Policies

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Privacy Policy

from More Positive Me

General

We collect and process your data in order to provide you with More Positive Me’s services. We keep your data secure and will not share it beyond More Positive Me.

You can contact us at any time to ask what data we hold about you (a Subject Access Request) and to ask us to delete any data we hold about you. We will respond within 30 days. Our main contact for data enquiries is Jeanette Brown morepositiveme@gmail.com. If you’re unhappy with the way we’ve handled your data or your request for access to it, you’re entitled to make a complaint to the Information Commissioner’s Office.

Email News

If you sign up to the newsletter mailing list, we will hold and process your data (name, email address and organisation name and job title if you provide these) in order to send you the newsletter. We will use tracking data in our mailing software (Mailchimp) to analyse engagement with the newsletter and to improve its content and distribution on an ongoing basis.

We will not use your data for any other purpose or share it with any other organisation. You can opt out of receiving the newsletter at any time using the link in the footer of the email or by contacting info@morepositiveme.co.uk.

21 Days to a More Positive Me mailing list

If you opt in to our mailing list for 21 days self-care program, we will only email you for the 21 days of the program. You will need to sign up to the newsletter mailing list to stay in touch. We will not use your data for any other purpose or share it with any other organisation. You can opt out at any time by clicking on the unsubscribe link at the bottom of the email or email us morepositiveme@gmail.com.

Social Media Platforms

This applies to More Positive Me’s accounts at www.facebook.com/Morepositiveme, including groups and www.twitter.com/morepositiveme. These platforms operate on their own terms and conditions which visitors to More Positive Me’s pages should read with regard to their privacy and personal data. Twitter’s privacy policy is here and Facebook’s privacy policy is here. Our website offers social sharing buttons which help users share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

More Positive Me will monitor users’ behaviour on our social media platforms using the tracking data gathered by the respective platforms. We will use this data in anonymised form and will not link it to any identifying information or use it for profiling individual users.

More Positive Me will not use any of our social media platforms to ask for personal or sensitive information and encourages users wishing to discuss sensitive information to contact us through primary communication channels such as by telephone or email.

Reminder

You can contact us at any time to ask what data we hold about you (a Subject Access Request) and to ask us to delete any data we hold about you. We will respond within 30 days. Our main contact for data enquiries is Jeanette Brown morepositiveme@gmail.com.

If you’re unhappy with the way we’ve handled your data or your request for access to it, you’re entitled to make a complaint to the Information Commissioner’s Office.

Published: 24th May 2018

Reviewed annually 28th February 2020

Revision: 1

1. Introduction

1.1 More Positive Me has a responsibility under the Children Act 2004 and the Care Act 2014 for ensuring that it provides a service having regard to safeguarding and promoting the welfare of children, young people and adults at risk. 

The definition of a young person in this document is anyone under the age of 18 years.

1.2 The policy applies to all staff, including Directors and volunteers, sessional workers, agency staff and students working on behalf of More Positive Me. All will be referred to as staff within the policy.

1.3 All Directors need to be aware of how their staff interact with children, young people and adults at risk, providing appropriate training on safe working practices and developing safe working environments. Staff should be alert to any indications that a child, young person or adult at risk may need to be safeguarded from harm and who to contact if they have concerns.

1.4 This Policy should be read in conjunction with More Positive Me Policies regarding Boundaries, Confidentiality, Whistle Blowing, Supervision and recruitment. 

1.5 More Positive Me will work to the Policies and procedures of the Local Safeguarding Partners. Staff should be familiar with the appropriate procedures in conjunction with this policy. 

This policy and associated procedures had been prepared with reference to the South West Safeguarding and Child Protection Procedures and Working Together to Safeguard Children (2018 update) which all staff should read and make themselves familiar with.

2. Purpose

2.1 The purpose of this policy is:

• To protect vulnerable children, young people and adults who receive services from More Positive Me;

• To provide staff and volunteers with the overarching principles and procedures that guide their approach to safeguarding individuals.

3. Legal Framework

3.1 This Policy has been drawn up on the basis of law and guidance that seeks to protect children, young people and adults. The key pieces of legislation are detailed below:

• Children Act 1989

• United Convention of the Rights of the Child 1991

• Human Rights Act 1998

• Sexual Offences Act 2003

• Children Act 2004 (amended by the Children and Social Work Act 2017)

• Safeguarding Adults (ADSS 2005)

• Mental Capacity Act 2005

• The Disability Discrimination Act 2005

• Equality Act 2010

• Safeguarding Vulnerable Groups Act 2006

• Protection of Freedoms Act 2012

• Working Together to Safeguard Children (HMG 2015) updated 2018

• Police and Criminal Evidence Act 1990

• NHS and Community Care Act 2014

• Data Protection Act 2018

4. Principles

4.1 More Positive Me recognise that:

• The welfare of adults, young people and children is paramount, as enshrined in the legislation listed;

• All children, young people and adults, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have the right to equal protection from all types of harm or abuse;

• Some individuals are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues;

• Working in partnership with adults, children, young people, parents, carers and other agencies is essential in promoting an individual’s welfare.

4.2 We will seek to keep children, young people and adults safe by:

• Valuing them, listening to and respecting them;

• Adopting protection practices through procedures and a code of contact for staff and volunteers;

• Ensuring that safeguarding concerns are taken seriously, and that appropriate action is taken;

• Developing and implementing an effective e-safety policy and related procedures;

• Providing effective management of staff and volunteers through supervision, support and training;

• Recruiting staff and volunteers safely, ensuring all necessary checks are made;

• Sharing information about personal protection and good practice with all our service users, staff and volunteers;

• Sharing concerns appropriately, according to More Positive Me procedure, with agencies who need to know and involving service users, children and young people and their parents in the process.

5. Promoting Good Practice

5.1 All incidents of abuse but particularly child abuse and sexual abuse, can arouse strong emotions in those facing such a situation. It is important to understand these feelings and not allow them to interfere with your judgement about the appropriate action to take.

5.2 Abuse can occur within many situations including the home, school and social situations. Some individuals will actively seek employment or voluntary work with young people in order to harm them. All suspicious cases of poor practice should be reported following the guidelines in this document.

5.3 There are several types of abuse, which identified in Appendix 1 for children. These include child sexual abuse, female genital mutilation and honour-based violence. For adults please refer to the Safeguarding Adults Procedure for information applicable to adults. 

5.4 All staff should demonstrate exemplary behaviour in order to protect themselves from false allegations. This includes the use of social media; guidelines are found in Appendix 9.

5.5 Good practice means:

• Always working in an open environment avoiding private or unobserved situations and encouraging open communication.

• Treating all individuals equally with respect and dignity.

• Always putting the welfare of the individual first.

• Maintaining a safe and appropriate distance (e.g. it is not appropriate for staff or volunteers to have an intimate relationship with a service user.)

• Building balanced relationships based on mutual trust and empowering service users to share in decision making. 

• Where children or young people are involved, then including parents or carers where possible. 

• Being an excellent role model – this includes not smoking or drinking alcohol in the company of service users. 

• Giving enthusiastic and constructive feedback rather than negative criticism.

• Recognising the developmental needs and capacity of service users and not pushing them against their will.

• Keeping a written record of any injury that has occurred/evidence of harm, along with the details of treatment given. 

• If the need arises to administer emergency first aid and/or other medical treatment to children or young people, securing parental consent in writing to act in loco parentis. 

• Transporting young people in your car should only be considered where there is no other option, for example an emergency putting the child or young person at risk. However if this does occur then there should also be another child or trusted adult in the car. 

6. Safeguarding Lead

6.1 The safeguarding lead is responsible for managing safeguarding matters within More Positive Me. In the absence of the safeguarding lead or their deputy, concerns should be raised with the appropriate authority in accordance with the procedures in this document and in Safeguarding Vulnerable Adults Policy. The safeguarding lead is:

• Debbie Coleiro – Safeguarding Lead

7. Reporting Safeguarding Concerns

7.1 There is a responsibility to act on any concerns through discussion with the Directors of More Positive Me and contact with the appropriate authorities. Where a concern has been identified by a member of staff with regard to a child or young person then the guidelines outlined in the More Positive Me Safeguarding Flowchart. (appendix 2) should be followed with regard to reporting a safeguarding concern. If the concern is regarding an adult, then refer to the Safeguarding Adult Procedure.

7.2 If there is an indication that there is an immediate risk of harm to the child, young person or vulnerable adult or that they are in immediate risk of harm to the child, young person or vulnerable adult or that they are in immediate danger then it is the staff members responsibility to call 999 and ask for the appropriate service to attend. 

7.3 More Positive Me will work to the policies and procedures of the local Authority Safeguarding Partners. Staff should be familiar with the appropriate local policies and procedures in conjunction with this policy, which may be found by following the links below. Particular attention should be given to reporting concerns, information sharing and escalation procedures.

Devon Children and Families Partnership

Devon Adult Safeguarding Partnership

7.4 The safety of the child or young person or adult will remain the organisations first priority. The individual will be notified of any concern that is discussed with a Director or referred to social care, as long as by doing so they are not at an increased risk.

7.5 An allegation of abuse or neglect may lead to a criminal investigation, so be mindful of not doing anything that may jeopardise a police investigation, such as asking leading questions or attempting to investigate the allegations of abuse.

7.6 In the case of a child or young person, staff should seek to discus any concerns with the family (including the child where appropriate) and where possible seek their agreement to make a referral to social care. This should only be done where such discussion and agreement seeking will not place the child at an increase of significant harm. 

7.7 If the parents, carers or child do not agree to information being shared, this should not prevent referrals where child protection concerns persist. The reasons for dispensing with consent from the parents or carer or child should be clearly recorded and communicated with Social Care.

7.8 In cases where an allegation has been made against a family member living in the same household as the child and it is your view that discussing the matter with the parent would place the child at risk of harm, or where discussing it may place a member of staff/volunteer at risk, consent does not have to be sought prior to the referral being made.

7.9 Staff should comply with the local procedures by following the links to the Safeguarding Partnership Procedures. Reporting Flowcharts can be found in (Appendix 3, 4 and 5)

7.10 Information sharing. The protection of the child, young person or adult is paramount. Data protection legislation does not overrule safeguarding matters. Information relating to the incident and circumstances leading up to the allegation may be shared with other agencies as appropriate. Information should only be shared within the organisation with those who need to know in order to fulfil their duties. For further guidance on Information Sharing, refer to Information Sharing Guidelines (APPENDIX 6)

7.11 Recording Safeguarding Incidents. Safeguarding incidents must be properly recorded. The issue can be reported verbally initially but must be recorded as soon as possible in the service user record and in the safeguarding log. This log will be reviewed by the Safeguarding Lead and Directors.

8. Use of cameras and mobile phones

8.1 The use of a camera or mobile phone to record one to one or group work is only to be done with the consent of the individual and where children or young people are concerned with the permission of the parent. Written permission is to be sought using the Photographic Permission Form (APPENDIX &)

8.2 The use of such images is to be limited to the promotion of the project through our annual reports, reports to funders or other publicity events as agreed with the individuals concerned. The use of photographic or filming equipment is not to be used for any other purposes.

9. Concerns about a member of staff.

9.1 Any suspicion that an individual is being abused by a member of staff or a volunteer should be immediately reported to the Safeguarding Lead, who will take such steps as considered necessary to ensure the safety of the individual in question and anyone else who may be at risk.

9.2 If an allegation is made against a member of staff or volunteer, they may have

• Behaved in a way that has harmed a child or may have harmed a child

• Possibly committed a criminal offence against a child

• Behaved in a way that indicates they may pose a risk of harm to a child.

9.3 The Safeguarding Lead will refer the allegation to the Designated Lead for Allegations or LADO according to local authority procedures. Please refer to the Safeguarding Children Board for the local Authority for guidance on the following correct procedure.

9.4 If, following consideration, the allegation is clearly about inappropriate activity, the Safeguarding Lead will deal with it as a misconduct issue. It is important that this be dealt with by following the guidelines described in Allegations Against Staff (APPENDIX &)

9.5 If the Safeguarding Lead is the subject of the suspicion/allegation, the report must be made to another Director who will refer the allegation to the Designated Lead for Allegations or LADO.

9.6 Raising Concerns. More Positive Me endeavours to provide the highest quality of service at all times, in conjunction with partners and other agencies, However if a staff member does have concerns about poor practice within More Positive Me or elsewhere, then they should first report these to their line manager. If the issue is within More Positive Me and is not addressed, then the Whistleblowing Policy should be used. If the concern is external to More Positive Me, then the Local Authority guidelines should be followed.

10. Safe Recruitment

10.1 More Positive Me subscribe to the safer recruitment principles as recommended by the Local Authority Safeguarding Board.

10.2 These principles include:

• Recruitment documentation will include the organisations commitment to safeguarding

• Applications are scrutinised for the gaps in employment and for safeguarding concerns

• At least one member of the interview panel will have completed the recognised safer recruitment training

• Interviews will include questions relevant to safeguarding

• If a candidate is successful, this will be dependant on satisfactory references and checks

• References will be confirmed and recorded on staff files

• A DBS check must be carried out and the member of staff cannot be in contact with children, vulnerable adults or the service user database until the results are known to be clear of any issue regarding safeguarding.

10.3 Staff members and volunteers will have a thorough induction programme.

10.4 Staff members and volunteers will have a thorough induction programme.

10.4 Staff members would attend foundation training and meet the minimum standard’s set by the Local Authority Safeguarding Board. In addition, any staff member who may be likely to attend Child Protection Conferences or Core Groups should attend an Advanced Safeguarding Training. All training will be renewed in line with Local Authority guidance.

10.5 Staff will have regular supervision arrangements.

Appendices:

1. Definitions of Abuse

2. More Positive Me Safeguarding Flowchart

3. Devon Reporting Flowchart

4. Information Sharing

5. Photographic Permission Form

6. Allegations Against Staff

7. Social Media Guidelines