Our Media Policies

Safeguarding Policy 

Last reviewed: Sept 2024 (EB)

Next review: Autumn 2025

OUR MEDIA SAFEGUARDING MANAGERS:

CONTENTS:

1.     DEFINITION

2.     GENERAL OVERVIEW

3.     NOMINATED SAFEGUARDING MANAGERS

4.     DBS CHECKS

5.     REHABILITATION OF OFFENDERS ACT

6.     BBC EDITORIAL GUIDELINES

7.     ONLINE GROOMING

8.     CHILDREN OF EMPLOYEES

9.     PHOTOSHOOTS

10.   SCHOOL VISITS AND EVENTS

11.   HEALTH AND SAFETY

12.   TRANSPORT AND ACCOMODATION

13.   SECURE HANDLING AND SAFEKEEPING OF DBS DISCLOSURES

APPENDIX – SAFEGUARDING: BEHAVIOURAL GUIDELINES

1. DEFINITION

Our Media Limited (“Our Media”) is committed to safeguarding the welfare of all children and young people who are involved, in any way, with Our Media’s work. The guidelines and procedures set out in this policy will apply equally to any vulnerable adults involved in Our Media’s work, and any reference to a child or a young person should be read as a reference to a vulnerable adult also.

Our Media is committed to safeguarding the welfare of all children and young people who are involved in any way with Our Media’s work. Our guidelines and procedures are laid out in our Safeguarding Policy, which also applies to vulnerable adults. If you believe that a child, young person or vulnerable person may be at risk of harm or you believe that a person may pose a risk of harm to any child, young person or vulnerable person, you should discuss your concern with one of Our Media’s Safeguarding Managers as soon as possible.

2. GENERAL OVERVIEW

  • Children and young people should be treated with care, respect and dignity. For the purposes of the Disclosure and Barring Service (and previously the Criminal Records Bureau), a child is defined as someone who is under 18 (or under 16 if the child is employed). Our Media also uses this definition. 
  • Everyone who works for or with Our Media, in any capacity, has a responsibility for the protection and welfare of the children and young people we meet in our work. We know that people who work for Our Media will be perceived by children and young people as trustworthy.  
  • Our Media acknowledges that some of its employees may be or become vulnerable adults. Where this is the case, Our Media will carry out appropriate risk assessments and implement any adjustments necessary to ensure that they can work safely. 
  • Our Media’s staff should never be alone with a child or young person in the course of their work and any activity with children and young people should be planned accordingly. Our Media’s Safeguarding Behavioural Guidelines form part of this document and must be followed by all staff. 
  • Any offer of work made by Our Media in respect of a position which may involve working with children, young people or vulnerable people will be subject to a satisfactory DBS (formerly known as a CRB) check. This applies to individuals engaged on any type of contract (e.g. employment, casual or freelance contracts). 
  • A risk assessment should be carried out whenever children, young people or vulnerable people undertake activities with Our Media. Speak to the Facilities Manager to arrange for a risk assessment to be performed. 
  • Children and young people may not carry out paid work for Our Media unless they have an appropriate work permit – our People Team can advise you further. 
  • Managers offering work experience placements must do so in compliance with Our Media’s work experience policy. Please refer any questions to the People Team. 

3. NOMINATED SAFEGUARDING MANAGERS

Our Media’s “Safeguarding Managers”have responsibility for Our Media’s Safeguarding Policy. They are:

They will: 

  • Ensure that Our Media’s staff are aware of the requirement to work in compliance with Our Media’s Safeguarding Policy. 
  • Be the point of referral for questions in relation to Our Media’s Safeguarding Policy. 
  • Be the point of referral for anyone who, during the course of their work for or other involvement with Our Media, believes that a child or young person may be at risk of harm, is told by a child or young person of a child welfare issue; or believes that a person may pose a risk of harm to any child. 
  • Keep a record of any safeguarding issues which arise. 

4. DBS CHECKS

If your job requires you to work with children in any capacity, whether during a photo shoot, a focus group, or in another setting, you will need to have a DBS check. The type of check required depends on a few factors, so we’ll speak to you on your specific circumstances when the need arises.  

Per our Safeguarding Policy, no employee or freelancer should ever be left alone with a child or young person during activities organised by Our Media. They must always be accompanied by a parent, legal guardian, or an approved licensed chaperone. Please speak to your relevant contact (such as the modelling agency in the case of photo shoots) to ensure this is possible for your planned project or event.  

Please note, if you are running a project that involves vulnerable adults, the process is slightly different. Please get in touch with the People Team as soon as possible so we can ensure the correct process is followed.  

Risk Assessment 

If an individual requires a DBS check to be carried out for their role and begins work with Our Media before a satisfactory DBS check is received, their manager must, with input from the Safeguarding Managers, complete a risk assessment (available on Our Zone). Such a risk assessment is likely to mean that the individual will be placed on restricted duties and cannot work unsupervised with children or young people.  

The individual’s manager will be responsible for ensuring a plan is in place in respect of these restricted duties and this will be authorised by a more senior manager. If restricted duties are not possible, the individual will not be allowed to start work with Our Media.  

DBS Check Process for Employees 

When planning a project that will involve children, please inform the People Team of the plan as soon as possible, a minimum of 3 weeks before the date the project, event, or shoot involving children is due to start.  

A member of the People Team will ask you about the type of work you will be doing, how often you will be interacting with children across the project, and whether you have any unspent convictions. This is so we can ascertain what kind of DBS check is needed for your specific circumstances.  

We will then create a profile for you on our DDC (Due Diligence Checking) company profile. You will be invited via email to complete your profile and to submit the types of documents you will be using to process your DBS check request. DDC will advise you on the types of documents needed.  

Once submitted, DDC will inform the People Team that you are ready for the document checking stage. You will need to arrange a time with a member of the People Team to come into the office and have your original documents checked in person. This should only take 5 or so minutes.  

Once your documents have been checked, DDC will proceed with processing your request. The length of time this will take depends on the type of check requested. If the check is successful, the People Team will be informed over email and your certificate confirming the check will be sent to your home address.  

DBS Check Process for Freelancers 

Anyone who we engage with who is required to work with children while working for us will also need to have a DBS check, or will need to already have an in-date DBS certificate.  

When engaging with freelancers and briefing them on a project that involves children, you will need to inform them that we will require a DBS certificate before they are able to work with us on that project. In some instances, they may already have a DBS certificate. If they do not, then we will need to confirm further details on the type of work they typically do as a freelancer outside of their work for us before processing the check.  

Please speak to the People Team as soon as possible to discuss specific details before confirming work involving children with any freelancers. 

Missing or Unconfirmed DBS Checks 

Activities cannot proceed until all necessary DBS checks are completed and confirmed. You are able to refuse a DBS check, but if that occurs then you will not be able to participate in the parts of the project that involve working with children. Please let us know if you have any questions or concerns about the process.  

DBS Check Renewal Process 

Before working on a project or activity that involves working with children, please check whether your DBS certificate is currently in date. If you’re not sure, please get in touch with the People Team.  

Our company policy states that DBS checks are valid for one year. A new check will be required if you are due to start a new activity or project involving children and more than a year has passed since your most recent check. 

Finally, DBS checks should only be requested for individuals who are confirmed to participate in an activity; they should not be conducted randomly. 

If you have any further questions on the DBS check process, please contact Lizzie or the People Inbox. 

5. REHABILITATION OF OFFENDERS ACT

In most circumstances, individuals who are convicted of offences are regarded as “rehabilitated” after a defined period of time and at that point, their conviction is said to be “spent”. Normally, once a conviction is spent, the convicted person does not have to reveal or admit its existence and the conviction is treated as though it had never occurred. However, where an individual is required to work with children, young people or vulnerable people, all convictions (whether spent or unspent) will be disclosed by the DBS. 

6. BBC EDITORIAL GUIDELINES

 Employees working on BBC-branded titles must also be compliant with the BBC’s Editorial Guidelines which set out the BBC’s editorial values and cover all aspects of working with children, including safeguarding the welfare of children. You can access the BBC Editorial Guidelines here – https://www.bbc.co.uk/editorialguidelines/

7. ONLINE GROOMING

Any concerns you have that a child or young person may be being “groomed” online must be referred immediately to the Safeguarding Managers. Please note that the BBC’s Editorial Guidelines also include specific advice about suspected online grooming..

8. CHILDREN OF EMPLOYEES

We recognise that Our Media’s employees may bring their children to Our Media’s premises in exceptional circumstances. If it is necessary for you to bring your children to the office, you must have the permission of your manager and your children must remain under your direct supervision at all times. 

9. PHOTOSHOOTS

When organising a photoshoot involving children or young persons, you must ensure you follow the following steps:

  • Risk Assessment – Complete a risk assessment early in the planning process. For further details, refer to the Health and Safety section of this policy.
  • DBS Checks – All individuals who’ll be present at the shoot are required to undergo DBS checks. This includes any external contributors such as photographers or stylists. You must inform them of this requirement when arranging their participation and obtain their consent for the DBS check. The photoshoot cannot not proceed until all DBS checks have been completed. If any contributor refuses to undergo the check, they will be unable to participate in the photoshoot. The Safeguarding Manager will conduct these checks on your behalf, please ensure you notify them well in advance of the photoshoot to allow time for completion.
  • Supervision – It is your responsibility to ensure that children and young people are supervised by a parent, legal guardian, or an approved licensed chaperone, and that separate toilet and dressing facilities are provided for them, away from adults and the public. Our Media staff should not be responsible for supervising children or young people at any point during the photoshoot. Under no circumstances should anyone from Our Media or affiliated with Our Media (e.g. photographers/stylists) be alone with a child or young person during the shoot.
  • Informing everyone about Our Media’s Safeguarding Policy – You should distribute Our Media’s Safeguarding Policy to all attendees before the shoot.

10. SCHOOL VISITS AND EVENTS

 If your team’s work involves a visit to any nursery, school, youth group or similar establishment, you must send the school or event organisers a copy of Our Media’s Safeguarding Policy before the visit or event. At an early stage in the planning of any such visit or event, you must ensure that you have contact details for a nominated person from the school or event organisers who holds responsibility for safeguarding the welfare of children and young people during with the activity (the “Safeguarding Contact”). 

  • Our Media’s staff attending any visit or event must do so in full compliance with this Safeguarding Policy, and Our Media’s Safeguarding Behaviour Guidelines. 
  • Any member of Our Media’s staff who, through the course of their work, becomes concerned about the welfare of a child must share that concern immediately with the Safeguarding Contact, or if that is impossible, with Our Media’s Safeguarding Managers. 
  • If the notification is made directly to the school, the staff member who makes the notification should follow up immediately on their return to the office with Our Media’s Safeguarding Managers. 

11. HEALTH AND SAFETY

 Any activity which involves a child or young person must be subject to a risk assessment. The Facilities Manager can arrange for a risk assessment to be performed. 

The risk assessment must set out what arrangements are in place for their care and supervision e.g. by a school, parent, guardian or chaperone and how these will be communicated to the appropriate parties. 

The health and safety controls in place will include those needed for: 

  • the people the children or young person will meet; 
  • the environment they will be in; 
  • the equipment they will be using; 
  • the activity they will be doing; 
  • the way the activity will be organised and carried out; 
  • the pattern and hours of their activity; and 
  • any transport arrangements. 

12. TRANSPORT AND ACCOMODATION

Transport 

If children are being transported on behalf of Our Media, they must be accompanied by their parent, guardian, chaperone or teacher. Our Media has a duty of care for young persons between the minimum school leaving age and under 18 if they are travelling on behalf of Our Media. 

Accommodation 

If any Our Media activity requires a child or young person to stay away from home overnight, the arrangement must first be approved by Our Media’s Safeguarding Managers. The child or young person must be accompanied by their parent or guardian. 

13. SECURE HANDLING AND SAFEKEEPING OF DBS DISCLOSURES

General principles  

Our Media complies fully with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of DBS disclosures (each a “Disclosure”) and Disclosure information. Our Media also complies fully with its obligations under the Data Protection Act 1998 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information. 

Storage and access 

Hard copies of DBS information are kept securely in locked cabinets by the People Team team for the periods of time detailed in the ‘Retention’ paragraph below. 

In most cases, Our Media will keep an electronic record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was requested, the unique reference number of the Disclosure and the details of the recruitment or other decision taken. These electronic records are password-protected and access will be restricted to Our Media’s Safeguarding Managers and an appropriate member of the People Team for your division of the business. These records will be retained until either you leave the business or your DBS record is updated by making a subsequent check. 

Handling 

Disclosure information is only passed to those who are authorised to receive it in the course of their duties. Our Media recognises that it is a criminal offence to pass this information to anyone who is not entitled to receive it. Our Media maintains a record of all those to whom Disclosures or Disclosure information has been revealed. 

Usage 

Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given. 

Retention 

Once a recruitment (or other relevant) decision has been made, Our Media will shred the disclosure certificate unless there is a reasonable likelihood of the decision being disputed, in which case it will keep a hard copy of the certificate until the dispute has been resolved. The maximum period for which certificates would be retained is in accordance with the applicable data protection legislation. 

If, in very exceptional circumstances, Our Media considers it is necessary to keep hard copies of this information for longer than six months, Our Media will consult the DBS and consider the data protection and rights of the individual before doing so. Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will prevail. 

Disposal 

All records will be deleted or destroyed securely (for example, by shredding) when they are no longer required or the prescribed retention period has elapsed.

 

APPENDIX – SAFEGUARDING: BEHAVIOURAL GUIDELINES

  1. Everyone who works for Our Media in any capacity (including all staff and anyone working for Our Media on a freelance or casual basis) will follow all of these Behavioural Guidelines whenever their work brings them into contact with children, young people or vulnerable people. All references to “child” or “children” in these Behavioural Guidelines should be read as a reference to children, young people and vulnerable people. 
  2. Everyone who works for Our Media has a duty to promote open, honest, trustworthy and respectful relationships with the people we meet in the course of our work. 
  3. Everyone who works for Our Media will demonstrate proper personal and professional behaviour at all times during their work. 
  4. Everyone who works for Our Media will behave responsibly during work-related social events, especially if children are present. 
  5. Everyone who works for Our Media will work in an open environment, avoiding private or unobserved situations with children and encouraging open communication with no secrets. We will ensure that the child is accompanied by a parent or guardian and wherever possible, all activities will take place in open-plan environments. If an activity has to happen in a room rather than an open-plan space, no adult should ever be left on his or her own with any child or children – two adults should always be present. If an emergency means that an adult is left alone with any child or children, the door to the room must remain open at all times. 
  6. Anyone working with children as part of their role with Our Media will maintain a safe and appropriate distance at all times. We will engage in the minimum of physical contact with the child, and any necessary physical contact will be public and appropriate. Our Media staff will not do things of a personal nature for any child that s/he is able to do independently. 
  7. Our Media’s staff will not engage children in discussions relating to personal matters (including any discussion of problems at home or emotional issues). Where discussion of a personal matter is the subject of the activity (for example, interviewing the subject of a real-life story for a pre-teen magazine), we will ensure that a parent, guardian or teacher is present throughout the discussion. 
  8. If a child shares concerns with us, we will listen, stay calm, be reassuring, avoid judgements and we will never promise to keep the disclosure secret. We will then make an immediate report to an appropriate person – either the nominated Safeguarding Contact from the child’s school or similar, or to one of Our Media’s Safeguarding Managers. We will not share the child’s disclosure with any other person. 
  9. Our Media’s staff will respond appropriately to all concerns about a child’s welfare, escalating the matter promptly in accordance with Our Media’s Safeguarding Policy. 
  10. Inappropriate or illegal behaviour will be treated extremely seriously and will result in action being taken in accordance with Our Media’s disciplinary policy.