Safeguarding Policy

Statement of Purpose

1. DiveInclusive(the Organization, we, our or us) is committed to preventing and responding to risks of harm to and promoting the welfare of all children that we work with (i.e. as DiveInclusive’s clients). These individuals are referred to as the ‘Beneficiaries’ of this Safeguarding Policy.
2. We recognise the importance of this commitment to safety and welfare and, further, are committed to safeguarding all Beneficiaries without discrimination due to an individual’s age, disability, race, religion or belief, sex, gender reassignment, pregnancy or maternity leave status, marriage or civil partnership status, or sexual orientation.
3. This Safeguarding Policy is based on the safeguarding laws of England, Wales, and Scotland, including related guidance issued by the UK Government and relevant governmental departments, agencies, and public bodies. If this Policy is at any time inconsistent with this body of law, DiveInclusivewill act to meet the requirements of up-to-date safeguarding laws in priority to the requirements set out in this Policy.
4. DiveInclusive has a specific focus on protecting children and vulnerable individuals within the scuba diving environment, and the safeguarding principles outlined n this policy are based on those issued by governing bodies like PADI, alongside UK safeguarding law.
5. DiveInclusive has implemented this Safeguarding Policy in order to meet its obligations as an organisation working with children. This includes a commitment to adhere to any regulatory guidance provided by the Charity Commission and PADI.
6. Any questions in relation to this Policy should be referred to Designated Safeguarding Lead (DSL) in the first instance, by emailing admin@diveinclusive.com.

Scope of this Safeguarding Policy

7. This Policy explains key aspects of how DiveInclusiveprevents harm in relation to its Beneficiaries via its practices and its Staff Members’ conduct.

8. This Safeguarding Policy covers the organization and operation of all DiveInclusive’s activities involvingchildren (i.e. our Relevant Activities). These primarily include:

a. Scuba Diving Training

9. This Policy’s guidelines and obligations apply to all individuals working for or acting on behalf of DiveInclusivein the UK at all levels, including senior managers, officers, employees, consultants, trainees, homeworkers, part-time and fixed-term workers, casual workers, agency workers, volunteers, and interns (collectively ‘Staff Members’).

10. This Policy does not form part of any contract of employment or similar and DiveInclusivemay amend it at any time at our absolute discretion.

Defining Safeguarding

11. ‘Safeguarding’ is an umbrella term that refers to work (e.g. practices and procedures) aimed at preventing or responding to harm or risks of harm posed to vulnerable individuals, and at promoting these individuals’ wider welfare. Safeguarding is particularly important for children and adults at risk. Most safeguarding legal obligations relate to the care of these groups.This Safeguarding Policy specifically deals with safeguarding children. For safeguarding purposes, children are individuals younger than 18 years old.

12. The commitments and practices contained in this Safeguarding Policy apply to the safeguarding of DiveInclusive’s Beneficiaries from harm caused by either:

• The activities and practices of DiveInclusiveand any conduct of its Staff Members, or
• People and situations outside of DiveInclusive’s and its Staff Members’ control, where DiveInclusive’s Staff Members are aware of, ought to be aware of, or reasonably suspect the risks posed by a situation.

For the purposes of this Policy, a ‘Safeguarding Concern’ is any conduct or situation that is known or reasonably suspected by a Staff Member or another party that risks violating the safeguarding commitments set out above.

Key Measures that DiveInclusive is Committed to Implementing and Maintaining to Safeguard its Beneficiaries

DiveInclusive ensures that all diving activities under its programs are carried out in line with safeguarding policies outlined by PADI and local safeguarding arrangements in the UK, including the following:

13. Following the PADI Youth Risk Management Guidelines and complying with relevant UK safeguarding frameworks to ensure that child protection laws are upheld in all activities, with an emphasis on health and safety standards during scuba diving training.
14. Ensuring that Staff Members are trained to, and encouraged to, report any Safeguarding Concerns that they identify. Staff Members will be encouraged to follow DiveInclusive’s safeguarding reporting procedures as closely as possible when reporting concerns (set out below under the heading ‘Procedures: Reporting’).
15. Ensuring that all Staff Members listen to all safeguarding-related queries and concerns raised by other Staff Members, Beneficiaries, or relevant other parties, with respect and professionalism. Staff Members should be trained how to, and encouraged to, then assist with reporting any such concerns via DiveInclusive’s regular reporting procedures.
16. Ensuring that all reported Safeguarding Concerns are dealt with by appropriate individuals and teams and in accordance with DiveInclusive’s relevant procedures (set out below under the heading ‘Procedures: Investigation and Response’).
17. Implementing and maintaining comprehensive, accessible, fair, and efficient procedures for Staff Members to use when reporting and dealing with Safeguarding Concerns. These procedures will be made known and easily accessible to all Staff Members.
    1. Procedures will be designed to ensure all safeguarding issues are dealt with fairly and objectively even when allegations are made against one of DiveInclusive’s Staff Members. Any such allegations will be treated in a manner that takes into account the gravity of the accusations, but which does not vilify or presume the guilt of an accused individual without a fair investigation.
    2. Any reports that qualify as protected disclosures under whistleblowing law will be treated securely and in a protected manner in line with whistleblowing law.
18. Appointing Designated Safeguarding Lead to hold responsibility for managing safeguarding policies and procedures within DiveInclusive.
19. Following appropriate recruitment processes when recruiting new Staff Members, including volunteers. This includes:
    1. Conducting all appropriate pre-employment checks (e.g. Disclosure and Barring Service (DBS) criminal record checks).
    2. Ensuring new Staff Members take part in, and understand the content of, all necessary safeguarding training before having any contact with DiveInclusive’s Beneficiaries.
    3. Following DiveInclusive’s policies and procedures on hiring and recruitment.
20. Providing appropriate safeguarding training for all relevant Staff Members. Every Staff Member should be provided with, and required to undertake, training that is appropriate to their role, responsibilities, and degree and type of contact with Beneficiaries. This should, where appropriate, include training on:
    1. How to define and identify potential signs of different types of abuse, including physical abuse, emotional abuse, sexual abuse and exploitation, neglect, and others.
    2. How to listen to and respond to concerns or disclosures about safeguarding issues during an initial conversation (e.g. how to explain when information can and cannot be kept confidential).
    3. How to use DiveInclusive’s safeguarding reporting procedures and when doing so is appropriate.
    4. Which additional resources (e.g. policies, other supporting documents, or external educational resources) are available to ensure Staff Members remain informed about safeguarding.
21. Ensuring that all information related to Safeguarding Concerns, including the content of reported concerns as well as the personal data of anybody involved, is handled safely and securely. This involves:
    13.  Following the requirements set out by the UK’s data protection laws, including The UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
    14. Following DiveInclusive’s data protection policies and procedures, including our Data Protection and Data Security Policy.
    15. Providing Staff Members with training on data protection and privacy, where appropriate.
    16. Ensuring Staff Members always have an identifiable point of contact for questions or concerns about data protection and privacy. This is currently Data Protection Officer, who can be contacted by emailing enquiries@diveinclusive.com.
    17. Only sharing information about a Safeguarding Concern internally as far as is necessary to manage the concern for the relevant Beneficiary’s benefit.
22. Ensuring transparency and awareness regarding safeguarding information and procedures. For example, by:
    1. Providing information to Beneficiaries about our safeguarding procedures so that they are aware of how to raise any concerns.
    2. Ensuring all Staff Members are aware of safeguarding laws, DiveInclusive’s safeguarding commitments and procedures, and Staff Members’ responsibilities in relation to these.
23. Regularly reviewing all safeguarding policies and procedures to ensure that they are up-to-date with safeguarding law and that they remain suitable for DiveInclusive’s Relevant Activities and workforce, and meeting any review and evaluation requirements specific to DiveInclusive’s industry and organisation type.

Staff Members’ Responsibilities 

Staff Members working with DiveInclusive, including volunteers and coaches from partner diving schools, are required to meet the highest safeguarding standards as outlined by UK safeguarding laws and PADI guidelines. Each staff member must do the following:

24. All Staff Members have a responsibility to promote the safety and wellbeing of all of DiveInclusive’s Beneficiaries. This means that all of DiveInclusive’s policies and procedures relevant to safeguarding and all UK laws relevant to safeguarding must be followed at all times.
25. All Staff Members must contribute to upholding the key measures that DiveInclusive has committed to taking to safeguard its Beneficiaries (set out above) to an extent that is appropriate for their role, responsibilities, and degree and type of contact with Beneficiaries. Specific ways that Staff Members should do this will be clarified during training. If a Staff Member is uncertain as to their responsibilities, it is their responsibility to raise this with Designated Safeguarding Lead.
26. Have undergone the required PADI certifications and relevant safeguarding training specific to the risks and safety concerns of scuba diving for minors. Staff members must also comply with DiveInclusive’s DBS checks and other pre-employment screening processes that are in place to protect vulnerable individuals.
27. Staff Members must never do anything to actively risk the safety or wellbeing of any of DiveInclusive’s Beneficiaries. This includes, but is not limited to:
    1. Subjecting them to or facilitating abuse of any sort.
    2. Engaging in any sexual activity with children (i.e. anybody under the age of 18).
    3. Participating in or facilitating any activities that may commercially exploit Beneficiaries. For example, failing to report suspected child labour or trafficking.
28. Staff Members must report all Safeguarding Concerns that they have regarding Beneficiaries, regardless of whether the concerns relate to potential wrongdoing of other Staff Members, other Beneficiaries, or external parties (e.g. parents, teachers, other organisations, or members of the public).

Procedures: Reporting

29. Staff Members will receive safeguarding training that should enable them to identify Safeguarding Concerns (e.g. suspected abuse, neglect, or threats to wellbeing) relevant to DiveInclusive’s Beneficiaries.
30. If a Staff Member identifies a Safeguarding Concern, to report it they should:
    1. Recognize and Identify Concerns – Be vigilant and aware of any signs of abuse or neglect. Concerns may arise from direct observation, disclosure by a child, or from third-party information.
    2. Record the Concern – Document the concern as soon as possible using the official safeguarding reporting form. Include details such as dates, times, the nature of the concern, and any direct quotes or behaviors observed. Ensure that the record is factual, objective, and clear. Avoid assumptions or interpretations.
    3. Report the Concern Immediately – Contact the Designated Safeguarding Lead (DSL) or Deputy DSL at DiveInclusive as soon as the concern is identified. If the DSL is unavailable, report to the next senior person in the organization. If the concern is urgent and involves immediate danger to a child, contact emergency services or local safeguarding authorities immediately, and inform the DSL as soon as possible afterward.
    4. Confidentiality – Maintain confidentiality and do not discuss the concern with anyone other than the DSL, safeguarding team, or relevant authorities. Only share information on a need-to-know basis.
    5. Follow-Up – The DSL will assess the concern and decide on the next steps, including whether to refer the case to external safeguarding authorities or to monitor the situation internally. The staff member reporting the concern should be kept informed of the action taken, where appropriate, and may be required to provide further information or support.
    6. Support for the Child – Ensure that the child involved is provided with appropriate support during and after the reporting process. This may include emotional support, ensuring their safety, and offering reassurance.
    7. Feedback and Review – The DSL should provide feedback to the staff member on the outcome of the concern raised, where appropriate, and review the incident to identify any areas for improvement in the safeguarding process.
    8. Record Keeping – All safeguarding concerns, reports, and outcomes must be securely stored in accordance with data protection laws and organizational policies. This ensures the integrity and confidentiality of the information.
31. If a Staff Member feels unable to follow the above steps, they should report their Safeguarding Concern in a reasonable alternative manner. This may the case if, for example:
    1. Following the above procedure would require disclosing the concern to somebody who is implicated in the Safeguarding Concern or who the Staff Member is otherwise uncomfortable contacting about this concern, or
    2. The matter is time sensitive and involves a risk of serious harm to somebody, in which case contacting an external agency (e.g. the police, the ambulance service, or a mental health crisis line) or a more senior member of DiveInclusive’s staff first may be more appropriate.

Procedures: Investigation and Response

32. Reported Safeguarding Concerns will be dealt with promptly according to the following process:
    1. Initial Receipt of Concern – The Designated Safeguarding Lead (DSL) or Deputy DSL receives the reported concern from a staff member. The report should be documented in writing, using the organization’s safeguarding reporting form.
    2. Immediate Risk Assessment – Upon receiving the report, the DSL conducts an initial risk assessment to determine if the child is in immediate danger. If so, the DSL must take urgent action by contacting the local authorities or emergency services.
    3. Confidentiality and Information Sharing – The DSL ensures that all details of the concern are handled with strict confidentiality. Information is shared only with relevant parties, such as safeguarding authorities, the organization’s safeguarding team, or senior management, on a need-to-know basis.
    4. Internal Investigation – If the concern does not require immediate external intervention, the DSL may carry out an internal investigation. This involves gathering more information, interviewing relevant parties (with due care for the child’s well-being), and documenting findings.
    5. Decision Making – Based on the investigation, the DSL, in consultation with the safeguarding team or senior management, decides the appropriate course of action. This could involve monitoring the situation, referring the case to external safeguarding authorities, or taking internal disciplinary action.
    6. Referral to External Authorities – If the concern meets the threshold for external intervention, the DSL refers the case to the local safeguarding board, children’s services, or the police. The organization must cooperate fully with any external investigations.
    7. Follow-Up and Support – The organization ensures that the child involved receives appropriate support, including counseling or other interventions as necessary. The DSL also ensures that the staff member who reported the concern is kept informed of the outcome, where appropriate.
    8. Record Keeping – All reports, assessments, actions taken, and outcomes are meticulously recorded and securely stored. These records must be kept in accordance with data protection laws and organizational policies to maintain confidentiality and compliance.
    9. Review and Continuous Improvement – After a concern is handled, the safeguarding team reviews the process to identify any areas for improvement in the organization’s safeguarding procedures. This may involve updating policies, providing additional training, or improving reporting mechanisms.
    10. Training and Awareness – Regular training sessions are conducted to ensure that all staff members are familiar with the safeguarding procedures and know how to report concerns. The organization also promotes awareness of safeguarding issues within its programs and to the children it supports.
33. Staff Members who report a Safeguarding Concern will be kept informed about the progression of the matter they reported to an appropriate degree. Note that, depending on the nature of the concern and consequent investigations, some information about matters may be kept confidential and not shared with the reporter.
34. If a Staff Member is found to be in breach of this Safeguarding Policy or safeguarding law in general, they will be treated fairly andwill only be dismissed if appropriate in the circumstances and in accordance with employment law.
35. Referrals or notifications to external organisations (e.g. police services, local authorities, or regulatory bodies) will be made when, and only when, this is appropriate, and will always be made in accordance with the law (e.g. data protection law).

Supporting Documents and Other Protections

36. DiveInclusivehas various other documents in place that support this Safeguarding Policy. These include:
    1. Detailed safeguarding investigation and response procedures.
    2. Safeguarding training materials for ongoing learning and reference.
37. This Safeguarding Policy does not cover all of DiveInclusive’s commitments relevant to protecting its Beneficiaries. We also have other policies in place that protect our Beneficiaries, Staff Members, and/or others. These include:
    1. A Data Protection and Data Security Policy.
38. All of the policies, procedures, and other documents set out above are available on request from the person within the Organisation responsible for HR matters or via Staff Members’ line managers.