1. Purpose 

The purpose of this policy is to ensure that Life Lumina Hub (LLH) fulfills its moral and legal obligations to protect children from harm. 

Children and young people are at the heart of our mission, and their welfare is our primary concern. This policy provides a clear framework for all staff, volunteers, and trustees to ensure we operate in a way that prevents abuse and responds effectively when concerns arise. 

Definition of a child/young person: A child is anyone who has not yet reached their eighteenth birthday or in the case of a disabled young person or one with learning difficulties under twenty five. ‘Children’ therefore means children and young people throughout. 

2. Aim 

The overarching aim of this policy is to create a “culture of vigilance” where safety is integrated into everything we do. Specifically, we aim to: 

• Protect: Provide a safe environment for all children who interact with our services, ensuring they are protected from physical, emotional, sexual abuse, and neglect. 
• Empower: Ensure that children know they have a right to feel safe and understand how they can seek help if they are worried.
• Educate: Equip our staff and volunteers with the training and confidence to identify risks, recognize signs of harm, and follow reporting procedures without hesitation. 
• Respond: Establish clear, robust procedures for taking action and sharing information appropriately with statutory agencies (such as Social Care or the Police) when a child is at risk. 
• Prevent: Implement safer recruitment practices to ensure that only suitable individuals are permitted to work or volunteer with the children in our care. 

3. Statutory Framework 

This policy is based on the foundation of both domestic and international law. LLH operates in accordance with the following legislation and guidance: 

Primary Legislation 

• The Children Act 1989: Established the principle that the welfare of the child is “paramount” and set out the duties of local authorities to protect children. 
• The Children Act 2004: Strengthened the 1989 Act and introduced the requirement for agencies to work together to safeguard and promote the welfare of children. 
• The United Nations Convention on the Rights of the Child (UNCRC): An international treaty that grants every child the right to protection from all forms of physical or mental violence, injury, or abuse. 
• The Safeguarding Vulnerable Groups Act 2006: Set up the Disclosure and Barring Service (DBS) and defines “regulated activity.” 
• The Data Protection Act 2018 & UK GDPR: Provides the framework for sharing information legally when there is a safeguarding concern. 

Key Government Guidance 

• Working Together to Safeguard Children (Current Edition): The statutory guidance that outlines how organizations and individuals should work together to safeguard children. 
• Keeping Children Safe in Education (KCSiE): While primarily for schools, the principles of this guidance are considered best practice for all organizations working with children.
• The Charity Commission Guidance: Specifically “Safeguarding and protecting people for charities and trustees,” which outlines the duties of charity trustees to take all reasonable steps to protect beneficiaries. 

Legal Principles 

In alignment with the laws above, this policy adheres to the following principles: ● The Welfare Principle: The child’s welfare is always the primary consideration. ● No Delay: Safeguarding actions must be taken promptly to minimize risk. 

• Partnership: We work collaboratively with parents, carers, and statutory agencies (Social Care and Police) to achieve the best outcomes for children. 

4. Safeguarding Leadership: The DSL and Deputy 

To ensure the safety of children at LLH, we appoint a Designated Safeguarding Lead (DSL) and a Deputy Designated Safeguarding Lead (DDSL). Together, they oversee all safeguarding concerns and ensure the charity meets its legal obligations. 

Core Responsibilities 

While the DSL takes primary lead, both the DSL and Deputy are trained to: 1. Managing Referrals and Advice 

• Acts as the main point of contact for staff, volunteers, and external agencies regarding safeguarding concerns. 
• Decides whether a concern meets the threshold to be referred to Children’s Social Care or the Police. 
• Provides immediate advice and support to staff members who have received a disclosure or witnessed a concerning incident. 

2. Record Keeping 

• Maintains a secure, confidential, and centralized system for all safeguarding records. 
• Ensures that records include the date, time, and context of concerns, and that they are kept separate from general staff or volunteer files. 
• Regularly reviews records to identify patterns or “low-level” concerns that may escalate over time.

3. Training and Culture 

• Ensures that all staff and volunteers receive appropriate safeguarding training at induction and regular updates thereafter. 
• Promotes a culture of “it could happen here,” encouraging staff to remain vigilant and feel confident in reporting concerns. 
• Keeps their own knowledge up to date by attending advanced DSL training every two years. 

4. Working with Others 

• Liaises with the Local Authority Safeguarding Partnership and follows their specific local procedures. 
• Represents the charity at multi-agency meetings, such as Child Protection Conferences or Core Groups, where necessary. 
• Works closely with the Board of Trustees to provide regular, anonymized reports on the effectiveness of the charity’s safeguarding measures. 

5. Qualities, Training and Authority 

• Availability: The DSL or the Deputy must be reachable at all times during the charity’s operating hours. 
• Authority: The DSL must have the appropriate status and authority within the charity to act on behalf of children, even if it involves challenging senior management decisions. 

The Deputy is fully trained to the same level as the DSL. Their specific role is to: 

• Ensure Continuous Coverage: Assume full responsibility whenever the DSL is unavailable due to leave, illness, or off-site work. 
• Provide Impartiality: Act as the lead contact if a safeguarding concern involves the DSL themselves. 
• Case Consultation: Provide a “second opinion” on complex cases to ensure robust decision-making. 

Important Note: The DSL or DDSL are not a private investigator. Their role is to gather enough information to make an informed referral to the authorities—not to prove that abuse has taken place.

6. Contact Information 

In any situation involving a child’s safety, contact one of the following immediately: 

Designated Safeguarding Lead (DSL): 

Name: Ms. TL Monteil Cheung 

Phone: 07428914365 

Email: info@lifeliminahub.org.uk 

Deputy Safeguarding Lead (DDSL) 

Name: Ms. MS Helen Chow 

Phone: 07743187747 

Email: info@lifeliminahub.org.uk 

5. Procedures for Handling Safeguarding Concerns 

All staff and volunteers must follow these four key stages when a concern is identified. Speed and accuracy are vital to ensuring the child’s safety. 

Stage 1: Recognition and Response 

If a child makes a disclosure (tells you they are being harmed) or you observe concerning signs: 

• Listen: Stay calm and listen carefully. Do not interrupt or “interview” the child. ● Reassure: Tell the child they have done the right thing by speaking up. 
• Be Honest: Do not promise “to keep it a secret.” Explain that you must tell someone who can help keep them safe. 
• Observe: Note any physical marks or behavioral changes, but do not ask the child to remove clothing or show you injuries. 

Stage 2: Immediate Reporting 

• Contact the DSL/Deputy: Immediately inform the Designated Safeguarding Lead (DSL) or the Deputy. This should happen as soon as the child is safe, ideally within the hour.
• External Contact: If the child is in immediate danger of further harm, call 999 first, then inform the DSL. 

Stage 3: Recording Information 

A written record must be completed (on the LLH Safeguarding Incident Form) within 24 hours. The report must include: 

• The Facts: Date, time, and location of the incident or disclosure. ● The “Voice of the Child”: Use the child’s exact words where possible ● Observations: Describe physical marks or behavior objectively 
• Signature: The report must be signed and dated by the person reporting the concern. 

Stage 4: Action and Referral 

Once the DSL/Deputy receives the report, they will take one of the following actions: 

1. Direct Referral: Contact Children’s Social Care or the Police if the “threshold of harm” is met. 
2. Early Help: Seek advice from local authorities to provide support to the family before a situation escalates. 
3. Monitor: Keep the report on a secure file and monitor the child closely if the concern does not yet meet the referral threshold. 
4. No Further Action: If the concern is found to be unfounded (though the report is still kept for audit purposes). 

Escalation (“Whistleblowing”) 

If a staff member has reported a concern to the DSL and feels it has not been taken seriously or handled correctly, they have a legal duty to escalate the concern. 

• Step 1: Discuss the concern with the Charity’s CEO or Chair of Trustees. 
• Step 2: If the concern remains, contact the Local Authority Designated Officer (LADO) or NSPCC Whistleblowing Advice Line. 

Key Contacts: 

Hertfordshire Children’s Social Care (MASH): 

• Concern/Referral Line: 0300 123 4043 (Hertfordshire County Council).
• Out of Hours (Emergencies): 0300 123 4043. 
• Online Portal: Use the Hertfordshire Council website to report concerns. Nottinghamshire Children’s Social Care (MASH): 
• Concern/Referral Line: 0300 500 80 90 (Nottinghamshire County Council). ● Out of Hours (Emergencies): 0300 456 4546. 
• Online Portal: Use the Nottinghamshire Council website to report concerns. Local Police (Non-Emergency): 101 

NSPCC Whistleblowing Line: 0800 028 0285 

Emergency Services: 999 (if a child is in immediate danger). 

6. When to be Concerned: Recognizing Abuse 

Safeguarding is not just about responding to a child telling you something is wrong; it is about being alert to the signs and indicators of harm. Abuse and neglect can happen to any child, regardless of their background. 

Staff and volunteers should be concerned if they notice changes in a child’s appearance, behavior, or development that fall into these four categories: 

1. Physical Abuse 

• Bruising: Unexplained bruises, or bruises in unusual places (e.g., tops of arms, thighs, or neck). 
• Injuries: Burns, bite marks, or fractures that do not match the explanation given. 
• Shrinking away: A child flinching when touched or appearing afraid of certain adults. 

2. Emotional Abuse 

• Extreme Behaviors: A child being unusually aggressive or, conversely, extremely withdrawn and “frozen.” 
• Developmental Delays: A sudden drop in speech or social skills. 
• Low Self-Esteem: Constant self-criticism or statements like “I’m bad” or “I’m a burden.”
• Over-compliance: Trying too hard to please adults to avoid conflict. 3. Sexual Abuse 
• Inappropriate Knowledge: Knowledge or behavior that is sexually explicit or beyond their developmental age. 
• Physical Symptoms: Pain, itching, or injury in the genital area. 
• Secretive Behavior: Sudden changes in friendships or becoming very secretive about online activities or “new adult friends.” 

4. Neglect 

• Poor Hygiene: Consistently dirty clothes, unwashed hair, or persistent body odor. 
• Hunger: Stealing or begging for food, or appearing consistently tired and weak. 
• Untreated Medical Needs: Persistent skin infections, untreated dental pain, or parents consistently missing medical appointments. 
• Lack of Supervision: A child being left alone or in the care of unsuitable people for long periods. 

Factors Increasing Vulnerability (The Trio of Risks) 

1. While abuse can happen in any circumstances, research shows that children are at a significantly higher risk of harm when one or more of the following “interstitial risks” are present in the home: 
2. Domestic Abuse: Children living in a home where there is violence or coercive control between adults are victims of emotional abuse and are at higher risk of physical harm. 
3. Parental Substance Misuse: Excessive use of drugs or alcohol can impair a parent’s ability to provide a safe, stable, and nurturing environment. 
4. Parental Mental Ill-Health: When left unsupported, severe mental health challenges can affect a parent’s capacity to respond to a child’s physical and emotional needs. 
5. Staff Responsibility: If you become aware that a child’s family is struggling with these issues, you must inform the DSL. This allows us to offer “Early Help” and support to the family before a safeguarding crisis occurs.

The “Golden Rule”: You do not need “proof” to be concerned. If a child’s behavior or appearance makes you feel uneasy, or if “something just doesn’t feel right,” you must report it to the DSL or Deputy immediately. 

7. Dealing with a Disclosure 

A disclosure occurs when a child tells a staff member or volunteer, either directly or indirectly, that they are being abused or are at risk of harm. If a child begins to disclose to you, follow the TED principle and the “4 Rs”. 

7.1 The 4 Rs of Disclosure 

1. Receive: Listen quietly and stay calm. Do not show shock, anger, or disbelief. 
2. Reassure: Tell the child they have done the right thing. Reassure them that it is not their fault. 
3. React: Do not promise “to keep it a secret.” Explain that you must tell the person whose job it is to keep children safe (the DSL). 
4. Record: Write down exactly what was said as soon as possible. 7.2 Do’s and Don’ts for Staff 

7.3 Using “TED” Questions 

To avoid leading a child or influencing their statement, staff should only use TED (Open-Ended) questions if clarification is needed:

• T – “Tell me more about that…” 
• E – “Explain that to me…” 
• D – “Describe what happened…” 

7.4 After the Disclosure 

Once the child has finished speaking: 

1. Ensure Safety: Make sure the child is in a safe place and supervised (but not by anyone implicated in the disclosure). 
2. Immediate Notification: Contact the DSL or Deputy immediately. Do not wait until the end of the day or the end of your shift. 
3. Self-Care: Dealing with a disclosure is emotionally exhausting. Once you have handed over the information and completed your report, speak to the DSL about support for your own well-being. 
4. Confidentiality and Information Sharing 

At LLH, we recognize the importance of respecting the privacy of children and their families. However, staff and volunteers must understand that confidentiality is never absolute when a child is at risk of harm. 

8.1 The “Golden Rule” 

Staff must never promise a child, a parent, or a colleague that they will “keep a secret” regarding a safeguarding concern. You must be honest and explain that you have a duty to share information with the Designated Safeguarding Lead (DSL) to ensure everyone stays safe. 

8.2 Sharing Information Internally 

• Need-to-Know Basis: Information regarding a safeguarding concern should only be shared with the DSL or Deputy. 
• Avoid “Staff Room Gossip”: Do not discuss concerns with other colleagues, volunteers, or friends. This protects the child’s privacy and prevents the “contamination” of evidence if a police investigation follows. 
• Trustee Oversight: The Board of Trustees should receive regular reports on safeguarding, but these must be anonymized unless it is absolutely essential for them to know the child’s identity.

8.3 Sharing Information Externally (GDPR and Data Protection) 

The Data Protection Act 2018 and UK GDPR are not barriers to sharing information when a child is at risk. You do not need the consent of a parent or carer to share information with the Police or Social Care if: 

• Seeking consent would place the child at increased risk of harm. ● It would interfere with a criminal investigation. 
• There is a legal requirement to report (e.g., a court order or a Section 47 enquiry). 

8.4 Secure Record Keeping 

• All safeguarding reports and notes must be kept in a secure, locked file or an encrypted digital folder. 
• These records must be kept separate from general child participation files or staff personnel files. 
• Access is restricted to the DSL and Deputy DSL only. 

Key Principle: The Data Protection Act 2018 states that the “public interest” in safeguarding a child overrides the “private interest” of data confidentiality. If you are acting in good faith to protect a child, you are legally protected. 

9. Record Keeping 

LLH maintains a rigorous approach to recording safeguarding concerns. Accurate records ensure that we can provide an evidence-based history of a child’s welfare and protect staff by documenting their actions. 

9.1 What Must Be Recorded 

Every concern, however small, must be documented. The record must include: 

• The Basics: Name of the child, date, time, and location of the incident/disclosure. 
• Context: What triggered the concern? (e.g., a specific activity, a comment made by the child, or a physical observation). 
• The Facts: An objective description of what was seen or heard. 
• The Voice of the Child: Use the child’s exact words in quotation marks. Do not “translate” their language into professional jargon.
• Action Taken: Who was informed (e.g., the DSL), at what time, and what was the immediate outcome? 
• Signature: The name and signature of the person making the report. 9.2 The “FACT” Principle 

All records must be written according to the FACT principle: 

• F – Factual: Only record what actually happened or was said. ● A – Accurate: Ensure dates, times, and names are correct. 
• C – Concise: Keep it clear and professional; avoid “waffle.” 
• T – Timely: Records should be completed as soon as possible, and always within 24 hours of the concern arising. 

9.3 Storage and Retention 

• Separation: Safeguarding records are not kept in general participation folders or staff files. They are held in a centralized, “restricted access” safeguarding file. 
• Security: Physical files must be kept in a locked cabinet; digital files must be password-protected or encrypted, accessible only to the DSL and Deputy. 
• Retention: Records will be kept until the child’s 25th birthday (or longer, depending on specific legal requirements and the nature of the charity’s work) to comply with independent inquiry standards. 

9.4 Professional Language 

Staff should avoid subjective language. 

• Avoid: “The child looked miserable and I think the mum is lazy.” 
• Use: “The child sat with their head down and did not engage in the activity. The child arrived in clothes that appeared heavily soiled and had a strong odor.” 

Important: Notes should never be written on scraps of paper or “post-its.” Use the official Safeguarding Incident Form provided by the charity. If you must take a quick note, transfer it to the official form immediately and then securely destroy the original scrap. 

This is a critical “protective” section of your policy. It ensures that if a member of your own team is accused of harm, the charity handles it with absolute neutrality and follows the law, rather than trying to “handle it internally” to protect its reputation.

10. Allegations Involving Staff or Volunteers 

LLH takes all allegations against staff or volunteers seriously. We recognize that our team holds a position of trust, and any breach of that trust must be investigated thoroughly and transparently. 

10.1 Initial Response 

If a child, parent, or colleague makes an allegation against a staff member or volunteer: 

• Immediate Safety: The child’s safety is the first priority. Ensure they are supported and moved away from the individual involved. 
• No Internal Investigation: Staff must not attempt to interview the accused person or “investigate” the claim. This could jeopardize a future police investigation. 
• Reporting: The concern must be reported immediately to the Designated Safeguarding Lead (DSL). 

o Note: If the allegation involves the DSL, it must be reported to the Chair of Trustees or the Deputy DSL. 

10.2 The LADO (Local Authority Designated Officer) 

The DSL must contact the Local Authority Designated Officer (LADO) within 24 hours of the allegation. The LADO is a statutory role responsible for overseeing allegations against people who work with children. 

The LADO will advise on: 

• Whether the police or social care need to be involved. 
• Whether the staff member should be suspended (as a neutral act) during the investigation. 
• How to inform the parents of the child involved. 

10.3 Suspension and Disciplinary Action 

• Neutral Act: Suspension is not an admission of guilt; it is a protective measure to ensure a fair investigation and the safety of the child. 
• DBS Reporting: If a staff member or volunteer is removed from their role (or resigns) because they harmed a child or posed a risk of harm, LLH has a legal duty to refer them to the Disclosure and Barring Service (DBS).

10.4 Support During the Process 

• For the Child: The charity will ensure the child and their family receive support through the appropriate channels. 
• For the Accused: The charity will appoint a “link person” (not involved in the investigation) to keep the staff member informed of the process, ensuring they have access to emotional support or their union representative. 

10.5 Reporting to the Charity Commission 

As a registered charity, we must report any serious safeguarding incident—including allegations against staff—to the Charity Commission as a “Serious Incident Report.” This is the responsibility of the Board of Trustees. 

Key Contacts for Allegations: 

Local Authority Designated Officer (LADO) Contacts 

If an allegation is made against a staff member or volunteer, the DSL must contact the relevant LADO within 24 hours. 

Hertfordshire 

• Service: Hertfordshire Safeguarding Children Partnership (HSCP) ● LADO Contact Number: 01992 555420 
• Email: lado.referral@hertfordshire.gov.uk 
• Referral Method: Hertfordshire prefers the use of their official LADO Referral Form, available on the Hertfordshire County Council website. 

Nottinghamshire 

• Service: Nottinghamshire Safeguarding Children Partnership (NSCP) ● LADO Contact Number: 0115 804 1272 
• Email: lado@nottscc.gov.uk 
• Referral Method: Initial contact can be made via phone or email, followed by the submission of the Nottinghamshire LADO Notification Form. 

The “Golden Rule”: Even if the allegation seems “unlikely” because the staff member is well-liked or long-serving, the procedure must be followed. We treat all allegations with equal seriousness to protect the child and the integrity of the charity.

11. Use of Cameras and Mobile Phones 

LLH is committed to ensuring that all digital imagery and communication are handled responsibly. We recognize that mobile phones and cameras can be tools for harm if not strictly managed. 

11.1 Staff and Volunteer Use 

• Personal Devices: Staff and volunteers must not use their personal mobile phones or cameras to take photos or videos of children during charity activities. 
• Work Devices: Only charity-owned equipment (phones/tablets/cameras) should be used to document activities. Photos must be transferred to the secure charity server and deleted from the device’s local memory immediately. 
• Social Media: Staff must never “friend” or “follow” children they meet through the charity on their personal social media accounts, nor should they share photos of beneficiaries on personal profiles. 

11.2 Taking and Using Images of Children 

Before any photo or video is taken, the following must apply: 

• Consent: Written consent must be obtained from the parent/carer (and the child, if they have the capacity to understand). This consent must specify how the image will be used (e.g., social media, website, or internal reports). 
• Appropriate Dress: Children must be appropriately dressed. No images should be taken of children in swimwear or states of undress. 
• Context: Images should focus on the activity, not the individual child. Where possible, use group shots or photos where the child’s face is not the primary focus. 
• Right to Withdraw: Parents and children have the right to withdraw consent at any time, at which point the image must be deleted from all platforms. 

11.3 Use of Phones by Children/Service Users 

• Safe Zones: If children bring phones to sessions, they should be encouraged to keep them in their bags. 
• Cyberbullying: We have a zero-tolerance policy for children taking photos/videos of other children during our sessions to tease, bully, or humiliate them.
• Inappropriate Content: If a staff member becomes aware that a child is accessing inappropriate content on their phone during a session, this must be reported as a safeguarding concern to the DSL. 

11.4 Photography at Public Events 

If the charity holds a public event, we will: 

• Post clear signage informing attendees that photography is taking place. 
• Provide “Opt-Out” stickers or lanyards for children whose parents do not wish them to be photographed. 
• Remind parents that they should only take photos of their own children. 

Policy Breach: Any staff member found to have unauthorized images of children on their personal devices will be subject to an immediate investigation, which may result in disciplinary action and a referral to the Police and LADO. 

12. Recruitment and Training of Staff and Volunteers 

Refer to LLH Safe Recruitment Policy.