Do we need a safeguarding policy to apply for a grant?

Often, yes. Many funders ask for one, and some will not fund work with children, young people or adults at risk without a policy and active procedures in place. The Charity Commission expects charities to take reasonable steps to protect from harm anyone who comes into contact with them.

How often should a safeguarding policy be reviewed?

The Charity Commission says policies and procedures should be reviewed as necessary, always following a serious incident and at least once a year.

Does our safeguarding policy need to be public?

The Charity Commission says safeguarding policies and procedures should be available to the public. Publishing it on your website is a common way to do this.

Do all volunteers need a DBS check?

Not always. The Charity Commission says trustees should risk assess each role to see whether it is eligible for a check and at what level, and always get the right check when a role is eligible. Use the DBS eligibility checker for each role.

Safeguarding Policies for Grant Applications

Safeguarding comes up in almost every grant application, and it is easy to treat it as a box to tick by attaching a policy. Funders increasingly look further than that. Several now say they will not fund work with children, young people or adults at risk unless you have a policy and active procedures in place, and some talk it through with you before they decide. This guide explains what funders ask for, what the Charity Commission expects a charity's safeguarding to cover, and how to show that your policy is real. It is general guidance, not legal advice. For your own situation, take advice from your local safeguarding partnership or a specialist.

Why funders ask about safeguarding

Funders have their own duties. The Charity Commission says that when a charity makes grants to other organisations, it must make sure any grant recipient is suitable and has appropriate safeguarding procedures in place. That is why the question appears so often.

Some examples from funders' own guidance, checked on the date shown on this page:

Paul Hamlyn Foundation lists, among its general exclusions, organisations working with children and young people or adults at risk that do not have a safeguarding policy and active procedures in place, or cannot show they are working towards this.
Esmée Fairbairn Foundation asks about your approach to safeguarding on its assessment call if you work with children or adults at risk, and reviews your safeguarding policy and processes at proposal stage.
The National Lottery Community Fund asks about safeguarding as part of what it needs to know when you apply for National Lottery Awards for All in England.

Our guides to Paul Hamlyn Foundation grants, Esmée Fairbairn Foundation grants and the National Lottery Community Fund cover each funder in more detail.

What the Charity Commission expects

The Charity Commission's guidance on safeguarding and protecting people is the main reference for charities in England and Wales. It says that, as part of their duties, trustees must take reasonable steps to protect from harm people who come into contact with the charity, whether online or in person. That includes beneficiaries, staff, volunteers and anyone else.

The Commission's guidance uses two words carefully. "Must" means a legal or regulatory requirement. "Should" means good practice it expects trustees to follow. It expects all trustees to make sure their charity:

has appropriate policies and procedures that everyone follows
has a clear system for referring or reporting to the relevant agencies as soon as concerns are suspected or identified
has a balanced board where no one trustee dominates
has enough resources, including trained staff, volunteers and trustees, for safeguarding

It also lists the kinds of harm charities should be aware of. These include abuse and exploitation, bullying and harassment, discrimination, data breaches, domestic abuse, extremism and radicalisation, and modern slavery. A charity's culture, and people abusing a position of trust, are on the list too.

Even if you are not a charity, most funders apply the same standard. Community groups, CICs and social enterprises should expect the same questions.

What your policy should cover

The Commission says your safeguarding policies and procedures should be:

put into practice
responsive to change
reviewed as necessary, always after a serious incident and at least once a year
available to the public
compliant with relevant legislation, which can vary depending on who you work with

In the policy, it says you should make clear how you will protect people from undue harm, make sure people can raise concerns, handle allegations or incidents, and respond, including reporting to the relevant authorities. How much detail you need depends on what you do, where you work, whether you work online or in person, and the level of risk.

A practical policy for a small organisation usually includes:

Who the policy covers and the people you work with.
Your named safeguarding lead, with contact details, and a deputy.
How to recognise and raise a concern, written so a new volunteer can follow it.
What happens next, including who you refer to and when.
Safer recruitment, including references and DBS checks where the role is eligible.
Training, who gets it and how often.
Online safety, if you run any online services, groups or social media.
Review date and who approved the policy.

The Commission also says that if you have staff or volunteers, you should have a clear code of conduct setting out your culture and values and how people should behave.

If you work with children or adults at risk

The Commission says there are more legal requirements if you work with children or adults at risk, and you must check whether they apply to you. If your charity works with these groups, it says you should:

have policies and procedures that fit with those of your local authority safeguarding partnership or safeguarding adults board
make sure all staff and volunteers have regular training
appoint a safeguarding lead to work with the local partnerships or boards
manage concerns, complaints, whistleblowing and allegations effectively
have clear policies on when DBS checks are needed, what level and how you handle the information

Safeguarding children duties apply to any charity working with, or coming into contact with, anyone under 18. The Commission points to the NSPCC's resources and standards, and to Working Together to Safeguard Children 2023 in England and the Wales Safeguarding Procedures in Wales. For adults at risk it points to guidance on the Care Act 2014 in England.

If you are applying for youth grants, grants for older people or disability charity grants, expect safeguarding to be one of the first things a funder checks.

DBS checks

The Commission says you should consider DBS checks alongside references and interviews, risk assess each role to see whether it is eligible and at what level, and always get the right check when a role is eligible. It also says that if you use DBS information, you must have a policy on recruiting ex-offenders, in line with the DBS Code of Practice. Use the DBS eligibility checker to decide which checks apply.

Showing a funder your procedures are real

Funders know a template can be downloaded in minutes. These details show that safeguarding is part of how you work:

A named lead who has had training, and who trustees can name.
A recent review date, ideally in the last year, signed off by the board.
Training records, even a simple list of who has done what and when.
A standing item on safeguarding at board meetings. The Commission suggests this as one way trustees can check their arrangements.
Learning from concerns, such as a short note of what you changed after a near miss, without personal details.

If you are not there yet, say so honestly and give a date. Paul Hamlyn Foundation, for example, says it will consider organisations that can show they are working towards having a policy and procedures in place.

When something goes wrong

The Commission's guidance says that if you have an incident or allegation of abuse, you should handle and record it securely, follow your policies, act quickly to stop further harm, report it to the relevant agencies and regulators, and review what happened. In some cases, charities should send a serious incident report to the Commission.

Your grant terms may also require you to tell your funder. Read the conditions in your offer letter before you sign. Our guide to grant agreements and terms and conditions explains what to look for.

Working with partners

If another organisation delivers part of your project, its safeguarding matters too. The Commission says charities working with partners should carry out due diligence and have a written agreement that sets out the relationship, each organisation's role, and monitoring and reporting arrangements. Our guide to partnership agreements for grant projects covers what to include.

Before you apply

Check the policy date, the named lead and the contact details. Make sure the version you attach matches the one on your website. Then add it to your standard application pack with your governing document and accounts, as set out in our guide to how funders assess grant applications. You can find funders open to your organisation in our community group grants and charity grants listings.