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Safeguarding Policy: 

Safeguarding Children and Vulnerable Young Adults Policy and Procedure 

1. Policy Statement 

Anna Daphna Coaching Ltd (“the Company”) recognises that the welfare of children and young adults is paramount and that it has a responsibility to safeguard and promote the welfare of children and young people.  

All children and young adults, regardless of age, disability, gender, racial or ethnic origin, religious belief and sexual identity, have a right to be treated with care, respect and dignity. 

The welfare of the child or young person is the paramount consideration.  

Our ambition is to help children and young adults to unlock and fulfil their potential in a safe and caring environment. The Company is committed to safeguarding practises and procedures that protect children and young adults from harm or distress.  

We take safety concerns very seriously and will always act in the best interests of the child.  

We recognise that any procedure is only as effective as the ability and skill of those who operate it. The Company is committed to:  

• Proper recruitment processes;  

• Clear processes for recognizing and responding to concerns; and  

• Working together with parents, carers and agencies to ensure that the needs and welfare of all remain paramount.  

2. Purpose 

The purpose of this policy is to: 

• Safeguard and promote the welfare of all the children and young adults with whom the Company works, regardless of their age, disability, gender, racial or ethnic origin, religious belief and  sexual identity, socioeconomic background or other; 

• Enable those engaged by, employed by or working through the Company to safeguard and  promote the welfare of children and young vulnerable young adults and protect them from harm,  discrimination or degrading treatment;


• Respect the wishes, rights and feelings of the children and young adults. 

This policy applies to all who are employed, engaged by or working through the Company.


3. What is safeguarding? 

In the UK, safeguarding means protecting people's health, well-being and human rights and enabling them to live free from harm, abuse and neglect. We understand it to mean safeguarding people, including children and at-risk, vulnerable young adults.  

It is the responsibility of everyone at Anna Daphna Coaching Ltd to promote the safety of the children and young people we work with and to protect the child's or the young person’s welfare as the key priority. 

4. Application 

Everyone employed, engaged by or working through the Company will be provided with a copy of this policy and will be required to sign to say that they have received, read and understood the policy.  

Legal framework  

The practices and procedures within this policy are based on the principles of UK legislation and  Government Guidance.


They take the following into consideration:  

• Human Rights Act of 1998  

• Children Act 1989  

• Sexual Offences Act of 2003  

• Children Act 2004  

• Serious Crime Act 2015  

• Working Together to Safeguard Children 2018  

• Keeping Children Safe in Education 2018  

• Data Protection Act 2018 

5. Definitions & Terminology 

The following definitions are referred to in this policy; 


In England, Northern Ireland and Wales, a child is someone under 18, whether living with their families,  in state care, or independently (Working Together to Safeguard Children 2018). This generally applies in  Scotland, but in some cases, for example, for parts of the Scottish Child Protection Process, it will be 16.  

Vulnerable young adults: 

Individuals aged 18 or over who are considered vulnerable due to having;  

• a substantial learning or physical disability; 

• a physical or mental illness or mental disorder, chronic or otherwise, including an addiction to alcohol  or drugs; 

• or a significant reduction in physical or mental capacity. 

Safeguarding and promoting:  

Protecting children and vulnerable young adults from maltreatment, preventing harm to children’s and vulnerable young adults’ health or development; ensuring children and vulnerable young adults grow up with the provision of safe and effective care; and taking action to enable children and vulnerable young adults to have the best outcomes.  

Safeguarding concern:  

When there is information that a child, vulnerable young adult or an adult at risk has been harmed, or is at risk of being harmed, by their own or someone else’s behaviour. 

Safeguarding allegation (as defined by the Children Act 1989) 

Where anyone engaged, employed by or working through the Company has:  

• Behaved in a way that has harmed a child or an adult at risk, may have harmed a child or an adult at  risk, or behaved in a way that might lead to a child or an adult at risk being harmed;  

• Possibly committed or is planning to commit a criminal offence against a child or an adult at risk or  related to a child or an adult at risk, or;  

• Behaved towards a child or an adult at risk in a way that indicates they are or would be, unsuitable to work with children or vulnerable young adults at risk. 

Abuse of Trust: 

The Sexual Offences (Amendment) Act 2000 Section 3 created the offence of abuse of trust. It is an offence for a person aged 18 or over to have sexual intercourse with a person under 18 or to engage in any other sexual activity with or directed towards such a person if, in either case, that person is in a position of trust in relation to the under 18-year-old. This applies even if the relationship is consensual.  

A person aged 18 or over ("Person A") is in a position of trust in relation to a person under that age ("Person B")  if any of the four conditions are satisfied. One relates to the education field as follows: "Person A" looks after persons under 18 and are receiving full-time education in an institution, and "Person B" is receiving such education within that institution. It is a defence to show that the person charged did not know, or could not reasonably have known, that the other party was a person in relation to whom he or she was in a position of trust.  

Whilst this legislation does not apply to Anna Daphna coaching Ltd, if any person engaged, employed by or working through the Company breaches the principles of this legislation, this will be viewed as a breach of this policy.  



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. Abuse can take many forms and can take place wholly online, or technology may be used to facilitate offline abuse. The possible Types of Abuse are set out in Appendix B.  

Poor practice:  

Sometimes, concerns may relate to poor practice, where an adult’s or another young person’s behaviour is inappropriate and may be causing distress to a child or young person. In applying this policy, the poor practice includes any behaviour that contravenes the principles of this policy. Where the poor practice is serious or repeated, this could also constitute abuse and should be reported immediately.  

Examples of poor practices towards children, which should never be sanctioned, include:  

• use of excessive, physical or humiliating punishments;  

• failure to act when you witness possible abuse or bullying, or other safeguarding issues;  

• spending excessive amounts of time alone with young people away from others;  

• whilst not engaged in tutoring, inviting or allowing young people into your home where they will be  alone with you;  

• engaging in rough, physical or sexually provocative activity;  

• allowing young people to use inappropriate language unchallenged;  

• making sexually suggestive comments even in fun;  

• reducing a person to tears as a form of control;  

• allowing allegations made by a young person to go unchallenged, unrecorded or not acted upon;  • doing things of a personal nature for young people that they can do for themselves.  


Designated Safeguarding Lead. (Working Together to Safeguard Children 2018) 

Child and Young Adult Safeguarding Procedures 

This policy applies to all children and vulnerable young adults. The aim of these procedures is to detail how the Company and anyone engaged, employed by or working through the Company should respond  if: 

• they suspect that a child or young adult is suffering abuse;  

• a child or young adult makes a disclosure or reports that they, or someone else, has been abused; 

• the behaviour of an adult or child towards a child or young adult gives them cause for concern; 

• they identify a breach of this policy. 

This policy outlines the behaviour expected of anyone engaged, employed by or working through the Company when they are engaging with children and young adults. 

All those engaged, employed by or working through the Company have a responsibility to be alert to the fact that children and young adults may be abused and that those engaged, employed by or working through the Company MUST report safeguarding concerns. This process is summarised in Appendix C.  

Even for those experienced in working with child abuse, it is not always easy to recognise a situation where abuse may occur or has already taken place. The Company recognises that all engaged, employed by or working through it are not experts in such recognition.


The Company, therefore, expects all those engaged,  employed by or working through it to report any concern they may have about the welfare of a child or young adult immediately with the applicable local authority or DSL. 

By following the four simple safeguarding principles of recognising, responding, reporting and recording, the Company and those engaged, employed by or working through the Company can keep those children and young adults who may be at risk of abuse safe from harm.



Signs and indicators of abuse and neglect 

We should all be alert for the signs and indicators that children and vulnerable young people who interact or engage with those engaged, employed by or working through the Company may suffer abuse.  

Indicators that a child may be being abused may include the following: 

• Unexplained or suspicious injuries such as bruising, cuts or burns, particularly if situated on the part of the body not normally prone to such injuries; 

• An injury for which the explanation seems inconsistent; 

• The young person describes what appears to be an abusive act involving him/her; 

• Someone else (a young person or adult) expresses concern about the welfare of another; 

• Unexplained changes in behaviour (e.g. becoming very quiet, withdrawn or displaying sudden  outbursts of temper, changes in educational progress); 

• Inappropriate sexual awareness; 

• Engaging in sexually explicit behaviour; 

• Sudden or unusual distrust of vulnerable young adults, particularly those with whom a close  relationship would normally be expected; 

• Having difficulty in making friends; 

• Being prevented from socialising with other young people; 

• Displaying variations in eating patterns, including overeating or loss of appetite; or a sudden weight  change; 

• Becoming increasingly dirty or unkempt. 

It should be recognised that this list is not exhaustive, and the presence of one or more of the indicators is not proof that abuse is actually taking place. For example, a family bereavement, which could cause some of the changes listed above. A good working relationship with parents, guardians and other individuals or institutions will help to identify any other concerns that a child or young person may be experiencing.  


It is always difficult to hear about or witness harm or abuse experienced by a child or young adult. The following  points will be helpful for both you and the child should they choose to disclose abuse to you: 

• Stay calm. 

• Listen carefully to what is said and try not to interrupt. 

• Find an appropriate point early on to explain that it is likely that the information will need to be shared with others – do not promise to keep secrets. 

• Allow them to continue at their own pace. 

• Ask questions for clarification only and avoid asking questions that suggest an answer (leading questions). 

• Reassure them that they are not to blame and have done the right thing in telling you. If the concern is serious, explain that you will need support from other people to help keep the child safe. This must be shared even if the child doesn’t want you to tell anyone else. 

• Tell them what you will do next and with whom the information will be shared. If they are adamant that they do not wish the information to be shared, explain that you will have to tell the DSL and that it will be discussed further with them. 

• Be aware of the possibility of forensic evidence if the disclosure relates to a recent incident of physical harm or injury, and try to protect any supporting materials, e.g. bedding or clothing. 

• Report the disclosure to the DSL immediately (or where this is not possible, at the earliest opportunity) and follow this policy. 

• Where you are unable to contact the DSL, or you would prefer to direct your concern somewhere else, advice  can be sought from: 

• the Local Authority Children Services. Use the website to find the Local Authority Services for your area. 

• the NSPCC Helpline (0808 800 5000

• Local Police - Telephone 101 for non-emergency referrals and 999 for emergency response. 

Where the concern or allegation is about someone engaged, employed by or working through the Company, this just like all other concerns must be reported to the local authority or the DSL. If the DSL considers the concern serious, for example, potentially child abuse or a crime, they must report the incident to the police. 

When a safeguarding concern or poor practice has been identified concerning a specific child or young adult,  the parents/guardians/carers of that child should be notified (unless informing them will put the child or young adult at further risk). Where the DSL has reported the incident to the statutory authorities, advice should be sought from them regarding this duty before notifying the parents/guardians/carers. 


Remember, it is not the responsibility of those engaged, employed by or working through the Company or anyone assisting in their activities with children to decide if child abuse is occurring, but it is their responsibility to act on any concerns by reporting them. 

Report concerns that you have to the local authority or DSL. This includes seeking advice on how to complete the Safeguarding Report Form (see appendix D). 

Safeguarding concerns MUST be reported immediately (or where this is not possible at the earliest opportunity)  so that the report can be assessed and action taken to protect the person involved. If any person is at immediate risk of harm or requires medical attention, the emergency services should be contacted immediately by telephoning 999. 

If a member of the public, parent/guardian, police or Local Authority Services reports a safeguarding concern to the Company, the matter must be referred to the DSL for assessment no later than the next working day. 

If for any reason, the DSL cannot be contacted, the following organisations can be contacted for advice: 

• Concern about a child - You should contact the Local Authority Children Services. Use the website to find the Local Authority Services for your area.

• the NSPCC Helpline (0808 800 5000

• Local Police - Telephone 101 for non-emergency referrals and 999 for emergency response.



It is important that you keep an accurate written record of any safeguarding concern you have or someone raises with you. Your written record must: 

• be made as soon as possible after the event/concern is raised; 

• contain the date, time, people present, and anything said (verbatim if possible); 

• detail the behaviour and demeanour of the person disclosing the safeguarding issue; 

• detail any action you have taken (for example, how you have reduced risk or whether you have  referred the matter to the DSL); 

• be a factual account of what has happened; 

• be accurate and comprehensive. 

Do not record any opinion about what has happened. You are not there to judge or ascertain whether what you are being told is correct. 

You can record your concern(s) on the Company's Safeguarding Report Form (Appendix D). Once you have recorded your concerns, you should sign and date the report or record the date and time the concern was recorded on the report. 

All Safeguarding Reports must be emailed to:


Confidentiality and sharing information 

Effective and timely sharing of information is essential for the early identification of a child or young adult’s needs and to ensure that the most appropriate services are provided to keep them safe. 

Those with concerns should be proactive in sharing information as early as possible to help the DSL identify,  assess and respond to risks or concerns about the safety and welfare of children. 

Fears about sharing information must not be allowed to stand in the way of the need to promote the welfare and protect the safety of children and young adults, which must be the paramount concern always. The Data  Protection Act 2018 and/or the General Data Protection Regulations 2018 do not prevent you from sharing information in relation to safeguarding. 

You should not assume that someone else will pass on information that you think may be critical to keeping a  child safe. 

Those engaged, employed by or working through the Company should aim to gain consent to share information but should be mindful of situations where to do so would place a child or young adult at increased risk of harm. 

Information may be shared without consent if the DSL or another person has reason to believe that there is a  good reason to do so and that the sharing of information will enhance the safeguarding of a child or young adult in a timely manner. When decisions are made for sharing or withholding information, this should be recorded, along with the information and why. 

Where the DSL is contacted, information should not be shared with any external organisation without the DSL’s  consent, except in cases where there is a risk of immediate or serious harm and an emergency referral is  

The Data Protection Act 2018 contains the ‘safeguarding of children and individuals at risk as a processing condition that allows practitioners to share information. This includes allowing practitioners to share information without consent. If it is not possible to gain consent, it cannot be reasonably expected that a practitioner gains consent, or if gaining consent would place a child at risk necessary. The DSL will manage the process of sharing information with the police, local authority services and/or any third-party organisation as appropriate.  

Information should be kept confidential and should only be shared with the DSL. If there is any doubt about  whether to share information or whom to share it with, the DSL should be contacted for advice by telephoning  or emailing the following before disclosing any information: 

Designated Safeguarding Lead: 07834857534 /

Action by the DSL if contacted  

The DSL will manage the safeguarding process and respond to any safeguarding concerns. Their role is not to investigate the reported concern or make judgements about the individuals or allegations involved but to ensure that appropriate referrals are made to statutory agencies and effective internal action is taken to keep people safe. 

When a safeguarding concern has been reported, the DSL will: 

• Assess the information received; 

• Identify any risks to individuals contained within the report; 

• Decide if immediate action is needed to remove, reduce or control the risks identified; 

• Take such action if it is required; 

• Decide whether the information in the safeguarding concern constitutes a safeguarding allegation against anyone employed, engaged by, or working through the Company; 

• Decide whether a referral to the police and/or Local Authority Services is required; 

• Decide what further action by the Company may be needed to manage the investigation. 

When a safeguarding concern is raised, the DSL will determine what action is needed. The action taken may include monitoring the situation, a referral to children's social care or the police or taking no action. Whatever decision is taken, they will record this together with a rationale, even if no further action is to be taken. A decision to take no further action, monitor, or defer a decision is taken as seriously as a decision to make a referral. 

Any referrals to the local authority or other agency must be made by the DSL by the next working day unless it is an emergency or they consider it better for another person to make the referral and report back. 

Any referrals to the local authority or other agency must be followed up in writing within 48 hours, and feedback must be received/sought within three working days of making the referral to check what action is being taken. It is the responsibility of the DSL to ensure this takes place and that comprehensive records are maintained. 

Each local authority has a process for receiving referrals, and the DSL must use the relevant process in their area.  The DSL making the referral should complete the local authority’s referral form when making a formal referral about child protection. 

Escalation Policy 

If, after reporting on a concern, it is evident that the local authority or other agency has not taken appropriate next steps in relation to the safeguarding concern, the DSL will determine if the matter needs to be escalated.


The Child Safeguarding Strategic Partnerships will have specific procedures to be followed when escalation is warranted. A record of any decisions and outcomes must be kept by the DSL. 

Child and Young Adult Safeguarding


Those engaged, employed by or working through the Company must never: 

• Sexually abuse or exploit at-risk, vulnerable children and young adults;  

• Subject a child or an at-risk adult to physical, emotional or psychological abuse or neglect; 

• Engage in poor practice in relation to a child or young adult;  

• Engage in any abuse of trust in relation to a child or young adult.  

Protection from sexual exploitation and abuse 

Those engaged, employed by or working through the Company must never: 

• Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance. 

• Engage in sexual relationships with assistance beneficiaries since they are based on inherently unequal power dynamics. 

Those engaged, employed by or working through the Company must: 

• Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes implementing this Policy.  

Good practice 

You can reduce situations for the abuse of children and young adults and help protect them and those working through the Company by being open publicly when working with children and young adults.  

You should be responsive to a child’s or young adult’s reactions. Talk to them about what you are doing and give them choices. 


If you accidentally hurt a child or young adult, the child or young adult seems distressed in any way,  appears sexually aroused by your actions, or misunderstands or misinterprets something you have done, report any such incident as soon as possible to the DSL.  

Recruitment and Training 

As part of the Company's recruitment and selection process, offers of employment or engagement to positions where working with children and young people unsupervised is an expected part of the job will be subject to Disclosure and Barring Service (DBS) enhanced disclosure. This applies to persons engaged in all types of contracts.  

If the disclosure reveals that they have been convicted of any offence relating to children or young people;  and/or subject to any disciplinary action or sanction relating to children or young people, the candidate will not  be appointed to the position. 

Any decision will be recorded in writing and stored for future reference.  

Procedural implementation and review: 

These procedures were implemented in March 2020.

Supporting documents 

This policy statement should be read alongside our Terms and Conditions, Terms of Sale, Privacy Notice and Cookie Policy.

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