Safeguarding Policy and Procedure

Preface and Disclaimer

This policy sets the minimum safeguarding standards for clubs in the GrappleTrust network. It is written for BJJ and grappling clubs and is intended to be adopted by each club in the network. It should be read alongside relevant government guidance and local safeguarding arrangements.

Clubs in the GrappleTrust network will not tolerate discrimination, harassment or victimisation. Members can raise concerns using the reporting routes set out in this policy. Breaches may lead to disciplinary action and may be reported to external bodies, depending on severity and risk.

This policy does not provide legal advice. If you suspect criminal conduct or immediate risk, contact emergency services (999 or 101) and/or your Local Authority.

1. Purpose, Scope and Principles

• Purpose: To prevent harm, protect children and adults, and set clear standards of conduct across clubs in the network – including independent, cross-club reporting routes.
• Scope: Applies to everyone involved in club activities: coaches, owners, contractors, volunteers, staff, members, visitors and participants – whether at training, events, competitions, socials or online.
• Principles: Safety first; putting children and people at the centre; respect and inclusion; openness; fairness; confidentiality (within safeguarding limits); no retaliation against anyone who reports a concern; independent reporting through cross-club Safeguarding Officers (SOs).

2. Legal and Policy Framework

• Working Together to Safeguard Children (DfE, 2023 and as updated) – multi-agency duties and standards.
• Keeping Children Safe in Education (DfE, current edition) – safer recruitment and allegations guidance (used here as best practice for clubs working with children).
• Safeguarding Vulnerable Groups Act 2006 (as amended by the Protection of Freedoms Act 2012) – regulated activity, barred lists and DBS referrals.
• Disclosure and Barring Service (DBS) framework and guidance – eligibility for checks, legal duty to refer.
• Equality Act 2010 – protected characteristics; anti-discrimination, harassment and victimisation.
• Data Protection Act 2018 and UK GDPR – lawful, proportionate information sharing for safeguarding; records and retention.
• Ann Craft Trust / Sport England safeguarding adults in sport guidance – adult safeguarding principles in sport and activity settings.
• Local Authority Designated Officer (LADO) procedures – allegations against adults who work with children.

3. Key Definitions

• Child: Any person under 18 years old.
• Adult at risk: An adult who needs care and support and, because of that, may not be able to protect themselves from abuse or neglect.
• Safeguarding concern: Any worry about harm, abuse, grooming, harassment, bullying, coercion, discrimination or boundary-crossing – including online.
• Incident: A specific event or pattern of behaviour.
• Low-level concern: Early warning signs that could lead to an incident.

4. Governance, Roles and Responsibilities

• Club Owner/Head Coach: Responsible for safe operations; must cooperate with investigations and must not block reporting.
• Club Safeguarding Lead (CSL): Leads day-to-day safeguarding at their club; keeps records; works with Cross-Club SOs and relevant authorities; makes sure new members are told about this policy.
• Deputy CSL: Supports the CSL and steps in when the CSL is absent or has a conflict of interest.
• Cross-Club Safeguarding Officers (SOs): Independently receive informal enquiries and formal reports from members of other clubs via the GrappleTrust platform; assess concerns, offer advice, and arrange independent handling where there is a local conflict of interest.
• Verification of SOs (best practice): Up-to-date safeguarding-in-sport training; DBS check; endorsements from two members (ideally including at least one woman, with exceptions where a club has very few women); a declaration of any conflicts of interest; agreement to follow the SO Code of Conduct.
• All coaches/volunteers/staff: Must follow codes of conduct, report concerns, cooperate with enquiries and meet safer recruitment and DBS requirements.

5. Equality, Diversity and Anti-Discrimination

Clubs and the network prohibit discrimination, harassment and victimisation based on protected characteristics (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation). Breaches are treated as safeguarding concerns and may lead to sanctions including expulsion and referral to external bodies.

6. Codes of Conduct

• Behaviour: Be respectful and inclusive; zero tolerance for bullying, harassment, hazing or sexualised conduct.
• Boundaries: Be aware of the power dynamic between coaches and students; intimate relationships must be disclosed and managed, and may be banned by club rules; never exploit trust.
• Training safety: Adjust intensity for size and experience; everyone has the right to refuse to train with someone – no explanation is required; no "proving dominance"; prioritise learning and safety.
• Changing rooms and travel: Supervise appropriately; avoid one-to-one situations behind closed doors where possible; keep communications open and transparent.
• Online conduct: The same standards apply on messaging apps and social media; no private one-to-one messaging with under-18s unless a parent can see it; use club channels where possible.

7. Safer Recruitment, Vetting and Supervision

• Written role descriptions and interviews for all coaching and volunteer roles; check identity and references; explain safeguarding responsibilities.
• DBS checks for anyone in a regulated role working with children and/or adults; use the DBS Update Service where appropriate; renew checks at regular intervals.
• Anyone on a barred list must not work in a regulated role; keep a central record of all checks and training.
• Probation periods, supervision and ongoing monitoring of behaviour; act quickly on early warning signs.

8. Training and Induction

• All coaches and volunteers must complete safeguarding-in-sport training, refreshed at least every 3 years.
• New members must be told about key standards, how to report concerns (including the independent cross-club option), and given links to reporting forms.

9. Reporting Options and Whistleblowing

• Informal chat: Speak informally with an independent Cross-Club SO through GrappleTrust. What you say will be kept confidential unless there is a risk of harm to you or someone else, in which case the SO may need to share information to keep people safe.
• Formal internal report: Report to your Club Safeguarding Lead, either directly or using the Concern Form.
• Cross-club report: Report to an SO from another club where there is a conflict of interest (e.g. the concern involves an owner or head coach).
• External: Contact the Police, Local Authority, NSPCC (for children), Adult Safeguarding, or other relevant bodies. DBS referrals must be made where there is a legal duty to do so.
• Whistleblowing: We encourage anyone to speak up; retaliation against someone who raises a concern is prohibited and may result in warnings, suspension, expulsion from the club, and/or removal from the network.

10. Confidentiality, Information Sharing and Data Protection

• Only share information with people who need to know. If a child or adult is at risk of serious harm, information may be shared without consent where necessary.
• Keep records secure and only share them where there is a lawful reason to do so.
• Provide privacy notices; set how long records are kept; limit who can access them.
• Photography and images: Photographs and videos of children must not be taken or shared without explicit consent from a parent or guardian. For adults, consent should be obtained before images are taken or published – particularly on social media or promotional material. Anyone may withdraw consent at any time. Clubs should make clear at events and sessions whether photography is taking place and give people a genuine opportunity to opt out.
• Hidden vulnerability: Be aware that vulnerability is not always visible or disclosed. A person may have an undisclosed disability, mental health condition, trauma history, or other factor that affects their ability to protect themselves. Do not assume that someone is not at risk simply because they have not told you about a vulnerability.

11. Triage, Risk Assessment and Thresholds

• When a concern comes in, assess: does it involve a child or adult at risk? Is there immediate danger? Could it be criminal? Is there an ongoing risk? Is there a conflict of interest? Put temporary safeguards in place if needed (e.g. supervision or suspension).
• Distinguish early warning signs from serious incidents; escalate where needed; record the reasoning in the Decision Log.

12. Investigations, Fair Process and Outcomes

• Fairness: Tell the person accused (unless doing so would put someone at risk), let them respond, and keep both sides updated.
• Evidence: Gather statements, training records, CCTV (where lawful), messages and screenshots.
• Findings: Substantiated / Inconclusive / Unsubstantiated / Malicious. Record the reasoning and any actions taken.

13. Allegations About Adults Who Work With Children (LADO)

If an allegation meets the threshold, notify the Local Authority Designated Officer (LADO) within one working day. Stay in contact with the police and/or children's services and follow local procedures.

14. Adults at Risk – Safeguarding

Follow adult safeguarding principles: seek consent, empower the person, and act proportionately. Consider whether the person has the mental capacity to make decisions. Refer to Adult Safeguarding services where appropriate. Give the person choices and support, and explain how information may be shared.

15. Interim Measures and Sanctions

• Interim: Supervision, restricted duties, conditions on who they can train with, temporary suspension.
• Final: Warnings, required training, removal from coaching, suspension or expulsion, referral to the DBS or regulators.

16. Rehabilitation and Return to Training/Coaching

In non-criminal cases that do not involve children, a structured return plan may be considered – including acknowledgement, apology, training, monitoring, conditions and time limits. Cases involving minors, serious violence or sexual offences will normally prevent someone from returning to the club.

17. Events, Trips and Competitions

Where children are involved: carry out risk assessments; appoint a welfare lead; set supervision ratios; collect parental consent forms; put transport and accommodation safeguards in place; get photography permissions. For all participants, keep emergency contact details.

18. Physical Contact in Coaching

Keep unnecessary physical contact to a minimum; explain why contact is needed before making it; ask for consent; make sure others can see what is happening; record any incident where contact caused concern.

19. Communications and Visibility

Display a safeguarding summary poster with contact details for the CSL and independent SOs. Provide QR codes linking to reporting forms. Publish this policy on club websites and include it in onboarding and waivers.

Download (light)

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20. Monitoring, Audit and Review

Review this policy at least once a year, or sooner after a significant incident or change in the law. Check that SO credentials, DBS checks and contact details are still up to date.

21. Network Participation

To be part of the GrappleTrust network, clubs must adopt this, or an admin-confirmed equivalent policy. Failure to cooperate, or retaliation against anyone who raises a concern, may lead to removal from the network.

Contact

You can submit a report through our reporting platform.

If you have any questions about this policy, please contact us at:
grappletrust@protonmail.com