- Safeguarding Policy
- Governance Policy - Practitioner qualifications & supervision
- Photography and Filming Policy
- Mental Health Training Cancellation Policy
Isle Listen is committed to promoting the safeguarding of children and adults at risk; protecting them from risks of harm, as required by the Isle of Man Children and Young Persons Act 2001, section 17 of the Safeguarding Act 2018 and the Inter Agency Safeguarding Adults Policy and Procedures 2018-2020. Our approach to safeguarding and child protection has been developed in line with NICE guidance NG76 2017 and the Isle of Man Safeguarding Board Multi-Agency Safeguarding procedures.
Other relevant legislation and guidance:
- Children Act 1989
- Children Act 2004
- Children and Families Act 2014
- Care Act 2014
- Working together to safeguarding children 2018: a guide to inter-agency working to safeguard and promote the welfare of children
- Keeping children safe in education 2022
- Isle of Man Safeguarding Together 2019: Guidance for collective working to safeguard children and vulnerable adults in the Isle of Man
- Information sharing guidance for professionals working with children and adults at risk of abuse or neglect.
This Policy is intended to be used by all staff within Minds Matter and Isle Listen. It is complementary to the local Isle of Man policies and procedures.
This policy applies to all Children and Adults at risk.
A “child” is defined as anyone who has not yet reached their 18th birthday.
An “adult at risk” is any person aged 18 or over who is, or may be, eligible for social care services by reason of mental or other disability, age or illness, or who is unable to take care of themselves or
protect themselves against harm.
The purpose of this policy is to provide staff and volunteers, as well as children and young people and their families, with the overarching principles that guide our approach to child and adult protection.
We recognise that:
- the welfare of children and adults at risk is paramount in all the work we do and in all the decisions we take;
- working in partnership with children, adults, parents, carers and other agencies is essential in promoting the welfare of children and adults at risk;
- all children and adults at risk, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have an equal right to protection from all types of harm or abuse;
- extra safeguards may be needed to keep children and adults who are additionally vulnerable safe from abuse.
We will seek to keep children and adults safe by:
- valuing, listening to, and respecting them;
- appointing a Designated Safeguarding Lead, a deputy, and a lead trustee/board member for safeguarding;
- adopting safeguarding best practice through our policies and procedures for staff and volunteers;
- providing effective management for staff and volunteers through supervision, support, training, and quality assurance measures;
- recruiting and selecting staff and volunteers safely, ensuring all necessary checks are made;
- recording and storing and using information professionally and securely, in line with data protection legislation and guidance;
- making sure that children, adults, and their families know where to go for help if they have a concern;
- using our safeguarding procedures to share concerns and relevant information with agencies who need to know, and involving children, adults, parents, families, and carers appropriately;
- using our procedures to manage any allegations against staff and volunteers appropriately;
- ensuring that we have effective complaints and whistleblowing measures in place;
- ensuring that we provide a safe physical environment for our children, adults, staff, and volunteers, by applying health and safety measures in accordance with the law and regulatory guidance.
Related Minds Matter/Isle Listen policies, procedures, and documents:
- Clinical risk policy
- Procedure for responding to concerns about the welfare of children/adults at risk (including allegations made against staff)
- Clinical record keeping
- Complaints policy
- Remote therapy policy and practice
- Data Protection: The Retention and Destruction Policy, Storage, Retention and Records
- Management Policy
- General confidentiality policy
- Whistleblowing policy
- Social media policy
- Health and safety policy
- Lone working policy.
Roles and Responsibilities
Chief Executive Officer
The Chief Executive Officer (CEO) is the Accountable Officer who has direct responsibility for ensuring that this policy and related procedures are adhered to across specific departments and fulfil the overall responsibility for ensuring this policy is implemented, monitored and on a minimum annual basis reviewed through the Clinical Lead and Designated Safeguarding Lead and Officer.
Training requirements should be guided by the Isle of Man Safeguarding Board. The Isle of Man Safeguarding Board may be contacted via:
Telephone: (01624) 687365
The Clinical Lead has overall responsibility for safeguarding procedures within Isle Listen and will:
- Provide advice and expertise to fellow professionals, support the interface with other agencies and promote good professional practice in safeguarding children and adults at risk.
- Review and update the safeguarding policy, procedures and practices alongside the Designated Safeguarding Officers, to ensure that standards reflect current Isle of Man legislation and guidance.
- Ensure investigation and response to child and adult protection concerns on behalf of Isle Listen.
The Clinical Supervisors have responsibility for individual cases and must ensure that this policy informs not only their own practice, but also the supervision of all therapists, trainees, wellbeing practitioners and all employees and other persons providing services on behalf of Isle Listen. The Clinical Supervisors will provide additional support and knowledge regarding safeguarding to support the role of the Clinical Lead and the Designated Safeguarding Lead and Officer.
Designated Safeguarding Officer Lead and Officer for Isle Listen
The Designated Safeguarding Lead and Officer will act as the professional leads within Isle Listen for safeguarding and child and adult protection matters. They are responsible for developing and improving policy, procedure and practice in relation to safeguarding across the organisation and ensuring that robust systems are in place to monitor practice. They will take responsibility for the initial response to all Isle Listen safeguarding enquiries and liaise with Social Services and the Adult Protection Team. They should have expertise in abuse and neglect, as well as local Isle of Man arrangements for safeguarding children and adults at risk.
Human Resources Manager for Isle Listen
The Human Resources Manager is responsible for ensuring that all staff:
- Are subject to enhanced Disclosure and Barring Service (DBS) checks (expedited in a timely manner).
- Have an induction and mandatory training, inclusive of safeguarding and child/ adult protection training.
All staff are required to:
- Undertake Child Protection and Safeguarding training provided by Isle Listen.
- Ensure that they attend any update training.
- Access help and advice from the Designated Safeguarding Lead and Officer in relation to safeguarding and child/adult protection matters as soon as is practically possible and at the latest,
before close of business on the same day as the concern arises: safeguarding and child/adult protection issues should never be managed by a single professional.
- Understand that the sharing of personal information about children, adults and families held by them should not be disclosed without the consent of the data subject. However, the law permits disclosure of confidential information necessary to safeguarding in circumstances of significant harm i.e., protecting children and adults at risk, will override the subject’s right to confidentiality. Staff should take advice from the Designated Safeguarding Lead and/or Officer in complex cases and ensure that any confidential information shared, is undertaken in the child/ adult’s best interests.
- Report any allegation related to safeguarding regarding a member of staff to the CEO and Clinical Lead, who will determine the process thereafter.
- Where a child or adult at risk is suspected to be at risk of significant harm, these concerns should be shared with the Children and Families Service or the Adult Protection Team without delay, and an initial discussion undertaken and recorded; this process will be supported by the Designated Safeguarding Lead and Officer. The police should be notified if an offence is believed to have been committed.
Board of Directors and Designated Director for Safeguarding
Directors have a legal duty to take reasonable steps within their power to ensure that children and adults who come into contact with Isle Listen are safeguarded from harm. The board of directors delegates the day-to-day implementation of this responsibility to the senior team in the roles described above. The board of directors has appointed a Designated Director to act on its behalf in relation to ensuring the appropriate development, implementation and monitoring of this.
Governance Policy - Practitioner qualifications & supervision
Isle Listen is a registered trading name of MCH Psychological Services (MCH) which is an Isle of Man registered charity number 1024 and organisational member of The British Association for Counselling and Psychotherapy.
MCH Psychological Services can trace its roots back to 1983 and The Lisa Lowe Centre and Manx Cancer Help and we have explicit standards for practitioner qualification and supervision. It is the strict adherence to these standards of care, which more than anything, has cemented the Charity’s reputation. For a third sector organisation on a small island, with no university or established post-qualification training programmes, this is particularly difficult.
Eligibility for Health and Care Professions Council (HCPC) or the General Medical Council (GMC) registration is a minimum requirement for our health care professionals. The Clinical Lead should be eligible for consultant NHS status. Our Clinical Lead of over a decade is a former band 9 Consultant Clinical Psychologist and is the most senior such post on the island.
Counsellors are required to have, or be eligible for, British Association for Counselling and Psychotherapy (BACP) accreditation. On occasions, a counsellor may be appointed who is working towards BACP accreditation. The BACP is the leading UK accreditation body for training courses and individual counsellors and psychotherapists. It has on public record, stringent training, supervision and CPD requirements and a clear Ethical Framework for the Counselling Professions. MCH is always careful to draw the distinction between accreditation and registration. The latter does not constitute a counselling qualification. We regard the BACP supervision requirements as a minimum and in most cases our counsellors enjoy additional supervision from a range of appropriately qualified professional staff.
With the increase in efficacy of cognitive behavioural and 3rd wave psychotherapies, as indicated by their exponential increase in National Institute for Health Care (NICE) guidance, the British Association for Behavioural and Cognitive Psychotherapies (BABCP), established in 1974, has become the key CBT accreditation body in the UK and Ireland. The BABCP essentially offers accreditation for cognitive behavioural psychotherapists and their supervisors & trainees. BABCP accreditation requirements are equivalent to the BACP and it is the key qualification requirement for the UK NHS Improving Access to Psychological Therapies programme (IAPT).
This ensures a high standard of clinical practice, clinical supervision and continued professional development. Indeed, the latter is routinely audited by the BABCP. Like the BACP, the BABCP also accredits university training courses on a number of different levels. We could appoint individuals with what is called “provisional” BABCP accreditation but who are working towards full accreditation. Like the NHS, MCH regards these two organisations as the key counselling and psychotherapeutic accreditation bodies in the UK.
Isle Listen follows the training and supervision template of the UK NHS Education Mental Health Practitioner model, which is aimed at provision of healthcare for children and young people in schools. The role of our practitioners is to provide low intensity, level 1 and level 2 interventions, essentially guided by the principles of CBT. The Isle Listen practitioners must have access to supervision for a minimum of four hours per calendar month regardless of the number of clients. Supervision is provided by a qualified counsellor or psychotherapist and must be a mix of group facilitation as well as one-to-one work. Isle Listen staff will be funded to complete level 5 accreditation in partnership with the Chester University counselling course. As with the Education Mental Health Practitioner programme, entrance requirements for our programme do not require previous degree qualification although our Wellbeing Practitioners (Listeners) are required to demonstrate their ability to work at degree level and require a similar skill set and personal characteristics of the NHS Education Mental Health Practitioners.
Essentially MCH has specific practitioner qualifications, standards, and skill sets. It is not enough to describe practitioners as “accredited professionals” or use other historical euphemistic language of some third sector organisations. Rather, MCH at the very least, ensures qualification equivalence with the statutory sector.
Photography and Filming Policy
This policy applies to all staff employed by MCH, including volunteers and other adults associated with our organisation.
Purpose and scope of this policy
The purpose of this policy statement is to:
- protect children and young people who take part in MCH’s services, events and activities, specifically those where photographs and videos may be taken
- set out the overarching principles that guide our approach to photographs/videos being taken of children and young people during our events and activities
- to ensure that we operate in line with our values and within the law when creating, using and sharing images of children and young people
A child is defined as a person under the age of 18 years within the Isle of Man Children and Young Persons Act 2001 and this policy has been drawn up upon the basis of that legislation.
We believe that:
- children and young people should never experience abuse of any kind
- we have a responsibility to promote the welfare of all children and young people and to take, share and use images of children safely.
We recognise that:
- sharing photographs and films of our activities can help us celebrate the successes and achievements of our children and young people, provide a record of our activities and raise awareness of our organisation
- the welfare of the children and young people taking part in our activities is paramount
- children, their parents and carers have a right to decide whether their images are taken and how these may be used, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation
- consent to take images of children is only meaningful when children, their parents and carers understand how the images will be used and stored, and are fully aware of the potential risks associated with the use and distribution of these images
- there are potential risks associated with sharing images of children online.
Promoting good practice
We will seek to keep children and young people safe by:
- always asking for written consent from a child’s parents or carers before taking and using a child’s image
- always explaining what images will be used for, how they will be stored and what potential risks are associated with sharing images of children
- making it clear that if a child or their family withdraw consent for an image to be shared, it may not be possible to delete images that have already been shared or published
- changing the names of children whose images are being used in our published material whenever possible (and only using first names if we do need to identify them)
- never publishing personal information about individual children and disguising any identifying information (for example the name of their school or a school uniform with a logo)
- making sure children, their parents and carers understand how images of children will be securely stored and for how long (including how we will control access to the images and their associated information)
- reducing the risk of images being copied and used inappropriately by:
- only using images of children in appropriate clothing (including safety wear if necessary)
- avoiding full face and body shots of children taking part in activities such as swimming where there may be a heightened risk of images being misused
- using images that positively reflect young people’s involvement in the activity.
Photography and/or filming for personal use
When children themselves, parents, carers or spectators are taking photographs or filming at our events and the images are for personal use, we will provide guidance about image sharing either on our website or announce details of our photography policy before the start of the event. This includes:
- reminding parents, carers and children that they need to give consent for us to take and use their images
- asking people to gain permission from children, their parents and carers before sharing photographs and videos that include them
- recommending that people check the privacy settings of their social media account to understand who else will be able to view any images they share
- reminding children, parents and carers who they can talk to if they have any concerns about images being shared.
Photography and/or filming for our use
We may use photography and filming as an aid in activities such as art and physical activity workshops.
Children, young people, parents and carers must be made aware that photography and filming is part of the programme and give written consent.
If we hire a photographer for one of our events, we will seek to keep children and young people safe by:
- providing the photographer with a clear brief about appropriate content and behaviour
- ensuring the photographer wears identification at all times
- informing children, their parents and carers that a photographer will be at the event and ensuring they give written consent to images which feature their child being taken and shared
- not allowing the photographer to have unsupervised access to children
- not allowing the photographer to carry out sessions outside the event or at a child’s home
- reporting concerns regarding inappropriate or intrusive photography following our child protection procedures.
Photography and/or filming for wider use
If people such as local journalists, professional photographers (not hired by MCH) or students wish to record one of our events and share the images professionally or in the wider world, they must seek permission from us in advance.
They must provide:
- the name and address of the person using the camera
- the names of children they wish to take images of (if possible)
- the reason for taking the images and/or what the images will be used for
- a signed declaration that the information provided is valid and that the images will only be used for the reasons given.
MCH will verify these details and decide whether to grant permission for photographs/films to be taken. We will seek consent from the children who are the intended subjects of the images and their parents and inform the photographer of anyone who does not give consent.
At the event we will inform children, parents and carers that an external photographer is present and ensure they are easily identifiable, for example by using them with a coloured identification badge.
If we are concerned that someone unknown to us is using their sessions for photography or filming purposes, we will ask them to leave and (depending on the nature of the concerns) follow our child protection procedures.
We will store photographs and videos of children securely, in accordance with our safeguarding policy and data protection law.
We will keep electronic images in a rights-restricted folder on our system for a period of 2 years from the date of capture.
We will never store images of children on unencrypted portable equipment such as laptops, memory sticks and mobile phones.
MCH does not permit staff and volunteers to use any personal equipment to take photos and recordings of children.
Mental Health Training Cancellation Policy
- Cancellations made 14 days or more in advance of the event date will receive a full refund.
- Cancellations made within 3-14 days of the event date will receive a 50% refund.
- No refund will be available for cancellations made within 72 hours of the event.
Courses we deliver at your organisation/premises
Our courses delivered at your organisation/premises are subject to a 25% non-refundable deposit paid within 7 days of your booking.