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International Safeguarding Policy and Procedure

The International Safeguarding Policy applies to the safeguarding of staff, students and research participants overseas.

In an emergency

If a UCL student or member of staff is in immediate danger or at risk of harm to themselves or others call the local emergency services, if appropriate to that country, or the relevant Consulate. You should inform the person you report to at UCL as soon as possible and they should inform the relevant Designated Safeguarding Lead at UCL London:

Designated Research Safeguarding Lead:

  • Claire Glen, Executive Director of Research and Innovation Services 
    c.glen@ucl.ac.uk +44 (0) 203 108 7918

Designated Student Safeguarding Lead: 

Designated Staff Safeguarding Lead:

Chief Safeguarding Lead: 

Contents

1. Introduction and principles
2. Scope
3. Definition of safeguarding
4. Safeguarding roles and responsibilities
5. Training and support
6. Recognising concerns in a participant, recipient or colleague
7. Responding to someone who raises a concern
8. Safeguarding allegations
9. Recording and reporting concerns 
10. Working with other organisations
11. Record keeping
12. Review of Policy
13. Appendix 1​​​​​​

1. Introduction and principles

1.1 UCL recognises that it has social, moral and legal obligations to safeguard (or protect) the wellbeing and safety of children and vulnerable adults who may be participants in international development research; recipients of international aid or programmes; or who may come in contact with students or workers of UCL who are working abroad.  In addition, UCL has an obligation to protect its staff and students from harm.   

1.2 UCL acknowledges that it can be difficult balancing the protection of individuals while being culturally sensitive to local norms.  However, culture must not be used as an excuse for UCL students or staff to abuse children, young people or vulnerable adults.

1.3 UCL also acknowledges that staff and students may be involved in active research on topics which involve criminality, safeguarding and wellbeing, where the purpose is to research the topic and not report it. 

2. Scope

2.1 This policy applies to: UCL staff, students, workers or sub-contractors including emeritus and honorary staff who usually live and work in the UK and who are abroad on behalf of UCL both during and outside normal working hours. These will be referred throughout as UCL staff and students.

2.2 Throughout this procedure the term “Manager” will refer to a Head of Department,  Director, Dean, Principal Investigator, PHD or Research Supervisor, or Line Manager.

2.3 UCL staff and students should read this policy in conjunction with UCL’s Safeguarding Children and Adults at Risk Policy and Procedure (Staff and Students). 

2.4  Where this policy conflicts with local legislation, local legislation must be followed with guidance from the local partnership organisation or from a UCL Designated Safeguarding Lead.

2.5  UCL staff and students should be aware of the local legislation and customs of any country they are travelling to. There may be serious repercussions or penalties for doing something that might be legal in the UK but illegal in the country you are visiting.  UCL staff and students who have a protected characteristic (such as women; those within the LGBT+ community; those who practise a religion) may need to take particular care when travelling to countries where anti-discrimination or harassment laws may not exist or may not be as robust as those in the UK; or where certain practices are forbidden. The government has published foreign travel advice for each country, with further advice specifically for women and those in the LGBT+ community.

2.6 Breaches of this policy by UCL staff or students will be investigated under the relevant disciplinary procedure which may result in dismissal or expulsion and referral to the police or relevant authority.

2.7 Breaches by UK partners or partner organisations may result in termination of the partnership agreement and reporting to the police, relevant authorities or bodies.

2.8 Where partnership organisations have their own International Safeguarding Policy, UCL’s Policy will take precedence, unless the partnership organisation’s policy and procedure is equally or more robust.   

3. Definition of safeguarding

3.1 The UK Collaborative on Development Research (UKCDR) has agreed the following definition of safeguarding with UK funders and an expert advisory group:

“Preventing and addressing any sexual exploitation, abuse and harassment of research participants, communities and research staff, plus any broader forms of violence, exploitation and abuse relevant to research such as: bullying, psychological abuse, and physical violence."

This is a narrow definition and applies to research development work only. 

3.2  Therefore UCL defines safeguarding in the context of working abroad as:

“Preventing and addressing any sexual exploitation, abuse and harassment of individuals, communities, colleagues or staff, plus any broader forms of violence, exploitation and abuse relevant such as: bullying, harassment, psychological abuse, and physical violence.”

3.3  It should be noted that this definition is different to the legal definition usually applied in the UK which covers children and adults at risk only (see Safeguarding Children and Adults at Risk Policy and Procedure (Staff and Students)).

4. Safeguarding roles and responsibilities

4.1 The UCL Designated Safeguarding Leads are based in London and are responsible for:

  • Reporting to and supporting the Vice President Operations with regards to safeguarding matters.
  • Monitoring, promoting and reviewing the policy, guidance documents and resources.
  • Ensuring the dissemination of the policy to all UCL staff through forums, committees and stakeholder meetings.
  • Acting as the first point of contact for safeguarding concerns and providing support.
  • Ensuring referrals to the relevant authorities happen without delay.
  • Providing support to, and dealing with any queries from, members of staff or students who have been accused of misconduct related to a safeguarding issue.
  • Keeping records of all safeguarding referrals and outcomes.
  • Working collaboratively with the Executive Director of Human Resources, Students Union UCL and UCL’s network of safeguarding contacts.
     

4.2 All UCL departments are responsible for ensuring that this policy is incorporated as part of any UK partnership agreement or third-party contract which involves overseas work, and that their UK based staff and volunteers abide by a code of conduct pursuant to the standards of this policy. The failure of partnerships or individuals, as appropriate, to take preventive measures against sexual exploitation, abuse and harassment, to investigate and report allegations thereof, or to take corrective actions, shall constitute grounds for UCL to terminate such agreements.
 

4.3 “Managers” who are involved with sending staff and students abroad,  or hiring UK staff or volunteers who will work abroad, on projects with children or vulnerable adults are responsible for ensuring that such staff and students are vetted appropriately with a criminal background check, where possible; that a risk assessment is undertaken and that they are briefed on this safeguarding policy.   They should also ensure that those going abroad are briefed on the local culture, customs and law.   
 

4.4 UCL staff and students and those working in partnership with UCL are in a position of trust. It is important that you demonstrate exemplary behaviour. Remember that someone else might misinterpret your actions, no matter how well intentioned. You should always give due consideration as to what is an appropriate environment and what is appropriate conduct in relation to the activities you are undertaking.

4.5      You should:

  • Read, understand, and follow this policy as well as the Prevention of Bullying, Harassment and Sexual Misconduct Policy and the Personal Relationships Code.
  • Ensure that you are familiar with the local culture, customs and law.  
  • Complete the  UCL Safeguarding Training – self-paced online training course.
  • Act as an appropriate role model and provide an example you wish others to follow
  • Challenge unacceptable behaviour of UCL students or staff, including abusive activities, bullying, harassment or sexual misconduct, including online behaviours
  • Avoid use of language, terminology or behaviour which could be interpreted as having a sexual connotation or innuendo
  • Challenge the use of inappropriate or offensive language by UCL students or staff
  • Report any potential safeguarding concerns (see definition para. 3.2) to a UCL Designated Safeguarding Lead.

4.6      You should not:

  • Engage in sexual behaviour with someone with whom you are in a position of trust.
  • Engage in private social media correspondence with someone with whom you are in a position of trust.
  • Engage in sexual activity with children under the age of 18 regardless of the age of consent locally.  Mistaken belief in the age of the child is not a defence.
  • Engage in the exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour. This includes buying sex or giving additional assistance over and above what is due to programme participants.

4.7     You should not normally:

  • Give children, vulnerable adults, research participants or recipients of aid or programme funding, your personal mobile number or personal email address unless there is no alternative.  

5. Training and support

5.1 Staff and students who will come in contact with children and vulnerable adults must complete the  UCL Safeguarding Training – self-paced online training course.

5.2 UCL provides a free and confidential Employee Assistance Programme (EAP) to staff. The EAP employs professionally qualified Counsellors and Information Specialists, who are experienced in helping people to deal with all kinds of practical and emotional issues including Safeguarding.

5.3 UCL Report and Support also provides an opportunity for support regarding any bullying, harassment or sexual misconduct experienced by the UCL community.

6. Recognising concerns in a participant, recipient or colleague

6.1 The behaviour of a participant, recipient or colleague may cause you concern or you may feel that circumstances that have arisen could lead you to be the subject of a false allegation relating to your conduct.

This includes:

  • A relationship developing which is an abuse of a position of trust
  • A child or vulnerable adult is becoming attracted to a colleague
  • A child or vulnerable adult is becoming attracted to you
  • A child or vulnerable adult has misunderstood or misinterpreted  something you have done or said
  • Needing to physically restrain a child or vulnerable adult to prevent them from  harming themselves or others or from causing significant damage to property

6.2 If you have concerns relating to a participant, a recipient, yourself or a fellow worker you should discuss this, in the first instance, with the “Manager” or the safeguarding lead in country. 

7. Responding to someone who raises a concern

7.1 If someone tells you directly about a concern relating to their wellbeing you should:

  • Remain calm
  • Offer reassurance that they have done the right thing in telling you
  • Listen attentively and show you are taking what you are being told seriously
  • If they are under 18, explain that you have a responsibility to tell someone else about what you have been told because you want to keep them safe
  • If they are a vulnerable adult, it is good practice to gain the person’s consent to share your concern. If information has been shared with you in confidence, a safeguarding concern may mean that there is justification to share the information without consent.  
  • Explain to them what will happen next

7.2 Do not:

  • Interrupt or stop them from speaking freely
  • React strongly for instance saying, “That’s awful” or “How could someone do that?”
  • Jump to conclusions about what happened or who is to blame
  • Ask leading questions to gain more information; you can ask questions to clarify, for example “Are you telling me that…?” using their own words
  • Promise confidentiality

8. Safeguarding allegations

8.1 This is where a UCL student or worker has allegedly:

  1. Behaved in a way that has harmed a child or vulnerable adult, may have harmed a child or vulnerable adult or might lead to a child or vulnerable adult being harmed.

  2. Possibly committed or is planning to commit a criminal offence against a child or vulnerable adult or related to a child or vulnerable adult or

  3. Behaved towards a child or vulnerable adult in a way that indicates they are or would be unsuitable to work with children or vulnerable adult.

8.2 The allegation may:

  • Involve a child or a vulnerable adult
  • Not directly have an identified victim as such. For example, if someone is looking at abusive images of children online or using the internet to groom children with the intent to harm in future.
  • Be about any type of abuse.

8.3 A safeguarding allegation may arise when:

  • A child or vulnerable adult makes a disclosure about themself
  • A third party reports or makes an allegation about a UCL student or employee
  • Harmful behaviour is observed
  • UCL is informed by the police or local authority or an individual that they are the subject of a child/adult protection and/or criminal investigation

9. Recording and reporting concerns

9.1 As soon as possible after noticing or being told of a concern (that does not form part of your academic research) you must:

  • Report such concerns to the local organisation in charge of the project and/or your “Manager” (if appropriate or applicable) and the Designated Safeguarding Lead at UCL (London).
  • Record your concern using the Concern form at Appendix A, providing as much detail as possible, following the guidance on the form.
  • Be precise and use their own words where possible
  • You can give an opinion if it relates to their behaviour or demeanour if you note that it is your opinion
  • Send the form to the Designated Research Safeguarding Lead at UCL Andrew Cooper,   +44 (0) 203 108 5416

9.2 You should not:

  • Discuss the concern with anyone other than your “Manager”, the local safeguarding lead   and the Designated Staff Lead at UCL  
  • Investigate any allegations

9.3 After you have reported your concern:

  • Hearing about suspected or actual abuse can be upsetting. If you need advice and support you can contact your “Manager” the Wellbeing team, or the Employee Assistance Programme.

9.4 The Designated Safeguarding Lead may:

  •  Arrange for the child or vulnerable adult to be contacted to offer support
  • Refer the child or vulnerable adult to a local external support agency.
  • Contact the local police
  • Contact a local medical service
  • Convene an Interim Measures Panel (see Prevention of Bullying, Harassment and Sexual Misconduct Policy)
  • Recall the student or staff member to the UK and instigate an investigation under the Disciplinary Policy.

10. Working with other organisations

10.1 UCL may work with other organisations to deliver activities. As part of these activities UCL will agree which organisation will take lead safeguarding responsibility. When planning to work with an external organisation UCL representatives must ensure that as part of due diligence they:

  • Have the name and contact details of the other organisation’s safeguarding lead
  • Agree the process for reporting safeguarding concerns
  • Agree responsibility for any risk assessments to be carried out
  • Agree the responsibility for gaining consent and other permissions relating to confidential data
  • Ensure that staff have the appropriate training, qualifications and country specific police checks to work with children or vulnerable adults

11. Record keeping

11.1 The appropriate Designated Safeguarding Lead at UCL will keep records of safeguarding concerns or allegations including details of how they were resolved, details of decisions reached and how those decisions were arrived at. These records will be kept securely for 6 years.          

12. Review of Policy

12.1 This policy is not contractual and may be varied from time to time following consultation with UCL’s recognised trade unions.

13. Appendix 1

    Managers' Toolkit