Safeguarding Policy

Programme safeguarding lead

For any programme where the DSL is the lead facilitator, the Deputy DSL acts as programme safeguarding lead for that programme. Disclosures and concerns arising in that programme are reported to and managed by the programme safeguarding lead, keeping the management of concerns separate from the delivery role. The named programme safeguarding lead is recorded on the programme safeguarding sheet (see Section 6).

1. Policy statement

Photo 51 CIC is committed to the safety, welfare and wellbeing of all children and young people who participate in our programmes. We recognise that the welfare of children is paramount and takes precedence over all other considerations, including the interests of the organisation, its partners and its staff.

This policy applies to all staff, volunteers, freelancers, sessional workers and partners working on behalf of Photo 51 CIC. It applies across all settings: in person, online, on partner premises, and in any other context where we interact with young people.

2. Definitions

A child or young person is anyone under the age of 18. Safeguarding means protecting children from abuse and neglect, preventing harm to their health or development, and ensuring they grow up in circumstances consistent with safe and effective care.

Categories of abuse include:

• Physical abuse: hitting, shaking, burning, or otherwise causing physical harm.
• Emotional abuse: persistent emotional maltreatment causing severe and lasting effects on a child’s development.
• Sexual abuse: forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. This includes non-contact activities such as involving children in looking at sexual images or grooming a child in preparation for abuse.
• Neglect: persistent failure to meet a child’s basic physical and psychological needs.

Extra-familial harm (risk outside the home). Photo 51 CIC recognises that children and young people can be at risk of harm outside their families, including child sexual exploitation (CSE), child criminal exploitation (CCE) including county lines, grooming (in person and online), serious youth violence, and harmful sexual behaviour between peers. Much of our delivery is designed around these risks, and all staff and volunteers are expected to understand and remain alert to them. We apply a contextual safeguarding approach: understanding and responding to the risks young people face in the spaces where they spend their time, including online.

3. Our responsibilities

• Prioritise the welfare of children and young people at all times
• Be familiar with this policy and follow its procedures
• Maintain appropriate professional boundaries with young people at all times
• Report any concerns, disclosures or allegations immediately to the Designated Safeguarding Lead
• Never investigate concerns themselves or promise confidentiality to a young person who discloses abuse
• Record any concerns or disclosures accurately and promptly
• Never work alone with a group of young people: all group delivery is staffed by a minimum of two workers

4. Safer recruitment

• Enhanced DBS check (with children’s barred list check where the role qualifies) before commencing work with young people
• Two references obtained and verified
• Signed agreement to this Safeguarding Policy
• Induction including safeguarding procedures before first delivery

These requirements apply equally to sessional and freelance workers engaged for specific programmes.

5. Responding to a disclosure

• Listen carefully and stay calm. Do not show shock or disbelief.
• Do not promise confidentiality. Explain that you may need to share what they tell you to keep them safe.
• Do not ask leading questions or investigate. Only ask open questions if needed to clarify.
• Reassure the young person that they are doing the right thing by telling you.
• Report to the Designated Safeguarding Lead as soon as possible, the same day.
• Write a factual record of what was said, using the young person’s own words. Record the time, date, location and those present.
• Do not share information with anyone other than the DSL unless the DSL is unavailable and the young person is in immediate danger.

6. Reporting concerns

Concerns must be reported to the Designated Safeguarding Lead immediately. If the DSL is unavailable, report to the Deputy DSL. If a young person is at immediate risk, contact the police on 999 or the local authority children’s social care emergency team directly, and inform the DSL as soon as possible afterwards.

Before each programme begins, the DSL prepares a programme safeguarding sheet recording: the named programme safeguarding lead, the children’s social care and out of hours contact details for the borough of delivery, the host organisation’s named safeguarding contact, and the agreed escalation route. The sheet is circulated to all workers on that programme before the first session and kept with the programme records.

National contacts:

• NSPCC Helpline: 0808 800 5000
• Police: 999 (emergency) or 101 (non-emergency)

7. Allegations against staff or volunteers

Any allegation or concern about the conduct of a Photo 51 CIC staff member, volunteer, freelancer or partner in relation to a child must be reported to the DSL immediately. Where the allegation concerns the DSL, it must be reported to the Deputy DSL. Allegations will be referred to the Local Authority Designated Officer (LADO) for the borough in which the concern arose within one working day, and Photo 51 CIC will cooperate fully with any resulting process. No internal investigation will be conducted ahead of LADO advice.

8. Working on partner premises

Much of our delivery takes place on premises operated by schools, local authorities and partner organisations. Before delivery begins at any partner venue, Photo 51 CIC agrees with the host: a named safeguarding contact, the escalation route between our DSL and theirs, and an information sharing protocol. Photo 51 CIC staff follow the host organisation’s safeguarding procedures alongside this policy. Where the two differ, the procedure offering the child the greater protection applies, and the concern is escalated through both routes.

9. Online safety

Staff and volunteers must not communicate with young people via personal social media accounts or personal messaging. All communications must be through official Photo 51 CIC channels. Sessions conducted online must follow the same safeguarding principles as in-person delivery, including two-worker staffing.

10. Photography, film and images

As a creative media organisation, Photo 51 CIC films and photographs participants only with explicit written consent (parental or guardian consent for under 18s), obtained at the start of each programme and specific to the intended use. Consent may be withdrawn at any time. Images and footage are stored securely, used only for the purpose consented to, and never in a way that could identify a young person as connected to a sensitive programme or subject matter. Filming never takes place in programmes where the subject matter makes it inappropriate.

11. Confidentiality and records

Information shared by or about a young person in a safeguarding context will only be shared with those who need to know. All safeguarding records are kept securely, separately from general programme records, and retained in line with our Privacy Notice and UK GDPR obligations. Safeguarding records are retained for a minimum of seven years.

12. Training

All staff and volunteers receive safeguarding induction before working with young people. The Designated Safeguarding Lead and Deputy DSL undertake formal safeguarding training appropriate to the role, refreshed at least every two years. All staff receive refresher training at least every two years. Training records are held by the DSL.

13. Policy review

This policy is reviewed annually by the Photo 51 CIC partners, or immediately following any safeguarding incident or relevant change in statutory guidance. Changes are communicated to all staff and volunteers.