Safeguarding Policy 

Last reviewed: June 2023 

Next review: Summer 2024  


  1. Definition 
  1. Principles 
  1. Nominated Safeguarding Managers 
  1. DBS Checks 
  1. Rehabilitation of Offenders Act 
  1. BBC Editorial Guidelines 
  1. Online Grooming 
  1. Children of Employees 
  1. School Visits and Events 
  1. Health and Safety 
  1. Transport and Accommodation 
  1. Secure Handling and Safekeeping of DBS Disclosures 
  1. 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.    Principles 

  • 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 HR 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 HR team. 


3.    Nominated Safeguarding Managers 

The Head of People have responsibility for Our Media’s Safeguarding Policy. They are Our Media’s “Safeguarding Managers”. 

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 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. 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. 

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. 

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 for childcare purposes 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.    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. 

10.     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. 

11.     Transport and Accommodation 


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. 


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. 


12.     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 HR 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 the appropriate HR Business Partner 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. 


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. 


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. 


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. 


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. 
  1. 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. 
  1. Everyone who works for Our Media will demonstrate proper personal and professional behaviour at all times during their work. 
  1. Everyone who works for Our Media will behave responsibly during work-related social events, especially if children are present. 
  1. 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. 
  1. 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. 
  1. 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. 
  1. 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. 
  1. 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. 
  1. Inappropriate or illegal behaviour will be treated extremely seriously and will result in action being taken in accordance with Our Media’s disciplinary policy. 


 Our Media Safeguarding Managers: 

Hannah King, Head of People, , +44 117 300 8271