The Festival will prevent and reduce harm to children and vulnerable adults when they are in contact with Festival staff, partners and suppliers, volunteers or audience members with the aim to:
- Promote and prioritise the safety and wellbeing of children and vulnerable adults, including forms of exploitation, victimisation and other violation of fundamental human rights, such as modern slavery.
- Provide assurance to parents, carers and other parties that the Festival takes reasonable steps to manage risks and keep children and vulnerable adults safe
- Ensure that everyone understands their roles and responsibilities in respect of safeguarding and are provided with the necessary information, training and support on safeguarding matters, including preventing interaction where appropriate
- Ensure that appropriate action is taken in the event of any allegations or suspicions regarding harm to children or vulnerable adults arising from contact with Festival staff, partners, volunteers or audience members.
The Safeguarding Vulnerable Groups Act 2006 (“SVGA”) is designed to avoid harm, or risk of harm, by preventing people who are deemed unsuitable to work with children and vulnerable adults from gaining access to them through their work.
The Modern Slavery Act 2015 (“MSA”) covers antislavery and human trafficking offences that might take any form, including forced labour, slavery, servitude and human trafficking.
Child or vulnerable adult exploitation or slavery of any kind are crimes that can manifest in many ways, but what each of their forms will have in common is the exploitation of a person for another person or another person’s (or organisation’s) benefit.
The Festival will support safeguarding actions by:
- Completing a risk assessment process which involves identifying risks and means of reducing or eliminating these.
- Implementing the required actions identified by the risk assessment process, reviewing the effectiveness of these on a regular basis and highlighting this Safeguarding Policy to new Festival employees, volunteers and partners. Examples include supply chain oversight, where higher-risk services and functions are given greater scrutiny, such as for distribution companies, venues and caterers.
- Ensuring that staff, trustees and volunteers have a right to work in the UK by demonstrating evidence that may include a UK passport, UK driving license or a UK birth or adoption certificate plus a National Insurance card, or non-UK passport with a suitable visa with entitlement to work in the UK.
This policy requires that any suspicions and allegations involving harm to children and vulnerable adults be referred to the Director of the Festival who will enrol Trustees to determine what action, if any, must be taken. This will enable each situation to be investigated thoroughly, while treating the parties involved fairly and with sensitivity. Suitable steps will be taken as a result of any investigations, which may include contacting the police and fulfilling the legal duty to refer information to the Disclosure and Barring Service (DBS) as required. The procedure for managing suspicions and allegations aims to strike a balance between the need to protect children and vulnerable adults from abuse and the need to protect staff, partners and volunteers from false or unfounded accusations.
A child is any person under the age of 18. Adults have the potential to be vulnerable (either temporarily or permanently) for a variety of reasons and in different situations. An adult may be vulnerable if he/she has a learning or physical disability, has a reduction in physical or mental capacity, chronic or otherwise, including an addiction to alcohol or drugs or is unable, for any other reason, to protect himself/herself against significant harm or exploitation. It is recognised that it may be impossible to identify whether vulnerability exists in relation to an activity or event involving adults.
A person may abuse or neglect a child/vulnerable adult by inflicting harm, or by failing to act to prevent harm. According to the Department for Education and Skills, there are four main types of abuse,[1] with variation and crossover within these:
- Physical abuse is physical harm to children and vulnerable adults or any other form of harm that causes illness in a child or vulnerable person.
- Emotional abuse involves the persistent emotional maltreatment of a child or vulnerable adult such as to cause severe and persistent adverse effects on their emotional wellbeing and/or development.
- Sexual abuse and exploitation is forcing or manipulating a child or vulnerable adult to take part in sexual activities.
- Neglect involves the persistent failure to meet a child or vulnerable adult’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s or vulnerable adult’s health or development.
Steps to help and what to look out for
It is not always easy to recognise a situation where abuse may occur or has taken place, however, each person has a responsibility to act if they have any concerns about someone’s behaviour towards a child or vulnerable adult. It is important that the recipient of any complaint or accusation that a child or vulnerable adult has been or is being abused listens carefully without making or implying any judgment as to the truth of the complaint or accusation.
The Home Office has issued guidance related modern slavery awareness and victim identification [2]. Behaviours and signs to look out for that might identify an instance of child or vulnerable adult exploitation, including modern slavery might be:
- Distrustful of authorities
- Signs of physical or psychological trauma (including post traumatic stress disorder)
- The person acts as if instructed by another
- Restriction of movement and confinement to the workplace or to a limited area
- Signs of ritual abuse, substance misuse and witchcraft (juju)
- Inappropriate (including sexual) behaviour or incoherent/changing accounts of events
- Unexplained eagerness to leave or remain a safe space/to work
Victims may not recognise themselves as a victim or want to talk to the authorities or be formally referred for support. This should not prevent information about potential exploitation being passed to the police (and completion of a Duty to Notify form for relevant organisations) which could help the police identify a crime. Victims can be traumatised and there are various barriers that may make it difficult for them to come forward or co-operate with a friendly person or the authorities, for example they may be:
- Unaware they are a victim or that help is available
- Fear of repercussions (for themselves or their families)
- Always accompanied by a perpetrator
- Feel they are still better off than in their home country situation
- Involvement in criminal activity
- Lack of trust in authorities
Anyone who is worried about sharing concerns about abuse are encouraged to speak with an appropriate agency for further advice, for example: Childline on 0800 1111 or the NSPCC Child Protection Helpline on 0808 800 5000. The Oxfordshire Safeguarding Children Board website is: www.oscb.org.uk.
The Modern Slavery Helpline is an independent, confidential advice service where you may access further information and support regarding all forms of slavery and where you may report concerns, issues or suspicions of modern slavery, anonymously if preferred: 0800 121 700 or online at www.modernslaveryhelpline.org.
Avoiding compromising situations
Do not put yourself in potentially compromising situations. You can look after others and yourself by following best practice for working with vulnerable adults and children, which includes an assessment of risks involved in any given situation.
A risk assessment should consider the nature, length and frequency of contact and if it would be supervised or unsupervised to highlight whether any children and adults may be at risk. It should identify any potential areas for harm, evaluate the risks and determine actions to prevent harm occurring, which might include consideration of alternative working practices, and prompting individuals to ensure that they are implemented. In addition to other points, a risk assessment might include:
- safe methods of working/activities, the result of potential allergies or specific visible or non-visible mental or physical characteristics of the individual
- the environment of the activity, eg. work in an open environment with children where they can be seen by others and avoiding unnecessary physical contact
- the provision of First aid, or escorting anyone to the toilet or any other private location, to involve more than one adult
- the potential for misinterpretation of emotional, suggestive or inappropriate remarks to or about a child or vulnerable adult, even in fun
- the possibility that inappropriate behaviour can also occur over the telephone, email, social media or internet.
Where it is necessary for staff, students or volunteers to take photographs or video images of children or vulnerable adults, written consent must be obtained (from parents/guardians in the case of children) before these images are taken in order to comply with the General Data Protection Regulation (GDPR). Personal details and photos, which clearly identify an individual, must only be published where he/she (or his/her parent/guardian) has given specific agreement. Subjects should be suitably dressed in photographs (e.g. when taking place in a sporting activity).
[1] Child abuse concerns: guide for practitioners, DFES, March 2015: What to do if you’re worried a child is being abused: advice for practitioners
[2] Modern Slavery Awareness and Victim Identification Guide, The Home Office