Safeguarding Children Policy
November 2023
Cross reference: This policy should be used in conjunction with policies and procedures from Derby and Derbyshire safeguarding children partnership: https://www.ddscp.org.uk/
And the NSPCC Safeguarding and Child Protection Standards for the Voluntary and Community Sector: https://learning.nspcc.org.uk/media/1079/safeguarding-standards-and-guidance.pdf
- Introduction
The NSA Therapy Services Ltd is a small social enterprise committed to safeguarding and promoting the welfare of families, children and young people. We have a responsibility to safeguard and promote the welfare of children, as outlined in the Children’s Acts 1989 and 2004 and in Working Together 2018), and to ensure that directors and employees have an awareness of potential indicators of abuse and neglect of children and to be able to respond as appropriate considering their role, to address these concerns. We also have a responsibility to have a safeguarding policy that is easily accessible to members of the organisation and to ensure that directors and employees cooperate and share information with partner organisations to safeguard children. For the purposes of this policy, all children under the age of 18 are referred to as children.
- Purpose
This policy outlines the responsibility and accountability of members of staff, contractors and volunteers, including the directors, to safeguard and promote the welfare of children. It outlines the need for a timely and appropriate response following allegations or concerns about the welfare of children. It aims to give staff a clear understanding of their role and responsibilities for safeguarding children as defined in Working Together to Safeguard Children, 2018.
- Scope
This policy applies to all children up to the age of 18 years (Section 105 Children Act, 1989), whether the children are accessing the services of NSA Therapy Services Ltd or if they are cared for by people accessing our services. It also applies to other children in the wider community who come into our awareness as a result of our work.
- Definitions
A child: The Children Act 1989 defines a child as anyone who has not yet reached their 18th birthday. The child’s circumstances or perceptions of their independence does not alter their status as a child.
Early help: Working Together (2018) identified that early help is more effective in promoting the welfare of the child than reacting later. Providing support as soon as a problem emerges can help to prevent other issues from arising, particularly if provided as part of a support plan in the context of more complex difficulties, including parental mental health issues, substance misuse, and conflict. Early help requires organisations to work together to identify children who would benefit from this early help, undertake assessments of the family’s needs and provide targeted early help services to improve outcomes for the child and their family.
Children in Need are children defined under Section 17 of the Children Act (1989) as those whose vulnerability is such that they are unlikely to reach or maintain a satisfactory level of health or development, or their health or development will be significantly impaired without the provision of services.
Child Protection is part of safeguarding and promoting welfare; it refers to the actions taken to protect children who are suffering or at risk of suffering significant harm, as defined under Section 47 of The Children Act, 1989.
Significant harm is a concept outlined in The Children Act, 1989, as the threshold that justifies compulsory intervention in family life in the best interests of children. Physical abuse, emotional abuse, sexual abuse and neglect are all categories of significant harm.
Contextual safeguarding: As well as threats to the welfare of children from within their families, children might also be vulnerable to abuse or exploitation from outside their families. These extra-familial threats might arise at school, within other institutions, from peer groups or the wider community, or online. Consideration needs to be given to criminal exploitation, trafficking, online abuse, sexual exploitation and the influences of extremism and radicalisation.
- Duties
NSA Therapy Services Ltd currently has two directors, Nicola Armstrong, Integrative Counsellor and Lee Armstrong. Nicola Armstrong is the current safeguarding lead. Other staff members hold safeguarding responsibilities outlined in this document.
The safeguarding lead will participate as appropriate in any safeguarding reviews convened by external safeguarding agencies (i.e. local authorities involved with families using NSA Therapy Services Ltd). The safeguarding lead will also ensure that all new staff members are provided with access to safeguarding training via the local safeguarding board, and this training is repeated on a three-yearly basis.
In addition, the lead and any additional employees will:
- Safeguard and promote the welfare of children.
- Be knowledgeable about the issues of safeguarding and protecting children.
- Be aware of NSA Therapy Services Ltd and the local safeguarding board’s procedures and protocols.
- Access safeguarding training appropriate to their role and ensure that regular updates are accessed to equip them with the knowledge and skills required to safeguard and protect children.
- Maintain accurate contemporaneous, legible and complete health records, including discussions with other professionals about families accessing our services.
- Access advice, support and supervision in relation to safeguarding, with supervisors external to NSA Therapy Services Ltd if required.
- Disclosure and Barring Service (DBS)
The Disclosure and Barring Service (DBS) helps employers make safer recruitment decisions. It also prevents unsuitable people from working with vulnerable groups, including children, through its criminal record checking and barring functions. An employer may request a criminal records check processed through the Disclosure and Barring Service (DBS) as part of its recruitment process.
As part of the check on directors and new members of T NSA Therapy Services Ltd, an enhanced DBS check will be completed through an umbrella body, for all service employees, if required. All directors who are working directly with service users will hold a current Basic DBS check.
- Processes and procedures
- Principles of Safeguarding Children
It is not assumed that parents accessing NSA Therapy Services Ltd, because of relationship difficulties will struggle to provide safe and effective care for their children. However, this might be the case, and relationship difficulties (e.g. attunement difficulties or parental conflict) can be associated with poor outcomes for children. Secondary factors, such as deprivation, housing difficulties, stressed family relationships, and societal prejudice or racism, can compound vulnerability. Additional conflict or dynamic shifts might be experienced in families with adolescents, with potentially increasing intensity or volatility. The impact on children of some of these difficulties can create a repeating cycle of abusive behaviour and coping strategies that are harmful in themselves. These issues must be addressed appropriately and, where necessary, with multi-agency, multidisciplinary working.
Equality and Diversity
It is essential that staff within NSA Therapy Services Ltd are sensitive to differing but safe parenting styles, practices and cultures. We must not discriminate based on age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion and belief, sex or sexual orientation. All of NSA Therapy Services Ltd staff must be aware of the broader societal factors that serve to discriminate against people of colour, religious groups, the LGBTQIA community and people with disabilities. An awareness of social justice is central to NSA Therapy Services Ltd's ethos.
- Information Sharing
To ensure effective safeguarding arrangements:
- The child’s needs will be at the forefront of our thinking, including prioritising the child’s safety over concerns about confidentiality. However, this balance will be approached thoughtfully and as transparently as possible.
- Effective information sharing between local agencies on safeguarding matters is essential for early identification of need, assessment and service provision to keep children safe.
- We will be clear in outlining our purpose for sharing or requesting information of a sensitive nature.
- Consideration will be given to whether parents will be informed of the need to share information with other agencies, with a preference for discussing this collaboratively with parents where possible. It is recognised that information might need to be shared without consent in a small minority of cases where the risk of escalation is noted.
The Data Protection Act, 2018, contains “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, or if gaining consent would put that child at increased risk.
Information shared must be:
- Necessary and proportionate: the minimum necessary to communicate the concerns / risks needed.
- Relevant
- Adequate, in order to ensure that it is understood,
- Accurate and up to date,
- Timely, in order to reduce the risk of missed opportunities.
Decisions about sharing information of a sensitive nature should be discussed in supervision. If there is any doubt within this discussion, the therapist’s legal advice line should be accessed (through the indemnity insurance provider) for a further view. These conversations should be recorded in the professional’s notes, indicating the action advised and then the action taken.
Agreement for any referrals to children’s social care should be sought from the parents as far as possible. Parents should be offered the opportunity to contact these services themselves and provide the details to NSA Therapy Services Ltd professional after the fact. This should then be confirmed by NSA Therapy Services Ltd professional.
- Record keeping
Information is sought on parenting responsibilities / parent-child relationships in the self-referral document sent to everyone seeking services from NSA Therapy Services Ltd, along with their GP details, address and contact details. This is considered to be essential data collection and processing.
Any discussion about safeguarding must be recorded by the practitioner dealing with that particular family. At the current time, these notes are handwritten (at a minimum) and then stored appropriately in a secure manner to maintain confidentiality. These notes should indicate that the concern has been discussed in supervision and potentially with the legal advice line of the safeguarding lead, if needed. Actions taken should also be recorded. The discussion regarding the consent of the parent / carer of the child to share information with safeguarding agencies, if decided, should also be recorded.
An assessment of the child’s ability to give their own consent to information sharing will be undertaken if there are indicators that the child might be competent in this regard (e.g. over the age of 12). Children over the age of 16 will be assumed to have the capacity to give or withhold consent. However, if there is a risk of significant harm, NSA Therapy Services Ltd professionals will still be required to consider information sharing with safeguarding agencies even if the child does not want this to be the case.
Where a child is not able to consent for themselves, one parent with parental responsibility will be asked to consent on their behalf. Where parents are separated, attempts will be made to obtain consent from both parents. Disagreements of consent between parents will not prevent an intervention from being offered to a child or information being shared about that child if the practitioner and one parent believe this to be in the best interests of the child. However, this issue can be discussed with the safeguarding lead’s legal advice line if needed. If adults or children with the capacity to consent have additional needs, these need to be considered by NSA Therapy Services Ltd. These might be, for example, interpreters or materials translated into other languages or BSL.
The local safeguarding board information can be used to help practitioners to decide whether a safeguarding referral should be made to the local authority. The local authority in question will be determined based on the postcode of the child’s address for at least half of their time.
If the threshold for significant harm is unmet, consideration can be given to referring to the Early Help team in the relevant local authority. If the threshold is unclear, a discussion with the local MASH team can help decide on a course of action. This should also be documented clearly in the notes relating to that specific family.
Procedure when there are concerns (summary)
- If anyone who is associated with NSA Therapy Services Ltd has concerns about the welfare of a child at risk, they must raise those concerns and inform the safeguarding lead / one of the directors without delay.
- If a child discloses that they are being or have been abused, this information must be taken seriously and following a discussion in supervision, if considered appropriate and necessary, the information must be passed on to the relevant agencies without delay.
- Discussion with the parents must always be considered, and if there is no evidence to suggest that this will increase the risks to the child, the parents must be informed that a referral is being made to the local authority. If appropriate, the parents can be given the option of engaging the local authority themselves with NSA Therapy Services Ltd, providing supporting information and follow-up.
- If there are difficulties regarding consent to share this information and / or complexities regarding the need to share the information, in addition to supervision, the member of staff or the director being consulted shall contact the legal advice line of the insurance provider for a legal perspective.
- The information regarding the concerns and the action taken will be recorded (in document form) including discussions in supervision and with the legal advice line, and passed to the relevant agencies.
- If the director is the concerned professional, discussion will take place in external supervision and / or with the other director, and documented.
- If a child is at risk of immediate harm, then the designated person will inform the appropriate agency without delay.
- If the child is not in immediate harm, the information must be responded to without delay.
- Failure to report concerns may lead to suspension pending investigation and for staff, disciplinary action.
- If a member of staff, volunteer or director is alleged to have put the welfare or safety of a child at risk, the designated person will inform the appropriate agency and cooperate fully with the authority in the manner in which the matter is dealt with including the immediate suspension of the person pending an investigation.
Additional documents and resources of relevance are:
https://www.ddscp.org.uk/
https://learning.nspcc.org.uk/media/1079/safeguarding-standards-and-guidance.pdf
Safeguarding training (and more) can be accessed for NSA Therapy Services Ltd staff at:
This policy will be reviewed every 3 years, or when additional employees are taken on at NSA Therapy Services Ltd, with their roles and responsibilities in mind.
Designated Safeguarding Person
NSA Therapy Services Ltd Directors (i.e. Nicola Armstrong and Lee Armstrong) are ultimately responsible for safeguarding.
Retention of Records
A factual, dated record of concerns about an adult at risk in a family supported will be kept, in line with NSA Therapy Services Ltd record keeping and procedures.
Contact Us
If you have any questions, concerns or complaints about this Safeguarding Children Policy please contact us:
- By email: [email protected]
- By visiting this page on our website: www.nicolasaunderstherapy.com
- By phone number: 07914714469
