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Session 3 Finalising policy and procedures
3.1 Introduction
In this session, you will build on your understanding from Course 2 to think about how your safeguarding
Learning outcomes
In this session, you will cover:
How to finalise a safeguarding policy and get it approved by senior management. |
How the safeguarding policy links to other relevant procedures. |
The steps you can take to finalise your procedures. |
An example of how codes of conduct should apply to everyone at any level. |
The consequences of individuals failing to comply with a |
3.2 Applying your learning: comment
Task 1
Identify people in your organisation who can understand and champion safeguarding, and external safeguarding experts who can support you.
Comment
Within your organisation, it's important you connect with colleagues who interact regularly with children in sport. This can help you to identify those who are committed to the concept of safeguarding and keeping children safe. This can be a great place to start to build your internal network of safeguarding champions.
It’s important you also identify and engage with local experts on safeguarding. This could be Safeguarding Leads in other sports, or at sport for development organisations, or people in relevant government departments or
We hope you were able to make some good connections. They will help you begin to develop a network of support.
Next, you return to the course content by exploring the importance of your policies and procedures.
3.3 Getting your policy formally approved
With support from your manager and external experts, and using the templates provided in Course 2, you may have already developed or refined your organisation’s safeguarding policy. If not, now is a good time to go back to Course 2: Session 5 Policies, procedures, and codes of conduct and work through this process.
Your safeguarding policy provides an overview of the organisation’s responsibilities for – and commitment to – safeguarding, and the main actions to be taken. You should consult widely on the development of your policy internally and externally, including with other staff, athletes, athlete unions/representatives and survivor groups where applicable. You should do this for all the policies and procedures you develop as part of your role, to make sure they are person-centred.
The final version of the policy must be formally endorsed by your senior management group or Board before it is promoted and put into practice. Senior management approval is what gives the policy its status and authority.
In the next section, you explore how other policies of your organisation link to safeguarding.
3.4 The role of other existing organisational policies and procedures
The journey from developing your safeguarding policy to getting it approved at a senior level will involve helping people understand why a network of connected policies and procedures is needed to keep children and others safe in sport.
No single policy or procedure will prevent every abuse – but taken together, they help build a much stronger system. This is why it is important to think about all the relevant measures in your organisation.
3.5 What are the other policies and procedures that play a role in safeguarding?
Let’s think about some of the other organisational policies, systems and processes that play an integral part in safeguarding everyone.
Activity: Identify the existing policies and procedures that contribute to keeping people safe
Think about the following examples of policies and procedures and identify how you think each can contribute to safeguarding. Note that this is not meant to be an exhaustive list. Others that are equally important include compliance and legal policies and procedures.
| Policy and/or procedure | Possible contributions to safeguarding |
|---|---|
| Human Resources (HR) safer recruitment processes | |
| Organisation’s internal or external complaints mechanisms | |
| Disciplinary or ethics processes | |
| Integrity processes |
Comment
| Policy and/or procedure | Possible contributions to safeguarding |
|---|---|
| Human Resources (HR) safer recruitment processes | If recruitment/hiring information refers to the organisation’s stance on safeguarding – and includes police or criminal records checks for eligible roles – it may deter some dangerous individuals. |
| Any information from criminal background checks, or that comes out through the process (e.g. in interviews or in references), must be reviewed and risk-assessed by the Safeguarding Lead. This will help make sure dangerous people are kept out, or that appropriate risk management plans are in place. | |
| Organisation’s internal or external complaints mechanisms | Issues coming to light through internal or external complaints or reporting processes may have safeguarding implications. Once identified, they can be discussed with the Safeguarding Lead to decide on an appropriate response. |
| Disciplinary or ethics processes | Disciplinary and ethics processes provide a clear and |
| Integrity processes | Integrity processes have generally been set up to address sports rule-breaking (usually cheating, betting, corruption, or performance-enhancing doping issues). However, investigation or assessment of cases sometimes reveal concerns that have an implication for safeguarding. If staff involved in the process are supported to recognise these potential safeguarding issues and implications, they can be shared with the Safeguarding Lead to decide on an appropriate response. |
These examples demonstrate how safeguarding relies on much more than a sound safeguarding policy and procedure. No single policy or procedure is sufficient, and staff responsible for different areas need to understand this. Staff also need to understand the need for specific safeguarding sanctions and risk management approaches. These will be different from those used in integrity or other disciplinary processes.
Now let us consider how you might review other policies and procedures.
3.6 Reviewing other policies and procedures
One of your early tasks is to review all your organisation’s policies and procedures that may be relevant to safeguarding – to check that they reference and will address the broad range of safeguarding issues. This could also include
Once you understand how these policies can be relevant to safeguarding, you can identify gaps or parts that need to be strengthened and add this to your safeguarding
Here are the most common ones:
- Code of conduct.
- Recruitment.
- Disciplinary/ethics code and policies.
- Complaints and reporting mechanism.
- Procedure for referral to the relevant authorities.
- Victim support systems.
Whistleblowing or Speak Up.- Social media.
- Integrity.
- Diversity, equity and inclusion.
- Anti-bullying.
- Practice guidance (including events; travel; trips; social media; changing rooms; supervision of children).
- Rules governing children who take on roles as coaches, officials, volunteers, mascots, etc.
 |
| A network of policies and procedures |
To safeguard children and other vulnerable groups, this network of different policies and procedures needs to work together seamlessly – to prevent concerns arising and to respond quickly and effectively when issues come to light. Ensuring that safeguarding is included in other policies and procedures is what is called ‘mainstreaming safeguarding across the organisation’. |
Let us now examine developing procedures in more depth.
3.7 Developing procedures
In Course 2, you may have identified some of the supporting procedures that are needed to implement your safeguarding policy and have begun to prioritise these. Once your policy has been approved, your focus will turn to developing or revising these procedures further – starting with your identified priorities.
This isn’t something that you should try to do on your own. You should get help from external experts and internal
Let’s use an example – developing guidance for taking children away to tournaments or training camps. Patience describes how she approached this task.
Activity: Patience develops guidance for away trips
As you read her account, make a list of the actions you need to include in your safeguarding Action Plan.
‘Our initial assessment identified that we had very little written guidance for staff responsible for taking groups of children away to competitions. We identified that trips are one of the highest risk situations we can put children in, and that without clear guidelines we were making children, staff, and the organisation, vulnerable.
‘As a first step, we needed to develop clear, practical guidance that identified and addressed all the main considerations when taking children away. We identified two staff members with experience of regularly taking child athletes away, to lead on this work.
‘We started by breaking a trip into its key parts. We came up with these:
- Pre-trip planning and preparation (staff).
- Pre-trip planning and preparation (athletes and parents).
- Having a Safeguarding Lead for the trip.
- Departure/return timetable and handovers.
- Travel arrangements.
- Welcome and induction (itinerary, codes of conduct, support available).
- Accommodation, refreshments, and meals.
- A process to report incidents and concerns.
- A process for managing and referring cases to authorities if needed.
- Missing person arrangements.
- Supervision by appropriate adults – at all points on the trip.
- Activities – competition, training, and free-time.
‘We then thought about each part in more detail. For example, pre-trip planning and preparation for staff:
- A full itinerary (including travel, activities, and down-time).
- Checking accommodation and other facilities.
- Planning for travel including gathering relevant regional security advice.
- Information from athletes/parents (consents, medical and dietary information, emergency contact details).
- Supervision arrangements throughout the trip.
- Considerations for athletes with additional needs (e.g. disabilities, special dietary needs, etc.).
- Travelling staff code of conduct – include rules about smoking and alcohol.
‘Pre-trip planning and preparation for athletes and parents:
- Itinerary.
- Consents, medical and dietary information, emergency contact details.
- Athletes’ code of conduct.
- Drop-off and collection arrangements.
- Rules on the use of technology and social media.
- Contact with child during the trip.
‘Finally, we pulled all the information together into easy guidance, for staff, parents/carers, and also for children in child-friendly language.’
Comment
You can see that when you start to think about how to put policy into practice, there are lots of things to consider. Make sure you involve staff and athletes in thinking this through, to help you come up with really effective procedures.
In the next section, you look at an important part of procedures – the code of conduct.
3.8 Implementing procedures: a code of conduct example
Let us hear how Patience went about the task of implementing a coaches’ code of conduct.
Activity: Patience implements the new code of conduct
Listen to Patience again and reflect on the actions she took to develop and introduce the new code of conduct.
Transcript
Comment
Patience showed the value of explaining what the code of conduct was meant to do – but when needed she also made clear that this was a system that everyone had to comply with. It is important that the organisation requires everyone to sign up to their relevant code of conduct. There should be arrangements in place to respond to those who do not comply. This is what you will explore next.
3.9 Enforcing Procedures: a code of conduct example
Codes of conduct work most effectively when the following are understood:
- The purpose.
- Who is a Covered Person under the code.
- The requirement to comply.
- The consequences for not complying.
- The links to a system to report and respond (including disciplinary action where appropriate) when it is suspected that someone has behaved in an unacceptable way.
This is what gives a code of conduct authority and
Activity: The purpose of a coaches’ code of conduct
Write an appropriate description of the purpose of a coaches’ code of conduct.
This needs to convey this important information as an introduction to the code of conduct – it sets the scene.
Remember that the language that describes the purpose should be clear, simple to understand and should relate to the environments in which coaches work.
Comment
Here is our example of a description of the purpose of the code of conduct – could this help you develop your own version?
Our organisation has zero tolerance for abuse and poor practice. Every child or adult who participates in our sport should be able to do so in a safe, inclusive, and respectful environment. Everyone involved in our sport has a responsibility to promote high standards of behaviour.
We will achieve this by encouraging positive coaching behaviours that are person-centred. This coaches’ code of conduct details the type of behaviours we require and those behaviours which will not be tolerated.
A coach is an important role model and has the biggest single impact on an athlete’s wellbeing, development, and experience of our sport. This code of conduct helps to create a positive, enjoyable environment for athletes to experience our sport. It also helps coaches, by providing clarity about what is OK and what is not, and the type of behaviour they should report. The code of conduct can also help prevent coaches getting into potentially difficult situations, by helping you to set and maintain professional boundaries, and adopt safer working practices with athletes.
|
| The consequences of failing to comply with a code of conduct |
Every covered person should be required to sign a code of conduct to confirm that they understand what the organisation expects of them in terms of their behaviour – and that a failure to comply will result in action being taken. This is often very important in any investigation, as it prevents an individual claiming not to have understood how they were expected to behave. |
Below we have provided an example of language that addresses these points and can be included in a code of conduct:
I understand that if I fail to comply with the requirements in this code of conduct, any/all of the following actions may be taken by the organisation.
I may be the subject of an investigation and be:
- Required to attend a safeguarding education course(s).
- Monitored by another coach.
- Required to meet with disciplinary and/or safeguarding staff as part of an investigation.
- Provisionally suspended from some or all activities.
- Referred to the relevant authorities if a crime is suspected to have been committed, for the commencement of legal proceedings.
- Banned from participating in any sport-related activities.
In addition:
I have read, understood, and agree to abide by the terms of the coach code of conduct. I understand that failure to adhere to the coach code of conduct may result in further action being taken against me.
PRINT NAME………………………………….
Signed…………………………………………
Dated …………………………………………
Next, let’s think about why codes of conduct are so important.
3.10 How can a code of conduct help to manage some serious cases?
Let’s have a look at how one organisation effectively used a code of conduct to resolve a serious and difficult safeguarding case, when the police were not able to take formal action.
Activity: Challenges in responding to alleged bad behaviour by a senior employee
Patience describes handling one of her most challenging situations. Read what she says and then pick out the factors that helped her in responding to this case.
‘One of our highest profile Board members, Dalbir, is also a senior coach. He’s a familiar figure at major tournaments.
We recently held our under-20s finals, with men’s and women’s teams from across the country brought together for a weekend. On the second day the competition leader called me. He was agitated. The previous night, staff had been called to the women’s sleeping quarters. Dalbir had been seen leaving one of the bedrooms and staff found a very distressed young woman. Her belongings and bedding were all over the place – like there had been a fight – though she had no obvious physical injuries. The young woman didn’t want to say anything about what had happened except that Dalbir had been there and she never wanted to see him again.
I came to the same conclusion as the competition leader – this young woman may have been sexually assaulted by Dalbir. This needed to be investigated, although I was also aware of Dalbir’s power and reputation within the organisation. I consulted my contact in the police – and he said that unless the young woman was willing to make a complaint against Dalbir – or we had clearer evidence of an assault – they could not take any action or even investigate the incident.
When I spoke to the young woman and her parents – they were upset and angry – but they did not want their daughter to speak to the police or get involved in any legal action against him. They demanded that we ban Dalbir from coaching and from the organisation.
I spoke to Dalbir, and he denied doing anything wrong. He said that he had gone into the room because he had heard the young woman crying and wanted to check that she was ok. He had no idea why she was so upset. Dalbir was very angry. He threatened me about what would happen if I took the matter further. He saw the police’s refusal to get involved as proof that there was nothing the organisation needed to investigate.
So, despite my suspicions, there was nothing more I could do along the legal path. However, like all the other coaches, Dalbir had signed the code of conduct which had been adapted for staff involved in trips away with athletes. This clearly stated that coaches were never permitted to enter the bedrooms of athletes alone.
As a result of this – and even though we had no way to prove or disprove our suspicions of a sexual assault by Dalbir – we were able to act on Dalbir’s admission that he had broken one of the code of conduct’s important rules. A disciplinary investigation took place – which Dalbir refused to cooperate with, and the outcome was that Dalbir was banned from attending any activities involving athletes. However, before we could formally inform him of this, Dalbir submitted his resignation as a Board member and as a coach, claiming he had been the victim of a witch-hunt – and he left the sport.’
Comment
Here are our thoughts:
| Patience was right to speak to the police for advice about what should happen. |
| Despite no police investigation, Patience’s organisation was able to act. |
| The clarity of the code of conduct, and the organisation’s requirement for coaches to sign it confirming their understanding of it, helped the disciplinary investigation. It eventually restricted Dalbir’s access to athletes. |
| The code of conduct provided a solid base from which to assess Dalbir’s behaviour – without this the sports organisation would be left with very few options in responding to the concerns. |
| Patience followed the formal process and procedure, regardless of Dalbir’s position and reputation. |
|
| Positive messages for the wider organisation |
This case provides a positive message to the wider organisation and emphasises that safeguarding rules apply to everyone, without exception. |
3.11 Summary of Session 3
|
| The main learning and messages from this session are: |
|
In the next session, you will look at the reporting process in more detail.
3.12 Course quiz 1
Now it’s time to complete Course quiz 1 – it’s a great way to check your understanding of the course content so far.
This quiz contains 16 questions and a pass mark of 70% and above is required to obtain your digital badge and course certificate.
You can review the answers you gave, and which were correct/incorrect, after each attempt has been completed.
If you don’t pass the quiz at the first attempt, you are allowed as many attempts as you need to pass. There is a 24-hour delay between each attempt to allow you time to look back at the course content again.