Bromley Y is committed to providing a safe and secure environment for young people, staff, students and volunteers. We are committed to promoting a climate where young people and adults feel confident about sharing any concerns that they may have about their own safety or the well being of others.

‘Everybody shares some responsibility for promoting welfare of children, as a parent or family member, a concerned friend or neighbour, an employer, staff member or volunteer. Members of the community can help to safeguard children if they are mindful of children’s needs, and willing and able to act if they have concerns about a child’s welfare.’

Working together to safeguard children, Home Office/DfEE, 1999 Bromley Y operates within the pastoral systems of the referral agencies that it seeks to support, always working in conjunction with existing policies of referring agencies, and the Area Child Protection Committee guidelines & procedures. As such, this policy has been designed in accordance with the relevant legislation and guidelines such as the Protection of Children Act (1999), the Children’s Act (2004), the Safeguarding of Vulnerable Groups Act (2006) and the Protection of Freedoms Act (2012).

We actively accept our responsibility, in conjunction with our partner agencies to protect children and young people from abuse & believe that their welfare is paramount. At Bromley Y we believe that all children without exception have the right to protection from abuse, regardless of gender, ethnicity, disability, sexual orientation or religious beliefs.

Abuse may come to light in a number of ways, including:

• A child/young person may tell you what has happened to them

• From a third party (for example, another young person)

• Through their behaviour

• A suspicious, unexplained injury to the child/young person

These notes are intended to provide a guide to help you identify signs of possible abuse and know what action to take in such cases. Children and Parents should be made aware of this policy and procedures as deemed appropriate. The Main Forms of Abuse The definitions of child abuse recommended as criteria for registration by the Department of Health, “Working Together under the Children Act 1989” are set out below. A basic definition of abuse is that it is the abuse of power by a person who is developmentally older and/or stronger than another, resulting in some distress, harm or neglect of necessary attention for the victim.

Child abuse is a term that describes all the ways in which a child’s development and health are damaged by the actions or inaction of other, usually adults. The following passages describe particular types of abuse, these often overlap and many children suffer the effects of a range of destructive forms of abuse.

Physical Abuse

This is where adults physically hurt or injure children. Hitting, shaking, squeezing, burning and biting are all forms of physical abuse. Giving children alcohol, inappropriate drugs or poison is classified as physical abuse. Attempted suffocation or drowning also comes within this category. “Munchausen Syndrome by Proxy” is when a parent or carer feigns the symptoms of, or deliberately causes, ill health in a child.

Sexual Abuse

This is where adults abuse children to meet their own sexual needs. It involves forcing or enticing a child or young person to take part in sexual activities whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative or non-penetrative acts. They may involve non-contact activities such as showing children pornographic magazines or videos or watching sexual activities, or encouraging children to behave in sexually inappropriate ways.

Organised Abuse

Organised abuse is sexual abuse where there is more than a single abuser and the adults concerned appear to act in concert to abuse children and/or where an adult uses an institutional framework or position of authority to recruit children for sexual abuse.


This is where adults persistently fail to meet a child’s basic physical and psychological needs, likely to result in the serious impairment of the child’s health or development. It may involve a parent or carer failing to provide needs, like food, shelter and appropriate clothing, failing to protect a child from physical harm or danger, or failure to ensure access to appropriate medical care or treatment. Children might also be constantly left alone unsupervised. Sometimes adults fail to, or refuse to, give their children love and affection. It may also include neglect of a child’s basic emotional needs.

Emotional Abuse

This is the persistent ill treatment of a child such as to cause severe and persistent adverse effects on the child’s emotional or behavioural development. It may conveying to children that they are worthless or unloved, inadequate, or valued insofar as they meet the needs of another person. It may involve causing children frequently to feel frightened or in danger. All abuse involves some emotional ill treatment. This category is used where it is the main or sole form of abuse.

Identifying signs of Possible Abuse Recognising abuse is not easy, even for individuals who have experience of working with child abuse. Most children will receive cuts grazes and bruises from time to time and their behaviour may give reason for concern. There may well be other reasons for these factors other than abuse. Any concern should be immediately discussed with a senior colleague to assess the situation.

Warning signs which may alert you to the possibility of abuse can include:

• Unexplained bruising cuts or burns on the child, particularly if these are parts of the body not normally injured in accidents.

• An injury, which a parent or carer tries to hide, or for which they might have given different explanations.

• Changes in behaviour such as the child suddenly becoming very quiet, tearful, withdrawn, aggressive, or displaying severe tantrums.

• Loss of weight without a medical explanation.

• An inappropriately dressed or ill kept child who may also be dirty.

• Sexually explicit behaviour, for instance playing games and showing awareness which is inappropriate for the child’s age.

• Continual masturbation, aggressive and inappropriate sex play.

• Running away from home, attempted suicides, self-inflicted injuries.

• A lack of trust in adults, particularly those who would normally be close to the child.

• Disturbed sleep, nightmares and enuresis, particularly if a child has previously been dry.

• Eating problems, including over-eating or loss of appetite.

Remember, the above signs do not necessarily mean that a child has been abused. If, however, you are concerned about the welfare of a child you must act. Do not assume that someone else will help the child: they might not. Be aware and alert to signs of injury, neglect or distress. Act without delay. Listen to what the young person is saying, but do not quiz them. Reassure the young person that they have not done anything wrong and can be helped. Inform the young person of what will happen next and whom you will need to tell. Make a careful note of what you have noticed or been told. Be discreet. Do not alert the abuser and only share your concerns or information with your designated manager/supervisor at Bromley Y, who will decide the appropriate action to be taken. It is vital that good open communication is maintained between the staff, student or volunteer and their designated supervisor.

Many forms of abuse or neglect are detected over time, following close monitoring through supervision and other mechanisms. The Designated person for child protection at Bromley Y is: CLAIRE ELY. In exceptional circumstances where the staff, student or volunteer is unable to contact their supervisor or a Bromley Y manager and the young person is at immediate risk of serious harm, they should contact Bromley Social Services directly or in an emergency the police child protection team. In such circumstances Bromley Y managers/supervisor should be contacted at the earliest possible opportunity.

• Bromley Social Services 020 8464 3333

• Police Child Protection Team 020 8284 5882

All trustees, staff, volunteers and students recruited by Bromley will be subject to references, and D.B.S checks, following careful interview to screen out potential concerns. All workers will be informed of the Child Protection policy. All staff, students and volunteers will be trained in the implementation of this policy, and enabled to attend Bromley ACPC training. All staff, volunteers and students are expected the treat young people with respect and dignity. Whilst it would be unrealistic to preclude all physical contact between adults and young people, workers are expected to exercise extreme caution and avoid placing themselves in a position where their actions might be open to criticism or misinterpretation. Where incidents occur which might be misconstrued or where it becomes necessary to physically restrain a client for their own or other’s safety, or to comfort an emotionally distressed young person, this will be appropriately recorded and reported to their designated supervisor. All staff, students and volunteers are required to keep regular reports of contact with young people through their work with Bromley Y. In cases involving young people, or adults being at risk of harm, reports will be written in depth and discussed with the Senior Practitioner. For their own safety and protection workers should exercise caution in situations where they are alone with clients. The Senior Practitioner should know where you are meeting. Children & Parents should be made aware of this policy when deemed appropriate. It is, of course, the right of any individual to make direct referrals to the child protection agencies or seek advice from Social Services, although we hope that those involved with Bromley Y will not feel this necessary. If, however, you feel that Bromley Y has not responded appropriately to your concerns, then it is open to you to contact the relevant organisation direct.

This policy is approved and endorsed by the board of trustees and will be reviewed annually at Board level.


What is privacy/ confidentiality for children and young people?

Privacy means that what you tell us is kept as private as possible – it is also known as ‘keeping confidentiality’. The only exception to us keeping confidentiality is if we become concerned about your safety or the safety of others. We will always try to discuss with you who we need to talk to and what we’re going to say, in a supportive and open way.

Usually the person who has asked us to see you and your doctor (GP) will know that you are coming here. It’s up to you whether or not you tell other people that you are coming.

We don’t talk to other people about you without discussing it with you first. Some young people find it helpful to let their school or others know so that people around them are more aware that they are having a difficult time. We can do this for you if you want.

Complaints Procedure

Complaints Policy

Bromley Y will take seriously any complaints made by young people, parents or members of staff from other referral agencies
against a worker. All such concerns will be brought to the attention of the Director and other appropriate persons. Bromley Y will work in conjunction with the complaint procedures of referring agencies. Bromley Y may have a responsibility to suspend any person against whom such a complaint is brought (which should be seen as a neutral act) from working until a complaint/allegation has been investigated.

Procedures for dealing with complaints regarding services provided by Bromley Y

1. Introduction
This procedure is concerned with complaints made against Bromley Y staff, trustees or

2. Principles
2.1 The opportunity to make a complaint or grievance is an essential right for all those who
users the services provided by Bromley Y. Complaints can be a valuable way of evaluating
and improving our services and of ensuring that they remain responsive to the needs and
preferences of service users.
2.2 Bromley Y’s complaints procedure intends to be quick, effective and clear. To ensure
fairness any investigation required will be carried out by someone who was not involved in
any way with the incident relating to the complaint.
2.3 Bromley Y recognises that bringing a complaint can be difficult and stressful.
Assistance will be available to the complainant while information will be provided about
independent advocacy.
2.4 Any member of staff or volunteer against whom a complaint is made will be given the
fullest opportunity to answer any criticisms and assistance and support will also be
available for them if required.
2.5 In situations where a complaint may have financial or legal consequences for Bromley
Y its insurers require Bromley Y to cease direct contact with the complainant. It may then
be necessary, in the best interests of the complainant, to refer them to a third party, both
for assistance with the complaint and to ensure that their service needs are met.
2.6 Bromley Y will respect the confidentiality of both the complainant and any person
complained about, subject to the provisions of Bromley Y’s Confidentiality Policy. This
states that, if a complaint is to be properly investigated and action taken as a result of a
complaint, it may not always be possible to avoid a breach of confidentiality. The
permission of the complainant will be sought for this but when the welfare of the complainant or other people is seriously at risk it may be necessary to breach
confidentiality even if that permission is withheld.
2.7 The outcome of all complaints and investigations will be reported in confidence to the
Trustees and in writing to the complainant. A report on Complaints will also constitute part
of the evaluation of Bromley Y services, as made available to funders of these services.
2.8 Bromley Y will make efforts to ensure that every user of its services is aware that this
procedure exists, through leaflets and other forms of publicity.
When a complaint is received, the Director is to be notified. If the complaint is made
verbally it must subsequently be submitted in writing.

3. Procedure
3.1 1st Stage: discussion with the service user to see if the complaint can be resolved
informally by a member of staff who is not the subject of the complaint.
3.2 2nd Stage: formal complaint in writing, sent as follows:
– Where a complaint is against a member of staff or volunteer, to the Director;
– Where a complaint is against the Director, to the Chair of theTrustees;
– Where a complaint is against a trustee, to the Chair of the Trustees;
– Where a complaint is against the Chair of Trustees, to the Trustees via the Director.
The person who receives the complaint (normally the Director) will carry out an
investigation, or where appropriate, appoint someone else to do so. The investigator will
report the result in writing within three weeks to the complainant and the relevant members
of staff.
3.3 3rd Stage: where the complainant is dissatisfied with the 2nd stage report they can
write to the Trustees asking for the complaint to be referred to this stage. The Director will
set up a panel consisting of third parties who have not previously been involved in the
Complaint, to consider the issues. A service user and a trustee will be included on this
panel. The panel will aim to meet within 28 days.
The complainant and the person or persons against whom the complaint has been made
will be invited to attend the meeting, separately, if preferred. Any such persons may be
accompanied by a friend, supporter, union representative or independent advocate.
The panel will report their decision and any recommendations in writing to the complainant
and any persons against whom the complaint was made within three days.
3.4 Appeal Stage: If the complainant remains dissatisfied after the 3rd Stage they can
request that an independent external adjudicator be appointed. Efforts will be made to
appoint someone acceptable to both sides; however, it is acknowledged that this may not be possible in all cases. The adjudicator will be appointed within four weeks of this request
and will be expected to reach a decision within a further two weeks. The adjudicator’s
decision will be final.
Bromley Y is an organisational member of The British Association for Counselling and
Psychotherapy which has a Complaints Procedure which service users may have recourse
to when they fail to gain a satisfactory result from the full Bromley Y procedure, as outlined

4. Review 
This policy will be reviewed annually at board level.