Last reviewed: September 2025

Immediate Media’s Safeguarding Leads are:

For all parts of the business:

Katherine Conlon – safeguarding@immediate.co.uk

David Reay – safeguarding@immediate.co.uk

For their respective parts of the business:

Paul Byrom, Immediate Live – paul.byrom@immediate.co.uk

1. Immediate Media’s approach to safeguarding
2. Definitions
3. Principles of best practice at Immediate Media
4. Safeguarding Leads
5. Concerns about a child or young person
6. Concerns about an adult at risk
7. If I’m concerned, what do I do?
8. Disclosures
9. Safeguarding children online
10. Adults at Risk

Appendix 1 –Immediate – Behavioural Rules

Appendix 2 – Definitions of Abuse

Immediate Media is committed to ensuring that all children and adults at risk with whom we engage are kept safe and protected from harm or abuse.

Safeguarding is everyone’s responsibility. This policy sets out what constitutes abuse, how to recognise it and what Immediate Media’s staff and suppliers are required to do if they are concerned about the welfare of a child or adult at risk.

This policy must be followed by everyone regardless of their employment status, seniority or role. It applies to all Immediate Media staff, freelancers, independent contractors, suppliers, chaperones and parents.

In this policy, the following words mean:

• Adult at risk – Someone who is aged 18 years or over and is at risk of abuse or neglect because they need particular care or support. Their vulnerability may be connected to:
  • age;
  • physical or mental disabilities, or special educational needs;
  • any illness, either mental or physical that they may have, or pregnancy;
  • isolation or loneliness;
  • finances and work; or
  • living conditions.
• Child – someone under 18 years of age
• Child protection – part of the safeguarding process which focuses on protecting the child once they are identified as suffering or likely to suffer significant harm.
• Harm – the impact of the abuse, exploitation, or neglect of the child, young person or adult at risk, whether deliberate or accidental as the result of a lack of knowledge or awareness. Harm may result in an impairment of physical, intellectual, emotional, or mental health or well-being. Harmful conduct may constitute a criminal offence or professional misconduct.
• Safeguarding – action that is taken to promote the welfare of the child, young person or adult at risk and protect them from harm.
• Young person – someone aged between 16 – 18 years.

 

Immediate Media’s principles in all safeguarding situations are:

• Children and young people should be treated with care, respect and dignity.
• Everyone who works for or with Immediate Media in any capacity, has a responsibility for safeguarding the welfare of the children and adults at risk that we meet in the course of our work.
• Anyone intending to work with children must attend Immediate Media’s safeguarding training to develop or refresh their skills and knowledge on how they should work with children and this policy.
• Immediate Media will follow employment laws and rules and always seek work permits and Child Performance Licenses where required.
• Immediate Media follows safe recruitment practices to ensure we do not engage anyone who may pose a risk to children or adults at risk.
• When working with children or adults at risk, Immediate Media will always undertake a dynamic and ongoing risk assessment.
• Immediate Media’s Work Experience policy is managed by HR. When young people choose to join us for work experience, this policy will always be followed.

All staff must read Immediate Media’s Code of Conduct before working with children or adults at risk. It explains the behaviour we require and makes our expectations clear. It supports respectful, positive relationships between Immediate Media and the children, young people and adults at risk that we engage with.

The Code of Conduct can be found at Appendix 2.

Immediate Media has trained a number of its senior leaders in safeguarding and their details are provided on page 1 of this document.

The Safeguarding Leads are the point of referral for concerns about the welfare and safety of a child or adult at risk, whether there is a perceived or actual risk of harm, a child or adult at risk has made a disclosure or provided us with information that raises concerns or someone is behaving in a way that suggests they may pose a risk, cause harm or have caused harm to a child, young person or adult at risk.  The Safeguarding Leads will maintain confidential records of safeguarding issues.

Every safeguarding issue which arises must be referred to a safeguarding lead as soon as possible.

Reasons for becoming concerned about the welfare of a child or young person may include:

• observing an injury;
• witnessing or heard an interaction (between children or between an adult and a child) that you find worrying or which is against Immediate Media’s Code of Conduct;
• being concerned about bullying, whether physical, verbal or online;
• becoming aware of inappropriate communications – which could include sexting (between children, or between an adult and child) or up-skirting;
• discovering that someone creates, accesses or shares images of child abuse;
• if a child exhibits sexualised awareness or behaviour, or seems neglected or withdrawn in their behaviour; or
• if a child makes a disclosure to you about abuse or a risk of abuse, towards them or someone else.

Reasons for becoming concerned about the welfare of an adult at risk may include:

• observing injuries which they are reluctant or unable to explain;
• noticing that they are withdrawn, fearful or over-eager to please;
• if they seem not to have access to money, or not be able to pay bills, complain of hunger etc., even if they are employed or receive benefits;
• if they may appear unkempt, and uncared for even though they have family/friends seemingly ‘caring’ for them;
• if they act in a sexually inappropriate way or are fearful of being touched; or
• if they, or someone close to them, discloses abuse or expresses concern about potential harm.

These examples are not exhaustive. If anything makes you feel uncomfortable, please raise it immediately with a Safeguarding Lead who will take you seriously and make time to discuss your concerns.

It’s vital that you share your concerns with a Safeguarding Lead as soon as possible. You can email or call them directly or email safeguarding@immediate.co.uk. Your concern may be an important piece of information in building the full picture to protect the child, young person or adult.

Remember that we do not expect or require you to decide whether abuse has or is happening. But you are expected to alert a Safeguarding Lead immediately.

You should go directly to one of the Safeguarding Leads, even if your role would not normally involve direct contact with any of that person. You should not refer your concern through your usual line manager – this way, we can make sure concerns are dealt with only by people who’ve been trained in safeguarding matters , and keep the circle of people small enough to protect the privacy of the child, young person or adult at risk. You should never try to investigate this yourself or inform anyone other than the Safeguarding Lead.

In particular, you should never tell the person named as the potential abuser in any disclosure. Doing so could increase the risk to the person who has trusted you with their disclosure and could be considered gross misconduct.

The Safeguarding Lead is responsible for taking the decision on whether your concern should be referred to the police, to the local authority, to a child’s school (through its Designated Safeguarding Lead) or to some other safeguarding authority. The Safeguarding Lead may not be able to share further details with you but will explain what they can.

If a child, young person or adult at risk discloses information to you that suggests they have been or may be abused, you cannot keep this information to yourself and you must not promise to keep it to yourself. To keep them safe, you must tell someone else.

In this situation it is important that you:

• remain calm and do not show shock or disbelief.
• listen carefully to what is being said.
• do not ask detailed, probing or leading questions.
• tell them that you take what they are saying seriously.
• tell them that you are going to refer this to a Safeguarding Lead;
• tell them that you and the Safeguarding Lead will only share their disclosure with people who need to know;
• tell them that when you have spoken to someone, they will be told what is going to happen next.

If the child has been subjected to a lesser crime – for example, if their property has been stolen or they’ve been subject to anti-social behaviour or bullying, the Safeguarding Lead can discuss this with the child’s parent or guardian, who will be expected to act in the child’s best interests.

If a child or young person is the alleged perpetrator, this is still a safeguarding issue and should be reported to a Safeguarding Lead.

Immediate danger – if the child or adult at risk is in immediate danger, dial 999 and ask for the police – do not delay. Having made sure they are safe, contact your Safeguarding Lead immediately to let them know what has happened.

 

Any incidents of inappropriate user generated content (UGC), images of child abuse, online grooming or cyberbullying, must be referred to your Safeguarding Lead immediately.

If you have received an email that you suspect may contain child abuse images, it is vital that you do not open it or forward it on. You must alert your Safeguarding Lead and working with Immediate Media’s Infosec team, they will take the action necessary to refer the email to the appropriate agencies.  If, after investigation, the email is found to be inoffensive, we would rather be alerted to the potential than not know about it.

If an adult at risk reports they have been subject to sexual, physical, psychological, or emotional abuse, financial abuse, exploitation, or neglect, you have a duty to report it to a Safeguarding Lead, in accordance with this policy.

If the adult at risk has a responsible person such as a parent, carer, or someone with power of attorney looking after their interests, this may suggest that the adult at risk lacks capacity and so the Safeguarding Lead may notify the responsible person about the concern, unless they are believed to be the perpetrator.

If the issue is a crime against an adult (who is not an adult at risk), the Safeguarding Lead will usually seek their consent before reporting the crime. Information relating to adults with capacity is generally only shared without consent where it is in the public interest or if there is a legal reason to do so.

These rules have been created to keep you, and the children and adults you work with, safe.

1. Everyone who works for Immediate Media in any capacity (including all staff and anyone working for us 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 are a reference to children, young people and adults at risk.

 

1. Everyone who works for Immediate Media has a duty to promote open, honest, trustworthy and respectful relationships with everyone we meet in the course of our work. Everyone who works for us will demonstrate proper personal and professional behaviour and boundaries at all times during their work. Everyone who works for Immediate Media will behave responsibly during work-related social events, especially if children are present.

 

3. We will, whenever possible, make arrangements and share practical communications through the child’s parent, guardian or chaperone rather than directly with the child. We will use suitable language when communicating with the child and will not share our personal information. We do not give out personal contact details, and will not ‘friend’, ‘follow’ or search for children on any social networking site.

 

4. Everyone who works for Immediate Media will work in an open environment, avoiding private or unobserved situations with children and encouraging open communication with no secrets. While having the consent of their parent, guardian or chaperone is important, we will always explain to the child what we plan to do and seek their consent to participate.

 

5. We will ensure that the child is accompanied by a parent, guardian or chaperone 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 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.

 

6. We will maintain a safe and appropriate distance at all times. We will engage in the minimum of physical contact with the child, and any necessary physical contact will be public and appropriate. Our staff will not do things of a personal nature for any child but instead, we will ask the child’s parent, guardian or chaperone to help.

 

7. Immediate Media’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 secret. We will then make escalate the concern immediately to one of Immediate Media’s Safeguarding Leads who will refer it appropriately to the police, the Local Authority, the child’s school (through the Designated Safeguarding Lead) or another suitable safeguarding authority. We will not share the child’s disclosure with any other person.

 

9. We are prepared to challenge inappropriate behaviour and will respond appropriately to all concerns about a child’s welfare, escalating the matter promptly to our Safeguarding Leads in accordance with Immediate Media’s Safeguarding Policy.

 

10. We will treat inappropriate or illegal behaviour extremely seriously and may take action in accordance with Immediate Media’s disciplinary policies.

 

 

A.            What is child abuse?

Child abuse is any action by another person – adult or child – that causes significant harm to a child. It can occur by omission or commission, by direct means or online, and cause physical, sexual or emotional harm, but can also be about a lack of love, care and attention. Neglect can be as damaging to a child as any other type of abuse.

A.1          An abused child can experience more than one type of abuse, and this can happen over time, or be a one-off event.

A.2          Children can be more vulnerable to abuse if they have a disability, or if they are exposed to parental and child mental health issues, bullying, parental or child substance misuse, such as drugs or alcohol, and behavioural issues including exclusion from education, social isolation etc.

B.             Types of abuse

B.1           Physical abuse happens when a child or adult at risk is deliberately hurt, causing injuries such as cuts, bruises, burns and broken bones. It can involve hitting, kicking, shaking, throwing, poisoning, burning, use of restraint, denial of treatment or improper administration of medication, or suffocation.

It’s also considered physical abuse if a parent or carer makes up or causes the symptoms of illness in children, for example, by giving them medicine they don’t need, thus making them unwell. This is known as fabricated or induced illness (FII).

B.2.          Emotional Abuse is the emotional ill-treatment or neglect of a child or adult at risk. It is sometimes called psychological abuse and can cause serious harm. It may lead to the child or adult at risk thinking that they are worthless, unloved, and inadequate.  It may include expecting a child to be able to do more than their stage of development would allow, such as expecting a baby to feed themselves, be toilet trained or not to cry, as well as being over-protective and stopping children from having opportunities to explore or participate in normal social interaction.  It can also include verbal threats, control, intimidation and experiencing domestic abuse, either as a victim or seeing or hearing it, being subject to or witnessing bullying (including cyber-bullying) which can cause the child or adult at risk to feel frightened or in danger.  Emotional abuse is a factor in all forms of abuse although it may also exist alone.

B.3           Neglect is the ongoing failure to meet basic needs of a child or adult at risk and can cause serious and long-term harm. Neglect may occur during pregnancy because of maternal alcohol or drug misuse, or neglect may involve a parent, guardian or carer failing to provide adequate food, clothing, heat and shelter, lack of supervision, access to medical care or education, or failing to keep the child or adult at risk safe from danger. It may also include unresponsiveness to basic emotional needs.

B.4           Sexual abuse is when a child or adult at risk is forced or persuaded to take part in sexual activities. This does not have to be physical contact but could involve being forced or coerced into looking at, or being the subject of sexual images, encouraging to behave in sexually inappropriate ways, or being groomed in preparation for abuse. It doesn’t necessarily involve violence and the child or adult at risk may not be aware that what is happening is abusive.

Sexual abuse can involve contact abuse and/or non-contact abuse. Contact abuse happens when the abuser makes physical contact with the child or adult at risk.   Non-contact abuse involves showing images of a sexual nature, encouraging them to observe sexual activity or talking about sexual matters. Sexual abuse is not solely perpetrated by adult men; women can also commit acts of sexual abuse, as can other children.

A child over 16 years of age can legally consent to sexual activity, however for people working in a ‘position of trust’ sexual activity with a child over 16 is illegal.  Examples of positions of trust includes teachers, care workers, youth justice workers, social workers, doctors, faith group leaders and sports coaches.

For children over 16 or adults at risk, sexual activity that takes place without consent or understanding is illegal.

 

B.5           Online Abuse is any type of abuse that happens on the web including grooming, sexual abuse, sexual exploitation and bullying.

When bullying (known as cyberbullying) happens online it can involve social networks, games and mobile devices and includes –

• sending threatening or abusive text messages.
• creating and sharing embarrassing images or videos.
• ‘trolling’ – sending menacing or upsetting messages on social networks, chat rooms or online games.
• excluding children from online games, activities, or friendship group.
• setting up hate sites or groups focusing on a specific child or young person.
• encouraging young people to self-harm.
• voting for or against a child or young person in an abusive poll.
• creating fake accounts, hijacking, or stealing online identities to embarrass a young person or cause them trouble by using their name.

B.6           Child and Adult Sexual Exploitation

Children and adults in exploitative situations and relationships may initially be groomed by being given high value gifts, money, drugs, alcohol, status, or affection in exchange for engaging in sexual activities that they are unable to consent to because they are too young or because of the power differential between them and the perpetrator. They may initially be tricked into believing they are in a loving, consensual relationship and not understand that they are being abused. They may depend on their abuser or be too scared to tell anyone what’s happening. They might be invited to parties and given drugs and alcohol before being sexually exploited and subject to violent, humiliating and degrading sexual assaults which may involve multiple perpetrators.

Some children and adults are trafficked into or within the UK for the purpose of sexual exploitation. Sexual exploitation can describe a one-off situation between two people (child-adult or adult-adult), while at the other end it may include instances of organised crimes where a number of adults or children are trafficked and sexually exploited. Sexual exploitation can also happen to children and young people in gangs.

B.7          Harmful sexual behaviour occurs when children and young people engage in sexual behaviour (HSB) which harms themselves and others.

It can include:

• using sexually explicit words and phrases.
• inappropriate touching.
• using sexual violence or threats.
• full penetrative sex with other children or adults.

Sexual behaviour between children is considered harmful if one of the children is much older, particularly if there is more than 2 years’ difference in age or if one of the children is pre-pubescent and the other isn’t. However, a younger child can abuse an older child, particularly if they have power over them for example, if the older child is vulnerable.

B.8           Domestic abuse is any type of controlling, bullying, threatening or violent behaviour between people who are or were in an intimate relationship. There are many different types of abusive behaviours that can occur within intimate relationships, including emotional, sexual, financial, psychological, and physical abuse. Both males and females can be abused or be abusers and domestic abuse can happen in any relationship regardless of age (including relationships between young people aged 16 and 17), sexuality, gender identity, race, or religious identity.

Exposing children to domestic abuse is also considered abusive. Children can be directly involved in incidents of domestic abuse, or they may be harmed by seeing or hearing the abuse happening. Children in homes where there is domestic abuse are also at risk of other types of abuse or neglect.

B.9           Bullying is behaviour that hurts someone and can happen anywhere – at school, at home, at social events, at work or online. It usually a sustained behaviour and can harm a child, physically, mentally, and emotionally.

Bullying includes:

• verbal abuse, such as name calling.
• non-verbal abuse, using hand gestures and body language.
• emotional abuse, such as threatening, intimidating or humiliating someone.
• exclusion, such as ignoring or isolating someone.
• undermining, by constant criticism or spreading rumours.
• controlling or manipulating someone.
• racial, sexual, or homophobic bullying.
• physical assaults, such as hitting and pushing.
• making silent, hoax or abusive calls.

B.10       Human trafficking is a form of abuse where children and adults are tricked, forced or persuaded to leave their homes. Grooming techniques are used to gain the trust of the child/adult, their family or community. Children and adults can be trafficked into the UK from overseas but can also be trafficked from one part of the country to another.

Children and adults are trafficked for:

• sexual exploitation.
• benefit fraud.
• forced marriage.
• domestic servitude such as cleaning, childcare, cooking.
• forced labour in factories or agriculture.
• criminal exploitation such as pickpocketing, begging, transporting drugs across county lines and other crimes.

When children and adults are trafficked, they may experience other forms of abuse such as physical, sexual, and emotional abuse to control them and they’re also likely to suffer physical and emotional neglect.

Human trafficking generally involves organised criminals who recruit, transport and exploit children and adults but can also be organised by individuals known to them and their family.

B.11        Financial Abuse

Financial abuse happens if someone steals or defrauds (or tries to) an adult at risk money, goods or property. This includes:

• Exploitation.
• Embezzlement.
• Withholding pension or benefits.
• Exerting pressure around wills, property, or inheritance.
• Cuckooing.

B.12        Modern slavery is another term which may be used in relation to human trafficking. Modern slavery encompasses slavery, servitude, forced and compulsory labour and human trafficking (HM Government, 2014). The Modern Slavery Act passed in 2015 in England and Wales categorises offences of slavery, servitude, forced or compulsory labour and human trafficking (NCA, 2017).

B.13        Female genital mutilation (FGM) is illegal in the UK and is a form of child abuse. It involves the partial or total removal of external female genitalia for non-medical reasons and is also known as female circumcision or cutting. Religious, social, or cultural reasons are sometimes given for FGM but it’s effect can cause severe and long-lasting damage to the girl’s physical and emotional health. The age at which FGM is carried out varies and it may be carried out when a girl is new-born, during childhood or adolescence, just before marriage or during pregnancy