Riverside

The Riverside Group Safeguarding Children Policy
February 2023

1.1 Safeguarding and promoting the welfare of children is defined as:

• Protecting children from maltreatment and neglect,
• Preventing impairment of children’s health or development,
• Ensuring that children grow up in circumstances consistent with the provision of safe and effective care,
• Taking action to enable all children to have the best life chances and outcomes.^[1]

1.2 All children, without exception, have the right to protection from abuse and neglect regardless of gender, ethnicity, disability, sexuality or beliefs. Safeguarding children and the action we take to promote the welfare of children and protect them from harm is everyone’s responsibility.

1.3 Riverside’s staff have a key safeguarding role to play, alongside colleagues in social care, health and the police, in promoting the welfare of children and young people and in protecting them from harm. We are committed to protecting the right of children to live in safety and be free from abuse or neglect. The purpose of this Policy is to set out Riverside’s approach to safeguarding children, preventing abuse and responding to concerns or allegations of abuse where these arise.

2.1 This policy applies to all colleagues working within The Riverside Group and all its subsidiaries, including One Housing, with the exception of Riverside Scotland which has a separate policy. This includes those working in both a paid and voluntary capacity, members of the governance community and those working for Riverside as a contractor or sub-contractor. This policy also applies to customers of Riverside and members of the public who may have concerns regarding a child which fall under the remit of this policy.

2.2 This policy covers the safeguarding of children. For the purposes of this Policy a child is anyone who has not yet reached their 18^th birthday. All instances of suspected or actual abuse towards children will be managed in accordance with this policy and associated procedure(s). There is a separate policy and associated procedure(s) which relates to safeguarding adults.

2.3 All associated policies and procedures are available:

• Riverside – on the Riverside Information Centre (RIC),
• One Housing – SharePoint.

Raising Awareness

3.1 Abuse can take place in many forms, including physical abuse, sexual abuse, emotional abuse, neglect and domestic violence – please see ‘Definitions’ for further information on types of abuse or harm. Raising awareness is a key part of our approach to preventing abuse and neglect from occurring. Riverside utilise a range of approaches to raise awareness, amongst colleagues and customers, with regards to safeguarding children and action they should take if they have concerns. This includes awareness campaigns and communications through various channels, training and cascading good practice.

Prevention

3.2 Riverside encourage vigilance from all colleagues with regards to recognising the signs of abuse, particularly in services and households where domestic abuse, mental health problems or substance misuse are apparent.

3.3 We will deal with applications for housing and/or support from sex offenders in accordance with an agreed procedure which seeks to balance their rights as an individual against the risk they may pose to the community.

3.4 Riverside ensure that all colleagues working directly with children are given appropriate guidance on their behaviour to protect themselves from allegations and how to respond in the event of a concern.

Safe Recruitment and Selection

3.5 Riverside is committed to safe recruitment and employment practice. We have comprehensive recruitment and selection procedures in place. These procedures cover employees, contractors, sub-contractors, and volunteers who come into contact with children and include requirements around relevant qualifications and experience, receiving satisfactory references and Disclosure & Barring Service (DBS) checks.

Safe Working

3.6 Riverside expects all colleagues to abide by the Code of Conduct and Group Safeguarding Children Procedure(s) when working with or coming into contact with children.

3.7 When entering a formal arrangement with an external contractor, sub-contractor or managed agent to provide services to our customers, Riverside will ensure that those agents have in place their own policies and procedures for the support and safeguarding of children. These policies and procedures should be in line with legislative requirements and regularly reviewed.

Training

3.8 Robust mandatory training on safeguarding children is provided to teams to ensure that colleagues are aware of indicators of abuse or neglect and how to raise and respond to safeguarding concerns. Training is provided through a mixture of e-Learning and tutor led sessions and is based around the competencies required for each role. Most Local Authority Safeguarding Children Partnerships run Safeguarding Children Training which is delivered locally and can often be accessed free of charge. The completion of mandatory safeguarding training is regularly monitored.

3.9 All Riverside colleagues working with children will be trained to:

• Recognise the signs of abuse and behaviours which should give cause for concern.
  • Where appropriate, assess the risk of abuse to children that we work with and ensure measures are in place to minimise this as part of assessment and support planning.
  • Respond to abuse in accordance with this policy and the relevant Safeguarding Children Procedure.
  • Refer cases of abuse to Safeguarding teams in line with Local Authority reporting processes.

3.10 Riverside will provide appropriate supervision and support for all colleagues ensuring they are aware of the procedures and the delivery of Safeguarding training.

Empowerment

3.11 We will foster a culture of listening to children and taking account of their wishes and feelings, both in individual decisions and the development of services.

3.12 We will value and respect children as individuals, regardless of their gender, ethnicity, disability or sexual identity.

3.13 We use a child centred approach: for a service to be effective they should be based on a clear understanding of the needs and views of children and young people.

Environment

3.14 We ensure that there are robust policies and procedure in place relating to health and safety to ensure that we provide safe physical environments for children and young people.

3.15 We will ensure that all reasonable precautions are put in place to minimise the particular risks that children might face when living in or visiting our services.

3.16 We are mindful of the accommodation needs of young people, who may be vulnerable and lack support, ensuring that they are signposted to appropriate advice and support.

Whistleblowing

3.17 Riverside promotes an open culture in which colleagues are encouraged to raise concerns relating to the safety of children that they interact with. We have a robust Whistleblowing Policy in place for colleagues to use if they suspect that a child is being abused by a Riverside colleague, where there is a failure to respond appropriately to allegations of abuse, or where staff have concerns that a colleague or superior is responsible for the abuse. There are clear lines of reporting for whistleblowing concerns, including routes to use if colleagues feel unable to report directly to their line manager or if they are concerned that appropriate action has not been taken in relation to a concern already raised.

Prevent

3.18 The Government Prevent programme highlights that some people may be vulnerable to radicalisation and involvement in terrorism. Prevent is the Government’s strategy to stop people becoming terrorists or supporting terrorism, in all its forms. Prevent works with individuals and communities by using voluntary early intervention to encourage them to challenge extremist and terrorist ideology and behaviour.

3.19 Riverside recognises that it supports children who may be at risk of radicalisation. We believe that community engagement is essential, and we will work closely with local voluntary and community groups as well as Local Authorities and the Police to engage with and co-deliver support to customers who might be at risk of radicalisation.

Partnership Working

3.20 Safeguarding children and young people – the action we take to promote the welfare of children and protect them from harm – is everyone’s responsibility. Everyone who interacts with children and families should work together and has a role to play. Providing a child will not be put at further risk, where possible Riverside colleagues will discuss concerns with the child’s family to gain consent to make referrals.

3.21 We will work actively within a multi-agency framework with agencies such as social services, health professionals, family and the police to prevent, assess and investigate allegations of abuse. Where appropriate we ensure that Local Safeguarding Children Partnerships and the police are given all assistance in pursuing investigations into safeguarding incidents and we actively participate in such investigations where required.

3.22 We will work within an inter-agency framework with agencies such as education welfare or youth offending teams and family to address any anti-social behaviour issues relating to the dependents of tenants. This may include the use of acceptable behaviour contracts (ABCs) or parenting orders.

3.23 Where we are supporting customers who are pregnant, where applicable, we work will work in partnership with appropriate Health or other agencies and Children’s Social Care who may be responsible for working with the mother and family in the planning, assessment and actions required to safeguard the unborn baby.

3.24 Teams will liaise with police regarding Multi-Agency Public Protection Arrangements (MAPPA) for high risk offenders and Multi-Agency Risk Assessment Conferencing (MARAC) with regards to incidents of domestic abuse.  Local agencies, including the police and health services, have a duty under section 11 of the Children Act 2004 to ensure that they consider the need to safeguard and promote the welfare of children and young people when carrying out their functions.

Confidentiality

3.25 Riverside have robust policies and procedures in place for teams to follow covering issues of confidentiality and data protection.

3.26 Working in partnership with statutory and other relevant agencies is a key element of investigations into suspected abuse. The wishes of the child or family in relation to what information should be shared, and with whom, should be respected where possible. However, where there is a concern that the child may be suffering or is at risk of abuse or neglect, their safety must be the over-riding priority. Information must be shared with statutory authorities where there is any indication of abuse or harm to a child.

Performance and accountability

3.27 Riverside ensure that there are clear lines of accountability for safeguarding children across the business, including having a senior organisational lead to take responsibility for the organisation’s safeguarding arrangements.

3.28 To ensure that all safeguarding concerns are managed effectively and transparently, Riverside has robust governance and monitoring arrangements in place which provide oversight at all levels of the business. This includes regular reporting to the Executive Team, organisational governance committees and the Group Board.

3.29 Good practice and lessons learned from safeguarding incidents will be shared regularly across the group. Safeguarding groups have been set up to support this.

3.30 Safeguarding children and child protection will be engrained into all key policies, procedures and practice across the business.

Recording and Reporting

3.31 Riverside ensure that there are robust processes in place in relation to the recording and reporting of allegations of, or concerns about, abuse or neglect of children across the business. This includes reporting where there is a belief that an unborn child could be at significant risk of harm once born. Processes also cover reporting where children do not live in Riverside accommodation, or use Riverside services, but where colleagues come into contact with them whilst carrying out their role e.g. visitors.  These processes are set out in the Safeguarding Children Procedure(s).

3.32 Riverside takes concerns relating to self-harm and suicide seriously and understand the need to ensure that protective and supportive action is taken, and incidents are reported appropriately:

• Where a child or young person has harmed themselves and this has resulted in medical intervention being needed, this will be reported as a safeguarding concern.
• Where a child or young person discloses that they have had thoughts of suicide or made attempts to end their life, this will also be reported as a safeguarding concern.

3.33 Teams understand and work in line with Local Safeguarding Children’s Partnership procedures, ensuring that safeguarding concerns are reported in line with local arrangements. For Care Quality Commission (CQC) registered services, allegations or incidents of abuse or neglect will also be reported to the CQC

3.34 We ensure that allegations regarding inappropriate conduct of colleagues, in or outside the workplace, are investigated thoroughly and with urgency, through the Disciplinary and Grievance policies and the policies of the Local Safeguarding Children’s Partnership. The Local Authority Designated Officer (LADO) and relevant Riverside Safeguarding Lead will be notified in all cases.

3.35 Riverside will inform the DBS if an employee is implicated in a Safeguarding incident.

Legal and regulatory context and framework

4.1 The following acts and guidance documents are relevant in developing safeguarding policy and procedure:

• The Police Act 1997
• The Care Standards Act 2000
• Housing Act 1996
• The Care Act 2014
• The Sexual Offences Act 2003
• The Gangmaster (Licensing) Act 2004
• The Childcare Act 2006
• The Children Act 1989/2004
• The Safeguarding Vulnerable Groups Act 2006
• Protection of Freedom Act 2012
• Children And Families Act 2014
• Female Genital Mutilation Act 2003
• Children and Young Persons Act 2008
• Borders, Citizenship and Immigration Act 2009
• Protection of Children Act 1999
• Adoption & Children Act 2002
• The Mental Health Act 1983 (amended 2007)
• General Data Protection Regulation (GDPR) 2016 enforced May 2018
• Freedom of information Act 1998
• The Crime & Disorder Act 1998
• Anti-social behaviour Act 2003
• Criminal Justice and Courts Services Act 2000
• Domestic Violence, Crime and Victims Act 2004
• Human Rights Act 1998
• Anti-social behaviour, Crime and Policing Act 2014
• Every Child Matters: change for children, Home Office, 2004
• SCIE Guidance for Housing 2014
• The Modern Slavery Act 2015
• NSPCC’s Safeguarding toolkit (2016)
• Common Inspection framework: education, skills and early years (CIF)
• Safeguarding: Statutory Requirements and Ofsted Expectations (2016)
• Working together to safeguard children (DfE 2018)
• Statutory Guidance on Children who run away or go missing from home or care (DofE 2014)
• Domestic Abuse Act 2021

4.2 This policy should be read in conjunction with other relevant policy and procedures on:

• Safeguarding Children Procedure(s)
• Safeguarding Adults
• Volunteering
• Risk Assessments
• Recruitment
• Whistleblowing
• DBS (including DBS Roles and Schemes List)
• Disciplinary
• Grievance
• Privacy Statement
• Housing of Sexual Offenders
• Domestic Abuse
• Aids and Adaptations
• Anti-Social Behaviour
• Hate Crime and Harassment
• Lone Working
• Mental Capacity Act
• Managing Performance
• Equality and Diversity
• Duty of Candour

5.1 The Lead Director(s) and Policy Owner(s) for this policy are:

• Liz Turner, Head of Quality and Compliance (Riverside),
• Charlotte Smith – Head of Community Safety & Safeguarding (One Housing),
• Amy Crocker – Assistant Director of Business Development and Compliance (One Housing)

5.2 This policy will be fully reviewed every 3 years, with an annual update to reflect change to legislation or guidance.

6.1 Riverside’s risk appetite in relation to safeguarding children is low. It is fundamental to our values, the reputation of the organisation, and the risks associated with children’s wellbeing and safety that we meet legislative, regulatory and good practice guidance in this area.

The risks that we are mitigating by having this policy are:

• Risks of harm to children that may occur if safeguarding concerns are not recognised, reported and addressed appropriately.
• Risks of non-compliance with key legislation covering safeguarding children.
• Risks of non-compliance with regulatory requirements in registered services or with contractual obligations for our services.
• Risk of reputational damage that may occur through not following key legislation and guidance in relation to safeguarding.

If a customer wishes to complain about the service they have received under this Policy/Procedure, this should be handled through our Complaint Handling Procedure, which is governed by the Housing Ombudsman’s Complaint Handling Code of Practice.

These associated procedures are available on our Customer feedback pages, our Policies page, and are also available by contacting our Customer Service Centre.

Riverside is committed to Equality, Diversity & Inclusion. We strive to be fair in our dealings with all people, communities and organisations, taking into account the diverse nature of their culture and background and actively promoting inclusion. This policy aligns with Riverside’s Equality, Diversity and Inclusion Policy and has been subject to an Equality Impact Assessment.

Key Word / Phrase	Definition
Child	A child is ‘anyone who has not yet reached their 18th birthday. The fact that a child has reached 16 years of age, is living independently or is in further education, is a member of the armed forces, is in hospital or in custody in the secure estate, does not change their status or entitlements to services or protection.’[1] Certain legislation includes in their reference to duties towards children, young people who are 18, 19 and 20 who have been looked after by the local authority after the age of 16 or who have a learning disability, Children Act 2004 Part 1. In the context of this Policy, children may be: Customers in their own right e.g. supported housing services for 16 and 17 year olds, The children of customers e.g. children staying with their mother at service for young parents, children living in general needs accommodation owned by Riverside, or children of customers living in their own homes who receive a floating support service, Visitors to customers residing in a Riverside property or service, Any child that is reported to and/ or seen by a Riverside colleague where a concern is raised.
Riverside recognises that harm can take place in many forms. The categories below set out key categories, however, this is not a definitive list, and our teams will always consider the individual circumstances of cases that arise when deciding if an act or incident may be abuse:
Abuse	A form of maltreatment of a child.  Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm.  Children may be abused by a stranger, or someone known to them within their family or family network. Abuse can also take place by someone known to them in an institutional or community setting. Abuse can take place in person, child’s phone or via the internet. They may be abused by an adult or adults, or another child or children.
Physical Abuse	A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child.  Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
Emotional Abuse	The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development.  It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person.  It may include not giving the child opportunities to express their views, deliberately silencing them or “making fun” of what they say or how they communicate.  It may feature age or developmentally inappropriate expectation being imposed on children.  These may include interactions that are beyond the child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction.  It may involve seeing or hearing the ill-treatment of another.  It may involve serious bullying (including on-line bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children.  Some level of emotional abuse is involved with all types of maltreatment of a child, though it may occur alone.
Sexual Abuse	Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening.  The activities may involve physical contact, including assault by penetration (e.g. rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing.  They may also include non-contact activities, such as involving children in looking at, in the production of, or sharing sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet).  Sexual abuse is not solely perpetrated by adult males.  Women can also commit acts of sexual abuse, as can other children.
Neglect	The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development.  Neglect may occur during pregnancy as a result of maternal substance abuse.  Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment.  It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
Domestic Abuse	Children can witness domestic abuse in a variety of ways and this can have many negative physical and emotional effects. The Domestic Abuse Act 2021 states that children are a victim of domestic abuse in their own right if they witness, hear or have an awareness of domestic abuse happening.
All colleagues also need to be aware of other specific sources of harm which may include:
Online Abuse	This any type of abuse that happens online, whether through social networks, playing online games or using mobile phones. Children and young people may experience cyberbullying, grooming, sexual abuse, sexual exploitation or emotional abuse. Children can be at risk of online abuse from people they know, as well as from strangers. Online abuse may be part of abuse that is taking place in the real world (for example bullying or grooming). Or it may be that the abuse only happens online (for example persuading children to take part in sexual activity online). Children can feel like there is no escape from online abuse – abusers can contact them at any time of the day or night, the abuse can come into safe places like their bedrooms, and images and videos can be stored and shared with other people.
Exploitation	Child Sexual Exploitation (CSE) is a type of sexual abuse. Children in exploitative situations and relationships receive something such as gifts, money or affection as a result of performing sexual activities or others performing sexual activities on them. Children or young people may be tricked into believing they’re in a loving, consensual relationship. They might be invited to parties and given drugs and alcohol. They may also be groomed and exploited online. Some children and young people are trafficked into or within the UK for the purpose of sexual exploitation. Sexual exploitation can also happen to young people in gangs.
	Grooming is when someone builds an emotional connection with a child to gain their trust for the purposes of sexual abuse, sexual exploitation or trafficking. Children and young people can be groomed online or face-to-face, by a stranger or by someone they know – for example a family member, friend or professional. Groomers may be male or female. They could be any age. Many children and
	Gang Exploitation falls into three categories: peer groups, street gangs and organised crime groups.  There is a distinction between organised criminal groups and street gangs based on the level of criminality, organisation, planning and control. Children can often feel a strong sense of belonging to a gang and view this as their family and therefore do not often see the exploitation or abuse that exists.  Effective information sharing can help agencies to respond in a timely and appropriate way.
	County lines is a term used by the police where children and young people are exploited into moving drugs, often to towns outside of their home county.
	Cuckooing is where a criminal befriends an individual who lives on their own. The criminal then moves in and uses the property to operate unlawful activity.
Female Genital Mutilation (FGM)	FGM involves procedures that intentionally alter or injure female genital organs for non-medical reasons. It is illegal[2] to practice FGM in the UK or to take girls who are British Nationals or permanent residents of the UK abroad for FGM whether or not it is lawful in another country. In addition, staff have a mandatory duty[3] to make a personal report to the police if they hear disclosure that a girl under 18yrs appears to have undergone FGM. UK communities at risk of FGM include Kenyans, Somalis, Sudanese, Sierra Leoneans, Egyptians, Nigerians and Eritreans. Those from non-African communities that are at risk of FGM include Yemeni, Kurdish, Indonesian and Pakistani women.
Human Trafficking	Child trafficking is where ‘children and young people tricked, forced or persuaded to leave their homes and are moved or transported and then exploited, forced to work or sold.’[4] Children are trafficked for many reasons, including domestic slavery and forced labour, sexual exploitation, forced marriage or to be used in committing criminal offences / involved in gangs.
Honour Based Violence	This is an umbrella term for a collection of practices which are used to control behaviour within families or other social groups to protect perceived cultural and religious beliefs and/or honour. Such violence can occur when perpetrators perceive that a relative has shamed the family and/or community by breaking their honour code. It is important to flag any Honour Based Violence at the first instance, so it is managed properly. Honour Based Abuse is more prevalent within communities from South Asia, the Middle East, and North and East Africa. Reports come from Muslim, Sikh, Hindu, Orthodox Jewish and occasionally traveller communities. It is not determined by gender – both perpetrators and victims can be male or female. However, cultural tradition does not mean Honour Based Abuse is acceptable.
Forced Marriage	A marriage that is conducted without valid consent from one or both parties and duress is a factor.
Radicalisation	Radicalisation is the process by which a person comes to adopt increasingly extreme political, social, or religious ideals. This can, in extreme cases, result in condonation or support of terrorism. Extremism covers vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. Every case is different, but the following are possible indicators that someone might be at risk: Desire for status, Victim of or experience of discrimination or racism, Going through a transitional time of life, Being influenced or controlled, Feelings of grievance or injustice, Experiencing a traumatic event, A desire for political or moral change, Struggling with a sense of identity, meaning, and belonging or questioning their place in society.
Self-harm	Self-harm is when a person hurts themselves intentionally. This is often a way of coping with difficult feelings or situations, painful memories or trauma. Self-harm can present in many forms including cutting, pinching, burning, hitting or punching oneself and hair pulling (not an exhaustive list). Excessive use of alcohol and/or drugs and people putting themselves into harmful situations, where they may be subjected to physical or sexual abuse, can also be considered as self-harm.
Suicide	Suicide involves a person intentionally ending their own life. Suicidal feelings can range from a person having fleeting or general thoughts of ending their own life, right through thinking of or planning ways to end their own life.

[1] HM Government, ‘Working Together to Safeguard Children’, (2018)

[2] The Female Genital Mutilation Act 2003

[3] Serious Crimes Act 2015

[4] NSPCC, ‘Child Trafficking’, What You Need to Know About Child Trafficking | NSPCC