ManDad Media Ltd. (“ManDad”) is committed to safeguarding the welfare of all children and young people who are involved, in any way, with ManDad’s work. The guidelines and procedures set out in this policy will apply equally to any vulnerable adults involved in Mandad’s work. Any reference to a child or a young person should be read as a reference to a vulnerable adult also.
- Children and young people should be treated with care, respect and dignity. For the purposes of the Disclosure and Barring Service (and previously the Criminal Records Bureau), a child is defined as someone who is under 18 (or under 16 if the child is employed). ManDad also uses this definition.
- Everyone who works for or with ManDad, in any capacity, has a responsibility for the protection and welfare of the children and young people we meet in our work. We understand that people who work for ManDad will be perceived by children and young people as trustworthy.
- ManDad acknowledges that some of its employees or associates may be or become vulnerable adults. Where this is the case, ManDad will carry out appropriate risk assessments and implement any adjustments necessary to ensure that they can work safely.
- ManDad’s staff should never be alone with a child or young person in the course of their work, and any activity with children and young people should be planned accordingly. Mandad’s Safeguarding Behavioural Guidelines form part of this document and must be followed by all staff.
- Any offer of work [including volunteering] made by ManDad in respect of a position which may involve working directly with children, young people or vulnerable people will be subject to a satisfactory DBS (formerly known as a CRB) check. This applies to individuals engaged on any type of contract (e.g., employment, casual or freelance contracts).
- A risk assessment should be carried out whenever children, young people or vulnerable people undertake activities with MadDad. Speak to Lordë De Laurentiis or Matthew Carvell to arrange for a risk assessment to be performed.
- Children and young people may not carry out paid work for ManDad unless we have the consent of appropriate adults – parent, carer, guardian or local authority [where relevant].
- Managers offering work experience placements must do so in compliance with ManDad’s work experience policy.
3. Nominated Safeguarding Managers
Lordë De Laurentiis (Managing Director) and Matthew Carvell (Operations Director and Head of Professional Services) have responsibility for Mandad’s Safeguarding Policy. They are Mandad’s “Safeguarding Managers”.
- Ensure that ManDad’s staff are aware of the requirement to work in compliance with Mandad’s Safeguarding Policy.
- Be the point of referral for questions in relation to ManDad’s Safeguarding Policy.
- Be the point of referral for anyone who, during the course of their work for or other involvement with ManDad, believes that a child or young person may be at risk of harm, is told by a child or young person of a child welfare issue; or believes that a person may pose a risk of harm to any child.
- Keep a record of any safeguarding issues which arise.
The Safeguarding Managers will receive training on safeguarding issues at least once every two years.
4. DBS Checks
ManDad insists on a satisfactory DBS certificate where staff are or will be working directly with children.
If an individual begins work with ManDad before a satisfactory DBS check is received, their manager must, with input from the Safeguarding Managers, complete a risk assessment. Such a risk assessment is likely to mean that the individual will be placed on restricted duties and cannot work unsupervised with children or young people.
The individual’s manager will be responsible for ensuring a plan is in place in respect of these restricted duties and this will be authorised by a more senior manager. If restricted duties are not possible, the individual will not be allowed to start work with ManDad.
5. Rehabilitation of Offenders Act
In most circumstances, individuals who are convicted of offences are regarded as “rehabilitated” after a defined period of time and at that point, their conviction is said to be “spent”. Normally, once a conviction is spent, the convicted person does not have to reveal or admit its existence and the conviction is treated as though it had never occurred. However, where an individual is required to work with children, young people or vulnerable people, all convictions (whether spent or unspent) will be disclosed by the DBS.
6. Online Grooming
ManDad will not tolerate inappropriate conduct online, which includes but is not limited to: discussing children in an inappropriate manner, requesting photographs/ images of children, sharing images of children other than the normal posting of shareable family-friendly content as per other social platforms (e.g. Facebook, Instagram, Twitter); discussing or alluding to sexual contact with a minor (anyone aged under 18).
Adults are not to attempt to make contact with children [online or otherwise] or via any of ManDad’s activity, work, or social media channels.
Any concerns you have that a child or young person may be being “groomed” online must be referred immediately to the Safeguarding Managers.
This policy will be updated where new risks are identified or technology advances give rise to necessary safeguarding provision.
7. Children of Employees
We recognise that ManDad’s employees may bring children with them to offices or work-related activities and events. If it is necessary for you to bring your children to work, you must have the permission of your manager and your children must remain under your direct supervision at all times.
8. School Visits and Events
If your team’s work involves a visit to any nursery, school, youth group or similar establishment, you must send the school or event organisers a copy of ManDad’s Safeguarding Policy before the visit or event. At an early stage in the planning of any such visit or event, you must ensure that you have contact details for a nominated person from the school or event organisers who holds responsibility for safeguarding the welfare of children and young people during with the activity (the “Safeguarding Contact”).
- ManDad’s staff attending any visit or event must do so in full compliance with this Safeguarding Policy, and ManDad’s Safeguarding Behaviour Guidelines.
- Any member of ManDad’s staff who, through the course of their work, becomes concerned about the welfare of a child must share that concern immediately with the Safeguarding Contact, or if that is impossible, with ManDad’s Safeguarding Managers.
- If the notification is made directly to the school, the staff member who makes the notification should follow up immediately on their return to the office with ManDad’s Safeguarding Managers.
9. Health and Safety
Any activity which involves a child or young person must be subject to a risk assessment. Lordë De Larentiis or Matthew Carvell can arrange for a risk assessment to be performed.
The risk assessment must set out what arrangements are in place for their care and supervision e.g., by a school, parent, guardian or chaperone and how these will be communicated to the appropriate parties.
The health and safety controls in place will include those needed for:
- The people the children or young person will meet.
- The environment they will be in.
- The equipment they will be using.
- The activity they will be doing.
- The way the activity will be organised and carried out.
- The pattern and hours of their activity.
- Any transport arrangements.
10. Transport and Accommodation
If children are being transported on behalf of ManDad, they must be accompanied by their parent, guardian, chaperone or teacher. ManDad has a duty of care for young persons between the minimum school leaving age and under 18 if they are travelling on behalf of ManDad.
If any ManDad activity requires a child or young person to stay away from home overnight, the arrangement must first be approved by Mandad’s Safeguarding Managers. The child or young person must be accompanied by their parent or guardian.
11. Secure Handling and Safekeeping of DBS Disclosures
ManDad complies fully with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of DBS disclosures (each a “Disclosure”) and Disclosure information. ManDad also complies fully with its obligations under the Data Protection Act 1998 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information.
Storage and access
Hard copies of DBS information are kept securely in locked cabinets by the HR team for the periods of time detailed in the ‘Retention’ paragraph below.
In most cases, Mandad will keep an electronic record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was requested, the unique reference number of the Disclosure and the details of the recruitment or other decision taken. These electronic records are password-protected and access will be restricted to ManDad’s Safeguarding Managers and the appropriate HR Business Partner for your division of the business. These records will be retained until either you leave the business or your DBS record is updated by making a subsequent check.
Disclosure information is only passed to those who are authorised to receive it in the course of their duties. ManDad recognises that it is a criminal offence to pass this information to anyone who is not entitled to receive it. ManDad maintains a record of all those to whom Disclosures or Disclosure information has been revealed.
Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.
Once a recruitment (or other relevant) decision has been made, ManDad will shred the disclosure certificate unless there is a reasonable likelihood of the decision being disputed, in which case it will keep a hard copy of the certificate until the dispute has been resolved. The maximum period for which certificates would be retained is in accordance with the applicable data protection legislation.
If, in very exceptional circumstances, ManDad considers it is necessary to keep hard copies of this information for longer than six months, ManDad will consult the DBS and give full consideration to the data protection and rights of the individual before doing so. Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will prevail.
All records will be deleted or destroyed securely (for example, by shredding) when they are no longer required or the prescribed retention period has elapsed.
Appendix – Safeguarding: Behavioural Guidelines
- Everyone who works for ManDad in any capacity (including all staff and anyone working for ManDad on a freelance or casual basis) will follow all of these Behavioural Guidelines whenever their work brings them into contact with children, young people or vulnerable people. All references to “child” or “children” in these Behavioural Guidelines should be read as a reference to children, young people and vulnerable people.
- Everyone who works for ManDad has a duty to promote open, honest, trustworthy and respectful relationships with the people we meet in the course of our work.
- Everyone who works for ManDad will demonstrate proper personal and professional behaviour at all times during their work.
- Everyone who works for ManDad will behave responsibly during work-related social events, especially if children are present.
- Everyone who works for ManDad will work in an open environment, avoiding private or unobserved situations with children and encouraging open communication with no secrets. We will ensure that the child is accompanied by a parent or guardian and wherever possible, all activities will take place in open-plan environments. If an activity must happen in a room rather than an open-plan space, no adult should ever be left on his or her own with any child or children – two adults should always be present. If an emergency means that an adult is left alone with any child or children, the door to the room must remain open at all times.
- Anyone working with children as part of their role with ManDad will maintain a safe and appropriate distance at all times. We will engage in the minimum of physical contact with the child, and if any necessary physical contact is necessary, it will be in public and appropriate. ManDad staff will not do things of a personal nature for any child that he/she is able to do independently.
- ManDad’s staff will not engage children in discussions relating to personal matters (including any discussion of problems at home or emotional issues). Where discussion of a personal matter is the subject of the activity (for example, interviewing the subject of a real-life story), we will ensure that a parent or guardian is present throughout the discussion.
- If a child shares concerns with us, we will listen, stay calm, be reassuring, avoid judgements and we will never promise to keep the disclosure secret. We will then make an immediate report to an appropriate person – either the nominated Safeguarding Contact from the child’s school or similar, or to one of ManDad’s Safeguarding Managers. We will not share the child’s disclosure with any other person. Staff will also complete an Incident Report – to be securely stored by the Safeguarding Managers.
- ManDad’s staff will respond appropriately to all concerns about a child’s welfare, escalating the matter promptly in accordance with ManDad’s Safeguarding Policy.
- Inappropriate or illegal behaviour will be treated extremely seriously and will result in action being taken in accordance with ManDad’s disciplinary policy.
ManDad Media Ltd. Safeguarding Managers:
Lordë De Laurentiis – Managing Director
Matthew Carvell – Operations Director & Head of Professional Services