WCGBA CHILD PROTECTION
POLICY
WELSH CROWN GREEN
BOWLING ASSOCIATION
PROTECTING CHILDREN
and THE VULNERABLE
Children Learn what they Live
If
a child lives with criticism
He learns to condemn
If
a child lives with hostility
He learns to fight
If
a child lives with ridicule
He learns to be shy
If
a child lives with shame
He learns to feel guilty
If
a child lives with tolerance
He learns to be patient
If
a child lives with encouragement
He learns confidence
If
a child lives with praise
He learns to appreciate
If
a child lives with fairness
He learns justice
If
a child lives with security
He learns to have faith
If
a child lives with approval
He learns to like himself
If
a child lives with acceptance and friendship
He learns to find love in the world.
Contents
1 Introduction
1.1
National Governing Bodies (NGBs) and Joint Panel for the Protection of Children
and Vulnerable Adults
1.2 Policy
Statement
1.3 Aims and
Objectives
1.4 Principles
2
Definitions
2.1 What is
a
child?
2.2 What is
a vulnerable
adult?
2.3 Relevant
legislation and guidance (England and
Wales)
3
What is
Abuse?
3.1 Forms of
Abuse
3.2 What is
child
abuse?
3.3 Abuse of
a vulnerable adult
4
Bullying
5
Race and Racism
6
Recognition of
Abuse
6.1 Symptoms
of abuse and indicators
6.2 Acting
on something an individual says
6.3 Acting
on suspicions or
allegations
7
Promoting Good Practice with Children and Vulnerable
Adults
7.1 What is
Good Practice?
8
Responding to Complaints
8.1 Dealing
with complaints where a child or vulnerable adult is involved
8.2
Responding to suspicions or
allegations
9
Disciplinary Procedures and
Appeals
9.1
General
9.2
Process
9.3 Policy
re previous
misdemeanours
10
Guidance for Associations and
Clubs
10.1
General
10.2 The
role of Child Protection Officers
(CPOs)
10.3
Associations and
Clubs
10.4 How
to
begin
10.5 What
next?
10.6
Recruitment
10.7
Recruitment of Ex-Offenders – Statement of Policy
10.8
Forms
10.9
Training
10.10 Adoption of
Policy and Constitution changes
10.11 Why does Bowls
need a Child and Vulnerable Adult Protection Policy?
10.12 Anything
else?
11
Club policy and procedure
12
Parental Involvement
13
Photography and Dealing with the Media
13.1
Guidelines for Use of Photographs at Sporting Events
13.2
Dealing with the Media
14
Transport
15
Criminal Record Bureau (CRB) and Personal Disclosures
15.1
Criminal Record Bureau (CRB)
15.2
Personal Disclosures
16
Code of Behaviour for those involved with Children and Vulnerable Adults
17
Implementation and
Monitoring
17.1
Implementing
policy
17.2
Monitoring
18
Child Protection – some frequently asked questions
Appendixes
Strategies to combat
Bullying (Appendix 1)
A1.1 Bulling –
the facts
A1.2 If you’re
being bullied right now, what do you do?
A1.3 Standing up
to Bulling
Behaviour
A1.4 Severe
Intimidation and Violence
A1.5 Bullying at
Work
A1.6 If You’re
Bulling
Someone
A1.7 Further
Information
Protecting Children
and the Vulnerable (Appendix 2)
A2.1 Forms of
Abuse
A2.2 Abuse in
Sport
A2.3 Commonest
Physical Signs
A2.4 Signs of
Neglect
A2.5 Symptoms of
Emotional Abuse
A2.6 Symptoms of
Sexual Abuse
Dealing with concerns
(Appendix 3)
A3.1 About the
behaviour of a member of the club or association
A3.2 Reporting
procedure: Advice to children, parents and coaches
A3.3 What to do
if concerned about abuse by a parent or other adult
A3.4 Specimen
Incident Report Form
Use of Photographs and
Consent to Photography (Appendix 4)
Transport: Guidance
Procedures (Appendix 5)
A5.1
General
A5.2 Good
Practice
A5.3
Collection
A5.4 Summary
advice for coaches and other volunteers
Sample Notice of Child
and Vulnerable Adult Protection Policy Statement (Appendix 6)
Action Plan/ Check
List (Appendix 7)
Contact Details
(Appendix 8)
A8.1 Joint Panel
for the Protection of Children and Vulnerable Adults: Members
A8.2 Joint Panel
for the Protection of Children and Vulnerable Adults: Constitution and
Rules
A8.3 Contact
details for National Associations involved in the protection of Children and
Vulnerable Adults
A8.4
Names and Contact Details at Local Level
Job Specification:
Child Protection Officers (Appendix 9)
A9.1 Association
/ Club Child Protection Officer
A9.2 Child
Protection Officers: Knowledge, Skills and Tasks
Criminal Record Bureau
Checks (Appendix 10)
A10.1 Criminal Record
Bureau Checks
A10.2 Portability of
CRB Disclosures
Handling and Storage
of Disclosures and Information (Appendix 11)
A11.1 Policy
Statement
Voluntary Disclosure
and Referencing (Appendix
12)
Reference Enquiry
Form
Volunteer Disclosure and Reference
Form
Special Consent Forms
(Appendix
13)
Consent Form for Parent/
Carers
Special
Consents
Legal and Procedural
Framework and Further Information (Appendix 14)
A14.1 UK and
International legislation and government guidance
A14.2 Further
Information
Case Management Group
(Appendix 15)
Specimen Club Policy
and Documentation (Appendix 16)
The National Governing
Bodies (NGBs) of all Bowling Codes recognise and acknowledge their joint and
several responsibilities to establish policies which promote and encourage
their affiliated associations and clubs to adopt the highest possible standards
of care towards children and other vulnerable people participating in the Game
of Bowls.
NGBs believe that
everyone has a duty of care towards the children and other vulnerable people
with whom they have contact, and to safeguard and protect them from abuse. This
is both a moral and legal obligation. Everybody, whether administrator,
official, coach, or bowler, involved in working with children, young people and
the vulnerable has a responsibility to be informed about, and be able to
recognise the different forms of abuse. They also need to know what
precautions or steps should be taken for its prevention and what action to take
if an incident occurs.
1.1
National Governing Bodies (NGBs) and Joint Panel for the Protection of Children
and Vulnerable Adults
In common with
governing bodies in other sports, steps were taken towards producing a
comprehensive Child and Vulnerable Adult Protection Policy by the English
Bowling Association, the English Women's Bowling Association, the English
Indoor Bowling Association, and the English Women's Indoor Bowling Association.
The British Crown Green Bowling Association, the English Short Mat Bowling
Association, the English Bowling Federation and the English Women’s Bowling
Federation later joined them.
To implement and progress the policy and procedures
throughout the sport, they have established a joint working group – The Joint
Panel for the Protection of Children and Vulnerable Adults on which
representatives from other interested associations [The English Bowls Coaching
Scheme (EBCS), English Bowls Youth Development Scheme (EBYDS), English Bowls
Umpires Association (EBUA) and English Women’s Umpires Association (Bowling)
(EWUA (B))] also participate.
This panel, working in
liaison with the National Society for Prevention of Cruelty to Children (NSPCC)
Child Protection in Sports Unit (CPSU), has the task of helping to implement
the policy and to monitor progress.
It will offer help and
advice to affiliated Clubs and Associations, who are introducing procedures for
child protection in their own locality; it will also seek feedback on their
experiences.
The panel will also
act with the governing bodies as an advice and control point for Criminal
Records Bureau referrals.
An acceptance that
abuse does take place within sport is a pre-requisite for safeguarding children
and young people. If the sport of bowls is to establish a culture and
ethos where the rights of children are respected and promoted, it is essential
that everyone involved recognise their responsibility for safeguarding and protecting
children and the vulnerable.
Everyone in the sport
of bowls needs to be aware of their individual and collective responsibilities
for:
¤
Challenging
poor practice,
¤
Preventing
abusive behaviour,
¤
Developing
a vigilant and whistle blowing culture,
¤
Promoting
safeguarding interventions.
This requires that
everyone is informed about the nature and extent of abuse in sport. Bowls
must promote a zero tolerance approach to harm or abusive behaviour and ensure
that everyone involved in the sport can, with confidence, report concerns with
any of these matters.
The aim of this
document is to set out a joint policy on child protection for Bowls, and to
provide guidelines to assist those people who may work with children in
associations and clubs, to understand and fulfil their obligations. Although
emphasis is given on child welfare, the contents of this document are equally
valid as general guidance for those involved with the disabled and other
vulnerable adults.
The person in charge
may be the Club Child Protection Officer (CPO)/ the Club Chairman/President/
Secretary or the Teacher or Youth worker concerned where the activity is part
of a school or youth project.
This document follows
recommendations published by the Home Office, NSPCC, Sport England, Sportscoach
UK, and other concerned bodies.
The following principles form the basis
of the policy and guidelines contained in this document:
¤
The
welfare of children and vulnerable adults is paramount.
¤
Each
individual irrespective of age, gender, religion, race or disability has the
right to protection from abuse.
¤
Allegations
and suspicions of abuse will be taken seriously and responded to swiftly and
appropriately.
¤
Each
individual has the right to be safe, and to be treated with respect and
dignity.
¤
Coaches,
and other adults, having had an allegation made against them may seek
assistance from their appropriate governing body.
¤
Recognition
that working in partnership with individuals, their parents or guardians,
carers, families, social services, and other agencies necessary for their
welfare and protection.
A child (or young
person) is defined by the Children’s Act 1989 as any male or female under the
age of 18 years.
For the purpose of
Bowls the date of achieving 18 years will be 1 May for the outdoor season or
1 October for the indoor season in the appropriate year.
2.2
What is a vulnerable adult?
A vulnerable adult is
any person aged 18 or over who is, or may be, in need of community care
services because they have health or other disabilities related to age or
illness. They are people who are not able to take care of themselves or
protect themselves against significant harm or exploitation. (Department of
Health guidance document ‘No Secrets: Guidance on Developing Multi Agency
Policies and Procedures to Protect Vulnerable Adults from abuse’ [March 2000]).
2.3
Relevant Legislation and Guidance (England and Wales)
A list of relevant
legislation and guidance is given in Appendix 14.
The term abuse is used
to describe ways in which an individual is harmed, usually by adults, and often
by people they know and trust.
Physical and emotional
abuse, as well as neglect and sexual abuse, make up the four recognised main
categories of abuse. In addition, bullying is now recognised as another
major form of abuse in its own right.
3.1.1
Neglect
¤
Where
adults fail to meet the individual’s basic physical needs for food, warm
clothing etc.
¤
Where
adults fail or refuse to give the individual love or attention.
¤
Where
adults consistently leave an individual alone or unsupervised.
3.1.2
Physical Abuse
¤
Where
an individual is physically hurt or injured by the use of inappropriate force,
given alcohol and/or inappropriate drugs.
3.1.3
Sexual Abuse
Sexual molestation is
the most widely published form of abuse, but is not the only way in which
children or vulnerable people are harmed.
¤
When
adults of either sex use them to meet their own sexual needs.
¤
Engaging
in any kind of direct sexual display or activity.
¤
The
showing to a child or vulnerable person of any form of pornographic material or
taking photographs for any such purposes.
3.1.4
Emotional Abuse
¤
Where
there is a persistent lack of love or affection.
¤
Constant
over protection preventing the individual from socialising.
¤
Frequent
taunting or being shouted at.
¤
Experiencing
any of the other categories of abuse.
The term child abuse
is used to describe ways in which children are harmed, usually by adults, and
often by people they know and trust. Both boys and girls are at risk of
having their physical and mental health damaged by any of the forms of abuse
stated above.
Child abuse can take
many forms, and may occur within and outside the family, at school, and even
within a social or sports environment.
3.3
Abuse of a vulnerable adult
Abuse is mistreatment
by any other person or persons that violates the individual’s human and civil
rights. The abuse can vary from treating someone with disrespect in a way which
significantly affects the person’s quality of life, to causing actual physical
or mental suffering.
Abuse can happen
anywhere – in a residential or nursing home, a hospital, in the workplace, at a
day centre or educational establishment, in supported housing or in the street.
¤
Physical
Abuse such as hitting, pushing, pinching, shaking, misusing medication,
scalding, restraint, hair pulling.
¤
Sexual
Abuse such as rape, sexual assault, or sexual acts to which the vulnerable
adult has not or could not have consented, or to which they were pressurised
into consenting.
¤
Psychological
or Emotional Abuse such as threats of harm or abandonment, being deprived of
social or any other form of contact, humiliation, blaming, controlling,
intimidation, coercion, harassment, verbal abuse, being prevented from
receiving services or support.
¤
Financial
or Material Abuse such as theft, fraud or exploitation, pressure in connection
with wills, property, or inheritance, misuse of property, possessions or
benefits.
¤
Neglect
such as ignoring medical or physical care needs and preventing access to
health, social care or educational services or withholding the necessities of
life such as food, drink and heating.
¤
Discriminatory
Abuse such as that based on race or sexuality or a person’s disability and
other forms of harassment or slurs.
¤
Institutional
Abuse can sometimes happen in residential homes, nursing homes or hospitals
when people are mistreated because of poor or inadequate care, neglect and poor
practice that affect the whole of that service.
3.3.1
What should be done if there is cause for concern
Any concerns should be
reported as soon as possible, no matter how insignificant they appear to be. A
copy of this report should be given to the CPO. The agency to which the
report is made will vary according to the vulnerable adult’s living
arrangements.
If the vulnerable
adult lives:
¤
Within
a residential care home, report your concerns to the care home manager
first. Once reported to the manager, also report your concerns to the
County Registration and Inspection Unit (contact details will be in your local
directory or publicised through your local authority web-site or literature).
¤
In
a nursing home, report concerns to the County/ Local Authority Nursing Homes
Inspectorate.
¤
In
their own home and receiving services from an agency or individual, make your
report to the Agency concerned and/ or Adult Protection Co-ordinator.
¤
In
the community, report concerns to the Adult Protection Co-ordinator.
¤
If
concerns are regarding hospital treatment of a vulnerable adult, contact the
Nursing Homes Inspectorate or Adult Protection Co-ordinator.
¤
Bullying
behaviour can occur anywhere especially if supervision is inadequate.
¤
It
is an abuse which can take many forms from simple verbal taunts and persistent
teasing to humiliation and physical abuse.
¤
It
should be recognised that the competitive nature of sport creates a potentially
ideal environment for bullying. The bully may be a child or an adult.
¤
Expectations
of a ‘pushy’ or over anxious parent or carer may give rise to signs of bullying.
¤
All
signs of bullying must be taken seriously.
Measures to combat
bullying and advice on action to help the victim and deal with the bully are
given in Appendix 1.
Children from ethnic
communities and their parents are likely to have experienced harassment, racial
discrimination and institutional racism.
All organisations working with children or vulnerable
adults, including those operating where ethnic communities are numerically
small, should address institutional racism as defined in the Macpherson Inquiry
Report on the death of Stephen Lawrence as ‘……the collective failure by an
organisation to provide appropriate and professional service to people on
account of their race, culture or religion’.
A situation where
child or vulnerable adult abuse has, or may have occurred, is not easy to
recognise even for those experienced in working in this field. It is
acknowledged that members of an association or club, whether Team Managers or
Coaches, etc. are not experts at such recognition.
It is not their
responsibility to decide whether abuse is occurring, but they are expected to
be vigilant and act on any concerns by being prepared to report and discuss
these matters with the appropriate persons or authority.
6.1
Symptoms of abuse and indicators
The following signs
are among known indicators of abuse.
¤
Something
a child or vulnerable adult says
¤
Unexplained
or suspicious bruising or injuries
¤
Sudden
changes in behaviour
¤
Sexually
explicit language or actions, especially by children
¤
Observed
change in weight or appearance over a period of time
See also Appendix 2
which details symptoms of abuse that might be seen
6.2
Acting on something an individual says
If a child or
vulnerable adult says or indicates that he or she is being abused, it is
important that the person receiving the information stays calm so that he or
she can:
¤
Ensure
that the individual is, and feels, safe
¤
Tell
and show the individual that what he or she says is being taken seriously
¤
Reassure
the individual that he or she is not to blame
¤
Be
honest and explain that it will be necessary to tell someone else
¤
Obtain
medical help if individual needs immediate treatment
¤
Write
a full report of what the individual has said as soon as possible after the
event
¤
Maintain
confidentiality, and only tell others if it will protect the child
On no account should
that person rush into actions that may not be appropriate, or make promises
that cannot be kept. Nor should they ever take sole responsibility; they should
consult the CPO or Club Secretary so that they can begin to protect the child
or vulnerable adult, and gain support for themselves.
6.3
Acting on suspicions or allegations
Abuse of any kind is
an emotive and difficult subject. The action to be taken needs to be
governed by the nature of the concern, see Appendix 3.
A specimen report form
is given in Appendix 3.
If a change in the
individual's behaviour has been noticed, it may be that difficulty with schoolwork
or a bereavement etc has caused the individual to be unhappy.
It may be appropriate
to speak to the parents, guardians or carers. However, if the concern is
about physical, emotional or sexual abuse, talking with these adults may put
the individual at greater risk as they may be the perpetrators. In such
cases, consult with the Club CPO.
It is for that person
to decide the action to be taken. This may require contacting Social
Services or the Police, who have responsibilities under the Children Act if the
individual concerned is a young person.
If the CPO is not
available, the person receiving the information should do this themselves. If
in doubt, advice may be obtained in confidence by telephoning one of the
help-lines listed in Appendix 14.
7 Promoting Good Practice with
Children and Vulnerable Adults
Abuse of children and
vulnerable adults can arouse strong emotions in those facing such a
situation. It is important to understand these feelings and not allow
them to interfere with the judgement about any action to take. Abuse can
occur within many situations including the home, school and the sporting
environment. Some individuals will actively seek employment or voluntary
work with children in order to harm them. A coach, instructor, official
or volunteer may have regular contact with children and be an important link in
identifying cases where the child needs protection. All suspicious cases
or poor practice should be reported following guidelines in this
document. When a child or vulnerable adult enters the club having been
subjected to abuse outside the sporting environment, sport can play a crucial
role in improving the individual’s self esteem.
7.1
What is Good Practice?
Always:
¤
Be
an excellent role model.
¤
Give
enthusiastic and constructive feedback rather than negative criticism.
¤
Treat
everyone equally with respect and dignity.
¤
Always
work in an open environment (avoid private and unobserved situations).
¤
Respect
a child/ vulnerable adult’s right to privacy.
¤
A
commitment to a drug-free sport.
¤
Securing
parental consent in writing to act in loco parentis.
¤
Be
aware of any medical problems and medication should a medical emergency arise.
¤
Keep
a written record of any injury sustained and the treatment given. Report
the incident immediately to the Club CPO/ County CPO with a copy to the Club/
County Secretary.
¤
Secure
written parental consent if club members/ officials are required to transport
children / vulnerable adults in their cars.
¤
Recognise
that someone else may misinterpret your actions no matter how well intentioned.
¤
Report
any concerns you may have.
Never:
¤
Work
alone. Ensure a parent of other adult is present.
¤
Allow
ridicule or bullying.
¤
Engage
in rough, physical or sexual provocative games, including horseplay.
¤
Make
suggestive comment to a child/ vulnerable adult, even in fun.
¤
Show
favouritism to any individual.
¤
Allow
allegations made by a young person to go unchallenged, unrecorded or not acted
upon.
¤
Try
to investigate any concerns personally.
¤
Rely
on your good name to protect you.
¤
Believe
“it could never happen to me”.
¤
Allow
yourself to be drawn into in appropriate attention seeking behaviour such as tantrums
and crushes.
8.1
Dealing with complaints where a child or vulnerable adult is involved
Always
¤
Stay
calm and do not rush into inappropriate action.
¤
Reassure
the child/vulnerable adult he/she is not to blame. Communication should
be at the individual’s pace without pressure.
¤
Listen
to what the individual is saying and take them seriously.
¤
Do
not make promises you cannot keep.
¤
Ensure
that confidentiality is maintained at all times.
¤
Explain
to the individual what steps you intend to take having heard their account.
¤
Ensure
that you understand what the individual has said and that you record it
accurately immediately after the conversation.
¤
You
should not take sole responsibility, consult the Club CPO/Club Secretary so
that they can take steps to protect the child / vulnerable adult and offer
support.
8.2
Responding to Suspicions and Allegations
It is not the
responsibility of anyone working in the sport of bowls, in a paid or unpaid
capacity to take the responsibility or to decide whether or not abuse has taken
place.
However, if there are
concerns that abuse is occurring and you need advice you can contact the
Police, or Social Services, who have the responsibility under the Children’s
Acts to investigate the matter further where children people are
involved. Where a vulnerable adult is involved guidance is provided at
Section 3.3.1.
For further reference
see Appendix 3.
Confidential advice
can be obtained by telephoning any of the help-lines listed in Appendix 14.
9 Disciplinary Procedures and
Appeals
Provision must be made
to empower a specified senior committee member (eg, CPO and/or Secretary/ Chief
Executive) to take action if notification of an offence against a child or
vulnerable adult within the sport has been received. This should permit
such action as interim suspension pending full enquiry and formal hearing by a
disciplinary committee.
The accused must have
the right of appeal to an independent panel for example via the Sports Disputes
Resolution Panel. In addition, reference should also be made to the
disciplinary procedures as contained in the constitution of all the relevant
NGBs, County Associations and Clubs. These can be found in the relevant
Handbooks or Constitutions.
See also flowcharts
under Appendix 3.
Any act, statement or
other matter which causes, poses, or indicates a risk of harm to a child or
other vulnerable person is deemed to constitute unacceptable improper behaviour
and may be referred to the Case Management Group (see Appendix 15).
Within these regulations
the expression ‘offence’ shall include such behaviour, and any other criminal
act which may pose a risk or cause harm to a child or vulnerable adult.
Upon receipt by the
Senior Officer of the Club/ Association information or notification that an individual:
a) has been charged with an offence; or
b) is subject to investigation by the police, social services, or other agency
relating to an offence; or
c) poses or may pose a risk to a child/ vulnerable adult,
then the Senior
Officer/ Disciplinary Committee shall have the power to order that the
individual is suspended from the sport for such period and on such terms as
[he/she] shall decide according to the guidelines set out in the relevant NGB
complaints procedure.
In reaching their
decision due consideration shall be given to whether:
a) The child or vulnerable adult is or may be at risk;
b) The matters are of a serious nature;
c) The order is necessary or desirable to allow any investigation to
proceed.
Written notice of any
order made shall be given to the person concerned and his club as soon as
reasonably practical.
There shall be a right
of appeal against the decision to an independent appeals panel, (reference
should be made the relevant NGB disciplinary code).
Any complaint brought
by one person against another must be in writing. If the Senior Officer
finds that there is a case to answer, the matter is to be placed before the
Executive/ Disciplinary Committee, and the person involved notified in writing
of the complaints made, with an invitation to respond within 21 days.
Following the 21 day
period, the Executive/ Disciplinary Committee shall decide to accept the
response and take no action, or take simple disciplinary action, or schedule a
full hearing. The accused may request a full hearing.
The date set for the
hearing shall not be later than four weeks from the date of the decision or
request, and must be notified to the parties in writing.
There shall be a right
of appeal to the decisions reached at the hearing to an independent panel.
9.3
Policy re previous misdemeanours
Reference should also
be made to Section 10.7 regarding the rights of ex-offenders under the
Rehabilitation of Offenders Act 1974.
10 Guidance for Associations and Clubs
The responsibility of
making bowls safe and free from harm for children and vulnerable people is one
which must be shared at all levels of our sport. This Guide is designed to help
you understand the part which your association or club is expected to play, and
the necessary steps to take in doing so.
In it, references to a
child or young person means anyone under the age 18 years and the term parent
is used generically to represent parents, carers and guardians.
All of the policies
and procedures mentioned refer equally to those who, as a result of physical or
mental handicap and irrespective of their age, are deemed to be vulnerable.
10.2
The role of Child Protection Officers (CPOs)
Each Association and
Club should identify a designated person (see also Section 10.5 and 11) to be
titled the Child Protection Officer (CPO) and deal with issues relating to
child and vulnerable adult protection.
Clubs with
insufficient members who are unable to appoint their own CPO may seek the
assistance of a neighbouring CPO to act on their behalf.
Prior to this
appointment it is strongly recommended that the person undertakes a Criminal
Record Check at Enhanced Level through their NGB. The CPO will be
supported by a Case Management Group (see Appendix 15) and the Joint Panel for
the Protection of Child and Vulnerable Adults.
All Associations
linked to each NGB are strongly recommended to identify a designated person to
take on the role of CPO for that Association with responsibility for child and
vulnerable adult protection policies. Clubs or local organisations within
member associations (or affiliated directly to NGBs) are also strongly
recommended to identify a designated person to be titled Club CPO to handle
child and vulnerable adult protection issues. Similarly, prior to
appointment these persons should also undertake a Criminal Record Check at
Enhanced Level.
The Club CPO acts as
the first point of contact for anyone in the Club who has a concern about a
child or vulnerable adult and/or about poor practice or possible abuse by
anyone working with them.
Each Association CPO
(whether at National, Regional, County or Club Level) must have a formal role
within the Association’s management structure. The Association’s CPO will
require support from the Association, and designated training should be
provided. The Association may wish to appoint more than one CPO.
The role of
Association CPO is critical in ensuring that the Child and Vulnerable Adult
Protection Policy and Implementation Procedures work in practice. The
Association CPO may also act as the first point of contact for anyone who has a
concern about a child/ vulnerable adult and about poor practice/ possible abuse
by anyone working with them.
The CPO therefore
needs to be perceived as being approachable and as having a child-focussed
and/or vulnerable adult-focussed approach.
The CPO does not need
to be child or vulnerable adult protection ‘experts’. That is the role of
the statutory agencies (Police and Social Services).
Both Association and
Club CPO’s should be supported by their NGB, Associations and Club management
and have a formal role in the management structure.
Whether or not
children or vulnerable adults currently participate in its activities, each
affiliated Association and Club has a duty to play its part in the
implementation process.
This Guide (see
Section 18) offers practical advice with responses to some frequently asked
questions aimed at helping your understanding. Specimens of the various
recommended forms will be found in the Appendixes.
A good way to begin is
to get an overview of the issues. Then let everyone know that your
association or club is committed to the protection of children and vulnerable
adults by issuing a simple statement of intent or a more formal policy
document.
The form of words used
in a Statement of Intent need not be very complex.
The following is a suggestion,
which could also be introduced as an additional clause in your organisation's
Rules and Constitution.
“The XYZ Bowling Club
/ Association is committed to promoting a safe environment in which children
and vulnerable adults can enjoy taking part in games of bowls.
It will seek to
underpin and ensure this commitment by following and promoting the joint Child
Protection Policy and Procedures of the National Governing Bodies.”
Appendix 6 gives an
example of a formal policy document, which incorporates the underlying
principles. It is important that the statement of commitment to child and
vulnerable adult safety is prominently displayed in the club, and copies made
available on request to members and parents.
The next step is for
your Executive Committee to set a timed action plan to guide the scheduling of
implementation. An example is given at Appendix 7.
The plan will need to
cater for the following:
¤
Recruitment
of an Officer responsible for Child/ Vulnerable Adult Protection.
¤
Preparation
and printing of necessary forms for parental consent, volunteer disclosure and
references, accident / incident reports, etc.
¤
Training
policy for volunteers.
¤
Formalised
adoption by members of the policy and procedures, including monitoring and
disciplinary matters.
¤
Amendment
of Constitution & Rules.
To ensure that
unsuitable people are prevented from working with children or vulnerable
adults, all applicants should be interviewed, and asked to undertake an
Enhanced CRB Check or complete a Volunteer Disclosure and Reference Form (as
appropriate). References should be taken up.
There may be an
administrative charge for handling the processing of the CRB form on behalf of
the NGB.
Clubs with paid staff
should review the extent to which their employees have access to children and
vulnerable adults, and seek advice from their NGB as to whether a CRB check is
appropriate.
10.7
Recruitment of Ex-Offenders: Statement of Policy
This applies to all
aspects of employment albeit as a post as part of an NGB or at Club level.
10.7.1 Policy
Any organisation using
the Criminal Records Bureau (CRB) Disclosure service to assess an applicants’
suitability for positions of trust, must comply fully with the CRB Code of
Practice. Also undertake to treat all applicants for positions fairly. It
undertakes not to discriminate unfairly against any subject of a Disclosure on
the basis of conviction or other information revealed.
They
must:
¤
Be
committed to the fair treatment of its staff, potential staff or users of its
services, regardless of race, gender, religion, sexual orientation,
responsibilities for dependants, age, physical/mental disability or offending
background;
¤
Have
a written policy on the recruitment of ex-offenders, which is made available to
all Disclosure applicants at the outset of the recruitment process.
¤
Actively
promote equality of opportunity for all with the right mix of talent, skills
and potential and welcome applications from a wide range of candidates,
including those with criminal records. Select all candidates for interview
based on their skills, qualifications and experience
¤
Ensure
that a Disclosure is only requested after a thorough risk assessment has
indicated that one is both proportionate and relevant to the position
concerned. For those positions where a. Disclosure is required, all application
forms, job adverts and recruitment briefs will contain a statement that a
Disclosure will be requested in the event of the individual being offered the
position.
¤
Be
aware that where a Disclosure is to form part of the recruitment process, that
they encourage all applicants called for interview to provide details of their
criminal record at an early stage in the application process. The CRB request
that this information is sent under separate, confidential cover, to a designated
person within this sport and we guarantee that this information is only seen by
those who need to see it as part of the recruitment process.
¤
Be
aware that unless the nature of the position allows the NGB to ask questions
about an individuals entire criminal record that only “unspent” convictions as
defined in the Rehabilitation of Offenders Act 1974 are considered.
¤
Ensure
that all those in the bowls (Club/ Association or NGB) who are involved in the
recruitment process have been suitably trained to identify and assess the
relevance and circumstances of offences. Also ensure that they have received
appropriate guidance and training in the relevant legislation relating to the
employment of ex-offenders, eg the Rehabilitation of Offenders Act 1974
¤
At
interview, or in a separate discussion, ensure that an open and measured
discussion takes place on the subject of any offences or other matter that
might be relevant to the position. Failure to reveal information that is
directly relevant to the position sought could lead to withdrawal of an offer
of employment.
Having a criminal
record will not necessarily bar a person from working with an organisation
associated with bowls. This will depend on the nature of the
position and the circumstances and background of the offences.
Specimen forms are
given in the Appendixes, but there is no objection to them being modified to
meet local requirements, or to designing your own provided that they elicit the
same minimum information. Remember that you will need to add the name and
address, etc of your association or club, and to adopt a firm policy on their
completion.
Particular attention
should be given to completion of parental consent forms for both general
association / club activities, and for special multiple or 'one off' events.
Accept that
circumstances may have changed and obtain fresh consents each time.
Decisions will need to
be taken on the training needs for your Association/Club CPO, volunteers and coaches,
including cost implications. A number of agencies offer awareness courses and
other training related to child protection. Some have been attended by
members of the Joint Panel for the Protection of Children and Vulnerable Adults
who can offer advice on their suitability. (See Appendix 8 for contact
details.)
Financial support to
help with course fees may be available from local award schemes, and
information on these is often obtainable from the local authority or library
service.
10.10
Adoption of Policy and Constitution changes
County Associations
are required to make provision in their Rules and Constitution to ensure that
those Clubs with members under 18 years of age and other vulnerable people,
adopt appropriate protection procedures or will do so at an early date.
The Club and officials
having adopted and placed on display their Child and Vulnerable Adult
Protection Policy, should make sure that the appointed CPO is known to all
members of the club, and fully supported by the committee.
NGBs, County Associations and Clubs should also
recognise the importance of making early arrangements to bring the policy and
other relevant child and vulnerable adult protection matters into their Rules
and Constitution.
10.11 Why
do Bowls need a Child and Vulnerable Adult Protection Policy?
This question is
frequently asked. We need only to look around us to find the reply. Most
bowlers acknowledge that our sport is undergoing change, with many more
children, disabled and vulnerable people taking part than before.
Everyone has a duty of
care for the welfare of children and other vulnerable people.
This is a legal and
moral responsibility, which our sport must be prepared to meet.
By adopting and
implementing a Child and Vulnerable Adult Protection Policy we can provide
reassurance to the child's parents, and show our acceptance of responsibility
for child and vulnerable adult welfare.
It also demonstrates
that we have procedures in place for the correct conduct of the individuals
delivering the activity, which should help to deter the undesirable.
It is acknowledged
that this guide is not exhaustive, and that you may have unanswered questions.
Please make your first point of call one of the members of the Joint Panel for
the Protection of Children and Vulnerable Adults listed in Appendix 8.
This helps with NGB
monitoring arrangements, and will ensure that your query receives an answer.
There is no desire
that the contents of this document should deter any club from opening their
membership and activities to children or vulnerable people. Each club
must decide what is appropriate, having regard to local circumstances.
All are recommended to adopt and publish their policy, for the guidance of all.
It is strongly recommended that a statement of the Club Child and Vulnerable
Adult Protection Policy is displayed on the Club notice board (see Appendix 6
for a proforma).
It is advisable for
the club or association to appoint a responsible person to be the CPO who will
be willing to liaise with their NGB/ County Associations (see also Section
1.2).
Clubs with
insufficient members who are unable to appoint their own CPO may seek the
assistance of a neighbouring CPO to act on their behalf.
See also Section 9 on
matters relating to disciplinary proceedings.
Parents and guardians
should be asked to sign a form of consent to cover activities at the club/
association and match play, both home and away. See example forms at
Appendix 11 which may be amended as appropriate to meet the Club’s/
Association’s needs.
It is also a good idea
to promote a code of conduct for both young people and their parents to ensure
their ‘buy-in’ to good behaviour and practice and therefore minimise the risk
of any kind of abuse.
Special Consent forms
(see Appendix 11) must be completed when an overnight stay is required.
It is also good
practice to make the club policy and procedures available to parents and
guardians, and to keep a complete record of the participating children.
13 Photography and Dealing with the Media
13.1
Guidelines for Use of Photographs at Sporting Events
13.1.1 General Policy
statement
Where
children/ vulnerable adults are involved
¤
The
interests and welfare of children and vulnerable adults taking part in events
is paramount.
¤
Parents/
carers and children/ vulnerable adults have the right to decide whether
children’s/ vulnerable adult’s images are to be taken and how those images may
be used.
¤
Images
should convey the best principles and aspects of sport, such as fairness and
safety.
¤
Care
should be taken to make sure that the images are not sexual or exploitive in
nature, not open to obvious misinterpretation and misuse.
¤
Images
should only be taken by accredited persons who must wear identification at all
times. See Appendix 4.
¤
All
images of children/ vulnerable adults should be securely stored.
¤
Care
must be taken when reproducing photographs in the press and on the web-site
that no identifying details could permit contact with a child/ vulnerable adult
by a potential abuser.
¤
Do
not allow unsupervised access of children or vulnerable adults for photo
sessions without consent.
Specimen forms for
consent by parents/ carers and individuals can be found in Appendix 4.
Also at Appendix 4 is
a specimen form for those wishing to take photographs and it is strongly
advised that all parents/ carers and family attending events where other
children/ vulnerable adults are involved are urged to register.
13.1.2 Photographic
images (cameras or video media or mobile phones)
Care should also be
taken to monitor the use of mobile phones with a photo capability to ensure
that the above guidelines are adhered to.
The individuals being
photographed must be appropriately dressed for the activity and the photography
or recording should focus on the activity rather than on the individual.
13.1.3 Coaching and
Photography
All individuals
featured must be appropriately dressed for the sport with garments adhering to
the dress code of bowls for the appropriate NGB.
Any photography or
recording should focus on the activity and be recorded in small groups (which
may comprise a combination of adults and young individuals).
Coaches are allowed to
use video equipment as a legitimate coaching aid and means of recording special
occasions. However, care should be taken in the dissemination and storage
of the material.
13.1.4 Use of
photographic/ filming equipment by parents/ carers and spectators
Whenever parents,
carers, or other spectators intend to photograph or video at an event they must
be made aware by the Event Organiser/ CPO that they must be prepared to
identify them selves and state their purpose for filming.
The Event Organiser
and/or Event CPO should approach or challenge any person taking photographs who
has not made them selves known and/or registered with them. If need be
advice may be sought from the Police if this person continues to record images
unauthorised within the confines of the event.
13.2.1 General
The abuse of children
and the vulnerable is an issue which will generate media interest at any
level. It is important that at all levels within bowls, from Club to NGB
that there is an effective strategy for handling media.
If there is an
allegation made it is important that initial enquiries are handled in such a
way that it will not aggravate any situation or generate negative publicity.
Be prepared:
¤
If
you are made aware of any allegation of abuse it is important to be prepared in
advance for potential publicity.
¤
To
consult the relevant Lead CPO of your NGB (or County CPO if appropriate) for
advice and liaise with them giving them all the facts.
¤
To
have a responsible representative to handle media enquiries.
¤
To
be aware of the policy regarding the employment of ex-offenders (see Appendix
10.2).
13.2.2 Contact from
the press or a journalist
If contacted or
approached by a member of the press, it is likely that the journalist might
have heard about an alleged case of abuse from a source or directly from a
relative or acquaintance of the alleged victim.
¤
You
are likely to be asked for your response. As the press might approach a
NGB, Club or individual, it is worth remembering that the journalist may
already have a story ‘mapped out’, so what you say, and how you say it, is
important.
¤
Make
sure you clearly hear the name of the journalist and the media they are working
for. If needed, ask them to repeat so you can take notes.
¤
Make
sure you fully understand what the journalist is asking you, asking them to
repeat if needed. You may be aware of the incident concerned, or you may
not be aware of it.
¤
Do
not say ‘No Comment’ as it makes you sound guarded as if you had something to
hide.
¤
Take
details of contact telephone where the journalist can be easily contacted and
find out what their deadline is.
¤
Contact
your NGB and/or County Associations for advice and to discuss the matter.
They will help you formulate an appropriate response, deal with the journalist
on your behalf and inform you of the response made.
13.2.3 Follow up
Be prepared for follow
up enquiries (either by telephone or personal contact) as allegations of abuse
are rarely one-day stories. Just because an initial response has been
given does not mean to say that there will be no more questions in the
future. Continue to liaise with your NGB and County Body as needed.
Do not comment ‘Off
the record’ on any allegations of abuse of children or the vulnerable.
Journalists like nothing better than comments made of this nature. They
can use this tool to elicit more information on the understanding that they
will not publish what you say.
A chart is indicated
at Appendix 4.
It is important to
take steps to ensure the safe transport of children and vulnerable adults.
¤
If
private cars are being used make sure that parental consent has been obtained.
¤
If
the driver undertaking this role on behalf of the club is not a parent/ carer
or relative, they must be made aware of guidance in relation to working with
children and vulnerable adults.
¤
Unaccompanied
children/vulnerable adults should carry with them a contact name and telephone
number.
¤
Parents/
Carers should be made aware of pick up and drop off points and times.
¤
The
following points should be complied with:
¥
Name/
contact number provided.
¥
Pick
up / drop off point named.
¥
Name
of parent/ carer to collect.
¥
Emergency
telephone contact number.
¥
Participants
are not left unsupervised (dropped off without parent/ carer present).
¥
Do
not take the child/ vulnerable adult home or to another location.
More detailed guidance
notes can be found in Appendix 5.
15 Criminal Record Bureau (CRB) and Personal
Disclosures
Anybody may have the
potential to abuse children/ vulnerable adults in some way, and it is essential
that all reasonable steps are taken to ensure that unsuitable people are not
allowed to work with them. It is therefore important that checks are made as to
the suitability of those volunteering to become involved with individuals, and
they should be asked to complete a disclosure to an Enhanced Level.
15.1
Criminal Record Bureau (CRB)
The CRB enables
employers of private, paid and voluntary organisations in England and Wales to
do checks related to an applicant’s suitability to work with children or
vulnerable adults. Access to the CRB checking service is available to all
organisations working with children and vulnerable adults by using the services
of one of its Registered Bodies.
The NGBs for the Flat
Green Codes and Short Mat use the auspices of The Media Group (TMG).
British Crown Green currently has a separate dedicated system and applications
should be made to their Lead CPO, Mr Ken Jarvis (contact details are in
Appendix 8).
Coaches (licensed
under the EBCS) should apply for forms through Mrs Pat Ostler (EWBA) (contact
details are in Appendix 8)
The CRB Disclosure
application form and the procedure to be followed on completion of the form can
be obtained from your NGB representative (see also Appendix 10).
Persons with regular
contact with children or vulnerable adults should ensure that they have
obtained a CRB Disclosure, updated every 3 years. Advice on whether a CRB
check is appropriate can be sought from any of the Panel members listed in
Appendix 8.
Care should be taken
as the CRB Disclosure information may reveal personal information on an
individual regarding convictions on which the Rehabilitation of Offenders Act
may apply for spent convictions.
The policy for
handling and storing of confidential information is detailed in Appendix 11.
The Voluntary
Disclosure procedure may be used for one-off occasions (see Appendix 10).
Where Personal
Voluntary Disclosures are taken these should be considered confidential and
kept in a secure place by the CPO. See Appendix 11 for standards for
holding and storing confidential information.
16 Code of Behaviour for those involved with
Children or Vulnerable Adults
All should adopt an acceptable code of
behaviour guided by the following principles
Always:
¥
Provide
an example you wish to be followed;
¥
Treat
everyone with respect;
¥
Plan
activities which involve more than one other person, or which are within sight
or hearing of others;
¥
Respect
an individual’s right to personal privacy;
¥
Provide
access for individuals to talk to others about any concerns they may have;
¥
Recognise
that someone else may misinterpret your actions no matter how well intentioned;
¥
Exercise
caution especially in sensitive times of counselling;
¥
Report
any concerns you may have about the individual.
Never:
¥
Work
alone. Ensure that a parent or other adult is present;
¥
Allow
ridiculing or bullying, by peers, team colleagues, etc;
¥
Indulge
in or allow physical contact ;
¥
Make
suggestive remarks or gestures;
¥
Show
favouritism to any individual;
¥
Allow
yourself to be drawn into inappropriate attention seeking behaviour, eg
tantrums, or crushes;
¥
Jump
to conclusions about others without checking facts;
¥
Try
to investigate any concerns personally;
¥
Rely
on your good name to protect you;
¥
Believe
" it could never happen to me ".
17 Implementation and Monitoring
To ensure the adoption
and effective management of child and vulnerable adult protection policies and
procedures, there must be agreement on the methods and strategy to be employed
firstly to introduce them, and then to measure how they are performing.
To enable the agreed
policy and procedures to be effective, they will need to be merged with
existing philosophies and practices. There may be some resistance to the
inevitable changes, diplomacy will be required.
The process will
involve some or all of the following:
¤
Raising
committee awareness of the issues;
¤
An
acceptance by club/ association of the principles of child and vulnerable adult
protection;
¤
Establishing
budgets and financial constraints, eg training;
¤
Disseminating
information;
¤
Overseeing
the operation of procedures;
¤
Recruitment
and training;
¤
Review
and development of current knowledge and practices
Throughout it will be
necessary to keep abreast of changes to legislation and good practice in child
and vulnerable adult protection, and make periodic amendments as required.
In order to make
informed assessments of the progress of implementation, it will be necessary to
decide from among the many factors involved which are both relevant and
measurable. They may include monitoring:
¤
Raising
awareness of child and vulnerable adult protection within the Club environment;
¤
Effectiveness
of CPO’s duties and responsibilities;
¤
Requests
and recommendations for training;
¤
Case
management to include analysis of feedback reports and recommendations for
policy and practice (see Appendix 15)
It could also include
analysis of feedback reports, and recommendations for changes to policy and
practices.
18 Child Protection – Some Frequently asked
Questions
We
have got along without child/vulnerable adult protection all these years; why
should we change our thinking now? What has changed to suddenly make this so
important?
For many years, the
general public preferred not to acknowledge the existence of child and
vulnerable adult abuse and its harmful long-term effects. The high profile
media reporting of incidents in recent years has heightened awareness of the
issues. This disclosure has brought to many the stark reality that the abuse
does take place in all walks of life. It even occurs in sport, with instances
of coaches and other trusted adults being convicted.
Doesn’t
anyone realise that this is more work for already over stretched club officials
and committees? Little clubs are struggling; this is one more burden they don’t
need.
The demands made on
voluntary club officials and committees are fully recognised and understood.
Nevertheless, it is
important that they do not to see protection issues as a burden. Instead, it
should be seen as an opportunity to demonstrate their awareness and of the
club’s commitment to keeping safe any individual taking part in its activities.
Protection is the responsibility of the club as a whole, and should be shared.
Officials should look for help from members outside of the committee, some of
whom may already have experience in this field.
Who
are we safeguarding? Do adults need protecting too?
The principle
objective of protection policies is to safeguard the welfare of children and
those adults who are vulnerable to abuse by reason of physical or mental
disability. A secondary objective but no less important, is to assist coaches
and other volunteer helpers to have recourse to counter false allegations made
against them.
Who
decides if a member is a child?
This is already
decided by Parliament in The Children's Act 1989 which defines a child as any
male or female person who has not attained 18 years of age.
We
don’t have any ‘youngsters’; so why do we need to bother?
There is a growing
trend to encourage child participation in all sports through youth development
schemes and other initiatives, and this could result in a change in the age
profile in membership applications. Although all NGB's recommend the adoption
of a child protection policy, it is voluntary and a matter for the club
committee to decide.
Remember that the
success of grant aid applications is dependant on being able to show a positive
attitude to junior membership and child protection.
What
is the ‘Children’s Charter'?
The Children’s Charter
is a set of human rights principles designed to safeguard the well being of
children and protect them from abuse. They are set out in the Human
Rights Act 1998 and the United Nations Convention on the Rights of the Child
(1989). They are the principles underlying child protection policies.
Who
decides if a member is a vulnerable adult?
A vulnerable adult is
any person aged 18 or over who is or may be in need of community care services
because they have health or other disabilities related to age or illness.
They are people who are not able to take care of themselves or protect
themselves against significant harm or exploitation. (Department of Health
guidance document ‘No Secrets: Guidance on Developing Multi Agency Policies and
Procedures to Protect Vulnerable Adults from abuse’ [March 2000]).
What
exactly is the ‘code of practice'?
The code of practice
forms part of a general Code of Ethics and Conduct for coaches and others
involved in delivery of the activity. It is a set of common sense guidelines
designed to ensure that sport is delivered in a safe and positive manner. The
code offers examples of exemplary behaviour, which not only create a good
sporting environment, but should help to protect the coach and adult volunteers
from false accusations.
What
is meant by ‘best practice’?
Best practice refers
to those positive guidelines in the code of practice (the Do’s and Don’ts)
aimed at ensuring appropriate and exemplary behaviour by the individual.
There are no simple clear
instructions and complicated ‘bumph’ will only put people off.
Because of the
underlying legal requirements, it is inevitable that explanation of some
details of the issues involved may appear complicated and off putting. The
supplementary guidance notes are an attempt to offer more intelligible
instruction.
We
want to start a ‘junior’ section by advertising in our local village
newsletter; do we have to have this in place before we can proceed?
It is recommended that
the process of introducing child protection has begun before you proceed.
Local child protection action groups will join responsible parents in expecting
to see a formal policy statement or at least a statement of intent. They are
also likely to demand reassurance on issues relating to safety issues and the
credentials of the personnel involved.
My
Club Committee is considering starting a junior section, but have been told
that we must provide separate changing rooms for them. This will prevent us
doing so, as we have no funds for building work of this nature.
Separate facilities
for juniors would be ideal, but few clubs or public buildings can offer
them. However, it makes sense and is generally accepted that there should
be some supervision in the changing rooms.
It can be achieved by
involving parents, and other trusted adults working in pairs. They should
be required to complete an Enhanced CRB Disclosure or a voluntary disclosure
form as deemed expedient.
We
have been told that adults must leave the toilet area if it is required to be
used by a child. Is this true?
This is neither true
nor feasible. See also the reply to the previous question.
After
our junior bowling sessions, I have always taken the children home in my
car. I am now told that this is against the law, and I must not do so. Is
this right?
No, it is not against
the law; nevertheless, it does not make sense to be alone with a child.
If there is no other viable option, it is all right to provide a lift on a
single occasion, but it is important to inform the parents. However, to do so
regularly or frequently is not very wise, and could lead to false
allegations. See also Appendix 5 for Transport Policy guidance.
Will
the relevant NGB Child Protection Officer be visible and easy to contact with
any worries we might have?
Yes, details of
members of the Joint Panel for the Protection of Children and Vulnerable Adults
are detailed at Appendix 8 as well as those with responsibility at County level
(see the relevant County or NGB Handbook). Remember that advice can also be obtained
from the Childcare helpline, and Local Child Protection Committee / Local
Safeguarding Child Boards.
We
feel it is time wasting bringing up concerns that are not important to other
people
For child protection to work, a very high priority
must be given to dealing with any concerns. Bringing them up is important and
not time wasting. None action is not an option!
I
help with the junior section at my Club. Do I have to undergo a character
check? by the police? Will such checking etc. stop people from volunteering?
Self-disclosure may be
subject to the option of authentication through the Criminal Records Bureau.
This would normally only be done where the individual has significant
responsibilities for child and/or vulnerable adult protection.
The self-disclosure
process will be acceptable for a large number of volunteer helpers.
It is believed that
the majority of volunteers will recognise and accept the need of some degree of
formal checking, but it is acknowledged that the thought of such a check could
discourage very few from volunteering.
I
already have a CRB Disclosure Certificate for my job, why do I need another for
Bowls?
The Disclosure
obtained for the employment purposes will have looked at information available
at that time. This may have changed and may not have been of the correct
(Enhanced) Level. It may have been in issue more than three years, and
when issued may not have included full checking of the lists held under the
Protection of Children and of Vulnerable Adults Acts.
Obtaining a fresh
Disclosure will give the club renewed assurance that all issues have been
examined (see also Appendix 10.2).