Book Club Bunch Safeguarding and Child Protection Policy and Procedures

Table of Contents
Key Contacts ———————————————–3
Book Club Bunch ——————————————3
National Contacts —————————————– 3
Policy Statements and Principles ———————-3
Key Points ————————————————— 3
Introduction ————————————————-  4
Safeguarding Statement ———————————-4
Core Safeguarding Principles —————————-4
Terminology ————————————————- 4
Contextual Safeguarding ———————————- 4
Safeguarding in BCB —————————————- 5
Policy Aims —————————————————- 5
Confidentiality ———————————————— 5
Safeguarding and Key Legislation ———————–5
Child Protection Procedures ——————————6
Recognising Abuse ——————————————-6
Indicators of Abuse ——————————————7
Peer-on-Peer Abuse ——————————————8
Sexual Violence and Harassment between Children 9
Serious Violence ———————————————– 9
Bullying ———————————————————- 9
If concerned about a child’s welfare ——————— 10
If a child makes a disclosure ——————————– 10
Notifying the child’s parents ——————————– 10
Referral to Police and Children’s Servises ————— 10
Criminal Exploitation of Children (CCE) —————— 11
Sexual Exploitation of Children (CSE) ——————— 11
County Lines —————————————————- 12
Youth Produced Sexual Imagery (Sexting) ————— 12
Looked After Children —————————————– 12
Confidentiality and Sharing Information —————— 12
Prevent Duty, Honour Based Violence and Forced Marriage – 13
Signs of Vulnerability —————————————— 13
Recognising Extremism —————————————- 14
‘Honour Based’ Abuse —————————————– 14
Forced Marriage ————————————————- 14
Roles and Responsibilities ———————————————– 15
Professional Expectations ————————————- 15
Designated Safeguarding Lead ——————————- 15
Deputy Designated Safeguarding Lead ——————— 15
All Staff ————————————————————- 15
Good Practice Guidelines and Staff Code of Conduct — 15
Whistleblowing and Complaints Procedure ————— 16
Concerns or Allegations Relating to Staff —————— 16
Staff Training —————————————————— 19
Safer Recruitment ———————————————— 20
Photography and Images ————————————— 20
Appendix 1: Safeguarding During the Covid-19 Measures ——– 20

Key Contacts
Book Club Bunch
Designated Safeguarding Lead (DSL) Matthew Carter, Creative Director
07982789028 (Mobile) (Email)

Deputy Designated Safeguarding Lead (DDSL) Melissa Haggist, Founding Director
07456489469 (Mobile) (Email)

Deputy Designated Safeguarding Lead (DDSL) Alex White, Senior Reader
07903094417 (Mobile) (Email)

National Contacts
Crimestoppers 0800 555 111
NSPCC Weston House, 42 Curtain Road, EC2A 3NH
0808 800 5000
NSPCC Whistleblowing Helpline (for staff) 0800 028 0285
Childline 0800 1111
Kidscape Bullying Helpline 020 7730 3300
Samaritans 0845 790 9090
Children’s Commissioner Anne Longfield
0800 528 0731
Shelter (Homelessness) 08088004444

Policy Statement and Principles
– This policy applies to all children engaged with Book Club Bunch.
– All members of staff have a responsibility for the implementation of this policy.
– Any concerns regarding child protection and/or safeguarding must be reported immediately to the Designated Safeguarding Lead (DSL) or in their absence to the Deputy Designated Safeguarding Leads (DDSLs). The Creative Director (Matthew Carter) is the DSL. The Founding Director (Melissa Haggist) and Senior Reader (Alex White) are DDSLs.
– All staff should be alert to identifying children who may benefit from early help.
– If, at any point, a child is in immediate danger or is at risk of harm, a referral should be made to Children’s Services and/or the police immediately.
– If a crime has been committed, it should be reported to the police.
– All staff must have read, understood, and then act in accordance with Part One and Annex A of Keeping Children Safe in Education (DfE, September 2020) – often abbreviated as KCSIE.
– All staff must know who the trained DSL and DDSLs are.
– All concerns of a safeguarding or child protection nature must be treated in the utmost confidence.
– The DSL or DDSL must report all concerns in line with local authority thresholds to Children’s Services.
– Allegations of abuse in relation to adults must be dealt with in line with the associated policy.
– When working in schools, Book Club Bunch’s Safeguarding and Child Protection Policies act as subordinate and supplementary to the school specific policy; where a safeguarding concern has arisen within a school, Book Club Bunch is to work with the school unless circumstances prevent this.

Book Club Bunch recognizes that it has a duty to ensure that safeguarding permeates all its clubs and activities, and expects all members of staff, volunteers and other third parties to share its commitment to safeguarding and promoting the welfare of children. This policy therefore complements and supports other policies including Code of Conduct, Whistleblowing and Complaints Policy, and Safer Recruitment practice. When the organisation undertakes development or planning of any kind, it will give careful consideration to safeguarding aspects.

Safeguarding Statement
Book Club Bunch believes that everyone has a responsibility to promote the welfare of all children and young people, to keep them safe, and to practise in a way that protects them. Book Club Bunch will give equal priority to keeping all children and young people safe regardless of their age, disability, gender reassignment, race, religion or belief, sex, sexual orientation or economic background. Book Club Bunch recognizes that additional needs may arise from children of minority ethnic groups, lower-economic backgrounds, and disabled children, and that there may be additional barriers such as communication or the impact of discrimination which they may have faced.

Book Club Bunch endeavours to provide a safe and welcoming environment where children are respected and valued. Members of staff should be alert to the signs of abuse and neglect, and follow procedures to ensure that children receive effective support, protection, and justice.

Book Club Bunch’s Core Safeguarding Principles
– Book Club Bunch has a responsibility to safeguard and promote children’s welfare.
– It is everyone’s responsibility to safeguard children. Everyone who comes into contact with children and their families has a role to play in keeping children safe.
– The welfare of the child is paramount.
– Children and staff involved in child protection issues will receive appropriate support.
– Safer children make more successful learners.

Safeguarding and promoting the welfare of children refers to the process of protecting children from maltreatment, preventing the impairment of health or development, ensuring that children grow up in circumstances consistent with the provision of safe and effective care, and taking action to enable all children to have the best outcomes.
Child Protection refers to the processes undertaken to protect children who have been identified as suffering or being at risk of suffering significant harm.
Book Club Bunch refers to the organisation and all staff employed in its name.
Contextual Safeguarding
In order to help prevent and tackle peer-on-peer abuse, Book Club Bunch understands the value of Contextual Safeguarding. Contextual Safeguarding is an approach to understanding, and responding to, children’s experiences of significant harm beyond their families. It recognises that the different relationships that children form in their neighbourhoods, schools and online can feature violence and abuse. Parents and carers sometimes have little influence over these contexts, and children’s experiences of extra-familial abuse can undermine parent-child relationships. Therefore, safeguarding practitioners need to engage with individuals and sectors who do have influence over/within extra-familial contexts, and recognise that assessment of, and intervention with, these spaces are a critical part of safeguarding practices. Contextual Safeguarding, therefore, expands the objectives of child protection systems in recognition that children are vulnerable to abuse in a range of social contexts.
Child includes everyone under the age of 18. However, Book Club Bunch’s duty to promote welfare and health and safety applies to all the boys in its care whether they are under or over the age of 18.
Parent refers to birth parents and other adults who are in a parenting role, for example stepparents, guardians, foster carers and adoptive parents.
Safeguarding in Book Club Bunch
This includes, but is not limited to:
– Ensuring children’s health and safety.
– Referring concerns or allegations about a child to the Local Authority promptly.
– Preventing bullying.
– Preventing all forms of abuse.
– Preventing harassment and discrimination.
– An awareness of the link between mental health and safeguarding.
Policy Aims
– To provide all members of staff with the necessary information to enable the to meet their child protection responsibilities.
– To ensure consistent good practice.
– To demonstrate Book Club Bunch’s commitment with regard to child protection to children, parents and other partners.
Book Club Bunch recognizes that all matters relating to child protection are sensitive and confidential. The DSL or the DDSLs will share that information on a ‘need to know, what and when’ basis. Concerns about individuals should never be discussed elsewhere, inside or outside Book Club Bunch clubs or meetings, unless in confidential meetings for that purpose.
Members of staff are expected to manage the requirement to maintain an appropriate level of confidentiality whilst at the same time liaising with relevant professionals such as the DSL and Children’s Services. Members of staff should never promise a child that they will not tell anyone about an allegation, as this may not ultimately be in the best interests of the child.
– Keeping Children Safe in Education (DfE, September 2020) is statutory guidance issued under Section 175 of the Education Act 2002. The guidance is applicable to all schools in England and Wales. Schools and colleges must have regard to it when carrying out their duties to safeguard and promote the welfare of children. This means they should comply with it unless exceptional circumstances arise. The document contains information on what schools and colleges should do and sets out the legal duties with which schools and colleges must comply in order to keep children safe. It should be read alongside Working Together to Safeguard Children (DfE, July 2018) and department advice What to do if you are worried a child is being abused – Advice for Practitioners (DfE, March 2015). Unless otherwise stated, ‘school’ in this guidance means all schools, whether maintained, non-maintained or independent, including academies and free schools, alternative provision academies and pupil referral units.
Although Book Club Bunch is not a school, the organisation’s safeguarding policies and procedures are informed by and in fulfilment of these key legislation and guidance, where applicable. This is particularly applicable when working with and in schools.
All members of staff are required to have signed a document to confirm that they have read and understood Part One and Annex A of Keeping Children Safe in Education (DfE, September 2020)
– The statutory guidance Working Together to Safeguard Children (DfE, July 2018) covers the legislative requirements and expectations on individual services to safeguard and promote the welfare of children. The guidance applies to all local authorities, clinical commissioning groups and police, as well as all other organisations and agencies. It applies, in its entirety, to all schools. It applies to children up to the age of 18 years whether living with their families, in state care, or living independently.
– What to do if you are worried a child is being abused – Advice for Practitioners (DfE, March 2015) provides more information on understanding and identifying abuse and neglect. Examples of potential signs of abuse and neglect are highlighted throughout the advice. The NSPCC website also provides useful additional information on types of abuse and what to look for.
– The Prevent Duty: from 1 July 2015 all schools became subject to a duty under Section 26 of the Counter-Terrorism and Security Act 2015, in the exercise of their functions, to have ‘due regard to the need to prevent people from being drawn into terrorism’. Book Club Bunch recognises that ‘safeguarding vulnerable people from radicalisation is no different from safeguarding them from other forms of harm’.
– Guidance for the safer working practice for those working with children and young people in education settings (Safer Recruitment Consortium, October 2015), whilst not safeguarding guidance, provides advice for all staff working with children regarding illegal, unsafe, unprofessional or unwise behaviour and advises staff to monitor their own standards and practice.
– Sexual violence and sexual harassment between children in schools and colleges (DfE, May 2018) covers what sexual violence and harassment is, schools’ and colleges’ legal responsibilities, a whole school approach to safeguarding and child protection, and how to respond to reports of sexual violence and sexual harassment.
– Criminal Exploitation of Children and Vulnerable Adults. This guidance outlines what county lines (and associated criminal exploitation) is, signs to look for in potential victims, and what to do about it. The document is a supplement to existing safeguarding policies, to help identify and protect those exploited through this criminal activity.
– Information Sharing: Advice for Practitioners Providing Safeguarding Services to Children, Young People, Parents and Carers. This advice is for practitioners and senior managers. It helps them decide when and how to share personal information legally and professionally. It might also be helpful for practitioners working with adults who are responsible for children who may be in need.

All members of staff have a responsibility to identify the symptoms and triggers of abuse and neglect, to share information and work together to provide children and young people with the help they need. Members of staff are advised to maintain an attitude of ‘it could happen here’ where safeguarding is concerned. When concerned about the welfare of a child, staff members should always act in the best interests of the child.
Book Club Bunch will act on identified concerns and provide early help to prevent concerns from escalating. If a child is in immediate danger or is at risk of harm, a referral should be made to children’s social care and/or the police immediately.
To ensure that the children are protected from harm, it is important to understand what types of behaviour constitute abuse and neglect.
All members of staff should be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases, multiple issues will overlap with one another.
Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (eg via the internet). An adult, or adults, or another child or children may have abused them.
There are four categories of abuse: physical abuse, emotional abuse, sexual abuse and neglect. The definitions are taken from Keeping Children Safe in Education (DfE, September 2020)
Physical Abuse
Physical abuse is any form of threatened or actual violence, which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child (this used to be called Munchausen’s Syndrome by Proxy but is now more usually referred to as fabricated or induced illness).
Emotional Abuse
Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s psychological state and emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber-bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.
Sexual Abuse
Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of children by other children is a specific safeguarding issue in education.
Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy because of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. This form of abuse may also include neglect of, or unresponsiveness to, a child’s basic emotional needs..
Indicators of Abuse
It is the responsibility of all members of staff to report any and all niggling worries or concerns over safeguarding and welfare. It is not their responsibility to investigate or decide whether a child has been abused. A child who is being abused or neglected may:
– have bruises, bleeding, burns, fractures or other injuries;
– show signs of pain or discomfort;
– keep arms and legs covered, even in warm weather;
– look unkempt and uncared for;
– change their eating habits;
– have difficulty in making or sustaining friendships;
– appear fearful;
– be reckless with regard to their own or other’s safety;
– self-harm;
– showing other signs of deterioration in mental health;
– show signs of not wanting to go home;
– display a change in behaviour – from quiet to aggressive, or happy-go-lucky to withdrawn;
– challenge authority;
– become disinterested in their schoolwork;
– be constantly tired or preoccupied;
– be wary of physical contact;
– be involved in, or particularly knowledgeable about drugs or alcohol; or
– display sexual knowledge or behaviour beyond that normally expected for their age;
– be showing signs of being drawn into anti-social or criminal behaviour including gang involvement and association with organised criminal groups.
Individual indicators will rarely, in isolation, provide conclusive evidence of abuse. They should be viewed as part of a jigsaw, and each small piece of information will help the DSL to decide how to proceed. It is therefore essential that members of staff report their concerns. Staff do not need ‘absolute proof’ that a child is at risk but should act on any hunches or worries in the knowledge that they will be supported in their safeguarding role. Reports made in good faith will always be dealt with in accordance with Book Club Bunch’s Whistleblowing policy, regardless of outcome.
All members of staff should have awareness of safeguarding issues in the broad. In particular, they should know that behaviours linked to drug-taking, alcohol abuse, deliberately missing education and sexting (also known as youth-produced sexual imagery) put children in danger.
Peer-on-Peer Abuse
All members of staff should be alert to the risk of peer-on-peer abuse and understand their role in preventing, identifying and responding to it.
It is important that members of staff recognise the gendered nature of peer-on-peer abuse but that all such abuse is unacceptable and will be taken seriously. It should never be tolerated or passed off as ‘banter’, ‘just having a laugh’ or ‘part of growing up’.
Peer-on-peer abuse may take different forms, such as:
– sexual violence and sexual harassment;
– upskirting (referred to in the Voyeurism (Offenses) Act 2019 and relevant to any gender);
– physical abuse (such as hitting, kicking, shaking, biting, hair pulling or otherwise causing physical harm);
– sexting (also known as youth produced sexual imagery); or
– initiation type violence and rituals.
Members of staff will first consult with the DSL and/or DDSLs, and alert parents. Members of staff will refer to such abuse to an external agency where there is a risk of significant harm.

Sexual Violence and Sexual Harassment Between Children
Book Club Bunch adheres to DfE Sexual violence and sexual harassment between children in schools and colleges (DfE, May 2018), and it recognises the following:
– That members of staff need to choose terminology carefully (for example, the sue of ‘victim’ and ‘perpetrator’), on a case by case basis;
– That a child abusing another child may have been abused themselves and may therefore need support too;
– That sexual violence and sexual harassment can be driven by wider societal factors such as everyday sexist stereotypes and everyday sexist language;
– That all members of staff, and particularly the DSL, need to adopt a contextual safeguarding approach to incidents, which involves considering the context within which incidents or behaviours occur;
– That assessments of children need to consider wider environmental factors present in a child’s life that are a threat to their safety or welfare;
– The importance of information sharing and effective multi-agency working, especially where children involved in allegations of sexual violence or sexual harassment attended two or more different schools or colleges;
There are four likely routes to consider when managing a report of sexual violence or sexual harassment:
– Managing internally; in some cases of sexual harassment (such as one-off incidents) Book Club Bunch may manage the incident internally, via liaising with parents or the relevant school;
– Early help; this is particularly useful in addressing non-violent, harmful sexual behaviours and may prevent escalation;
– Referrals to Children’s Services: in cases where there has been harm, or there is an immediate risk, a referral should be made to Children’s Services;
– Reporting to Police; in cases where rape, assault by penetration or sexual assault is reported, the DSL will work closely with the Police to ensure that Book Club Bunch’s actions do not jeopardise the police investigation.
The management of children and young people with sexually harmful behaviour is complex and Book Club Bunch will follow DfE guidance when issued. Book Club Bunch will work with other relevant agencies to maintain the safety of its community. Young people who display such behaviour may be victims of abuse themselves and the child protection procedures will be followed for both victim and perpetrator. Members of staff, who become concerned about a boy’s sexual behaviour, should speak to the DSL as soon as possible.
Serious Violence
Staff should be aware of the indicators, which may signal that children are at risk from, or are involved with serious violent crime. KCSIE 2020 sets out what is required in relation to this in paragraphs 31 and 32. These may include: increased absence from school, a change in friendships or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, or signs of assault or unexplained injuries. Unexplained gifts or new possessions could also indicate that children have been approached by, or are involved with, individuals associated with criminal networks or gangs.
Staff need to be able to identify the signs and indicators of these and share their concerns immediately with the DSL.
While bullying between children is not a separate category of abuse and neglect, it is a very serious issue that can cause considerable anxiety and distress. At its most serious level, bullying can have a disastrous effect on a child’s wellbeing and has even featured in the suicide of some young people. Members of staff will be aware of harm caused by bullying, and engage either with parents or via the school to remedy. However, there will be occasions when a child’s behaviour warrants a response under child protection rather than counter-bullying procedures.
If concerned about a child’s welfare
All members of staff should be able to distinguish between a safeguarding concern about a child and a child who is in immediate danger or at significant risk of harm. There will be occasions when a member of staff may suspect that a child may be at risk but have no ‘real’ evidence. The child’s behaviour may have changed, their actions may reveal confusion or distress, or physical but inconclusive signs may have been noticed. In these circumstances, the member of staff must try to give the child an opportunity to talk. The signs they have noticed may be due to a variety of factors. It is fine for a member of staff to ask the child if they are okay, or if they can help in any way.
Members of staff should report their concerns to the child’s parents or relevant school staff member. If the child starts to reveal that they are being (or have been) harmed, members of staff should follow the advice below. Following an initial conversation with the child, if the member of staff remains concerned, they should discuss their concerns with the DSL.
If a child makes a disclosure
It takes courage for a child to disclose that they have been or are being abused. They may feel ashamed, particularly if the abuse is sexual. The abuser may have made threats about what will happen if they tells. The child may have lost trust in adults; or they may believe, or have been told, that the abuse is their own fault.
During such conversations with the child, members of staff will:
– Allow the child to speak freely;
– Remain calm and avoid overreaction;
– Offer reassurance and general words of comfort (rather than physical touch);
– Not be afraid of pauses or silences;
– Not ask investigative or leading questions;
– Explain at an appropriate time that, in order to help, the information must be passed on to relevant people in positions of responsibility;
– Not reprimand the child for failing to disclose earlier;
– Establish next steps, but let the child know that someone will come to see them as soon as possible;
– Report verbally to the DSL and/or DDSL, even if the child has promised to do it themselves;
– Write up the conversation as soon as possible as a record of concern and hand it to the DSL; and
– Seek support, if distressed.
Notifying Parents
Book Club Bunch will normally seek to discuss any concerns about a child with their parents, if appropriate. This must be handled sensitively. Book Club Bunch will make contact with parents in the event of a concern, suspicion or disclosure. If the disclosure occurred in a school club however, this will be handled through the relevant school authority, rather than independently. However, if Book Club Bunch believes that notifying parents could increase the risk to the child or exacerbate the problem, advice will first be sought from the relevant children’s service or the police.
If a child is in immediate danger, Book Club Bunch will contact the police and Children’s Services immediately.
Book Club Bunch may contact statutory agencies to seek advice about concerns before making a referral.
The DSL will make a referral to Children’s Services, 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 boy or issues of confidentiality pertain. First response will be by telephone to the relevant Children’s Services and then followed with written confirmation on the appropriate Inter-Agency Referral Form within 24 hours.
Where subsequently the child’s situation does not appear to improve, staff will press for re-consideration by Children’s Services. Concerns should always lead to help for the child at some point.
Staff should challenge any inaction and follow this up with the DSL and Children’s Services, as appropriate. All concerns, discussions and decisions made and the reasons for those decisions should be recorded in writing. Staff should understand that they can refer a child directly to Children’s Services, especially where they are concerned that a child is suffering or likely to suffer significant harm. Indeed, there is a duty on all staff to persist with referrals to Children’s Services, if they feel that appropriate action is not being taken.
Book Club Bunch will contribute to any assessment as required, providing information about the boy and his family. The DSL or DDSLs will attend any strategy discussion or child protection conference, and work together to safeguard any child from harm in the future.
Book Club Bunch understands that there are no absolute criteria on which to rely when judging what constitutes ‘significant harm’. Harm is defined as ill treatment or impairment of health and development which may include impairment suffered from seeing or hearing the ill treatment of another.
Criminal Exploitation of Children
Child Criminal Exploitation (CCE) is where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into any criminal activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial or other advantage of the perpetrator or facilitator and/or (c) through violence or the threat of violence. The victim may have been criminally exploited even if the activity appears consensual. CCE does not always involve physical contact; it can also occur through the use of technology.
CCE can include children being forced to work in cannabis factories, being coerced into moving drugs or money across the country, forced to shoplift or pickpocket, or to threaten other young people.
Some of the following can be indicators of CCE:
– Children who appear with unexplained gifts or new possessions;
– Children who associate with other young people involved in exploitation;
– Children who suffer from changes in emotional well-being;
– Children who misuse drugs or alcohol;
– Children who go missing for periods of time;
– Children who regularly miss school or education, or do not take part in education
Sexual Exploitation of Children
Child sexual exploitation (CSE) is a form of sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage of increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. CSE does not always involve physical contact. It can also occur with technology.

A significant number of children who are victims of exploitation go missing from home, care and education at some point. Some of the following signs may be indicators:
– Children who appear with unexplained gifts or new possessions;
– Children who associate with other young people involved in exploitation;
– Children who have older girlfriends or boyfriend;
– Children who suffer from sexually transmitted infections or become pregnant;
– Children who suffer from changes in emotional well-being;
– Children who misuse drugs or alcohol;
– Children who go missing for periods of time;
– Children who regularly miss school or education, or do not take part in education
CSE 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. All members of staff are made aware of the indicators of sexual exploitation in their safeguarding training and any concerns should be reported immediately to the DSL.
County Lines
County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs (primarily crack cocaine and heroin) into one or more importing areas [within the UK], using dedicated mobile phone lines or another form of “deal line”. Exploitation is an integral part of the county lines offending model with children and vulnerable adults exploited to move [and store] drugs and money. Offenders will often use coercion, intimidation, violence (including sexual violence) and weapons to ensure compliance of victims. Children can be targeted and recruited into county lines in a number of locations including schools. Children are often recruited to move drugs and money between locations and are known to be exposed to techniques such as ‘plugging’, where drugs are concealed internally to avoid detection. Children can easily become trapped by this type of exploitation as county lines gangs create drug debts and can threaten serious violence and kidnap towards victims (and their families) if they attempt to leave the county lines network. One of the ways of identifying potential involvement in county lines is missing episodes (both from home and school), when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism should be considered. If a child is suspected to be at risk of or involved in county lines, a safeguarding referral should be considered alongside consideration of availability of local services/third sector providers who offer support to victims of county lines exploitation.
This refers to the creating and sharing of sexual imagery by young people. Any incident involving youth-produced sexual imagery should be reported to the DSL immediately who will follow the guidance set out in Sexting in schools and colleges: responding to incidents and safeguarding young people (UK Council for Child Internet Safety).
A looked after child is a child who is looked after by a local authority, subject to a care order or who is voluntarily accommodated by a local authority, commonly as a result of abuse or neglect. All staff should understand how to keep a looked after child safe, and should liaise either with the relevant school (should the child be part of a school club) or the local authority (should the child be part of a private club). The DSL and DDSL will ensure all relevant discussions occur before such an event occurs.
All staff will understand that child protection issues warrant a high level of confidentiality, not only to respect any children or staff involved but also to ensure that information released into the public domain does not compromise evidence.
Members of staff should only discuss concerns with the DSL or a DDSL. That person will then decide who else needs to have the information and they will disseminate it on a ‘need-to-know’ basis.
However, following a number of highly publicised cases where senior leaders in schools failed to act upon concerns raised by staff, Keeping Children Safe in Education (DfE, September 2020) emphasises that any member of staff can make a referral to a Children’s Services, if they are concerned about a child. If anyone other than the DSL makes the referral, they should inform the DSL, as soon as possible.
Child protection information will be stored and handled in line with the Data Protection Act 2018 principles. Information is processed for limited purposes; adequate, relevant and not excessive; accurate; kept no longer than necessary; processed in accordance with the data subject’s rights; and secure.
Child Protection Records and other written information will be stored in a locked facility and any electronic information will be password protected and only made available to relevant individuals.
Child protection records are normally exempt from the disclosure provisions of the Data Protection Act. This means that children and parents do not have an automatic right to see them. If any member of staff receives a request from a child or parent to see child protection records, they will refer the request to the DSL and/or DDSLs.
The Data Protection Act does not prevent staff from sharing information with relevant agencies, where that information may help to protect a child.
The Prevent Duty is the duty in the Counter-Terrorism and Security Act 2015 on specified authorities, in the exercise of their functions, to have due regard to the need to prevent people from being drawn into terrorism. The Department of Education advice for schools and childcare providers, June 2015, states that, ‘School staff should use their professional judgement in identifying children who might be at risk of radicalisation and act proportionately’.
Radicalisation refers to the process by which a person comes to support terrorism or forms of extremism. There is no single way of identifying an individual who is likely to be susceptible to a terrorist ideology. As with managing other safeguarding risks, staff should be alert to changes in children’s behaviour which could indicate that they may be in need of help or protection.
Members of Staff, who have concerns about a child, will make these concerns known to the DSL at the earliest opportunity. The DSL will then make a judgement as to whether or not it is appropriate to make a referral to the Channel programme.
Channel is a programme which focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism.
Signs of Vulnerability
There are no known definitive indicators that a young person is vulnerable to radicalisation, but there are a number of signs that together increase the risk. Signs of vulnerability include:
– Underachievement;
– Being in possession of extremist literature;
– Poverty
– Social Exclusion;
– Traumatic Events;
– Global or National events;
– Religious conversion;
– Change in behaviour;
– Extremist influences;
– Conflict with family over lifestyle;
– Confused identity;
– Victim or witness to race or hate crimes;
– Rejection by peers, family, social groups or faith.

Recognising Extremism
Early indicators of radicalisation or extremism may include:
– Showing sympathy for extremist causes;
– Glorifying violence, especially towards other faiths or cultures;
– Making remarks or comments about being at extremist events or rallies;
– Evidence of possessing illegal or extremist literature;
– Advocating messages similar to illegal organisations or other extremist groups;
– Out of character changes in dress, behaviour and peer relationships (but there are also very powerul narratives, programmes and networks that young people can come across online so involvement with particular groups may not be apparent);
– Secretive behaviour;
– Online searches or sharing extremist messages or social profiles;
– Intolerance of difference, including faith, culture, gender, race or sexuality;
– Graffiti, art work or writing that displays extremist themes;
– Attempts to impose extremist views or practices on others;
– Verbalising anti-Western or anti-British views;
– Advocating violence towards others.
Non-emergency advice is available via DfE’s helpline 020 7340 7264 and by email at
‘Honour Based’ Abuse
So-called ‘honour based’ abuse encompasses crimes which have been committed to protect and defend the honour of the family and/or the community. Honour based violence includes the physical act of Female Genital Mutilation (FGM). This is a form of child abuse and a method of violence against women and girls, and therefore should be dealt with as part of existing child safeguarding/protection structures, policies, and procedures. FGM is illegal in the UK. In England, Wales and Northern Ireland, the practice is illegal under the Female Genital Mutilation Act 2003.
Members of staff recognise the possibility that a pupil may disclose information relating to a sibling or close friend who has suffered abuse in the form of honour-based abuse, including FGM. Members of Staff are alert to the mandatory reporting requirement for suspected cases of FGM, which became a statutory duty from October 2015.
Forced Marriage
Another component to ‘honour-based’ abuse is forced marriage; forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of free and full consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some communities use religion and culture as a way to coerce a person into marriage. Schools and colleges can play an important role in safeguarding children from forced marriage. There are a range of potential indicators that a child may be at risk of forced marriage, details of which can be found on pages 13-14 of the Multi-Agency Guidelines: Handling cases of forced marriage 2014. Staff can also contact the Forced Marriage Unit, if they need advice or information: contact 020 7008 0151 or email

Everyone who encounters the children and their families of Book Club Bunch has a role to play in safeguarding. We are aware that we play a role within the wider safeguarding system for children. Together with the schools we work with, the police, health, and other children’s services, we promote the welfare of children and protect them.
The Designated Safeguarding Lead (DSL)
– Has a job description consistent with Annex B of Keeping Children Safe in Education (DfE, September 2020) and ensures all staff are aware of his role;
– Has the status and authority within Book Club Bunch to carry out the duties of the post, including committing recourses and supporting and directing other staff;
– Receives regular child protection training;
– Encourages a culture of listening to children and taking account of their wishes and feelings;
– Keeps detailed written records of all concerns, ensuring that such records are stored securely and flagged on, but kept separate from general files;
– Works closely with partner schools, and defers to the relevant authorities as and when needed;
– Ensures that all staff sign to indicate that they have read and understood Part One and Annex A of Keeping Children Safe in Education (DfE, September 2020) and this Child Protection and Safeguarding policy, and that mechanisms are in place to assist staff to understand and discharge their responsibilities thereunder;
– Ensures that the Safeguarding Policy is annually reviewed by the Founding Director, Creative Director and Senior Reader;
– Ensures that a record of staff attendance at child protection training is kept;
– Makes the Safeguarding Policy available publicly, on Book Club Bunch’s website or by other means;
– Ensures parents/partner schools are aware of Book Club Bunch’s role in safeguarding and that referrals about suspected abuse and neglect may be made;
– That at least the DSL or one of the DDSLs is available at all times;
The Deputy Designated Safeguarding Lead (DDSLs)
– The DDSLs are appropriately trained in Safeguarding regularly. In the absence of the DSL, they carry out the duties of the post.
– In the event of the long-term absence of the DSL, the DDSLs will assume all o the functions as for the DSL above.
All Staff
– Will have been DBS checked, and be suitably qualified for their position;
– Will have confirmed that they have read and understood Part One and Annex A of Keeping Children Safe in Education (DfE, September 2020) and this Child Protection and Safeguarding policy;
– Will abide by Book Club Bunch’s Code of Conduct, and expected practices;
– Will be aware of Book Club Bunch’s Whistleblowing and Complaints Policy.
Book Club Bunch has a code of conduct containing expected levels of professionalism and good practices which it expects all staff to have read and abide by. This ensures that members of staff meet and maintain their responsibilities towards children.

Book Club Bunch’s complaints procedure will be followed where a child or a parent raises a concern about poor practice or professionalism which does not initially reach the threshold for child protection action. The Founding Director and/or Creative Director manage such complaints. See the organisation’s ‘Whistleblowing and Complaints Policy and Procedure’ document for details.
Relevant guidance can be found in:
– Working Together to Safeguard Children (DfE, July 2018)
– Keeping Children Safe in Education (DfE, September 2020)
– What to do if you’re worried a child is being abused (DfE, March 2015)
1. Reporting Concerns
It is essential that any concern or allegation of abuse made against a member of Book Club Bunch staff, or any staff of partner organisations, is dealt with quickly, and in a fair and consistent way that provides effective protection for the child(ren) and at the same time supports the individual who is the subject of the allegation.
All staff should know how to recognise and report concerns or allegations and should understand what to do if they have such concerns personally or hear an expression of such concerns or allegations against colleagues.
On hearing an allegation or concern about abuse directly from a child, a member of staff should limit questioning to the minimum necessary for clarification. Leading questions should be avoided, and inappropriate guarantees of confidentiality should not be given. Rather, the child should be told the matter will be referred in confidence to the appropriate people in positions of responsibility. An accurate written record should be made for this purpose.
All allegations, concerns or niggling worries about members of staff must be reported without delay to the DSL and/or DDSLs.
All allegations against the DSL must be reported immediately to the DDSLs without informing the DSL.
All allegations against the DDSL must be reported immediately to the DSL without informing the DDSL.
All allegations made against the DSL and DDSL must be reported immediately either to the relevant school’s DSL/DDSL (if in a school environment), or the NSPCC.
It is vital that expressions of concern that do not necessarily amount to ‘allegations’ are reported, particularly if there are repeated reports of such concerns and/or questionable conduct. It may be that the concern expressed has been raised by another party. If there are repeated reports of such concerns and/or questionable conduct, a pattern of unacceptable behaviour may be identified.
This procedure will be used in all cases in which there is an allegation or suspicion that a person working with or who is in contact with child has:
– Behaved in a way that has harmed a child, or may have harmed a child;
– Possibly committed a criminal offence against or related to a child; or
– Behaved towards a child or children in a way that indicates they would pose a risk of harm if they worked closely with children.
These criteria should be considered in the context of the four categories of abuse (ie. Physical, sexual, and emotional abuse, and neglect, as described in the document above). These include concerns relating to inappropriate relationships between members of staff and children.
2. Checklist of Immediate Reporting Actions
Procedure for Individual Members of Staff
– Write a dated and timed note of what has been disclosed or noticed, said or done.
– Report immediately the information to the DSL and DDSLs.
– Pass on the written record.
– If the suspicion or allegation of abuse is against the DSL, the information must be taken to the DDSLs only. If the suspicion or allegation of abuse is against one of the DDSLs, the information must be taken to the DSL (and other DDSL, if applicable) only.
Procedure for the DSL and DDSLs
– If there is no written record, write a dated and timed note of what has been disclose or noticed, said or done.
– Notify the Safeguarding team and LADO (Local Authority Designated Officer) on the same day.
– The DSL may ask to clarify details or circumstances of the allegation, but this must not amount to an investigation.
– Copies of the documents concerning the allegation must be sent to the LADO on the same day.
– On-going involvement in cases; liaison with the LADO (and school if applicable) and co-operation with the investigating agencies as appropriate; consideration of employment issues and possible disciplinary action where the investigating agencies take no further action.
3. How allegations will be managed
Initial Action
Decisions about course of action would be taken on a case by case basis, bearing in mind the paramount importance of the safety of any child(ren) involved but also remembering that the member of staff, against whom an allegation has been made, has the right to remain anonymous and to expect any allegations to be investigated as expeditiously as possible. Any course of action would be subject to a risk assessment. Decisions would also follow the guidance of the LADO and/or police.
Upon receiving an allegation or concern about a staff member, the case manager (whether the DSL, the DDSL, the school representative or a local authority representative) will immediately discuss the allegation with the LADO. The purpose of an initial discussion is for the LADO and the case manager to consider the nature, content and context of the allegation and agree a course of action. In the process of this liaison, the case manager and LADO will:
– Share what information is available, both from the source of the allegation and also from Personnel files;
– Identify what other information might be needed;
– Consider whether the alleged perpetrator should continue working or remain in contact with children;
– Consider whether suspension is appropriate advice to Book Club Bunch on this aspect;
– Decide what information and/or advice is to be given to the DSL (or DDSL/nominated case manager), including whether the member of staff should be informed of the allegation at this stage;
– Decide what action is needed, and who needs to be involved and informed (including the DBS)
Strategy Meeting
If the parties involved in these discussions consider it necessary, a Strategy Meeting is arranged, usually by Social Services, which will involve representatives from the LADO, the police and Book Club Bunch.
From the above discussions, there are three possible courses of action:
– It may be the subject of a police and/or joint police and Social Services investigation and possible action through the courts; or
– It may be the subject of a disciplinary investigation; or
– The matter may be remitted to the School to be dealt with.
The following definitions will be used when determining the outcome of allegation investigations:
– Substantiated: there is sufficient evidence to prove the allegation;
– Malicious: there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive;
– False: there is sufficient evidence to disprove the allegation;
– Unsubstantiated: there is insufficient evidence to either prove or disprove the allegation; the term, therefore, does not imply guilt or innocence;
– Unfounded: to reflect cases where there is no evidence or proper basis which supports the allegation being made.
If Social Services and the police decide to take action, Book Club Bunch will still need to consider what further investigation is necessary. If there is a case to answer, a disciplinary hearing will be called, which could lead to dismissal.
Case Subject to Police Investigation
Where a criminal investigation has taken place and either (i) a trial has resulted, (ii) the investigation has been closed without charge or (iii) a decision has been taken not to prosecute a case after charge, the case manager will discuss with the LADO what, if any, further action is required as regards the member of staff concerned and the sharing of information obtained by the agencies involved in assisting any further action to be taken by Book Club Bunch.
Disciplinary Investigation
Wherever possible the person will be given a full opportunity to answer the allegation and make representations about it. The process of investigating the allegation, and reaching a judgment about whether it is substantiated, will continue even if the person does not cooperate.
Suspension is never a default option and the Book Club Bunch will consider all other options before suspending a member of staff. Book Club Bunch would only suspend someone, if there were no reasonable alternative.
Allegations against Pupils
A child, against whom an allegation of a child protection nature has been made, will primarily be dealt with via either the relevant school authority, or with parents. They may be asked to not return to Book Club Bunch.
Peer-on-peer abuse will be referred to an external agency where there is a risk of significant harm. Allegations of peer-on-peer abuse will be referred to Children’s Services.
Book Club Bunch will follow advice on the investigation of such allegations and will take appropriate action to ensure the safety and welfare of all pupils involved, including the child/(ren) accused of abuse.
If it is necessary for a child to be interviewed by the Police or other authorities in relation to allegations of abuse, Book Club Bunch will ensure that, subject to advice from external agencies, parents are informed as soon as possible, and that the child is supported during the interview by an appropriate adult.
4. Action upon Conclusion of a Case
Book Club Bunch will refer to the DBS (following consultation with the LADO) any person who has been removed from working (paid or unpaid) in regulated activity, or would or might have been so removed had he/she not resigned or left of his/her own accord, and it believes the person may have harmed, attempted to harm, incited another to harm or put a child at risk of harm or if there is reason to believe the person may have committed one of a number of offences listed under the Safeguarding Vulnerable Groups Act (Prescribed Criteria and Miscellaneous Provisions) Regulations 2009.
In cases where it is decided on the conclusion of the case that a person who has been suspended can return to work, Book Club Bunch will consider how best to facilitate this. Book Club Bunch appreciates that most people would benefit from some help and support when returning to work after a very stressful experience. Depending on the individual’s circumstances, a phased return and/or the provision of a mentor to provide assistance and support in the short term may be appropriate. Book Club Bunch will also consider how the person’s contact with the child/(ren) who made the allegation can best be managed if they are still attending Book Club Bunch.
If an allegation is determined to be false, the case manager may refer the matter to Children’s Services to determine whether the child concerned is in need of services or may have been abused by someone else.
In the event that an allegation is shown to have been deliberately invented or malicious, Book Club Bunch will consider whether any disciplinary action is appropriate against the boy who made it. This will be done in liaison with parents and/or the relevant school.
Abuse of Trust
All members of staff should be aware that the Sexual Offences Act 2003 makes it an offence for a person over 18 to have a sexual relationship with a child under 18 where the person is in a position of trust, even if the relationship is consensual.
5. Records
A central record of all allegations and concerns (and connected documents) against members of staff will be kept securely by the DSL, separate from normal staff and child records, and with access limited to officers who may be key workers for cases. The DSL and DDSLs will always be kept informed of safeguarding and child protection matters and will have access to all records.
The record of allegations may provide clarification in cases where a future DBS disclosure reveals information from the police about an allegation that did not result in a criminal conviction. It will also help to prevent unnecessary re-investigation if, as occasionally happens, an allegation re-surfaces after a period. The record will be retained at least until the member of staff involved has reached normal retirement age, or for a period of 10 years from the date of the allegation if that is longer.
An allegation which was proven to be false, unsubstantiated or malicious will not be included in references for staff.
Every effort will be made to maintain confidentiality and to guard against publicity while an allegation is being investigated or considered. Apart from keeping the child/(ren), parent(s)/guardian(s) and the person about whom the allegation has been made (in cases when this would not place the child at further risk) up to date with progress of the case, information should be restricted to those who have a need to know in order to protect children, facilitate enquiries or manage related disciplinary processes.
Monitoring and Evaluation
This policy will be reviewed regularly by the DSL and revised if necessary. It will be shared with staff and made available on the Book Club Bunch’s website.
All members of Book Club Bunch staff will receive appropriate training in safeguarding and child protection, which is regularly updated.
All members of staff will be required to have read and understood Part One and Annex A of Keeping Children Safe in Education (DfE, September 2020), and Book Club Bunch’s Safeguarding Policy and Procedures Document, and have signed in acknowledgement.
All members will receive annual safeguarding booster meetings with the DSL and DDSLs, either online or in person, which will cover, consolidate and explain the salient points in these documents. These meetings will contain an element of a quiz.
The DSLs and DDSLs will receive Advanced Level Safeguarding and Child Protection training, to be updated regularly.
Book Club Bunch endeavours to ensure that it does its utmost to employ ‘safe’ staff by following the guidance in Keeping Children Safe in Education (DfE, September 2020). This includes mandatory DBS certificates and checks, two references, proof of the necessary qualifications, and a training period. Details can be found via contacting the Founding Director and enquiring about the Safer Recruitment Practices.
The vast majority of people who take or view photographs or videos of children do so for entirely innocent, understandable and acceptable reasons. Sadly, some people abuse children through taking or using images, so we must ensure that we have safeguards in place.
To protect the children who are part of Book Club Bunch, we seek written parental consent for photography, and accept that parents reserve the right to revoke their consent at any time.
This annex to our Safeguarding Policy sets out details of the arrangement for the period that COVID-19 measures are in place.
Due to the nature of Book Club Bunch’s operations and organisational practices, safeguarding policies and procedures remain fundamentally the same and are largely unaltered by the new contexts.
Particular attention is to be paid to the expected practises and measures put in place for online clubs, as found in the Code of Conduct document. This is due to the increase in online clubs.
Staff are expected to comply with any and all health and safety measures put in place either by the schools they’re operating in, or the government. All staff conducting clubs in schools will evidence a negative rapid response test before arriving on school premises. Should staff exhibit any of the symptoms of COVID-19, they should alert the Founding Director immediately and comply with current government guidelines. To not do so would be to place the children in their clubs at risk of exposure or contraction of the virus. Care is to be taken to ensure masks are worn where necessary, and hands are thoroughly cleaned regularly, to avoid the spread of the virus. This is particularly important when working in schools, where there is higher risk of transmission. Staff wherever possible are to ensure they maintain a safe distance from children, as per current government guidelines.
Negative experiences and distressing life events, such as the current circumstances, can affect the mental health of pupils and their parents. Staff will be aware of this in setting expectations of pupils’ work where they are at home, and are to contact the DSL or the DDSL if they have any concerns.
Staff reserve the right to challenge or refuse work, if they are uncomfortable with undertaking it as a result of COVID-19. The Founding Director will work hard to ensure all work is undertaken safely and comfortably.
The Creative Director, Matthew Carter (Designated Safeguarding Lead),
September 2020