Safeguarding Policy

Safeguarding Policy: Three Thirty

What You Can Expect from Three Thirty

We adhere strictly to UK statutory guidance (Keeping Children Safe in Education - KCSIE) and the highest international standards.

What Three Thirty Expects from Parents and Carers

We rely on you to help us maintain a supportive, positive, and safe environment for all participants.

Table of Contents

1. Policy Commitment, Scope, and Principles

1.1 Statement of Intent

As a provider of children's clubs and activities, Three Thirty affirms that the welfare and safety of every child is paramount in all operational decisions, activities, and interactions. Our intent is to fulfil our non-negotiable legal duties, as defined by UK statutory guidance, by creating a safe and trustworthy environment where children are protected from all forms of harm and exploitation, and where every adult associated with Three Thirty is held strictly accountable to the highest standards of professional conduct and vigilance.

1.2 Scope and Applicability

This document is mandatory for all individuals defined as a Representative of Three Thirty. This includes:

• Employees & Coaches/Instructors (full-time, part-time, and temporary)
• Board/Trustees/Governors
• Volunteers and Interns
• Contractors, consultants, and third-party service providers
• Partners operating under an agreement with Three Thirty

The policy applies to all environments, including:

• Three Thirty premises and facilities
• All spaces used as children's clubs by Three Thirty, including schools
• Educational or non-educational visits, trips, or residential activities
• Digital and online platforms, including official email, video conferencing, and social media
• Interactions between staff, instructors/coaches, contractors, and children that occur outside of the normal working environment if they result from the professional relationship

1.3 Legal and Statutory Framework

As a provider of children's clubs, under the OOSS purview, Three Thirty must demonstrate compliance with the following core UK legal and statutory frameworks:

• The Children Act 1989 and 2004: The foundation of UK child protection law, enshrining the principle of the child's paramount welfare
• Keeping Children Safe in Education (KCSIE) 2025: Full adoption of the guidance related to safer recruitment, staff training, staff behaviour, and the non-negotiable procedures for managing allegations against staff
• DfE's Safeguarding guidance for providers of after-school clubs: Mandatory compliance with the DfE OOSS checklist requirements
• The Counter-Terrorism and Security Act 2015 (The Prevent Duty): Placing a duty to have due regard to the need to prevent people from being drawn into terrorism
• Health and Safety at Work etc. Act 1974: Governing our duty of care to ensure a safe environment
• Charities Act 2011: Governing the legal duties and responsibilities of our Trustees
• Data Protection Act 2018 / UK GDPR: Governing the secure, lawful, and necessary processing of personal data
• Human Rights Act 1998 (HRA): Ensuring policy implementation respects Article 3 and Article 8

1.4 International Child Safeguarding Standards (UNICEF)

In line with UNICEF's safeguarding best practice for global businesses, Three Thirty incorporates international standards to ensure comprehensive risk management. Our policy specifically addresses:

• Commitment to Child Rights: Recognising the United Nations Convention on the Rights of the Child (UNCRC) as the ethical foundation for all activities
• Organisational Risk Mapping: Identifying and mitigating specific risks created by the organisation's operations, supply chain, and digital footprint
• Auditable Systems: Establishing monitoring, evaluation, and reporting systems to ensure accountability beyond statutory compliance

2. Definitions and Types of Harm

2.1 Key Definitions (OOSS Context)

2.2 Types of Abuse and Harm (KCSIE Indicators)

All staff should be aware of the following indicators of abuse and neglect, understanding that harm can occur inside and outside of the home, and online.

2.3 Contextual Safeguarding and Harm Outside the Home

Harm to children can originate from outside the immediate family context, particularly in activities that involve group dynamics, online interaction, or external movement. Representatives must be alert to these risks:

2.3.1 Child Sexual Exploitation (CSE) and Criminal Exploitation

• CSE: Any child under 18 involved in sexual activity in exchange for something (e.g., accommodation, money, drugs, gifts) or where they are coerced or groomed.
• Criminal Exploitation: A child being coerced into criminal activity, often through threats, violence, or financial debt. This includes involvement in County Lines drug trafficking.
• Indicators: Unexplained money, new clothing or items, inappropriate relationships with older individuals, sudden change in language, aggression, or going missing from home/activities.

2.3.2 Trafficking, Modern Slavery, and Counter-Human Trafficking

• Three Thirty strictly prohibits any form of human trafficking or modern slavery. Our policy extends to active compliance with the standards to prevent trafficking.
• Any suspicion that a child is a victim of trafficking or modern slavery must be reported to the DSL immediately for referral to the National Referral Mechanism (NRM) via the local authority or police.
• This commitment extends to monitoring our supply chain and third-party contracts to ensure no exploitation is taking place (UNICEF principle).

2.3.3 Extremism and Radicalisation (The Prevent Duty)

• Three Thirty adheres to the Prevent Duty, having due regard to the need to prevent people from being drawn into terrorism.
• The DSL is the Prevent Lead and will assess concerns regarding a child's vulnerability to extremist ideology.
• All staff must complete Prevent awareness training to recognise the signs of radicalisation, which may include changes in appearance, isolation, expressing extremist views, or using extremist vocabulary.

2.3.4 Female Genital Mutilation (FGM) and Honour-Based Violence (HBV)

Representatives must be aware of their legal duty to report suspected FGM. Concerns regarding FGM, HBV, or forced marriage must be reported immediately to the DSL for swift referral to statutory agencies.

2.3.5 Child-on-Child Abuse

Child-on-child abuse includes bullying, sexual violence, sexual harassment, and the non-consensual sharing of intimate images. It must be addressed seriously, focusing on both the victim's protection and the perpetrator's behaviour management and potential need for intervention.

3. Roles, Responsibilities, and Designated Leads

3.1 DSL Responsibilities (Operational)

• Managing all internal and external referrals, liaising with Children's Social Care and the Local Authority Designated Officer (LADO).
• Acting as the first point of contact/ source of advice and support for staff.
• Ensuring all staff receive appropriate induction and refresher training.
• Maintaining all safeguarding records securely and confidentially.
• Coordinating the use of the Three Thirty Incident Report Form (Annex A).
• Ensuring that the setting's procedures reflect local multi-agency protocols.
• Ensure that child protection files are transferred securely to a new organisation's DSL within 5 days for an in-year transfer and receipt confirmed.

3.2.2 DSL Training Requirements

The DSL must undertake training that is updated at least every two years. This training must include:

• Understanding local referral thresholds and pathways.
• Knowledge of the impact of trauma and harm on children.
• Specific training on OOSS risks (online safety, trips, etc.).
• Prevent awareness training.

3.2.3 Absence and Handover Protocol

In the absence of the DSL, the DDSL assumes full responsibility. If both are unavailable, the Company Director with Safeguarding Oversight must be contacted. A robust, secure handover protocol must be in place for periods of absence (e.g., annual leave) to ensure critical case continuity and immediate response capability.

3.3 Responsibilities of All Representatives

Every individual working for or on behalf of Three Thirty has a duty to safeguard children.

• Read and sign the Staff Code of Conduct annually.
• Report any concern, suspicion, or disclosure about a child's welfare or a colleague's conduct immediately to the DSL.
• Be prepared to identify children who may benefit from Early Help.
• Be knowledgeable about all four types of abuse and the risks of contextual safeguarding.
• Challenge poor practice or non-compliance with the Code of Conduct, even if it does not meet the harm threshold (Low-Level Concerns).

4. Procedures for Reporting and Responding to Concerns

4.1 Internal Reporting Procedure

The procedure for raising a concern is uniform and mandatory for all Representatives:

• Immediate Action: If a child is in immediate danger, call 999.
• Verbal Report: Immediately inform the DSL or DDSL verbally. If the DSL is the subject of the concern, report to the Head of the Organisation or the DST.
• Listen and Do Not Investigate: Listen non-judgementally. Do not promise confidentiality and do not ask leading questions. Explain that the information must be shared to ensure their safety.
• Written Record: Complete the Three Thirty Incident Report Form (Annex A) by the end of the working day. The record must be factual, dated, timed, and signed, detailing the child's exact words in quotation marks.
• DSL Action: The DSL will review the report and determine the appropriate action, which may include internal support, Early Help intervention, or an external referral.

4.2 External Referral and Information Sharing Protocol

4.2.1 Referral to Children's Social Care (CSC)

• The DSL will make a referral to CSC if the concern meets the threshold of Significant Harm or if the child requires targeted support (Child in Need, Section 17 of The Children Act 1989 & 2004).
• Referrals must be made by telephone immediately, followed by a written referral within 24 hours.

4.2.2 Police Involvement

The DSL will contact the police immediately in cases where:

• A crime has been committed against the child.
• There is a clear and immediate risk of serious physical harm.
• The child is missing or is suspected to be a victim of trafficking.

4.2.3 Parental Notification

Parents/Carers will generally be informed of a referral unless the DSL or statutory agency determines that doing so would place the child at further risk of harm, impede a criminal investigation, or jeopardise the child's safety. The safety of the child always overrides the right to parental notification.

4.2.4 Secure Record Keeping

• All safeguarding files must be kept separate from the child's main records, stored in a lockable cabinet or encrypted digital system with limited access.
• Records are retained until the child reaches age 25, or longer if a serious incident/allegation has occurred.

4.3 Early Help Strategy

• Three Thirty is committed to providing Early Help to children who have additional needs but do not meet the threshold for statutory intervention.
• The DSL will coordinate an Early Help response, working with local partners to identify and provide targeted support.
• Staff must be vigilant in identifying indicators for Early Help, such as persistent poor attendance, behavioural changes, or parental engagement issues.

5. Safer Recruitment and Allegations Against Staff

5.1 Safer Recruitment Process (KCSIE Part 3 Compliance)

Three Thirty operates a rigorous, multi-stage Safer Recruitment process to deter, reject, or identify individuals who are unsuitable to work with children.

5.1.1 Vetting and Advertising

• All job adverts and candidate information packs must include a clear commitment to safeguarding.
• The application form must require applicants to account for any gaps in employment history and declare all relevant convictions and cautions.

5.1.2 Interview Stage

• The interview panel must include at least one member who has completed Safer Recruitment Training.
• Interviews must include questions designed to explore the candidate's attitude toward safeguarding, professional boundaries, and challenging poor practice.

5.2 Pre-Appointment Vetting Checks and the Single Central Record (SCR)

No representative may commence work until all checks are complete. The Single Central Record (SCR) must be maintained accurately and fully for all staff, governors, and volunteers engaged in Regulated Activity.

5.4 Allegations Against Staff, Volunteers, and Contractors

5.4.1 The Role of the LADO

• Any allegation that meets the Harm Threshold against a Representative must be reported immediately and without investigation to the Local Authority Designated Officer (LADO).
• The LADO will be contacted within one working day of the allegation being made.
• The LADO provides guidance on whether the matter requires a Police investigation, Social Services Enquiry, or employer disciplinary action.
• The decision to suspend an individual will be made in consultation with the LADO and is not automatic.

5.4.2 Management of Low-Level Concerns

• A Low-Level Concern is any concern about a staff member's behaviour towards a child that does not meet the LADO referral threshold but may indicate poor practice or lack of judgment.
• All low-level concerns must be recorded confidentially on a designated system, separate from the main personnel file.
• The DSL must periodically review all recorded low-level concerns to identify any patterns of behaviour or repetition. If a pattern emerges, the DSL will escalate the matter, potentially to the LADO, or initiate formal disciplinary action.

6. Risk Management and Organisational Safety

6.1 Health and Safety Mandates (DfE OOSS Compliance)

As an OOSS provider, Three Thirty has a non-delegable duty of care to ensure a safe environment.

6.1.1 Premises and Site Security

• A formal Health and Safety Policy is in place, and a competent person is appointed to manage these responsibilities.
• Risk Assessments are mandatory for all activities, premises, and external visits. These must be reviewed at least annually and immediately if there are any significant changes to the venue, activity, or staffing.
• Procedures are in place for the safe admission and collection of children, ensuring all adults collecting children are authorised by parents/carers.

6.1.2 Attendance and Monitoring

• Accurate registers are mandatory for every session and trip.
• Staff must check the register at the start and end of every session, and during transition points.
• Any unexpected absence or non-arrival of a registered child is investigated immediately by contacting the parent/carer.

6.1.2 Non-Collection Protocol

If a child is not collected at the agreed time, staff must follow the steps below:

6.1.4 Fire Safety and Emergency Planning

• A formal Fire Risk Assessment must be conducted and regularly reviewed.
• All staff and children must be familiar with fire safety procedures, escape routes, and assembly points. Regular (at least termly) fire drills must be conducted and recorded.
• Emergency procedures for other events (e.g., intruders, medical emergencies, severe weather) are documented and rehearsed.

6.1.5 First Aid and Medical Needs

• A sufficient number of staff must be trained and current in paediatric First Aid.
• Detailed records of a child's medical needs, allergies, and necessary medications must be obtained from parents.
• Procedures for the safe storage and administration of medication must be strictly followed and recorded.

6.2 Managing Physical Contact and Professional Boundaries

• Professional Boundaries: Staff must maintain appropriate professional boundaries with children at all times. This includes following the rule of 'Open Environment' (avoiding private, unsupervised, one-to-one situations) unless professionally required (e.g., First Aid) and documented.
• Physical Contact: Physical contact should be limited to that which is necessary, appropriate, and intended to comfort, reassure, or provide necessary assistance (e.g., first aid). Physical contact should never be intrusive, secretive, or for the gratification of the adult.
• Transporting Children: Specific procedures and written parental consent are mandatory for staff who transport children in private vehicles.

6.3 Online Safety and Acceptable Use of Technology

• Staff Communication: Staff must never communicate with a child using personal social media accounts, private email addresses, or personal mobile phones. All electronic communication must be professional, transparent, and auditable.
• Digital Risk Assessment: A specific risk assessment for all digital platforms used by Three Thirty (e.g., learning platforms, video conferencing) must be conducted to minimise risks such as grooming, cyberbullying, and inappropriate content exposure.
• Photography and Image Sharing: Explicit, written parental consent must be obtained for taking and using images of children. Images must be stored securely, and only authorised staff may take and use photographs.
• Online Platforms: Staff are prohibited from accessing, viewing, or storing inappropriate material on any device used for Three Thirty activities.

6.4 Children with Special Educational Needs and Disabilities (SEND)

• Children with SEND can be disproportionately more vulnerable to abuse and exploitation. Representatives must be acutely aware of this increased vulnerability.
• Communication barriers may make it harder for children with SEND to disclose abuse.
• The DSL will work closely with specialist services to ensure that any disclosure or concern from a child with SEND is managed in a manner that is appropriate to their communication needs.

7. Monitoring, Evaluation, and External Assurance

7.1 Child Safeguarding Risk Assessment and Auditing

Three Thirty adopts a continuous risk mapping and auditing framework to ensure proactive safeguarding.

7.1.1 Organisational Risk Mapping

The DSL and Board must conduct an annual risk mapping exercise to identify specific child safeguarding risks arising from:

• Direct Interaction: Risks from staff behaviour, recruitment, and service delivery.
• Indirect Interaction (Supply Chain): Risks from contractors, suppliers, and business partners (e.g., ensuring zero child labour or modern slavery in supply chains).
• Digital Footprint: Risks associated with data storage, online platforms, and marketing/communications.

7.1.2 Monitoring and Assurance

The Board is responsible for ensuring the following monitoring mechanisms are in place:

• Annual Audit: An annual independent audit or deep-dive review of the SCR, training records, and allegation management to ensure compliance and effectiveness.
• Internal Oversight: Quarterly reports from the DSL to the Board on the number and type of concerns, referrals, and staff training completion rates.
• Child Feedback: Regular mechanisms for children and young people to provide feedback on safety and well-being, ensuring their voice is heard.

7.2 Policy Review and Improvement Cycle

The policy review process is cyclical and evidence-based:

• The policy must be reviewed annually and approved by the Company Directors.
• Reviews must be triggered immediately following any significant changes in UK legislation, or following any major safeguarding incident, LADO case, or audit finding.
• The review must involve consultation with staff, parents, and, where appropriate, children.

7.3 Training, Knowledge, and Skills

• DSL Training: The Designated Safeguarding Lead (and deputies) must complete training that is updated at least every two years.
• Staff Training: All staff must receive appropriate safeguarding and child protection training at induction, which should be updated (including online safety updates) at least annually.

7.4 Complaints and Whistleblowing

7.4.1 Complaints Policy

A clear, accessible Complaints Policy is in place to allow parents, children, and staff to raise concerns about the organisation's policies, procedures, or the service provided. Concerns relating to a child's safety will be immediately diverted to the DSL via the safeguarding procedure, not the general complaints procedure.

7.4.2 Whistleblowing Policy

The Whistleblowing Policy is in place to protect staff who report serious concerns about dangerous, illegal, or unethical practices where they believe the child's welfare is at risk and their concerns are not being addressed through normal procedures. Staff must be protected from retribution or detrimental treatment as a result of whistleblowing.

ANNEX A: Three Thirty Incident Report Form Template

This form must be completed immediately after a verbal report is made to the Designated Safeguarding Lead (DSL) and submitted by the end of the working day.

ANNEX B: Safeguarding Contact List (Internal and External)

ANNEX C: Detailed Safeguarding Summary for Parents and Carers

What You Can Expect from Three Thirty (Our Commitments)

We adhere strictly to UK statutory guidance (Keeping Children Safe in Education - KCSIE) and the highest international standards.

What Three Thirty Expects from Parents and Carers (Your Role)

We rely on you to help us maintain a supportive, positive, and safe environment for all participants.

ANNEX D: Staff Code of Conduct and Professional Boundaries

D.1 Core Principles

All Representatives must adhere to the highest ethical and professional standards, recognising their position of trust. This Code is mandatory and failure to comply may result in disciplinary action up to and including dismissal and referral to the Disclosure and Barring Service (DBS) and Police, keeping the core principles in mind:

• Welfare Paramount: The child's welfare is paramount.
• Open Working: All interactions must take place in an open environment. Lone working with children is strictly prohibited until full DBS and Barred List checks are complete and verified.
• Integrity: Maintain high standards of behaviour, both inside and outside of Three Thirty activities, being mindful of the impact of personal life on professional status.

D.2 Mandatory Prohibitions

D.3 Professional Boundaries

• Openness and Transparency: Always work in an open environment, avoiding private or unobserved situations, and encouraging open communication with no secrets.
• Language: Use correct, proper, and respectful language at all times. Never use inappropriate, abusive, or demeaning language towards children.

D.4 Communication and Digital Technology

• Approved Channels: All communication with children must be conducted through approved Three Thirty channels (e.g., work email, official phone numbers).
• Social Media: Staff are prohibited from accepting connection requests from children or young people on personal social media accounts. Staff must maintain a professional online profile and not post any content that could compromise their professional standing or the organization's reputation.
• Personal Devices: The use of personal mobile phones/devices during activities should be minimal and limited to essential contact. Never use a personal device to photograph children.

D.5 Challenging Poor Practice

All Representatives have a responsibility to challenge and report poor professional practice by colleagues, even if it does not meet the threshold for a LADO referral.

• Poor practice includes: Inappropriate handling of a child; aggressive language; showing favouritism; failing to maintain confidentiality; or breaching professional boundaries.
• Concerns must be reported immediately to the DSL or Head of Organisation.
• Any Representative who suspects a breach of this Code, or has a concern about a colleague's conduct (Low-Level or Allegation Threshold), has a duty to report it immediately to the DSL/Head.
• If the concern relates to the DSL or Head, the report must be made directly to the Trustee/Governor with Safeguarding Oversight. The Whistleblowing Policy protects the anonymity of the reporting party.