Safeguarding Policy

Address: The Prison Phoenix Trust, PO Box 328, Oxford OX2 7HF
Telephone: 01865 512 251
Director: Selina Sasse, 01865 512 521.
Safeguarding Officer: Selina Sasse 01865 512 521.
Registered charity number: 1163558
Insurance company: Ecclesistical Insurance Office plc (EIO) Reg No 24869.

The following is a brief description of our organisation and the type of work and activities we undertake with adults and children who have care and support needs.
The Prison Phoenix Trust facilitates hope and healing to people in prison and secure establishments through meditation and yoga. We support these breath-based practices in more than 200 prisons and other secure establishments in the UK and Ireland. This includes adults living or working in these settings and children living in secure establishments.
We offer individual support through written mentoring, resources for practice guidance, newsletters, teaching and the training of teachers and mentors. We are not a faith based organisation but consider those of any faith or none can benefit and we are respectful of all faith backgrounds.

The purpose of this policy statement is:
• To protect adults, children and young people who receive services from The Prison Phoenix Trust from harm. This includes the children of adults who use our services and work with us.
• To provide staff, trustees and volunteers, as well as the teachers we work with, with the overarching principles that guide our approach to safeguarding and child protection.

This policy applies to anyone working on behalf of The Prison Phoenix Trust, including senior managers and the Board of trustees, paid staff, volunteers, sub-contracted yoga teachers and self-employed yoga teachers working with the Trust, consultancy staff, researchers and any other people engaged with our work.

Section 2: Introduction
Good governance helps an organisation prevent abuse and means it can respond quickly and with integrity when concerns arise. Central to this, is the Governance Board or Board of Trustees
The governance board is appointed to have independent authority and legal responsibility for how an organisation or charity and have a critical role in decision making and compliance as well as setting the values, standards and behaviours of the organisation.
The standards and behaviours may be referred to as the culture of the organisation or “the way we do things around here”. Culture can be shaped in both negative and positive ways.
“The culture of a charity goes beyond mere compliance with legal and regulatory demands. Charity governance is most effective when it provides assurances not just that legal requirements are met, but that the behaviour of people working for the charity, and those who come into contact with it, is proper and ethical. Culture, alongside good governance, can be pivotal to whether a charity achieves its stated object” (ICSA The Governance Institute, 2017)

Positions of Trust
All adults working with children, young people and vulnerable adults are in a position of trust. All those in positions of trust need to understand the power this can give them over those they care for and the responsibility they have because of this relationship.
It is vital that all workers ensure they do not, even unknowingly, use their position of power and authority inappropriately. They should always maintain professional boundaries and avoid behaviour which could be misinterpreted.

The following Safeguarding Policy and Statement aims, to not only meet the requirements of ensuring a safe environment for those accessing activities in our organisation but to also build an open culture where:
• those who lead do so by example,
• are committed to the safeguarding of all
• those that work or volunteer are safely recruited and trained for their roles.
• there are accountability structures
• there are codes of conduct
• the values of the organisation are embedded in its day to day actions and behaviours of its people
• there is open communication
• recording and storing and using information professionally and securely, is in line with data protection legislation and guidance based on guidance from the Information Commissioner’s Office:

Our commitment
As a Leadership we recognise the need to provide a safe and caring environment for children, young people and adults. We acknowledge that children, young people and adults can be the victims of physical, sexual and emotional abuse, and neglect. We accept the UN Universal Declaration of Human Rights and the International Covenant of Human Rights, which states that everyone is entitled to “all the rights and freedoms set forth therein, without distinction of any kind, such as race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status”. We also concur with the Convention on the Rights of the Child which states that children should be able to develop their full potential, free from hunger and want, neglect and abuse. They have a right to be protected from “all forms of physical or mental violence, injury or abuse, neglect or negligent treatment or exploitation, including sexual abuse, while in the care of parent(s), legal guardian(s), or any other person who has care of the child.” As a Leadership we have therefore adopted the procedures set out in this safeguarding policy in accordance with statutory guidance. We are committed to build constructive links with statutory and voluntary agencies involved in safeguarding.
The policy and any attached practice guidelines are based on the ten safeguarding standards published by Thirtyone:eight (

Section 3
Understanding abuse and neglect
Defining child abuse or abuse against an adult is a difficult and complex issue. A person may abuse by inflicting harm or failing to prevent harm. Children and adults in need of protection may be abused within a family, an institution or a community setting. Very often the abuser is known or in a trusted relationship with the child or adult.

To safeguard those in our organisation and those we support we adhere to the UN Convention on the Rights of the Child and have as our starting point as a definition of abuse, Article 19:
1. States Parties shall take all appropriate legislative, administrative, social and educational measures to protect the child from all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse, while in the care of parent(s), legal guardian(s) or any other person who has the care of the child.
2. Such protective measures should, as appropriate, include effective procedures for the establishment of social programmes to provide necessary support for the child and for those who have the care of the child, as well as for other forms of prevention and for identification, reporting, referral, investigation, treatment and follow-up of instances of child maltreatment described heretofore, and, as appropriate, for judicial involvement.

Also for adults the UN Universal Declaration of Human Rights with particular reference to Article 5:
No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment.
Detailed definitions, and signs and indicators of abuse, as well as how to respond to a disclosure of abuse, are included here in our policy. APPENDIX 2.

Safer recruitment
The Leadership will ensure all workers will be appointed, trained, supported and supervised in accordance with government guidance on safe recruitment. This includes ensuring that:
· There is a written job description / person specification for the post
· Those applying have completed an application form
· Those short listed have been interviewed
· Safeguarding has been discussed at interview
· Written references have been obtained, and followed up where appropriate
· A self-declaration form and disclosure and barring check (DBS) has been completed where necessary (we will comply with Code of Practice requirements concerning the fair treatment of applicants and the handling of information)
· Qualifications where relevant have been verified
· A suitable training programme is provided for the successful applicant
· The applicant has completed a probationary period
· The applicant has been given a copy of the organisation’s safeguarding policy and knows how to report concerns.

Safeguarding training
The Leadership is committed to on-going safeguarding training and development opportunities for all workers, developing a culture of awareness of safeguarding issues to help protect everyone. All our workers will receive induction training and undertake recognised safeguarding training on a regular basis.
The Leadership will also ensure that children and adults with care and support needs are provided with information on where to get help and advice in relation to abuse, discrimination, bullying or any other matter where they have a concern.

Practice Guidelines
As an organisation working with children, young people and adults with care and support needs we wish to operate and promote good working practice. This will enable workers to run activities safely, develop good relationships and minimise the risk of false or unfounded
Management of Workers – Codes of Conduct
As a Leadership we are committed to supporting all workers and ensuring they receive support and supervision. All workers have been issued with a code of conduct towards children, young people and adults with care and support needs, and will be given clear expectations about what is expected of them both within their job role and out. They will also receive further training as necessary.

Section 4:
Partnership working
The diversity of organisations and settings means there can be great variation in practice when it comes to safeguarding children, young people and adults. This can be because of cultural tradition, belief and religious practice or understanding, for example, of what constitutes abuse.
We therefore have clear guidelines with regards to our expectations of those with whom we work in partnership, whether in the UK or not. We will discuss with all partners our safeguarding expectations and have a partnership agreement for safeguarding. It is also our expectation that any organisation using our premises, as part of the letting agreement will have their own policy that meets Thirtyone:eight’s safeguarding standards.
We believe good communication is essential in promoting safeguarding, both to those we wish to protect, to everyone involved in working with children and adults and to all those with whom we work in partnership. This safeguarding policy is just one means of promoting safeguarding.

Section 5
Responding to allegations of abuse

Under no circumstances should a volunteer or worker carry out their own investigation into an allegation or suspicion of abuse. Follow procedures as below:

• Documenting a concern
The worker or volunteer should make a report of the concern in the following way:

• The person in receipt of allegations or suspicions of abuse should report concerns as soon as possible to:
Name: S Sasse (hereafter the “Safeguarding Co-ordinator”)
Tel: 01865 512 521
The above is nominated by the Leadership to act on their behalf in dealing with the allegation or suspicion of neglect or abuse, including referring the matter on to the statutory authorities.

• In the absence of the Safeguarding Co-ordinator or, if the suspicions in any way involve the Safeguarding Co-ordinator, then the report should be made to:
Name: L Steele (hereafter the “Deputy”)
Tel: 01865 512 521

If the suspicions implicate both the Safeguarding Co-ordinator and the Deputy, then the report should be made in the first instance to The Prison Phoenix Trust trustee responsible for safeguarding:
Name: Nicholas Colloff.
Tel: +41 799 29 2260 (for calls or WhatsApp messages)

Or thirtyone:eight PO Box 133, Swanley, Kent, BR8 7UQ.
Tel: 0303 003 1111.
Alternatively contact Social Services or the police.

• The Safeguarding Co-ordinator documents the concern and should contact the appropriate agency or they may first ring the thirtyone:eight helpline for advice. They should then contact social services in the area the child or adult lives.

• The Safeguarding Co-ordinator may need to inform others depending on the circumstances and/or nature of the concern
 Chair, trustee responsible for safeguarding and may need to liaise with the insurance company or the charity commission to report a serious incident.
 Designated officer or LADO (Local Authority Designated Officer) if the allegation concerns a worker or volunteer working with someone under 18.

• Suspicions must not be discussed with anyone other than those nominated above. A written record of the concerns should be made in accordance with these procedures and kept in a secure place.

• Whilst allegations or suspicions of abuse will normally be reported to the Safeguarding Co-ordinator, the absence of the Safeguarding Co-ordinator or Deputy should not delay referral to Social Services, the Police or taking advice from Thirtyone:eight.

• The Leadership will support the Safeguarding Co-ordinator/Deputy in their role and accept that any information they may have in their possession will be shared in a strictly limited way on a need to know basis.

• It is, of course, the right of any individual as a citizen to make a direct referral to the safeguarding agencies or seek advice from Thirtyone:eight, although the Leadership hope that members of the place of worship / organisation will use this procedure. If, however, the individual with the concern feels that the Safeguarding Co-ordinator/Deputy has not responded appropriately, or where they have a disagreement with the Safeguarding Co-ordinator(s) as to the appropriateness of a referral they are free to contact an outside agency direct. We hope by making this statement that the Leadership demonstrate its commitment to effective safeguarding and the protection of all those who are vulnerable.

The role of the safeguarding co-ordinator/ deputy is to collate and clarify the precise details of the allegation or suspicion and pass this information on to statutory agencies who have a legal duty to investigate.

Detailed procedures where there is a concern about a child:

Allegations of physical injury, neglect or emotional abuse.
If a child has a physical injury, a symptom of neglect or where there are concerns about emotional abuse, the Safeguarding Co-ordinator/Deputy will:

• Contact Children’s Social Services (or Thirtyone:eight) for advice in cases of deliberate injury, if concerned about a child’s safety or if a child is afraid of being in the secure setting.
• Not tell the staff unless advised to do so, having contacted Children’s Social Services.
• For lesser concerns, (e.g. poor care), report this to safer custody at the secure setting, but not if this places the child at risk of significant harm.
• Seek and follow advice given by Thirtyone:eight (who will confirm their advice in writing) if unsure whether or not to refer a case to Children’s Social Services.

Allegations of sexual abuse

In the event of allegations or suspicions of sexual abuse, the Safeguarding Co-ordinator/Deputy will:

• Contact the Children’s Social Services Department Duty Social Worker for children and families or Police Child Protection Team direct. They will NOT speak to safer custody at the secure setting or anyone else.

• Seek and follow the advice given by Thirtyone:eight if for any reason they are unsure whether or not to contact Children’s Social Services/Police. Thirtyone:eight will confirm its advice in writing for future reference.

Detailed procedures where there is a concern that an adult needs protection:
Suspicions or allegations of abuse or harm including; physical, sexual, organisational, financial, discriminatory, neglect, self-neglect, forced marriage, modern slavery, domestic abuse.

If there is concern about any of the above, Safeguarding Co-ordinator/Deputy will:

• Contact the Adult Social Care Team who have responsibility under the Care Act 2014 to investigate allegations of abuse. Alternatively Thirtyone:eight can be contacted for advice.
• If the adult is in immediate danger or has sustained a serious injury contact the Emergency Services, informing them of any suspicions.

If there is a concern regarding spiritual abuse, Safeguarding Co-ordinator will:
• Bring this to the awareness of Safer Custody at the secure setting.
• Contact Thirtyone:eight and in discussion with them will consider appropriate action with regards to the scale of the concern.

Allegations of abuse against a person who works with children/young people
If an accusation is made against a worker (whether a volunteer or paid member of staff) whilst following the procedure outlined above, the Safeguarding Co-ordinator, in accordance with Local Safeguarding Children Board (LSCB) procedures will:
• Liaise with Children’s Social Services regarding the suspension of the worker
• Make a referral to a designated officer formerly called a Local Authority Designated Officer (LADO) whose function is to handle all allegations against adults who work with children and young people whether in a paid or voluntary capacity.
• Make a referral to Disclosure and Barring Service for consideration of the person being placed on the barred list for working with children or adults with additional care and support needs. This decision should be informed by the LADO if they are involved.
Allegations of abuse against a person who works with adults with care and support needs

The safeguarding co-ordinator will:

• Liaise with Adult Social Services in regards the suspension of the worker

• Make a referral to the DBS following the advice of Adult Social Services

The Care Act places the duty upon Adult Services to investigate situations of harm to adults with care and support needs. This may result in a range of options including action against the person or organisation causing the harm, increasing the support for the carers or no further action if the ‘victim’ chooses for no further action and they have the capacity to communicate their decision. However, this is a decision for Adult Services to decide not the church.

Section 6
Pastoral Care

Supporting those affected by abuse

The Leadership is committed to offering pastoral care, working with statutory agencies as appropriate, and support to all those who have been affected by abuse who have contact with or are part of the place of worship/organisation.

Working with offenders and those who may pose a risk

When someone attending the organisation is known to have abused children, is under investigation, or is known to be a risk to adults with care and support needs; the Leadership will supervise the individual concerned and offer pastoral care, but in its safeguarding commitment to the protection of children and adults with care and support needs, set boundaries for that person, which they will be expected to keep. These boundaries will be based on a risk assessment and through consultation with appropriate parties.


Adoption of the policy

This policy will be reviewed annually in June 2024

Signed by: Selina Sasse

Position:  Director

Date:  23 May 2024

A copy of this policy is also lodged with N Colloff, trustee of The Prison Phoenix Trust