Cogs AI Limited
Children and Young People, and Adults at Risk Safeguarding and Digital Safeguarding Policy and Procedure
1. Introduction
Safeguarding is at the heart of all our work with children, young people and adults at risk. Cogs AI Ltd has a duty to ensure that it makes arrangements to safeguard and promote the welfare of children and young people, and to protect adults at risk from abuse or the risk of abuse. This policy applies to both real-world and digital contexts.
The legislation and guidance relevant to safeguarding and promoting the welfare of children and young people, and adults at risk includes the following: The Children and Social Work Act (2017), The Children Act 1989 and 2004, Working together to safeguard children (2015), No Secrets (2000), The Crime and Disorder Act (1998), The Health and Social Care Act (2008) and the Care Act (2014).
2. Scope of the policy
The policy is to be used by any member of staff or volunteer working directly with children and young people, and adults at risk. Children, young people, adults at risk and parents/carers are informed of the policy as appropriate. The policy applies to anyone with whom we are in contact in the course of our work, who is a child, a young person, or adult at risk.
Where the policy or procedure refers to a ‘child’ or ‘young person’ it means anyone who has not yet reached the age of 18 years. An adult at risk is someone aged 18 years or over ‘who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation’ (Department of Health, No Secrets, 2000).
3. Purpose of this Policy and Procedure
This policy and procedure sets out how Cogs AI Ltd implements safeguarding for children, young people, and adults at risk with whom we come into contact with in the course of our work. Cogs AI Ltd is committed to devising and implementing policies so that everyone within the organisation accepts their responsibilities for safeguarding children, young people and adults at risk from abuse and neglect. This means following procedures to protect them and reporting any concerns about their welfare to the appropriate authorities.
This policy and procedure helps us to achieve this by:
Supporting us to safeguard children, young people and adults at risk in practice, by defining abuse
Ensuring we all work to the same policy and procedure
Making sure we are accountable for what we do
Being clear what roles and responsibilities we all have in safeguarding
Saying what staff can expect from the organisation to help them work effectively
This policy is informed by and supports our organisational purpose and is how we comply with local Safeguarding Children and Adults at Risk policies and procedures in the areas where we operate.
4. Objectives of Policy
We will achieve the objectives of this policy by having these things in place:
Safe organisational ethos
Safe environment, including digital and online environments
Safe processes for working with research participants, beta testers and users
Safe collection and use of information, and ways of communicating, including digital methods and online
Safe staff and volunteers
Principles
In support of these objectives, we are committed to the following principles, both in real-world and digital settings:
To achieve a safe project ethos, we will
Promote the safety of children, young people and adults at risk in all our work, both directly and indirectly through partnership and research work
Support the spirit and practice of this safeguarding policy in all our work as an organisation
Support the spirit and practice of Cogs AI Ltd’s safeguarding ethos in all that we personally do
Treat all children, young people and adults fairly in being able to access services which meet their needs, regardless of gender, ethnicity, disability, sexual orientation or beliefs
To achieve a safe environment, we will
Ensure the welfare and safety of children, young people and adults at risk is paramount in all our activities
Listen to research participants, beta testers and users and take account of what they tell us in making decisions about them
Take all reasonable steps to protect research participants, beta testers and users from harm, discrimination, and degrading treatment
Practice with respect for children’s rights, wishes and feelings
To achieve safe processes, we will
Take all suspicions and allegations of abuse, from inside or outside the organisation, seriously and respond to them promptly and appropriately
Be clear about everyone’s roles and responsibilities
Implement safeguarding procedures that are compliant with the expectations of the safeguarding arrangements in the areas where we operate
Have in place clear arrangements for how we would respond to concerns about how we implement safeguarding in practice within the organisation
To achieve safe information, we will
Be clear with research participants, beta testers and users how the things they tell us will be used, in line with our Privacy and GDPR Policies
Communicate promptly within the organisation and with external agencies
Keep good records of our work with research participants, beta testers and users
Hold research participants’, beta testers’ and users’ information with care, and use it for agreed purposes only, in line with our Privacy and GDPR Policies
Use best practice security protocols when handling and storing research participants’, beta testers’ and users’ information in a digital format
Use best practice security protocols when communicating digitally or online with research participants, beta testers and users
To achieve safe staff, we will
Recruit staff and volunteers with regard to their suitability for work with children, including requiring an enhanced Disclosure and Barring Service checks if the staff member or volunteer is to be left alone with children, young people, or adults at risk
Provide staff and volunteers with guidance and training in their safeguarding role, and ensure they have access to our policies and procedures
Make it clear to staff and volunteers that Zareen Ali is the Designated Safeguarding Lead and all safeguarding concerns should be immediately reported to her
Make sure all staff and volunteers know Zareen Ali is always contactable to provide advice on safeguarding at all times in the course of their work
Provide staff and volunteers with access to this safeguarding policy
Be clear with everyone what their individual role and responsibility is in safeguarding
Support staff and volunteers to carry out their job with appropriate supervision
5. Roles and Responsibilities
This section describes the general roles and responsibilities held by different positions in the
organisation with regard specifically to safeguarding. It does not describe ‘what to do’ in a particular situation, which will be found in the ‘Procedures’ section following.
Chief Executive Officer
Act as the Designated Safeguarding Lead for all safeguarding actions and decisions, which come from:
- Making referrals
- Supporting a safeguarding investigation or plan
- Reviewing the assessed level of risk which informs the way staff and volunteers work with children, young people, and adults at risk
Puts in place arrangements to recruit, train and manage staff and volunteers to practice safely
Supervise staff and volunteers and agree and implement individual training plans
Supervise and review contact work carried out by staff and volunteers, and agree and review the assessments of level of risk allocated to children, young people and adults at risk; follow procedures if any concern or allegation arises as a result, and support good practice
Ensures this policy and procedure is in place, is communicated to staff and volunteers, reviewed and practiced
Receives and responds to requests for procedural advice or guidance from staff and volunteers
Agrees when any formal action is needed to ensure that another agency is carrying out its safeguarding procedure with respect to a child, young person, or adult at risk known to Cogs AI Ltd
Acts upon any concern raised about staff practices in relation to safeguarding
Contact: zareen@cogs-ai.com
Staff working with young people
Act upon concerns and allegations involving service users and safeguarding
Report concerns and allegations according to these procedures to the Designated Safeguarding Lead and agree what Cogs AI Ltd will do
Act in a timely manner, taking account of the perceived level of risk, when the Designated Safeguarding Lead is not available
Record concerns, analysis of concerns, information, decisions, actions, clearly and promptly and keeps a log on the file of work in progress
Support safeguarding investigations or plans by sharing information appropriately and working to the plan with the child, young person, or adult at risk
Report safeguarding concerns to another agency’s safeguarding coordinator/s or manager/s, when these arise in the course of participating in events and activities where other agency professionals are the supervising workers (for example activities in settings such as schools, play facilities, youth clubs, residential units, etc.) Ensure a manager is aware of changes that might affect the assessment of the level of risk carried by a child, young person, or adult at risk they are working with, and generally work with the guidance and within the decisions of their line manager.
Report any concerns about safeguarding practice of a colleague or Board member to the Designated Safeguarding Lead
6. Safeguarding Procedures
Procedure for making a Child protection referral
Scenario: A child/young person makes an allegation or raises concerns about abuse OR your assessment of the level of risk to a child changes OR An allegation or concern is raised by someone about a child/young person.
Is the child/young person under 18 years of age? If not, follow the Adult at Risk Protection Referral procedure in the next section.
Listen to the concern – do not ask detailed questions at this stage. Believe the child/young person. Reassure them they have done the right thing by telling you.
Explain what you will need to do with the information, who you will tell, who you won’t tell, when you will tell, what might happen. Do not make reassurances that you won’t tell anyone else, even if the child/young person asks for this.
Make an immediate record of the concern or allegation, include details of the referrer, any alleged victim, any alleged perpetrator/s, date and time, how it was received (phone, text, email, letter, in person).
Assess whether the child/young person is in imminent danger or will be if they were to leave an in-person session. If so, contact the Designated Safeguarding Lead before letting the child/young person leave the session. If not, the child/young person can leave but the Designated Safeguarding Lead should be contacted immediately. If the child/young person is in immediate danger contact 999.
Discuss what immediate action to take with the Designated Safeguarding Lead, or a colleague, if they are not immediately available.
You, or the Designated Safeguarding Lead, will talk the referral through with the Duty Officer within the Children’s Social Care team of the child’s local authority.
Follow up by emailing all details to the agreed social care officer recipient within 24 hours of referral with the Designated Safeguarding Lead cc’d in.
Procedure for making an Adult at Risk Protection Referral
Is the person over 18 years of age? If not, follow the Child Protection Referral procedure in the previous section.
Listen to the concern – do not ask detailed questions at this stage. Believe the adult at risk. Reassure them they have done the right thing by telling you.
Explain what you will need to do with the information, who you will tell, who you won’t tell, when you will tell, what might happen. Do not make reassurances that you won’t tell anyone else, even if the adult at risk asks for this.
Make an immediate record of the concern or allegation, include details of the referrer, any alleged victim, any alleged perpetrator/s, date and time, how it was received (phone, text, email, letter, in person).
Assess whether the adult at risk is in imminent danger or will be if they were to leave an in-person session. If so, contact the Designated Safeguarding Lead before letting the adult at risk leave the session. If not, the adult at risk can leave but the Designated Safeguarding Lead should be contacted immediately. If the adult at risk is in immediate danger contact 999.
Discuss what immediate action to take with the Designated Safeguarding Lead, or a colleague, if they are not immediately available.
You, or the Designated Safeguarding Lead, will talk the referral through with the Duty Officer within the Adults’ Social Care team of the adult at risk’s local authority.
Follow up by emailing all details to the agreed social care officer recipient within 24 hours of referral with the Designated Safeguarding Lead cc’d in.
7. What is Child Abuse or Neglect?
Abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Abuse means a child’s rights and needs are not being met as defined in The Children’s Act 2004 and the United Nations Convention on the Rights of the Child (1989). Children may be abused in a family or in an institutional or community setting; by those known to them or, more rarely, by a stranger. Abuse may occur through the actions of an adult or adults, or another child or children.
Where a child is disabled, injuries or behavioural symptoms may mistakenly be attributed to his/her disability rather than the abuse. Similarly, where a child is black or from a minority ethnic group, aggressive behaviour, emotional and behavioural problems and educational difficulties may be wrongly attributed to racial stereotypes, rather than abuse. Cultural and religious beliefs should not be used to justify hurting a child. Safeguards for all children and young people are the same regardless of disability or ethnicity.
Physical Abuse
Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces or causes ill health to a child whom they are looking after. This situation is called Induced Fabrication Illness by a Carer (formerly known as Munchausen’s by proxy).
Emotional Abuse
Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to children that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may feature age or developmentally inappropriate expectations being imposed on children. It may involve causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Witnessing the harm of another person, such as in the case of domestic violence, is a form of emotional abuse. Some level of emotional abuse is involved in all types of ill treatment of a child, though it may occur alone.
Sexual Abuse & Sexual Exploitation
Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, including sexual exploitation, whether or not the child is aware of what is happening, and whether it is for money or reward or not. The activities may involve physical contact, including penetrative contact or non-penetrative acts. They may include non-contact activities, such as involving children in seeing or receiving or sending sexually suggestive emails or text-messages, or inappropriate behaviour in Internet chat rooms, involving children looking at, or in the production of, pornographic material of watching sexual activities, or encouraging children to behave in sexually inappropriate ways.
Neglect
Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur as a result of maternal substance abuse during pregnancy. Once a child is born, neglect may involve a parent or carer failing to provide adequate food, shelter and clothing, failing to protect a child from physical harm or danger, failure to ensure adequate supervision including the use of inadequate care-givers, or the failure to ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
Abuse of Disabled Children
Disabled children are at increased risk of abuse and those with multiple disabilities are at even more significant risk both of abuse and neglect. Parents of disabled children may experience multiple stresses. This group of children may be particularly vulnerable to abuse for a number of reasons including:
Having fewer social contacts than other children
Receiving intimate personal care from a larger number of carers
Having an impaired capacity to understand what they are experiencing is abuse or to challenge the abuser
Having communication difficulties resulting in difficulties in telling people what is happening
Being reluctant to complain for fear of losing services
Being particularly vulnerable to bullying or intimidation
Being more vulnerable to abuse by peers than other children
Disability is defined as:
A major physical impairment, severe illness and/or a moderate to severe learning difficulty
An ongoing high level of dependency on others for personal care and the meeting of other basic needs
Bullying
Bullying may be defined as deliberately hurtful behaviour, usually repeated over a period of time, where it is difficult for those bullied to defend themselves. It can take many forms, but the three main types are physical (e.g. hitting, kicking, theft), verbal (e.g. racist or homophobic remarks, threats, name calling) and emotional (e.g. isolating an individual from the activities and social acceptance of their peer group). There is increasing use of new technologies as a tool for bullying and such incidents should be taken seriously.
Self-Harming Behaviour
Children and young people who harm or attempt to harm themselves should be taken seriously. The self-harming behaviour in itself may cause impairment of the child’s health or development and in some circumstances present significant harm or the risk of significant harm. Self-harming behaviour may also arise alongside eating disorders and/or drug misuse.
Female Genital Mutilation (FGM)
Female genital mutilation is a collective term for procedures that include the removal of part or all of the external female genitalia for cultural or other non-therapeutic reasons. The practice is medically unnecessary, extremely painful and has serious physical and mental health consequences both at the time and in later life. The procedure is typically performed on girls of 4-13 years but may be performed on newborn babies or on young women. FGM can result in death.
FGM is a criminal offence (Prohibition of Female Circumcision Act 2003). Under the act it is an offence to arrange, procure, aid or abet female genital mutilation. Parents/carers may be liable under this act. It is also an offence to allow the procedure to be undertaken in another country. Where agencies become aware that a girl is at risk of FGM a referral should be made to Children’s or Adults’ Social Care.
Domestic Violence as Abuse
Domestic Violence is defined by the Home Office as: ‘Any incident of threatening behaviour, violence or abuse (psychological, physical, sexual, financial or emotional) between adults who are or have been intimate partners or family members, regardless of gender or sexuality. This includes issues of concern to black and minority ethnic (BME) communities such as so-called 'honour killings'.
The term domestic violence is used to include any form of physical, sexual or emotional abuse between people in a close relationship. It can take a number of forms such as physical assault, sexual abuse, rape, threats and intimidation. It may be accompanied by other kinds of intimidation such as degradation, mental and verbal abuse, humiliation, deprivation, systematic criticism and belittling. The term domestic violence includes the term domestic abuse.
Forced Marriage
A forced marriage is one that is conducted without the full consent of both parties and where duress is a factor. Forced marriage can amount to sexual and emotional abuse and put children or adults at risk of physical abuse. In circumstances where there are concerns that someone is at imminent risk of a forced marriage urgent referrals should be made to Children’s or Adults’ Social Care. In the case of a young person at risk of forced marriage it is likely that an initial discussion with the parent, carer or other community member may significantly increase the level of risk to the young person.
Internet Harm
Sexual exploitation (see above) also includes non-contact activities, such as involving children in seeing or receiving or sending sexually suggestive emails or text-messages, or inappropriate behaviour in Internet chat rooms, involving children looking at, or in the production of, pornographic material of watching sexual activities, or encouraging children to behave in sexually inappropriate ways.
Trafficking
Children can be trafficked into, within and out of the UK for many reasons and all different types of exploitation. Trafficking is a form of child abuse and needs an appropriate safeguarding response. Any child who is recruited, transported, transferred, harboured or received for exploitative reasons is considered to be a victim of trafficking, whether or not they have been forced or deceived. This is because it is not considered possible for children in this situation to give informed consent. Even when a child understands what has happened, they may still appear to submit willingly to what they believe to be the will of their parents or accompanying adult. It is important these children are protected too.
Children are trafficked for many reasons, including sexual exploitation, domestic servitude, labour, benefit fraud, forced marriage, begging and involvement in criminal activity such as pick pocketing, theft and working on cannabis farms. They are likely to be subjected to other forms of abuse, as a means of coercing and controlling them.
Trafficking is carried out by individual adults and organised crime groups.
Sexual activity with child/young person under the age of 18, or living away from home Consensual sexual activity involving a young person under 18 years is not always abusive, but it may be. A child’s or young person’s ability to consent can be impaired due to lack of freedom, capacity or choice; for example because of an age/power imbalance; because it is leading into sexual exploitation; because one person is in a position of trust with the other (e.g. a teacher); where one person is vulnerable because of disability or capacity; where the child/young person is in the care of another away from home. No child under the age of 13 or under is able to consent to any sexual activity according to the Sexual Offences Act (2003).
Child Criminal Exploitation
Child Criminal Exploitation is common in ‘county lines’ and occurs where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or young person under the age of 18. The victim may have been criminally exploited even if the activity appears consensual. Child Criminal Exploitation does not always involve physical contact; it can also occur through the use of technology. Criminal exploitation of children is broader than just county lines, and includes for instance children forced to work on cannabis farms or to commit theft.
8. What is abuse of an Adult at Risk?
Abuse is a violation of a person's rights or dignity by someone else. It can be done by anyone including relatives and family members, professional staff, paid care workers, volunteers, other users of services, neighbours, friends and associates or strangers. There are many kinds of abuse including:
Physical
This could be hitting, slapping, pushing and kicking
Sexual
This includes rape and sexual assault or sexual acts to which the adult at risk:
has not consented
could not consent
was pressured into consenting
Emotional/Psychological
This could be:
emotional abuse
threats of harm or abandonment
depriving the person of contact
humiliating
blaming
controlling
intimidating
coercing
harassing
verbally abusing
isolating
withdrawing a person from services or support networks
Financial or material
This includes:
theft
fraud
exploitation
pressure in connection with wills, property, inheritance or financial transactions
misusing or misappropriating property, possessions or benefits
Neglect or acts of omission
This includes:
ignoring medical or physical care needs
failing to provide access to appropriate health care, social care or education services
misusing medication
inadequate nutrition or heating
Discriminatory
This includes:
racist behaviour
sexist behaviour
harassment based on a person's ethnicity, race, culture, sexual orientation, age or
disability
other forms of harassment, slurs or similar treatment