Springtide Scotland

Safeguarding Policy

Jonathan Lovett, owner of Springtide Scotland commits to the following principle when carrying out his work as a counsellor and psychotherapist and as the named person for safeguarding at Springtide Scotland.

‘In exceptional circumstances, the need to safeguard our clients or others from serious harm may require us to override our commitment to making our client’s wishes and confidentiality our primary concern.’ BACP Ethical Framework , 10.

Statement of Purpose

Springtide Scotland is committed to preventing and responding to risks of harm to, and promoting the welfare of all children and adults at risk that we work with, including people outwith the client relationship we are informed about. These individuals are referred to as the ‘Beneficiaries’ of this Safeguarding Policy.

We recognise the importance of this commitment to safety and welfare. Furthermore we are committed to safeguarding all Beneficiaries without discrimination due to an individual’s age, disability, race, religion or belief, sex, gender reassignment, pregnancy or maternity leave status, marriage or civil partnership status, or sexual orientation.

This Safeguarding Policy is based on the safeguarding laws of England, Wales, and Scotland, including related guidance issued by the UK Government and relevant governmental departments, agencies, and public bodies. If this Policy is at any time inconsistent with this body of law, Springtide Scotland will act to meet the requirements of up-to-date safeguarding laws in priority to the requirements set out in this Policy.

Springtide Scotland has implemented this Safeguarding Policy in order to meet its obligations as an organisation working with children and adults at risk.

Any questions in relation to this Policy should be referred to Jonathan Lovett in the first instance by emailing jonny@springtidescotland.com.

Scope of this Safeguarding Policy

This Policy explains key aspects of how Springtide Scotland prevents harm in relation to its Beneficiaries via its practices and its operators, staff, contractors and associates conduct hereby known collectively for the purposes of this policy as ‘Staff and / or Associates’.

This Safeguarding Policy covers the organisation and operation of all of Springtide Scotland’s activities involving children and adults at risk, our relevant activities are primarily individual Counselling and Psychotherapy as well as Family Therapy.

This Policy’s guidelines and obligations apply to all individuals working for or acting on behalf of Springtide Scotland in the UK at all levels, including but not limited to contractors, associate counsellors, officers, and employees.

This Policy does not form part of any contract of employment or similar and Springtide Scotland may amend it at any time at our absolute discretion.

Defining Safeguarding

‘Safeguarding’ is an umbrella term that refers to work (e.g. practices and procedures) aimed at preventing or responding to harm or risks of harm posed to vulnerable individuals, and at promoting these individuals’ wider welfare. Safeguarding is particularly important for children and adults at risk. Most safeguarding legal obligations relate to the care of these groups and these are the groups to whom the protections set out in this Policy apply. For safeguarding purposes:

  1. Children are individuals younger than 18 years old (England and Wales), under 16 years old (Scotland).
  2. Adults at risk are individuals 18 years old or over (in England and Wales) or 16 years old or over (in Scotland) who have care and/or support needs and who are, because of these needs, unable to protect themselves from harm (e.g. due to illness or disability). This need not be on a permanent basis.

The commitments and practices contained in this Safeguarding Policy apply to the safeguarding of Springtide Scotland’s Beneficiaries from harm caused by either:

  1. The activities and practices of Springtide Scotland and any conduct of its Staff and Associates, or
  2. People and situations outside of Springtide Scotland’s and its Staff and Associates’ control, where Springtide Scotland’s Staff and Associates are aware of, ought to be aware of, or reasonably suspect the risks posed by a situation.

For the purposes of this Policy, a ‘Safeguarding Concern’ is any conduct or situation that is known or reasonably suspected by a Staff Member or another party that risks violating the safeguarding commitments set out above.

Key Measures that Springtide Scotland is Committed to Implementing and Maintaining to Safeguard its Beneficiaries

Ensuring that Staff and Associates are trained to, and encouraged to, report any Safeguarding Concerns that they identify. Staff and Associates will be encouraged to follow Springtide Scotland’s safeguarding reporting procedures as closely as possible when reporting concerns (set out below under the heading ‘Procedures: Reporting’).

Ensuring that all Staff and Associates listen to all safeguarding-related queries and concerns raised by other Staff and Associates, Beneficiaries, or relevant other parties, with respect and professionalism. Staff and Associates should be trained how to, and encouraged to, then assist with reporting any such concerns via Springtide Scotland’s regular reporting procedures.

Ensuring that all reported Safeguarding Concerns are dealt with by appropriate individuals and teams and in accordance with Springtide Scotland’s relevant procedures (set out below under the heading ‘Procedures: Investigation and Response’).

Implementing and maintaining comprehensive, accessible, fair, and efficient procedures for Staff and Associates to use when reporting and dealing with Safeguarding Concerns. These procedures will be made known and easily accessible to all Staff and Associates.

  1. Procedures will be designed to ensure all safeguarding issues are dealt with fairly and objectively even when allegations are made against one of Springtide Scotland’s Staff and Associates. Any such allegations will be treated in a manner that takes into account the gravity of the accusations, but which does not vilify or presume the guilt of an accused individual without a fair investigation.
  2. Any reports that qualify as protected disclosures under whistleblowing law will be treated securely and in a protected manner in line with whistleblowing law.
  3. Appointing Jonathan Lovett to hold responsibility for managing safeguarding policies and procedures within Springtide Scotland.

Following appropriate recruitment processes when recruiting new Staff and Associates, including volunteers. This includes:

  1. Conducting all appropriate pre-employment checks (e.g. Disclosure and Barring Service (DBS) criminal record checks, PVG checks in Scotland).
  2. Ensuring new Staff and Associates take part in, and understand the content of, all necessary safeguarding training before having any contact with Springtide Scotland’s Beneficiaries.
  3. Following Springtide Scotland’s policies and procedures on hiring and recruitment.

Providing appropriate safeguarding training for all relevant Staff and Associates. Every Staff and Associate should be provided with, and required to undertake, training that is appropriate to their role, responsibilities, and degree and type of contact with Beneficiaries. This should, where appropriate, include training on:

  1. How to define and identify potential signs of different types of abuse, including physical abuse, emotional abuse, sexual abuse and exploitation, neglect, and others.
  2. How to listen to and respond to concerns or disclosures about safeguarding issues during an initial conversation (e.g. how to explain when information can and cannot be kept confidential).
  3. How to use Springtide Scotland’s safeguarding reporting procedures and when doing so is appropriate.
  4. Which additional resources (e.g. policies, other supporting documents, or external educational resources) are available to ensure Staff and Associates remain informed about safeguarding.
  5. Child Protection and Adult Protection.

Ensuring that all information related to Safeguarding Concerns, including the content of reported concerns as well as the personal data of anybody involved, is handled safely and securely. This involves:

  1. Following the requirements set out by the UK’s data protection laws, including The UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
  2. Following Springtide Scotland’s data protection privacy policies and procedures.
    Providing Staff and Associates with training on data protection and privacy, where appropriate.
  3. Ensuring Staff and Associates always have an identifiable point of contact for questions or concerns about data protection and privacy. This is currently Jonathan Lovett, who can be contacted by emailing jonny@springtidescotland.com.
  4. Only sharing information about a Safeguarding Concern internally as far as is necessary to manage the concern for the relevant Beneficiary’s benefit.

Ensuring transparency and awareness regarding safeguarding information and procedures. For example, by:

  1. Providing information to Beneficiaries about our safeguarding procedures so that they are aware of how to raise any concerns.
  2. Ensuring all Staff and Associates are aware of safeguarding laws, Springtide Scotland’s safeguarding commitments and procedures, and Staff and Associates’ responsibilities in relation to these.

Regularly reviewing all safeguarding policies and procedures to ensure that they are up-to-date with safeguarding law and that they remain suitable for Springtide Scotland’s Relevant Activities and workforce, and meeting any review and evaluation requirements specific to Springtide Scotland’s industry and organisation type.

Staff and Associates Responsibilities

All Staff and Associates have a responsibility to promote the safety and wellbeing of all of Springtide Scotland’s Beneficiaries. This means that all of Springtide Scotland’s policies and procedures relevant to safeguarding and all UK laws relevant to safeguarding must be followed at all times. Specifically:

All Staff and Associates must contribute to upholding the key measures that Springtide Scotland has committed to taking to safeguard its Beneficiaries (set out above) to an extent that is appropriate for their role, responsibilities, and degree and type of contact with Beneficiaries. Specific ways that Staff and Associates should do this will be clarified during training. If a Staff Member is uncertain as to their responsibilities, it is their responsibility to raise this with Jonathan Lovett.

Staff and Associates must actively participate in all safeguarding training they are assigned and, if they do not understand any aspects of their training, must raise this with Jonathan Lovett.

Staff and Associates must never do anything to actively risk the safety or wellbeing of any of Springtide Scotland’s Beneficiaries. This includes, but is not limited to:

  1. Subjecting them to or facilitating abuse of any sort.
  2. Engaging in any sexual activity with children or adult clients of Springtide Scotland and Beneficiaries.
  3. Participating in or facilitating any activities that may commercially exploit Beneficiaries. For example, failing to report suspected child labour or trafficking.

Staff and Associates must report all Safeguarding Concerns that they have regarding Beneficiaries, regardless of whether the concerns relate to potential wrongdoing of other Staff and Associates, other Beneficiaries, or external parties (e.g. parents, teachers, other organisations, or members of the public).

Procedures: Reporting

Staff and Associates will receive safeguarding training that should enable them to identify Safeguarding Concerns (e.g. suspected abuse, neglect, or threats to wellbeing) relevant to Springtide Scotland’s Beneficiaries.

If a Staff and Associate identifies a Safeguarding Concern, to report it they should:

  1. When working in school, for EAP providers or any other agency that Springtide Scotland contracts counselling services to, apply local procedures by reporting to the named safeguarding officer in that organisation and follow organisational policies as instructed.
  2. When working in private practice to use discretion depending on the circumstances and to either report to clients GP, local relevant social work services or the police.

If a Staff or Associate feels unable to follow the above steps, they should report their Safeguarding Concern in a reasonable alternative manner. This may the case if, for example:

  1. Following the above procedure would require disclosing the concern to somebody who is implicated in the Safeguarding Concern or who the Staff or Associate is otherwise uncomfortable contacting about this concern, or
  2. The matter is time sensitive and involves a risk of serious harm to somebody, in which case contacting an external agency (e.g. the police, the ambulance service, or a mental health crisis line) or a more senior member of Springtide Scotland’s staff first may be more appropriate.

Procedures: Investigating and Response

Reported Safeguarding Concerns will be dealt with promptly according to the following process:

  1. Information will be assessed for risk to children or vulnerable adults.
  2. Risk will be determined as high, medium or low.
  3. High risk will be subject to immediate reporting to the named safeguarding officer (in agency), police, GP or social work (in private practice).
  4. Medium risk will be immediately taken to a supervisor consultation for consideration.
  5. Low risk will be monitored and taken to supervision at the next scheduled meeting.

Staff and Associates who report a Safeguarding Concern will be kept informed about the progression of the matter they reported to an appropriate degree. Note that, depending on the nature of the concern and consequent investigations, some information about matters may be kept confidential and not shared with the reporter.

If a Staff or Associate is found to be in breach of this Safeguarding Policy or safeguarding law in general, they will be treated fairly and will only be dismissed if appropriate in the circumstances and in accordance with employment law.

Referrals or notifications to external organisations (e.g. police services, local authorities, or regulatory bodies) will be made when, and only when, this is appropriate, and will always be made in accordance with the law (e.g. data protection law).

Supporting Documents and Other Protections

Springtide Scotland has other documents in place that support this Safeguarding Policy. These include:

  1. Safeguarding Risk Assessment.
  2. Client Contract.

All of the policies, procedures, and other documents set out above are available on request from the named person, Jonathan Lovett.