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
Immediate risk:
Contact emergency services (999)Non-emergency safeguarding concern:
Report to the Safeguarding Lead immediatelyRecord the concern:
factual and accurate
dated and signed
stored securely
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