Last reviewed: May 2016

Next review: May 2017

1. Definition
2. Principles
3. Nominated Safeguarding Managers
4. DBS Checks
5. Rehabilitation of Offenders Act
6. BBC Editorial Guidelines
7. Online Grooming
8. Children of Employees
9. School Visits and Events
10. Health and Safety
11. Transport and Accommodation
12. Secure Handling and Safekeeping of DBS Disclosures

Appendix – Safeguarding Behavioural Guidelines

Immediate Media Company Limited (“Immediate”) is committed to safeguarding the welfare of all children and young people who are involved, in any way, with Immediate’s work. The guidelines and procedures set out in this policy will apply equally to any vulnerable adults involved in Immediate’s work, and 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). Immediate also uses this definition.
• Everyone who works for or with Immediate, in any capacity, has a responsibility for the protection and welfare of the children and young people we meet in our work. We know that people who work for Immediate will be perceived by children and young people as trustworthy.
• Immediate acknowledges that some of its employees maybe or become vulnerable adults. Where this is the case, Immediate will carry out appropriate risk assessments and implement any adjustments necessary to ensure that they can work safely.
• Immediate’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. Immediate’s Safeguarding Behavioural Guidelines form part of this document and must be followed by all staff.
• Any offer of work made by Immediate in respect of a position which may involve working with children, young people or vulnerable people will be subject to a satisfactory DB S (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 Immediate. Speak to Edel Ryan to arrange for a risk assessment to be performed.
• Children and young people may not carry out paid work for Immediate unless they have an appropriate work permit – our HR team can advise you further.
• Managers offering work experience placements must do so in compliance with Immediate’s work experience policy. Please refer any questions to Caroline Martin.

Jo Brandl (Director of HR) and Katherine Conlon (Head of Legal Affairs) have responsibility for Immediate’s Safeguarding Policy. They are Immediate’s “Safeguarding Managers”.

They will:

• ensure that Immediate’s staff are aware of the requirement to work in compliance with Immediate’s Safeguarding Policy;
• be the point of referral for questions in relation to Immediate’s Safeguarding Policy;
• be the point of referral for anyone who, during the course of their work for or other involvement with Immediate, 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;
• and keep a record of any safeguarding issues which arise.

The Safeguarding Managers will receive training on safeguarding issues at least once every two years.

If an individual begins work with Immediate 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 Immediate.

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.

Employees working on BBC-branded titles must also be compliant with the BBC’s Editorial Guidelines which set out the BBC’s editorial values and cover all aspects of working with children, including safeguarding the welfare of children.

Any concerns you have that a child or young person may be being “groomed” online must be referred immediately to the Safeguarding Managers. Please note that the BBC’s Editorial Guidelines also include specific advice about suspected online grooming..

We recognise that Immediate’s employees may bring their children to Immediate’s premises for childcare purposes in exceptional circumstances. If it is necessary for you to bring your children to the office, you must have the permission of your manager and your children must remain under your direct supervision at all times.

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 Immediate’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”).

• Immediate’s staff attending any visit or event must do so in full compliance with this Safeguarding Policy, and Immediate’s Safeguarding Behaviour Guidelines.
• any member of Immediate’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 Immediate’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 Immediate’s Safeguarding Managers.

Any activity which involves a child or young person must be subject to a risk assessment. Edel Ryan 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; and
• any transport arrangements.

Transport

If children are being transported on behalf of Immediate, they must be accompanied by their parent, guardian, chaperone or teacher. Immediate has a duty of care for young persons between the minimum school leaving age and under 18 if they are travelling on behalf of Immediate.

Accommodation

If any Immediate activity requires a child or young person to stay away from home overnight, the arrangement must first be approved by Immediate’s Safeguarding Managers. The child or young person must be accompanied by their parent or guardian.

General principles

Immediate 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. Immediate 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, Immediate 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 Immediate’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.

Handling

Disclosure information is only passed to those who are authorised to receive it in the course of their duties. Immediate recognises that it is a criminal offence to pass this information to anyone who is not entitled to receive it. Immediate maintains a record of all those to whom Disclosures or Disclosure information has been revealed.

Usage

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.

Retention

Once a recruitment (or other relevant) decision has been made, Immediate 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, Immediate considers it is necessary to keep hard copies of this information for longer than six months, Immediate 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.

Disposal

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.

1. Everyone who works for Immediate in any capacity (including all staff and anyone working for Immediate 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.
2. Everyone who works for Immediate has a duty to promote open, honest, trustworthy and respectful relationships with the people we meet in the course of our work.
3. Everyone who works for Immediate will demonstrate proper personal and professional behaviour at all times during their work.
4. Everyone who works for Immediate will behave responsibly during work-related social events, especially if children are present.
5. Everyone who works for Immediate 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 has to 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 prese 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.
6. Anyone working with children as part of their role with Immediate will maintain a safe and appropriate distance at all tim We will engage in the minimum of physical contact with the child, and any necessary physical contact will be public and appropriate. Immediate staff will not do things of a personal nature for any child that s/he is able to do independently.
7. Immediate’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 for a pre-teen magazine), we will ensure that a parent or guardian is present throughout the discussion.
8. 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 secre 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 Immediate’s Safeguarding Managers. We will not share the child’s disclosure with any other person.
9. Immediate’s staff will respond appropriately to all concerns about a child’s welfare, escalating the matter promptly in accordance with Immediate’s Safeguarding Policy.
10. Inappropriate or illegal behaviour will be treated extremely seriously and will result in action being taken in accordance with Immediate’s disciplinary policy.

Immediate Media Company’s Safeguarding Managers:

Joanne Brandl, HR Director 020 7150 5012 or jo.brandl@immediate.co.uk

Katherine Conlon, Director of Legal Affairs 020 7150 5210 or katherine.conlon@immediate.co.uk