At Athena Activities we respect the privacy of the children attending the Club and the privacy of their parents or carers. Our aim is to ensure that all those using and working at Athena Activities can do so with confidence. 

We will respect confidentiality in the following ways: 

• Parents can ask to see the records relating to their child, but will not have access to information about any other children. 
• Leaders only discuss individual children for purposes of planning and group management. 
• Leaders are made aware of the importance of confidentiality during their induction process. 
• Information given by parents to Athena Activities Leaders will not be passed on to third parties without permission unless there is a safeguarding issue (as covered in our Safeguarding Policy). 
• Concerns or evidence relating to a child’s safety, will be kept in a confidential file and will not be shared within Athena Activities, except with the designated Child Protection Officer and the manager. 
• Issues relating to the recruitment of Leaders, whether paid or voluntary, will remain confidential to those making personnel decisions.
• Confidential records are stored securely in a lockable file.   
• Students/visitors on work placements are informed of our confidentiality policy and are required to respect it. 

Sharing information with outside agencies 
We will only share information with outside agencies on a need-to-know basis and with consent from parents, except in cases relating to safeguarding children or criminal activity. If we decide to share information without parental consent, we will record this in the child’s file, clearly stating our reasons.  

We will only share relevant information that is accurate and up to date. Our primary commitment is to the safety and well-being of the children in our care.   

Data Protection Act 
We comply with the requirements of the Data Protection Act 1998, regarding obtaining, storing and using personal data. 

We are registered with the Information Commissioner’s Office. 

Athena Activities Limited is committed to building a ‘culture of safety’ in which the children in our care are
protected from abuse and harm.
Athena Activities Limited will respond promptly and appropriately to all incidents or concerns of abuse that may
occur. Athena Activities Limited child protection procedures comply with all relevant legislation and with guidance
issued by the Local Safeguarding Children Board (LSCB).
Athena Activities Limited Designated Safeguarding Officers (DSL) are Robert Anderson, Rosemary Saunders, Joanna
Norton and Debbie Edwards. The DLS coordinates child protection issues and liaises with external agencies (eg
LADO, MASH, the Local Safeguarding Children’s Board and Ofsted).

Forms of child abuse and neglect
Child abuse is any form of physical, emotional, or sexual mistreatment or lack of care that leads to injury or harm.
An individual may abuse or neglect a child directly, or by failing to protect them from harm. Some forms of child
abuse and neglect are listed below.

• Emotional abuse is the persistent emotional maltreatment of a child so as to cause severe and persistent adverse effects on the child’s emotional development. It may involve making the child feel that they are worthless, unloved, or inadequate. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
• Physical abuse can involve hitting, shaking, throwing, poisoning, burning, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may be also caused when a parent or carer feigns the symptoms of, or deliberately causes, ill health to a child.
• Sexual abuse involves forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. This can involve physical contact, or non-contact activities such as showing children sexual activities or encouraging them to behave in sexually inappropriate ways, showing sexual images. This also includes child sexual exploitation and female genitalia mutilation. See below for more detail.
• Neglect is the persistent failure to meet a child’s basic physical and emotional needs. It can involve a failure to provide adequate food, clothing, and shelter, to protect a child from physical and emotional harm, to ensure adequate supervision or to allow access to medical treatment.

Signs of child abuse and neglect
Signs of possible abuse and neglect may include:

• significant changes in a child’s behaviour
• deterioration in a child’s general well-being
• unexplained bruising or marks
• comments made by a child which give cause for concern
• inappropriate behaviour displayed by other members of staff, or any other person. For example, inappropriate sexual comments, excessive one-to-one attention beyond the requirements of their role, or inappropriate sharing of images.

Female Genital Mutilation (FGM)
FGM refers to the practice, which is traditional in some cultures, of partially or totally removing the external
genitalia of females for non-medical reasons. This is illegal in the UK and considered child abuse, more specifically
sexual abuse. FGM is not affiliated with any religion and is not supported by religion. FGM is considered a hidden
crime.
Signs of FGM:

• have difficulty walking, sitting or standing
• spend longer than normal in the bathroom or toilet
• ask for help, but may not be explicit about the problem due to embarrassment or fear
• talk about a secret procedure that they are not allowed to talk about
• unexpected visit from an elderly female family member

Child Sexual Exploitation
Child sexual exploitation is a type of sexual abuse in which children are sexually exploited for money, power or
status. Children may be tricked into thinking they are in a loving relationship and that the relationship is consensual.
This may also involve drugs or alcohol. CSE is considered a hidden crime and can also happen online and in gangs.
Signs of CSE:

• Overtly sexual behaviour
• Be intimidated and fearful of particular situations
• Involvement with gangs
• Association with other young children who have been known to be involved in CSE
• Spend time at places of concern (hotels, brothels)
• Not knowing where they are because they have been moved around the country
• Going missing from home, care, or education

If abuse is suspected or disclosed
When a child makes a disclosure to a member of staff, that member of staff will:

• Reassure the child that they were not to blame and were right to speak out
• Listen to the child but not question them
• Inform we will not to keep secrets
• Give reassurance that the staff member will take action
• Record the incident as soon as possible (see Logging an incident below)

If a member of staff witnesses or suspects abuse, they will record the incident straightaway. If a third party
expresses concern that a child is being abused, we will encourage them to contact Social Care directly. If they will
not do so, we will explain that Athena Activities Limited is obliged to and the incident will be logged accordingly.

Logging an incident
All information about the suspected abuse or disclosure will be recorded on the Logging a Concern form as soon as
possible after the event. Forms will be kept at reception within the colour-coded blank forms folder. The record
should include:

• Date of the disclosure or of the incident causing concern
• Date and time at which the record was made
• Name and date of birth of the child involved
• A factual report of what happened. If recording a disclosure, you must use the child’s own words.
• Name, signature and job title of the person making the record.

The record will be given to Athena Activities Limited DSL who will decide whether they need to contact Social Care
or make a referral. All referrals to Social Care will be followed up in writing within 48 hours.
If any member of staff thinks that the incident has not been adequately dealt with, they may contact Social Care
themselves.

Private Fostering
If a child under the age of 16 (or aged 18 if disabled) is living in a private arrangement with someone who is not
their parent, step-parent, grandparent, aunt/uncle or adult sibling, for 28 days or more then local authority must be
notified. This is likely to be a private fostering arrangement.

Prevent Duty
This refers to the duty to prevent and protect children from the risk of radicalisation. From 1st July 2015, it became
law that all school and childcare providers engage in prevent duty. In order to protect children in the care of CSD
staff must be alert to any reasons for concern in the child’s life at home or elsewhere. Directors, managers and
assistant managers should all undergo specific training for this. If any concerns are raised, they should be reported
to the designated people on site. All precautions should be taken to ensure children have no access to materials
involving radicalisation including internet access.

British Values
British values refer to the values installed in early years, these are the rule of law, mutual respect and tolerance of
different faiths and beliefs, democracy and individual liberty. These should be taught and followed throughout
camp.

Allegations against staff

• For allegations against staff, please see whistleblowing policy.

Selection and Recruitment of Staff
Recruitment must take place in accordance with the CSD Safer Recruitment Policy.
For those posts involving regular or close contact with children, the preferred candidate requires
satisfactory completion of the following prior to commencement in post:

• Disclosure Barring Service (DBS) Enhanced check.
• Professional Register check (if applicable).
• Confirmation of identity through official documents, particularly if they are married or have otherwise changed their name.
• Verification of authenticity of qualifications.
• Verification of employment and professional references for most recent employer.

Promoting awareness among staff
Athena Activities Limited promotes awareness of child abuse issues through its staff training. Athena Activities
Limited ensures that:

• Its designated DSL has relevant experience and receives appropriate training
• Safe recruitment practices are followed for all new staff
• All staff have a copy of this Safeguarding Children policy, understand its contents and are vigilant to signs of abuse or neglect
• All staff are aware of their statutory requirements with regard to the disclosure or discovery of child abuse
• Staff are familiar with the Safeguarding File which is kept at reception on the Athena Activities Limited folder trolley.
• Staff are familiar with the ‘What To Do If You’re Worried A Child Is Being Abused’ flowchart
• Its procedures are in line with the guidance in ‘Working Together to Safeguard Children’ (2018)’.
  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/942454/ Working_together_to_safeguard_children_inter_agency_guidance.pdf

Safe Caring
All staff understand Athena Activities Limited child protection procedures and have had appropriate training and
guidance in the principles of safe caring. To this end:

• Every effort will be made to avoid or minimise time when members of staff, students or volunteers are left alone with a child. If staff are alone with a child, the door of the room should be kept open and another member of staff should be informed.
• If a child makes inappropriate physical contact with a member of staff, students or volunteer, this will be recorded fully in the Incident Record Book.
• Staff will never carry out a personal task for children that they can do for themselves. Where this is essential, staff will help a child whilst being accompanied by a colleague. Unless a child has a particular need, staff should not accompany children into the toilet. Staff are aware that this and other similar activities could be misconstrued.
• Staff will be mindful of how and where they touch children, given their age and emotional understanding. Unnecessary or potentially inappropriate physical contact will be avoided at all times.
• All allegations made by a child against a member of staff will be fully recorded, including any actions taken, in the Incident Record Book. In the event of there being a witness to an incident, they should sign the records to confirm this.

Use of mobile phones and cameras – Refer to separate Mobile Phone policy.

Who to contact
If you have any concerns at all, your designated safeguarding officer should be the first point of contact. For CSD
these are Rosemary Saunders or Robert Anderson, Joanna Norton or Debbie Edwards. Rosemary Saunders should
be informed of all concerns.
If you feel like any of the children in your care are ‘unsafe’ or you have any concerns about this safeguarding policy,
then the Multi-Agency Safeguarding Hub (MASH) should be contacted immediately.

Contact numbers
MASH: 0300 1263000 – email MASH@nctrust.co.uk
LADO (Local Authority Designated Officer): 07831 123193 or 07850854309 or 01604 362993
LADO email ladoconsultations@nctrust.co.uk
LADO Out of Hours team: 01604 837999
LSCB (Local Safeguarding Children Board): 0300 126 7000
Ofsted: 0300 123 1231
Police: 101/999 in emergencies
NSPCC: 0808 800 500

A) INTRODUCTION
We may have to collect and use information about people with whom we work.  This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means. 

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business.  We will ensure that we treat personal information lawfully and correctly. 

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR). 

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR. 

This policy applies to the personal data of job applicants, existing and former employees, apprentices, volunteers, placement students, workers and self-employed contractors. These are referred to in this policy as relevant individuals. 

B) DEFINITIONS
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.  

“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes). 

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences. 

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

C) DATA PROTECTION PRINCIPLES 
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that: 

1. processing will be fair, lawful and transparent  
2. data be collected for specific, explicit, and legitimate purposes 
3. data collected will be adequate, relevant and limited to what is necessary for the purposes of processing 
4. data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay 
5. data is not kept for longer than is necessary for its given purpose 
6. data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures 
7. we will comply with the relevant GDPR procedures for international transferring of personal data 

D) TYPES OF DATA HELD
We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system. 

Specifically, we hold the following types of data: 

1. personal details such as name, address, phone numbers 
2. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history etc 
3. details relating to pay administration such as National Insurance numbers, bank account details and tax codes 
4. medical or health information  
5. information relating to your employment with us, including: 
   1. job title and job descriptions 
   2. your salary  
   3. your wider terms and conditions of employment 
   4. details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information 
   5. internal and external training modules undertaken 

All of the above information is required for our processing activities. More information on those processing activities are included in our privacy notice for employees, which is available from your manager. 

E) EMPLOYEE RIGHTS  
You have the following rights in relation to the personal data we hold on you: 

1. the right to be informed about the data we hold on you and what we do with it; 
2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”; 
3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’; 
4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’; 
5. the right to restrict the processing of the data;  
6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’; 
7. the right to object to the inclusion of any information; 
8. the right to regulate any automated decision-making and profiling of personal data. 

More information can be found on each of these rights in our separate policy on employee rights under GDPR. 

F) RESPONSIBILITIES
In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection. 

We have also appointed employees with responsibility for reviewing and auditing our data protection systems.