Safeguarding Policy for Grant Holders

• “You” and “your” means the organisation or individual that is in receipt of, or applying for, a grant from Arts Council England that is bound by our terms and conditions of funding.  

• “We”, “us” and “our” means Arts Council England, or “the Arts Council”, and includes our employees and those acting for us. 

• “Abuse” can be physical, sexual, psychological or emotional harm, neglect, maltreatment, radicalisation or exploitation. Abuse may consist of a single or repeated act, affecting one or more people. It can take place in person or online, and can be carried out by any person or organisation. 

• An “Adult at risk of abuse” is defined by the Care Act (2014) as someone who is aged 18 and over and is experiencing or at risk of abuse and has needs for care and support which means that they are unable to protect themselves against the abuse or neglect or the risk of it.  

• “Children and young people at risk of abuse” refers to any person who has not yet reached the age of 18 and that may be vulnerable to abuse. This may be because of their age, mental health, disability, illness, gender, race, religion or belief, sexual orientation, economic status or because they are unable to take care of themselves. 

• The “Funding Agreement” includes and incorporates any requirements as set out in relevant Programme Guidance / Guidance for Applicants and our terms and conditions of funding, including any payment or additional conditions that you have accepted. 

• A “Grant holder” is any organisation or individual that holds a funding agreement with Arts Council England and is bound by our terms and conditions of funding. 

• “Safeguarding” is the action that is taken to promote the welfare of children, young people and adults at risk of abuse and to protect them from harm 

Our terms and conditions make it clear that, by signing a funding agreement with the Arts Council, grant holders agree to fulfil the requirements set out in this policy. By this, we mean: 

• Having their own tailored policy for safeguarding and protecting children, young people and adults at risk, which is proportionate and relevant to their organisation’s activities and has been agreed by their trustees or other governing body  

• Ensuring that all organisations and third parties appointed by the grant holder to carry out any part of the agreed activity that involves working with children, young people and adults at risk have their own, appropriate safeguarding and protection policies and procedures in place, and that these adhere to the requirements set out in this policy 

• Advising Arts Council England where there are potentially serious concerns or disclosures about the safeguarding or protection of any child, young person or adult at risk of abuse 

Safeguarding policies and procedures must be reviewed regularly, with appropriate and regular training offered to employees, volunteers, trustees, partners or contractors who will supervise, care for, or otherwise have significant direct contact with children, young people and adults at risk. 

Appropriate and effective safeguarding policies and procedures should, as a minimum (though not an exhaustive list): 

• Outline the organisation’s commitment to:  
• safeguarding and protecting children, young people and adults at risk; and  
• developing a safeguarding culture 

• Provide a named Safeguarding Lead, who has the knowledge and skills to promote safe environments for children, young people and adults at risk, and who can respond to concerns and disclosures. If you are an individual grant holder or applicant, this will be you 

• Clearly define the roles and responsibilities of all staff, volunteers, trustees, partners or contractors who will supervise, care for, or otherwise have significant direct contact with children, young people and adults at risk in respect of safeguarding and child protection 

• Demonstrate that there are safe recruitment procedures in place, including regular background checks for all staff, volunteers, trustees, partners or contractors who will supervise, care for, or otherwise have significant direct contact with children, young people and adults at risk (for example, checks with the Disclosure and Barring Service) 

• Ensure appropriate and regular training is offered to all employees, volunteers, trustees, partners or contractors who will supervise, care for, or otherwise have significant direct contact with children and adults at risk 

• Demonstrate how robust risk assessment processes are carried out, with appropriate guidance to help ensure a safe and inclusive environment is made available to children, young people and adults at risk 

• Explain the procedures that will be taken in the event of a concern being raised, or incident taking place, including reporting mechanisms and appropriate escalation measures to external agencies, where applicable (for example, children’s services, police, Prevent agencies or specialist support and advisory services) 

• Demonstrate and evidence clear connectivity (and links) to other appropriate organisational policies and procedures – for example, Code of Conduct, health and safety, raising a concern/complaint, HR and whistleblowing policies – with steps outlining what happens if someone does not uphold or adhere to these relevant policies or procedures 

• Outline how often the safeguarding policy and procedures will be reviewed and kept up to date 

Your safeguarding policy and procedures should be publicly available and promoted to the beneficiaries of your work. This includes any children and adults at risk that experience your work, including their parents and/or carers, as appropriate.  

There should opportunities to give constructive feedback on your policies and procedures, with clear processes on how to report any concerns or incidents to staff. 

Grant holders are expected to take a proactive, common-sense approach to prevent the risk of harm to children or adults at risk of abuse. In doing so, we expect grant holders to be considerate of how children and adults at risk of abuse experience their projects and activities – for example, as participants, audience members, visitors or volunteers – recognising the need to tailor safeguarding policies and procedures proportionately. 

In addition, organisations and individuals may have other safeguarding expectations or considerations, dependent on:  

• the type of organisation they are  
• who their participants and beneficiaries are 
• the content and location of their work 
• the method of delivery (e.g. online) 
• the roles and responsibilities of staff, volunteers and/or partners 

We have provided further information about these expectations and considerations, including links to further support and guidance, in an accompanying information sheet on our website. 

When you apply to become a grant holder, we will ask you to confirm that you will have safeguarding policies and procedures in place that are appropriate and proportionate to the way in which children, young people and adults at risk will experience your work, if your application for funding is successful. 

If you become a grant recipient of the Arts Council, our terms and conditions of funding will set out our expectations in relation to this policy for grant holders. This may include additional conditions that relate to safeguarding children, young people and adults at risk of abuse.  

From time to time, safeguarding incidents may occur. All incidents you identify should be reported, logged, managed and, if applicable, escalated to appropriate agencies for further action or support.  

In line with the Arts Council’s terms and conditions for grant holders, you should report any serious or significant concerns or incidents (including those that are potentially serious or significant) to us in line with the terms and conditions of funding.  

We will then consider whether any incident may have breached our terms and conditions. In order to do this, we may ask you to provide copies of policies and procedures for review. When we have fully considered the situation, along with any policies and procedures requested, we will let you know what, if any, action would be taken. 

Any organisation or individual that has been appointed to supervise, care for, or otherwise have significant direct contact with children, young people or adults at risk should, as a minimum, be meeting the standards outlined for out-of-school settings by the Department for Education – ‘Keeping children safe in out-of-school settings: code of practice’. 

You should also ensure that other relevant statutory guidance is being followed and/or complied with, for example as listed below (but not limited to): 

• Safeguarding for charities and trustees – Organisations that are registered charities must also follow guidance from the Charity Commission  
• Working together to safeguard children (2023)  – statutory guidance on inter-agency working to safeguard and promote the welfare of children 
• Keeping children safe in education (2023)  – statutory guidance for schools and colleges on safeguarding children and safer recruitment 
• The Care Act (2014) – sets out the legal framework for safeguarding adults  

This Policy was first published in April 2024 and will be reviewed after 12 months, or in line with any changes to relevant statutory guidance.  

 The National Society for the Prevention of Cruelty to Children (NSPCC) website has an extensive resource library to assist in the development and implementation of good practice safeguarding policies and procedures. 

You can find information about the Arts Council’s safeguarding processes and procedures, including further information and advice for grant holders and applicants, on our website.