OPAL Trust Limited     Safeguarding Policy (Non-Contractual)


Date of this version:          February 2020


Safeguarding Officer:       Iain Jamieson [Appointed February 2020]



This policy is non-contractual and as such can be changed at any time as required by regulations or best practice. 

1. Scope

This policy applies to anyone who represents OPAL Trust Limited including staff (part-time, full-time, paid or unpaid), volunteers, trustees, members and directors (collectively referred to as staff in this policy).

2. OPAL Trust Limited commitments

OPAL Trust Limited is committed to:

Ensuring that children and vulnerable adults are protected from all forms of harm and abuse, enabling them to live life with dignity, respect and security. All staff who work for or with OPAL Trust Limited must ensure that their behaviour promotes and encourages freedom from:

  • Harm and Abuse - Physical, sexual and emotional
  • Exploitation and abuse (physical, sexual and economic)
  • Neglect
  • Discrimination
  • Human Trafficking 

OPAL Trust Limited is committed to:

  • Valuing children and vulnerable adults
  • Listening and acting upon allegations and concerns relating to abuse and exploitation
  • Creating a culture of openness to enable issues and concerns about safeguarding to be raised and discussed
  • Forming a sense of accountability between staff so that potential poor or abusive behaviour can be challenged and prevented
  • Providing appropriate, on-going safeguarding training for staff and regularly reviewing the standards and guidelines in this policy
  • Appointing and supporting a Safeguarding Officer in any action they may need to take to protect children and vulnerable adults.

OPAL Trust Limited is committed to

  • A zero-tolerance policy approach to the abuse and exploitation of children and vulnerable adults.

 3. The purpose of this policy

This policy is designed to provide guidance on; the importance of safeguarding children and vulnerable adults, acceptable and unacceptable behaviour, staff responsibilities both in and outside the work environment and how to report.



4. Standards

OPAL Trust Limited is committed to ensuring that the wellbeing of children and vulnerable adults is given paramount consideration. This policy is based on principles encapsulated within:

  • UN Universal Declaration of Human Rights and the International Covenant of Human Rights
  • The UN Convention on the Rights of the Child, 1989, its Optional Protocols (on Worst Forms of Child Labour; Forced Recruitment), and other international child-rights and human-rights instruments
  • Safeguarding standards published by thityone:eight
  • National Society for the Prevention of Cruelty to Children (NSPCC)
  • The Scottish Government Guidance “National Guidance for Child Protection in Scotland 2014”
  • All relevant national laws of Scotland, OPAL Trust Limited being a registered charity within this jurisdiction, particularly the Children (Scotland) Act 1995, the Adult Support and Protection (Scotland) Act 2007 and the Protection of Vulnerable Groups (Scotland) Act 2007.

5. Definitions


A child is anyone under the age of 18

Vulnerable Adults:  

A vulnerable adult is anyone over the age of 18, who by reason of disability, age, illness or circumstance; may be unable to take care of or unable to protect themselves against significant harm or exploitation. Vulnerability cannot be defined by one factor such as age, health or location, but often occurs as a response to external changes. The vulnerability may last for a few days, months or be permanent. For example, bereavement, a change in financial situation, or physical or mental illness. A vulnerable adult may also include beneficiaries who because of extreme poverty or desperation are more susceptible to exploitation and abuse.


OPAL Trust Limited accepts the working definitions of abuse detailed within The Scottish Government Guidance “National Guidance for Child Protection in Scotland 2014”:

“Abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting, or by failing to act to prevent, significant harm to the child. Children may be abused in a family or in an institutional setting, by those known to them or, more rarely, by a stranger. Assessments will need to consider whether abuse has occurred or is likely to occur.”

Categories of abuse are defined as follows:

Physical Abuse

Physical abuse is the causing of physical harm to a child or young person. Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning or suffocating. Physical harm may also be caused when a parent or carer feigns the symptoms of, or deliberately causes, ill health to a child they are looking after.

Emotional Abuse

Emotional abuse is persistent emotional neglect or ill treatment that has severe and persistent adverse effects on a child's emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate or valued only insofar as they meet the needs of another person. It may involve the imposition of age- or developmentally-inappropriate expectations on a child. It may involve causing children to feel frightened or in danger, or exploiting or corrupting children. Some level of emotional abuse is present in all types of ill treatment of a child; it can also occur independently of other forms of abuse.

Sexual Abuse

Sexual abuse is any act that involves the child in any activity for the sexual gratification of another person, whether or not it is claimed that the child either consented or assented. Sexual abuse involves forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative or non-penetrative acts. They may include non-contact activities, such as involving children in looking at, or in the production of, pornographic material or in watching sexual activities, using sexual language towards a child or encouraging children to behave in sexually inappropriate ways.


Neglect is the persistent failure to meet a child's basic physical and/or psychological needs, likely to result in the serious impairment of the child's health or development. It may involve a parent or carer failing to provide adequate food, shelter and clothing, to protect a child from physical harm or danger, or to ensure access to appropriate medical care or treatment. It may also include neglect of, or failure to respond to, a child's basic emotional needs. Neglect may also result in the child being diagnosed as suffering from 'non-organic failure to thrive', where they have significantly failed to reach normal weight and growth or development milestones and where physical and genetic reasons have been medically eliminated. In its extreme form children can be at serious risk from the effects of malnutrition, lack of nurturing and stimulation. This can lead to serious long-term effects such as greater susceptibility to serious childhood.

6. Indicators of possible abuse 

Physical indicators:

  • Any injuries not consistent with the explanation given for them
  • Injuries which occur to the body in places which are not normally exposed to falls, rough games etc 
  • Injuries which have not received medical attention
  • Instances where children are kept away from the group inappropriately
  • Reluctance to change for, or participate in, games or swimming
  • Bruises, bites, burns, fractures, etc. which do not have an accidental explanation
  • Cutting/slashing/substance abuse

Sexual indicators:

  • Any allegations made by a child concerning sexual abuse
  • Child with excessive pre-occupation with sexual matters and detailed knowledge of adult sexual behaviour, or who regularly engages in age-inappropriate sexual play
  • Sexual activity through words, play or drawing 
  • Child who is sexually provocative or seductive with adults
  • Inappropriate bed-sharing arrangements at home
  • Severe sleep disturbances with fears, phobias, vivid dreams or nightmares, sometimes with overt or veiled sexual connotations
  • Child who is frightened of or avoids being alone with particular individuals

Emotional indicators:

  • Changes or regression in mood and behaviour, particularly where a child withdraws or becomes clinging
  • Depression/aggression
  • Nervousness/frozen watchfulness
  • Sudden under-achievement or lack of concentration
  • Inappropriate relationships with peers and /or adults
  • Attention-seeking behaviour
  • Persistent tiredness
  • Running away/stealing/lying

Neglect indicators:

  • Consistent hunger
  • Poor hygiene
  • Inappropriate dress
  • Consistent lack of supervision, especially in dangerous activities for long periods
  • Unattended physical problems or medical needs
  • Abandonment

7. Safeguarding awareness

OPAL Trust Limited is committed to appropriate safeguarding training for staff and all staff will receive a copy of the Safeguarding policy.

8. Reporting

Any allegation or concern regarding the abuse or exploitation of a child or vulnerable adult will be treated seriously and with urgency.  Reporting concerns regarding the abuse or exploitation of children or vulnerable adults is mandatory and can arise when abusive behaviour is observed or suspected; or when an allegation is made or disclosed or there are indicators (signs and symptoms) of suspected abuse on the victim.

OPAL Trust Limited will refer all incidents of concern, disclosures or allegations of abuse to the appropriate authorities. It is not the responsibility of OPAL Trust Limited to investigate them.

What to do if you suspect that abuse may have occurred: 

  • Report concerns as soon as possible to the OPAL Trust Limited Safeguarding Officer who will liaise with thirtyone:eight regarding process. 
  • Alternatively contact your local Social Services Department or, outside office hours, contact the local police (Child Protection Team).
  • You should not discuss your concerns with anyone other than those mentioned above.

The Safeguarding Officer will inform the CEO and will take advice and guidance from thirtyone:eight and refer the case to Social Services, or the Police as required.

9. Guidelines on acceptable and unacceptable behaviour

All OPAL Trust Limited staff are required to understand and abide by the rules of acceptable and unacceptable behaviour when working with children or vulnerable people. These rules are designed to protect children or vulnerable adults and to protect OPAL Trust Limited staff from false accusations. Staff should avoid actions or behaviour that could constitute poor practice or potentially abusive behaviour.

Acceptable Behaviour

Staff should:

  • Create a culture of openness and accountability allowing issues or concerns to be raised and discussed and where abusive behaviour can be challenged
  • Conduct a risk analysis when organising activities and programmes involving children or vulnerable people, with the view to plan for ways to reduce the risk of harm
  • To reduce the risks of working alone with a child or vulnerable person, apply the ‘two-adult’ rule or ensure that you and the child or vulnerable person is visible to others
  • Ensure physical contact is always appropriate and not an invasion of the child’s or vulnerable person’s privacy
  • Use positive, non-violent methods to manage the child’s or vulnerable person’s behaviour
  • Raise any concerns of inappropriate behaviour immediately with the Safeguarding Officer
  • If the concerns relate to the Safeguarding Officer then they should be raised with the Chairperson

 Unacceptable Behaviour

 Staff must not:

  • Develop a physical or sexual relationship with a child or vulnerable person
  • Behave physically in a way which is inappropriate or sexually provocative
  • Spend time alone with a child or vulnerable person, away from others, behind closed doors or in a secluded area
  • Take a child or vulnerable person to their home or visit a child or vulnerable person at their home, where they may be alone.
  • Allow a child or vulnerable person to stay overnight at their home unsupervised or sleep in the same room or bed as that child or vulnerable person
  • Do things of a personal nature for a child or vulnerable person
  • Engage in sexual activity with a child or vulnerable person regardless of the age of consent locally (the mistaken age of a child or vulnerable person is not a defence)
  • Be intoxicated as a result of alcohol or drug usage, prior to assuming responsibility for a child or vulnerable person
  • Hit or otherwise physically assault or abuse a child or vulnerable person
  • Use language, make suggestions or offer advice which is inappropriate, offensive or abusive.
  • Condone, or participate in behaviour with a child or a vulnerable person which is illegal, unsafe or abusive
  • Act in ways intended to shame, humiliate, belittle, degrade or perpetrate any form of emotional abuse
  • Show favouritism to a particular child or vulnerable person to the exclusion of others - for example, promising gifts, support and enticements
  • Exploit a child or vulnerable person for their labour or for sexual purposes
  • Take a child or vulnerable person alone in a vehicle unless it is absolutely necessary and with parental and managerial consent. 

10. Recruitment and Selection 

OPAL Trust Limited will take the following actions when recruiting and selecting staff:

  • Job descriptions will refer to responsibilities for Safeguarding and the Code of Conduct
  • During shortlisting all gaps, discrepancies or anomalies in CV’s will be scrutinised
  • Questions will be asked about safeguarding in the interview process
  • Checks regarding candidate’s identity, employment history and qualifications will be carried out before appointment
  • Professional and pastoral references will be obtained
  • In any situation where a member of staff is required to supervise, or being in sole charge of, children or vulnerable adults, Enhanced Disclosure and Barring (DBS) checks will be carried out in advance.
  • Self-declaration – Candidates will be asked to declare criminal convictions, written warnings, dismissal or resignations following allegations of improper or unprofessional conduct or unsatisfactory work performance.

11. Children visiting the premises of OPAL Trust Limited

When children visit the premises of OPAL Trust Limited, they remain the responsibility of parents.

12. Events

Where OPAL Trust Limited staff are asked to assist with events, they must ensure that they adhere to this policy and under no circumstance spend time alone with or touch children. Staff should not accept supervisory responsibility for children.



Telephone / Fax +44 (0) 1576 203670 -