Spark Safeguarding Policy

Purpose

The purpose of this policy is to protect people from any harm that may be caused due to their coming into contact with Spark & Co.  or Spark Insights. This includes harm arising from: 

  • The conduct of staff or personnel associated with Spark & Co.
  • The design and implementation of Spark & Co’s programmes and activities 
  • The design and implementation of Spark Insights research and audit activities.

The policy lays out the commitments made by Spark & Co., and informs staff and associated personnel of their responsibilities in relation to safeguarding. 

This policy does not cover: 

  • Sexual harassment in the workplace – this is dealt with under Spark & Co’s Anti-Bullying and Harassment Policy
  • Safeguarding concerns in the wider community.

What is safeguarding?

In the UK, safeguarding means protecting peoples’ health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect

In our work, we understand it to mean protecting people, including children at-risk adults, from harm that arises from coming into contact with our staff, research, activities or programmes.

Further definitions relating to safeguarding are provided in the glossary below.

Scope

  • All staff contracted by Spark & Co.
  • Associated personnel whilst engaged with work or visits related to Spark & Co., including but not limited to the following: consultants; volunteers; contractors; programme visitors including journalists, celebrities and politicians.

Policy Statement

Spark & Co. believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm, abuse, neglect and exploitation. Spark & Co. will not tolerate abuse, harassment and exploitation by staff or associated personnel.

Spark & Co. commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.

Prevention

Spark & Co. responsibilities

Spark & Co. will:

  • Ensure all staff have access to, are familiar with, and know their responsibilities within this policy
  • Design and undertake all its programmes and activities in a way that protects people from any risk of harm that may arise from their coming into contact with Spark & Co.  This includes the way in which information about individuals in our programmes is gathered and communicated
  • Implement stringent safeguarding procedures when recruiting, managing and deploying staff and associated personnel 
  • Ensure staff receive training on safeguarding at a level commensurate with their role in the organisation
  • Ensure that all clients we work with for training, research, audits and consultancy are aware of our safeguarding and research ethics approach
  • Follow up on reports of safeguarding concerns promptly and according to due process.

Staff responsibilities

Child safeguarding

Spark & Co. staff and associated personnel must not:

  • Engage in sexual activity with anyone under the age of 18 
  • Sexually abuse or exploit children 
  • Subject a child to physical, emotional or psychological abuse, or neglect 
  • Engage in any commercially exploitative activities with children including child labour or trafficking.

Adult safeguarding

Spark & Co. staff and associated personnel must not:

  • Sexually abuse or exploit at risk adults
  • Subject an at risk adult to physical, emotional or psychological abuse, or neglect.

Protection from sexual exploitation and abuse

Spark & Co. staff and associated personnel must not:

  • Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance
  • Engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics.

Additionally, Spark & Co. staff and associated personnel are obliged to:

  • Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of the Safeguarding Policy
  • Report any concerns or suspicions regarding safeguarding violations by an Spark & Co. staff member or associated personnel to the appropriate staff member.

Enabling reports

Spark & Co. will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to staff and the communities we work with.

Any staff reporting concerns or complaints through formal whistleblowing channels (or if they request it) will be kept confidential, unless otherwise expressed due to legitimate cause. 

Spark & Co. will also accept complaints from external sources such as members of the public, partners and official bodies.  

How to report a safeguarding concern

Staff members who have a complaint or concern relating to safeguarding should report it immediately to their Safeguarding Focal Point [Director, Ishita Ranjan] or line manager.  If the staff member does not feel comfortable reporting to their Safeguarding Focal Point or line manager (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to any other appropriate staff member.  For example, this could be a senior manager or a member of the HR Team.

Safeguarding Focal Point: CEO, Ishita Ranjan

Contact: Ishita@sparkandco.co.uk or 07415 312 775. 

Response

Spark & Co. will follow up safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations (see Procedures for reporting and response to safeguarding concerns in Associated Policies).

Spark & Co. will apply appropriate disciplinary measures to staff found in breach of policy.

Spark & Co. will offer support to survivors of harm caused by staff or associated personnel, regardless of whether a formal internal response is carried out (such as an internal investigation).  The survivor will lead decisions regarding support.

Research Ethics Principles

At Spark Insights, all our research and audits are conducted in alignment with seven key research ethics principles to ensure ethical, safe, and responsible practice.

1. Respect for Autonomy

  • All participants in research must take part voluntarily, free from any coercion or undue influence.
  • Their rights, dignity, and autonomy should be respected and appropriately protected.
  • When a potential research participant may lack the capacity to make autonomous decisions, they must be protected against harm.

2. Beneficence and Non-Maleficence

  • Research should be worthwhile and provide value that outweighs any risk or harm.
  • Researchers should aim to maximise the benefit of the research and minimise potential risk of harm to participants and researchers.
  • All potential risk and harm should be mitigated by robust precautions (for example, interview guides, facilitator training, and safeguarding lead involvement).

3. Justice

  • Research should be just and equitable among different members or groups in society; a core principle of justice in research is equal treatment.
  • An injustice occurs when a benefit to which a person is entitled is denied to them without good reason or when some burden is imposed unduly on them.

4. Informed Consent

  • Informed consent requires that participants be given appropriate and comprehensible information about the research without duress or inappropriate inducement.
  • The information should include:
    • Research procedure
    • Purpose of the research
    • Risks and anticipated benefits
    • A statement offering the participant the opportunity to ask questions and to withdraw at any time from the research.

5. Confidentiality and Data Protection

  • Preferences regarding anonymity should be respected.
  • Participant requirements concerning the confidential nature of information and personal data should be respected.
  • When collecting data (e.g., via Typeform) or sharing data (e.g., in research reports), we must:
    • Ensure the purpose is clear
    • Ensure private data is stored securely
    • Ensure only those who need access to private data have access
    • Ensure all data is anonymised prior to sharing research or insights.
  • Exceptions to Confidentiality: Confidentiality may need to be broken when there is a serious risk of harm to an individual or others, when required by law (e.g., disclosure of illegal activities such as abuse, harassment, discrimination, terrorism, or criminal acts), or when safeguarding concerns necessitate intervention. In such cases, we will follow appropriate legal and organisational protocols.

6. Integrity

  • Research should be designed, reviewed, and undertaken to ensure recognised standards of integrity are met, and quality and transparency are assured.
  • Unacceptable practices include:
    • Fabrication of data
    • Not checking consent
    • Manipulation of data or imagery
    • Plagiarism
    • Misrepresentation of data
    • Flawed analysis of data.

7. Conflicts of Interest

  • The independence of research should be clear, and any conflicts of interest should be explicit.
  • A conflict of interest arises where a researcher’s obligation to the institution or a funder to conduct research independently is likely to be compromised or may appear to be compromised.
  • It may also arise if the researcher has a personal or lived experience that compromises their ability to conduct the research impartially.
  • Research should always be conducted in line with an agreed brief to maintain transparency and accountability.

This safeguarding framework ensures that our research practices prioritise the well-being, dignity, and rights of all participants while maintaining ethical and professional standards.

Confidentiality

It is essential that confidentiality in maintained at all stages of the process when dealing with safeguarding concerns.  Information relating to the concern and subsequent case management should be shared on a need to know basis only, and should be kept secure at all times. 

Confidentiality may need to be broken when there is a serious risk of harm to an individual or others, when required by law (e.g., disclosure of illegal activities such as abuse, terrorism, or criminal acts), or when safeguarding concerns necessitate intervention. In such cases, we will follow appropriate legal and organisational protocols.

Glossary of Terms

Beneficiary of Assistance: Someone who directly receives goods or services from Spark & Co’s programme.  Note that misuse of power can also apply to the wider community that Spark & Co. serves, and also can include exploitation by giving the perception of being in a position of power.

Child: A person below the age of 18

Harm: Psychological, physical and any other infringement of an individual’s rights

Psychological harm: Emotional or psychological abuse, including (but not limited to) humiliating and degrading treatment such as bad name calling, constant criticism, belittling, persistent shaming, solitary confinement and isolation

Protection from Sexual Exploitation and Abuse (PSEA): The term used by the humanitarian and development community to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel.  The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13)

Safeguarding: In the UK, safeguarding means protecting peoples’ health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect

In our sector, we understand it to mean protecting people, including children and at risk adults, from harm that arises from coming into contact with our staff or programmes.  One donor definition is as follows:

Safeguarding means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur.

This definition draws from our values and principles and shapes our culture. It pays specific attention to preventing and responding to harm from any potential, actual or attempted abuse of power, trust, or vulnerability, especially for sexual purposes.

Safeguarding applies consistently and without exception across our programmes, partners and staff. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and having mature, accountable and transparent systems for response, reporting and learning when risks materialise. Those systems must be survivor-centred and also protect those accused until proven guilty.

Safeguarding puts beneficiaries and affected persons at the centre of all we do. 

Sexual abuse: The term ‘sexual abuse’ means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. 

Sexual exploitation: The term ‘sexual exploitation’ means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.  This definition incudes human trafficking and modern slavery.

Survivor: The person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive, however it is the individual’s choice how they wish to identify themselves.

At risk adult: Sometimes also referred to as vulnerable adult.  A person who is or may be in need of care by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.