Safeguarding Policy

Policy Last Updated: 30/01/2025

Objectives of this policy

This policy covers Talk Consent, a subcontractor, and a service provider of consent education to educational settings.

Talk Consent is an organisation which provides delivers workshops and assemblies to educational institutions to tackle sexual violence. Talk consent’s PSHE lessons are built on positivity and inclusivity, creating a safe and non-judgemental atmosphere for students to openly engage in and discuss consent and sexual violence.

Talk Consent’s sessions are adapted for each age group, so the content is appropriate for the age of the audience. Talking to students about sex, consent and sexual violence in a way that applies to the young person. The aim is to help young people understand how to establish enthusiastic consent and keep each other safe in relationships.

Talk consent’s mission is to offer education to all schools across the UK, to reduce rape and sexual assault through extraordinary and effective education.

Talk Consent recognises its moral and statutory responsibility to safeguard and promote the welfare of all children and vulnerable adults. We endeavour to provide a safe and welcoming environment where all children and adults are respected and valued. We are alert to the signs of abuse and neglect and follow our procedures to ensure that children and vulnerable adults receive effective support, protection, and justice.

Principles

Our core safeguarding principles are as follows:

  • We will take all reasonable steps to safeguard those who attend our consent education sessions.
  • Policies will be reviewed annually, unless an incident or new legislation or guidance suggests the need for an earlier review date.
  • We will ensure that the welfare of children and vulnerable adults is given consideration when developing and delivering sessions.
  • All children, regardless of age, gender, ability, culture, race, language, religion, or sexual identity, have equal rights to protection.
  • All staff have an equal responsibility to act on any suspicion or disclosure that may suggest a child or vulnerable adult is at risk of harm in accordance with this guidance.
  • All safeguarding concerns will be shared with Talk Consent’s in-house Designated Safeguarding Lead, as well as being shared with the educational settings’ Designated safeguarding lead for referral and management purposes.

Aims

To provide all staff with the necessary information to notice, hear and record any safeguarding concerns arising during Talk Consent’s sessions. This is to promote and safeguard the wellbeing of children and vulnerable adults.

To ensure consistent good practice across facilitators and sessions.

To demonstrate Talk Consent’s commitment to safeguarding children and vulnerable adults.

To ensure clarity in Talk Consent’s safeguarding processes, where all safeguarding concerns are shared directly with the educational settings’ Designated Safeguarding Lead for management and referral purposes.

Policy

This policy covers all children and young people (i.e persons under the age of 18) and vulnerable adults who attend Talk Consent sessions. It also covers facilitators who deliver the sessions and other Talk Consent staff.  This policy has been created with due regards to all relevant legislation including, but not limited to the ‘Working Together to Safeguard Children’ (2018) statutory guidance and ‘The Care Act 2014’.

Through this policy Talk Consent ensures that our consent education takes place in a safeguarded environment, that welfare concerns are recorded and referred, and that disclosures by children and vulnerable adults are listened to and acted upon.

As Talk Consent is an external provider of consent education it is important to be clear of Talk Consent’s safeguarding responsibilities and those of the educational setting. Children and vulnerable adults who are attending an educational setting are considered under the care of the state and the setting in which they are in. As such, safeguarding Children and Vulnerable adults in educational settings is the responsibility of the educational setting, the setting’s designated safeguarding officer and the associated multi-disciplinary team.

Talk consent are external providers of consent education for educational settings, therefore we will share any safeguarding information with the school where appropriate to do so. The educational setting will hold safeguarding responsibility, and will be responsible for the management, referral, and ongoing process of safeguarding.  Once safeguarding information has been passed on to an educational setting’s designated safeguarding lead, Talk Consent will no longer hold any responsibility for the management of the concern/disclosure.

Where an allegation is made against a Talk Consent facilitator or member of staff, Talk Consent will take full responsibility for the reporting, referral, and management of such safeguarding cases.

In some cases, it may not be appropriate for allegations to be shared with Talk Consent’s designated safeguarding lead or deputy designated safeguarding lead and in these cases, facilitators will be responsible for sharing concerns/disclosures directly with the local authority designated officer.

Roles and Responsibilities

General Procedures

Responsibilities of Talk Consent’s Designated Safeguarding Lead

The Designated Safeguarding Lead for Talk Consent is Dan Allchurch, who can be contacted on team@talkconsent.org 

  • To make all Talk Consent staff and facilitators aware of this policy and procedures by ensuring all new staff members read the policy as part of their onboarding process and ensuring all existing staff members read it when any changes are made.
  • To monitor that this policy and procedures is used by staff and facilitators through supervision of new staff members and during frequent checks/performance reviews with all staff.
  • To review this policy and procedures at least every year, with every change in legislation and after each incident.
  • To keep safe and secure records of safeguarding report forms in line with the Data Protection Act 2018.
  • To complete a Safeguarding Report Form if they become aware of any allegation made against an instructor or member of staff.
  • To report allegations of significant harm done by a facilitator or member of staff towards a child or vulnerable adult to the appropriate LADO within 48 hours.

Management and Safer Recruitment of Facilitators

Responsibilities of Talk Consent

  • To verify candidates’ identity, preferably from the most current photographic ID and proof of address.
  • To request DBS (Disclosure and barring service) certificates for all staff and facilitators.
  • To check the candidates right to work in the UK. If there is uncertainty about whether an individual needs permission to work in the UK, the advice set out on the GOV.UK website will be followed.
  • To get at least 2 satisfactory references for all roles
  • To check qualifications for all roles.
  • To conduct interviews with applicants for all roles.
  • To ensure candidates are appropriately trained, with experience necessary to fulfil the role.

Responsibilities of the Safeguarding Lead

  • To attend safeguarding training every two years.
  • To ensure that facilitators always hold valid and clean enhanced DBS certificates, no older than three years.
  • To ensure all facilitators are aware of the policy and their safeguarding responsibilities.
  • To keep a register of facilitators’ and staff’s, references, qualifications and DBS checks.

Responsibilities of Facilitators

  • To always hold a valid and clean DBS certificate, no older than three years.
  • To use the procedures set out in this policy.

Session Delivery in Educational Settings

Responsibilities of the Safeguarding Lead

  • To give facilitators a teacher contact for every education setting at which they deliver, prior to sessions.
  • To report and refer any concerns or allegations which are made against a facilitator or Talk Consent member of staff to the LADO.

Responsibilities of Facilitators

  • To know the names and contact details of the educational setting.
  • To have access to the Safeguarding report forms
  • To refer all safeguarding concerns which arise prior to, during or after the session within 24 hours to Talk Consent’s Designated Safeguarding Lead.

Welfare Concerns and Disclosures of Abuse

It may happen that prior to, during and after a training session a facilitator has concerns about the welfare of a child or vulnerable adult. Also, a child or vulnerable adult may speak about abuse they experience at home, at school or in a different place. Facilitators need to know what to do in such an instance.

Responsibilities of Talk Consent’s Designated Safeguarding Lead

  • To receive copies of Safeguarding report forms from facilitators and members of staff
  • To keep a record of welfare concerns, disclosures of abuse and reports made to educational settings and their Designated Safeguarding Lead.
  • To report and refer any concerns or allegations which are made against a facilitator or Talk Consent member of staff to the LADO.
  • To keep a record of welfare concerns, disclosures of abuse and reports made to the LADO.

Responsibilities of Facilitators

  • To be alert & notice welfare concerns and accept any disclosures of abuse from any child or vulnerable adult.
  • To report the welfare concern or disclosure of abuse using the Safeguarding report form, to Talk Consent’s Designated Safeguarding Lead within 24 hours of noticing the concern or disclosure of abuse made.
  • To manage any disclosures that arise within a session sensitively and appropriately.
  • To report and refer any concerns or allegations which are made against a facilitator or Talk Consent member of staff to the LADO where it is not appropriate to share with Talk Consent’s Designated Safeguarding Lead.

Recording Suspicions of Abuse and Disclosures

Facilitators should make an objective record of any observation or disclosure using Talk Consent’s Safeguarding Report Form. This record should include, where possible:

  • Child(rens) or vulnerable adults name(s)
  • Session where disclosure or observation was noticed.
  • Date and time of the observation or the disclosure.
  • As much detail about the observation or disclosure as can be recalled.

These records should be signed by the facilitator and the educational setting’s designated safeguarding lead and kept in a confidential file.

As soon as possible after the disclosure, details must be logged accurately. 

Recording and Reporting Concerns About a Facilitator or Talk Consent Member of Staff

Responsibilities of the Designated Safeguarding Lead

If a concern is raised or an allegation made against any member of Talk consent staff or facilitator, Talk Consent’s safeguarding lead will follow the procedures below.

  • The Local Authority Designated Officer (LADO) will be informed immediately for advice, guidance and investigation.
  • The educational setting (if allegation occurred here) will be informed immediately to ensure support and safeguarding measures can be put in place for a child or vulnerable adult.
  • A full investigation will be carried out by the appropriate professionals (LADO) to determine how this will be handled.
  • Talk Consent will follow all instructions from the LADO and ask all members of staff to do the same and co-operate when required.

Responsibilities of Facilitators

  • To notice and report any concerns or allegations made against a member of Talk consent staff or fellow facilitator.
  • To fill in a Safeguarding Report Form within 24 hours of the allegation or concern being noticed and shared with Talk Consent’s Designated Safeguarding Lead.
  • Should the allegation be made against Talk Consent’s Designated Safeguarding Lead, the matter should be reported directly to the LADO.

Confidentiality

All staff understands that safeguarding issues warrant a high level of confidentiality, not only out of respect for the child, vulnerable adult and staff involved but also to ensure that being released into the public domain does not compromise evidence. Staff should only discuss concerns with the designated persons. That person will then decide who else needs to have the information and they will disseminate it on a “need-to-know” basis. Cases can be discussed in facilitator debriefs and/or reflective practice sessions to ensure best practice, however due care will be taken to ensure the child or vulnerable adult’s identity is kept anonymous.

Monitoring and Review

This policy is reviewed annually by Talk Consent’s Designated Safeguarding Lead. Any changes made to this policy by the DSL will be communicated to all members of staff and facilitators.

All members of staff and facilitators are required to familiarise themselves with all the processes and procedures outlined in this policy.

Appendices

Appendix 1 Types of Harm definitions (Children and Vulnerable adults)
Appendix 2 Relevant Legislation

Appendix 1: Definitions of Abuse and Harm

Types of Harm: Children

The following definitions of child abuse recommended for registration are as stated in the joint government departments’ document, ‘Working Together to Safeguard Children’ published in 2018.

Child abuse manifiest itself in a variety of ways, some overt and some less obvious. Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to prevent harm. Children may be abused in a family or in an institution or community settings by those known to them or more rarely by others. Abuse can take place wholly online or technology may be used to facilitate offline abuse. They may be abused by an adult or adults or by another child or children.

Abuse & Neglect: Somebody may abuse a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting, by those known to them or, more rarely, by a stranger. Abuse and neglect can take place online and offline.

Physical Abuse: Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer feigns the symptoms of, or deliberately causes ill health to a child whom they are looking after.

Sexual Abuse: Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (e.g. rape, buggery or oral sex) or non-penetrative acts. They may include noncontact activities, such as involving children looking at, or in the production of, pornographic material or watching sexual activities, or encouraging children to behave in sexually inappropriate ways.

Neglect: Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to provide adequate food and clothing, shelter including exclusion from home or abandonment, failing to protect a child from physical and emotional harm or danger, failure to ensure adequate supervision including the use of inadequate care-takers, or the failure to ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Emotional Abuse: Emotional abuse is the persistent emotional ill treatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to children that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond the child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.’

Bullying: Bullying is behaviour that is threatening, aggressive or intimidating, abusive, insulting or offensive, cruel or vindictive humiliating, degrading or demeaning.

Child criminal exploitation (CCE): CCE is where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into any criminal activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial or other advantage of the perpetrator or facilitator, and/or (C) through violence or the threat of violence. The Victim may have been criminally exploited even if the activity appears consensual. CC does not always involve physical contact; it can office through the use of technology. CCE can include children being forced to work in cannabis factories, being coerced into moving drugs or money across the country (county lines), forced to shoplift or pickpocket, or to threaten other young people.

Child Sexual Exploitation (CSE): CSE occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. CSE does not always involve physical contact; it can also occur through the use of technology. CSE can affect any child or young person (male or female) under the age of 18 years, including 16 and 17 year olds who can legally consent to have sex. It can include both contact (penetrative and non-penetrative acts) and non-contact sexual activity and may occur without the young person’s immediate knowledge (e.g., through others copying videos or images they have created and posted on social media).

Female Genital Mutilation (FGM): Female genital mutilation (sometimes referred to as female circumcision) refers to procedures that intentionally alter or cause injury to the female genital organs for non-medical reasons. It has no health benefits and harms girls and women in many ways. It involves removing and damaging healthy and normal female genital tissue and hence interferes with the natural function of girls’ and women’s bodies. FGM causes severe pain and has several immediate and long-term health consequences, including difficulty in childbirth also causing dangers to the child. It is practised by families for a variety of complex reasons but often in the belief that it is beneficial for the girl or women. Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime Act 2015) places a statutory duty upon teachers along with regulated health and social care professionals in England and Wales, to report to the police where they discover (either through disclosure by the victim or visual evidence) that FGM appears to have been carried out on a girl under 18. Information on when and how to make a report can be found at: Mandatory reporting of female genital mutilation procedural information.

Domestic Abuse: The cross-government definition of domestic violence and abuse is; Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over, who are or have been intimate partners or family members regardless of gender or sexuality. The abuse can encompass but is not limited to: physical, sexual, financial, emotional and psychological.

All children can witness and be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members.

Exposure to domestic abuse and/or violence can have serious, long lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result. Domestic abuse affecting young people can also occur within their personal relationships, as well as in the context of their home life.

Preventing Radicalisation: “Radicalisation” refers to the process by which a person comes to support terrorism and extremist ideologies.

The Counter-Terrorism and Security Act 2015 places a duty on specified authorities, including local authorities and childcare, education and other children’s services providers, in the exercise of their functions, to have due regard to the need to prevent people from being drawn into terrorism (“The Prevent Duty”). Young people can be exposed to extremist influences or prejudiced views, in particular those via the internet and other social media. Schools can help to protect children from extremist and violent views in the same ways that they help to safeguard children from drugs, gang violence or alcohol.

Upskirting: The Voyeurism (Offences) Act, which is commonly known as the Upskirting Act, came into force on the 12th April 2019. ‘Upskirting is where someone takes a picture under a person’s clothing (not necessarily a skirt) without their permission and/or knowledge, with the intention of viewing their genitals or buttocks (with or without underwear) to obtain sexual gratification or cause the victim humiliation, distress or alarm. It is a criminal offence. Anyone of any gender can be a victim.

Peer on peer abuse: Children can abuse other children. This is generally referred to as peer on peer abuse and can take many forms. This can include (but is not limited to0 bullying (including cyberbullying): sexual violence and sexual harassment: physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexting and initiation/hazing type violence and rituals.

Types of Harm: Vulnerable Adults

The Care Act 2014 recognises 10 types of harm for adults:

Self-neglect: This covers a wide range of behaviour, but it can be broadly defined as neglecting to care for one’s personal hygiene, health, or surroundings. An example of self-neglect is behaviour such as hoarding.

Modern Slavery: This encompasses slavery, human trafficking, forced labour, and domestic servitude.

Domestic Abuse: This includes psychological, physical, sexual, financial, and emotional abuse perpetrated by anyone within a person’s family. It also includes so-called “honour” based violence.

Discriminatory: Discrimination is abuse that centres on a difference or perceived difference, particularly with respect to race, gender, disability, or any of the protected characteristics of the Equality Act.

Organisational: This includes neglect and poor care practice within an institution or specific care setting, such as a hospital or care home, or in relation to care provided in one’s own home. Organisational abuse can range from one off incidents to ongoing ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes and practices within an organisation.

Physical: This includes hitting, slapping, pushing, kicking, restraint, and misuse of medication. It can also include inappropriate sanctions.

Sexual: This includes rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, indecent exposure and sexual assault, or sexual acts to which the adult has not consented, or was pressured into consenting.

Financial or Material: This includes theft, fraud, internet scamming, and coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions. It can also include the misuse or misappropriation of property, possessions, or benefits.

Neglect and Acts of Omission: This includes ignoring medical or physical care needs and failing to provide access to appropriate health social care or educational services. It also includes the withdrawing of the necessities of life, including medication, adequate nutrition, and heating.

Emotional or Psychological: This includes threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation, or withdrawal from services or supportive networks.

There are four additional types of harm that are not included in The Care Act, but they are also relevant to safeguarding adults.

Cyber Bullying: Cyber bullying occurs when someone repeatedly makes fun of another person online, or repeatedly picks on another person through emails or text messages. It can also involve using online forums with the intention of harming, damaging, humiliating, or isolating another person. It includes various different types of bullying, including racist bullying, homophobic bullying, or bullying related to special education needs and disabilities. The main difference is that, instead of the perpetrator carrying out the bullying face-to-face, they use technology as a means to do it.

Forced Marriage: This is a term used to describe a marriage in which one or both of the parties are married without their consent or against their will. A forced marriage differs from an arranged marriage, in which both parties consent to the assistance of a third party in identifying a spouse. The Anti-Social Behaviour, Crime and Policing Act 2014 make it a criminal offence to force someone to marry.

Mate Crime: A “mate crime” is when “vulnerable people are befriending by members of the community who go on to exploit and take advantage of them” (Safety Network Project, ARC). It may not be an illegal act, but it still has a negative effect on the individual. A mate crime is carried out by someone the adult knows, and it often happens in private. In recent years there have been a number of Serious Care Reviews relating to people with a learning disability who were seriously harmed, or even murdered, by people who purported to be their friend.

Radicalisation: The aim of radicalisation is to inspire new recruits, embed extreme views and persuade vulnerable individuals to the legitimacy of a cause.

Appendix 2: Relevant Legislation

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