Safeguarding Vulnerable Groups
This page gives advice, about safeguarding vulnerable groups, to the Croquet Association's member clubs and federations, which it recomments them to follow as a matter of best practice.
Children are defined as persons of less than 18 years of age. Vulnerable adults are those aged 18+ while they are receiving health or certain types of personal care. (Please ask if you want more information on these categories).
All organisations that deal with these vulnerable groups are expected to have policies/procedures in place relating to these issues and there are specific requirements for checking that individuals who undertake Regulated Activity for them are not barred from doing so. This is defined in more detail below, but in a croquet context broadly means coaching or supervision of children by an individual frequently or intensively.
The Croquet Association has a CA Safeguarding Policy to cover its own activities.
Croquet Clubs and Federations are not exempt from these issues as many will have some contact with these vulnerable groups, even if they do not do so to the extent of organising Regulated Activity. The Croquet Association offers the following model documents, which you could use as a starting point:
- Model Safeguarding Policy
- Model Code of Good Practice - Safeguarding Children
- Model Safeguarding Incident Report Form
The World Croquet Federation also has papers relating to these matters. There are many other organisations that have sample documents similar to the above that could be adapted to comply with Croquet.
Federations and clubs should be aware that most, if not all, funding bodies require clubs to have these documents in place, as well as a designated Safeguarding Officer, when considering grant applications.
To reiterate a comment made earlier "I am sure that the CA, Federations and clubs would wish to have the interest and well-being of children and vulnerable adults taking part in the game as an achievable objective and not to see it as yet another difficulty or bureaucratic measure to be imposed on the game".
Federations and clubs should have their policies etc. formally adopted at their Committee meeting or AGM whichever is appropriate. They should include details of the Safeguarding Officer. It is advisable for some members of each club to receive some training in Safeguarding Vulnerable Groups. If possible this should include the Safeguarding Officer, Chairman and any coaches of the club or Federation. It may be possible to arrange this, or get advice on available training, through the Local Authority or police. Some churches or local youth organisations also have people who can carry out this training for club/Federation members.
In addition to a general duty of care towards people using their facilities, clubs are (or, in the case of the first point, will be when the legislation is brought into force) legally required to:
- Check (with the Disclosure and Barring Service, DBS, through the CA's Safeguarding Officer) that a person is not barred from engaging in Regulated Activity before permitting them to do so.
- Not knowingly allow a barred person to engage in "Regulated Activity".
- Inform the Disclosure and Barring Service if an individual is removed from Regulated Activity because they have harmed or pose a risk of harm to vulnerable groups.
(Individuals who are barred from working in Regulated Activity do, of course, also commit an offence if they attempt to do so.)
Conversely, clubs are prohibited (by the Rehabilitation of Offenders Act 1974) from requesting a Barred List Check on individuals unless they will be engaged in Regulated Activity, and from requesting a disclosure of their criminal record unless they are doing so under the current or previous definition of Regulated Activity.
Regulated Activity - Children
Clearly, the definition of "Regulated Activity" is key to interpreting these requirements. The part of the definition that is likely to be relevant to activities undertaken by croquet clubs with children is:
- any form of teaching, training or instruction of children, unless the teaching, training or instruction is merely incidental to teaching, training or instruction of persons who are not children
- any form of care for or supervision of children, unless the care or supervision is merely incidental to care for or supervision of persons who are not children
- driving a vehicle which is being used only for the purpose of conveying children and any person supervising or caring for the children pursuant to arrangements made in prescribed circumstances
provided that they are carried out by the same person frequently (once a week or more often), intensively (on 4 or more days in a 30 day period), or overnight (between 2am and 6am).
Thus, for example, someone coaching a group of children weekly during the summer term would be undertaking Regulated Activity, whereas someone who gave a bit of advice to a youngster they had just played in a club competition, or gave first-aid to one that had been stung by a wasp, would not. Note also that merely being an officer of, or employed as a groundsman by, a club that was offering coaching to children does not qualify as Regulated Activity.
The CA advises that if half or more of a group under instruction are under 18 then teaching them would be Regulated Activity (if the frequency or intensity conditions were met), but a few children attending a course aimed mainly at adults would not.
The Supervision Exception
There is an exception to the first of these bullet points, that teaching, training or instruction by a person is not Regulated Activity if it is under regular and day to day supervision by someone who is engaging in Regulated Activity and which is reasonable in all the circumstances to ensure the protection of children However, in the context of croquet coaching, it is difficult to see how one of several coaches could effectively supervise the others, given the size of a court, so the Croquet Association's advice is that this exception should generally be ignored Note that, even if it was felt that a group of coaches could effectively supervise each other, at least one of them would have to be treated as undertaking Regulated Activity, and hence checked against the Barred List (and there would then be problems if the coach that had been checked was not available for some reason). The CA's recommendation is therefore that anyone coaching children who meets the frequency or intensity test should be treated as being involved in Regulated Activity, unless the activity is in a specified establishment, such as a school, where adequate supervision will be available.
Regulated Activity - Adults
The old categories of vulnerable adults no longer apply. Croquet clubs are not likely to carry out any of the activities which (if undertaken for adults) are classed as Regulated Activity: things like healthcare, personal care, social work etc.
DBS Disclosures and Checks
It is thought that the changes to the definition of Regulated Activity will mean that few individuals will be engaged in it, even if, as hoped, clubs increase the amount of activity involving young people. However, those who are will need to be checked that they are not on the list of those barred from engaging in it, or have criminal records that indicate that they might pose a risk to children.
The CA has been advised by the Sport and Recreation Alliance that the CA should provide a service for obtaining DBS Disclosures and Barred List checks for member clubs or other bodies who wish to engage a CA member in Regulated Activity. It is hoped that doing this centrally will help to maintain consistent standards and reduce duplication of effort if an individual is involved in coaching children at several clubs or nationally. It also reduces concerns that people being checked might have about confidentiality, as local club officers will not be shown Disclosures.
Given the relatively small size of the sport and its generally low involvement with children, the anticipated number of checks required each year is too few for the CA to register with the DBS. Instead, it has found an "Umbrella Body", APCS, which is willing to obtain checks and disclosures on its behalf. Applications for checks will be managed by me as the CA's Safeguarding Officer. The CA will pay the administrative costs involved: the checks themselves are free for volunteers.
In future, it may not be necessary to obtain a new disclosure for each regulated activity that an individual undertakes, as it is now possible for them to register a recently obtained disclosure on the DBS update service website, which will enable the Croquet Association and other organisations to check that the information in it is still current.
The procedure for a club or other body wishing to engage a CA member in Regulated Activity is:
- The club asks the individual if they are on the CA's list of those that have been successfully checked and confirms that with me, as the CA's Safeguarding Officer, if so.
- If not, the club asks the individual if they already have a Disclosure that is registered on the update service. If so, the club asks the individual to send it and the registration details to me for approval. Having checked it, I will return the disclosure to the individual and inform the club whether or not it was approved.
- If not, the club will ask me to obtain a Disclosure and Barred List check for the individual. I will issue an application number and ask the individual to complete a web form, giving address and identity information. The individual will then have to show their identity documents (e.g. passport) to the club's secretary, who will inform me when they have been checked. The application will then submitted.
- The Disclosure will be returned to the individual, who, if satisfied that it is correct, should register it with the update service and send the disclosure and registration details to me for approval.
- I will then inform the club accordingly.
- In the, hopefully unlikely, event that concerns are raised that someone whom the CA has approved may pose a risk to children then I should be informed.
- The update service will be used periodically to check that disclosures remain current.
We would hope that all clubs feel they can welcome children and vulnerable adults as it is to our advantage to nurture and develop these people for the benefit of Croquet. I understand some clubs still have grave reservations about having junior members, but the previously excessive requirements for checking people have been relaxed. A vast amount of Safeguarding is based on common sense. Please do not be put off by what you might have heard previously.
Meanwhile, any Federation, club or individual requiring information or assistance please contact me by letter, email or by phone. I will try my best to help.
Jean Hargreaves, CA Safeguarding Officer. Last updated January 2017.