Safeguarding and
Data Protection Policy

1. Purpose and Scope

This policy outlines how ANCHOR Inclusion fulfils its safeguarding responsibilities and handles personal data in the course of its work. It is an internal working document intended to guide the practice of all staff, associates, and contractors working with or on behalf of Anchor Inclusion.

It applies to all services delivered by ANCHOR Inclusion, including work with schools, families, and professionals, whether delivered in person or online.

This policy should be read alongside:

ANCHOR Inclusion Privacy Policy
ANCHOR Inclusion Terms & Conditions
Any service-specific agreements or protocols

2. Safeguarding Commitment

ANCHOR Inclusion is committed to promoting the safety, welfare, and best interests of all children, young people, and vulnerable individuals we work with or come into contact with.

We operate in line with UK safeguarding legislation and statutory guidance, including:

Working Together to Safeguard Children (2023)
The Children Act 1989 and 2004
Keeping Children Safe in Education (where applicable to school-based work)
The Care Act 2014 (in relation to adults at risk)
The Equality Act 2010

Safeguarding is not an add-on to our work : it is embedded in everything we do. All individuals working with or on behalf of ANCHOR Inclusion share this responsibility.

The welfare of the child or vulnerable individual is always the primary consideration.

3. Designated Safeguarding Lead

The Designated Safeguarding Lead (DSL) for ANCHOR Inclusion is:

Name: S Asha

Role: Early Help Practitioner

Contact: info@anchorinclusion.co.uk

The DSL is responsible for:

Receiving and responding to safeguarding concerns raised by staff, associates, or clients
Making referrals to children's services, the LADO, or other relevant agencies where required
Maintaining accurate and confidential safeguarding records
Ensuring safeguarding practice is consistent and up to date
Liaising with schools' own DSLs where services are school-based
Ensuring all staff and associates receive appropriate safeguarding training

4. Safer Recruitment

ANCHOR Inclusion is committed to safer recruitment practices. All individuals engaged to work directly with children or vulnerable individuals on behalf of ANCHOR Inclusion must:

Hold a current Enhanced DBS (Disclosure and Barring Service) check, including a children's barred list check where applicable
Provide at least two references prior to engagement
Confirm they are not subject to any sanctions, restrictions, or ongoing investigations that would affect their suitability to work with children
Complete safeguarding induction before beginning direct work

DBS certificates must be renewed in line with the Update Service or at intervals no greater than three years.

No individual will begin direct work with children or vulnerable individuals until appropriate DBS clearance has been received and references have been verified.

5. Safeguarding Training

All staff and associates working with or on behalf of ANCHOR Inclusion are expected to:

Complete recognised safeguarding training appropriate to their role and level of contact
Refresh safeguarding training at least every two years, or sooner if statutory guidance changes significantly
Be familiar with this policy and able to follow the procedures it sets out

The DSL will maintain a record of training completed by all staff and associates. Training completion will be reviewed at least annually.

Where ANCHOR Inclusion delivers training to schools or other organisations, the content will be reviewed regularly to ensure it reflects current legislation and best practice.

6. Recognising Safeguarding Concerns

Safeguarding concerns may arise in many forms. They include but are not limited to:

Disclosure of abuse or neglect by a child, young person, or adult
Physical signs of harm, injury, or neglect
Significant changes in behaviour, mood, or presentation
Concerns raised by a parent, carer, school, or professional
Information shared indirectly during a session, training, or consultation
Online safety concerns arising from remote or digital work

Concerns may arise directly or indirectly and may relate to current or historic harm. All concerns, however small they may seem, should be taken seriously and recorded.

It is not the role of ANCHOR Inclusion staff or associates to decide whether abuse has taken place. Our role is to recognise, record, and refer.

Staff and associates are expected to maintain professional curiosity : recognising when something does not feel right, noticing patterns or changes over time, and exploring concerns appropriately rather than dismissing them. A concern that cannot be easily explained should always be taken seriously.

7. Responding to Safeguarding Concerns

If a child or adult makes a disclosure

If someone discloses abuse or a safeguarding concern to you:

Listen carefully and remain calm. Do not show shock or disbelief.
Reassure them that they have done the right thing by sharing.
Do not promise confidentiality : explain that you may need to share what they have told you to keep them safe.
Do not ask leading questions or conduct your own investigation. Ask only open, clarifying questions if necessary (e.g. 'Can you tell me more about what happened?').
As soon as possible after the disclosure, record what was said using the child or adult's own words, noting the date, time, and any other relevant context.
Report to the DSL without delay.

Do not investigate, do not delay, and do not keep concerns to yourself. If in doubt, report.

DSL response

On receiving a concern, the DSL will:

Review the concern and assess the level of risk
Determine whether a referral to children's services, the LADO, or other agencies is required
Make any referral without delay where there is risk of harm
Record all decisions and actions taken
Inform relevant parties as appropriate, in line with confidentiality principles

Where there is immediate risk of harm to a child or individual, emergency services (999) will be contacted without waiting for the DSL.

Recording standards

All safeguarding records must be:

Written as soon as possible after the event, using factual and objective language
Based on direct observation or disclosure : clearly distinguishing fact from opinion
Dated, attributed (signed or named), and stored securely with restricted access
Retained in line with the data retention periods in Section 17

Use the child or adult's own words where possible. Record what was said and done, not what you think it means.

Referral

Referrals may be made to:

The school's Designated Safeguarding Lead (where services are school-based)
Local Authority Children's Services (MASH or equivalent)
The Local Authority Designated Officer (LADO) : where the concern involves a person in a position of trust
Police or emergency services : where there is immediate risk
Adult safeguarding teams : where the concern relates to an adult at risk

8. Allegations Against Staff or Associates

If a concern or allegation is raised about the conduct of any member of staff, associate, or contractor working with or on behalf of ANCHOR Inclusion: including behaviour that may have harmed a child or put a child at risk, the following procedure applies.

The concern must be reported to the DSL immediately.
If the concern involves the DSL, it must be reported directly to S Asha or, where necessary, to the LADO.
The DSL will assess whether the concern meets the threshold for LADO referral. Any allegation involving a person in a position of trust working with children must be referred to the LADO.
The individual subject to the allegation must not be informed before advice has been sought from the LADO or children's services, as this may compromise the process.
The individual may be suspended from duties during the investigation, at the discretion of the DSL, without prejudice.
All actions and decisions will be recorded confidentially.

Please find LADO contact details, publicly available from your local authority. All allegations involving staff or associates working with children must be referred to the LADO, even where the allegation appears minor.

Low-level concerns

Not all concerns about staff conduct will meet the threshold for a formal allegation or LADO referral. Low-level concerns : such as behaviour that seems inappropriate but does not suggest immediate risk : should still be:

Recorded in writing with the date, a factual description, and the name of the person recording it
Reported to the DSL for review
Retained securely and reviewed over time to identify any emerging patterns

Early recording of low-level concerns is essential. Patterns of minor concerns can indicate more serious underlying issues. This approach is in line with Keeping Children Safe in Education expectations.

9. Confidentiality and Information Sharing

All information shared in the course of ANCHOR Inclusion's work is treated with care and respect. Staff and associates must not share personal or sensitive information outside of its intended purpose.

Confidentiality is not absolute. Information will be shared without consent where:

There is a risk to the safety or wellbeing of a child or vulnerable individual
Disclosure is required by law or a court order
Sharing is necessary to prevent serious harm to the individual or others

Where information needs to be shared, individuals will be informed wherever possible and appropriate, unless doing so would increase risk or compromise a safeguarding process.

Information sharing decisions will be made on a need-to-know basis, involving only those who require it to fulfil their role. The reason for sharing will always be recorded clearly.

When in doubt about whether to share information, seek advice from the DSL. The key question is: will sharing this information help keep someone safe?

10. Working with Schools and Other Organisations

Where services are commissioned by or delivered within a school or organisation:

The school retains overall safeguarding responsibility for its pupils
ANCHOR Inclusion operates within the school's safeguarding framework while maintaining its own professional responsibilities
Any safeguarding concerns arising during school-based work will be reported to the school's DSL, unless an immediate external referral is required
Roles and responsibilities will be clarified at the start of engagement and documented where appropriate

ANCHOR Inclusion will not begin school-based work without sight of the school's safeguarding policy, or at minimum confirmation that one is in place and the DSL is identifiable.

11. Online Safety

Where services are delivered online, all staff and associates must be aware of online safeguarding risks, including:

Inappropriate content or contact occurring during or around online sessions
Children or young people being in unsupervised or unsafe environments during sessions
Privacy risks associated with video platforms and shared documents
Risks relating to recording, screenshots, or sharing of session content

Online sessions must not be recorded without the explicit prior consent of all participants. Where a child is involved, parental or carer consent is also required.

Any online safeguarding concern, including anything seen or heard during a remote session, should be reported to the DSL using the same procedures as for in-person concerns.

12. Photography and Images

No photographs, images, or video recordings of children or young people will be taken during ANCHOR Inclusion's work without:

Prior written consent from a parent or person with parental responsibility
A clear explanation of how the image will be used and stored
The child's own agreement, where age and capacity allow

Images of children will not be stored on personal devices. Where images are taken for legitimate purposes (e.g. training documentation), they will be stored securely and deleted when no longer needed.

This also applies to group settings such as training events where children may be present.

13. Whistleblowing : Raising Concerns Internally

All staff and associates of ANCHOR Inclusion have a responsibility to raise concerns about practice, conduct, or safeguarding : including concerns about the behaviour of colleagues or the DSL.

Concerns should be raised with the DSL in the first instance. Where the concern involves the DSL, it should be raised with S Asha directly.

Where internal channels are not appropriate or have not resolved the concern, individuals may contact.

The LADO: where the concern involves a person working with children
The NSPCC whistleblowing helpline: 0800 028 0285
The Information Commissioner's Office (ICO) : for data protection concerns

No individual will be penalised for raising a safeguarding concern in good faith. ANCHOR Inclusion is committed to a culture where concerns are welcomed, taken seriously, and acted upon.

Raising a concern in good faith is always the right thing to do, even if the concern turns out to be unfounded.

14. Equality, Inclusion, and Safeguarding

ANCHOR Inclusion recognises that some children and individuals may face additional safeguarding risks due to factors including, but not limited to:

Disability or additional needs
Race, ethnicity, or cultural background
Gender or sexual identity
Mental health or emotional wellbeing
Family circumstances or poverty

We are committed to ensuring that our safeguarding practice is inclusive, culturally sensitive, and free from assumptions or bias. Every child and individual deserves the same quality of care and the same rigour in safeguarding response, regardless of background or identity.

This commitment is grounded in the Equality Act 2010 and in ANCHOR Inclusion's broader values of inclusion and trauma-informed practice.

15. Data Protection in Practice

Principles

ANCHOR Inclusion processes personal data in line with UK GDPR. In practice, this means:

Data is collected only where there is a clear and lawful reason to do so
Only the minimum necessary data is collected for each purpose
Data is used only for the purpose for which it was collected
Data is kept accurate and up to date
Data is not retained longer than necessary
Data is kept secure and accessed only by those who need it

Systems and storage

Personal and sensitive data held by ANCHOR Inclusion is stored in the following systems:

Google Workspace (Gmail and Drive): email communications and working documents
Wix: booking information and website enquiry forms
Eventbrite: event registration data
Physical records: where held, stored in a locked cabinet and accessible only to the DSL and authorised individuals

All digital systems are password-protected. Shared passwords are not used. Two-factor authentication is enabled where available.

Access controls

Access to personal data is limited to those who require it to carry out their role. Associates and contractors will only be given access to the minimum data necessary for their specific engagement. Access is reviewed when a working relationship ends.

Data subject rights

Individuals have rights under UK GDPR, including the right to access their personal data, request corrections, and in some circumstances request deletion. Any such requests received by staff or associates must be:

Acknowledged promptly and referred to the DSL without delay
Handled in line with the ANCHOR Inclusion Privacy Policy
Responded to within one calendar month of receipt

Staff and associates should not attempt to respond to data subject requests independently. All requests must be routed through the DSL.

16. Data Breach Response

A data breach is any incident that leads to the accidental or unlawful destruction, loss, alteration, or unauthorised disclosure of or access to personal data.

If a data breach is identified or suspected, the following steps must be taken:

Identify and contain the breach as quickly as possible : for example, by changing passwords, removing access, or recovering a lost device.
Report the breach to the DSL immediately. Do not attempt to resolve it independently.
The DSL will assess the severity of the breach and whether it is likely to result in a risk to the rights and freedoms of individuals.
If the breach is notifiable, it must be reported to the Information Commissioner's Office (ICO) within 72 hours of becoming aware of it.
Where individuals are at high risk as a result of the breach, they must be informed directly without undue delay.
A full record of the breach, the assessment, and any action taken must be maintained regardless of whether it is reported to the ICO.

The 72-hour reporting window to the ICO is strict. If in doubt about whether a breach is notifiable, seek advice promptly: do not wait.

ICO breach reporting: https://ico.org.uk/report-a-breach

17. Data Retention

Personal data is retained only for as long as necessary. ANCHOR Inclusion's retention periods are:

Safeguarding and service records: up to 6 years from the end of engagement
Enquiry and contact data: up to 12 months from last contact
Financial and funding records: up to 6 years
Training records: up to 6 years
Recruitment records (unsuccessful applicants): up to 6 months

Records are securely deleted when no longer required. Digital files are permanently deleted (not just moved to trash). Physical records are shredded.

Retention periods may be extended where there is an ongoing legal matter, safeguarding investigation, or regulatory requirement.

18. Children's Data

Where ANCHOR Inclusion processes data relating to children:

The best interests of the child are the primary consideration
Age and capacity are taken into account in decisions about consent and involvement
Data is handled in line with the ICO's Children's Code (Age Appropriate Design Code)
Parental or carer consent is obtained where required
Children's data is not shared beyond those directly involved in their support without appropriate authority

Where a child is old enough to understand, they are involved appropriately in decisions about their own information, in line with Gillick competence principles.

19. Review and Accountability

This policy is reviewed at least annually, or sooner where:

Legislation or statutory guidance changes
A safeguarding incident or near-miss occurs
Significant changes to ANCHOR Inclusion's services or structure take place

Responsibility for implementation and review sits with the Designated Safeguarding Lead. All staff and associates are responsible for following this policy in their day-to-day practice.

A record of policy reviews, training completion, and any safeguarding incidents or referrals will be maintained by the DSL and held securely.

This policy does not replace statutory guidance. Where statutory guidance and this policy conflict, statutory guidance takes precedence.

20. Key Contacts and Resources

Internal

Designated Safeguarding Lead:

S Asha, info@anchorinclusion.co.uk

External: Safeguarding

Local Authority Children's Services (MASH): Contact and LADO details publicly available on your local authority’s website.

Police (non-emergency): 101

Emergency services: 999

NSPCC Helpline: 0808 800 5000

NSPCC Whistleblowing Helpline: 0800 028 0285

External: Data Protection

Information Commissioner's Office (ICO): https://ico.org.uk

ICO helpline: 0303 123 1113

ICO breach reporting: https://ico.org.uk/report-a-breach

Safeguarding and Data Protection Policy

ANCHOR Inclusion, Early Help Support

Last updated 11th May 2026, Version 1.0