Safeguarding Children & Vulnerable Adults Policy

Protecting everyone in our care.

Entity: School Of Fish

Jurisdiction: United Kingdom

Date of Review: 01/01/2026

Next Review Date: 01/01/2027

Last Amended: 25/07/2026 (Section 5.1 extended: physical intervention to prevent harm) 23/07/2026 (Section 3 restructured to a two-level model: an organisation-wide School Of Fish Safeguarding Lead and a local DSL at every delivery unit including Peterborough, with an interim provision until each appointment is made; Sections 12 to 19 added; scope extended to delivery units and franchisees; safer recruitment extended; 6.1 extended to sexual abuse and grooming; LADO standard aligned; external escalation routes added) 04/07/2026 (Sections 10 and 11 added; Incident Report Form linked; Adults at Risk Policy cross-referenced)

1. Policy Statement

School Of Fish acknowledges its duty of care to safeguard the welfare of all children and young people (under 18) and adults at risk involved in our angling coaching and training activities.

We are committed to ensuring that every participant, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation, or identity, has the right to protection from all forms of harm, abuse, neglect, and exploitation. Adults at risk are covered in greater depth by our Adults at Risk Policy.

2. Scope of the Policy

This policy applies to:

• All Staff: Paid coaches, freelance coaches, and administrators.
• Trainee Coaches: Adults undergoing professional development with us.
• Volunteers: Anyone assisting on the bankside.
• External Contractors: Guest speakers or specialist demonstrators.
• Delivery units: Every place where School Of Fish sessions are delivered, including Peterborough, appoints its own Designated Safeguarding Lead under section 3.2.
• Franchisees: Every School Of Fish franchise operates to this policy. A franchise appoints its own Designated Safeguarding Lead, reports safeguarding incidents to School Of Fish within 24 hours, and applies these standards in full to its own staff and volunteers.
• Franchise escalation: Where a franchise's concern is about School Of Fish itself, or about a person at School Of Fish, it does not travel through School Of Fish. The franchise uses the external routes in section 9 directly, and the same protection applies to them as to anyone raising a concern internally.

3. Key Roles and Responsibilities

3.1 The School Of Fish Safeguarding Lead

Safeguarding at School Of Fish runs on two levels. The School Of Fish Safeguarding Lead holds the standard across the whole organisation. Every place where sessions are delivered has its own Designated Safeguarding Lead, who is the person coaches report to on the day.

The School Of Fish Safeguarding Lead is not the local DSL for any delivery unit, including Peterborough. Holding both roles would mean a concern about a local session travelling to the same person who runs it, which is the arrangement this policy exists to prevent.

• Name: Ulvis Strokss
• Phone: 07713 177685
• Email: safeguarding@schooloffish.co.uk

The DSL is responsible for:

• Receiving and recording information from staff, parents, or participants regarding safeguarding concerns.
• Assessing information promptly and carefully.
• Referring cases to the Local Authority Children's Social Care or the Police when necessary.
• Making referrals to the Disclosure and Barring Service where section 14 applies, and retaining a record of them.

The DSL holds designated safeguarding lead training appropriate to the role, refreshed at least every two years, and keeps current with changes in law and statutory guidance. Where the DSL is unable to act because a concern relates to them, section 9 applies.

3.2 Local Designated Safeguarding Leads

Every School Of Fish delivery unit appoints its own Designated Safeguarding Lead. That includes Peterborough and every franchise. The local DSL is the person coaches and volunteers report to, and their name and contact details are given at induction and displayed wherever sessions run.

• The local DSL is not the School Of Fish Safeguarding Lead. The two roles are held by different people.
• Wherever possible the local DSL does not hold a coaching position at that unit, so that a concern about a coach can be received by someone who is not one.
• The local DSL holds designated safeguarding lead training appropriate to the role, refreshed at least every two years.
• The local DSL reports safeguarding incidents to the School Of Fish Safeguarding Lead within 24 hours, and takes the standard from them.
• Where a local DSL is unavailable, or the concern is about them, the concern goes to the School Of Fish Safeguarding Lead, and from there to the external routes in section 9.
• Until a local DSL is appointed at a delivery unit, the School Of Fish Safeguarding Lead acts as the local DSL for that unit. That is an interim arrangement, and the appointment is made as soon as a suitable person is in place.

Which lead this policy means. Where this policy refers to the DSL without qualification, it means the local Designated Safeguarding Lead for the unit where the concern arises. The local DSL receives concerns, records them, decides the immediate response, and makes contact with the Local Authority Designated Officer, children's social care or the police where the situation requires it, informing the School Of Fish Safeguarding Lead at the same time.

Referrals to the Disclosure and Barring Service under section 14 are made by the School Of Fish Safeguarding Lead for School Of Fish staff and volunteers, since School Of Fish is the regulated activity provider for them. A franchise makes its own referrals for its own people and tells School Of Fish it has done so.

Safeguarding records under section 16 are held by the local DSL for their unit and are accessible to the School Of Fish Safeguarding Lead. Neither destroys, amends or reclassifies a record without the other knowing.

3.3 Staff and Volunteers

All staff, coaches and volunteers must read this policy and are responsible for reporting any concerns about a child's welfare to the DSL immediately.

This policy forms part of induction. School Of Fish keeps a record of who has read it and when, and that record is refreshed whenever the policy is materially amended. Nobody coaches a School Of Fish session before that record exists for them.

3.4 When a Safeguarding Lead Cannot Be Reached

A concern is never held over because someone is unavailable. If the local DSL cannot be reached, the concern goes to the School Of Fish Safeguarding Lead. If neither can be reached and a child is at risk, the coach uses the external routes in section 9 directly, and rings 999 where a child is in immediate danger.

Reporting onward without reaching a safeguarding lead first is always the right call in those circumstances, and is never treated as going over anyone's head.

4. Safer Recruitment

To prevent unsuitable people from working with children, School Of Fish enforces a strict recruitment procedure:

• DBS Checks: All coaches and volunteers with regular access to children must undergo an Enhanced Disclosure and Barring Service (DBS) check.
• References: At least two professional references will be sought and verified for all new staff and trainee coaches.
• Qualifications: Verification of coaching qualifications and First Aid certification.
• Identity: Identity is verified from original documents before any role begins.
• Self-declaration: Every applicant declares any conviction, caution or barring that would affect their suitability to work with children, and any prior investigation by an employer or a statutory agency.
• Interview: Every applicant is interviewed in person, and any gap in their history is explored and recorded.
• References: References are obtained by School Of Fish directly from the referee and are never accepted from the applicant.
• Renewal: DBS checks and safeguarding training are refreshed on a three-year cycle. A lapsed check means the person does not coach until it is back in place.

5. Code of Conduct: Bankside & Coaching Practice

Due to the nature of angling (remote locations, use of equipment, physical guidance), specific rules apply:

5.1 Physical Contact

• Principle: Physical contact should be minimal, appropriate, and open.
• Permitted Contact: Guiding a child's hand on the rod handle for casting, or assisting with holding a fish safely.
• Procedure: Coaches must ask permission before touching a participant (for example, "Is it okay if I guide your arm for this cast?").
• Prohibited: Any contact that is invasive, secretive, or unnecessary.
• Physical intervention to prevent harm: A coach may make physical contact where it is immediately necessary to prevent harm, such as stopping a child entering deep water. It is a last resort, uses the minimum contact for the shortest time, and is never used to punish or to manage behaviour. Every physical intervention is reported to the DSL and recorded within 24 hours. The statutory power of school staff to use reasonable force does not extend to coaches; this provision rests on the duty of care.

5.2 One-to-One Situations

• Every School Of Fish session runs with at least two DBS-checked adults present; no session, including one-to-one coaching, is ever staffed by a single coach. Coaches must avoid being alone with a child in a secluded area.
• All coaching should take place within sight or hearing of others (parents, other coaches, or the main group).
• If a child requires assistance away from the group (for example, a tangled line in bushes), two adults should ideally be present.

5.3 Transport

School Of Fish staff must never transport a child in their private vehicle unless in a specific emergency and accompanied by another adult, or with explicit written parental consent.

6. Recognising and Responding to Concerns

6.1 Signs of Abuse

Staff are trained to look for signs of:

• Physical Abuse: Unexplained bruises, injuries, or fear of physical contact.
• Emotional Abuse: Withdrawn behaviour, fear of making mistakes, or aggression.
• Sexual Abuse: Sexual language, knowledge or behaviour that does not fit the child's age, reluctance to be alone with a particular person, unexplained gifts or money, or a marked change in behaviour with no obvious cause.
• Neglect: Inadequate clothing for the weather, consistent hunger, or poor hygiene.
• Grooming: A pattern of behaviour by an adult or an older child that builds a relationship in order to abuse it. Individual acts often look harmless, which is why patterns are assessed by the DSL and not by the person reporting.

6.2 Reporting Procedure (The 3 Rs)

If a staff member or trainee coach has a concern:

1. Recognise: Accept the concern is real. Do not investigate or ask leading questions.
2. Record: Write down exactly what was seen or heard (using the child's own words where possible) on an Incident Report Form. Include the date, time, and witnesses.
3. Report: Pass the information to the DSL immediately. If a child is in immediate danger, call 999.

7. Allegations Against Staff

If an allegation is made against a School Of Fish staff member or trainee coach:

1. The accused will be suspended from duties immediately pending investigation, without prejudice.
2. The DSL will contact the Local Authority Designated Officer (LADO). The statutory standard is within one working day; School Of Fish works to 24 hours, whichever falls sooner. The LADO is contacted before anyone speaks to the person concerned or to the child's family.
3. We will cooperate fully with any police or social care investigation.

8. Photography and Digital Safety

• Consent: No image of a child is taken, used, or published without the written consent of a parent or guardian. For catch submissions, this consent is captured on the submission form, and it can be withdrawn at any time.
• Purpose: Images are used only for School Of Fish purposes, including coaching records, the Diploma, and School Of Fish's own channels and materials. They are not for personal use.
• Handling: Images are submitted through official School Of Fish channels. Once submitted, they should not be retained on personal devices, and must not be shared, copied, or forwarded privately.
• Publication: Any image of a child published by School Of Fish carries a visible watermark.
• Suitability: No image is taken or used that could embarrass or place a child at risk, or that shows a child inappropriately dressed.
• Social media: Staff and trainee coaches must not post images of junior participants on personal social media, and must not accept friend requests from or follow junior participants on personal accounts. All communication goes through official channels or via parents.

9. Whistleblowing

School Of Fish encourages a culture of openness. If a staff member or trainee feels unable to report a concern to the DSL (for example, if the concern is about the DSL), If the concern is that the DSL has harmed a child, may have committed an offence against a child, or has behaved in a way that makes them unsuitable to work with children, contact the Local Authority Designated Officer for the relevant council, who holds statutory responsibility for exactly that. If the concern is that safeguarding is not being handled properly here, for example that reports are not being acted on, use the NSPCC Whistleblowing Advice Line on 0800 028 0285. Where a child is at immediate risk, ring 999, and children's social care or the police are available at any hour. That line is open 8am to 8pm on weekdays and 9am to 6pm at weekends, and is not a 24-hour service.

Where the internal route cannot be used and the advice line is closed, use the following. Their hours differ, and the ones staffed at any hour are marked:

• 999 where a child is in immediate danger.
• NSPCC Helpline, 0808 800 5000 for advice about a child. The telephone line operates 10am to 4pm Monday to Friday; help@nspcc.org.uk is available at any time.
• Children's social care at the local council for the area the child lives in, which operates an out-of-hours duty team.
• Police non-emergency, 101, staffed around the clock.
• Staffed at any hour: 999, 101, and the local authority out-of-hours duty team. These are the routes to use outside the operating hours of the advice lines above.

Raising a concern in good faith is protected, and will never be held against anyone at School Of Fish.

10. Positions of Trust

Under the Sexual Offences Act 2003, as amended in 2022, sports coaches are in a position of trust in law towards 16 and 17 year olds they coach, supervise or train. Any sexual activity between an adult in a School Of Fish coaching, assisting or supervisory role and a 16 or 17 year old in their care is a criminal offence. Consent is no defence.

Beyond the legal threshold, School Of Fish prohibits romantic or sexual relationships between anyone in a coaching or supervisory role and any learner under 18, whatever the ages involved. A breach is reported to the police and the LADO where the law applies, and is gross misconduct in every case.

11. Late Collection and Missing Children

Parents and carers collect juniors promptly at the end of a session. If a child is not collected: two DBS-checked adults stay with the child at the meeting point. We ring the parent or carer, then the emergency contact from the booking. After 30 minutes without contact, the lead coach informs the DSL and considers ringing the police on 101 for advice. A coach never takes an uncollected child home or anywhere else, and never waits alone with them.

Heads are counted at fixed points: arrival, any move between swims, and the close of the session. If a child is unaccounted for beside open water, we call 999 immediately. There is no search-first period near water. One coach coordinates from the meeting point while the others keep the remaining children together and supervised. The DSL and the parent or carer are contacted at once, and the incident is recorded on the Incident Report Form within 24 hours.

12. Child-on-Child Abuse

School Of Fish recognises that children can abuse other children, and that group sessions, squads and shared transport create opportunities for it. It is treated as a safeguarding matter and follows the reporting procedure at section 6.2. It is never dismissed as banter, horseplay, or a normal part of growing up.

12.1 Forms it takes

• Physical abuse, including roughness presented as messing about.
• Emotional abuse, bullying and deliberate exclusion, whether in person or online.
• Sexual harassment, sexual violence, and sexualised comments or touching.
• Initiation or hazing behaviour connected to joining a group or squad.
• Sharing of nude or semi-nude images between children, including where it appears consensual.
• Upskirting, and abuse connected to a real or perceived difference such as disability, race, or sexual orientation.

12.2 Response

Staff and volunteers stop the behaviour, record what was seen or heard, and report to the DSL immediately, in line with section 6.2. Children are not asked to resolve the matter between themselves, and are not asked to account for their behaviour in front of other children. Both children are safeguarded: the child who was harmed, and the child who caused the harm, who may be experiencing harm themselves.

Where the concern involves sexual behaviour, or nude or semi-nude images, the DSL is contacted immediately rather than at the end of the session. Section 15 applies to any image.

13. Self-Harm and Suicidal Disclosure

A disclosure of self-harm, or that a child or adult at risk does not want to go on living, is a safeguarding concern and follows the reporting procedure at section 6.2.

• The disclosure is taken seriously on the first occasion. Staff do not assess whether the person means it.
• Confidentiality is not promised, and the matter is not withheld from the DSL at the person's request.
• Staff do not ask how the person harms themselves, do not ask them to show any injury, and do not search for injuries.
• Where there is believed to be immediate danger, the person is not left alone, a second adult is called, and the emergency services are contacted on 999.
• The DSL is informed immediately. Where the person is a child, the parent or carer is informed by the DSL, not by the reporting member of staff, unless the DSL directs otherwise.
• The disclosure is recorded in the person's own words on the Incident Report Form.

Staff and volunteers are not expected to provide counselling or clinical support. Their duty is to respond safely, report promptly, and record accurately.

14. Referrals to the Disclosure and Barring Service

Where School Of Fish dismisses or removes a member of staff, a coach or a volunteer from regulated activity because they have harmed a child or an adult at risk, or because they pose a risk of harm, School Of Fish has a legal duty under the Safeguarding Vulnerable Groups Act 2006 to refer that person to the Disclosure and Barring Service. The duty applies equally where the person resigns, retires, or ceases involvement before a decision is reached.

• The duty applies to volunteers and unpaid roles in the same way as to paid staff.
• The duty overrides any obligation of confidentiality owed to the individual.
• A referral is made after an internal investigation has established that the referral criteria are met, and is not made at the point an allegation is first received.
• A referral to the DBS does not replace referral to the Local Authority Designated Officer or to the police, and does not delay either.

The DSL is responsible for making the referral and for retaining a record of it.

15. Indecent Images and Online Disclosures

Where a child sends an indecent or semi-indecent image, or where such an image comes to the attention of a member of staff or volunteer, the image must not be viewed further, copied, saved, printed, forwarded or screenshotted by any member of School Of Fish, including the DSL. Copying such an image is a criminal offence under the Protection of Children Act 1978, irrespective of the purpose or the recipient.

• The material is left in place and is not deleted, because deleting it destroys evidence. Where the material has arrived on a personal device, the matter is reported immediately so that there is a dated record of how and why it is there.
• The DSL is contacted immediately, and the DSL contacts the police, who have lawful means to obtain the material.
• Where a message contains text only, a screenshot may be taken and passed to the DSL as evidence.
• No member of staff investigates the content or questions the child about it.

This section applies to communications on any platform, including messaging applications, social media, and any School Of Fish online community.

16. Safeguarding Records

Safeguarding records are held separately from general membership and booking records, and are accessible only to the Designated Safeguarding Lead and, where the law requires it, the statutory agencies.

• A safeguarding record about a child is retained until that child reaches the age of 25. A safeguarding record about an adult at risk is retained for six years from the date the matter was concluded.
• Where a record is known to relate to an allegation or case of child sexual abuse, it is retained for 75 years with periodic review, following the recommendation of the Independent Inquiry into Child Sexual Abuse.
• Records found to be unfounded or malicious are removed from the individual's record.
• No record is destroyed, amended after the fact, or judged to be no longer relevant by anyone other than the DSL.
• Staff and volunteers do not retain personal copies of safeguarding records on personal devices, in personal accounts, or in personal email.

Retention periods and the lawful basis for holding this information are set out in the Privacy Policy.

17. Communication and Accessible Disclosure

A disclosure does not have to be spoken to be a disclosure. Where this policy or any School Of Fish guidance refers to recording a person's own words, that includes words that are written, typed, drawn, signed, or produced through augmentative and alternative communication.

• Where a disclosure is made in written or typed form, the original is preserved and passed to the DSL.
• Staff allow processing time and do not fill silences, since doing so risks leading the person.
• Staff use literal language and avoid figurative phrasing when responding to a disclosure.
• Distress presenting as behaviour, including shutdown or meltdown, is treated as communication and not as misconduct.

This section reflects the communication standards applied across School Of Fish coaching.

18. Mandatory Reporting of Child Sexual Abuse

The Crime and Policing Act 2026 received Royal Assent on 29 April 2026 and creates a statutory duty on individuals engaged in regulated activity with children in England to report child sexual abuse of which they are made aware. The duty had not commenced at the date of the last amendment to this policy, and the Government has yet to publish the accompanying guidance.

18.1 Effect when commenced

• The duty applies to anyone in regulated activity with children, including coaches, assistants and volunteers.
• A report is required where a child discloses sexual abuse, where the person responsible discloses it, or where a member of staff witnesses it.
• The report is made to the police or the local authority as soon as is reasonably practicable, and may be delayed by no more than seven days and only where immediate reporting would increase the risk to the child.
• Only one report is required for each disclosed incident.
• The duty does not apply where a person has observed indicators of abuse alone. Such concerns remain subject to section 6.2 of this policy.
• Obstructing or deterring another person from making a report is a criminal offence.
• Failure to comply may result in referral to the Disclosure and Barring Service.

18.2 Position until commencement

Until the duty commences, staff and volunteers follow section 6.2 and report to the DSL immediately. School Of Fish will amend this policy, the coach guidance and its coach training when the duty commences and the statutory guidance is published, and will notify all coaches at that point.

19. Away Events, Competitions and Travel

The School Of Fish Squad fishes competitions away from home water, and juniors attend events run by other organisations. Every standard in this policy applies away from home exactly as it does on our own bank. The following additional requirements apply.

• A named lead coach is responsible for the group for the whole event, from the agreed meeting point to the agreed hand-back point.
• Two DBS-checked School Of Fish adults attend as a minimum, and the ratio agreed for the event is maintained throughout.
• A register is taken at the meeting point, at any move between venues or pegs, and at the close. Head counts are not left to memory.
• Written parental consent is obtained for the specific event, and includes emergency contact details and any medical information the coaches need.
• Parents are told in advance where the event is, when it starts and ends, and who the named lead coach is.
• School Of Fish remains responsible for its own juniors at an event run by another organisation. Our coaches do not hand supervision to another organisation's staff, and our juniors are not left in the care of adults who are not known and checked by us.
• A junior leaving an event early goes only to a parent, carer, or a person named in writing by them in advance.
• Transport is arranged by parents or by an agreed group arrangement. Section 5.3 applies to private vehicles without exception.
• Any safeguarding concern arising at an away event is reported to the DSL immediately, from the venue, and is not held over until the group returns.

Overnight stays are not currently part of any School Of Fish junior activity. If that changes, this policy is amended before the first overnight event takes place.

Safeguarding Concern?

Contact our Designated Safeguarding Lead, Ulvis Strokss.

07713 177685 · safeguarding@schooloffish.co.uk