1. Purpose

The purpose of this policy is to:

  1. Protect children, young people, and vulnerable adults who receive Variety’s services or any part thereof.
  2. Provide staff and volunteers with the overarching principles that guide our approach to safeguarding children and young people.

Variety, the Children’s Charity, believes that no child or young person should ever experience abuse at any time. The Charity recognises that it has a responsibility to promote the welfare of all children and young people and to keep them safe. The welfare of children, young people, and adults is paramount in all the work we do.

Legislative framework

This policy has been drawn up on the basis of legislation, policy, and guidance that seeks to protect children in England, Wales, and Scotland. Key legislation and guidance include:

  • The Children Act 1989 and The Children Act 2004
  • Working Together to Safeguard Children (2023): The statutory guidance on inter-agency working to safeguard and promote the welfare of children.
  • The Care Act 2014: Regarding the protection of adults at risk.
  • The Domestic Abuse Act 2021: Which legally recognises children as victims of domestic abuse if they see, hear, or experience the effects of abuse.
  • The Online Safety Act 2023: Regarding the protection of children from harmful online content.
  • Police, Crime, Sentencing and Courts Act 2022: Regarding positions of trust.

This policy applies to the Board of Trustees, staff (inclusive of agency staff), committee members, volunteers and anyone else working on behalf of Variety, the Children’s Charity.

2. Definitions

Children and Young People
A child or young person is anyone under 18 years old. A child or young person becomes an adult on the day of their 18th birthday.

Vulnerable Adult
The Care Act (2014) describes an adult at risk as anyone over 18 years who:

  • Has care and support needs (even if these are not met).
  • Is experiencing, or is at risk of, abuse or neglect.
  • Is unable to protect themselves.

Abuse and significant harm

Abuse is any action by another person (adult or child) that causes significant harm to a child or vulnerable adult. This includes physical abuse, emotional abuse, sexual abuse, neglect, bullying (including cyberbullying), modern slavery, organisational abuse, and being exposed to domestic abuse.

Domestic abuse: Under the Domestic Abuse Act 2021, Variety recognises that children who witness domestic abuse or live in a home where it occurs are victims in their own right.

Child-on-child abuse: Variety recognises that children can abuse other children. This is referred to as “Child-on-Child Abuse” (formerly peer-on-peer abuse). This can include bullying, cyberbullying, sexual violence, and sexting. We take these concerns as seriously as abuse perpetrated by an adult.

3. Types of abuse and signs

The NSPCC recognises 12 different types of child abuse. Variety staff must be vigilant to these, which include:

  • Primary: Physical, sexual, emotional, neglect.
  • Specific: Domestic abuse, online abuse, Child Sexual Exploitation (CSE), Female Genital Mutilation (FGM), child trafficking, grooming, harmful sexual behaviour, bullying and cyberbullying.

Position of Trust:

It is a criminal offense for any person in a Position of Trust (including staff and volunteers) to engage in sexual activity with a 16 or 17-year-old, even if consensual.

A shift in the way a child behaves or appears is often the most useful indicator that a child is at risk.

Staff should be vigilant for unusual behaviour including withdrawal, anxiety, aggression, self-harm, or inappropriate sexual knowledge.

4. Roles and responsibilities

Safeguarding is everyone’s responsibility. However, specific staff oversee the function:

Designated Safeguarding Lead (DSL): Lindsey Cape

  • Role: Director of Fundraising and Communications
  • Contact: lindsey.cape@variety.org.uk | 0207 428 8115
  • Responsibilities: first point of contact for concerns, providing advice compliant with legislation, and referring to statutory agencies.

Deputy Designated Safeguarding Lead (DDSL): Hannah Gooding

  • Role: Programme Engagement Manager:
  • Contact: hannah.gooding@variety.org.uk | 0207 428 8133
  • Responsibilities: acts in the absence of the DSL or where concerns are raised about the DSL.

5. Reporting procedures

Immediate danger

If there is an immediate risk of harm or if emergency medical assistance is required, contact the emergency services on 999.

Reporting concerns

If you have any concerns, no matter how small, about the safety or welfare of a child or young person, you must discuss this with the Safeguarding Lead (DSL) as soon as practically possible.

  • Variety records all concerns about the welfare of a child, not just disclosures of abuse.
  • Always record everything clearly and accurately using a Safeguarding Incident Form.

Responding to a disclosure

If a child discloses abuse to you:

  1. Listen and accept.
  2. Try not to interrupt.
  3. Tell the child they’ve done the right thing.
  4. Do not promise confidentiality; inform the child you must tell someone who can help.
  5. Make accurate notes using the child’s own words within 24 hours.
  6. Inform the Safeguarding Lead immediately.

If the DSL/Deputy are unavailable, seek advice from the NSPCC helpline on 0808 800 500.

6. Managing allegations and concerns

A. Low-Level Concerns policy

Variety promotes a culture of openness. A “Low-Level Concern” is any concern about an adult’s behaviour towards a child that does not meet the allegation threshold (harm) but is inconsistent with the Code of Conduct.

  • Examples: being over-friendly, favouritism, using inappropriate language.
  • Action: staff must report “nagging doubts” or low-level concerns to the DSL. These are recorded securely to monitor patterns of behaviour, ensuring that minor issues do not escalate into abuse.

B. Allegations against staff/volunteers

Any allegation that an employee or volunteer has behaved in a way that has harmed or may have harmed a child must be taken seriously.

  1. Report immediately to the Safeguarding Lead. (If against the DSL, report to the Chief Executive/Chair of Trustees).
  2. Suspension: the staff member should be suspended immediately pending investigation. Suspension is authorised by the Chief Executive.
  3. Investigation: an initial investigation will be carried out by the line manager and DSL within 5 working days.
  4. LADO Referral: if the threshold is met (harm, criminal offence, unsuitability), the DSL will refer to the Local Authority Designated Officer (LADO).
  5. Police: police investigations take precedence over internal disciplinary processes.

C. Whistleblowing

If a staff member feels their concerns have not been acted upon by the DSL or Charity leadership, they should contact the NSPCC Whistleblowing Advice Line: 0800 028 0285.

7. Safeguarding at events (Variety Great Days Out)

Supervision ratios and chaperones

  • Responsibility: Variety does not take sole responsibility for anyone under 18 at a Variety Great Day Out.
  • Requirement: Families/Groups must bring sufficient adults (minimum 1) to take responsibility for their children.
  • First Aid: All events must have at least one trained First Aider present.
  • Lone Working: Variety staff must never be left alone to temporarily supervise or toilet a child.

16 and 17-year-olds

  • General: may attend without a parent/carer at the discretion of the event manager.
  • Exceptions: chaperones are required if alcohol is served, if the young person has a disability requiring care, or is attending as part of a school group.
  • Travel: Variety will ensure safe transport home is agreed in writing if the young person attends alone.

8. Online safety and social media

Variety adheres to the Online Safety Act 2023 principles and the “4 Cs” of online safety:

  1. Content: Protecting children from exposure to illegal or harmful material.
  2. Contact: Protecting children from harmful interaction (grooming, peer pressure).
  3. Conduct: Protecting children from aggressive behavior or bullying.
  4. Commerce: Preventing risks related to scams or gambling.

Rules for staff:

  • Personal accounts: employees/volunteers are not permitted to follow, befriend, or communicate with beneficiary children via personal social media (Facebook, Instagram, WhatsApp, etc.).
  • Official accounts: Variety’s official accounts will not be used to contact children under 18 directly or tag them without written consent.
  • Reporting: any potentially illegal content or online grooming must be reported to the DSL immediately.

9. Training

  • Mandatory training: all employees, trustees, and volunteers must attend safeguarding training annually.
  • Levels:
    • Level 1/2: All staff and volunteers (Basic awareness).
    • Level 3: The DSL and Deputy DSL (Multi-agency safeguarding).
  • Refresher: staff are required to attend a refresher every year.