SALFORD CITY FOOTBALL CLUB
Safeguarding of children and vulnerable adults policy and procedures
V1 – September 2019
1. Introduction to the policy
The Board of Salford City Football Club, are ultimately responsible for ensuring that there is effective safeguarding within the organisation. All board members and staff have a responsibility to ensure that safeguarding and consideration of risk is a part of everything they do.
At Salford City Football Club we recognise the need to provide a safe and positive environment for all. We accept the responsibility for the safety and well-being of children and those other vulnerable groups who come within the care of the organisation including Academy 92 and Foundation 92.
This policy is adopted and implemented by the board of Salford City Football Club, intends to provide overarching principles and guidance to those who represent us as staff and volunteers, to guide our approach to safeguarding and the protection of children, young people and vulnerable adults. Through this policy we aim to ensure the safety & wellbeing of all young people, children and adults at risk.
The purpose of the policy is:
- To provide protection for children, young people and vulnerable adults who receive services from Salford City Football Club and its partners.
- To provide staff and volunteers with guidance on procedures they should adopt in the event that they suspect somebody may be experiencing, or be at risk of, harm.
- The policy is intended to protect children, young people and adults at risk who receive any service from us.
- To create and establish a culture where safeguarding practice is widely understood, openly discussed and where the workforce recognise the role they play in keeping children, young people, adults free from abuse.
We recognise that:
- The welfare of the children, young people and adults at Salford City is of paramount importance.
- Every person has the right to live a life free from abuse, regardless of age, disability, gender, race, religious belief, sexual orientation or identity.
- Everyone has the right to equal protection from all types of harm or abuse.
- Working in partnership with young people and vulnerable adults and their support networks is essential in promoting and embedding this policy.
We will seek to safeguard children and vulnerable groups by:
- Valuing, listening to and respecting them.
- Recruiting staff and volunteers safely, ensuring all necessary checks are made.
- Sharing information about safeguarding and best practice through training and Continual Personal Development (CPD).
- Sharing information about concerns with the appropriate agencies.
- Providing effective management of staff and volunteers through supervision, support and training.
- Creating clear policies and guidance systems which promote and support prevention, vigilance and early intervention where there are matters relating to safeguarding.
- Provide training, support and advice across all areas where there will be children, young people or vulnerable adults.
Our safeguarding aims:
- Preventing unsuitable people working with children and ensuring that staff are appropriately trained.
- Procedures for identifying and reporting cases, or suspected cases, of abuse. The definitions of the six categories of abuse are attached (see Appendix B).
- Supporting vulnerable children, adults or those who may have been abused or at risk of significant harm.
DSO refers to the designated safeguarding officer within Salford City FC.
‘Child’ and ‘Young Person’ is any person below the age of 18.
‘Vulnerable Adults at risk/groups’ refers to a person aged 18 or over who has a need for care and support and is experiencing, or at risk of neglect or abuse, and as a result of those care needs is unable to protect themselves. This may include a person with mental health needs, learning disabilities, older people and people with physical disabilities.
‘Workforce/Staff’ refers to any person who works on behalf of the club either in a paid or voluntary capacity.
‘Safeguarding’ is the action taken to promote the welfare of children in preventing harm. All children and young people have the right to be safe. All adults who spend time with young people and children have a responsibility to make sure that their well-being is prioritised.
2. Recruitment and employment
2.1 Safer Recruitment
No individual will be recruited on a paid or voluntary basis into a ‘Position of Trust’ without satisfactory clearance from the Disclosure and Barring Service (DBS) and two written references. Nor without the necessary qualifications, coaching qualifications for the role in which they have been appointed.
Due to the roles of much of our workforce, they are considered to be in a position of trust in relation to those in their care, meaning that where staff or any other members are in a position of influence and power over children, young people or vulnerable adults that they must not abuse their position for gratification or personal gain.
Salford City Football Club, through the EFL, will ensure appropriate checks are completed. Records of all staff/volunteers’ DBS numbers will be kept on file and recorded on the single central record (SCR).
No applicant, conditionally offered a position of trust with Salford City Football Club, will start until all satisfactory clearances have been received.
An individual applying for a post which involves contact with children/vulnerable groups must attend the necessary safeguarding training in line with their professional development.
Appropriate renewals of an individual’s criminal history and safeguard training will be completed in line with guidance issued by the EFL and FA at the justified time.
2.2 Understanding Roles and Responsibilities
All staff, paid and unpaid, working on behalf of the Salford City Football Club will be supported through their training to understand their duty around safeguarding.
Poor or unsafe practice regarding children, young people and adults at risk should be raised by staff immediately to DSO (designated safeguarding officer) sensitively and effectively.
All staff, paid and unpaid, will be reminded that it is not the responsibility of anyone within Salford City Football Club to decide whether abuse has taken place. However there is a responsibility to act on any concerns and report issues to the DSO.
Salford City Football Club will then investigate and in serious cases if and when required information will be shared with social services, the police, DBS service and the FA who may decide to take the lead on investigations.
2.2.1 Club Coaches Code of Conduct
- Respect the right, dignity and worth of each child.
- Develop an appropriate working relationship with each child. Over familiarity between coach and player may be misunderstood, therefore clear boundaries must be established from the beginning.
- Encourage and guide children to accept responsibilities.
- Ensure that all activities are safe and appropriate for participants.
- Clarify with children exactly what is expected of them and what they are entitled to expect from their coach.
- Co-operate fully with other specialists.
- Ensure that all players are aware of the procedures that are in place, i.e. when injured reporting to the physiotherapist before training. Failure to observe this may result in the player being withdrawn from playing. Coaches must not encourage children to train or play with injuries or illnesses.
- Consistently display high standards of behaviour and appearance.
- Personal data of children must be kept in a secure place. All such information is confidential. Access to the information should be limited to the squad coaches, the Scheme Administrator or Development Officers.
It is now against the law to work, or to employ someone to work, with Children and Young People without the receipt of a satisfactory DBS Clearance. A volunteer will not start at Salford City Football Club, until all satisfactory clearances have been received.
- In compliance with the Salford City Football Club’s Recruitment Policy, all volunteers employed to work in the Club must be confirmed as ‘suitable and safe adults to work with children and young people’ by the DBS. They must not start work until a satisfactory DBS clearance has been received.
- All volunteers will be trained in, and adhere to, Salford City Football Club’s Safeguarding Policy and Procedures.
- All volunteers must adhere to these guidelines.
- All volunteers should complete the EFL online safeguarding module.
2.3 Professional Boundaries
Professional boundaries are what define the limits of a relationship between a member of the workforce and a service user. They are a set of standards we agree to uphold that allows this necessary and often close relationship to exist while ensuring the correct detachment is kept in place.
Salford City expects staff to protect the professional integrity of themselves and the Club. The following professional boundaries must be adhered to:
2.3.1 Personal Relationships
Personal relationships between a member of staff (paid or unpaid) and a current service user is prohibited.
This includes relationships through social networking sites such as Facebook, Instagram, Snapchat and WhatsApp. It is also prohibited to enter into a personal relationship with a young person who has been a service user over the past 12 months. This extends to personal relationships with a third party related to service users and Under-18s.
2.3.2 Use of abusive language
No staff, volunteers or those engaged in activity with Salford City Football Club should use abusive language at any Salford City event. All staff at Salford City Football Club have a right to to hear civil, reasonable language at all times.
Salford City Football Club regards abusive language as swearing and language that expresses stereotypical and perverse comments about Race, Sexuality, Gender, Religious Belief, age and Disability.
Any incidents of abusive language should be referred to the Safeguarding Officer who will take relevant action.
2.3.3 Selling to or buying items from a service user
Under no circumstances should a member of Salford City Staff, paid or voluntary, buy or sell any items to any service users associated with the club.
2.3.4 Accepting money as a gift / Borrowing money from or lending money to service users
Under no circumstances should a member of Salford City staff, paid or voluntary, accept money as a gift from a service user. If a service user request to borrow money the Safeguarding Officer should be contacted as this could be a sign of an underlying safeguarding issue.
2.3.5 Accepting responsibility for any valuable on behalf of a service user
On occasions a service user may ask staff to hold on to or keep safe a valuable item such as a phone or a watch. This is acceptable, however the staff must let the service user know that this is at their own risk and Salford City Football Club accept no responsibility for lost or damaged items.
Salford City must make this policy clear to young people engaged in activity with the Club.
3. Procedures for reporting cases (or suspected cases) of abuse
3.1 Safeguarding Training
Salford City Football Club will provide an online safeguarding module in conjunction with the EFL for all staff, paid and unpaid from the point of their induction which is updated regularly. All staff working with young people have to take part in FA safeguarding training, this has to be done every 3 years.
At Salford City we support our staff to be confident about:
- Salford City Football Club legislative responsibilities.
- Their personal responsibilities.
- Salford City Football Club policies and procedures.
- The need to be alert to the signs and indicators of possible abuse, including possible child sexual exploitation, female genital mutilation and radicalisation.
- The need to record concerns.
- How to support and respond to a child who makes a disclosure of abuse.
- Salford City Football Club will if required support staff who have been affected by such reports.
3.2 Recognising Abuse
To ensure that our children are protected from harm, we need to understand what types of behaviour constitute abuse and neglect.
Abuse and neglect are forms of maltreatment. Somebody may physically abuse a child by inflicting harm, for example by hitting them, or by failing to act to prevent harm, for example by leaving a small child home alone. Abuse may be committed by adult men or women and by other children and young people.
Working Together to Safeguarding Children 2019 (HM Gov) and Keeping Children Safe in Education (DfE 2016) refer to five main categories of abuse and a sixth referring to finance. These are set out below along with indicators of abuse.
What is abuse?
Defined as the actual or likely injury to a child or vulnerable adult, or the failure to prevent physical injury or suffering to a vulnerable individual. This may include:
- Physical signs such as injuries that are unexplained.
- Injuries that have not received medical attention.
- Medical problems that go unattended such as persistent pressure sores and skin infections.
- Scalds or unusual bruises.
- Bullying and aggression or abuse of others.
- Withdrawal or feelings of depression.
- Fear of going to a certain place or having contact with a particular individual.
Neglect is the persistent failure to meet a child or vulnerable adult‘s basic physical and/or psychological needs, likely to result in the serious impairment of the Vulnerable Individual’s health or development.
- A child or vulnerable adult appears malnourished or dehydrated.
- A child or vulnerable adult has untreated medical problems.
- A child or vulnerable adult lacks physical aids when they are required by the child or vulnerable adult to live normally.
- A child or vulnerable adult lives in accommodation which falls below minimum practical standards.
- A child or vulnerable adult’s physical appearance or condition is poor.
- Callers or visitors are refused access to the child or vulnerable adult’s home.
- A child or vulnerable adult does not appear to be receiving their prescribed medication.
- A child or vulnerable adult has a prolonged unusual period of absence.
Sexual abuse involves forcing or enticing a child or vulnerable adult to take part in sexual activities, whether or not the child or vulnerable adult is aware of what is happening. This again may be difficult to identify, but there are some indicators:
- Urinary tract infections or sexually transmitted disease.
- Pain, soreness or itchiness.
- A child or vulnerable adult discloses fully or partially that sexual abuse is occurring or has occurred in the past.
- A child or vulnerable adult appears unusually withdrawn or has poor concentration.
- Running away.
- Age inappropriate sexually explicit knowledge or behaviour.
Emotional abuse is the persistent emotional ill-treatment of a child or vulnerable adult such as to cause severe and persistent adverse effects on the child or vulnerable adult’s emotional development. It may feature age or developmentally inappropriate expectations being imposed on the child or vulnerable adult. This form of abuse is more difficult to identify, but here are some signs to be aware of.
- A carer always being present so you cannot see the child or vulnerable adult on their own.
- Low self-worth, lack of confidence, worried appearance.
- Increased levels of confusion.
- Toileting problems.
- Lack of growth or development.
- Submissive behaviour when the perpetrator is around.
- Excessive distress, particularly when a visitor is leaving.
Bullying is the use of aggression with intention of hurting another person. It results in pain and distress for the victim. It may occur from coach to player, within player peers and sometimes players to coach. It can be difficult to define below are some examples.
- A player intimidates other players.
- An official is over officious.
- Emotional, Eg. Being unfriendly towards or excluding others.
- Verbal, Eg. Name calling, teasing, spreading rumours.
- Electronic, Eg. Emails, texting, comments on social networking sites.
Financial abuse can take many forms, from denying you all access to funds, to making you solely responsible for all finances while handling money irresponsibly themselves.
Money becomes a tool by which the abuser can further control the victim, ensuring either the child or vulnerable adult’s financial dependence on them, or shifting the responsibility of keeping a roof over the family’s head onto the child or vulnerable adult while simultaneously denying their ability to do so or obstructing them.
- Unusual financial transactions or loss of financial assets.
- Unexplained loss of valuable items, jewellery, heirlooms, personal collections etc.
- Changed signatories to bank accounts or other assets.
- A person who always visits on the day they receive state payments.
- Unexplained visits from neighbours or local young people, where these are not supervised.
- Professional Contract ‘promise’ by a coach to an aspiring player and/or players family in return for progression.
3.3 Taking Action
Any child in any family and in any organisation could become a victim of abuse. Staff should always maintain an attitude of “it could happen here”.
- In an emergent take immediate action necessary to help the child. If required call 999.
- Report your concerns as soon as possible to the DSO, this should be before the end of the day.
- Do not start your own investigation.
- Share information on a need-to-know basis only – do not discuss the issue with colleagues, friends or family.
- Seek support for yourself if required.
- Complete a referral form.
All concerns are to be reported to the Club Safeguarding team via 0161 792 6287.
3.3.1 Referral Form
- It is important for staff to record, without delay anything which they may have been told or observed where a concern has been identified.
- It is important that they right an accurate record leaving out their own feelings and remain objective throughout.
- Reports should be completed on the referral form (within that working day), if the referral form is not to hand all written evidence recorded will need to be attached to the completed form. This will be important in the event that a case goes to court as this will form the basis of legal evidence.
- All reports must be kept factual and not subjective.
- Should there be an injury, provide a note or sketch of the injury where possible on the Salford City Body Map form, for example appearance and size.
3.3.2 If you are concerned about a Child’s welfare
There will be occasions when staff may suspect that a child may be subject to harm or abuse. These concerns may arise as a result of issues within Club activities or outside of the Club environment. Their behaviour may have changed, they may show signs of confusion or distress, or physical indicators may have been noticed. In these circumstances, staff should give them the opportunity to talk and ask if they are okay or if they can help in any way.
Staff should record these early concerns and report them to the DSO. If the child does reveal that they are being harmed, staff should follow the advice below and discuss their concerns with the DSO.
Concerns noted by Parents / Carers
Parents and Carers will know their children best and are best placed to notify changes in their well being or behaviour. Should you be concerned abut your child’s behaviour or wellbeing, you contact a member of the Safeguarding team.
3.3.3 If somebody discloses to you
It takes a lot of courage for anybody to disclose that they are being abused and there are even greater blocks for children and young people. They may feel ashamed, particularly if the abuse is sexual; their abuser may have threatened what will happen if they tell; they may have lost all trust in adults; or they may believe, or have been told, that the abuse is their own fault. Sometimes they may not be aware that what is happening is abusive.
If a child talks to a member of staff about anything that indicates a potential risk to their safety or wellbeing, the staff member will, at the appropriate time, let the child know that in order to help them they must pass the information on to someone who can help or advise (the DSO).
- Appropriate questioning is a specialist area which should be undertaken by social services or police officers. It is important that staff record all information that is being shared with them at the time of the disclosure.
- Remain calm and not over-react.
- Give reassuring nods or words of comfort:
- ’I’m so sorry this has happened’,
- ‘I want to help’,
- ‘This isn’t your fault’,
- ‘You are doing the right thing in talking to me’
- Not be afraid of silences.
- Under no circumstances ask investigative questions such as how many times this has happened, whether it happens to siblings, or what does their mother think about it. It is fine to say ‘Do you want to tell me what has happened?’ or ‘Can you describe what you mean by [quote something they have said]?’ in order to clarify what has caused them distress or harm.
- At an appropriate time tell the child/adult at risk that in order to help them, the member of staff must pass the information on to the Club’s Safeguarding lead to get advice and support.
- Not automatically offer any physical touch as comfort. If the child is upset and initiates the contact themselves, this should be recorded and reported.
- Tell the child what will happen next.
- Report verbally to the DSO themselves (never assume the child or someone else will or has done so).
- Provide reassurance, but false promises of confidentiality should never be made.
- Complete a written record and hand it to the DSO as soon as possible.
- Seek support for themselves as managing concerns always has an emotional impact.
3.4 Notifying Parents
The Club will normally seek to discuss any concerns about a child with their parents or legal guardian. This must be handled sensitively and the DSO will make contact with the parent in the event of a concern, suspicion or disclosure.
Our focus is the safety and wellbeing of the child. Therefore, if the Club believes that notifying parents could increase the risk to the child or exacerbate the problem, advice will first be sought from children’s social care and/or the police before parents are contacted.
3.5 Confidentiality and sharing information
All staff will understand that safeguarding issues warrant a high level of confidentiality, not only out of respect for the person and staff involved but also to ensure that information being released into the public domain does not compromise evidence or any subsequent investigation.
Staff should only discuss concerns with the DSO and/or Senior Safeguarding Manager. That person will then decide who else needs to have the information and they will disseminate it on a ‘need-to-know’ basis.
However, any member of staff can contact children’s social care if they are concerned about a child.
Safeguarding information will be stored and handled in line with the General Data Protection Regulations Policy 2018. Information sharing is guided by the following rules and principles*:
- Neither data protection legislation and guidance or human rights law are barriers to sharing information in the interests of safeguarding.
- Be open and honest.
- Seek advice (from designated people, eg. DSO or statutory agencies).
- Share information with consent where possible.
- Always consider safety and wellbeing.
- The information shared is necessary, proportionate, relevant, adequate, accurate, timely and secure.
- A record must be kept of your actions, decisions and reasons for it.
* Information sharing Advice for practitioners providing safeguarding services to children, young people, parents and carers. HM Gov. March 2015.
Information sharing decisions will be recorded, whether or not the decision is taken to share.
In accordance with Salford City Football Club’s Data Policy (GDPR), referral forms and other written information will be stored in a locked facility with restricted access and any electronic information will be stored in a protected file, transferred securely and only made available to appropriate individuals.
Child protection records are normally exempt from the disclosure provisions of the Data Protection Act, which means that children and parents do not have an automatic right to see them. If any member of staff receives a request to see child protection records, they will refer the request to the DSO/SSM.
The Club’s Data Policy is available to parents and young people/adults at risk on request.
3.6 Referral to Children’s Social Care
The DSO will make a referral to children’s social care if it is believed that a child is suffering or is at risk of suffering significant harm. The child (subject to their age and understanding) and the parents will be told that a referral is being made, unless to do so would increase the risk to the child.
Any member of staff may make a direct referral to children’s social care if:
- They believe independent advice and action is necessary to protect a child.
- The situation is an emergency and the DSO and SSM are unavailable.
- They are convinced that a direct report is the only way to ensure the child’s safety.
- For any other reason they make a judgement that direct referral is in the best interests of the child.
3.7 What is abuse and what will raise concern
3.7.1 Peer on peer abuse
A child may be harmed by other children or young people. Staff will be aware of the harm caused by bullying and will use the Club’s anti-bullying procedures where necessary. However, there will be occasions when a child’s behaviour warrants a response under child protection rather than anti- bullying procedures.
Peer on peer abuse can take many forms, including:
- Physical abuse such as biting, hitting, kicking or hair pulling.
- Sexually harmful behaviour/sexual abuse such as inappropriate sexual language, touching, sexual assault.
- Sexting, including pressuring another person to send a sexual imagery or video content.
- Teenage relationship abuse – defined as a pattern of actual or threatened acts of physical, sexual or emotional abuse, perpetrated against a current or former partner
- Initiation / Hazing – used to induct newcomers into an organisation such as sports team or school groups by subjecting them to a series of potentially humiliating, embarrassing or abusing trials which promote a bond between them.
- Prejudiced behaviour – a range of behaviours which causes someone to feel powerless, worthless or excluded and which relates to prejudices around belonging, identity and equality, in particular prejudices linked to disabilities, special educational needs, ethnic, cultural and religious backgrounds, gender and sexual identity.
Abuse is abuse and should never be tolerated or passed off as ‘banter’ or ‘part of growing up’. Different gender issues may be prevalent when dealing with peer on peer abuse, for example girls being sexually touched/assaulted or boys being subject to initiation/hazing type violence.
At our Club, we take the following steps to minimise or prevent the risk of peer on peer abuse:
- We will seek to promote an open and honest environment where young people feel safe to share information about anything that is upsetting or worrying them.
- Induction processes are used to provide a moral framework outlining codes of conduct, acceptable behaviour and stressing the effects of bullying.
- Staff will endeavour always to create surroundings where everyone feels confident and at ease in the Club.
- We will ensure that Club activities are well supervised by appropriate and qualified staff and volunteers.
All allegations of peer on peer abuse should be passed to the DSO immediately. They will then be investigated and dealt with as follows:
- Information gathering – children, staff and witnesses will be spoken with as soon as possible to gather relevant information quickly to understand the situation and assess both the impact and whether there was intent to cause harm.
- Decide on action – if it is believed that any young person is at risk of significant harm, a referral will be made to children’s social care. The DSO will then work with children’s social care to decide on next steps, which may include contacting the police.
- Inform parents – as with other concerns of abuse, the school will normally seek to discuss concerns about a child with parents. Our focus is the safety and wellbeing of the child and so if the Club believes that notifying parents could increase the risk to the child or exacerbate the problem, advice will first be sought from children’s social care and/or the police before parents are contacted.
While bullying between children is not a separate category of abuse and neglect, it is a very serious issue that can cause anxiety and distress. All incidences of bullying, including cyber-bullying and prejudice-based bullying should be reported and will be managed through our anti-bullying procedures.
(Refer to bullying policy)
There is no accepted definition of ‘sexting’ but most professionals agree that it refers to the sending or posting of sexually suggestive images, including nude or semi-nude photographs of a person under 18 years of age, via mobiles or over the internet.
The UK Council for Child Internet Safety defines sexting as the production and/or sharing of sexual photos and videos of and by young people who are under the age of 18. It includes nude or nearly nude images and/or sexual acts. It is also referred to as ‘youth produced sexual imagery’.
‘Sexting’ does not include the sharing of sexual photos and videos of Under-18s with or by adults. This is a form of child sexual abuse and must be referred to the police.
Guidance for staff and volunteers dealing with sexting incident/disclosure:
- The incident should be referred to the DSO immediately and the DSO will clarify the concerns with any staff involved in reporting and ensure concerns are accurately recorded.
- Never view, download or share the imagery yourself, or ask a child to share or download – this is illegal.
- If you have already viewed the imagery by accident (e.g. if a young person has showed it to you before you could ask them not to), report this to the DSO.
- Do not delete the imagery or ask the young person to delete it.
- Do not ask the young person(s) who are involved in the incident to disclose information regarding the imagery. This is the responsibility of the DSO.
- Do not share information about the incident with other members of staff, the young person(s) it involves or their, or other, parents and/or carers.
- Do not say or do anything to blame or shame any young people involved.
- Do explain to them that you need to report it and reassure them that they will receive support and help from the DSO.
- If there is a concern a young person has been caused distress, harmed or is at risk of harm a referral will be made to the police immediately. The police do not seek to criminalise young people but take sexting very seriously and will take appropriate action which may include seizure of devices and speaking to the young people involved. On-line abuse through sexting can have very serious consequences and undertaking an investigation at Club level can lead to images and evidence being deleted which prevents appropriate action being taken to support and/or educate those involved or impacted by these issues. Parents will be informed at an early stage and involved in the process unless the police advise against this or there is good reason to believe that involving parents would put the young person at risk of harm.
3.7.4 Sexual Exploitation of Children
Sexual exploitation involves an individual or group of adults taking advantage of the vulnerability of an individual or groups of children or young people, and victims can be boys or girls. Children and young people are often unwittingly drawn into sexual exploitation through the offer of opportunities, future career gains, friendship and care, gifts, drugs and alcohol, and sometimes accommodation. Sexual exploitation is a serious crime and can have a long-lasting adverse impact on a child’s physical and emotional health. It may also be linked to child trafficking.
A common feature of sexual exploitation is that the children often don’t recognise the coercive nature of the relationship and therefore do not see themselves as a victim. In some cases parents/guardians also fail to recognise that a relationship is potentially abusive and both the child and their carers may initially resent what they perceive as interference by staff, but staff must act on their concerns, as they would for any other type of abuse.
All staff are made aware of the indicators of sexual exploitation and all concerns are reported immediately to the DSO.
3.7.5 Honour-based Violence
‘Honour-based’ violence (HBV) encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation (FGM) forced marriage, and practices such as breast ironing. All forms of HBV are abuse.
FGM is the collective name given to a range of procedures involving the partial or total removal of external female genitalia for non-medical reasons. In England, Wales and Northern Ireland, the practice is a criminal offence under the Female Genital Mutilation Act 2003. The practice can cause intense pain and distress and long-term health consequences, including difficulties in childbirth.
FGM is carried out on girls of any age, from young babies to older teenagers and adult women. Many such procedures are carried out abroad and staff should be particularly alert to suspicions or concerns expressed by a girl of any age about going on a long holiday during the summer vacation period.
A forced marriage is a marriage in which a female (and sometimes a male) does not consent to the marriage but is coerced into it. Coercion may include physical, psychological, financial, sexual and emotional pressure. It may also involve physical or sexual violence and abuse. In England and Wales the practice is a criminal offence under the Anti-Social Behaviour, Crime and Policing Act 2014. The reporting of any concerns about either suspected forced marriage or FGM is mandatory.
Children may be married at a very young age, and well below the age of consent in the UK which would make it unlawful in relation to a UK citizen. Relevant Club staff receive training and should be particularly alert to suspicions or concerns raised in relation to a young person who is being taken abroad and may be anxious or prevented from returning to the UK.
3.7.6 Radicalisation and Extremism
Radicalisation is defined as the process by which people come to support terrorism and extremism and, in some cases, to then participate in terrorist groups or activities.
The government defines extremism as ‘vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs’ (HM Government Prevent Strategy).
Some children are at risk of being radicalised: adopting beliefs and engaging in activities which are harmful, criminal or dangerous. Islamic extremism is the most widely publicised form however staff should also remain alert to the risk of radicalisation into white supremacy extremism.
‘Prevent’ is a cross-Government policy that forms one of the four strands of the UK’s strategy for counter terrorism which includes the prevention of radicalisation of vulnerable adults and children. Those who are targeted with a view to radicalise them are often the most vulnerable in society including those with poor networks of support or who are experiencing socially isolated, mental health issues and/or learning and communication issues.
Keeping children safe from these risks is a safeguarding matter and should be approached in the same way as safeguarding children from other risks.
If the behaviour of anybody involved in our activities indicates that they or those around them are at risk of harm, staff should report these concerns immediately to the DSO. In the event that there appears to be an immediate risk or danger call 999.
3.7.7 Supporting those involved
The support required for the child who has been harmed will depend on their circumstance and the nature of the abuse. Support could include counselling, mentoring, the support of family and friends and/or support with improving peer relationships.
We acknowledge that support may also be required for the child that exhibited harmful behaviour. We will seek to understand if appropriate why the child acted in this way, in order to consider what support may be required to help the child change behaviours or whether support is required through external agencies.
3.8 Childs Living Arrangement
3.8.1 Private Fostering Arrangements
A private fostering arrangement occurs when someone other than a parent or a close relative cares for a child for a period of 28 days or more, with the agreement of the child’s parents. It applies to children under the age of 16 or aged under 18 if the child is disabled. By law, a parent, private foster carer or other persons involved in making a private fostering arrangement must notify children’s services as soon as possible.
Where a member of staff becomes aware that a child may be in a private fostering arrangement they will raise this with the DSO and the Club will notify the local authority who will check whether the arrangement is suitable and safe for the child. The Club, on very rare occasions, makes arrangements for Academy scholars to stay with a host family. In such circumstances the Club will adhere to its Host Family policy to ensure that all safeguarding considerations are addressed and agreed with the player and his parents.
Where any accommodated scholar is aged under 16 arrangements will be agreed in partnership with the local authority and in line with the Children (Private Arrangements for Fostering) Regulations 2005.
3.8.2 Looked-after Children
The most common reason for children becoming looked after (taken into care) is as a result of abuse or neglect. Children’s early experiences have a significant impact on their development and future life chances. As a result of their experiences, both before and during care, looked after children are at greater risk than their peers.
Appropriate staff will be informed about a child’s looked after legal status and care arrangements, including the level of authority delegated to the carer by the local authority looking after the child. Any indicators or signs that a looked after child may require additional support or protection must be reported without delay to the DSO who will share concerns with the Local Authority without delay.
Related Safeguarding Portfolio Policies
These policies should be read alongside our other Club Safeguarding policies and procedures:
Risk Assessment Policy
Social Media Policy
Health and Safety Policy
Data Protection Policy
Equal Opportunities Policy
Photography / image consent Policy
Safer recruitment Policy
Trips Tours and Tournamnets Policy
Late collection of children Policy
Staff Induction / process
Acceptable IT use Policy
4.1 Whistleblowing Policy
All organisations face the risk of things going wrong or of unknowingly harbouring malpractice. Salford City Football Club believes it has a duty to identify such situations and take the appropriate measures to remedy the situation. By encouraging a culture of openness within our organisation, Salford City Football Club believes it can help prevent malpractice – prevention is better than cure. That is one of the aims of this policy.
Workers have a right and duty to raise matters of concern they may have about the services being offered by Salford City Football Club or serious malpractice associated with them. Workers may be worried that by reporting such issues they will be opening themselves up to victimisation or detriment, or risking their job security. However, all staff are protected by law if they raise concerns in the right way. Provided they are acting in good faith, it does not matter if they are mistaken.
By knowing about malpractice at an early stage Salford City Football Club stands a good chance of taking the necessary steps to safeguard the interests of all staff and protect the organisation. In short, please, do not hesitate to “blow the whistle” on malpractice.
This policy is designed to ensure workers raise concerns properly and to ensure that mechanisms exist in Salford City Football Club whereby issues raised by workers will be addressed quickly and effectively. The policy also sets out the legitimate course of action, which may be taken by the worker to raise issues with parties outside of Salford City Football Club if an issue is not addressed by Salford City Football Club, or it is felt that by raising it internally may lead to evidence of malpractice being concealed.
The purpose of this policy is to outline how workers may deal with concerns about other workers and/or service provision which may have an impact or threaten the wider public interest.
Please note that this policy does not affect the existing Grievance Procedure. If workers have a complaint about their own personal circumstances then they should use the normal Grievance Procedure. If workers have concerns about malpractice within the organisation then they should use the procedure outlined in this policy. This policy is applicable to all the Salford City Football Club staff and volunteers.
4.2 Complaints Policy
All complaints will be dealt with in accordance with the Salford City Football Club Complaints Policy. However, due consideration will be given to the nature of the complaint if it contains a safeguarding concern. No complaint can be dealt with if the concern is being dealt with by statutory agencies, as this may hinder any legal or care proceedings. Complainants of a safeguarding matter can refer their concerns to either the Salford City Football Club Safeguarding Manager or the EFL Safeguarding Officer.
4.3 Social Media Policy
Salford City Football Club has developed a Social Media Policy. This includes information about use of social media, taking and sharing of photographs and inappropriate internet use etc…
4.3.1 Communication with Children and Young People involving technology
For the purpose of this policy ‘technology’ includes the use of mobile phones, text messaging, e-mails and all forms of electronic Messaging Services and Web Sites.
Communication between Children and Young People and Adults, by whatever means, must only take place within the boundaries of professional behaviour.
Salford City Football Club staff must not give their personal contact details, including home / mobile phone numbers, or e-mail, or messaging addresses to children and young people with whom they work at Salford City Football Club, nor may they respond to any personal information from children and young people.
Designated Staff must ensure that any communication with children and young people is used only for professional reasons, and that parents/carers are aware and have consented to such contact.
Company e-mail systems should be the primary means of forwarding information if parents have given their consent for the use of this means of communication.
The only permissible information to be communicated would be to inform players and their parents/ carers of any urgent changes in arrangements.
In the case of tours, tournaments, residential courses, Salford City Football Club will have a central contact number for parents/carers.
4.3.2 Texting and Electronic Communication
Text messaging makes staff vulnerable and should under no circumstances be used for personal communication.
Personal telephone numbers e-mail, Social Networking or other Electronic Communications addresses should NEVER be given to the young people you work with at Salford City Football Club. When communicating professionally to young people at the club via text or email, there must be at least one other adult over the age of 18 copied into the conversation. It is best practice for that to be a parent/guardian of the young person concerned and another member of Salford City Football Club staff.
All communications between Salford City Football Club and young people should be through official Salford City Football Club channels. If in the case a child texts a member of staff, or contacts them through social media, they should notify the Academy Manager or Designated Safeguarding Officer and the child’s parent at the earliest opportunity. Staff should constantly reinforce to parents that their contact numbers or email addresses are not to be shared with children.
4.3.3 Social Networks
Most children will assume they are safe when using the internet because they are in their own home. They will usually assume that the person they are chatting with is who they say they are. Using the internet is now central to how children and young people stay in touch with their friends and family by using Social Networks like Facebook, Instagram, Snapchat and Twitter. However the internet is also a public place and while bringing many benefits and opportunities, also opens up new risks and challenges.
Children and Young People
- Don’t give out any personal information: Guard your home address and family information. Abusers will use this to groom a child or young person over the internet.
- Do not save images of a child in Salford City Football Club clothing on a social network: Those who wish to harm children will use this as a tool to gain trust in them and it will create an obvious connection of celebrity status which children and young people are interested in.
- Report inappropriate behaviour.
- Report incidents of bullying, sexual exploitation, or other fraud to the chat room moderator (as well as to the police if applicable).
Employees and Volunteers
- It is prohibited that Salford City Football Club staff and volunteers use the internet to contact children and young people.
- Do not become ‘friends’ on social networks with children and young people you are in a position of trust with.
- If you are concerned about the way a player is attempting to contact you via the internet e.g. using a social networking site or a chat area, speak to your Academy Manager or Designated Safeguarding Officer.
- Remember that even when outside of work, the law deems that if you are in a position of trust, this must be maintained at all times.
4.3.4 Club Medical Department
In compliance with Salford City Football Club’s Recruitment Policy, all physiotherapists employed to work in the Club must be confirmed by the DBS as appropriate and safe adults to work with children and young people. This clearance must be received by Salford City Football Club before the physiotherapist commences work at the Club.
All Physiotherapy staff working in the Club will be trained in and adhere to the Salford City Football Club’s Safeguarding Children Policy and Procedures.
All members of staff should ensure that when treating or assessing a player with an injury on any part of the body, an adult chaperone is present. This chaperone may be the child’s parent/carer or coach.
Physiotherapists must advise squad coaches of injuries. They must advise children, parents/carers and coaches of the treatment required and whether non-participation in training and or playing is necessary.
After injury, physiotherapists must advise coaches and parents/carers when a child is fit to participate in training and playing.
4.4 Information Sharing
Information sharing is key to the Government’s goal of delivering better, more efficient public services that are coordinated around the needs of the individual. It is essential to enable early intervention and preventative work, for safeguarding and promoting welfare and for wider public protection.
Information sharing is a vital element in improving outcomes for all. The Government understands that it is important that people remain confident that their personal information is kept safe and secure and that practitioners maintain the privacy rights of the individual, whilst sharing information to deliver better services. It is therefore important that practitioners can share information appropriately as part of their day-today practice and do so confidently. It is important to remember there can be significant consequences to not sharing information as there can be to sharing information. You must use your professional judgement to decide whether to share or not, and what information is appropriate to share.
Golden rule – Remember that the GDPR Act is not a barrier to sharing information but provides a framework to ensure that personal information about living persons is shared appropriately.
4.5 Best practice in the use of images
As part of Salford City Football Club’s commitment to safeguarding children and young people, in accordance with guidance from the Football Association and the Premier League, the only photography allowed at all Salford City Football Club activities will be that taken by designated Club official(s). The Club will provide them with a clear brief about what is appropriately required.
Guidelines for all age groups:
- Salford City Football Club must have parental consent to use a player’s image if it is to be used in the public domain e.g. club website or newspaper article. This should be obtained via section 5.1.9 of the Academy 92 Scholar Contract which is signed by a Parent/Guardian
- Do not publish photographs on the Academy 92 with or without the full name(s) of the individual(s) featured unless you have permission by the Academy and in some cases without written consent to do so and you have informed the parents as to how the image will be used.
- Ensure that any child at Salford City Football Club, who is under care proceedings, is protected by ensuring that their image is not placed in the public domain. This can be done by using a Consent Form, so that parents/carers can identify whether this applies to children in their care.
- The image should focus on the activity and not the child or young person. Unless it is for club promotional purposes and permission is obtained from parent/carer for each individual instance eg. player profiles on club website.
- Ensure that those featured are appropriately dress – a minimum of a vest/shirt and shorts is required.
Guidelines for Under-18 players:
- No individual profiling – it is strongly recommended that no under-18 player should become the focus of excessive media attention and that commentators, presenters and journalists should respect this principle, modifying their contact with the young players accordingly.
- Try not to use images that include individuals wearing jewellery (as wearing jewellery whilst playing is contrary to the Laws of the Game as well as being a health and safety issue).
- If you have serious concerns about a possible child protection issue relating to the recording of images then call the Police. This action should only be taken where you believe that someone may be acting unlawfully or putting a child at risk.
Images on tour, at tournaments and training camps
In order to capture the fun, enjoyment and learning opportunities that takes place on Tours, Tournaments and Training Camps the Tour Leader will appoint a designated person to take photographs. The pictures will be used for the Tour diary. If they are used for any other purpose parents will be notified by Salford City Football Club. The Tour Leader will ensure that the person is documented on the relevant travel log.
The designated person for photographs will be the only member of staff who is permitted to take photographs whilst away and will follow the above guidelines. This will also include ensuring that photographs are taken with a camera and not on a mobile phone. Permission for images will have been gained at the beginning of the season but it is advised that the Tour Leader raises parent’s awareness by notifying them of the possibility of photographs being taken whilst on Tours, Tournaments and Training Camps.
4.6 Matchday Safeguarding Policy
The following section provides some further detail with regards to incidents that take place at a Salford City Football Club home fixture at The Peninsula Stadium, a youth team fixture at the training ground and any Salford City Lionesses home fixture.
Salford City Football Club endeavours to ensure that attending a fixture is a positive experience for everyone. When considering bringing a child or vulnerable adult, please consider their age, time of the fixture, the weather conditions and any other applicable factors that may create risk.
4.6.2 Staying Together
Staff at the Peninsula Stadium and Training Ground are well trained and experienced in providing a safe environment for all our visitors but wherever there are large gatherings of people, there are risks. We aim to have a family-friendly environment but that does not mean common sense should not always prevail. Parents or other chaperones have primary responsibility for the safety of the children they bring and should keep them close always.
Please be aware of where your child is always during your visit and have a plan to meet somewhere if you get separated (one point inside and one point outside). Ensure they know who to contact should they feel lost or worried. Stewards are situated around the stands in high visibility jackets. Our stewards are trained in how to deal with lost children, please ensure your child knows not to go off with a spectator they do not know.
Should you get separated from your child please contact a steward immediately and listen to announcements over the stadium speakers.
Please ensure your child is aware what to do in case of an emergency including how to evacuate the stadium in an emergency and where to meet up with you.
Weather conditions vary through the football season and visitors are likely to experience all weather types: early and late season may mean high temperatures and strong sunshine – parts of the stadium may be in full sun for long periods of time; mid-winter games, especially at night, may mean sub-zero temperatures, rain, wind and snow; and frost and ice underfoot may also be an extra hazard for those carrying or walking with small children. Be very careful in cold and wet and windy conditions.
Babies and very small children can become very cold very quickly, even at times of the year where adults feel that it is warm outside, they will more than likely be inactive at the stadium and get cold quickly. Keep an eye on your child. Don’t forget, unusually quiet with bright red skin doesn’t necessarily mean they are warm and happy, this could be a sign of hypothermia (their skin will be cold). If you do choose to bring your child to a match remember to clothe them with layers, at least one more than you are likely to be wearing as well as an outer coat, hat and gloves in wintry conditions.
Check the weather forecast before you leave and be prepared for it to be colder, wetter, hotter than predicted.
Football matches are noisy events and the noise levels go up and down throughout a match; small children are more sensitive to noise and thus are more prone to hearing damage. Whilst long term damage from the noise at stadiums is unlikely, the peak sounds can reach the same levels experienced in a nightclub. Ear plugs or muffs may help to protect their hearing and ear muffs may also help to keep them a little bit warmer.
The club has Safeguarding Officers that are present at all matches. Should you have a concern about a child or vulnerable adult whilst at a match please contact a steward immediately who will put you in contact with the Safeguarding Officer. Please view the Salford City Football Club Safeguarding of Children and Vulnerable Adults Policy for further information.
4.7 Training Ground Policy
All aspects of the clubs policy apply to the use of the Training Ground and the people who work there.
All visits to the Salford City Football Club Training Ground must be done by prior arrangement. All visitors, including staff not based at the training ground, must sign in on arrival and sign out upon leaving.
All visitors will be supervised by a member of Salford City’s staff whilst on site. Non-staff visitors must wear a visitor pass.
- Never find yourself alone one on one in a room with a child or young person. If you do remove yourself from the situation immediately.
- If it is unavoidable, make sure that the door is open and that you are in easy view of other staff.
- No one should engage in any inappropriate behaviour, actions or language in the presence of an Academy Member.
- There is to be designated Academy Changing Rooms separate from First Team Changing Rooms.
- All match officials will be provided with a gender specific changing room and toilet facility.
- No one other than Academy Members and Academy Staff should enter the designated Academy Changing Rooms.
- Academy Members should only use the bathrooms in the Academy Changing Rooms and no one else should use these for any reason.
- The use of mobile phones by both Staff and Academy Members in the Academy Changing Rooms is strictly prohibited.
- All visitors must be signed in, wear a visitors pass clearly at all times and never be left unattended at any point during their visit.
- All Academy Staff and those in regular contact with the Academy must have a current FA Enhanced DBS Certificate and have completed the FA Safeguarding Course. Anyone who has not completed this will not be allowed access to the Training Ground.
- No unauthorised photography or video filming is to be taken at any time whilst onsite.
4.8 Transport Policy
- If driving an Academy Member you must have Full Business Insurance.
- Each driver should check the number of people their car is insured to carry, and carry no more than that number (including the driver).
- Check that the vehicle is mechanically sound, has a valid road-fund licence and a valid MOT certificate (where appropriate).
- You must not carry Academy 92 Members where seatbelts are unavailable (i.e. every member must have a seatbelt).
- Ensure seat belts are on.
- Take directions and a map if necessary, and nominate a map-reader so that the driver is not distracted trying to map-read and drive at the same time.
- Ensure someone is expecting you at a certain time at a certain place, so that if you appropriate steps can be taken to determine where you are.
- Always drive within the speed limits, and within the limits of your driving ability, the car and the prevailing conditions (weather, road surface, other vehicles, road works, etc).
- Do not drive under the influence of drink or drugs. (The club has a zero tolerance threshold on driving after alcohol consumption this is even if you are under the legal limit)
- Mobile phones and any other electronic devices must NOT be used by drivers when driving.
- Keep your distance from the vehicle in front.
- Be courteous to others, anticipate what might happen, keep a watch for the unexpected (child stepping off the kerb, car pulling out, sudden braking, etc).
- Don’t show off – avoid the temptation to impress your passengers with speed or handling.
- Don’t turn the stereo up so loud that you’re distracted.
- From both a safeguarding and safety perspective, you must have at least 2 Adults per vehicle when you are transporting Academy 92 Members.
- If it is unavoidable you find yourself alone in a car with an Academy Member (under the age 18) they must sit in the back of your car. You must also notify the Welfare Officer and the Parent/Guardian of the Academy 92 member you are transporting.
- Have a mobile phone on you in case of a breakdown.
- Anyone transporting Under-18 players must provide evidence of a full enhanced DBS check. Dated within the last 3 years.
4.8.2 Club Drivers
- Drivers will have appropriate training and licences (See Drivers policy).
- Drivers will only transport players they have been authorised to transport. Drivers must check that the appropriate parental consent has been given.
- Drivers must ensure that all those being transported are wearing seat belts.
- Drivers must ensure that all those being transported remain seated throughout the journey.
- Should a driver be left with one child he/she must insist that the child is sitting in the rear of the car/mini bus.
- Regular check will be made to ensure that the individuals’ driving license is clean and valid.
4.8.3 If a Young Person is not collected
In the event of a parent/carer failing to collect their child after a match or training session, the following procedures must be followed:
- Under no circumstances must a child be allowed off-site or left unsupervised.
- All possible attempts must be made to contact the parent/ carer using the Emergency Contact Numbers.
- If contact cannot be made with the parent/carer or approved emergency contact, the coach must contact the Police Safeguarding Unit or Children’s Services for advice.
- The coach must record the telephone contact made including the name and position of the person contacted.
- Continue to try to contact the parent/ carer and emergency contacts.
- Continue to seek advice from the Police/ Social Services.
- Keep senior Salford City Football Club staff informed of the situation (including the “Designated Person” or Designated Safeguarding Officer).
- Prepare a full written report for the Designated Person for Safeguarding.
- Should it be necessary to transport the boy home (with the permission of the parent/ carer), it is preferable for two members of staff to accompany the boy. The boy must sit in the rear seat of the vehicle.
4.8.4 If a Young Person/Vulnerable Adult is reluctant, or refuses to be collected
If a Young Person/Vulnerable Adult speaks in confidence to a coach or member of staff stating that they do not want to return home at the end of a session or Salford City Football Club fixture, the coach or staff member must remember that their first duty is to ensure the young person’s safety.
In the presence of a second member of staff, they must encourage the Young Person/Vulnerable Adult to give reasons why they not wish to return home.
If the reasons given suggest that the young person is being abused, coaches must inform Children’s Services or the Police Safeguarding
If the Young Person/Vulnerable Adult has been involved in an argument at home, staff must use their considered judgement as to whether the student would be at risk by returning home.
This involves responsible and serious decisions being made. Should coaches have any doubts, they should immediately contact the Academy Manager or the Designated Safeguarding Officer for advice. Alternatively Children’s Services or the Police Safeguarding Unit may be contacted.
If, however, the reluctance to return home appears to relate to ‘naughtiness’, petty quarrels at home, or trivial matters that do not put the young person at risk, the parents should be contacted to resolve the matter.
5. Safeguarding responsibilities of the senior management team
The Senior Management Team fully recognises its responsibilities with regard to safeguarding. It will ensure that this Safeguarding Policy is annually reviewed, updated and shared with staff.
6. Working with partners
Where services or activities are provided separately by another body, either on or off Salford City Football Club property/site, Salford City Football Club will seek assurance that the body concerned has appropriate policies and procedures in place for safeguarding children and child protection and there are arrangements to liaise with Salford City Football Club in these matters where appropriate.
The Board of Trustees for Salford City Football Club are ultimately responsible for ensuring that there is effective safeguarding within the organisation. The Chair of the Board of Trustees is responsible for the effective implementation of this policy. All trustees and staff have a responsibility to ensure that safeguarding and consideration of risk is a part of everything they do.
Last Updated: 20/09/2019