SAFEGUARDING POLICY
 

Impact Transition Services CIC
 

Protecting Children and Adults at Risk
 

Document reference: ITS-POL-001 Version: 1.0 Date adopted: June 2026 Review date: June 2027 Approved by:Board of Directors, Impact Transition Services CIC Companies House number: 17201212

 

CONTENTS

1. Policy Statement and Commitment

2. Scope and Application

3. Legal and Regulatory Framework

4. Designated Safeguarding Lead

5. Definitions

6. Recognising Abuse and Harm

7. Reporting and Response Procedures

8. Safe Conduct — Staff and Volunteer Standards

9. Safer Recruitment

10. Information Sharing and Confidentiality

11. Recording and Documentation

12. Working with Partner Agencies

13. Whistleblowing

14. Training Requirements

15. Policy Review
    
     

Appendix A — Safeguarding Concern Report Form Appendix B — Key Contacts and Escalation Numbers Appendix C— Definitions of Abuse

 

1. POLICY STATEMENT AND COMMITMENT

Impact Transition Services CIC is committed to the safety, welfare, and protection of every young person we work with. We believe that every young person — regardless of age, background, offending history, or circumstance — has the right to be safe, to be treated with dignity, and to receive support without fear of harm.

We recognise that the young people we support have often experienced significant trauma, instability, and harm throughout their lives. Many have been failed by institutions and adults who were supposed to protect them. This makes our safeguarding responsibility not merely a legal obligation but a fundamental expression of our purpose.
 

This policy sets out our commitment to:

• Protect every young person we work with from abuse, neglect, exploitation, and harm

• Ensure our staff, founders, and volunteers act with the highest standards of professional conduct

• Create a culture in which concerns are taken seriously, reported promptly, and acted upon

• Work collaboratively with statutory agencies to promote the welfare of young people at risk

• Ensure that no safeguarding concern is ever dismissed, minimised, or ignored
   

This policy applies to all activities undertaken by Impact Transition Services CIC, including release-day collections, escorted transport, orientation support, accommodation handovers, and follow-up mentoring.

Safeguarding is everyone's responsibility. It is never optional.

 

2. SCOPE AND APPLICATION

This policy applies to:

• All directors and founders of Impact Transition Services CIC

• All employees, sessional workers, and contractors

• All volunteers and peer mentors

• Any individual acting on behalf of Impact Transition Services CIC in any capacity

It applies across all settings in which we operate, including:

• Prison and Young Offender Institution gate collections (HMYOI Feltham and other sites)

• Vehicles used for escorted transport

• Probation offices, YOT offices, and court buildings

• Supported accommodation and hostels

• Domestic addresses

• Public spaces during escort or follow-up support

• Any digital or remote communication with young people
   

This policy covers:

• Young people aged 16–17 (who are children in law under the Children Act 1989)

• Young adults aged 18–24 who may be adults at risk under the Care Act 2014

• Any individual we encounter in the course of our work who may be at risk of harm

3. LEGAL AND REGULATORY FRAMEWORK

This policy has been developed in accordance with the following legislation, guidance, and frameworks:
 

Primary legislation:

• Children Act 1989 and Children Act 2004

• Care Act 2014 (adults at risk)

• Safeguarding Vulnerable Groups Act 2006

• Modern Slavery Act 2015

• Equality Act 2010

• Data Protection Act 2018 and UK GDPR

• Human Rights Act 1998
   

Statutory guidance:

• Working Together to Safeguard Children 2023 (HM Government)

• Care and Support Statutory Guidance 2014 (updated 2023)

• Keeping Children Safe in Education 2023 (for context and alignment)

• Framework for the Assessment of Children in Need and their Families
   

Sector-specific frameworks:

• HMPPS Safeguarding Framework for contracted providers

• Youth Justice Board — Child Safeguarding in Youth Justice Settings

• HMYOI Feltham Safeguarding Strategy 2023

• Hounslow Safeguarding Children Partnership procedures

• London Safeguarding Children Procedures
   

4. DESIGNATED SAFEGUARDING LEAD (DSL)

4.1 Named DSL

Name: [Del Steele Founder — Del Steele
Role: Director and Designated Safeguarding Lead
Organisation: Impact Transition Services CIC 
Contact: [delsteele@impacttransitionservices.org.uk] | [phone number: 07930 447 587]

The DSL is responsible for all safeguarding matters within Impact Transition Services CIC. They are the first point of contact for any safeguarding concern raised by a staff member, volunteer, partner agency, or young person.

4.2 Deputy DSL

Name: [Founder — Jayden Wilson] 
Role: Director and Deputy Designated Safeguarding Lead Contact: [jaydenwilson@impacttransitionservices.org.uk] | [07930447587

The Deputy DSL acts in the absence of the DSL and has the same authority to receive, assess, and escalate safeguarding concerns.
 

4.3 Responsibilities of the DSL

The Designated Safeguarding Lead is responsible for:

• Receiving and reviewing all safeguarding concerns raised within the organisation

• Making decisions about whether a concern requires a referral to statutory agencies

• Making referrals to children's social care, adult social care, or the police where appropriate and without delay

• Maintaining accurate, confidential records of all safeguarding concerns and actions taken

• Ensuring all staff, volunteers, and contractors complete required safeguarding training and maintain competency

• Liaising with HMPPS, YOTs, probation services, and local authority safeguarding teams as required

• Attending safeguarding meetings, child protection conferences, or multi-agency risk assessment conferences (MARACs/MALTs) where invited

• Leading the organisation's response to any serious safeguarding incident

• Reviewing and updating this policy annually or following any significant incident

• Maintaining their own DSL training and professional development
   

4.4 DSL Training

The DSL and Deputy DSL will complete:

• Designated Safeguarding Lead training (minimum Level 3 or equivalent) within 3 months of appointment and every 2 years thereafter

• Annual safeguarding updates and refresher learning

• Trauma-informed practice training — completed prior to service launch

• Safeguarding Level 1 and Level 2 — completed (both founders)
   

5. DEFINITIONS

Child: Any person under the age of 18 (Children Act 1989). Young people aged 16–17 are children in law regardless of their offending history or custodial status.
 

Adult at risk: A person aged 18 or over who has care and support needs, and is experiencing or at risk of abuse or neglect, and as a result of their care and support needs is unable to protect themselves (Care Act 2014). Many of the young adults we support will meet this definition.
 

Safeguarding: The action taken to promote the welfare of children and vulnerable adults and protect them from harm.
 

Child protection: Action taken to protect specific children who are suffering or likely to suffer significant harm.
 

Abuse: See Appendix C for full definitions. Categories include: physical abuse, emotional abuse, sexual abuse, neglect, exploitation (including criminal exploitation and county lines), domestic abuse, and modern slavery / trafficking.

Concern: Any information, observation, disclosure, or behaviour that causes a staff member to be worried about a young person's safety or welfare, even if it does not constitute a clear allegation of abuse.

 

6. RECOGNISING ABUSE AND HARM
 

6.1 Types of harm relevant to our work

Given the specific context of our work — supporting young people leaving custody — our team is trained to be alert to the following:
 

Criminal exploitation and county lines Young people leaving custody are a primary target for exploitation by criminal networks. Indicators include: being met at the gate by an unknown adult, being directed to an address not confirmed in the release plan, having a phone that is not their own, appearing controlled or fearful, being evasive about their plans.
 

Domestic abuse and harmful relationships Young people may be returning to abusive family environments or intimate relationships. A young person who is anxious about going home, who has injuries, or who does not want to be taken to their confirmed address may be at risk.

Modern slavery and trafficking Where a young person's release destination is unknown or suspicious, where third parties are controlling their movements, or where a young person discloses they have been made to work against their will.
 

Self-harm and suicide risk The immediate post-release period carries a significantly elevated risk of self-harm and suicide. Staff must be alert to: statements of hopelessness, disclosures of self-harm, requests for information about methods of harm, and significant distress or dissociation during the escort.
 

Substance misuse A young person who appears intoxicated, who requests to make a detour to obtain substances, or who discloses immediate plans to use substances may be at risk of harm.
 

Homelessness and unsafe accommodation Where a confirmed accommodation placement falls through or where a young person expresses that they cannot go to their confirmed address and has no alternative, this constitutes a safeguarding concern.
 

6.2 Behavioural and physical indicators

Staff should be alert to, and record, any of the following:

• Unexplained injuries or marks

• Significant distress, dissociation, or emotional dysregulation

• Disclosures — direct or indirect — of abuse, harm, or exploitation

• Fear or avoidance of a specific person, address, or location

• Signs of being controlled or monitored by a third party

• A young person who does not appear to have been expected or prepared for release
  
   

7. REPORTING AND RESPONSE PROCEDURES

7.1 If a young person makes a disclosure

If a young person discloses abuse, harm, or exploitation to a member of our team:
 

DO:

• Stay calm and continue to give the young person your attention

• Listen without interrupting

• Acknowledge what they are telling you ("Thank you for telling me. You've done the right thing.")

• Use open, non-leading questions only if clarification is needed ("Can you tell me more about that?")

• Explain clearly that you will need to share what they have told you to keep them safe

• Record exactly what was said, in the young person's own words, as soon as possible after the conversation

• Report to the DSL immediately — by phone call, not message
   

DO NOT:

• Promise confidentiality

• Conduct a formal interview or ask investigative questions

• Express shock, disbelief, or judgment

• Contact the alleged abuser

• Share the information with anyone other than the DSL (and statutory agencies if directed)

• Delay reporting because you are unsure
   

7.2 Step-by-step reporting procedure

Step 1 — Immediate safety If the young person is in immediate danger, call 999 first. Do not delay emergency response to complete internal reporting. Safety comes first.
 

Step 2 — Contact the DSL Contact the DSL by phone immediately. If the DSL is unavailable, contact the Deputy DSL. Do not leave a voicemail — keep calling until you reach a person.

Step 3 — Complete a Safeguarding Concern Report Complete the Safeguarding Concern Report Form (Appendix A) as soon as safely possible after the incident or disclosure. Record factual observations and direct quotes only — do not interpret or speculate. The form must be completed within 2 hours of the concern arising.
 

Step 4 — DSL assessment The DSL will assess the concern and determine whether:

• (a) The concern can be monitored and reviewed internally

• (b) A referral to statutory agencies is required

• (c) The matter requires immediate police involvement
   

Step 5 — Referral to statutory agencies (where required) For young people aged 16–17: referral to the relevant local authority children's social care team. For Feltham releases, this is typically the London Borough of Hounslow — 020 8583 3290. For young adults aged 18+: referral to the relevant local authority adult social care team where the person meets the adult at risk threshold. For criminal matters: referral to the Metropolitan Police Service via 101 (non-emergency) or 999 (emergency).

Referrals should be made by the DSL by telephone, followed by written confirmation within 24 hours.
 

Step 6 — Record and monitor All actions taken following a safeguarding concern must be recorded in the safeguarding log. The DSL will monitor the case and follow up with statutory agencies as required.

7.3 Timescales

Action
Call DSL following concern or disclosureImmediately
Complete Safeguarding Concern Report Form
DSL assessment and decision
Referral to statutory agencies (where needed)
​Written confirmation of referral
​Follow-up with statutory agency

Timescale

Immediately

Within 2 hours
Within 4 hours
Same day, within 24 hours max

Within 24 hours of telephone referral
​Within 5 working days if no response received

8. SAFE CONDUCT — STAFF AND VOLUNTEER STANDARDS

All staff, founders, and volunteers must adhere to the following standards at all times.

8.1 Physical safety during transport and escort

• A minimum of one team member must be present at every gate collection and escort

• Where a young person is aged 16–17, a same-gender escort should be provided wherever possible and practicable

• The young person must be informed of the route and destination before the journey begins

• The young person must not be transported to any destination other than the one confirmed in the release plan without the explicit agreement of the referring professional

• Mobile phones are permitted for young people during transport but staff must not allow calls or contacts that appear to be from criminal networks or that cause the young person distress

• Staff must never be alone in a vehicle with a young person aged 16–17 of a different gender without prior risk assessment and agreement from the DSL
   

8.2 Professional boundaries

• Staff must not give personal mobile numbers to young people — all contact must be through the organisation's registered contact details

• Staff must not accept gifts, loans, or payment of any kind from young people or their families

• Staff must not share personal information about themselves (home address, personal relationships, personal social media) with young people

• Staff must not contact young people outside of their professional role without the knowledge and agreement of the DSL

• Staff must not consume alcohol or any substance before or during any delivery activity
   

8.3 Social media and digital conduct

• Staff must not connect with young people on personal social media accounts

• Any digital contact with young people for legitimate operational purposes must take place through the organisation's registered communication channels only

• Staff must not post images or identifying information about young people on any platform
   

8.4 Physical contact

• Physical contact should be limited to what is appropriate, necessary, and consensual

• A guiding hand or supportive gesture may be appropriate — but must always be responsive to the young person's comfort

• Any physical contact that a young person appears uncomfortable with must cease immediately

• Any incident of physical contact that could be misinterpreted must be recorded and reported to the DSL
   

9. SAFER RECRUITMENT

Impact Transition Services CIC is committed to safer recruitment practices. All individuals working with young people on behalf of the organisation must:

• Hold a current Enhanced DBS check, registered on the DBS Update Service (mandatory — no exceptions)

• Provide a minimum of two references before beginning any contact with young people

• Complete safeguarding induction training before beginning delivery

• Declare any cautions, convictions, or investigations — including spent convictions where relevant to work with young people

• Declare any personal relationships with current or former service users

The DSL is responsible for maintaining a central record of all DBS checks, training certificates, and reference records.

10. INFORMATION SHARING AND CONFIDENTIALITY

We recognise that young people have a right to privacy and confidentiality. However, safeguarding concerns override this right.
 

Confidentiality cannot be promised where:

• A young person is at risk of significant harm

• A third party is at risk of harm

• A crime has been committed or is being planned

• A young person's welfare requires a statutory referral
   

When sharing information with partner agencies, we will:

• Share the minimum necessary information to protect the young person

• Inform the young person that information is being shared, where it is safe to do so

• Record all information sharing in the safeguarding log

• Comply with the principles of UK GDPR and the Data Protection Act 2018
   

All safeguarding records are stored securely, accessible only to the DSL and Deputy DSL, and retained for a minimum of 7 years (or until the young person reaches 25, whichever is later).

 

11. RECORDING AND DOCUMENTATION

All safeguarding concerns must be documented on a Safeguarding Concern Report Form (Appendix A) and stored in a secure, password-protected file.

Records must include:
 

• Date, time, and location of the concern or disclosure

• Name and date of birth of the young person

• Factual description of the concern — in the young person's own words where a disclosure was made

• Name of the staff member who received or identified the concern

• Actions taken and by whom

• Date and details of any referral made to statutory agencies

• Outcome (where known)
   

Records must never be stored alongside general case notes or in any unsecured location.

 

12. WORKING WITH PARTNER AGENCIES

Impact Transition Services CIC works alongside a range of statutory and voluntary sector organisations. In all partnerships, we commit to:

• Sharing safeguarding concerns promptly and without delay

• Participating in multi-agency safeguarding arrangements where invited

• Attending child protection conferences, strategy meetings, or adult safeguarding enquiries where our involvement is relevant

• Maintaining clear lines of communication with the referring caseworker, YOT officer, or probation worker for every case

• Notifying the referring professional immediately if a safeguarding concern arises during or after delivery
   

We will always follow the lead of the statutory agency in safeguarding matters — we are not the decision-making authority, but we are a responsible reporting organisation.
 

13. WHISTLEBLOWING

Any member of staff, volunteer, or contractor who has concerns about the conduct of a colleague — including the DSL — must report this promptly.

• Concerns about any team member other than the DSL: report to the DSL

• Concerns about the DSL: report directly to the Deputy DSL, or to the NSPCC Whistleblowing Helpline: 0800 028 0285

• Concerns about the organisation as a whole: report to the Charity Commission or Companies House

No individual will be penalised for raising a genuine safeguarding concern in good faith. Whistleblowing reports will be treated with confidentiality and responded to within 5 working days.

 

14. TRAINING REQUIREMENTS

Role
1. All staff and founders
2. All staff and founders
3. DSL and Deputy DSL
4. All staff and founders
5. All staff and founders


Minimum training required
1. Safeguarding Awareness (Level 1)
2. Safeguarding Level 2
3. Designated Safeguarding Lead (Level 3 equivalent)
4. Trauma-informed practice
5. Annual safeguarding update


Frequency

1. Every 2 years
2. Every 2 years
3. Every 2 years
4. Before service launch, then annually​
5. Every year

​

Training records are maintained by the DSL and held on file. No individual may carry out unsupervised contact with young people without current training certification.

 

15. POLICY REVIEW

This policy will be reviewed:

• Annually (next review: June 2027)

• Following any significant safeguarding incident

• Following changes in legislation or statutory guidance

• Following feedback from partner agencies or inspecting bodies
   

All updates will be approved by the Board of Directors and communicated to all staff and volunteers. Previous versions will be retained for audit purposes.


 

APPENDIX A — SAFEGUARDING CONCERN REPORT FORM

CONFIDENTIAL — DSL EYES ONLY

Field                                                                                            Detail

Date of report

Time concern arose

Location

Name of young person

Date of birth

Age

Name of staff member completing this form

Name of DSL notified

Time DSL notified
 

Description of concern (factual only — use the young person's exact words where a disclosure was made):

 

Any immediate action taken (e.g. 999 called, journey paused, destination changed):

DSL decision:

• [ ] Monitor internally — no referral at this time

• [ ] Referral to children's social care

• [ ] Referral to adult social care

• [ ] Referral to police

• [ ] Other (specify):
   

Details of referral made: Agency contacted: _______________ Contact name: _______________ Date and time: _______________ Reference number (if given): _______________

Signed (DSL): _______________ Date: _______________

APPENDIX B — KEY CONTACTS AND ESCALATION

Contact.                                                                   Detail

Emergency services                                               999

Police (non-emergency)                                       101

Hounslow Children's Social Care                      020 8583 3290

Hounslow Adult Social Care                               020 8583 3060

NSPCC Helpline (professionals)                        0808 800 5000

NSPCC Whistleblowing Helpline                      0800 028 0285

HMYOI Feltham — main number                      020 8844 5000

London Probation Service                                   0113 241 4000

DSL (Impact Transition Services)                      07930 447 587

Deputy DSL (Impact Transition Services.       07930 447 587

APPENDIX C — DEFINITIONS OF ABUSE

Physical abuse: Hitting, shaking, throwing, poisoning, burning, drowning, suffocating, or otherwise causing physical harm.

Emotional abuse: Persistent emotional ill-treatment causing severe and persistent adverse effects on emotional development. Includes: threats, humiliation, rejection, witnessing domestic abuse, and age-inappropriate expectations.

Sexual abuse: Forcing or enticing a child or young person to take part in sexual activities, whether or not the young person is aware. Includes non-contact activities such as producing or viewing sexual imagery.

Neglect: Persistent failure to meet basic physical and/or psychological needs, likely to result in serious impairment.

Criminal exploitation: When an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or adult, compelling them to commit criminal activity. Includes county lines drug trafficking and cuckooing.

Modern slavery and trafficking: Recruiting, transporting, or receiving a person through coercion for the purposes of exploitation, including forced labour, sexual exploitation, and criminal servitude.

Domestic abuse: Any incident or pattern of incidents of controlling, coercive, or threatening behaviour, violence, or abuse between those aged 16 or over who are or have been intimate partners or family members.

Self-harm and suicide: Any behaviour where an individual causes deliberate harm to themselves. In the context of this policy, staff must treat any disclosure of self-harm or suicidal ideation as a safeguarding concern requiring DSL review.

Document ends.

Impact Transition Services CIC — Safeguarding Policy v1.0 — June 2026 Review due: June 2027 Companies House: 17201212