Safeguarding Children and Adults at Risk Policy

1.Policy statement

1.1 Family Federation for World Peace and Unification (UK), referred to in this policy as FFWPU (UK), is committed to promoting a safe culture and protecting all people who come into contact with the charity through its work.

1.2 FFWPU (UK) recognises that children and adults at risk may experience abuse, neglect, exploitation or other harm within families, communities, institutions, religious settings, online environments or the charity’s own activities.

1.3 The welfare and safety of a child or adult at risk must not be placed below the reputation, interests or relationships of FFWPU (UK), its leaders, trustees, members or associated organisations.

1.4 FFWPU (UK) will:

Take reasonable steps to prevent harm.
Make it as easy as reasonably possible to raise a concern.
Respond promptly and proportionately.
Cooperate with the police, local authorities, regulators and other safeguarding bodies.
Treat people with dignity, compassion and fairness.
Protect people who report genuine concerns from retaliation.
Learn from concerns, incidents and near misses.

1.5 Safeguarding is everyone’s responsibility. Specialist decisions and case coordination will be led by the Designated Safeguarding Lead (David Schroder), with trustee-level safeguarding oversight provided by the Safeguarding Trustee (Dawn Pollitt). This does not remove the responsibility of any person to contact the emergency services or statutory safeguarding agencies directly where necessary.

2.Purpose

2.1 This policy establishes how FFWPU (UK) will:

Prevent and reduce safeguarding risks.
Recognise abuse, neglect, exploitation and boundary concerns.
Receive and record safeguarding information.
Protect a child or adult who may be at risk.
Make referrals to appropriate external authorities.
Manage allegations or concerns involving people working for or representing FFWPU (UK).
Recruit and supervise people safely.
Share and retain information lawfully.
Provide governance assurance to the Board of Trustees.

2.2 This policy does not replace the role of the police, local-authority children’s services, adult safeguarding services, Scottish social-work services or other statutory bodies.

3.Scope

3.1 This policy applies to:

Trustees and committee members
Employees and workers
Volunteers
Ministers, pastors and pastoral leaders acting for or on behalf of FFWPU (UK) • Consultants, contractors and agency workers.
Interns, students and work-experience participants.
Members when leading, organising, supervising or officially representing an FFWPU (UK) activity.
Partner personnel where FFWPU (UK) has allocated or shared safeguarding responsibility.
Any other person authorised to act on FFWPU (UK)’s behalf.

3.2 The protection provided by this policy extends to:

Children
Adults at risk
Beneficiaries and service users
Employees and volunteers
Members
Visitors
Family members and carers
Other people who come into contact with FFWPU (UK) through its activities.

3.3 This policy applies to:

FFWPU (UK) premises
Externally hired venues
Religious services and ceremonies
Education, youth, family and community programmes
Events, residential activities and trips
Home visits and pastoral meetings
Transport provided or arranged by FFWPU(UK)
Telephone, email, social media and online platforms
Fundraising and outreach
Activities delivered jointly with another organisation
Conduct outside an FFWPU (UK) activity where it may indicate that a person is unsuitable to work with children or adults at risk.

3.4 Partner organisations must be informed in writing which organisation is responsible for safeguarding leadership, referrals, record keeping and allegation management. FFWPU (UK) remains responsible for matters within its control and must not assume that a partner has acted unless this is confirmed.

3.5 The policy applies whether the alleged harm is current, recent or historic. 4.Definitions

4.1 Child

A child is a person under the age of 18.

4.2 Adult at risk: England and Wales

For the purposes of this policy in England and Wales, an adult at risk normally means a person aged 18 or over who:

Has needs for care and support, whether or not those needs are being met by a local authority
Is experiencing, or is at risk of, abuse or neglect
Because of those needs, is unable to protect themselves from the risk or experience of abuse or neglect.

A person’s age, disability, illness or diagnosis alone does not automatically make that person an adult at risk.

4.3 Adult at risk: Scotland

In Scotland, the Adult Support and Protection framework applies to people aged 16 or over who meet the statutory three-part test. They must:

Be unable to safeguard their own wellbeing, property, rights or other interests b. Be at risk of harm
Because of disability, mental disorder, illness or physical or mental infirmity, be more vulnerable to being harmed than adults who are not so affected.

A person aged 16 or 17 remains a child for child-protection purposes and may also fall within Scottish adult-support and protection arrangements. FFWPU (UK) must seek advice from the relevant Scottish services about the most appropriate or combined route.

4.4 Safeguarding concern

Any information, disclosure, observation, allegation, pattern or intuition giving reasonable cause to believe that:

A child or adult may have been harmed.
A child or adult may be at risk of harm.
A person may present a risk to children or adults.
Safeguarding procedures have not been followed.
An organisational culture, practice or activity creates an avoidable risk of harm. Proof is not required before reporting.

4.5 Abuse and harm

Abuse or harm may include, depending on the person and jurisdiction: • Physical abuse

Sexual abuse or sexual exploitation
Emotional or psychological abuse
Neglect or acts of omission
Financial or material abuse
Discriminatory abuse
Domestic abuse and coercive or controlling behaviour
Organisational or institutional abuse
Modern slavery, trafficking or criminal exploitation
Online abuse, grooming or image-based abuse
Bullying, harassment or hate-related abuse
Self-neglect or self-harm
Misuse of medication or restraint
Abuse by another child or adult at risk
Misuse of spiritual, religious or pastoral authority to coerce, frighten, isolate, exploit or control a person
Conduct that may not meet a statutory abuse threshold but breaches safe professional or personal boundaries.
Spiritual abuse*

*For the purposes of this policy, “spiritual abuse” is used as an organisational safeguarding term. It is not a separate statutory category in every part of Great Britain.

4.6 Allegation against a person working with children or adults at risk

An allegation or concern that a person working for or representing FFWPU (UK) has: • Harmed or may have harmed a child or adult at risk.

Possibly committed a criminal offence against or related to a child or adult at risk. • Behaved in a way indicating that they may pose a risk of harm.
Behaved in a way that may indicate unsuitability for a role involving children or adults at risk.

4.7 Low-level concern

A concern about conduct that is inconsistent with FFWPU (UK)’s expected standards, including inappropriate boundaries, but which does not initially appear to meet the threshold for a formal safeguarding allegation.

Low-level concerns must still be reported and recorded so patterns can be identified.

4.8 Regulated activity and regulated role

Regulated activity is an England and Wales legal term used in determining barred list and referral arrangements.
Regulated role is the relevant Scottish term for mandatory PVG scheme membership.

These terms must not be determined by job title alone. The actual activities, frequency, setting and level of responsibility must be assessed using current official guidance.

Legal and regulatory framework

5.1 FFWPU (UK) will apply the legislation and official guidance relevant to the location and nature of each activity.

5.2 The main framework includes, where applicable:

England and Wales

Children Act 1989
Children Act 2004
Safeguarding Vulnerable Groups Act 2006
Police Act 1997
Protection of Freedoms Act 2012
Care Act 2014 and associated statutory guidance in England
Social Services and Well-being (Wales) Act 2014 and associated Codes of Practice in Wales
Working Together to Safeguard Children 2026 in England
Wales Safeguarding Procedures and Working Together to Safeguard People guidance • Crime and Policing Act 2026, subject to commencement of the relevant provisions • Rehabilitation of Offenders Act 1974 and relevant exceptions legislation. Scotland
Children (Scotland) Act 1995
Children’s Hearings (Scotland) Act 2011
Adult Support and Protection (Scotland) Act 2007
Protection of Vulnerable Groups (Scotland) Act 2007
Disclosure (Scotland) Act 2020
National Guidance for Child Protection in Scotland
Adult Support and Protection Code of Practice and applicable local procedures. Great Britain-wide or organisation-wide
Equality Act 2010
Health and Safety at Work etc. Act 1974
UK General Data Protection Regulation
Data Protection Act 2018
Employment Rights Act 1996 and whistleblowing provisions
Human Rights Act 1998 where applicable
applicable charity legislation and regulator guidance.

5.3 Working Together to Safeguard Children 2026 is statutory guidance for the organisations and agencies within its scope and is an authoritative safeguarding benchmark for voluntary and faith organisations working with children in England.

5.4 Charity Commission safeguarding guidance is a regulatory expectation for FFWPU (UK) and its trustees. It requires trustees to take reasonable steps to protect people who come into contact with the charity and to establish clear referral systems.

5.5 FFWPU (UK) will maintain a controlled Legal and Regulatory Register. The DSL and Policy Owner must review it at least annually.

6.Safeguarding principles

FFWPU (UK) will apply the following principles:

Safety first: Immediate protection takes priority over internal procedure.
Listen and act: Concerns will be taken seriously without requiring proof from the reporter.

Child-centred practice: The child’s welfare, views, communication needs and lived experience will inform decisions.
Person-centred adult safeguarding: An adult’s wishes, autonomy, desired outcomes and capacity will be considered.
No promise of secrecy: Information may need to be shared to protect a person or comply with law.
Need-to-know handling: Information will be shared only with those who need it for a lawful safeguarding purpose.
Fairness: An allegation is not proof, and all parties will be treated fairly without compromising safety.
Non-discrimination: Safeguarding action will not be affected by race, nationality, sex, disability, religion, belief, sexual orientation, gender reassignment, age or other protected characteristic.
Accessibility: Reasonable adjustments and communication support will be provided where appropriate.
No retaliation: No person will be penalised for raising a genuine concern in good faith.
Independence: Conflicts of interest and loyalty will be identified and managed. 12. Learning: Concerns and near misses will be used to improve practice.

7.Roles and responsibilities

7.1 Board of Trustees

The Board has ultimate responsibility for safeguarding governance and must:

Approve this policy and ensure sufficient resources are available
Appoint a suitably competent DSL and Safeguarding Trustee
Ensure serious incidents are assessed for regulator reporting
Ensure conflicts are managed and independent advice is obtained where required e. Review safeguarding risks within the charity’s risk assessments
Ensure legal vetting and referral duties are met
Review the effectiveness of safeguarding arrangements annually

The Board must not expect to receive unnecessary identifying case details. Information should normally be anonymised unless individual details are required for a trustee decision.

7.2 Safeguarding Trustee

The Safeguarding Trustee must:

Provide constructive oversight and challenge
Ensure safeguarding remains a board priority
Support escalation where a senior person or the DSL is implicated • Monitor, but not routinely take over, operational case management • Ensure serious-incident and conflict decisions reach the Board or Chair promptly • Report concerns about the adequacy of resources or implementation

7.3 Designated Safeguarding Lead

The DSL must:

Receive and triage concerns promptly
Arrange immediate protection
Make or coordinate external referrals
Obtain local-authority or police advice where required
Maintain safeguarding records
Advise on risk management and allegations
Coordinate DBS, PVG and regulator referral decisions with authorised personnel • Monitor patterns and recurring risks
Provide or arrange training
Maintain local referral information
Report anonymised assurance information to trustees
Liaise with the HR adviser, insurer and legal advisers as appropriate The DSL must not personally manage a case where they have a conflict of interest.

7.4 Operations Officer

As Policy Owner, the Operations Officer must:

Coordinate policy review and implementation
Ensure relevant forms, systems and connected policies are maintained • Support risk-assessment and training administration
Ensure the current policy is accessible
Escalate resource or implementation failures to the Board

7.5 Data Protection Lead – (David Schroder)

The person responsible for data protection must advise on:

Lawful bases and conditions for safeguarding data;
Privacy information;
Access controls;
Retention and destruction;
Data-subject requests;
Information sharing;
Personal-data breaches; and
Data protection impact assessments.

7.6 Managers and activity leaders

Managers and activity leaders must:

Complete proportionate activity and role risk assessments • Make sure workers understand the reporting route
Enforce the Safeguarding Code of Conduct
Establish attendance, collection, supervision and emergency arrangements • Report every concern immediately
Avoid investigating the matter themselves
Implement interim protective measures directed by the DSL

7.7 Employees, workers, trustees, volunteers and representatives Every person within scope must:

Complete required safeguarding induction and training
Comply with this policy and the Code of Conduct
Remain alert to signs of harm
Report safeguarding concerns immediately
Call emergency services where required
Preserve relevant information and evidence
Maintain appropriate boundaries
Cooperate with authorised safeguarding enquiries
Declare conflicts of interest

No person requires a manager’s permission to contact the police, local authority or other safeguarding body.

8.Prevention and safer working

8.1 Role and activity risk assessment

FFWPU (UK) must assess:

each role involving contact with children or adults at risk;
mixed-age as well as specialist activities;
one-to-one and small-group arrangements;
pastoral counselling, prayer and spiritual guidance;
home visits;
online communication and digital platforms;
photography and recordings;
transport;
residential and overnight activities;
personal or intimate care;
financial assistance;
medication;
external venues;
missing-person risks;
accessibility and communication needs; and
partner or contractor involvement.

Risk assessments must identify responsible persons, control measures, emergency arrangements and review dates.

8.2 Safer recruitment

Recruitment and appointment procedures must be proportionate to the role and may include:

a written role description and safeguarding responsibilities;
an application or recorded expression of interest;
proof of identity;
interview or suitability discussion;
examination of unexplained work or volunteering gaps;
at least two suitable references for roles with significant safeguarding responsibility; • qualification or professional-registration checks;
overseas checks where relevant and available;
DBS or PVG checks at the legally permitted level;
a declaration of relevant convictions or safeguarding concerns where lawful; • induction;
a probationary, trial or supervised period; and
ongoing supervision and performance review.

No criminal-record check will be treated as proof that a person is currently suitable. The check forms one part of the assessment.

8.3 DBS checks in England and Wales

FFWPU (UK) must:

assess the actual duties against current DBS eligibility guidance;
record the legal basis and approved level of check;
request barred-list information only where legally entitled;
apply the same eligibility test to paid and unpaid roles;
maintain a written recruitment-of-people-with-criminal-records procedure; f. consider the relevance, seriousness, circumstances and age of disclosed information rather than automatically excluding a person; and
reassess the check if the role materially changes.

A DBS certificate has no universal statutory expiry date. Subject to trustee approval, FFWPU (UK) will either:

use a risk-based renewal interval not exceeding 3 years; or
use the DBS Update Service where appropriate and with the individual’s permission.

The existing three-year cycle may be approved as an organisational maximum, but must not be described as a legal requirement.

8.4 PVG scheme in Scotland

Before a person undertakes a regulated role in Scotland, FFWPU (UK) must ensure that the person has the legally required PVG scheme membership and that the appropriate disclosure process has been completed.

The DSL or authorised recruitment lead must use current Disclosure Scotland guidance to determine whether the role is regulated.

8.5 DBS and PVG information

FFWPU (UK) must:

restrict access to authorised personnel;
avoid retaining a full certificate or disclosure longer than necessary; • retain a limited audit record of the check, decision and date;
record any risk assessment relating to disclosed information separately and securely; • follow the applicable code of practice; and
securely destroy copies when the approved period expires.

8.6 Code of Conduct and boundaries

No person acting for FFWPU (UK) may:

use physical punishment, humiliating treatment, threats or degrading language; • engage in sexualised conduct with a child;
form an exploitative or inappropriate relationship with a child or adult at risk;
use religious or spiritual authority to compel secrecy, isolate a person or secure personal, financial or sexual advantage;
communicate secretly with a child through an unapproved personal account;
deliberately arrange avoidable, unobserved one-to-one access contrary to an agreed risk assessment;
take, retain or publish images contrary to FFWPU (UK) procedures; • exchange significant gifts, loans or money outside approved arrangements; • transport or accommodate a child contrary to the approved activity plan; or
ignore, conceal or discourage a safeguarding report.

Touch must be appropriate, necessary, non-sexual and respectful of the person’s wishes and communication needs.

8.7 One-to-one and pastoral work

One-to-one work must be:

necessary and appropriately authorised;
conducted in an observable or interruptible environment where practicable; • recorded or scheduled through approved arrangements;
subject to parental/carer information where appropriate;
risk assessed if conducted in a home, vehicle, hotel room or other isolated place; and • never used to create secrecy or exclusive dependency.

Confidential pastoral support must not be described as absolutely secret. The person must be told that information may be shared where someone is at risk or the law requires it.

8.8 Digital communication and social media

Communication with children must use approved organisational channels wherever practicable.

Private disappearing messages, secret groups and sexualised or inappropriate content are prohibited.

Group communications should normally include more than one authorised adult, or a parent/carer where appropriate.

Online activity must have:

moderation arrangements;
identity and access controls;
reporting tools;
content and conduct expectations; and
procedures for preserving evidence of online harm.

8.9 Photography and recordings

Images must be obtained, used, stored and published in accordance with the Photography, Filming and Privacy Procedure.

Consent does not remove the need to consider safeguarding risk. Images must not disclose sensitive location, personal or vulnerability information unnecessarily.

8.10 Partners and contractors

Before involving another organisation in an activity with significant safeguarding risk, FFWPU (UK) must conduct proportionate due diligence. This may include:

safeguarding policy review;
vetting and training assurances;
insurance;
allegation and referral procedures;
contact details for the partner’s safeguarding lead; and
a written allocation of responsibilities.

9.Recognising safeguarding concerns

9.1 People must report information rather than attempt to decide whether abuse has been proved.

9.2 Possible indicators may include:

Unexplained injury
Sudden behavioural, emotional or attendance changes
Fear of a particular person or place
Sexualised behaviour or knowledge inconsistent with age or understanding • Hunger, poor hygiene or unmet medical needs
Unusual financial transactions or loss of possessions
Controlling relationships
Isolation from family or friends
Repeated boundary violations
Concerning online contact
A disclosure by the person or someone else
An adult being prevented from speaking privately
Unexplained changes to wills, donations or financial arrangements • A worker discouraging supervision or record-keeping
Concerns arising from another organisation, family member or authority

9.3 A single indicator may have an innocent explanation. It must nevertheless be reported where it creates a safeguarding concern.

Reporting and immediate action

10.1 Immediate danger

Call 999 immediately where:

A person is in immediate danger
Urgent medical attention is required
A serious crime is in progress
A child or adult has gone missing in circumstances creating immediate risk • Delaying action would expose someone to serious harm

The DSL must then be informed as soon as it is safe to do so.

10.2 Internal report

A concern must be reported immediately to:

The DSL
The Safeguarding Trustee if the DSL is unavailable.

The concern may initially be reported:

In person
By telephone
By text or email
Through a safeguarding report form
By any accessible method reasonably available

10.3 Where the normal route cannot be used

Concern about the DSL: report to the Safeguarding Trustee.
Concern about the Safeguarding Trustee: report to the Chair and DSL. • Concern about the Chair: report to the DSL and National Director
Concern about several trustees or organisational concealment: contact the relevant local authority, police and charity regulator directly.

10.4 Written record

The person receiving or reporting the concern must make a factual record as soon as possible and normally before the end of the working period or within 24 hours.

The record must include:

Date and time
People present
What was observed or disclosed
The person’s exact words where possible
Questions asked
Visible injuries or immediate risks
Action taken
Information shared and with whom
The reporter’s name and signature/electronic authentication
Any communication or accessibility support used (Sign language/language translation)

The reporter must not delay immediate action to complete the record.

10.5 Direct external reporting

Any person may contact a safeguarding authority directly. Internal reporting does not remove this right or responsibility.

A person should make a direct referral where:

Immediate protection is needed
An internal recipient is implicated
The person reasonably believes that FFWPU (UK)
has failed to act
Delay may cause harm
The law requires the individual to ensure that a report is made

Responding to a disclosure

A person receiving a disclosure must:

Stay calm and listen
Take the person seriously
Allow the person to speak in their own words
Reassure them that they were right to speak
Avoid expressing shock, disbelief or blame
Do not promise secrecy
Explain that the information must be shared with people who can help 8. Ask only minimal, open questions needed to clarify immediate safety 9. Do not investigate, test the account or repeatedly ask the person to retell it 10. Do not confront the alleged person
Preserve messages, images, documents, clothing or other potential evidence without examining illegal material unnecessarily
Obtain urgent medical help where required
Report immediately
Make a factual record of the disclosure

No person should photograph an injury unless requested or authorised by the police, medical staff or the DSL following professional advice.

DSL triage and external referral

12.1 Immediate assessment

The DSL must assess the concern without delay and consider:

Immediate safety
Urgent medical needs
Whether a crime may have occurred
Whether other children or adults may be at risk
The wishes and communication needs of the person affected
Whether the allegation concerns someone in a position of trust • Whether evidence needs to be preserved
Whether an insurer, regulator or professional body may need to be notified • Conflicts of interest

12.2 Referrals involving children

Where there is reasonable cause to suspect that a child is suffering or likely to suffer harm, the DSL must contact the relevant local-authority children’s service and/or police without delay.

In England, allegations against a person working with children must also be discussed promptly with the Local Authority Designated Officer or designated allegation-management team. Working Together 2026 provides for local authorities to have designated arrangements for advising employers and voluntary organisations about allegations.

In Wales, the DSL must follow the Wales Safeguarding Procedures and relevant local social-services arrangements.

In Scotland, the DSL must contact the relevant local social-work/child-protection service and follow the local Child Protection Committee procedures.

12.3 Referrals involving adults at risk

The DSL must refer the concern to the applicable adult safeguarding or adult support and protection service where the threshold may be met, or advice is needed.

The local authority or relevant statutory body determines whether its statutory enquiry threshold is met. FFWPU (UK) should not withhold a referral simply because it cannot prove every element of the test.

12.4 Police

The police must be contacted where:

There is immediate danger
A crime is in progress
Urgent preservation of evidence is required
There is suspected sexual abuse, serious physical harm, exploitation or other criminal conduct
The statutory safeguarding service advises that police involvement is required

Use 999 for an emergency and 101 or the appropriate local route for a non emergency.

12.5 If an external agency takes no action

Where FFWPU (UK) remains concerned after a referral:

The DSL must seek the reasons for the decision
Provide relevant additional information
Use the agency’s escalation or professional-disagreement procedure • Consult the Safeguarding Trustee
Document the action and rationale

12.6 Decision not to refer

Where the DSL decides that external referral is not necessary, the record must explain:

Information considered
Advice obtained
The applicable threshold
The reasons for the decision
The internal safety plan
The review date
Any circumstances that would trigger reconsideration

Concerns or allegations about personnel

13.1 Immediate action

When an allegation concerns an employee, worker, trustee, volunteer, minister, contractor or representative, FFWPU (UK) must:

Protect the child or adult
Obtain external safeguarding advice
Protect potential evidence
Consider risks to other people and activities

Prevent conflicts of interest
Inform only those who need to know
Avoid prejudging the allegation.

13.2 Interim risk-management measures

Depending on external advice and the risk assessment, FFWPU (UK) may: • Increase supervision

Change duties
Remove access to particular people, systems or premises
Require remote or alternative work
Pause volunteering or representative duties
Suspend an employee on full pay where necessary and contractually appropriate
Suspend a contractor’s or volunteer’s involvement.

Suspension is a neutral risk-management step, not a disciplinary finding. For employees it must be necessary, proportionate, reviewed regularly and alternatives must be considered.

13.3 External safeguarding process before internal investigation

FFWPU (UK) must ask the police, local authority or allegation-management service whether and when an internal employment or volunteer investigation may begin.

The charity may gather the minimum information necessary for immediate safety and referral but must not conduct extensive interviews or test evidence in a way that could prejudice an external enquiry.

13.4 Employment and volunteer procedures

Once permitted, any internal investigation must:

Be conducted by an impartial and competent person
Consider evidence fairly
Follow the Disciplinary Policy where an employee is involved
Allow the person to respond
Separate the investigator and decision-maker where practicable • Record the decision and reasons
Provide an appropriate appeal route

Different contractual consequences apply to employees, workers, contractors and volunteers. A volunteer role may be restricted or ended, but the decision must still be rational, fair and appropriately recorded.

13.5 Outcomes

Possible outcomes include:

No further action
Advice, training or increased supervision
Formal management action
Reassignment or restriction
Disciplinary warning
Dismissal or termination
Removal from a volunteer, trustee or representative role
Referral to DBS or Disclosure Scotland
Referral to a professional regulator
Charity Commission or OSCR reporting
Police or local-authority action
Organisational learning measures

13.6 DBS referrals

FFWPU (UK) must make a DBS referral where it is legally required as a regulated activity provider and the statutory conditions are met.

The DSL must record:

Whether FFWPU (UK) is a regulated activity provider
The relevant role and regulated activity
The harm or risk condition
Removal or proposed removal
Whether the person left before action
The referral deadline and responsible person
The final referral decision

13.7 Disclosure Scotland referrals

Where a matter concerns a regulated role in Scotland, the DSL must apply the current Disclosure Scotland referral requirements and time limits. Specialist advice must be obtained where the duty is uncertain.

13.8 Support for the person accused

FFWPU (UK) will:

Identify an appropriate point of contact
Explain the process as far as this can lawfully be disclosed
Maintain confidentiality
Provide or signpost wellbeing support
Avoid unnecessary delay
Make clear that support does not imply that any conclusion has been reached

Safeguarding adults: consent, capacity and desired outcomes

14.1 The views, desired outcomes and autonomy of an adult must be considered.

14.2 Where an adult has capacity and does not wish information to be shared, the DSL must consider:

The seriousness and immediacy of the risk
Whether another person, including a child, may be at risk
Whether a serious crime may have occurred
Whether the adult is subject to coercion, duress or undue influence • Whether a legal duty applies
Whether the adult’s capacity relates to the particular decision • Whether sharing is necessary and proportionate
Whether specialist advice is required

14.3 Consent is not always required for safeguarding information sharing. Data protection law does not prevent necessary and proportionate disclosure where an appropriate lawful basis and condition apply.

14.4 Where consent is not sought or is overridden, the reason must be documented and the adult should normally be informed unless doing so would increase risk, obstruct an investigation or be otherwise unlawful.

14.5 Questions about mental capacity must be referred for appropriate professional advice. FFWPU (UK) personnel must not make unsupported clinical or legal capacity determinations.

Confidentiality, information sharing and data protection

15.1 Safeguarding information is sensitive and will be protected. Absolute confidentiality cannot be promised.

15.2 Information may be shared where necessary to:

Protect a child or adult
Make a statutory or regulatory referral
Report or investigate a crime
Manage a risk to others
Obtain legal or safeguarding advice
Conduct a fair employment or volunteer process
Comply with another legal obligation

15.3 Before sharing, the DSL or authorised person should consider: • Purpose

Lawful basis
Necessity
Proportionality
Accuracy
Recipients
Security
Whether the person should be informed.

15.4 Urgent protection must not be delayed solely because the precise data-protection basis has not yet been documented. The basis and decision must be recorded as soon as possible.

15.5 Safeguarding data must be stored:

In a restricted location separate from general personnel files where practicable • With role-based access
With encryption and secure backup
With an access or audit trail
Using unique case references where appropriate
In accordance with FFWPU (UK) safeguarding records will normally be retained for 6 years after the case is closed, with longer retention where justified by seriousness, ongoing risk, legal proceedings, regulatory requirements or another safeguarding reason.

15.6 Any suspected loss, unauthorised access or disclosure must be reported immediately under the Personal Data Breach Procedure.

This statement can be downloaded as PDF here.

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