The National Lottery Community Fund safeguarding expectations for organisations we fund
Keeping people safe from harm – in our own organisation and in the organisations we fund.
- What we mean by safeguarding
- What we expect from the organisations we fund
- How we’ll check you’re meeting our expectations
- What and when you should report to us (if you have funding)
- Examples of when to report incidents
- Where to get guidance on safeguarding policies and procedures
- Definitions of safeguarding terms used on this page
What we mean by safeguarding
By safeguarding we mean taking steps in your organisation to prevent harm and responding to incidents.
By incidents we mean any time someone raises a safeguarding issue or concern with you. This includes confirmed issues, allegations and risks. They are sometimes called concerns, disclosures or complaints.
To find out more about the words we use here see our definitions of terms used on this page.
What we expect from the organisations we fund
If we give you funding, we expect that you’ll:
These expectations apply to all organisations we are giving funding to, as well as partners doing any part of the activities we’re funding. We’ll consider these expectations when we make decisions about who to fund. We may use them when we ask for updates on your funding. They’re also written into the terms and conditions for all of our funding.
Promote a culture of safeguarding
- See safeguarding as a priority in your organisation. This means you have an open and safe culture around safeguarding. You should have clear responsibilities for safeguarding at different levels of the organisation, including oversight from senior leaders and trustees.
- Record your safeguarding risks. Make sure that your organisation understands, records and proactively manages safeguarding risks.
- Have your own tailored policy for safeguarding and a code of conduct. This should be appropriate, proportionate and relevant to your organisation’s activities. You must review this policy as necessary (at least once a year). All staff, volunteers, beneficiaries and trustees should understand and follow it.
- Have your policy and practices publicly available. Promote these to anyone who comes into contact with your organisation. Reassure them about how you will keep people safe and what to do if they have any concerns.
- Make sure that any partners you work with have their own appropriate safeguarding policies and practices. Make sure they are aware of our safeguarding expectations.
Keep people safe
- Use safe and transparent recruitment processes including
- deciding if a criminal record check is needed, based on the role and the work they’ll do.
Criminal records checks include Disclosure and Barring Service (DBS) in England and Wales, Protecting Vulnerable Groups (PVG) in Scotland, or AccessNI in Northern Ireland. - getting references
When you check the references, you should ask if they know of any reasons why the applicant should not work with people at risk.
- deciding if a criminal record check is needed, based on the role and the work they’ll do.
- Provide appropriate, regular safeguarding training and guidance to staff, trustees and volunteers. This should include how to manage safeguarding risks and report concerns.
Respond to safeguarding incidents
- Have a tailored, up-to-date procedure for reporting safeguarding incidents that everyone knows about and feels confident using. This includes anyone who comes into contact with your organisation.
- Take all safeguarding incidents seriously and respond promptly, following your policy. This includes reporting incidents to the relevant authorities or regulators.
- Tell us about any serious safeguarding incidents within 10 working days. Follow our guidance on what and when you should report to us.
How we’ll check you’re meeting our expectations
We may ask you about safeguarding when you apply and after you get funding
Including how you meet our safeguarding expectations.
If you have funding, and we’re concerned you’re not meeting our expectations
We may meet with you to understand what has happened and discuss the next steps. It is important that you cooperate with us.
If we have serious concerns we may have to suspend your funding while we find out more information. Suspending funding is something we rarely do. We would always discuss this with you and consider the impact on your organisation and the people you support.
What and when you should report to us (if you have funding)
Before contacting us, take action to ensure the safety of everyone involved
This also applies to any partners you are working with.
Then report serious safeguarding incidents to us within 10 working days
Or sooner if you can. You should tell whoever is your normal contact at the National Lottery Community Fund. We’d normally expect you to do this once you decide you may need to investigate the incident, or refer it to the authorities or regulator.
What we mean by serious safeguarding incidents
We mean any safeguarding incident that is not routine for your organisation. This includes confirmed or alleged incidents.
Depending on the type of organisation you are you may have safeguarding incidents regularly. We understand this and only expect you to report serious incidents.
You must let us know if there’s an incident that:
- is not routine for you, or
- might be reported to an authority (like the police), or
- might lead to media coverage.
What you need to tell us when you report an incident
We need to know what has happened and what actions have been taken to keep people safe. In our role as a funder, we would only expect you to share:
- an overview of the incident, leaving out any identifying details of people involved
- a summary of the actions taken and anything you’re planning to do in the future, including whether the incident was reported to the authorities or the regulator
- any learning or recommendations made to prevent similar incidents in the future.
We may ask for updates on ongoing investigations
We know that safeguarding incidents can be complex and take time to resolve. If all the information we need is not available straight away, we may ask you to update us until the incident is resolved.
Find out how we’ll use any information you share
By checking our data protection and privacy notice.
Examples of when to report incidents
We would expect you to report to us if:
- someone who has come in contact with your organisation has been significantly harmed.
- you’re made aware of an allegation relating to safeguarding within your organisation. You think it is likely to attract negative media attention or complaints to regulators and funders.
- a member of staff has been suspended because of a serious safeguarding allegation.
- a beneficiary of your organisation has died or been seriously harmed.
We would not expect you to report to us if:
- there is a safeguarding incident but nobody was significantly harmed. Your organisation has logged it.
- the police are called about a minor incident that took place at your organisation. But there is no further action taken.
Where to get guidance on safeguarding policies and procedures
We do not have the specialist expertise to give you advice on your safeguarding policies and practices. These must be tailored to fit the activities of your organisation.
If you need advice, we recommend:
- NCVO’s guidance on safeguarding policies and procedures
- NSPCC Learning's guide to writing safeguarding policies and procedures
- Ann Craft Trust's guide to writing a safeguarding adults policy and procedure document
- Zurich's guidance on what to include in your charity’s safeguarding policies and procedures
- Scottish Charity Regulator’s (OSCR) safeguarding guidance
- The Charity Commission's guidance on safeguarding for charities and trustees
- The Charity Commission for Northern Ireland's safeguarding resources
- Northen Ireland’s Volunteer NOW safeguarding information.
Definitions of safeguarding terms used on this page
By safeguarding we mean taking steps in your organisation to prevent harm, and responding to incidents and concerns.
Harm can include:
- physical, sexual or emotional harm
- neglect or negligent treatment
- maltreatment
- radicalisation or exploitation
- cyber abuse
- bullying or harassment
- people abusing a position of trust.
Harm can take place in person or online, by any person.
Children means people under the age of 18 years old.
Young adults means people between the ages 18 and 24 years old.
Adults at risk are anyone aged 18 or over who:
- has needs for care and support
- is experiencing, or is at risk of, abuse or neglect and,
- because of those care and support needs is unable to protect themselves from either the risk of, or the experience of, abuse or neglect.
An adult at risk of abuse may:
- have an illness affecting their mental or physical health
- have a learning disability
- be frail
- suffer from drug or alcohol problems.
Your contact means the person at the National Lottery Community Fund who you normally talk to about your funding. Usually they are a funding officer or funding manager.