Let’s Make Noise

POLICY AND PROCEDURE

Safeguarding Policy

Safeguarding Children, Young People and Adults at Risk

Document controlDetails
DocumentSafeguarding Policy
VersionVersion 2.0
StatusApproved by the Board of Trustees
Effective date29 October 2026
Next scheduled reviewOctober 2027
Policy ownerNawal Sulieman, Designated Safeguarding Officer
Approved byThe Board of Trustees: Osman Osman (Chair), Fahad Hassan and Faduma Mohamed
Applies toAll trustees, staff, volunteers, contractors and partners
SupersedesSafeguarding Policy, Version 1.4 (04 January 2026)

Let’s Make Noise · Registered Charity in England and Wales No. 1212537
Office 705, Avicenna House, 258–262 Romford Road, London E7 9HZ
info@letsmakenoise.org · 020 8058 9885 · www.letsmakenoise.org

1. Policy Statement

1.1 Let’s Make Noise ("the Charity", "we", "us" or "our") is a Charitable Incorporated Organisation registered with the Charity Commission for England and Wales under charity number 1212537. The Charity provides free, inclusive and accessible programmes for children and young people with special educational needs and disabilities (SEND), and support for their parents, carers and families.

1.2 The Charity recognises that the welfare of every child, young person and adult at risk is paramount. We have a legal, moral and professional duty to safeguard and promote the welfare of all those who participate in our programmes, attend our events or engage with our services, whether in person or through our digital platforms, including www.letsmakenoise.org.

1.3 We are committed to fostering a culture of vigilance in which safeguarding is everybody’s responsibility, concerns are raised and acted upon without delay, and every individual is treated with dignity, respect and compassion. We adopt a zero-tolerance approach to abuse, neglect, exploitation and discrimination in any form.

1.4 This Policy has been adopted by the Board of Trustees and is binding upon all individuals within its scope. It should be read in conjunction with the Charity’s Privacy Policy, Photography and Consent Procedures, Whistleblowing Policy, Health and Safety Policy, Equality, Diversity and Inclusion Policy and Complaints Procedure.

2. Purpose and Objectives

2.1 The purpose of this Policy is to establish a robust, transparent and legally compliant framework for the protection of children, young people and adults at risk. Its principal objectives are to:

  1. protect children, young people and adults at risk from abuse, neglect, exploitation and harm while they are engaged in the Charity’s activities;
  2. provide staff, volunteers, trustees and contractors with clear guidance on recognising, responding to, recording and reporting safeguarding concerns;
  3. define the roles, responsibilities and lines of accountability for safeguarding within the Charity;
  4. ensure that safer recruitment, vetting, induction and training procedures are rigorously applied;
  5. promote safe working practices that protect participants and minimise the risk of unfounded allegations against those working on the Charity’s behalf; and
  6. ensure effective co-operation and information sharing with statutory agencies, including local authority children’s and adult social care, the police and the Local Authority Designated Officer (LADO).

3. Scope and Application

3.1 This Policy applies to all individuals working for or on behalf of the Charity in any capacity, including trustees, employees, sessional workers, volunteers, students and work experience participants, contractors, freelance practitioners, delivery partners and any person acting in the Charity’s name (collectively, “personnel”).

3.2 It applies to all activities delivered, organised or hosted by the Charity, including but not limited to speech and language therapy sessions, the Life Skills Initiative (cooking classes, supported work experience, money management and social skills sessions), fun days out, residential or off-site visits, the Let’s Make Noise Cup and associated public events, fundraising activities and all online and digital engagement.

3.3 The Charity works with children (under 18 years of age) and with young adults aged 18 and over who have SEND. Where a participant is aged 18 or over and may be an adult at risk, the provisions of this Policy apply equally, having due regard to the Care Act 2014, the Mental Capacity Act 2005 and the individual’s right to make their own decisions.

3.4 Where activities are delivered in partnership, the Charity will agree in writing, before delivery commences, which organisation’s safeguarding procedures take precedence and who holds lead safeguarding responsibility.

4. Legislative and Statutory Framework

4.1 This Policy is informed by, and should be interpreted in accordance with, the following legislation, statutory guidance and regulatory expectations (as amended or superseded from time to time):

Legislation and guidanceRelevance
Children Act 1989 and Children Act 2004The paramountcy of the child’s welfare; duties to co-operate and to safeguard and promote welfare.
Working Together to Safeguard Children (2023)Statutory guidance on multi-agency working, referral and information sharing.
Children and Families Act 2014 and the SEND Code of Practice: 0 to 25 yearsThe legal framework for children and young people with SEND up to the age of 25.
Care Act 2014 and the Mental Capacity Act 2005Safeguarding adults at risk and supporting decision-making for those aged 18 and over.
Safeguarding Vulnerable Groups Act 2006 and the Protection of Freedoms Act 2012Regulated activity, barring and Disclosure and Barring Service (DBS) checks.
Equality Act 2010Duties to prevent discrimination and to make reasonable adjustments for disabled people.
UK GDPR and the Data Protection Act 2018Lawful recording, retention and sharing of safeguarding information.
Sexual Offences Act 2003; Female Genital Mutilation Act 2003; Modern Slavery Act 2015; Domestic Abuse Act 2021Specific forms of abuse, exploitation and mandatory reporting duties.
Counter-Terrorism and Security Act 2015 (Prevent)Recognising and responding to the risk of radicalisation.
Online Safety Act 2023The online safety of children and young people.
Charity Commission guidance: Safeguarding and protecting people for charities and trusteesTrustee accountability and the reporting of serious incidents.
London Child Protection Procedures and Newham Safeguarding Children Partnership proceduresLocal multi-agency referral pathways.

5. Definitions

TermMeaning for the purposes of this Policy
ChildAny person who has not yet reached their 18th birthday.
Young adultA person aged 18 to 25 participating in the Charity’s programmes, consistent with the SEND Code of Practice.
Adult at riskA person aged 18 or over who has needs for care and support, is experiencing or at risk of abuse or neglect, and as a result of those needs is unable to protect themselves.
SafeguardingProtecting individuals from maltreatment; preventing impairment of their health or development; ensuring they grow up in circumstances consistent with safe and effective care; and taking action to enable the best outcomes.
Child protectionActivity undertaken to protect specific children who are suffering, or are likely to suffer, significant harm.
Designated Safeguarding Officer (DSO)The person appointed by the Charity to lead on safeguarding, receive concerns and make referrals.
PersonnelAll persons within the scope of paragraph 3.1.

6. Guiding Principles

6.1 The Charity’s safeguarding practice is founded upon the following principles:

  • Paramountcy: the welfare and best interests of the child or adult at risk are the overriding consideration in every decision.
  • Shared responsibility: safeguarding is the responsibility of everyone; no single individual holds the complete picture.
  • Child-centred and person-centred practice: we listen to children and young people, take their views seriously and communicate in ways appropriate to their needs.
  • Equality and inclusion: every individual has an equal right to protection, regardless of age, disability, ethnicity, religion or belief, sex, gender identity, sexual orientation or socio-economic background.
  • Prevention and early help: we seek to identify concerns at the earliest opportunity and to work in partnership with families and agencies.
  • Proportionality and accountability: we respond in a manner proportionate to the risk and are accountable for the decisions we make.
  • Making Safeguarding Personal: for adults at risk, we seek to involve the individual and to respect their wishes wherever it is safe and lawful to do so.

7. Recognising Abuse, Neglect and Exploitation

7.1 All personnel must be alert to the signs and indicators of abuse, neglect and exploitation. Abuse may be perpetrated by adults or by other children, may occur in person or online, and may take place in the home, in the community or within organisations.

CategoryDescription and possible indicators
Physical abuseHitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating or otherwise causing physical harm, including fabricated or induced illness. Indicators include unexplained injuries or inconsistent explanations.
Emotional abusePersistent emotional maltreatment causing severe adverse effects on emotional development, such as conveying that a child is worthless or unloved, humiliation, intimidation or exposure to domestic abuse.
Sexual abuseForcing or enticing a child or adult at risk to take part in sexual activity, whether or not they are aware of what is happening, including non-contact and online activity.
NeglectPersistent failure to meet basic physical or psychological needs, including adequate food, clothing, shelter, supervision, medical care or access to education.
ExploitationChild sexual exploitation (CSE), child criminal exploitation (CCE) including “county lines”, modern slavery and financial exploitation.
Child-on-child abuseBullying (including cyberbullying), physical abuse, sexual harassment or violence, and the non-consensual sharing of images between children.
Other forms of harmDomestic abuse, so-called honour-based abuse, female genital mutilation (FGM), forced marriage, radicalisation and online abuse.
Adults at risk (additional)Financial or material abuse, discriminatory abuse, organisational abuse, self-neglect and psychological abuse.

8. Children and Young People with SEND: Additional Vulnerabilities

8.1 The Charity recognises that children and young people with SEND may face additional safeguarding vulnerabilities and barriers to disclosure. Personnel must therefore exercise heightened vigilance and professional curiosity.

8.2 In particular, personnel must not assume that indicators of possible abuse, such as changes in behaviour, mood or injury, are attributable solely to a child’s disability or condition without further consideration. Additional vulnerabilities include:

  • communication difficulties that may prevent a child from disclosing harm, or from being understood when they attempt to do so;
  • dependency on others for intimate and personal care, which may increase exposure to harm;
  • reduced capacity to recognise abusive or exploitative behaviour, including online grooming;
  • heightened susceptibility to bullying, isolation, peer pressure and criminal or sexual exploitation; and
  • the potential for behaviour that challenges to be misinterpreted, or to result in inappropriate restraint.

8.3 The Charity will make reasonable adjustments to enable every participant to communicate concerns, including the use of visual supports, Makaton, symbols, communication aids and trusted adults, in accordance with the Equality Act 2010.

9. Roles and Responsibilities

9.1 Board of Trustees

The Board of Trustees holds ultimate accountability for safeguarding. Trustees shall: approve and annually review this Policy; appoint a Designated Safeguarding Officer and a lead Safeguarding Trustee; ensure that adequate resources, training and supervision are in place; receive regular safeguarding reports; and ensure that serious incidents are reported to the Charity Commission and other relevant bodies.

9.2 Designated Safeguarding Officer (DSO)

The DSO shall: act as the first point of contact for all safeguarding concerns; assess concerns and make timely referrals to statutory agencies; maintain accurate, secure and confidential safeguarding records; arrange safeguarding training and induction; provide advice and support to personnel; liaise with partner organisations; and report to the Board of Trustees. A Deputy DSO shall be appointed to ensure continuity of cover.

9.3 Project Manager

The Project Manager shall ensure that every activity is subject to a documented risk assessment, appropriate supervision ratios and a named safeguarding lead on the day; that personnel are suitably vetted and briefed; and that consent, medical and emergency contact information is obtained before participation.

9.4 Staff, Volunteers and Contractors

All personnel shall read, understand and comply with this Policy; complete safeguarding training appropriate to their role; adhere to the Code of Conduct; and report any concern, disclosure or allegation to the DSO immediately and in any event on the same day.

9.5 Parents, Carers and Participants

Parents and carers are encouraged to familiarise themselves with this Policy, to provide accurate information regarding their child’s needs, and to raise any concern with the DSO. Parents and carers retain responsibility for their children at events where this has been expressly agreed, such as open public events.

10. Safer Recruitment, Vetting and Training

10.1 The Charity operates safer recruitment practices for all roles involving contact with children, young people or adults at risk. These include a written role description, application form, structured interview, verification of identity and right to work, at least two satisfactory references and a declaration of any criminal convictions.

10.2 All personnel engaged in regulated activity shall obtain an Enhanced Disclosure and Barring Service (DBS) check with a check of the relevant barred list(s) before commencing their role. DBS checks shall be renewed at least every three years, or personnel shall be registered with the DBS Update Service.

10.3 All new personnel shall complete an induction, including this Policy and the Code of Conduct, before working unsupervised. Safeguarding training shall be refreshed at least every three years, with annual briefings on updates. The DSO and Deputy DSO shall undertake advanced (Level 3 or equivalent) safeguarding training.

10.4 Volunteers and staff shall be subject to a probationary period and appropriate supervision. Any person who is barred from working with children or adults at risk shall not be engaged in any capacity.

11. Code of Conduct

11.1 All personnel shall uphold the highest standards of personal and professional conduct. Personnel must:

  • treat every child, young person and adult with respect, dignity, patience and compassion;
  • listen actively to children and young people and value their views, opinions and concerns;
  • maintain appropriate and professional boundaries at all times, both in person and online;
  • work in open and visible environments and avoid situations in which they are alone and unobserved with a participant, unless this is agreed and risk-assessed (for example, a one-to-one therapy session in a room with a viewing panel or open door);
  • follow agreed procedures for intimate care, medication, first aid and behaviour support; and
  • report any concern, disclosure, allegation or breach of this Code without delay.

11.2 Personnel must not:

  • engage in any form of physical, emotional, sexual or verbal abuse, or behaviour which may reasonably be construed as such;
  • use physical punishment, or physical intervention, except where strictly necessary to prevent immediate harm and in accordance with agreed procedures;
  • make sexually suggestive comments, or engage in any sexual relationship with a participant;
  • contact participants through personal social media, private messaging or personal telephone numbers, or share personal contact details with participants;
  • take, store or share images of participants on personal devices, or other than in accordance with the Charity’s photography procedures;
  • give gifts, money or preferential treatment to individual participants, or transport participants alone in a private vehicle without prior authorisation;
  • consume alcohol, illegal substances or anything that impairs judgement while responsible for participants; or
  • discriminate against any person on the basis of a protected characteristic.

12. Responding to Concerns and Disclosures

12.1 Where a child, young person or adult discloses harm, or personnel otherwise become concerned about their welfare, personnel shall:

  1. Remain calm and reassure the individual that they were right to tell someone.
  2. Listen carefully and allow them to speak freely, at their own pace and using their preferred method of communication.
  3. Not ask leading questions, investigate, or seek to establish the facts beyond what is needed to understand the concern.
  4. Never promise confidentiality; explain, in terms appropriate to their understanding, that the information must be shared to keep them safe.
  5. Not confront the alleged perpetrator or discuss the matter with others who do not need to know.
  6. Record what was said and observed, as soon as possible and in any event on the same day, using the individual’s own words, and including the date, time, location and those present. Records must be factual and signed.
  7. Report the concern immediately to the DSO, or, in their absence, to the Deputy DSO. If a child or adult is in immediate danger or requires urgent medical attention, call 999 without delay and inform the DSO as soon as it is safe to do so.

13. Reporting and Referral Procedures

13.1 The DSO shall consider every concern without delay and determine the appropriate course of action. Where there is reasonable cause to suspect that a child is suffering, or is likely to suffer, significant harm, the DSO shall make a referral to the relevant local authority children’s social care department within 24 hours, and immediately where the risk is urgent.

13.2 For children resident in the London Borough of Newham, referrals shall be made to the Newham Multi-Agency Safeguarding Hub (MASH). For children resident elsewhere, referral shall be made to the local authority in which the child lives. Concerns relating to adults at risk shall be referred to the relevant local authority adult social care service.

13.3 Where the DSO is unavailable and the matter is urgent, any member of personnel may make a referral directly to children’s social care or the police. Any person may also contact the NSPCC Helpline for advice.

13.4 The DSO shall record the rationale for every decision, including any decision not to refer, and shall follow up referrals to confirm that they have been received and acted upon. Where the DSO disagrees with a decision of a statutory agency, the matter shall be escalated in accordance with local multi-agency escalation procedures.

14. Allegations Against Staff, Volunteers or Trustees

14.1 Any allegation that a member of personnel has behaved in a way that has harmed, or may have harmed, a child; has possibly committed a criminal offence against or related to a child; or has behaved in a way indicating that they may pose a risk of harm to children, shall be reported immediately to the DSO, or to the Chair of Trustees where the allegation concerns the DSO.

14.2 The DSO or Chair shall refer the matter to the Local Authority Designated Officer (LADO) within one working day and shall not undertake any investigation before obtaining the LADO’s advice. The individual concerned may be suspended or redeployed, as a neutral act, pending the outcome.

14.3 Where an individual is dismissed or removed from regulated activity, or would have been had they not left, because they have harmed or posed a risk of harm, the Charity shall make a referral to the Disclosure and Barring Service, as required by the Safeguarding Vulnerable Groups Act 2006.

14.4 Low-level concerns, being conduct that does not meet the harm threshold but is inconsistent with the Code of Conduct, shall also be reported to the DSO, recorded and reviewed to identify patterns of behaviour.

15. Record Keeping, Confidentiality and Information Sharing

15.1 Safeguarding records shall be accurate, factual, contemporaneous and stored securely, with access restricted to the DSO, Deputy DSO and those with a legitimate need to know. Records shall be retained in accordance with the Charity’s retention schedule and statutory guidance, which ordinarily requires child protection records to be retained until the individual’s 25th birthday, and records of allegations against personnel to be retained for at least ten years or until the person’s normal retirement age, whichever is longer.

15.2 The Charity recognises that the Data Protection Act 2018 and UK GDPR do not prevent the lawful sharing of information for the purpose of keeping children and adults at risk safe. Information shall be shared in a manner that is necessary, proportionate, relevant, accurate, timely and secure, in accordance with the Government’s guidance, Information sharing: advice for practitioners. Where possible, consent shall be sought, but information may be shared without consent where this is necessary to protect an individual from significant harm.

16. Operational Safeguarding Arrangements

16.1 Supervision and Risk Assessment

Every session, visit and event shall be subject to a documented risk assessment, approved by the Project Manager. Supervision ratios shall reflect the age, needs and number of participants, the nature of the activity and the venue, and shall never fall below the minimum identified in the risk assessment. A named safeguarding lead shall be identified for every activity.

16.2 Registration, Consent and Medical Information

Before participation, parents or carers shall complete a registration and consent form detailing emergency contacts, medical conditions, medication, allergies, dietary requirements, communication needs, behaviour support plans and photography consent. A register shall be taken at the start and end of every activity.

16.3 Intimate and Personal Care

Where a participant requires intimate or personal care, this shall be provided only in accordance with an agreed individual care plan, by appropriately trained and vetted personnel, with respect for the participant’s privacy and dignity. Parents and carers will normally be asked to remain responsible for intimate care unless otherwise agreed in writing.

16.4 Fun Days Out, Trips and Transport

All off-site activities require prior approval, a venue-specific risk assessment, confirmation of accessible facilities, a first aider in attendance, an emergency plan and a means of identifying personnel (such as high-visibility clothing). Transport shall be provided only by insured and appropriately licensed providers.

16.5 The Let’s Make Noise Cup and Public Events

For large public events, the Charity shall implement an event management and safeguarding plan, including a clearly identified safeguarding point, stewarding arrangements, a lost child procedure, accessible facilities and quiet spaces, and appropriate liaison with the venue’s own safety and security arrangements.

16.6 Missing Child Procedure

Should a participant go missing, personnel shall immediately alert the activity lead, conduct a structured search, notify the venue and inform the parent or carer. If the participant is not located within 15 minutes, or sooner where there is heightened risk, the police shall be contacted on 999.

16.7 Speech and Language Therapy Sessions

One-to-one therapy sessions shall take place in rooms with a viewing panel or open door, or with a parent or carer present or nearby, and shall be delivered only by appropriately qualified practitioners registered with the Health and Care Professions Council (HCPC).

16.8 Work Experience Placements

Before a young person commences a work experience placement, the Charity shall obtain confirmation of the employer’s health and safety arrangements and employer’s liability insurance, conduct a placement risk assessment, agree supervision arrangements and provide the employer with relevant safeguarding guidance.

17. Online Safety, Photography and Social Media

17.1 Personnel shall communicate with participants and families only through the Charity’s official accounts, devices and channels. Group communications shall be transparent and include a parent or carer where the participant is a child.

17.2 Photographs and video recordings of participants shall be taken only with prior written consent, on Charity-owned devices, and in accordance with the Charity’s Privacy Policy. Full names, school names or other identifying details shall not be published alongside images.

17.3 Online sessions shall be hosted on secure platforms, with waiting rooms enabled, recordings made only with consent, and at least two members of personnel present wherever practicable.

18. Whistleblowing

18.1 The Charity encourages personnel to raise concerns, in good faith, about poor or unsafe practice or potential failures in safeguarding. Concerns may be raised with the DSO, the Chair of Trustees or, where internal routes are not appropriate, with the NSPCC Whistleblowing Advice Line or the Charity Commission. Individuals who raise concerns in good faith will be protected from detriment in accordance with the Public Interest Disclosure Act 1998.

19. Serious Incident Reporting to the Charity Commission

19.1 The Board of Trustees shall report any serious incident to the Charity Commission promptly, in accordance with the Commission’s guidance. This includes incidents where a beneficiary has been, or is alleged to have been, abused or mistreated while in the Charity’s care, or where an allegation has been made against a trustee, employee or volunteer. Reports shall also be made to the police, local authority, insurers and funders as appropriate.

20. Monitoring, Review and Governance

20.1 The DSO shall provide a safeguarding report to the Board of Trustees at each meeting, summarising, in anonymised form, the number and nature of concerns, referrals, allegations, training completed and lessons learned.

20.2 This Policy shall be reviewed at least annually, and sooner following a serious incident, a change in legislation or statutory guidance, or a material change in the Charity’s activities. Any amendments shall be approved by the Board of Trustees and communicated promptly to all personnel.

21. Key Safeguarding Contacts

ContactDetails
Designated Safeguarding OfficerNawal Sulieman nawal@letsmakenoise.org safeguarding@letsmakenoise.org
Deputy Designated Safeguarding OfficerTo be appointed. In the absence of the DSO, contact the Safeguarding Trustee, Fahad Hassan.
Safeguarding TrusteeFahad Hassan info@letsmakenoise.org
Chair of TrusteesOsman Osman info@letsmakenoise.org
Charity officeOffice 705, Avicenna House, 258–262 Romford Road, London E7 9HZ 020 8058 9885
Newham MASH (children’s social care)020 3373 4600 mash@newham.gov.uk
Newham out-of-hours (via Contact Centre)020 8430 2000
Local Authority Designated Officer (LADO)Via Newham Safeguarding Children Partnership: www.newhamscp.org.uk/lado
NSPCC Helpline0808 800 5000 help@nspcc.org.uk
PoliceEmergency: 999 · Non-emergency: 101

Appendix A: Safeguarding Reporting Procedure

StepActionResponsibility and timescale
1Concern identified, disclosure received or allegation made.Any member of personnel.
2Is anyone in immediate danger? If yes, call 999.Immediately.
3Report the concern verbally to the DSO (or Deputy DSO).Immediately, and on the same day.
4Complete a written Record of Concern (Appendix B) and pass it securely to the DSO.Within 24 hours.
5DSO assesses the concern and decides on action: refer to MASH or the local authority, seek advice, or monitor.DSO, within 24 hours.
6If the allegation concerns personnel, refer to the LADO. If it concerns the DSO, report to the Chair of Trustees.Within one working day.
7Record decisions and rationale, follow up the referral, and report serious incidents to the Charity Commission.DSO and Board of Trustees.

Appendix B: Record of Concern Template

FieldDetails
Name of child or adult
Date of birth or age
Date, time and location of concern
Nature of concern (factual account, using the individual’s own words)
Observations (injuries, behaviour, demeanour)
Action taken
Persons informed
Name, role and signature of person reporting
Date and time recorded
DSO decision and rationale
DSO signature and date