The BBHQ Safeguarding Manager is responsible for the day-to-day management of all reported safeguarding concerns or allegations on behalf of the organisation. They are supported in their role by the Director of Operations, the BB Safeguarding Panel and in ROI, the Regional Safeguarding Panel. There are some specific responsibilities that must be undertaken when the safeguarding concern or allegation is about a leader.
Initial Action
On receipt of a report (which may be by phone initially and followed up in writing), the BBHQ Safeguarding Manager will conduct a review of the information and will consider if there is any immediate action required to safeguard anyone. This will be prioritised and may include contact with Emergency Services. The information will then be further assessed. The person reporting will be advised of any further action they may need to take. This may include:
A record of the safeguarding concern or allegation will be created on the BB Safeguarding Case Management System. The BBHQ Safeguarding Manager will make decisions about action required, taking account of any relevant statutory guidance. Consideration will also be given to any support required for any child or young person concerned, any adult involved, and the person raising the concern.
Safeguarding concerns and allegations are confidential. Information should not be shared further with anyone else unless the reporting person is advised to by the BBHQ Safeguarding Manager.
If, after initial assessment, the BBHQ Safeguarding Manager does not consider the matter constitutes a safeguarding allegation or concern, they will consult with the Director of Operations and consider the most appropriate course of action. This could be:
When a Leader is concerned that a safeguarding concern or allegation about another Leader has not been followed up properly, they should discuss their concerns in the first instance with the BBHQ Safeguarding Manager. If they still have concerns, they should put them in writing to the Director of Operations, who will review the circumstances. When a Leader remains worried that a safeguarding concern is still not being responded to appropriately, the BB whistleblowing policy outlines what other action can be taken. (Link to Whistleblowing Policy when this is complete)
The person reporting should discuss their concerns initially with the BBHQ Safeguarding Manager or the Director of Operations, and the circumstances will be reviewed.
If the reporting person remains worried that a safeguarding concern or allegation about a Leader is still not being responded to appropriately, and they believe a child remains at risk of harm or abuse, they can report their concerns to:
Leaders are appointed/affirmed by and operate in the name of the Church, the Company is partnered with. Many leaders have additional roles and responsibilities within the Church. On receipt of a report, after the initial assessment, the BBHQ Safeguarding Manager will inform the relevant employed Denomination Safeguarding Lead.
Information will be promptly shared. Initial action is agreed upon via a joint case-planning discussion or meeting. This may include:
There may also be circumstances where concerns or complaints have arisen about a leader’s behaviour, and action is necessary to prevent this from developing into a safeguarding concern. Where the leader has additional responsibilities in the Church, there may be a joint approach with the Denomination Safeguarding Lead. Together, the BBHQ Safeguarding Manager and the relevant Denomination Safeguarding Lead can agree how the concerns will be addressed, who is responsible for them, and where appropriate, whether there is a need for any training or other development/mentoring.
Of note – There are circumstances when either the Police or Child Protection services request that information is not shared, or only limited details are provided to the Denomination Safeguarding Lead. When this occurs, it will be documented within the BB Case management record.
Where it is alleged that a leader has:
The BBHQ Safeguarding Manager MUST consult with the relevant Local Authority Children’s Services and make a referral, ordinarily within 24 hours. In ROI, a referral will be made to the Tusla Child and Family agency.
In most circumstances, the leader will be informed by the BBHQ Safeguarding manager when a safeguarding concern or allegation has arisen. There are occasions, however, when either the Police or Child Protection services request that they are not informed initially, or that only limited information is provided.
The Boys’ Brigade is required to manage any risk from the leader, subject to the safeguarding concern or allegation, and the priority is always to protect children and young people. A leader may be suspended throughout the investigation process. This is a neutral position to protect all involved.
In England and Wales, there is a multi-agency process to manage allegations and concerns about adults in a position of trust. In England, they are normally referred to as the Designated Officer (DO) or Local Authority Designated Officer (LADO). A meeting will normally be held, which can include Police, Children’s Social Care, BBHQ Safeguarding Manager, Church or Denomination Safeguarding Lead, and any other relevant agency or organisation. The leader concerned will not be invited and may be unaware that a concern has arisen about them. Information will be shared, and a decision will be made as to whether an investigation will be undertaken, and by whom. The meeting will also consider whether there are any other children who may be at risk, including the children of, or any residing with, the leader. If the leader is unaware at this point, decisions will be made about who will inform them and the information that will be given. Review meetings will be held during the investigation to share relevant updates, consider any changes in circumstances, and agree on any action required.
At the conclusion of the investigation, there should be a final review meeting to determine the outcome of the concern or allegation made, as follows:
The concerns will be investigated. Depending on the nature and seriousness, this could be a criminal investigation by the Police, and/or a child protection enquiry by Children’s Social Care, or an internal investigation by the BBHQ Safeguarding Manager. The responsible person will gather information about the safeguarding concern or allegation. This may include, but is not limited to:
Investigations should be proportionate. Where sufficient information is gathered, it may not be necessary to contact every individual who has information about the safeguarding concern or allegation. Leaders should not discuss the investigation amongst themselves, with other adults or young people and should not ask anyone else what they know. This will avoid undermining any ongoing enquiries and accounts being contaminated.
There may be circumstances where both a BB internal investigation is required as well as the police investigation and/or Child Protection Enquiry by Children’s Social Care. The BB internal investigation may be delayed, awaiting the conclusion of enquiries by the statutory agencies to ensure statutory agency processes are not hampered in any way.
Any individual who is the subject of a safeguarding concern or allegation, or complaint where they could present a risk to BB members, may be suspended by The Boys’ Brigade’s Chief Executive, or a person appointed on their behalf. The BBHQ Safeguarding Manager and members of the Senior Management Team have been appointed to undertake this task in circumstances where the Chief Executive is unavailable. Suspension may also occur during re-registration when vetting and barring checks are completed if there is a previously unknown or new blemish. A suspension may occur as an investigation begins or during an investigation.
Ordinarily, the BB Safeguarding Manager will notify a leader of their suspension in a telephone call.
A record of the suspension will be made in the confidential safeguarding area of OBM. The leader will receive written communication from the CEO outlining the reasons for the suspension and what it means.
Suspension is a neutral position, not a sanction. As a youth organisation, we must prioritise the safety and well-being of Young People within the organisation. We also need to consider the well-being of other leaders and any reputational risk.
Whilst suspended, a leader must not:
If a suspended leader’s children attend BB, advice should be sought from the BBHQ Safeguarding Manager to ensure they can continue to attend whilst any risk in relation to the individual can be managed. It may also be necessary to amend the suspension to allow the leader to attend a particular event in their capacity as the parent of a child or young person member.
Captains are not authorised to formally suspend a leader. However, there may be immediate or exceptional circumstances where a Captain needs to inform a leader that they cannot attend a session or a particular event, or that they need to immediately leave a session/event. The Captain MUST then inform the BBHQ Safeguarding Manager ASAP so that the appropriate procedures and relevant statutory guidance can be followed. Aside from in the Republic of Ireland, the Church appoints/affirms all BB leaders. Ordinarily, the Church or Denomination Safeguarding lead will be advised of a leader’s suspension. Churches are also able to suspend leaders from their role. Normally, this is done following consultation with the BBHQ Safeguarding Manager or Director for Operations
Confidentialtiy
Safeguarding information is confidential and needs to be managed carefully. It should only be shared on a need-to-know basis. Captains (and/or Leaders-in-Charge in their absence) will always be informed when a leader has been suspended, but depending on the circumstances, they might not know why. When a criminal investigation is ongoing, statutory agencies may direct what can and cannot be shared. There is nothing to prevent a suspended leader from informing people that they have been suspended. Captains should seek advice from the BBHQ Safeguarding Manager if queries arise locally from parents or other leaders. When a leader has been suspended, the BBHQ Safeguarding Manager will take responsibility for informing the relevant person(s) from the Denomination, Battalion, or Region.
When a leader resigns linked to a safeguarding concern or allegation about them, the investigation will continue. In most circumstances, the resignation will be “pended” until the conclusion of any statutory agency or BB internal investigation.
In some limited circumstances, the resignation will be accepted, but only when there is sufficient information available to be satisfied that the leader would have had their membership withdrawn had they not resigned. This ensures The Boys’ Brigade is able to comply with their responsibilities regarding vetting and barring referrals.
It is recognised that facing a safeguarding concern or allegation can be a stressful and difficult experience, especially when the leader is suspended. The BBHQ Safeguarding manager or Director of Operations will discuss support needs with the leader concerned.
Where possible, support will be accessed locally. Pastoral support may be provided by the Church the Company is partnered with. Where appropriate, the BBHQ Safeguarding Manager will provide information about National Organisations. The BBHQ Safeguarding Manager will keep the leader updated with case progression unless statutory agencies take responsibility for this.
Although police and Children’s Social Care work closely when conducting enquiries, they have different roles, thresholds for action and outcomes. The Prosecuting Authorities for criminal matters must be satisfied that there is a realistic prospect of a criminal conviction, and it is in the public interest to take a case to court. The Judge and/or Jury must then be satisfied beyond a reasonable doubt that a person has committed an alleged offence to convict them.
Children’s Social Care assess and decides whether it is more likely than not that a child has suffered or is at risk of suffering harm because of a person’s action or inaction. This is sometimes referred to as “on balance”.
Therefore, it is possible to be deemed a risk to work with children and young people without a criminal conviction, and in circumstances where statutory agencies are taking no further action.
After the statutory agency and/ or BB internal investigation has concluded, the BB Risk Assessment process will be undertaken to determine an appropriate outcome regarding the Leaders role and membership.
At the conclusion of the statutory agency or BB internal investigation, the Leader will be invited to participate in a risk assessment process. This process considers information that has been gathered and may involve obtaining additional or further accounts from the leader concerned and others who may hold relevant information. This could include young People members, their parents, and other leaders. Statutory Agencies ordinarily do not share the actual accounts/statements/interviews that have been obtained during their investigation. The leader may also be required to have a vetting and barring update.
Members of the Safeguarding Panel will meet with the leader concerned either virtually or face to face. The leader will have the opportunity to explain what has happened from their perspective. They may also be asked about their history in the BB, the training and development they have received, their understanding of the responsibilities for their role and anything else that is deemed relevant. A Risk Assessment report will be prepared, which will include findings, analysis, management of risk, assessment of future risks and recommendations. The assessment of risk is made on the balance of probabilities and considers whether there is a risk, within or outside of the organisation, to:
The Safeguarding panel will consider whether the allegation or concern is substantiated, unsubstantiated, unfounded, malicious, or false. This may already be pre-determined if there has been a Statutory Agency outcome.
The risk assessment report will be considered by the wider Safeguarding panel members, who will determine whether the leader will be reinstated to their role or their membership will be withdrawn. Where a leader is reinstated, there may be additional requirements made, including further training and development, mentoring and a review period. Direct supervision of a leader to mitigate any risk is not considered to be a suitable outcome.
The above procedures relate to a “Full Risk Assessment Process”. Where safeguarding concerns or allegations relate to less serious or low-level matters, a micro risk assessment can be conducted. It is difficult to be prescriptive as to the circumstances where this will apply. The BBHQ Safeguarding Manager will have a case discussion with the Director of Operations and/or Chair of the Safeguarding Panel. The decision will be documented.
The current process for a Micro risk assessment is as follows.
All available information will be gathered by the BBHQ Safeguarding Manager. This may, but not always, involve a meeting with the leader concerned. A report will be prepared, outlining any risks, mitigations, and recommendations. The report will be shared with at least one member of the BB Safeguarding panel, and a case discussion meeting will be held. If the recommendations are agreed with, the Micro Risk Assessment process will conclude. Where agreement cannot be reached, the report will be shared with all members of the BB safeguarding panel.
Where more than one leader has been subject to an investigation linked to the same incident, there may be different outcomes for each of them. This allows for a fair process that takes account of any relevant history, training, role, previous concerns and the specific involvement of each individual.
Where a leader’s registration has been withdrawn, the leader may appeal against the decision. The notice of appeal must be made in writing, within 28 days and addressed to
Chair of the Safeguarding Appeals Panel
The Boys’ Brigade
Adeyfield Free Church
Hemel Hempstead
Herts
HP2 4GZ
An appeal will not be considered simply on the basis that an individual disagrees with a decision made by the BBHQ Safeguarding Panel. A request for an appeal must provide all relevant details, including any new evidence. The withdrawal of membership will remain in place during the appeal process.
An appeal will only be considered if one of the following applies:
If the grounds for appeal have not been met, the individual will be informed in writing. If the Chair of the Safeguarding Appeals Panel accepts that the grounds to appeal have been met, they will convene a meeting of the Appeals Panel to determine the next steps and anticipated timescale. The Safeguarding Appeals Panel will review the investigation and any new evidence submitted. They may choose to gather and/or review new information. The panel may determine the appeal based on written submissions only and/or by holding a hearing, which can be face-to-face or virtual.
Appeal Outcome
The Safeguarding Appeals Panel can either:
Where the Safeguarding Panel have been asked to review their decision, they will liaise with the Safeguarding Appeals panel to ensure their guidance has been fully considered in reaching the final appeals decision.
The individual will be notified of the outcome in writing.
The appeals outcome is final and marks the end of the appeal process. The Chair of the Safeguarding Appeals Panel must inform the BBHQ Safeguarding Manager, Chair of the BB Safeguarding Panel and Director of Operations if the appeal identifies any systemic issues related to The Boys’ Brigade Safeguarding Procedures and Investigation Processes.
When a leader has their membership withdrawn because of a safeguarding concern or allegation, The Boys’ Brigade must consider making a referral to the relevant disclosure and barring authority. There is a legal duty to make a referral when certain conditions or criteria are met regarding harm or likelihood of harm to children and young people, and other related conduct. Whilst the principles are similar, each authority has different requirements.
OF NOTE: When a leader would or might have had their membership withdrawn, but left before they could be, a referral must still be made.
Safeguarding information is confidential and needs to be managed carefully. It should only be shared on a need-to-know basis. Captains (and/or Leaders-in-Charge in their absence) will ordinarily be informed when a leader is the subject of a safeguarding concern or allegation.
Depending on the circumstances, they might not know why. When a criminal investigation is ongoing, statutory agencies may direct what can and cannot be shared. There is nothing to prevent a leader, who is the subject of an investigation talking about their circumstances, though they should be mindful of any actions that could undermine the investigation process, cause anyone involved to feel intimidated, or lead to any imposed bail conditions being breached.
Captains should seek advice from the BBHQ Safeguarding Manager if queries arise locally from parents or other leaders.
There may be circumstances where it is appropriate to inform others (internally and externally) that a leader is the subject of an investigation, that they have been suspended, or that there has been a BB Risk assessment Process and what the outcome was. This will be considered on a case-by-case basis by the BBHQ Safeguarding Manager, in consultation with Statutory Agencies when necessary. The reason for sharing will be documented, and where appropriate, the suspended leader will be notified.
Those informed could include the child or young person concerned, their parent(s), and any person directly involved in the investigation. In addition, other BB staff members, or specific volunteers linked to their roles, may need to be made aware. The information they are provided with is likely to be minimal unless there is a necessity to provide additional details.
It is not unusual for reports to appear in the Media when a leader/ or former leader is convicted of offences against children, particularly if they have occurred linked to their role.
Where leaders or staff members are made aware of any media interest in relation to Safeguarding cases, they should report this immediately to the BBHQ Safeguarding Manager and/or the Director of Operations. They will consider together whether parents and leaders locally need to be provided with any information. This will be done in consultation with the police.
If approached directly by any media personnel, leaders should not provide information themselves about any Safeguarding Concerns or allegations.
