top
Image Alt

Safeguarding Policy

New Inn Congregational Church, Pontypool

Contents

1. Introduction

1.1 New Inn Congregational Church (“NICC”) is committed to the safeguarding and protection of all children, young people and adults at risk. That covers everyone who is part of the life of the church and everyone who comes into contact with it. This commitment flows from the church’s own calling: every person bears the image of God and is to be treated with dignity, care and respect.

1.2 This policy replaces the previous Statement of Safeguarding Principles (2019) and the Policy for Safeguarding and Promoting the Welfare of Children and Young People. It brings together in a single document the church’s approach to the safeguarding of children, young people and adults at risk.

1.3 This policy sits under the NICC Constitution (adopted 15 February 2016) and forms part of the church’s policy framework. It is adopted by the Church Officers, the Pastor, the Elders and the Deacons with the Secretary and Treasurer among them, who meet as the deacons’ meeting. They act under the authority delegated to them by the Managing Trustees (Constitution, Clause 8.2(iii)). It does not require adoption by Church Meeting.

2. Scope

2.1 This policy applies to all personnel of the church. For the purposes of this policy, “personnel” means the pastor, elders, deacons, secretary, treasurer, employees, volunteers, and any other person acting on behalf of NICC in any capacity.

2.2 This policy covers:

  1. Children and young people: any person under the age of 18.
  2. Adults at risk: any person aged 18 or over who is experiencing, or is at risk of, abuse or neglect, and who has needs for care and support, and who as a result of those needs is unable to protect themselves against the abuse or neglect or the risk of it. This is the definition used in the Social Services and Well-being (Wales) Act 2014 (section 126) and adopted by the Wales Safeguarding Procedures. The older term “vulnerable adults” means the same thing.

2.3 Children’s work: dormant, not abolished. No regular children’s or youth work runs. Children are present at services and church events from time to time, and toys are kept for any ad-hoc provision. This policy includes children so that the church remains equipped and ready, keeps its people properly checked, and safeguards children in every contact they have with the church. Section 14 sets out what must be in place before any regular children’s work resumes.

2.4 The care of adults at risk is the church’s principal safeguarding responsibility. Given the age profile of the congregation, the pastoral care of adults at risk is a regular part of church life. It includes visiting members and attenders in care homes, at home and in hospital, and some who are terminally ill.

2.5 This policy applies to all NICC premises: the chapel building, the Sunday School Hall, the graveyard, the pastor’s home where church contact and pastoral care often take place, and any other location where church activities take place. It applies to church activities wherever they occur, including pastoral visits.

2.6 This policy applies to every activity the church runs, listed in the Reference. A special event in the hall is a church activity, not a letting: a church member, normally an officer, is responsible for it.

3. Definitions

3.1 Safeguarding means taking all reasonable steps to prevent harm, abuse, neglect or exploitation, and to promote the welfare and wellbeing of children and adults at risk.

3.2 Abuse may take many forms, including but not limited to:

  1. Physical abuse: hitting, shaking, burning, scalding, or any other action causing physical harm.
  2. Emotional abuse: persistent ill-treatment, intimidation, threats, verbal cruelty, or rejection that damages emotional development or wellbeing.
  3. Sexual abuse: any sexual act or behaviour involving a child or an adult at risk who has not given, or is unable to give, informed consent.
  4. Neglect: the persistent failure to meet basic physical or psychological needs, or the failure to protect from harm or danger.
  5. Financial abuse (particularly relevant to adults at risk): theft, fraud, pressure in connection with wills or property, or the misuse of someone’s money or possessions.
  6. Spiritual abuse: the misuse of spiritual authority, coercion in matters of faith, or the use of religious teaching to justify or conceal abuse.
  7. Domestic abuse: any pattern of controlling, coercive, threatening, or violent behaviour between those who are or have been intimate partners or family members.

3.3 Abuse may be carried out by adults or by other children. It may occur within families, within institutions, or within the community. It may be a single act or a pattern of behaviour over time.

3.4 Position of Trust: the Sexual Offences Act 2003, as amended by the Police, Crime, Sentencing and Courts Act 2022, applies to religious settings. A person who teaches, trains, supervises, instructs or cares for someone under 18 is in a position of trust. Sexual activity with a person under 18 who is in their care is a criminal offence, regardless of apparent consent. This applies to the pastor, elders, and any other personnel engaged in pastoral or youth work.

3.5 Child at risk has the meaning given in the Social Services and Well-being (Wales) Act 2014 (section 130): a child who is experiencing or is at risk of abuse, neglect or other kinds of harm, and who has needs for care and support.

3.6 Low-level concern: any behaviour by a member of NICC’s personnel that is inconsistent with this policy or the expected standards of conduct, but which does not meet the threshold for a referral to statutory agencies. Low-level concerns shall still be recorded by the Safeguarding Lead and kept under review, as a pattern of low-level concerns may indicate a more serious problem.

3.7 Single Central Record: a register maintained by the Safeguarding Lead recording the pre-appointment checks (including DBS disclosures, training, and self-declarations) for all personnel in safeguarding-relevant roles. See Section 8.

3.8 Regulated activity: the specific work with children or adults at risk that in law requires the highest level of DBS check. Its meaning and its bearing on the church’s DBS checks are explained in Section 8.

3.9 Safeguarding Lead: the church’s designated person responsible for safeguarding (see Section 7). This is NICC’s term for the role known in the Welsh framework and to CSS as the Designated Safeguarding Person (DSP), and in English schools guidance as the Designated Safeguarding Lead (DSL). This policy uses “Safeguarding Lead” throughout.

4. Statement of Commitment

4.1 NICC is committed to:

  1. The care and nurture of, and respectful pastoral ministry with, all children, young people and adults.
  2. The safeguarding and protection of all children, young people and adults when they are at risk.
  3. The establishing of a safe, caring community which provides a loving environment where there is informed awareness of the dangers of abuse.

4.2 We will carefully select and train those with responsibility within the church, in line with safer recruitment principles, including the use of criminal records disclosures.

4.3 We will respond without delay to every concern raised which suggests that a child, young person or adult may have been harmed or may be at risk of harm. We will cooperate with the police and social services in any investigation.

4.4 We will work with anyone who has suffered abuse, developing with them an appropriate ministry of informed pastoral care.

4.5 We will seek to challenge any abuse of power, particularly by anyone in a position of trust.

4.6 Where a person in the congregation has offended, or poses a risk to children or adults at risk, we will offer pastoral care. We will agree and supervise the terms on which that person may be present, and refer where referral is required. Section 11A sets out how.

4.7 NICC also recognises that the duty of care extends to those who serve on the church’s behalf. Personnel are entitled to clear guidance, supervision arrangements that protect them from foreseeable risk, and a fair procedure if a concern is ever raised about them. The good practice provisions in Section 14, including witness practice for pastoral visits and accountability for one-to-one contact, are set out with this in mind as well as for the protection of those visited.

4.8 In all of the above we will follow legislation, statutory guidance and recognised good practice.

5. Legal and Regulatory Framework

5.1 NICC is in Wales. Safeguarding is devolved, and this policy is written for the Welsh framework. Guidance produced by English bodies is adapted to Welsh law and practice before it is used.

5.2 This policy has regard to the following legislation and guidance. References are to the versions current at the date of this policy. NICC will have regard to any subsequent amendments or replacements.

Welsh primary legislation:

  1. Social Services and Well-being (Wales) Act 2014 (Part 7: Safeguarding)
  2. Regulation and Inspection of Social Care (Wales) Act 2016
  3. Violence against Women, Domestic Abuse and Sexual Violence (Wales) Act 2015
  4. Children (Abolition of Defence of Reasonable Punishment) (Wales) Act 2020
  5. Well-being of Future Generations (Wales) Act 2015

National guidance and procedures (Wales):

  1. Wales Safeguarding Procedures (www.safeguarding.wales), the national practice procedures for safeguarding in Wales, issued under the Social Services and Well-being (Wales) Act 2014. The Procedures are maintained as a continuously updated digital resource.
  2. Working Together to Safeguard People (Welsh Government), including Volume 5, Handling Individual Cases to Protect Children at Risk
  3. Welsh National Safeguarding Training, Learning and Development Standards

UK-wide legislation relevant to Wales:

  1. Children Act 1989
  1. Children Act 2004 (Wales provisions)
  2. Safeguarding Vulnerable Groups Act 2006
  3. Protection of Freedoms Act 2012
  4. Mental Capacity Act 2005
  5. Equality Act 2010
  6. Data Protection Act 2018 and UK GDPR
  7. Sexual Offences Act 2003 (as amended)
  8. Domestic Abuse Act 2021
  9. Counter-Terrorism and Border Security Act 2019; Prevent Duty Guidance

Regional:

  1. Gwent Safeguarding Board protocols and guidance (www.gwentsafeguarding.org.uk). The Gwent Safeguarding Board (covering Torfaen, Blaenau Gwent, Caerphilly, Monmouthshire and Newport) is the Regional Safeguarding Board established under the Social Services and Well-being (Wales) Act 2014. It operates as two boards: the South East Wales Safeguarding Children Board and the Gwent-wide Adult Safeguarding Board.

Charity regulation:

  1. Charity Commission for England and Wales guidance: Safeguarding and protecting people for charities and trustees (CC48), and Charities and serious incident reporting (where applicable).

Advisory and good practice bodies:

  1. Christian Safeguarding Services (CSS), the church’s safeguarding umbrella body (www.thecss.co.uk). CSS provides DBS processing, advice, training, and templates, and is the church’s first point of external advice.
  2. Safer Places of Worship (www.spow.co.uk), as recommended by the church’s insurer.

5.3 Statutory duties. Under the Social Services and Well-being (Wales) Act 2014, sections 128 and 130 place a duty to report safeguarding concerns on “relevant partners”. Section 162 defines those as local authorities, health boards, police and other specified public bodies. A church is not a “relevant partner” and does not carry this statutory duty. However, the Wales Safeguarding Procedures are clear that all organisations, including faith and voluntary bodies, are expected to report concerns in the same way. This policy commits NICC to doing so. Any person may report a concern to the local authority under the Act. NICC will always do so where there is reasonable cause to suspect that a child or adult is at risk.

5.4 Prevent. NICC is not a “specified authority” under the Counter-Terrorism and Border Security Act 2019 (churches are outside the named sectors). Awareness of the Prevent duty and of indicators of radicalisation is, however, a matter of good practice. Prevent awareness is incorporated into the safeguarding training described in Section 9.

5.5 Mandatory reporting of child sexual abuse (on the horizon). A new statutory duty to report child sexual abuse has been created for England by the Crime and Policing Act 2026. At the date of this policy the duty applies to England only, and the equivalent question for Wales remains under consultation. NICC is therefore not yet subject to a statutory mandatory-reporting duty. The church is aware of this development and will adopt the duty, and update this policy, when it applies in Wales and when CSS updates its Welsh guidance. In the meantime the church already adopts the good practice behind it. Anyone who reports a concern to the Safeguarding Lead should confirm that it has been passed on to the statutory services, rather than assume it (Section 11).

5.6 NICC is an independent Congregational church, not part of a denomination with a central safeguarding structure. It has regard to safeguarding guidance issued by the bodies it is in fellowship with, listed in the Reference, and adopts it where appropriate to the church’s circumstances.

6. Insurance Compliance

6.1 The church’s insurance policy includes a safeguarding endorsement which is a condition precedent to liability. This means that compliance with the endorsement is a requirement for the church’s insurance cover to respond to a claim.

6.2 The endorsement’s requirements are set out in the Reference.

6.3 This policy is written to satisfy each of those requirements.

7. Responsibilities

The Church Officers (the Diaconate)

7.1 The Church Officers (the Pastor, the Elders and the Deacons, with the Secretary and Treasurer among them, who meet as the deacons’ meeting) are responsible for approving, reviewing and maintaining this policy. The officers have oversight of the church’s temporal affairs (Constitution, Clause 11.1(i)) and this includes ensuring that safeguarding arrangements are in place and effective.

7.2 The officers shall ensure that:

  1. A Safeguarding Lead is appointed and supported. This is an appointed role, not an elected one, and the person appointed need not be a deacon.
  2. Adequate resources are made available for safeguarding (including DBS checks, training and any necessary professional advice).
  3. This policy is reviewed annually and any changes are minuted.
  4. All personnel are made aware of this policy and their responsibilities under it.

The Safeguarding Lead

7.3 The Safeguarding Lead is the designated person responsible for safeguarding within NICC, and is appointed by the officers. The Safeguarding Lead is the church’s Designated Safeguarding Person (DSP) for the purposes of CSS membership and training, and the “Safeguarding Officer” for the purposes of insurance correspondence. The term “Safeguarding Lead” is used throughout this policy.

7.4 The umbrella body’s template provides for a Safeguarding Trustee, a Designated Safeguarding Person and a Deputy, with the trustees as a body behind them. At NICC the officers are the trustees; they retain the governance oversight and receive the annual safeguarding report (Section 15). The three offices are held as follows, whatever the shape of the eldership, and the holders are named in Section 16:

  1. Safeguarding Trustee. An officer appointed and minuted by the officers, who is neither the Pastor nor the Safeguarding Lead: an elder where one is available, otherwise a deacon. The Safeguarding Trustee carries the church’s oversight of what is right and proper in safeguarding, supports the Safeguarding Lead, and is the independent route for any concern about the Safeguarding Lead or the Pastor (7.10).
  2. Designated Safeguarding Person. The Safeguarding Lead (7.3), who is responsible for the operational work and the detail.
  3. Deputy. The Pastor, by virtue of his office (7.7). Where there is no Pastor, an officer appointed and minuted by the officers, who is not the Safeguarding Trustee; references in this policy to the Pastor as backup then mean that officer.

7.5 The responsibilities of the Safeguarding Lead include:

  1. Being the first point of contact for any safeguarding concern.
  2. Assessing concerns and taking appropriate action, including making referrals to statutory agencies where necessary.
  3. Maintaining secure safeguarding records.
  4. Ensuring that DBS checks are carried out at the correct level and kept up to date.
  5. Coordinating safeguarding training for personnel.
  6. Reporting to the officers on safeguarding matters, including the annual written safeguarding report (Section 15), and as concerns arise.
  7. Keeping up to date with current legislation, guidance and good practice.
  8. Reporting any serious safeguarding incident to the Charity Commission in accordance with Charity Commission guidance, or confirming with the officers that reporting is not required.

7.6 The current Safeguarding Lead is identified in Section 16.

Backup arrangements (no separate Deputy)

7.7 NICC does not appoint a titled Deputy Safeguarding Lead. The Pastor holds the Deputy’s function by virtue of his office (7.4(c)), trained to the same standard as the Safeguarding Lead (9.5). The Safeguarding Lead may be unavailable, or a concern may be one that cannot be brought to the Safeguarding Lead. In that case the concern may be brought to the Pastor, who acts as the primary backup, or to the Safeguarding Trustee named in Section 16.

7.8 Where a concern involves the Safeguarding Lead personally, it should be brought to the Pastor or to the Safeguarding Trustee. Where a concern involves the Pastor, it should be brought to the Safeguarding Lead or to the Safeguarding Trustee, who leads on any concern about the Pastor. These routes are additional to the right of any person to contact statutory agencies directly (Section 11).

The Pastor

7.9 The pastor has a particular responsibility for the spiritual oversight of the congregation (Constitution, Clauses 9 and 10). He is often the first person to become aware of a pastoral concern. The pastor shall:

  1. Be familiar with this policy and apply it in pastoral ministry.
  2. Report any safeguarding concern to the Safeguarding Lead without delay.
  3. Cooperate with the Safeguarding Lead and, where appropriate, with statutory agencies.
  4. Not investigate safeguarding concerns independently but refer them in accordance with this policy.

The pastor also acts as the primary backup to the Safeguarding Lead (Section 7.7). Any concern about the pastor goes to the Safeguarding Lead or to the Safeguarding Trustee, never through the pastor.

The independent route: the Safeguarding Trustee

7.10 A route independent of both the Safeguarding Lead and the pastor must exist. The Safeguarding Trustee (7.4(a)) is the person to whom any concern about the Safeguarding Lead or about the pastor may be brought directly, and leads on any concern about the pastor. The current holder is named in Section 16. This is an additional route, and does not replace the right to contact statutory agencies directly (Section 11).

All Personnel

7.11 Every person acting on behalf of NICC has a responsibility to:

  1. Be alert to signs of abuse, harm or neglect.
  2. Report any concern to the Safeguarding Lead (or, where appropriate, to the pastor or the Safeguarding Trustee) without delay.
  3. Not investigate concerns themselves.
  4. Cooperate with any safeguarding enquiry or investigation.
  5. Attend safeguarding training as required.

8. Safer Recruitment and DBS Checks

8.1 NICC will follow safer recruitment principles when appointing any person to a role that involves contact with children or adults at risk, whether paid or voluntary. This means a clear role description, an application or expression of interest appropriate to the role, and a self-declaration regarding criminal convictions and relevant history. It also means an Enhanced DBS check at the correct level before the person begins, and references where appropriate.

8.2 How DBS levels are decided. The level of DBS check is set by law according to the role, not by preference. An Enhanced check is available to those working with children or adults at risk. A barred list check may be added only where the person is engaged in regulated activity with that group, or is otherwise eligible. There is a separate barred list for children and for adults. Eligibility on another basis covers, for example, a trustee of a charity that carries out that regulated activity, or a religious office holder. For children, regulated activity must meet a frequency test (broadly, weekly, or four or more days in any thirty, or overnight). For adults, there is no frequency test: a single instance of qualifying care, such as personal care, help with medication, help with money, or transport because of illness, counts.

8.3 The church’s checks. The level of check for each role is the one attached to the position selected for it from the list Christian Safeguarding Services holds on its portal. CSS is the church’s umbrella body and, as the Registered Body, answers for the eligibility of every position on that list; the church selects the position that truthfully describes the office and does not settle a level for itself. The office each person holds and the position selected are recorded in the Safeguarding Risk Assessment, a companion document.

8.4 Enhanced DBS checks shall in any event be undertaken through CSS for the pastor, the Pastoral Visitors, the Safeguarding Lead and the Safeguarding Trustee. The same applies to any other person who works with children or adults at risk, or who has access to them, whether supervised or not. Supervision is not a reason to omit a check. From 1 September 2026 supervision no longer affects whether work with children is regulated activity. Section 139 of the Crime and Policing Act 2026 removed the supervision exemption from the Safeguarding Vulnerable Groups Act 2006, an Act extending to England and Wales, and the church takes the change as reaching Wales. Nothing turns on it: the church’s own standard at 14.2 was already the higher one and is unchanged by it.

8.5 Additional DBS checks shall be undertaken for any person whom the officers identify as requiring one. The officers shall have regard to the nature of the role and the degree of access to children or adults at risk. Where a person already holds a suitable check through another organisation (for example an Enhanced adults’ check held through NHS volunteering), that check may be relied upon where the DBS Update Service allows.

8.6 Blemished checks. Where a certificate contains information, the applicant presents it to the Safeguarding Lead and may withdraw the application. Anything the applicant disclosed beforehand is checked against the certificate; anything not disclosed is discussed openly, and a refusal to discuss heightens concern without deciding the matter. The Safeguarding Lead and the Safeguarding Trustee together assess the applicant’s suitability for the role, using the umbrella body’s DBS risk assessment form: a conversation with the applicant, signed by both, on what was declared, whether the certificate is accepted as correct, whether attitude and circumstances have changed, and whether references from other organisations can be given; then an assessment of what could go wrong, to whom, how likely and how serious, and whether the risk can be removed or controlled. The decision is one of unsuitable for the role, further enquiry needed, suitable with restrictions, or the information has no bearing. A barred list entry for the workforce concerned is decisive. Advice may be taken from CSS. The outcome is explained to the applicant and recorded on the Single Central Record; the certificate is returned and no copy kept. Where the certificate is the Safeguarding Lead’s own, the Deputy (7.4(c)) and the Safeguarding Trustee decide. The existence of a criminal record does not automatically bar a person from serving, and the church will always prioritise the safety of children and adults at risk. Where the person is to serve despite the information, the Safeguarding Lead shall apply the procedure in Section 11A.

8.7 DBS checks shall be renewed at least every three years, or at such shorter intervals as the officers may determine. Where the holder is registered with the DBS Update Service, a status check shall be made at least once a year and used rather than a new application, unless it shows new information or the role needs a different level or workforce.

8.8 The Safeguarding Lead shall maintain a confidential Single Central Record, recording the date of each check, the disclosure number, the level of check, and the outcome. Certificates themselves shall not be retained beyond six months of the recruitment decision, in accordance with the DBS code of practice. Where an identity check is carried out manually rather than digitally, the photocopies of the documents used to validate identity shall be kept for two years and then destroyed; where copies cannot be kept, the details shall be recorded on the Single Central Record. The DBS Identity Checking Guidelines of April 2025, in use from November 2025, require a record of the documents used to be kept for a minimum of two years; destroying the copies at two years is the church’s own practice. Nothing requires identity to be re-checked or re-recorded at any interval. The church holds the retention duty itself rather than relying on the organisation that processes the check, that relationship not being guaranteed to continue.

8.9 A DBS check cannot always be completed before a person is needed in a role. Before any early start is permitted, the Safeguarding Lead shall conduct and record a written risk assessment, with clear authorisation from the officers. It sets out the supervision arrangements that apply until the disclosure is received.

8.10 Identity and right to work. Before any paid appointment, NICC shall verify the applicant’s identity and right to work in the United Kingdom through documentary evidence consistent with the Home Office employer’s guide. For volunteer appointments, identity verification shall be carried out as part of the DBS process; right-to-work verification is not required for volunteer roles.

9. Training

9.1 The Safeguarding Lead and the pastor shall undertake recognised safeguarding training and refresh it at appropriate intervals.

9.2 All personnel shall receive a level of safeguarding awareness appropriate to their role. As a minimum, this means being given a copy of this policy, or directed to it on the church website, and confirming they have read and understood it. It also means a briefing from the Safeguarding Lead on recognising concerns and the reporting procedure.

9.3 Training shall include awareness of the Prevent duty and of indicators of radicalisation, proportionate to NICC’s context. For NICC this is a brief component of refresher training rather than a standalone course.

9.4 Where NICC resumes regular children’s or youth work, all personnel involved in that work shall complete a recognised safeguarding training course (such as that provided by CSS) before beginning in the role.

9.5 The Safeguarding Lead and the pastor, as primary backup, shall refresh their safeguarding training at least every two years. That follows the DSP-level refresher specified by CSS, and is consistent with the Welsh National Safeguarding Training, Learning and Development Standards.

9.6 All other personnel shall receive a safeguarding awareness update at least annually, which in most years is a briefing at a deacons’ meeting or the circulation of current guidance, recorded under 9.7.

9.7 The Safeguarding Lead shall keep a record of training undertaken, including dates, content and attendees.

10. Recognising Concerns

10.1 Abuse is not always obvious. Personnel should be alert to any sign that a child or adult at risk may be at risk of harm, including but not limited to:

  1. Unexplained injuries, bruising, burns or marks.
  2. Changes in behaviour, mood or demeanour.
  3. Withdrawal, fearfulness or reluctance to go home.
  4. Inappropriate sexual behaviour or language (in a child).
  5. Signs of neglect: poor hygiene, inadequate clothing, hunger.
  6. Signs of financial exploitation (in an adult at risk): unexplained loss of money, changes to a will under pressure, anxiety about finances.
  7. A disclosure made by a child or adult about something that has happened to them.

10.2 Sudden confusion or changed behaviour in an older person. A sudden change in an older person’s behaviour, meaning confusion, agitation or being unlike themselves, is often a sign of a medical problem such as an infection. A urinary tract infection is a common cause. It is not simply difficult behaviour. Personnel should treat an acute change of this kind as a welfare and medical concern. Stay with the person, seek help, contact family, a GP or 999 if needed, and inform the Safeguarding Lead. It should never be dismissed as the person being awkward.

10.3 If someone tells you about abuse or you have a concern, the following guidance applies:

  1. Listen carefully. Do not interrupt.
  2. Reassure the person that they are right to tell you and that it is not their fault.
  3. Do not promise to keep a secret. Explain that you may need to tell someone who can help.
  4. Do not ask leading questions or press for detail beyond what is offered.
  5. Make a written note as soon as possible, recording what was said in the person’s own words, the date, time, and who was present.
  6. Report the concern to the Safeguarding Lead without delay (see Section 11).
  7. Do not investigate the matter yourself.
  8. Do not confront the person against whom the concern has been raised.
  9. Do not discuss the concern with anyone other than the Safeguarding Lead (or the pastor or the Safeguarding Trustee where appropriate), or a statutory agency.

11. Reporting Procedure

If someone is in immediate danger

11.1 If a child or adult at risk is in immediate danger or at risk of serious harm, call the police on 999 without delay. Do not wait for advice from the Safeguarding Lead. Inform the Safeguarding Lead as soon as possible afterwards.

Reporting a concern

11.2 All safeguarding concerns, whether about a child or an adult at risk, should be reported to the Safeguarding Lead as soon as reasonably possible and in any event within 24 hours. Reports may be made in person, by telephone, or by email to the safeguarding email address (see Section 16).

11.3 Concerns from the public. A concern may come from anyone, including a neighbour or member of the public who knows someone connected to the church, and including a person who does not wish to be further involved. NICC welcomes such concerns and takes them seriously. A concern that arrives at the church’s general email address, rather than the safeguarding address, shall be passed to the Safeguarding Lead without delay. Whoever monitors the general inbox is briefed to do this.

11.4 Who makes contact. The Safeguarding Lead coordinates the response and decides who, if anyone, should make contact with the person concerned. Where it is appropriate to make contact, the church will do so sensitively. That includes matching a woman to make contact with a vulnerable woman where that is the more suitable approach.

11.5 Confirming the referral. Anyone who reports a concern to the Safeguarding Lead should confirm that it has been passed on to the statutory services where a referral is due, rather than assume it. This good practice is adopted now, ahead of any future mandatory-reporting duty (Section 5.5).

11.6 If the concern involves the Safeguarding Lead, the report should be made to the pastor or to the Safeguarding Trustee. If the concern involves the pastor, the report should be made to the Safeguarding Lead or to the Safeguarding Trustee, who leads on concerns about the pastor. The pastor shall not be informed in advance of the Safeguarding Lead taking advice from statutory agencies or CSS. If the concern involves both the Safeguarding Lead and the pastor, the report should be made to the Safeguarding Trustee, or directly to a statutory agency.

Sub-threshold concerns and Early Help

11.7 A concern may not meet the threshold for a referral to Torfaen Social Services or the police. The Safeguarding Lead shall still record it in the confidential file and review it in the light of any other concerns on record. They shall also consider whether Early Help services, which are Torfaen’s non-statutory support for children and families, should be signposted to the family concerned. Patterns of sub-threshold concerns may, in aggregate, meet a referral threshold even where individual concerns do not.

Disclosure of historic abuse by an adult

11.8 Where an adult discloses that they experienced abuse during their own childhood, the Safeguarding Lead shall treat the disclosure with the same care as any current disclosure. Where the alleged abuser may still pose a risk to children, the Safeguarding Lead shall refer to Torfaen Social Services regardless of the age of the original events. The disclosing adult’s wishes shall be respected so far as is consistent with the duty to protect others.

What the Safeguarding Lead will do

11.9 On receiving a concern, the Safeguarding Lead shall:

  1. Make a written record of the concern, including the date, the name of the person reporting, what was said or observed, and any action taken.
  2. Assess the concern and determine whether it should be referred to a statutory agency.
  3. Where the concern relates to a child: refer to Torfaen Children’s Services, as the authority for the area in which the concern arose, or to the police. This is the routing the Wales Safeguarding Procedures require, and it is the authority where the concern arose rather than where the child lives. A referral is made unless the Safeguarding Lead is satisfied that the concern does not meet the threshold for a statutory referral.
  4. Where the concern relates to an adult at risk: refer to Torfaen Adult Services, again as the authority for the area in which the concern arose, or to the police. A referral is made unless the Safeguarding Lead is satisfied that the concern does not meet the threshold.
  5. Where there is any doubt about whether a referral is needed, seek advice from the local authority duty team or from CSS before deciding not to refer.
  6. Inform the officers that a concern has been received and referred (or the reasons for not referring), without disclosing identifying details unless necessary.
  7. Confirm a telephone referral in writing within 24 hours. If Social Care has not acknowledged it within 7 working days, chase it.
  8. Record whether the parent or the competent adult’s consent to the referral was sought, and whether it was given, withheld or refused, and why. Tell the parent or the competent adult that a referral is being made. Do not tell them where doing so would increase risk to the child or adult at risk, or would alert an alleged abuser and prejudice a police investigation. Where they are not told, record the reason.

Allegations against personnel

11.10 Any allegation of abuse against a member of NICC’s personnel shall be reported immediately to the Safeguarding Lead. Where the Safeguarding Lead is conflicted, it goes to the pastor or the Safeguarding Trustee. It is referred without delay to the relevant statutory agency. The person against whom the allegation is made shall not be informed until advice has been taken from the police or social services. Where the allegation is against an adult who works with children, it is also reported to Torfaen’s Designated Officer for Safeguarding, through the referral route in Section 16. That is the role formerly called the Local Authority Designated Officer (LADO).

11.11 Where an allegation is made against a person in a position of trust within the church, NICC will cooperate fully with Torfaen Social Services and with any multi-agency process under the Wales Safeguarding Procedures. The person concerned may be suspended from their role pending investigation. Suspension is a neutral act and does not imply guilt.

Right to report directly

11.12 Nothing in this policy prevents any person from reporting a safeguarding concern directly to Torfaen Social Services (Section 16), the police, or CSS. The right to report to statutory agencies is always available and is not diminished by the church’s internal procedures. Any person who has raised a concern under this policy and believes it has not been properly acted upon should contact Torfaen Social Services or CSS directly.

Escalation

11.13 Where the Safeguarding Lead disagrees with the local authority’s handling of a concern and cannot resolve it directly, the matter goes to Gwent Safeguarding. The route is the Regional Safeguarding Board’s Protocol for the Resolution of Professional Concerns. This route is available to the church regardless of any relationship with the individual case worker or team.

11A. Management of individuals who have offended or who pose a potential risk

11A.1 Scope. This section applies where NICC becomes aware of a person attending, or wishing to attend, worship or other church activities, who has offended in a way that might pose a risk to others at NICC. It applies equally where the person has been the subject of safeguarding concerns that suggest a continuing potential risk. The church’s position is that no one is beyond the reach of God’s grace and the gospel, and the church has a duty of care to everyone in its congregation. Both can be held together only by an explicit, honest, documented arrangement.

11A.2 Initial conversation. On becoming aware of the matter, the Safeguarding Lead shall meet the individual privately, with one other officer present where possible. The purpose of that meeting is to:

  1. acknowledge the individual’s wish to be part of the life of NICC;
  2. understand the nature of the offence or concern;
  3. understand whether any statutory agencies are currently involved, and who the allocated officer is;
  4. explain that a written agreement will be put in place for the safety of everyone, including the individual;
  5. invite the individual’s cooperation in a formal risk assessment. A written note shall be held in the confidential file.

11A.3 Partnership with statutory services. The individual may have an allocated officer, for example a probation officer, an MAPPA officer or a social worker. NICC shall contact that officer, with the individual’s consent or where public-protection law allows without it. The purpose is to confirm the nature of the risk, to confirm any licence or order conditions relevant to church attendance, and to share NICC’s proposed arrangements. Where no statutory agency is involved but the concerns are of a safeguarding nature, the Safeguarding Lead shall seek advice from CSS before proceeding.

11A.4 Formal risk assessment. A formal risk assessment shall be completed using the umbrella body’s template, “Risk Assessment, Individual who poses a risk”, adapted at the point of need. It considers the nature of the offence or concern, who is most at risk, and the settings in which the risk is higher. It also considers the factors that increase and reduce the risk, and any restrictions that would reduce residual risk to a tolerable level. It shall be conducted by the Safeguarding Lead with at least one other officer, and reviewed by the pastor before being finalised.

11A.5 Formal written agreement. The outcome shall be captured in a formal written agreement, using the umbrella body’s template, “Formal contract, Individual who poses a risk”, adapted at the point of need. The agreement sets out:

  1. the support NICC will provide;
  2. the measures and restrictions the individual commits to, for example not being alone with under-18s or adults at risk, not undertaking specific roles, and agreed arrival and departure arrangements;
  3. the steps to be taken on accidental or intentional breach;
  4. who the individual may contact;
  5. what information will be shared, with whom, and the individual’s consent to that;
  6. the review date, typically six months. It shall be signed by the individual, the Safeguarding Lead, and the pastor or an authorising officer.

11A.6 Ongoing management. The Safeguarding Lead shall hold the agreement and risk assessment in the confidential file. They shall name the personnel who are aware of the arrangement and who have a supervisory role. They shall record any concern or breach at the time it arises, and convene a review at the date set, or sooner if needed.

11A.7 Refusal or breakdown. An individual may refuse to engage, refuse to sign, or intentionally breach the agreement in a way that creates unacceptable residual risk. In that case the officers, on the Safeguarding Lead’s recommendation, shall withdraw NICC’s welcome. That is communicated in writing by the pastor, with reasons, and in a pastorally appropriate manner. Statutory agencies shall be informed where relevant.

11A.8 Confidentiality. Information relating to the risk assessment and agreement is sensitive personal data under UK GDPR. It shall be accessible only to the Safeguarding Lead, the pastor, the Safeguarding Trustee, and any personnel named in the agreement, on a strictly need-to-know basis. Access is with the individual’s consent wherever practicable, and always where necessary to prevent harm.

11A.9 Adoption note. The presence of this section does not imply that any current attender is the subject of such an arrangement. The framework is in place so that, if the question ever arises, the church’s response is ready and does not have to be improvised under pressure.

12. Record Keeping

12.1 The Safeguarding Lead shall maintain a confidential safeguarding file. Where a matter develops over time, a chronology is kept at the front of the file and maintained as it does. The file contains:

  1. records of all concerns reported: the concern, the assessment, the action taken and the outcome;
  2. records of referrals;
  3. the Single Central Record;
  4. records of training;
  5. copies of this policy and previous versions;
  6. records of annual reviews;
  7. any correspondence with statutory agencies, insurers or CSS.

12.2 Safeguarding records shall be stored securely. Paper records shall be kept in a locked location with access restricted to the Safeguarding Lead and, where necessary, the pastor or the Safeguarding Trustee. Electronic records shall be password-protected and stored on a device or account with appropriate security.

12.3 Records relating to allegations of abuse shall be retained indefinitely, as they may be relevant to future investigations or DBS checks. Other records shall be retained in accordance with statutory requirements and good practice.

12.4 All safeguarding records shall be handled in accordance with the church’s Data Protection Policy and UK GDPR. Information shall be shared only on a need-to-know basis and in accordance with the law. A survivor of domestic abuse may need to be protected from another person, and information about where they are living is highly sensitive and shall not be shared without their agreement except where the law requires it.

13. Pastoral Care

13.1 NICC recognises that safeguarding concerns arise in a pastoral context. The church is committed to three things:

  1. offering appropriate care and support to anyone who discloses that they have been the victim of abuse, whether the abuse occurred within the church or elsewhere;
  2. signposting individuals to specialist support services where the church’s own pastoral resources are insufficient;
  3. offering pastoral care to any member of the church community who is known to have offended against a child or adult at risk. That care includes supervision and appropriate boundaries, and the safety of potential victims comes first (see Section 11A).

13.2 The pastor and Safeguarding Lead shall work together to ensure that pastoral care and safeguarding responsibilities are properly coordinated.

14. Good Practice for Activities

14.1 This section sets out the good practice standards that apply whenever NICC activities involve children or adults at risk, whether or not regular children’s or youth work is currently running.

Before any regular children’s work resumes

14.2 Regular children’s work is dormant (Section 2.3). Before any such work resumes, the Safeguarding Lead shall be satisfied that the leaders are DBS-checked at the correct level, that training is in place, and that the arrangements meet the supervision requirements at 14.2A.

14.2A The following supervision requirements apply to any activity where children are in the church’s care, without exception.

  1. Two approved, DBS-checked adults present is the normal standard for any activity where children are left in the church’s care.
  2. Where only one approved adult is available, the activity may proceed only if it is held in continuous view of the gathered congregation, for example in the vestry with the door to the church open. The single adult is never unobserved. In a separate or unobserved room, for example the Sunday School Hall away from the chapel, two approved adults are required.
  3. A child is never to be alone and unobserved with a single adult.
  4. Where parents remain present and responsible for their own children (as at a parent-and-toddler group), this is not regulated activity and the two-adult requirement is met by the parents’ presence.

Supervision ratios

14.3 Where NICC runs activities specifically for children, the following minimum adult-to-child ratios shall apply, being NSPCC’s published bands: children aged under 2, one adult to three children; aged 2 to 3, one adult to four; aged 4 to 8, one adult to six; aged 9 to 12, one adult to eight; aged 13 to 18, one adult to ten. The two-adult rule at 14.2A stands over and above the ratio in every case. At least one approved adult present should be female.

Occasional and ad-hoc care of children

14.4 From time to time a child may be in the brief care of church members without a parent present. That might be when a young family visits a coffee morning, or at a church member’s family event in the hall. In such cases the child remains the responsibility of the parent or carer, who stays reachable and nearby. At least one DBS-checked adult should be involved, the supervision requirements at 14.2A apply, and the care should be brief and in an observed part of the building. Care of a child should never take place out of sight of others.

General conduct

14.5 Personnel shall avoid being alone with a child or adult at risk in a closed or unobserved setting. Where one-to-one contact is unavoidable it should occur with the knowledge of the Safeguarding Lead and, in the case of a child, the parent or carer. Personnel shall not:

  1. use physical punishment;
  2. engage in rough physical games or inappropriate touching;
  3. make sexually suggestive comments, even in jest;
  4. offer lifts to children unaccompanied by another adult, unless agreed in advance with the parent and the Safeguarding Lead.

Personnel shall report any accident, injury or incident to the Safeguarding Lead and record it on the church’s incident form.

Pastoral visits and home contact

14.6 The pastor and other personnel visit adults at risk in their homes, in care homes and in hospital as part of pastoral ministry. On any such visit they should:

  1. ensure that someone else knows where they are and when they expect to return;
  2. be aware of the vulnerability of the person being visited, and conduct themselves accordingly;
  3. ensure a witness is present, or make a contemporaneous written note, where money, valuables or signed documents change hands;
  4. report any safeguarding concern arising from a visit to the Safeguarding Lead. A pastoral visit may include practical help such as personal care, help with medication, help with money, or transport because of illness. The visitor should then be DBS-checked at the appropriate level (Section 8).

15. Review

15.1 This policy shall be reviewed annually. The review shall normally take place at the deacons’ meeting held in March or April each year and shall be minuted.

15.2 The Safeguarding Lead shall prepare a brief written safeguarding report for the annual review. It covers any concerns received, by number and type and without identifying details; any referrals made; the status of DBS checks; training completed and due; any changes to legislation or guidance affecting the policy; and a recommendation on whether the policy requires amendment. In a year with no concerns to report, the report may be brief.

15.3 The review shall confirm that the policy remains fit for purpose and compliant with current legislation and guidance. It shall confirm that DBS checks are up to date and that training has been undertaken or refreshed. It shall confirm that any concerns during the year were handled in accordance with this policy, and that contact details and named persons remain current.

15.4 Where no changes are required, the outcome will be a minute recording that the policy has been reviewed, the annual report received, and the policy remains in order. Where changes are needed, the Safeguarding Lead shall prepare a revised draft for approval, and any change affecting what a person must do shall be communicated to all personnel.

16. Contact Information

Safeguarding Lead

Mr Matthew Fawcett (Honorary Treasurer and Deacon) Safeguarding Lead, New Inn Congregational Church Email: safeguardingnewinn@gmail.com

Backup (Safeguarding Lead unavailable)

Rev. Gordon Cooke (Pastor) Reachable through the church in the usual way.

Safeguarding Trustee (independent contact for any concern about the Safeguarding Lead or the Pastor)

Mr Stephen Boraman (Elder), who leads on any concern about the Pastor. Reachable through the church in the usual way.

Emergency and Statutory Contacts

Police (emergency): 999 Police (non-emergency): 101

Torfaen Social Services (all safeguarding referrals, children and adults at risk): Telephone: 01495 762200 (Monday to Thursday 8:30am to 5:00pm, Friday 8:30am to 4:30pm) Children’s Services email: cs.contact@torfaen.gov.uk Adult Services email: ss_calltorfaen@torfaen.gov.uk Allegations about a person in a position of trust: the same route, asking for the Designated Officer for Safeguarding, the role formerly called the Local Authority Designated Officer (LADO)

South East Wales Emergency Duty Team (out of hours): Telephone: 0800 328 4432 (freephone; evenings, weekends and bank holidays)

Live Fear Free (domestic abuse helpline, Wales): Telephone: 0808 80 10 800 (freephone, 24 hours) Website: www.livefearfree.gov.wales

Christian Safeguarding Services (CSS) (DBS, training, advice): Telephone: 0116 218 4420 Website: www.thecss.co.uk

Safer Places of Worship: Website: www.spow.co.uk

Gwent Safeguarding (regional strategic oversight, not for individual referrals): Website: www.gwentsafeguarding.org.uk

Wales Safeguarding Procedures: Website: www.safeguarding.wales

Jurisdiction and sources. This policy is written for the Welsh safeguarding framework, safeguarding being devolved and the law and practice in Wales differing from England’s. It rests on the Social Services and Well-being (Wales) Act 2014, Part 7, and the Wales Safeguarding Procedures, with regard to the guidance of the Gwent Safeguarding Board and of the Charity Commission (CC48). It draws on the model policy of Christian Safeguarding Services, the church’s umbrella body, produced with the Fellowship of Independent Evangelical Churches for smaller churches, and it is written to satisfy the church’s insurance safeguarding endorsement (Section 6). It sits under the NICC Constitution and its Savoy Declaration (1658) framing: safeguarding at NICC is a practical outworking of the church’s own faith and care, not a set of external rules bolted on. Where English-origin material has informed it, that material has been adapted to the Welsh context, and the whole is proportionate to the life and activities of a small independent Congregational church in Wales.

Where to find us

Chapel

Lorem ipsum dolor sit amet, consectetur elit sed do eiusmod tempor incididunt.
a

Error: Contact form not found.