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:
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.
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:
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.
The children’s workforce should understand their responsibility to identify and report information about locations, to regulators and community workers (places or facilities where children at risk are working, socialising, travelling, staying, meeting) and should understand how regulatory and community partners can contribute to disruption at risk locations.
Regulators and enforcement officers should understand their safeguarding responsibilities and be able to recognise and report suspicious activity (know how to recognise safeguarding concerns embedded within regulatory complaints; for example, a Trading Standards officer should recognise the ‘red flag’ in a complaint that a child is obtaining cigarettes/alcohol from a shop and has run up debt); they should understand how to recognise and report safeguarding concerns observed during enforcement visits (for example, children working illegally; signs of a shop basement being used as ‘living’ quarters or signs of sexual activity). They should understand the importance of ‘thinking twice’ and take a trauma informed approach to challenge perceptions of young people so that they do not dismiss signs of child exploitation as ‘anti-social behaviour’ or assume that an aggressive or distressed young person is a ‘typical teenager’.
Decision makers and Policy Officers should understand the interface between regulation and safeguarding and know how to use regulatory procedures and policies towards prevention and disruption of child exploitation and trafficking.
Business operators should be encouraged by the authorities to develop safeguarding practice within their own business setting. This may be done by professionals delivering training and guidance to operators, or by signposting business operators to suitable training.
Partner services, business operators and community workers should be encouraged to assign a single point of contact (a suitably trained member of staff) as a ‘Safeguarding Coordinator to liaise with contextual partners
Safeguarding Coordinators should ensure the flow of information across services / multi agency meetings, in a compliant and timely way.
Safeguarding Coordinators should also liaise with business operators, community partners and others to promote safeguarding practice in the context of the business and wider community
Children’s services should contribute to licensing processes (for example influence or respond to licence applications, support reviews, request licence conditions to ensure business operators have safeguarding arrangements in place)
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.
Training for all contextual partners should include the following (this list is not exhaustive):
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:
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:
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.