Safeguarding and Protection Policy

A Biblical and Practical Framework for Protecting Children, Adults at Risk, Workers and the Church Community

• Church: Spirit of Life Reformed Baptist Church
• Working Draft — Version 1.0
• Jurisdiction: England
• Policy Owner: Charity Trustees

Safeguarding Statement

“Defend the poor and fatherless: do justice to the afflicted and needy. Deliver the poor and needy.”

Psalm 82:3–4

Spirit of Life Reformed Baptist Church is committed to providing an environment in which children, young people, adults at risk, members, visitors, employees and volunteers are treated with dignity and protected from abuse, exploitation, neglect and improper use of authority.

Safeguarding is not merely the Church's response after serious harm has occurred.

It includes the ordinary habits, boundaries, recruitment decisions, supervision, accountability and culture by which the Church seeks to reduce opportunities for harm before it occurs.

Accordingly:

The reputation of the Church, the reputation of a leader, fear of scandal, concern about litigation, family relationships, financial consequences, institutional loyalty, or a desire to resolve a matter privately shall never take precedence over the protection of a child or adult at risk.

The Church shall not use:

• forgiveness;
• reconciliation;
• church unity;
• confidentiality;
• submission;
• pastoral authority;
• church discipline;
• or concern for Christian witness

as reasons for concealing abuse, discouraging legitimate reporting, preventing statutory agencies from becoming involved, or restoring a person prematurely to a position of trust.

Forgiveness does not remove accountability.

Repentance does not automatically restore suitability for ministry.

Reconciliation is not, by itself, a safeguarding outcome.

Where safety requires continuing boundaries, those boundaries may remain even where genuine repentance and forgiveness have occurred.

Current Charity Commission guidance treats safeguarding as a governance priority, requires trustees to take reasonable steps to protect everyone who comes into contact with a charity, and expects an open culture in which concerns can be raised and responded to. Trustees retain overall responsibility even where operational safeguarding duties are delegated. (GOV.UK)

Part I — Foundations

1. Purpose

The purposes of this policy are:

1. to establish a culture in which safeguarding is understood as part of ordinary Christian conduct rather than merely a crisis procedure;
2. to establish clear behavioural expectations for leaders, workers and volunteers;
3. to reduce opportunities for abuse, grooming, exploitation and boundary violations;
4. to make unhealthy behaviour easier to notice and report at an early stage;
5. to establish clear routes for responding to concerns and disclosures;
6. to ensure that no person controls a safeguarding concern involving themselves or someone with whom they are materially conflicted;
7. to provide appropriate pathways to statutory safeguarding agencies, police, the Disclosure and Barring Service and the Charity Commission;
8. to protect those who raise genuine concerns in good faith;
9. to provide fair treatment for persons against whom allegations are made;
10. to ensure that safeguarding failures are examined and learned from rather than concealed.

This policy is intended to be understood and used, not simply filed.

The Charity Commission expects safeguarding policies to be put into practice, made known to those who need them, reviewed at least annually and after serious incidents, and supported by a clear code of conduct. (GOV.UK)

2. Biblical Foundation

2.1 Human Dignity

Every human being is made in the image of God and is therefore to be treated with dignity.

Children, those who are frail, those experiencing disability, illness, abuse, dependency or distress must never be treated as less worthy of protection because they possess less social, physical or institutional power.

2.2 Leadership is Stewardship

Christian leadership is not ownership.

Christ entrusts His people to shepherds; He does not give shepherds permission to possess, manipulate or exploit them.

Those who teach and lead carry greater responsibility, not greater freedom from accountability.

“Neither as being lords over God's heritage, but being ensamples to the flock.”

1 Peter 5:3

2.3 Protection of the Vulnerable

Scripture repeatedly requires God's people to protect those who may be easily mistreated, ignored or overpowered.

Safeguarding therefore belongs naturally within Christian discipleship.

It is not a secular inconvenience attached to ministry.

2.4 Truth and Justice

Christian love does not require wrongdoing to be hidden.

Truth, justice, mercy and protection belong together.

A desire to protect a person's reputation must never result in another person's safety being compromised.

3. The Church's Safeguarding Culture

The Church seeks to create a culture in which:

• children know that they may speak;
• parents know whom to approach;
• adults at risk are treated as persons rather than problems;
• volunteers may report concerns about leaders;
• leaders are open to appropriate scrutiny;
• concerns are recorded rather than carried merely in memory;
• nobody is regarded as “too respected” to be questioned;
• reasonable boundaries are treated as wisdom, not insult;
• poor behaviour can be addressed before it becomes serious abuse;
• external safeguarding agencies are treated as legitimate partners rather than threats to the Church.

The Charity Commission specifically identifies poor organisational culture, weak accountability and abuse of positions of trust as safeguarding risks and expects trustees to ensure people know how to recognise, respond to, report and record concerns. (GOV.UK)

4. Scope

This policy applies to:

• Charity Trustees;
• Elders;
• Deacons;
• employees;
• children's and youth workers;
• ministry leaders;
• volunteers;
• visiting ministry workers where appropriate;
• anyone acting on behalf of the Church;
• Church activities taking place on Church premises;
• Church activities elsewhere;
• online ministry conducted by or on behalf of the Church.

It concerns the protection of:

• children and young people under 18;
• adults at risk;
• members;
• volunteers;
• employees;
• visitors;
• and others who come into contact with the Church through its activities.

Working Together to Safeguard Children 2026 expressly applies in England to voluntary, charity and faith-based organisations with functions relating to children. (GOV.UK)

5. Important Definitions

Child

A person under 18 years of age.

Adult at Risk

For the purposes of statutory adult safeguarding in England, an adult aged 18 or over who:

• has needs for care and support, whether or not those needs are currently being met;
• is experiencing or at risk of abuse or neglect;
• and, because of those needs, is unable to protect themselves from the abuse or neglect or risk of it.

This reflects the Care Act framework. (GOV.UK)

A person does not cease to deserve protection merely because they do not meet that statutory definition. Other concerns may still require pastoral, employment, police or other action.

Safeguarding Concern

Information or behaviour giving reasonable cause to consider whether a person may have been harmed, may be at risk of harm, or whether someone's behaviour may present a safeguarding risk.

Proof is not required before a concern may be reported.

Allegation

Information that a person who works or volunteers with children may have:

• harmed or possibly harmed a child;
• committed a relevant offence concerning a child;
• behaved in a way suggesting they may pose a risk of harm;
• or behaved in a way suggesting they may not be suitable to work with children.

This reflects the current Bristol LADO threshold. (Bristol Safeguarding)

Low-Level Concern

Behaviour by a Church worker or volunteer that does not presently appear to meet the threshold of an allegation requiring statutory management but:

• is inconsistent with this policy or Code of Conduct;
• causes unease;
• shows poor boundaries;
• could form part of a concerning pattern;
• or would reasonably merit being recorded and reviewed.

“Low-level” describes the apparent threshold, not the importance of recording it.

Spiritual Abuse

For the purpose of this Church policy, spiritual abuse means the misuse of religious or spiritual authority, teaching, office, Scripture, discipline or claims of divine approval in order to control, intimidate, manipulate, exploit, silence or improperly dominate another person.

It may include:

• claiming divine authority for personal preferences;
• threatening God's judgement to compel improper obedience;
• using church discipline to silence legitimate safeguarding concerns;
• manipulating confession or pastoral disclosure;
• demanding secrecy;
• equating disagreement with rebellion against God;
• using Scripture selectively to maintain coercive control.

Not every exercise of pastoral authority, disagreement, rebuke or Church discipline is spiritual abuse.

The issue is misuse of authority and coercion, not merely the existence of authority.

6. Safeguarding Is Not the Same as Church Discipline

The Church shall distinguish between:

Sin or Pastoral Concern

A matter requiring pastoral counsel, discipleship, correction or ordinary Church discipline.

Boundary or Conduct Concern

Behaviour inconsistent with expected standards but not presently indicating abuse.

Safeguarding Concern

Information suggesting actual or potential harm.

Allegation Against a Worker

A concern meeting or potentially meeting the relevant statutory allegations threshold.

Crime or Immediate Danger

A matter requiring emergency or police intervention.

These categories may overlap.

A serious safeguarding matter may also be a matter of sin and Church discipline.

However:

Church discipline shall never replace safeguarding action that ought properly to involve statutory authorities.

The Church is not the police, children's social care, adult safeguarding authority or criminal court.

Part II — Governance and Responsibility

7. Trustee Responsibility

The Charity Trustees carry overall governance responsibility for safeguarding.

They shall ensure that:

• this policy remains appropriate;
• suitable safeguarding leadership exists;
• sufficient resources are provided;
• safer recruitment operates;
• safeguarding training is maintained;
• safeguarding appears regularly on Trustee agendas;
• significant safeguarding risks are reflected within the Church risk register;
• allegations and serious incidents are reported externally where required;
• lessons from incidents are implemented.

Delegating safeguarding activity to a DSL does not transfer away Trustee responsibility. (GOV.UK)

8. Safeguarding Leadership Structure

The Church shall ordinarily appoint:

Designated Safeguarding Lead — DSL

Name

Contact

Deputy Safeguarding Lead

Name

Contact

Safeguarding Trustee

Name

Contact

The roles may overlap only where doing so does not create an unsafe concentration of responsibility.

Where practicable, safeguarding arrangements should not depend entirely upon the Lead Pastor or a single family.

9. The Designated Safeguarding Lead

The DSL shall:

• receive and record safeguarding concerns;
• provide initial procedural guidance;
• make or coordinate external referrals where appropriate;
• maintain secure safeguarding records;
• liaise with statutory agencies;
• oversee safeguarding training;
• assist with safer recruitment;
• monitor patterns of low-level concerns;
• support ministry leaders in risk assessment;
• report appropriately to Trustees without unnecessary disclosure of confidential information.

The DSL does not determine whether criminal abuse has occurred.

The DSL coordinates safeguarding action; statutory agencies investigate matters within their jurisdiction.

10. Independent Escalation

No safeguarding system is adequate if the person accused controls the reporting route.

Accordingly:

Concern involving the DSL

Report to the Deputy DSL or Safeguarding Trustee.

Concern involving the Deputy DSL

Report to the DSL or Safeguarding Trustee.

Concern involving the Pastor or an Elder

The Pastor or Elder concerned shall take no part in deciding how the safeguarding concern is handled.

Concern involving a Trustee

That Trustee shall withdraw from governance decisions concerning the matter.

Concern involving a spouse, close family member or other materially connected person

The conflicted person shall not lead, investigate or determine the response.

Several senior leaders implicated

Where internal independence cannot reasonably be maintained, the remaining unconflicted Trustees shall obtain independent safeguarding assistance and make necessary referrals directly to external agencies.

All internal routes compromised

Any person may contact the relevant statutory authority or police directly.

Nobody is required to obtain permission from Church leadership before reporting suspected abuse or criminal conduct to an appropriate authority.

11. Responsibilities of All Workers

Every person serving in a relevant Church role shall:

• know how to raise a safeguarding concern;
• comply with the Code of Conduct;
• maintain appropriate boundaries;
• attend required training;
• report concerns promptly;
• cooperate with safeguarding procedures;
• not conduct their own investigation;
• not destroy or conceal evidence;
• not retaliate against a person raising a concern.

Part III — Prevention and Safer Ministry

12. Safer Recruitment

Safeguarding begins before someone enters ministry.

No person shall be placed into substantial responsibility for children or adults at risk merely because:

• they are a long-standing member;
• they are related to a leader;
• they appear spiritually mature;
• they have served elsewhere;
• there is an urgent shortage of workers;
• or “everyone knows them”.

Trust and screening serve different purposes.

13. Recruitment Process

Roles involving significant safeguarding responsibility should ordinarily include:

1. clear role description;
2. application or expression of interest;
3. discussion/interview concerning suitability;
4. appropriate references;
5. consideration of relevant gaps or concerns;
6. DBS eligibility assessment;
7. appropriate DBS check where legally eligible;
8. safeguarding induction;
9. acknowledgement of the Code of Conduct;
10. an initial supervised or supported period.

Existing workers should not be permanently exempted from safer recruitment standards merely because they began serving before this policy existed.

The Charity Commission recommends combining DBS checks with references, interviews and other suitability checks rather than treating a DBS certificate as a complete safeguarding assessment. (GOV.UK)

14. DBS Checks

The Church shall determine the appropriate DBS check according to the actual activities carried out, not merely the job title.

Roles in places of worship may be eligible for enhanced checks and, where statutory conditions are satisfied, Children's Barred List checks—for example certain regular teaching, care, supervision, pastoral guidance and driving activities involving children. (GOV.UK)

The Church shall therefore:

• assess each role;
• use current DBS eligibility guidance;
• record the level of check determined;
• reassess when responsibilities materially change;
• not request a level of check to which the role is not legally entitled.

DBS law and eligibility can change. In 2026, for example, legislation was enacted changing regulated-activity rules, including removal of the supervision exemption from 1 September 2026. This is precisely why this policy does not permanently hard-code historic DBS assumptions. (GOV.UK)

15. DBS Does Not Equal Safety

A clear DBS certificate means only that the particular check did not reveal information preventing or materially affecting appointment.

It does not prove that a person is safe.

Safeguarding therefore also depends upon:

• observation;
• accountability;
• culture;
• boundaries;
• supervision;
• willingness to challenge behaviour;
• and prompt reporting of concerns.

16. Training

Appropriate safeguarding training shall be provided according to responsibility.

All Relevant Volunteers

Basic recognition, response, reporting, Code of Conduct and boundaries.

Children's and Youth Leaders

Additional child-protection, disclosure, digital and activity-specific training.

DSL and Deputy

More advanced safeguarding and referral training suitable to their responsibilities.

Trustees

Governance safeguarding responsibilities, external reporting and institutional risk.

Pastor/Elders

Pastoral boundaries, domestic abuse, spiritual abuse, confidentiality and escalation.

The Charity Commission expects regular training for those working with children and adults at risk and expects Trustees to oversee the effectiveness of safeguarding arrangements. (GOV.UK)

Part IV — Church Safeguarding Code of Conduct

17. General Standard

Every person serving in the Church shall seek to behave in a way that is:

• visible;
• accountable;
• appropriate;
• respectful;
• non-coercive;
• and capable of reasonable explanation.

A useful question is:

Would I be comfortable for a parent, another worker or the safeguarding team to know exactly what happened?

If not, the behaviour should ordinarily not occur.

18. Prohibited or Unsafe Behaviour

Church workers shall not:

• engage in sexualised behaviour with children;
• make sexualised jokes or comments to children;
• deliberately expose children to sexual material;
• cultivate secret relationships;
• ask children to conceal contact from parents or safeguarding personnel;
• seek inappropriate emotional dependency;
• use gifts or special privileges to cultivate exclusivity;
• threaten children into silence;
• use humiliation as discipline;
• use corporal punishment on behalf of the Church;
• consume illegal drugs while responsible for Church activities;
• be impaired by alcohol while responsible for children;
• take inappropriate photographs;
• engage in unnecessarily private digital communication;
• deliberately create opportunities for unsupervised access contrary to this policy.

19. Favouritism and Grooming Behaviour

Workers should avoid creating “special” relationships characterised by:

• disproportionate private attention;
• repeated one-to-one contact;
• gifts;
• secrecy;
• emotional exclusivity;
• unnecessary transport;
• private messaging;
• bypassing parents;
• physical familiarity;
• or encouraging a child to see the worker as the only person who truly understands them.

None of these behaviours necessarily proves abuse when seen alone.

Patterns matter.

Concerns should therefore be reported early rather than waiting until serious abuse can be proven.

Part V — Working Safely With Children and Young People

20. Supervision

Where the Church formally takes responsibility for children during an activity, there should ordinarily be at least two authorised workers present or readily accountable to one another.

The Church shall not create rigid numerical ratios pretending that one number is universally safe.

Appropriate staffing shall instead consider:

• children's ages;
• number of children;
• disabilities or additional needs;
• venue;
• activity;
• duration;
• toilet arrangements;
• transport;
• whether parents remain present;
• and foreseeable risks.

A written activity risk assessment should be used where circumstances warrant it.

21. One-to-One Situations

Unnecessary private isolation of one adult and one child should be avoided.

Where a legitimate one-to-one conversation is appropriate:

• another responsible adult should know it is taking place;
• the location should ordinarily be visible or interruptible;
• doors should remain open or glazed where appropriate;
• parents should normally be aware of planned continuing pastoral contact;
• the meeting should occur for a proper ministry purpose.

A child who spontaneously asks for help should not be ignored simply because another worker is not immediately present.

The worker should respond appropriately, then bring the conversation within proper safeguarding accountability as soon as reasonably possible.

22. Pastoral Conversations With Young People

Young people sometimes need to discuss matters they do not feel able immediately to discuss with parents.

Pastoral care may therefore involve some degree of privacy.

Privacy does not mean secrecy.

The young person should be told that information may need to be shared where:

• they or another person may be at risk;
• abuse is disclosed;
• serious criminal conduct is involved;
• or safeguarding action is necessary.

Workers shall never promise absolute confidentiality.

23. Physical Contact

Physical contact with children shall be:

• appropriate to the circumstances;
• proportionate;
• non-sexual;
• respectful;
• responsive to the child's age, wishes and needs;
• and ordinarily visible to others.

Workers should not demand affection.

A child should not be shamed for declining a hug or other contact.

Where a young child legitimately needs comfort or physical care, sensible care should be given without turning safeguarding boundaries into coldness.

24. Toileting and Personal Care

Where children require toileting, nappy-changing or other personal assistance:

• parental expectations should be clear;
• privacy and dignity should be preserved;
• workers should avoid unnecessary isolation;
• personal care should be appropriate to the child's needs;
• unusual incidents or concerns should be recorded.

Where parents remain on site and can reasonably provide intimate personal care, they should ordinarily do so.

25. Discipline of Children

Church discipline of children within ministry activities shall be:

• calm;
• proportionate;
• age-appropriate;
• non-humiliating;
• non-violent.

Workers may set boundaries, redirect behaviour, separate children where necessary for safety and involve parents.

They shall not:

• strike children;
• intimidate them spiritually;
• threaten abandonment;
• publicly shame them;
• or use punishment designed to frighten rather than correct.

26. Children With Additional Needs

Children should not be excluded merely because safeguarding their participation requires additional planning.

Where a child has:

• disability;
• communication difficulty;
• medical need;
• sensory need;
• behavioural need;
• or another additional requirement,

the Church should work with parents or carers to establish reasonable and safe arrangements.

Workers should recognise that communication difficulties or dependency can increase vulnerability and may require particular care when recognising signs of abuse.

Part VI — Digital and Online Safeguarding

27. General Principle

Digital ministry is real ministry and therefore requires real boundaries.

The same standards governing face-to-face contact apply to:

• WhatsApp;
• SMS;
• social media;
• email;
• video calls;
• gaming platforms;
• Church apps;
• and future communication systems.

Charity Commission guidance specifically requires charities to manage online risks concerning content, contact, conduct, personal data and images. (GOV.UK)

28. Messaging Children

Church workers should ordinarily communicate with children through:

• a parent or guardian;
• a Church-managed group;
• a ministry channel involving more than one authorised adult;
• or another transparent arrangement.

Routine private one-to-one messaging should be avoided.

Where a young person sends a private message unexpectedly:

• the worker should not simply ignore a safeguarding disclosure;
• respond appropriately;
• avoid developing a private ongoing channel;
• transfer further communication into an accountable setting;
• report safeguarding content where necessary.

Messages should never be deleted in order to conceal a conversation.

29. Social Media Boundaries

Workers should exercise particular caution regarding:

• private accounts;
• disappearing-message functions;
• direct messages;
• late-night communication;
• sending photographs;
• commenting on physical appearance;
• and the sharing of personal or sexual content.

A Church worker's personal account does not make inappropriate ministry contact private from safeguarding expectations.

30. Online Meetings

Where children participate in online Church activities:

• approved platforms should be used;
• access should be reasonably controlled;
• workers should understand platform safety features;
• private breakout contact should be appropriately managed;
• recording should occur only where authorised.

Part VII — Images, Photography and Livestreaming

31. Images of Children

The Church shall obtain appropriate permission before intentionally publishing identifiable images of children.

The Charity Commission advises charities to manage online images carefully and obtain appropriate individual or parental permission where required. (GOV.UK)

Workers shall not:

• photograph children in toilets or changing circumstances;
• take images intended to embarrass;
• use Church access to build personal collections of children's photographs;
• privately distribute images contrary to consent.

32. Livestreaming

Where Church services are livestreamed:

• parents should be informed that filming occurs;
• camera positioning should seek to avoid unnecessary close-up exposure of children;
• safeguarding restrictions concerning a particular child or family shall be respected;
• recordings should be administered through authorised Church accounts.

Part VIII — Transport, Trips and Residential Activities

33. Transport

Where workers transport children on behalf of the Church:

• the driver must be legally entitled and appropriately insured;
• vehicle arrangements must be safe;
• parents must know the transport arrangements;
• seat-belt and child-restraint requirements must be followed;
• unnecessary repeated one-adult/one-child journeys should be avoided.

Where a lone journey cannot reasonably be avoided, parents should know and agree to the arrangement and reasonable accountability should exist.

34. Trips

For activities away from normal premises, leaders should consider:

• consent;
• emergency contacts;
• medical information;
• travel;
• supervision;
• venue risks;
• first aid;
• accessibility;
• lost-child arrangements;
• emergency plans.

35. Overnight Activities

Residential activities require enhanced planning.

Workers responsible for children overnight must have the appropriate safeguarding checks for the actual role.

Current DBS guidance specifically recognises overnight care, supervision and relevant teaching/guidance as activities capable of triggering enhanced checks and barred-list eligibility. (GOV.UK)

Sleeping and changing arrangements shall preserve privacy and minimise opportunities for abuse.

Adults shall not ordinarily share beds with children who are not their own.

Part IX — Adults at Risk

36. Principle

Adults should be protected without unnecessarily removing their autonomy.

Adult safeguarding should therefore seek both:

safety and empowerment.

The Care Act safeguarding framework emphasises empowerment, prevention, proportionality, protection, partnership and accountability. (GOV.UK)

37. Forms of Adult Abuse

Safeguarding concerns may include:

• physical abuse;
• sexual abuse;
• psychological or emotional abuse;
• financial or material abuse;
• neglect;
• discriminatory abuse;
• organisational abuse;
• domestic abuse;
• modern slavery;
• self-neglect;
• coercion;
• exploitation.

Bristol's current adult safeguarding arrangements use the Care Act criteria and recognise these forms of abuse. (Bristol City Council)

38. Consent and Adult Safeguarding

Where an adult has capacity, their wishes should ordinarily be central to safeguarding decisions.

Where practicable, consent should be sought before taking safeguarding action.

However, action may still be necessary where, for example:

• others are at risk;
• coercion prevents free decision-making;
• the adult lacks relevant capacity;
• a serious crime has occurred;
• or wider public protection considerations apply.

This reflects the Care Act approach. (GOV.UK)

39. Pastoral Dependency

Particular caution is required where an adult becomes heavily dependent upon:

• a Pastor;
• Elder;
• counsellor;
• ministry worker;
• carer;
• or another Church member.

Pastoral care must seek maturity and support, not ownership.

A worker shall not exploit pastoral dependency for:

• sexual relationships;
• money;
• gifts;
• housing;
• labour;
• personal loyalty;
• business advantage;
• or emotional gratification.

40. Financial Exploitation

A Church leader or worker shall not use spiritual or pastoral influence to pressure an adult into:

• making donations;
• changing a will;
• making a loan;
• providing accommodation;
• transferring property;
• employing a leader or relative;
• purchasing goods or services;
• or making another substantial financial decision.

Where a Church officer becomes aware that they may benefit personally from a vulnerable person's financial decision, they must declare the conflict and remove themselves from influence over it.

This section operates alongside the Financial Controls and Stewardship Policy.

Part X — Domestic Abuse

41. Domestic Abuse Is a Safeguarding Matter

The Church recognises domestic abuse as potentially involving:

• physical abuse;
• sexual abuse;
• threatening behaviour;
• controlling or coercive behaviour;
• economic abuse;
• psychological or emotional abuse.

The Domestic Abuse Act framework also recognises children as victims in their own right where they see, hear or experience the effects of domestic abuse and meet the statutory relationship criteria. (GOV.UK)

42. The Church Shall Not Require an Abuse Victim to Remain Unsafe

Pastoral teaching concerning:

• marriage;
• forgiveness;
• reconciliation;
• headship;
• submission;
• Church membership;
• or divorce

shall never be used to require a person to remain in immediate danger or to obstruct access to police, safeguarding agencies, medical help, legal advice or specialist domestic-abuse support.

Safeguarding immediate safety and determining the longer-term theological or marital questions are distinct matters.

43. Joint Pastoral Meetings

Where domestic abuse or coercive control is suspected, automatically placing both parties together for marital counselling or confrontation may increase danger.

The Church shall therefore consider safety before arranging joint meetings.

The alleged victim's disclosures shall not automatically be passed to the alleged perpetrator without appropriate consideration of risk.

Part XI — Spiritual Abuse and Misuse of Church Authority

44. Authority Has Boundaries

The Church believes in genuine biblical pastoral authority.

For that very reason, misuse of that authority must be recognised.

Pastoral authority does not permit a leader to:

• demand personal loyalty beyond legitimate Church authority;
• compel secrecy concerning wrongdoing;
• threaten safeguarding reporters;
• control lawful family relationships improperly;
• demand access to private communications without proper reason;
• manipulate vulnerable people for financial or personal benefit;
• claim that reporting wrongdoing to statutory authorities is inherently rebellion against the Church.

45. Church Discipline and Safeguarding

A safeguarding reporter shall not be threatened with Church discipline merely for:

• raising a concern in good faith;
• contacting a statutory safeguarding authority;
• contacting police;
• cooperating with a safeguarding investigation;
• seeking independent advice.

A maliciously false accusation may itself require appropriate action, but an allegation is not malicious merely because it is ultimately unsubstantiated.

Part XII — People Who May Pose a Safeguarding Risk

46. Gospel Welcome Does Not Require Naivety

The Church exists for sinners and believes in the transforming grace of God.

Nevertheless:

Welcoming a person to hear the gospel is not the same as giving them unrestricted access to children or vulnerable people.

A person may participate in worship while being subject to safeguarding restrictions.

47. Safeguarding Agreements

Where a person:

• has relevant convictions;
• is under investigation;
• has admitted harmful conduct;
• presents a credible safeguarding risk;
• or is otherwise reasonably assessed as requiring restrictions,

the Church may adopt a written Safeguarding Agreement.

It may specify:

• permitted attendance;
• designated arrival/departure arrangements;
• areas not to be entered;
• no children's ministry;
• no unsupervised contact with children;
• no transporting children;
• no children's toilet/changing areas;
• named supervisors;
• seating arrangements where appropriate;
• digital-contact restrictions;
• ministry restrictions;
• review arrangements;
• consequences of breach.

The terms should be proportionate to the actual risk.

48. Restoration to Ministry

Repentance and forgiveness do not automatically restore suitability for leadership or safeguarding-sensitive ministry.

Certain conduct may permanently or indefinitely disqualify a person from particular roles even where the Church has good reason to believe genuine spiritual repentance has occurred.

The question:

“Has this person repented?”

is not identical to:

“Is it now prudent and lawful to place vulnerable people under this person's care?”

Part XIII — Responding to a Disclosure

49. If Someone Tells You They Have Been Harmed

The worker should:

1. remain calm;
2. listen;
3. allow the person to speak in their own words;
4. take the disclosure seriously;
5. reassure them that telling someone was the right thing to do;
6. explain that information may need to be shared to help keep people safe;
7. report promptly through the safeguarding procedure;
8. make an accurate written record.

50. Do Not Investigate

The worker should not:

• interrogate;
• demand proof;
• repeatedly question;
• ask leading questions;
• attempt to obtain a confession from the alleged perpetrator;
• contact witnesses to compare stories;
• confront the person accused;
• promise a particular outcome.

Where clarification is necessary, use minimal open questions such as:

“Can you tell me what happened?”

rather than suggesting an answer.

51. Do Not Promise Secrecy

A worker should never say:

“I promise I won't tell anybody.”

An appropriate response is:

“I'm glad you told me. I will only tell people who need to know so that we can help keep you safe.”

52. Recording a Disclosure

As soon as reasonably possible, record:

• date and time;
• location;
• who was present;
• what prompted the conversation;
• the person's own words as accurately as possible;
• questions actually asked;
• visible injuries or behaviour observed;
• immediate action taken;
• who was informed;
• date/time of reporting.

Clearly distinguish:

fact from observation from opinion.

Do not rewrite the original account later to make it appear neater.

Corrections or later information should be added transparently.

Part XIV — Reporting and Referral

53. Immediate Danger

Where a child or adult is in immediate danger, or urgent police/medical intervention is required:

Internal Church reporting may follow immediately afterwards.

Protecting a person takes precedence over completing internal forms.

54. Child Safeguarding Concerns

A child safeguarding concern should ordinarily be reported immediately to the DSL or Deputy.

The DSL shall decide promptly whether:

• advice is required;
• a referral should be made;
• immediate protective action is needed;
• police involvement is appropriate.

For Bristol children, the current professional safeguarding route is First Response on 0117 903 6444; urgent concerns outside office hours that cannot wait may be directed to the Emergency Duty Team on 01454 615 165. These details must be checked during each annual policy review. (Bristol City Council)

Parents or carers should normally be informed about a child referral, unless doing so may increase risk, cause violence, cause information to be withdrawn or otherwise compromise safety; Bristol's current guidance reflects this distinction. (Bristol City Council)

55. Adult Safeguarding Concerns

Where the Care Act safeguarding criteria may be met, concerns should be referred to the appropriate local authority adult safeguarding service.

For Bristol, the current route includes the Council's adult safeguarding reporting system and Care Direct on 0117 922 2700. Immediate danger remains a police matter. (Bristol City Council)

The adult's wishes should ordinarily be sought and respected, subject to the exceptions explained in Chapter 38.

56. If the DSL Chooses Not to Refer

Where a worker has raised a concern and reasonably believes that failure to refer leaves someone at significant risk, the worker may:

• raise the matter with the Deputy DSL;
• raise it with the Safeguarding Trustee;
• obtain independent safeguarding advice;
• or make a direct referral to an appropriate statutory agency.

Internal hierarchy shall never require silence where a person reasonably believes urgent safeguarding action is necessary.

Part XV — Allegations Against Church Workers

57. Allegations Concerning Children

Where an allegation concerns an adult who works or volunteers with children and potentially meets the LADO threshold, it shall be referred through the LADO procedure without first conducting an internal investigation.

For Bristol, the current procedure states that the LADO team should be notified through the referral process within one working day where an allegation potentially meets the threshold, and that the employer should seek LADO advice before beginning its own safeguarding investigation. (Bristol Safeguarding)

The Church may still take immediate steps necessary to:

• protect children;
• preserve evidence;
• prevent further contact;
• secure systems;
• or address an emergency.

58. Current Bristol LADO

At the date of this policy:

Local Authority Designated Officer
Email: LADO@bristol.gov.uk
Telephone: 0117 903 7795

These details shall be verified annually. (Bristol Safeguarding)

59. Allegation Against Pastor, Elder or Trustee

Seniority does not alter the threshold for referral.

If the subject is:

• Pastor;
• Elder;
• Trustee;
• DSL;
• longstanding member;
• founding member;
• major donor;
• relative of a leader,

the safeguarding question remains the same.

The individual concerned shall not:

• decide whether the allegation is credible;
• interview the complainant;
• contact witnesses;
• decide whether statutory agencies should be informed;
• control relevant records;
• participate in Trustee decisions concerning their own restrictions.

60. Suspension and Temporary Restrictions

An allegation does not itself prove guilt.

However, temporary protective action may be necessary.

This may include:

• suspension from a role;
• temporary removal from children's work;
• restriction from particular areas;
• suspension of system access;
• supervised attendance.

Such measures are precautionary and should not be described as findings of guilt.

Where LADO involvement applies, the Church should seek LADO advice on employment and safeguarding measures. Bristol's current procedure specifically provides for LADO advice on safeguards while allegations are investigated. (Bristol Safeguarding)

61. Fairness to the Person Accused

Safeguarding requires fairness as well as protection.

The Church shall:

• avoid unnecessary public disclosure;
• avoid treating allegation as proven fact;
• provide appropriate information when safe and lawful;
• provide welfare support where appropriate;
• cooperate with statutory processes;
• avoid prejudicing police or social-care investigations.

Protection of the alleged victim and procedural fairness to the subject of the allegation are not mutually exclusive.

Part XVI — Low-Level Concerns and Boundary Drift

62. Report Early

Workers are encouraged to raise behaviour that feels inappropriate before it becomes a crisis.

Examples may include:

• repeated private messaging;
• unnecessary lone transport;
• repeated physical familiarity;
• one child receiving unusual gifts;
• attempts to bypass parents;
• resistance to supervision;
• frequent “accidental” isolation with children;
• inappropriate jokes;
• boundary-blurring social media contact;
• deleting messages;
• unusual secrecy;
• hostility when reasonable safeguarding questions are asked.

63. Recording Low-Level Concerns

The DSL shall record relevant low-level concerns.

The record should include:

• behaviour reported;
• context;
• source;
• response;
• whether the person was spoken to;
• any action;
• review outcome.

Patterns should be reviewed periodically.

A series of individually minor events may reveal a significant pattern.

64. Escalation

If information later suggests that the LADO or statutory threshold may be met, the matter must be escalated.

The Church shall not keep calling something “low-level” merely because it was first recorded that way.

Part XVII — Child Sexual Abuse and Mandatory Reporting

65. Church Policy Requirement

Regardless of minimum statutory requirements, a credible disclosure, direct observation or reasonable suspicion of child sexual abuse shall never be handled solely as an internal pastoral matter.

Appropriate external safeguarding or police referral shall be made.

66. 2026 Legislative Change

The Crime and Policing Act 2026 contains a new statutory duty requiring specified adults engaged in relevant activities to report suspected child sexual offences to police or a local authority in defined circumstances, together with an offence of obstructing a required report. However, the relevant mandatory-reporting provisions were not among the provisions brought into force immediately on Royal Assent, and implementation is subject to commencement arrangements and further guidance. (Legislation.gov.uk)

Accordingly, the Church shall monitor commencement of the new duty and amend procedures when necessary.

The existence or commencement date of that statutory duty does not alter this policy's present standard: Child sexual abuse must not be covered up, privately mediated or deliberately withheld from appropriate safeguarding authorities.

The Government's explanation for the 2026 reforms specifically identifies institutional reputation-protection and failures to act on disclosures as problems the mandatory-reporting regime is designed to address. (GOV.UK)

Part XVIII — DBS Referrals

67. Referral Duty

Where the Church provides regulated activity and removes a person from such activity—or would have done so had the person not resigned—because relevant statutory harm criteria are met, the Church must consider and fulfil any legal duty to refer that person to the Disclosure and Barring Service.

The Charity Commission expressly reminds charities that a DBS referral can be mandatory where the statutory conditions are satisfied. (GOV.UK)

A person's resignation shall not be used to avoid consideration of a DBS referral.

Part XIX — Whistleblowing and Speaking Up

68. Right to Raise Concerns

No worker, volunteer or member shall be disadvantaged merely for raising a safeguarding concern honestly and in good faith.

Nobody shall be instructed:

• “Don't take this outside the Church”;
• “You will damage the ministry”;
• “You are dishonouring leadership by reporting this”;
• or equivalent language intended to deter legitimate safeguarding action.

69. External Reporting

Where a person:

• believes the Church is failing to act;
• believes leaders are conflicted;
• fears retaliation;
• or reasonably believes external reporting is necessary,

they may approach the appropriate statutory or regulatory authority.

The Charity Commission itself expects charities to maintain whistleblowing arrangements and recognises external whistleblowing routes for charity workers and volunteers. (GOV.UK)

Part XX — Confidentiality, Information Sharing and Records

70. Confidentiality Is Not Secrecy

Safeguarding information shall not be casually spread around the congregation.

It should be shared only with people who genuinely need it for:

• protection;
• referral;
• investigation;
• governance;
• legal compliance;
• or appropriate professional advice.

But confidentiality shall never be used to keep relevant information from someone who properly needs it to protect another person.

71. Children's Information Sharing

Protecting a child from harm may justify or require sharing information without consent.

Bristol's current guidance states that protecting children from harm takes priority over privacy and that consent is not required to share information about concerns that a child is or may be at risk of harm, although parents should ordinarily be informed unless doing so would increase risk or compromise safeguarding. (Bristol City Council)

72. Safeguarding Records

Safeguarding records shall be:

• accurate;
• dated;
• factual;
• secure;
• access-controlled;
• separate where appropriate from ordinary pastoral records;
• retained according to applicable legal and safeguarding requirements.

Records shall not be altered in a way that hides the original information.

Access shall be limited according to legitimate need.

73. Preservation of Evidence

Where allegations involve:

• digital communication;
• emails;
• messages;
• photographs;
• CCTV;
• documents;
• financial transactions,

relevant material shall be preserved.

Nobody shall destroy, edit or conceal information because they believe it may embarrass the Church or another person.

Part XXI — Support After a Safeguarding Concern

74. Person Who May Have Been Harmed

The Church should consider appropriate support for the person who may have been harmed without attempting to influence:

• their account;
• statutory investigation;
• or their decision concerning police or external support.

Support may include:

• pastoral care from an appropriate unconflicted person;
• practical assistance;
• signposting to specialist services;
• reasonable adjustments to Church participation.

75. Family

Parents, spouses and families may also require support.

The person providing that support should not improperly pass confidential information between parties.

76. Person Subject to Allegation

Where appropriate, an unconflicted person should be identified to provide welfare support to the person subject to allegation.

That support must remain distinct from safeguarding decision-making.

77. Congregation

Where a serious matter becomes known publicly, the Church may need to communicate with members.

Communication shall:

• be truthful;
• preserve necessary confidentiality;
• avoid speculation;
• avoid implying guilt before findings;
• avoid misleading statements designed merely to protect reputation.

Part XXII — Learning, Review and Accountability

78. Review After Significant Incidents

After a significant safeguarding incident, the Trustees shall ask:

• What happened?
• What warning signs existed?
• Were procedures followed?
• Were concerns raised earlier?
• Were they heard?
• Did authority or relationships inhibit reporting?
• Did anyone protect the institution rather than the person?
• Did information fail to move between people?
• What must change?

The purpose is not merely to identify an individual mistake.

It is to identify whether the Church's system or culture helped the harm occur or continue.

The Charity Commission expects charities to review serious incidents and learn how to prevent recurrence. (GOV.UK)

79. Independent Review

Where:

• senior leadership is implicated;
• there are allegations of systemic failure;
• several incidents reveal a pattern;
• internal confidence has materially broken down;

the Trustees should consider an appropriately qualified independent safeguarding review.

The reviewers should be genuinely independent of those whose conduct or decisions they are evaluating.

80. Annual Review

This policy shall be reviewed at least annually, and sooner where:

• legislation changes;
• statutory guidance changes;
• local safeguarding procedures change;
• Church activities materially change;
• serious incidents occur;
• practice demonstrates that the policy is inadequate.

Annual review is consistent with current Charity Commission expectations. (GOV.UK)

Appendix A — Immediate Safeguarding Card

If Someone Is in Immediate Danger

If a Child Discloses Harm

LISTEN
Do not investigate.

REASSURE
“I'm glad you told me.”

DO NOT PROMISE SECRECY
Explain that people who can help may need to know.

RECORD
Use their own words.

REPORT
DSL / Deputy / Safeguarding Trustee.

REFER
External safeguarding authority where appropriate.

Never:

• confront the alleged perpetrator;
• conduct your own investigation;
• delay because the person accused is respected;
• promise to keep abuse secret.

Appendix B — Safeguarding Reporting Structure

Ordinary Concern

Worker ↓ DSL

DSL Implicated

Worker ↓ Deputy DSL / Safeguarding Trustee

Pastor/Elder Implicated

DSL/Deputy/Safeguarding Trustee ↓ Unconflicted decision-makers ↓ Statutory referral where appropriate

Worker With Children Allegation

DSL/Deputy ↓ LADO referral if threshold potentially met ↓ Follow LADO advice before internal investigation

Immediate Danger

999 first

Internal Independence Impossible

External statutory referral / independent safeguarding advice

Appendix C — Bristol Safeguarding Contacts

Details correct when Version 1.0 was drafted in August 2026. Verify annually.

Emergency

Police / Ambulance: 999

Police Non-Emergency

101

Children — Bristol First Response

0117 903 6444

Emergency Duty Team

01454 615 165 for an urgent concern outside office hours that cannot wait. (Bristol City Council)

Bristol LADO

Telephone: 0117 903 7795
Email: LADO@bristol.gov.uk (Bristol Safeguarding)

Adult Safeguarding — Bristol Care Direct

0117 922 2700, alongside Bristol's online adult safeguarding referral route. (Bristol City Council)

Church Safeguarding Officers

Church DSL

Name

Telephone

Email

Deputy DSL

Name

Telephone

Email

Safeguarding Trustee

Name

Telephone

Email

Appendix D — Safeguarding Concern Record

Person completing record

Date/time completed

Person of concern

Date/time of incident/disclosure

Location

What happened?

Record facts and the person's own words where possible.

What did you personally observe?

What questions did you ask?

Immediate action taken

Who was informed?

Date/time reported

External referral?

• No
• First Response
• Adult Safeguarding
• LADO
• Police
• DBS
• Charity Commission
• Other

Reference

DSL signature

Appendix E — Safer Recruitment Checklist

For safeguarding-sensitive roles:

• Role description prepared
• Safeguarding responsibilities identified
• Applicant suitability discussed
• Relevant history considered
• References obtained
• Identity verified
• DBS eligibility assessed
• Correct DBS level obtained where applicable
• Overseas checks considered where relevant
• Safeguarding training completed
• Code of Conduct acknowledged
• Role boundaries explained
• Reporting routes explained
• Initial supported period arranged
• Recruitment decision recorded

Appendix F — Children's Ministry Code: Quick Rules

A children's worker shall:

BE VISIBLE — Avoid unnecessary secrecy or isolation.

BE ACCOUNTABLE — Another worker should know what you are doing.

BE APPROPRIATE — Touch, language and communication must suit the context.

DO NOT CREATE SECRET RELATIONSHIPS

DO NOT PRIVATELY MESSAGE CHILDREN AS A NORMAL MINISTRY METHOD

DO NOT GIVE UNUSUAL GIFTS OR ATTENTION TO ONE CHILD

DO NOT USE HUMILIATION OR PHYSICAL PUNISHMENT

DO NOT PROMISE CONFIDENTIALITY WHEN SAFETY MAY BE INVOLVED

REPORT BEHAVIOUR THAT CONCERNS YOU

Appendix G — Pastoral Safeguarding Code

Pastoral workers shall not:

• cultivate improper emotional dependency;
• use pastoral information for personal leverage;
• make sexual or romantic advances within an exploitative pastoral relationship;
• pressure vulnerable people for money;
• demand secrecy concerning misconduct;
• use claims of spiritual authority to control safeguarding reporting;
• automatically assume that reconciliation is safe;
• meet in unnecessarily secret circumstances;
• undermine professional medical, safeguarding or police assistance merely to preserve internal control.

Pastoral care should seek to strengthen the person, not make them increasingly dependent upon the pastor.

Appendix H — Low-Level Concern Record

Person observed

Behaviour

Date

Context

Why did this cause concern?

Action taken:

Previous related concerns checked

• Yes
• No

DSL review:

• No further action
• Advice/guidance
• Supervision/training
• Formal management action
• Escalated to LADO
• Other

Appendix I — Safeguarding Agreement for a Person Who May Pose Risk

Person

Reason agreement required

Date agreed

The following restrictions apply:

• No children's ministry
• No youth ministry
• No unsupervised contact with children
• No transport of children
• No entry to children's ministry areas
• No children's toilets/changing areas
• No digital contact with children
• Named supervisor required
• Specified seating/attendance arrangement
• No pastoral counselling of vulnerable persons
• No leadership position
• Other:

Named safeguarding contact

Review date

Consequences of breach:

Appendix J — Annual Trustee Safeguarding Review

The Trustees shall consider:

Leadership

• DSL appointed
• Deputy appointed
• Safeguarding Trustee appointed
• Contact information correct
• Appropriate independence exists

Recruitment

• Worker list current
• Role DBS eligibility reviewed
• Checks current/appropriate
• New volunteers recruited safely
• No unreviewed historic workers

Training

• DSL training current
• Children's workers trained
• Trustees trained
• Pastor/Elders understand safeguarding routes

Practice

• Children's ministry observed/reviewed
• Digital arrangements reviewed
• Transport arrangements reviewed
• One-to-one practices reviewed
• Photography arrangements reviewed

Concerns

• Low-level concerns reviewed for patterns
• Open safeguarding cases reviewed appropriately
• LADO matters handled correctly
• Adult safeguarding referrals considered
• DBS referrals considered where relevant
• Charity Commission reporting considered

High-Risk Persons

• Safeguarding Agreements current
• Restrictions remain appropriate
• Relevant people know their responsibilities

Culture

Ask explicitly:

Could a child, member, employee or volunteer safely raise a safeguarding concern about our most senior leader?

• Yes

If the truthful answer is uncertain, the safeguarding system requires improvement.

Learning

• Incidents/near misses reviewed
• Changes implemented
• Risk register updated
• Policy reviewed

Appendix K — Decision Guide: What Kind of Matter Is This?

Pastoral Matter

Ordinary struggle, conflict or sin with no indication of safeguarding harm.
Route: pastoral care.

Conduct/Boundary Concern

Poor behaviour inconsistent with expected standards.
Route: DSL / low-level concern process.

Safeguarding Concern

Possible harm, abuse, neglect, exploitation or serious risk.
Route: DSL and safeguarding assessment/referral.

Allegation About a Worker With Children

Potential LADO threshold.
Route: LADO process.

Immediate Danger

Person presently unsafe.
Route: 999.

Suspected Crime

Route: safeguarding plus police consideration.

Church Discipline

May operate alongside safeguarding.
Never use it to replace statutory safeguarding processes.

Appendix L — Policy Relationship Map

Constitution

Establishes governance authority and responsibilities.

Safeguarding and Protection Policy

Establishes how people are protected, concerns handled and safeguarding risk managed.

Pastoral Employment Agreement

Makes safeguarding compliance an employment responsibility and provides employment procedures where serious safeguarding conduct is alleged.

Financial Controls and Stewardship Policy

Protects Church resources and helps prevent financial exploitation.

Pastoral Remuneration and Benefits Policy

Prevents leaders determining their own financial benefit.

Conflict of Interest Policy

Ensures persons with personal interests do not control decisions involving themselves or those closely connected to them.

Church Discipline Procedures

Address ecclesiastical membership and spiritual accountability.

They do not replace safeguarding, police or employment procedures.

Document Control

DocumentSafeguarding and Protection Policy

SubtitleA Biblical and Practical Framework for Protecting Children, Adults at Risk, Workers and the Church Community

ChurchSpirit of Life Reformed Baptist Church

Policy OwnerCharity Trustees

Operational LeadDesignated Safeguarding Lead

Version1.0

Date Approved

Effective Date

Next Review

Next Mandatory Annual Review

Closing Statement

“Whatsoever ye would that men should do to you, do ye even so to them.”

Matthew 7:12

A safeguarding policy succeeds only when its principles become ordinary behaviour.

The goal is not that the Church can produce a document after something has gone wrong and say:

“We had a policy.”

The goal is that:

• workers naturally avoid unnecessary secrecy;
• leaders welcome appropriate accountability;
• children know they can speak;
• adults experiencing coercion are heard;
• poor boundaries are challenged early;
• allegations cannot be quietly controlled by the person accused;
• people understand when matters must leave the Church's internal processes;
• records tell the truth;
• and safeguarding decisions are made according to the protection of people rather than the preservation of reputation.

The Church will inevitably be composed of imperfect people.

Safeguarding does not proceed from the assumption that every leader is dangerous.

Neither does Christian trust require the assumption that a respected leader could never do harm.

Wise safeguarding recognises both human dignity and human fallibility.

It therefore seeks neither suspicion nor naivety.

It seeks faithful vigilance.

And where harm does occur, the Church's responsibility is not first to ask:

“How do we protect ourselves from this?”

but:

“Who may be in danger, what is our responsibility now, and how do we act truthfully and faithfully?”

That is the culture this policy is intended to establish.