Safeguarding Policy

SAFEGUARDING CHILDREN POLICY INTRODUCTION

WO Sports acknowledges and accepts it has a responsibility for the wellbeing and safety of all Children and young people who are under the Company’s care or utilising the Company’s facilities. It is the duty of all adults working at the Company to safeguard the welfare of Children and young people by creating an environment that protects then from harm.

The wellbeing of Children and young people is paramount for all staff and accordingly, they must make themselves aware of the Company’s Safeguarding Children Policy. Where appropriate, the following guidelines will be supplemented by in-service training and additional guidance.

RULES & REGULATIONS

WO Sports is governed by the rules and regulations set out in the 1989 and 2004 Children Act, Working Together to Safeguard Children (2015), the London Child Protection Procedures (4th edition), FA Safeguarding Children Rules and Premier League and Football League Rules and guidance.

WO Sports is fully committed to ensuring that the best practice recommended by these bodies is employed throughout the Company.

The Company also has a responsibility to maintain regular dialogue with the Local Safeguarding Children Board.

DEFINITIONS

A “Child” (collectively referred to as “Children”) is defined as anyone under the age of 18. An “Activity” means any activity or series of activities arranged for a Child or Children by or in the name of a Club. These are deemed to be regulated and therefore activate the required levels of Criminal Record Check that are associated.

AIMS & KEY PRINCIPLES

The aims of WO Sports Safeguarding Children Policy are:

  • To safeguard all Children and young people who interact with WO
  • To demonstrate best practice in the area of safeguarding children.
  • To positively reflect and promote the WO Sports Values (Confident Custodians, Open & Inclusive and Service Excellence) in regard to safeguarding children.
  • To develop a positive and pro-active welfare programme to enable all Children and young people to participate in an enjoyable and safe environment.
  • To encourage parents and other members of the Child or young person’s family to be involved in a relationship with WO Sports.
  • To ensure that coaches, parents and other adults who come in contact with Children and young people provide good role models of behaviour.
  • To promote high ethical standards throughout the Company.

The key principles underpinning this policy are:

  • The Child’s welfare is, and must always be, the paramount
  • All Children and young people have a right to be protected from abuse regardless of their age, gender, disability, culture, language, racial origin, religious beliefs or sexual identity.
  • All allegations of abuse or poor practice will be taken seriously and responded to efficiently and proportionately.

Safeguarding Officer (SO)

The Company has a Safeguarding Officer(SO) who has overall responsibility for the safeguarding of Children at the WO Sports and a number of Designated persons who work within various areas of the business. These Officers have special responsibilities and are the focal point for safeguarding Children in their nominated area.

The SO undertakes regular monitoring and risk assessments of all Activities involving Children and holding formal minuted meetings with departmental Safeguarding Officers on a bi-monthly basis.

Anybody with a concern about a Child or young person’s welfare should contact the Safeguarding Officer for advice in the first instance – details can be found at the end of this policy.

HUMAN RESOURCES & DISCLOSURE

Recruitment

As part of WO Sports recruitment and selection process, offers of work for positions which involve working with Children are subject to a satisfactory Disclosure & Barring Service (DBS) Criminal Records Check (CRC) at the level deemed suitable for the position offered and subject to appropriate references.

Staff Training & Awareness

A Staff Briefing Note giving guidance to WO Sports employees and casual workers who come into contact with Children is provided at induction. The SO holds a specific Safeguarding & Safer Working Practice Induction with all new fixed-term, permanent starters and volunteers during which the Staff Briefing Note and key elements of the Company’s Safeguarding Children Policy are discussed in more detail and specifically to the individuals’ role.

All staff working in direct contact with Children are required to complete the FA’s 3 hour Safeguarding Children Awareness workshop and undertake a refresher course, as advised by the FA, at least once every 3 years. Details of those satisfactorily completing this course are retained by the Human Resources Department.

A continual programme of Safeguarding Awareness courses are also provided by the Club to develop knowledge which are department specific.

Work Experience

WO Sports may from time to time offer work experience placements to young people. The Club has a central work experience scheme which provides forwardly planned and structured work experience placements. Whilst undertaking work for the Company , those on work experience will not have unsupervised access to Children.

For those undertaking work experience who are under the age of 18, more detailed guidelines can be found in the policy regarding the employment / engagement of workers under the age of 18.

DISCLOSURE & BARRING SERVICE

WO Sports is an affiliate of The Media Group and the DBS to carry out CRCs on individuals who work for the Company using other registered subsidiaries. Enhanced CRCs, plus barred list check where appropriate, enable the Club to undertake more thorough recruitment and selection procedures for positions which involve working with Children.

PROCESS FOR CRIMINAL RECORDS CHECKS

New Appointments

All staff who are offered a position which involves working with Children will be required to complete a Self Declaration Form and also undertake an Enhanced CRC with a barred list check where appropriate. All offers of work are subject to the outcome of the screening process and where applicable, this is set out in the initial job advertisement and the applicant’s offer of work. Until such time as a satisfactory CRC has been received, the member of staff will not be permitted to work with Children.

WO Sports is committed to providing equal opportunities to staff and therefore a positive CRC will not necessarily result in a bar from work.

Should a positive CRC be received, a risk assessment will be carried out by the Safeguarding Officer, relevant Head of Department, the HR Manager or CEO (or his designate) and, where applicable the department Safeguarding Officer, to assess the information contained within the CRC. The member of staff may also be asked to attend an interview prior to a recruitment decision being made. The rehabilitation of offenders act and protection of freedoms Act should be considered in all cases before a final decision is made.

New Appointments who already have a CRC

If a new member of staff has been subject to a CRC check by their previous employer the WO Sports will still require a further check.

Temporary Staff and External Consultants

The Company will ensure that all temporary staff and external consultants sign a Self Declaration Form where appropriate and, in any case, will not have unsupervised access to Children during their time with the Company.

Equal Opportunities

WO Sports is committed to providing equal opportunities for all staff. A copy of the Company’s policy on equal opportunities can be obtained from the Human Resources department.

Disqualification by Association

WO Sports works in accordance to guidance set out by The Childcare (Disqualification) Regulations 2009 (“the 2009 Regulations”) are made under section 75 of the Childcare Act 2006 (“the 2006 Act”) and set out the circumstances in which an individual will be disqualified for the purposes of section 75 of the Act. Disqualification by Association dictates that WO Sports as an employer would be unable to offer employment to those living in the same household where another person who is disqualified lives or is employed (disqualification ‘by association’) as specified in regulation 9 of the 2009 Regulations. Also failure to disclose this information can result in employment being withdrawn or terminated.

Annex:DBS Recruitment Policy and Procedure Employing/Engaging Workers Under 18    Staff Briefing Note

Equal Opportunities Policy

RATIOS & SUPERVISION OF CHILDREN

Any Activity undertaken by the WO Sports will always give full consideration to the appropriate number of staff members available depending on the age of the Children involved, the degree of risk the Activity involves and whether there are any additional disability needs. The lower the age of the participants, the greater the need for supervision.

Regardless of these ratios a minimum of 2 members of staff or delivery partner will always be available to supervise an Activity. This ensures at least basic cover in the event of something impacting on the availability of one of the adults during the Activity (e.g. in the event of a participant requiring the attention of an adult during the Activity following an accident).

  • For Children under 5 the recommended ratio should be no more than 1:6.
  • For Children under 8 the recommended ratio should be no more than 1:8.
  • For Children over 8 the recommend ratio should be no more than 1:10, but this varies depending on the Advice should be sought from the Children’s Services’ Officer if unsure.
  • For Elite Players Activities, the Premier League’s Youth Development Rules prescribe a ratio of 1 Coach to 8 Players (over 8s).
  • Where the WO Sports is taking responsibility for the care of the Children, parents/carers should not be included in supervision

These ratios are partially based on Ofsted’s guidelines which are as follows: Child’s ageAmount of adultsAmount of Children

0 – 2 1 3

2 – 3 1 4

4 – 8 1 6

9 – 12 1 8

13 – 18 1 10

GIFTS & FAVOURITISM

Staff should take care that they do not accept any gift that might be construed as a bribe by others, or lead the giver to expect preferential treatment.

The WO Sports recognises that there are occasions when Children or parents wish to pass small tokens of appreciation to staff, for example at Christmas or as a “thank you”, and this is acceptable. However, it is unacceptable to receive gifts on a regular basis or of any significant value as this may be misinterpreted by others. Staff should report any gifts received to their line manager and they should be dealt with in accordance with the WO Sports Ethics in Business Policy.

Similarly, it is not permitted for staff to give personal gifts to Children. This could be misinterpreted as a gesture either to bribe, or to single out the Child. It might also be perceived that a “favour” of some kind is expected in return.

Any reward given to a Child must first be agreed with the staff member’s line manager as part of a structured reward system in line with the departmental policy and not based on favouritism.

It should be noted that these guidelines are in addition to employees’ obligations under the WO Sports Ethics in Business Policy.

Annex: WO Sports Ethics in Business Policy USE OF IMAGES

The WO Sports takes its guidance on the use of images from guidelines issued by the FA and Premier League. All images are taken by WO Sports Staff who have been briefed by other

member of staff (and where possible Safeguarding Officer) responsible for the activity being photographed / filmed.

  • Before taking images of Children, parental consent is sought in writing at the start of football training or prior to the Parents/Legal Guardians are responsible for informing the WO Sports of any change of circumstances within the season which may affect consent.
  • Parents/Legal Guardians will be informed of how the image will be The WO Sports will not allow an image to be used for something other than that for which it was initially agreed.
  • All Children featured in WO Sports publications will be appropriately
  • Where possible, the image will focus on the activity taking place and not a specific
  • Where appropriate, images represent the broad range of people participating safely in the
  • Designated photographers will, where applicable, undertake a CRC and attend a Safeguarding Children workshop and in any case will be personally responsible for keeping up to date with the latest guidelines on the Use of Images policies issued by the WO Sports and by the Premier League from time to WO Sports Identification will be worn at all times.
  • Children who are subject to family, care or legal proceedings, or who are under a court order will not have their images published in any WO Sports
  • No images of Children featured in WO Sports publications will be accompanied by personal details such as their school or home
  • Recordings of Children for the purposes of legitimate coaching aids are only filmed by WO Sports officials and are stored safely and .
  • Any instances of inappropriate images in football should be reported to the WO Sports Publications Editor or Safeguarding Officer
  • The WO Sports does not put young player profiles with images and personal information on its

Annex: WO Sports Use of Images Policy and Guidance

COMMUNITY ACTIVITY – “THE WO sports”

The FA Charter Standard

Although the WO sports ensures full compliance with the FA Charter Standard, it endeavours to adhere to the rules and guidelines issued by the Premier League with regard to safeguarding Children.

Fit For Purpose Policy

All WO Sports activities are governed by a Fit for Purpose Policy which covers the following:

  • DBS detail
  • Coaching qualifications
  • Adult : Child Ratios
  • Risk Assessment
  • Registration & Dispersal Procedures
  • Accident / Incident Report Forms
  • Coach Guidelines & Code of Conduct
  • Late Collection Procedures
  • First Aid

This Policy is written in consultation with the WO Sports staff, Safeguarding Officer and is under constant review.

Parental Consent

The WO sports will obtain parental consent for all activities using the Parental Consent Form. The WO sports will do everything it can to safeguard Children and young people in its care but recognise that in some circumstances, due to the nature of the work carried out, obtaining parental consent for specific activities is not always possible.

Annex: WO sports Fit for Purpose Policy

Criminal Records Checks

In accordance with the procedures detailed above, all WO Sports staff undergo an Enhanced CRC every 3 years. Content will be risk assessed by the safeguarding Manager, provision manager and HR. Completed in line with the process detailed in the DBS recruitment policy and procedure

Risk Assessments

The WO sports undertakes a Risk Assessment for each Activity they operate. These Risk Assessments are undertaken on a bi-annual basis and are completed in consultation with the WO Sports Chief Executive Officer and, where necessary, the Safeguarding Officer.

Activities for Disabled Persons & Adults at Risk

The WO Sports carries out all activities for disabled persons and adults at risk under the guidelines of the Disability Discrimination Act and Safeguarding Vulnerable Groups Act, and in accordance with the WO Sports Disability Policy and Safeguarding Adults at Risk Policy.

GUIDELINES IN THE EVENT OF CONCERN

Highlighting Concern

Although the WO Sports is committed to doing the utmost to safeguard Children from harm there may be occasions when concern is raised over the treatment of a Child.

“Child abuse” and “neglect” are generic terms encompassing all ill treatment of Children as well as cases where the standard of care does not adequately support the Child’s health or development. Children may be abused or suffer neglect through the infliction of harm, or through the failure to act to prevent harm. Abuse can occur in a family or an institutional or community setting. The perpetrator may or may not be known to the Child and may be of the same or opposite sex. There is often a common misconception that only a certain type

of person can abuse Children but this is simply not the case – abuse can take place in any setting, by someone of either sex, of any sexual orientation and of any age.

Recognition – Signs of Abuse

There are five main forms of abuse identified as follows, should you have any concern that abuse is occurring you should contact the SM or a Safeguarding Officer immediately.

Physical Abuse: Physical abuse 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. A person might do this because they enjoy or need the attention they get through having a sick Child. Physical abuse can be caused through omission or the failure to act to protect.

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 (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other Children.

Neglect: 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 as a result 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. It may also include neglect of, or unresponsiveness to, a Child’s basic emotional needs.

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 emotional development. It may involve conveying to Children 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 the 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 cyberbullying), 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, though it may occur alone.

Bullying: Bullying is not always easy to define and can take many forms. The three main types are: physical, verbal and emotional.

WO Sports has a zero-tolerance approach to bullying and any reported incidents of bullying by a staff member to a Child, Child to staff member or Child to Child will be taken seriously and investigated by a Safeguarding Officer and, where necessary, the Club’s Children’s Services’ Officer. The Elite centre has a separate Anti-Bulling policy which is issued to parents, players and coaches.

All staff members who undergo the FA’s 3 hour Safeguarding Children Workshop receive bullying awareness training as part of the workshop as well as attending a Safer Working Practice workshop facilitated by the Safeguarding Manager.

For more detailed information on the five main forms of abuse, reference should be made to the Football Association’s Safeguarding Children Policy and Procedures, which can be found on www.thefa.com.

Concerns around Radicalisation & Extremism

The Counter-Terrorism and Security Act, which received Royal Assent on 12 February 2015, places a duty on specified authorities, including local authorities and childcare, education and other children’s services providers including Sport, in the exercise of their functions, to have due regard to the need to prevent people from being drawn into terrorism (“the Prevent duty”). This guidance will be updated further to reflect the implications of the Prevent duty, which is expected to come into force later in 2015.

The Counter-Terrorism and Security Act 2015 will also place a duty on local authorities to ensure Channel panels are in place. The panel must include the local authority and chief officer of the local police. Panels will assess the extent to which identified individuals are vulnerable to being drawn into terrorism, following a referral from the police and where considered appropriate and necessary consent is obtained, arrange for support to be provided to those individuals. The Act will require partners of Channel panels to co-operate with the panel in the carrying out of its functions and with the police in undertaking the initial assessment as to whether a referral is appropriate. Schools and colleges which are required to have regard to Keeping Children Safe in Education are listed in the Act as partners of the panel. The relevant provisions of the Act will come into force on 12 April 2015 but many local authorities already have Channel panels set up in their area.

Government guidance: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/439598/p revent-duty-departmental-advice-v6.pdf

Annex: WO Sports Anti-Bullying Policy RESPONDING TO A REPORT OR SUSPICION

A Safeguarding Officer or the Designated person should be contacted as early as possible and within 24 hours in any circumstance, however it is recognised that an individual may

need to respond to a situation immediately. With this in mind the following guidelines offer help and support in responding to abuse or a suspicion of abuse or poor practice:

Do:

  • Ensure the child or young persons safety
  • Treat any allegations extremely seriously and act at all times towards the Child as if you believe what they are saying, although do not directly say the words “I believe you”.
  • Tell the Child they are right to tell
  • Reassure the Child that they are not to
  • Be honest about your own position, who you have to tell and
  • Tell the Child what you are doing and when and keep them up to date with what is
  • Take further action – you may be the only person in a position to prevent future
  • Write down everything said and what was done (handwritten is preferable) and sign and date the An Incident Report Form should be used where possible and, in any case, a referral must be made to the WO Sports within 24 hours of the incident taking place.
  • Seek medical advice if

Don’t:

  • Make promises you cannot keep or to keep
  • Interrogate the Child – it is not your job to carry out an investigation – this will be up to the Police and Children’s Services, who have experience in
  • Cast doubt on what the Child has told you, don’t interrupt or change the
  • Say anything that makes the Child feel responsible for the
  • Inform parents / carers – the SO/DP will make this decision based on whether there is suspicion of their

DOING NOTHING IS NOT AN OPTION; IT IS YOUR RESPONSIBILITY TO ACT.

Make sure you tell a Safeguarding Officer immediately, they will know how to follow this up and where to go for further advice.

Annex: Procedures for Responding to a Report or Suspicion Incident Report Form

RECORDING ALLEGATIONS OR SUSPICIONS

The Safeguarding Officer will immediately report any allegation to the SM, who will ask for a written factual statement from the person making the report. If an Incident Report Form has been completed a copy should be provided to the SM.

Any statement made by the Child should be reported in their own words. These reports should be confined to facts. Any opinion, interpretation or judgement should be clearly stated as this, keeping any questions to a minimum and they should be of an open format. No suggestion of who the perpetrator was or how any concern or incident happened should be suggested.

WO Sports will ensure that any Child concerned is immediately removed from any possible risk of harm.

Investigations into possible abuse will require careful management. In these cases the SO will first seek the advice of the Premier League, the Football Association Safeguarding Children Team, Children’s Social Care, a Local Authority Designated Officer (LADO) or the Police before setting up an internal inquiry and take their advice on informing the Child’s parents. In any case of suspected abuse, as soon as the Local Authority or the Police have been informed, the Company must provide a report to the FA Head of Safeguarding Children, the Premier League Head of Safeguarding Children and inform the Company’s Chief Executive Officer. Any external local authority provision will naturally take the lead on any case.

Providing it is appropriate to do so the SO will maintain constant dialogue with all parties involved with the allegation until such time as the matter has reached a reasonable outcome, taking the lead from the external agency. Escalation to inform board level will take place at the Safeguarding Officer earliest opportunity.

Specific information regarding allegations against members of WO Sports Staff

If the report involves an allegation about any member of WO Sports staff (whether full time, part time, paid, unpaid, contracted, engaged, voluntary etc) and the Company believes that the report could demonstrate that the member of staff in question 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 he or she is unsuitable to work with children.

th SO shall immediately inform the LADO of the Borough where the alleged incident took place so that he or she can consult with the Police and local authority children’s social care colleagues as appropriate. Where the SO are unsure as to whether the report meets the criteria stated above, the advice of the LADO shall still be sought.

The member of staff in question may be asked to write a brief report, as may any other person that is deemed to have an involvement in the allegation. This process would only be carried out once the advice of the above mentioned external bodies had been sought and only then in consultation with the SO.

Providing it does not contradict with any advice received from the LADO, any internal investigation will be carried out in line with the Company’s People Management Policy and either general or department-specific Grievance Procedures, insofar as they are applicable.

Confidentiality

There is always tension and caution around issues of confidentiality. The advice for all staff at WO Sports is that no guarantee of confidentiality can be given to a Child (although this does not necessarily mean that the parents / carers have to be told).

A Child should never be pressured to give information or show physical marks unless they do so willingly. If they chose to show markings, two members of staff should be present and any marks raising concern should be recorded on the skin map included within the incident and report form.

There are actions which staff have to and are obliged to take once we are aware of a problem. Undertakings of confidentiality should not be given either to the person making the allegations or to the person being interviewed. A matter is confidential on a need to know basis and nobody should have any reservations about referring any issue to the any Safeguarding Officer. The key issue is that the welfare of the Child is protected.

Safeguarding Manager & Safeguarding Officer

EXTERNAL CONTACT DETAILS

FA Premier LeagueThe Football Association Jess AddicottSue Law

Head of SafeguardingHead of Safeguarding Children

E: safeguarding@premierleague.com E: sue.law@thefa.com T: 0207 864 9000 T/F: 020 7745 4649/5649

THE FA / NSPCC HELPLINE: 0808 800 5000 / Textphone: 0800 056 0566 NSPCC SMS: 88858

EXTERNAL RESOURCES

FA Safeguarding Children Guidelines: http://www.thefa.com/TheFA/WhatWeDo/FootballSafe/Downloads

London Child Protection Procedures (4th Edition April 2011): http://www.londonscb.gov.uk/procedures/london_child_protection_procedures_chapters/

Information Sharing Guidance for Managers and Practitioners: http://www.education.gov.uk/publications/standard/publicationdetail/page1/DCSF-00807- 2008

Working Together to Safeguard Children 2015: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/419595/

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