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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Protecting Children and Young People from Bullying, Harassment, and Exploitation Policy

1. Purpose

The purpose of this policy is to ensure that all children and young people in the care of {{org_field_name}} are protected from bullying, harassment, and exploitation. {{org_field_name}} is committed to fostering an environment where children feel safe, valued, and respected, free from any form of abuse or mistreatment. This policy establishes clear procedures for prevention, intervention, and reporting, ensuring that staff take a proactive role in safeguarding children and young people.

2. Scope

This policy applies to:

• All children and young people residing at or receiving support from {{org_field_name}}.
• All staff members, volunteers, and visitors interacting with children in our care.
• External agencies and professionals who work in collaboration with our care home.

It addresses:

• Bullying (physical, verbal, and cyberbullying).
• Harassment (including discriminatory and sexual harassment).
• Exploitation (including grooming, online abuse, and financial abuse).

3. Legal and Regulatory Compliance

This policy must be implemented in accordance with the legislation, regulations and statutory safeguarding requirements applicable to care home services for children in Wales, including:

• The Social Services and Well-being (Wales) Act 2014, particularly Part 7 and the statutory duty to report a child who is experiencing, or is at risk of, abuse, neglect or other kinds of harm and who has needs for care and support.
• The Regulation and Inspection of Social Care (Wales) Act 2016, as amended.
• The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, including:
  • Regulation 12 – requirements for policies and procedures, including a policy on the prevention of bullying and procedures for dealing with allegations of bullying where accommodation is provided to children;
  • Regulation 26 – the overarching requirement to ensure that individuals are safe and protected from abuse, neglect and improper treatment;
  • Regulation 27 – safeguarding policies and procedures and the action required where abuse, neglect or improper treatment is alleged or identified;
  • Regulation 39 – requirements relating to staff disciplinary procedures where abuse or suspected abuse has not been reported;
  • Regulation 59 – requirements relating to records; and
  • Regulation 60 and Schedule 3 – statutory notifications, including notifications concerning abuse, child protection enquiries, child sexual exploitation and child criminal exploitation.
• The Children Act 1989, including the statutory child protection functions of local authorities.
• The Children Act 2004, including duties relating to safeguarding and promoting the welfare of children.
• The Equality Act 2010, including protection from unlawful discrimination, harassment and victimisation relating to protected characteristics.
• The Wales Safeguarding Procedures, including the procedures for children at risk and the procedures concerning allegations or concerns about practitioners and persons in positions of trust.
• Welsh Government statutory guidance issued under the Social Services and Well-being (Wales) Act 2014, including Working Together to Safeguard People: Volume 5 – Handling Individual Cases to Protect Children at Risk.
• Welsh Government statutory guidance issued under section 29 of the Regulation and Inspection of Social Care (Wales) Act 2016 for service providers and responsible individuals on meeting the service standard regulations for care home services.

Where this policy conflicts with legislation, statutory guidance or the Wales Safeguarding Procedures, the applicable statutory requirement or safeguarding procedure will take precedence and this policy will be reviewed without delay.

4. Definitions

4.1 Bullying

Bullying is repeated behaviour that intentionally hurts, intimidates, or undermines another person. This includes:

• Physical bullying – hitting, pushing, damaging belongings.
• Verbal bullying – insults, name-calling, threats.
• Social bullying – excluding someone, spreading rumours.
• Cyberbullying – online harassment via social media, messaging apps, or gaming platforms.

4.2 Harassment

Harassment is unwanted conduct that violates a person’s dignity or creates an intimidating, hostile, degrading, or offensive environment. This includes:

• Discriminatory harassment – based on race, gender, disability, sexuality, or other protected characteristics.
• Sexual harassment – inappropriate touching, comments, or coercion.
• Psychological harassment – gaslighting, manipulation, or threats.

4.3 Exploitation

Exploitation occurs when a person is taken advantage of for someone else’s benefit. This includes:

• Child Sexual Exploitation (CSE) – grooming, coercion, or abuse.
• Criminal Exploitation – forced involvement in illegal activities (e.g., gang-related crime).
• Financial Exploitation – taking control of a child’s money or belongings.
• Online Exploitation – grooming through social media, gaming, or forums.

5. Prevention Strategies

5.1 Creating a Safe and Inclusive Culture

• Staff are trained to promote positive behaviour and conflict resolution.
• Children are encouraged to speak up and report any concerns.
• Clear behaviour expectations are set and regularly reinforced.

5.2 Staff Training and Awareness

All staff and volunteers must receive safeguarding information and training appropriate to their role as part of their induction and must understand their individual responsibility to safeguard children and young people.

Safeguarding training must include, as relevant to the person’s role:

• recognition of abuse, neglect, improper treatment, bullying, harassment, grooming and exploitation;
• child sexual exploitation and child criminal exploitation;
• online abuse and exploitation;
• the duty to report safeguarding concerns;
• how to respond when a child makes a disclosure;
• the requirement to record concerns factually and accurately;
• how and when concerns must be reported to local authority social services or the police;
• procedures for allegations or concerns involving staff, volunteers or other persons in positions of trust;
• the service’s whistleblowing arrangements; and
• the relevant Wales Safeguarding Procedures.

Safeguarding training must be refreshed at appropriate regular intervals in accordance with local safeguarding arrangements and the safeguarding training, learning and development standards applicable to the social care workforce in Wales.

Staff supervision must regularly revisit safeguarding responsibilities and identify and address any gaps in an individual staff member’s safeguarding knowledge, understanding or practice.

Staff must understand that reporting a safeguarding concern is an individual professional responsibility and that concerns must not be ignored, delayed or withheld on the assumption that another person will make the report.

5.3 Supervision and Monitoring

• Staff must actively supervise children in all communal areas.
• Regular checks are conducted in online activities to prevent cyberbullying and online grooming.
• CCTV and incident logs are reviewed to identify patterns of behaviour.

6. Responding to Bullying, Harassment and Exploitation

All concerns, disclosures, allegations or evidence relating to bullying, harassment or exploitation must be taken seriously and responded to promptly. The immediate safety and well-being of the child or young person must be the first consideration.

Where information indicates that a child may be experiencing, or may be at risk of, abuse, neglect or other harm, the matter must be treated as a safeguarding concern and dealt with in accordance with the organisation’s Safeguarding Policy, the Wales Safeguarding Procedures and applicable statutory reporting and notification requirements.

6.1 Immediate Response to a Concern or Disclosure

When a child or young person reports, discloses or indicates that they may have experienced bullying, harassment, exploitation, abuse or other harm, the member of staff must:

• listen carefully and take the child seriously;
• remain calm and respond in a supportive and non-judgemental manner;
• not promise confidentiality or secrecy;
• explain, in a manner appropriate to the child’s age and understanding, that information may need to be shared with people who can help keep them or others safe;
• not investigate the allegation, ask leading questions or repeatedly question the child;
• obtain only the information necessary to establish the immediate circumstances and whether urgent protective action is required;
• take immediate action to protect the child and any other child who may be at risk;
• contact the police on 999 where a child is in immediate danger or immediate police assistance is required;
• make an accurate, factual and contemporaneous written record of what was seen, heard, disclosed or reported, using the child’s own words wherever practicable;
• report the concern immediately to the manager or person with designated responsibility for safeguarding; and
• ensure that the matter is referred to local authority social services where there is knowledge, concern or suspicion that the child is experiencing, has experienced or is at risk of abuse, neglect or other harm and meets the statutory child-at-risk criteria.

A member of staff must not delay necessary safeguarding action because the manager or designated safeguarding person is unavailable. Where necessary, the member of staff must contact local authority social services or the police directly.

6.2 Safeguarding Referral and Decision-Making

Where there is an allegation or evidence of abuse, neglect, improper treatment or other safeguarding harm, the service provider must:

• act in accordance with its safeguarding policies and procedures;
• take immediate action to secure the safety of the child concerned and any other children who may be at risk;
• make the appropriate referral to local authority social services and, where necessary, the police or another relevant statutory agency;
• cooperate with safeguarding enquiries and multi-agency decision-making;
• preserve relevant evidence and records;
• record the substance of the allegation or concern, the evidence available, actions taken, decisions made, referrals made and outcomes received; and
• complete all statutory notifications required by Care Inspectorate Wales and other relevant authorities.

The service must not undertake an internal investigation into a suspected safeguarding or criminal matter where doing so could interfere with, prejudice or duplicate enquiries being undertaken by social services or the police.

Any internal fact-finding, disciplinary process or management investigation must be coordinated with the relevant safeguarding or investigating authority where necessary.

6.3 Allegations or Concerns About Staff, Volunteers or Other Persons in Positions of Trust

Any allegation or concern that a member of staff, volunteer or other person working with children has harmed a child, may have harmed a child, may have 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 must be reported immediately to the manager or designated safeguarding person.

The service provider must:

• take immediate action to ensure the safety of children;
• undertake an immediate organisational risk assessment;
• follow the Wales Safeguarding Procedures relating to allegations or concerns about practitioners and persons in positions of trust;
• notify the relevant Local Authority Designated Officer/Designated Officer for Safeguarding in accordance with the Wales Safeguarding Procedures;
• make any required referral to local authority social services or the police;
• make the required notification to Care Inspectorate Wales;
• consider, in accordance with the service’s disciplinary procedures and the safeguarding process, whether suspension, redeployment or other precautionary action is necessary and proportionate;
• ensure that any precautionary action does not prejudice a police, safeguarding or regulatory investigation; and
• consider whether referral to the Disclosure and Barring Service, Social Care Wales or another professional regulator is required.

A member of staff’s failure to report an incident of abuse or suspected abuse may result in disciplinary proceedings in accordance with the service’s disciplinary procedure and applicable regulatory requirements.

6.4 Support and Protection for the Child

Following an allegation or incident, the child or young person must receive appropriate support and protection based on their individual circumstances, wishes, feelings and assessed needs.

This may include:

• an immediate individual risk assessment and safety plan;
• increased staff support or supervision;
• access to the child’s key worker;
• emotional, therapeutic or specialist support where required;
• support to access independent professional advocacy;
• appropriate changes to routines, activities or accommodation where necessary for safety;
• support in maintaining appropriate education, family and significant relationships;
• information about what action is being taken, provided in a way appropriate to the child’s age, understanding and communication needs; and
• involvement of parents, persons with parental responsibility, representatives and the placing authority where appropriate and consistent with safeguarding requirements and the child’s well-being.

The service provider must ensure that the outcome of a safeguarding referral is communicated to the child in a manner appropriate to their age and level of understanding and, where appropriate, to their representative.

6.5 Where Another Child is Responsible for the Behaviour

Where bullying, harassment, harmful sexual behaviour, exploitation or other harmful behaviour is alleged to have been carried out by another child, the service must safeguard all children involved.

The child alleged to have caused the harm must not automatically be treated solely as a perpetrator. Their own safeguarding, care and support needs must also be considered.

The service must:

• undertake or review individual risk assessments;
• take proportionate action to prevent further harm;
• make safeguarding referrals where the statutory threshold is met;
• involve the placing authority and other relevant professionals as required;
• review the personal plans of affected children where necessary; and
• ensure that any behaviour-management response is lawful, proportionate and consistent with the child’s individual needs and personal plan.

Restorative approaches must only be considered where this is safe, appropriate, voluntary and consistent with safeguarding plans. They must not replace a safeguarding referral, statutory investigation or other protective action where these are required.

6.6 Statutory Notifications

The service provider must ensure that all notifications required under Regulation 60 and Schedule 3 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, are made without delay and in the required form.

Care Inspectorate Wales must be notified where required, including in relation to:

• abuse or an allegation of abuse involving the service provider, a member of staff or a volunteer;
• an allegation of misconduct by a member of staff;
• the instigation and subsequent outcome of a child protection enquiry involving a child accommodated by the service;
• an allegation that an accommodated child has committed a serious offence;
• any incident of child sexual exploitation or child criminal exploitation, or suspected child sexual exploitation or child criminal exploitation;
• any incident involving an accommodated child going missing or having an unexplained absence; and
• any incident reported to the police where notification is required by Schedule 3.

Where a care home service is provided to children, the service provider must also make the additional notifications required by Schedule 3 to the placing authority, the local authority in whose area the home is situated and the appropriate police officer.

In particular, any incident of child sexual exploitation or child criminal exploitation, or suspected child sexual exploitation or child criminal exploitation, must be notified without delay to:

• Care Inspectorate Wales;
• the child’s placing authority;
• the local authority in whose area the care home is situated; and
• the appropriate police officer.

All statutory notifications must include details of the relevant event and must be recorded within the service’s records.

Notifications to Care Inspectorate Wales must be submitted using the notification method and format required by CIW.

7. Multi-Agency Safeguarding

{{org_field_name}} will work cooperatively with local authority social services, the child’s placing authority, the police, health services, education providers, Care Inspectorate Wales and other relevant professionals and agencies in order to safeguard children and young people.

Where a safeguarding concern arises, the service will:

• make appropriate safeguarding referrals without delay;
• provide relevant information lawfully to the agencies responsible for safeguarding the child;
• participate in safeguarding enquiries, strategy discussions, meetings, assessments and plans as required;
• implement agreed protective actions;
• keep the placing authority informed where required;
• cooperate with police investigations and local authority child protection enquiries;
• cooperate with Care Inspectorate Wales in relation to regulatory matters and notifications; and
• record referrals, decisions, agreed actions and outcomes.

Information must be shared where necessary and proportionate for safeguarding purposes in accordance with applicable legislation and safeguarding procedures. A concern must not be withheld solely because consent to share information has not been obtained where sharing is necessary to protect a child or another person from harm.

8. Online Safety Measures

• Internet filtering software is used to prevent access to harmful content.
• Staff conduct regular checks on digital devices used by children.
• Education on online safety is provided to all children and young people.

9. Record Keeping and Documentation

Accurate, complete and up-to-date records must be maintained in relation to bullying, harassment, exploitation and associated safeguarding concerns.

Records must include, where applicable:

• the original concern, disclosure, allegation or incident;
• the date, time and circumstances in which the concern arose;
• the child’s account, recorded factually and using their own words wherever practicable;
• observations or other relevant evidence;
• immediate protective action taken;
• risk assessments and safety measures;
• safeguarding referrals made;
• referrals to, or communications with, local authority social services, the police, placing authority or other relevant agencies;
• notifications made to Care Inspectorate Wales and other statutory bodies;
• decisions made and the reasons for those decisions;
• advice or instructions received from safeguarding agencies;
• actions agreed at safeguarding meetings or discussions;
• support provided to the child or young person;
• outcomes of referrals, enquiries or investigations insofar as these are provided to the service; and
• subsequent reviews and actions taken to reduce the risk of recurrence.

Records must distinguish clearly between fact, direct observation, information reported by another person and professional opinion.

Records relating to individuals must be accurate, kept up to date, stored securely and made available to Care Inspectorate Wales on request in accordance with the applicable Regulations.

Records relating to children must be retained for 15 years from the date of the last entry, unless they are delivered to the placing authority in accordance with Regulation 59 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended.

Where the service is a care home provided wholly or mainly for children, records relating to an accommodated child must be delivered to the placing authority when the service ceases to be provided to that child, in accordance with the applicable regulatory requirements.

Access to records and the sharing of information must comply with applicable data protection legislation, safeguarding requirements and the organisation’s confidentiality and records-management procedures.

10. Policy Compliance and Monitoring

The manager and Responsible Individual must ensure that this policy is implemented effectively and that safeguarding arrangements are subject to appropriate oversight.

Monitoring arrangements must include:

• review of bullying, harassment, exploitation and safeguarding incidents;
• review of safeguarding referrals and their outcomes;
• confirmation that required referrals and statutory notifications have been made;
• monitoring of patterns, themes, repeated incidents or emerging safeguarding risks;
• review of the effectiveness of risk assessments and protective measures;
• monitoring of staff understanding and compliance with safeguarding procedures;
• identification and correction of any gaps in safeguarding knowledge or practice through supervision, training or management action; and
• evidence that learning from safeguarding incidents is used to improve the quality and safety of the service.

Safeguarding information must be included within the service’s governance and quality-monitoring arrangements so that the manager, Responsible Individual and service provider can maintain effective oversight of the safety and well-being of children accommodated by the service.

Where monitoring identifies an immediate or significant risk to a child, corrective action must be taken without delay.

11. Related Policies and Procedures

This policy must be read and implemented alongside the organisation’s relevant policies and procedures, including:

• Safeguarding Policy (CHW13);
• Whistleblowing Policy (CHW29);
• Staff Conduct and Ethics Policy (CHW28);
• Staff Disciplinary Policy and Procedure;
• Confidentiality and Data Protection Policy (CHW34);
• Online Safety and Social Media Policy;
• Missing or Unauthorised Absence Policy and Procedure;
• Positive Behaviour Support and Use of Control or Restraint Policy, where applicable; and
• Complaints Policy and Procedure.

Where an incident of bullying, harassment or exploitation also constitutes, or may constitute, abuse, neglect, improper treatment or another safeguarding concern, the organisation’s Safeguarding Policy and the Wales Safeguarding Procedures must be followed.

Where the concern involves the conduct of a member of staff or volunteer, the safeguarding process must take precedence over, and where necessary be coordinated with, internal disciplinary procedures so that internal action does not prejudice a safeguarding or police investigation.

12. Policy Review

This policy will be reviewed annually or sooner if legislative changes or operational needs require amendments.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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