Our Child Protection Policy Statement


104 films has a duty of care to safeguard all children involved in our projects All children have a right to protection, and the needs of disabled children and others who may be particularly vulnerable must be taken into account. 104 films will ensure the safety and protection of all children involved in our projects through adherence to the Child Protection guidelines adopted by 104 films. A child is defined as a person under the age of 18 (The Children Act 1989).


Policy aims


The aim of the 104 films Child Protection Policy is to promote good practice:

+  Providing children and young people with appropriate safety and protection whilst in the care of 104 films

+  Allow all staff/volunteers to make informed and confident responses to specific child protection issues.


Promoting good practice

Child abuse, particularly sexual abuse, can arouse strong emotions in those facing such a situation. It is important to understand these feelings and not allow them to interfere with your judgement about the appropriate action to take.


Abuse can occur within many situations including the home, school and the sporting environment. Some individuals will actively seek employment or voluntary work with young people in order to harm them. A coach, instructor, teacher, official or volunteer will have regular contact with young people and be an important link in identifying cases where they need protection. All suspicious cases of poor practice should be reported following the guidelines in this document.


Good practice guidelines


All personnel should be encouraged to demonstrate exemplary behaviour in order to protect themselves from false allegations. The following are common sense examples of how to create a positive culture and climate.


Good practice means:

+  Always working in an open environment avoiding private or unobserved situations and encouraging open communication.

+  Treating all young people/disabled adults equally with respect and dignity.

+  Always putting the welfare of each young person first.

+  Maintaining a safe and appropriate distance with young filmmakers (eg it

is not appropriate for staff or volunteers to have an intimate relationship with a child or to share a room with them).

+  Building balanced relationships based on mutual trust and empowering children to share in decision making.

+  Making filmmaking fun, enjoyable and promoting inclusion.

+  Keeping up to date with technical skills, qualifications and insurance.

+  Ensuring that at residential events, adults should not enter children’s rooms or invite children into their rooms.

+  Being an excellent role model – this includes not smoking or drinking alcohol in the company of young people.

+  Giving enthusiastic and constructive feedback rather than negative criticism.

+  Recognising the developmental needs and capacity of young people and disabled adults –not pushing them against their will.

+  Securing parental consent in writing to act in loco parentis, if the need arises to administer emergency first aid and/or other medical treatment.

+  Keeping a written record of any injury that occurs, along with the details of

any treatment given.


Practices to be avoided

The following should be avoided except in emergencies. If a case arises where these situations are unavoidable (eg the child sustains an injury and needs to go to hospital, or a parent fails to arrive to pick a child up at the end of a session), it should be with the full knowledge and consent of someone in charge in the club or the child’s parents.

2.01 Child Protection Guidelines

Otherwise, avoid:

+  Spending excessive amounts of time alone with children away from others.

+  Taking or dropping off a child to an event.


Practices never to be sanctioned


The following should never be sanctioned. You should never:

+  Engage in rough physical or sexually provocative games, including horseplay.

+  Share a room with a child.

+  Allow or engage in any form of inappropriate touching.

+  Allow children to use inappropriate language unchallenged.

+  Make sexually suggestive comments to a child, even in fun.

+  Reduce a child to tears as a form of control.

+  Allow allegations made by a child to go unchallenged, unrecorded or not acted upon.

+  Do things of a personal nature for children or disabled adults that they

can do for themselves.

+  Invite or allow children to stay with you at your home unsupervised.


NB It may sometimes be necessary for staff or volunteers to do things of a personal nature for children, particularly if they are young or are disabled. These tasks should only be carried out with the full understanding and consent of parents and the young people involved. There is a need to be responsive to a person’s reactions. If a person is fully dependent on you, talk with him/her about what you are doing and give choices where possible.


Incidents that must be reported/recorded


If any of the following occur you should report this immediately to another colleague and record the incident. You should also ensure the parents of the child are informed: 

+  if you accidentally hurt a young filmmaker

+  If he/she seems distressed in any manner

+  if a young person appears to be sexually aroused by your actions

+  if a young person misunderstands or misinterprets something you have



Use of photographic/filming equipment

There is evidence that some people have used filmmaking as an opportunity to take inappropriate photographs or film footage of young and disabled people in vulnerable positions. All filmmakers should be vigilant and any concerns should to be reported to the Child Protection Officer.


Recruitment and training of staff and volunteers

104 films recognises that anyone may have the potential to abuse children in some way and that all reasonable steps are taken to ensure unsuitable people are

prevented from working with children.


All applicants, staff and volunteers working with children will be DBS checked.


Pre-selection checks must included the following:

+  All volunteers/staff should complete an application form. The application form will elicit information about an applicant’s past and a self-disclosure about any criminal record.

+  Consent should be obtained from an applicant to seek information from the

Criminal Records Bureau.

+  Two confidential references, including one regarding previous work

with children. These references must be taken up and confirmed through

telephone contact.

+  Evidence of identity should be provided (eg passport or driving licence with photo).


Interview and induction


All employees (and volunteers) will be required to undergo an interview carried out to acceptable protocol and recommendations. All employees and volunteers should receive formal or informal induction, during which:

+  A check should be made that the application form has been completed

in full (including sections on criminal records and self-disclosures).

+  Their qualifications should be substantiated.

+  The job requirements and responsibilities should be clarified.

+  They should sign up to 104 films Code of Ethics and Conduct.

+  Child protection procedures are explained and training needs are identified.




In addition to pre-selection checks, the safeguarding process includes training after recruitment to help staff and volunteers to:

+  Analyse their own practice against established good practice, and to

ensure their practice is likely to protect them from false allegations.

+  Recognise their responsibilities and report any concerns about suspected

poor practice or possible abuse.

+  Respond to concerns expressed by a child or young person.

+  Work safely and effectively with children.


104 films requires:

+  Staff to attend a recognised 3-hour good practice and child protection

awareness training workshop, to ensure their practice is exemplary and

to facilitate the development of a positive culture towards good practice

and child protection.

+  Volunteers to complete a recognised awareness training on child


+  Relevant personnel to receive advisory information outlining good

practice and informing them about what to do if they have concerns

about the behaviour of an adult towards a young person.

+  Relevant personnel to undergo national first aid training (where



Responding to allegations or suspicions

It is not the responsibility of anyone working for 104 films’ in a paid or unpaid capacity, to decide whether or not child abuse has taken place. However, there is a responsibility to act on any concerns through contact with the appropriate authoritiy’s (LADO) – Local Designated Officer.


104 films will assure all staff/volunteers that it will fully support and protect anyone who in good faith reports his/her concern that a colleague is, or may be, abusing a child.


Where there is a complaint against a member of staff there may be three types of investigation:

+  a criminal investigation

+  a child protection investigation

+  a disciplinary or misconduct investigation.


The results of the police and child protection investigation may well influence the disciplinary investigation, but not necessarily.



  1. Concerns about poor practice:

+  If, following consideration, the allegation is clearly about poor practice, the Child Protection Officer will deal with it as a misconduct issue.

+  If the allegation is about poor practice by the Child Protection Officer, or if the matter has been handled inadequately and concerns remain, it should be reported to the relevant officer who will decide how to deal with the allegation and whether

or not to initiate disciplinary proceedings.


  1. Concerns about suspected abuse:

+  Any suspicion that a child has been abused by either a member of staff or

a volunteer should be reported to the Child Protection Officer, who will take

such steps as considered necessary to ensure the safety of the child in

question and any other child who may be at risk.  1 Child Protection Guidelines

+  The Child Protection Officer will refer the allegation to the social services

department which may involve the police, or go directly to the police if


+  The parents or carers of the child will be contacted as soon as possible

following advice from the social services department.

+  The Child Protection Officer should also notify the relevant 104 films officer who in turn will deal with any media enquiries.



Every effort should be made to ensure that confidentiality is maintained for all concerned. Information should be handled and disseminated on a need to know basis only.


This includes the following people:

+  the Child Protection Officer

+  the parents of the person who is alleged to have been abused

+  the person making the allegation

+  social services/police

+  the alleged abuser (and parents if the alleged abuser is a child).


Seek social services advice on who should approach the alleged abuser.


Information should be stored in a secure place with limited access to designated people, in line with data protection laws (eg that information is accurate, regularly updated, relevant and secure). 


Internal enquiries and suspension

+  The 104 films Child Protection Officer will make an immediate decision about whether any individual accused of abuse should be temporarily suspended pending

further police and social services inquiries.

+  Irrespective of the findings of the social services or police inquiries the

104 films Disciplinary Committee will assess all individual cases to decide

whether a member of staff or volunteer can be reinstated and how this can be sensitively handled. This may be a difficult decision, particularly where there is insufficient evidence to uphold any action by the police. In such cases, the 104 films Disciplinary Committee must reach a decision based upon the available information,

which could suggest that on a balance of probability, it is more likely than not that the allegation is true. The welfare of the child should remain of paramount importance throughout.


Support to deal with the aftermath of abuse 

+  Consideration should be given to the kind of support that children, parents and members of staff may need. Use of helplines, support groups and open meetings will maintain an open culture and help the healing process. The British Association for

Counselling Directory is available from The British Association for Counselling, 1 Regent Place, Rugby CV21 2PJ, Tel: 01788 550899, Fax: 01788 562189.www.bacp.co.uk

+  Consideration should be given to what kind of support may be appropriate for the alleged perpetrator.


Allegations of previous abuse

Allegations of abuse may be made some time after the event (eg by an adult who was abused as a child or by a member of staff who is still currently working with children).


Where such an allegation is made, 104 films should follow the procedures as detailed above and report the matter to the social services or the police. This is because other children, may be at risk from this person. Anyone who has a previous criminal conviction for offences related to abuse is automatically excluded from working with children. This is reinforced by the details of the Protection of Children Act 1999.

2.01 Child Protection Guidelines

Action if bullying is suspected

If bullying is suspected, the same procedure should be followed as set out in ‘Responding to suspicions or allegations’ above.


Action to help the victim and prevent bullying in sport: 

+  Take all signs of bullying very seriously.

+  Encourage all children to speak and share their concerns (It is believed

that up to 12 children per year commit suicide as a result of bullying, so if

anyone talks about or threatens suicide, seek professional help immediately). Help the victim to speak out and tell the person in charge or someone in authority.

+  Investigate all allegations and take action to ensure the victim is safe.

Speak with the victim and the bully(ies) separately.

+  Reassure the victim that you can be trusted and will help them, although

you cannot promise to tell no one else.

+  Keep records of what is said (what happened, by whom, when).

+  Report any concerns to the Child Protection Officer or the school

(wherever the bullying is occurring).


Action towards the bully(ies):  

+  Talk with the bully(ies), explain the situation, and try to get the bully(ies)

to understand the consequences of their behaviour. Seek an apology to

the victim(s).

+  Inform the bully(ies)’s parents.

+  Insist on the return of ‘borrowed’ items and that the bully(ies)

compensate the victim.

+  Provide support for the victim’s coach.

+  Impose sanctions as necessary.

+  Encourage and support the bully(ies) to change behaviour.

+  Hold meetings with the families to report on progress.

+  Inform all organisation members of action taken.

+  Keep a written record of action taken.


  1. Concerns outside the immediate sporting environment (eg a parent or carer):

+  Report your concerns to the Child Protection Officer, who should contact

social services or the police as soon as possible.

+  See 4. below for the information social services or the police will need.

+  If the Child Protection Officer is not available, the person being told of or discovering the abuse should contact social services or the police


+  Social services and the Child Protection Officer will decide how to

involve the parents/carers.

+  Maintain confidentiality on a need to know basis only.

+  See 4. below regarding information

needed for social services.


  1. Information for social services or the police about suspected abuse:

To ensure that this information is as helpful as possible, a detailed record should always be made at

the time of the disclosure/concern, which should include the following:

+  The child’s name, age and date of birth of the child.

+  The child’s home address and telephone number.

+  Whether or not the person making the report is expressing their own

concerns or those of someone else.

+  The nature of the allegation. Include dates, times, any special factors and

other relevant information.

+  Make a clear distinction between what is fact, opinion or hearsay.

+  A description of any visible bruising or other injuries. Also any indirect

signs, such as behavioural changes.

+  Details of witnesses to the incidents.

+  The child’s account, if it can be given, of what has happened and how

any bruising or other injuries occurred.

+  Have the parents been contacted?

+  If so, what has been said?

+  Has anyone else been consulted? If so, record details.

+  If the child was not the person who reported the incident, has the child

been spoken to? If so, what was said?

+  Has anyone been alleged to be the abuser? Record details.

+  Where possible referral to the police or social services should be confirmed in writing within 24 hours and the name of the contact who took the referral should be recorded. If you are worried about sharing concerns about abuse with a senior colleague, you can contact social services or the police direct, or the NSPCC Child Protection Helpline on 0808 800 5000, or Childline on 0800 1111.


Safeguarding and promoting the welfare of children is defined as:

+  Protecting children from maltreatment;

+  Preventing impairment of children’s health or development;

+  Ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and

+  taking action to enable all children to have the best outcomes.


Child Protection is a part of safeguarding and promoting welfare. It refers to the activity that is undertaken to protect specific children who are suffering, or are likely to suffer, significant harm.


Staff refers to all those working for or on behalf of the organisation, full or part time, temporary or permanent, in either a paid or voluntary capacity.