Safeguarding Policy

1. Policy Statement & Scope

Water Creations Swim Academy (WCSA) is committed to safeguarding and promoting the welfare of all children and young people who participate in our services.

This policy applies to all staff, volunteers, and contractors working across
all WCSA services:

• Swimming Lessons (weekly term-time programme)
• Holiday Camps (Ofsted voluntary childcare register)
• STA Courses (teaching qualifications and CPD)

This policy is informed by:

• Working Together to Safeguard Children (2023)
• Keeping Children Safe in Education (2024)
• Children Act 1989 and 2004
• STA Safeguarding Guidelines
• NSPCC Child Protection in Sport Unit (CPSU) Standards
• Swim England Wavepower (reference document)

A child is defined as anyone under the age of 18. WCSA operates across multiple venues and the operational procedures for each venue are detailed in venue-specific Normal Operating Procedures (NOPs) and Emergency Action Plans
(EAPs). This policy sets the overarching safeguarding standards that apply regardless of venue or service.

2. Key Principles

• The welfare of the child is paramount
• All children have the right to protection from abuse regardless of age, gender, ethnicity, disability, sexuality, or beliefs
• All concerns and allegations of abuse will be taken seriously and responded to swiftly and appropriately
• All staff have a responsibility to report concerns — it is not their responsibility to investigate
• WCSA will work with parents, carers, and external agencies to safeguard children
• Safeguarding is everyone’s responsibility

3. Designated Safeguarding Roles

The following roles hold safeguarding responsibilities within WCSA:

WCSA — Safeguarding & Child Protection Policy — v2 · April 2026 Named
individuals for each role are recorded in the WCSA ‘Who To Go To’ document and
communicated to all staff at induction and at the start of each term.

4. Safer Recruitment

WCSA is committed to safer recruitment practices to deter, identify, and reject individuals who may pose a risk to children. Before employment begins, all staff must have:

• Enhanced DBS check with Children’s Barred List check — verified and recorded
• Two satisfactory references (one from most recent employer/education)
• Proof of identity (passport or driving licence)
• Right to work verification
• Relevant teaching qualification (STA, Swim England, or equivalent)
• Current safeguarding qualification (STA, Swim England, or equivalent provider)
• Signed Staff Code of Conduct
• Completed induction programme

All compliance data is recorded on the Single Central Record (SCR) which is maintained by the Administrator and audited termly by the DSL. Staff must not begin unsupervised work with children until all checks are satisfactorily completed. In exceptional circumstances, a risk assessment may permit supervised work pending DBS clearance.

5. Staff Training Requirements

All staff receive safeguarding training as part of their induction before working with children. Training is refreshed annually and must be from a recognised provider (STA, Swim England, or equivalent). Training must cover:

• Types and signs of abuse and neglect
• How to receive and respond to a disclosure
• WCSA reporting procedures
• Boundaries and professional conduct
• Position of trust legislation

Training completion is recorded on the SCR. Staff whose safeguarding training lapses will not be scheduled for sessions until training is renewed.

6. Recognising Abuse & Neglect

All staff should be aware of the four main categories of abuse: 

Physical abuse — hitting, shaking, burning, drowning, suffocating, or otherwise causing physical harm. In a swimming context, be alert to unexplained bruises, fear of water, or flinching.

Emotional abuse — persistent emotional maltreatment causing severe effects on emotional development. May include making a child feel worthless, inadequate, or valued only for meeting another’s needs.

Sexual abuse — forcing or enticing a child to take part in sexual activities, including non-contact activities such as showing sexual images or encouraging inappropriate behaviour.

Neglect — persistent failure to meet a child’s basic physical or psychological needs. May include failure to provide appropriate clothing
(e.g., swim kit), food, or supervision. Additional concerns to be aware of:

• Child sexual exploitation (CSE) and child criminal exploitation (CCE)
• Peer-on-peer abuse
• Radicalisation and extremism
• Female genital mutilation (FGM)
• Domestic abuse (impact on children in the household)
• Mental health concerns

7. Reporting Procedures

If a member of staff has a concern about a child, or a child makes a disclosure, they must:

Step 1 — Listen and reassure

• Listen carefully without asking leading questions
• Reassure the child that they have done the right thing
• Do not promise confidentiality — explain you may need to tell someone who can help
• Do not investigate or ask the child to repeat their account

Step 2 — Record

• Write down exactly what was said or observed as soon as possible
• Include date, time, location, people present, and the child’s own words
• Sign and date the record

Step 3 — Report

• Report to the Session Co-ordinator immediately (if during a session)
• Session Co-ordinator escalates to the DSL the same day
• If the DSL is unavailable, report to the Deputy DSL or Welfare Officer
• If a child is in immediate danger, call 999 without delay

The DSL will assess the concern and decide the appropriate action: monitor, discuss with parents, or refer to Children’s Services / Police. All decisions and rationale are recorded.

Safeguarding email: cory@wcsacademy.co.uk

8. Allegations Against Staff

If an allegation is made against a member of staff (including the DSL), the following procedure applies:

• The allegation is reported to the DSL immediately
• If the allegation is about the DSL, report to the Welfare Officer or the company owner directly
• The DSL (or Welfare Officer) will contact the Local Authority Designated Officer (LADO) within 1 working day
• The staff member may be suspended pending investigation — this is a neutral act, not a presumption of guilt
• WCSA will follow the LADO’s guidance on next steps
• All allegations are recorded regardless of outcome

Staff must not discuss allegations with colleagues, the accused, or parents other than those directly involved. Confidentiality protects all parties.

9. Position of Trust

Under the Sexual Offences Act 2003 (as amended by Working Together 2023), sport coaches are in a legally recognised ‘position of trust’. This means:

• It is a criminal offence for any person in a position of trust to engage in sexual activity with a person under 18 in their care, even if the young person is over the age of consent (16)
• This applies to all WCSA staff, regardless of the age gap
• Staff must maintain professional boundaries at all times
• Personal relationships with swimmers under 18 (including via social media) are prohibited

10. Missing Child Procedure

If a child cannot be accounted for during any WCSA session:

Immediate actions (0–5 minutes):

• Teacher alerts the Session Co-ordinator immediately
• SC conducts headcount and confirms which child is missing
• SC instructs a staff member to check: pool area (including bottom of pool), changing rooms, toilets, reception area, and car park entrance
• Remaining staff maintain supervision of all other children

If not found within 5 minutes:

• SC contacts parent/carer immediately
• If parent has not collected the child, call 999
• DSL is notified immediately
• Incident is recorded in full

For Holiday Camps, where WCSA has full custody of children for extended periods, the missing child procedure is more detailed — see Annex A.

11. Changing Facilities & Intimate Care

• Baby and pre-school swimmers: baby changing mats or stations are provided at all venues
• Children aged 8 and over must use the appropriate changing room for their gender, separate from adults where possible
• Staff must never be alone in a changing room with a single child
• Parents/carers are responsible for changing their own children before and after swimming lessons
• If a child needs assistance with changing (e.g., a child with additional needs), two members of staff must be present
• Any intimate care needs (e.g., toileting accidents) are managed with the parent present wherever possible. If the parent is unavailable, two staff members attend and an incident form is completed

For Holiday Camps, additional toilet and changing supervision arrangements apply — see Annex A.

12. Photography & Image Management

No photographs or videos of children may be taken without prior written consent from the parent/carer.

Rules:

• All photography for WCSA purposes (marketing, social media, progress records) must be taken on a designated company device
• If in an emergency a personal device is used, the image must be sent to the company email immediately and deleted from the personal device the same day
• No images of children may be stored on personal devices overnight
• Consent forms are issued at enrolment and recorded centrally
• Parents who withdraw consent must notify info@wcsacademy.co.uk — their child’s images will be removed from future use within 14 days
• Parents are not permitted to photograph or video other people’s children at WCSA sessions
• Staff must report any concerns about photography at venues to the Session Co-ordinator immediately

13. Online Safety & Communication

• Staff must not communicate with children or young people via personal social media, phone numbers, or messaging apps
• All parent communication goes through
• info@wcsacademy.co.uk or official WCSA channels
• Staff must not accept friend/follow requests from swimmers or their siblings under 18
• Any online contact initiated by a child towards a staff member must be reported to the DSL
• Staff use of social media must comply with the WCSA Social Media & Photography Policy (CP8)

14. Information Sharing & Confidentiality

Safeguarding information is shared on a strictly need-to-know basis. However:

• Information will be shared with external agencies (Children’s Services, Police, LADO) where necessary to protect a child
• Staff cannot promise confidentiality to a child — they must explain that they may need to tell someone who can help
• Safeguarding records are stored securely and separately from general personnel files
• Only the DSL and Deputy DSL have access to safeguarding records
• Records are retained in line with GDPR and statutory retention requirements

15. Record Keeping

All safeguarding concerns, disclosures, allegations, and actions are recorded using a three-stage process:

• Stage 1 — Initial concern record: completed by the person who witnessed or received the concern, same day.
• Stage 2 — Assessment and action: completed by the DSL recording what action was taken and why.
• Stage 3 — Outcome and learning: completed by the DSL recording the outcome, any changes to practice, and whether the concern was referred externally.

Records are retained for the lifetime of the organisation plus 7 years, or until the child’s 25th birthday, whichever is longer.