This Code of Conduct details the standards and practice required by all Scottish Schools’ FA members, including verbal and non-verbal actions when involved in activities with children and young people.
**All concerns about breach of this Code of Conduct will be taken seriously and responded to in line with the Scottish Schools’ FA Procedures for Responding to Concerns about the Conduct of an Adult and/or Disciplinary Procedures.
In the context of the Scottish Schools’ FA, the following practice should be avoided:
All SSFA personnel will be required to complete and the Bullying Code of Conduct Form (Appendix 2)
The role of risk assessment within the Scottish Schools’ FA in relation to promoting, supporting and safeguarding a child’s wellbeing lies with the Child Protection & Safeguarding Officer. This is completed on an annual basis and risks identified form the relevant policies, procedures and safeguards, as well as training provision. While there are numerous risks, these are assessed and acted on in different ways. It is important however to highlight some areas in particular to improve knowledge and understanding of why some risks exist and why some groups may be more vulnerable, though these examples are not exclusive.
The risks in recruitment are around the suitability of people working with children. Therefore, all reasonable steps must be taken to ensure unsuitable people are prevented from working with children, including PVG clearance, induction and training. Safeguarding checks will be continued through regular completion of self-declaration forms and three-yearly updates on PVG scheme membership during involvement with the Scottish Schools’ FA.
The power and influence a person has over someone they are coaching or looking after in football cannot be underestimated. If there is an additional competitive aspect to the activity and the older person is responsible for the young person’s success or failure, then the dependency of the younger member upon the older will be increased. It is therefore vital for everyone to recognise the responsibility they must exercise in ensuring that they do not abuse their position of trust.
It must also be understood that the notion of ‘relationships of trust’ applies as much to young people who have taken on a leadership role as it does to adults involved in football.
The majority of adults involved in Scottish Schools’ FA programmes with children participate with the main aim of providing a fun, positive experience for those with whom they work. However, others (though a minority) may use football as a way of gaining access to children for inappropriate reasons such as sexual abuse.
In order to gain access to children, those who commit offences often first earn the trust of people surrounding the child. This process is referred to as ‘grooming.’
Those who commit offences often portray themselves as caring and trustworthy individuals so they are freely entrusted with the care of children. Once they have gained access to children, they befriend them in order to break down any pre-existing barriers. As soon as a trusting friendship has been established, they manipulate and control children into gratifying their sexual needs.
Procedure for Responding to Concerns about a Child
These procedures apply to all persons involved in Scottish Schools’ FA activities with children under 18 years old.
Best Interests of the Child
The Scottish Schools’ FA is committed to working in partnership with parents/carers whenever there are concerns about a child.
Parents/carers have the primary responsibility for the safety and wellbeing of their children.
Where concerns are raised about a child, this will be considered in line with the wellbeing indicators and may be discussed with parents/carers. For example, if a child seems withdrawn, he/she may have experienced an upset in the family, such as a parental separation, divorce or bereavement. Common sense is advised in these situations and the best interests of the child will be considered as to what is the best support for each individual child. Children will be asked who they feel is suitable to be informed and, when relevant, consent gained from the child.
Confidentiality will not be maintained if it is assessed that a child is at risk or their wellbeing is being impacted in such a way that their right to be protected becomes more significant. Any incidents which cause concern about the wellbeing of a child should be recorded on the Concern Recording Form (see Appendix 3) and reported to the Scottish Schools’ FA Child Protection and Safeguarding Officer as soon as possible. In line with early intervention, the principles of the Children and Young People (Scotland) Act 2014 and the Getting it Right for Every Child approach, appropriate and proportionate information may be shared with the child’s Named Person.
Information Regarding Concern about a Child
Members of staff, volunteers or members of the Council may be informed in different ways with regards to details of a concern about a child. This may be a direct disclosure by the child. In this situation follow section 4 in responding to that disclosure. The details may become clear due to the observation of a child, which is perhaps demonstrated in a change in their behaviour, appearance or nature. A third option could be information that is shared from another individual or organisation. A concern or possible abuse of a child may be observed by another child or adult.
Depending on the nature of the concern, observations or information from others, this may not need to be discussed with the child, instead the information recorded then reported. Advice should be sought from the Child Protection and Safeguarding Officer if there is any uncertainty about the appropriate course of action where there are concerns about a child’s wellbeing which can be discussed by anonymising the child, therefore maintaining confidentiality if appropriate.
If the Child Protection and Safeguarding Officer is not available and an immediate response is required, the police and social work services must be contacted. They have a statutory responsibility for the protection of children and they may already hold other concerning information about the child. Record any advice given, actions taken and the response by other agencies. At the earliest opportunity thereafter the Child Protection and Safeguarding Officer should be informed and the child’s Named Person notified.
Concerns affecting a Child’s Wellbeing
If a concern about a child is identified that affects one or more of their eight wellbeing indicators (safe, healthy, active, nurtured, achieving, respected, responsible, included), complete Part A of the Concern Recording Form.
When information is being recorded about a child, it is important that the child understands why we are recording their details and gain their consent where possible for further reporting of the concern. If a child recognises that people can help and support, and that this is the purpose of their details being shared, they will be more included and informed of the processes.
Where there is information or details in relation to the conduct an adult affecting a child’s wellbeing, this should be recorded in Part B of the Concern Recording Form.
Child’s Right to be Protected
Where the concern about a child’s wellbeing suggests they are in need of protection, the information must be passed on with or without their consent for the purposes of their protection. Allegations of abuse must always be taken seriously.
No member of the Scottish Schools’ FA shall investigate allegations of abuse or decide whether or not a child has been abused.
False allegations are very rare. If a child says or indicates they are being abused or information is obtained which gives concern that a child is being abused, the information must be responded to on the same day in line with the following procedure.
What to Do if a Child Discloses Abuse
1. Respond, so:
- React calmly so as not to frighten the child.
- Listen to the child and take what they say seriously. Do not show disbelief.
- Reassure the child they are not to blame and were right to tell someone.
- Be aware of interpreting what a child says, especially if they have learning or physical disabilities which affect their ability to communicate or English is not their first language.
- Do not assume that the experience was bad or painful - it may have been neutral or even pleasurable.
- Avoid projecting your own reactions onto the child.
- Avoid asking any questions. If necessary only ask enough questions to gain basic information to establish the possibility that abuse may have occurred. Only use open-ended, non-leading questions e.g. What? When?Where? Who?
- Do not introduce personal information from either your own experiences or those of other children.
- Showing shock or distaste.
- Probing for more information than is offered.
- Speculating or making assumptions.
- Making negative comments about the person against whom the allegation has been made.
- Approaching the individual against whom the allegation has been made.
- Making promises or agreeing to keep secrets and giving a guarantee of confidentiality.
If you are concerned about the immediate safety of the child:
- Take whatever action is required to ensure the child’s immediate safety.
- Pass the information immediately to the police and seek their advice.
Make a written record of the information as soon as possible using the Concern Recording Form completing as much of the form as possible. It is important that the contact details of the child’s parent/guardian/ Named Person are included.
Contact the Child Protection and Safeguarding Officer as soon as possible after completion.
Do not delay by attempting to obtain information to complete all sections.
Please do not keep any electronic, printed or written versions of this form. It is important to maintain confidentiality to delete or shred as soon as the information has been passed on.
Sharing Concerns with Parents/Carers
Where there are concerns that the parents/carers may be responsible for or have knowledge of the abuse, sharing concerns with the parents/carers may place the child at further risk. In such cases advice must always firstly be sought from the police/social work services or Named Person as to who informs the parents/carers.
Procedure for Responding to Concerns about the Conduct of an Adult
In all cases where there are concerns about the conduct of an adult towards a child, the best interests and wellbeing of the child will be the paramount consideration. These procedures aim to ensure that all concerns about the conduct of an adult are dealt with in a timely, appropriate and proportionate manner. No person in receipt of information that causes concern about the conduct of an adult towards children shall keep that information to himself or herself, or attempt to deal with the matter on their own.
At any point in responding to concerns about the conduct of an adult, advice may be sought from the police or social work services.
Initial Reporting of Concerns
Any concerns for the wellbeing of a child arising from the conduct of an adult must be reported to the Scottish Schools’ FA Child Protection and Safeguarding Officer on the day the concern arises, as soon as practically possible.
Where the concern is about the Child Protection and Safeguarding Officer it must be reported to the General Secretary or President. In this situation, they will then take on the role and responsibilities as listed below of the Child Protection and Safeguarding Officer.
Recording and Reporting
Concerns must be recorded using the Concern Recording Form (see Appendix 3) as soon as possible. Contact the Child Protection and Safeguarding Officer to report the concern then email the completed form as soon as possible after completion.
Do not delay by attempting to obtain information to complete all sections. Please do not keep any electronic, printed or written versions of this form. It is important to maintain confidentiality to delete or shred as soon as the information has been passed on.
All subsequent actions taken and reasons for decisions shall be recorded (in the order in which they happened).
These records should be signed and dated by the Child Protection and Safeguarding Officer. Where Scottish Schools’ FA Disciplinary Procedures are invoked for members of staff or volunteers, a written record will be made of all actions and reasons for decision.
Once the concerns have been reported, the Child Protection and Safeguarding Officer will:
Establish the basic facts:
- Conduct an initial assessment of the facts in order to determine the appropriate course of action.
- Consult external agencies such as the police and social work services for advice at any time. This is important because they may hold other important information which, when considered alongside the current concerns, builds a significant picture of concern.
The Child Protection and Safeguarding Officer will conduct the initial assessment.
The purpose of the initial assessment is to clarify the nature and context of the concerns. It should determine if the adult’s conduct was inappropriate behaviour, serious poor practice/misconduct or whether there is reasonable cause to suspect an adult’s behaviour and conduct has been criminal. Every situation is unique so guidance cannot be prescriptive.
Where the established facts support a concern of criminal behaviour, the initial assessment will not form part of the disciplinary investigation.
Subject to the nature and seriousness of the situation, if it is not clear at this stage whether a criminal offence may have been committed, the member of staff, volunteer or member of the Council may be approached as part of the information gathering process.
Where the nature and seriousness of the information suggests that a criminal offence may have been committed, or that to assess the facts may jeopardise evidence, advice will be sought from the police before the member of staff, volunteer or member of the Council is approached.
An initial assessment of the basic facts may require the need to ask a child some basic, open-ended, non-leading questions solely with a view to clarifying the basic facts. It may also be necessary to ask similar basic questions of other children, or other appropriate individuals.Interviewing children about possible abuse and criminal offences is the sole remit of specially trained police officers and social workers. Questioning of children by those conducting an initial assessment should always be avoided as far as possible. If it is necessary to speak to the child in order to clarify the basic facts, best practice suggests that consent from the parent/carer be obtained.
Possible outcomes of initial assessment:
- No further action (facts do not substantiate complaint).
- Situation is dealt with under the Scottish Schools’ FA Disciplinary Procedures for members of staff and volunteers or complaint raised about a member of the Council with the Scottish Schools’ FA Compliance Officer.
- Child protection investigation (jointly by police and social work services).
- Criminal investigation (by the police). The results of a criminal investigation may well influence the disciplinary investigation, but not in all cases.
- Civil proceedings (by the child/family who raised the concern).
Initial Assessment Supports Concerns about Poor Practice and/or Misconduct
The Child Protection and Safeguarding Officer will deal with the concern in line with the Scottish Schools’ FA Disciplinary Procedures for members of staff and volunteers. With respect to a member of the Council, a complaint with be made to the Scottish Schools’ FA Compliance Officer. In the event of an investigation into the conduct of a member of staff, volunteer or member of the Council, all actions will be informed by the principles of natural justice:
- They will be made aware of the nature of concern.
- They will be given an opportunity to put forward their case.
- The Scottish Schools’ FA will act in good faith, ensuring the matter is dealt with impartially and as quickly as possible in the circumstances.
Pending the outcome of any investigation, precautionary suspension will be considered in all cases where there is significant concern about the conduct of a member of staff, volunteer or member of the Council towards children.
Any impact on a child’s wellbeing caused by an adult’s poor practice and/or misconduct will be passed on to the child’s Named Person.
Initial Assessment Supports Concerns about Possible Criminal Behaviour
Where the initial assessment of information gives reasonable cause to suspect an adult’s behaviour and conduct has been a criminal offence, the Child Protection and Safeguarding Officer will report the concerns to the police as soon as possible on the day the information is received. The Child Protection and Safeguarding Officer will make a written record of the name of the police officer to whom the concerns were passed together with the time and date of the call, in case any follow up is required.
Referrals to the police will be confirmed in writing by the Child Protection and Safeguarding Officer within 24 hours.
A copy of the Concern Recording Form should be provided to the police on request. Appropriate steps will be taken to ensure the safety of the child(ren) or who may be at risk. The parents/carers of the child(ren) involved will be informed as soon as possible following advice from the police. Any impact on a child’s wellbeing caused by an adult’s possible criminal behaviour will be passed on to the child’s Named Person.
Advice will firstly be obtained from the police about informing the member of staff, volunteer or member of the Council involved in the concerns. If the advice is to inform them, they will be told that information has been received which may suggest an allegation of abuse or possible criminal offence. As the matter will be sub judice (i.e. under judicial consideration) no details will be given unless advised by the police. All actions will ensure the best evidence is preserved for any criminal proceedings while at the same time safeguarding the rights of the member of staff, volunteer or member of the Council.
The Scottish Schools’ FA will take all reasonable steps to support a member of staff, volunteer or member of the Council against whom a concern has been raised.
Suspension is not a form of disciplinary action. The member of staff or volunteer involved may be suspended whilst an investigation is carried out. Suspension will be carried out by the Head of HR in accordance with the Scottish Schools’ FA Disciplinary Procedures. At the suspension interview the member of staff or volunteer will be informed of the reason for suspension (within the confines of sharing information) and given the opportunity to make a statement – which will be recorded – should they wish to do so.
Notification of the suspension and the reasons will be conveyed in writing to the member of staff or volunteer in accordance with the Scottish Schools’ FA Disciplinary Procedures.
An ongoing criminal investigation does not necessarily rule out disciplinary action. However, any action taken must not jeopardise the criminal investigation. Advice must be taken from the police on this. Sufficient information should be available to enable the Child Protection and Safeguarding Officer to make a decision whether to go ahead with disciplinary action.
False or Malicious Allegations
In exceptional circumstances where an investigation establishes an allegation or concern raised is false, unfounded or malicious:
- The member of staff, volunteer or member of the council involved will receive an account of the circumstances and/or investigation and a letter confirming the conclusion of the matter. They may wish to seek legal advice.
- All records pertaining to the circumstances and investigation shall be kept confidentially.
- The Child Protection and Safeguarding Officer will take all reasonable steps to support the individual in this situation.
- In these circumstances the Scottish Schools’ FA will review the child’s participation in football. It will be appropriate to have a discussion with the child (with parental/carer permission) in determining their views and opinions.
- Data collected for the investigation will be destroyed in accordance with the requirements of the Data Protection Act 1998.
Historic Allegations of Abuse
Allegations of abuse may be made some time after the event e.g. an adult who was abused as a child by someone who is still currently working with children. These procedures will be followed in the event of an allegation of historical abuse.
Protection of Vulnerable Groups (Scotland) Act 2007
The Scottish Schools’ FA will refer to Disclosure Scotland the case of any member of staff or volunteer who (whether or not in the course of their role with the Scottish Schools’ FA) has:
- placed a child at risk of harm
- engaged in inappropriate conduct involving pornography
- engaged in inappropriate conduct of a sexual nature involving a child, or
- given inappropriate medical treatment to a child.
AND as a result:
1. The Scottish Schools’ FA has dismissed the member of staff or volunteer.
2. The member of staff or volunteer would have been dismissed as a result of the incident had they not resigned, retired or been made redundant.
3. The Scottish Schools’ FA has transferred the member of staff or volunteer to a position in the Scottish Schools’ FA which is not regulated work with children.
4. The member of staff or volunteer would have been dismissed or considered for dismissal where employment or volunteer role was not due to end at the expiry of a fixed term contract; or,
5. The member of staff or volunteer would have been dismissed or considered for dismissal had the contract not expired.
The Scottish Schools’ FA will also refer the case of a member of staff or volunteer where information becomes available after the member of staff or volunteer has:
- been dismissed by the Scottish Schools’ FA,
- resigned, retired or been made redundant,
- been transferred to another position in the Scottish Schools’ FA which is not regulated work with children; and,
- where the Scottish Schools’ FA receives information that a member of staff or volunteer who holds a position of regulated work has been listed on the Children’s List, the member of staff or volunteer will be removed from the regulated work with children post.
If Disclosure Scotland notifies the Scottish Schools’ FA that a member of staff or volunteer is considered for listing, that individual will be suspended as a precaution until the outcome of the case is determined. Precautionary suspension is not a form of disciplinary action and does not involve pre-judgment. In all cases of suspension the best interests and wellbeing of children will be the paramount consideration.
If Disclosure Scotland informs the Scottish Schools’ FA that an individual is barred, that member of staff or volunteer will be removed from regulated work with children immediately in line with the Protection of Vulnerable Groups (Scotland) Act 2007.
All media enquiries relating to the conduct of a member of staff, volunteer or member of the Council will be referred to the Scottish Schools’ FA General Secretary.