Safeguarding Policy

Last updated: October, 2023

Part A – Context

  1. Purpose: Protecting Children, Young People and Vulnerable Adults

Our charitable activities include working with vulnerable people. The purpose of this policy is to protect children, young people and vulnerable adults and provide our staff, trustees, freelance practitioners, volunteers, partners and funders with the overarching principles that guide our approach in doing so. 

Children and Young People

In this policy, the terms child, children or children and young people refer to anyone under the age of 18.


The term adult or vulnerable adult refers to people over the age of 18 who are at risk of abuse or neglect. They may need additional care services because of mental or physical disability, age or illness. They may be unable to care of themselves or unable to protect themselves against significant harm or serious exploitation.

An adult may be considered to have safeguarding needs if they

  • Are elderly
  • Are frail due to ill health, physical disability or cognitive impairment
  • Are carers
  • Have a learning disability, physical disability and/or sensory impairment
  • Have mental health needs
  • Have a long term illness or health condition
  • Misuse substances or alcohol
  • Do not have capacity to make a decision and are in need of care and support
  1. Safeguarding Principles

At London Bubble, we believe that:

  • Nobody who is involved in our work should ever experience abuse, harm, neglect, or exploitation.
  • We all have a responsibility to promote the welfare of all our beneficiaries, staff and volunteers, to keep them safe and to work in a way that protects them.
  • We all have a collective responsibility for creating a culture in which our people not only feel safe, but also able to speak up, if they have any concerns.
  • Children, young people and vulnerable adults have a right to be heard, listened to and taken seriously.
  • Individual and agencies must share information and work together in the best interest of children, young people and vulnerable adults.
  • Parents and carers have a right to respect and should be consulted and involved in matters which affect their families.
  1. Legislation and Guidance

This policy is derived from a number of legislative provisions and statuary guidance. In particular, it is based on good practice found in:

Working Together to Safeguard Children (2018)–2

Keeping Children Safe in Education (2021)–2

The Children Act 1989 (and 2004 amendment)

Safeguarding Vulnerable Groups Act (2006)

Statement of Government Policy on Safeguarding Adults (2011)

Six Principles for Safeguarding Adults (2011)

First introduced by the Department of Health in 2011, but now embedded in the Care Act, these six principles apply to all health and care settings.

  1. Empowerment

People being supported and encouraged to make their own decisions and informed consent

  1. Prevention

It is better to take action before harm occurs.

  1. Proportionality

The least intrusive response appropriate to the risk presented

  1. Protection

Support and representation for those in greatest need.

  1. Partnership

Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse.

  1. Accountability

Accountability and transparency in safeguarding practice.

  1. Safeguarding Policy Applicability & Responsibilities

This safeguarding policy applies to anyone working on our behalf, including our core staff, freelance practitioners, associate artists, trustees, students on work placement and other volunteers.

Partner organisations will be required to have their own safeguarding procedures that must, as a minimum, meet the standards outlined below, and include any additional legal or regulatory requirements specific to their work.  Safeguarding should be appropriately reflected in other relevant policies and procedures. 

  1. Related Policies

This policy works alongside and makes reference to other London Bubble policies:

  • Anti-Racism Policy
  • Data Protection Policy
  • Diversity, Equality and Inclusion Policy
  • Health and Safety Policy
  • Rehabilitation of Offenders Policy
  • Safe Recruitment Policy
  • Staff Wellbeing Policy
  • Social Media Policy
  • Whistleblowing Policy
  1. Diversity, Equality and Inclusion

At London Bubble we believe that everyone should be treated equitably so that each member can thrive.

Diversity, equality and inclusion are part of safeguarding as these issues often impact an individual’s lived experience and therefore their mental and physical wellbeing.

Practitioners must consider diversity, equality and inclusion when planning to ensure the suitability of the activity for the people involved.

We commit to offering a safe space for everyone regardless of background.

We are inspired by John Burnham’s Social GRACES model for attributes that we will not tolerate discrimination against:

                        G    Gender          Geography

                        R    Race              Religion

                        A    Age                Ability             Appearance

                        C    Culture          Class

                        E    Ethnicity        Economics    Education

                        S    Sexuality       Spirituality     Sexual Orientation

It is recommended that staff diversity reflects that of the group where possible.

Some children, young people and vulnerable adults face an increased risk of abuse, and additional barriers may exist for them with respect to recognising or disclosing it. Part of our commitment to anti-discriminatory practice is recognising people’s diverse circumstances. We ensure that all children, young people and vulnerable adults have the same protection, regardless of any barriers they may face.

We give special consideration to those who:

  • Have special educational needs or disabilities
  • Have mental health needs
  • Are young carers
  • Are in the care system or are care leavers
  • May experience discrimination due to their race, ethnicity, religion, gender identification or sexuality
  • Have English as an additional language
  • Are known to be living in difficult situations – for example, are homeless or in temporary accommodation or where there are issues such as substance abuse or domestic abuse at home
  • Are at risk of FGM, sexual exploitation, forced marriage, or radicalisation
  • Are asylum seekers
  1. Types of Abuse

Below are some of the types of abuse that the children, young people and vulnerable adults may have experienced or be experiencing. Staff should be mindful of these definitions in case indicators occur.

Abuse can take many forms, such as physical, psychological, emotional, financial, sexual or institutional abuse, including neglect and exploitation. 

Somebody may abuse or neglect a child, young person or vulnerable adult by inflicting harm, or by failing to act to prevent harm. Harm can include ill treatment that is not physical as well as the impact of witnessing ill treatment of others. This can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse. Abuse can happen within a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse.

Children may be abused by an adult or adults, or another child or children.

Adults may be abused by another adult or adults, or a child or children.

Physical Abuse

A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm. Physical harm may also be caused when a parent or carer fabricates the symptoms of or deliberately induces illness.

Sexual Abuse

Involves forcing or enticing a person to take part in sexual activities, not necessarily involving a high level of violence and whether or not they are aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children, young people or vulnerable adults in looking at, or in the production of, sexual images, watching sexual activities, encouraging children, young people or vulnerable adults to behave in sexually inappropriate ways, or grooming in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can children.

Financial Abuse

Includes theft, fraud, exploitation, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions, or benefits


County Lines or Criminal Exploitation

A term used to describe gangs and organised criminal networks involved in exporting illegal drugs into one or more importing areas within the UK, using dedicated mobile phone lines or other form of ‘deal line’. They are likely to exploit children and vulnerable adults to move and store the drugs and money, and they will often use coercion, intimidation, violence (including sexual violence) and weapons.

Child Criminal Exploitation

Where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or young person under the age of 18 into any criminal activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial or other advantage of the perpetrator or facilitator and/or (c) through violence or the threat of violence. The victim may have been criminally exploited even if the activity appears consensual. Child criminal exploitation does not always involve physical contact; it can also occur through using technology.

Child Sexual Exploitation (CSE)

Child sexual exploitation (CSE) is a type of sexual abuse. When a child or young person is exploited they’re given things, like gifts, drugs, money, status and affection, in exchange for performing sexual activities.


Organised crime gangs create a base in their chosen target area, usually by taking over the homes of local adults who gang members have identified as vulnerable. They do this either by force or coercion (known as ‘cuckooing’).

Coercive or Controlling Behaviour

Also known as coercive control, the use of control and coercion in relationships is a form of domestic abuse and a criminal offence.

Controlling behaviour is: a range of acts designed to make a person subordinate and/or dependent by isolating them from sources of support, exploiting their resources and capacities for personal gain, depriving them of the means needed for independence, resistance and escape and regulating their everyday behaviour

Coercive behaviour is: an act or a pattern of acts of assault, threats, humiliation and intimidation or other abuse that is used to harm, punish, or frighten their victim.

Coercive control is a form of abuse that involves multiple behaviours and tactics which reinforce each other and are used to isolate, manipulate and regulate the victim. This pattern of abuse creates high levels of anxiety and fear. This has a significant impact on children and young people, both directly, as victims in their own right, and indirectly due to the impact the abuse has on the non-abusive parent. Children may also be forced to participate in controlling or coercive behaviour towards the parent who is being abused.

Discriminatory Abuse

This includes discrimination on grounds of race, gender and gender identity, disability, sexual orientation, religion, and other forms of harassment, slurs or similar treatment

Domestic Abuse

Domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. Domestic abuse is not limited to physical acts of violence or threatening behaviour, and can include emotional, psychological, controlling or coercive behaviour, sexual and/or economic abuse. Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse and adolescent to parent violence. Anyone can be a victim of domestic abuse, regardless of gender, age, ethnicity, socio-economic status, sexuality or background and domestic abuse can take place inside or outside of the home.

Domestic abuse has a significant impact on children and young people. Children may experience domestic abuse directly, as victims in their own right, or indirectly due to the impact the abuse has on others such as the non-abusive parent.

Emotional Abuse

The persistent emotional maltreatment of a child, young person or vulnerable adult can cause severe and persistent adverse effects on their emotional development and wellbeing. It may involve conveying to a child, young person or vulnerable adult that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving them opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed. These may include interactions that are beyond a child, young person or vulnerable adult’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing them participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), causing them frequently to feel frightened or in danger, or exploitation or corruption. Some level of emotional abuse is involved in all types of maltreatment, though it may occur alone.


Extremism is vocal or active opposition to fundamental values such as democracy, the rule of law, individual liberty, and mutual respect and tolerance of different faiths and beliefs.

Female Genital Mutilation (FGM)

FGM comprises all procedures involving partial or total removal of the external female genital organs or any other injury to the female genital organs for nonmedical reasons. FGM is most often carried out on young girls aged between infancy and 15 years old. It is often referred to as ‘cutting’, ‘female circumcision’, ‘initiation’, ‘Sunna‘ and ‘infibulation’.

Human trafficking and modern slavery

Human Trafficking involves men, women and children being brought into a situation of exploitation through the use of violence, deception or coercion and forced to work against their will. People can be trafficked for many different forms of exploitation such as forced prostitution, forced labour, forced begging, and forced criminality, domestic servitude, forced marriage, forced organ removal. When children are trafficked, no violence, deception or coercion needs to be involved: simply bringing them into exploitative conditions constitutes trafficking.


The persistent failure to meet a child or vulnerable adult’s basic physical and/or psychological needs, likely to result in the serious impairment of their health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

  1. Provide adequate food, clothing and shelter (including exclusion from home or abandonment);
  2. Protect a child from physical and emotional harm or danger;
  3. Ensure adequate supervision (including the use of inadequate care- givers);
  4. Ensure access to appropriate medical care or treatment.

It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

For vulnerable adults, neglect includes ignoring medical, emotional or physical care needs; failing to provide access to appropriate health or care and support; or withholding the necessities of life, such as medication, nutrition and heating (whether intentional or not). Not enabling access to assistive equipment like hearing aids, walking aids, or dentures may be neglect and can also indicate coercive control.


This covers a wide range of behaviour neglecting to care for one’s personal hygiene, health or surrounding and includes behaviour such as hoarding. It is important to consider capacity when self-neglect is suspected. Also consider how it may impact on other family members and whether this gives rise to a safeguarding concern.

  1. Specific Areas of Concern

The following factors can increase the risk of abuse and/or neglect to a child, young person or vulnerable adult. We ask staff to remain vigilant to identifying the additional vulnerabilities that some members may face as people experiencing these issues may require additional consideration, action or support.

Alcohol and Substance Abuse

London Bubble does not permit people under the influence of drugs or alcohol to participate in activity and will ensure that someone has the means to get home safely if they are inebriated. We will provide age-appropriate information on drugs and alcohol and address problem behaviour, working with local partners to prevent drug or alcohol misuse.

In the case of parental substance misuse (drugs or alcohol), we recognise that this may impact on parental capacity and can significantly exacerbate other concerns such as domestic abusee or mental health issues. We will remain vigilant in identifying and supporting children and their families facing such issues, and work in collaboration with other agencies where necessary to prevent significant harm.

Children Missing from Education

A child going missing from education is a potential indicator of abuse or neglect, and such children are at risk of being victims of harm, exploitation or radicalisation. If you become aware that a child is no longer attending school and you think this is not a formal arrangement (i.e. they are being home schooled), please contact the DSL. There are many circumstances where a child may become missing from education, but some children are particularly at risk.

These include children who:

  • Are at risk of harm or neglect
  • Come from Gypsy, Roma, or Traveller families
  • Come from the families of service personnel
  • Go missing or run away from home or care
  • Are supervised by the youth justice system
  • Cease to attend a school
  • Come from new migrant families


The current definition of homelessness includes people who are:

  • staying with friends or family
  • staying in a hostel, night shelter or B&B
  • squatting (because you have no legal right to stay)
  • at risk of domestic abuse
  • experiencing violence in their home
  • living in poor conditions that could affect health
  • separated from family because they do not have a place to live together

People attending Bubble may be more vulnerable to homelessness because they are:

  • leaving care or leaving home for the first time
  • pregnant with nowhere to stay now or when the baby comes
  • struggling to live on benefits or a low income
  • from abroad without the right to claim benefits
  • leaving prison

If we are aware that a member is experiencing homelessness, we will refer to necessary services.

Mental Health

London Bubble seeks to promote and support positive mental health and improve social and emotional wellbeing through theatre projects. We welcome people with needs ranging from mild to severe. Although we recognise the indirect therapeutic outputs of our work, we are clear that we do not offer therapy.

We are committed to supporting people with more severe needs and to help make appropriate referrals to specialist agencies and local services such as Child and Adolescent Mental Health Services (CAMHS) and/or Community Mental Health Teams where necessary.

We recognise that some parents with mental health issues may experience difficulties at times with their parenting responsibilities and that this can impact child welfare and be connected to safeguarding concerns.

There are currently three people trained in Mental Health First Aid on the team; Marie Vickers, Natalie Clarke and Kehryse Johnson-Fraser.

Marie Vickers is also part of the Wellbeing Faculty at the Institute for Arts in Therapy and Education and has undertaken training in Therapeutic Wellbeing Practice.

Practitioners engaging with children, young people and vulnerable adults are invited to participate in Reflective Practice with a qualified therapist so that they can reflect on and process the impact of working with vulnerable people on their own wellbeing.

Special Educational Needs and Disabilities

As an inclusive organisation, we recognise that people with disabilities or special educational needs have exactly the same human rights to be safe from abuse and neglect, to be protected from harm and achieve the same outcomes as non-disabled people. They can experience greater vulnerability as a result of negative attitudes and because they may have additional needs relating to physical, sensory, cognitive and/or communication impairments. We are committed to adapting our practice and providing Access Support Workers where appropriate so that members can participate.

Part B – Procedures at London Bubble

  1. Reporting Safeguarding Concerns

If a crime is in progress, or an individual is at immediate risk of harm, call the police on 999.

If you are a member, participant, partner or member of the public, make your concerns known to a member of our team, who will alert a senior member of the charity. Marie Vickers is the Designated Safeguarding Lead.

For staff and volunteers, make your concerns known to your line manager. If you feel unable to speak to a member of the team, speak to a trustee. Dr Georgia Bowers is the nominated trustee for Safeguarding.

London Bubble staff should never let suspicion, disclosure or allegation of abuse go unrecorded or unreported.

Staff should use the Cause for Concern form to write an objective, factual account. We do not show bias to any individual, exaggerate or trivialise abuse.

Staff should not jump to conclusions.

Staff are advised to refer rather than investigate.

In the event of witnessing a concern or hearing a disclosure, staff can offer reassurance and commitment to helping a participant.

Best practice includes:

  • Allowing the individual to speak without interruptions or judgement
  • Avoiding leading questions
  • Staying calm and not rushing into actions which may be inappropriate
  • Confirming you understand how difficult it must have been to confide in you
  • Showing you take what is being said seriously
  • Alleviating feelings of guilt or isolation
  • Not making promises you cannot keep
  • Explaining that you will have to tell someone else or order to help stop what is happening
  • Assuring the individual that their safety and wellbeing is at the centre of our work
  • Ensuring that no situation arises at London Bubble which could cause further concern


A blank concern form is included at the back of this policy or can be collected from the office or can be emailed by any member of the Bubble team.

  1. London Bubble Safeguarding Team

Designated Safeguarding Lead (DSL):

Marie Vickers                       07845 308 359

The DSL is responsible for coordinating safeguarding issues, producing the policy, implementing its’ practice, ensuring staff are appropriately trained and taking necessary action when required.

Marie is point of contact for staff who have a concern about members’ welfare, safeguarding and/or child protection issues, including where the concern involves a mental health issue.

The DSL can offer advice and support to staff, volunteers, members, parents and partners regarding safeguarding and welfare.

Other staff on the Safeguarding Team include:

Lucy Bradshaw                        0207 237 4434

Natalie Clarke                     0207 237 4434

Kehryse Johnson-Fraser      0207 237 4434

Nominated Trustee for Safeguarding:

Dr Georgia Bowers                07944 190 800

Any of the people named above can deputise for the DSL.

  1. Southwark Safeguarding Contact Details (to be used by the DSL)

Once a concern has been raised with the DSL, it is their job to check whether it meets Southwark’s thresholds for safeguarding and inform the relevant services.

The numbers below are to be used by the DSL.

Are you worried about a child?

If you have concerns about a specific child, contact the Multi-Agency Safeguarding Hub (MASH)

0207 525 1921 (Mon-Fri 9-5)

0207 525 5000 (out of hours)

Concerns about Child Sexual Exploitation can be reported to


Are you worried about an adult with physical/sensory disabilities, or an adult over 65?


            0207 525 3324

Are you worried about an adult with a mental illness?


            0207 525 0088

Are you worried about an adult with a learning disability?


            0207 525 2333

Deprivation of Liberty Safeguards (DoLS)


Allegations against people who work with children and young people

The Local Authority Designated Officer (LADO) provides advice and guidance to employers and other individuals/organisations who have concerns relating to an adult who works with children and young people (including volunteers, agency staff and foster carers) or who is in a position of authority and having regular contact with children (for example religious leaders or school governors).

In Southwark the LADO roles in based within the Quality Assurance Unit.

            QAU duty number                             0207 525 3297

            QAU service manager (LADU)        0207 525 0689

Concerned about cuckooing?

Southwark has launched a new multi-agency forum to help tackle cuckooing, the practice in which an individual’s home is taken over and used for criminal activities.

  1. Safer Recruitment & DBS Checks

All staff and volunteers who will as part of this job have contact with children, young people or vulnerable adults will undergo an Enhanced DBS Check for either the Child or Adult workforce (as relevant) or both. If the disclosure reveals that a person is not suitable to work with children, young people or vulnerable adults, they will not be appointed.

The company will cover the cost of checks for salaried staff but freelance artists must provide their own.

If appropriate, London Bubble may inform the DBS, police and/or other agencies of a person’s attempt to secure employment with children or vulnerable adults if their check shows that they are barred.

If a DBS Enhance Check cannot be issued in time for the start of a contract, a DBS disclosure issued by another body within the previous three years may be deemed adequate in the interim.

All potential employees must provide the details of two referees. London Bubble will contact referees for verification that this person is suitable to work with children, young people and vulnerable adults. London Bubble will reject any applicant who is deemed unsuitable to work with children, young people or adults at risk.

New staff and volunteers receive a Safeguarding induction from the DSL and are made aware of London Bubble’s policies and procedures.

  1. Safeguarding Training

Training is considered part of our organisation-wide approach to safeguarding.

A safeguarding induction is given by the DSL to all new staff and volunteers.

Every two years, we offer whole company Safeguarding training. This is carried out by an appropriately qualified external person. Training will include recognising indicators of abuse and/or neglect.

Salaried project staff are required to undergo Level 2 training every two years.

The Designated Safeguarding Lead (DSL) and nominated Trustee for Safeguarding will undertake Level 3 Safeguarding Lead training every two years.

Regular facilitators are encouraged to attend Safeguarding, Trauma Awareness and First Aid training sessions organised by London Bubble. They will be made aware of other more specific training opportunities from time to time.

  1. General Safeguarding Procedures and Practices at London Bubble

Ensuring delivery spaces are safe

Risk assessments are carried out ahead of group activity. This helps us ensure that spaces are safe and suitable. A minimum temperature of 18 degrees should be maintained in rooms used by children and vulnerable adults. Heating must be safe and properly guarded. Rooms should be well lit and well ventilated. Window locks should be fitted where recommended. All fire exits must be unobstructed.

Members leaving the space and getting home

At the end of sessions, staff should ensure that all members have left safely before leaving themselves. We ask parents/carers to inform us should a different adult be collecting their child.

If a participant hasn’t been collected as expected, staff should reassure the participant and attempt to contact their parents/carers to arrange a safe journey home. If necessary, the staff member may escort them in a licensed or registered taxi. If two staff are available, participants can be taken very short distances by foot.

Staff and freelance members should not take members in their cars.

When working in Sheltered Housing Units, staff should not enter the private dwellings (individual flats) of participants.

Members’ Personal Details

Personal details are kept on Salesforce, a password protected CRM. Paper copies are kept in a locked unit until they can be shredded.

A record of certain personal information is maintained as part of our registration process. This is stored so that members do not have access to it. Sessions leaders delivering off site or out of office hours will be given a password protected copy of emergency contact details, information regarding health concerns including allergies, medical needs, and/or additional support needs.

Communication with participants

All Bubble activity and communication with participants that is not ‘in person’ should be carried out through official Bubble channels. This may include Zoom, Microsoft Teams, Bubble registered mobile numbers etc. All postal returns should be directed to the Bubble registered office. This is unless we are working in partnership with another organisation and the project risk assessment concludes that it is more appropriate to use the partner’s channels.

Example: Speech Bubbles online sessions carried out with individual schools’ Microsoft Teams accounts.

Code of Conduct

All participants are made aware of the Code of Conduct at the start of a project. This highlights our expectations regarding safety and what is expected in terms of conduct whilst in a Bubble session. There is also a version for online delivery.

Participants are advised to wear suitable clothing and footwear for physical activity. Socks on hard surfaces are considered dangerous and advised against.

A copy of the latest Code of Conduct is included at the back of this policy.

Minimising per-on peer abuse

We will minimise the risk of peer-on-peer abuse by:

  • Challenging any form of derogatory or sexualised language or behaviour
  • Being vigilant to issues such as sexualised or aggressive touching or grabbing, and initiation or hazing type violence
  • Ensuring our activities help to educate children about appropriate behaviour and consent
  • Ensuring that children know they can talk to staff
  • Understand that a child/ young person harming a peer could be a sign that the child is being abused themselves, and that this would fall under the scope of this policy


Staff: Participant Ratio

The number of participants who can participate in sessions will depend on the size of the premises, the number of staff and the needs/purposes of the group.

Local authorities recommend that the minimum staff to participant ratio should be:

1:8 for ages 5-8 years

1:16 for ages 8 and over

London Bubble commits to at least two members of staff working on any group.

Session leaders must be over the age of 18.

If a member of staff is working with a participant on a one to one basis, this should happen in a public area, or, if this is not possible, with the door open.

  1. Touch and Physical Contact

Physical contact within activities

In recognition that physical contact is often an integral part of drama activity, it is important to highlight good practice.

Practitioners should seek permission before touching participants, check participants are comfortable with physical touch before starting an exercise and give alternative options for those who are not.

Practitioners should consider the context of the group, age, gender, religion and culture when planning activities involving physical contact.

Staff must not use any physical punishment (including slapping, smacking or shaking) not practices that humiliate or frighten participants or threaten these kind of punishments.

If a participant makes any inappropriate physical advances towards a member of staff, they should inform the DSL immediately.

Comforting someone in distress

If a member of staff thinks it is appropriate to comfort a participant who is distressed, they must offer this support in a public area.

If a member instigates a hug, a side-to-side hug is advised.

  1. Photographs and Videos

Photographs and videos featuring children or vulnerable adults may only be used within the following parameters:


Written consent is given by the individual (if over 18) or carer of the subject (if under 18) prior to the photographs or video being taken. In addition, we should gain consent from the subject on the day of photos or video being taken.

Future use

The consent form will specify whether the photograph or video may be re-used in the future without the need for future consent, how it may be published e.g. online/printed materials.


The image is only used for the purposes(s) for which consent has been given.


Due consideration is given to the appropriateness of content of an image e.g clothing, position etc.


Photographers / film makers engaged by London Bubble may not work alone with children, young people or vulnerable adults.


Photographers / film makers engaged by London Bubble agree to abide by the terms of this policy including providing a DBS check.

Use of Personal Devices, Platforms and Accounts

Session leaders should not take or save photos on personal devices or post pictures of members from their personal accounts.


London Bubble will follow the GDPR and the Data Protection Act 2018 when taking and storing photos and recordings for use within the organisation.

  1. Online Safety

We will identify and manage online risks by ensuring that:

  • Volunteers, staff and trustees understand how to keep themselves safe online eg not having personal items in view. We may use high privacy settings, blurred backgrounds and password access to meetings to support this.
  • The online services we provide are suitable for our users. For example, using age restrictions and offering password protection to help keep people safe.
  • The services we use and/or provide are safe and in line with our Code of
  • A specific Code of Conduct for online sessions is sent to members ahead of and/or during sessions.
  • We follow GDPR legislation to protect personal details.
  • We have permission to display any images on our website or social media accounts, including consent from an individual, parent, etc.
  • We clearly explain how users can report online concerns. Concerns may be reported using this policy, or direct to a social media provider using their reporting process. 
  1. Confidentiality and Record Keeping

Concerns are recorded and saved on the highway, encrypted with a password so that only the DSL can access them, unless requested by the Board of Trustees.

Records are kept of all meetings, decisions made and information received. The DSL should keep records of all Strategy Meetings held and their conclusion.

Live cases are reviewed ahead of every board meeting.

Reviewing records will enable us to identify any patterns in systemic issues within London Bubble.

  1. Safeguarding and Supervision

We understanding that safeguarding related incidents can have a personal impact on staff. Supervision takes a number of forms at London Bubble, all of which offer an opportunity to reflect on the role of safeguarding within our projects and our practice.

Salaried staff will receive annual appraisals as well as informal and ad-hoc meetings with their line manager throughout the year.

Freelance staff will be invited to pre and post project meetings with the project team, Programme Producer and either the Artistic or Executive Director. These sessions will include opportunities to discuss the practice, the process, the performance/sharing, the people in the group and safeguarding risks and/or incidents.

With groups that are more vulnerable, we may have team debriefs at the end of each session to ensure that staff feel supported and that no one person is dealing with safeguarding incidents alone.

We often work together as team to discuss best practice and make action plans to safeguard individuals.

Clinical supervision (also described as Reflective Practice) with a qualified therapist is offered termly to all delivery staff. Staff are also able to access free counselling through our Employee Assistance Programme. You can call the 24 hour confidential helpline on 0800 032 7697.

Any member of staff is welcome to ask for a supervision session with their line manager, the DSL, the Artistic or Executive Director at any time.

  1. Allegations Against a Member of Staff

If an allegation of abuse is made against a member of staff or volunteer, it must be brought to the attention of the DSL immediately. Where the allegation meets the ‘threshold’, the DSL will conduct basic enquiries to decipher whether there is any foundation to the allegation and liaise with the LADO and other authorities as appropriate. If the DSL is the subject of the investigation, the Board will manage the case.

The threshold for an allegation may have been met in the following circumstances:

  • They have behaved in a way that has harmed a child or may have harmed a child, young person or vulnerable adult
  • They possibly committed a criminal offence against a child, young person or vulnerable adult
  • They have behaved towards a child, young person or vulnerable adult in a way that indicates they may pose risk of harm to children
  • They have behaved towards a child, young person or vulnerable adult that indicates they are unsuitable to work with children, young people or vulnerable adults

This includes behaviour from outside of London Bubble which might make the person unsuitable to work with our members (known as transferable risk). Some cases may require immediate intervention by the police.

Any member of staff under allegation will not have contact with any  child, young person or vulnerable adult whilst an investigation is underway. 

Following an investigation, London Bubble will keep a summary of the case on the person’s confidential personnel file. The record should include details of how the allegation was followed up and resolved, the decisions reached and the action taken. A copy of this summary should be given to the individual concerned. It should be kept for at least 10 years or until the person reaches normal retirement age.

Low Level Concerns

As part of an open culture to safeguarding concerns which do not meet the threshold for a referral to LADO or the police should still be talked about. Everyone is encouraged to report or self-refer low level concerns so that professional boundaries are maintained. This may include a member of staff

  • Being over friendly with children, young people or vulnerable adults
  • Using inappropriate language
  • Favouring one member
  • Picking on one member
  • Making fun of a member
  • Accompanying a member home (even with consent)
  • Independently contacting a member outside of an organised session

Part C – Governance

  1. Management of this policy

The Designated Safeguarding Lead, Marie Vickers, is responsible for monitoring this policy.

This policy is endorsed and ultimately the responsibility of the London Bubble Board of Directors who review the policy every year. Dr Georgia Bowers is the trustee with responsibility for safeguarding.

Within each review, London Bubble

  • monitors the effectiveness of the policy
  • identifies any gaps between policy and practice
  • identifies new legislation and models of best practice which may be incorporated

A record is kept of any events or incidents in the scope of this policy. This record is reported at the policy review. With due regard for confidentiality, it simply reports the nature of an incident, the action taken and the outcome.

A copy of this policy document is issued to all artists, consultants and volunteers engaged by London Bubble who may have direct contact with children, young people or vulnerable adults.

All partners (e.g. schools, youth organisations, sheltered housing units) and participants (including their parents and carers) will be informed that the policy exists and that they are welcome to request a copy of it.

Delivery staff should familiarise themselves with the Safeguarding Policy of the setting they are working in when delivering London Bubble projects remotely.

  1. Trustee Safeguarding Responsibilities

The trustees are mindful of their reporting obligations to the Charity Commission in respect of Serious Incident Reporting and, if applicable, other regulators.  They are aware of the Government guidance on handling safeguarding allegations.

Responsibilities should be made clear and individuals provided with any necessary training and resources to enable them to carry out their role.  It should be reflected in job descriptions, annual plan and appraisal objectives, reporting to the trustee Board and other procedures, as necessary.

This safeguarding policy will be reviewed and approved by the Board annually. 

Trustees are aware of and will comply with the Charity Commission guidance on safeguarding and protecting people (see hyperlink) and also the 10 actions trustee boards need to take (see hyperlink) to ensure good safeguarding governance. 

The lead trustee for safeguarding has responsibility for the oversight of all aspects of safety, including Whistleblowing and Health & Safety. 

As of October 2023, this is Dr Georgia Bowers.

This includes (alongside the DSL):

  • Creating a culture of respect, in which everyone feels safe and able to speak up.
  • An annual review of safety, with recommendations to the Board.
  • Receiving regular reports, to ensure this and related policies are being applied consistently.
  • Providing oversight of any lapses in safeguarding.
  • Ensuring that any issues are properly investigated and dealt with quickly, fairly and sensitively, and any reporting to the Police/statutory authorities is carried out.
  • Governing the organisation in way that makes everyone feels safe and able to speak up.
  • Ensuring safeguarding risk assessments are carried out and appropriate action taken to minimise these risks, as part of our risk management processes.
  • Ensuring that all relevant checks are carried out in recruiting staff and volunteers.
  • Ensuring that all appointments that require DBS clearance and safeguarding training are identified, including the level of DBS and any training required.
  • Ensuring that a central register is maintained and subject to regular monitoring to ensure that DBS clearances and training are kept up-to-date.
  • Ensuring that safeguarding requirements (eg DBS) and responsibilities are reflected in job descriptions, appraisal objectives and personal development plans, as appropriate.
  • Listening and engaging, beneficiaries, staff, volunteers and others and involving them as appropriate.
  • Responding to any concerns sensitively and acting quickly to address these.
  • Ensuring that personal data is stored and managed in a safe way that is compliant with data protection regulations, including valid consent to use any imagery or video.
  • Making staff, volunteers and others aware of:
    • Our safeguarding procedures and their specific safeguarding responsibilities on induction, with regular updates/reminders, as necessary.
    • The signs of potential abuse and how to report these.

  1. Safeguarding and Fundraising

London Bubble will ensure that:

  1. Approval and Review

Approval By


Next Review Date

Trustee Board


Part D – Resources for Delivery Staff Use

  1. Safeguarding at a Glance: Key Principles

Things to think about when you are working with children, young people and vulnerable adults on behalf of London Bubble Theatre.

Safeguarding is everyone’s responsibility

If someone is in danger or at risk of immediate harm, call 999

Refer don’t investigate We are not detectives! Someone else will be better placed to find out what has happened.

Tell the DSL It is never your responsibility to  deal with a safeguarding concern alone, always involve the DSL

Marie Vickers – 07845 308 359 / 07776 124 589 / 0207 237 4434

If something doesn’t feel right, mention it There is no harm in raising a concern, even if it turns out to be nothing.

Maintain professional boundaries to protect yourself and participants

  • Don’t give your personal contact details to members
  • Don’t make contact with members outside of sessions
  • Think about whether you can be found easily on social media and what you are sharing
  • Avoid 1:1 situations with members

Don’t use personal devices to take photos of members Ask for a Bubble device. If you do take pictures on a personal device, please email to the Programme Producer and delete immediately.

Take good care of yourself As a Bubble employee, you are welcome to contact Croner Wellbeing Services on their 24 hour confidential line: 0800 032 7697.

They have a number of resources available including free counselling.

These key principles are explored in more detail throughout this policy and are covered in training.

Below you will find our Code of Conduct.