.

6.3 Training and Awareness Raising

Upon joining OneRichmond, new employees, trustees and volunteers will be made aware of their safeguarding responsibilities and provided with support to adhere to these. This includes ensuring that:

• All new employees, trustees and volunteers are briefed on OneRichmond’s approach to safeguarding as part of their induction and are given a copy of this policy.

• Where appropriate, an additional induction to safeguarding is provided by the OneRichmond’s Safeguarding Lead Officer

• Regular role-specific training and guidance is provided to the Trustee Safeguarding Lead and the Safeguarding Lead Officer, with Refresher at least once every three years

• Role-specific training and guidance will be provided to other staff as the team grows.

• Records are kept of training which has been undertaken

• All employees and volunteers receive a refresher briefing on safeguarding following the annual review of the safeguarding policy

• OneRichmond provides space in meetings and other forums to discuss safeguarding and build knowledge and capacity within the team

6.4 Code of Conduct

Our organisational values act as a guide for our employees, trustees and volunteers about how we work at OneRichmond. As a charity we are committed to maintaining the highest standards of behaviour in all areas of our operations. The OneRichmond Code of Conduct is set out in the Employee Handbook and the expectation of trustees is set out in the Trustee Onboarding Pack. This Code of Conduct must be adhered to by employees, trustees and volunteers at OneRichmond.

The Code of Conduct includes that all employees, trustees and volunteers have a responsibility to help ensure children and adults at risk who have contact with OneRichmond are protected from abuse. Any concerns about the safety of any individual connected with our work must be reported in line with the Safeguarding Policy.

6.5 Contact with funded partners

Employees, trustees and volunteers must:

• Only visit organisations with the prior knowledge of OneRichmond

• Ask the organisation visited if they have any specific safeguarding measures that should be followed and always adhere to their instructions related to safeguarding at all times

• Not ask for or accept personal contact details (including social media addresses, contact details, email, phone numbers etc.) from any individuals supported through OneRichmond grants unless this has been explicitly authorised for business purpose

• Ensure that any children or adults at risk attending events arranged by OneRichmond are accompanied by appropriately checked and qualified staff

• Never engage in a physical/sexual relationship with children or adults at risk or develop relationships which could in any way be deemed abusive or exploitative.

• OneRichmond employees/trustees/volunteers who have not had a DBS check cannot be left alone with children or adults at risk when visiting an organisation or project and will refuse to do so if asked

 

6.6 Handling Personal Data

Employees, trustees and volunteers must:

• Always follow OneRichmond’s data protection policies and procedures when handling personal information

• When using social media refer to the Social Media Guide and never share personal information or data about OneRichmond’s employees, funded partners, or beneficiaries of the work funded by OneRichmond

• Only take photos and/or video where informed consent has been obtained. Written parental consent should also be obtained for children aged 16 or under

• When using images in reports, presentations or other communication materials never include the person’s full name or include details that could identify the person’s exact location.

7. Internal Reporting Procedures

Anyone who is alerted to a safeguarding concern, or who observes an issue which causes concern in any work OneRichmond funds or is involved with must report this within 24 hours to the Safeguarding Lead Officer. The Safeguarding Officer will take appropriate action within 3 working days. You should record what you have seen or heard as soon as possible. The report form in Appendix B should be completed with the support of the Safeguarding Lead Officer. You must never promise to keep a concern a secret. You should not take action yourself as this could place you or others at risk. However, in an emergency, where people are in immediate danger, you should call 999.

OneRichmond’s Safeguarding Lead Officer is responsible for ensuring that all concerns are taken seriously, listened to and responded to in a timely and appropriate manner. This includes but is not limited to:

• Where a child or adult at risk is suffering or at risk of significant harm, notifying the local authority and/or police
• Cooperating fully with any actions or investigations which may be initiated by statutory services
• Ensuring support is provided to any OneRichmond personnel who may have been affected, including the person reporting the concern
• Maintaining a confidential record of the concern, actions taken and any learning or improvements which could help prevent similar incidents in the future.

Anyone who believes that OneRichmond has failed to take appropriate action in relation to safeguarding concerns, should report this to the Trustee Safeguarding Lead or make a report via OneRichmond’s Whistleblowing Policy (see Employee Handbook).

Managing Allegations against People Working and Volunteering with Children or Adults at Risk

Where the concern relates to the conduct of a OneRichmond employee, volunteer or trustee, OneRichmond’s Safeguarding Lead Officer will also:

• Inform the Trustee Safeguarding Lead so that they can provide oversight and support to ensure a robust response
• Advise the Chair of Trustees that a serious incident report should be submitted in line with Charity Commission requirements
• • The Charity Commission’s serious incident reporting regime requires trustees to report serious incidents. A serious incident is an adverse event, whether actual or alleged, which results in or risks significant:
    – harm to a charity’s work, beneficiaries, staff, volunteers or others who come into contact with the charity through its work
    – loss of a charity’s money or assets
    – damage to a charity’s property
    – harm to a charity’s work or reputation
• If the concern relates to the conduct of the Safeguarding Lead Officer then advice should be sought from the Trustee Safeguarding Lead [email protected]

Allegations against People Working and Volunteering with Children under 18

• It is a statutory requirement to report a concern where staff or volunteers:
  • Have behaved in a way that has harmed or may have harmed a child
  • Possibly committed a criminal offence against or related to a child
  • Behaved in a way that indicates they pose a risk of harm to children or behaved towards a child or children in a way that indicates s/he is unsuitable to work with children.
• Report the concern to the Safeguarding Lead Officer as soon as it’s come to your attention. The SLO is required to report to the Local Authority Designated Officer (LADO) within 24-hours or 1-working day. The SLO does not investigate the allegation before they have had advice from the LADO.

• Contact details are [email protected] 07774 332675.

• This is not a 24-hour service so if there are immediate concerns ring 999 or report using the Single Point of Access out of hours service.

• The LADO will advise the SLO on proportionate action whilst an investigation is taking place, for example to change work duties to remove from front-line activity, ensure chaperoned so no sole working, or suspension.

8. Safeguarding and Fundraising Activities

During our fundraising activities both staff and volunteers may come into contact with children and adults at risk. OneRichmond is committed to ensuring everyone is treated fairly and with respect, and that safeguarding is paramount, so that everyone can be kept safe and fundraising is an enjoyable experience for all.

8.1 Children as fundraisers

Children can get involved in fundraising in different ways, such as attending events, joining in at school or taking the initiative with their own activities. OneRichmond will not allow children to do any of the following, without adult supervision:

• carry out house-to-house collections of any kind

• get involved in events involving alcohol or gambling

 

If OneRichmond work with children as fundraisers, in line with fundraising regulations, we will

• have procedures in place that everyone knows how to follow

• carry out role risk assessments for all staff and volunteers

• carry out DBS checks where appropriate and eligible

• make sure everyone understands their responsibility to speak up if they have any concerns

• make sure everyone is aware of the procedures for reporting any concerns

• get consent from a parent or guardian to take photographs or share images

• not allow regular donations (like direct debits) from under 19’s.

• get approval from a school for any activity carried out in or near their premises.

 

8.2 Other donors who may be vulnerable

We will assess each situation where we are concerned that a donor may be vulnerable, including:

• someone who does not have mental capacity to make a decision

• someone affected by a particular condition or life event including things like bereavement, depression or financial hardship.

If a representative of OneRichmond reasonably believes someone is not in a position to make a decision they must:

• not accept the donation

• return a donation if it’s already been made

• make sure the person is not approached for further donations whilst they’re unable to make informed decisions.

During the donation process the representative of OneRichmond must:

• make sure the fundraising information is clear and accessible

• always treat a donor fairly, taking into account any additional needs they have

• never pressure someone into donating

• be alert to signs that someone may be confused or vulnerable and may need additional support

• be careful not to take advantage of mistakes by donors

• be careful not to exploit donors’ lack of knowledge or need for support

• avoid asking for a donation if a person clearly indicates they don’t want to speak with you

• never deny someone the right to donate on account of their age or any other factor that does not relate to their ability to make an informed decision.

9. Safeguarding within Grant Making

9.1 Application & Assessment Stage

Partners to whom we make grants must have appropriate safeguarding procedures in place. Applicants are required to submit their Safeguarding Policy with their application. All organisations must have a Safeguarding Policy that is dated and is reviewed annually. In line with Charity Commission guidance, Safeguarding Policies and Procedures should be ‘reviewed as necessary, always following a serious incident and at least once a year’. Partner safeguarding policies should therefore clearly state the date of the last review (within the last 12 months) and the date of the next review. As a minimum the safeguarding policy must include:

• A recruitment procedure

• Reference to when a DBS search disclosure/check is required for representatives of the organisation

• A named designated safeguarding officer for the organisation (with their contact details)

• An outline of reporting/disclosure procedures and escalation (including managing allegations against staff and volunteers and reporting to trustees).

If any of these minimum requirements are not in place, a condition will be added to any grant awarded by OneRichmond and no funding can be paid by OneRichmond until this condition has been met.

OneRichmond aims to promote excellence and good practice with regard to safeguarding policies and procedures which go over and above minimum requirements. We request that applicants review the OneRichmond Safeguarding Policy Checklist which has information about best practice and links to useful resources. Although OneRichmond may discuss safeguarding with applicants, it is not able to provide advice and support around the development of safeguarding policies and procedures. If an applicant or organisation OneRichmond works with requires advice, we will refer them to Richmond CVS and to the other resources on the OneRichmond Safeguarding Policy Checklist

9.2 Terms and Conditions

Once funding is approved, OneRichmond’s funding agreements outline our expectations in regard to safeguarding for those that we fund. This will include the requirement to notify us of any serious incident report (as defined in Charity Commission guidance) your organisation makes to the Charity Commission during the lifetime of our grant or any serious incidents that meet this threshold if you are not regulated by the Charity Commission.

9.3 Monitoring

OneRichmond will monitor safeguarding in the following ways:

• Monitoring Reports include a question asking funded partners to inform OneRichmond of key risks within their organisation. This includes safeguarding risks Policies and funded partners will be required to inform OneRichmond of any safeguarding incidents in response to this question.

• If the funded partner has multi-year funding they will be required to submit their latest Safeguarding Policy with their annual Monitoring Report

• Where the funded work involves work with children or adults at risk, safeguarding will be included as an agenda item for monitoring calls/visits with funded partners.

 

9.4 Reporting of Safeguarding Incidents within Funded Partners

Funded partners are asked to inform OneRichmond of any serious safeguarding incidents as soon as it is reasonably possible after it happens, in line with Charity Commission guidelines. This will usually be if the following occur:

• Incidents of abuse or mistreatment (alleged or actual) of beneficiaries of the grant funded charity (adults or children) which have resulted in or risk significant harm to them and:
  • this happened while they were under the care of the grant-funded charity
  • someone connected with the grant-funded charity, for example a trustee, staff member or volunteer, was responsible for the abuse or mistreatment (alleged or actual)
• Other incidents of abuse or mistreatment (alleged or actual) of people who come into contact with the grant-funded charity through its work, which have resulted in or risk significant harm to them and are connected to the charity’s activities
• Breaches of procedures or policies at the charity which have put people who come into contact with it through its work at significant risk of harm, including failure to carry out relevant vetting checks which would have identified that a person is disqualified in law from holding their position within the charity.

We do not require immediate reporting as the priority must always be for the organisation to take action to protect everyone involved. However, we do ask that funded partners report safeguarding incidents to us as soon as possible and within one working week. Our aim, when receiving reports, is to ensure that appropriate action has been taken and learning identified to prevent similar incidents in the future. The responsibility for responding to the concern, including notifying relevant authorities and the regulator, rests with the funded partner and should be undertaken in line with their own safeguarding procedures.

Whenever a safeguarding incident is reported to OneRichmond by a funded partner the Safeguarding Lead Officer will be notified, so as to provide guidance on what further information is required. Where OneRichmond is satisfied that appropriate action has been taken, we will simply thank the funded partner for sharing details of the concern and their response. A confidential record of the incident will be made using the form in Appendix B.

If further information is required, a relevant member of staff will:

• Contact the funded partner at the earliest possible opportunity, unless doing so would place individuals at further risk

• Discuss what actions the funded partner has taken or plans to take to address the concern, including details of any investigation and/or referral to statutory agencies

• Discuss timescales for action and ensure that the funded partner informs OneRichmond of progress and outcomes

• Ensure that the funded partner has referred any serious incidents to the Charity Commission in line with Charity Commission guidance

The additional information will be shared with the Safeguarding Lead Officer who will determine whether OneRichmond is satisfied with the response. A confidential record of the incident will be made using the form in Appendix B.

When discussing safeguarding incidents with funded partners:

• OneRichmond will avoid imposing actions as it is important that the funded partner follows their own procedures and internal processes

• Employees should not offer advice around safeguarding as OneRichmond does not have the resources or expertise around this specialist area. If an applicant or organisation OneRichmond works with requires advice, we will refer them to Richmond CVS and to the other resources on the Safeguarding Policy Checklist

• OneRichmond will only step in to report safeguarding issues to the police or other statutory services if the organisation has failed or refused to do so and OneRichmond has reasonable grounds to believe that this places individuals at continuing risk of significant harm or abuse

• OneRichmond will only notify the Charity Commission of safeguarding incidents within a funded partner if the funded partners refuses to do so or the incident is likely to have a material impact on OneRichmond

• If a funded partner is unable or unwilling to respond appropriately to safeguarding concerns, we may suspend existing funding and/or pause consideration of any application for future funding until improvements are made. The decision to pause funding will be taken by the Director in discussion with trustees.

Appendix A: Legal Context and Useful Resources

a) Duties under Charity Law

OneRichmond is regulated by the Charity Commission for England and Wales. We have duties under the Charities Act 2011 and our trustees seek to comply with their duties as summarised in CC3: The essential trustee: what you need to know, what you need to do. In developing this policy, we recognise the specific duties set out by the Charity Commission for safeguarding and protecting people and protecting charities from abuse for extremist purposes. As a Funder we also recognise the specific responsibilities the Charity Commission establishes on funders to carry out due diligence checks on beneficiaries and local partners and how to monitor end use of funds.

 

b) Legislative Framework for Safeguarding

This policy and any associated procedures and guidance were developed with reference to key domestic legislation to safeguard and promote the welfare of children and adults at risk of harm affected by our work:

• Children
  • Children Act 1989 & 2004, Protection of
    Children Act 1999 and Safeguarding
    Vulnerable Groups Act 2006, Working
    Together to Safeguard Children (2023), the Counter-Terrorism and Security Act 2015, Domestic Abuse Act 2021, Online Safety
    Act 2023, and Keeping Children Safe in Education (2021).
• Adults at Risk
  • Care Act 2014 and Care and support
    statutory guidance (2020), the Counter-Terrorism and Security Act 2015, Domestic Abuse Act 2021, Online Safety Act 2023, and Mental Capacity Act 2005.

 

c) Wider duties

We recognise our wider duties of care including under the Data Protection Act 2018, Public Interest Disclosure Act 1998, and the Equality Act 2010. We work in line with duties and principles of the Malicious Communications Act 1988, Communications Act 2003, Computer Misuse Act 1990, the Serious Crime Act 2015 and the Age appropriate design: a code of practice for online services (2020).

d) Useful Safeguarding Resources

Child safeguarding

Richmond CVS Child Safeguarding Information and Resources
Kingston and Richmond Safeguarding Children Partnership resources for Safeguarding in the Voluntary, Community and Faith Sector
Kingston and Richmond Safeguarding Children Partnership
Kingston and Richmond Safeguarding Children Partnership free training offer NSPCC guidance on developing a safeguarding policy and procedures
NSPCC guidance on safeguarding children who come from Black, Asian and minoritized ethnic communities and intersectionality
London Safeguarding Children Procedures

Adult Safeguarding

Richmond and Wandsworth Adult Safeguarding Board
Community resources – Richmond and Wandsworth Safeguarding Adults Board
Richmond and Wandsworth adult safeguarding training
Richmond Self Neglect and Hoarding Panel
London Multi-Agency Adult Safeguarding Policy and Procedures
Hourglass offers information relating to the harm, abuse and exploitation of older people in the UK

General Safeguarding

The Funder Safeguarding Collaborative offers members access to webinars, resources, training and capacity building tailored to the needs of funding organisations.
NCVO resources and guides to help organisations do safeguarding well
Ann Craft Trust resources to assist organisations in achieving best practice in safeguarding
Charity Commission resources highlighting Trustee safeguarding responsibilities

Eligibility guidance for standard DBS checks
Guidance on the legal duty to refer: Making barring referrals to the DBS

Catalyst offers a selection of information on safer working online. Resources are aimed at voluntary organisations, small groups, organisations and charities working in the UK.