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Being prepared for safeguarding

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As a charity or foundation, you must make sure you’re doing all you can to keep people safe. As a grant maker, no matter what size of the grants, you must also make sure the people you give grants to are doing all they can to keep people safe.

The Charity Commission requires that you:

  • carry out due diligence checks on that organisation to make sure it’s suitable
  • check it has appropriate safeguarding procedures in place
  • make sure there are clear lines of responsibility and reporting between all bodies involved
  • have a written agreement or contract.

If you’re starting on safeguarding from scratch, use this guide alongside other advice such as the pages in steps to a safer organisation.

Your people (staff and volunteers)

Your staff who deal with grants may have varying responsibilities that need to be considered as you decide what level of recruitment checks, training and support they need.

  • Do they assess applications and carry out due diligence checks?
  • Do they attend monitoring visits to groups including children or adults at risk? Do they do this alone?
  • Will they be involved in the process when a grantholder reports a safeguarding concern?

Things that must be in place:

  • The right level of safeguarding training. Our training page can help you find and review training.
  • A policy for risk assessment of monitoring visits and a lone working policy if needed.
  • The right level of disclosure and barring and other recruitment checks for the role. Our checking staff and volunteers page can help with decisions regarding checks.

Complaints and whistleblowing

Sometimes, when people have a safeguarding concern about an organisation, they will want to tell the people who fund it, rather than the organisation itself.

You must make sure that whoever deals with complaints looks out for when someone is whistleblowing about a safeguarding issue in one of your grant organisations.

You also need to make sure you have a whistleblowing policy in case your staff or volunteers feel like their safeguarding concerns are not being listened to.

Decision making and concerns

Your safeguarding policy and procedures must identify who in your organisation is the designated safeguarding lead. They will oversee all the usual procedures for raising safeguarding concerns within the organisation. You must make sure that there is a specific procedure for making decisions about safeguarding concerns that relate to grant applicants and grant holders.

When you are creating that section of your procedures, there are some key questions you should ask yourself:

  • Do you need different approaches depending on when the concern is raised? For example, during the assessment or when a grant is running.
  • When will you need to involve senior staff and/or trustees?
  • Do you have enough expertise in-house or will you need to seek external support if a safeguarding concern about a grant holder is raised?
  • If you are contacted directly about the concern, when do you inform the grant holder?

Information sharing and data protection

Like in any organisation, you must take care to make sure you meet rules about data protection and data sharing under the General Data Protection Regulation (GDPR). One specific area that grant makers need to think about is sharing case studies, images and quotes from either grant recipients or the people they work with.

  • Remember, you must get informed consent about exactly what you intend to use the data for.
  • Remember that there are ethical considerations as well as laws to think about.
  • Consider whether the information you share might put people at risk.
  • Take into account the emotional impact of asking people to share their stories.
  • For children or adults unable to give informed consent, you may need to also ask their parent or carer.

You must make it clear to all your grant holders that safeguarding responsibilities override data protection and privacy rules. In your grant agreement, make it clear that you must be given information when:

  • An allegation has led to an investigation and/or referral to the police, local authority or other regulatory body - such as the Disclosure and Barring Service (DBS).
  • A breach or failure of policy which could have put people at risk of harm and/or resulted in a referral to the police, local authority or regulatory body.

If you want to know more about data protection and sharing within safeguarding, use storing and sharing information from our guide for designated safeguarding leads.

If you want to know more about collecting case studies safely, see our guide for communication and marketing managers for further details.

Investment and fundraising

Make sure you’ve considered how safeguarding could affect how you invest your assets and raise money. Trustees have a duty to get the best return on their investments. However, they must make sure their choice of investment doesn’t harm those they seek to help and isn’t connected to activities which are criminal or unethical.

You should:

  • carry out due diligence checks on all organisations you intend to do business with before making investments or setting up partnerships
  • have a schedule for renewing checks on long term investments
  • have a policy for what could be considered as safeguarding or reputational risks that you will not be accepted.

Joint funding

Where you are providing co-funding with another organisation, make sure you’ve put arrangements in place for how you will share relevant information with each other. For example, this could be serious safeguarding concerns or information relating to investigations.

Want to know more? Our guide to working with partners gives ideas for making shared safeguarding arrangements.

Helpful resources

  • If you’re new to safeguarding, you should start with what is safeguarding? This page explains why it’s important and contains what you need to know about why all charities must do safeguarding.
  • If you know about safeguarding and want to find out more about what you need to do overall, then use our getting started with safeguarding page. This maps our resources to the Charity Commission’s expectations.
  • If you already have a good general understanding of safeguarding, you can get started with specialist guides for funders. It comes in two sections. Safeguarding in the grant making process has two sections that work through all the different things that should be in place to support applicants and grant holders.
  • Independent trusts and charitable foundations as well as other grant making charities (e.g. intermediary grant makers) can use the Association of Charitable Foundations' Safeguarding Framework for Foundations to consider their own internal practices and integrate safeguarding within their funding cycle.
  • Charitable trusts and foundations, intermediary funders, and funder networks can join the Funder Safeguarding Collaborative for free. Members can connect with likeminded funders, a range of support and training and opportunities to invest in initiatives to improve practice.

Last reviewed: 18 June 2021

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This page was last reviewed for accuracy on 18 June 2021

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