Managing Allegations Against Staff and Volunteers

This policy explains how Street Lights Collective CIC will respond to allegations, concerns and low level concerns about the behaviour of adults who work with or represent the Organisation.

Street Lights works with children, young people, families and communities where trauma, exploitation, serious youth violence, online harm, postcode conflict and contextual safeguarding risks may be present. Because of this, the Organisation must have clear, safe and accountable procedures for managing concerns about adults in positions of trust.

This policy protects children, young people, adults at risk, families, staff, volunteers and the integrity of Street Lights Collective CIC. It ensures that concerns are taken seriously, handled fairly, recorded properly, escalated appropriately and used to strengthen safer practice.

This policy applies to all adults connected to Street Lights Collective CIC, whether paid or unpaid, formal or informal, temporary or permanent.

Directors and board members

Board advisors and specialist advisors

Designated Safeguarding Lead and deputy safeguarding roles where appointed

Employees and sessional workers

The six trauma informed practitioners within the delivery team

Volunteers, mentors and youth workers

Youth ambassadors where they are acting in a leadership or representative capacity

Contractors, trainers, consultants and external facilitators

Partners delivering activity with or on behalf of Street Lights

Visitors or adults attending Street Lights activities in a formal role

Street Lights Collective CIC is committed to creating safe, trusted and trauma informed spaces. Everyone representing the Organisation must act with integrity, respect, professionalism and appropriate boundaries.

Any allegation or concern about an adult must be handled promptly and proportionately. The safety and welfare of children, young people and adults at risk is the first priority. At the same time, adults who are subject to allegations must be treated fairly, with confidentiality, dignity and due process.

Street Lights will not ignore, minimise, hide or privately manage allegations that require safeguarding escalation. The Organisation will cooperate with statutory agencies, local authority safeguarding partners, the police, the Local Authority Designated Officer where applicable, and other relevant bodies.

For this policy, an allegation is any information which suggests that an adult connected to Street Lights may have harmed, may pose a risk of harm, or may be unsuitable to work with children, young people or adults at risk.

A low level concern is any concern about adult behaviour that does not appear to meet the threshold for a formal allegation, but still falls short of expected conduct or may indicate a pattern of unsafe practice. Low level does not mean unimportant. Small concerns can reveal wider risk when viewed together.

A person in a position of trust is an adult whose role gives them influence, authority, access, credibility or responsibility in relation to children, young people, vulnerable adults, families or communities.

A concern must be reported immediately to the Designated Safeguarding Lead, or to another director if the concern relates to the Designated Safeguarding Lead, where it is alleged or suspected that an adult has:

• Behaved in a way that has harmed or may have harmed a child, young person or adult at risk
• Possibly committed a criminal offence against or related to a child, young person or adult at risk
• Behaved towards a child or young person in a way that indicates they may pose a risk of harm
• Behaved in a way that indicates they may not be suitable to work with children, young people or adults at risk
• Abused a position of trust, authority or influence
• Crossed professional or personal boundaries
• Used sexual, threatening, humiliating, discriminatory or exploitative language or behaviour
• Engaged in inappropriate online contact or direct messaging
• Shared or requested inappropriate images or personal information
• Used violence, intimidation, bullying, harassment or coercion
• Failed to follow safeguarding instructions, risk assessments or safe practice rules
• Concealed safeguarding information or discouraged reporting
• Used young people for personal, financial, social, religious, political, criminal or reputational gain

Because Street Lights works in communities affected by serious youth violence, exploitation and postcode conflict, allegations may arise in contexts outside a formal session. Concerns may involve behaviour in the street, online spaces, community events, schools, homes, group chats, transport routes, youth clubs, placements or partner settings.

Adults must never use community credibility, lived experience, local reputation, faith position, professional status, social media following or personal relationships to bypass safeguarding expectations.

Inappropriate contact with young people outside agreed channels

Adults becoming involved in postcode conflict, retaliation, threats or community tensions

Adults using social media to shame, pressure, expose or contact young people privately

Adults encouraging young people to disclose unsafe information in public spaces

Adults taking young people into cars, homes or private settings without authorisation

Adults using mentoring relationships to build dependency or secrecy

Adults failing to report concerns about exploitation, criminal activity or online harm

Adults softening language around harm, exploitation or risk in a way that prevents protection

The Board of Directors has ultimate responsibility for ensuring this policy is implemented, reviewed and understood. The Board must ensure there are safe procedures for reporting concerns about any adult connected to the Organisation.

The Designated Safeguarding Lead for Street Lights Collective CIC is Phillip Chackochen. The Designated Safeguarding Lead is responsible for receiving concerns, making safeguarding decisions, seeking advice, recording actions, liaising with statutory agencies, and reporting themes to the Board where appropriate.

All staff, volunteers, practitioners, advisors, partners and representatives must report concerns immediately. It is not their role to investigate, test the truth of an allegation or decide whether a concern is serious enough to record.

Concerns about staff, volunteers, practitioners, advisors, partners or representatives must be reported to Phillip Chackochen as the Designated Safeguarding Lead.

If the concern relates to the Designated Safeguarding Lead, the concern must be reported to Andrew Fuller or another director who is not implicated in the concern.

If the concern relates to a director, it must be reported to another director or to the Designated Safeguarding Lead, who must seek external safeguarding advice where required.

If any person believes that Street Lights is not responding safely, they may raise the concern externally with the relevant local authority safeguarding team, Local Authority Designated Officer, police, NSPCC helpline, Charity Commission where relevant, CIC Regulator where relevant, or other appropriate statutory body.

When an allegation is received, the person receiving it must:

• Listen carefully and take the concern seriously.

Avoid promising secrecy.

Avoid asking leading questions.

Record the information accurately, using the person’s own words where possible.

Record the date, time, location, people involved and any immediate safety concerns.

Report the matter to the Designated Safeguarding Lead without delay.

Do not discuss the matter widely.

Do not alert the subject of the allegation unless advised to do so by the Designated Safeguarding Lead or statutory agencies.

Preserve any relevant evidence, including messages, emails, images, screenshots, attendance records or incident notes.

Take immediate protective action if there is risk of harm.

The Designated Safeguarding Lead, in consultation with directors where appropriate, will make an initial decision about the required response. This may include:

• Taking immediate steps to protect a child, young person or adult at risk
• Contacting emergency services where there is immediate danger
• Seeking advice from the Local Authority Designated Officer where the concern relates to a person working with children
• Referring to children’s social care, adult safeguarding or the police
• Suspending or restricting the person’s duties while advice is sought
• Informing a partner organisation, school or placement provider where appropriate and lawful
• Managing the matter under internal conduct procedures where it does not meet safeguarding thresholds
• Recording a low level concern and monitoring for patterns
• Commissioning an internal investigation only where statutory agencies confirm this is appropriate

Where an allegation involves a person who works with children or young people and may meet the allegations threshold, Street Lights will seek advice from the relevant Local Authority Designated Officer, often known as the LADO.

The LADO should be contacted where an adult may have harmed a child, may have committed an offence against a child, may pose a risk to children, or may be unsuitable to work with children.

Street Lights will follow the advice of the LADO, police, children’s social care or other statutory agencies. Internal action must not interfere with any external investigation.

Suspension is not an automatic response to every allegation. However, Street Lights may suspend, restrict or adjust duties while an allegation is considered, especially where there may be risk to children, young people, adults at risk, staff, volunteers, the public or the integrity of an investigation.

Protective measures may include:

• Temporary removal from direct work with children or young people
• Removal from online groups or communication channels
• Pausing mentoring or outreach responsibilities
• Changing duties or supervision arrangements
• Preventing contact with specific individuals
• Restricting access to records, venues, programmes or social media accounts
• Suspension from role pending further advice or investigation

Street Lights will record and respond to low level concerns because they help build a culture of openness and prevention.

Examples of low level concerns may include:

• Over familiarity with young people
• Inappropriate jokes, comments or language
• Unapproved direct messaging
• Meeting or offering lifts without authorisation
• Sharing personal problems with young people
• Favouritism or special relationships
• Failure to follow agreed boundaries
• Poor judgement in social media use
• Ignoring reporting procedures
• Repeated minor conduct issues
• Low level concerns will be reviewed to identify patterns. Repeated low level concerns may become a safeguarding or disciplinary matter.

Street Lights will treat any person subject to an allegation fairly. The Organisation will avoid assumptions, gossip, public judgement or unnecessary disclosure.

Where appropriate and where it does not compromise safeguarding or an investigation, the person subject to the allegation will be informed of the concern, the process being followed, any restrictions in place, and sources of support.

The Organisation will not allow personal loyalty, status, friendship, community reputation or professional position to influence safeguarding decisions.

Information about allegations must be shared only with those who need to know in order to protect people, manage risk, meet legal duties or carry out a fair process.

Confidentiality cannot be promised where there is a safeguarding risk, criminal concern, risk to the public, regulatory issue or legal duty to share information.

Records must be stored securely and shared in line with the Data Protection Policy, Safeguarding Policy and relevant legal requirements.

All allegations and low level concerns must be recorded clearly and securely. Records should include:

• Date and time of concern
• Name and role of the person making the report
• Name and role of the person subject to the concern
• Name of any child, young person or adult at risk involved
• What was said, seen, heard or disclosed
• The exact words used where possible
• Any immediate action taken
• Who was informed and when
• Advice received from external agencies
• Decisions made and reasons for those decisions
• Protective measures taken
• Outcome and learning points

Where an allegation is investigated, the outcome should be recorded using clear language. Possible outcomes may include:

Street Lights will make external referrals where required. This may include referrals to:

• Children’s social care
• Adult safeguarding services
• The police
• The Local Authority Designated Officer
• The Disclosure and Barring Service where legal criteria are met
• A professional regulator where relevant
• A commissioning body, school or local authority where required by contract or safeguarding duties
• The CIC Regulator or other appropriate body where governance concerns require escalation

Where Street Lights removes a person from regulated activity, or would have removed them had they not left, because they harmed or posed a risk of harm to a child or vulnerable adult, the Organisation will consider its legal duty to refer to the Disclosure and Barring Service.

The Board and Designated Safeguarding Lead will seek appropriate advice where a DBS referral may be required.

Where an allegation involves a person employed or managed by a partner organisation, school, placement provider or contractor, Street Lights will report the concern to the appropriate safeguarding contact within that organisation and will also consider its own safeguarding duties.

Partnership agreements should make clear how allegations, safeguarding concerns, information sharing and escalation will be handled.

This policy applies across all Street Lights delivery settings, including school sessions, mentoring, youth clubs, community events, outreach, online sessions, trips, NEET Futures placements, family education sessions and professional training.

Every activity must have clear reporting routes and named safeguarding contacts. Staff and volunteers must know how to report a concern during delivery and after the activity has ended.

Anyone who raises a genuine concern in good faith must not be bullied, punished, isolated, threatened, removed from opportunities or treated unfairly for speaking up.

If a person believes a concern is being ignored, covered up or mishandled, they should use the Complaints and Whistleblowing Policy and may report externally where appropriate.

Street Lights will consider what support is needed for any child, young person, adult at risk, parent, carer or family affected by an allegation.

Support may include safeguarding referral, signposting, communication with parents or carers where appropriate, emotional support, safety planning, changes to delivery arrangements, or referral to specialist services.

Allegations can affect the wellbeing of staff, volunteers and teams. Street Lights will consider appropriate support for those involved, while ensuring that safeguarding and investigation processes are not compromised.

Support may include supervision, welfare check ins, clear communication, temporary adjustment of duties, and signposting to external support where needed.

After an allegation or serious concern has been concluded, the Board and Designated Safeguarding Lead will review whether there are lessons for the Organisation. This may include changes to training, supervision, recruitment, risk assessment, social media practice, mentoring boundaries, partnership agreements, record keeping or programme design.

Learning will be used to strengthen Street Lights Collective CIC and prevent future harm.

All relevant adults must receive information about this policy during induction and through ongoing training. Staff, practitioners and volunteers must understand the difference between allegations, low level concerns, complaints, safeguarding concerns and whistleblowing.

Managers and directors must ensure the policy is not simply stored, but actively understood and used.

This policy should be read alongside the following Street Lights Collective CIC policies:

• Safeguarding and Child Protection Policy
• Contextual Safeguarding Practice Guidance Policy
• Safer Recruitment Policy
• Code of Conduct Policy
• Complaints and Whistleblowing Policy
• Incident Reporting Policy
• Mentoring and Boundaries Policy
• Online Safety and Social Media Policy
• Photography, Filming and Consent Policy
• Volunteer Policy
• Data Protection Policy
• Risk Assessment Policy
• Anti Bullying and Harassment Policy
• NEET Futures Placement Policy

This policy will be reviewed annually by the Board of Directors and the Designated Safeguarding Lead.

It will also be reviewed sooner if there is a serious allegation, a safeguarding review, a change in law or guidance, a change in organisational activity, or learning from practice.

Street Lights Collective CIC Presence. Power. Purpose.