Safeguarding Policy

Trauma Informed Development and Learning

Safeguarding Policy

Version NO: 1.1
Last reviewed: 14th of July 2025
Next Review: 14th of July 2026


Statement and purpose of policy


Policy Statement

TIDAL GLOBAL LTD (“TIDAL GLOBAL LTD”) is committed to adopting the highest standards and taking all reasonable steps in relation to the safety and welfare of young people and adults in respect of its learning services. We will meet our social and moral responsibilities to protect such individuals fully in accordance with the law and where appropriate, with the support of relevant external agencies.

All young people and adults, without exception, have the right to protection from abuse regardless of age, disability, gender, marriage and civil partnership, pregnancy and maternity, race, religion and belief, gender, sexual orientation or socio-economic background.

We aim to create a positive learning and working environment where every individual can be true to themselves and is able to learn and work without fear of harm. We will ensure that our employees and contractors are carefully selected, trained, supervised and have an appropriate level of DBS check in place if required. We will ensure that all employees and contractors adopt and abide by the Company’s Safeguarding Code of Conduct, are proactive and respond to any allegations appropriately in accordance with the reporting procedure.


Scope and Purpose

This policy applies to:

learners and customers.

employees and contractors (individuals who work – or have applied to work for the company either on a permanent, temporary, contractual or voluntary basis)

employers (organizations that work in partnership with us)

suppliers (external partners)

external stakeholders and visitors

The purpose of this policy is to set out our approach to safeguarding young people and adults and protecting them from a range of potential harm.


General Principles

TIDAL GLOBAL LTD’s Safeguarding Policy and associated policies are based on the following principle:

The welfare of young people and vulnerable adults are the primary concern

All young people and vulnerable adults have the right to protection from abuse.

It is the responsibility of experts to determine whether abuse has taken place, but it is everyone’s responsibility to report any concerns using the appropriate procedures outlined in this policy.

All incidents of suspicious practice and allegations must be taken seriously and responded to swiftly and appropriately.

Confidentiality must be upheld in line with the General Data Protection Regulation (GDPR) 2018, Data Protection Act 1998 and the Human Rights Act 1998.


Definitions and terms of abuse

Child – A child is defined as someone who has not reached 18 years of age.

Young Person – A young person is defined as someone normally between the age of 14–17 years of age.

Vulnerable Adult – Following the Protection of Freedoms Act 2012 the definition of regulated activity relating to adults no longer labels adults as ‘vulnerable’.

Instead, the definition identifies the activities which, if any adult requires them, lead to that adult being considered vulnerable at that particular time. This means that the focus is on the activities required by the adult and not on the setting in which the activity is received; or the personal characteristics or circumstances of the adult receiving the activities or the frequency in which they receive the service. An adult is defined as vulnerable when they are in receipt of a ‘regulated activity’ in relation to vulnerable adults.

Regulated activity is therefore defined by the following 6 broad categories:

Providing health care

Providing personal care

Providing social work

Assistance with cash, bills and/or shopping

Assistance in the conduct of a person’s own affairs

Providing transportation of individuals where that transport is provided because of age, health or disability.

For more information, please see the Safeguarding Vulnerable Groups Act 2006, as amended by the Protection of Freedoms Act 2012.


Discriminatory Abuse

Discriminatory abuse includes psychological abuse, harassment and discrimination which is motivated by a person’s age, gender, disability, sexual orientation, race, cultural background or religion. Discrimination may be a motivating factor in other forms of abuse such as domestic violence or hate crime.

Where the abuse or neglect is motivated by age, gender, sexual orientation, immigration status, racial, religion or disability; or occurs in a domestic violence situation; or perceived as a Hate Crime: the abuse will be considered to be aggravated by these factors.

Discriminatory abuse can be in the form of personal or institutional discrimination. Personal discrimination is the prejudice of the individual, whereas Institutional discrimination is where systems and structures directly discriminate against potential or actual users of a service.

Signs and symptoms of Discriminatory Abuse can include:

fearfulness expressed in the eyes, person avoids looking at the potential abuser, flinching on approach.

emotional withdrawal

sleep disturbance

low self-esteem

unexplained fear or defensiveness

isolation / shunning by others

threats or intimidation, bullying or shouting.

unexplained attacks on property or possessions

continual favouritism to other people in preference to the individual

internalising the discrimination to the extent that they express similar discriminatory views about others.

Other types of Abuse which could be considered Discriminatory:

Hate Crimes: any incident which constitutes a criminal offense which is perceived by the victim or any other person as being motivated by prejudice and hate.

Ageism: discrimination based on age, especially against the elderly.

Gender Discrimination: belief that one sex is superior to the other and that the superior sex has endowments, rights, prerogatives and status greater than those of the inferior sex.

Homophobia: discrimination against (fear or dislike of) homosexual people and homosexuality

Transgender Discrimination: discrimination against people who are transgender.

Religious Intolerance: intolerance motivated by one's own religious beliefs or intolerance against another's religious beliefs or practices.

Racism: the belief that all members of each race possess characteristics or abilities specific to that race, especially so as to distinguish it as inferior or superior to another race or races.

Disablism: discriminatory, oppressive or abusive behaviour arising from the belief that disabled people are inferior to others.


Physical Abuse

Physical Abuse is the physical mistreatment of one person by another which may or may not result in physical injury. Physical abuse includes assault, hitting, slapping, scratching, pushing, kicking, pinching, burning, force-feeding, misuse of medication or the withholding of medication or treatment, unwarranted or inappropriate restraint, forced isolation or inappropriate sanctions, unwarranted or unauthorised deprivation of liberty, false imprisonment or abduction, rough handling causing injury or any injury not fully explained by the history given.

Signs and symptoms of Physical Abuse can include:

unexplained bruises or welts on body, including face, lips, mouth, body, arms, back, buttocks, thighs.

bruises in various stages of healing, clusters forming regular patterns, reflecting the shape of an article or finger marks.

unexplained burns, especially on soles, palms and back, immersion burns, rope burns, electric appliance or carpet burns

unexplained fractures to any part of the body, especially if in various stages of healing, multiple or spinal injuries

unexplained lacerations or abrasions to the mouth, lips, gums, eyes, external genitalia

recoiling from physical contact or flinching.

malnutrition – rapid or continuous weight loss, insufficient supply of food on premises, dehydration, complaints of hunger

lack of personal care, inadequate or inappropriate clothing, inadequate heating

untreated medical problems

unmanaged urinary / faecal incontinence

signs of medication misuse such as drowsiness

use of furniture and other equipment to restrict movement

Other types of Abuse which could be considered Physical:

Domestic Violence: any incident, or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are, or have been intimate partners, or family members regardless of gender or sexuality.

Forced Marriage: a marriage conducted without the valid consent of one or both parties where duress is a factor.

‘Honour’ Based Violence: an incident or crime carried out to protect or defend the honour or ‘izzat’ of the family or community.

Environmental Abuse: includes depriving someone of their liberty, sustained restrictions on a person’s freedom of movement as a result of the physical environment, culture of the environment or institution; or living without expressions of love, or in unsuitable/unclean accommodation.


Sexual Abuse

Sexual abuse is the involvement of individuals in sexual activities to which they have not had the freedom and capacity to give their informed consent to, before and during the act, and/or may not fully comprehend. These acts include rape and attempted rape, sexual assault by penetration, sexual assault, abuser touching the victim’s body for their own gratification, indecent exposure, non-contact abuse (pornography), and sexual harassment, causing or inciting a person to engage in sexual activity without their consent. The use of social media and the internet has introduced ‘cyber’ sexual abuse such as ‘sexting’ and un-authorised sharing of sexual images.

Signs and symptoms of sexual abuse can include:

full or partial disclosure or hints of sexual abuse

signs of depression, stress

recoiling from physical contact

unusual difficulty in walking and sitting

sexually transmitted disease, urinary tract / vaginal infections

love bites, bruises or finger marks on thighs or arms

significant change in sexual behaviour, language or outlook

fear of males or females

pregnancy in a person who is not able to consent

worries over social media content and sharing of personal content (see Cyber Abuse)

Other types of Abuse which could be considered Sexual:

Female Genital Mutilation (FGM): procedures which include the removal of part or all of the external female genitalia for cultural or other non-therapeutic reasons.

Sexual Exploitation: exploitative situations where a vulnerable person receives something in exchange for sexual activity.


Psychological / Emotional Abuse

Psychological or emotional abuse is action or neglect by a person which impairs the psychological wellbeing of another person. This includes emotional abuse, threats of harm or abandonment, deprivation of contact, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal from services or supportive networks. People who use social media can be at risk from being humiliated or abused ‘on-line.’

Signs and symptoms of Psychological/Emotional abuse can include:

fearfulness expressed in the eyes, avoids looking at the caregiver, flinching on approach

ambivalence to carer

emotional withdrawal

sleep disturbance

low self-esteem

unexplained fear or defensiveness

threats or intimidation, bullying or shouting

significant pressure on a person to commit criminal acts

threat to abandon person or put them “away”

promises which are not kept

few visitors, phone calls or outings

locking the person in at home, or in a car

significant community pressure (e.g., anti-social behaviour)

withdrawing from online or real-life social groups (see Cyber Abuse)

Other types of Abuse which could be considered Psychological:

Anti-Social Behaviour

Discriminatory Abuse (as described above)

Cyber Abuse: use of technology/social media to threaten, bully, harass, groom, stalk or discriminate.


Financial or Material Abuse

Financial abuse is the misappropriation of an individual’s funds, benefits, savings, assets etc. or any other action that is against the person’s best financial interests.

Signs and symptoms of Financial/Material Abuse can include:

unusual or inappropriate bank activity

a Power of Attorney obtained when a person is unable to comprehend

recent change of deeds or title of house

person lacks belongings or services which they can clearly afford

recent acquaintances expressing sudden or disproportionate affection for a person with money or property

carer asks only financial questions of the worker, does not ask questions about care

withholding money

person managing financial affairs is evasive or uncooperative


Neglect and Acts of Omission

Neglect is the deliberate withholding OR unintentional failure to provide appropriate and adequate care and support. Section 44 Mental Capacity Act 2005 states: anyone who has a duty of care to a person who lacks capacity is guilty of an offence if they deliberately or recklessly ill-treat that person or if they wilfully neglect that person.

Signs and Symptoms of Neglect and Acts of Omission can include:

poor physical condition

unexplained or untreated deterioration in health and wellbeing

inadequate heating or lighting

poor personal hygiene

malnutrition – weight loss

dehydration

demanding food or drink

pressure sores

inconsistent or reluctant contact with health/social agencies

lack of social support / refusal to arrange access to callers/visitors

inappropriate, old or shabby clothing, or being kept in night clothes during the day

sensory deprivation (e.g., not allowed hearing aid, glasses)

accumulation of medication, or prescriptions not collected

increased incidents/accidents due to lack of supervision


Extremism and Radicalisation

Since 2010 (Prevent Strategy), there has been an awareness of the need to safeguard from violent extremism. TIDAL GLOBAL LTD values freedom of speech and expression of beliefs, but free speech that manipulates the vulnerable or leads to violence and harm goes against our principles.

Signs and Symptoms can include:

contact with extremist recruiters

accessing violent extremist websites/literature

using extremist narratives to explain personal disadvantage

justifying violence

joining or seeking to join extremist organisations

significant changes to appearance/behaviour

high social isolation leading to identity/personal crisis

TIDAL GLOBAL LTD has a separate policy to ensure compliance with CONTEST and PREVENT.


Procedure for reporting (5 R’s Model)

Recognition

Covers both disclosures of abuse and your personal concerns about a learner’s welfare.

Disclosure of abuse is likely to be direct.

A concern may arise from a conversation or a change in behaviour.

Response

Do not interview – just listen and clarify if necessary.

Remain calm and listen.

Inform the person that the concerns must be recorded and passed on.

Reassure the person they did the right thing in reporting.

Do not make unrealistic promises around confidentiality.

Reporting

All disclosures must be reported to the Designated Safeguarding Lead at [email protected]

DO NOT DISCUSS THE DISCLOSURE WITH ANYONE ELSE

Recording

Record precisely what has been alleged/happened — use the learner’s words.

Scan and email to the Designated Safeguarding Lead. Send the original in a sealed, confidential envelope.

Do not automatically add to a learner/employer file and do not make copies.

Use accurate quotation and include factual observations if appropriate.

After reporting, the Designated Safeguarding Lead will determine next actions (which may or may not involve you).

Referral

Only a Designated Safeguarding Lead can decide to refer a complaint or allegation.

Only a Designated Safeguarding Lead should look into a complaint, allegation or suspicion of abuse.

No employee is in a position to decide whether abuse has taken place.


Contact points for advice and support

The following members of staff have been identified as Safeguarding contacts.

Designated Safeguarding Lead (DSL) – TIDAL GLOBAL LTD
All disclosures must be reported to the Designated Safeguarding Lead at [email protected]


Training

Staff complete a comprehensive induction and mandatory training when they join the business on:

Safeguarding young People and Vulnerable Adults

Prevent

Modern Slavery and Human Trafficking

Fundamental British Values

Lone Working

Cyber Security

Driver Safety Awareness

DSE Awareness

Fire Safety Awareness

General Data Protection Regulation

Manual Handling

Protecting Against Bribery and Corruption in the Workplace

Understand Organisational Cultures, Equality, Diversion, and Inclusion.

We provide regular information and CPD activities to staff within our quality update to ensure staff are kept up to date and given the confidence to address and respond to issues. All staff undertake formal refresher training annually.

We provide all learners/participants with opportunities to explore safeguarding in a safe environment and in a way that is relevant to their learning programme with the aim of improving their knowledge, confidence, and awareness of safeguarding. Each month we send a learner newsletter to all live learners/participants which provides information to extend their learning on many key areas including safeguarding, Prevent and British Values.


Support

TIDAL GLOBAL LTD is committed to providing timely and effective support to all learners, customers and employees and contractors to achieve and maintain a safe and secure environment for all. To support this, staff receive training to support the 5 R’s model. Details of useful contacts and support agencies such the local Safeguarding Board; Local Children’s’ Services, Local Adult Services; Local Police Station and other specialist agencies are also available locally and centrally.


This document reflects the following key pieces of legislation

Safeguarding Vulnerable Groups Act (2006)

Education Act (2002)

Information Sharing (2018)


Associated Policies

Recruitment selection policy

Whistleblowing policy

Lone Working Policy

Staff Code of Conduct

Equality and Diversity Policy


Monitoring and review

This policy will be monitored annually to review its effectiveness and will be updated in accordance with necessary changes.


Creating A Wave of Change Through Trauma Informed Development And Learning In The Workplace

©TIDAL. 2025. All Rights Reserved.

Company Policies