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        Safeguarding Policy Document

        THE TORCH TRUST FOR THE BLIND

        SAFEGUARDING POLICY

        Company Limited by Guarantee No. 4616526

        Registered Charity No. 1095904

        Torch House, Torch Way, Market Harborough, Leicestershire LE16 9HL

        Tel: 01858 438260         Email: info@torchtrust.org

        Insurer: Ansvar Insurance Company: Charity & Connect Policy CCP2155260

        Date of approval: 04/11/2021

        Introduction

        The document is made up of three elements: Torch Trust Safeguarding Policy, Implementing our Policy: Practice and Procedures and Appendices.


        Contents

        Torch Trust Safeguarding Policy

        • Torch Trust’s purpose and values
        • Policy scope
        • Our safeguarding commitment

        Implementing our policy: practice and procedures

        1. Code of behaviour

        2. Specific responsibilities for safeguarding

        3. Safer recruitment

        4. Working with offenders

        5. Partnerships

        6. Management of concerns

                a. Responding to concerns – all Torch workers (other than holiday events)

                b. Responding to concerns – all workers on Torch holidays only

                c. Responding to concerns – Safeguarding Coordinator

                d. Referral to a statutory agency – Safeguarding Coordinator

        e. Internal investigation – Safeguarding Coordinator, Head of Central Services, Head of Technical Services and/or Head of Services, Chief Executive, Lead Trustee for Safeguarding, Chair of Trustees

        f. Support – Safeguarding Coordinator with Head of Central Services

        g. Case review – Safeguarding Coordinator, relevant Leadership Team members, Lead Trustee for safeguarding

        7. Data Protection

        8. Complaints

        Appendices

        Appendix 1 Types of abuse

        Appendix 2 Key legislation relating to safeguarding

        Appendix 3 Contact Information and sources of help and advice

        Appendix 4 Management of concerns process diagram


        TORCH TRUST SAFEGUARDING POLICY

        Torch Trust’s purpose and values

        Torch Trust aims to enable blind and partially sighted people to encounter Jesus, grow in their Christian faith and thrive in Christian community.

        We provide Christian resources for blind and partially sighted people worldwide and provide activities within the United Kingdom for people with sight loss. Our services are offered to all who experience sight loss, of all faiths or none. Most, but not all, of the people we serve are adults. Our services are delivered by a dedicated team of paid staff and volunteers. Our core values are ‘Christ-centred’, ‘people-focussed’, ‘open’ and ‘creative’. We endeavour to make our values real in everything we do, all of the time.

        Policy scope

        This policy applies to all of the contexts in which Torch operates, including online as well as in-person activities. The detailed implementation of some procedures may vary according to the specific context of the activity, as laid out in the supporting procedural section of this document.

        We recognise that abuse and threats to wellbeing can occur in a range of settings which children and adults at risk experience as they live their lives. These contexts may not be connected to Torch and could, for example, be domestic or school-based. Whatever the context, we will respond in line with our safeguarding commitments and procedures.

        Our safeguarding commitment

        Consistent with our aims and values, we commit to the protection and safeguarding of all, including children and adults at risk. We will provide a safe and caring environment for all who use our services and all who work for us.

        We are committed to:

        • developing a culture of awareness of safeguarding to help protect everyone.
        • Preventing harm and reducing the risk of abuse. Any abuse disclosed, discovered or suspected will be reported consistent with our procedures.
        • Respecting children and adults at risk, recognising that we all have been created equal by God. All those who work for Torch are expected to comply with our values and agreed code of behaviour. We will seek to ensure that the behaviour of any individuals who may pose a risk to children and adults is managed appropriately so that all are protected.
        • Safer recruitment. We will recruit paid staff and volunteers carefully to minimise the risks to those to whom we provide a service and to fellow workers. All workers will be provided with the training and support appropriate to their role so that they can keep people safe.
        • Complying with international conventions and legislation and accompanying guidance applying within the UK that relates to the safeguarding of children and adults. As such, we commit to the safeguarding principles of empowerment, prevention, proportionality, protection, partnership and accountability.
        • Working with others. We will work with statutory and non-statutory agencies with a responsibility for safeguarding, consistent with the remit of their powers. When delivering our charitable activities in partnership with others, we will only partner with organisations who share our commitment to safeguarding children and adults at risk.
        • Assigning responsibilities. Safeguarding is the responsibility of everyone associated with Torch. Some individuals or groups of people have been allocated specific responsibilities. Details of these specific responsibilities are contained in the second part of this document.
        • Being accessible. This policy and the operational procedures which accompany this policy are available on request in all accessible formats. We will seek to provide information on where to get help and advice in relation to abuse, discrimination, bullying or any other matter of concern.
        • Implementing our safeguarding policy. The second section of this document contains the procedures and practices that we follow. We are committed to turning these policy commitments into regular, consistent practice.

        The Board of Trustees will review and approve the safeguarding policy regularly, at least on an annual basis.

        Approved by the Board of Trustees:  04/11/2021


        IMPLEMENTING OUR POLICY: PRACTICE AND PROCEDURES

        This part of the document provides details on how Torch’s safeguarding policy should be implemented.

        1. Code of behaviour

        Torch’s workers (employed and volunteers) are required to comply with this Code of behaviour when working with children and adults at risk of harm:

        • Demonstrate Torch’s values through their actions
        • Treat everyone with dignity, respecting their individuality and not showing favouritism
        • Seek to include everyone who uses Torch services in the full range of activities offered
        • Use age and ability appropriate means of communicating, whether orally or in written form, including online
        • Listen well to everyone and not make assumptions about what is being said
        • Not to make inappropriate, sexually suggestive or threatening comments
        • Not to scapegoat, belittle, ridicule or reject anyone
        • Do not have physical contact with a child unless it is to protect them, yourself or others from harm
        • Do not assume or withhold physical contact with an adult at risk; always ask them first other than in circumstances where the contact is to protect them, yourself or others from harm
        • Avoid working alone with a child or adult at risk, being within sight or hearing distance of others; where such working is required to fulfil the requirement of your role, a risk assessment must be completed and approved in advance
        • Do not trivialise abuse or let it go unreported

        2. Specific responsibilities for safeguarding

        Some individuals within Torch have specific safeguarding responsibilities. Specific areas of involvement are shown throughout this document.

        • The Board of Trustees has the responsibility to proactively safeguard and promote the welfare of the charity’s beneficiaries. The Board are responsible for the reporting of serious incidents to the Charity Regulator; this responsibility may be delegated to either the CEO, a director or Company Secretary.
        • The Lead Trustee for Safeguarding will support the other trustees in developing their understanding of safeguarding and will support the Chief Executive in establishing the culture and practice of safeguarding throughout the organisation.
        • The Chief Executive will, working with the Leadership Team, ensure that safeguarding is central to Torch’s work. They will maintain a clear organisational focus on safeguarding and make sure that statutory requirements are complied with. They will support other Torch staff with specific responsibilities for safeguarding. They are accountable to the Board of Trustees for safeguarding matters. In their absence, these responsibilities will be taken by the Head of Central Services (HCS).
        • The Head of Central Services will, working with the Chief Executive, the Head of Services and the Head of Technical Services ensure the implementation of our safer recruitment procedures. They are also responsible for ensuring the implementation of disciplinary procedures and in that regard, will work with the Safeguarding Coordinator (SC), ensuring that procedures are followed consistent with any requirements of the statutory agencies involved in a safeguarding case.
        • Our Safeguarding Coordinator is responsible for the development of our safeguarding practice and will take the appropriate action when abuse is disclosed, discovered or suspected. The Safeguarding Coordinator is responsible for making referrals to the Vetting and Barring Service as required. In their absence, or if they are personally connected in any way to an allegation, the Coordinator’s responsibilities will be taken on by a member of Torch’s leadership team, as decided by the Chief Executive.
        • External safeguarding experts (currently Thirtyone:eight) will be retained to assist with practice development and case management. The case management advice provided by the retained experts will always be complied with unless a different course of action is authorised by any two of the Safeguarding Coordinator, the CEO and the Trustee with a specific responsibility for safeguarding

        Any of the individuals with a specific responsibility for safeguarding as described within this document who is involved in a safeguarding case as the alleged perpetrator or alleged victim will not fulfil their safeguarding responsibility in relation to that case. The decision about who to replace them will be made by the Chief Executive or the Chair of Trustees.

        3. Safer recruitment

        Our safer recruitment procedures consist of the following actions:

        • The agreement of written job descriptions (for employees, Trustees and other volunteers) prior to recruitment. These will clearly set out the responsibilities of the role and the role holder’s general or specific responsibility for safeguarding.
        • When advertising a role that works with adults at risk and/or children (or has oversight responsibility for those who do), the advertisement will make it clear that an appointment is subject to a DBS check (or appropriate national equivalent). The level of check will depend on the specific requirements of the role and will always comply with the criteria set by the national government for checks.
        • Application forms will be used for all recruitment and will require applicants to provide the details of two referees, at least one of whom (when relevant) will be able to, and will be asked, to comment on the applicant’s suitability to work with adults at risk and/or children.
        • Interviews will be carried out by a minimum of two people, at least one of whom will have received training in safer recruitment.
        • Roles requiring work with adults at risk or children will include specific safer recruitment questions during the interview.
        • References, a Self-Disclosure certificate and, where required, a DBS (or equivalent) check must be satisfactorily completed before an individual can start work with Torch.
        • By exception, and with the approval of the Head of Central Services, an individual may start work with Torch ahead of the receipt of the disclosure check, but must never work with adults at risk or children without close supervision until the check is received.
        • If a DBS contains adverse information, the Head of Central Services, along with the Safeguarding Coordinator and other relevant Head of Service, will undertake a risk assessment to determine if an offer of employment/work may be made. In all such cases, the decision made will ‘err on the side of caution’ to protect those at risk. For existing workers whose DBS contains adverse information, a decision will be made as to whether the disciplinary process should be followed.
        • DBS checks (or equivalent) will be undertaken by the agents commissioned by Torch to perform this task (currently undertaken by Disclosure Services). Torch will not accept the checks carried out by other organisations, other than checks which are registered with the update service.
        • DBS checks will be renewed every three years where work for Torch has been continuous during that period. If the break from work has exceeded a year, and Torch has not retained contact with the individual, a new check will be required before the worker can recommence working for Torch with adults at risk or children.
        • A computer record of the DBS certificate number will be stored in a secure location. No copies of certificates will be stored, in any format.
        • Torch will reimburse employees (and, as far as it is relevant, volunteers) for any costs they incur through the checking process.
        • All new workers will receive an induction from Torch and this will cover their responsibilities in relation to safeguarding.
        • Safeguarding training will be delivered thereafter consistent with a training needs assessment and refresher training will be given, normally every three years.

        4. Working with offenders

        When a person attending a Torch activity as a guest or client is known to have committed an offence against children or adults at risk of harm, or a serious allegation against them has been made, the SC and, as relevant the Holiday SC, will ensure that the person is supervised, with boundaries put in place which they will be expected to keep. The person will be offered pastoral care.

        5. Partnerships

        The adoption and implementation of a safeguarding policy and associated procedures is the responsibility of partner organisations. Torch will not partner with those who do not have a safeguarding policy and procedures in place.

        We will consider and respond appropriately to requests to support partner organisations in their management of safeguarding cases which affect Torch and its clients. Such requests should be made to the Safeguarding Coordinator.

        If a partner’s safeguarding case involves Torch Trust or one of its workers or representatives or it may affect the reputation of Torch Trust, we would expect the matter to be reported to Torch’s Safeguarding Coordinator unless the partner is instructed otherwise by their responsible safeguarding person or a statutory agency.

        6. Management of concerns

        The following procedures must be followed in all instances. A simplified process diagram is appended (Appendix 4).

        6a Responding to concerns – all Torch workers (other than on Torch Holiday events)

        If you have a concern about an adult or child who is associated with Torch, you should:

        1. Recognise that abuse may be taking place
        2. Record all of the information that you have received. If a disclosure is made to you, do not promise to keep the matter secret, but explain that you will need to inform the people who have responsibility for responding to such disclosures
        3. Report the concern to the Safeguarding Coordinator (SC). You should never investigate the concern but should always share the concern with the SC even if you do not have consent to do so.
        4. Never share any information about this case (either in writing or orally) with anyone not mentioned in these procedures.

        The only exception to this process is if you think that anyone is in immediate danger of harm, in which case you should immediately call the Police on 999 before taking steps 2 and 3.

        If you are not able to contact the Safeguarding Coordinator (currently Keren Mallinson), try to make immediate contact with one of the individuals listed on the cover sheet. If they are also unavailable, contact Torch’s retained safeguarding advisers (currently thirtyone:eight on 0303 003 1111) and seek advice from their helpline (option 2). Make it clear to them that you are calling on behalf of Torch and have not been able to contact anyone with a safeguarding responsibility within the organisation. Follow the advice which the advisers give you. As soon as you can (and always within the day) email or call the SC to make them aware that you have contacted the advisers. (The advisers will send a written copy of the advice they give to you to the SC within approximately 24 hours.)

        6b Responding to concerns – all workers on Torch Holidays only

        Every Torch Together holiday will have an appropriately-trained person to be the holiday’s Safeguarding Coordinator (HSC).

        If you have a concern relating to an adult or child who is attending the holiday, you should:

        1. Recognise that abuse may be taking place
        2. Record all of the information that you have received If a disclosure is made to you, do not promise to keep the matter secret, but explain that you will need to inform the people who have responsibility for responding to such disclosures
        3. Report the concern to the Holiday’s Safeguarding Coordinator (HSC) as quickly as possible, and always the same day. You should never investigate the concern but should always share the concern with the HSC even if you do not have consent to do so.
        4. Never share any information about this case (either in writing or orally) with anyone not mentioned in these procedures.

        The only exception to this is if you think that anyone is in immediate danger of harm, in which case you should immediately call the Police on 999 before taking steps 2 and 3.

        The HSC will, on receipt of this information, contact Torch’s retained safeguarding advisers, Thirtyone:eight for advice and then notify Torch’s overall Safeguarding Coordinator(SC).

        The advice given by the advisers must be followed unless the SC, following the agreed procedures, notifies the HSC otherwise.

        The SC will liaise with the HS about their relative involvement in taking forward the advice given by the advisers but, as a general expectation, the actions to be taken by the HSC will relate to those actions pertinent to the holiday only. Matters such as making referrals to statutory agencies etc will normally be undertaken by the SC and the procedures in the following sections will be followed.

        The HSC will forward all documentation and relevant information to the SC in a timely fashion, as requested by the SC.

        6c Responding to concerns – Safeguarding Coordinator

        As soon as the Safeguarding Coordinator is made aware of the concern, they will contact Torch’s retained safeguarding advisers for advice, unless already done so by the Holiday Safeguarding Coordinator (as above).

        The advice of Thirtyone:eight will be followed unless a decision to do otherwise is made by any two of the Safeguarding Coordinator, the Chief Executive and the Lead Trustee for Safeguarding. A full record of their decision-making will be retained in such circumstances.

        In all cases, consideration should be given to the potential requirement to make a referral to the Disclosure and Barring Service (or equivalent) and/or the Charity Commission. Consideration should be given also to any requirement to notify Torch’s insurers. This matter will need to be considered throughout the management of a case as more information becomes known.

        6d Referral to a statutory agency – Safeguarding Coordinator

        For adults at risk of harm, concerns will only be referred to the Police or Social Services without consent where the alleged victim of abuse lacks the mental capacity to make such a choice, or there is a risk of harm to others or in order to prevent a crime occurring. If there are concerns about an adult’s mental capacity, the Safeguarding Coordinator will contact the relevant Local Authority’s Safeguarding team for advice.

        Subject to the above, if the Safeguarding Coordinator is advised by Thirtyone:eight to refer the matter to a statutory agency, that must be done without delay – and always within 24 hours. Depending on the advice received, and the context, the referral may be to the Police, a Social Services team or, if the allegation is made against someone who works in regulated activity with children, to the Local Authority Designated Officer (LADO) or equivalent role in the UK nations other than England.

        In cases where a referral to a statutory agency has been made, the person who is the alleged perpetrator must not be informed of the concerns unless the Safeguarding Coordinator has been instructed to do so by a statutory agency.

        The advice of the statutory agency must always be followed and Torch will not investigate the matter of concern unless asked to do so by the appropriate statutory agency.

        The Safeguarding Coordinator will liaise with the statutory agencies about the timing of any internal investigations and implementation of Torch’s disciplinary procedures, such as suspension.

        Some cases which are referred to a statutory agency, may not result in them undertaking an investigation or their investigation is inconclusive. In such cases, an internal investigation is likely to be required. It is likely that the statutory agency will provide directions regarding this course of action, but if there is any doubt, the advice of Thirtyone:eight should be sought.

        6e Internal investigation – Safeguarding Coordinator, Head of Central Services, Head of Technical Services and/or Head of Services, Chief Executive, Lead Trustee for Safeguarding, Chair of Trustees.

        An internal investigation will take place after the referral process to the statutory agency has been completed (see above) or consistent with the advice of Thirtyone:eight.

        Such an investigation may take place under the disciplinary process or may lead to that process being invoked. It may result in disciplinary measures being taken against a worker, including dismissal for gross misconduct.

        The relevant members of the Leadership Team, must consider with the Safeguarding Coordinator, whether it is appropriate to suspend the person against whom allegations have been made whilst the investigation is taking place.

        An appropriate person will be asked to carry out the investigation. This may be one of the people named in this document, but it does not have to be. The investigation may be undertaken by someone independent of Torch. The Investigator must have experience of undertaking investigations of a safeguarding or similar nature or must receive training to be able to do so.

        The Investigator will be issued with appropriate terms of reference. Authority for signing off the terms of reference lies with the Safeguarding Coordinator, in consultation with the Lead Trustee for Safeguarding for any investigation held prior to the disciplinary process. Authority for signing off an investigation within the disciplinary process lies with the relevant Head of Department. If any of these individuals are the subject of the investigation, as relevant, the authorisation is carried out by the Chief Executive or Chair of Trustees.

        The Investigator will have the authority to require any information or documents to be submitted for the investigation, or for individual employees to submit themselves for interview. The report must be concluded in a timely manner and its findings acted on. At this stage, further advice from Thirtyone:eight may be sought.

        6f Support – Safeguarding Coordinator with Head of Central Services

        Support (which may range from pastoral care to professional counselling, depending on case circumstances) should be offered to all parties who are known to Torch and are involved in a safeguarding case, including the alleged victim and the individual making the referral. This will be done, where appropriate, in consultation with the statutory agencies involved as they may be providing support of their own.

        If a case is not referred to a statutory agency as the alleged victim/s was able to give consent but withheld consent, they should also be given clear information about the options available to them to resolve the situation, including how to report the matter to Social Services or the Police. Advice regarding this and potential signposting to other agencies will be sought from Thirtyone:eight.

        For the alleged victims of abuse in particular, their need for support may be later as well as immediate. At the closure of a case, consideration should be given to Torch providing longer-term support or signposting to support services.

        6g Case Review – Safeguarding Coordinator, relevant Leadership Team members, Lead Trustee for Safeguarding

        At the closure of a case, the SC in conjunction with the relevant member(s) of the Leadership Team and the Lead Trustee for Safeguarding will review the handling of the case, the efficacy of procedures so that lessons can be learned and any needed improvements made.

        7. Data Protection

        The requirement to keep data confidential will be adhered to in all safeguarding matters and personal data will be shared only when there are legitimate grounds for doing so.

        Full and accurate records will be maintained during the undertaking of a case. These records will be stored electronically within the Safeguarding folder. Access to this folder is limited to Torch employees who have a specific responsibility for safeguarding.

        All safeguarding records will be kept for at least 90 years.

        8. Complaints

        If you are not satisfied with the implementation of Torch’s safeguarding policy by those associated with Torch, either contact the Chief Executive, the Lead Trustee for Safeguarding or the Safeguarding Whistleblowing Hotline. Contact details are on the front cover and in Appendix 3. A copy of our complaints and feedback policy is available on request.

        Torch workers are encouraged to use the charity’s whistleblowing procedures to raise concerns about any form of illegality, injustice or breach of health and safety which has occurred or is likely to occur. Full details are contained within the Employee Handbook.


        Appendix 1

        Types of abuse

        Abuse and neglect are forms of maltreatment of a child or adult at risk. Abuse can take many forms but some of the more common forms are listed below. Some forms of abuse have differing definitions in relation to adults at risk and children.

        Type of abuse

        Adult at risk

        Child

        Physical

        Inflicting pain, physical injury or suffering to an adult at risk

        Actual or likely physical injury to a child or failure to prevent injury to a child. Physical harm may be caused when a parent or carer fabricates the symptoms of illness in a child.

        Emotional (psychological)

        The use of threats, fear or power gained by another adult’s position to invalidate the person’s individual wishes. (see also spiritual abuse below)

        The persistent, emotional ill-treatment of a child that affects their emotional and behavioural development. It may involve conveying to a child that they are worthless and unloved, inadequate or that they are given responsibilities inappropriate for their age.

        Sexual

        The involvement of a person in sexual activities or relationships that either they have not consented to or they cannot understand. This may include unwanted physical contact or the use of offensive or suggestive language.

        Forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. This includes non-contact activities, such as involving children in looking at sexual activities, or contributing to the production of pornographic material or encouraging them to behave in sexually inappropriate ways.

        Neglect

        A person’s wellbeing is impaired and their care needs are not met. Neglect may be deliberate or may occur as a result of not understanding what someone’s needs are

        Adults failing to care for children and protect them from danger, seriously impairing the child’s health and development. Neglect may occur during pregnancy, damaging the baby’s development in the womb.

        Financial

        The misappropriation, embezzlement, or theft of property, money or possessions, including in connection with wills.

        Spiritual

        Forcing people to accept religious ideas or values. This may include the misuse of authority or leadership, oppressive teaching, unsolicited healing or deliverance ministries and extreme pastoral interference in pastoral matters which may reduce individual choice and responsibility

        Discriminatory

        Any form of abuse based on discrimination because of a person’s race, culture, gender, age, disability etc (current version) or Any form of abuse, including harassment, slurs and similar mistreatment because of race, gender and gender identity, age, disability, sexual orientation or religion (31:8)

        Institutional

        The mistreatment or abuse of a person by an institution or organisation or individuals within it. It can occur through repeated acts of poor or inadequate care and neglect or poor professional practice or ill-treatment.

        Domestic

        Any threatening behaviour, violence or abuse between adults who are, or have been, in a relationship, or between family members. Domestic abuse can be physical, sexual or psychological. Usually there is a pattern of abusive and controlling behaviour where an abuser seeks to exert power over their family member or partner.

        Cyber

        The use of information technology (including social media) to reportedly harm or harass other people in a deliberate manner

        Self-harm

        The intentional damage or injury to a person’s own body

        Self-neglect

        A person neglecting to care for their own health, hygiene or surroundings, including behaviours such as hoarding

        Modern slavery

        The practice of treating people as property. It includes bonded labour, child slavery, sex slavery and trafficking.


        Appendix 2    

        Key legislation relating to Safeguarding

        This list is not exhaustive but contains key legislation and associated guidance relevant to Torch’s safeguarding policy and procedures. Legislation may vary throughout the United Kingdom and due diligence must be undertaken to ensure compliance with the relevant nation’s legislation.

        The Children’s Acts 1989 and 2004

        Working Together to Safeguard Children 2018

        The Care Act 2014

        Safeguarding Vulnerable Groups Act 2006

        Sexual Offences Act 2003

        Mental Capacity Act 2005

        Social Services and Well-being (Wales) Act 2014

        Children and Young People (Scotland) Act 2014

        Adult Support and Protection Act (Scotland) 2007

        Co-operating to Safeguard Children and Young People in Northern Ireland 2017

        Safeguarding for Northern Ireland Procedures Manual 2017

        Adult Safeguarding: Protection and Prevention in Partnership Northern Ireland 2015

        The United Nations’ Universal Declaration of Human Rights

        The United Nations’ Convention on the Rights of the Child


        Appendix 3

        Contact information and sources of help and advice

        Torch contact details are included on the front sheet of this document

        Other contact details

        In emergency, contact the Police on 999. For non-urgent cases, call 101

        NHS Direct: call 111

        Concerns about a child:  NSPCC 0808 800 5000

        Safeguarding Whistleblowing Hotline (children) 0800 028 0285

        National Domestic Abuse helpline 0808 200 247


        Appendix 4

         Management of concerns process diagram

        (An amended version of this process will be made available to the Torch Holidays’ Safeguarding Coordinators and all workers on those events)

        If the person is at immediate risk of harm:

        1. Worker calls the Police on 999
        2. Worker records details and passes them to the Safeguarding Co-ordinator
        3. Safeguarding Co-ordinator calls Thirty-One Eight for advice
        4. Safeguarding Co-ordinator implements advice

        If the person is not at immediate risk of harm:

        1. Worker records details and passes them to the Safeguarding Co-ordinator
        2. Safeguarding Co-ordinator calls Thirty-One Eight for advice
        3. Safeguarding Co-ordinator implements advice

        In both instances, after advice has been received, and in consultation with statutory agencies as relevant:

        1. Support offered to all parties
        2. Consideration of an internal investigation
        3. Case reviewed at closure for future learning
        4. Case documentation retained securely