Abuse: By abuse we mean child abuse or abuse against an adult by another person (abuser) who inflicts harm on the victim or fails to prevent harm to the victim. Abuse may take place within a family, an institution or a community or church setting. Very often the abuser is known to or in a trusted relationship with the child or adult victim.
Adult: Anyone aged 18 years old or older.
Adult with care and support needs: Previously referred to as “vulnerable adults” who have an increased vulnerability to harm and abuse due to certain personal characteristics (old age, disability, special educational needs, illness, mental or physical infirmity, or impairment or disturbance of the mind or brain), or due to their life circumstances (isolation, socio-economic factors, environment or living conditions) and so being in need of protection, or being in need for someone else to take action on their behalf. Hence, they are adults to whom safeguarding duties apply, and we may use these two terms interchangeably.
The Care Act 2014 now defines an adult to whom safeguarding duties apply as any person aged 18 years old or older who:
Adults (Abuse of): The Care Act 2014 provides the following non-exhaustive list of the forms of abuse or neglect that can affect adults.
Child: Anyone who has not yet reached their 18th birthday. (Children’s Act, 1989); (Working Together to Safeguard Children (rev.2023)).
Therefore, in the church in London, and as used throughout this Policy (and in all our Key Documents), the term “Child” or “Children” is inclusive of “Young People” and always means “Children and Young People”, that is, all those below the age of 18 years old.
Nevertheless, in our practical arrangements for the care of the Children when they participate in our events and activities, we may separate them out into the following age categories:
Child Abuse: A form of maltreatment of a child. A child may be abused by someone causing them harm, or by someone failing to prevent harm to them. Harm can include ill treatment that is not physical as well as the impact of witnessing ill treatment of others. Abuse may take place in the family or in an institutional or community or church setting by those known to the child or, more rarely, by others. A child may be abused by an adult or adults, or by another child or children. Abuse can take place wholly online, or technology can be used to facilitate offline abuse. (Working Together (rev. 2023)).
Statutory guidance (Working Together (rev.2023)) sets out four main categories of child abuse, namely:
(Please refer to Appendix I for further information on what may constitute these categories of abuse and the Signs and Indicators to look out for.)
Child Protection: That part of the Safeguarding process that promotes the welfare of children and refers to the activity that is undertaken to protect specific children who have been identified as suffering, or likely to suffer, significant harm (Working Together (rev.2023)). It is the way in which society responds to harm that has already occurred, while safeguarding is what society does to prevent harm from occurring.
Local Authority Designated Officer (LADO): (Please refer to Statutory Agencies below)
Person in Position of Trust: This is defined in the Sexual Offences Act 2003 as an adult “caring for, training, supervising or being in sole charge of” a child or children under the age of 18. It is well-accepted that a worker or volunteer (paid or unpaid) may also be a person in a position of trust over adults to whom safeguarding duties apply.
The concern with persons in positions of trust is the risk they may pose to children or adults with care and support needs who are under their care. The term has always included teachers, doctors, care workers, youth workers and social workers.
Since 2022 (Police, Crime, Sentencing and Courts Act), the term now extends to those holding positions of trust in the settings of “sport” and “religion”, defined as anyone who: “coaches, teaches, trains, supervises or instructs someone under 18 on a regular basis, in a sport or a religion”.
The 2022 Act makes it illegal for a person in a position of trust to engage in sexual activity with a child in their care or supervision, even if that child is over the age of consent. This means that even though a child may be over the age of consent (that is, aged 16-17 years old), if you hold a position of trust, it is illegal to engage in sexual activity with that child.
Therefore, in the church in London, all adults employed to work with or volunteering or serving with the children and young people, or with adults with care and support needs on a regular basis, are persons in positions of trust. Such persons need to understand the concerns surrounding the risks their positions of trust may pose to those under their care or supervision, and the responsibility they bear as a result. It is vital that all such persons ensure that they do not, even unknowingly, use their position, influence, power or authority inappropriately. They should always maintain clear professional boundaries and avoid behaviours that may cause harm, that fail to prevent harm, or that could be misinterpreted as such.
As a church we sometimes encourage responsible young people (12-17 years old) with a burden, to volunteer to serve with the younger children in some of our events and activities. From the outset we expect that those supervising them would ensure their awareness of the concerns and risks outlined above (albeit by using age-appropriate language and messaging), and their understanding of the boundaries set by the church and the behaviours we want to discourage, and that they would undertake to be guided by the Good Practice Guidelines and Code of Conduct (see Appendix B and C below) in the same way as for all adult persons in positions of trust.
Safeguarding: Safeguarding refers to the duty of care we have to protect all who meet with us from harm. Although it is the Trustees who have oversight legal and moral responsibility to ensure safeguarding in the church in London, and have designated certain persons as Safeguarding Coordinators to carry out specific actions towards this on their behalf, everyone who meets with us regularly is encouraged to develop the mindset that: Safeguarding is Everyone’s Responsibility (Working Together (rev.2023)).
Safeguarding Coordinators: The Safeguarding Coordinators of the church in London are the persons appointed by the Trustees to carry out the following functions, namely to:
Safeguarding Incident: In the church in London a safeguarding incident is the occurrence of anything or any matter that gives rise to an allegation, complaint, concern or suspicion that a child or adult has suffered or is at risk of suffering harm, abuse or neglect.
Any individual may report a safeguarding incident by using the procedure outlined in this Policy (specifically, section 6 below).
Once a safeguarding incident report has been submitted, this amounts to a safeguarding disclosure requiring a response from the church through its Safeguarding Coordinators as outlined in this Policy (specifically, section 7 below).
Specialist Adviser: The Trustees have engaged Thirtyone:Eight, (formerly the Churches’ Child Protection Advisory Service (CCPAS)) as the church in London’s specialist adviser on Safeguarding. In certain circumstances specified below, you may choose to make a report to them directly, rather than to the Safeguarding Coordinators. You may do so by writing to them at: P.O. Box 133, Swanley, Kent, BR8 7UQ, or by calling their phone number: 0303 003 1111, or by emailing info@thirtyoneeight.org.
Statutory Agencies: The relevant statutory agencies in England are:
Statutory Guidance and Legislation:
Trustee Safeguarding Lead: The Trustee designated with specific responsibility for safeguarding in the church in London. These responsibilities include:
Key principles sought to be achieved with this role include transparency, clarity, challenge and the ability to evidence the rationale for decision-making in safeguarding matters.
2a. Church Details
Name: The Church in London (the church of the Londoners)
Address: Bower House, Orange Tree Hill, Romford, RM4 1PB
Tel No: +44 – 1708-380330
Email address: office@churchinlondon.org.uk
Charity Number: 1093426
Insurance Company: Congregational: Public Liability
2b. Trustees
Dennis Szubert (Trustee Safeguarding Lead) Tel. No: 07740 626 537
Terry Murray Tel. No: 07740 281 450
Fergus Fung Tel No: 07761 843 157
Keith Woolnough Tel No: 07789 564 912
2c. Safeguarding Coordinators
Emmanuel Freeman Tel No: 07878 653 775 Email: emmanuel@churchinlondon.org.uk
Samuel Alexander Tel No: 07960 316 662 Email: samuel@churchinlondon.org.uk
Diane Ward Tel No: 07789 910 390 Email: diane@churchinlondon.org.uk
2d. Church Life and Activities
Christ is our life, and the church is our living
The following is a brief description of our church life and the type of work and activities we undertake.
“Because the church has the status of the assembly, the ekklesia, we need to gather together. We must assemble and meet in order to have a congregation for God to work and move among us.” (The Conclusion of the New Testament: The Church, the Kingdom, and the New Jerusalem (msgs. 189-264), msg 207: The Church the Status of the Church (1) The Assembly)
We are a people who love to gather, assemble and meet. The church in London holds meetings in various locations in London each week, including the Lord’s Day meeting, the Prayer Meeting, Home Meetings and Group Meetings. Participation in these meetings may be in person or online, and all are welcome to join us.
Several times a year we also hold conferences and trainings, and organise events, retreats and activities, all of which normally include our children and young people, invited guests and members of the public. These take place in venues we own or hire in London, or in venues elsewhere in the UK or even further afield in Europe and beyond.
With such a rich and full church life comes corresponding duties and responsibilities, which may be legal or moral, or may be requirements placed on us by our insurers or by our Regulator (the Charity Commission), or may simply be accepted best practice.
To meet all our obligations there is the need for us to have in place robust policies, processes and procedures that set out our objectives, the steps we take to reach them and the guidelines we follow to ensure we operate effectively yet safely. This Safeguarding Policy is one such policy, and by complying with it we ensure that all those who meet with us and participate in our activities are well cared for, kept safe and are protected from harm.
We take our duties and responsibilities under this Policy very seriously, and we encourage all who meet with us to read, understand, accept and always be guided by its provisions, remembering that:
Safeguarding is Everyone’s Responsibility.
3a. Trustees’ Commitment
The Trustees of the church in London:
3b. Reporting Serious Incidents
The Trustees are aware of their responsibility to report all serious incidents to the Regulator, the Charity Commission.
The Trustees undertake to make prompt, full and frank disclosure to the Commission of all serious incidents that occur, including how they are dealing with the situation, together with regular updates of any further developments.
Where a serious incident relates to safeguarding, the Trustees have delegated their responsibility to report to the Trustee Safeguarding Lead, Dennis Szubert. In his absence or unavailability, the Trustees may request the church’s specialist adviser, Thirtyone:eight, to make this report on their behalf. These necessary and practical arrangements do not detract from the fact that it is all the Trustees together who bear ultimate responsibility for ensuring that a report is made to the Charity Commission, and in a timely manner.
The responsibility for determining whether an incident meets the threshold of “serious” and so should be reported, rests with the Trustees, who will base this decision on the guidance provided by the Regulator.
Where a reportable incident involves actual or alleged criminal activity, the Trustees will additionally ensure that it is reported to the relevant statutory agencies, namely, the Police and the Local Authority. Where the incident takes place outside the UK, the report will also be made to the local law enforcement authorities and/or local safeguarding organisations.
3c. Public Liability Insurance Claims: It is also the responsibility of the Trustee Safeguarding Lead to inform the church’s insurer of any safeguarding incident or disclosure that might trigger any public liability claims, and to keep the insurer abreast of developments.
4a. Safer Recruitment
The church will ensure that all persons in positions of trust (whether paid workers or volunteers) are appointed, trained, supported and supervised in accordance with all current government guidance and best practice on safe recruitment and working practices.
This includes ensuring that safeguarding has been discussed with them at their interview, that references have been obtained and followed up where appropriate, a self-declaration form and the relevant Disclosure and Barring Service (DBS) (England and Wales) checks have been completed where necessary, a suitable training programme and induction is provided for them, and that they have been given a copy of our safeguarding policy and know how to report safeguarding incidents.
Where we employ workers from outside the UK we undertake all necessary background checks, including ‘fit person’ checks from the home country as well as taking up references from there.
4b. Application and Safeguarding Approvals Process
For volunteers and those wishing to serve with the children and young people, the starting point for all recruitment is by application to the church. The relevant application form and all information on the recruitment process can be found on the church’s recruitment website at: https://safeguarding.churchinlondon.org.uk/ypc-service-application.
Following an application, the applicant will be taken through the Safeguarding Approvals Process, which can be found at Appendix A below. This also describes how we use the Disclosure and Barring Service (DBS) as part of this process to ensure the safe recruitment of all those volunteering or serving with children.
4c. Safeguarding Training
The church is committed to providing safeguarding training and development opportunities for those carrying out safeguarding responsibilities and persons in positions of trust.
All such persons will undertake recognised safeguarding training on a regular basis. We provide or facilitate:
Training Providers: We engage Thirtyone:Eight as our main training provider for the above purposes. The Safeguarding Coordinators may additionally attend any safeguarding training offered by the statutory agencies, such as the Local Safeguarding Children’s Board or Local Adult Protection Board. The Trustees may also attend any safeguarding training provided by the Charity Commission.
5a. Managing and Supporting Workers and Volunteers
In this section we seek to demonstrate how we carry out our work and activities in a safe manner, through our management and support of persons in positions of trust to ensure children and adults who meet with us are protected, well cared for and kept safe from harm.
A key principle that we strongly encourage is that all persons in positions of trust work or serve in groups or teams for coordination purposes, and not independently or in isolation. What this means practically is that each week there are several opportunities for workers and or volunteers to come together for coordination and for fellowship. This approach fosters a mutually supportive working environment where help and advice is freely available and accessible. We also take the way of coordination in groups for all event planning for our conferences, trainings and other activities.
In our children’s work we adhere strictly to our Good Practice Guidelines and Code of Conduct, with which all persons in positions of trust are expected to comply.
We follow the principles contained in the Public Interest Disclosure Act 1998. Therefore, we expect that all workers (paid or voluntary) would report any improper actions and omissions to act by anyone. Whilst we will investigate all malpractice and illegal acts, it is especially important that suspicions of abuse are immediately reported to the Safeguarding Coordinators using the process outlined in this Policy.
Good Practice Guidelines
These are the guidelines we adhere to when carrying out specific activities, and which prescribe specific tasks and responsibilities pertaining to those activities. (Please see Appendix B below for a copy of the Guidelines.)
Code of Conduct
We have developed this code of conduct to set clear boundaries for persons in positions of trust, the behaviours we expect them to display and to refrain from, and in particular, in regard to the personal relationships that can or cannot be developed. These boundaries need to exist to maintain healthy working attitudes and relationships. (Please see Appendix C below for a copy of the Code of Conduct.)
5b. Working Safely in Partnership with Others
In this section we seek to demonstrate how we carry out work and activities in a safe manner whenever we work together with, or hold joint events and activities with, other local churches or other organisations known to us who may be based in London, elsewhere in the UK, or in Europe or beyond, to ensure children and adults we invite are protected, well cared for and kept safe from harm.
Safeguarding remains of critical importance whenever we work together with others, and we seek to assure ourselves of comparable high standards of safeguarding provision and care.
We follow certain key principles that we find effective in providing us with the assurances we seek. Depending on the specific situation and circumstances, we may employ any one or more of the following approaches:
Any person wishing to make an allegation or complaint or to report a concern or suspicion relating to safeguarding, that is, to report a safeguarding incident, should do so immediately or, as soon as possible after the occurrence of the incident or incidents in question.
You may report a safeguarding incident in any of the following ways:
Please note: Under no circumstances should you carry out your own investigation into any allegation, complaint, concern or suspicion relating to safeguarding. Neither should you make assumptions, discuss the matter with anyone else, offer any alternative explanations or promise confidentiality to anyone.
A report should always be made to the Safeguarding Coordinators as soon as you know of a safeguarding incident, or become aware that a safeguarding incident has occurred, or have a concern or suspicion that a safeguarding incident may have occurred.
Emergencies. However, in the event of an emergency, where you consider that there is immediate or imminent danger of harm or risk of harm to any person you should first call the Police directly on 999. This should be followed with a report to the Safeguarding Coordinators as described above.
In the absence or unavailability of the Safeguarding Coordinators, or of the one to whom you wish to make your report, or where the allegation, complaint, concern or suspicion implicates any one or more of the Safeguarding Coordinators, you may make your report to another one of the Safeguarding Coordinators who is present and available, or to one who is not so implicated.
Alternatively, you may make your report directly to the specialist adviser or to any of the statutory agencies listed above using the contact details provided above.
Confidentiality: Before, during or after making a report as outlined above, the matter should be kept confidential and should not be discussed with anyone other than the Safeguarding Coordinators or specialist adviser or statutory agency, except where you consider it is absolutely necessary to do so, and then in a strictly limited way and only on a need-to-know basis.
For the purposes of assisting in any future investigation or further questioning by the Safeguarding Coordinators or by the specialist adviser or by any of the statutory agencies, you may make and keep a copy of the report you have made in a secure place, but this should be securely destroyed as soon as possible after the investigation in order to maintain confidentiality.
It is, of course, the right of anyone to make a direct referral to the specialist adviser or to the statutory agencies, or to seek their advice directly on any matter, bypassing the internal processes altogether. However, it is the Trustees’ hope and expectation that individuals will retain confidence in and choose to use the internal route outlined above to make their report.
Where, however, you form the view that the Safeguarding Coordinators have not responded appropriately to a report, or where there is disagreement as to the appropriateness or otherwise of the making of a referral to the statutory agencies, then there is freedom to contact the statutory agencies directly. By making this statement the Trustees hope to demonstrate their absolute commitment to effective safeguarding.
7a. This section outlines the role and functions of the Safeguarding Coordinators and the actions they will take in responding to safeguarding disclosures made to them.
The Safeguarding Coordinators will:
7b. Investigations and Outcomes: It is the role of the statutory agencies to conduct all investigations, if they choose to, into safeguarding referrals made to them (s.47 of the Children Act, 1989), and to take any necessary and appropriate actions resulting from their investigations.
However, to the extent required by the statutory agencies, the Safeguarding Coordinators, supported by the Trustee Safeguarding Lead, will fully cooperate and assist with all such investigations to the best of their abilities.
Moreover, to the extent permitted by the statutory agencies, the Safeguarding Coordinators, supported by the Trustee Safeguarding Lead, will maintain close contact with the statutory agencies and follow up with them to seek progress updates, evidence of actions being taken and to generally satisfy themselves and the Trustees that a referral is progressing in a timely manner to a satisfactory outcome. It is the Trustees’ expectation that the Safeguarding Coordinators will maintain interest in and pursue every referral made to the statutory agencies to its logical conclusion and not remain satisfied with simply having made a referral.
Ultimately, it is the Safeguarding Coordinators’ responsibility to ensure that safeguarding disclosures are actively pursued until further harm to the alleged victim or others is prevented and there no longer remains a safeguarding threat or risk to any person.
Therefore, the eventual report presented by the Safeguarding Coordinators to the Trustees on how they have handled a safeguarding disclosure should include a timeline detailing all actions they have taken continuing right down to any victim support offered, and the outcomes of those actions. This report could be made as part of their presentation in the Annual Safeguarding Report to the Trustees.
7c. Physical Injury, Emotional Abuse, Neglect: Where a safeguarding disclosure contains an allegation, complaint, concern or suspicion that a child has or was seen to have a physical injury, or to be suffering from emotional abuse, or is being subjected to, or displays symptoms or signs of neglect, the Safeguarding Coordinators will respond in one or more of the following ways:
Where a disclosure made is non-urgent, for example, the symptoms or facts point more toward signs of poor parenting or lack of parenting skills rather than of a child being abused or harmed, the Safeguarding Coordinators may respond in any of the following ways that may be appropriate or necessary:
Where the parent, carer or guardian is unwilling to seek the help or assistance offered or fails to act as recommended by the Safeguarding Coordinators, then, in cases where there remains an ongoing concern, the Safeguarding Coordinator will make a referral to the statutory agencies.
7d. Sexual Abuse: Where a disclosure made to the Safeguarding Coordinators contains an allegation, complaint, concern or suspicion of child sexual abuse, the Safeguarding Coordinators must:
7e. Where a disclosure made to the Safeguarding Coordinators contains accusations against a person in position of trust, the Safeguarding Coordinators will:
7f. Statutory Agencies: The statutory agencies referred to in this section are the following:
Charity Commission for England and Wales
8a. The Trustees are mindful of the fact that harm and abuse have deep and far-reaching adverse impacts on victims of abuse and may extend to affecting their mental and physical health, their relationships, careers and their faith. Victims may also include families, friends and witnesses to the harm or abuse, as well as alleged perpetrators who eventually turn out to have been wrongly accused of wrongdoing.
The Trustees are committed to meaningful engagement with victims, putting their interests uppermost and offering appropriate support and care to all who need it, and all such persons are encouraged to come forward and take advantage of the available provision.
8b. Support and care provision may include:
In this section we set out how we manage the risks associated with previous offenders and any others who pose a safeguarding risk.
The Trustees’ commitment to safeguarding, as expressed throughout this Policy, takes absolute precedence over the rights or needs of any individual.
Where any person meeting with us is known to be a previous offender, or to have previously abused or harmed a child or adult with care and support needs, or is known or suspected to pose any kind of safeguarding risk, the Trustees will take active steps to manage that individual and/or the risks associated with that individual in order to protect others.
However, the Trustees will endeavour to balance this with a proportionate and sensitive approach that seeks to also assist the individual overcome their negative tendencies or eliminate or lessen the risk of their re-offending.
The Trustees will adopt the following approach:
Where it is determined that this approach has failed and that there remains the risk of re-offending or of harm to others, the Trustees may exclude the individual from the meetings of the church, either temporarily or on a permanent basis.
Section 10: Approval of Policy and Review Date
10a. This Safeguarding Policy was approved and signed by the Trustees on 16 February 2026
The Policy comes into effect immediately and supersedes all previous safeguarding policies of the church.
Signed: Dennis Szubert
Signed: Terry Murray
Signed: Fergus Fung
Signed: Keith Woolnough
10b. Review Date. The next review date for this Policy is 31 January, 2027.
10c. A copy of this Policy is displayed on the church website at https://www.churchinlondon.org.uk/safeguarding. Copies are also made available in each Hall’s Health & Safety Binder and are available on demand by anyone.