Bankhall Mission Church
Safeguarding Policy, Procedures, and Codes of Conduct
1. Purpose
This policy with its procedures and appendices outlines how we will seek to:
1.1. Ensure that we provide a healthy and spiritually nurturing, environment for everyone who engages with our church community.
1.2. Ensure that every member of our church community is protected from harm, including harassment, abuse, and exploitation.
1.3. Ensure that that any harm that is identified, regardless of where it occurred is handled effectively, promptly, and proportionately.
1.4. Ensure that when supporting people who have experienced harm:
1.4.1. We treat with dignity, respect, and compassion.
1.4.2. That their views and wishes are given full consideration.
1.4.3. That we act in their best interest.
1.4.4. That we ensure they are appropriately involved in and informed of decisions that affect them.
1.5. Ensure that where concerns or support needs that fall below the threshold for reporting to statutory services are identified, responses that are appropriate, proportionate, and consent-based are made.
1.6. Ensure that appropriate, confidential safeguarding records, that allow us to fulfil our duty of care to protect and promote the wellbeing of those to whom we minister, are securely kept, and disposed of in line with our legal duties and best practice under both safeguarding and data-protection legislation and guidance (details of our data storage and disposal procedures can be found at appendix.)
1.7. Ensure that our trustees, staff, and volunteers are clear about their responsibilities and duties and are supported to fulfil them competently and confidently.
1.8. Support the development of an open and transparent culture that listens to the views and wishes of every member of our church community and encourages and supports the raising of concerns, complaints, and allegations.
1.9. Provide leadership and accountability for every member of our church community, including our most senior leaders in relation to safeguarding.
1.10. Ensure that all our ministry, is provided in a manner that is consistent with our biblical beliefs, and that where challenge, or even formal church discipline are required, that Christian love, grace and mercy, gentleness and kindness characterise our interactions.
1.11. Ensure that church leaders model biblical and Christlike servant leadership, valuing, caring for and nurturing those that God brings under their authority with meekness and humility, as those who will give an account in the final judgement.
1.12. Ensure that all church members have a basic understanding of safeguarding and that they understand their responsibility to raise and challenge any abusive behaviours.
2. Scope
2.1. This policy applies in particular to staff or volunteers who work on our behalf with vulnerable people (children, young people, their parents / carers, adults at risk of abuse or adults with care and support needs) and to those who have leadership and oversight of the church’s activities. This includes trustees, senior leaders, group / ministry leaders, paid staff, volunteers, or others working on our behalf.
2.2. The policy also outlines the general responsibilities of every member of our church community to raise concerns about individuals or practice in the church with the appropriate officers.
3. Context
Bankhall Mission Church is a charitable incorporated organisation and exists to live out our faith, preach hope, and love our community. We meet on Knowsley Road in Bootle, Liverpool.
We are a mix of young and old, predominantly white British but also consisting of members from Africa and Asia.
The church is led by a team of elders, with decisions being made amongst the leadership team, consisting of elders and deacons, before being voted on by the church membership.
4. Definitions
Additional needs: is a term most often applied to children who require support beyond what we would usually expect to provide to a child of that age or developments stage.
Adult: a person who is at least 18 years of age
Adult at risk of abuse / in need of protection: refers to adults who have care and support needs, are at risk of abuse, and due to their support needs are unable to protect themselves from the abuse.
Adult with care and / or support needs: refers to an adult who requires help with day-to-day tasks that most people would be able to perform for themselves.
Child: A child is a person who has not yet attained their 18th birthday which aligns with the United Nations Convention of the Rights of the Child. In Scotland, the position is slightly more complex as Scottish law also recognises an age of “Legal Capacity” which is 1. Unborn children are included within the scope of Child Protection.
Child in Need: Similar to targeted safeguarding, this refers to care and support that is offered to a child or family with more complex needs such that if effective support is not provided, the child is unlikely to achieve or maintain a satisfactory level of health, development, or wellbeing.
Child Protection: refers to safeguarding activity that has met the statutory threshold for referral to the Police or Social Care and involves the prevention of, or response to “significant harm”.
Deacon(s): refers to those appointed by the church to that office to support the Elders and serve the church in practical and legal matters.
Elder(s): refers to those appointed by the church to that office to provide spiritual leadership and instruction. The Elders have the spiritual authority within the church.
Officers: refers to all those who hold formal office in the church including Deacons and Elders, and Trustees.
Regulated activity: refers to activity that a barred person must not do. In simple terms, it is activity that requires a DBS check.
Safeguarding arrangements: is used in this policy, procedures and related documents as a generic term that includes all aspects of the church’s approach to safeguarding, including matters related to policy, process, culture, and practice.
Single Central Record: is the master record of all pre-appointment checks and processes that were completed prior to appointment to a role.
Spectrum of safeguarding: is the whole range of safeguarding activities that includes universal safeguarding, consent-based care, and support (i.e., support that falls below the statutory threshold), and the statutory responsibility to protect children, young people, and adults at risk of abuse from significant harm.
Staff: refers to any paid employee or office holder.
Statutory threshold: the point at which the church has a duty to report a concern to report a matter to one of the statutory bodies such as the Police, Social Care, or the Charity Commission.
Sub-threshold (or consent based) safeguarding: matters or concerns which do not meet the criteria for referral to statutory authorities. These issues may still be serious and require a response from the church, however, internal processes will be followed.
Targeted Safeguarding: care or support that is offered to a child or their family on the basis of consent to prevent harm and promote wellbeing where there is a risk of poor outcomes form the individual if their support needs are not met.
Trustee(s) refers to those who are legally responsible for the governance and oversight of the charity.
Universal safeguarding: activity that is required to keep everyone safe. This includes those who have no additional needs and includes the interface with other aspects of safety such as Health and Safety and employer responsibilities.
Volunteer(s): refers to anyone who is appointed by the church to a role or who performs identified tasks on behalf of the church for which they receive no payment (other than out-of-pocket expenses that are appropriately authorised).
Vulnerable people: is a generic term that can be used to mean different things and so care is needed. In the context of this policy, the term is used in a generic sense to include anyone who has a support or care need or whose ability to protect themselves against abuse is limited. This includes children, young people, adults with support needs and adults at risk of abuse. It also includes those who, due to specific individual circumstances find themselves, either for a short time or over a more extended time, requiring additional care, support, or protection, but who would not otherwise be regarded as needing support.
5. Values and beliefs
If the church has articulated values and a mission statement these can be referenced or inserted here
We believe that:
5.1. Everyone who engages with our church community, including staff, volunteers, and beneficiaries, has the right to be protected from any form of bullying, harassment, exploitation, or abuse and we will seek to ensure that we provide a caring and nurturing environment that is open and transparent, and that promotes the raising of concerns with senior leaders.
5.2. We have a particular responsibility to protect and promote the wellbeing of those who have care and support needs and those at risk of abuse including children, young people, and adults at risk of abuse; ensuring they are safe while in our care and that we respond appropriately to disclosures or indicators that they may be experiencing abuse or neglect while in our care or elsewhere.
5.3. Every member of our church community has a responsibility to act to support the values and commitments outlined in this policy.
5.4. Everyone who engages with our church community has the right to be treated with dignity and respect.
5.5. Our approach to safeguarding is rooted in, and is a practical outworking and expression of, our biblically based values and supports and confirms our gospel witness.
5.6. Our approach to safeguarding is shaped by our belief as Christians that:
5.6.1. God is holy, loving, merciful and just and he requires his people to live in accordance with his character; acting justly, loving mercy, and living humbly before our God who will ultimately judge all people for the deeds performed in this life.
5.6.2. The church, as the body of Christ on earth should uphold truth and justice with grace, without fear or favour, prejudice, or privilege.
5.6.3. Those in authority within the church are accountable to and will be judged by the God who sees all things and judges impartially.
5.6.3.1. Higher standards are expected of leaders, who will be judged more severely than those who do not teach.
5.6.3.2. Leaders are to follow the example of Christ, leading with sacrificial, servant-hearted humility.
5.6.4. Sin in the church, should be identified, confronted, and dealt with through confession and repentance.
5.6.4.1. Where such sin involves criminal activity, it should be reported to the civil authorities who are appointed by God to uphold justice and order in society.
5.6.5. The church is not a gathering of sinless and perfect people, but rather a community of grace where we seek to encourage one another to grow in faith and obedience to God.
5.6.5.1. We are called to encourage and challenge each other lovingly and to spur one another on to greater holiness and obedience to God in an attitude of humility, grace, and forgiveness.
5.6.5.2. Where necessary, the church may impose formal discipline on its members in accord with its governing documents and rules of church order.
5.6.6. We are to honour those that God has set in authority over us and to live as responsible and good citizens in the time and place that God has set us.
5.6.7. Every human life, including that of the unborn, is valuable to God and each person bears his image.
5.6.8. We live in a fallen and sinful world, where there are many risks and dangers and we must seek to protect everyone, but particularly the vulnerable in our midst from those dangers.
5.6.9. God cares for the widow, the orphan, and the stranger; he calls us to protect and care for those who are vulnerable in our society and to oppose exploitation, oppression, abuse, and the inflicting of harm due to negligence.
5.6.10. Jesus’ example was one of valuing and caring about those with whom he came into contact; even when delivering difficult and challenging messages.
5.6.11. We are to love those around us as God loves them and to seek to bring healing, restoration, and reconciliation to broken and damaged lives by the manifestation of the love of God through us.
5.6.12. The church is a place of grace, forgiveness and transformation, justice, truth, and holiness.
5.6.12.1. The gospel offers forgiveness by grace, through faith, but does not negate justice or remove the temporal consequences of the sin that has been forgiven.
5.6.13. In this present time, the kingdom of God on earth is a spiritual kingdom that resides in the lives of God’s people, and it only be advanced by proclamation and the work of the Holy Spirit in convicting and convincing.
5.6.13.1. The kingdom of God cannot be advanced by coercion or force.
6. Our responsibilities and commitments
6.1. Our responsibilities
6.1.1. To ensure that the protection of all members of our community, but particularly children, young people, and adults at risk of abuse, and the promotion of their welfare is of paramount importance to us and that best practice in safeguarding is embedded into the culture or our church.
6.1.2. To treat each person as equal in the sight of God, showing no favour or partiality.
6.1.3. To seek to minister to, and to encourage growth in obedience to God and his word with equity, transparency, and sensitivity, in accordance with our fundamental beliefs as laid out in our statement of faith, charitable aims and governing documents.
6.1.4. To value, respect and listen to the wishes of every member of our community, including those who are vulnerable or find it difficult to make their voice heard.
6.1.5. To ensure that as a church we are alert to the risks within society, including risks associated with grooming, online abuse, radicalisation, gender-based violence, exploitation, domestic abuse etc and to report appropriately.
6.1.6. To work in partnership with children, young people, their parents / carers, adults at risk of abuse and local and national partner agencies and organisations as appropriate, to promote the welfare of, and to protect, each member of our community; particularly those who are more vulnerable.
6.1.7. To work to develop and maintain an environment that is protective, caring and nurturing for all who engage with our community, in accordance with our doctrines and beliefs as outlined in our governing documents.
6.1.8. To ensure that everyone who ministers or serves within the life of the church is suitable and competent to do so and that they understand the responsibilities of their role.
6.1.9. To ensure that we will support victims of past and present abuse and trauma recognising our limitations and referring to specialist services where necessary.
6.2. How we will seek to fulfil these responsibilities
6.2.1. We aim to visibly demonstrate our commitment to safeguarding throughout the church and our most senior leaders will support the development of best practice and provide accountability to everyone who works (whether paid or voluntarily) on our behalf; including providing accountability and challenge to each other.
6.2.2. We will ensure that those who are responsible for safeguarding at the various levels of the church are appropriately trained and supported to fulfil their role competently and confidently.
6.2.3. We will actively seek to create and maintain a culture that is consistent with our biblical beliefs and best practice in safeguarding.
6.2.4. We will ensure that we have robust and relevant policies, procedures and systems that support the culture or our organisation and the work of all those involved in safeguarding, and that these are reviewed for effectiveness annually.
6.2.5. We will ensure that we appoint a Designated Safeguarding Lead and at least one deputy who will take responsibility for leading the safeguarding of children and adults across the organisation.
6.2.5.1. Safeguarding will be promoted and overseen by our senior leaders.
6.2.5.2. Delegation of tasks and responsibilities will be clearly outlined in the relevant role descriptions and the organisation’s safeguarding structures, complete with contact details, will be included in our procedures, and made publicly available.
6.2.6. We will adopt proportionate safer recruitment best practice in the recruitment and selection of staff and volunteers.
6.2.7. We will provide effective leadership, management, and support to the staff and volunteers who deliver services on our behalf including:
6.2.7.1. Ongoing training and skills development.
6.2.7.2. Supervision and pastoral support.
6.2.7.3. Quality and performance management measures.
6.2.8. We will ensure that we consider safety in all areas of our work and ministry:
6.2.8.1. Developing a positive culture.
6.2.8.2. Managing health and safety through effective policies and procedures; using risk assessment processes and proportionate systems.
6.2.8.3. Creating a positive and nurturing environment in all aspects of the community, including physical, social, emotional, psychological, spiritual etc environments.
6.2.8.4. Considering the online as well as the physical environments; including our use of social media and technology.
6.2.9. We will ensure that we monitor the conduct of our staff and that we have policies, procedures, and systems for managing allegations against staff or volunteers, supported by a culture of listening to allegations and responding with rigor, fairness, and transparency.
6.2.10. We will ensure that our expectations in relation to the conduct of members of our community are clear through codes of conduct, policies and procedures including:
6.2.10.1. Anti-bullying and zero-tolerance approach to bullying; including cyber-bullying and the bullying of volunteers, staff, and leaders.
6.2.10.2. Dealing with peer-abuse (including domestic abuse) and harassment (including sexual harassment.)
6.2.10.3. Clear accountability processes and sanctions for infringements of the codes of conduct.
6.2.10.4. Equality and diversity and a culture of zero-tolerance of discriminatory or abusive attitudes, language, or behaviours.
6.2.11. We will seek to clearly identify concerns about the safety or wellbeing of those who are part of our community and to respond appropriately and proportionately:
6.2.11.1. To signpost or refer them to local or national services that can help them.
6.2.11.2. To provide information, guidance, and support as we are able.
6.2.11.3. To share information appropriately with partner agencies where we have concerns about the safety of an individual and statutory thresholds and / or criteria are met.
6.2.12. We will record and store information accurately, keeping it securely in line with our legal duties, information sharing policies and national and local guidance and agreements. This will include records such as:
6.2.12.1. Consent forms.
6.2.12.2. Attendance data for work with children, young people, and Adults at Risk of Abuse.
6.2.12.3. Accident and incident reporting.
6.2.12.4. Confidential recording of safeguarding concerns.
6.2.13. We will involve children, young people, their parents or carers and adults at risk of abuse in our safeguarding processes wherever possible; making reasonable adjustments where necessary to enable them to participate in the decisions that affect them.
6.2.14. We will ensure that we have a culture and policies and procedures for raising concerns or complaints by any member of our community including children, young people, adults at risk of abuse and their parents / carers and for dealing with those concerns in an efficient, open, honest, and fair manner, including clear appeals processes.
6.2.14.1. We will also ensure that our leaders are competent and confident in handling complaints, concerns, and allegations.
6.2.15. We will develop a culture that encourages every member of our community to identify and raise concerns and will support this with a clear whistleblowing policy.
6.2.16. We will ensure that relevant policies, procedures, codes of conduct etc are publicly available.
Safeguarding Procedures
7. Purpose
These procedures aim to provide staff and volunteers with clear and simple instructions as to how safeguarding is promoted and how concerns should be handled. They are not provided for training purposes and will not be used as a substitute for training.
8. Scope
These procedures apply to all staff and volunteers and others who act on behalf of the church.
9. Governance and oversight
The Trustees will provide effective oversight of safeguarding across the church by:
9.1. Ensuring that they appoint from amongst their number a nominated Safeguarding Trustee who will act on their behalf to provide leadership and guidance on matters related to safeguarding.
9.2. Ensuring that the church leadership promote the importance of safeguarding and lead the development of a culture that is biblically faithful, healthy, transparent, and accountable and that safeguarding is appropriately prioritised, and its profile maintained.
9.3. Ensuring that a suitably knowledgeable and appropriately trained and skilled Designated safeguarding Lead (DSL) and a deputy are appointed and that they are adequately supported and resourced.
9.4. Ensuring that a proportionate and legally compliant safeguarding policy is implemented and that it is reviewed by the trustees with input and support from the DSL and Deputy DSL at least annually, but more frequently as required.
9.5. Ensuring that clearly defined safeguarding procedures and systems are in place, that they are understood and implemented by all staff, volunteers, and anyone else who acts on our behalf.
9.6. Ensuring that the DSL provides a verbal update to all trustee meetings (which will be conveyed by the safeguarding trustee) and that a written annual report is provided to the trustees by the Safeguarding Trustee, the DSL, and Deputy DSL.
9.7. Ensuring that the effectiveness of the safeguarding arrangements is monitored on an ongoing basis and reviewed annually in line with the review of the policy and procedures.
9.8. Ensuring that safeguarding roles and responsibilities are clearly defined, and that appropriate accountability is provided (see appendix A).
9.9. That a clear statement in relation to safeguarding is included in the annual Charity Commission submission.
9.10. That any “Serious Incidents” (as defined in the Charity Commission Guidance – https://www.gov.uk/guidance/how-to-report-a-serious-incident-in-your-charity) are reported accurately and in a timely manner
10. Recruitment and ongoing support of staff and volunteers
The recruitment / appointment and support of staff and volunteers is of critical importance to Bankhall Mission Church and to our work and ministry. To fulfil our legal duties and to ensure we meet the still higher standards dictated by scripture, all staff and volunteers will be subject to appropriate recruitment processes.
10.1. Management of recruitment processes
10.1.1. At least one person who is involved in the process of recruitment of staff or appointment of volunteers will be trained in Safe Recruitment.
10.1.2. Staff and volunteers will be provided with written Job / role descriptions and person specifications prior to deciding whether to take up the position / role.
10.1.2.1. Roles that involve regulated activity and which consequently are subject to a DBS check will be clearly identified as exempt from the Rehabilitation of Offenders Act.
10.1.3. Appropriate records will be kept of all recruitment processes and decisions.
10.1.4. A “Single Central Record” of recruitment checks and a training log will be maintained.
10.2. Recruitment process
10.2.1. Prior to appointment, all staff and volunteers will be required to submit an application form (see appendix D) including a self-declaration of fitness and suitability for the role (see appendix). Where necessary and appropriate (e.g., lack of literacy skills, English as a second language etc) support can be provided for completion of the forms.
Paid staff positions
10.2.2. Prior to appointment all paid staff will be required to attend a formal interview, regardless of whether a competitive process is in operation.
10.2.3. Prior to appointment of staff, references will be sought, including, where possible, a reference from the current or previous employer.
10.2.4. Upon commencement of their position, all staff will be required to complete a formal induction process as outlined in their role description and including any matters identified during the recruitment process.
10.2.5. The Single Central Record, training Log and Personnel file will be updated as appropriate throughout the process.
Volunteer positions
10.2.6. Prior to appointment, all volunteers will be required to attend a formal discussion to ensure their suitability and clarity of understanding of the role and its requirements.
10.2.7. Prior to appointment, references will be sought. Where an appropriate reference was obtained at the time of application for formal church membership, this may be used, and internal references are acceptable.
10.2.8. Following appointment and prior to commencement of the role, volunteers will be required to complete a formal induction process as defined in the role description.
10.2.9. The Single Central Record, training Log and Personnel file will be updated as appropriate throughout the process.
DBS Checks
10.2.10. Following appointment and prior to commencement of the role, staff and volunteers involved in regulated activity will be required to complete a DBS check.
10.2.10.1. Under normal circumstances, the individual will not commence their role until the result of the DBS check has been received.
10.2.10.2. Under exceptional circumstances and where it is necessary for the person to commence prior to receipt of the DBS check result, a formal risk assessment will be completed.
10.2.10.3. A formal agreement that outlines the duties that are permitted, and all measures implemented to prevent the individual having unsupervised access to vulnerable people will be drawn up and signed by the appointee and the DSL or the Safeguarding Trustee.
10.2.11. Once formal notification of a clear DBS check has been received, the Single Central Record will be updated with the relevant information.
Blemished DBS Checks
10.2.12. The applicant will be asked to present the DBS certificate to the Lead Recruiter
10.2.12.1. The applicant may, if they wish to, withdraw their application.
10.2.12.2. If the application is withdrawn, consideration should be given to whether this required the triggering of the “Management of ex-offenders or those who pose an actual or potential risk to others; particularly to vulnerable people” (see section 14 of this policy) process needs to be triggered.
10.2.13. If the applicant self-declared the blemish and it has been discussed previously, the recruiter will check to ensure that the detail provided in the self-disclosure is consistent with the information on the DBS certificate.
10.2.14. If the applicant did not self-disclose, an open conversation about the circumstances of the blemish will be discussed with the applicant.
10.2.15. Whether the discussion arises from self-disclosure or examination of the certificate, a formal assessment will be conducted to ascertain the applicant’s suitability for the role and the outcome will be recorded.
10.2.15.1. Advice can be sought from CSS if required.
10.2.15.2. The applicant will be given every opportunity to provide input to the assessment and the outcome will be explained to them.
10.2.16. A blemished DBS check does not necessarily prevent the individual from engaging in regulated activity. The risk assessment may conclude:
10.2.16.1. That the individual is unsuitable for the role.
10.2.16.2. That further investigation is required.
10.2.16.3. That the person is suitable for the role with restrictions.
10.2.16.4. That the blemish does not indicate unsuitability.
10.2.17. If the risk assessment concludes that the individual is unsuitable for the role, consideration will be given to whether the “Management of ex-offenders or those who pose an actual or potential risk to others; particularly to vulnerable people” (see section 14 of this policy) process needs to be triggered.
10.2.18. Once the details of the certificate have been recorded in the Single Central Record, the certificate will be returned to the applicant and no copies will be retained.
Probationary periods
The precise nature and expectations of probationary periods will vary from role-to role as described in the role description, however, they are intended to be supportive of the volunteer / employee and to provide a framework that provides accountability to both the individual and the organisation. Probationary periods will not be used for punitive purposes.
10.2.19. Al staff and volunteers will be subject to a formal probationary period.
10.2.20. Prior to commencement of the role, a clear statement of the criteria for successful completion of the probationary period will be provided.
10.2.21. Regular support, guidance and review will be provided throughout the probationary period and the outcome (passed, extended, failed) will be communicated to the employee or volunteer prior to the end of the probationary period and records will be retained of all discussions.
Ongoing support and supervision
10.2.22. All staff and volunteers will receive proportionate supervision and pastoral care. Supervision will include both personal wellbeing and performance management.
10.2.23. Where DBS checks are required, these will be updated at least every three years.
Training
10.2.24. All staff and volunteers in roles that involve regulated activity or those who manage such staff will be required to attend regular safeguarding training.
10.2.24.1. Trustees will receive initial training. While there is no legal requirement for formal update training, the trustees will ensure that they are competent in their roles and that their knowledge of compliance with legislation and Charity Commission guidance up to date.
10.2.24.2. Church leaders will refresh their training every three years.
10.2.24.3. Volunteers and staff involved in working with children, young people, or adults at risk of abuse are required to update their training at least every three years.
10.2.24.4. The Designated Safeguarding Lead and the Deputy DSL are required to attend formal update training at least every two years.
10.2.24.5. All staff, volunteers and trustees will undergo some informal update activity annually.
10.2.24.6. Training should include themes on domestic abuse and trauma and the impact on victims including children.
10.2.24.7. Children are now regarded by law (Domestic Abuse Act 2021) as victims of domestic abuse if they are living in a home where their parents or relational care givers are abusing each other.
10.2.25. A log of training and DBS checks will be maintained by Bankhall Mission Church.
11. Ensuring a safe and healthy environment
Bankhall Mission Church fully recognises that there are many factors that impact on and contribute to the safety of the environment for everyone; some of these being procedural and others cultural. Here we describe only the procedural aspects.
Health and Safety
11.1. The officers aim to ensure that the health and safety of everyone who enters our church community is protected by:
11.1.1. Regularly reviewing our health and safety policy to maximise effectiveness and ensure ongoing legal compliance.
11.1.2. Maintaining and implementing proportionate Risk Assessments for both the premises and the activities of the church.
11.1.3. Maintenance and analysis of Accident and Incident Reports on receipt to ensure appropriate lessons are learned and timely responses are implemented and an overview analysis of reports that examines trends and recurring themes will be conducted at least annually.
11.1.4. Ensuring that adequate First Aid cover is available, and that only qualified First Aiders administer First Aid, except in emergency situations when instructed to do so by Emergency Services.
11.1.5. Ensuring that appropriate safety equipment such as First Aid kits, Fire Extinguishers etc are available and maintained on an ongoing basis.
11.1.6. Key Health and Safety information will be prominent and best practice will be promoted through announcements, effective signage etc.
Awareness raising
11.2. Bankhall Mission Church recognises that any member of our church community could discover or receive a disclosure of abuse, and therefore all members need a basic awareness and competence, regardless of whether they engage directly in ministry to children, young people, or vulnerable adults. We will raise awareness by ensuring that:
11.2.1. Information about our policies, procedures and codes of conduct are publicly available and promoted by our leaders.
11.2.2. Details of our safeguarding team are prominently displayed.
11.2.3. We set clear expectations of conduct and that clear processes for identifying, challenging, investigating, and dealing with inappropriate conduct are implemented.
11.2.4. We implement and promoting clear and transparent processes for the raising of concerns or complaints, supported by a culture that encourages and welcomes these as opportunities to learn and improve.
When engaging in ministry to children and / or young people we will:
11.3. Ensure that registers of children attending, and leaders present are maintained.
11.4. Ensuring that those involved in such ministries have been appointed in accordance with our Safe Recruitment procedures.
11.5. Ensure that consent is obtained for their attendance at the group and that contact details and information about any additional or specific needs are recorded.
11.6. Ensure that appropriate child: adult ratios are maintained in line with guidance from the NSPCC:
0 – 2 years – one adult to three children
2 – 3 years – one adult to four children
4 – 8 years – one adult to six children
9 – 12 years – one adult to eight children
13 – 18 years – one adult to ten children
11.7. Ensure that appropriate accident / incident reporting is in place and that any accidents or incidents are reported to parents / carers in a timely manner.
11.8. Ensure that appropriate order and discipline are maintained.
11.9. Ensure that children are encouraged and empowered to raise any concerns that they may have with leaders or their parents as appropriate.
When children or young people are present at meetings that are primarily aimed at adults and childcare is not provided and their parents are present
11.10. During these times, children remain the responsibility of their parents who are responsible for their safety and care.
11.11. Any concerns or support needs identified will be recorded and reported to the DSL in the usual way.
When young people are present at meetings that are primarily aimed at adults and participating in that meeting in their own right
11.12. Although there are not specific procedures for such meetings, the normal principles of safeguarding will apply.
11.13. If the young person is not believed to be competent to consent to attendance, consent will be sought from their parents / carers.
11.14. If the young person is believed to be competent to consent to attendance, they will be encouraged to be open and transparent with their parents / carers and consent will be sought for the church to contact the parents and establish open communication and transparency.
11.15. Leaders of the church or of the meeting in question will be vigilant to ensure that the young person is adequately protected.
11.16. Any concerns or support needs identified will be recorded and reported to the DSL in the usual way.
When ministering to Adults at Risk of Abuse or Adults with additional support needs
11.17. If the individual is not believed to be competent to consent to attendance, consent will be sought from their carers.
11.18. If the individual is believed to be competent to consent to attendance, they will be encouraged to be open and transparent with their carers, and consent will be sought for the church to contact them with a view to establishing open communication and transparency.
11.19. Leaders of the church or of the meeting in question will be vigilant to ensure that the individual is adequately protected.
11.20. Any concerns or support needs identified will be recorded and reported to the DSL in the usual way.
General provisions
11.21. The church will ensure that information relating to safeguarding, including contact details and other relevant information is prominently displayed in the building and online.
11.22. Leaders will promote the need for every member to be vigilant to safeguarding concerns through the processes, teaching, and culture of the church and by personal example.
12. Responding to and reporting safeguarding concerns and disclosures
Managing immediate risk
12.1. Upon identification of a concern or receipt of a disclosure, the worker involved should make an assessment as to whether any immediate action is necessary to protect the individual.
12.1.1. The worker may seek advice from the team leader or from the DSL, however, the seeking of advice should not unnecessarily delay or prevent the protective action or place the individual at risk of further or increased harm.
12.1.2. In such urgent situations and if the DSL cannot be immediately contacted, the worker should contact either the police on 999 or Social Care to obtain support. Under such circumstances, the DSL should be notified at the earliest possible opportunity.
Reporting concerns to the Designated Safeguarding Lead
12.2. Once it has been established that the individual is not, or is no longer in imminent danger, the concern will be reported to the DSL.
12.2.1. The concerns will be discussed with the DSL at the earliest opportunity, to ensure clarity of understanding.
12.2.2. Details of the concern must be recorded on the “Incidents and concerns reporting form” (See appendix D) either before, during, or immediately after the discussion with the DSL.
Managing the risks: the role of the DSL
12.3. In discussion with the worker reporting the concern, the DSL will review any immediate actions taken and will be responsible for follow-up or further action that may be required.
12.4. Upon receipt of the completed form, the DSL will establish a “Confidential File” in relation to the person at risk.
12.4.1. A Chronology (See appendix D) will be established and inserted at the front of the confidential file.
12.4.2. The confidential file will be updated with any further discussions or actions, including any advice sought or referrals made and updating will continue on an ongoing basis.
12.4.2.1. The DSL will confirm to the person raising the concern that the matter has been actioned. The DSL will not provide any unnecessary information. Information is only shared on a “need to know” basis.
12.5. Where the concern meets the statutory threshold, the DSL will notify the parent or carer of the individual concerned (or the individual themselves if they are a competent adult) that a referral is being made to Social Care.
12.5.1. Information will not be shared with the parent / carer in situations where:
12.5.1.1. To do so would place a child at increased risk of harm or neglect.
12.5.1.2. To do so would place an adult at increased risk of harm or abuse.
12.5.1.3. The concern relates to Fabricated or Induced Illness.
12.5.2. The referral will be made to the appropriate Social Care service (See appendix B for contact details).
12.5.3. If the referral has not been acknowledged within 3 working days, the DSL will follow up with Children’s Social Care.
12.5.4. The DSL will work with the Local Authority and other partners on behalf of the church to ensure that we fully participate in the safeguarding process.
12.5.5. All conversations, correspondence, and documentation etc will be placed into the confidential file and the “Record of action” and Chronology will be maintained on an ongoing basis.
12.6. Confidential files will be stored in a password secured cloud folder.
12.7. The DSL will share information as necessary with other individuals in the church to facilitate effective safeguarding.
13. Allegations against or concerns about staff and volunteers
Bankhall Mission Church takes allegations against our staff and volunteers very seriously and will ensure that they are investigated thoroughly, via a transparent process that expedites the matter in a timely manner. We recognise that that we have a responsibility to take the allegation seriously, to manage the situation effectively while the investigation takes place and to and to support the person accused throughout the process.
13.1. Allegations against staff or volunteers within the church should be reported to the DSL, Trevor Scott, on 07377064122
13.1.1. If the allegation is against the DSL, it should be reported the deputy DSL, Eddie Bridle, on 07912884279.
13.2. Full details of the allegation will be recorded.
13.3. The church’s investigating officer will assess whether any immediate action is required to ensure the safety of everyone involved.
13.3.1. Dependent upon circumstances and the immediate action required, notifying the individual that an allegation has been received may be unavoidable.
13.3.2. If so, care will be taken not to compromise the gathering of evidence.
13.3.3. If it is necessary to notify the individual at this stage, details of the allegation will not be divulged.
13.3.4. Support must be offered to the subject of the allegation as well as any potential victims.
13.4. At the earliest opportunity, the LADO (Local Authority Designated Officer) should be consulted.
13.4.1. If the LADO cannot be contacted due to working hours, initial advice can be sought from Christian Safeguarding Services (CSS).
13.5. If the allegation meets the threshold for LADO, the church’s investigating officer will work with LADO to ensure that the allegation is thoroughly investigated, and all issues raised are addressed.
13.6. If the allegation does not meet the threshold for LADO, the investigating officer will consult with CSS, who will provide independent support and advice to ensure transparency.
13.7. Thorough records of all aspects of the handling of the allegation will be retained throughout the process.
13.7.1. These records will be held confidentially in a password secured cloud folder.
13.8. The DSL will seek and follow specialist advice throughout the process.
14. Management of ex-offenders or those who pose an actual or potential risk to others; particularly to vulnerable people
As a church, we believe in the power of God to forgive and transform individuals. We also believe that every individual is valuable to God and should be protected; particularly those who are vulnerable.
14.1. Where the church becomes aware that an individual is an ex-offender or that they may pose a risk to vulnerable people, the church leaders will enter into an open and frank discourse with that individual to understand the context and the risks.
14.2. With the consent of the individual (if required), the church will seek to work in partnership with probation services or other agencies supporting the individual where this is appropriate.
14.3. The leaders will assess the risk posed by the individual and a formal risk assessment will be formulated.
14.4. A formal agreement with the individual will be drawn up and will be signed by both the church leaders. The agreement will include:
14.4.1. The church’s commitments to the individual who poses the risk.
14.4.2. The steps the church will take to support the individual while simultaneously protecting everyone in the church community.
14.4.3. The restrictions and conditions that will be applied to the individual’s involvement in the life of the church.
14.4.4. The consequences of failure to comply with the agreement.
14.4.5. When and how the risk assessment and formal contract will be reviewed.
14.5. All decisions and agreements will be formally recorded and securely stored.
14.6. The individual who poses a risk will be fully involved in the planning process and information will only be shared with church members by the leaders either:
14.6.1. With the agreement of the individual who poses a risk.
14.6.2. Where information needs to be shared to protect vulnerable people and then, only the minimum information that is essential will be shared and the individual will be informed in advance what information will be shared.
14.7. If the individual chooses to leave the church to avoid the management of the risk and starts to attend elsewhere, the church leaders will take specialist advice as to whether this information should be passed on.
15. Complaints and concerns
Bankhall Mission Church recognises the importance of listening to all members of our church community, including those who find it hard to make their voices heard and those who hold contrary views to the church leadership. The trustees will proactively seek the views of all who engage with the church in a variety of ways; however, we also recognise the importance of responding well when concerns, criticisms or complaints are raised with us.
It is our hope that the majority of concerns that do not meet the statutory thresholds for referral to external agencies can be resolved informally through constructive discussion and in line with Matthew 18: 15-35, however, we recognise that for a variety of reasons, resolution via such dialogue will not always be possible or appropriate. This procedure seeks to establish a robust process for dealing with complaints or concerns that have not or cannot be resolved through informal discussion.
Use of informal discussion (as described above) is not a prerequisite for initiating the formal complaint process. Not all complaints will involve a safeguarding element. The same process will be followed for all complaints.
Complaint’s log
15.1. Bankhall Mission Church will maintain a log of all complaints (See appendix F).
Anonymous complaints and media campaigns (including social media)
15.2. Complaints that are made anonymously cannot be handled in the usual way and will generally be filed without full investigation.
15.3. Complaints that request a level of confidentiality that would compromise the integrity of an investigation, or its outcome will not be investigated, but may be considered in general terms. They will generally be filed without full investigation.
15.4. CSS will not respond to complaints made in public space such as social media or other online or in-print publications. All complaints should be addressed to Bankhall Mission Church directly using this complaints process
15.5. Although anonymous complaints cannot, by definition, be handled in the usual way, Bankhall Mission Church will:
15.5.1. log the complaint/s.
15.5.2. Seek to establish whether any pattern or consistency can be identified.
15.5.3. Consider whether any form of investigation or action can and should be taken.
External investigations
15.6. Concerns, complaints, and allegations will generally be investigated internally.
15.7. In exceptional circumstances such as where Bankhall Mission Church has concerns about the independence or competence of staff, or their capacity to conduct a timely investigation, Bankhall Mission Church will consider whether it is appropriate to involve an independent external individual or organisation to assist with the investigation.
15.8. Unless directed by a statutory or regulatory body to involve an independent, external body, Bankhall Mission Church will make such decisions. Advice can be sought from CSS or other sources, but this decision rests solely in the hands of (Bankhall Mission Church) trustees and senior leaders.
Making a complaint
15.9. Complaints should be addressed to one of the Elders.
15.9.1. If the complaint is about all of the Elders, the complaint should be addressed to the Trustees.
15.10. The details will be entered into the complaints log and progress to conclusion will be tracked.
15.11. The Elders will inform the Trustees of the complaint and an initial plan of action will be developed.
15.12. Consideration will be given to whether a Serious Incident Report to the appropriate charity regulator is required.
15.13. An Investigating Officer(s) will be identified.
Preliminary actions
15.14. The Trustees or the Investigating Officer may consult with CSS, who will provide independent support and advice to ensure transparency.
15.15. The Investigating Officer will acknowledge receipt of the complaint and will notify the complainants of the initial plan of action which will include:
15.15.1. Discussing the complaint with the complainants to confirm and clarify the details of the complaint.
15.15.2. Details of the complaint process and of key contacts will be provided to the complainants.
15.15.3. The investigating Officer will establish whether the complainants wish to start the process at stage 1 (informal resolution) or stage 2 (formal investigation).
15.15.4. A detailed investigation plan will be developed by the investigating officer and signed off the Trustees.
Stage 1 – Informal resolution
15.16. Where possible, Bankhall Mission Church prefers to commence at this stage; believing this to be best aligned to the biblical principles, however, this will be a decision for the complainants, and if they request commencement at stage 2, that decision will be fully respected by the church.
15.17. The investigating officer, supported by a note-taker if required will arrange to discuss the matter with the complainants.
15.18. The aim at this stage is to establish whether agreement can be reached about action that is required.
15.19. Bankhall Mission Church will make a written record of the discussion that includes:
15.19.1. The key points discussed, and views expressed.
15.19.2. Areas of agreement.
15.19.3. Areas of disagreement.
15.19.4. Conclusions and actions agreed.
15.20. A copy of the written record of the meeting will be provided to the complainants who will have opportunity to request amendments or clarification.
15.21. Once agreed, the complainants will be asked to confirm the accuracy of the notes of the discussion.
If resolution has been agreed
15.22. Once Bankhall Mission Church have completed the agreed actions, they will notify the complainants of the action taken.
15.23. The complainants will be asked to confirm that they are happy that the matter has been addressed.
15.24. The complaints log will be updated, and the notes will be stored securely.
If resolution has not been agreed
15.25. A record of the closing position of the informal stage will be agreed between these complainants and the Investigating Officer. This will include any progress made and actions agreed / completed and the issues that could not be resolved.
15.26. The closing report will be signed off by the Trustees, who will escalate the matter to the formal stage.
Stage 2 – formal investigation
15.27. Complaints at the formal stage will be reviewed by the Trustees to establish whether there are sufficient grounds for a full investigation.
15.28. If a full investigation is required / justified, this will be agreed and authorised.
15.29. The “Investigation officer” for this stage will be agreed.
15.30. An investigation plan will be developed and communicated to the complainants.
15.31. The matter will be thoroughly investigated, and a final (Stage 2) report will be delivered to the Trustees for sign off.
15.32. Once signed off, the outcome will be communicated to the complainants,
15.32.1. The complainants will be notified of their right of appeal and of the process and timescales for doing so.
15.33. All records will be stored confidentially.
Stage 3 – Appeal
15.34. If the complainants believe that the process or findings if the formal investigation is incorrect, they can raise their concerns using the appeal process.
15.35. The complainant must clearly outline the basis of the appeal and the justification for appealing the process and / or outcome.
15.36. The trustees will consider the grounds of appeal and decide whether the appeal is justified.
15.37. The appeal will be conducted by a suitably skilled individual(s) who were not part of the stage 2 investigation (excluding the sign off process) and who are not involved in the complaint.
15.38. An appeal report will be produced and submitted to the trustees (or the subgroup thereof) for final signoff.
15.39. The complainants will be notified of the outcome of the appeal and their options of further action (e.g., referral to the Charity regulator, the police, or the Local Authority etc will be provided.
15.40. The process will be reviewed to identify lessons that can be learned.
16. Concerns about practice and whistleblowing
Bankhall Mission Church strives to create an environment that is open, transparent, and accountable. We want to listen and respond well to any concerns raised by our staff and volunteers.
16.1. Staff and volunteers are encouraged to raise concerns about process, practice, or culture with the ministry team leader.
16.1.1. If they do not feel able to do so, or if they feel that concerns raised have not been given due consideration, they can be raised with one of the senior leaders, or with the Safeguarding Trustee, or the Chair of Trustees.
16.2. The concerns will be carefully considered, and a formal response will be provided to the individual explaining the decision. The examination of the concerns raised may conclude:
16.2.1. The concerns are wholly or partially valid and require corrective action.
16.2.2. That the concerns did not take account of all relevant factors, and no further action is required.
16.2.3. That the concerns were invalid and have been dismissed.
16.3. If the complainant is not satisfied with the response, they should formally raise the matter with the Safeguarding Trustee or the Chair of Trustees, explaining their concerns about the adequacy of the initial response. Details of how this can be done will be communicated at the same time as the initial response.
16.4. Once the Trustees have considered the matter, they will formally respond to the complainant in writing, explaining their findings and the rationale for their decision.
16.4.1. Details of how to raise the complaint externally will also be provided as part of the response.
16.4.2. This will include contacting the Charity Commission, details of the NSPCC whistleblowing helpline and any other measures that the trustees wish to offer.
Basis of policy and legal framework
This policy is consistent with:
• Current legislation
• National guidance
• Local arrangements
• Our charitable objectives, governing documents, and doctrinal statements
Details of the relevant legislation and guidance is available in appendix B
Related policies and procedures
This policy should be read in conjunction with:
• Our statement of Faith
• Our governing documents
Policy due for review: 26/02/2025
Policy last reviewed: 26/02/2024
Last review conducted / approved by: Bankhall Leadership