Terms and Conditions

Safeguarding and Child Protection Policy and Procedures

17 March 2026

Key Contacts Policy Owner: Kat Heath

Policy approved by: Kat Heath, Jamie Stumbles and Udo Klienitz

Next review Date: March 2027 

CONTENTS 

1. INTRODUCTION 
2. DEFINITIONS
3. APPLICATION OF THE POLICY 
4. POWER TO CHANGE, RESCIND OR ADD TO THE PROVISION OF THE POLICY
5. LAWS
6. STAFF OBLIGATIONS AND TRAINING
7. WHAT IS SAFEGUARDING? 
8. GOOD PRACTICE GUIDANCE 
9. RECOGNITION OF POOR PRACTICE AND IDENTIFYING CONCERNS
10. ADDITIONAL VULNERABILITIES 
11. ONLINE SAFETY 
12. DBS DISCLOSURES 
13. DISCLOSURE 
14. WHAT TO DO IF YOU ARE CONCERNED ABOUT A CHILD
15. THRESHOLDS AND LOW-LEVEL CONCERNS 
16.  RESPONSE TO CONCERNS 
17. HISTORICAL (NON-RECENT) CONCERNS 
18. INFORMATION SHARING 
19. CONFIDENTIALITY AND DATA PROTECTION 
20. POSITION OF TRUST 
21. PREVENT DUTY
22. REPORTING CONCERNS RELATING TO RADICALISATION AND/OR EXTREMISM

Appendix 1: EXAMPLES OF SIGNS, ACTIONS OR BEHAVIOURS WHICH MAY GIVE RISE TO CONCERNS 

Appendix 2: EXTERNAL CONTACTS ……………………………………………………………………..

• 1. INTRODUCTION 

1.1 Reading Bike Hub CIC (“the Hub) is a. community space providing bike and skate repairs, bike sales, bike hire, workshops, a Kids’ Bike Library, corporate bike repair services, and a basement skatepark. It is a Climate Emergency Centre (CEC) and a not-for-profit organisation that reinvests any surplus back into the community

1.2 This Safeguarding Children Policy (the “Policy”) reflects the safeguarding ethos of Reading Bike Hub CIC ; a CIC limited by guarantee, incorporated and registered in England with company number 16560033 whose registered office is at 14 – 16A  King Street, Reading, RG1 2HE. For the purposes of this policy, a child (or children) means any person under the age of 18.

1.3 Reading Bike Hub CIC believes Children have the right to take part in cycling, skateboarding, and all community activities in an environment which is safe and free from any risk of Abuse and that everyone has a responsibility to promote the welfare of all participants including Children, to keep them safe and to practise and operate in a way that protects them. 

1.4 Reading Bike Hub CIC has a duty of care to all participants, and it recognises its moral, legal and regulatory responsibility to safeguard and promote the welfare of all Children. Upon that basis, Reading Bike Hub CIC’s approach to safeguarding is underpinned by current UK legislation, statutory and regulatory guidance and current best practice. Key frameworks include: 

• the Children Act 1989, which establishes that the welfare of the child is paramount;
  
  
• the Children Act 2004, which places duties on organisations to safeguard and promote the welfare of children;
  
  
• Working Together to Safeguard Children 2023, which sets out how organisations and agencies should work together to safeguard children;
  
  
• the Safeguarding Vulnerable Groups Act 2006, which establishes the Disclosure and Barring Service (DBS) and the barring framework;
  
  
• the Protection of Freedoms Act 2012, which defines regulated activity relating to children;
  
  
• the Sexual Offences Act 2003 (as amended), including provisions relating to abuse of positions of trust;
  
  
• the Data Protection Act 2018 and UK General Data Protection Regulation (UK GDPR), which govern the handling and protection of personal data;
  
  
• the Equality Act 2010, which protects individuals from discrimination; and
  
  
• the Counter-Terrorism and Security Act 2015, which includes the Prevent Duty.

This list is not exhaustive. Reading Bike Hub CIC will comply with all relevant and updated legislation, statutory guidance and local safeguarding procedures.

1.5 Reading Bike Hub CIC is dedicated to taking all reasonable steps to minimise the risk of any form of child abuse, to take place in both physical and online environments and this Policy forms part of those efforts to ensure safeguarding is firmly embedded in the values and practices of Reading Bike Hub CIC. 

1.6 In furtherance of this commitment, this Policy includes provisions for identifying potential risks and continued suitability in respect of staff working with or coming into contact with children. This Policy also provides guidance for responding to concerns of poor or unprofessional conduct, which may indicate that a member of Staff or a volunteer poses a risk of harm to Children. 

1.7 Reading Bike Hub CIC is committed to working closely with local authorities and the Local Authority Designated Officer (“LADO”) to ensure safeguarding is prioritised and that high standards of safeguarding practices are in place across all areas of the organisation and that all Concerns are taken seriously and responded to swiftly, fairly and appropriately. 

1.8 Reading Bike Hub CIC undertakes to make available (on request) electronic copies of this Policy as amended from time to time. Electronic copies of this Policy are available on the Reading Bike Hub CIC website (the “Website”). 

If any person is unable to access or download this Policy, or requires it in an alternative format (for example, large print), they are encouraged to contact Reading Bike Hub CIC using the contact details provided on the website. Requests for alternative formats will be considered and accommodated wherever reasonably practicable.

Reading Bike Hub CIC will take all reasonable steps to ensure that this Policy is communicated in a way that is accessible and understandable, taking into account the needs of children, young people and others who may require additional support. Where appropriate, this may include working with parents, carers or those with legal responsibility for the individual.

1.9 Reading Bike Hub CIC also agrees that in any case where there is an actual or alleged breach of this Policy, Reading Bike Hub CIC will take into account any relevant individual needs or vulnerabilities, including where a person may have a disability or require additional support, when determining an appropriate and proportionate response, including whether additional support, adjustments or alternative approaches are required. 

1.10 Reading Bike Hub CIC has a dedicated “ Designated Safeguarding Lead” (DSL) to provide guidance and support in relation to any safeguarding Concerns or queries. 

1.11 Reading Bike Hub CIC’s board of directors are committed to contributing to raising safeguarding awareness and communicating policies and procedures as well as driving Reading Bike Hub CIC’s culture of vigilance and action. In furtherance of this commitment, Reading Bike Hub CIC maintains effective lines of communication between its board of directors and  Designated Safeguarding Lead. 

1.13 Safeguarding Concerns can be addressed to  the DSL via the contact details contained within the table below. 

2. DEFINITIONS 

2.1 The following definitions apply in this Policy: 

Abuse: is any form of harm or maltreatment of a Child. There are four main types of Abuse: Emotional Abuse, Physical Abuse, Sexual Abuse and Neglect. Other forms of Abuse may include Discriminatory Abuse or Psychological Abuse.

Applicable Laws: all laws, statutes, regulations, decisions, rulings, directives, codes of practice, government policies, enactments, or instruments (including national, regional, local or principal laws, regulations or by-laws of any kind whatsoever) relevant to this Policy.

Bullying: a form of Emotional Abuse whereby a Child is discriminated against, intimidated or harassed repeatedly.

Child/Children: : a person under the age of 18.

Child Sexual Exploitation (CSE): 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, usually in exchange for something the victim needs or wants.

Concern: fear, worry or concern that a Child may be at risk of Abuse.

Cyber Bullying: a form of online Emotional Abuse whereby a Child is discriminated against or harassed using digital technology.

Data Protection Legislation: all applicable laws relating to data protection, the processing of personal data and privacy, including the Data Protection Act 2018, UK General Data Protection Regulation (UK GDPR), and any other applicable data protection and/or privacy legislation in the UK from time to time. 

Code of Conduct: Reading Bike Hub CIC’s code of conduct and volunteer agreement as in place from time to time, setting out expected standards of behaviour for all Staff and volunteers.

Designated Safeguarding Lead (DSL): the named individual within Reading Bike Hub CIC who has lead responsibility for safeguarding and child protection. The DSL is the first point of contact for all safeguarding concerns.

Emotional Abuse: the persistent emotional maltreatment of a Child such as to cause severe and persistent adverse effects on the Child’s emotional development.

Extremism: vocal or active opposition to fundamental values, including the rule of law, individual liberty and the mutual respect and tolerance of different faiths and beliefs.

Neglect: 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.

Online Safety: (also known as internet safety, e-safety, or cyber safety) refers to the act of staying safe online and the safe and responsible use of technology, including the internet, social media, text or other messaging applications, gaming devices, and email.

Physical Abuse: a form of Abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a Child.

Position of Trust: a relationship in which a person has responsibility for, or authority over, a Child. Under the Sexual Offences Act 2003 (as amended by the Police, Crime, Sentencing and Courts Act 2022), it is a criminal offence for a person in a position of trust to engage in sexual activity with a person under 18, even if that person has reached the age of consent. 

Psychological Abuse: including Emotional Abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, Verbal Abuse, isolation or withdrawal from services or supportive networks.

Radicalisation: the process by which a person comes to support or engage with Terrorism and forms of Extremism leading to Terrorism.

Regulated Activity: as defined by the Safeguarding Vulnerable Groups Act 2006 (as amended by the Protection of Freedoms Act 2012), regulated activity in relation to children includes teaching, training, instructing, caring for or supervising children on a frequent, intensive or overnight basis. Persons engaged in regulated activity must hold an Enhanced DBS check with children’s barred list check.

Sexual Abuse: forcing or enticing a Child to take part in sexual activities, not necessarily involving a high level of violence, whether or not the Child is aware of what is happening. The activities may involve physical contact as well as non-contact activities, such as grooming. Child Sexual Exploitation is a form of Sexual Abuse.

Staff and Volunteers: any person acting for or on behalf of Reading Bike Hub CIC in any capacity, including volunteers (who form the primary workforce of the Hub), any future employees, casual workers, or consultants. Given that Reading Bike Hub CIC is currently entirely volunteer-run, this definition primarily applies to volunteers.

Terrorism: an action that endangers or causes serious violence to a person/people; causes serious damage to property; or seriously interferes or disrupts an electronic system. The use or threat must be designed to influence the Government or to intimidate the public and is made for the purpose of advancing a political, religious, racial or ideological cause.

Verbal Abuse: the use of words to cause harm to the person being spoken to.

Vulnerability: a state of being exposed to the possibility of being harmed, either physically or emotionally.

3. APPLICATION OF THE POLICY 

3.1 The Policy shall apply to: 

3.1.1 All staff and volunteers

3.1.2 All board members and directors;

3.1.3 Any future employees, casual workers, or contractors; and

3.1.4 Any other person acting on behalf of Reading Bike Hub CIC.

3.2 The Policy shall not apply to: 

3.2.1 Members of the public visiting the Hub as customers or participants, except insofar as they are subject to the standards of behaviour expected within the Hub’s premises; and

3.2.2 Any other body outside of Reading Bike Hub CIC’s jurisdiction.

3.3 All Staff and volunteers under the jurisdiction of Reading Bike Hub CIC agree to abide by all Reading Bike Hub CIC policies and procedures as in place from time to time, including this Policy.

4. POWER TO CHANGE, RESCIND OR ADD TO THE PROVISION OF THE POLICY 

4.1 In the event an issue arises that is not foreseen in this Policy, it will be addressed by Reading Bike Hub CIC.

4.2 Reading Bike Hub CIC is committed to reviewing this Policy periodically which may be amended from time to time by Reading Bike Hub CIC. The Policy will be reviewed following any significant safeguarding incident, change in legislation, or change in the organisation’s activities.

5. LAWS 

5.1 The laws of England and Wales shall apply to this Policy. 5.2 The key legislation underpinning this Policy includes the Children Act 1989, the Children Act 2004, the Safeguarding Vulnerable Groups Act 2006, the Protection of Freedoms Act 2012, the Sexual Offences Act 2003 (as amended), the Counter-Terrorism and Security Act 2015, the Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), and the Equality Act 2010. Reading Bike Hub CIC will have regard to statutory guidance, including Working Together to Safeguard Children 2023, and best practice guidance from the NSPCC and relevant sporting bodies.

6. STAFF OBLIGATIONS AND TRAINING 

61 In addition to the duties and obligations arising under any other contracts, policies or procedures under which they may be subject, all Staff shall: 

6.1.1 accept the moral, legal and regulatory responsibility to provide a duty of care for Children, to safeguard their wellbeing, and to protect them from Abuse; 

6.1.2 respect and promote the rights, wishes and feelings of Children; 

6.1.3 recognise that some Children may face additional barriers to getting help because of additional Vulnerabilities which could include their ethnicity, gender, age, religion, disability, sexual orientation, social background or culture. There should be awareness that these characteristics may mean that they are at greater risk of Abuse because of factors such as prejudice, discrimination, reduced ability to resist or report Abuse, communication barriers or myths based on stereotypes; 

6.1.4 create a safe culture and environment; 

6.1.5 challenge all inappropriate behaviour and report any breaches of this Policy by Affiliate Partners and other members of Staff and volunteers; 

6.1.6 listen to and respect Children at all times and respond appropriately to any Concerns in accordance with this Policy; and 

6.1.7 read, accept and abide by this Policy as well as all other Reading Bike Hub CIC policies and procedures as in place from time to time including this Policy. 

6.2 All new Staff shall complete Reading Bike Hub CIC’s induction process which includes familiarisation with the Reading Bike Hub CIC’s safeguarding policies, procedures (including this Policy) and expected standards of behaviour. 

6.3 All Staff and volunteers who have regular contact with children, or who are engaged in Regulated Activity, must complete an appropriate safeguarding awareness training course before commencing their role, and refresher training at least every three years thereafter. Reading Bike Hub CIC will maintain records of all training completed. 

6.4 Safer Recruitment: Reading Bike Hub CIC is committed to safer recruitment practices. All volunteers and staff who will have regular or unsupervised contact with children must:

•       complete an application form or volunteer registration form;
•       provide references which will be followed up;
•       complete an Enhanced DBS check with children’s barred list check where they are engaged in Regulated Activity; and
•       receive a safeguarding induction before commencing their role.

7. WHAT IS SAFEGUARDING? 

7.1 Safeguarding is the action that is taken to promote the welfare of Children and protect them from harm. 

7.2  Safeguarding means: 

7.2.1 protecting Children from Abuse; 

7.2.2  preventing harm to Children’s health or development; 

7.2.3 ensuring Children grow up with the provision of safe and effective care; and 

7.2.4 taking action to enable all Children to have the best outcomes. 

7.3 Child protection is part of the safeguarding process. It focuses on protecting individual Children identified as suffering or likely to suffer significant harm. This includes Child protection procedures which detail how to respond to Concerns about a Child.

7.4 In the context of Reading Bike Hub CIC, safeguarding is relevant across all activities and services, including: the Kids’ Bike Library (where children visit the Hub to collect or exchange bikes); Learn to Ride sessions (where children learn to cycle); workshops (where children may be present with parents or carers); and the basement skatepark (where children may be present). The Hub’s inclusive and welcoming ethos means that children from a wide range of backgrounds may visit, including those who may be particularly vulnerable.

8 . GOOD PRACTICE GUIDANCE 

8.1 Abuse, particularly Sexual Abuse, can generate strong emotions in those having to deal with such a Concern. It is important to understand these feelings and not allow them to interfere with your judgement about what action to take.,

8.2 All staff and volunteers should be encouraged to demonstrate exemplary behaviour in order to protect Children and to protect themselves from Concerns. 

8..3 The following are common sense examples of good practice and how to create a positive culture when working within Reading Bike Hub CIC and with Children: 

8.3.1 always putting the welfare of Children first; 

8.3.2 always working in an open environment (e.g., avoiding private or unobserved situations and encouraging an open environment with no secrets); 

8.3.3 build balanced relationships based on mutual trust which empowers Children to share in the decision making process; 

8.3.4 treating all Children equally and with respect and dignity; 

8.3.5 maintaining a safe and appropriate distance with Children both emotionally and physically; 

8.3.6 being an excellent role model; and 

8.3.7 recognising the developmental needs, capacity and additional Vulnerabilities of Children. 

8.4 Specific good practice guidance for Reading Bike Hub CIC activities: 

8.4.1 During the Kids’ Bike Library service, parents or carers should remain present and responsible for their children. Volunteers should not be left alone with a child without a parent or carer present;

8.4.2 During Learn to Ride sessions, ensure that the session is visible to other volunteers or members of the public and that parents or carers are aware of and consent to the activity;

8.4.3 In the basement skatepark, ensure adequate supervision is in place and that children are not left unsupervised;

8.4.4 When taking photographs or videos of children for promotional purposes, written consent must be obtained from a parent or carer in advance; and

8.4.5 If a child is disabled and requires assistance with personal care, this should be carried out by their parent or carer, not by a Hub volunteer.

9. RECOGNITION OF POOR PRACTICE AND IDENTIFYING CONCERNS 

9.1  Affiliate Partners, Staff and volunteers are not expected to be experts at recognition of Child Abuse. However, they do have a responsibility to act if they have any Concerns about the behaviour of someone (an adult or another Child) towards a Child and to follow the reporting procedures in this Policy. 

9.2 Concerns may relate to poor practice where an adult’s or another Child’s behaviour is inappropriate and may be causing harm to a Child. In the application of this Policy, poor practice includes any behaviour bringing Reading Bike Hub CIC into disrepute of a Child protection nature or contravening any Applicable Laws, Data Protection Legislation or Reading Bike Hub CIC policy or guidance, infringing an individuals’ rights and/or is a failure to fulfil the highest standards of care. 

9.3 Examples of poor practice: 

9.3.1 failure to act when you witness possible Abuse, Bullying or Neglect; 

9.3.2 spending excessive amounts of time alone with a Child or Children away from others; 

9.3.3 using inappropriate language; 

9.3.4 making sexually suggestive comments; and 

9.3.5 allowing Concerns raised by a Child to go unchallenged, unrecorded or not acted upon. 

9.4 Upon this basis, Reading Bike Hub CIC would usually recommend that if a Child is disabled to the extent that they need assistance with personal care, this should be carried out by their parent, or other person with parental responsibility.

9.5 It can be very hard for Children to speak out about Abuse. Often, they fear there may be negative consequences if they tell anyone what is happening to them. Some may delay telling someone about Abuse for a long time, while others never tell anyone, even if they want to. 

9.6 It is vital that Children are able to speak out and that whoever they tell takes them seriously and acts on what they have been told. Even if a Child does not tell someone verbally about what has happened to them, there may be other indicators that something is wrong. Staff and Volunteers need to be able to recognise the signs and know how to respond appropriately. 

9.7 Maintain an attitude of “it could happen here”. Some common signs that there may be something concerning happening in a Child’s life include: 

9.7.1 unexplained changes in behaviour or personality; 

9.7.2 becoming withdrawn; 

9.7.3 seeming anxious; 

9.7.4 becoming uncharacteristically aggressive; 

9.7.5 poor bond or relationship with a parent, or other person with parental responsibility; 

9.7.6 knowledge of adult issues inappropriate for their age (for example sexually explicit language or actions); 

9.7.7 running away or going missing; 

9.7.8 always choosing to wear clothes which cover their body; 

9.7.9 unexplained or suspicious injuries such as bruising, cuts or burns, particularly if situated on a part of the body not normally prone to such injuries; 

9.7.10 a change observed over a long period of time (for example losing weight or becoming increasingly dirty or unkempt); 

9.7.11 a general distrust and avoidance of adults; 

9.7.12 an unexpected reaction to normal physical contact; and 

9.7.13 difficulty in making friends or abnormal restrictions on socialising with others. 

9.8 It should be recognised that this list is not exhaustive and the presence of one or more of the indicators is not proof that Abuse is actually taking place. Further examples of signs, actions or behaviours which may give rise to Concerns are contained within Appendix 1. 

9.9 It is not the responsibility of Members, of Staff or volunteers to decide if Child Abuse is occurring, but it is the responsibility of all Staff and Volunteers to act on any Concerns by reporting them to the  Designated Safeguarding Lead. 

9.10 Staff and volunteers must report any Concerns or examples of poor practice to the Designated Safeguarding Lead immediately and within 24 hours.

10. ADDITIONAL VULNERABILITIES 

10.2 Some Children may be at increased risk of Abuse. Many factors can contribute to an increase in risk, including prejudice and discrimination, isolation, social exclusion, social deprivation, Children who have experienced adverse Childhood experiences, those with communication issues and reluctance on the part of some adults to accept that Abuse happens.

10..2 Special consideration and attention should be given to Children who are: 

10..2.1 disabled or have special educational needs; 

10.2.2 looked after Children (i.e., those in care, or those who have experienced being in care); 

10.2.3 living in a known domestic Abuse situation or chaotic or dysfunctional household; 

10.2.4 affected by known parental substance misuse or parental criminality; or 

10.2.5 living away from home. 

10.3 Reading Bike Hub CIC’s inclusive ethos means that children from a wide range of backgrounds visit the Hub. The Hub’s commitment to making cycling accessible to all, regardless of background or ability, means that volunteers may encounter children who face additional vulnerabilities. Volunteers should be particularly attentive and supportive in these circumstances, without making assumptions.

10.4  The presence of these factors does not mean that Child Abuse will occur, but Staff and Volunteers should use their judgement to assess their significance in a particular Child and they should be considered alongside any concerning factors. 

11. ONLINE SAFETY 

11.1 While online gaming, social media, communication and engagement platforms offer many benefits and positive opportunities, it is important to be aware that they present a wide range of risks for Children, including being exposed to illegal, harmful, explicit or inappropriate content and contact.

11.2 Risks include:

11.2.1 Content: pornography, misinformation, racism, misogyny, self-harm, suicide, anti-Semitism, Radicalisation and Extremism, harmful challenges and hoaxes, and violence;

11.2.2 Contact: being subjected to harmful online interaction with other users, including peer pressure, commercial advertising and adults posing as Children with the intention to groom or exploit them;

11.2.3 Conduct: personal online behaviour that increases the likelihood of, or causes, harm, including making, sending and receiving explicit images and Cyber Bullying; and

11.2.4 Commerce: financial risks such as online gambling, inappropriate advertising, phishing and financial scams.

11.3 Reading Bike Hub CIC’s use of social media (including Facebook, Instagram and LinkedIn) for community engagement means that volunteers should be mindful of online safety when interacting with children or young people via these platforms. Volunteers should not communicate with children via personal social media accounts or personal messaging applications.

11.4 Extremist groups actively use social media to share propaganda, radicalise and recruit. Staff and volunteers must be aware of Reading Bike Hub CIC’s Online Safety measures which are an important element of protection from Radicalisation and Extremism

12. DBS DISCLOSURES 

12.1  Reading Bike Hub CIC is committed to safer recruitment. Any volunteer or member of staff who will be engaged in Regulated Activity with children (i.e., teaching, training, instructing, caring for or supervising children on a frequent, intensive or overnight basis) must hold a current Enhanced DBS check with children’s barred list check before commencing that activity.

12.2 Where a person has undergone a DBS Check (including an Enhanced DBS Check with a check of the children’s barred list) as required as part of their role; Reading Bike Hub CIC reserves the right to disclose their DBS Certificate (where it contains  any caution, conviction, or statutory agency comment) with the  Designated Safeguarding Lead. 

12.3 If a person has undergone a DBS Check and the results have not been disclosed to Reading Bike Hub CIC; a disclosure must be made immediately and within 24 hours. The person must not continue to have any contact or involvement with Children until such time as Reading Bike Hub CIC has provided written permission. 

12.4 Following review of the disclosure, the Designated Safeguarding Lead, if deemed appropriate (for example where the DBS Certificate consists of any caution, conviction, or statutory agency comment), may convene a risk assessment meeting with the person subject to the DBS. 

12.5 If a person required to hold an Enhanced DBS Certificate is cautioned or convicted of an offence or is restricted from working with Children by any regulatory or governing body, they must notify the Designated Safeguarding Lead immediately and within 24 hours.

12.6 Reading Bike Hub CIC reserves the right to refer to the DBS for a decision on barring where necessary.

13. DISCLOSURE

13.1 Disclosure is the process by which Children start to share their experiences of Abuse with others. This can take place over a long period of time – it is a journey, not one act or action. Children may disclose directly or indirectly and sometimes they may start sharing details of Abuse before they are ready to put their thoughts and feelings in order. 

13.2 Not all disclosures will lead to a formal report of Abuse, or a case being made, or a case being taken to court, but all disclosures should be taken seriously. 

13.3 It takes extraordinary courage for a Child to go through the journey of disclosing Abuse. 

13.4 It is, therefore, vital that all Staff and volunteers working with Children are able to provide them with the support they need. 

13.5 Children may disclose Abuse in a variety of ways, including: 

13.5.1 Directly: making specific verbal statements about what’s happened to them; 

13.5.2 Indirectly: making ambiguous verbal statements which suggest something is wrong;  

13.5.3 Behaviourally: displaying behaviour that signals something is wrong or  

13.5.4 Non-verbally: writing letters, drawing pictures or trying to communicate in other ways. 

13.6 If a Child discloses: 

13.6.1 listen to what you are told without leading the conversation; 

13.6.2 use open questions, starting with words such as “what”, “how”, “when”, “where”, asking the Child to tell you what happened, allowing them the space, privacy and time to say what they need to; 

13.6.3 continue asking questions until you know whether it is a concern / to rule out a concern; 

13.6.4 report the disclosure immediately and in any event within 24-hours to the  Designated Safeguarding Lead; 

13.6.5 follow the  Designated Safeguarding Lead’s guidance on the best next steps; 

13.6.6 share information on a need-to-know basis only. Do not discuss with colleagues, friends or family; and 

13.6.7 seek support for yourself if you are distressed. 

13.7 Non-biased approach: It is vital that any Child who is trying to disclose Abuse feels that they are being listened to and taken seriously. However, it is equally important to maintain an unbiased approach to ensure each case is treated in a fair and transparent manner. 

13.8 Making notes: It is important to keep accurate and detailed notes of any Concerns about a Child. Where possible the note should include: the Child’s details (name, age, address); what the Child said or did that gave cause for concern 20 (if the Child made a verbal disclosure, write down their exact words); and any information the Child has given about the alleged abuser. 

13.9 Staff and volunteers should not: 

13.9.1 start their own investigation; 

13.9.2 ask leading questions or 

13.9.3 promise a Child that you will keep a secret, or

13.9.4 speak to the alleged abuser about the Concern; or 

13.9.5 fail to report the Concern to the  DSL. .

14. WHAT TO DO IF YOU ARE CONCERNED ABOUT A CHILD 

14.1 If you witness or are worried about a Child, because of something you have noticed in their behaviour or appearance, or because of something they or another person has told you, you must report your concerns to a member of the  DSL immediately and within 24-hours.A report can be made directly to the DSL via email to safeguardingreadingbikehub@gmail.com

 Upon receipt, the DSL will provide you with a report form which must be completed.

14.2 If a Concern comes to your attention “out of hours”, you must report the Concern to the DSL immediately and within 24 hours. Staff and volunteers must also take the action necessary to help the Child and ensure their safety. If the Child is in immediate danger, call 999 for local Police. If the Child is in need of immediate medical attention, contact 999 and request emergency medical services.

14.3 Being concerned about a Child for example, where their behaviour is out of character may not always mean that they are being harmed or Abused. Sometimes a conversation with the Child and/or their parent, or other person with parental responsibility is warranted to try to understand what is going on. If concerns persist after talking to Children and their parent, or other person with parental responsibility, Staf and volunteers must report the Concern immediately and within 24-hours to the  DSL.

14.4 Concerns may relate to poor practice where an adult’s or another Child’s behaviour is inappropriate and may be causing harm to a Child. The  DSL will take any Concern seriously and no action will be taken (disciplinary or otherwise) for raising a Concern if it proves to be unfounded or does not merit action, provided the Concern was raised in good faith and not maliciously. 

14.5 Whenever there are Concerns involving a member of Staff or Volunteer in respect of a Child, it is a requirement to report them to the  DSL immediately and in any event within 24-hours. 

15 THRESHOLDS AND LOW-LEVEL CONCERNS 

15.1 Reading Bike Hub CIC’s obligations to take certain positive actions arise in response to two types of Concern: 

15.1.1 Concerns which meet any one of the Thresholds; and 

15.1.2 Concerns which amount to Low-Level Concerns. 

15.2 This means behaviour which might indicate that a Staff member or volunteer may pose a risk of harm if they continue to participate or work in their present position or in any capacity with Children. This will be the case where the Concern meets any one of the below “Thresholds”: 

15.3 A “Low-Level Concern” is any Concern that an individual has acted towards a Child in a way that is inconsistent with this Policy and/or code of conduct but does not meet any of the Thresholds. The term “Low-Level Concern” does not mean that it is insignificant.

15.4 Low-Level Concerns may include:

15.4.1 being over friendly with Children;

15.4.2 engaging on a one-to-one basis, in a secluded area, or behind a closed door;

15.4.3 using inappropriate language, including insensitive, derogatory or sexually suggestive comments; or

15.4.4 humiliating or degrading someone.

15.5 Low-Level Concerns may also include actions that fall short of expected professional standards or failure to take appropriate actions, such as:

15.5.1 not providing the appropriate supervision for a group;

15.5.3 not following the organisation’s policy or procedure for reporting concerns.

15.6 Low-Level Concerns may not always be managed through a safeguarding procedure; however, they can be red flags for signs of more serious behaviour or concerns and therefore it is crucial that they are managed swiftly and appropriately.

15.7 Where Low-Level Concerns are left unchallenged, they can result in inappropriate or unhealthy behaviours becoming normalised. This can lead to an unsafe, often toxic, environment and culture.

15.8 Reading Bike Hub CIC is committed to creating an environment that appropriately challenges poor practice and that is open, encouraging people to share concerns, no matter how small. A Low-Level Concern is still a Concern and therefore must be taken seriously and reported as soon as possible.

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16. RESPONSE TO CONCERNS

16.1 The  DSL shall endeavour to ensure that the Child is protected and reassured and that any immediate harm is prevented and where required reported to the appropriate external agencies. 

16.2 Following a Concern being reported, the  DSL will discuss the particulars of the Concern and consider the appropriate next steps. 

16.3 The  DSL may: 

16.3.1 collate, gather and share information, including deciding in consultation with other agencies whether a referral is to be made; 

16.3.2 undertake a risk assessment; 

16.3.3 ensure that the Child and families affected are appropriately supported and updated; 

16.3.4 ensure that any witnesses are supported and updated (where appropriate); 

16.3.5 ensure that all affected parties understand the requirements for full confidentiality (so far as is practicable) during the process of investigation, prior to an outcome being achieved; and 

163.6 ensure that the Concern where necessary and appropriate is referred to: the relevant statutory body. 

16..4 Where a Police investigation concludes without a criminal disposal or finding of guilt, Reading Bike Hub CIC reserves the right to conduct its own investigation in relation to a Concern.  Such investigation may result in action being taken under the organisation’s Code of Conduct.

17. HISTORICAL (NON-RECENT) CONCERNS 

17.1 Reading Bike Hub CIC takes all Concerns seriously, including Concerns that are historical (non-recent). Reports of historical (i.e., non-recent) Concerns will be dealt with in the same manner as recent or current Concerns. 

17.2 A report can be made directly to the  DSL via email to  safeguardingreadingbikehub@gmail.com

Upon receipt, the  DSL will provide you with a report form which must be completed.

18. INFORMATION SHARING 

18.1 Sharing information appropriately is a cornerstone of all safeguarding practice. Serious Case Reviews (statutory reviews into why a Child has died / was killed, or suffered life changing trauma, as a result of Abuse) over the past three decades all share a common failing – a failure of professionals to share information appropriately. 

18.2 No one person is responsible for safeguarding – safeguarding is everyone’s responsibility. 

18.3 No member of Staff or volunteer should hold responsibility for a Concern alone; best practice requires that all safeguarding Concerns, however seemingly minor, must always be shared and held centrally by the  DSL. 

18.4 The DSL has expertise in safeguarding, holding the wider understanding of risks to individual Children. This makes them best able to judge the severity of concerns presenting. 

18.5 The  DSL may share information with partner agencies, such as schools, social care, health and Police. 

18.6 Children should be given the opportunity to decide whether they agree to their personal information being shared. If a Child does not have the capacity to make their own decisions ask their parent, or other person with parental responsibility (unless doing so would put the Child at risk of harm). 

18.7 If consent is refused or if you are unable to seek consent, you can still share information with relevant professionals if this is in the public interest, including protecting Children from significant harm and promoting the welfare of Children.

18.8 The Data Protection Act 2018 and UK GDPR allow data sharing to take place without consent for safeguarding purposes.

19. CONFIDENTIALITY AND DATA PROTECTION 

19.1 While sharing information is crucial in order to safeguard Children, it’s equally important that this is done in line with government guidance Information Sharing: Advice for Practitioners Providing Safeguarding Services 2024. 

19.2 Data protection should not cause us to be overcautious and not share safeguarding Concerns, but it must be recognised that data protection is about protecting people not just data. Confidentiality within a safeguarding context is key to lawful practice, and it sits alongside our obligations under the Data Protection Act and the Human Rights Act.

19.3  All Concerns reported to the DSL and in particular all personal information provided to Reading Bike Hub CIC under this Policy will be dealt with in strict confidence at all times in accordance with the provisions of Data Protection Legislation and Reading Bike Hub CIC policies.

19.4 All Concerns reported to the  DSL and in particular all personal information provided to Reading Bike Hub CIC under this Policy will be dealt with in strict confidence at all times in accordance with the provisions of Data Protection Legislation and Reading Bike Hub CIC policies.

19.5 Child protection information will be stored and handled in line with the Data Protection Act 2018 and UK GDPR. Information will be stored separately from other records and in a secure place with access granted to designated people only. See NSPCC Guidance on Child Protection Records Retention and Storage for more information.

20. POSITION OF TRUST 

20.1 A “Position of Trust” involves a person in a position of authority over another person. Individuals who have responsibility for or authority over a Child / Children are in a position of trust. There is a need to protect Children aged 16 and 17 who, despite reaching the age of consent for sexual activity, are considered to be vulnerable to Sexual Abuse and exploitation, in defined circumstances. 

20.2 20.2 The Police, Crime, Sentencing and Courts Act 2022 extended the position of trust offences under the Sexual Offences Act 2003 to include sports coaches, instructors and supervisors. This means that any Reading Bike Hub volunteer or staff member who teaches, trains, instructs or supervises children is in a position of trust and must not engage in any sexual activity or relationship with a child in their care, even if that child has reached the age of consent.

20.3 The power and influence that a member of Staff or volunteer has over someone cannot be under-estimated. It is therefore vital for Staff and volunteers to recognise the responsibility they must exercise in ensuring that they could not be considered to have abused their positions of trust. 

20.4 Staff and volunteers are expected to at all times maintain healthy, positive and professional relationships with all Children. 

20.5 Within the context of Reading Bike Hub CIC, this position of trust can be compounded by the ability to provide access to bikes, equipment, and opportunities. Staff and volunteers must always be mindful of this power differential to ensure that their position is not used for personal advantage or gratification.

Staff and volunteers must always be mindful of this power differential to ensure that their position is not used for personal advantage or gratification and exercised with responsibility and respect. 22.5 All Staff and volunteers are in a Position of Trust in relation to all Children, participants and players whether or not they are in regulated activity. 

20.6 No Staff or volunteer should engage in sexual relationships with any Child. Reading Bike Hub CIC will consider such action gross misconduct, which will result in dismissal or removal from the volunteer role, and referral to the appropriate authorities.

21. PREVENT DUTY 

21.1 PREVENT is one of the four elements of “CONTEST”, the government’s counter Terrorism strategy. The four elements are: Pursue; Protect; Prepare; and Prevent.

21.3 PREVENT aims to stop people becoming involved in violent Extremism. The Prevent strategy responds to the ideological challenge of Terrorism and aspects of Extremism, and the threat from those who promote these views. 

21.3 The Prevent Duty incorporates the responsibility to promote fundamental British Values:

21.3.1 democracy;

21.3.2 the rule of law;

21.3.3 individual liberty; and

21.3.4 mutual respect and tolerance of those of different faiths and beliefs.

21.4 Reading Bike Hub CIC acknowledges the importance of the Prevent Duty. While as a small community CIC it is not a “specified authority” under the Counter-Terrorism and Security Act 2015, it nonetheless recognises its moral responsibility to be vigilant. All Staff and volunteers should complete the free online “Workshop to Raise Awareness of Prevent” (WRAP) training, available at gov.uk, as part of their induction.

21.5 Identifying a Child who is being exploited or radicalised can often be difficult as there is no single factor that leads to a Child being radicalised. Safeguarding from Radicalisation is no different to protecting Children from other forms of harm.

21.6 All Concerns relating to Radicalisation and/or Extremism must be reported to the Designated Safeguarding Lead immediately and within 24 hours. If the Concern represents an immediate threat or risk, Staff and volunteers must also contact:

21.6.1 Police: 101 (999 in an emergency);

21.6.2 Counter Terrorism Police: https://actearly.uk/contact/; and

21.6.3 Report online material promoting Terrorism or Extremism: https://www.gov.uk/report-terrorism

Appendix 1: EXAMPLES OF SIGNS, ACTIONS OR BEHAVIOURS WHICH MAY GIVE RISE TO CONCERNS

1. CHILD ON CHILD ABUSE

1.1 Staff and volunteers should be aware that Children can Abuse other Children (often referred to as Child-on-Child Abuse), and that it can happen both onsite and offsite.

1.2 Child-on-Child Abuse is most likely to include, but may not be limited to:

1.2.1 Bullying (including Cyber Bullying);

1.2.2 Abuse in intimate personal relationships between Children (sometimes known as “Teenage Relationship Abuse”);

1.2.3 Physical Abuse;

1.2.4 Sexual Abuse, including sexual violence, sexual harassment, and the non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth produced sexual imagery); and

1.2.5 Initiation/hazing type violence and rituals.

2. SEXUAL IMAGE SHARING

2.1 Reading Bike Hub CIC is committed to ensuring Children are protected from the inappropriate use of their images. No images should be taken of Children without the necessary consent being obtained first, including consent as to how the images will be used.

2.2 Staff and volunteers need to be aware that where Children send naked or inappropriate photographs of themselves to other people, they are actually sending indecent images of Children and are therefore committing a criminal offence.

3. CHILD SEXUAL EXPLOITATION (CSE) AND CHILD CRIMINAL EXPLOITATION (CCE)

3.1 Both CSE and CCE are forms of Abuse that occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a Child into taking part in sexual or criminal activity.

3.2 CSE and CCE can affect Children of any gender and can include Children who have been moved (commonly referred to as trafficking) for the purpose of exploitation.

4. DOMESTIC ABUSE

Domestic Abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. Children can be victims of domestic Abuse. They may see, hear, or experience the effects of Abuse at home and/or suffer domestic Abuse in their own intimate relationships. All of which can have a detrimental and long-term impact on their health, well-being, development, and ability to learn.

5. MENTAL HEALTH

5.1 All Staff and volunteers should be aware that mental health problems can, in some cases, be an indicator that a Child has suffered or is at risk of suffering Abuse or exploitation.

5.2 If Staff or volunteers have a mental health concern about a Child that is also a safeguarding Concern, immediate action should be taken, following this Policy and speaking to the Designated Safeguarding Lead.

6. SERIOUS VIOLENCE AND CRIMINAL EXPLOITATION

6.1 Staff and volunteers should be aware of the indicators which may signal Children are at risk from, or are involved with, serious violent crime. These may include increased absence, a change in friendships or relationships with older individuals or groups, signs of self-harm or a significant change in wellbeing, or signs of assault or unexplained injuries.

6.2 Unexplained gifts or new possessions could also indicate that Children have been approached by, or are involved with, individuals associated with criminal networks or gangs and may be at risk of criminal exploitation.

Appendix 2: EXTERNAL CONTACTS

Berkshire West Safeguarding Children Partnership: www.berkshirewestsafeguardingchildrenpartnership.org.uk