This section contains;
Safeguarding Policy Statement
Photography and Mobile Phone Policy
Anti-Bullying Policy Statement
Last updated
July 2022
Safeguarding Policy Statement
Tonbridge Sea Turtles is committed to providing an environment in which all children and vulnerable adults participating in its activities have a safe and positive experience.
In order to achieve this Tonbridge Sea Turtles agrees to:
- Adopt and implement Wavepower and the Swim England Child and Vulnerable Adult Safeguarding Policies and Procedures in full.
- Recognise that all children and vulnerable adults participating in activities regardless of their age, gender, race, faith, sexual orientation and ability have the right to enjoy their involvement in our sports in a safe environment and be protected from harm.
- Ensure that all individuals who work or volunteer with children and vulnerable adults in our organisation provide a positive, safe and enjoyable experience for all.
- Appoint a Welfare Officer with the necessary skills and training as outlined in Wavepower who will take the lead in dealing with all child and vulnerable adult safeguarding matters raised within the organisation.
- Ensure that the Welfare Officers’ name and contact details are known to all staff, members and parents/guardians of members that are under 18 and to any carer/parent/guardian of a vulnerable adult.
- Ensure that all individuals who work with children and vulnerable adults in the organisation have undertaken the appropriate training, have had the relevant DBS checks and adhere to Wavepower and the Regulations of our sports.
- Ensure that all individuals who will be working or will work with children and vulnerable adults in either a paid or voluntary role have been recruited in accordance with the Safe Recruitment Policy contained in Wavepower.
- Ensure that all individuals who work with children and vulnerable adults in the organisation have received the appropriate training for their role and been provided, understand and adhere to the requirements of the Codes of Conduct and Wavepower.
- Provide all members of the organisation and parents/guardians of members under 18 and parents/guardians/carers of vulnerable adults, with the opportunity to raise concerns in relation to a swimmer’s welfare in a safe and confidential manner.
- Ensure that all child and vulnerable adult safeguarding matters, whether they be concerns about welfare or protection, are dealt with appropriately in accordance with the guidance for reporting and action in Wavepower.
- Ensure that confidentiality is always maintained and in line with the best interests of the child or vulnerable adult.
- Ensure all information relating to child and vulnerable adult safeguarding matters are held safely and securely.
Photography and Mobile Phone Policy
Tonbridge Sea Turtles operate in compliance with the Wavepower Photography Guidance
This guidance applies to all images and videos, which are not suspected of falling under the guidance on indecent/child abuse images of children, taken on any type of camera or recording device (including mobile/smart phones).
It should be acknowledged that although the majority of images taken are appropriate and in good faith, images can be misused and children can be put at risk if common sense procedures are not observed.
Aims
This guidance aims to help organisations avoid three often unintended and unforeseen potential sources of child abuse:
• The use, adaptation, sharing or copying of images for child abuse purposes, either electronically or in print.
• The possible identification of a child when an image is accompanied by significant personal information, which can lead to the child being “groomed”.
• The identification and locating of children where there are safeguarding concerns; such cases would include, for example, children who could be compromised by an image because:
1 They have been removed from their family for their own safety.
2 There are restrictions on their contact with one parent/guardian following a parental separation.
3 They are a witness in criminal proceedings.
Recommended best practice
The publishing of a photograph of a member under 18, either on a noticeboard or in a published article or video recording (including video streaming) of a competition (“publication”) should only be done with parental consent and in line with Swim England guidelines.
A parent or guardian has a right to refuse to have their child photographed.
The exercise of this right of refusal should not be used as grounds for refusing entry into a competition.
Therefore, any photo that may go to press or on a noticeboard, be it through a member of the organisation or an official photographer, should receive parental consent before being published or displayed, preferably in writing.
A suggested template allowing parents/ guardians to indicate refusal of consent is provided online.
In the case of any event or competition where the host organisation has an official photographer, or for example intends to stream the event or competition online, all parents/guardians or members who are attending should be made aware of this in the event details.
If photos are to be published anywhere, each individual parent/guardian should be given the opportunity to withhold their consent. Their right to do so should be specifically drawn to their attention.
Swim England guidelines state that all photographs for publication must observe generally accepted standards of decency, particularly:
• Action shots should be a celebration of the sporting activity and not a sexualised image in a sporting context.
• Action shots should not be taken or retained where the photograph reveals a torn or displaced swimming costume.
• Poolside shots of children should be above the waist only in a swimming costume. Full length shots are permitted if the children are fully clothed.
• Photographs should not be taken from behind the starting blocks or that show children climbing in and out of the pool. Published photographs may identify the individual by name and organisation but should not state the member’s place of residence or school attended.
Swim England does not wish to stop parents/guardians photographing their child if they wish, but all organisations must ensure they do all they can to safeguard every child’s wellbeing, helping parents/ guardians understand why they should refrain from including other individual children in such shots.
The official photographer In some cases, the organisation will ask a member or officer to act as an official photographer for an event and in some cases they may employ a specialist photographer. Their role is to take appropriate photos that celebrate and promote one of our sports. When taking any image, they should be asked to:
• Focus on the activity rather than the individual child.
• Include groups of children rather than individuals, if possible.
• Ensure all those featured are appropriately dressed.
• Represent the broad range of children participating in one of our sports.
• Organisations should screen applicants for their suitability (just as they would check any other member of staff or volunteer working with children) and then provide training and information on the organisation’s child safeguarding policies and procedures.
• The official photographer (whether a professional photographer or a member of staff) should receive clear instructions, preferably in writing, from the organisation at an early stage.
• The organisation should provide them with a copy of this guidance and a clear brief about what is appropriate in terms of content.
• Images should not be allowed to be taken outside the activity being covered.
• The organisation should determine who will hold the images recorded and what is to be done with them after they have served their purpose.
Guidance on filming children during training sessions
Filming during training sessions is not recommended unless there is a legitimate need or purpose for the filming. For example wishing to film children to assist in their stroke technique.
If there is a legitimate need or purpose parents/guardians must be provided with full information such as when the filming is proposed, its purpose, who is filming, how the film will be used or published and an agreement on what will happen once the film has served its purpose. This allows parents/ guardians to provide informed consent or otherwise.
Written consent to the filming should be requested from the parents/ guardians.
Invite parents/guardians to be present at the filming; if this is impractical allow them to view the film before publication.
Mobile/smart phones
Members must be made aware that while Swim England does not support the banning of phones, as children may need them to keep in touch with parents/guardians, particularly in emergencies, we do support the requirement that phones should emit a “noticeable sound” if the camera facility is used.
Clubs should also remind members that any photos taken should fall within our guidelines and that if devices are taken into changing rooms, the facility to take photos must not be used.
It is vital that any suspected misuse of mobile/ smart phone devices is reported in accordance with Wavepower guidance.
Should photographs or footage of children be posted on an organisation’s website or social media platform?
It is recommended that photographs or footage of individual children should not be kept on an organisation’s website or social media platform if the site is publicly “open for the world to see”, particularly images of a child with their name displayed, that could lead to that child being identified, approached and placed in a vulnerable position.
The same could apply to printed materials such as an organisations’ annual report or kit. Many organisations have member only areas on their website or have privacy settings on social media platforms to allow and control access so that only members and their families can see the content.
It is recommended that children are not fully identified on such sites. Many organisations use just a first name, a surname or a nickname or simply just refer to the squad name. If an organisation wishes to publish a child’s name this should only be done with the consent of the parent/guardian. Parental consent may be withdrawn at any time and the organisation should take all reasonable steps to respect the wishes of the parent/guardian
Anti-Bullying Policy Statement
Tonbridge Sea Turtles comply with Wavepower Anti-Bullying Policy
Objectives of this policy
• All club members, coaches, teachers, officers of the club and parents/guardians should have an understanding of what bullying is.
• All club members, coaches, teachers, officers of the club and parents/guardians should know what the club policy is on bullying, and follow it when bullying is reported.
• As an organisation we take bullying seriously. Members and parents/guardians should be assured that they would be supported when bullying is reported.
• Bullying will not be tolerated.
What is bullying behaviour?
The Anti-Bullying Alliance defines bullying as “the repetitive, intentional hurting of one person or group by another person or group, where the relationship involves an imbalance of power. Bullying can be physical, verbal or psychological. It can happen face-to-face or through cyberspace”. Bullying can include:
Verbal: name calling, persistent teasing, mocking, taunting and threats.
Physical: any degree of physical violence including hitting, kicking and pushing.
Intimidating behaviour, theft or the intentional damage of possessions.
Emotional: excluding, tormenting, ridiculing, humiliation, setting people up and spreading rumours.
Cyber: the misuse of digital technologies or communications to bully a person or a group, typically through messages or actions that are threatening and/or intended to cause offence, anxiety or humiliation.
Why are children bullied?
Children are most commonly bullied because of a real or perceived “difference”. This difference can be anything but could be attributed to:
Racism: bullying based on ethnicity, skin colour, and language, religious or cultural practices.
Homophobic and transphobic: bullying based on sexuality or gender identity.
Disablist: bullying children who have special educational needs and disabilities.
Sexual: unwelcome sexual advances, comments that intended to cause offence, humiliation or intimidation.
Discriminative: Bullying based on any perceived weakness or difference. This could be because of their gender, age, race, nationality, ethnic origin, religion or belief, sexual orientation, gender reassignment, disability or ability.
It could also be factors surrounding the way someone looks or the clothes they wear, their family and social situation, hobbies and interests.
Signs and indicators
A child may not always ask for help or tell you their concerns. There may be signs or behaviours that indicate they may be being bullied. Adults should be aware of these signs and be prepared to investigate if a child is:
• Unwilling to go to club sessions.
• Becomes withdrawn, anxious, or lacking in confidence.
• Feels ill before or during training sessions or feigns sickness.
• Starts to drop in their level of training or competition.
• Doesn’t want to travel with the club or attend club events.
• Comes home with clothing torn or training equipment damaged.
• Has possessions that go “missing”.
• Has unexplained cuts and bruises.
• Asks for money or starts stealing money (to pay the bully).
• Is frightened to say what is wrong.
• Becomes aggressive, disruptive or unreasonable.
• Starts stammering.
• Cries themselves to sleep or has nightmares.
• Is bullying other children or siblings.
• Stops eating or poor appetite.
• Attempts or threatens suicide or runs away.
• Gives improbable excuses for any of the above.
This list is not exhaustive and could indicate other problems, but bullying should be considered a possibility and should be investigated.
Why is it important to respond to bullying?
Bullying hurts. No one deserves to be a victim of bullying. Everybody has the right to be treated with respect. Individuals who are bullying others need to learn different ways of behaving. Most bullying incidents are not crimes. But some types of bullying are illegal and should be reported to the police. This includes bullying that involves violence, assault and theft; harassment or intimidation over a period of time including calling someone names or threatening them, making abusive phone calls and sending abusive emails or text messages (one incident is not normally enough to get a conviction); and anything involving hate crimes.
All Swim England affiliated organisations have a responsibility to respond promptly and effectively to issues of bullying.
Procedures • Report bullying incidents to the Club Welfare Officer, coach, teacher or other officer at the club. • The Club Welfare Officer should be informed if a report of bullying is received by another officer so that appropriate action is taken. • The Club Welfare Officer will discuss the concerns with the Club Chair to decide whether the matter should be dealt with as an alleged breach of the club Code of Conduct or whether the matter proceeds under the Anti-Bullying Policy. • Advice can be sought at any time from the County or Regional Welfare Officer, Swim England Child Safeguarding Team or Swimline. • If necessary and appropriate the police should be consulted. • Parents/guardians should be informed and may be asked to come to a meeting to discuss the problem. • Bullying behaviour or threats of bullying must be investigated and the bullying stopped quickly. • If bullying is found appropriate action will be taken. • Attempts will be made to help the bully to change their behaviour. • If bullying is seen to continue despite best efforts to stop the behaviour the club may initiate disciplinary action under their club constitution.
Recommended club action
The Welfare Officer to be fully informed of any allegations involving bullying of a child or children at the club. The Welfare Officer to discuss the concerns with the Club Chair so a decision can be made as to whether it is appropriate for the club to deal with the situation as an alleged breach of the Code of Conduct or for the Welfare Officer to proceed with support from the club under the Anti-Bullying Policy. Agree who will lead the investigation, this will usually be the Welfare Officer but sometimes the children’s coach or teacher may wish to take the lead with assistance from the Welfare Officer. This is sometimes a preferred option if the children are more familiar with their coach/teacher. Remember advice can be sought from the County or Regional Welfare Officer or the Swim England Child Safeguarding Team at any time.
• Initially try to reconcile the parties by bringing them together. A genuine recognition of the effects of their behaviour and an apology may solve the situation. • Ensure that parents/guardians are made aware of the concerns and the proposed club action of reconciliation as described above. • Record the outcome of the reconciliation attempt and advise the parents/guardians of that outcome. If reconciliation fails, is deemed inappropriate in the situation or parents/guardians don’t agree to a reconciliation attempt then:
1 Set up a panel of three, this would normally be led by the Welfare Officer alongside either the Club Secretary, Chairman, committee member or coach/teacher. 2 The panel to meet with the child and their parent/guardian alleging the bullying. Allow the child to explain in their own words what has been happening so that full details of the allegation are known. The panel will need to know when and where this has been happening, by whom and whether they think anyone witnessed the behaviour. 3 Some children may not feel comfortable talking to the panel even with the support of their parent/guardian so the child should be allowed to give a written account in their own words. The child’s parent/guardian to then provide this account to the panel. 4 If there were any witnesses the same panel to speak to them to determine what they saw and any other information they have. If the witness is a child the panel to make that contact via the parent/guardian. The advice at point 3 to be followed if required. The panel meet with the alleged bully and their parent/guardian to put the allegation to them and allow them the opportunity to respond to the allegation in their own words. The advice at point 3 to be followed if required. 6 If the bullying is admitted then the panel can make decisions immediately on appropriate actions. 7 If the bullying is denied the panel will need to consider and form a view on what is alleged on the balance of probabilities. This view will be formed on all the available information gained by the panel from all sides, previous concerns and knowledge of the parties involved. 8 At all stages minutes should be taken for clarity and agreed by all as a true account.
Potential club actions if bullying is found
• An apology from the bully and an agreement on future behaviour. • A formal behaviour contract and ongoing monitoring to prevent repeated bullying. • Disciplinary action such as a written warning, temporary suspension or permanent exclusion. • Ensure all actions are recorded and that all parties are kept informed on what is happening and the outcomes.
Prevention
Everybody within the club has a responsibility to work together to stop bullying. It is mandatory for all Swim England clubs to have a written constitution and adhere to the Swim England Code of Ethics and accompanying Codes of Conduct. Wavepower provides Code of Conduct templates for clubs to use and adapt. We would recommend all club members sign a copy of the Code of Conduct when they join a club so they are aware and understand acceptable standards of behaviour. Clubs should promote and implement the Codes of Conduct and Anti-Bullying Policy. Many organisations have free resources that clubs can access to help raise awareness and some useful links have been provided at the end of this policy for clubs to use. We would urge clubs to encourage and facilitate children at the club playing an active part in developing and adapting the Code of Conduct for members. Some clubs have a representative group of children, youth forums, club captains and young leaders that could assist the club in this role. Their views, feedback and input can help clubs put in place a Code of Conduct that is relevant to the age group and promotes positive relationships within the club and prevents bullying behaviour. Some clubs through their youth forums, club captains, young leaders or other such groups promote a “buddy” system. This is where young people in the club act as a “buddy” to another child to help them feel supported, promote friendship and to help that child have a greater sense of belonging within the club. “Buddies” can be really helpful for children joining a club as well as for children who have had issues or struggle to interact and make friends.
Cyberbullying Behaviour that is classed as cyberbullying can include: • Abusive comments, rumours, gossip and threats over the internet or using other digital communications. This includes “trolling”. • Sharing pictures, videos or personal information without consent and with the intent to cause harm and/or humiliation. Hacking into someone’s email, phone, or online profiles to extract and share personal information, or to send abusive or inappropriate content while posing as that person. • Creating specific websites that negatively target an individual or a group. • Blackmail or pressuring someone to do something online they do not want to do. Some cyberbullying activities could be criminal offences under a range of different laws, including the Malicious Communications Act 1988 and the Protection from Harassment Act 1997. Whilst our clubs and organisations can commit to ensure that club websites and club social networking sites are being used appropriately and deal with any bullying behaviour on these platforms it becomes more challenging when behaviour being reported is happening outside the environment of the club.
State Schools have powers under the Education Act 2002 to intervene in bullying incidents outside of the school grounds including on home to school transport, in the community and online. The same power does not extend to Swim England or our affiliated organisations to be able to investigate children allegedly using their personal social media sites to cyberbully or use their personal social media inappropriately towards others. If children involved in alleged cyberbullying are members of the same club, parents/guardians can be assured that the club will ensure that behaviour within the club environment remains in accordance with the Code of Conduct and should any bullying behaviour be reported during club time then any necessary action will be taken. Practical steps parents and guardians can take • Many incidents of cyberbullying allow those experiencing it to keep evidence, for example, a screen shot, to show their parent/ guardian or in serious cases the police. • Make sure your child knows how to block anyone who posts hateful or abusive things. This can usually be found on the help or online safety area of the app or online service. • Report anyone who is bullying your child to the platform that carried the offending comments, audio, image or video. Many online services and apps have a report now button that can be used. • Advice can always be sought from the police. • Refer parents/guardians to the links provided at the bottom of this policy where they can receive expert advice and guidance.
Further help can be found at:
Kidscape kidscape.org.uk Anti-Bullying Alliance anti-bullyingalliance.org.uk NSPCC Child Protection in Sport Unit thecpsu.org.uk Childline childline.org.uk Bullying UK bullying.co.uk
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