SAFEGUARDING POLICY
(Children, Babies, Infants, and Adults at Risk)
Effective Date: 1st September 2026
(This policy consolidates and replaces all previous safeguarding and clinical consent policies)
INTRODUCTION AND PURPOSE
Our Commitment
The Clinic believes it is essential to create and preserve a safe, supportive environment for children, babies, infants, and adults at risk. We are committed to promoting their welfare, safety, and well-being by following best practice guidance and statutory legislation.
This policy applies to all employees, self-employed practitioners, contractors, health professionals, and staff working on behalf of The Clinic who come into contact with patients or visitors.
Statutory Framework
This policy complies with current UK safeguarding legislation and guidance, including:
The Children Act 1989 and Children Act 2004
Working Together to Safeguard Children guidance
Care Act 2014 (Adults at Risk)
General Osteopathic Council (GOsC) Osteopathic Practice Standards (Standards A4, C4, and D5)
Key Definitions:
Child: Any person under the age of 18 years.
Baby / Infant: A child from birth up to their first birthday.
Adult at Risk: A person aged 18 or over who has care and support needs and may be unable to protect themselves from abuse, neglect, or exploitation.
2. SAFEGUARDING PRINCIPLES
We adhere to the following core principles:
Everyone’s Responsibility
Safeguarding is the responsibility of all staff and practitioners.
Prompt Action
Concerns must be recognised, recorded, and reported without delay. Patient-Centred
The comfort, dignity, and safety of the child, baby, or adult at risk remain the absolute priority during any consultation or treatment.
Multidisciplinary Cooperation
Information will be shared with local authority safeguarding teams, the police, or healthcare agencies where necessary to protect an individual from harm.
3. CLINICAL CONSENT AND PAEDIATRIC CAPACITY
Valid consent is fundamental to clinical practice. For consent to be valid, it must be given voluntarily by an appropriately informed person who has the capacity to consent to the proposed assessment or treatment.
Consent for Babies and Infants (Under 1 Year Old)
Parental Presence
A baby or infant must never be left alone with a practitioner or staff member. A parent or legal carer must remain present in the treatment room throughout the assessment and treatment.
Identity & Authority
Practitioners must verify the identity of the baby and confirm that the accompanying adult holds parental responsibility or valid legal authority.
Undressing & Privacy
Practitioners must explain why clothing needs to be removed, ensure only the minimum necessary clothing is removed, keep the baby warm and covered, and handle them gently.
Ongoing Consent
Consent is ongoing. Treatment must stop immediately if the parent/carer withdraws consent or if the baby shows signs of distress.
Children Under 16 Years Old (Not Competent)
Where a child under 16 lacks capacity or understanding, consent must be provided in writing or verbally by a person holding Parental Responsibility.
Who holds Parental Responsibility?
The child's birth mother.
The child’s father if married to the mother at birth, or if listed on the birth certificate (subject to UK country registration rules).
Same-sex parents who were civil partners at the time of treatment/conception or who have a parental responsibility agreement.
Legally appointed guardians or local authorities holding a residence/care order.
Who cannot automatically consent?
Grandparents, step-parents, nannies, foster carers, or mothers under 16 cannot give valid consent unless formal delegated written authority or court orders are provided.
Gillick Competence (Children Under 16 Years Old)
A child under 16 may consent to their own treatment if the treating practitioner assesses them as Gillick competent—meaning they possess sufficient intelligence, maturity, and understanding to fully comprehend the nature, risks, benefits, and alternatives of the proposed treatment.
Parents cannot override a competently given consent by a Gillick competent child.
Practitioners should still encourage young people to involve their families wherever appropriate.
Young People Aged 16 to 17 Years
Young people aged 16 and 17 are presumed in law to have the capacity to consent to their own medical treatment.
If a 16- or 17-year-old lacks capacity due to learning disabilities or acute illness, consent may be given by a person with parental responsibility or provided in their best interests under applicable law.
4. CLINICAL PRACTICE AND CHAPERONES
Chaperone Requirement In accordance with GOsC guidelines, a chaperone (parent, legal guardian, or designated clinic staff member) must be present at all times when examining or treating children under 16 years of age.
Stopping Treatment Practitioners must pause assessment or treatment immediately if:
Consent is withdrawn by the patient or parent;
The patient or baby shows unmanageable distress; or
A safeguarding concern or unexplained injury is identified.
Photography and Digital Media
No photograph, video, or audio recording of any child, baby, or adult at risk may be taken on personal or clinic devices without formal, written legal consent. Personal mobile devices must not be used for clinical imaging.
Chaperone Documentation
The identity, relationship to the patient, and presence of any chaperone must be formally recorded within the patient’s clinical notes at every single consultation.
Adult Chaperones
Chaperones or advocates will be proactively offered to any Adult at Risk undergoing an intimate physical examination or assessment.
"Was Not Brought" Protocol
A pattern of two or more consecutive missed or cancelled appointments for a child or baby without a valid clinical or personal reason must be flagged to the DSL as a potential indicator of neglect.
5. RECOGNISING AND REPORTING SAFEGUARDING CONCERNS
Signs of Harm or Abuse
Staff and practitioners must remain vigilant for signs of abuse, non-accidental injury, neglect, emotional abuse, sexual abuse, domestic violence exposure, or fabricated illness.
Immediate Danger (Call 999)
If a child, baby, or adult at risk is in immediate danger or requires urgent medical attention, call 999 immediately. Inform the Safeguarding Lead as soon as it is safe to do so.
Non-Emergency Concerns
All safeguarding concerns, disclosures, or suspicious injuries must be reported to the Designated Safeguarding Lead as soon as possible on the same day.
Information Sharing & Confidentiality
Patient confidentiality (GOsC Standard D5) is vital, but safeguarding overrides confidentiality where a child or vulnerable person is at risk of significant harm. Consent from a parent/carer is not required to make a safeguarding referral if seeking consent would put the individual at further risk.
Confidentiality Safeguards
The clinic guarantees that any employee or associate who raises a concern in good faith will be fully protected against victimisation, discrimination, or professional reprisal.
Whistleblowing Policy
Identity Protection
Your identity will be kept confidential throughout the internal investigation, unless disclosure becomes legally mandated by statutory authorities. ï
External Escalation If the concern directly involves senior clinic management, or if internal reports are ignored, staff must bypass internal structures and report directly to the GOsC Regulation Team (020 7357 6655).
Independent Legal Advice Staff can contact the independent whistleblowing charity Protect (0203 117 2520) for free, confidential legal advice before making an external regulatory report.
6. REPORTING PROCEDURE
Immediate DSL Notification
Report the concern or disclosure verbally to the clinic's Designated Safeguarding Lead (DSL) within 2 hours of the incident or appointment.
Written Documentation
Complete the internal Safeguarding Incident Form before the end of your working shift, capturing exact quotes, factual observations, and timeline details without speculation.
DSL Risk Assessment:
The DSL will review the record to determine the immediate risk level and identify the appropriate external statutory agency.
Statutory Referral
For children or adults at risk, the DSL will contact the relevant Local Authority Multi-Agency Safeguarding Hub (MASH) or Adult Social Care team by phone within 24 hours, followed by a formal written referral within 48 hours.
Emergency Escalation: If a patient is in immediate physical danger, any staff member must bypass internal channels and dial 999 for the Police straight away, notifying the DSO immediately afterwards.
Regulatory Reporting
For serious incidents involving fitness to practise or systemic clinic failures, the DSL or Deputy will notify the General Osteopathic Council (GOsC) inline with professional guidelines.
Duty of Candour
In accordance with GOsC guidance, if a safeguarding breach or harm occurs as a result of clinic operations, the DSL will ensure the patient and/or their legal guardians receive a full, transparent explanation, an apology, and ongoing support.
CQC Registration Status
The Clinic provides purely osteopathic, nutrition, and exercise-based movement services (Pilates). In accordance with the Health and Social Care Act 2008, standard practices delivered by individual statutory-regulated professionals (GOsC) do not fall under the scope of regulated activities. The Clinic is therefore exempt from Care Quality Commission (CQC) registration.
7. SAFEGUARDING LEAD ROLES
Designated Safeguarding Contacts The clinic has two people as designated contacts who are called Designated safeguarding leads (DSL) and a deputy DSL
Designated Safeguarding Lead
Name: Matthew Glithero
Contact Us
Deputy Safeguarding Lead
Name: Eleonora Sansoni
Contact Us
Further contact information for related organisations concerning safeguarding are at the end of this policy.
8. TRAINING, RECRUITMENT, AND POLICY REVIEW
DBS Checks & Safe Recruitment All practitioners and staff undergo safe recruitment procedures, including Enhanced Disclosure and Barring Service (DBS) checks prior to commencing work.
Training
Staff and practitioners receive safeguarding training appropriate to their clinical role.
Review
This policy will be reviewed annually or when statutory guidance or working practices change.
Specific Statutory Reporting Duties (FGM & Prevent)
In accordance with UK statutory duties, practitioners are legally required to report any identified or suspected cases of Female Genital Mutilation (FGM) in girls under 18 directly to the police via 101. Staff also remain alert to risks associated with Child Sexual Exploitation (CSE) and radicalisation under the UK Prevent Duty.
Mandatory DBS & Training Levels
All practitioners examining or treating children or infants must hold a valid Enhanced DBS check (with Children’s Barred List check) registered on the DBS Update Service. Paediatric practitioners and the Safeguarding Lead must maintain Level 3 Safeguarding certification, refreshed at least every three years.
Managing Allegations Against Staff (LADO Protocol)
Any safeguarding allegation or concern made against a practitioner, employee, or volunteer must be reported immediately to the Safeguarding Lead. The Safeguarding Lead will notify the Local Authority Designated Officer (LADO) within 24 hours and before conducting any internal investigation. Where appropriate, the individual concerned will be suspended from paediatric duties pending LADO advice and external investigation.
Safeguarding Contact Directory
Internal Clinic Contacts
Designated Safeguarding Lead (DSL): Matthew Glithero
Deputy DSL Name: Eleonora Sansoni
Statutory Emergency Services
Immediate Physical Danger: Dial 999 (Ask for Police or Ambulance).
Non-Emergency Police Support: Dial 101 (To report a crime that is not a live emergency).
Operational Operational Reporting Teams (MASH)
Use these contacts to report an active concern regarding a child or vulnerable adult. Use the borough where the patient resides.
Royal Borough of Kensington and Chelsea (RBKC)
Children’s Social Services Line (MASH): 020 7361 3013 (Mon–Fri, 9am–5pm).
Children’s Secure Referral Email: socialservices@rbkc.gov.uk.
Out of Hours Emergency Duty Team (EDT): 020 7373 2227 (Nights, weekends, bank holidays).
Adult Social Care Team (Safeguarding Adults): 020 7361 3013.
City of Westminster Access to Children’s Services (MASH): 020 7641 4000 (Mon–Fri, 9am–5pm).
Children’s Secure Referral Email: accesstochildrensservices@westminster.gov.uk.
Out of Hours Emergency Duty Team (EDT): 020 7641 2388 (Nights, weekends, bank holidays).
Adult Social Care Team (Safeguarding Adults): 020 7641 2176.
Allegations Against Staff or Practitioners (LSCP Framework)
If a safeguarding concern involves an osteopath, employee, or volunteer at the clinic, do not use the standard MASH lines above. Contact the Local Authority Designated Officer (LADO) immediately.
RBKC LADO Duty Line: 020 7361 3013 (Ask for the Duty Child Protection Adviser).
RBKC LADO Secure Email: kclado.enquiries@rbkc.gov.uk.
Westminster LADO Line: 020 7641 6156.
Westminster LADO Secure Email: LADO@westminster.gov.uk.
Regulatory and Professional Bodies
General Osteopathic Council (GOsC): 020 7357 6655 / regulation@osteopathy.org.uk(For fitness to practise reporting).
National Advisory Helplines
NSPCC Child Protection Helpline: 0808 800 5000 (For professional advice on child safety).
Childline: 0800 1111 (For young people under 19).
Policy Last Updated: 1st September 2026