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Bridging Barriers – Safeguarding policy

Bridging Barriers is a charity focused on providing equal access to opportunities for ethnically diverse and low socioeconomic young people aged 16-25. Our aim is to help them with their personal and professional development. In terms of personal development, we aim to support young people with their soft skills such as time management, organisation, and confidence. In terms of professional development, we aim to help young people with their employability skills and application support, including CV’s, cover letters and career guidance

E-13 Safeguarding Policy

This policy addresses the expectations, responsibilities, and safeguarding procedures with which we require Bridging Barriers Employees, Contractors and Volunteers to comply. It is designed to promote the safety and wellbeing of all those involved in Bridging Barriers activities through compliance with applicable laws and regulations, implementing best practices and robust policies, volunteer training, and volunteer oversight, and to ensure that all those involved with Bridging Barriers Charitable Company (‘Bridging Barriers’) are equipped to take appropriate action in the event of a safeguarding or wellbeing concern.
Bridging Barriers does not work with adults known to be at risk; in line with the principles of the 2005 Mental Capacity Act, we assume that adults have the capacity to make their own decisions on matters regarding their safety and how they choose to live. Our safeguarding procedure, therefore, focuses on taking reasonable action to ensure the safety and wellbeing of all those who engage with Bridging Barriers activities, including through signposting to other resources and sources of support as appropriate.

This policy is designed to:

  1. Promote the safety and wellbeing of Associates/Participants and all those involved in Bridging Barriers activities;
  2. Empower Employees, Contractors and Volunteers to respond in a timely, effective and proportionate manner to safeguarding issues; and
  3. Ensure that Bridging Barriers complies with applicable laws and regulations whilst incorporating and applying current industry best practices.
This policy is not a part of any Employee, Contractor or Volunteer’s contract and does not vest any Employee, Contractor or Volunteer with any rights. Bridging Barriers reserves the right to modify this policy at any time without notice.

Scope

Applicability. This policy applies to all Bridging Barriers Employees, Contractors and Volunteers.
  1. Administration. Bridging Barriers’ Designated Safeguarding Officer (‘DSO’) retains primary responsibility for implementing and updating this policy. The DSO’s contact information can be found at the end of this document. 
Definitions:
  • Candidate. Any person who meets Bridging Barriers eligibility criteria, including completion of all onboarding steps, and has been accepted by Bridging Barriers to participate in a Bridging Barrier programme as a beneficiary. This definition includes Associates who are considered ‘dormant’ and those who are ‘Recent Graduates’, but excludes Bridging Barriers Alumni.
  • Contractor(s). Any self-employed person providing goods or services to Bridging Barriers through a contract with Bridging Barriers; also commonly referred to as an ‘Independent Contractor.’
  • Designated Safeguarding Officer (DSO). The named individual(s) responsible for acting as the main source of support, advice and expertise for safeguarding at Bridging Barriers.
  • Employee(s). Any person employed by Bridging Barriers full-time or part-time through an employment contract.
  • Incident. Any event or action that does, or may, result in a safeguarding concern or harm (including physical, mental, or emotional harm) to a person, or otherwise gives rise to a safeguarding issue or concern.
  • Mentee. Any individual who is currently participating in the Bridging Barriers professional mentoring programme and is actively matched with a volunteer mentor.
  • Misconduct indicators. Any actions or behaviours exhibited by a Bridging Barriers Employee, Contractor or Volunteer which would indicate a potential safeguarding concern requiring action from Bridging Barriers.
  • Recent Graduate. Any person who completed their time on the Bridging Barriers programme and graduated from university within the last 12 months.
  • Reporting Party. Any individual who becomes aware of a safeguarding concern and alerts Bridging Barriers the DSO to the issue.
  • Safeguarding. For the purposes of this policy, the terms ‘safeguarding’ and ‘to safeguard’ describe the prevention methods and the precautionary approach to planning and procedures that is needed to protect adults from any potential harm.
  • Volunteer. Any unpaid person assisting Bridging Barriers with carrying out activities relating to its mission including, but not limited to, mentoring or event volunteers.
  • Participants: refers to any individual, who attends one or more Bridging Barriers event.

Bridging Barriers Webinar Host: refers to members of the Bridging Barriers team who host Webinars with under-18s in attendance. These hosts will all be required to undergo Enhanced DBS checks and external safeguarding training prior to commencing this responsibility.

Bridging Barriers Webinar Speaker: refers to Bridging Barriers staff members (other than the Bridging Barriers Webinar Host) or individuals from selected organisations outside of Bridging Barriers who may be invited to speak and answer questions on their experiences in a particular sector or to provide expertise on the university application process during one or more Webinar. These Webinar Speakers will be required to attend safeguarding training from Bridging Barriers prior to taking part in a Webinar.

Policy

It is the policy of Bridging Barriers to:
  1. Promote the safety and wellbeing of all those involved in Bridging Barriers activities through compliance with applicable laws and regulations, implementing best practices and robust policies, volunteer training, and volunteer oversight;
  2. Ensure all safeguarding concerns and issues are identified and addressed in a timely, effective and proportionate manner;
  3. Manage all safeguarding issues and risks using clearly established procedures and protocols; and
  4. Ensure that Employees, Contactors and Volunteers:
    1. Refrain from engaging in abusive or inappropriate behaviours directed towards Candidates/Participants;
    2. Are adequately trained to identify, and appropriately respond to, safeguarding issues;
    3. Receive adequate support to engage with Bridging Barriers Participants in a positive and constructive manner; and
    4. Adhere to Bridging Barriers policies and procedures.

Employees, Contractors and Volunteers

Employees, Contractors and Volunteers are responsible for:
  1. Understanding and implementing this policy and applicable procedures;
  2. Ensuring safeguarding issues or concerns are reported and acted upon in a timely manner while responding sensitively and appropriately to such concerns;
  3. Maintaining open lines of communication with the Designated Safeguarding Officer(s) regarding safeguarding issues;
  4. Demonstrating appropriate behaviour with Participants including, without limitation:
    1. Treating each Candidate/Participant with respect and dignity;
    2. Refraining from discriminating against Candidates/Participants on the basis of age, gender, ethnicity, disability, religion, political beliefs, sexual orientation, socio-economic status, or race;
    3. Maintaining appropriate professional boundaries in relationships with all Candidate/Participants and refraining from instigating, engaging in, or continuing intimate or sexual relationships;
    4. Taking reasonable steps to ensure the wellbeing of Candidates/Participants;
    5. Engaging with Candidates/Participants in an open environment and avoiding private or unobserved situations whenever possible;
    6. Taking reasonable and appropriate steps to protect the privacy and confidentiality of each Participant, including complying with applicable Bridging Barriers policies and regulations, such as the General Data Protection Regulation (‘GDPR’).
5. Refraining from engaging in, or otherwise displaying, ‘Misconduct Indicators’ (see Definitions above).
Bridging Barriers recognises the following non-exhaustive list of actions as indicators of potential safeguarding issues requiring action by Bridging Barriers. If an Employee, Contractor or Volunteer is found to have engaged in any behaviours suggestive of Misconduct Indicators, this may result in disciplinary action for the Employee, Contractor or Volunteer concerned, and enforcement action for Volunteers.
    1. Engaging in discriminatory behaviour against any person;
    2. Failing to maintain personal and professional boundaries with Candidates/Participants, including engaging in intimate or sexual relationships with Candidate/Participants;
    3. Using position or influence to intimidate, threaten, coerce, or undermine a Candidate/Participant or other Employee, Contractor or Volunteer;
    4. Failing to enforce Bridging Barriers policies or procedures with a Participant on the basis of favouritism or an inappropriate relationship with the Candidate/Participant;
    5. Failing to report inappropriate Candidate/Participant behaviour or safeguarding risks or concerns in accordance with this policy or training;
    6. Making comments or engaging in discussions, even in jest, that could be construed as abusive or sexually provocative, or which concern sensitive subject matter topics like politics or religion; and
    7. Encouraging or engaging in home visits, outings, or any other communications (including electronic communications) not expected or authorised as part of the professional relationship.
Bridging Barriers Charitable Company
To ensure the safety of all those connected with Bridging Barriers, Bridging Barriers shall:
  1. Ensure that suitable training for Employees, Contractors and Volunteers is provided on an appropriate basis;
  2. Maintain updated policies and procedures compliant with applicable laws, regulations, and best practice;
  3. Maintain a safeguarding log and documentation system;
  4. Ensure direct and open lines of reporting for Employees, Contractors and Volunteers to Designated Safeguarding Officer(s);
  5. Ensure direct and open lines of reporting to Bridging Barriers trustees regarding safeguarding issues, including the designated Trustee Safeguarding Lead;
  6. Appoint and maintain a Designated Safeguarding Officer and secondary or Backup Designated Safeguarding Officer to implement and ensure compliance with this policy, procedure, and applicable laws;
  7. Engage in annual stress testing, audits, or both of Bridging Barriers safeguarding policies and procedures;
  8. Engage in data protection to protect Candidate and Participant data in line with other Bridging Barriers policies and procedures, as well as applicable regulations;
  9. Report serious incidents to relevant agencies and statutory bodies, including the Charity Commission.
Enforcement
Any Employee, Contractor or Volunteer violating this policy may be subject to disciplinary action up to and including suspension or termination as well as:
  1. Legal action against the Employee, Contractor or Volunteer;
  2. Immediate dismissal;
  3. Reporting to applicable authorities, including law enforcement.

Any violation of this policy by a Bridging Barriers Volunteer may result in enforcement actions up to and including:

  1. Legal action;
  2. Dismissal from the Bridging Barriers volunteer programme;
  3. Reporting to applicable authorities, including the Bridging Barriers Volunteer’s employer and/or law enforcement. 

Steps to Take in the Event of a Safeguarding Concern:

Emergency Incidents:
  1. The reporting party will immediately contact emergency services;
  2. The reporting party will contact the Designated Safeguarding Officer via phone and then email to report the matter;
  3. The reporting party will complete the Safeguarding Report Form and submit it to the Designated Safeguarding Officer within twenty-four (24) hours, or as soon as reasonably possible after the event;
  4. The DSO, backup DSO, and Chief Executive will meet within twenty-four (24) hours for a Review Meeting to assess the matter and to discuss the next steps;
  5. The DSO will log in safeguarding database and take action as decided by Review Meeting participants;
  6. The Chief Executive will report to Trustee Safeguarding Lead and any statutory bodies as appropriate, including the Charity Commission;
  7. The DSO will follow up on a weekly basis or as appropriate with reporting party until the issue is resolved or downgraded.
Child or Adult Protection Concerns: 
  1. If an individual is in immediate danger, the reporting party will immediately contact emergency services, then contact the DSO by phone then email to report the matter. If the individual is not in immediate danger, the reporting party will contact the DSO by phone and then email to report the matter;
  2. The reporting party will complete the Safeguarding Reporting Form and submit it to the Designated Safeguarding Officer as soon as possible and no more than 24 hours after the incident first occurs or the reporting party becomes aware of the issue;
  3. The DSO will contact the local authority safeguarding team and make a referral via within 24 hours of receiving the report, following up with a written referral;
  4. The DSO will complete follow-up actions as guided by the local authority safeguarding team or police as required;
  5. The DSO, backup DSO, and Chief Executive will meet within twenty-four (24) hours for a Review Meeting;
  6. The Chief Executive will report to the Trustee Safeguarding Lead and any statutory bodies as appropriate, including the Charity Commission;
  7. The DSO will follow up on a weekly basis or as appropriate with reporting party until issue is resolved or downgraded.
Allegations Concerning Bridging Barriers Staff or Volunteers:
  1. The Reporting party will complete the Safeguarding Reporting Form and submit it to the Designated Safeguarding Officer within twenty-four (24) hours, or as soon as reasonably possible after the event or reporting party becomes aware of the allegation. If the reporting party deems it necessary, they should also contact the Designated Safeguarding Officer by phone or email in order to flag the matter;
  2. The DSO, backup DSO, Chief Executive and Chief of Staff will meet within twenty-four (24) hours for a Review Meeting and to determine the next steps;
  3. Disciplinary action (in accordance with E-01 Disciplinary Procedure) will be taken as appropriate, including internal investigation and suspension if deemed necessary;
  4. The Chief Executive will report to Trustee Safeguarding Lead and any statutory bodies as appropriate, including the Charity Commission;
  5. The DSO will follow up on a weekly basis or as appropriate with the reporting party until the issue is resolved or downgraded.
Welfare Concerns:
6. The reporting party will complete the Safeguarding Reporting Form and submit it to the Designated Safeguarding Officer within forty-eight (48) hours, or as soon as reasonably possible after the event or the reporting party becomes aware of the concern. If the reporting party deems it necessary, they should also contact the Designated Safeguarding Officer by phone or email in order to flag the matter;
7. The DSO will review the Safeguarding Reporting Form within 48 hours of submission, log in to the Safeguarding database and confirm classification. The DSO may work with the reporting party to determine the next steps;
8. The DSO will follow up as appropriate with reporting party until the issue is resolved or downgraded;
9. The DSO will report to the Trustee Safeguarding Lead as appropriate, in line with scheduled Trustee Meeting updates;
10. The reporting party will notify the DSO of any changes to the matter which may lead to its reclassification.
Designated Safeguarding Officer (or Back-up Designated Safeguarding Officer) Actions:

The Designated Safeguarding Officer upon receiving a report shall:

  1. Assess the matter to affirm or reclassify the reporting party’s classification;
  2. Update the safeguarding log;
  3. Investigate and address the safeguarding issue in conjunction with the backup Designated Safeguarding Officer and, if applicable, report the safeguarding issue(s) to Chief Executive, designated Trustee Safeguarding Lead, or both;
  4. Determine an appropriate course of action to take, including signposting to any external sources of support such as university wellbeing services or referring to statutory bodies such as local authority safeguarding teams or police, and share this course of action with any relevant individuals;
  5. Provide an update on outstanding safeguarding issues to Trustee Safeguarding Lead, in time for each Trustee Meeting; and
  6. Organise, file, and maintain the safeguarding log, documentation, and files to ensure accuracy and consistency with the status of the matter. 

Section 2: Under-18s Safeguarding Policy

In addition to following the policies and procedures listed above, Bridging Barriers has additional safeguarding measures in place relating to its work with under-18s.

Background:

Bridging Barriers currently doesn’t work with under-18s, however in the near future, Bridging Barriers will be working with under-18s, through virtual mentorship and online webinars. Additional safeguarding measures for this are detailed in Section 2 of this document. 

Webinar Safeguarding:

All Bridging Barriers focused webinars will be delivered via Zoom’s Webinar feature, with students registering their interest online via the website. To eliminate risks of Participants interacting inappropriately with each other, or with Webinar Speakers privately or publicly, participants will only be able to interact with the Bridging Barriers Webinar Host, and cannot communicate with each other. An individual Participant will not be able to view any details about any other Participant (i.e. name, photo, video, etc). Participants can privately ask questions to the Bridging Barriers Webinar Host(s) who may, where appropriate, ask the Webinar Speakers to answer the question, but will not identify the source of the question by name.

It is the responsibility of the Bridging Barriers Webinar Host(s) to report any safeguarding concerns that arise from either the Webinar Speaker(s) or Participants during the broadcast. In the event of a serious safeguarding concern being raised by a Participant, the Bridging Barriers Webinar Host(s) will take appropriate action as detailed above in Section 1 of this document (“Steps to Take in the Event of a Safeguarding Concern”)

Data protection:

All personal data collected for the purposes of Webinar attendance will be processed in line with Bridging Barriers full Privacy Policy & Cookie Policy, and deleted within 2 years of Webinar registration

Contact Information:

References

  1. A-02 Bridging Barriers Privacy Notice & Use of Cookies
  2. Data Protection Act 2018
  3. The Care Act 2014
  4. Mental Capacity Act 2005
  5. Safeguarding Vulnerable Groups 2006
  6. Working Together to Safeguard Children 2018
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