Protecting Children, Young People and Vulnerable Adults
- Safeguarding Policy
1. Policy Statement
Spring Together CIC is committed to the safety, welfare and dignity of every child, young person, and vulnerable adult who comes into contact with our work. As a Community Interest Company operating in the fields of education and human health activities, we recognise that safeguarding is not a peripheral concern but a core responsibility embedded in everything we do. We believe that safeguarding is the responsibility of every person connected with our organisation from directors to volunteers. This policy sets out our commitment, the legal framework we operate within, the responsibilities of all those involved with Spring Together CIC, and the clear procedures to follow whenever a concern arises. Spring Together CIC operates a zero-tolerance approach to abuse, neglect, and exploitation. The welfare of every child and vulnerable adult is always our first and paramount priority. This policy applies to all directors, staff, volunteers, contractors, work placement participants, and any person or organisation working alongside Spring Together CIC in a formal capacity.
2. Scope and Application
2.1 Who This Policy Covers
This policy applies to:
- All directors of Spring Together CIC
- All paid employees and contractors
- All volunteers, including short-term, sessional, and remote volunteers
- All work placement participants
- Any partner organisation or individual working alongside Spring Together CIC in a formal or structured capacity
2.2 Who Is Protected
This policy protects:
- Children and young people: Any person under the age of 18 anywhere, or any person defined as a minor in their region
- Adults at risk: Any adult aged 18 or over who has care and support needs and, as a result of those needs, is unable to protect themselves from abuse, neglect, or exploitation
Spring Together CIC's work in education and health activities means our services may bring us into contact with both groups. This policy covers all such contact, whether in person, online, or through third parties.
3. Legal Framework
This policy has been developed in accordance with the following legislation, statutory guidance, and regulatory requirements:
- Children Act 1989 and Children Act 2004
- Safeguarding Vulnerable Groups Act 2006
- Protection of Freedoms Act 2012
- Care Act 2014
- Children and Social Work Act 2017
- Working Together to Safeguard Children (HM Government, 2023 edition)
- No Secrets: Guidance on Developing and Implementing Multi-Agency Policies and Procedures to Protect Vulnerable Adults from Abuse (DoH, 2000)
- Mental Capacity Act 2005
- Keeping Children Safe in Education (DfE, 2023) — where applicable to Spring Together CIC's educational activities
- UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018
- Equality Act 2010
- Human Rights Act 1998
This policy will be updated whenever relevant legislation or statutory guidance is amended. The Designated Safeguarding Lead (DSL) is responsible for monitoring legislative changes and bringing them to the attention of the Board of Directors.
4. Definitions of Abuse and Neglect
The following categories of abuse are recognised by this policy. This list is not exhaustive and Spring Together CIC will respond to any concern about harm or risk of harm, whether or not it falls within a defined category.
4.1 Abuse of Children and Young People
| Type of Abuse | Description |
|---|---|
| Physical abuse | Hitting, shaking, throwing, burning, biting, or other forms of deliberate physical harm inflicted on a child. |
| Emotional abuse | Persistent emotional maltreatment causing severe and adverse effects on a child's emotional development. Includes threats, humiliation, excessive criticism, and age-inappropriate expectations. |
| Sexual abuse | Forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. Includes contact and non-contact abuse, and exploitation online or in person. |
| Neglect | Persistent failure to meet a child's basic physical, emotional, or psychological needs, likely to result in serious impairment of the child's health or development. |
4.2 Abuse of Adults at Risk
| Type of Abuse | Description |
|---|---|
| Physical abuse | Hitting, slapping, pushing, burning, restraining, or administering medication inappropriately. |
| Psychological abuse | Threats, humiliation, controlling or coercive behaviour, intimidation, isolation, or emotional manipulation. |
| Sexual abuse | Any sexual activity to which the adult has not or cannot consent, or to which they have been coerced or pressured. |
| Financial abuse | Theft, fraud, exploitation, misuse, or misappropriation of a person's money, property, benefits, or assets. |
| Neglect and acts of omission | Failing to provide adequate care, ignoring medical or physical needs, withholding necessities of life, or failing to act on a known risk. |
| Discriminatory abuse | Abuse motivated by prejudice relating to age, disability, gender, race, religion, sexual orientation, or any other protected characteristic. |
| Domestic abuse | Controlling, coercive, or threatening behaviour, violence, or abuse by a partner or family member. Includes economic, psychological, and physical abuse. |
| Modern slavery | Trafficking, forced labour, domestic servitude, or any form of exploitation where a person cannot leave freely. |
| Organisational abuse | Neglect or poor care practice within a care setting, programme, or by a provider, resulting in harm or distress to service users. |
| Self neglect | A person failing to care for their own essential needs, including hygiene, nutrition, medical needs, or living conditions. |
5. Roles and Responsibilities
5.1 Designated Safeguarding Lead (DSL)
Spring Together CIC shall designate a Designated Safeguarding Lead (DSL) who is a director or senior staff member with appropriate training. The DSL is the first point of contact for all safeguarding concerns and is responsible for:
- Being accessible and available as the primary point of contact for all safeguarding concerns raised within the organisation
- Ensuring all safeguarding concerns are recorded, assessed, and referred appropriately & without delay
- Liaising with statutory agencies including the police, local authority children's services, local authority adult safeguarding teams, and the Local Authority Designated Officer (LADO)
- Ensuring all directors, staff, volunteers, and contractors receive appropriate safeguarding training at induction and at the required intervals
- Maintaining and reviewing the safeguarding training log
- Reviewing and updating this policy annually and bringing any required amendments to the Board of Directors for approval
- Reporting serious safeguarding incidents to the CIC Regulator and/or relevant statutory agencies as required
- Supporting any person who has raised a safeguarding concern throughout the process
| Role | Name | Contact |
|---|---|---|
| Designated Safeguarding Lead (DSL) | Ayodele Balogun | support@springtogether.org · +447402861520 |
| Deputy Designated Safeguarding Lead | Sodeeq Olalekan | support@springtogether.org · +447402861520 |
5.2 Board of Directors
The Board of Directors is collectively responsible for:
- Ensuring that Spring Together CIC operates in a way that actively safeguards all children, young people, and vulnerable adults it works with
- Ensuring this policy is formally adopted, implemented, and reviewed at least annually
- Ensuring adequate resources including time, training, and funding are available to implement safeguarding effectively
- Designating a qualified and trained DSL and ensuring their details are kept current
- Receiving reports from the DSL on any significant safeguarding concerns or incidents
5.3 All Staff, Volunteers, and Contractors
Every person working on behalf of Spring Together CIC regardless of role, seniority, or duration of involvement is responsible for:
- Reading, understanding, and acknowledging this policy before undertaking any activity on behalf of Spring Together CIC
- Treating all participants, service users, and beneficiaries with dignity and respect at all times
- Reporting any safeguarding concern however minor it may appear immediately to the DSL
- Maintaining appropriate professional boundaries in all relationships with participants and service users
- Not investigating concerns themselves or confronting an alleged perpetrator
- Recording only what they have seen, heard, or been told using the person's own words where possible
- Completing safeguarding training as required by Spring Together CIC
6. Safer Recruitment
Spring Together CIC is committed to safer recruitment practices to minimise the risk of appointing or engaging individuals who may pose a risk to children or vulnerable adults. Safeguarding checks are a condition of engagement for all roles involving contact with children or adults at risk.
6.1 Disclosure and Barring Service (DBS) Checks
All roles involving direct or unsupervised contact with children or adults at risk require a DBS check at the appropriate level before the individual commences in their role. The required level of check is determined by the nature of the role:
| DBS Level | When Required |
|---|---|
| Basic Disclosure | Roles that do not involve regulated activity but where a check is considered proportionate and appropriate. |
| Standard DBS Check | Roles involving regular contact with children or adults at risk in regulated settings that do not constitute regulated activity. |
| Enhanced DBS Check | Roles involving more intensive or frequent contact with children or vulnerable adults, including supervised regulated activity. |
| Enhanced DBS with Barred List Check | Roles constituting regulated activity as defined by the Safeguarding Vulnerable Groups Act 2006. Spring Together CIC will not knowingly appoint or engage any individual who appears on the DBS Barred Lists. |
No individual in a role requiring a DBS check shall commence unsupervised work with children or vulnerable adults until a satisfactory check has been received, or appropriate supervision is in place pending the outcome of the check. Spring Together CIC will maintain a DBS check log, reviewed annually by the DSL.
6.2 References
All paid staff must provide at least two satisfactory written references, one of which must be from a current or most recent employer, before an offer of employment or engagement is confirmed. References will be verified in writing. Unverified or unsatisfactory references will result in the offer being withdrawn.
6.3 Right to Work
Spring Together CIC will verify the right to work in the UK for all staff, volunteers and contractors before engagement commences, in accordance with its legal obligations.
6.4 Safeguarding Induction
All new directors, staff, volunteers, contractors, and placement participants shall receive a safeguarding induction before beginning their role. The induction will include:
- Reading and signing an acknowledgement of this policy
- Meeting the DSL and being introduced to the safeguarding reporting procedure
- Being briefed on the signs and indicators of abuse (Appendix B)
- Completing appropriate safeguarding training within 12 weeks of starting
7. Reporting and Responding to Concerns
7.1 How to Report a Concern
Any person connected with Spring Together CIC who has a concern about the welfare of a child or vulnerable adult — whether based on something they have witnessed, been told, or suspected — must act on it without delay. Follow these steps:
- Do not ignore the concern, however minor it may seem. Act on it immediately.
- Do not investigate the concern yourself or confront the person alleged to have caused harm.
- Do not promise confidentiality to anyone disclosing a concern. Explain clearly and honestly that you may need to share the information to keep the person safe.
- Report the concern to the Designated Safeguarding Lead (DSL) as soon as possible and always within 24 hours.
- If the DSL is unavailable, contact the Deputy DSL. If neither is available and the concern is urgent, contact the local authority safeguarding team or the police directly.
- Record what you have seen, heard, or been told as soon as possible using the Spring Together CIC Safeguarding Concern Report Form (Appendix A). Use the person's exact words where possible.
Do not delay recording while waiting for the DSL.
7.2 Action by the DSL
On receipt of a safeguarding concern, the DSL will:
- Assess the nature and severity of the concern promptly and without delay
- Record all information received in the safeguarding records, kept securely and separately from general files
- Refer the matter to the appropriate statutory authority such as local authority children's services, adult safeguarding services, or the police where there are reasonable grounds to believe abuse has occurred, is occurring, or is likely to occur
- Inform the lead director or Chair of the Board of any significant concern
- Report to the CIC Regulator or other relevant body where required
- Support the person who raised the concern throughout the process and keep them informed of the outcome where lawfully possible
7.3 Allegations Against Directors, Staff, or Volunteers
If an allegation is made against any director, staff member, volunteer, or contractor of Spring Together CIC, it must be reported to the DSL immediately. The DSL will:
- Refer the matter to the Local Authority Designated Officer (LADO) where the allegation relates to a child — this must be done within one working day
- Refer to adult safeguarding services where the allegation relates to a vulnerable adult
- Ensure that the person who is the subject of the allegation is appropriately managed pending investigation, which may include suspension from duties without prejudging the outcome
- Not conduct an internal investigation that could compromise or interfere with a statutory investigation
If the allegation is made against the DSL, it must be reported directly to the lead director or Chair of the Board, who will take the necessary action including contacting the LADO directly.
7.4 Confidentiality and Information Sharing
All safeguarding information will be treated as confidential and shared only on a strictly need-to-know basis. Spring Together CIC recognises that the right to confidentiality is not absolute. Where there is a risk of serious harm to a child or vulnerable adult, information must be shared with the appropriate statutory agencies even without the consent of the person concerned.
Information sharing in safeguarding contexts will be handled in accordance with:
- The UK GDPR and the Data Protection Act 2018
- The Information Commissioner's guidance on data sharing in safeguarding contexts
- Working Together to Safeguard Children (2023)
Spring Together CIC will not allow data protection principles to be used as a reason to withhold information where sharing is necessary to protect a child or vulnerable adult from harm.
8. Safer Working Practices
All persons working on behalf of Spring Together CIC must adhere to the following safer working practices at all times. These standards apply equally to in-person and online activities.
8.1 Code of Conduct — All Staff, Volunteers, and Contractors
- Always treat participants, service users, and beneficiaries with dignity, respect, and professionalism
- Maintain appropriate professional boundaries at all times — do not develop personal or social relationships with beneficiaries outside of the authorised programme context
- Never be alone with a child or vulnerable adult in an unobserved or private setting
- Never make physical contact with a beneficiary except where it is clearly appropriate, necessary, and consented to (for example, a supportive handshake or assisting with mobility)
- Never share personal contact details including personal phone numbers, email addresses, or social media profiles with beneficiaries
- Never contact beneficiaries outside of authorised channels without prior approval from the DSL
- Never take photographs, videos, or audio recordings of beneficiaries without explicit written consent in accordance with Spring Together CIC's Taking Photos at Community Events Policy
- Never discuss beneficiaries' personal information in public or social settings
- Never use personal social media accounts to communicate with beneficiaries in a personal capacity
- Never offer gifts, money, or personal favours to beneficiaries
8.2 One-to-One Working
Where one-to-one sessions with participants or beneficiaries are required, for example, in mentoring, health activities, employment support, or educational sessions — the following standards must be observed:
- Sessions must take place in a visible, open environment, or in a room with a window or open door where another responsible adult is nearby
- Another responsible adult must be present in the same building or immediately accessible
- The session must be recorded in a log, including the date, time, duration, nature of the session, and the names of those present
- Where a one-to-one session is planned in advance, the DSL must be notified
8.3 Online Safety
Where activities are delivered online or via digital platforms, including webinars, virtual health consultations, online education, or community engagement, Spring Together CIC will:
- Use only approved, secure, and organisationally controlled platforms for online engagement with beneficiaries
- Ensure that online sessions involving children or vulnerable adults are never conducted via personal accounts
- Record and retain consent for all online sessions involving children or vulnerable adults
- Apply the same safeguarding standards to all online activity as to in-person activity
- Never permit the private or direct messaging of a beneficiary through online platforms without the explicit approval of the DSL
9. Training
Spring Together CIC is committed to ensuring that all directors, staff, volunteers, and contractors are appropriately trained in safeguarding before they begin any activity involving children or vulnerable adults. Training is not optional — it is a condition of involvement with Spring Together CIC.
| Role | Required Training | Frequency |
|---|---|---|
| All directors | Safeguarding awareness for leaders and governance | At induction, then every 3 years |
| All staff and volunteers | Basic safeguarding awareness (children and adults at risk) | At induction, then every 2 years |
| Staff in direct contact roles (education, health, mentoring) | Intermediate safeguarding Level 2 | Every 2 years |
| Designated Safeguarding Lead (DSL) | Advanced safeguarding Level 3 or equivalent (e.g. DSL training) | Every 2 years |
| Deputy DSL | Intermediate to Advanced safeguarding Level 2/3 | Every 2 years |
| Contractors and work placement participants | Basic safeguarding awareness appropriate to role | At induction, and updated if placement exceeds 12 months |
A training log shall be maintained by the DSL recording the training completed by each individual, the date of completion, the training provider, and the renewal date. The DSL will ensure that all individuals are reminded when their training is due for renewal. Spring Together CIC will not permit any person to undertake unsupervised work with children or vulnerable adults before the relevant safeguarding training has been completed.
10. Record Keeping
Spring Together CIC recognises that safeguarding records are among the most sensitive documents the organisation holds. All safeguarding records shall be:
- Kept securely and separately from general personnel, volunteer, or beneficiary files
- Stored in a locked physical file or a password-protected, access-controlled digital system
- Accessible only to the DSL, Deputy DSL, and lead director and to statutory agencies where required
- Retained for a minimum of 25 years, or until the subject's 25th birthday if they were a child at the time of the incident (whichever is longer), or as directed by statutory guidance
- Held in full compliance with the UK GDPR, the Data Protection Act 2018, and Spring Together CIC's Data Protection & Storage Policy
Safeguarding records shall include:
- The original Safeguarding Concern Report Form (Appendix A)
- Any additional information gathered during assessment
- Decisions made and the reasons for them
- Any referrals made to statutory agencies and the outcome of those referrals
- Records of any LADO notifications and outcomes
- Any correspondence with statutory agencies, the CIC Regulator, or legal advisers
11. Whistleblowing
Any person connected with Spring Together CIC who has concerns about unsafe or improper conduct by a colleague, director, or volunteer in relation to safeguarding is expected and encouraged to raise those concerns without delay. Staying silent when a concern exists is not acceptable.
Spring Together CIC operates a zero-tolerance approach to the victimisation, harassment, or detriment of any person who raises a safeguarding concern in good faith. Any person found to have victimised a whistleblower will be subject to disciplinary action, which may include dismissal or termination of their engagement.
Concerns may be raised:
- Directly with the DSL
- With the lead director or Chair of the Board — particularly where the concern involves the DSL
- Through Spring Together CIC's Whistleblowing Policy
Where internal reporting does not resolve the concern, or where the concern relates to a director or senior member of staff, individuals may report directly to:
- The CIC Regulator
- The Local Authority Designated Officer (LADO) where the concern relates to a child
- The local authority adult safeguarding team where the concern relates to a vulnerable adult
- The police where a criminal offence may have been committed
12. Policy Review and Monitoring
This policy shall be reviewed and formally approved by the Board of Directors at least once per year.
A review shall also be triggered sooner in the event of:
- A change in relevant legislation or statutory guidance
- A safeguarding incident, near-miss, or serious concern involving Spring Together CIC
- A recommendation from an external inspection, audit, or review
- A significant change in Spring Together CIC's activities, service areas, or beneficiary groups
- A change in the designated DSL or Deputy DSL
The DSL is responsible for initiating the annual review, bringing any required amendments to the Board for approval, and updating the version number and review date on the cover of this policy following each review.
13. Related Policies
This policy should be read alongside the following Spring Together CIC policies:
- Taking Photos at Community Events Policy (Policy 01)
- Using the Disclosure and Barring Service (DBS) Policy (Policy 02)
- Volunteering Policy (Policy 04)
- Contractor Policy (Policy 06)
- Data Protection & Storage Policy (Policy 13)
- Equality & Diversity Policy (Policy 14)
- Health & Safety Policy (Policy 15)
- Safety of Work Placements Policy (Policy 16)
- Whistleblowing Policy (Policy 12)
- Complaints & Harassment Policy (Policy 22)
- Recruitment & Personnel Policy (Policy 20)
14. Key External Contacts
| Organisation | Purpose | Contact |
|---|---|---|
| Emergency Services | Immediate risk of harm to a child or adult | 999 |
| Police (non-emergency) | Non-urgent concerns or to report a crime | 101 |
| NSPCC Helpline | Child protection advice and referrals for professionals and public | 0808 800 5000 |
| Childline | Direct support line for children and young people | 0800 1111 |
| Local Authority Children's Services | Referrals for children at risk — Oldham / Greater Manchester | 0161 770 7777 |
| Local Authority Adult Safeguarding | Referrals for adults at risk — Oldham / Greater Manchester | 0161 770 7777 |
| Local Authority Designated Officer (LADO) | Allegations against staff, volunteers, or contractors involving children | 0161 770 8870 |
| CIC Regulator | Serious incident reporting and regulatory guidance | 0303 1234 500 |
| Information Commissioner's Office (ICO) | Data protection and information sharing guidance | 0303 123 1113 |
| NHS Safeguarding | Health-related safeguarding concerns | Via local NHS trust safeguarding team |
| Modern Slavery Helpline | Reporting suspected trafficking or modern slavery | 0800 0121 700 |
Appendix A — Safeguarding Concern Report Form
Appendix B — Signs and Indicators of Abuse
The following are possible signs and indicators of abuse. No single sign is conclusive on its own — it is a pattern of indicators, a change in behaviour, or a disclosure that must always be taken seriously and reported to the DSL immediately. When in doubt, report.
Children and Young People
- Unexplained injuries, bruising, or marks particularly in unusual locations or inconsistent with the explanation offered
- Significant and unexplained changes in behaviour, mood, or attendance
- Sexualised behaviour, language, or knowledge inappropriate for the child's age
- Withdrawal, anxiety, depression, excessive fearfulness, or low self-esteem
- Appearing dirty, unkempt, hungry, or inappropriately dressed for the weather
- Being overly protective of a mobile device or secretive about online activity
- Flinching at sudden movements or appearing frightened of a particular person
- Disclosures made by the child, whether directly or indirectly
- Signs of self-harm or unexplained deterioration in physical health
- Being frequently absent, arriving late, or appearing reluctant to go home
Adults at Risk
- Unexplained injuries, weight loss, or deterioration in physical appearance
- Fearfulness, anxiety, passivity, or withdrawal particularly in the presence of a specific person
- Confusion or disorientation that cannot be explained by a medical condition
- Unpaid bills, missing money, unusual financial transactions, or changes to wills or property arrangements
- A person speaking on behalf of the adult and preventing them from speaking for themselves
- Signs of poor hygiene, malnourishment, or inadequate care
- Unexplained changes in behaviour, mood, or communication
- Disclosures of abuse, whether direct or indirect
- Isolation from family, friends, or community
- Signs of over-medication or under-medication
Appendix C — Policy Acknowledgement Form
I confirm that I have read, understood, and will comply with the Spring Together CIC Safeguarding Policy (Version 1.0, May 2026). I understand that:
- Safeguarding is the responsibility of every person connected with Spring Together CIC
- I must report any safeguarding concern to the Designated Safeguarding Lead immediately
- I must not investigate concerns myself, promise confidentiality, or confront an alleged perpetrator
- I must complete the required safeguarding training before working unsupervised with children or vulnerable adults
- Failure to comply with this policy may result in disciplinary action or termination of my role