Safeguarding Policy and Procedure (Adults at Risk)

Policy Owner: Co-Founder (Nigel Stewart)

Approved by: School of Pan African Studies (Board)

Effective date: 26 February 2026

Next review date: 26 February 2027 (or sooner if required)

Version: 1.0

Website: https://panafricanstudies.net

1.1 This Safeguarding Policy and Procedure (Adults at Risk) (the Policy) sets out the School of Pan African Studies’ (SPAS, we, us, our) arrangements to:

prevent harm to Adults at Risk engaged with our activities, including global and diaspora learners participating from outside the UK;
promote welfare and safe learning environments in online settings; and
respond promptly and appropriately to safeguarding concerns, including where the person at risk is located in a different jurisdiction.

1.2 This Policy applies to:

all SPAS learners, applicants, alumni (where interaction occurs), and participants in SPAS events and communities, including those based in the UK and those located internationally;
all staff, contractors, visiting lecturers, research collaborators, mentors, and volunteers (Staff); and
all learning, teaching, support, and community activity delivered by SPAS, including online courses, synchronous seminars, one-to-one academic support, discussion forums, events, and research activities.

1.3 This Policy addresses safeguarding of adults. Where a learner is under 18, SPAS will treat them as a child for safeguarding purposes and will apply child safeguarding duties and procedures as applicable. For the avoidance of doubt, this includes learners under 18 who are located outside the UK (SPAS will apply the same internal reporting and risk-management approach, and will signpost and, where appropriate and lawful, refer to relevant local agencies in the learner’s jurisdiction).

1.4 This Policy should be read alongside SPAS policies on: Equality, Diversity and Inclusion; Student Terms and Conditions; Student Complaints Procedure; Harassment and Sexual Misconduct; Freedom of Speech and Academic Freedom; Data Protection/Student Privacy; Staff Code of Conduct (where applicable); and Health and Safety (where applicable).

School of Pan African Studies will:

put the welfare of Adults at Risk first and promote wellbeing in all SPAS learning and community spaces;
operate a culture of safeguarding as “everyone’s responsibility” (reflecting the principles set out in Keeping Children Safe in Education (KCSiE) as good practice, even where SPAS activity is delivered primarily in a higher education (HE) context);
take all concerns seriously and act without delay;
act proportionately, fairly, and lawfully;
respect confidentiality, sharing information only on a “need to know” basis and where lawful;
avoid victimisation and retaliation against anyone raising a concern in good faith;
work with external agencies where necessary (including the police and local authority safeguarding services in the UK, and equivalent bodies and support services internationally);
take particular care in online environments, including digital safety (e-safety/online safety) as a core part of safeguarding (including boundaries, record-keeping, safe communications, and platform controls);
safeguard learners’ dignity and rights in knowledge production, including protection from coercion, exploitation, harassment, or misappropriation connected to African indigenous knowledge, lived experience, and other culturally situated knowledge systems (see also section 7 and section 16).

This Policy is informed by relevant UK legislation and guidance, including where applicable:

Care Act 2014 (adult safeguarding framework and duties on local authorities);
Mental Capacity Act 2005 and associated Code of Practice;
Safeguarding Vulnerable Groups Act 2006 (as amended);
Protection from Harassment Act 1997;
Sexual Offences Act 2003;
Domestic Abuse Act 2021;
Counter-Terrorism and Security Act 2015 (Prevent duty—where applicable, and as informed by revised guidance effective from 2024);
Online Safety Act 2023 (online safety duties and the wider regulatory framework supporting safer online environments);
Data Protection Act 2018 and UK GDPR (lawful processing and sharing of personal data); and
Keeping Children Safe in Education (KCSiE) (latest principles adopted by SPAS as safeguarding good practice, including in relation to culture, reporting, and online safety, even where SPAS activity is delivered primarily in an HE context).

SPAS is a UK-based provider and applies UK safeguarding standards and good practice to its operations. However, SPAS learners and community members may be located globally (including across the African continent and the African diaspora). Where a safeguarding concern involves a person located outside the UK:

SPAS will follow this Policy for internal reporting, triage, risk management, online safety measures, and record-keeping; and
SPAS will provide support and signposting to appropriate services in the individual’s jurisdiction and, where appropriate and lawful, assist the individual to contact local authorities, emergency services, or specialist support services in that jurisdiction.

Nothing in this Policy limits an individual’s right to contact emergency services or the police at any time (in the UK or in their local jurisdiction).

4.1 Adult at Risk (also referred to as “adult at risk of abuse or neglect”): a person aged 18 or over who:

has needs for care and support (whether or not the local authority is meeting any of those needs); and
is experiencing, or is at risk of, abuse or neglect; and
as a result of those needs is unable to protect themselves against the abuse or neglect or the risk of it.

4.2 Safeguarding Concern: any information suggesting an Adult at Risk is experiencing or at risk of abuse or neglect, or any situation presenting a safeguarding risk (including risk created by SPAS activity).

4.3 Abuse/Neglect: includes (non-exhaustive) physical, sexual, psychological/emotional, financial/material, domestic abuse, discriminatory abuse, modern slavery, organisational/institutional abuse, neglect and acts of omission, and self-neglect.

4.4 Disclosure: where an individual tells a member of Staff about abuse, neglect, exploitation, or risk.

4.5 DSL: Designated Safeguarding Lead. SPAS will designate a lead and publish contact details internally and, where appropriate, externally.

5.1 Founder / Governance

Ensures SPAS has appropriate safeguarding policies, resources, and oversight.
Ensures safeguarding is embedded in governance, risk management, and organisational culture.
Receives safeguarding reports (where escalated) and ensures appropriate action and learning.

5.2 Designated Safeguarding Lead (DSL)

Acts as the central point of contact for safeguarding concerns.
Advises Staff on safeguarding issues, thresholds, and referrals.
Coordinates internal actions and referrals to external agencies.
Maintains safeguarding records and case logs.
Oversees safeguarding training and periodic policy review.
Ensures online safeguarding controls and boundaries are implemented.

5.3 Deputy DSL (where appointed)

Supports the DSL and acts in their absence.

5.4 All Staff

Must complete safeguarding training as required by SPAS.
Must promptly report safeguarding concerns to the DSL (or Deputy/Founder where necessary).
Must maintain appropriate professional boundaries and follow this Policy.
Must not investigate allegations themselves.
Must keep accurate, contemporaneous notes and preserve evidence where relevant.

5.5 Learners and participants

Are encouraged to report concerns about their own welfare or that of others.
Must comply with SPAS community standards and online conduct expectations.

Indicators may include (non-exhaustive):

unexplained injuries, fearfulness, withdrawal, changes in behaviour or engagement;
disclosures of being controlled, threatened, stalked, or coerced;
signs of financial exploitation or pressure;
distress during contact, sudden changes in communication patterns;
repeated missed sessions where this is unusual, or evidence of self-neglect;
expressions of suicidal ideation, self-harm, or immediate risk to life;
signs of radicalisation risk (where applicable), including coercion into extremist beliefs or activities.

The presence of indicators does not prove abuse; it may warrant sensitive enquiry and/or referral.

7.1 Staff must:

use SPAS-approved communication channels (institutional email, approved learning platforms);
avoid private, personal, or encrypted messaging for teaching/support unless expressly authorised and documented;
avoid one-to-one sessions without appropriate scheduling and record-keeping; where one-to-one support is necessary, it must be conducted via SPAS-approved tools and logged;
maintain respectful, professional interactions at all times;
avoid any sexualised, coercive, or exploitative behaviour;
never request or accept passwords, financial access, or personal favours from learners;
not engage in romantic/sexual relationships with learners where there is a power imbalance or where it creates a safeguarding or conflict-of-interest risk; any potential conflict must be declared to the Founder/DSL immediately.

7.2 Staff must not:

promise confidentiality in response to a safeguarding disclosure;
attempt to mediate serious abuse/neglect concerns informally;
share learners’ personal information except as permitted by law and SPAS policies.

7.3 SPAS will apply online community moderation measures proportionate to risk, including content reporting tools, moderation, and appropriate sanctions under Student Terms and Conditions.

7.4 Online learning environment safeguarding (specific)SPAS recognises that online learning environments can create safeguarding risks (including harassment, sexual misconduct, grooming behaviours, coercion, hate incidents, doxxing, stalking, and the misuse of recordings/screenshots). To manage these risks, SPAS will, proportionate to the nature of the activity:

set clear expectations for online conduct and boundaries (including for synchronous sessions, forums, group chats, and events);
provide clear routes for reporting and flagging harmful content or behaviour (including where incidents occur across time zones);
use moderation and access controls to manage risk (including removing content, restricting access, and suspending accounts where necessary to protect others);
encourage learners to protect personal information (e.g., limiting sharing of phone numbers, addresses, immigration status, financial details, or other sensitive data in public forums);
handle recordings carefully (where sessions are recorded), including notice, lawful basis, secure storage, and restrictions on sharing, in line with SPAS privacy/data protection requirements;
preserve relevant digital evidence (e.g., screenshots, chat logs, emails) securely where needed for safeguarding and/or conduct processes.

7.5 Digital safety (e-safety/online safety) as safeguarding (Online Safety Act 2023)SPAS treats digital safety as a subset of safeguarding. In an online-first institution, “safeguarding” includes preventing and responding to harm that occurs through, is facilitated by, or is exacerbated by digital platforms and online communications. Informed by the Online Safety Act 2023 and wider UK good practice, SPAS will, proportionate to risk:

design learning spaces to reduce foreseeable harm (including appropriate access controls, moderation, reporting routes, and staff oversight);
support safer engagement for international and remote learners (including clear time zone-aware reporting routes and escalation pathways);
address online risks including (non-exhaustive): cyberbullying; harassment; hate; coercive control; grooming; impersonation; blackmail/sextortion; extremist content; misinformation/disinformation that targets vulnerable learners; and unwanted sharing of images, recordings, or personal data;
encourage good digital hygiene and privacy protection (including minimising oversharing, managing screen names, and using platform safety features);
act promptly where SPAS becomes aware of harmful content or behaviour linked to SPAS spaces (including takedown/removal within SPAS-controlled platforms, account restriction, and/or referral under SPAS conduct processes);
take particular care where learning activities involve sensitive personal narratives, political experience, community organising, or culturally situated knowledge that could expose learners (especially diaspora learners) to surveillance, retaliation, or targeting.

8.1 Immediate danger / emergency

If anyone is in immediate danger or needs urgent medical attention, call 999 (UK) or the relevant local emergency number in the person’s country.
If you are not in the same country as the person at risk, encourage them (or someone physically with them) to contact their local emergency number immediately.
Then inform the DSL as soon as reasonably practicable.

8.2 Non-emergency safeguarding concern

Report to the DSL as soon as possible (same day where practicable), regardless of where the learner/participant is located.
If the concern relates to the DSL, report to the Founder or a Deputy DSL (where appointed).

8.3 What to include in a report

Name and contact details of the person at risk (if known).
Date, time, and method of disclosure/incident.
What was said/observed (use the person’s words where possible).
Any immediate actions taken.
Any known risks (e.g., ongoing contact with alleged perpetrator, suicidal ideation, threats).
Your name, role, and contact details.

8.4 Anonymous reports

SPAS will consider anonymous reports, though it may limit the action that can be taken.

When receiving a disclosure:

Listen calmly and attentively; do not show shock or disbelief.
Do not promise secrecy; explain you may need to share information to keep them safe.
Do not ask leading questions; ask only open questions needed to clarify immediate safety (e.g., “Are you safe right now?”).
Reassure the person they have done the right thing by speaking up.
Record key facts promptly, accurately, and objectively.
Report to the DSL immediately.

If the person indicates immediate risk of self-harm or harm by others, treat it as an emergency and follow section 8.1.

10.1 Initial triageThe DSL will:

assess immediacy and severity of risk;
consider whether the person is an Adult at Risk under the Care Act framework;
consider the adult’s wishes and desired outcomes (where possible);
consider mental capacity where relevant.

10.2 Consent and information sharing

SPAS will seek consent to share information with external agencies where appropriate.
Consent may be overridden where lawful and necessary, including where:

10.3 ReferralsWhere appropriate, the DSL may refer to:

the relevant Local Authority Adult Safeguarding team (based on the adult’s location) (UK); or the relevant adult protection/safeguarding authority or equivalent service in the adult’s jurisdiction (outside the UK);
the Police (criminal concerns, immediate risk, stalking/harassment, sexual offences) (UK) or the relevant law enforcement agency in the adult’s jurisdiction (outside the UK);
NHS services or crisis teams (urgent mental health concerns) (UK) or local crisis/medical services in the adult’s jurisdiction (outside the UK);
specialist services (domestic abuse, sexual violence support, modern slavery helplines) in the person’s jurisdiction.

Where the person at risk is outside the UK, SPAS may not be able to make a direct “statutory safeguarding referral” in the way a UK organisation might to a UK local authority. In such cases, SPAS will focus on (i) urgent risk management, (ii) supporting the individual to access local help, and (iii) signposting to reputable local/national/international services, while applying UK safeguarding standards to SPAS’s own conduct and online environment.

10.4 Internal safety measuresSPAS may implement proportionate measures such as:

adjustments to learning arrangements (extensions, alternative participation formats);
restricted contact arrangements and moderated spaces;
temporary suspension of access to platforms pending investigation (where allegations involve SPAS community safety);
referral to student support resources (where available) and signposting.

10.5 Risk assessment

The DSL will document a safeguarding risk assessment and an action plan, reviewed as needed.

11.1 Where a safeguarding allegation concerns a member of Staff/contractor:

The matter must be reported to the DSL immediately (or to the Founder if the DSL is implicated).
SPAS will take steps to protect learners and others, which may include restricting duties or access pending enquiries.
SPAS may initiate disciplinary or contractual processes in parallel with external referrals, taking care not to compromise any criminal investigation.

11.2 Low-level concernsConcerns that do not meet the threshold of abuse but indicate boundary issues, inappropriate communications, or unprofessional behaviour must still be reported and recorded, and may trigger supervision, training, or restrictions.

12.1 SPAS may address learner-on-learner safeguarding concerns through:

safeguarding referral routes (where an Adult at Risk is involved);
the Harassment and Sexual Misconduct Policy;
Student Complaints Procedure; and/or
Student disciplinary processes under Student Terms and Conditions.

12.2 SPAS will balance:

fair process and natural justice;
confidentiality and data protection;
freedom of speech and academic freedom obligations; and
the overriding need to prevent harm and protect welfare.

13.1 SPAS recognises mental health issues may arise in learning contexts. A mental health difficulty in itself is not necessarily a safeguarding issue; it becomes one where there is risk of harm, exploitation, abuse/neglect, or inability to protect oneself.

13.2 If a person expresses suicidal thoughts, self-harm intent, or plans:

treat as urgent; if immediate risk, contact emergency services (999 in the UK or the relevant local emergency number in the person’s jurisdiction);
where the person is located outside the UK, encourage them to contact local crisis support in their locality and, where possible, identify appropriate crisis contact routes for that jurisdiction;
inform the DSL immediately;
record and escalate per this Policy.

13.3 SPAS does not provide clinical services but will signpost to appropriate support, including services relevant to the learner’s country/region where reasonably practicable.

14.1 SPAS supports robust academic debate, including critical analysis of politics and ideology, consistent with lawful freedom of speech and academic freedom.

14.2 SPAS recognises that radicalisation risk is a safeguarding matter. Where applicable, SPAS will have due regard to the need to prevent people from being drawn into terrorism under the Prevent duty (Counter-Terrorism and Security Act 2015) and will implement arrangements informed by the revised Prevent duty guidance effective from 2024, proportionate to SPAS’s size, risk profile, and online-first delivery model.

14.3 Where a safeguarding concern indicates a person may be at risk of coercion, grooming, or exploitation into extremist activity, SPAS will follow this Policy, seek specialist advice as appropriate, and make referrals where legally required and proportionate. This may include:

considering whether an immediate safeguarding response is required (including emergency services where there is an immediate risk);
making an appropriate referral to relevant Prevent/Channel mechanisms in the UK where applicable; and/or
supporting international/remote learners to access appropriate local safeguarding and support services in their jurisdiction, recognising that UK Prevent mechanisms may not apply outside the UK.

14.4 SPAS will seek to reduce “permissive environments” for harm within SPAS-controlled spaces (including online forums and events), while ensuring decisions are evidence-based, proportionate, and consistent with freedom of speech and academic freedom obligations.

15.1 SPAS will:

keep safeguarding records securely, with access restricted to authorised personnel;
maintain accurate case notes, decisions, rationales, and actions taken;
retain records in line with SPAS retention schedules and legal requirements.

15.2 Information sharing will be:

lawful, fair, and transparent where possible;
limited to what is necessary for safeguarding purposes;
documented, including reasons for sharing without consent where applicable.

16.1 SPAS will provide:

safeguarding induction for Staff;
periodic refresher training (at least annually or as determined by risk);
role-specific training for the DSL/Deputy.

16.2 SPAS will promote an organisational culture that:

supports speaking up;
takes disclosures seriously;
respects dignity and autonomy; and
aligns safeguarding with SPAS’s mission of epistemic justice and inclusive, decolonised learning—without compromising safety, including by:

17.1 SPAS will ensure safeguarding reporting routes are accessible, including for individuals with disabilities, language barriers, or digital access constraints.

17.2 SPAS will consider cultural context sensitively while applying consistent safeguarding standards. No cultural, political, or ideological position justifies abuse, exploitation, coercion, or neglect.

18.1 The DSL will report (in an anonymised and proportionate manner) safeguarding themes, risks, and learning to governance at appropriate intervals.

18.2 This Policy will be reviewed:

annually;
after any serious incident; and/or
following changes in law, guidance, or SPAS operations.

Designated Safeguarding Lead (DSL): Nigel Stewart, Co-Founder

Deputy DSL: Christopher Amaning, Co-Founder