Purpose and Scope

Hampshire Cultural Trust (HCT) was established as an independent charity in 2014 to promote Hampshire as a county that offers outstanding cultural experiences to both its residents and visitors that were previously operated by Hampshire County Council and Winchester City Council.

From museums to galleries and art centres, we manage 23 attractions across the county and run a varied programme of exhibitions, workshops, classes, events and projects for both young and old, in schools and in communities, with particular emphasis on reaching people who are vulnerable or disadvantaged and would not normally be able to access arts and culture. It is imperative that we do all we can to ensure that the experience of children and adults with whom we have contact is safe and free from harm. This is also a requirement of the bodies that fund us including Hampshire County Council as well as a requirement of the Charity Commission.

Child and adult abuse can have severe consequences including serious injury, disability, threats to survival or even death. It can affect a person’s development, mental health, ability to form relationships including parenting, confidence or achievements. It has huge personal and economic consequences for the individual, their family, community and society.

HCT also has a duty of care to those that work for the trust or on its behalf. The safeguarding policy, procedures and code of conduct all will serve to protect team members and service users as well as preserve the reputation and brand of HCT.

It is the responsibility of staff, volunteers, trustees, partners and freelancers to act if there is cause for concern about the welfare of a child or adult at risk (see Appendix 1 for Terminology).  It is not the responsibility of team members to determine if abuse has occurred or what protective action is required.  It is however the responsibility of HCT’s designated safeguarding staff or the designated safeguarding staff in organisations where we are working in a partnership agreement, to decide whether to escalate a concern to the appropriate authority.

Our Commitment

We believe that:

  • All children and adults at risk have an equal right to protection from abuse and neglect, regardless of their age, ability, gender, disability, nationality, racial heritage, faith, sexual orientation, identity or any other additional vulnerability.
  • The law requires that the best interests of the child are paramount in all considerations about their welfare and protection, including when to maintain confidentiality and when to share information about them.
  • The entire staff contingent, volunteers, partners and freelancers all have a role to play in safeguarding children and adults at risk.
  • Concerns or allegations that HCT staff or volunteers or freelancers have abused or neglected a child or adult should be managed fairly in accordance with this policy, relevant legislation and local safeguarding procedures.
  • Working together with Hampshire County Council, other relevant authorities and organisations is essential in promoting welfare and ensuring the protection of children and adults at risk.
  • As part of working together, HCT expect the relevant authorities and organisations to act on our concerns. If ever we have concern that this has not been done satisfactorily, we will escalate the matter further.


Whilst HCT trustees are ultimately responsible for safeguarding arrangements, with the support of the leadership team (LT), we have also identified specific staff to embed this policy and procedures (see Appendix 2):

  • A safeguarding manager who takes a lead responsibility for safeguarding implementation assisted by the other heads of department
  • Designated safeguarding officers to whom any safeguarding concerns or allegations should be reported to

We expect all staff, volunteers and anyone else working on our behalf to take safeguarding seriously, know who to report concerns on to, uphold the code of conduct, follow the safeguarding procedures when necessary and follow the procedures for safer recruitment and vetting where this is part of their role.

Our approach

We will create an environment that seeks to prevent and deter any actions or omissions, whether deliberate or inadvertent, that places children or adults at risk of any kind of abuse. Therefore, we will:

  • Value, listen to and respect children and adults at risk in all our activities
  • Provide a code of conduct for staff and volunteers which links to our capability and disciplinary procedures and volunteer issue resolution policy and procedures respectively
  • Provide reporting procedures to follow when anyone identifies a safeguarding concern or allegation
  • Use safer recruitment, selection and vetting processes to ensure suitable staff, freelancers and volunteers are recruited to work in premises and activities where there are children or adults at risk (see Safer Recruitment and Selection Policy).
  • Establish a safeguarding governance structure with assigned roles and responsibilities (see Appendix 2)
  • Provide staff and volunteers with induction, regular training and support appropriate to their safeguarding role and responsibilities
  • Risk assess venues, events and activities with respect to safeguarding
  • Ensure our online work is conducted safely with appropriate controls in place
  • Ensure that licensing requirements for children engaged in performance are adhered to when required
  • Prevent our end users being exposed to inappropriate material in exhibitions, events or workshops
  • Communicate our safeguarding policy and procedures to all relevant stakeholders and beneficiaries
  • Ensure safeguarding requirements are in place for those that work with us including our partners, hirers and freelancers
  • Capture, use and store images consistent with safeguarding and data protection requirements
  • Provide a safe and trusted culture so that staff and volunteers can express any concerns they have about the conduct of others or unsafe working practices
  • Quality assure our safeguarding practice to draw out lessons learnt
  • Review the safeguarding policy, procedures and code of conduct every three years or sooner if required due to legal changes or learning from safeguarding incidents

Law and guidance

Our safeguarding policy and procedures are underpinned by English legislation and statutory guidance which includes:

UN Convention on the Rights of the Child 1991

Protection of Freedoms Act 2012

Data Protection Act 2018 and the GDPR 2018

HM Government (2018) Working Together to Safeguard Children

Children Act 1989 and 2004

Counter Terrorism and Security Act 2015

Care Act 2014

Female Genital Mutilation Act 2003

Mental Capacity Act 2005

Charity Commission safeguarding guidance 2018

Sexual Offences Act 2003

Serious Crime Act 2015

Modern Slavery 2015

Safeguarding Vulnerable Groups Act 2006

Children (Performances and Activities) (England) Regulations 2014

Child performance and activities licensing legislation in England, 2015


Appendix 1: Safeguarding Terminology

For the purposes of this policy and related procedures, the following terms and definitions apply:


a form of maltreatment of a child or adult. Somebody may abuse or neglect a child or adult by inflicting harm, or by failing to act to prevent harm. Children or adults may be abused in 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. They may be abused by an adult or adults, or another child or children.


Legally, a child includes babies, children and young people from pre-birth up to 18 years. The fact that a young person has reached the age of 16, is living independently or is in further education, is a member of the armed forces, is in hospital or in custody does not change his/her entitlement to protection.

Adults at risk

Any person who is aged 18 years or over and who is at risk of abuse or neglect because of their needs for care and support’ (Care Act 2014 [England]). Some organisations are still using the term “vulnerable adult” however we will use the terminology ‘adult at risk’ as this focuses our attention on the risks that people face rather than any inherent vulnerability and is also in line with the terminology used in the Care Act 2014.

Safeguarding and promoting the welfare of children

This means protecting children from maltreatment; preventing harm to children’s health or development; ensuring children grow up with the provision of safe and effective care; and taking action to enable children to have the best outcomes.

Child or adult protection

This is part of safeguarding and promoting welfare. It refers to the activity that is undertaken to protect specific children or adults who are suffering, or at risk of suffering, significant harm. Different types of abuse (e.g. physical, emotional, sexual or neglect) may constitute significant harm. More details about these forms of abuse are presented in the accompanying procedures for this policy.

Early identification and help

Statutory guidance[1] stresses the importance of children and adults having the opportunity of early help and support to avoid child or adult protection intervention later. Early identification and help or intervention may consist of one or more professionals supporting a child, adult or family once an assessment of needs has been made. 

Appendix 2: Safeguarding roles and responsibilities

Board of Trustees

  • Hold ultimate responsibility for safeguarding across HCT
  • Ensure safeguarding policies, procedures and a code of conduct are in place and understood
  • Ensure the necessary checks are done on staff, freelancers, volunteers and trustees
  • Set out risks and the management of them in a risk register which is regularly reviewed
  • Promote a culture and environment whereby staff, volunteers and freelancers are empowered to raise concerns and feel supported in their safeguarding role
  • Carry out proper due diligence when HCT works with other bodies to achieve their aims
  • Comply with the Charity Commission serious incident notification requirements[2]
  • Receive and review regular feedback on safeguarding activity, issues and remedial action from the ELT

Chief Executive and Leadership Team (LT)

  • Take overall responsibility for ensuring that robust safeguarding policy and procedures are in place
  • Monitor effectiveness and compliance with the policy and procedures
  • Take account of safeguarding risks in any new business ventures and projects


  • Ensure that safer recruitment and vetting policies and procedures are in place for relevant staff, volunteers and freelancers
  • Assist in the management of safeguarding allegations and disciplinaries involving safeguarding matters
  • Ensure internal procedures such as disciplinary, complaints and whistleblowing link to the safeguarding policy and procedures
  • Ensure that there is provision for safeguarding training for staff and volunteers appropriate to their roles and responsibilities

Designated Safeguarding Manager (DSM)

  • Takes responsibility for the overall implementation of the safeguarding policy and procedures and its review
  • Provides support and advice to the designated safeguarding officers
  • Oversees the management of safeguarding allegations against staff, volunteers and freelancers
  • Briefs the board of trustees on safeguarding activity and issues on a regular basis and produces an annual report on safeguarding
  • Keeps abreast of changes in safeguarding law and best practice

This role will be undertaken the Head of Community, Deborah Neubauer.

Designated Safeguarding Officers (DSOs)

  • Provide advice and support on safeguarding matters for staff and volunteers
  • Make referrals to police or social care when necessary
  • Ensure that all partnership arrangements/contracts/projects have the necessary safeguarding requirements and arrangements in place
  • Alerts the Learning and Development Manager to safeguarding training needs
  • Keeps abreast of changes in safeguarding law and best practice
  • Undertakes duties delegated by the designated safeguarding manager

[1] HM Government (2018) Working Together to Safeguard Children

[2] Trustees should make a report to the Charity Commission if any of the following occur:

  • beneficiaries of HCT (adults or children) have been, or alleged to have been, abused or mistreated while under the care of the HCT, or by someone connected with it, for example a trustee, staff member or volunteer
  • there has been an incident where someone has been abused or mistreated (alleged or actual) and this relates to the activities of the HCT
  • there has been a breach of procedures or policies at HCT which has put beneficiaries at risk, including failure to carry out checks which would have identified that a person is disqualified in law, under safeguarding legislation, from working with children or adults.
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