Safeguarding policy
Kaizen Safeguarding Limited Safeguarding Policy
Document control
Policy owner: Director, Kaizen Safeguarding Limited
Approved by: Leigh McFarlane, Director, Kaizen Safeguarding Limited
Effective from: 11 September 2026
Review date: September 2027, or earlier following significant change
Public contact: info@kaizensafeguarding.org
Registered company in Northern Ireland NI740655 | www.kaizensafeguarding.org
1. Purpose and commitment
Kaizen Safeguarding Limited is an independent safeguarding organisation working across faith, education, charity, voluntary and other settings in the UK, Ireland and internationally. This policy explains how Kaizen safeguards children, young people and adults who may be at risk of harm in the course of its own work.
Kaizen is committed to practice that is survivor-centred, trauma-informed, rights-respecting, culturally responsive and evidence-informed. Safety, dignity, voice, choice, equality and accountability guide our decisions. Safeguarding is everyone’s responsibility, but responsibility must be clear: Kaizen will act on concerns arising through its work while client organisations retain their own statutory, regulatory, employment and operational duties.
This policy is designed for Kaizen’s activities. It is not a substitute for a client’s safeguarding policy, local multi-agency procedures, professional advice or emergency action.
2. Scope
This policy applies to the Director and to every employee, associate, consultant, researcher, contractor, volunteer or other person acting for or representing Kaizen Safeguarding. Compliance with it is a condition of engagement.
It applies to in-person, online and hybrid work, including:
· open and commissioned safeguarding training, workshops, webinars and events;
· consultancy, policy development, audits, reviews, case review support, risk assessment, advice clinics and organisational capacity building;
· research, consultation, surveys, interviews, focus groups, publications and knowledge exchange;
· public policy, systems and survivor advocacy, including engagement with organisations, regulators, public bodies and the media;
· survivor support and advocacy within Kaizen’s stated competence and agreed remit;
· professional supervision, reflective practice and work with designated safeguarding leads or senior leaders;
· digital communications, social media, websites, recordings and the processing of safeguarding information; and
· partnerships, subcontracted work and activity outside Northern Ireland.
Where Kaizen Safeguarding works under contract to a client, the written agreement should identify the lead organisation, applicable policies, reporting route, information-sharing arrangements and responsibility for statutory or regulatory notifications. If arrangements are unclear or unsafe, Kaizen Safeguarding will pause the relevant work while responsibilities are clarified, unless pausing would increase immediate risk.
3. Principles
Safety and welfare. The welfare and protection of a child is a primary consideration. Adults are supported to be safe while retaining autonomy, legal rights and control over decisions wherever possible.
Voice and participation. Children and adults are listened to and involved in decisions in ways suited to their age, understanding, communication needs and circumstances.
Trauma-informed practice. We seek to promote safety, trust, choice, collaboration and empowerment and to avoid unnecessary repetition, disbelief, blame, coercion or re-traumatisation.
Equality and inclusion. Safeguarding applies to everyone. We recognise that disability, age, race, sex, gender reassignment, sexual orientation, religion or belief, poverty, migration status, language, culture and unequal power can affect risk, disclosure and access to help.
Proportionality and least intrusion. Action is timely, necessary and proportionate to the risk. Adult safeguarding is consent-led unless law, serious risk or the protection of another person justifies action without consent.
Accountability and learning. Decisions, rationale, action and dissent are recorded. Conflicts are declared, practice is open to challenge, and learning is used to improve systems.
No statutory investigation by Kaizen Safeguarding. We may undertake a commissioned review or fact-finding exercise within agreed terms, but does not carry out criminal or statutory child or adult protection investigations. Such work must not obstruct police, social care, regulatory or disciplinary processes.
4. Roles and accountability
4.1 Director and designated safeguarding lead
The Director is Kaizen’s designated safeguarding lead and policy owner. The role includes receiving concerns, assessing immediate safety, seeking advice, agreeing and recording action, making or supporting referrals, managing information securely, identifying conflicts, supporting personnel, monitoring themes and reviewing this policy.
The Director remains accountable for safeguarding decisions made by Kaizen. Where specialist knowledge is needed, independent legal, safeguarding, clinical, research ethics or data protection advice will be sought.
4.2 All Kaizen personnel
Everyone covered by this policy must:
· read and follow this policy and the code of conduct;
· complete safeguarding induction and role-appropriate refresher learning;
· work within their competence, role and agreed terms of reference;
· maintain professional boundaries and declare actual, potential or perceived conflicts of interest;
· report safeguarding concerns promptly and preserve relevant information;
· co-operate with safeguarding action and lawful external enquiries; and
· raise concerns about unsafe practice, including concerns about Kaizen.
4.3 Concerns involving the Director
A concern or allegation involving the Director must not be managed solely by the Director. It should be reported directly to the relevant client safeguarding lead (where connected to client work) and, according to the circumstances, to children’s or adult social care, police, the relevant position-of-trust or allegations service, regulator, commissioner, insurer or professional body. Kaizen Safeguarding will appoint an independent, suitably qualified person to oversee its organisational response and protect the integrity of evidence and decision-making. No person who is the subject of a concern will control the response to that concern.
5. Safer working arrangements
5.1 Recruitment and associates
Kaizen Safeguarding uses proportionate safer recruitment for roles that may involve contact with children or adults at risk, access to sensitive safeguarding information, or significant authority. Depending on the role, this includes a clear role description, application or work history, identity and qualification checks, interview, references, conflict and misconduct declarations, assessment of competence, a code of conduct, supervision and the legally appropriate criminal record or barred-list check. A disclosure check is requested only when the role is legally eligible in the relevant nation.
Associates and subcontractors must meet equivalent standards. Their agreement will specify safeguarding, confidentiality, data protection, insurance, reporting, ownership of records and limits of authority. Kaizen may suspend or end an engagement where safety, integrity or compliance is in doubt.
5.2 Professional boundaries and conduct
Kaizen Safeguarding personnel must not exploit a relationship, misuse authority, create dependency, seek personal benefit, promise outcomes they cannot control, enter an inappropriate sexual or intimate relationship, exchange inappropriate gifts or money, or use information gained through work for personal or organisational advantage. Contact must use agreed professional channels. Any unavoidable boundary crossing, dual relationship or pre-existing connection must be declared, assessed and recorded.
5.3 Direct contact and online activity
Kaizen Safeguarding does not ordinarily provide unsupervised care, pastoral ministry, therapy or social work services to children or adults. If direct work with a child is agreed, it requires a written purpose, parental responsibility and consent analysis, the child’s informed assent where appropriate, a safe setting, clear contact arrangements and the involvement of the client’s safeguarding lead. One-to-one online or in-person contact with a child will be avoided unless specifically risk assessed and necessary.
Online delivery must use appropriate access controls, host permissions, privacy settings and behaviour standards. Private messaging, recording, screenshots or sharing participant details is not permitted unless necessary, lawful, explained and agreed. Participants will be told how to obtain help and report concerns.
6 Recognising safeguarding concerns
A concern may arise from a disclosure, observation, document, pattern, online communication, research response, complaint, allegation, professional disagreement or information from a third party. It may involve current or non-recent abuse, a person who poses a risk, unsafe organisational practice, retaliation, or a failure to respond.
Abuse and harm may include physical abuse, sexual abuse or exploitation, emotional or psychological abuse, neglect, domestic abuse and coercive control, financial or material abuse, organisational abuse, discriminatory abuse, modern slavery and trafficking, criminal exploitation, online abuse, self-neglect, spiritual abuse, harassment, bullying or hate-related harm. Terminology and statutory thresholds differ across the four nations; decisions will use the law and procedures applicable to the person’s location and circumstances.
A child is a person under 18. The statutory definition of an adult covered by adult safeguarding duties differs across the UK. Kaizen Safeguarding will not rely on labels alone: it will consider the applicable national definition, the person’s care and support needs or disability, exposure to harm, ability to protect themselves, coercion, capacity and the risk to others.
7 Responding to a concern or disclosure
The immediate role of Kaizen Safeguarding personnel is to recognise, respond, record, report and reflect. It is not to investigate or determine whether abuse occurred.
7.1 Recognise and respond
· Check whether anyone is in immediate danger or needs urgent medical help. Call 999 where there is an emergency.
· Listen calmly and take the person seriously. Thank them for telling you and acknowledge the difficulty of doing so.
· Do not express disbelief, blame, make promises, press for detail or ask leading questions. Ask only what is necessary to clarify immediate safety and the basic nature, location, time and people involved. Open prompts such as Tell, Explain and Describe may be used.
· Do not promise secrecy. Explain that information will be shared only with people who need it to help keep someone safe or meet a legal duty.
· Do not contact the person alleged to have caused harm, or a parent or carer, where doing so could increase risk, contaminate evidence or conflict with statutory advice.
· Preserve messages, documents or other potential evidence without investigating, circulating or making unnecessary copies.
7.2 Record
Make a factual record as soon as possible, normally on the same day. Record the date, time, place, people present, the person’s words as closely as possible, relevant observations, immediate risk, questions asked, wishes and consent, action taken, advice received and the rationale for decisions. Distinguish fact, professional opinion and information reported by others. Sign and date the record and send it securely to the designated safeguarding lead.
7.3 Report
Report the concern to Kaizen’s designated safeguarding lead without delay. If it arose during client work, also follow the agreed client route unless that route is implicated or doing so would increase risk. A report to Kaizen does not remove anyone’s right to contact police, social care or another authority directly.
The designated safeguarding lead will consider immediate safety, the applicable national threshold and procedures, the person’s wishes and capacity, whether a child or another person may be at risk, alleged criminal conduct, position-of-trust requirements, conflicts of interest, and whether a client, commissioner, regulator, insurer or professional body must be informed. Advice will be sought where the threshold or route is uncertain. Decisions not to refer externally will also be recorded and reviewed if new information arises.
7.4 Consent and information sharing
For children, information may be shared without consent where necessary and proportionate to safeguard or promote welfare. The child and parents or carers should ordinarily be told what will happen unless this may increase risk, prejudice an enquiry, or is otherwise unsafe or unlawful.
For adults, Kaizen will normally seek informed consent before sharing a safeguarding concern. Information may be shared without consent where there is a lawful and proportionate basis, including serious or immediate risk, risk to a child or another adult, suspected serious crime, coercion or undue influence, impaired decision-making capacity, or another legal or regulatory requirement. Refusal of consent and the reasons for any override must be recorded. Capacity is decision-specific and must not be assumed from diagnosis, disability, communication style or an unwise decision.
Data protection law does not prevent necessary safeguarding information sharing. Kaizen Safeguarding will share relevant, accurate and proportionate information with those who need it, use a valid lawful basis and additional condition for special category or criminal offence data where required, record the decision, and share securely.
7.5 Reflect and support
After immediate action, Kaizen Safeguarding will consider whether the person needs information, advocacy, accessibility support, specialist services or a safe follow-up. Personnel affected by receiving distressing information will be offered proportionate reflective supervision or other support. Learning will be captured without compromising confidentiality or live processes.
8. Activity specific safeguards
8.1 Training and events
Before delivery, Kaizen Safeguarding will clarify the host’s safeguarding lead and emergency route, accessibility and support arrangements, expected participants, recording arrangements and how disclosures will be managed. Training will use content warnings and choice where material may be distressing. Case material will be anonymised or fictionalised unless there is a clear lawful and ethical basis for its use. A participant who discloses harm will be responded to under section 7; a training setting will not be turned into a public fact-finding process.
8.2 Consultancy audits and reviews
Every commission will have written terms of reference that define purpose, scope, methodology, authority, deliverables, information governance, ownership and storage of records, reporting routes, conflicts, limitations and arrangements if a safeguarding concern emerges. Kaizen Safeguarding will be clear whether it is advising, auditing, reviewing, investigating or providing supervision. Independence will not be claimed where it cannot reasonably be demonstrated.
A review concerning abuse, organisational failure or lived experience will be planned to minimise re-traumatisation, manage expectations and provide safe participation. Participants will understand the limits of confidentiality, how their information may be used, whether they may withdraw, and what support is available. Relevant evidence will not be destroyed, altered or withheld where a legal hold, statutory process or preservation duty applies.
8.3 Research and consultation
Research will use a proportionate written protocol covering ethical oversight, safeguarding, lawful data processing, recruitment, informed consent, assent where relevant, accessibility, researcher competence, distress, withdrawal, confidentiality limits, incentives, referral pathways, anonymisation, publication and data retention. Participation must be voluntary and must not be shaped by dependency, organisational power, financial pressure or unrealistic promises of change.
Survivors and people with lived experience will not be required to disclose more than is necessary. Where anonymity is offered, its practical limits will be explained, particularly if responses indicate that a child or another person may be at risk. High-risk or sensitive research may require independent ethics review and a specialist distress and disclosure protocol before recruitment begins.
8.4 Survivor support and advocacy
Kaizen Safeguarding will agree the purpose, desired outcome, authority to act, communication channels, review points and limits of the advocacy relationship. The survivor’s account, choices and pace will be respected, while being honest about reporting duties, legal processes and outcomes Kaizen Safeguarding cannot control. Advocacy is not legal representation, counselling, healthcare, crisis support or statutory case management unless separately provided by an appropriately qualified professional.
Kaizen Safeguarding will not use a person’s story, image, identity or case detail in training, publicity, research, campaigning or media work without specific, informed and freely given permission and a lawful basis. Consent can be reviewed; withdrawal may not be able to retract material already lawfully published, and this will be explained in advance.
8.5 Professional supervision and advice
Supervision and advice will operate under a written agreement covering purpose, confidentiality and exceptions, record ownership, emergencies, conflicts and responsibilities. The supervisee and their employer retain responsibility for case decisions and statutory action. If information indicates that someone may be unsafe, Kaizen Safeguarding will support or make appropriate escalation rather than treating supervision as absolutely confidential.
8.6 Public advocacy media and publication
Public-interest advocacy must not expose a survivor, child or adult at risk to identification, retaliation, harassment or avoidable distress. Kaizen will distinguish substantiated fact, allegation, professional opinion and lived experience; apply defamation, privacy, reporting restriction and data protection considerations; obtain specialist advice where necessary; and plan for online abuse or unwanted media attention.
9. Allegations and concerns about people in positions of trust
Any allegation that a Kaizen Safeguarding worker or another professional has harmed a child or adult, may have committed an offence, breached a position of trust, or may pose a risk must be reported immediately through section 7. The person managing it will protect the individual at risk, preserve evidence, avoid alerting the subject where this could prejudice enquiries, and seek advice from the relevant nation’s allegations or position-of-trust route.
Kaizen Safeguarding may use precautionary measures, including changing duties, restricting access to information or suspending an engagement, without implying guilt. Statutory and regulatory processes take priority. The person who is the subject of an allegation will be treated fairly, informed when safe and lawful, and offered an appropriate contact and support. Where legal criteria are met, Kaizen Safeguarding will make referrals to the Disclosure and Barring Service, Access NI or Disclosure Scotland and any relevant regulator or professional body.
10. Partnerships and international work
Before joint work, Kaizen Safeguarding will undertake safeguarding due diligence proportionate to risk and agree who leads on safeguarding, referrals, vetting, incident management, communications and data control. A partner’s policy does not displace this policy where Kaizen personnel are involved. Concerns about a partner’s response may be escalated outside the partnership.
For work outside the UK, Kaizen Safeguarding will apply local law, reporting routes and cultural knowledge alongside this policy and relevant UK law with extraterritorial effect. A country-specific safeguarding and security plan will address the safety and effectiveness of authorities, alternative escalation, travel, interpreters, digital security, consent, power and resource inequalities, and support. Local custom or organisational reputation will never justify abuse, exploitation or suppression of a concern.
11. Information governance and records
Safeguarding information is handled under the UK GDPR, Data Protection Act 2018, confidentiality duties, contractual requirements and Kaizen Safeguarding’s privacy arrangements. Before receiving client records, Kaizen Safeguarding will clarify whether it acts as controller, joint controller or processor; the written terms will reflect the actual decision-making relationship.
· Collect only information necessary for the stated purpose and avoid unnecessary duplication.
· Keep safeguarding records separate where practicable, access-controlled, encrypted or otherwise securely protected, with access limited to those who need it.
· Use secure transfer methods and verify recipients before sending sensitive information.
· Apply a documented retention schedule based on purpose, legal and contractual duties, limitation periods, the needs of people affected, and any investigation, inquiry, litigation or preservation hold. Records will not be kept for an arbitrary blanket period.
· Correct factual inaccuracies without erasing the original record or audit trail. Professional opinions may be supplemented by later information.
· Report and manage personal data breaches promptly, including assessment of notification to the Information Commissioner’s Office and affected people where legally required.
12. Complaints speaking up and non retaliation
Anyone may raise a safeguarding concern or complaint about Kaizen Safeguarding through info@kaizensafeguarding.org or directly with a relevant statutory body. A person will not be disadvantaged for raising a genuine concern, supporting another person or challenging unsafe practice. Malicious or knowingly false information may be addressed, but an unsubstantiated concern is not by itself malicious.
Complaints about service quality will follow Kaizen Safeguarding’s complaints process. Safeguarding concerns will be managed under this policy even when first presented as a complaint. Where independence is compromised, Kaizen Safeguarding will commission external handling or direct the matter to the appropriate authority. Confidentiality cannot be used to silence a person from reporting a concern to police, social care, a regulator, legal adviser or prescribed whistleblowing body.
13. Training supervision and wellbeing
Kaizen Safeguarding personnel will receive safeguarding induction and learning proportionate to role, jurisdiction and exposure. Competence is maintained through updates, reflective supervision, case consultation, professional development and review of law and guidance. Work allocation will consider cumulative exposure to traumatic material. Support may include reflective supervision, peer or clinical consultation, counselling or time away from particular work. Support does not replace safe workload design, competent management or accountability.
14. Monitoring review and assurance
The Director will review this policy at least annually and sooner after a significant incident, learning review, complaint, change in Kaizen’s services, relevant legal or guidance change, or evidence that the policy is not working. Assurance will consider training, concerns and response times, referrals and outcomes, complaints, data incidents, conflicts, participant feedback, partnership compliance and learning implemented. Information used for assurance will be minimised and anonymised where possible.
15. UK legal and practice framework
The following is a proportionate reference framework, not an exhaustive legal digest. The law and procedures of the nation in which the person is located and the concern arises will ordinarily guide the response. Cross-border cases require early clarification of lead agencies and may engage more than one framework.
4 UK Nations Principal legislation and guidance
UK wide
Human Rights Act 1998; Equality Act 2010 (with separate NI anti-discrimination law); Data Protection Act 2018 and UK GDPR; Safeguarding Vulnerable Groups Act 2006; Modern Slavery Act 2015; Domestic Abuse Act 2021 where territorially applicable; relevant sexual offences, criminal, employment and charity law.
Information Commissioner’s Office guidance; DBS guidance; local multi-agency procedures.
England
Children Act 1989; Children Act 2004; Care Act 2014; Mental Capacity Act 2005; Protection of Freedoms Act 2012.
Working Together to Safeguard Children 2026; Keeping Children Safe in Education 2026; Care and Support Statutory Guidance, especially chapter 14; local safeguarding children partnership and Safeguarding Adults Board procedures.
Scotland
Children (Scotland) Act 1995; Children and Young People (Scotland) Act 2014; Adult Support and Protection (Scotland) Act 2007; Adults with Incapacity (Scotland) Act 2000; Disclosure (Scotland) Act 2020.
National Guidance for Child Protection in Scotland 2021, updated 2023; Adult Support and Protection Code of Practice 2022; local Child Protection Committee and Adult Protection Committee procedures.
Wales
Children Act 1989; Children Act 2004; Social Services and Well-being (Wales) Act 2014, particularly Part 7; Mental Capacity Act 2005; Violence against Women, Domestic Abuse and Sexual Violence (Wales) Act 2015.
Working Together to Safeguard People statutory guidance; Wales Safeguarding Procedures, including current Section 5 procedures for allegations against practitioners and those in positions of trust; Regional Safeguarding Board procedures.
Northern Ireland
Children (Northern Ireland) Order 1995; Safeguarding Vulnerable Groups (Northern Ireland) Order 2007; Sexual Offences (Northern Ireland) Order 2008; Safeguarding Board Act (Northern Ireland) 2011; Mental Capacity Act (Northern Ireland) 2016; Domestic Abuse and Civil Proceedings Act (Northern Ireland) 2021; Justice (Sexual Offences and Trafficking Victims) Act (Northern Ireland) 2022; Criminal Law Act (Northern Ireland) 1967.
Co-operating to Safeguard Children and Young People in Northern Ireland; SBNI Regional Core Child Protection Policies and Procedures; Adult Safeguarding Prevention and Protection in Partnership; regional HSC adult safeguarding and child Gateway procedures.
16 Contact and escalation
Immediate danger or urgent medical need - call 999.
Non-emergency police concern -contact the relevant local police service using 101 or its published reporting route.
Child or adult safeguarding concern - contact the relevant local authority social care service, HSC Trust Gateway or adult safeguarding service, following the current local procedure, e.g. LADO in England and Wales..
Concern about Kaizen Safeguarding - Email info@kaizensafeguarding.org. If the concern involves the Director or requires independence, report directly to the client safeguarding lead and/or appropriate statutory or regulatory body.
Uncertain jurisdiction or threshold - Protect immediate safety, preserve information and obtain advice from the relevant statutory service or suitably qualified adviser without avoidable delay.
Contact details for statutory services change. Current details must be verified from the relevant government, local authority, HSC Trust, police or safeguarding partnership website at the time of referral.
Appendix 1 Quick response guide
Recognise
Notice a disclosure, observation, allegation, pattern, unsafe practice or other information indicating harm or risk.
Respond
Check immediate safety; listen; take seriously; do not blame, promise secrecy or investigate; obtain urgent help if needed.
Record
Write a timely, factual, dated account using the person’s own words and separating fact from opinion.
Report
Tell Kaizen’s safeguarding lead and follow the agreed client route. Escalate directly if the normal route is implicated or unsafe.
Reflect
Confirm action and support, record the rationale, review wellbeing and capture learning without compromising live processes.
Appendix 2. Minimum safeguarding record
· Name and contact details of person raising the concern and person affected, where known and necessary;
· date, time, location and context;
· what was seen, heard or disclosed, using exact words where possible;
· immediate safety or medical needs and action taken;
· people allegedly involved and any continuing access or position of trust;
· wishes, consent, capacity or communication considerations;
· who was informed, when, advice received and decisions made;
· lawful sharing, referrals, reference numbers and agreed follow-up;
· professional opinion clearly identified as such; and
· name, signature or secure identifier of recorder and date completed.
Records must be sent and stored securely. Do not retain safeguarding records on personal devices, personal email accounts or unapproved platforms.
Appendix 3 Core source links
· England Working Together to Safeguard Children 2026
· England Care and Support Statutory Guidance
· Scotland National Guidance for Child Protection
· Scotland Adult Support and Protection
· Wales Safeguarding Procedures
· Wales Working Together to Safeguard People
· Northern Ireland Co-operating to Safeguard Children and Young People
· Northern Ireland Adult Safeguarding Prevention and Protection in Partnership
· Northern Ireland SBNI procedures
· Information Commissioner’s Office data sharing guidance
This policy should be read with Kaizen’s code of conduct, complaints procedure, privacy information, data retention schedule, research or project protocol, and the terms of reference or contract for the relevant work.