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Being prepared for safeguarding

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This section gives some suggestions for your policies and procedures, which will contain elements of safeguarding that are specifically needed for a grant maker. If you’re starting on safeguarding from scratch, use it alongside other advice such as the pages in steps to a safer organisation.

Your people (staff and volunteers)

Your staff who deal with grants may have varying responsibilities that need to be considered as you decide what level of recruitment checks, training and support they need. 

  • Do they assess applications and carry out due diligence checks?
  • Do they attend monitoring visits to groups including children or adults at risk? Do they do this alone?
  • Will they be involved in the process when a grantholder reports a safeguarding concern?

Things that must be in place

  • The right level of safeguarding training. Our training page can help you find and review training.
  • A policy for risk assessment of monitoring visits and a lone working policy if needed.
  • The right level of disclosure and barring and other recruitment checks for the role. Our checking staff and volunteers page can help with decisions regarding checks. 

Complaints and whistleblowing

Sometimes, when people have a safeguarding concern about an organisation, they will want to tell the people who fund it, rather than the organisation itself.

You must make sure that whoever deals with complaints looks out for when someone is whistleblowing about a safeguarding issue in one of your grant organisations.

You also need to make sure you have a whistleblowing policy in case your staff or volunteers feel like their safeguarding concerns are not being listened to. 

Decision making and concerns 

Your safeguarding policy and procedures must identify who in your organisation is the designated safeguarding lead. They will oversee all the usual procedures for raising safeguarding concerns within the organisation. You must make sure that there is a specific procedure for making decisions about safeguarding concerns that relate to grant applicants and grant holders.

When you are creating that section of your procedures, there are some key questions you should ask yourself.

  • Do you need different approaches depending on when the concern is raised? For example, during the assessment or when a grant is running.
  • When will you need to involve senior staff and/or trustees?
  • Do you have enough expertise in-house or will you need to seek external support if a safeguarding concern about a grant holder is raised?
  • If you are contacted directly about the concern, when do you inform the grant holder?
Example
Arncourt Charitable Foundation have a designated safeguarding lead – all safeguarding matters are referred to them. They keep contact details for NSPCC in their safeguarding protocol in case they need more specialist advice.

Information sharing and data protection 

Like in any organisation, you must take care to make sure you meet rules about data protection and data sharing under the General Data Protection Regulation (GDPR).
One specific area that grant makers need to think about is sharing case studies, images and quotes from either grant recipients or the people they work with.

  • Remember, you must get informed consent about exactly what you intend to use the data for.
  • Remember that there are ethical considerations as well as laws to think about.
  • Consider whether the information you share might put people at risk.
  • Take into account the emotional impact of asking people to share their stories.
  • For children or adults unable to give informed consent, you may need to also ask their parent or carer.
Example
Kingsley Trust funds projects that work with trafficked children. They have a reporting template that includes guidance on what information to include in the monitoring report. It includes reminders to anonymise information about beneficiaries so that they can’t be identified.  

You must make it clear to all your grant holders that safeguarding responsibilities override data protection and privacy rules. In your grant agreement, make it clear that you must be given information when:

  • An allegation has led to an investigation and/or referral to the police, local authority or other regulatory body (such as the Disclosure and Barring Service (DBS)).
  • A breach or failure of policy which could have put people at risk of harm and/or resulted in a referral to the police, local authority or regulatory body.

If you want to know more about data protection and sharing within safeguarding, use ‘storing and sharing information’ from our designated safeguarding lead handbook.

Investment and fundraising

Make sure you’ve considered how safeguarding could affect how you invest your assets and raise money. Trustees have a duty to get the best return on their investments. However, they must make sure their choice of investment doesn’t harm those they seek to help and isn’t connected to activities which are criminal or unethical.  

You should:

  • carry out due diligence checks on all organisations you intend to do business with before making investments or setting up partnerships
  • have a schedule for renewing checks on long term investments
  • have a policy for what could be considered as safeguarding or reputational risks that you will not be accepted.
Example
Kernal Housing Association have made a commitment to providing affordable housing. They have adopted an ethical investment strategy. They screen investment opportunities to make sure that they don’t invest in companies with a poor human rights record.
  • If you raise funds as well as making grants you should use our safeguarding for fundraising managers pages.
  • Want to know more about trustees responsibilities when making investments? Use the charities and investment matters PDF. This is a guide for trustees from the Charity Commission.

Joint funding

Where you are providing co-funding with another organisation, make sure you’ve put arrangements in place for how you will share relevant information with each other. For example, this could be serious safeguarding concerns or information relating to investigations.

Example
Yellow Brick Road Trust ask in their application form whether match funding is being sought and if so, from whom. If the funding is granted, the Trust talks to the other funder to see how reporting, information sharing and project visits can be coordinated. If there’s a serious incident or concern, the Trust will check the other funder has been informed and how they want to be involved in the next steps.
Page last edited Oct 11, 2019

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