HASPv.25.03.15.1
The Oxford School for the Future of Journalism (OXSFJ) is committed to preventing and responding to risks of harm to and promoting the welfare of all children that we work with. This Safeguarding Policy has been introduced to ensure a structured, transparent, and proactive approach to safeguarding within all our programmes. It establishes clear guidelines for staff, volunteers, and partners, reinforcing our organisational values and compliance with safeguarding standards.
1. Definitions
Attended Course – A summer school, educational holiday trip, or other in-person training event organised by the Company, where safeguarding measures must be observed to ensure the safety of all participating Students.
Background Checks – Verifying an individual’s suitability to work with children. This includes Disclosure and Barring Service (DBS) criminal record checks or the closest equivalent in a staff member’s country of residence.
Beneficiaries – Children who receive Services from the Oxford School for the Future of Journalism under the Harbingers’ Academy line of services and thus are covered under this Safeguarding Policy. May be used interchangeably with “Student”.
Child – Any individual under the age of 18.
Client – The individual, organisation, or legal entity that purchases or funds services provided by the Company. Client might be, but not necessarily is Parent/Guardian.
Code of Conduct – The ethical guidelines that all Staff Members must adhere to promote a safe and professional environment for children and beneficiaries.
The Company – (“we”, “us”, “the OXSFJ”, “the Harbingers’ Academy) – The Oxford School for the Future of Journalism Ltd (OXSFJ).
Confidential Information – Any non-public information disclosed by the Company, Client, or Student, including personal data, business practices, or intellectual property. Confidential Information should be handled in accordance with the Company’s legal obligations, including safeguarding, whistleblowing, and data protection laws.
Consent Form – A document that must be signed by the Parent/Guardian of a Student under the age of 18 before the Student can participate in the Company’s services. The Consent Form confirms parental/legal guardian approval and establishes the primary methods of contact between the Company, the Parent/Guardian, and the Student.
Data Protection Laws – Refers to the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and other applicable laws governing the processing of personal data.
Designated Safeguarding Lead (DSL) – The individual responsible for overseeing safeguarding practices and policies, acting as the main point of contact for safeguarding concerns.
Investigation and Response – The process of handling reported safeguarding concerns, including maintaining records, investigating concerns, and referring cases to external authorities when necessary.
Online Course – A remote journalism workshop delivered via digital platforms that focuses on developing language and reporting skills.
Parent/Guardian – The legal guardian of a Student under the age of 18 who provides consent for their participation in the Company’s services. A Parent/Guardian may also be a Client when they purchase or fund Services.
Programme – A funded journalism project or other funded opportunity that enables Students to engage in educational and reporting activities.
Relevant Activities – The organisation and operation of all OXSFJ’s activities involving children, including online teaching, reporting trips, summer schools, and pop-up newsrooms.
Reporting Procedures – The internal processes for reporting and responding to safeguarding concerns, ensuring they are dealt with appropriately and fairly.
Safeguarding – An umbrella term referring to practices and procedures aimed at preventing harm or responding to risks of harm to vulnerable individuals, particularly children.
Safeguarding Concern – Any situation or conduct known or reasonably suspected by a Staff Member that risks violating the Company’s safeguarding commitments.
Service – Collectively refers to Online Courses, Attended Courses, and Programmes provided by the Company under the Harbingers’ Academy line of services.
Staff Member – All individuals working for, contracted by, or otherwise acting on behalf of The Harbingers’ Academy at any level, including senior managers, officers, employees, consultants, trainees, homeworkers, part-time and fixed-term workers, casual workers, agency workers, volunteers, and interns. These individuals are expected to know and follow the Safeguarding Policy.
Student – The individual enrolled in an Online Course, Attended Course, or Programme offered under the Harbingers’ Academy line of services.
Third-Party Service Provider – External vendor or contractor that the Company may engage to assist in delivering Services, including but not limited to guests, external contributors, accommodation providers, transportation providers, teachers, professionals, and software platforms used for Online Courses. These individuals or entities are not under the direct supervision of OXSFJ and cannot be reasonably expected to know and follow OXSFJ’s Safeguarding Policy.
Travel Consent Form – A required document for Students participating in Attended Courses. It contains details of the Attended Course, the Student’s personal information, and any applicable special terms. The Parent/Guardian must ensure that the Student has a printed, signed copy of the Travel Consent Form before departure. Failure to provide this document may result in denied participation.
Whistleblowing – The act of reporting safeguarding concerns in a manner protected by law to ensure confidentiality and prevent retaliation.
2. Statement of Purpose
2.1 This Safeguarding Policy applies to all staff engaged in The Harbingers’ Academy, a line of services offered by The Oxford School for the Future of Journalism Ltd (Registered with the Companies House for England and Wales under Company no: 13565860) whose registered office is at Suite 14, 266 Banbury Road, Summertown, Oxford, England, OX2 7DL, United Kingdom, and all other Company’s services involving engagement with children.
2.2 The Company recognises the importance of this commitment to safety and welfare and is committed to safeguarding all Beneficiaries without discrimination.
2.3 This Safeguarding Policy is based on the safeguarding laws of England, Wales, and Scotland, including related guidance issued by the UK Government and relevant governmental departments, agencies, and public bodies. This policy is specifically informed by UK legislation and guidance, including The Children Act 1989 and 2004, The Education Act 2002, Working Together to Safeguard Children 2018, Keeping Children Safe in Education 2022, as well as Public Interest Disclosure Act 1998 and Employment Rights Act 1996, especially where the latter two are relevant to whistleblowing and the protection of children.
If this Policy is at any time inconsistent with this body of law, the Company will act to meet the requirements of up-to-date safeguarding laws in priority to the requirements set out in this Policy.
2.4 As the Company is an international organisation, it seeks to ensure that values and practices derived from UK law are, at minimum, the standard in the Company while following international and national safeguarding regulations and guidance of the states where it operates.
2.5 The Company has implemented this Safeguarding Policy for the Harbingers’ Academy to meet its obligations as an organisation working with children.
2.6 The Company follows guidance, advice, and best practices from the National Society for the Prevention of Cruelty to Children (NSPCC), a leading British charity specialising in safeguarding and promoting the welfare of children, ensuring that all safeguarding measures are in line with the latest research and legal standards.
2.7 Any questions about this Policy should be referred to a Designated Safeguarding Lead (DSL).
3. Scope of this Safeguarding Policy
3.1 This Policy explains key aspects of how The Harbingers’ Academy prevents harm in relation to its Beneficiaries through its practices and the conduct of its Staff Members.
3.2 This Safeguarding Policy covers the organisation and operation of all services provided under the Harbingers’ Academy line of services that involve children. These primarily include Online courses, Attended courses, and Programmes.
3.3 Furthermore, this Policy’s guidelines and obligations apply to all the Company’s Staff Members engaged in activities that involve children.
3.4 This Policy does not form part of any contract of employment or similar, and the Director of the Company may amend it at any time at their discretion.
4. Company’s Safeguarding Commitments
To achieve the objectives of this Safeguarding Policy, the Company commits to:
4.1 Ensure that Staff Members are trained to, and encouraged to, report any Safeguarding Concerns that they identify. Staff Members will be encouraged to follow the Company’s safeguarding reporting procedures as closely as possible when reporting concerns (set out below under the heading ‘Procedures: Reporting’).
4.2 Ensure that all Staff Members listen to all safeguarding-related queries and concerns raised by other Staff Members, Beneficiaries, or other relevant parties with respect and professionalism. Staff members should be trained on how to, and encouraged to, then assist with reporting any such concerns via the Company’s regular reporting procedures.
4.3 Ensure that all reported Safeguarding Concerns are dealt with by appropriate individuals and teams and in accordance with the Company’s relevant procedures (set out below under the heading ‘Procedures: Investigation and Response’).
4.4 Implement and maintain procedures for Staff Members to use when reporting and dealing with Safeguarding Concerns. These procedures will be made known and easily accessible to all Staff Members.
4.4.1 Procedures will be comprehensive, accessible, fair, designed to ensure all safeguarding issues are dealt with fairly and objectively, even when allegations are made against one of the Company’s Staff Members. Any such allegations will be treated in a manner that considers the gravity of the accusations, but which does not vilify or presume the guilt of an accused individual without a fair investigation.
4.4.2 Any reports that qualify as protected disclosures under whistleblowing law will be treated securely and in a protected manner in line with whistleblowing law.
4.5 Appoint a Designated Safeguarding Lead (DSL) to hold responsibility for managing safeguarding policies and procedures within the Company, in particular:
4.5.1 Oversee safeguarding practices and policies.
4.5.2 Act as the primary point of contact for safeguarding concerns.
4.5.3 Ensure that Staff Members are trained, aware of their safeguarding responsibilities, and that their criminal record checks and safeguarding training are up to date.
4.5.4 Coordinate the referral processes into UK local authority children’s social care team and liaise with external agencies and authorities as necessary.
4.5.4 Coordinate improvements in safeguarding procedures across the Company.
4.5.5 The Designated Safeguarding Lead (DSL) is appointed by the Director of the Oxford School for the Future of Journalism from Staff Members.
4.5.6 The individual appointed to be the DSL should, where possible, not involved in delivering Company’s services to Beneficiaries.
4.5.7 The DSL undergoes additional training from the NSPCC.
4.6 Include safeguarding conferns into recruitment processes, in particular::
4.6.1 Conduct all appropriate pre-employment checks (e.g., Disclosure and Barring Service (DBS) criminal record checks or the closest equivalent in a Staff Member’s country of residence).
4.6.2 Ensure new Staff Members take part in necessary safeguarding training from the NSPCC, complete background checks and understand the content of the contents of this Safeguarding Policy before having any contact with the Company’s Beneficiaries.
4.7 Provide safeguarding training for all relevant Staff Members. Every Staff Member should be provided with, and required to undertake, training appropriate to their role, responsibilities, and degree and type of contact with Beneficiaries. This training should include:
4.7.1 How to define and identify potential signs of different types of abuse, including physical abuse, emotional abuse, sexual abuse and exploitation, neglect, and others.
4.7.2 How to listen to and respond to concerns or disclosures about safeguarding issues during an initial conversation (e.g. how to explain when information can and cannot be kept confidential).
4.7.3 How to use the Company’s safeguarding reporting procedures and when doing so is appropriate.
4.7.4 Which additional resources (e.g., policies, other supporting documents, or external educational resources) are available to ensure Staff Members remain informed about safeguarding.
4.7.5 Staff Members will participate in regular updates and refresher training sessions to stay informed about changes in UK legislation, best practices, and emerging safeguarding issues.
4.8 Ensure that all information related to Safeguarding Concerns is handled safely and securely, including the content of reported concerns and the personal data of anybody involved. This involves:
4.8.1 Following the requirements set out by the UK’s data protection laws.
4.8.2 Following the Company’s data protection policies and procedures.
4.8.3 Providing Staff Members with data protection and privacy training, where appropriate.
4.8.4 Ensuring Staff Members always have an identifiable point of contact for questions or concerns about data protection and privacy.
4.8.5 Only sharing information about a Safeguarding Concern internally as far as is necessary to manage the concern for the relevant Beneficiary’s benefit.
4.9 Ensure transparency and awareness regarding safeguarding information and procedures. For example, by:
4.9.1 Providing information to Beneficiaries about our safeguarding procedures so that they know how to raise any concerns.
4.9.2 Engaging with Beneficiaries’ parents and guardians to promote awareness of safeguarding practices and encourage open communication regarding any safeguarding-related concerns.
4.9.3 Ensuring all Staff Members are aware of safeguarding laws, the Company’s safeguarding commitments and procedures, and Staff Members’ responsibilities in relation to these.
4.10 Review all safeguarding policies and procedures once a year to ensure that they are up-to-date with safeguarding law and that they remain suitable for the Company’s Services and workforce, and meeting any review and evaluation requirements specific to the Company’s industry and organisation type.
4.11 Ensure that contact online and electronic communication between Staff Members and Beneficiaries is conducted professionally, securely, with clear boundaries set to maintain a safe and appropriate relationship.
4a. Delivery of Services
To ensure that Beneficiaries are properly supervised and safeguarded during the delivery of all Services, the Company commits to:
4a.1 Maintain appropriate staff-to-student ratios when delivering Services.
4a.2 A Consent Form must be signed by the Parent/Guardian of any Beneficiary under the age of 18 before they can participate in any of the Company’s Services. This form provides parental/legal guardian approval and establishes the primary methods of contact, reporting and communication monitoring between the Company, the Client/Parent/Guardian, and the Beneficiary.
4a.3 A Travel Consent Form is required for Beneficiaries participating in Attended Courses. The Parent/Guardian must sign this form before the Attended Course, confirming they are aware of who will be delivering the Services and exercise Duty of Care towards the Beneficiaries, and provide information required to ensure the safety and wellbeing of Beneficiaries.
4a.4 Not to arrange shared accommodation for Beneficiaries and Staff Members. Exceptions can be made upon reasonably argued request from the Benefifiary, Parent/Guardian, or when it is not possible to provide alternative accommodation arrangements due to accommodation shortages or emergency circumstances.
4a.5 When travelling overseas, the trips may also fall under local authorities’ jurisdiction. Education boards across the globe have specific guidance regarding school trips and activities involving minors, which must be followed.
4a.6 A list of emergency contacts, including local authorities and medical facilities, must be readily available during the trip.
4a.7 Attended Programmes will be reviewed will be conducted to evaluate the trip’s success and identify areas for improvement. Feedback from Staff Members and Beneficiaries will be collected to inform future programmes.
4a.8 The Company will appoint a Lead Instructors. Leads Instructor is expected to keep a journal of events, subjects discussed, and any possible Safeguarding Concerns.
5. Staff Members’ Responsibilities
To achieve the objectives of this Safeguarding Policy, the Company requires its Staff Members to:
5.1 Act with integrity and adhere to the highest ethical standards and good practices, promoting the safety and wellbeing of all of the Company’s Beneficiaries. This includes following all of the Company’s policies and procedures relevant to safeguarding and all UK or other applicable laws relevant to safeguarding at all times.
5.2 Contribute to upholding the key measures that the Company has committed to taking to safeguard its Beneficiaries, in a manner that is appropriate for their role, responsibilities, and degree and type of contact with Beneficiaries. Specific ways that Staff Members should do this will be clarified during training. If a Staff Member is uncertain about their responsibilities, it is their responsibility to raise this with the Director of the Company, Editor-in-Chief, Academic Director, or the Designated Safeguarding Lead (DSL).
5.3 Actively participate in all safeguarding training assigned and raise any misunderstandings or concerns with the Designated Safeguarding Lead (DSL).
5.4 Never engage in any activity that actively risks the safety and wellbeing of Beneficiaries. This especially includes, but is not limited to:
5.4.1 Subjecting Beneficiaries to or facilitating abuse of any sort.
5.4.2 Engaging in any sexual activity with Beneficiaries.
5.4.3 Smoking tobacco, using alcohol or other psychoactive substances other than prescribed by a doctor for medical reasons before and when delivering services to the Beneficiaries or when Staff Members can reasonably expect they might be exercising duty of care towards Beneficiaries.
5.4.4 Participating in or facilitating any activities that may commercially exploit Beneficiaries, such as failing to report suspected child labour or trafficking.
5.5 Immediately report all Safeguarding Concerns that they have regarding Beneficiaries, regardless of whether the concerns relate to potential wrongdoing by other Staff Members, other Beneficiaries, or external parties (e.g., parents, teachers, other organisations, or members of the public).
6. Procedures: Reporting Safeguarding Concerns
To ensure that safeguarding concerns are promptly identified and appropriately addressed, the Company follows the procedures below.
6.1 If a Staff Member identifies a Safeguarding Concern (or it is disclosed by a Beneficiary), they are obliged to report the concern within 24 hours to the Designated Safeguarding Lead (DSL). This can be reported via email, phone call, in person, or another platform, but must be followed by a written report by email. The report should contain:
6.1.1 The date, time, and details of identifying the Safeguarding Concern or its disclosure made by a Beneficiary.
6.1.2 Any additional actions taken by the Staff Member.
6.2 While writing a report, Staff Members should use clear and factual language, avoiding personal opinions or assumptions.
6.3 If a Staff Member feels unable to follow the regular procedure, they should report their Safeguarding Concern in a reasonable alternative manner. This may be necessary in situations such as:
6.3.1 Following the above procedure would require disclosing the concern to someone who is implicated in the Safeguarding Concern or someone the Staff Member is uncomfortable contacting about the concern.
6.3.2 The matter is time-sensitive and involves a risk of serious harm to someone, in which case contacting an external agency (e.g., the police, the ambulance service, or a mental health crisis line) or a more senior member of the Company’s staff first may be more appropriate.
6.4 After reporting, Staff Members should:
6.4.1 Keep a record of the report made and any subsequent actions taken.
6.4.2 Be available for any follow-up discussions or investigations as required by the Designated Safeguarding Lead (DSL) or external agencies.
7. Procedures: Investigation and Response
To ensure that safeguarding concerns are handled appropriately and effectively, the Company follows the procedures below:
7.1 Reported Safeguarding Concerns will be dealt with swiftly and in a timely manner. Responsibility for investigating concerns lies with the Designated Safeguarding Lead (DSL).
7.2 A chronology of key events, decisions, and actions taken should be maintained to provide a quick overview of progress.
7.3 Staff Members who report a Safeguarding Concern will be kept informed about the progression of the matter they reported to an appropriate degree. Note that, depending on the nature of the concern and consequent investigations, some information about matters may be kept confidential and not shared with the reporter.
7.4 Referrals or notifications to external organisations (e.g., police services, local authorities, or regulatory bodies) will be made in accordance with the law, prioritising safety and wellbeing of children.
7.5 Records should be kept and maintained at every stage of the process to ensure that sound decisions are made based on full, accurate, and up-to-date information, and that the rationale for those decisions can be traced, scrutinised, and justified where necessary. Records relating to allegations that have been found to be without substance must also be retained. These records must be handled sensitively, with appropriate security.
7.6 Referrals or notifications to external organisations (e.g., police services, local authorities, or regulatory bodies) will be made in accordance with the law, prioritising the safety and wellbeing of children. The Company will collaborate with external agencies to ensure a comprehensive response to safeguarding concerns.
7.7 All Staff Members involved in investigations will be treated fairly and given the opportunity to respond to any allegations made against them. The investigation process will be conducted with integrity and respect for all parties involved.
8. Review and Monitoring
To ensure that the Safeguarding Policy remains effective and up-to-date, the Company commits to:
8.1 Review this Safeguarding Policy annually or in response to changes in legislation or guidance.
8.2 Include feedback from Staff Members, Beneficiaries, and parents will be considered during the review process to ensure this Safeguarding Policy remains effective and responsive to the needs of all involved.
8.3 Engage with external experts, organisations and authorities to seek guidance on how to improve this Safeguarding Policy.
8.4 The Designated Safeguarding Lead (DSL) will be responsible for gathering information, initiating and conducting the review, and presenting the Director of the Company with possible improvements to the Safeguarding Policy.
9. Code of Conduct
9.1 Professionalism and Ethical Conduct
All Staff Members are responsible for promoting a professional, friendly environment within the Company, where the safety and well-being of Beneficiaries form a cornerstone of the educational experience. This requires Staff Members to maintain the highest standards of professionalism and ethical conduct when interacting with Beneficiaries.
9.2 Social Media
While social media is an important source of information for Beneficiaries, the Company finds that blanket measures entirely prohibiting Staff Members and Beneficiaries from contact on social media would stand against the Company’s educational purpose in journalism. Therefore, the following guidelines apply:
9.2.1 Staff Members are not to initiate contact with Beneficiaries on social media platforms.
9.2.2 Staff Members are prohibited from sharing content that might be perceived as explicit, offensive, or otherwise divisive on social media channels that are available to Beneficiaries. Staff Members are expected to use privacy settings to make sure that content inappropriate for the general public will not reach Beneficiaries. Staff Members are required to maintain the content of their social media profiles to the same standard as if the profile was open to the general public. Additionally, they are required to invite and accept the Company’s official media channels for monitoring purposes and take steps for the Beneficiary’s Parent/Guardian to follow the Staff Member as well.
9.2.3 If invited to ‘follow,’ ‘befriend,’ or similar, Staff Members are allowed, but not required, to accept, but must inform the Beneficiary that their interaction on social media will be kept professional.
9.2.4 Staff Members are strictly prohibited from ‘liking,’ ‘sharing,’ or otherwise engaging with content shared by Beneficiaries, except for content strictly related to the Company’s mission and education goals.
9.2.5 If Staff Members accept one Beneficiary as a ‘friend,’ ‘follower,’ or similar, they are required to accept all other Beneficiaries wishing to connect with them via social media.
9.2.6 Staff Members are not allowed to remove Beneficiaries from an existing account at their discretion; if they wish to change the arrangement, they must terminate the social media account in question and start a new account. The Company may consent to exceptions to this rule in cases when Beneficiaries act inappropriately towards the Staff Member.
9.3 Privacy Rules
Staff Members are required to focus on educational and professional aspects of their work. The details of a Staff Member’s private life should not form a significant part of the time spent with Beneficiaries. When asked about private or confidential aspects of life, Staff Members should treat the subject as a research query and an opportunity to seek truthful information, maintaining professional boundaries.
9.4 Boundaries in Relationships
While the Company values building positive and supportive relationships with Beneficiaries, Staff Members should always be aware of the necessary boundaries in maintaining a professional relationship. Personal involvement should be limited, and relationships must remain within the confines of the educational environment to prevent the risk of inappropriate conduct.
9.5 Handling Sensitive Issues
Staff Members, when approached by Beneficiaries for advice on private matters that do not constitute a Safeguarding Concern, should act with utmost care, provide the Beneficiary with appropriate information, and, where necessary, refer them to support services or professionals, ensuring that all advice given is in the best interest of the Beneficiary and maintains the integrity of the professional relationship.
9.6 Maintaining Professional, Neutral Background
Staff Members must ensure that their background during online sessions is neutral, professional, and free from personal or distracting elements. This includes using appropriate virtual backgrounds or ensuring the physical background is tidy, non-disruptive, and does not contain personal or inappropriate items.
9.7 Compliance with Policies and Laws
Staff Members must comply with all Company policies, local laws, and professional standards relevant to safeguarding and their work with Beneficiaries. This includes adhering to the principles of equality, non-discrimination, and respect for diversity, as well as actively working to prevent modern slavery and human trafficking.
9.8 Respect for Diversity and Inclusion
Staff Members should promote a culture of inclusion, respect, and understanding, recognizing and respecting differences in culture, background, race, religion, gender, disability, and sexual orientation.
9.9 Appropriate Dress Code
Staff Members should adhere to a professional dress code, ensuring that their attire is appropriate for the educational setting and upholds the standards of professionalism expected when interacting with Beneficiaries.
9.10 Conflict of Interest
Staff Members must disclose any potential conflicts of interest that may arise, whether personal, financial, or professional, and act.
9.11 Role model clause
Staff Members must maintain clear boundaries in their conduct, ensuring they do not engage in or promote illegal or inappropriate behaviors, including the use of alcohol or drugs, while engaging with Beneficiaries in any capacity related to their role, and taking into account that Beneficiaries might perceive them as role models.
9.12 Reporting Misconduct
Staff Members have a responsibility to report any misconduct, unethical behavior, or breach of this Code of Conduct that they witness, either by a Staff Member or Beneficiary. Failure to report such incidents may result in disciplinary action.
9.13 Digital Footprint and Online Reputation
Staff Members should be mindful of their digital footprint and ensure that their online presence, including personal websites or public social media, aligns with the Company’s values and does not harm the reputation of the Company or its Beneficiaries.