Say Something If You See Something

Guidance and resources for Professionals who work with Businesses and the Wider Community

Why local authority, regulatory and children’s services should take a contextual approach to safeguarding in the community.

Children can be exploited anywhere and can be at risk in public places, including those regulated by local councils, police and other services. To prevent or disrupt child exploitation, it’s vital that information held by colleagues working in children’s and regulatory services, is shared. Information may be sitting in records held by various services, about local hotspots, the journey’s made by young people at risk, where they stay; and these facts can be missed if professionals don’t take a contextual approach to safeguarding, or if the right information sharing arrangements are not in place. For example, by including council licensing or cctv security services at multi agency safeguarding meetings, information can be shared about individuals or locations in the business and wider community, that pose a risk.

As a professional working in children’s services, regulation/enforcement, community partnerships or voluntary sector, it’s important to establish a contextual approach to safeguarding; regulatory duties and statutory legislation can give professionals the opportunity to engage with the business sector, to develop safeguarding practice and improve the reporting of child exploitation signs. It is the responsibility of professionals to support the regulated and wider community, to understand child exploitation so that they can fulfil their social and legal responsibilities.

Safeguarding is increasingly becoming a part of business regulation and there is already a statutory framework that builds an interface between safeguarding and regulatory regimes. The framework aims to protect vulnerable young people when they are outside of the family home. This is known as a contextual approach to safeguarding.

The statutory framework includes:

• The Licensing Act 2003
• The Gambling Act 2005
• The Children Act 2004 (Section 11), The Children Act 1989 (as amended), The Children and Social Work Act 2017
• Working Together to Safeguard Children 2023
• Safeguarding Vulnerable Groups Act 2006 and the Department for Transport Guidance for Licensing.
• The Modern Slavery Act 2015
• The Taxi and Private Hire Vehicles (Safeguarding and Road Safety) Act 2022
• The Anti-Social and Policing Act 2014
• Sexual Offences Act 2003 Abuse of Position of Trust (updated 2022)
• The Education and Skills Act 2008
• The Education and Inspections Act 2005

As the Government places more safeguarding responsibilities on regulated business operators, there is a direct impact on the professionals and decision-makers who have regulatory responsibilities. Licensing Authorities in partnership with children’s services, the police and other responsible authorities have more accountability for the safeguarding arrangements that are in place, in business and public settings. Organisations that do not have arrangements in place for safeguarding in the business and the wider community may be exposed to reputational risk.

To promote a contextual approach to safeguarding, children’s and regulatory services along with community partnership teams should develop safeguarding practices to educate community partners about their safeguarding roles.

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Developing contextual safeguarding partnership arrangements

To encourage effective information sharing and strategic partnership work in response to child exploitation and trafficking in the business sector the following should be considered as part of your organisation’s policy and practice.

Arrangements for information sharing between children’s, regulatory and community partnership teams should be in place. For example:

• Responsible Authority Meetings to include attendance by safeguarding/children’s services to share information about young people and risk at regulated businesses or other community locations
• MACE, MASH or similar partnership meetings to discuss young people at risk of exploitation, should include input from regulatory/licensing services (including taxi licensing, child employment licensing, council CCTV controllers/wardens/ambassadors/neighbourhood officers)
• LADO to receive information about individuals who are licensed by, or operating at places regulated by the council.

If you are worried about information sharing and GDPR compliance you may wish to use a Data Protection Impact Assessment as a way to properly share information across the partnership, for example, to allow regulatory services, LADO and children’s services to share information about a child at risk, that was provided by taxi operators.

To encourage regulators to attend multi agency safeguarding meetings (and children’s workers to attend regulatory meetings about locations), it is important for regulatory and children’s services to understand the interface that links safeguarding and regulation.

Training and Awareness for Contextual Safeguarding Partnerships

It’s important that all partners including regulators, security officers, community safety, children’s practitioners and people in the business and wider community, understand the contextual approach to safeguarding and that they receive training about their safeguarding responsibilities. Professionals should be able to access this type of training through their employer, so that they are aware of how criminals/perpetrators misuse business operations and other community settings to facilitate child exploitation and trafficking.

If you are looking for a provider of safeguarding training in the context of the business community, there are some organisations that offer training free of cost, while other providers may charge. It is important that the safeguarding training is quality assured and recognised by the relevant statutory agencies such as safeguarding partnership, children’s social care, police.

Learn more about NWG training

Training for all contextual partners should include the following (this list is not exhaustive):

• The statutory framework that brings safeguarding into regulation
• The legal and social responsibility to protect children – safeguarding is everyone’s business
• Why we must work in partnership to protect children and the risk/consequences of not doing this
• What child exploitation and trafficking is
• How child exploitation and trafficking can be facilitated by trades/business operations and in other community settings
• How to spot the danger signs
• How to take a trauma-informed approach
• How to report safeguarding concerns (including local contact numbers for police, social care and contact details for organisations such as Crimestoppers, British Transport Police)

Due diligence and ‘Safeguarding Compliance’ in business and public settings

Regulators, or children’s professionals who have a role in safeguarding in the context of business community (such as responding to issues at licensed premises) could reasonably expect to see safeguarding control measures in place. This can be mandated using licence conditions but it can also be advised as good practice to people responsible for operating unregulated, voluntary and community settings.

The following may be considered when responsible authorities are proposing licence conditions, action plans for safeguarding improvement, or as a method to develop safeguarding practice at a regulated business.

Safeguarding control measures should including the following:

• Safeguarding awareness training for all staff/operational workers at the setting including: employees, volunteers, self-employed workers
• A safeguarding risk assessment
• A Safeguarding Coordinator (suitably responsible, vetted and trained)
• An age verification/Identification process to prevent access to adult venues or age-restricted products or illegal working.

Download Safeguarding Role Description
Download Risk Assessment Template

Information/key messages for professionals to convey to the business and wider community

Child exploitation and human trafficking can manifest in all types of businesses and public places, such as where young people learn, work, meet up to socialise, eat, shop, enjoy sports and training and these locations can become hotspots of risk if they are targeted by perpetrators for grooming or exploitation. The risk of child exploitation varies, depending on the location – for example, the risks at a hotel are different to those at a fast food outlet, or in a private hire vehicle. The risks in a park, or outdoor/community event, are different again. Criminals operate in plain sight and use busy (or remote) public places to conceal their activity. The social distractions at some locations allow perpetrators to act without raising suspicion. Even businesses and places that do not give access to young people or to the public, can be misused for exploitation and trafficking; for example, an employee who is a perpetrator may use company assets such as a laptop, smartphone, company credit card or vehicle, to facilitate exploitation; or a perpetrator might use a community location such as the back of a retail park warehouse.

Criminals who exploit young people are adept to find opportunities to target, groom and exploit their victims and are known to misuse all types of businesses and community locations to meet, groom and abuse children. If you are responsible for managing a business or community setting, it is important that you are aware of your social and legal safeguarding responsibilities (if your business, for example, is licensed) and have effective control measures in place, so that you can evidence due diligence towards the protection of children from harm. Effective risk management arrangements will also help protect the status and reputation of your business/community setting and this means that safeguarding policies and procedures should be implemented.

Measures may include:

• A safeguarding risk assessment, to identify potential risk and to help business/community setting managers decide their safeguarding policies and procedures.
• Staff training* should be given by a reputable training provider and staff training records should be maintained. Staff should understand the importance of taking a trauma informed approach to victims or young people at risk of child exploitation.
• If a business/community outlet is accessed by children and young people, records of any incidents/reports including those made to the police, should be maintained.
• A Safeguarding Coordinator should be assigned (suitably responsible, vetted and trained)
• An age verification/Identification process should be in place to prevent access to adult venues or age restricted products and to encourage staff/volunteers working in the setting to ‘Think 25’ . By focussing on the appearance and behaviour of people who look under 25 years, staff are more likely to spot the signs of an exploited young person

Members of the community neighbourhood are also in a good position to spot the signs. For example, noticing unusual vehicles or activity in the neighbourhood such as young people being picked up/dropped off at unusual times or places; adults hosting parties attended by young people, or young people associating with adults and behaving in a suspicious way and local meeting points where young people gather.

The following information and resources are available to download and can be used by professionals to develop a contextual approach to safeguarding practice.