Safeguarding Children Policy



  1. The physical, emotional and spiritual welfare of our students is of significant importance. SMART SWIM regards the need for safeguarding children from harm as vitally important. SMART SWIM recognises under, The Children Act 1989 and Every Child Matters, it has a legal and moral duty to promote the well being of children, and to protect them from harm, and to respond to any allegations, signs or evidence of child abuse.
  2. SMART SWIM believes that every child regardless of age has at all times and in all situations a right to feel safe and protected from any situation or practice that results in a child being physically, psychologically or spiritually damaged.
  3. SMART SWIM agrees that we have a primary responsibility for the care, welfare and safety of the children in our charge, and we will carry out this duty through our teaching. In order to achieve this, all employees of SMART SWIM will at all time act proactively in child welfare matters especially where there is a possibility that a child may be at risk of significant harm.
  4. SMART SWIM hopes that parents/guardians and children will feel free to talk about any concerns and will see staff and locations as a safe place if there are any difficulties at home.
  5. Children’s worries and fears will be taken seriously if they seek help from a member of staff. However, staff cannot promise confidentiality if concerns are such that a referral must be made to the appropriate agencies in order to safeguard the child’s welfare.



  1. If we have concerns that a child’s physical, sexual or emotional well-being is being, or is likely to be, harmed, or that they are being neglected, we will take appropriate action in accordance with the procedures issued by the Local Authorities (LAs) Safeguarding Children Board.
  2. As a consequence, we:
    1. Assert that all employees of SMART SWIM are an integral part of the child safeguarding process.
    2. Accept totally that safeguarding children is an appropriate function for all employees of SMART SWIM.
    3. Will ensure through training and supervision that all employees are alert to the possibility that a child is at risk of suffering harm and know how to report concerns or suspicions.
    4. Will designate a senior member of staff with knowledge and skills in recognising and acting on child protection concerns. They will act as a source of expertise and advice and is responsible for co-ordinating action within SMART SWIM and liaising with other agencies.
    5. Will share our concerns with others who need to know and assist in any referral process.
    6. Will ensure that all employees who have suspicion that a child may be suffering, or may be at risk of suffering significant harm, are aware of the need to refer such concerns to the designated person, who will refer on to Children’s Services in accordance with the procedures issued by the LAs Safeguarding Children Board. Employees will also be aware that they are able to refer such matters directly if they feel the need to.
    7. Safeguard the welfare of children whilst in a SMART SWIM lesson, through positive measures to address bullying, especially where this is aggravated by sexual or racial factors, disability or special educational needs.
    8. Will ensure that all employees are aware of the child protection procedures established by the LA Safeguarding Children Board and, where appropriate, the LA, and act on any guidance or advice given by them. This will be updated for all staff during CPDs.
    9. Will ensure through our recruitment that all employees are suitable to work with children.
    10. Will act swiftly and make appropriate referrals where an allegation is made that an employee of SMART SWIM has committed an offence against a child, harmed a child, or acted in a way that calls into question their suitability for working with children.



Designated Member of SMART SWIM

  1. The SMART SWIM designated senior member of staff for child protection is: Mrs Julia de Lucchi – Company Owner 
  2. The designated person is key to ensuring that proper procedures and policies are in place and are followed with regard to child safeguarding issues. They will also act as a dedicated resource available for other employees.
  3. All members of SMART SWIM must be made aware of who this person is and what their role is. The designated person will act as a source of advice and co-ordinate action within SMART SWIM over child protection cases. They will need to liaise with other agencies and build good working relationships with colleagues from these agencies. The designated person is the first person to whom members of staff report concerns. The designated person is responsible for referring cases of suspected abuse or allegations to the relevant investigating agencies.
  4. The designated person is responsible for dealing with allegations made against SMART SWIM employees.

Safer Recruitment

  1. In order to ensure that children are protected whilst attending SMART SWIM lessons, we will ensure that our staff are carefully selected, screened, trained and supervised. In particular:
    1. Before employing someone, follow up each reference with a telephone call or personal contact during which we will discuss the applicant’s suitability to work with children.
    2. Check that all adults employed by SMART SWIM have an enhanced DSB check before starting work, and prior to conformation of employment.
    3. Carry out identity checks to establish that applicants are who they claim to be (e.g., through birth certificate, passport, driving licence etc…)
    4. Check qualifications, to ensure that qualifications are genuine.
    5. Check professional and character references prior to offering employment.
    6. Satisfy conditions as to health and physical capacity.
    7. Check previous employment history to examine and gaps which are not accounted for.


  1. If at any time, SMART SWIM works with volunteers they will be given the same consideration as paid staff.
  2. Where a parent or other volunteer helps on a one-off basis, they will only work under the direct supervision of a trained member of staff.

Induction and Training

  1. All new employees of SMART SWIM will receive induction training, which will give an overview of the organisation and ensure they know its purpose, values, services and structure, as well as identifying and reporting abuse and confidentiality issues.
  2. All new employees will receive basic child protection information and a copy of this policy when commencing work with SMART SWIM.
  3. All new employees will be expected to undertake an eLearning course on Safeguarding children.

Dealing with Concerns

  1. Employees and volunteers are not required to investigate suspicion; if somebody believes that a child may be suffering, or may be at risk of suffering significant harm, they must always refer such concerns to the designated person, who will refer the matter to the relevant Children’s Services.
  2. To this end, employees and volunteers will follow the procedures below when:
    1. Upon receipt of any information from a child, or if any person has suspicions that a child may be at risk of harm, or
    2. If anyone observes injuries that appear to be non-accidental, or
    3. Where a child makes a direct allegation, or implies that they have been abused,
    4. Makes an allegation against a member of staff.
  3. They must record what they have seen, heard or know accurately at the time the event occurred, and share their concerns with the designated person and agree actions to take.
  4. SMART SWIM will ensure that all employees are familiar with the procedures for keeping a confidential written record of any incidents.
  5. Where any employee fails to report their concerns, this may be dealt with as a disciplinary matter.

Photographing Children

  1. We understand that parents like to take photos of or video record their children. This is a normal part of family life, and we will not discourage parents from celebrating their child’s success.
  2. SMART SWIM will not allow others to photograph or film children during a SMART SWIM activity without the parent’s permission.
  3. SMART SWIM will not allow images of children to be used on our website, publicity, or press releases, without express permission from the parent, and if we do obtain such permission, we will not identify individual children by name.
  4. SMART SWIM cannot however be held accountable for photographs or video footage taken by parents.
  5. Employees of SMART SWIM may take photographs of children whilst engaged in SMART SWIM activities for teaching purposes; for assessment purposes or as a means of celebrating success within SMART SWIM.


  1. SMART SWIM will ensure that all data about its customers is handled in accordance with the requirements of law and any national and local guidance.
  2. Any employee who has access to sensitive information about a child or the child’s family must take all reasonable steps to ensure that such information is only disclosed to those who need to know.
  3. Regardless of the duty of confidentiality, if any employee has reason to believe that a child may be suffering harm, or be at risk of harm, their duty is to forward the information without delay to the designated person.

Conduct of Employees

  1. SMART SWIM has a duty to ensure that professional behaviour applies to relationships between employees and children, and that all employees are clear about what constitutes appropriate behaviour and professional boundaries. At all times, members of staff are required to work in a professional way with children. All employees are to be aware of the dangers inherent in:
    1. Working alone with children.
    2. Physical interventions.
    3. Cultural and gender stereotyping.
    4. Dealing with sensitive information.
    5. Giving to and receiving gifts from children and parents.
    6. Contacting children through private telephones (including texting), e-mail, MSN or social networking websites.
    7. Disclosing personal information inappropriately.

Physical Contact and Restraint:

  1. Throughout SMART SWIM lessons, the teacher will undoubtedly have to make contact with a child. If a child is to be used for demonstration, then the parent/carer should be informed of what is going to happen. The child should be handed over after agreement has been sought and handed back immediately.
  2. On occasion, teachers may have to make physical interventions with children. Employees should only do this where:
    1. It is necessary to protect the child, or another person, from immediate danger, or
    2. Where the member of staff has received suitable training.

Allegations against Employees:

  1. If anyone makes an allegation that any employee of SMART SWIM may have:
    1. Committed an offence against a child.
    2. Placed a child at risk of significant harm, or
    3. Behaved in a way that calls into question their suitability to work with children, the allegation will be dealt with in accordance with national guidance and agreements.
  2. The designated person will handle such allegations; unless the allegation is against the designated person, then the STA will handle the response. The designated person will gather information, and report these immediately to the LA.