Safeguarding Policy - Touch Grass CIC

1. Introduction

Safeguarding is everyone’s responsibility. The safeguarding leads (see below) are responsible for addressing any safeguarding concerns. This policy applies to all co-directors, as well as freelancers, volunteers, sessional workers and visitors working with Touch Grass CIC. This policy should be kept in mind with all interactions and circumstances, including digitally.

Touch Grass CIC aims to embed the practices of transformative justice, non-violent communication and prioritising the needs of the person who has been harmed.

We acknowledge that systemic oppression can often be interwoven into safeguarding issues and we will continue our learning on relevant issues.

2. Purpose & Scope

Touch Grass CIC works exclusively with adults over the age of 18. This policy refers to adult safeguarding, unless stated otherwise. 

The wording of this document may not cover every eventuality or set of circumstances, and as such Touch Grass CIC will take care to consider on a case-by-case basis when a safeguarding case arises – prioritising the needs of the person who has been harmed, or is at risk of being harmed. This policy is not intended to replace anyone’s right to raise a formal complaint or grievance.

What is the purpose of safeguarding?

Touch Grass CIC defines safeguarding as support and care to protect people from abuse, neglect and harm. We encourage a proactive approach, so that where possible we can prevent harm before it takes place.

We aim to centre individuals and consider the multitude of ways that people might feel safer, along with supporting the perpetrator of harm to reflect on their actions and to access the support they need to prevent further harm.

What is considered a safeguarding concern?

A safeguarding concern is when someone is currently in, or is at risk of being in, a vulnerable or dangerous situation. Vulnerable or dangerous situations are situations where a breach of boundaries, abuse (including but not limited to racial, transphobic or homophobic abuse), or harm might take place, or are currently taking place.

Self-determination

Adults may choose not to have any safeguarding intervention, and it is only in extreme circumstances that the law intervenes. This will often only happen when an adult is assessed to lack capacity to make decisions around safeguarding (see capacity, below).

Our safeguarding culture should celebrate and respect self-determination—taking lead from the person experiencing harm and prioritising their needs and confidentiality. We should inform and consult people on all decisions affecting them before we take any actions regarding those decisions.

Capacity

All adults should be assumed to have capacity to make safeguarding decisions for themselves. If you are concerned someone does not have capacity to make safeguarding decisions for themselves, you should encourage them to take a  capacity test, which can be performed by a medical professional. Consider offering to attend doctor’s appointments and tests with that person (even just to sit in the waiting room for support).

See here for situations in which an adult might be assumed not to have capacity. Touch Grass CIC recognises that capacity is not linear. Touch Grass CIC also recognises that while capacity can be a useful measure, historically marginalised people, particularly Black, Brown, disabled and LGBTQ+ folk, sex workers and survivors of domestic and sexual abuse, have had arguments of incapacity used to harm, abuse and oppress them. Therefore, all assumptions of incapacity should be carefully considered. Ask yourself: “What are my preconceptions about what it means to ‘have capacity’? Is this person truly unable to think/act for themselves, or do I simply disagree with their decision/actions?”

The Designated Safeguarding Lead and the Deputy Designated Safeguarding Lead (see below) are responsible for considering the most caring approach.

3. Safeguarding Team

Designated Safeguarding Lead: Toni-Ann Murphy (toni@touchgrasscamp.com)

The Designated Safeguarding Lead (DSL) should be your first point of contact for any safeguarding concerns. They are responsible for:

  • Discussing safeguarding concerns.

  • Preventing situations where an individual may experience abuse, neglect and/or harm.

  • Managing any immediate actions to ensure the person at risk is safe from harm, abuse or neglect.

  • Follow up on any actions taken to resolve harmful situations. 


Deputy Designated Safeguarding Lead: Victoria Somerton (tori@touchgrasscamp.com)

The Deputy Designated Safeguarding Lead (DDSL) will work closely with the DSL to

carry out any actions that need to be taken. The DDSL role includes caring for the

Touch Grass CIC team itself. 

4. Accessing Safeguarding Support

If you are worried about your own safety, you can approach the safeguarding team for support. If you are feeling unsafe at any point whilst at an event hosted by Touch Grass CIC, you are welcome, and have the right to, leave any situation in which you feel you are being harmed, and can follow this up with the safeguarding team at a time that feels best for you after.

Consider what you need before, during and after the conversation. You will be asked if you need any reasonable adjustments for any conversations. Touch Grass CIC will welcome anyone supporting you as you liaise with the safeguarding team.

5. Supporting Someone Else with a Safeguarding Concern

If you are worried about someone’s safety, or if you receive a disclosure of harm, Touch Grass CIC recommends taking a person-centred approach; considering firstly what you and the person being harmed need. We recommend asking the person if they are willing to contact the DSL or DDSL and supporting them to do so.

If they would prefer to receive support from you, we recommend some steps below, while acknowledging that each situation is different and therefore we should all be flexible to act in an emergent way.

  • Assess your own capacity and safeguard yourself

  • Ask the person being harmed/at risk of harm what they want

  • With the person’s consent, document and get support

1. Assess your own capacity and safeguard yourself

Check in with yourself: Do you have space/capacity to approach the person being harmed, have a conversation about your/their concerns, and ask them what they want to happen next?

If you have capacity: Consider what might be helpful before, during and after the conversation, both for yourself and the person at risk of harm. For example, is there somewhere quiet you can sit, is there a time of day that works best for them to talk, how can you decompress after talking? How can you prioritise this conversation, and have it in a way that is gentle, supportive and centres the person being harmed?

If you don’t have capacity: Who can you ask to approach the person instead? We recommend this person being the DSL or DDSL where possible.

2. Ask the person being harmed/at risk of harm what they need

Make time and space to listen to the experiences of the person being harmed.

Form a plan with them about what to do next, asking these questions:

  • What would help you to be safe? What next steps can we take?

  • What practical support would you like? 

  • What emotional support would you like?

  • Can I pass some details of this conversation onto the Touch Grass CIC’s safeguarding team? What are you happy for me to share? Is there anything you’d like me to keep confidential between us?

A person’s confidentiality should always be respected, unless there is a serious risk of harm to another adult (see breaking confidentiality, below), in which case you are legally required to break confidentiality. If you are going to break confidentiality, inform the person first, explain why you will break confidentiality, and only share relevant information with the safeguarding team.

3. With the person’s consent, document and get support

Once you have consent, you should document all the details. The person at risk of harm can do this themselves, or ask for the person they have confided in to write a document. If the document is digital, make sure the document’s share settings are private, so that information remains confidential. If the document is physical, store securely in a locked drawer/area that only you and the person affected have access to.

The person at risk of harm should always see the document in full before it is shared further.

Contact the DSL as soon as possible. Send an email outlining your concerns, and call the DSL to make them aware of your email. You should receive a response within 24 hours. If you haven’t, you should contact the DDSL. If the safeguarding concern involves either the DSL or DDSL, defer to the other person. If the concern involves the DSL and DDSL, then contact another person at the Touch Grass CIC or someone else close to them involved in the situation.

6. Caring for those who are experiencing harm

All safeguarding concerns should be responded to within 24 hours, or immediately if a person is at risk of immediate harm.

The safeguarding team should prioritise discussing the solutions and needs of the person being harmed. The safeguarding team should also work with the person at risk of harm to make/adjust their safeguarding plan (see below) about what feels best for them. This plan should also consider what action the person wants to be taken by others if they are at immediate risk of harm.

As well as the practical safeguarding steps, the mental health and wellbeing of the person being harmed should be prioritised. 


External to Touch Grass CIC

If someone is being harmed, the relevant supporting person should ask the following questions:

  • Do you need time away from your involvement with Touch Grass CIC?

  • Is there anything Touch Grass CIC can do to support your wellbeing?

Touch Grass CIC Team Member

If a team member is being harmed, the DDSL should ask the following questions:

  • What can be put in place at work to support your wellbeing?

  • Do you need time away from Touch Grass?

  • If you are taking time away, how can Touch Grass CIC support your return to work?

  • Touch Grass CIC will facilitate time away for all team members e.g. for wellbeing, rest and to attend any relevant appointments.

7. Supporting those Causing Harm

Touch Grass CIC is committed to the values of transformative justice, and so should approach people causing harm with encouragement that they can change their behaviour. Touch Grass CIC recommends taking a person-centred approach; recognising that we all have capacity to harm.

We recommend asking the person if they are willing to contact the DSL or DDSL and supporting them to do so.

If that is not applicable, we recommend some steps below, while acknowledging that each situation is different and therefore we should all be flexible to act in an emergent way.

  • Assess your own capacity and safeguard yourself

  • Ask the person if they recognise they are causing harm, and if they are prepared to be accountable

  • With the person’s consent, document and get support

1. Assess your own capacity and safeguard yourself

Check in with yourself: Do you have space/capacity to approach the person causing harm, have a conversation about your/their concerns, and hold them accountable? Are you the best person to do this – or is there someone better suited? Will it feel safe for you to have this conversation? 

If you have capacity: Consider what might be helpful before, during and after the conversation, both for yourself and the person causing harm. For example, is there somewhere quiet you can sit, is there a time of day that works best for you to talk, how can you decompress after talking? How can you prioritise this conversation, and have it in a way that is transformative?

If you don’t have capacity: Who can you ask to approach the person instead?

2. Ask the person if they recognise they are causing harm, and if they are prepared to be accountable

It is important that those causing harm are accountable for the harm they are causing. Touch Grass CIC will endeavour to support people towards accountability if they are prepared to admit the harm they have caused, and are committed to ending that harm. Transformative justice practices will look different depending on the extent of harm caused, and crucially, considering what the person who has been harmed/is being harmed wants and needs. The person who has been harmed should always be prioritised.

Form a plan with the person causing harm about what to do next, asking these questions:

  • The person who has been harmed has stated they need “[x]”. Are you prepared to respect their needs and boundaries?

  • What next steps can we take to ensure future harm stops and past harm is addressed?

  • What practical support would you like to move towards accountability?

  • Can I pass some details of this conversation onto our safeguarding team? Is there anything you’d like me to keep confidential between us?

If the person causing harm is not prepared to admit harm and begin an accountability process, the safeguarding team will consider what action to take. Touch Grass CIC will not tolerate harm continuing unaddressed in any of its spaces.

Whether the person is happy to admit accountability or not, Touch Grass CIC should always act in the best interest of the person being harmed. This includes setting boundaries where necessary, for example if the person causing harm is a participant on a course, they could be ejected immediately. This also applies to team members, who could be subject to disciplinary action.


3. With the person’s consent, document and get support

Once you have consent, you should document all the details. The person causing harm can do this themselves, or ask for the person they have confided in to write a document. If the document is digital, make sure the document’s share settings are private, so that information remains confidential.

The person causing harm should always see the document in full before it is shared further.

Contact the DSL as soon as possible. Send an email outlining your concerns, and call the DSL to make them aware of your email. You should receive a response within 24 hours. If you haven’t, you should contact the DDSL. If the safeguarding concern involves either the DSL or DDSL, defer to the other person. If the concern involves the DSL and DDSL, then contact another person at the Touch Grass CIC or someone else close to them.


What to do if you would like support with harm you have caused/are causing

If you are worried about your own behaviours, you can approach the safeguarding team for support.

Consider what you need before, during and after the conversation. You will be asked if you need any reasonable adjustments for any conversations had.

Touch Grass CIC will welcome another person supporting you as you liaise with the safeguarding team.

  • If someone is at risk of immediate harm

  • If someone is experiencing, or at risk of, immediate harm, refer first to their safeguarding plan, and follow what it says.

The default procedure should be to call the DSL immediately. If they do not respond, call the DDSL immediately.


8. Breaking Confidentiality

A person’s confidentiality should always be respected, unless there is a serious risk of harm to themselves, or another adult. Touch Grass CIC defines ‘serious risk of harm’ as anything that could permanently damage a person’s physical, emotional, spiritual or mental health.

Some examples include if someone is at risk of ending their own life, ending someone else’s life or if serious sexual violence or stalking is taking place.

If you are going to break confidentiality, inform the person first, explain why you will break confidentiality. Only relevant information should be shared if you are breaking confidentiality – be particularly mindful not to share information about someone’s protected characteristics unless it is relevant to the safeguarding concern. 

Even if you consider there to be a serious risk of harm, your first point of contact should always be the DSL. It will then be up to the safeguarding team whether the risk of harm is serious enough to break confidentiality.

When a safeguarding professional believes there is a serious risk of harm to an adult, they are required by law to fill out an adult safeguarding form, one for each individual who is at risk/experiencing harm. It is worth considering that these services could involve police, and for Touch Grass CIC to consider the individual’s wellbeing during all of this.

Touch Grass CIC recognises the historic and current harm and danger of these institutions, particularly towards Black people, Muslim people, migrants, disabled people, people with mental ill health and other marginalised groups. Therefore, the Touch Grass team should always consider whether there are steps that can be taken to reduce risk before contacting these institutions.

If a safeguarding form is filled out, the person experiencing harm should be given options about how they can be supported and cared for by Touch Grass CIC. This care should be focused on what the individual wants/needs, and will therefore vary for each person. Some questions include:

  • Would you like to complete your own safeguarding form, or would you like someone else to complete one with/for you?

  • Would you like someone to be with you during your contact with police/social services?

  • Would you like someone to be your designated point of contact for police/social services?


9. Safe Recruitment of Staff, Facilitators, and Volunteers

We are committed to safeguarding the wellbeing of all participants by ensuring that all staff, facilitators, and volunteers who work with Touch Grass are safely and appropriately recruited.

Our safe recruitment practices include:

  • Clear role descriptions and expectations, including safeguarding responsibilities and codes of conduct.

  • Application and interview processes designed to assess values, relevant experience, and suitability to work with our communities.

  • Reference checks: At least two references will be obtained for all new team members and volunteers, with specific questions relating to behaviour, conduct, and safeguarding concerns.

  • All team members will be asked to disclose any past safeguarding concerns or investigations, and failure to do so may result in removal from the role.

  • Induction and training: All staff, facilitators, and volunteers will receive a safeguarding induction before beginning their role. This will involve going through the safeguarding policy so that everyone understands the duty of care to the community.

  • We maintain a culture of ongoing accountability and support. If safeguarding concerns arise during a person's time with us, we will follow clear procedures for review and, if needed, dismissal or referral to appropriate authorities.

10. Freelance Facilitators

We include a Safeguarding section in all our freelance contracts that highlights Touch Grass CIC’s Safeguarding Policy and makes clear that it applies to the facilitator while they’re undertaking work for Touch Grass CIC.

Partnerships

Similarly to facilitators, we include a new section in our partnership agreements outlining our policy, ensuring we each share policies and that our collaborative work is, at minimum, working at the level of Touch Grass CIC’s Safeguarding Policy.


11. Consent, Non-Consensual Touching, and Nudity at Residential Events

We are committed to creating spaces where all participants feel safe, respected, and in control of their bodies. At residential events, this includes clear expectations around consent, physical boundaries, and nudity.

Consent is essential in all interpersonal interactions. No form of physical contact should happen without explicit, enthusiastic consent from all parties involved. This includes but is not limited to hugs, massages, or sharing sleeping spaces.

Non-consensual touching, whether intentional or not, is a breach of our safeguarding expectations and will be taken seriously. We recognise that different people have different comfort levels, and consent must never be assumed, even within a familiar or communal setting.

Nudity is not permitted in shared communal areas at any residential events, including indoor and outdoor group spaces. This helps to maintain a sense of safety and comfort for all participants, especially those who may have past trauma, sensory sensitivities, or cultural considerations.

If nudity is appropriate in a specific context (e.g. wild swimming or sauna use), this must be clearly communicated in advance, and space will be made for attendees to opt in or out without judgment. Privacy and choice are key.

Reporting: Any participant who experiences or witnesses non-consensual behaviour or breaches of this policy is encouraged to report it to the designated safeguarding lead. We will respond promptly and with care.


12. Review period

Last reviewed: August 2025

Next review: February 2026


13. Acknowledgments

Touch Grass CIC is grateful to the Public Interest Research Company who provided their safeguarding policy as a template via RadHR, which enabled us to use it as inspiration.