Approved by Committee 15th July 2025
Review date 15th July 2026

Purpose and Commitment

At BRWR, we provide practical and emotional support to refugees and asylum seekers, who can be vulnerable; may be traumatised from their experience of war, torture or significant loss; and may have complex needs. We aim to empower them over time to integrate into their local and wider communities. Safeguarding vulnerable adults and children is integral to the support we offer.

We welcome new arrivals to Bromsgrove, Redditch and the surrounding areas, who are often signposted to us by Local Authorities; Social Care / Health professionals or other agencies, and we provide crisis help to meet the immediate needs of those who are destitute. We help people to access education, social benefits and health provision, working alongside other agencies. We offer emotional, practical and social support through our system of Key Friends; help people to develop English skills; employment skills and learn about life in the UK and to achieve long-term independence and to thrive. We regularly come into contact with service users* and the public, and therefore safeguarding matters throughout our work, including in communications and fundraising.

*[service users is the term used in this document to refer to those supported by BRWR and whom we work with in collaborative partnership].

We recognise that the safety and welfare of children and adults is paramount, and we do not tolerate the abuse of any person in any form. We are committed to Safeguarding, and we understand our duty of care to our service users and those who come into contact with our organisation, as well as to those who volunteer for BRWR. Safeguarding is about implementing the necessary measures to prevent harm to children, young people and vulnerable adults who are at significant risk of abuse and harm.

Our policy is designed to protect our Service users and our volunteers.

All safeguarding concerns will be taken seriously, and we strive to work in partnership with other agencies.

Building and maintaining an organisational culture which promotes safeguarding throughout our systems and processes.
Creating a safe and secure environment where everyone can work together confidently and with mutual respect.
Promoting the ‘think family’ approach which recognises that the needs of children and the needs of their parents, carers or other adults cannot be separated from each other, and their outcomes are mutually dependent on each other’s well-being.

Everyone has a right to equal protection from harm or abuse, regardless of race, ethnicity, religion or belief, age, disability, sex, sexual orientation, gender reassignment, marriage or civil partnership, pregnancy and maternity, immigration status, class or caste, or any other difference.

BRWR works with children (defined as those under 18 years) and adults (those over 18 years) and this safeguarding policy and procedure therefore applies to both children and adults.

This policy and procedure is approved by our trustees. It will be reviewed and updated annually or more frequently as needed. It will be available to all volunteers and to others who have an interest in our services.

Scope

This policy and procedure applies to everyone volunteering with BRWR, including all trustees and volunteers – these will be referred to, collectively, as volunteers in this document. It is expected that this policy and procedure will be read, understood, and applied by all volunteers.

Legislation and Guidance

This safeguarding policy is underpinned by law and statutory guidance including:

Human Rights Act 1998
Equality Act 2010
Charity Commission Safeguarding Guidance 2021
Data Protection Act 2018 (UK GDPR)
Information Sharing Guidance 2018
Children Act 1989
Children Act 2004
Working Together to Safeguard Children 2023
Children’s Social Care National Framework 2023
Care Act 2014
Health and Social Care Act 2022
Care & Support Statutory Guidance 2022
Mental Capacity Act 2005
Mental Health Act 2007
Safeguarding Vulnerable Groups Act 2006
Protection of Freedoms Act 2012

1. Roles and Responsibilities

1.1 Everyone

Everyone at BRWR is responsible for safeguarding. Everyone should:

read and apply this safeguarding policy and
be vigilant in the course of their work and respond to safeguarding concerns using the procedures in this document.
treat everyone they come into contact with
promote safe practices around working with service users e.g. no lone working with a child or adult with identified vulnerabilities; always ensure another adult is present.
attend safeguarding learning and development

1.1.1 Safeguarding Protocol for BRWR volunteers

All volunteers working directly with children and adults, whether on a regular or occasional basis, must:

have a current enhanced DBS certificate
sign to confirm they have read and understand this policy, the operational procedures and the Recording Form (Appendix 1).
undertake Safeguarding training every two years at a level suitable for their role.

Written Risk Assessments are required when planning BRWR activities to ensure all BRWR service users, volunteers and the public are safe. Plans and written risk assessments for activities must be shared with the Committee for approval.

1.2 Designated Safeguarding Leads (DSLs)

DSLs will act as the decision maker and lead in escalating as appropriate and managing safeguarding alerts as a proportionate response to significant harm concerns. In the absence of DSLs, the BRWR Chairperson should undertake these responsibilities. It is the responsibility of Safeguarding Leads to make referrals to outside agencies (social care, police etc), unless there is an emergency. Emergency and DSL contacts are listed in Appendix 3.

Sophie Vokal, (Committee member, Befrienders’ Support group Co-ordinator, Keyfriend) is the DSL responsible for safeguarding children. Contact: safeguarding@brwr.uk

Linda Fleming, (BRWR Volunteer, Keyfriend, Redditch Ukraine Support Group Lead), is the DSL responsible for safeguarding adults. Contact: safeguarding@brwr.uk

Yvonne Rendell is BRWR Chairperson. Contact: safeguarding@brwr.uk

The DSLs’ safeguarding responsibilities include:

promoting a safeguarding and listening culture and keeping updated about changes in safeguarding law and best practice.
promoting the safeguarding policy and procedures to volunteers, supporting them to follow them, providing opportunities to embed them, for example meetings and training.
being available to volunteers and providing safeguarding advice and
managing individual safeguarding alerts including making decisions, taking actions, seeking specialist advice, making referrals, multi-agency work, escalating concerns if required and managing record keeping.
overseeing safeguarding recording and support volunteers in record
alerting the BRWR Chairperson to safeguarding concerns relating to volunteers, or poor practice concerns.
reviewing the safeguarding policy and procedure in line with statutory guidance annually, overseeing implementation across BRWR.
ensuring effective safeguarding systems and processes are in place, including secure
managing safeguarding allegations against
escalating any serious incidents (as per Charity Commission guidance) to briefing trustees regularly about safeguarding activity and providing quarterly and annual reports on safeguarding.

1.3 Chairperson

The Chairperson oversees safeguarding across BRWR and the role includes:

promoting safeguarding and a listening
ensuring that the organisation has people, policies, practices, and systems in place to respond to safeguarding alerts.
managing escalated safeguarding cases
managing escalated safeguarding allegations against volunteers.
alongside DSL, report on safeguarding to
supporting the DSLs to undertake their safeguarding

1.4 Trustees

The Trustees are responsible for the governance of safeguarding, ensuring that BRWR is legally compliant, well run and effective in managing safeguarding risk across the organisation. Their responsibilities include ensuring:

- a culture of safeguarding is promoted whereby trustees assess and scrutinise safeguarding
- a culture of safeguarding is maintained across the organisation where volunteers and service users can raise concerns.
- a safeguarding policy is in place which is reviewed annually, understood, and
- compliance with the Charity Commission serious incident notification requirements, and other bodies such as regulators, grant-makers, and insurance companies.

2. Identifying Abuse & Neglect

2.1 Safeguarding children

A ‘child’ is a person who is aged under 18.

Safeguarding is defined in the statutory guidance ‘Working Together 2023’ as:

protecting children from maltreatment, whether that is within or outside the home, including
preventing impairment of children’s mental and physical health or development and providing help and support to meet the needs of children as soon as problems emerge.
ensuring that children grow up in circumstances consistent with the provision of safe and effective
promoting the upbringing of children with their birth parents, or family network whenever possible and where this is in the best interests of the children taking action to enable all children to have the best outcomes.

2.2 Safeguarding adults

Safeguarding means protecting an adult’s right to live in safety; free from abuse and neglect. It is about people and organisations working together to prevent and stop both the risks and experience of abuse or neglect, while at the same time making sure that the adult’s wellbeing is promoted including, where appropriate, having regard to their views, wishes, feelings and beliefs in deciding on any action.

Safeguarding duties under the legislation (Care & Support statutory guidance) apply to an ‘adult at risk’ who is aged 18 years and over and who:

is experiencing, or is at risk of, abuse or neglect
has care and support needs, (whether or not the local authority is meeting any of those needs)
because of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect

An ‘adult at risk’ may need care and support and be unable to protect themselves from harm for reasons such as, but not limited to, learning or physical disability, mental health difficulties, and infirmity. BRWR supports all the adults that we work with, although not all may be defined as an ‘adult at risk’ using the criteria set out in the legislation.

The Care Act identifies six key principles that underpin adult safeguarding work:

Empowerment – people being supported and encouraged to make their own decisions and informed consent.

Prevention – take action before harm occurs.

Proportionality – the least intrusive response appropriate to the risk presented.

Protection – support and representation for those in greatest need.

Local solutions – through services working with communities.

Communities – have a part to play in preventing, detecting and reporting neglect and abuse.

Accountability – transparency in delivering safeguarding.

2.3 Defining ‘abuse’ and ‘neglect’

Abuse is a violation of an individual’s human or civil rights by another person or people. It is the result of deliberate intent, negligence or ignorance. Somebody may abuse or neglect a person by inflicting harm, or by failing to act to prevent harm. Abuse and neglect can happen anywhere, for example, in a family, institutional or community setting or in a public place or online. Anyone can perpetrate abuse or neglect, e.g. family, friends, acquaintances, strangers, volunteers, carers, adults, or children.

2.4 Categories and indicators of abuse and neglect

Appendix 4 lists types of harm and their typical signs and indicators

2.5 Vulnerabilities

All our service users may have significant needs and vulnerabilities perhaps due to being refugees and people seeking asylum in the UK, or their inability to understand and communicate due to language differences and differing cultural norms. Homelessness and inadequate housing, poverty, and lack of access to provision to meet basic needs are some of the vulnerabilities which may affect our service users. These may be exacerbated by a person’s physical or mental health difficulties and/or traumatic life experiences, or hostile and discriminatory treatment they experience once they have arrived in the UK. The experience of excessive challenges in settling, in terms of meeting their education, employment or health care needs may also result in limited opportunities, isolation, and poorer outcomes.

Vulnerabilities do not always translate to harm, but it is helpful to consider that people who are exposed to such vulnerabilities are likely to need additional support over a longer term to achieve positive outcomes – this is what we at BRWR offer. It should also be considered that those who seek to exploit and harm others are more likely to target those who are vulnerable.

2.6 How Safeguarding Concerns May Arise at BRWR

Safeguarding concerns might be identified because

A service user says they have experienced harm, historically or
A BRWR volunteer reports that a service user has experienced harm, historically or
A third party, external to the organisation, says that a service user has experienced harm, historically or currently.
A service user has caused harm to another
Allegations are made about a person which lead to concerns about their care of
A volunteer involved with our work speaks out about abuse they have
There are queries about volunteer working practices or allegations made against volunteers.
A volunteer has witnessed whilst delivering services from BRWR, behaviours and actions which are causing them concern.

We could encounter these concerns throughout our work, whether it is through delivery of services to refugees and asylum-seeking people, or in our work such as fundraising and communications.

2.7 Barriers to Speaking Out

Many people are reluctant to disclose their experiences of abuse and neglect because they:

feel shame or embarrassment.
feel guilt or responsibility for the
do not have anyone that they can turn to or trust; may have sought help before but felt let
fear not being
have accepted the abuse or neglect as a ‘norm.’
fear the consequences of
believe they are protecting others.
lack language to speak out, g. have communication impairment, do not speak English fluently.
fear the response of authorities, including upon their asylum

It is essential that we are available to our service users and work to provide a culture of listening, and that we understand the barriers for people in speaking out so that we can help to counter them.

3. Information Sharing

3.1 Sharing internally

It is expected that information about safeguarding matters is shared with colleagues at BRWR on a ‘need to know’ basis as per this Safeguarding Policy and Procedure.

3.2 Sharing externally with other agencies

When sharing information about service users with external agencies, the law on confidentiality and information sharing must be applied. The general principle is that service users have a right to expect that their personal information is not shared with other agencies without their informed consent. However, there are exceptions when there is a duty to share information that is in the public interest and the need to gain consent to share information may be overridden. Examples include:

emergency or life-threatening
other people are, or may be placed at risk.
seeking consent could place the individual or others at

3.2.1. Sharing information about children

Government guidance on sharing information about children’s safeguarding is set out in this document: DfE non statutory information sharing advice for practitioners providing safeguarding services for children, young people, parents and carers (publishing.service.gov.uk)

It sets out Seven Golden Rules for information sharing which are:

Protecting a child from harm takes priority over protecting
Information may be shared where doing so will safeguard a child.
Where it is practicable and safe to do so, explain what information you intend to share, with whom and You do not need to do so if it may put the child at increased risk of harm.
You do not need consent to share information if a child is at risk of harm, but it is good practice to listen to the views of the child and/or their carers about information sharing.
Seek advice promptly if you are uncertain about whether to share
When sharing information, ensure you and the person receiving the information protect the identities of those who might suffer harm if their details became known to an abuser.
Only share relevant, accurate and necessary information that is adequate and proportionate for the recipient to provide their service.

Record the reasons for your information sharing decision, irrespective of whether or not you decide to share information, so the rationale is clear.

3.2.2 Sharing information about adults

It is important to make decisions with adults about their circumstances, to share information with their informed consent or empower them to make their own decisions about information sharing. The law does not prevent the sharing of information without consent in certain circumstances such as those set out in the paragraph above ‘Sharing externally with other agencies’.

If an adult does not give their consent to sharing safeguarding information, the reasons for this should be explored. Providing reassurance and support may give them confidence to permit their information to be shared. If they do not consent to information being shared, in general, their wishes should be respected, and they should be offered advice, signposting, and further opportunities to discuss matters and share information in future. Safeguarding concerns will override confidentiality.

Consent to share information should not be sought if this will place the person at further risk, e.g. if the person is at risk from a perpetrator. If in doubt, seek advice.

The Social Care Institute for Excellence (SCIE) have produced a guide called Safeguarding Adults: Sharing Information (2019) which is available here: https://www.scie.org.uk/safeguarding/adults/practice/sharing- information

4. Mental Capacity

The Mental Capacity Act 2005 (England & Wales) provides the legal framework for making decisions on behalf of people aged over 16 years who lack the mental capacity to make decisions themselves (for example about consenting for their information to be shared). Adults are assumed to have capacity until it has been assessed that they do not.

5. Volunteer Safeguarding and Support

BRWR is committed to supporting volunteers when there have been safeguarding concerns, and we recognise that this work may be challenging. Support is important for all our volunteers, whether they are working with challenging safeguarding concerns, or whether they are impacted when dealing with media and communications and listening to traumatic stories or hostile comments from members of the public.

BRWR recognises that volunteers may experience harm or have personal experience of safeguarding concerns in their private life. Volunteers will be helped to access support mechanisms like the BRWR Befrienders’ Support group, assisting them where there may be impact upon them when volunteering, and providing signposting information. Volunteers who are themselves the subject of a safeguarding allegation will be suspended from BRWR whilst the allegation is being investigated.

5.1 Safeguarding training for designated safeguarding leads

DSLs will receive training within 6 months of their role commencing which will relate to their safeguarding responsibilities including making decisions and referrals, contributing to the multi-agency process for safeguarding children and adults and making professional challenge and escalations. This training should be refreshed and updated every two years.

5.2 Safeguarding Governance

Trustees will receive training to be able to fulfil their safeguarding governance responsibilities and know the threshold for Charity Commission serious incident reporting. This should take place for all Trustees and be updated every two years.

6. Safeguarding Procedure

6.1 Responding to Safeguarding Concerns

A person is more likely to approach someone that they trust or because they are available and supportive. It is important to be clear about our boundaries if someone tells us about abuse or neglect. The matter may need to be reported to another agency and there may be criminal or safeguarding inquiries that commence. It is often not what you are told directly but what you see that are indicators of abuse and neglect.

BRWR volunteers are not responsible for undertaking investigations into allegations of abuse. If a person speaks to a volunteer about their experience of abuse or neglect, follow the guidelines below:

DO…

Actively listen and allow the person to say what they Do not write anything at this stage.
Provide advocacy or interpreters if
Remain calm and respond with care, reassuring the person they are right to tell you/someone.
If you need to ask questions, use open questions, such as those starting ‘who,’ ‘when,’ ‘where,’ ‘how.’ Try to avoid ‘why questions’.
Ask the person what they would like to
Explain what you will do next, including that you will have to tell
Consult with our relevant DSL within 24 hours.

DON’T…

Promise confidentiality.
Push the person to tell you more than they want, get them to repeat everything or interrupt if they are talking freely.
Ask leading questions (these are questions that presume an answer).
Show strong reactions or feelings such as shock, anger, distress, or
Speculate or blame
Ask to look at injuries, especially if it entails them lifting/removing clothing.

6.2 Recording

Recording is a key task in safeguarding. Records may be used in future legal proceedings and be accessed by other parties as well as the individual concerned.

Safeguarding concerns relating to service users must be recorded on the Recording Form [Appendix 1]. It is not sufficient to document the risk solely via email or verbally.

Safeguarding records must:

be made within 24
where possible, use the person’s own words to include their perspective on the
state the date, time, place and who was
be legible, in plain language and free from Explain any acronyms or initials used.
be made only on BRWR systems (Appendices 1 & 2). Records should not be kept elsewhere or be made on personal equipment such as phones.
be accessed only by those who are
not be
additional information or corrections should be written separately.

7. Managing Safeguarding Concerns Procedure

7.1 Responsibilities

It is not our responsibility to decide is a person has been abused or to undertake enquiries into abuse, but we are responsible for responding to concerns and ensuring that they have been appropriately acted upon in a timely way in accordance with this procedure. Referrals to local authority social care or police, if deemed appropriate, must be made immediately or as soon as possible after the concern becomes known and within the day. Record the conversation and what you have seen as soon as you are no longer with that person.

For any safeguarding concerns, whether they relate to children or adults, and however small they may appear, you must speak with BRWR DSLs or Chairperson if DSLs are not available.

*Responding to an Emergency*

In an emergency where someone is seriously hurt, is at immediate risk of abuse, is in danger or a criminal offence has occurred or is occurring, you should ring 999 and ask for the emergency service required. Alert the DSLs or Chairperson as soon as possible. Record all actions.

*Responding to a concern of Female Genital Mutilation (FGM)*

There is a legal requirement on all individuals who have a concern that a service user is a victim of FGM or is at risk of FGM, to report this directly to police immediately. Failure to do so is a criminal offence.

The procedures set out below in the paragraph ‘Responding to a safeguarding concern about a child or adult’ must then be followed.

7.2 Responding to Safeguarding Concerns about a Child or Adult

For all safeguarding concerns, follow these steps:

speak to the DSL about your This should be done as soon as possible and on the same day that you identify the concern.
record all relevant details on the BRWR Safeguarding Recording Form within 24 hours. All subsequent actions and decisions must be recorded on an ongoing basis.
The DSL will make decisions about the next steps, based on known information and after seeking any advice as needed from others, including from social care. If there is disagreement about the decision making between the DSL and the volunteer, this should be explored and discussed between them, seeking advice as needed. In any event anyone can make a referral to social care independently if they consider it to be necessary, but the steps below should be followed.
Any of these decisions may be made by the DSLs:
- There are no safeguarding concerns and therefore no safeguarding action to The situation may be monitored if this is thought necessary.
- The threshold has not been met to refer to the local authority, however the service user has needs which may be met by BRWR, or by signposting or referring to other sources of help, with the consent of the service user.
- A safeguarding referral is made to local authority social care because there is reasonable cause to suspect that the person has experienced or is at risk of abuse or neglect or there are serious concerns about their Referrals should be made to the social care department for the area where the service user is living. If this is not known, then the referral should be made to the local authority where the incident has occurred. Outside of office hours and if an urgent referral is required, the local authority’s Out of Hours or Emergency Duty Team should be contacted – Appendix 3.

Information sharing with other agencies should be in line with the principles set out in this policy and procedure.

The referral must be made immediately using the multi-agency procedures of the local authority area, and telephone reports must be followed up in writing within 24 hours. The DSL must be assured that the referral has been received by the local authority. Appendix 3 lists the national and local contacts of local authority social care departments for adults and children. Social Care departments should acknowledge within one working day that the referral has been received. If there has been no acknowledgement in three working days, the DSL must ensure this is followed up with social care.

Following the referral, the DSL may need to provide reports or attend meetings, contributing to and assisting with safeguarding enquiries in line with the multi-agency procedures.

If the person (adult or child) already has a local authority social worker allocated to them, that social worker should be contacted about the safeguarding concern. This may be done verbally but must always be followed up in writing within 24 hours. If the concern is of an urgent nature, and the allocated social worker is not available, contact their Line Manager, or the Local Authority central contact number.

8. Managing Allegations against BRWR volunteers

We have a duty to report safeguarding concerns and must not ignore concerns about a colleague who may be causing harm to a child or an adult, whether this is occurring in our organisation, in the community or in their private life.

A volunteer should self-report to their DSL if they have been involved in a matter which may have implications for their work with BRWR. Volunteers must contact the DSLs if they have any concerns about a colleague, or have been told about concerns relating to another volunteer.

8.1 What is an Allegation against a volunteer?

An Allegation refers to behaviour, actions and conduct which indicate that the volunteer may have harmed /pose a risk of harm / are unsuitable to work with adults with vulnerabilities and children where the volunteer is in a position of trust, in accordance with statutory safeguarding guidance including Working Together to Safeguard Children 2018 and Keeping Children Safe in Education.

A volunteer should self-report to BRWR’s DSLs or Chairperson if they have been involved in a matter which may have implications for their work at BRWR, for example if they have been arrested or cautioned by police or are subject to safeguarding enquiries by police or social care, or if they have accessed illegal material from banned or criminal organisations. These examples are illustrative, and volunteers should advise BRWR if they have any concerns that may affect their work with service users.

It is important that all allegations and concerns are taken seriously and are not ignored or downplayed. They should be properly addressed in line with this procedure and outcomes recorded.

8.2 Responding to a safeguarding concern about a volunteer

If anyone needs immediate emergency support, call 999 straight away.

Where there are safeguarding concerns about a volunteer, follow the steps below.

Please remember to treat these matters as highly confidential.

If you have a concern that appears to meet any of the above thresholds speak in confidence to DSL / Chairperson within 24 hours.

If the concern relates to DSL / Chairperson, please consult the Vice-Chair of Trustees.
The DSL will consult the Local Authority Designated Officer (LADO). The LADO will provide further guidance.
Never notify the subject of the allegation that you intend to / that you have reported the allegation.
Record details on the Managing Allegations Against Volunteers Form (Appendix 2).

8.3 Enquiries by LADO

The LADO is a local authority representative responsible for managing and monitoring safeguarding allegations about paid and unpaid staff who work with children and will provide advice, information, and guidance to employers about safeguarding allegations.

There is no statutory LADO equivalent for adults, although some Local Authorities do have an Adults LADO, so adult social care safeguarding should be contacted instead.

8.4 Referral to DBS

BRWR has a duty to refer to DBS any person engaged to work in regulated activity where the allegation has been substantiated and where we have withdrawn permission for them to work in regulated activity. The duty remains even where we would have taken this action, but the person was re-deployed, dismissed, resigned, retired, or left. Failure to report to DBS in these circumstances is an offence.

9. Safeguarding and Digital Information

There may be safeguarding implications in relation to the use of digital information by BRWR.

Please refer to BRWR’s Publicity Policy for guidance.