Safeguarding Policy

Annex A – Safeguarding Policy for CLC Services (Commercial and Health and Fitness Centre Activities)

To be used in conjunction with the CLC Safeguarding and Child Protection Policy and Procedures

Key CLC Services contacts

Other relevant contacts as per the CLC Safeguarding and Child Protection Policy and Procedures

1.               AIMS

1.1  This Annex is to be used in conjunction with CLC Safeguarding and Child Protection Policy and Procedures in order to encapsulate the safeguarding and child protection policy and procedures of CLC Services, the trading subsidiary of Cheltenham Ladies’ College.

1.2  The aims of this policy are as follows:

1.2.1       To actively promote the welfare of children, adults at risk, staff, hirers, members of the public and other who come into contact with College and its facilities and to protect them from harm

1.2.2       To have clear procedures in place for dealing with and referring concerns about the welfare of any individual and / or allegations of abuse (including child on child abuse) who may be using CLC facilities and premises outside of College use

1.2.3       To raise awareness about how to report concerns and ensure they are appropriately investigated

1.2.4       To ensure staff are competent to carry out their safeguarding responsibilities and feel supported in this role

1.2.5       To ensure hirers of CLC facilities are aware of their safeguarding responsibilities and have their own suitable policies and procedures in place

1.2.6       To ensure consistent good safeguarding practice throughout CLC Services, and

1.2.7       To create a culture of safety, equality and protection

2.               SCOPE

2.1  This policy applies to all CLC Services activity, including any activities of the Venues and Events Department, residentials and summer schools, and the public membership side of the Health and Fitness Centre

3.               REGULATORY FRAMEWORK

3.1  Alongside legislation and guidance stated in the CLC Safeguarding Policy, this policy has been prepared to meet CLCS’s responsibilities under:

3.1.1       KCSIE (updated annually), specifically paragraphs 208, and 209.

3.1.2       Working Together to Safeguard Children 2026

3.1.3       Out-of-School settings: safeguarding guidance for providers

3.1.4       Care Act 2014

3.1.5       Online Safety Act 2023

3.1.6       Care and support statutory guidance 2025

3.1.7       Domestic Abuse Act 2021

4.               PUBLICATION AND AVAILABILITY

4.1  This policy is published on the Venues website and Health and Fitness Centre website.

4.2  This policy is available in hard copy at the Health and Fitness Centre, or at main college on request.

4.3  A copy of the policy is available for inspection from the Principal's Office during the College day.

4.4  This policy can be made available in large print or other accessible format if required.

4.5  This policy and all policies referred to in it are also available to staff on the College intranet

5.               DEFINITIONS

5.1  Where the following words or phrases are used in this policy:

5.1.1       Safeguarding is the protection of people from harm.

5.1.2       Safeguarding and promoting the welfare of children is defined in WTSC and KCSIE as:

-        Protecting children from maltreatment, inside or outside the home, including online

-        Providing help and support to meet the needs of children as soon as problems emerge

-        Preventing impairment of children’s mental or physical health or development

-        Ensuring that children grow up in circumstances consistent with the provision of safe and effective care, and

-        Taking action to enable all children to have the best outcomes

5.1.3       DSL means the School's or CLC Service’s Designated Safeguarding Lead. References to the DSL include the Deputy DSL (DDSL) where the DSL is unavailable.

5.1.4       Reference to staff includes all those who work for or on behalf of College, regardless of their employment status, including contractors, volunteers and members of Council unless otherwise indicated

5.1.5       HFC is CLC’s Health and Fitness Centre, which serves the PE, Sport and Outdoor Education needs of College students as well as offering public membership

5.1.6       CLCS or CLC Services is the trading subsidiary of Cheltenham Ladies’ College

5.1.7       An adult at risk is someone over 18 years old who:

-        Has care and support needs stemming from a mental, physical or learning disability, age, illness or other impairment

-        Is unable to protect themselves from substantial harm or exploitation, either due to their condition or other circumstances

5.1.8       A vulnerable adult can be defined as:

-        Someone experiencing mental health problems

-        An older person who may be frail or lack financial resources

-        An individual with a physical or sensory impairment

-        Someone with a learning disability

6.               RESPONSIBILITY STATEMENT AND ALLOCATION OF TASK

6.1  The board of CLCS has overall responsibility for all matters which are the subject of this policy.

6.2  To ensure the efficient discharge of its responsibilities under this policy, the board has allocated the following tasks:

6.3  Designated Safeguarding Lead

6.3.1       The Commercial Manager acts as DSL, and the HFC Manager acts as DDSL for CLC Services. Both are Level 3 DSL trained to the same standard as the Designated Safeguarding Lead for College, and will continue to keep their training relevant and up to date. Both have undertaken training specific to the School Enterprise industry, which includes management of risk to adults at risk.

6.3.2       The CLC Services DSL and DDSL will be the main point of contact for any such safeguarding matters raised internally or externally by Hirers or HFC members concerning external users of CLC facilities, including summer schools and HFC members.

6.3.3       The CLC Services DSL and DDSL will liaise with the College DSL should any referral need to be made, and will also seek advice where necessary with relevant agencies.

6.3.4       Either the Services DSL or DDSL will be available at all times throughout the year, both during term time and holiday periods.

7.           ADULTS AT RISK AND VULNERABLE ADULTS

7.1  Adults at risk, or vulnerable adults, may be at increased risk of:

7.1.1       Physical abuse: Including being hit, restrained, or injured

7.1.2       Sexual abuse: Involving sexual harassment or other forms of sexual assault

7.1.3       Financial abuse: Such as stealing or misusing someone’s money

7.1.4       Self-neglect: When someone does not receive adequate food, medication, or help with personal care

7.1.5       Modern slavery: Being forced into servitude or labour

7.2  For any hirer working with adults who might be vulnerable or at risk, we expect that The Care Act 2014 and its guidance (June 2023), and the principles of the Mental Capacity Act 2005 are followed.

7.3  These include the following principles from the Care Act 2014:

7.3.1       Empowerment: People being supported and encouraged to make their own decisions and informed consent

7.3.2       Prevention: It is better to take action before harm occurs

7.3.3       Proportionality: The least intrusive response appropriate to the risk presented

7.3.4       Protection: Support and representation for those in greatest need

7.3.5       Partnership: Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse

7.3.6       Accountability: Accountability and transparency in safeguarding practice.

7.4  And the following principles from the Mental Capacity Act 2005:

7.4.1       A person must be assumed to have capacity unless it is established that he/she lacks capacity

7.4.2       A person is not to be treated as unable to make a decision unless all practicable steps to help him/her to do so have been taken without success

7.4.3       A person is not to be treated as unable to make a decision merely because he/she makes an unwise decision.

7.4.4       An act done, or decision made, under this Act for or on behalf of a person who lacks capacity must be done, or made, in his/her best interests

7.4.5       Before the act is done, or the decision is made, regard must be had to whether the purpose for which it is needed can be as effectively achieved in a way that is less restrictive of the person’s rights and freedom of action

7.5  Hirers must also abide by the Safeguarding Agreement which forms part of their contract (see Appendix 1).

8.           PROCESS SHOULD ANY MEMBER OF STAFF HAVE A SAFEGUARDING CONCERN

8.1  If there is an immediate risk to the child or adult at risk, call 999.

8.2  If no immediate risk, contact the CLC Services DSL or DDSL and make a full report of your concern. Even low-level concerns should be reported, do not assume someone else has reported it.

8.3  In exceptional circumstances where the CLCS DSL or DDSL are not available, staff must not delay action, and contact a member of the CLC Safeguarding Team. This information should then be shared with the CLCS DSL or DDSL as soon as practicable.

8.4  The DSL and DDSL will review the concern, investigate further and collate evidence where appropriate. They may seek advice from the College DSL and/or Gloucestershire LADO. Should the concern involve children or adults at risk who are the responsibility of a hirer, the DSL or DDSL will speak to the hirer. Should the concern be for a member of the public, the DSL or DDSL will speak to the parent or carer should this not put the individual at risk.

8.5  Should the DSL/DDSL feel the concern meets the threshold for referral, or there is a pattern of low-level concerns, an official MARF will be completed.

8.6  Any concerns regarding Prevent, radicalisation or Female Genital Mutilation should be reported to the police via 101, asking for the Prevent or FGM lead

8.7  If the referral is made by someone other than the DSL, the DSL should be informed of the referral as soon as possible.

8.8  Should the concern be regarding an Adult at Risk, if the adult is deemed to have capacity to understand and make decisions, their consent is required before any referrals or sharing of information with other agencies. Reporting without consent is permissible in the following circumstances:

8.8.1       There is a risk or harm to the wellbeing and safety of the adult or others

8.8.2       Other adults or children could be at risk from the person causing harm

8.8.3       It is necessary to prevent crime or if a crime may have been committed

8.8.4       The person lacks capacity to consent

8.9  A review will take place as to whether CLC Services processes can be improved in light of the incident.

8.10                  Any low-level concerns relating to a member of CLC staff must be reported to the Head of College.

9.           CLCS IN-HOUSE LESSONS AND COURSES

9.1  Where CLCS runs in-house lessons, courses or summer schools involving children or adults at risk, the following should be in place:

9.1.1       All staff, including fixed term and contractors, should have undergone appropriate Safeguarding training, be aware of the contents of the CLC Safeguarding Policy and CLCS Annex, and know the contact details for the CLCS DSL and DDSL.

9.1.2       All staff, including fixed term and contractors, must have undergone a DBS check and that the check shows no criminal history (blemishes). Where a DBS contains a blemish, a risk assessment should be undertaken in conjunction with HR.

9.1.3       Where freelance staff are working at the HFC (for example in a Personal Trainer capacity) and only subject to a Children's Barred List check, they should not conduct any PT sessions with under 18s or adults at risk

9.1.4       A suitable safeguarding risk assessment should be in place (this may be a section on the main risk assessment for the course or activity)

9.1.5       A suitable fire safety and evacuation plan should be in place and communicated to all staff.

9.1.6       Suitable and sufficient first aid provision should be in place

9.1.7       Any third party providers undergo suitable checks, or are under the direct supervision of CLC staff whilst interacting with children or adults at risk

9.1.8       Appropriate levels of supervision scheduled for all activities, lessons and overnights.

9.1.9       Consideration should be given to the allocation of facilities, for example separate labelled staff and student bathrooms in boarding houses, or changing areas in the HFC.

9.1.10   Where the course or lesson involves use of the CLC Wi-Fi, CLCS to provide monitoring and filtering of online activity

10.        PROCEDURE FOR COMMERCIAL AND HFC HIRERS

10.1                  Commercial and HFC Hirers must abide by the Safeguarding Agreement (Appendix 1) which forms part of their contract.

10.2                  A Safeguarding risk assessment (or safeguarding section included in the main risk assessment) must be produced by both CLCS and the hirer should the activity involve children or adults at risk.

10.3                  Where multiple events are taking place across the site during peak times (Easter and Summer holidays) a MUSRA (Multiple-Use Safeguarding Risk Assessment) should be completed by the CLCS DSL.

11.  PROCEDURE FOR HFC MEMBERS AND PUBLIC USE

11.1                  Whilst members of the public using CLC facilities are not required to undergo any checks or training, staff are required to be vigilant to any concerns or risks involving young members of the public, adults at risk or interactions between CLC students and public. They are encouraged to report any concern, no matter how minimal.

11.2                  During term time, CLC students are segregated from the public by using separate areas locked off by fast vein access systems, and separate labelled changing areas.

11.3                  Both PE and HFC staff are vigilant to any breach of segregation between members and students.

11.4                  Pool and multi-gym sessions are clearly timetabled to be either exclusively for member or student use.

11.5                  Only students aged 16 and over are able to use the gym facilities alongside members.

12.        REFERRALS AND RECORD KEEPING BY HIRERS

12.1                  Any hirer working with children or adults at risk has completed and signed a declaration indicating the designated DSL and the organisation’s safeguarding protocols.

12.2                  The hirer’s DSL will be expected to liaise without delay with the CLC Services DSL (or deputy) on any safeguarding matters that occur on College site.

12.3                  The hirer is responsible for managing referrals and/or seeking advice from any relevant agency, unless CLCS deems an intervention is required.

12.4                  The hirer is responsible for ensuring accurate records are kept and shared accordingly so that the Commercial team have awareness as soon as possible (within 24 hours) of any safeguarding or child protection issues and will retain records within the relevant hirer file.

12.5                  The Commercial team are here to support and guide where necessary and to notify the College DSL.

12.6                  The CLC Services DSL and DDSL shall store all confidential documentation regarding safeguarding concerns and referrals on a closed sharepoint with limited access.

13.        HOLDING AND SHARING INFORMATION

13.1                  Any hirer working with young children or adults at risk should ensure they keep adequate records of any concern, allegation or referral.

13.2                  Using their discretion, they should inform schools, colleges, agencies and practitioners where necessary.

13.3                  The hirer is responsible for ensuring any transferring of records is carried out safely and securely.

13.4                  Information from the CLC Services Safeguarding sharepoint may be shared with the College DSL for the purposes of seeking advice.

13.5                  Abridged and censored information may be shared with the COO and CLC Services board if appropriate

14.        STAFF TRAINING

14.1                  All Commercial and HFC staff undergo the mandatory CLC Safeguarding on induction and annual updates.

14.2                  In addition customer-facing staff also undergo bespoke Safeguarding training tailored to the industry and potential risks.

14.3                  All staff should be made aware of the identity of the CLCS DSL and DDSL and the process of reporting a safeguarding concern.

14.4                  All staff should be made aware that anyone can make a referral, not just the DSL or DDSL

14.5                  All staff should be made aware of the contents of the CLC Safeguarding Policy and CLCS Annex

15.        VERSION CONTROL

Appendix 1 – Safeguarding Agreement (Version 3, September 2025)

SEA Safeguarding Agreement for Hirers

Safeguarding of adults and children is integral to the hiring of our venue. This document outlines what assertions and documents relating to safeguarding are required from you prior to the hire commencing, and what is expected of you and your staff as a hirer. 

Where you are working with children, we expect that the statutory guidance Working Together to Safeguard Children 2023 and Keeping Children Safe in Education (KCSIE), or as updated, are followed.

Where you are working with adults who might be vulnerable or at risk, we expect that The Care Act 2014 and its guidance (22nd July 2025), and the principles of the Mental Capacity Act 2005 are followed.

Safeguarding Policy and Procedures

It is a condition of this agreement that:

1.                Prior to the start of the agreement, you provide us with written confirmation and a copy of your own safeguarding policy that is suitable for the activity you will carry out on the school premises during the period of this hire. The policy should include:

·        Identification and contact details of a Designated Safeguarding Lead (DSL)

·        Contact details for the Local Authority Designated Officer (LADO) and the local referral route into children’s social care

·        Expected recognition of safeguarding for children/adults as required

·        Reporting arrangements for safeguarding concerns within your organisation

·        Reporting any allegations or concerns of abuse made against members of your staff or volunteers

·        Arrangements for the care of children or adults about whom there are already safeguarding concerns.

2.                The policy should be disseminated to, and well known by your own staff and available to those undertaking the activity (or their parents/carers) if required.

3.                That prior to the start of the agreement, you will have conducted a risk assessment based on the hire activities and first aid supplies that relate to the risk assessment must be provided by you.  Risk assessments should be reviewed and updated annually, or earlier if the circumstances in the school change or public health advice changes.  Active arrangements should be in place to monitor whether your controls for managing risks are effective and working as planned.

4.                That you have paediatric first aid training where children aged 5 and under are attending the provision (unless you are exempt from registration with Ofsted).

5.                That you have a fire safety and evacuation plan in place.

Training:

6.               That all staff who will be present or have a position of responsibility at the activity have completed appropriate safeguarding and health and safety training relevant to children, adults (or both) depending on the activity, and that this training is regularly updated.  All staff should receive regular safeguarding and child protection updates as required and at least annually. All staff should ensure that they understand and will comply with the requirements set out in the most current version of KCSiE.

Staff Names:

7.               That you provide us with the names of all staff who will be on site before they attend. Please ensure that this includes first and last names and titles and that lanyards are provided for the staff who will be onsite as part of your activity, either by your organisation or by the school after consultation.

8.               That you verify the identity of your staff with an official document. Preferably this should be photographic such as a driving licence or passport. School will request verification of identity when your staff arrive on school site.

Safer Recruitment and Checks:

9.                You provide us with written confirmation that the following checks have been completed on each of member of staff associated with your activity and who will be on site, prior to the start of the hiring agreement:

·        An enhanced disclosure from the Disclosure and Barring Service (DBS) for working with children/adults (or both, depending on the activity) and that the check shows no criminal history (blemishes). Where you are an organisation from overseas, please provide us with the equivalent checks.

·        A check of the Children's and or Adults’ Barred List and that the individual is not barred from working with Children/Adults (activity dependent).

·        The individual’s right to work in the UK.

10.             Where a DBS contains an entry of any kind (a blemish), you provide us with a copy of the DBS certificate so that we may assess blemishes and determine whether staff are suitable to attend the school premises. Where you are an organisation from overseas, please provide us with the equivalent checks.

11.             You undertake to regularly monitor and performance review staff and volunteers to ensure their suitability and training requirements after their appointment, and agree to immediately notify us if:

·                  any member of staff relating to this hirer agreement are or become barred from working with children or adults;

·                  any member of staff relating to this hirer agreement are the subject of a referral to the DBS or any regulatory body;

·                  any member of staff relating to this hirer agreement are released under investigation, arrested, charged, cautioned or convicted of any criminal offence;

·                  any member of staff relating to this hirer agreement, or any member of their household becomes the subject of a formal child protection investigation;

·                  you become aware of any circumstances relating to any member of staff relating to this hirer agreement that may reasonably be considered to pose a safeguarding risk to children or adults; or

·                  there is any change in the circumstances of any member of staff relating to this hirer agreement that affects their right to work in the UK.

Conduct:

12.             You undertake and agree to ensure that each member of staff relating to this Hirer Agreement will conduct themselves in a professional way while on school site and will comply with any reasonable code of conduct or instruction in relation to safeguarding issued from time to time by us in relation to the hiring of the facilities.

13.             The hirer will liaise with the school’s DSL in relation to safeguarding throughout the period of hire.

14.             Any concerns about the conduct or behaviour of staff under this Hirer Agreement which relate to an allegation of abuse or neglect of children or adults at risk must be notified to the school’s DSL within 24 hours and will be referred to the Local Authority Designated Officer (LADO) for children or to the police or other applicable body. The hirer agrees to comply with any subsequent instruction in relation to safeguarding received from the school.

15.             If we determine that any member of staff related to this Hirer Agreement is unsuitable to attend the school premises for any reason, we may exclude that person from the school premises and prevent their future attendance.

16.             Any members of your activity who are not staff must not have unsupervised access to children or adults who may be deemed vulnerable unless they are a parent or relative.

17.             The hirer will have in place a complaints procedure that includes provision for children, young people, and families to raise a safeguarding concern; together with a whistleblowing policy so that staff can raise concerns about the maltreatment of any children; and a staff behaviour policy.

Online Safeguarding

18.            All adults on school site must conduct themselves online in a professional manner. This includes:

·       Not engaging with children on social media.

·       Not inviting pupils from the school or children from other groups onto adults’ own personal social media or requesting or offering personal contact details.

·       Not taking photographs of children unless this forms part of a group within your activity who have provided parental consent.

·       Not live-streaming activities without consent.

·        Not engaging in any online activity which could be viewed as grooming or sexually explicit with children or adults who might be vulnerable or at risk.

·        Not engaging in any online activity which could be viewed as bullying, or allowing online child on child abuse to go unreported.

Duties under Prevent:

19.             It is a condition of this Hirer Agreement that you and those attending as part of your activity:

·                  do not organise or take part in any activities or presentations that incite hatred, violence, or call for the breaking of the law take place on the school premises;

·                  do nothing to encourage, glorify or promote any acts of terrorism, including individuals, groups or organisations that support such acts;

·                  do nothing to spread hatred and intolerance of any minority group(s) in the community;

·                  avoid insulting other faiths or groups, within a framework of positive debate and challenge; and

·                  do not raise or gather funds for any external organisation or cause which supports, encourages or promotes hatred or intolerance of any minority group.

Supervision and Staff use of Facilities

20.             Required staffing levels for each activity will be agreed as part of the requirements for your activity. This may include:

·        Sufficient staff numbers for supervision of children staying overnight

·        Sufficient staff who are first aid qualified

·        How staff use the facilities required for their activities for example the use of separate bathrooms and sleeping arrangements.

Compliance

21.            The hirer shall comply with all instructions received from the school in respect of safeguarding requirements.

Breach

22.             Any breach of safeguarding matters highlighted in this document will be considered to be a material breach of the agreement and result in immediate termination.