Safeguarding Policy
Protection of children and vulnerable adults
The Vision Catalyst Fund (VCF) works to mobilise and catalyse significant funding to support governments across the globe to scale up eye health programmes and make them part of strengthened health systems in order to bring sight to entire populations across the Commonwealth and the world. At present, the VCF works towards this objective by grant funding organisations whose activities contribute towards VCF’s objective of significantly increasing access to vision in lower and middle income countries by supporting and facilitating sustainable eye health programmes at scale.
Therefore the VCF does not currently work directly with children or vulnerable adults. Nonetheless, it is committed to proactively safeguarding and promoting the welfare of its ultimate beneficiaries and staff and to taking reasonable steps to ensure those who come into contact with the VCF or the VCF’s programmes do not, as a result, come to any harm.
Over recent years there has been increasing recognition of the way in which vulnerable people can be at risk of harm from organisations and institutions that are supposed to help them, either as a result of abuse and exploitation by individuals in positions of trust, or via programme activities in general.
As a consequence, there has been a significant increase in the efforts made by agencies to ensure that no harm comes to beneficiaries or target communities from contact with their staff and associates or as a result of any of the organisation’s activities.
This duty of care extends beyond statutory safeguarding requirements. The VCF does not engage in any activity with children or vulnerable adults that is regulated by UK safeguarding legislation but it does take seriously its obligations to operate in a way that ensures, so far as is possible, that its work does no harm to anyone with whom it engages.
Given these values and in light of widely recognised risks, VCF has developed this policy to promote protection for all those people it comes into contact with, as well as staff and volunteers within VCF itself and the partner organisations with which it has relationships.
Should it come into contact with vulnerable groups (including children), the VCF’s responsibility will be to ensure it is doing all it can to protect such groups from all forms of harm, including abuse, neglect and exploitation and to ensure appropriate action is taken if such harm occurs.
Safeguarding Principles
The VCF is committed to the highest standards of safeguarding and our work (including that carried out by our partner organisations) is guided by the following principles:
The welfare of those we work with is paramount.
Everyone, without exception, has the right to protection from harm regardless of gender, ethnicity, disability, sexuality, beliefs or other issues.
All safeguarding concerns will be taken seriously.
We will proactively address safeguarding concerns and will engage with other individuals and agencies to ensure the welfare of all concerned.
We proactively engage with our partner organisations to ensure they have adequate safeguarding arrangements, including appropriate policies and mechanisms to provide assurance on compliance.
Scope of this Policy
This policy applies to all staff. For the purposes of this policy, ‘staff’ refers to:
VCF employees and Trustees
Freelance workers (self-employed or agency staff)
Volunteers, interns and secondees
Failure to follow this policy or to adhere to the Code of Conduct could lead to disciplinary action which may ultimately result in dismissal. Serious cases may be treated as gross misconduct, potentially leading to dismissal without notice. The VCF may also be required to report any incident to the police, which may lead to criminal prosecution, or to other statutory agencies.
Partner organisations - The VCF expects that the principles and approaches already shared with its partner organisations mean that they will fully support the values and commitments set out in this policy. The VCF recognises that some will already have safeguarding policies and associated measures in place. Where this is the case they should have no difficulty in also complying with the standards set out in this policy and in the Code of Conduct. All of the VCF’s grant recipients must ensure that they comply, as a minimum, with the standards as set out in this policy, and compliance is a condition of our grant terms used with grant recipients.
What is safeguarding?
Safeguarding is about embedding practices throughout the organisation to ensure the protection of children and vulnerable adults wherever possible and dealing sensitively and appropriately with the situation should any incident arise which places a child or vulnerable adult at risk or in which a child or vulnerable adult has suffered abuse.
Abuse is a selfish act of oppression and injustice, exploitation and manipulation of power by those in a position of authority. This can be caused by those inflicting harm or those who fail to act to prevent harm. Abuse is not restricted to any socio-economic group, gender or culture.
It can take a number of forms, including the following:
Physical abuse
Sexual abuse
Emotional abuse
Neglect
Financial abuse
Definitions
Child: means any young person under the age of 18.
Young person: means any person aged 18 to 29 years old.
Vulnerable adult: For the purposes of this policy, a vulnerable adult is defined as any person aged 18 years or over who may require additional assistance to protect themselves from harm or exploitation. This may be due to age, illness, disability or mental health. It may also be due to social factors such as poverty, lack of services and support.
Harm: behaviour that has a detrimental impact on an individual’s physical or emotional well-being. Although this includes the traditional categories of abuse (physical abuse, sexual abuse, emotional abuse, neglect, financial abuse) it also includes other harmful behaviours that may not meet the threshold of abuse but may have a detrimental impact on another individual’s well-being.
Safeguarding Concern: Any behaviour or action which is or is likely to cause harm to an individual associated with the work of the VCF.
Inappropriate Behaviour Any behaviour that is illegal, causes discomfort or offence to another individual or breaches the VCF’s Code of Conduct.
Partner organisation: an organisation which receives funding from the VCF or with which VCF collaborates to deliver its programmes or which is otherwise associated with the VCF name and brand.
Roles and Responsibilities
The VCF is committed to the highest standards of safeguarding and views safeguarding as a responsibility shared by all staff at all levels of the organisation:
Trustees have the ultimate responsibility for ensuring that VCF acts in the best interest of its beneficiaries. The trustees must have oversight of VCF’s safeguarding and risk management policies and procedures and should oversee VCF’s handling of safeguarding reports. The trustees also have responsibility for deciding whether any serious incident reports need to be made to the Charity Commission in relation to safeguarding incidents.
The Chief Executive is responsible for ensuring that any safeguarding concerns are taken seriously and appropriate action is proactively taken in any instances where concerns are raised. In such instances, the Chief Executive is responsible for notifying the Chair and Trustees.
The Executive Team is responsible for reviewing the Risk Register on a quarterly basis, ensuring the Safeguarding Policy is up-to-date in line with best practice and ensuring that all staff understand about their roles and responsibilities relating to safeguarding. The Executive Team is also responsible for taking proactive action to address safeguarding concerns where required, as instructed by either the Chief Executive or Designated Safeguarding Officer. It must ensure that appropriate safeguarding training is provided to staff and that staff are reminded about the importance of adhering to this policy.
The Designated Safeguarding Officer is the first point of contact for all safeguarding concerns, incidents and disclosures within VCF. They shall make any necessary reports to statutory agencies. They will keep records of any action taken in response to safeguarding concerns. They will monitor the overall trend of any safeguarding concerns and report annually (or more frequently, as appropriate) to the trustees. They will work with the Executive Team to ensure that VCF’s staff receive safeguarding training and will offer advice and support to staff to enable them to understand and fulfil their responsibilities. If the Designated Safeguarding Officer is unavailable for any reason, then the concern must be reported to the Deputy Safeguarding Officer.
All staff (including freelancers and contractors, as outlined above) are required to take action if any safeguarding concerns arise, including alerting the Designated Safeguarding Officer or Chief Executive, or engage with the Safeguarding Trustee or individuals or external agencies if required.
Prevention
The VCF will make every effort to ensure that adequate measures are in place to prevent harm being caused by its staff, representatives of partner organisations and operations. This will include:
Obtaining a Basic DBS Check and references for all employed staff (or the highest level of DBS check available if a role is eligible for a standard or enhanced DBS check or an enhanced DBS check with a check of the barred list) regardless of whether they come into contact with a child, young person or vulnerable adult as part of work undertaken on behalf of the VCF.
Obtaining the highest available level of DBS Check (or appropriate police or other checks available in the relevant jurisdiction for non-UK based individuals) and references for all freelancers, consultants, volunteers, interns and secondees if they are likely to come in contact with a child, young person or vulnerable adult as part of work undertaken on behalf of the VCF.
Providing all staff and volunteers with a printed copy of the Safeguarding Policy. A session about the Safeguarding Policy will additionally be held as part of staff and volunteers induction process.
All staff are required to read and sign that they understand and will comply with this policy and the VCF’s Code of Conduct (details in paragraph 16).
Requiring the VCF staff or partner organisations to complete Risk Assessments prior to any event or activity involving children, young people or vulnerable adults which will include a consideration of safeguarding concerns.
Proactively engaging with our partner organisations to ensure they have adequate safeguarding arrangements, including appropriate policies and mechanisms to provide assurance on compliance.
Ensuring that a representative from the VCF or a partner organisation is present during any communications-based activities, such as collecting case study materials and photography.
Reporting and Responding to concerns about children, young persons or vulnerable adults
Safeguarding concerns include any behaviour or action which is or is likely to have a detrimental impact on the physical or emotional well-being of any individual associated with the work of the VCF. Although this includes the traditional categories of abuse (physical abuse, sexual abuse, emotional abuse, neglect, financial abuse) it also includes other harmful behaviours that may not meet the threshold of abuse but may have a detrimental impact on another individual’s well-being.
If you suspect harm is being caused or likely to be caused to another person, the following steps should be followed:
Listen to the person carefully and calmly and offer them kindness and support.
You may ask simple questions to clarify the concern but you must not ask leading questions. You should not seek to conduct an investigation. Asking too many questions can make the person feel as though they are not believed. Your main responsibility is to listen and offer support.
Never agree to keep what is being said a secret and find an early opportunity to explain that you will need to share the information with the Designated Safeguarding Officer. All staff and representatives of the VCF have a duty to report safeguarding concerns and this should be reflected to the person who is raising their concerns.
Ask the person what they would like to happen and how they can be best supported. For young people visiting from overseas, this should consider how they can be linked to support from their friends and family at home.
As soon as you are able, you should report the concern to the Designated Safeguarding Officer (or in their absence the Chief Executive).
As soon as possible record in writing what was said using the person’s own words whenever possible. The person making the report should complete a Safeguarding of Children and Vulnerable Adults Report and send it to the VCF’s Designated Safeguarding Officer.
The Designated Safeguarding Officer will then consider:
What action needs to be taken to ensure that the individual is safe and supported? This should include how they will be supported by the VCF but also whether their family or others should be contacted to ensure their well-being.
What action needs to be taken to prevent harm being caused to this individual or others? This includes deciding whether the police, social services or any other agencies need to be informed. If the allegations relate to staff, it will also include deciding whether the individual needs to be suspended pending investigation.
Who will be responsible for investigating concerns and follow up action? Where concerns are reported to the police or social services, they will lead the investigation. If either agency decides not to investigate, the VCF will need to establish its own investigation – this may include appointing external experts to support the VCF in conducting the investigation.
All actions should be documented by the Designated Safeguarding Officer.
If there is a serious or immediate safeguarding concern which places a child or vulnerable adult at risk, anyone can make a referral to the police or other relevant statutory agency to prevent harm.
Reporting and responding to concerns about inappropriate or dangerous behaviour by members of staff or volunteers
Any concerns about the conduct of a member of staff or a volunteer should be reported to the Designated Safeguarding Officer. The response will be decided on a case-by-case basis depending on the nature and the severity of the concern. The VCF will always seek to have a proportional but robust response. All serious concerns will be escalated to the Executive Team and/or the Trustees to decide what action is to be taken. For staff, serious concerns may result in disciplinary action and serious inappropriate behaviour by volunteers, participants and beneficiaries may lead to them being removed from events run by the VCF. The VCF may also be required to report any incident to the police or other statutory authority, which may lead to criminal prosecution.
Where staff members feel able to challenge colleagues about inappropriate behaviour in the moment, they should feel empowered to do so. The VCF is committed to providing them with full support following any such events. Following any such incidents, a report should still be made to the Designated Safeguarding Officer (or in his/her absence, the Chief Executive).
Confidentiality
All safeguarding concerns should be managed with the strictest confidentiality. All staff have a duty to manage sensitive information in a manner that is respectful, professional and for a legitimate purpose, and that complies with the law. Details must be shared with the minimum number of people possible and only discussed with those directly involved in the management of the case.
However, confidentiality will never be a barrier to good safeguarding practice. If a child, young person or vulnerable adult tells a member of staff that they or another person is being hurt physically, sexually or emotionally, or likely to be hurt in the future, or in danger of hurting someone else, then that person may have to tell other people. Staff must not promise to ‘keep secrets’ and will always make it clear that if they are told something that means someone is at risk of harm or is being harmed, this will have to be passed to the Designated Safeguarding Officer (or in his/her absence, the Chief Executive).
Wherever possible, confidential information will not be passed to statutory agencies without the consent of the owner. There may be times, however, when disclosing confidential information without consent is necessary to safeguard a child or vulnerable adult or because the information suggests that there is a risk to others. If this is the case, information will be passed to the appropriate statutory agency by the Designated Safeguarding Officer, making it clear that consent has not been sought and why, or that consent has been refused. The reasons for the disclosure without consent must be recorded and stored securely by the Designated Safeguarding Officer.
Whistleblowing
If a staff member has a safeguarding concern and considers that it has not been appropriately addressed by the VCF following a report to the Designated Safeguarding Officer, (and that the child, young person or vulnerable adult has not been protected) the staff member should escalate the matter to the Chief Executive. In an extreme case, if you feel that you concern has not been responded to effectively, you should contact the Trustee with responsibility for safeguarding (“the Safeguarding Trustee”).
Partner organisations
The VCF is committed to the highest standards of safeguarding and ensures that it works with partner organisations who also commit to the same standards. The VCF will not fund or partner with an organisation unless confident that the partner organisation is capable of delivering the proposed activities or services and has in place appropriate systems of control, including adequate safeguarding policies and procedures. This will form part of the due diligence process prior to making a grant to a partner organisation and will be subject to ongoing monitoring under their grant agreement.
All partner organisations are required to provide details of their safeguarding policies and procedures, and advise the VCF’s Designated Safeguarding Officer of any incidents, suspected or actual, as soon as possible.
Responding to a report of an incident involving a partner organisation
The VCF will ensure that each partner organisation has appointed a member of staff who will be responsible for promptly reporting to the VCF’s Designated Safeguarding Officer any safeguarding concerns that arise in the context of the partnership.
If a safeguarding incident is reported to another member of VCF staff, they should advise the person making the disclosure that they will have to report the incident to the VCF’s Designated Safeguarding Officer and the relevant partner organisation’s Safeguarding Officer. The name of the person making the disclosure and full details of the incident(s) in question must be taken and noted.
When a partner organisation reports a safeguarding incident, the matter will be entered on the Issues Log by the Designated Safeguarding Officer. If necessary, further information will be sought about the incident, for example the partner organisation may be asked to clarify various details. The Designated Safeguarding Officer will proactively monitor the situation, keeping in touch with the partner organisation and will update the Issues Log with the action taken by both the VCF and the partner organisation to resolve the situation. Depending on the nature of the incident, it may be reported to the Audit Committee, Trustee Board and/or Charity Commission. The next steps will depend upon the nature of the incident and the partner organisation’s response to it, but they may include suspending further grant payments with immediate effect until more information is provided.
The Issues Log is discussed weekly at Executive Team meetings and progress updates are sent to the Audit Committee and Trustee Board regarding ongoing issues.
Serious Incident Reporting
As a UK Charity, the VCF is required to consider making a Serious Incident Report (SIR) to the Charity Commission if a safeguarding incident occurs. The responsibility for deciding whether it is necessary to make a SIR rests with the trustees.
The VCF is also required to consider making a Serious Incident Report to the Charity Commission with regards to a safeguarding incident relating to its partner organisations if the incident involves the VCF’s funds, brands or people or if the incident could otherwise have a significant impact on the VCF (including on its reputation).
Overseas visits
The VCF carries out overseas visits to its programmes which it has grant funded in order to monitor the work, secure government and stakeholder buy-in, and for media visits to gather collateral about our work to use in communicating about our impact. Safeguarding issues are incorporated into the planning of an overseas visit by liaising in advance with the partner organisation, identifying any potential risks and ensuring that the members of staff carrying out the visit are aware of any local policies and procedures. Staff must comply with this Policy and the Code of Conduct whilst overseas. If an incident occurs during an overseas mission, staff should report the incident to the Designated Safeguarding Officer in accordance with paragraphs 8 and 9 of this Policy.
All staff should take account of the advice for travelling overseas. This includes:
Avoiding travel at night.
Always wearing a seatbelt when travelling in vehicles.
Dressing in line with cultural norms
Avoiding time alone with people you don’t know and trust.
Using the hotel room safe to store valuables and passport.
Following FCO recommendations.
Having a check in point with a member of the VCF’s team on a daily basis.
Not openly carrying items of value.
Being cautious about using a mobile phone in public places.
Always seeking permission before taking photographs of people.
Code of Conduct
The Code of Conduct outlines the principles and behaviour staff must agree to
and display as part of their delivery of the VCF’s work.
Staff must:
Treat every child or vulnerable adult with dignity and respect regardless of differences of ethnicity, religion, age, ability, gender, sexual orientation, class and economic circumstances.
Be aware of situations which may present risks to children and vulnerable people (for example where they need to work closely with a particular individual or group for any length of time) and manage these situations appropriately in accordance with this policy.
Plan and organise their work so as to minimise risks.
Be visible to others when working with children and vulnerable people wherever possible.
Be accompanied at all times by an appropriate individual (e.g. parent, guardian or carer) when interacting with children and vulnerable people. Where this is not practical, staff should restrict interaction to settings where others are present, for example in a public space or large room used by others.
Immediately note the circumstances of any situation which may be subject to misinterpretation by a third party and report this to the Designated Safeguarding Officer.
Treat every individual with sensitivity and respect and explain what they can do if they feel there is a problem.
Follow the Code of Conduct for staff.
Staff must never:
Hit or otherwise physically assault or abuse a person.
Develop a physical or sexual relationship with a child or vulnerable person.
Develop a relationship with a child or vulnerable person which could in any way be deemed exploitative or abusive.
Act negligently with respect to a child or vulnerable person, for example by failing to provide adequate supervision of those with whom they are working.
Condone or participate in behaviour which is illegal, unsafe or abusive.
Discriminate against, showing differential treatment towards, or favouring a particular vulnerable person to the exclusion of others.
Use language, making suggestions or offering advice which is inappropriate, offensive or abusive.
Behave in a manner which is inappropriate or sexually provocative.
Invite a vulnerable person with whom they are working to come to their home or to stay overnight unsupervised.
Sleep in the same room or bed as a vulnerable person with whom they are working.
Do things of a personal nature for a vulnerable person that they can do themselves.
Act in ways intended to shame, humiliate, belittle or degrade.
Offer cigarettes or alcohol to children or vulnerable adults
Give personal gifts or cash to children or vulnerable adults
Perpetuate any form of abuse.
Misusing images in any format whether online, in printed material or other medium.
Give a child or vulnerable person their contact details, or contact them via social networking sites for non-work issues, or private messaging them.
Use of Social Media
Staff are expected to keep contact with beneficiaries on social media to a minimum and to avoid it where possible. Any contact with partners or beneficiaries on social media must be conducted via the public facing aspects of any given platform.
All inappropriate conduct must be escalated immediately using the procedures set out in this policy.
Staff must not post personal details of beneficiaries supported by the VCF on their personal social media pages. Consent is given to the VCF and not any individual.
Staff can promote the work of the VCF by sharing images and stories published on the VCF’s social media channels. Staff can only post images of the beneficiaries of the VCF, including with themselves, if consent is obtained from the beneficiary and if it falls within the principles outlined in this Code of Conduct and this Safeguarding Policy.
Staff must not post anything on social media which could bring the VCF into disrepute.
Communications
The VCF uses photographs, videos and case studies to tell the stories of those affected by sight loss and its causes. The VCF is committed to adhering to ethical guiding principles on communications to minimise the risks of people with ulterior motives misusing photographs and related information beyond the agreed purpose and content. The best interests of the child or vulnerable person are to be safeguarded as a primary consideration. To this effect, the VCF’s staff, representatives and partner organisations will abide by the following guidelines:
Ensure all interviews and images of children and vulnerable people are undertaken with sensitivity in order to safeguard the child’s rights to dignity, identity, confidentiality and privacy. Where possible children and vulnerable people should be prepared for interviews prior to being interviewed. A parent, guardian or carer should be present during interviews, or their permission sought beforehand for a professional adult with agreed responsibility (such as medical or education professional) to be present on their behalf. A representative from the VCF or the VCF’s partner organisations must also be present during any interviews of photography shoots.
Pictures of children and vulnerable people should be decent and respectful and should not stigmatise community, family or individual child or vulnerable person. All children, both boys and girls, and vulnerable people, must wear decent clothing appropriate to the local custom.
Prior consent to use information collected in interviews and/or images of children and vulnerable people should be obtained from the children themselves (if they possess the maturity to do so) and from their parents or guardians, and from the vulnerable people themselves or from their carers. This will include explaining to the children and vulnerable people and parent/guardian/carer how the images may be used in the public domain, with care taken to ensure the potential global reach of images or testimony is fully understood. To keep children safe, consideration should be given to how much information is published.
The VCF and its partners are committed to carefully guard any information about children and vulnerable people who feature in their publications, ensuring that personal data are used appropriately. This also applies when material is made available to third parties. Full names should never be provided or published alongside other identifiers such as date of birth or community.
Pictures, materials and personal information regarding children and vulnerable people will be held securely on a password-protected external hard drive and according to the VCF data security protocols. The misuse of images accessed will be treated in the same way as other breaches of this policy. Applicable data protection laws for all stored images will be followed.
Review
This policy will be regularly reviewed to ensure that any incidents which may have occurred will inform its development and that it remains fit for purpose in accordance with the work we are doing.