Photofusion Safeguarding Policy
Protecting Children and Vulnerable Groups
Date of Next Review: August 2025
1.Introduction
Photofusion is committed to the protection and safety of children and adults who come into contact with Photofusion as visitors to the galleries, as participants in Photofusion activities, and online. This commitment to safeguarding requires that appropriate procedures are in place and that Photofusion maintains consistent vigilance over these.
This policy sets out principles regarding Photofusion’s duty of care toward helping to protect children and adults who fall under the definition of regulated activity and to support staff and volunteers who have responsibility for these groups. This policy is consistent with the Health, Safety and Welfare Act 1974, the Protection of Children Act 1999, the Children Act 2004, the Safeguarding Vulnerable Groups Act 2006, the Safeguarding Vulnerable Groups Order (Northern Ireland) 2007 and the Protection of Freedoms Act 2012.
2. Scope of the Policy
For the purposes of this policy, the following definitions apply and are consistent with the guidance published by HM Government following the introduction of the Protection of Freedoms Act 2012, which amended the Safeguarding Vulnerable Group Acts 2006.
This policy applies to all people working at Photofusion site in whatever capacity
(employee, casual worker, volunteer, freelancer, agency worker or contractor).
2.1 Regulated activity relating to children
A child is any person up to the age of 18. Regulated activity relating to children comprises:
• Unsupervised activities: teaching, training, caring for or supervising children; driving a vehicle solely for children; providing advice/guidance on well-being
• Work for a limited range of establishments where there is opportunity for contact (for example children’s homes, schools, childcare premises). This does not include supervised contact by volunteers.
Work undertaken in the two categories above is only a regulated activity if it is done regularly.
2.2 Regulated activity relating to adults
Regulated activity in relation to adults no longer refers to ‘vulnerable adults. The focus is on the type of care that the adult requires, rather than the setting within which the adult receives that help. There is no longer a requirement for an activity to be carried out a certain number of times before it is categorized as a regulated activity.
Six categories of people fall within the definition of those carrying out a regulated activity. In addition, anyone supervising those in these six categories falls within the definition. The categories are:
• Those providing health care.
• Those providing personal care (for example help with washing and feeding).
• Those providing social care.
• Those providing assistance with handling cash, paying bills or shopping.
• Those assisting a person in his/her personal management of his/her affairs.
• Those who transport an adult because of their age, illness or disability from their place of residence to a place where they are receiving health or social care. This does not include taxi drivers or family and friends.
As a result of the changes to the definition of regulated activity relating to adults we now have no roles at Photofusion that undertake this type of regulated activity. However, employees may find themselves in settings where adults are deemed vulnerable (eg working with adults in care homes) and therefore adults are still referred to throughout this policy. References to ‘vulnerable adults’ throughout the rest of this document should be read in the context of the new definition of regulated activity relating to adults.
2.3 Abuse and Neglect
Somebody may abuse or neglect a child or vulnerable adult by inflicting harm, or by failing to act to prevent harm. Children and vulnerable adults may be abused in a family or in an institutional or community setting; by family members, those known to them or, more rarely, by a stranger.
2.4 Physical Abuse
Physical abuse is any intentional physical contact that results in discomfort, pain or injury. Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child or vulnerable adult. It may also involve inappropriate/unauthorised methods of restraint.
2.5 Emotional Abuse
Emotional abuse is the persistent emotional ill-treatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It includes grooming, harassment and inappropriate emotional involvement.
2.6 Sexual Abuse
Sexual abuse involves forcing or enticing a child or vulnerable adult to take part in sexual activities, whether or not they are aware of what is happening.
2.6 Neglect
Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s or vulnerable adult’s health or development.
2.7 Financial and Material
This could involve theft, fraud, exploitation or the misuse of property, possessions or benefits.
2.8 Discrimination
This may include racist, sexist, ageist, homophobic, religious or disability related and other forms of harassment.
2.9 Cause for Concern
Cause for concern means that a person may become aware that a child or vulnerable adult is suffering or is at risk of suffering harm, abuse or neglect through recognising signs of abuse.
Statement of Principles
3.1 Photofusion will seek to actively promote the well-being and empowerment of children and vulnerable adults through the services we provide.
3.2 In line with Photofusion’s Safer Recruitment Policy, all people working for Photofusion in any capacity, including casual workers, interns, contract staff and volunteers, will be security checked in accordance with the requirements of the Cabinet Office Baseline Security Standard. Those who have particular roles and responsibilities which involve working directly with children, young people or adults carrying out regulated activity will be required to have a satisfactory Disclosure and Barring Service (DBS) Enhanced Disclosure and a check to be made against the barring list for children and/or adults, as appropriate.
3.3 All employment recruitment advertisements, recruitment packs and induction packs, and any print or online employment information that relates to roles which are required to work with children, young people and adults and undertake regulated activity will include the statement: ‘Photofusion operates a Policy for the Protection of Children and Vulnerable Adults and successful applicants will be subject to a satisfactory Enhanced DBS Disclosure and a check against the barred list for children and/or adults, as appropriate. For further information please refer to
https://www.gov.uk/disclosure-barring-service-check/overview’.
3.4 In instances where freelancers, volunteers or contractors are undertaking activities with children or adults that come under the definition of regulated activity they will also be subject to the same enhanced vetting checks required of Photofusion’s employees.
3.5 In so far as possible, staff will avoid situations in which they are alone or in isolated one-to-one situations with children or vulnerable adults. All working practices should occur in open spaces, in front of others in an ‘open door’ environment.
3.6 Appropriate risk assessments will be carried out to ensure the protection of children and vulnerable adults taking part in Photofusion activities.
3.7 Any staff that come into contact with a child or vulnerable adult, and believe that they have cause for concern, should follow the reporting procedures outlined in Photofusion’s ‘Guidelines for Staff in Protecting Children and Vulnerable Groups’ (see Appendix 1
3.8 Photofusion have a Designated Safeguarding Officer (DSO) who will act as the first point of contact for staff and volunteers for advice if they are concerned about a child or vulnerable adult. The DSO will review Photofusion’s Safeguarding policies and procedures. The DSO will be provided with appropriate training to equip them with the knowledge and awareness to carry out their role.
3.9 The DSO will be responsible for ensuring Photofusion’s Safeguarding policy and procedures are up-to-date, mechanisms are in place to communicate and raise awareness about safeguarding issues and that those with specific responsibilities with regard to safeguarding receive appropriate training. They will also be responsible for ensuring that incidents are dealt with and reported appropriately and records of any concerns reported are maintained and stored securely.
3.10 If there is an allegation against a member of staff working at Photofusion, the procedures outlined in Section 7 of the London Child Protection Procedures
(www.londoncp.co.uk) will be followed. The alleged perpetrator may be subject to suspension from work and subsequent disciplinary action.
3.11 Photofusion will take additional safety measures, over and above those required of the Data Protection Act, to ensure children’s and vulnerable persons’ safety on Photofusion’s online channels. Photofusion will not disclose Children’s real name and location online.
3.12 Inductions materials for new staff will include reference to Photofusion’s procedures for the protection of children and vulnerable adults and appropriate awareness raising and training provided to staff.
Appendix 1 – Guidance for Staff in Protecting Children and Vulnerable Groups
1 Introduction Photofusion’s Safeguarding Policy defines and outlines the principles regarding Photofusion’s duty of care toward helping to protect children and adults who fall under the definition of regulated activity (referred to in this document as ‘vulnerable adults’) and to support staff and volunteers who have responsibility for these groups.
This guidance is supplementary to Photofusion’s Safeguarding Policy and provides additional information, guidelines, and procedures to staff to help ensure the protection of children and vulnerable adults at Photofusion.
2 Cause for Concern
In so far as possible, staff must avoid situations where they are alone or in isolated one-to-one situations with children or vulnerable adults. All working practices should occur in open spaces, in front of others in an ‘open door’ environment.
In the course of their work for Photofusion, staff may come into contact with children or vulnerable adults where allegations of abuse may be revealed. If staff are worried that a child or vulnerable adult is at risk, they are deemed to have ‘cause for concern’.
‘Cause for concern’ means that a member of Photofusion staff may become aware that a child or vulnerable adult is suffering or is at risk of suffering harm, abuse or neglect through recognising signs of abuse detailed below. Abuse can be carried out by young people as well as adults.
An allegation of abuse may come to light through the following situations:
• A child or vulnerable adult tells you about a worry or concern they have.
• You see or notice changes in a child or vulnerable adult’s behaviours or moods
• You see obvious physical signs of abuse or neglect.
• Someone else tells you about something they have seen or heard.
• An adult or another child tells you that they themselves may have harmed a child or vulnerable adult or that they are having difficulties with them.
• You see worrying behaviours from an adult, carer or another young person towards a child or vulnerable adult.
• You know something personal about an individual that causes you to be concerned about a child or vulnerable adult’s behaviour.
• A parent or carer shares information with you that they are having difficulty in meeting their child or dependent’s needs.
• A member of staff raises concerns about a colleague (this could be done informally or through the Whistle Blowing Policy).
In order that staff are supported and encouraged to act if they have ‘cause for concern’ a reporting structure is in place.
3 Reporting Structure
Any staff that come into contact with a child or vulnerable adult, and believe that they have cause for concern that the child or vulnerable adult may be the subject of abuse or neglect, should report this immediately to their line manager, or Photofusion’s Designated Safeguarding Officer (DSO). The current DSO is Jasmine Bell.
Line managers who receive a report of a potential safeguarding issue should report this to the DSO. The DSO will be responsible for ensuring that appropriate action is taken including reporting the incident to the relevant Local Authority Designated Officer
(LADO) and/or the Police if appropriate.
When receiving an allegation from a child or vulnerable adult, the following guidelines should be adhered to in order to ensure their future protection:
• Listen to the victim
• Never stop a child who is freely recalling significant events, but don’t push the child to tell you more than s/he wishes.
• Tell the victim you are taking what they are expressing or saying seriously.
• Reassure the victim that they are right to talk to someone.
• Do not attempt to interview the victim, although it may be necessary to clarify with them what they are saying.
• Do not promise confidentiality to the victim. Tell the victim you will need to talk to someone who can help.
• Write an account of the conversation immediately using the Safeguarding Incident Report Form (see Appendix b) and send this to the DSO.
4 Photofusion Guidelines
The following Guidelines are specific to Photofusion’s operation and programmes. They cover:
• Group visits
• Projects and Events
• Exhibitions
• Online
4.1 Group Visits
On entry to Photofusion it is the responsibility of staff to identify the group leaders and confirm their responsibility for the supervision of the young people and vulnerable adults in their care at all times.
• In all cases staff should avoid one-to-one situations with children and vulnerable adults.
• In cases of a first aid incident in addition staff should refer to the relevant Front of House procedures.
• In the case of an incident of a lost child staff must stay in a public area and call for assistance by radio or telephone.
• Staff should report any concerns to the Duty Manager.
The first contact for targeted group visits is by telephone or email to the Community Programmes team.
• Community Programme staff will inform teachers and group leaders verbally and will send written information and Guidelines for Group Visits. These guidelines should refer to Photofusion’s Health and Safety Policy and Safeguarding Policy.
• Where appropriate this may be followed up by a conversation with the relevant Community Programme staff in order to meet any particular special needs.
• Information on the content of exhibitions, displays and activities will be conveyed verbally and in written form sent to the teacher or group leader.
Where it is felt that there is a specific protection issue, teachers and group leaders will be informed. In these instances teachers and group leaders will be encouraged to:
• Visit the gallery to assess the risk in order to make informed choices about their proposed group visit.
• Undertake a planning visit session with staff to ensure content and themes are discussed and risk assessed.
4.2 Projects and Events
In devising and planning talks and workshops for groups, staff and artist educators will ensure that the protection of children and vulnerable adults is included in the risk assessments relating to the activity. Risk assessments will be available for teachers and group leaders on request.
Where projects are planned by the Community Programme Team, either independently or with external partners, a full risk assessment of the project should be undertaken. This assessment will include assessment of content, processes, staffing,
parental/adult supervision, use of photography/other media and appropriate behaviour.
Photofusion is not in a position to assume a duty of care directly over children and young people. The duty of care for children and young people should remain at all times within the sphere of responsibility of parents, teachers, carers or guardians.
Staff should only carry out risk assessed activities. Any changes should be agreed with Learning Curators and relevant senior management and a new risk assessment carried out. These risk assessments should:
• Be clear about roles and responsibilities of staff and accompanying adults.
• Ensure parental/teacher/group leader supervision at all times.
• Ensure an appropriate staff to child ratio.
• Gain parental/teacher/group leader consent for all photography/other media.
4.3 Admissions to Exhibitions
On entry to the galleries it is the responsibility of staff to be observant and be prepared to ask an unaccompanied child, if appropriate, whether they are accompanied by an adult. In the case of vulnerable adults staff should to ask, if appropriate, whether that person has or needs personal support. Staff should assess all situations sensitively and act accordingly, treating visitors with respect while recognising that the child or vulnerable adult’s welfare is paramount. If there is any cause for concern the staff member should report this to the Duty Manager. The lower age limit for unaccompanied children visiting the gallery is 12 years old.
Where there is an identified protection issue in terms of the content of Exhibitions or Displays a risk assessment will be undertaken during the planning process.
Where there is an issue Photofusion will take responsibility for informing visitors of the specific content through the appropriate channel from the following list:
• Front desk staff
• Community Programmes Team
• Printed information
• Information for teachers and group leaders
• Signage
• Information on the Photofusion website
4.4 Online & E-Safety
We have policies in place to ensure that any data we capture on our users is held in accordance with the Data Protection Act.
Photofusion Digital engages with audiences on a range of third party social media platforms to encourage engagement and participation. We are committed to a range of guidelines to protect participants and foster positive digital communities. We provide guidance and training to all staff and artists we invite to engage with young people online. We will moderate responses across all social media channels as far as the platforms’ built-in tools allow
With regard to children, Photofusion will have additional measures in place to ensure their safety online. This includes restricted internet access on computers accessed by children and young people.
Staff will
• Have an up to date awareness of online safety matters and of the Photofusion’s online safety policy and practices
• Report any suspected misuse or problem to the senior staff or director for investigation/action.
• Ensure that all digital communications with students/parents/carers should be on a professional level and only carried out using official systems
• Support young people understanding and following the Online Safety Policy and acceptable use policies
• Monitor the use of digital technologies, mobile devices, cameras, etc. in planned sessions and other activities.
• Guide young people to sites checked as suitable for their use and that processes are in place for dealing with any unsuitable material that is found in internet searches
• Be aware of the potential for serious child protection/safeguarding issues to arise from:
o Sharing of personal data
o Access to illegal/inappropriate materials
o Inappropriate on-line contact with adults/strangers
o Potential or actual incidents of grooming
o Online-bullying
• Inform young people about the importance of reporting abuse, misuse or access to inappropriate materials and know how to do so.
E Learning and Online Delivery
E- safety will be embedded into all teaching and learning so that learners know how to stay safe online. All learners will receive a safeguarding induction at the beginning of the course providing information on safeguarding processes for the project.
• The email or personal website addresses of children or vulnerable adults should not be disclosed by staff under any circumstances and are not to be used to make contact with those individuals except for approved professional purposes.
• Material submitted by children or vulnerable adults to the organisational website should be treated in the same way as photographs (see point above), i.e. any information which could be used to identify or trace individuals should be withheld unless written permission is obtained.
• Contributors of user generated content (UGC) are made aware of any content that is personal and likely to put people at risk.
4.41 Moderation
All content relating to children and young people on the Photofusion website or social media channels will be pre-moderated to ensure it is suitable. Photofusion does not tolerate online bullying. If we find bullying occurring Photofusion will step in and remove comments.
5 Photofusion’s Responsibility in Relation to Children and The Licencing Act 2003
Item 4 of the Licensing Act 2003 places specific responsibility on Photofusion for the welfare of children on its premises.
The licensing objectives are:
1. Prevention of crime and disorder
2. Public safety
3. Prevention of public nuisance
4. Protection of children from harm
Accordingly, the sale of alcohol to minors is prohibited. Photofusion does not permit smoking anywhere on the premises and does not sell tobacco products. There is no gaming or gambling on site.
6 Insurance
Photofusion has Employer’s Liability Insurance is no less than £10 million pounds. This is renewed annual, and is currently held with Towergate. Photofusion has Public Liability Insurance with Towergate with a limit of indemnity at £2million.
7 Recruitment, Induction and Training
All staff working for Photofusion in any capacity including casual workers, interns, contract staff and volunteers are security checked in accordance with the requirements of the Cabinet Office Baseline Security Standard. Those who have particular roles and responsibilities involving directly working with children, young people and adults carrying out regulated activity will be required to have a satisfactory Disclosure and Barring Service (DBS) Enhanced Disclosure and a check to be made against the barring list for children and/or adults, as appropriate.
All employment advertisements, recruitment packs and induction packs and any print or online employment information that relates to roles which are required to work with children, young people and vulnerable adults and undertake regulated activity will include the statement: ‘Photofusion operates a Policy for the Protection of Children and Vulnerable Adults and successful applicants will be subject to a satisfactory Enhanced DBS Disclosure and a check against the barred list for children and/or adults, as appropriate. For further information please refer to https://www.gov.uk/disclosure-barring-service-check/overview.
Inductions for new staff will include reference to Photofusion’s procedures for the protection of children and vulnerable adults. All volunteers, freelancers, interns and casuals will be made aware of Photofusion’s Safeguarding policy and associated procedures.
Photofusion will adopt a tiered approach to training. Awareness training will be provided to front of house employees and for those working in departments and teams that undertake regulated activity, ie Community Programmes. The Designated Safeguarding Officer will receive specific training tailored to their role.
If you have any further questions about Photofusion’s Safeguarding Policy, or the protection of children and vulnerable adults at Photofusion, please contact your line manager.
8. Epidemic or Pandemic
In situations, for example caused by Coronavirus (COVID-19) Photofusion will follow the government guidelines and understand that the guidelines will be subject to change. Unless classified as an essential service, Photofusion will remain closed until instructed otherwise, to ensure that staff volunteers and young people remain safe.
If staff or volunteers were working remotely during an outbreak, as experienced with COVID-19, they will:
• Continue to process and store personal information in line with our Data Protection policies.
• Not use personal devices to communicate with young people, store personal information on personal devices or download and use apps onto work or personal devices (phones/laptops/tablet computers) without express authorisation from senior staff
9. Prevent
Government published the Prevent Strategy in 2010 and this raised awareness of the need to safeguard young people and extremism and radicalization. The Government in the Prevent Strategy as defines extremism:
Vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas.
At Photofusion we understand that our Prevent policy is keeping the young people safe and keeping them within the law.
Staff will respond to suspicions by making a referral to Lambeth Prevent Duty.
Our Health & Safety policy, set out in a separate document, reflects the consideration we give to the protection of young people both physically within Photofusion, including internet use and prevent as well as when on offsite activities
1. Reporting – Contacts & Numbers
198 Designated Lead - Kareen Williams 020 7978 8309 kareen@198.org.uk
Photofusion Designated Lead - Jenni Grainger 020 7738 5774 jenni@photofusion.org
Police - Brixton Police Station 020 7326 1212
Lambeth Children’s Social Care - 020 7926 5555, out of hours emergency: 020 7926 1000 dutymanager@lambeth.gov.uk
NSPCC Child Protection Helpline - 0808 800 5000