SUPPORTING INFORMATION

It is extremely important that any safeguarding concerns are reported promptly so that appropriate action can be taken.

There are several routes to raise safeguarding concerns.

1. Directly with the Faculty, Department or University Safeguarding Officers.
2. With your Faculty, Department or University Prevent leads.
3. If you are concerned about the welfare or safety of a colleague, you should let their line manager or HR know, or raise it via the Report & Support system.
4. If you are concerned about the welfare or safety of a student, you should let their Lead Tutor know, or raise it via the Report & Support system.

A student or colleague could become an Adult at Risk at any time during their time at USW. You may notice a change in appearance or behaviour, attendance or performance. Whilst these do not necessarily indicate abuse or neglect, they may indicate a cause for concern.

Remember a failure to share information can place a child or an adult at risk of abuse and neglect and is a common feature of adult practice reviews. Whilst information in isolation may seem insignificant, put together with information from other sources it may become significant to safeguarding the adult at risk.

You can use the following resources to help you determine what action you need to take:

NSWorking together to safeguard people

PCC learning practice examples

Seeking advice and initial discussions

You can use the attached form to gather information you may need in reporting your concern.

Regulated activity with Children

Regulated activity with a child includes:

• Unsupervised teaching, training or instruction of Children (teaching/training provide wholly or mainly for Children, not courses aimed at/delivered to students who are mainly over the age of 18), carried out by the same person frequently (once a week or more often), or on 4 or more days in a 30-day period, or overnight (2am to 6am)
• Care (personal and health care) or supervision of Children
• Advice or guidance provided wholly or mainly for Children relating to their physical, emotional or educational well-being if carried out by the same person frequently (as above)
• Moderating a public electronic interactive communication service likely to be used wholly or mainly by Children, carried out by the same person frequently (as above)
• Driving a vehicle being used to convey Children

Regulated activity with Adults at Risk

Regulated activity with Adults at Risk includes:

• Personal care (physical assistance with eating or drinking, toileting, washing or bathing, dressing, oral care or care of the skin, hair or nails provided for reasons of age, illness or disability
• Healthcare (by a health care professional or person acting under the direction or supervision of a health care professional)
• Social work
• Assistance in day-to-day matters including handling cash
• Driving the adult to appointments for the purposes of: health care, personal care or social work required due to age, illness or disability
• People who hold a lasting or enduring power of attorney under the Mental Capacity Act 2005 (MCA), a deputy under the MCA, an Independent Mental Health/Capacity Advocate in respect of the individual

The following table provides definitions and examples of different types of safeguarding concern:

Welfare concerns:

Include but are not limited to risk of suicide, self-harm, untreated mental health needs, going missing, domestic abuse, exploitation, serious self-neglect, risk of homelessness, or sexual abuse

Abuse:

Abuse means physical, sexual, psychological, emotional or financial abuse (and includes abuse taking place in any setting, whether in a private dwelling, an institution or any other place).

Abuse is a form of maltreatment. Somebody may abuse or neglect a Child or Adult at Risk by inflicting harm or by failing to act to prevent harm. Abuse may occur in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse may also take the form of self-harm. Abuse can take place wholly online, or technology may be used to facilitate offline abuse.

Abuse can take different forms and includes physical abuse, sexual abuse, emotional abuse and neglect.

Neglect:

Neglect means a failure to meet a person’s basic physical, emotional, social or psychological needs, which is likely to result in an impairment of the person’s well-being, for example an impairment of the person’s health or, in the case of a child, an impairment of the child’s development. Examples include:

• ignoring medical or physical care needs
• failure to provide access to appropriate health, social care or educational services
• withholding of the necessities of life such as medication, adequate nutrition and heating
• failure to protect from physical harm or danger

Physical abuse:

Physical abuse is a form of abuse which may involve hitting, shaking, throwing, slapping, pushing, kicking, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a Child or Adult at Risk. Physical harm may also be caused when a parent or carer fabricates the symptoms or, or deliberately induces, illness in a Child or Adult at Risk
 
Possible indicators are:

• Frequent injuries
• unexplained or unusual fractures or broken bones
• unexplained bruises, cuts, burns, scalds, bite marks

Emotional abuse:

Emotional (or psychological) abuse is the persistent emotional ill-treatment so as to cause severe and persistent adverse effects on emotional development or wellbeing. It may include:

• Conveying to a person that they are worthless or unloved, inadequate or valued only in so far as they meet the needs of another person
• Age or developmentally inappropriate expectations being imposed on children
• Causing a person to frequently feel frightened or in danger, for example by witnessing domestic violence within the home, or being bullied, exploited or corrupted
• Threats of harm or abandonment
• Deprivation of contact
• Humiliation, blaming, controlling
• Intimidation, coercion
• Harassment
• Verbal abuse
• Enforcing social isolation – preventing someone accessing services, educational and social opportunities and seeing friends
• Some level of emotional abuse is involved in all types of ill-treatment of a child, though it may occur alone.

Possible indicators are:

• Lack of confidence or self-assurance
• Struggling to control their emotions
• Having difficulty making or maintaining relationships

Sexual abuse:

Child – sexual abuse involves forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact activities, including penetrative or non-penetrative acts. They may include non-contact activities, such as involving children in looking at, or in the production of, pornographic material or watching sexual activities, or encouraging children to behave in sexually inappropriate ways.

Adult at Risk – sexual abuse can include rape and sexual assault or sexual acts to which the Adult at Risk has not given consent, or is incapable of giving informed consent, or was pressured into consenting. This may involve contact or non-contact abuse (e.g. touch, masturbation, being photographed, teasing, inappropriate touching).

Sexual abuse can be perpetrated by adults regardless of their sex and/or gender identity, as can other children.

Possible indicators are:

• Displaying knowledge or interest in sexual acts inappropriate to their age
• Using sexual language or having sexual knowledge beyond their years
• Asking others to behave sexually or play sexual games
• Physical sexual health problems, sexually transmitted infections or underage pregnancy
• A change in behaviours such as becoming withdrawn or a change to their appearance
• It may be more difficult to identify possible indicators of abuse in adults than in children

Child sexual exploitation:

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity either in exchange for something the victim needs or wants and/or for the financial advantage or increased status of perpetrator. The victim may have been sexually exploited even if the sexual activity appears consensual. It can also occur through the use of technology.

Possible indicators are:

• Appearing with unexplained gifts or new possessions
• Associating with other young people involved in exploitation
• Having older boyfriends or girlfriends
• Changes in mental health and wellbeing
• Misuse of drugs and alcohol
• Missing from education

Financial or material abuse:

This may include theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.

Possible indicators include:

• Unusual activity in the bank accounts
• Unpaid bills
• Unexplained shortage of money

Online abuse:

Online abuse is any type of abuse that happens on the web, whether through social networks, playing online games or using mobile phones. Children and Adults at Risk ma experience cyber bullying, grooming, sexual abuse, sexual exploitation or emotional abuse. They can be at risk of online abuse from people they know, as well as from strangers. Online abuse may be part of abuse that is also taking place in the real world, or it may be that the abuse only happens online. Children and Adults at Risk can feel like there is no escape from online abuse – abusers can contact them at any time of day or night, the abuse can come into safe places like their bedrooms, and images and videos can be stored and shared with other people.

Domestic abuse:

Domestic abuse is categorised by any incident or pattern or incidents of controlling, coercive or 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. This can encompass physical, emotional, psychological, sexual and financial abuse.

Possible indicators include:

• Low self esteem
• Feeling that the abuse is their fault when it is not
• Physical evidence of violence such as bruising, cuts, broken bones
• Fear of outside intervention
• Isolation from friends or family
• Limited access to money

Modern slavery:

The term ‘modern slavery’ captures a whole range of types of exploitation, many of which occur together. These include but are not limited to:

• Sexual exploitation
• Domestic servitude
• Forced labour
• Criminal exploitation
• Other forms of exploitation: organ removal; force begging; forced benefit fraud; forced marriage; illegal adoption

Possible indicators include:

• Appearing to be under the control of someone else and reluctant to interact with others
• Having few personal belongings
• Not able to move around freely
• Reluctance to talk to strangers or the authorities
• Appearing frightened, withdrawn, or show signs of physical or psychological abuse

Discriminatory abuse:

Abuse based on discriminatory and oppressive attitudes towards people on the grounds of disability, gender and gender identity and reassignment, age, race, religion or belief, sexual orientation, and political beliefs.
 
It may be a feature of any form of abuse and manifests itself as physical abuse/assault, sexual abuse/assault, financial abuse/theft, neglect and psychological abuse/harassment. It includes verbal abuse and racist, sexist, homophobic or ageist comments, or jokes or any other form of harassment.
 
For more information: What is discrimination? | Equality and Human Rights Commission (equalityhumanrights.com)

Female Genital Mutilation (FGM):

FGM is when a female's genitals are deliberately altered or removed for non-medical reasons. It's also known as 'female circumcision' or 'cutting', but has many other names.
 
FGM is a form of child abuse, It’s dangerous and a criminal offence in the UK. We know:

• There are no medical reasons to carry out FGM
• It’s often performed by someone with no medical training, using instruments such as knives, scalpels, scissors, glass or razor blades
• Children are rarely given anaesthetic or antiseptic treatment and are often forcibly restrained
• It’s used to control female sexuality and can cause long-lasting damage to physical and emotional health
   

FGM can happen at different times in a girl’s or woman’s life, including:

• When a baby is new-born
• During childhood or as a teenager
• Just before marriage
• During pregnancy

A child who's at risk of FGM might ask you for help. But some children might not know what's going to happen to them. So, it's important to be aware of the signs.

Signs FGM might happen:

• A relative or someone known as a ‘cutter’ visiting from abroad
• A special occasion or ceremony takes place where a girl ‘becomes a woman’ or is ‘prepared for marriage’
• A female relative, like a mother, sister or aunt has undergone FGM
• A family arranges a long holiday overseas or visits a family abroad during the summer holidays
• A girl has an unexpected or long absence from school
• A girl struggles to keep up in school
• A girl runs away – or plans to run away- from home

 
Signs FGM might have taken place:

• Having difficulty walking, standing or sitting
• Spending longer in the bathroom or toilet
• Appearing quiet, anxious or depressed
• Acting differently after an absence from school or college
• Reluctance to go to the doctors or have routine medical examinations
• Asking for help – though they might not be explicit about the problem because they’re scared or embarrassed

Child:

• References to “child” or “Children” means anyone under the age of 18 years

Adult at Risk:

• The University bases its definition of an “Adult at Risk” on that used within the Social Services and Well-being (Wales) Act (2014)  and the All Wales Safeguarding Procedures and defines an Adult at Risk as someone over 18 years of age who:
  • Is experiencing, or is at risk of abuse or neglect,
  • Has needs for care and support (whether or not the authority is meeting any of those needs), and  
  • As a result of those needs is unable to protect themselves against the abuse or neglect or the risk of it.
• Someone aged 18 or over who receives or may need community care services because of a disability, age or illness and as a result of those needs is unable to take care of themselves or is unable to protect themselves against significant harm or exploitation. This can relate to physical, mental, or psychological wellbeing or the potential to be drawn into sexual, financial or criminal exploitation and activity.
• People with learning disabilities, mental health problems, older people and disabled people may fall within this definition.

“Work with Children or Adults at Risk”:

• “Work with Children or Adults at Risk” includes all engagement with Children and Adults at Risk whether in a professional capacity in connection with the work of the University, or in the course of other University-led activities supported by members of the University whether working in a paid or unpaid capacity

The SSG has specific responsibility to promote good safeguarding practice and ensure that the University has a fit for purpose Safeguarding Policy and related procedures that are reviewed at least annually (and on an as-needs basis) and, if necessary, revised to meet evolving regulatory requirements and relevant best practice guidance.

The University Safeguarding Steering Group will ensure that:

• this policy and accompanying procedures, advice and guidance are fit for purpose and sufficient to ensure that the University meets its statutory obligations and complies generally with good practice and where reasonably possible, with safeguarding guidance issued by relevant statutory bodies concerned with such matters
• Academic and Professional Service Departments are aware of their duties under the University Safeguarding Policy and receive any assistance that they may require to arrange appropriate training and guidance on developing their safeguarding-related procedures
• appropriate safeguarding training is available for members of the University who work with Children and Adults at Risk, whether directly in the course of their work, or indirectly by being involved in the selection process of colleagues who do work directly with Children and Adults at Risk
• processes and procedures are in place for relevant recruitment checks and that these are conducted for relevant roles including, but not limited to: DBS checks where lawfully permitted, Certificates of Good Conduct, Teacher Prohibition Orders, safeguarding aspects of Student Conduct and Fitness to Practice procedures, and that any issues arising from these checks are resolved before engagement with Children or Adults at Risk commences
• routes to report or escalate safeguarding concerns are clearly signposted, accessible and appropriately monitored
• reported safeguarding concerns are reviewed, specialist guidance sought and appropriate action taken to escalate internally and/or to the relevant external agency within statutory timeframes
• referrals are prepared and submitted as appropriate to regulatory authorities (e.g. Estyn/Ofsted), the Local Authority Designated Officer (LADO), the Multi Agency Safeguarding Hub (MASH) and/or Local Authority Children’s or Adults Safeguarding Board

The Safeguarding Steering Group is comprised of the Lead Safeguarding Officer (LSO), who chairs the group, and Principal Safeguarding Officers (PSO).

The Lead Safeguarding Officer (LSO) is a member of the University’s Senior Management Team and is currently the University Secretary.

The LSO has overall accountability and strategic responsibility for safeguarding vulnerable groups within the University.

• Accountable to the University Executive Team and Governing Body for USW’s safeguarding policy and practice
• Ensure there are appropriate structures in place to fulfil safeguarding responsibilities
• Develop University wide procedures, practice and guidance for safeguarding that are compliant with Local Safeguarding Children Board procedures
• Chair the SSG
• Ensure that safeguarding is afforded utmost priority at the most senior level within the University
• Undertake safeguarding training at an appropriate level
• Ensure that funding and human resources (including the development of colleagues and training) are available to fulfil safeguarding responsibilities
• Ensure procedures are in place for managing allegations, whistleblowing and safe recruitment practices
• Ensure that secure records of Vulnerable Groups Protection concerns are stored and shared appropriately
• Create links with relevant external agencies
• Identify the Principal Safeguarding Officers
• Ensure that monitoring and review systems are in place to incorporate new guidance and legislation and to test out existing systems
• Act as a source of support, advice and expertise to all members of the USW community on safeguarding matters

The University has two PSOs, who have strategic responsibility for overseeing the implementation of the Safeguarding Policy within the University and providing leadership and support to Designated Safeguarding Officers to undertake their role within their areas of responsibility. These are the Director of People and Inclusion in respect of individuals working at or for the University, and the Director of Student Services in respect of students. The PSOs also deputise for the LSO.

• Deputise for the LSO in the University’s senior management structure
• Receive referrals that have been escalated from Designated Safeguarding Officer level
• Liaise with the LSO to inform them of any issues and on-going investigations
• Devise the means by which the policy is implemented, monitored and refined
• Ensure the policy is accessible to colleagues and they receives appropriate information relevant to their role in order to fulfil their safeguarding responsibilities
• Refer cases of suspected abuse or allegations escalated from Designated Safeguarding Officer level to the relevant investigating agencies and report such referrals to the LSO
• Keep detailed, accurate and secure records of referrals/concerns

In those faculties and professional service departments where there are programmes or activities where colleagues, students, apprentices or volunteers work with Children and/or Adults at Risk as part of their roles, one or more Designated Safeguarding Officer will be appointed to take responsibility for safeguarding within that programme or activity. The Designated Safeguarding Officer will normally be the organiser or coordinator of the programme or activity.

Designated Safeguarding Officer’s should be specifically appointed for Apprenticeships and within Student Recruitment.

Depending on the scale of the activity affecting Children or Adults at Risk, for each Designated Safeguarding Officer appointed there may be one or more nominated Deputy to support the Designated Safeguarding Officer.

• Receive incident or case information from colleagues or students at the USW family
• Refer cases of suspected abuse or allegations to the relevant investigating agencies such as social services, police
• Report referrals to LSO/PSO when they need to be escalated and keep the LSO/PSO aware of developments in case manged by Designated Safeguarding Officer
• Act as a source of support, advice and expertise to colleagues
• Ensure programmes of activities are planned, organised and delivered in accordance with this policy
• Undertake safeguarding risk assessments of activities making suggestions for reasonable adjustments (e.g. to curriculum or assessment)
• Receive relevant and appropriate training to undertake the role
• Arrange the training, induction and guidance for all colleagues within the USW Family and volunteers appropriate for programmes or activities concerned, including drawing attention to this policy
• Ensure all relevant colleagues have induction training covering safeguarding (Level 1) and are able to recognise and report any concerns immediately they arise to the appropriate person
• Keep detailed, accurate and secure written records of referrals/concerns

For research activities it will be the responsibility of the Head of School to ensure that a Designated Safeguarding Officer is appointed for any research activities involving Children or Adults at Risk. The DSO will usually be the person with overall responsibility for the activity. The Designated Officer may appoint a Deputy DSO who is involved with day-to-day activity to support the DSO.

There are important issues to consider when working with vulnerable groups on a research project:

• The Faculty Ethics Committee/Ethics Champion/University Ethics Committee, with the Lead DBS Counter-signatory must consider whether anyone working with vulnerable groups as part of a research project (whether a colleague of the USW Family or student) requires a DBS disclosure.
• All research involving vulnerable groups must obtain approval from the relevant Faculty Ethics Committee/Champion and be consistent with the University’s policy on research ethics.
• The researcher should ensure that informed consent has been obtained from parents of children under 18. Children should be given the opportunity also to consent to participation, but parental consent is essential.
• Any research activity will respect the person’s right to confidentiality and comply with any relevant code of ethics applicable to the type of research being conducted.
• The researcher should monitor the effect of the research on the person to ensure that they feel comfortable with continuing with the research.
• Wherever possible, a same sex chaperone should always be present during the research.

In order to meet our safeguarding responsibility towards Children and Adults at Risk under this policy, Academic and Professional Services departments that work with Children and Adults at Risk must ensure that appropriately trained individuals are available and that procedures are in place to ensure that the department can comply with the University’s Safeguarding Policy.

It is recognised that the level of engagement with Children and Adults at Risk varies considerably between departments. Guidance on what arrangements would be appropriate in a range of particular circumstances is provided below, but departments should also seek advice from the University’s Safeguarding Team.

Faculties and departments that work with Children or Adults at Risk must:

• Appoint a DSO
• Appoint a Department Safeguarding Lead (DSL) if the department has an extensive programme working with Children and Adults at Risk. The DSL may also act as the DSO
• Ensure that financial provision is set aside to provide appropriately trained individuals to support the faculty’s/department’s work with Children and Adults at Risk
• Ensure that faculty/department colleagues, students, apprentices and volunteers who work with Children and Adults at Risk, are selected or recruited in line with Safer Recruitment best practice and subsequently receive appropriate safeguarding training which is updated at least annually.
• Ensure that procedures are in place to record the department’s work with Children and Adults at Risk and inform the University SSG of this activity
• Ensure that an appropriate Safeguarding Risk Assessment is carried out and that any actions identified by the risk assessment are completed before the activity commences. For example, this could include parental (carer) consent forms, contact information, allergens and dietary constrains, IT acceptable use agreement, etc.
• Ensure that faculty/departmental colleagues, students, apprentices and volunteers who work with Children and Adults at Risk are familiar with faculty/departmental and University safeguarding procedures to report and escalate safeguarding related concerns

Additionally, faculties offering apprenticeships programmes must:

• Ensure that apprentices have an awareness of safeguarding and PREVENT, and understand how to access support services at the University
• Maintain open communications with employers regarding the safety and wellbeing of apprentices
• Ensure that employers they work with are aware of their safeguarding and PREVENT obligations, with support from Degree Apprenticeship and Safeguarding teams where appropriate

We all have a duty to ensure that we treat everyone with respect. We should therefore report any concerns that we may have that Children or Adults at Risk are being abused or mistreated and that Children and Adults at Risk who engage with our colleagues, students and volunteers in the course of our work and university led activities, do so in a safe and supportive environment.

Individual members of the University community must:

• Ensure that Children and Adults at Risk are treated with respect and supported whenever they engage in university led activity
• Undertake appropriate training before engaging in any university led activity involving Children or Adults at Risk
• Ensure that they are aware of their responsibilities to safeguard Children and Adults at Risk, whether they are working for or at the University in a paid capacity or supporting university led activity in an unpaid capacity as a volunteer
• Ensure that they are aware how to report a safeguarding concern.

This is where a person has allegedly:

• Behaved in a way that has harmed, may have harmed, or might lead to the harm of a Child or Adult at Risk
• Possibly committed or is planning to commit a criminal offence against or related to a Child or Adult at Risk
• Behaved towards a Child or Adult at Risk in a way that indicates they are or would be unsuitable to work with Children or Adults at Risk

The allegation may:

• Involve a child(ren) or adult(s)
• Not directly have an identified victim as such. For example, if someone is looking at abusive images of children online or using the internet to groom children.
• Be about any type of abuse
• Relate to a person who no longer works or studies at USW (known as an ‘historical non-recent allegation’)
• Concern the child of a member of the USW family or student
• Concern a Child or Adult at Risk who is a research participant

A safeguarding allegation may arise when:

• A Child or Adult at Risk makes a disclosure about themselves
• A third party reports or makes an allegation about someone else
• Harmful behaviour is observed
• USW is informed by the police or local authority that an individual is the subject of a child/adult protection and/or criminal investigation

If someone tells you directly about a concern relating to their safety, you should:

• Remain calm
• Offer reassurance that they have done the right thing in telling you
• Listen attentively and show you are taking what you are being told seriously
• Do not interrupt the person when they are recalling significant events
• If they are under 18, explain that you have a responsibility to tell someone else about what you have been told because you want to keep them safe
• If they are an Adult at Risk, it is good practice to gain the person’s consent to share your concern. If information has been shared with you in confidence, a safeguarding concern may mean that there is justification to share the information without consent
• Explain to them what will happen next
• Make a full record of what is said and done. You can use the form for information gathering or via the Report & Support system, though this should not delay reporting the problem to the Designated Safeguarding Officer

Do not:

• Interrupt or stop them from speaking freely
• React strongly, for instance saying “that’s awful” or “how could someone do that?”
• Jump to conclusions about what happened or who is to blame
• Ask leading questions to gain more information; you can ask questions to clarify, for example “are you telling me that …?” using their own words
• Promise confidentiality
• Discuss the concern with anyone unless they hold a safeguarding role within the University
• Attempt to investigate any of the allegations

The record should include:

• The person’s account of what has occurred
• The nature of the allegation or concern
• A description of any visible physical injury (clothing should not be removed to inspect the injury)
• A verbatim record of the disclosure, which may be used later in a criminal trial. It is therefore vital that what is disclosed is recorded as accurately as possible. The record must be drafted in the person’s words and should not include the assumptions or opinions of others
• Any dates, times, or places
• Any other potentially useful information

Any safeguarding concerns or disclosure should be reported promptly to a Designated Safeguarding Officer. The problem should be reported IMMEDIATELY by the DSO/DDSO to the LSO or PSO who will take the appropriate action.

The Lead Safeguarding Officer and Principal Safeguarding Officer have the responsibility to act on behalf of the University in dealing with allegations or suspicion of abuse or neglect. This will include referring the matter to the appropriate statutory authorities (police and social services) who will assess the information and determine whether an investigation by the police and/or health and social care regulator is required, prior to the University considering whether any of its other internal procedures should be invoked I.e. disciplinary, staff dismissal, Student Conduct Regulations and Procedures and Fitness to Practise Regulations and Procedures.

If the concern is of a very serious nature and arises out of normal office hours (evenings and weekends), contact should be made directly with the relevant Safeguarding Board Emergency Duty Team.

Where there are outreach activities, for example in a school or hospital, reported or suspected abuse should be referred to the DSO of the school or hospital. The expectation of USW is that any such referral would be brought to the attention of the University’s Lead Safeguarding Officer by the school or hospital Designated Safeguarding Officer.

Receiving a disclosure can be difficult for the person it is reported to. Appropriate support will be offered to anyone who receives a disclosure, usually through line management.

Students or colleagues may disclose that they were the subject of historical abuse by someone external to USW. Some allegations of historical abuse may raise concerns that others may be at risk. If the individual has provided sufficient information to identify the alleged perpetrator, USW may have an obligation to share this information with the relevant authorities.

USW has a duty to share information with other agencies to safeguard Children and Adults at Risk.

USW will seek consent from the reporting Child or Adult at Risk before sharing the safeguarding information confidentially to an external authority or agency. However, information may be shared without consent if USW believes there is good reason to do so, and that the sharing of information will enhance the safeguarding of a Child or Adult at Risk in a timely manner. Data protection law and regulations should not be seen as a barrier to sharing information about safeguarding.

Where USW decides to share information without consent, there will be a record kept of the discussion and decision-making process to share that information.

Information should be shared on a need-to-know basis only, as judged by the Designated Safeguarding Officer/Principal Safeguarding Officer/Lead Safeguarding Officer and having taken advice from USW’s legal team.

Whistleblowing is an important aspect of a safeguarded institution whereby colleagues, student mentors and volunteers are encouraged to share genuine concerns about a colleague’s behaviour, in confidence, with a Principal Safeguarding Officer.

Working with Children or Adults at Risk places those working for the USW family and volunteers in positions of power. In order to retain the trust of a Child or Adult at Risk, it is essential that all reasonable steps are taken to ensure this power is exercised responsibly.

There may be situations whereby colleagues or volunteers have genuine concerns about the conduct of a colleague towards a child or adult. All members of the University have the right and the responsibility to raise concerns, without prejudice to their own position, about the behaviour of colleagues, managers, volunteers, students or others, which may be harmful to those in their care and will receive appropriate support when doing so.

The University will support and protect those colleagues and students who raise concerns which they believe are true (which are also made in the public interest). The concerns may include suspicions of abuse or concerns about colleagues and their actions.

This can be an extremely difficult issue to deal with. It can be difficult to accept that a colleague may harm a child or adult. It may also be the behaviour that causes concern is bad practice rather than abuse. Any concerns should be reported to the Designated Safeguarding Officer in the first instance.

It is important that any response is properly coordinated and that events are managed in the right order. For this reason, USW will not take any further action against a member of the University without the advice of the investigating agencies (e.g. the police or social services), except where such action is necessary to protect a child or adult.

If, following consideration and any consultation, the concern is clearly about bad practice rather than abuse, the University will take the necessary action to advise, manage or instigate disciplinary action against the member of the University about whom the allegation has been made.

Irrespective of the outcome of any police or social services investigations, the University may consider disciplinary action in accordance with its disciplinary procedure.

As a result of their contact with a child or adult, members of the University may become concerned that the person is being abused by someone unconnected with the University. In these circumstances the individual should report their concerns to the Designated Safeguarding Officer.

The Designated Safeguarding officer may seek advice from the Principal or Lead Safeguarding Officers to decide on an appropriate course of action and reporting.

A child or adult who is on campus through an external organisation may make an allegation of abuse to a member of the University about an adult member of that external organisation. In this situation, the member of the University must report the allegation to the Designated Safeguarding Officer.

The Designated Safeguarding Officer will report the matter to the external organisation and will notify the Lead Safeguarding Officer of their action.

The University expects the organisation to follow its own safeguarding policy and will require confirmation that the appropriate action has been taken. In addition, the Lead Safeguarding Officer will consider whether it is permissible to allow the external organisation continued use of the facilities during the investigation period and beyond.

Working together to safeguard people: code of safeguarding practice