The Charity Commission is producing guidance that is likely to advise every charity to establish how it comes into contact with vulnerable people.
Protecting children and vulnerable adults is high on the agenda in the UK, as the Independent Inquiry into Child Sexual Abuse rumbles on. It's also of import within the sector, with the Charity Commission announcing in August that it will be making safeguarding a priority in the next year.
The regulator is drawing up new guidance on safeguarding and revising its strategy with the help of an external advisory panel of charities, statutory bodies and umbrella groups working on education and vulnerable beneficiaries.
One of the strongest messages to emerge from the panel, according to its chair Sarah Atkinson, director of policy and communications at the commission, is that all charities, even those not working directly with vulnerable groups, need safeguarding policies. "Many charities don't think safeguarding applies to them," says Atkinson. "But even grant-making bodies, when they're visiting programmes they've funded or might fund, can come into contact with vulnerable people. It's important to be open-minded about the extent to which you need to consider safeguarding."
Cate Meredith, senior consultant for the voluntary and community sector at the NSPCC, often advises charities on safeguarding and says a good safeguarding policy should be the product of collaboration between those within the organisation and those using it. "One of the common mistakes people make is to think it's about giving one person that job and expecting them to sit by themselves and just keep typing until they've got a policy," she says.
Instead, she recommends that trustees, management and stakeholders get together and begin by mapping out what contact they might have with vulnerable people, directly and indirectly, and if they are already doing anything that could be considered safeguarding - notifying parents what time they are expected to collect children from an event, for example.
Charities will often find they are doing more than they realise, she says, but this process will also highlight and allow them to focus on any gaps. But Meredith says a policy document is only the beginning of a process that will take time. "You can't file it away in a folder somewhere and hope it weaves its magic from there - it has to be a lived reality for the organisation," she says.
Safeguarding has to become embedded as part of a normal conversation within the organisation, she says, so staff can spot situations and know how to respond. Ideally, she says, one trustee should lead on safeguarding, but all trustees need to be familiar enough with safeguarding issues and the charity's policy to be able to challenge and scrutinise the charity's work effectively.
And, although it sounds obvious, the policy must be followed, says Atkinson. She says it is common for the commission to find charities that have ignored their own policies, often through lack of awareness.
The policy also needs to be shared with people who use the charity's services, Meredith says, so that if they have concerns they know who to turn to and what response to expect. Atkinson agrees, saying one of the first things the regulator looks for when assessing a charity's safeguarding is whether the policy has been made public.
"Knowing how you would handle the problem isn't the same as making clear to users and workers in your charity what the expectations placed on them are and the consequences if expectations aren't met," she says.
And, where issues do arise, they should be reported to the commission as soon as possible, which will give the commission confidence the charity is dealing with it effectively, she says. "Ultimately, for most organisations, the key is that it's mostly about common sense - it doesn't have to be scary," she says.