Section 1: What to do on receipt of a safeguarding concern or allegation

The following section sets out the requirements imposed on a relevant person when they receive a safeguarding concern or allegation about a Church Officer.   However, in line with a ‘whole church’ approach to safeguarding, any person who receives a safeguarding disclosure should act in accordance with these principles.

Guidance

1.1.1 - General Principles

The routes by which safeguarding concerns or allegations come to light can be varied. The above requirements are framed in this way because the person first receiving the allegation could be any member of a congregation or community.

When receiving a disclosure regarding a safeguarding concern, it is important to remember the 4Rs: recognise, respond, record and refer. Whoever receives the information about the concern would normally first discuss it with:

• a Parish Safeguarding Officer (PSO),
• a Cathedral Safeguarding Lead,
• the Designated Safeguarding Person in a religious community (DSP),
• the nominated Safeguarding Lead in a Theological Education Institution (TEI)

depending on the Church Body or the part of the Church where the concern was raised. The concern is then to be reported to the Safeguarding Officer on the same day, or the next working day, if received outside of usual working hours.

1.1.2 – Responding to a disclosure

The person to whom the disclosure is made should listen carefully to what the person is saying, bearing in mind the person disclosing might not be the victim/survivor, they may be a third party. They should allow the person to continue at their own pace and should not try to investigate by asking probing or leading questions. They should remain calm and be compassionate and reassuring and should not make promises that cannot be kept, particularly in relation to confidentiality.

The limits of confidentiality

Whilst any safeguarding concern should be treated with sensitivity, the person receiving the concern should not make promises that cannot be kept regarding confidentiality.

Safeguarding concerns relating to children and young people must always be reported to the Safeguarding Officer, regardless of whether the child or young person disclosing has given their consent. Fears about sharing information should not be allowed to stand in the way of safeguarding and promoting the welfare of children and young people1 . This means that the person receiving the disclosure should treat the matter with care, respecting the privacy of the person who made the disclosure – for instance, they should not openly share it with others who do not need to know.

Concerns relating to adults require more careful consideration, as adults have a general right to independence, choice and self-determination, including control over information about themselves. In most cases, it is good practice to gain the consent of an adult before sharing information with the Safeguarding Officer. However, there are a number of situations in which the consent of an adult does not need to be sought prior to information being shared, including:

• if the person disclosing and/or other people are, or may be, at risk of harm;
• if a crime has been, or may have been, committed;
• if sharing the information could prevent a crime;
• if the person lacks the mental capacity to make that decision and it is in their best interests to share that information, in order to ensure their safety and wellbeing.

As long as it does not increase the risk to the adult making the disclosure or to others, the person receiving the information should explain that they have a duty to share information with the relevant person in their Church Body, who will refer it to the Safeguarding Officer2 . If there is uncertainty as to whether or not to share information with the Safeguarding Officer, advice should be sought from them.

1.2.2 - Support

The person receiving the disclosure should establish whether the person needs any immediate support, which might be practical or emotional, and where possible, ascertain if/when the Safeguarding Officer will be in contact. Even though they might not be the victim or survivor themselves, they may still need support as a result of their involvement. This information must be recorded and shared with the Safeguarding Officer.

1.3.1 - Making a written record

The person receiving the disclosure should make a written record as soon as possible afterwards. It is important to make it clear to the person raising the allegation that some basic information, such as contact details, needs to be recorded in order to enable the Safeguarding Officer to follow up on the allegation.

The basic information that someone receiving an allegation should seek to record is:

• the nature of the concern, allegation or risk;
• the names of the people involved;
• contact details for the person reporting the concern or allegation; and
• information on whether there are other individuals or dependants that may be at risk, for instance children and young people.

Where appropriate, it is good practice to read back or summarise the information that has been recorded, to ensure that it accurately captures the disclosure. If the person disagrees with the record, the person recording it should make a note of those disagreements and retain them with the notes of the conversation. A copy of the record may be provided to the person who raised the allegation, should they request it.

The record must always be signed by the person receiving the allegation, timed and dated and it must include the location or the means (in person, online, phone call) through which the allegation was received.

Responding to anonymous concerns or allegations

Concerns or allegations raised anonymously should be reported to the Safeguarding Officer, but need to be managed carefully. Anxiety and fear may persuade some complainants not to immediately reveal their identity. It can be difficult to act on information under these circumstances, unless at some point the name of the complainant becomes known.

The person reporting the allegation should be informed that anonymity might restrict the ability of professionals to intervene to protect a child, young person and or vulnerable adult or to offer support. As much openness as possible should be encouraged.

1.4.1, 1.4.2 – Referral to the police or emergency services 

If there is an immediate risk of harm to any individual or urgent medical help is needed, report the matter to the police or other emergency services without delay.

Referrals to police

If someone is at risk of harm, a crime has been, or might have been committed, or if information becomes available that may help prevent a crime, the person receiving the disclosure should refer that information to the police immediately. 

Referrals to children’s social care

The requirement to report safeguarding matters relating to children and young people (i.e. under-18s) to local children’s social care services is captured in the “Working together to safeguard children 2023” statutory guidance. If a child is suffering, or is at risk of suffering, significant harm, the person receiving the disclosure must immediately share that information with the relevant statutory agencies, even if they do not have the child’s or their parent’s consent. If the person receiving the disclosure is not the Safeguarding Officer, the Safeguarding Officer should support that person in making the referral. The Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR) support the sharing of relevant information for the purposes of keeping children safe.

Local authorities across England have in place multi-agency safeguarding arrangements to coordinate responses to safeguarding concerns involving children and young people, which bring together relevant statutory partners. Safeguarding Officers should ensure that they are familiar with what the arrangements are in their local area or areas3 .

The LADO is responsible for overseeing the management of allegations against adults who work or volunteer with children and young people. This involves working with the police, employers and other professionals involved in a case. The LADO does not conduct investigations directly, but rather oversees and directs them to ensure thoroughness, timeliness and fairness. The LADO can provide advice, information and guidance to Church Bodies around allegations and concerns that involve children and young people. The LADO also plays a key role in ensuring that information is appropriately shared with all parties – for instance, where a person holds multiple roles in different organisations.

Referrals to adult social care

Referrals to adult social care services should be considered in cases in which an adult:

• has care and support needs;
• is experiencing, or is at risk of experiencing, abuse or neglect; and
• is unable to protect themselves from either the risk of, or the experience of, abuse or neglect as a result of their care and support needs.

The responsibilities of statutory services with regard to adults can be found in the Care and support statutory guidance. Local authorities deliver these responsibilities through Safeguarding Adults Boards, which oversee and coordinate adult safeguarding arrangements across their locality and partner agencies.

Concerns or allegations relating to adults require more detailed consideration before a referral to adult social care is made, as adults have a general right to independence, choice and self-determination, including control over information about themselves. In most cases, it is good practice to gain the consent of an adult before sharing information with adult social care services. However, there are a number of situations in which the consent of an adult does not need to be sought prior to information being shared, including:

• if the person disclosing and / or other people are, or may be, at risk of harm;
• if a crime has been, or may have been, committed;
• if sharing the information could prevent a crime;
• if the person lacks the mental capacity to make that decision and it is in their best interests to share that information, in order to ensure their safety and wellbeing.

The Social Care Institute of Excellence has produced a helpful guide to “Safeguarding adults: sharing information”, which provides further advice and information. Further guidance can also be found on the website of the Information Commissioner’s Office.

• 1More information can be found in the Working together to safeguarding children 2023 statutory guidance A 10 step guide to sharing information to safeguard children from the Information Commissioners Office.
• 2Further advice is available from Safeguarding adults: sharing information, (The Social Care Institute of Excellence) and the Information Commissioner’s Office.
• 3For more information on multi-agency safeguarding arrangements, see HM Government, “Working Together to Safeguarding Children 2023”.