Safeguarding Policy The Prison Phoenix Trust
Organisation details
Address: The Prison Phoenix Trust, PO Box 328, Oxford OX2 7HF
Telephone: 01865 512 251
Email: all@theppt.org.uk
CEO: Selina Sasse, 01865 512 521. selina@theppt.org.uk
Safeguarding Lead: Selina Sasse 01865 512 521. selina@theppt.org.uk
Deputy Safeguarding Lead: Lou 01865 512 521 Lou@theppt.org.uk
Trustee Safeguarding Lead: Rebecca Amoroso 07808 155 614 rmlamoroso@gmail.com
3rd party: thirtyone:eight PO Box 133, Swanley, Kent, BR8 7UQ. 0303 003 1111
Registered charity number: 1163558
Insurance company: Ecclesiastical Insurance Office plc (EIO) Reg No 24869.
Safeguarding in Custodial and Criminal Justice Settings
The PPT delivers services within custodial and criminal justice settings and recognises that safeguarding in these environments operates within specific statutory, operational and security frameworks. Our safeguarding policy is therefore designed to work in partnership with the safeguarding responsibilities, procedures and reporting structures of prisons, probation services and other criminal justice agencies, including secure schools.
The PPT seeks to uphold safeguarding not only as a procedural responsibility, but as part of creating psychologically, emotionally and spiritually safe spaces within prison environments, while operating fully within criminal justice safeguarding and security frameworks. The Trust is not a faith-based organisation but considers those of any faith or none can benefit and respectful of all faith backgrounds and those who are agnostic or atheist.
The Trust acknowledges that people in prison and under probation supervision may be particularly vulnerable due to trauma, mental ill health, isolation, discrimination, abuse, self-harm risk, substance misuse, or unequal power dynamics within custodial environments. We are committed to creating safe, respectful and professionally boundaried spaces in which participants, staff, volunteers, yoga teachers and contractors are protected from harm.
Our safeguarding approach is informed by:
- relevant safeguarding legislation and guidance across the United Kingdom and Ireland;
- prison and probation service safeguarding procedures;
- multi-agency safeguarding principles;
- trauma-informed and person-centred practice;
- safer working practices within custodial environments; and
- the security, conduct and reporting requirements of each establishment in which we work.
Our safeguarding practice aims to support:
- physical safety
- psychological safety
- emotional wellbeing
- respectful relationships
- professional accountability
- spiritually safe and ethically grounded practice
Within prison environments, safeguarding requires vigilance, respect for protocol, clear boundaries and effective partnership working across agencies and disciplines.
What The Prison Phoenix Trust does
The PPT supports people living and working in prisons and other secure institutions and in their onward life to break the cycle of their offending by encouraging growth of physical, mental and spiritual wellbeing through yoga and meditation. This empowering practice encourages people to engage in other educational and rehabilitative interventions and to achieve sustainable, positive change.
This is done through sharing accessible, trauma-informed yoga and meditation with four core services combining to build individuals’ emotional resilience and self-worth:
- Group classes in trauma-responsive mindful yoga movement and meditation taught by certified Prison Yoga Teachers trained and supported by us;
- Peer-support by people living in prison sharing experiences with each other in our newsletter;
- Self-study using specialist resources including DVDs, CDs, books, hand-outs and digital content on in-cell devices suitable for a range learning styles and abilities;
- Mentoring and support of peer educators through one-to-one correspondence experienced practitioners in the staff and volunteer teams.
Trauma-informed Practice
The Trust seeks to deliver all services in a trauma-informed manner. This means recognising that many participants may have experienced significant trauma and adversity, and understanding that trauma can affect emotional regulation, behaviour, trust, relationships and engagement.
Trauma-informed practice within the Trust includes:
- creating physically and emotionally safe environments;
- offering choice wherever possible;
- using non-coercive and non-shaming approaches;
- respecting personal boundaries and autonomy at all times;
- avoiding practices that may unintentionally re-traumatise participants;
- maintaining predictable and professionally boundaried relationships; and
- responding calmly and appropriately to distress or disclosure, reporting appropriately to meet the statutory and security frameworks of the institution and in keeping with PPT policy
- focussing on yoga and meditation practice and that no interactions should encourage disclosure of personal experience, beliefs or trauma histories. For both the participants and members of The PPT
- Staff, volunteers, self-employed and contracted yoga teachers refrain from providing therapy or clinical interventions, remaining boundaried within the confines of sharing trauma-informed yoga and meditation as qualified teachers and practitioners.
Professional Boundaries
All staff, teachers, mentors, volunteers and contractors must maintain clear, appropriate and professional boundaries with participants at all times.
This includes:
- maintaining relationships that are supportive but not personal, exclusive or dependent
- avoiding favouritism or special relationships
- avoiding physical contact except where appropriate, consent-based, necessary and permitted within prison regulations
- never engaging in sexualised, flirtatious or exploitative behaviour
- not sharing personal contact details with those living or leaving prison and only with staff if authorised through organisational procedures
- maintaining appropriate communication boundaries
- avoiding financial involvement with participants
- reporting safeguarding or boundary concerns promptly
Staff and volunteers must remain aware of the power imbalance that can exist within prison environments and ensure that their conduct is always safe, respectful and professionally accountable.
Safer Working Practices in Prison Environments
All Trust representatives working in prisons are expected to:
- follow establishment rules and instructions
- comply with prison security procedures
- wear appropriate identification where required
- avoid situations where they are isolated inappropriately with prisoners
- maintain accurate records where appropriate
- report incidents, concerns or disclosures promptly
- understand emergency and security procedures within each establishment
- act in ways that protect both participants and them from harm or allegations
The Trust recognises that safeguarding and security are closely interconnected within custodial settings.
Information Sharing and Confidentiality
The Trust recognises that confidentiality is important in building trust and maintaining safe practice, particularly as part of the written mentoring programme and yoga teaching where individual come in to direct contact with people living and working in prisons. However, confidentiality cannot be absolute where there are concerns relating to:
- risk of harm
- abuse or neglect
- self-harm or suicide risk
- threats to safety or security
- terrorism, extremism or serious crime
- risks to children or vulnerable adults
It is made clear in our mentoring programme that safeguarding concerns may need to be reported to safer custody, prison staff, probation practitioners, healthcare teams, social services, police or other relevant agencies in accordance with safeguarding responsibilities and legal requirements.
Where possible and appropriate, the reason will be shared with the individual involved through written correspondence or the safer custody officer responsible in the institution.
Safeguarding Culture
The Trust seeks to foster a safeguarding culture rooted not only in compliance, but in dignity, accountability, compassion and professional integrity. The PPT board of trustees is appointed to have independent authority and legal responsibility for how the Trust is compliant, as well as setting values, standards and behaviours to inform and maintain its culture. 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) Cultural markers: assessing measuring and improving culture the charitable sector.
The Trust promotes safeguarding as everyone’s responsibility and is essential to creating environments in which transformation, wellbeing and rehabilitation can take place safely.
Our policy supports an open culture where:
- people lead by example
- are committed to safeguarding for all
- staff, volunteers & teachers are safely recruited and trained for their roles
- there are accountability structures and reporting lines
- there are codes of conduct
- the values of the organisation are embedded in its actions
- there is open communication
- recording and storing information is in line with data protection legislation and guidance from the Information Commissioner’s Office: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/
Our commitment
The PPT recognises 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. It accepts 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”. It also concurs 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 (thiryoneeight.org/ten-standards)
Prevention
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:
- 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.
- 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.
The Trust recognises the different ways of categorising harm and abuse as documented and updated by safeguarding experts thirtyone:eight https://thirtyoneeight.org/help-and-resources/knowledge-hub/responding-to-concerns/recognise/categories-of-abuse/categories-by-nation/
Safer recruitment
The CEO and Operations Director (the ‘Leadership’) ensure all workers are 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 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 operate and promote good working practice. This enables workers to run activities safely and develop good open relationships and minimise the risk of false or unfounded allegations.
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 our safeguarding policy with includes protocol for engaging with children, young people and adults with care and support needs, and are given clear expectations about what is expected of them both within their job role and out. They may also receive further training as necessary.
Procedure for a safeguarding concern
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 (staff member, trustee, volunteer, consultant, contracted or freelance yoga teacher) should make a report of the concern in the following way:
- Report a concern
The person in receipt of allegations or suspicions of abuse should report concerns as soon as possible to either:
Staff Safeguarding Lead: Selina Sasse 01865 512 521. selina@theppt.org.uk
Deputy Staff Safeguarding Lead: Lou 01865 512 521 Lou@theppt.org.uk
Trustee Safeguarding Lead: Rebecca Amoroso 07808 155 614 rmlamoroso@gmail.com
3rd party: thirtyone:eight PO Box 133, Swanley, Kent, BR8 7UQ. 0303 003 1111
Social services: If the concern relates to welfare, neglect, emotional abuse or vulnerability and there is no immediate danger contact. Contact social services in the area the adult or child lives
999 if there is immediate danger or if someone isn’t safe right now
0808 800 5000 NSPCC Helpline for child safeguarding advice or if you are unsure whether to contact the police
101 if someone is at risk and it is serious but not urgent, including disclosures of historic abuse.
- Inform others
The Safeguarding Lead/Deputy 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.
- Not discussed outside of safeguarding team
- Suspicions must not be discussed with anyone other than those nominated above.
- A written record of the concerns, including date and time of event or disclosure, should be made in accordance with these procedures and kept in a secure place, such as a lockable drawer or protected document.
- Whilst allegations or suspicions of abuse will normally be reported to one of the Safeguarding Leads, for urgent needs, in their absence refer to Social Services, the Police or taking advice from Thirtyone:eight.
- 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 encourages members of the organisation will use this procedure. If, however, the individual with the concern feels that the Safeguarding Leads have not responded appropriately, or where they have a disagreement 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 Lead/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 Lead 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 Lead/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 Lead/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 Lead 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 Lead/Deputy, 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 Lead 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-survivor’ 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 PPT.
Pastoral Care
Supporting those affected by abuse
The Leadership is committed to offering pastoral care and support, working with statutory agencies as appropriate, to all those who have been affected by abuse who have contact with or are part of the 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 carry out a risk assessment and supervise the individual concerned and offer pastoral care. 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.
Signed by:
Selina Sasse
Position: CEO
Date: 27 May 2026