Sussex Heritage Trust Policies

Equal Opportunities Statement

Our vision
We are committed to being recognised for achieving the highest standards of inclusion, diversity and equality of opportunity in our work and activity.

Our values
We treat everyone with respect and uphold a working environment free of bullying, harassment, victimisation and discrimination.

We respect and value the differences of individuals and we encourage and welcome the contributions of everyone involved in our activities.

We know we cannot understand the experiences of others without listening to and learning about their lived experience.

We are committed to:
Improving diversity in our staff, Trustees and anyone involved in the organisation in any capacity, to be truly representative of all sections of society.

Developing our understanding, examining our behaviours and challenging biases that prevent us from being truly inclusive.

Reviewing and improving out policies, processes and practices to ensure we match our Vision and Values.

Developing a strategy for inclusion that will improve representation and enable us to implement and sustain authentic, systemic change.

Updating this statement to reflect our practices as they develop and to sharing our learnings and revised approaches with the wider Sussex Heritage Trust audiences.

Responsibilities:
The overall responsibility for the Policy lies with the Trustees. However, all staff and volunteers are required to comply with the Policy and to act in accordance with its objectives so as to remove any barriers to equality opportunity. Any act of discrimination by staff or volunteers, or any failure to comply with the terms of the Policy will result in disciplinary action.

Agreed at the Meeting of the Board of Trustees on: 21st January 2025

Signed by David Cowan, Chair of the Board of Trustees:
Date: 21st January 2025
To be reviewed by SHT board of Trustees: 30th January 2026

Ethical Fundraising Policy

Purpose

The purpose of this document is to:
Help ensure that funding relationships do not indirectly support activities that are counter to the Sussex Heritage Trust’s charitable objectives.
Project the Sussex Heritage Trust’s reputation, by supporting decision-making on funding opportunities.
Provide guidance on the types of companies, funders, and fundraising events that the Sussex Heritage Trust will or will not be associated with in pursuing fundraising to support delivery of its charitable objectives.

Responsibility

The Ethical Fundraising Policy has been agreed by the Board of Trustees. The policy has been signed by the Chair of Trustees, who is publicly accountable for upholding the policy.

Procedures

The following procedures will be undertaken to uphold the policy:

• All fundraising activity will be regularly reviewed at the General Meeting of Trustees, who meet three times a year.
• The Trustee responsible for Fundraising, will review new funding partnerships and report to the Chair.
• The Trustee responsible for Risk, will review new funding partnerships and report to the Chair.
• A fundraising review will form part of the Risk Log, which will be approved by Trustees at the General Meeting of Trustees once a year.

Introduction to Sussex Heritage Trust

Sussex Heritage Trust is a Registered Charity (No. 274366) established in 1977 to preserve, improve and encourage the appreciation of the architectural and natural landscape of Sussex.

1. Rationale for Fundraising

To help guarantee the availability of ongoing funds to pay for the work of Sussex Heritage Trust. The Trust aims to maintain a broad base of different sources of funding. The purpose of this policy is to ensure clarity and openness to all who support the work of the charity.
Fundraising can include cash income, in-kind support, marketing, partnerships.

1. Key Issues for Sussex Heritage Trust to Consider

Donations, funding and partnerships which may pose a reputational risk to Sussex Heritage Trust including those which could lead to negative publicity and:

• The loss of donations from other supporters.
• The loss of volunteers whose services would be of equivalent or greater value that the gift of partnership.
• The loss of staff or inability to recruit staff with the necessary skills and dedication.

1. Policy Points

Context

Sussex Heritage Trust actively seeks opportunities to work together with external organisations and individuals to achieve shared objectives. However it is vital that Sussex Heritage Trust maintains its independence and does not allow any external partners to bring the name of Sussex Heritage Trust into disrepute.

Sussex Heritage Trust therefore accepts financial support from, and partnership working with, companies and individuals on the following conditions:

• There are strong grounds for believing that it will result in a benefit to Sussex Heritage Trust’s beneficiaries.
• The Chief Executive Officer and Trustees are satisfied that no adverse publicity will result from accepting such support.
• There is no attempt on the part of the Company or individual to influence the Sussex Heritage Trust’s policy or actions either explicitly or implicitly.
• That initiatives do not comprise the independent status of Sussex Heritage Trust.
• The company does not participate in business practices that are counter to Sussex Heritage Trust’s charitable objectives.

Cause-Related Marketing, Affinity Marketing and Product/Service Endorsement

• Sussex Heritage Trust may want to enter into a partnership in which it will actively endorse or promote a company. However, if the Trust enters into a partnership but that does not imply endorsement, a disclaimer statement to this effect will be included alongside any branding or promotion associated with products. E.g. ‘The use of this logo does not imply any endorsement by Organisation of this company, its products or services’.
• Only Sussex Heritage Trust will have direct access to its database and beneficiaries.

In order to ensure that all of Sussex Heritage Trust cause-related promotion reflects the Sussex Heritage Trust’s values, any potential initiative must come to the Chief Executive and relevant governance committee for approval.

Avoidance Criteria

Sussex Heritage Trust will not accept any funding form companies directly involved in activities that run contrary to its overall charitable objectives, vision and aims. It will not accept financial support or partnerships with companies currently involved with human right abuses and/or illegal activity.

Other reputational risks

Sussex Heritage Trust will also refuse donations from those that are known to instigate or repeat views of an inflammatory or derogatory nature concerning someone’s race, gender, disability, sexual orientation, religion, culture or any other aspect of that person’s life which may be counter to Sussex Heritage Trust’s purpose and values.

Due Diligence

The Fundraising Committee/Trustee is responsible for setting out intentions in relation to due diligence. This includes checking the identity of donors and partners to ensure there is no conflict (or potential conflict) of interest and carrying out research to guard against legal and reputational risk. This is in accordance with ‘Know Your Donor’ principals developed by the Charity Commission, including:

• Know what the organisation or individual business is and be assured this is appropriate for the charity to be involved in.
• Watch out for unusual or suspicious or unexpected activities, conduct or requests.
• Research is carried out using a range of publicly available sources which may include the Electoral Register, Companies House, the Register of Charities, the Charity Commission, newspaper reports and company websites.

Due Diligence may be carried out on donations of £10,000 or more from individuals, £20,000 or more from grant-making trusts, unsolicited corporate donations of £5,000 or more, and all businesses which the Sussex Heritage Trust is actively partnering with. In line with Charity Commission guidance, if a donation of £25,000 or more is received from an unknown or unverifiable source, it is to be reported to the Charity Commission as a serious incident. (This only applies when the donor is completely anonymous, not when the donor is known to the Sussex Heritage Trust but wishes to remain publicly anonymous.)

Acceptance Criteria

Sussex Heritage Trust endeavours to comply with all relevant legislation, including money laundering rules, the Bribery Act and Charity Commission guidance, including terrorism and political activity. The Trust would therefore not accept any donation where any of the following obtained:

• The donor was known to be associated with criminal sources and/or illegal activity
• Accepting the donation would help further a donor’s personal objectives which conflict with those of the Sussex Heritage Trust
• Accepting the donation would lead to a possible decline in support for the Trust, and so risk a fall in the resources available to fund its work or damage its longer-term fundraising prospects
• Accepting the donation would otherwise impact adversely on the Trust’s reputation
• Accepting a donation from any particular source is inconsistent with Government policy

Sussex Heritage Trust will actively seek support from donors and companies, and will prioritise those whose practices align to its values.

Purchasing

Sussex Heritage Trust will not knowingly purchase goods and/or services produced and delivered under conditions which involve any form of abuse or exploitation of third parties. Evidence (not exhaustive) of such abuse and exploitation includes:

• The use of child labour
• Failure to pay employees a minimum wage
• Working hours are excessive
• Evidence of any form of inhuman, unreasonable or discriminatory treatment of employees
• Undertake practices that violate human rights through environmentally unsustainable business practices.

Sussex Heritage Trust expects suppliers to accept responsibility for labour and environmental working conditions under which products are made and services are provided, and to make written statement of intent regarding the company’s policy.

Management

To manage funding partnerships within an ethical framework, Sussex Heritage Trust will outline partnership agreements for any funding over £20,000.

Further Points

Sussex Heritage Trust recognises that, in accepting funding from statutory bodies, it must consider the policy implications and obligations that might be tied to it and ensure that these do not contravene the aims of the Trust.
Sussex Heritage Trust will not allow any supporter to compromise our policy independence and all supporters, and staff associated with these supporters, must be clear that the positions we take are based on our independent assessment of the most effective way to advance our mission. They are not constrained in any way by the policy or priorities of any organisations or individuals that support us.

Sussex Heritage Trust can seek to raise funds from a series of Charitable Trusts and Foundations, but recognises that, simply because these have been registered with the Charity Commission does not mean that they are ethical givers.

Sussex Heritage Trust therefore does not accept money from any Charitable Trust where its source funding might run contrary to the Trust’s aims, or if it is a requirement of grant receipt to advertise any company or organisation whose activities run contrary to the Trust’s aims.

Sussex Heritage Trust will maintain accountability and open and honest relationships with all its partners, by regularly monitoring and evaluating its work.

This statement of policy is meant as a working guide for the Trust. Any final decisions will be governed by the Board of Trustees. It is the duty of the Board to advise of any potential conflicts of interest with regards to funding or partnerships, and for the Board to act in the best interests of the Sussex Heritage Trust at all times.

Agreed at the Meeting of the Board of Trustees on: 21st January 2025

Signed by David Cowan, Chair of the Board of Trustees:
Date: 21st January 2025
To be reviewed by SHT board of Trustees: 30th January 2026

GDPR Policy | May 2018

1. INTRODUCTION

1.1. Sussex Heritage Trust (SHT) collects and uses certain types of personal information about staff, Trustees, supporters, entries into the Sussex Heritage Trust Awards and other individuals who come into contact with SHT. We may be required by law to collect and use certain types of information to comply with statutory obligations related to employment and this policy is intended to ensure that personal information is dealt with properly and securely and in accordance with the General Data Protection Regulation and other related legislation. This policy is intended to ensure that personal information is dealt with properly and securely and in accordance with the General Data Protection Regulations and other related legislation.

1.2. The GDPR applies to all computerised data and manual files if they come within the definition of a filing system.

2. PERSONAL DATA

2.1. ‘Personal data’ is information that identifies an individual. A sub-set of personal data is known as ‘personal sensitive data’. This special category data is information that relates to a persons:

2.1.1. race or ethnic origin;
2.1.2. political opinions;
2.1.3. religious or philosophical beliefs;
2.1.4. trade union membership;
2.1.5. physical or mental health;
2.1.6. an individual’s sex life or sexual orientation;
2.1.7. genetic or biometric data for the purpose of uniquely identifying a natural person.

2.2. Personal sensitive data is given special protection, and additional safeguards apply if this information is to be collected and used.

2.3. SHT does not intend to seek or hold sensitive personal data about staff, trustees or clients except where it has been notified of the information, or it comes to light via legitimate means (e.g. a grievance) or needs to be sought and held in compliance with a legal obligation or as a matter of good practice.

3. THE DATA PROTECTION PRINCIPLES

3.1. Article 5 of the GDPR sets out six data protection principles which must be followed at all times:
3.1.1. personal data shall be processed fairly, lawfully and in a transparent manner;
3.1.2. Personal data shall be collected for specific, explicit, and legitimate purposes, and shall not be further processed in a manner incompatible with those purposes;
3.1.3. personal data shall be adequate, relevant and limited to what is necessary for the purpose(s) for which it is being processed;
3.1.4. personal data shall be accurate and, where necessary, kept up to date;
3.1.5. personal data processed for any purpose(s) shall not be kept for longer than is necessary for that purpose / those purposes;
3.1.6. personal data shall be processed in such a way that ensures appropriate security of the data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

3.2. In addition to this, SHT is committed to ensuring that at all times, anyone dealing with personal data shall be mindful of the individual’s rights under the law (as explained in more detail in paragraphs 7 and 8 below).

3.3. SHT is committed to complying with the principles in 3.1 at all times. This means that we will:

3.3.1. inform individuals as to the purpose of collecting any information from them, as and when we ask for it and will identify who we will share the information with and how long we intend to retain the information;
3.3.2. be responsible for checking the quality and accuracy of the information;
3.3.3. regularly review the records held to ensure that information is not held longer than is necessary, and that it has been held in accordance with the data retention policy;
3.3.4. ensure that when information is authorised for disposal it is done in accordance with our disposals policy;
3.3.5. ensure appropriate security measures to safeguard personal information whether it is held in paper files or on our computer system, and follow the relevant security policy requirements at all times;
3.3.6. share personal information with others only when it is necessary and legally appropriate to do so;
3.3.7. set out clear procedures for responding to requests for access to personal information known as subject access requests;
3.3.8. report any breaches of the GDPR.

4. CONDITIONS FOR PROCESSING

4.1. The individual has given consent that is specific to the particular type of processing activity.
4.2. The processing is necessary for the performance of a contract, to which the individual is a party, or is necessary for the purpose of taking steps with regards to entering into a contract with the individual, at their request.
4.3. The processing is necessary for the performance of a legal obligation to which we are subject.
4.4. The processing is necessary to protect the vital interests of the individual or another.

5. USE OF PERSONAL DATA BY THE SUSSEX HERITAGE TRUST

5.1. SHT collects and uses certain types of personal information about staff, Trustees, supporters, entries into the Sussex Heritage Trust Awards and other individuals who come into contact with SHT. In each case, the personal data must be treated in accordance with the data protection principles as outlined in paragraph 3.1 above.
5.2. Any wish to limit or object to use of personal data should be notified to SHT in writing. If, in the view of the Trustees, the objection cannot be maintained, the individual will be given written reasons why SHT cannot comply with their request.

Staff, Trustees, supporters and entries into the Sussex Heritage Trust Awards

5.3. The personal data held about staff, Trustees and volunteers will include contact details, employment history, information relating to career progression, and photographs.
5.4. The data is used to comply with legal obligations placed on SHT in relation to employment. We may pass information to other regulatory authorities where appropriate. Personal data will also be used when giving references.
5.5. It should be noted that information about disciplinary action may be kept for longer than the duration of the sanction. Although treated as “spent” once the period of the sanction has expired, the details of the incident may need to be kept for a longer period.

Other Individuals

5.6. SHT may hold personal information in relation to other individuals who have contact with the organisation. Such information shall be held only in accordance with the data protection principles and shall not be kept longer than necessary.

6. SECURITY OF PERSONAL DATA

6.1. SHT will take reasonable steps to ensure that members of staff and Trustees will only have access to personal data where it is necessary for them to carry out their duties. All staff will be made aware of this Policy and their duties under the GDPR. SHT will take all reasonable steps to ensure that all personal information is held securely and is not accessible to unauthorised persons.

7. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

7.1. The following list includes the most usual reasons that SHT will authorise disclosure of personal data to a third party:

7.1.1. To give a confidential reference relating to a current or former employee;
7.1.2. for the prevention or detection of crime;
7.1.3. for the assessment of any tax or duty;
7.1.4. where it is necessary to exercise a right or obligation conferred or imposed by law upon the organisation (other than an obligation imposed by contract);
7.1.5. for the purpose of, or in connection with, legal proceedings (including prospective legal proceedings);
7.1.6. for the purpose of obtaining legal advice;

7.2. SHT may receive requests from third parties to disclose personal data it holds about staff or other individuals. This information will not generally be disclosed unless one of the specific exemptions under data protection legislation which allow disclosure applies; or where necessary for the legitimate interests of the individual concerned or SHT.

7.3. All requests for the disclosure of personal data must be sent to the Trustees, who will review and decide whether to make the disclosure, ensuring that reasonable steps are taken to verify the identity of that third party before making any disclosure.

8. SUBJECT ACCESS REQUESTS

8.1. Anybody who makes a request to see any personal information held about them by SHT is making a subject access request. All information relating to the individual, including that held in electronic or manual files should be considered for disclosure.
8.2. A subject access request must be made in writing. SHT may ask for any further information reasonably required to locate the information.
8.3. All requests will be handled in line with the Subject Access procedural note.

9. OTHER RIGHTS OF INDIVIDUALS

Right to restrict processing

9.1. An individual has the right to object to the processing of their personal data and to block or suppress the processing.
9.2. Where such an objection is made, it must be sent to SHT who will assess whether there are compelling legitimate grounds to continue processing which override the interests, rights and freedoms of the individuals, or whether the information is required for the establishment, exercise or defence of legal proceedings.
9.3. SHT shall be responsible for notifying the individual of the outcome of their assessment within 20 working days of receipt of the objection.

Right to rectification

9.4. An individual has the right to request the rectification of inaccurate data or incomplete data without undue delay. Where any request for rectification is received, it should be sent to the Administrator and where adequate proof of inaccuracy is given, the data shall be amended as soon as reasonably practicable, and the individual notified within 20 days.
9.5. Where there is a dispute as to the accuracy of the data, the request and reasons for refusal shall be noted alongside the data, and communicated to the individual. The individual shall be given details of how to appeal to the Information Commissioner.
9.6. An individual also has a right to have incomplete information completed by providing the missing data, and any information submitted in this way shall be updated without undue delay.

Right to erasure

9.7. Individuals have a right, in certain circumstances, to have data permanently erased without undue delay. This right arises in the following circumstances:

9.7.1. where the personal data is no longer necessary for the purpose or purposes for which it was collected and processed;
9.7.2. where consent is withdrawn and there is no other legal basis for the processing;
9.7.3. where an objection has been raised under the right to object, and there is no overriding legitimate interest for continuing the processing;
9.7.4. where personal data is being unlawfully processed (usually where one of the conditions for processing cannot be met);
9.7.5. where the data has to be erased in order to comply with a legal obligation.
9.8. SHT will make a decision regarding any application for erasure of personal data, and will balance the request against the exemptions provided for in the law. Where a decision is made to erase the data, and this data has been passed to other data controllers, and / or has been made public, reasonable attempts to inform those controllers of the request shall be made.

Right to object

9.9. An individual has the right to object to:

9.9.1. processing based upon legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
9.9.2. direct marketing (including profiling);
9.9.3. processing for purposes of scientific /historical research and statistics.
9.10. Where such an objection is made, it must be sent to the Trustees who will assess whether there are compelling legitimate grounds to continue processing which override the interests, rights and freedoms of the individuals, or whether the information is required for the establishment, exercise or defence of legal proceedings.

Right to portability

9.11. If an individual wants to send their personal data to another organisation they have a right to request that SHT provides their information in a structured, commonly used, and machine readable format. This right is limited to situations where SHT is processing the information on the basis of consent or performance of a contract. If a request for this is made, it should be forwarded to the Trustees.

10. BREACH OF ANY REQUIREMENT OF THE GDPR

10.1. Any and all breaches of the GDPR, including a breach of any of the data protection principles shall be reported as soon as it is discovered, to the Trustees.

Once notified, the Trustees shall assess:

10.1.1. the extent of the breach;
10.1.2. the risks to the data subjects as a consequence of the breach;
10.1.3. any security measures in place that will protect the information;
10.1.4. any measures that can be taken immediately to mitigate the risk to the individuals.
10.2. Unless the Trustees concludes that there is unlikely to be any risk to individuals from the breach, it must be notified to the Information Commissioner’s Office within 72 hours of the breach having come to the attention of the Council.
10.3. The Information Commissioner shall be told:

10.3.1. details of the breach, including the volume of data at risk, and the number and categories of data subjects;
10.3.2. the contact point for any enquiries;
10.3.3. the likely consequences of the breach;
10.3.4. the measures proposed or already taken to address the breach
10.4. If the breach is likely to result in a high risk to the affected individuals then the Trustees shall notify data subjects of the breach without undue delay unless the data would be unintelligible to those not authorised to access it, or measures have been taken to mitigate any risk to the affected individuals.
10.5. Data subjects shall be told:

10.5.1. the nature of the breach;
10.5.2. who to contact with any questions;
10.5.3. measures taken to mitigate any risks.

10.6. The Trustees shall then be responsible for instigating an investigation into the breach, including how it happened, and whether it could have been prevented. Any recommendations for further training or a change in procedure shall be reviewed by SHT and a decision made about implementation of those recommendations.

Privacy Policy | May 2018

Sussex Heritage Trust takes the protection of your data seriously. Our aim is to provide a personalised and valuable service whilst safeguarding our users’ privacy. Collecting some personal information is necessary if we are to satisfy the expectations and requirements of our users and we have set out below what we will do with your personal information.

Visitors to this web site

When someone visits this website we may use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Security and Performance

We may use a third party service to help maintain the security and performance of our website. To deliver this service it processes the IP addresses of visitors to the site.

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Use of Cookies

This site may use cookies to maintain and keep track of users’ preferences and authenticated sessions, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance.

As of May 2018, the site only uses a ‘first-party’, temporary cookie, PHPSESSID. First party cookies are set by the website itself and can only be read by this site. It is required by PHP to store a logged-in user’s username and a 128bit encryption key. This information is required to allow a user to stay logged in to our web site without needing to submit their username and password for each page visited. Without this cookie, a user is unable to proceed to areas of the web site that require authenticated access – ie, when editing or updating the website.

You can check which cookies any website uses (including ours) here: www.cookie-checker.com

Disclosure of personal information

We collect contact details via the web site for the purposes of providing a service to existing and potential customers. We will never disclose personal details without the consent of the owner. Details are only held for as long as is necessary to fulfil the service request.

Access to personal information

Individuals can find out if we hold any personal information by making a ‘subject access request’ under the General Data Protection Regulations. If we do hold information about you we will:

• give you a description of it;
• tell you why we are holding it;
• tell you who it could be disclosed to; and
• let you have a copy of the information in an intelligible form

Please make any such request in writing via our email address office@sussexheritagetrust.org.uk or by post to PO Box 769, Chichester PO19 9RT.

If at any time you feel that we have failed to meet these standards then please either contact us or make a complaint direct to the Information Commissioner using their website www.ico.org.uk/concerns

SAFEGUARDING POLICY

POLICY STATEMENT
1.1 We are committed to protecting all children and vulnerable adults, where we are engaged in activities which do or may involve them, against all forms of abuse and we expect everyone who works in our organisation to share this commitment.

1.2 We also have a duty under section 26 of the Counter-Terrorism and Security Act 2015, to have “due regard to the need to prevent people from being drawn into terrorism”. This duty is known as the Prevent duty.

1.3 This policy sets out how the organisation will manage recruitment for job roles that involve any regulated activity and working with vulnerable groups, and how it will manage matters arising during employment where it is believed that vulnerable groups could be, or have been, placed at risk.

1.4 The policy also explains the responsibilities of all staff in relation to the safeguarding of vulnerable groups and the procedure that should be followed when reporting an allegation of abuse.

This policy does not form part of any employee’s contract of employment and it may be amended at any time. We may also vary elements, such as any time limits, as appropriate in any case.

WHO IS COVERED BY THIS POLICY?
1.5 This policy applies to all employees, directors and other officers, workers, agency workers and volunteers.

1.6 We also require in any contracts with self-employed consultants or contractors that they comply with the relevant parts of this policy. We will ensure they are given access to a copy.

1.7 All individuals covered in sections 2.1 and 2.2 are referred to as ‘staff’ in this policy.

WHO IS RESPONSIBLE FOR THIS POLICY?
1.8 While we ask all managers to take responsibility for making sure this policy is complied with, it is the responsibility of all staff to report any alleged or suspected abuse to your manager or a Director.

1.9 Please take the time to read and understand this policy and to go back to your manager with any questions you may have. References to Directors in this policy mean the most senior people within our organisation.

DEFINITIONS
1.10 ‘Child’ means anyone under the age of 18 years.

1.11 ‘Vulnerable adult’ means anyone over the age of 18 years who is defined as vulnerable under The Police Act 1997 (Enhanced Criminal Record Certificates), Protection of Vulnerable Adults Regulations 2002, or any broader definition of vulnerable adult as used within your organisation.

1.12 ‘Vulnerable groups’ means children and vulnerable adults.

1.13 ‘Regulated activity’ means any of the activities defined as regulated activity in the Safeguarding Vulnerable Groups Act 2006.

1.14 ‘Safeguarding concerns’ means a concern that an adult/child is at risk of or is experiencing abuse or neglect.

1.15 ‘Abuse’ is defined in section 8 below.

RECRUITMENT FOR REGULATED ACTIVITY
1.16 We will make it clear to candidates when advertising a job role if the work involved is regarded as a regulated activity, and will determine this in accordance with the provisions of the Safeguarding Vulnerable Groups Act 2006.

1.17 Before we can employ a candidate for a role in a regulated activity, we will require receipt of a satisfactory Enhanced Disclosure certificate with a relevant barred list check from the Disclosure and Barring Service (DBS).

1.18 The DBS helps us make safer recruitment decisions and prevent unsuitable people from working with vulnerable groups. We will ensure that the correct level of DBS certificate is sought. The purpose of this check is to confirm that the candidate is suitable to perform this work and is not barred from doing so.

1.19 All Enhanced Disclosure certificates will be issued to you directly by the DBS. As a consequence, we require you to provide the original DBS certificate to your manager or a Director upon receipt.

1.20 We will make any offer of employment in a regulated activity conditional upon receiving a satisfactory Enhanced Disclosure certificate with a barred list check.

EXISTING STAFF CHANGING TO REGULATED ACTIVITY
1.21 If your work either becomes a regulated activity, or if you are asked to perform work that is a regulated activity, we will require you to provide a satisfactory Enhanced Disclosure certificate with a relevant barred list check from the DBS. The purpose of this check is to confirm that you are suitable to perform this work and are not barred from doing so.

1.22 If you refuse to undertake these checks, or if a check confirms that you have a relevant criminal conviction or have been placed on a relevant barred list, we will investigate the circumstances further and will fully consider the effect of this on any continued employment.

1.23 Where you are not legally permitted to perform a regulated activity, or where we otherwise have reason to believe that this will be inappropriate, we may consider if there are any other non­ regulated activities in which you can be deployed.

1.24 We reserve the right to dismiss you where continued employment cannot be supported.

CHANGES TO YOUR DBS STATUS
1.25 You must inform us immediately of any change to your DBS Enhanced Disclosure status, or if you are investigated, cautioned or convicted of a criminal offence while working for us.

1.26 If you are added to a barred list, we cannot legally allow you to continue to engage in a regulated activity.

1.27 Where you are not permitted to perform a regulated activity, we may investigate if there are any other non-regulated activities in which you can be deployed.

1.28 We reserve the right to dismiss you where continued employment cannot be supported.

WHAT IS ABUSE OF VULNERABLE GROUPS?
1.29 Abuse may be a single incident or something that occurs over a long period oftime. It can take many forms including, but not limited to:

a. financial or material abuse
b. physical abuse
c. mental abuse
d. neglect and failures to act
e. sexual abuse
f. threats of abuse or harm
g. controlling or intimidating conduct
h. self-neglect
i. domestic abuse
j. poor practices within an organisation providing care
k. modern slavery.

1.30 The abuse may come from anyone coming into contact with the child or vulnerable adult, including but not limited to staff, personal assistants, service users, relatives, neighbours, social workers or providers of support services.

REPORTING ALLEGED OR SUSPECTED ABUSE
1.31 All staff must always be vigilant to risks of abuse towards vulnerable groups.

1.32 If you believe or suspect that abuse is occurring, you must refer the matter to your manager or a Director immediately. We will treat all complaints, allegations, or suspicions of abuse with the utmost seriousness.

1.33 When reporting an allegation of abuse, it is important to provide as much detail as possible, including the names of the people involved, the nature of the abuse, the dates and times of any specific incidents (if known) and details of any evidence or other witnesses that may be available.

1.34 We may ask you to refrain from discussing alleged abuse with fellow colleagues, other than those specified by your manager, to avoid the spread of potentially harmful misinformation and to protect the validity of any investigation.

INVESTIGATION
1.35 We will investigate all complaints of alleged or suspected abuse fully. The investigation will be conducted in a discreet and timely manner, and will involve the collation of evidence typically derived from witness statements and surveillance footage where possible.

1.36 We may be required to refer information to the DBS and may also consider it necessary to inform the police of allegations under investigation

SUSPENSION
1.37 If you are an employee suspected of abuse, you may be suspended on full pay pending a full investigation of the complaints. It should be noted that this suspension is not an indication of your guilt, but rather a necessity given the circumstances. We appreciate the impact prolonged suspension can have on your reputation, even when allegations are later found to be incorrect, and do not take the decision to suspend lightly.

DISCIPLINARY ACTION
1.38If we have reason to believe that an allegation of abuse has foundation, we will arrange a disciplinary meeting with the individual. Abuse is regarded as an act of gross misconduct and therefore may result in summary dismissal, in accordance with our Disciplinary Procedure.

DUTY TO REFER INFORMATION
1.39 We will discuss any safeguarding concerns with the local safeguarding team and would encourage any staff member with concerns to do the same.

1.40 Please remember that it is not for you to decide a child or vulnerable adult is or may be at risk of harm or abuse, but it is for you to refer that information to the relevant professional bodies who can assess risk and act as required.

1.41 The relevant bodies are:

a. West/East Sussex Children Services I Brighton & Hove Safeguarding Children Partnership
b. West and East Sussex Adults’ CarePoint
c. Brighton and Hove I East and West Sussex Safeguarding Investigations Unit
d. The NSPCC
e. The Care Quality Commission

1.42 We are legally required to refer certain information about an individual to the DBS.

1.43 This duty applies where:

a. you are dismissed or removed from working in a regulated activity because you have harmed or may harm a child or vulnerable adult.
b. we have suspended you and have reason to believe that you have engaged in relevant conduct or have harmed or may harm a child or vulnerable adult, or have received a caution or a conviction for a relevant criminal offence.
c. you resign in circumstances where there is a suspicion that you harmed, or may harm, a child or vulnerable adult. This may, for example, arise where an employee resigns before disciplinary action is taken by the organisation.

RETENTION OF RECORDS AND STORAGE PERIODS
1.44 We will ensure that all safeguarding records are retained and stored in accordance with data protection principles, any statutory requirements and any relevant guidance.

PREVENT DUTY
1.45 In order for us to fulfil our Prevent duty, it is essential that staff are able to identify those who may be vulnerable to radicalisation and know what to do when they are identified. Protecting vulnerable groups from the risk of radicalisation is part of our wider safeguarding duties under this policy. can take many forms including:

a. Being groomed online or in person
b. Exploitation, including sexual exploitation
c. Psychological manipulation
d. Exposure to violent material and other inappropriate information
e. The risk of physical harm or death through extremist acts.

Staff need to be aware of the indicators of radicalisation – Radicalisation and child protection I NSPCC Learning:

f. Spending increasing amounts of time talking to people with extreme views
g. Changing their style of dress or personal appearance
h. Losing interest in friends and activities that are not associated with the extremist ideology, group or cause
i. Having materials or symbols associated with an extreme cause
j. Trying to recruit others to join the cause

1.46 We will assess the risk of vulnerable groups in our care being drawn into terrorism, including support for extremist ideas that are part of terrorist ideology and will respond in an appropriate and proportionate way.

1.47 All staff should be alert to changes in behaviour which could indicate that they may be in need of help or protection. Those at risk of radicalisation may display different signs or seek to hide their views. Staff should use their professional judgement in identifying those who might be at risk of radicalisation and act proportionately.

1.48 The Prevent duty does not require staff to carry out unnecessary intrusion into family life. However, as with any other safeguarding risk, you must take action if you observe behaviour of concern and report any suspicions or concerns immediately to your manager or a Director.

1.49 Where appropriate, we may make a referral to the Channel programme.

MONITORING AND REVIEW OF THE POLICY
1.50 We will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives.

Agreed at the Meeting of the Board of Trustees on: 21st January 2025

Signed by David Cowan, Chair of the Board of Trustees: Date: 21st January 2025

To be reviewed by SHT board of Trustees: 30th January 2026