SAFEGUARDING & CONFIDENTIALITY POLICY

Organisation: Chocolate & Co

Policy Owner: Safeguarding Lead

Effective Date: March 2026

Review Date: March 2027

Our Vision 

We envision a community free from social exclusion, where all are given the opportunity to realise their full potential as an active member of society. 

 
Our Mission 

Through  supportive, non-judgemental relationships we enable a safe and nurturing space to create a new narrative, to realise lasting and authentic change through training, education and employment opportunities. Chocolate & Co provides mentoring, training and paid employment opportunities to people who are in recovery from addiction and or have a criminal record.  

Chocolate & Co is committed to safeguarding adults at risk both those within and external to the organisation, and we expect everyone who works for us to share this commitment. This policy sets out how Chocolate & Co will deliver these responsibilities and the role staff will play in ensuring that Chocolate & Co’s commitment to safeguarding adults who have care and support needs is fully met.  

This policy is intended to support staff and volunteers working within Chocolate & Co to understand their role and responsibilities in safeguarding adults. All staff and volunteers are expected to follow this policy.

1. PURPOSE

Chocolate & Co is committed to safeguarding and promoting the welfare of all individuals we work with.

We recognise that many of our participants may be in vulnerable situations, including recovery from addiction, involvement with the criminal justice system, or experiencing mental or physical health challenges.

This policy sets out how we:

  • protect individuals from harm

  • respond to safeguarding concerns

  • handle sensitive and confidential information

  • meet our legal obligations under UK GDPR and the Data Protection Act 2018

2. SCOPE

This policy applies to:

  • all staff

  • volunteers

  • trustees

  • contractors

It applies to all individuals engaging with Chocolate & Co, including:

  • programme participants and referrals

  • customers

  • members of the public

3. SAFEGUARDING PRINCIPLES

We adopt a person-centred and trauma-informed approach. We will:

  • treat all individuals with dignity and respect

  • create a safe, inclusive, and non-judgemental environment

  • empower individuals to make informed choices

  • recognise the impact of trauma and avoid re-traumatisation

  • prioritise safety and wellbeing at all times

4. WHAT IS SAFEGUARDING

Safeguarding means protecting individuals from:

  • abuse

  • neglect

  • exploitation

  • harm to themselves or others

We follow the principles of the Care Act 2014, focusing on:

  • prevention

  • protection

  • partnership

  • accountability

We use the term “adults at risk” to describe individuals who may need safeguarding support.

5. ROLES AND RESPONSIBILITIES

Safeguarding Lead

Chocolate & Co will appoint a Safeguarding Lead responsible for:

  • receiving and managing safeguarding concerns

  • advising staff and volunteers

  • making decisions about information sharing

  • liaising with external agencies (e.g. social services, police)

  • maintaining safeguarding records

All Staff and Volunteers

All staff and volunteers must:

  • complete safeguarding training

  • understand this policy

  • act promptly on concerns

  • maintain appropriate confidentiality

  • follow reporting procedures

6. CONFIDENTIALITY

We respect confidentiality and will:

  • only collect information that is necessary

  • explain why information is being collected

  • store information securely

  • limit access to authorised personnel only

However, confidentiality is not absolute.

We may share information without consent where:

  • there is a risk of harm to the individual or others

  • safeguarding concerns arise

  • we are required to do so by law

Where possible, we will explain this to the individual.

7. HANDLING DISCLOSURES

If someone shares a concern or sensitive information:

Staff must:

  • listen calmly and without judgement

  • allow the individual to speak at their own pace

  • reassure them they have done the right thing

  • explain that information may need to be shared to keep people safe

  • record the information accurately

Staff must not:

  • promise absolute confidentiality

  • ask leading or investigative questions

  • make assumptions or judgments

  • attempt to resolve the situation alone

All concerns must be reported to the Safeguarding Lead as soon as possible.

8. REPORTING PROCEDURE

  1. Immediate risk:
    Contact emergency services (999)

  2. Non-emergency safeguarding concern:
    Report to the Safeguarding Lead immediately

  3. Record the concern:

    • factual and accurate

    • dated and signed

    • stored securely

  4. Safeguarding Lead action:

    • assess risk

    • decide whether to refer to external agencies

    • document decisions and actions

9. SPECIAL CATEGORY AND CRIMINAL DATA

Due to the nature of our work, we may process sensitive information including:

  • mental health

  • substance use or recovery

  • physical health

  • criminal convictions

This data is:

  • collected only where necessary

  • processed in line with our Appropriate Policy Document (APD)

  • handled with strict confidentiality

  • accessed only by trained and authorised staff

We collect this information to:

  • provide appropriate support

  • maintain a safe environment

  • meet safeguarding responsibilities

10. INFORMATION SHARING

We follow the principle:

“Share information where necessary to safeguard, but only what is needed.”

When sharing information, we ensure it is:

  • necessary

  • proportionate

  • relevant

  • accurate

  • secure

Information is only shared with:

  • authorised staff

  • relevant external agencies where required

11. DATA SECURITY AND HANDLING

We protect sensitive information by:

  • restricting access to those who need to know

  • using secure systems for storage

  • ensuring staff understand confidentiality obligations

  • avoiding the use of unsecured communication methods for sensitive data where possible

Sensitive data (e.g. health or criminal history) is subject to:

  • additional access controls

  • heightened confidentiality

12. RECORD KEEPING

We will:

  • keep clear, factual, and accurate records

  • record decisions and actions taken

  • store records securely

  • restrict access appropriately

Records relating to safeguarding are retained in line with our data retention policy and reviewed regularly.

13. BREACHES AND INCIDENTS

Any breach of confidentiality or data security must be:

  • reported immediately

  • investigated promptly

  • escalated where necessary

Serious breaches may be reported to the Information Commissioner’s Office (ICO).

14. SAFER WORKING PRACTICE

All staff and volunteers must:

  • maintain professional boundaries

  • avoid relationships that could be considered an abuse of trust

  • act in a way that protects both themselves and others

15. CHILD SAFEGUARDING

Although Chocolate & Co does not directly work with children, we recognise that:

  • adults we work with may have contact with children

  • safeguarding concerns relating to children may arise

All staff must:

  • remain alert to risks involving children

  • report concerns in line with this policy

16. TRAINING AND AWARENESS

We ensure that staff and volunteers:

  • receive safeguarding training

  • understand confidentiality and data protection

  • are aware of trauma-informed approaches

  • understand reporting procedures

17. GOVERNANCE AND REVIEW

This policy will be:

  • reviewed annually

  • updated in line with legal and operational changes

Senior leadership and trustees are responsible for:

  • ensuring implementation

  • monitoring compliance