SAFEGUARDING POLICY
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1. Introduction
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The Club is committed to ensuring the safety and wellbeing of all those employed by or
who interact with the Club. We will promote good safeguarding practice and aim to
enable club personnel to:
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• Provide children (i.e. those under the age of 18), vulnerable or other individuals
with appropriate safety and protection whilst involved with the Club.
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• Be educated in relation to safeguarding and safeguarding processes.
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• Make informed and confident responses relating to specific safeguarding issues.
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• Through education and communication, raise awareness amongst all members of
the wider London City Lionesses community to understand their role in
safeguarding.
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This Policy should be read in conjunction with our Unacceptable Behaviour Policy which
covers issues such as bullying and harassment.
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2. Scope
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Safeguarding is the responsibility of everyone employed by or associated with the Club
(including for example volunteers).
This Policy applies to all activities run or managed by the Club whether they are
undertaken at the stadium, our training facilities or at any other venue.
The Club has a specific Safeguarding Policy in relation to the Academy.
The Club acknowledges its responsibility to safeguard the welfare of every child, adult
at risk and all individuals who have been entrusted to its care and is committed to
working to provide a safe environment for all.
A child or young person is anyone under the age of 18 engaged in any activity with the
Club.
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3. Safeguarding Children
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We support The Football Association’s Safeguarding Children - Policy and Procedures
and endorse and adopt the Policy Statement contained in that document.
The key principles of The FA Safeguarding Children Policy are that:
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• The child’s welfare is, and must always be, the paramount consideration.
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• All children, vulnerable persons and all individuals have a right to be protected
from abuse regardless of their age, gender, disability, culture, language, racial
origin, religious beliefs or sexual orientation.
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• All suspicions and allegations of abuse will be taken seriously and responded to
swiftly and appropriately.
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• Working in partnership with other organisations, children and young people and
their parents/carers is essential.
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4. Recruitment and checks
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In line with our Equal Opportunities Policy, we recruit on the basis of merit, against
objective criteria that avoid discrimination.
Through our “safe recruitment process”, we take all reasonable steps to create a safe
environment for children and adults at risk and ensure that the right people work in our
Club. This will include:
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• Developing a role profile / person specification – to describe the tasks, duties and
responsibilities of the role and the skills, experience and attributes the role
requires. This will include specific experience of working with children, being
child-centred and necessary sport or other qualifications.
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• Advertising the role – we will advertise the role to try and attract a wide candidate
pool and to demonstrate an open recruitment process. The advert will indicate
whether the role involves working with children, and/or adults at risk and where
appropriate, that a self-declaration, references and a DBS check to the correct
level is required.
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• Completing an application process - to help inform any subsequent interviews
and identify any gaps in employment/volunteering history. This may include selfdeclaring relevant convictions/investigations and consent for appropriate record
checks.
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• Interviewing candidates – with appropriate Club representatives (ordinarily at least
two). Where the role involves working with children or adults at risk, we will ask
questions that gauge the candidate’s knowledge of safeguarding to assess their
suitability for the role.
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• Obtaining written references: We will obtain at least two written references,
including (where appropriate to the role) information on the candidate’s previous
work with children or adults at risk.
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• Requesting identification documents - The club will ensure the candidates
identity, qualifications and right to work in the UK are checked prior to
appointment.
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• Checking Criminal Records - We will ensure a Disclosure and Barring Service
(“DBS”) check of the correct level is carried out if a person is selected for a role.
Most roles within our club will qualify for a DBS check, and the level of check will
depend on the individual’s role. Eligibility for a DBS Check is governed by
legislation. In brief this means a DBS Check is required for anyone aged 16 years
or over who undertakes any potentially unsupervised activity working directly with
children and young adults under the age of 18.
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If there are concerns regarding the appropriateness of an individual who is already
involved or who has approached us to become part of our club, guidance will be sought
from our Designated Safeguarding Officer (“DSO”) and if appropriate the County FA/The
FA and/or the Women’s Professional League Limited.
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5. Abuse and Unacceptable Behaviour
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The Club does not tolerate abuse or unacceptable behaviour. Abuse is broadly defined
under relevant legislation and can include:
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• Neglect: Including ignoring medical or physical care needs.
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• Self-neglect: Including neglecting to care for one’s personal hygiene or health.
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• Modern slavery: Encompasses slavery, human trafficking, forced labour and
domestic servitude.
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• Domestic abuse: Including psychological, physical, sexual, financial and
emotional abuse.
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• Discrimination - which centres on a difference or perceived difference particularly
with respect to race, gender or disability or any of the protected characteristics of
the Equality Act (2010).
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• Organisational abuse - Including neglect and poor care practice.
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• Physical abuse – including hitting, slapping, pushing, kicking, misuse of
medication, restraint or inappropriate sanctions
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• Emotional or psychological abuse – Including threats of harm or abandonment,
deprivation of contact, humiliation, blaming, controlling, intimidation, coercion,
harassment, verbal abuse, or isolation.
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• Sexual abuse - Including rape, indecent exposure, sexual harassment,
inappropriate looking or touching, sexual teasing or innuendo.
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• Financial abuse - Including theft, fraud or coercion in relation to someone’s
financial affairs or arrangements.
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• Cyber bullying / online abuse: Including repeatedly making fun of another person
online or repeatedly picking on another person through emails or text messages.
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The Club’s Unacceptable Behaviour Policy includes further information.
Where the abuse/unacceptable behaviour includes a child or vulnerable adult there
may be a safeguarding concern which you should report in accordance with this Policy.
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6. Reporting Concerns
We support the need to have in place a reporting mechanism to reveal and raise
concerns over misconduct or malpractice within our organisation.
Reporting your concerns about the welfare of a child or any other individual is
everyone’s responsibility. If you are worried, then taking no action is not an option. Do
not assume that someone else will help or report the issue.
If there is a concern about someone’s immediate safety call 999 and speak to the
police. If an individual needs immediate medical treatment which cannot be provided
by the Club, please call an ambulance or if this is not possible, take the individual to a
hospital. If the individual is a child and/or a vulnerable adult, then two responsible
adults should accompany the individual that requires assistance.
Anybody with concerns about a colleague’s conduct towards a child or any other
vulnerable individual can contact the DSO safeguarding@londondoncitylionesses.com.
Behaviour that might be considered as inappropriate will often depend on the
circumstances. A lower-level concern may not be seen as immediately dangerous or
intentionally harmful to a child or vulnerable person, but it can soon escalate and
become a serious concern. The risk in not receiving reports of low-level concerns when
they arise is that behaviour cannot be addressed as soon as possible. Potentially,
situations could escalate and adversely affect those involved. Although low-level
concerns will often occur through a misunderstanding or lack of awareness, some
behaviour may be intended to enable abuse at a later stage.
Examples of incidents which should be reported to the DSO, even if you consider these
to be “low level” include:
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• An injury to a child.
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• If you accidentally hurt a child or observe another adult hurting a child.
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• If the child seems excessively distressed in any manner.
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• If there is a sudden change in behaviour, i.e. the child's behaviour becomes bad, or
they become withdrawn.
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• Thoughtless behaviour that raises doubts around the ability, motivation or skill to
work with children.
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If you wish to raise your concern outside of the Club you may contact The FA by calling
0800 169 1863 and asking for the Safeguarding Team or via email to:
Serious concerns can be reported to the local Police, Children’s Social Care, or the
NSPCC Helpline on 0808 800 5000.
Having an awareness and culture of safeguarding issues within the Club allows us to act
promptly as soon as concerns are brought to our attention. This can include correcting
behaviour through education, or where necessary removing an individual from their role.
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7. Good Practice Guidelines
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All staff must demonstrate exemplary behaviour to safeguard children, adults at risk
and all other individuals, report any concern both in the best interests of the young
person, adults at risk and all individuals as well as to protect themselves from
allegations.
Examples of Good Practice
The following are examples of how we expect Staff to create a positive culture within the
club:
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• Promptly respond to any request to complete or update your Disclosure and
Barring Service Checks.
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• Ensure that you carry out any training which is required by the Club.
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• Promptly inform the Head of People and Culture and the DSO if you are subject to
any investigation, allegation or arrest which may impact your role in working with
young people, adults at risk or any other individual
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• Work in an open environment, for example, avoid private or unobserved situations
and encourage transparency in communication.
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• Treat all people equally and with respect and dignity.
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• Put the welfare of the individual first in all instances.
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• Avoid any “intimate relationship” which is prohibited by the Club under the
“Relationships at Work” Policy. This includes avoiding any intimate relationship
between a coach and a player, a manager and a subordinate and with anyone
under the age of 18.
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• Never take advantage of a position of trust, control, or responsibility for those in
your supervision, care, support, or coaching environment.
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• Make football fun, enjoyable and promote fair play.
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• Keep up to date with the technical skills and qualifications in football to the
appropriate level.
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• All Club personnel should be vigilant and ensure adults around children, adults at
risk and all individuals act in accordance with the standards set by the club. Club
personnel are also responsible to monitor those who enter changing rooms, etc.
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• Ensure that if teams are taken away, they should always be accompanied by club
personnel and that appropriate club personnel ratios are planned and maintained.
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• Ensure that at tournaments or residential events, adults do not enter the rooms of
children or adults at risk or invite children or adults at risk into their rooms.
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• Be an excellent role model – this includes not smoking, not drinking excessive
amounts of alcohol, not using drugs, or not using bad language in the company of
young people, adults at risk and all other individuals.
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• When coaching, give enthusiastic and constructive feedback recognising the
development needs.
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• Secure parental/guardian/carer consent in writing to act, if the need arises, in
emergency circumstances to give permission for the administration of medication
or emergency treatment.
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• Obtain parental/guardian/carer consent in writing for taking photographs and/or
video of any child or adult at risk and provide information on how such footage is
to be used.
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• Keep a written record of any injury or incident that occurs, along with the details of
any treatment given and/or action taken and advise parents/guardians/carers and
the DSO on any issue in relation to any treatment of any individual and to log such
details on an incident/accident report form.
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• Request written parental consent if club personnel are required to transport
children or adults at risk in club vehicles. Transporting vulnerable persons in club
members' personal vehicles should be avoided unless necessary.
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Examples of Unacceptable Practice
The following should be avoided. If cases arise where these situations are unavoidable
(e.g. because of an emergency), they should only occur with the full knowledge and
consent of either the child's parent/guardian/carer or someone in a position of authority
within the Club.
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• Avoid taking a child or an adult at risk to their own home where they will be alone.
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• Avoid taking a child or an adult at risk to your home where they will be alone with you.
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• An adult should never share a room with any child. In certain limited circumstances
players/academy players may share a room in accordance with the separate
safeguarding policies.
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• Do not allow allegations made by a child or vulnerable adult to go unacknowledged,
unchallenged, unrecorded, or not acted upon.
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8. Coaching Contact
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If any form of manual/physical contact is required between a coach and a
player/academy member, it should be provided openly and in line with coaching
guidelines. In particular, when dealing with children you must consider the following:
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• Adults should explain the type of/reason for physical contact.
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• Unless it is an emergency, children should always be asked for permission before
any physical contact (e.g. to demonstrate a particular football technique).
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• Unless specifically and essentially required for emergency first aid care, contact
must not involve touching genital areas, buttocks, breasts or any other part of the
body that might cause a child distress or embarrassment.
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• Physical contact should never be used as a punishment.
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• Physical contact should always take place in an open or public environment and
not take place in secret or out of sight of others. Where essential treatment or
emergency first aid provided by the designated first aider takes place away from
the rest of the group for confidentiality and privacy reasons, at all times, the first
aider should ensure another responsible adult is present for the duration.
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• Physical contact should be culturally sensitive.
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9. Recognition – signs of possible abuse
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Every individual is unique, so behavioural signs of abuse will vary from person to person.
In addition, the impact of abuse is likely to be influenced by the person’s age, the nature
and extent of the abuse, and the help and support the person receives. However, there
are some behaviours that are commonly seen in children and vulnerable persons who
have been abused:
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• The person appears distrustful of a particular adult, or a parent or a coach with
whom you would expect there to be a close relationship.
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• The person has unexplained injuries such as bruising, bites or burns, particularly if
these are on a part of the body where you would not expect them.
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• The person has an injury which is not explained satisfactorily or properly treated.
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• A deterioration in the person’s physical appearance or a rapid weight gain or loss.
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• Pains, itching, bruising or bleeding in or near the genital area.
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• A change in the person’s general behaviour. For example, they may become
unusually quiet and withdrawn or unexpectedly aggressive. Such changes can be
sudden or gradual.
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• If the person refuses to remove clothing for normal activities or wants to keep
covered up in warm weather.
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10. Investigations and disciplinary matters
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The DSO will obtain written details of the concern/allegation and record information
about the times, dates and locations of any alleged incidents along with details of any
potential witnesses.
A risk management plan will be created to protect any children or other individuals at
potential risk.
If required the DSO will refer the matter to the relevant County FA (Kent if the issues
involve an Academy Player/member of staff or London if the issues involve a first team
Player), The FA, police and/or other statutory authorities as needed if there is a possible
criminal offence.
Where appropriate, the Club may instruct external investigators and/or experts to assist
with any safeguarding issues on its behalf.
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11. Consequences of breach
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If the allegation is made against an employee of the Club, consideration will be given as
to whether any disciplinary action is needed and if so the Club will follow its Disciplinary
and Capability Policy. This may include the need to suspend the employee from work
whilst an investigation or disciplinary procedure (or both) is carried out.
Failure to report a safeguarding incident/concern, covering up a safeguarding
incident/concern, and/or not engaging in any investigatory process when asked to do so,
will all be considered to be breaches of this Safeguarding Policy which may result in
disciplinary action.
In cases of gross misconduct, the Club may dismiss the employee without warning, with
no notice or payment in lieu of notice (summary dismissal). The Club is permitted to
make a referral to the Disclosure and Barring Service in any circumstances where it is
necessary to do so, including dismissal for gross misconduct.
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12. Record keeping
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Where the issue involves an employee, the Club will keep a clear and comprehensive
summary of the case record on the individual’s confidential personnel file including
details of how the allegation was followed up and resolved, the decisions reached, and
the action taken.
The record will help the Club to provide an accurate response to any future request for a
reference if the person has moved on. It will provide clarification where a future DBS
request reveals non convicted information and will help to prevent unnecessary
reinvestigation if an allegation surfaces after a period of time. In this sense, it may serve
as a protector to the individual themselves, as well as in cases where substantiated
allegations need to be known about to safeguard future victims.
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13. Further contact details
Further advice on Safeguarding can be obtained from:
Kent Football Association Safeguarding (in relation to issues involving Academy Players
or Staff)
01622 792140
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London Football Association Safeguarding (in relation to first team Players)
The Football Association
http://www.thefa.com/football-rules-governance/safeguarding
0845 210 808
Childline offers free, confidential advice and support whatever your worry, whenever
you need help - 0800 1111.
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14. Associated policies and procedures
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The following policies have either been referred to in this Policy and/or are relevant to
procedures associated with this Policy and should be reviewed for relevant information:
• Unacceptable Behaviour Policy
• Academy Safeguarding Policy
• Equal Opportunities Policy
• Relationships at Work Policy
• Disciplinary and Capability Policy
• Raising Concerns Policy
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