Academy Safeguarding and Policies

Bradford City Football Club are fully committed to the safeguarding and welfare of children, young people, young players, vulnerable adults, and vulnerable groups and expects all staff, players and volunteers to share this commitment.  

The Club makes provisions for children and young people, young players and adults at risk (Vulnerable Groups), ensuring that: 

  • The welfare of these groups is paramount. 
  • All children, whatever their age, culture, disability, gender, language, racial origin, religious belief and sexual identity, have the right to safety and protection from abuse and harm. 
  • Prevent policies and processes are in place to protect vulnerable groups from radicalisation. 
  • All suspicions and allegations of abuse will be taken seriously and responded to swiftly and appropriately. 
  • All staff, players and volunteers working for the club are responsible for reporting concerns to the Senior Safeguarding Manage and Designated Safeguarding Officers.
  • Safeguarding is everyone’s responsibility; the club aims through its policy and practises to create a culture of vigilance and ensure all concerns are reported.

Safeguarding Children Policy  

Bradford City Football Club are passionate about creating an enjoyable, safe, and secure environment for all. We are fully committed to the safeguarding and welfare of children, young people, and young players, and expects all staff, players, and volunteers to share this commitment.  We have a separate Adults at risk policy available on the shared drive. 

Policy Statement 

Ryan Sparks, CEO “Bradford City AFC recognises its duty of care to safeguard all children, young people and young players, involved in activities organised by us from harm.  All children have the right to protection, and the needs of disabled children and others who may be particularly vulnerable must be considered. We will do their utmost to ensure the safety and protection of all children/groups involved in activities through adherence to the safeguarding guidelines adopted by the Club.”  

Principles and purpose of the policy 

Bradford City Football Club seek to ensure safety of all children who engage with the club, this equally applies to the safety and security of those working with and responsible for children’s activities. This policy applies to all activities within the Stadium, Training Ground, and Academy. The community foundation operates their own Safeguarding policies and processes in line with the code of capability. All third parties working within the stadium must adhere to and sign our safeguarding SLA. 


• Provide children, young people, young players, adults at risk, (vulnerable groups) with appropriate safety and protection whilst in our care.  

• Undertake to provide relevant safeguarding training, delivered by appropriate training providers as appropriate to their role for staff, players, and volunteers.  

Allow staff/volunteers to know the reporting lines to Paula Watson as Senior Safeguarding Officer or Lee-Ann Brewer as Designated Safeguarding Officer 

Allow the safeguarding team to make informed and confident responses to specific safeguarding issues. 

Give the safeguarding team the knowledge and understanding when to report to LADO, the FA, and other external agencies.    

• Provide education and awareness raising to young players and parents to understand their role in safeguarding.  

Key Principles 

• The welfare of children is paramount.  

• All children, whatever their age, culture, disability, gender, language, racial origin, religious belief and/or sexual identity have the right to safety and protection from abuse and harm.  

• Prevent policies and processes are in place for the protection of vulnerable groups from radicalisation.  

• All suspicions and allegations of abuse will be taken seriously and responded to swiftly and appropriately.  

• All staff, players and volunteers working for the club have a responsibility to report concerns to the Senior Safeguarding Manager and Designated Safeguarding Officers.   

• Safeguarding is everyone’s responsibility; the club aims through its policy and practises to create a culture of vigilance and ensuring all concerns are reported. 

• Working in partnership with other organisations, children and their parents/carer is essential 

Safer Recruitment and Disclosure 

Bradford City Football Club have put in place a recruitment process to reduce the risk to all children and adults at risk from those the organisation employs either paid, third party contractors or volunteers. As part of the Club’s safer recruitment and selection process, offers of work for positions which involve ‘regulated activity’ when working with children are subject to a satisfactory Enhanced Disclosure Barring Service (DBS) check and appropriate references.  

All offers of work are subject to a satisfactory outcome to the screening process and until a satisfactory disclosure has been confirmed, the individual concerned will not be permitted to commence work. Volunteers may work alongside another suitably assessed member of staff if a Risk assessment is carried out and signed off by the senior safeguarding officer. 

All new employees, workers, consultants, third party contractor staff and volunteers working with children at the Club will be required to complete a self-declaration on commencement of duties.  

All employees, workers, consultants, third party contractor staff and volunteers engaged in ‘regulated activity’ will be required to undergo regular DBS disclosure clearances, normally every 3 years or earlier if requested. Pending DBS clearance and obtaining references from previous employers they will not have unsupervised access to children and adults at risk during their time with the Club.  

Should an individual’s DBS check reveal any convictions the Club will consider whether the nature of the offence/ offences renders the person concerned unsuitable for working with children and adults at risk. In such circumstances, when the nature of any disclosure must be considered, a risk assessment will be carried out to assess the information contained within the disclosure certificate.  

The individual may also be asked to attend an interview prior to a recruitment decision being made. The Club will ensure that all third-party contractor staff and consultants working with children in ‘regulated activity’ are subject to a satisfactory Enhanced DBS disclosure and sign a self-declaration form prior to engagement 

Employee/Volunteer Training 

All staff and volunteers will receive an annual safeguarding training. The DSO and SSO will attend EFL training. There will be a training needs analysis and safeguarding workforce plan for all employees who directly work with children. 

All staff working directly with young people should also read Keeping Children Safe in Education (2023) Guidance  and should all sign and understand the Club’s Staff code of conduct. 

Position of Trust & Duty of Care 

The Club acknowledges its responsibility to safeguard the welfare of every child who has been entrusted to its care and is committed to working to provide a safe environment. All employees, workers, consultants, agency staff and volunteers (workers) are accountable for the way in which they exercise authority, manage risk, use resources, and protect children from discrimination and avoidable harm.  

To always ensure best practice staff must be fully aware of this safeguarding policy and procedures and their responsibilities. All staff have a duty of care to keep children safe; this can be exercised through the development of considered, respectful, caring, and professional practice between adults and children. Workers must demonstrate integrity, maturity and good judgement whilst working with children and adults at risk. Any person responsible for a child, whether solely or jointly, is in a position of trust which requires behaviour to be in accordance with this policy.  

Examples of positions of trust include (but are not limited to)  

• A head of a department,  

• Team manager,  

• Scout,  

• Physiotherapist,  

• Driver,  

• Learning mentor/tutor,  

• Staff engaged in matchday activity involving children and adults at risk, including supervising mascots, stewards, hosts/hostesses, catering personnel and photographers. 

Protecting Children with disabilities 

Children with disabilities are at an increased risk of abuse and that the greater the disability the greater the risk. There are a number of factors that contribute to this, and these include:  

• Lack of friends and peer group to support and protect.  

• Intimate/physical and or invasive medical care required. This can make it difficult for the child and adult at risk to know what an acceptable and unacceptable ‘touch’ is.  

• Lack of speech or limited communication, this makes it harder to report abuse.  

• Multiple parent/responsible persons – making it harder to identify who may be abusing.  

• History of being told what to do and not given choices.  

• Being dependent on the abuser for a service or basic need.  

• Having medical conditions that are used to explain injuries.  

Children with disabilities may also be less valued than their peers and poor care may be observed but tolerated by others. This might include such things as not speaking directly to the child; not offering choices, not moving and handling them safely, not respecting their privacy and dignity, not treating them according to their age; allowing physical restraint to occur or using derogatory language.  

There is no one way to ensure that children with disabilities are fully protected but the safest environments are those that assist children by helping them to speak out. Everyone must do their best to stop abuse from happening and take responsibility for observing, challenging, and reporting poor practice and suspected abuse. 

Poor Practice and Abuse 

This takes place whenever staff or volunteers fail to fulfil the highest standards of care and support in their working practice. Poor practice which is allowed to continue can cause harm and can become abuse. Poor practice is unacceptable and will be treated seriously with appropriate action. If appropriate this may be dealt concurrently with the club’s Disciplinary, Grievance and Harassment Policy.  

An individual may not be aware that poor practice or abuse is taking place, as they may deem the behaviour as ‘acceptable’. 

Poor practice is defined as  

• When insufficient care is taken to avoid injuries (e.g., by excessive training or inappropriate training for the age, maturity, experience, and ability of players)  

• Allowing abusive or concerning practices to go unreported (e.g., a coach who ridicules and criticises players who make a mistake during a match)  

• Allowing hazing practices to go unreported  

• Placing children or young people in potentially compromising and uncomfortable situations with adults (e.g., inappropriate use by a coach of social media with a young player(s))  

• Ignoring health and safety guidelines (e.g., allowing young players to set up goal posts unsupervised by adults)  

• Failing to adhere to the club’s codes of conduct practice (e.g., openly verbally abusing the referee)  

• Giving continued and unnecessary preferential treatment to individual 

Practices to be avoided  

The following should be avoided except in emergencies (this list is not exhaustive): 

 • Never taking children to your home where they will be alone.   

The following should never be sanctioned. You should never:  

• Share a room with any under 18’s.  

• Engage in rough, physical, or sexually inappropriate games, including horseplay.  

• Allow or engage in any form of inappropriate touching.  

• Allow children to use Inappropriate language unchallenged.  

• Make sexually suggestive comments to a child, even in fun.  

• Reduce a child to tears as a form of control.  

• Allow allegations made by a child to go unacknowledged, unchallenged, unrecorded, or not acted upon.  

• Do things of a personal nature for children or vulnerable adults that they can do for themselves          

• Staff should avoid taking on any caring responsibilities for which you are not appropriately trained, and for which consent forms have been obtained.  

If cases arise where these situations are unavoidable, they should only occur with the full knowledge and consent of someone in the safeguarding team or the child’s parents/guardian. For example, a child sustains an injury and needs to go to hospital, or a parent fails to arrive to pick a child up at the end of a training session/match. 

Abuse Categories 


Physical abuse indicators can include an explanation which is inconsistent with an injury, several different explanations provided for an injury, unexplained delay in seeking treatment or reluctance to give information or mention previous injuries.  


Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development.  


Sexual abuse is when adults, of either sex, or other children, use children to meet their own sexual needs. It involves forcing or enticing a child to take part in sexual activities, including prostitution, whether or not the child is aware of what is happening.  


Emotional abuse may be difficult to recognise. It is the persistent emotional ill-treatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development 

For more information see appendix 1 for information on types on abuse 

Responding to allegations or suspicions of abuse 

It is not the responsibility of anyone employed by Bradford City Football Club, in a paid or unpaid capacity to decide whether the alleged harm or abuse has taken place.  

All staff and volunteers have a responsibility to ensure the safety and welfare of children including taking appropriate steps (including those set out in this procedure) to ensure that suspicions and allegations of abuse and poor practice are taken seriously and reported immediately and appropriately. Bradford City Football Club will assure all staff and volunteers that it will fully support and protect anyone, who in good faith reports his or her concern that a colleague or another is, or may be, abusing a child.  

Children are likely to disclose abuse, or radicalisation to those they trust and how one responds to a disclosure is crucial. Deal with the disclosure as it happens and ensure that the child’s immediate needs are met and that they feel supported.  

When a disclosure is made, it is most important to understand that you must not investigate the disclosure yourself. The disclosure must always be taken seriously and dealt with according to the guidance in this Policy, even if the truth of the disclosure is uncertain. You are not expected to act as a social worker, counsellor, judge, jury, or avenge the abuser; you are expected to act in the best interest of the child who may be at risk.  


Recognising abuse or harm is often not easy. You need to act when you suspect Harm or Abuse is or has taken place, not just when you are sure that harm has occurred. You may not have proof, but it doesn’t mean you are jumping to conclusions, it simply means you don’t have ethe poof that the abuse is taking place. As soon as you suspect any kind of Abuse or Harm you should raise the concern  


Responding to abuse is vital, and you have a responsibility to report any concerns you have to the safeguarding team and your line manager. You may need to find out the basic facts, ensure you allow the individual to speak without interruption, do not make any judgement. Reassure them and let them know that you are going to have to speak to somebody to ensure that they are safe.  


Contact your safeguarding officer or the Head of Safeguarding, if you can’t reach them contact your line manager, you should also consider contacting local authorities. For example, the police or social services.  

RECORD You should also make sure you make a note of any disclosure so that this can be recorded on the clubs TOOT TOOT system. We will ensure that all staff/volunteers are fully supported and protect anyone, who in good faith, reports his/her concern that a colleague is, or may be, harming or abusing a child.    

See appendix for further guidance on dealing with disclosures 

Creating a positive culture 

All personnel are encouraged to demonstrate exemplary behaviour to safeguard children, to report any concerns about the welfare of a child and to protect themselves from allegations.   

We endeavour to:  

• Always respond to any request to complete or update your DBS Criminal Records Check  

• Always inform the HR Department in respect of your behaviour regarding any investigation, allegation or arrest which may have an impact upon the role you have in working with children or vulnerable groups.  

• Always work in an open environment; for example, avoid private or unobserved situations and encourage an open environment, i.e., no secrets.  

• Treating all young people/young players/groups according to their needs and with respect and dignity.  

• Always putting the welfare of each young person first before winning and achieving goals.  

• Always maintaining a professional relationship with young people and players; for example, never have an intimate relationship with a child U18 (even if they are over 16 years old) when you are responsible for their supervision, care, support, or coaching.   

• Building balanced relationships based on mutual trust which empowers children to share in the decision-making process.  

• Recognise children with social workers may continue to be vulnerable and be educationally disadvantaged in attendance, learning, behaviour and mental health and to use this information to inform the response to further safeguarding concerns (e.g., absence, missing) and support 

 • Making football fun, enjoyable and promoting fair play.  

Coaching Contact:   

• Ensure that if any form of manual/physical contact is required, it should be provided openly and according to coaching guidelines provided by the EFL Safer Working Practices Document and in line with the Football League Child Protection Guidance. Care is needed as contact may be difficult to maintain when a child is constantly moving.  Young people/young players should always be consulted, and their agreement gained.  Some parents are becoming increasingly sensitive about manual support and their views should be carefully considered.  

• Anyone in charge must be subject to DBS checks at the highest level.  

• All staff should be vigilant and ensure adults around children act in accordance with the clubs’ standards.  Staff are also responsible for those who enter changing rooms, etc.   

• Ensure that at tournaments or residential events, the accommodation guidelines are followed. 

• Being an excellent role model – this includes not smoking, not drinking alcohol, not using drugs, or not using bad language in the company of children/young people/young players/vulnerable groups.  

• When coaching gives enthusiastic and constructive feedback recognising the development needs and capacity of young people/young players– avoid excessive training or competition and not pushing them against their will.  

• Secure parental consent in writing to act, if the need arises, in emergency circumstances to give permission for the administration of medication or emergency treatment in line with the information advised on the current ‘Parental Consent Form’ as amended from time to time.  

• Keep a written record of any injury or incident that occurs, along with the details of any treatment given and/or action taken.  

• Advise the DSO on any issue in relation to any treatment of children or vulnerable groups and to log such details on an incident/accident report form.  

• Request written parental consent if Club Officials are required to transport children/young people/young players 

 in their cars and ensure that coaches/staff are accompanied by another member of staff. This should be avoided unless necessary.  

Use of photography 

The Club takes its guidance on the use of images from guidelines issued by The FA and EFL.  

All images are taken by Club officials who have been briefed by a Club Head of Safeguarding or by a member of the Communications and Marketing Department responsible for the activity being photographed or filmed.  

• Before taking images of children or adults at risk, parental consent must be sought in writing, at the start of the season or prior to the event.  

• Parents/responsible person are responsible for informing the Club of any change of circumstances within the season which may affect consent.  

• Parents/responsible person will be informed of how the image will be used. The Club will not allow an image to be used for something other than that for which it was initially agreed.  

• All children featured in Club publications will be appropriately dressed.  

• If possible, the image will focus on the activity taking place and not a specific child.  

• Where appropriate, images will represent the broad range of people participating safely in the event.  

• Club photographers will, where applicable, undertake a DBS check and attend an FA Safeguarding Children workshop; and in any case will be personally responsible for keeping up to date with the latest guidelines on the ‘Use of Images’ policies. Club identification will be always worn.  

• Children who are the subject of a court order will not have their images published in any Club document.  

• No images of children featured in Club publications will be accompanied with personal details such as their home address.  

• Recordings of children for the purposes of legitimate coaching aids will only be filmed by Club officials and stored safely and securely at the Club’s premises.  

• Mobile phone cameras are not to be used in changing rooms.  

• Any instances of inappropriate images in football should be reported to a Safeguarding Manger.  

• The Club does not put young player profiles with images and personal information on its website. 

E safety 

It is important that both players and parents are aware of the help and support available should they be concerned about something they have seen or experienced online. Appendix 5 provides links for parent/carer further information and support. 

Lone working and one and one time 

A lone worker, for the purpose of this Policy, is defined as a member of Staff who is engaged in activities which place them in a situation without direct contact with other Staff or without direct supervision (including online meetings) 

Staff responsibilities:  

• Work in an open and transparent way and avoid conduct which could raise concern or place Children and at Risk of harm.  

• Under no circumstances should Staff and Partners visit Children in their homes outside agreed work arrangements. Nor should they invite Children to their own home or to that of a family member, colleague, or friend.  

• Ensure that contact by whatever means and meetings with Children outside agreed working arrangements never take place without the knowledge and agreement of Bradford City AFC.  

Supervision ratios 

Staff are expected to provide appropriate supervision of the Children in their care, always. The level of supervision required will vary between activities. 

 Ratios for each Activity should be determined by taking the following into consideration:  

• The age, needs, abilities and behaviour of the Children, Young People participating.  Please see the FA guide for suitable ratios. 

• The competence and experience of Staff and Partners involved.  

• The nature and duration of the Activity.  

• Risk assessments and/or intelligence identifying potential behavioural or other issues and risks.  

• Staff must work with Bradford City AFC Club Safeguarding Team when planning activities to ensure that appropriate ratios and supervision arrangements are carefully considered 


Employees, workers, consultants, agency staff and volunteers may have access to confidential information about children and adults at risk in order to undertake their responsibilities. In some circumstances, employees, workers, consultants, agency staff or volunteers may be given highly sensitive or private information. They should never use confidential or personal information about a child and adult at risk or his/her family for their own or others’ advantage.  

Information must never be used to intimidate, humiliate, or embarrass children. Confidential information about a child should never be used casually in conversation or shared with any person other than on a need to know basis. In circumstances where the child identity does not need to be disclosed, the information should be used anonymously.  

There are some circumstances in which an employee, worker, consultant, agency staff or volunteer may be expected to share information about a child, for example when abuse is alleged or suspected. In such cases, individuals have a duty to pass information on without delay, but only to those with designated safeguarding responsibilities.  

If an employee, worker, consultant, agency staff or volunteer is in any doubt about whether to share information or keep it confidential, they should seek guidance from the Club’s Safeguarding team. Any media or legal enquiries should in the first instance be referred to the Senior Safeguarding officer.  

The storing and processing of personal information about children is governed by the Data Protection Act, 1998. For further information on the Club’s (and your) obligations under the Data Protection Act 1998, please see the Club’s Data Handling & Protection Policy, available on the Club’s shared drive.  

This means that employees, workers, consultants, agency staff and volunteers:  

• Are expected to treat information they receive about children/adults at risk in a discreet and confidential manner. 

• Should seek advice from the Senior Safeguarding Officer if they are in any doubt about sharing information they hold, or which has been requested of them 


Searching Children and Young People 

To ensure the safety and security for all club activities all children and young people may be subject to our search processes. Children and young people must always be asked to self-search as the preferred method to try to avoid any unnecessary contact being made with them. However, should the club suspect that the child or young person may be concealing a prohibited item, consent will be sought from their parent or carer before a suitably trained steward or member of the Security team of the same sex conducts a search of the child while being observed by a supervisor. No search of a child or young person must ever be carried out in a one-to-one situation.  

Lost or Missing Children and Young People 

During club activities every effort is made to ensure children and young people remain with their parents, carers or the activity leaders. Should a child or young person become lost or go missing during a club activity every effort will be made to locate the child or young person as quickly as possible. Should the child or young person not be located within a reasonable timeframe, contact will be made immediately with their parents or carers and the police to file a missing child/young person’s report. In the event of any such report being made the issue must also be reported to the Safeguarding team at the earliest possible opportunity.  Please see the lost child policy for further guidance. 

Ticketing Strategy 

Any supporter under 14 years old must be accompanied by, and seated with a qualifying adult, parent, or guardian, (age 18 years and over). Where seats directly together are not available, the Club will decide based on the proximity of the nearest seat, and the decision is not negotiable. 

A maximum of two under 11s season/match tickets can be purchased with an adult’s season/match ticket. The club may use its discretion to judge each case on an individual basis where supporters request for more than 2 under 11s season/match tickets per adult. Please contact if you want us to consider such a request. 

Babes in Arms policy:  Children under 2 who do not occupy a seat are admitted free of charge. Children aged 2 and over are -required to hold a match day or season ticket. The responsibility for the infant or baby’s welfare, comfort and safety always lie entirely with the parent during the match, pre- and post-match activities and always while on the footprint of the Stadium or any facilities on the periphery of the stadium whether that area is controlled by the football club. Specifically, parents must be aware there are risks to consider including, for example, the danger associated with a ball travelling at speed into the crowd, the impact of crowd noise on your baby and the potential for adverse weather. Therefore, the Club would recommend that infants and babies are not taken into sections of the stadium that are directly behind the goal in the North Stand Kop or South Stand or in the lower section of the West Stand.  Within the West Stand, access to banqueting rooms may be allowed with one parent if the child becomes fractious or unsettled by the behaviour of the crowd or the noise while the match takes place. The Club has only limited baby-changing facilities available within the stadium. The Club is unable to offer any storage facilities for prams or buggies. Bradford City Football Club confirms that admittance of an infant or baby to a match is entirely at the discretion of the parents who make an informed decision in this regard following the outlining of the risk factors to them. We accept no liability in the event of a child being harmed in any way by one of the risk factors listed above or any other incident in the stadium. 

Where many children are in attendance the safety officer will look at stewarding levels and the stewarding experience assigned to those areas of the ground. This will be covered off in the event specific risk assessments. 

At every match there is a matchday safeguarding officer in attendance who will support in any instances where there are unaccompanied children, or in the case of any child been denied access to the ground. 

Safeguarding Allegations Against Staff 

Bradford City Football Club will always take concerns and allegations about employees and volunteers seriously and will respond in a way that places the protection and needs of children, young people, and adults at risk first. 

The procedure will always be followed in respect of all cases where it is alleged that an employee or a volunteer has:  

• Behaved in a way that has, or may have, harmed a child, young person, and adult at risk. Possibly committed a criminal offence against, or related to, a child, young person, or adult at risk.   

• Behaved in a way that indicates s/he is unsuitable to work with children, young people, and adults at risk. This can include behaviour in their personal life that raises safeguarding concerns.  

• The Club will always inform the police when information is received that indicates that the criminal law has been, or may have been, broken. Additionally, the Club will inform other Statutory and Regulatory Authorities / Agencies when it is required to do so or when the circumstances regarding the allegations are such that the Authorities / Agencies should be so notified.  

• The Club will work with openness and transparency with all Authorities / Agencies.  

• The Senior Safeguarding Officer will have full oversight of any allegations against employees or volunteers who work with children or young people. The Senior Safeguarding Lead will hold management responsibility and the Club’s HR department will hold responsibility for advising on all aspects of the HR processes.  

• There will be circumstances when the policy and procedures may be used concurrently with other procedures such as Disciplinary, Whistleblowing and Complaints procedures. In such circumstances, the safeguarding process takes precedence, and other processes may need to be suspended whilst safeguarding processes are completed.  

• In circumstances where a whistleblowing event or other complaint is made of which the where safeguarding allegations or concern against employees or volunteers is only minor element nevertheless, the safeguarding concerns must be addressed using this policy and procedure and may require other processes to be delayed.  

•Bradford City Football Club recognises that children, young people, and some employees may have disabilities that require reasonable adjustments to be made to this procedure in accordance with The Equality Act 2010. In such cases, the Senior Safeguarding Officer will make these adjustments. 

The full policy can be found in Appendix 2 


Radicalisation & Extremism  

The following definitions are taken from the HM Government Prevent Strategy 2011. Radicalisation is defined as the process by which people come to support terrorism and extremism and, in some cases, to then participate on terrorist activity.  

During the process of ‘radicalisation’ it is possible to intervene to prevent vulnerable people being drawn into terrorist-related activity.  

Extremism is vocal or active opposition to fundamental British values including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. We also include in our definition of extremism calls for the death of members of the armed forces.  

Please note that being drawn into terrorism includes not only violent extremism but also non-violent extremism. Extremism can take several forms, including Islamist extremism, far right and animal rights extremism for example.  

The Prevent Duty is part of the UK Counter Terrorism Strategy (CONTEST), based on the Counter Terrorism and Security Act of 2015. It requires public bodies, including local authorities, the police, prisons, providers of probation services, schools, colleges, and universities to act to prevent people from being drawn into terrorism, ensuring awareness of risks of terrorism. The Prevent duty applies to those bodies, which include, for example, children’s homes and independent fostering agencies and bodies exercising local authority functions whether under voluntary delegation arrangements or via the use of statutory intervention powers. These bodies should ensure they are part of their local authorities’ safeguarding arrangements, and that staff are aware of and know how to contribute to Prevent-related activity in their area where appropriate.  

The Club recognises that some children and young people are more vulnerable to radicalisation, including those who may be isolated/marginalised in society (through mental health or disability) and may have no other support. Children who attend sports activities are not immune from this risk and therefore the Club ensure that all staff who work with children and young people are equipped at identifying potential indicators of abuse regarding radicalisation and extremism.  

There are often no obvious signs of extremism. There are frequent requests for a list of signs. but although changes in behaviour and dress are often cited as signs of extremism these will often be signs of perfectly normal behaviour, particularly among young people in their late teens and early 20s. There are some physical signs that would indicate concerns relating to extremism such as the tattoos that far right organisation supporters will sometimes display. You are not expected to be aware of the significance of tattoos but if you are worried about someone with what you think may be far right tattoos you should pass the details on to a Safeguarding officer. They can contact local Prevent coordinators for help if needed.  

You should follow the Notice, Check, share approach used by provider organisations.  

Notice: you should be aware of any behaviour which leads to any safeguarding concerns including Prevent duty related ones.  

Check: you should check what their concerns.  

Share: you should refer any concerns to the safeguarding officer or team. Any concerns you have will usually be like other Safeguarding concerns. These may include changes in behaviour; you should use your judgement to decide when these are worrying and when they are within the normal range.  

There are concerns which should always be passed on such as:  

• evidence of sharing of extremist websites  

• evidence of homophobic.  

• religion based or racist bullying  

It is your own judgement which will lead you to decide to refer a Safeguarding concern whether that relates to extremist exploitation or any other kind of exploitation It should be noted that individuals taking their religion more seriously, choosing to grow a beard or wearing a headscarf for religious reasons are NOT signs of extremism 

Late collection of children 

It is the parent/carer’s responsibility to ensure that their child is dropped off and collected by a responsible person if it is not safe for the child to walk home unsupervised. Unless written permission has been given for the child to walk home alone or to be picked up by another individual, coaches should not discharge the child from their responsibility. Whether a child has participated in a training session, fixture or is arriving back from a trip or tour, when collected parents must use the designated waiting area. Staff have a responsibility to ensure that they have signed all children out appropriately.  

For Academy activities the following applies: Only players who have been given prior written permission to walk home alone may do so. These players must still sign out on the register; and Any player being collected by their parent/carer who does not have permission to walk home alone must be signed out by parent/carer before they leave. All parents / carers are made aware that their children should be met no later than 15 minutes after an activity has finished. Should a child not be collected within 15 minutes, coaching staff have emergency contact numbers and should communicate with the phase lead to seek alternative numbers if necessary.  

If a child is not collected on time, a minimum of 2 coaching staff and/or responsible adults will wait at the venue until the parent / carer arrives. A young person should not be left alone with member of staff unless it is unavoidable and in this instance a manager or safeguarding lead should be notified immediately. 


If you’re worried about poor or unsafe safeguarding practices, or potential failures in the club or Academy, talk to the Designated safeguarding Lead, any senior leader, or the CEO. The complaints policy details this further. If you feel unable to talk to someone in the club, you can call the NSPCC whistleblowing helpline on 0800 028 0285 or email:  

Amendment History 

Date Version Author Details of Amendment 
Unknown James Mason Initial Release 
February 2019 Paula Watson update following EFL audit visits  
July 2019 Paula Watson Annual Review 
November 2019 3b Paula Watson to comply with EFL checklist  
September 2020 Paula Watson To update to comply with KCSIE 2020 
March 2021 4b Paula Watson New CEO, add in of whistleblowing paragraph 
September 2021 Paula Watson Updated following feedback from the Barnados Safeguarding Audit 
September 2022 Paula Watson Annual Review 
Nov 22 6b Paula Watson Update following review by local Authority 
Dec 23 Paula Watson Annual Review 


List of Appendices  

Appendix 1 – signs and indicators of abuse  

Appendix 2 – Safeguarding allegations against staff policy 

Appendix 3 – definitions 

Appendix 4 – Guidance for dealing with a disclosure 

Appendix 5 – online safety links 

Appendix 6 – Other applicable Club Policies:  

• Bullying & Harassment Policy (Employment Policy).  

• Data Handling and Protection Policy.  

• Disciplinary Policy (Employment Policy).  

• Equal Opportunities Policy (Employment Policy).  

• Grievance Policy (Employment Policy).  

• Health & Safety Policy.  

• Complaints Policy.  

• PREVENT Guidance.  

• Staff Safeguarding Allegations 

• Lost Child process 

Policy Relevant Legislation/Regulations:  

• Children Act 1989.  

• Children Act 2004.  

• Crime and Disorder Act 1998.  

• Data Protection Act 1998.  

• FA Safeguarding Children Rules.  

• FA Respect Codes of Conduct.  

• Human Rights Act 1998.  

• Police Act 1997.  

• EFL Guide for Safer Working Practice.  

• EFL Rules.  

• Protection of Children Act 1999.  

• Protection of Freedoms Act 2012.  

• Rehabilitation of Offenders Act 1974.  

• Safeguarding Vulnerable Groups Act 2006.  

• Sex Offenders Act 1997.  

• Sexual Offences Act 2003.  

• Youth Evidence & Crime Evidence Act 1999.  

• Working Together 2022  

• Keeping Children Safe in Education 2022  

Please note that these lists are not exhaustive 

Appendix 7 

Useful Contact Details 

Senior Safeguarding Officer T: 07494 209130 

If there are any concerns about the above-named person, then any of the external agencies can be contacted or Ryan Sparks (CEO) can be contacted via 

Bradford Council Children Safeguarding Services (Integrated Front Door) During Working Hours: Monday to Thursday 8:30am to 5:00pm, Friday 8:30am to 4:30pm First Contact Team:01274 435600– out of hours 01274 431010  

Police – 101 or 999 in an emergency  

FA NSPCC – 0808 800 5000 Child Line – 0800 1111 


Appendix 1 

Information about types of abuse   

Children may be abused or suffer neglect through the infliction of harm, or through the failure to act to prevent harm.  Abuse can occur in a family or an institutional or community setting.  The perpetrator may or may not be known to the child.   

Abuse can happen to a child regardless of their age, gender, race or ability.  Abusers can be adults (male or female) and other young people and are usually known to and trusted by the child and family.  

Physical abuse: Any deliberate act causing injury or trauma to another person, for example, hitting, slapping, pushing, kicking, burning, giving a person medicine that they do not need and/or that may harm them or application of inappropriate restraint measures. 

Emotional abuse: Any act or other treatment which may cause emotional damage and undermine a person’s sense of well-being, including persistent criticism, denigration or putting unrealistic expectations on vulnerable groups, isolation, verbal assault, humiliation, blaming, controlling, intimidation or use of threats. 

Sexual abuse: Any act which results in the exploitation of children and adults at risk, whether with their consent or not, for the purpose of sexual or erotic gratification. This may be by an adult or by a young person who is intellectually, emotionally, physically or sexually more mature than the victim. This includes non-contact activities, such as indecent exposure, involving children or adults at risk in witnessing sexual acts, looking at sexual images/pornography or grooming them in preparation for abuse (including via the internet). Whilst legally Children aged sixteen have reached the age of consent for sexual activity, it is unacceptable for any member of Staff to abuse their relationship of trust for sexual gratification. 

Child exploitation & Child sexual exploitation:  

CSE and CCE are forms of abuse and both occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into sexual or criminal activity. Missing education can also be a sign of CCE, including involvement in County Lines 

Peer-on-peer abuse: Children and young people can be taken advantage of or harmed by adults and by other Children. Peer-on-peer abuse is any form of physical, sexual, emotional and financial abuse, and coercive control, exercised between Children and within Children’s relationships (both intimate and non- intimate). All incidents of this and Sexting will be followed up. there is an inappropriate images policy in place at the club. Definition now widened to include Bullying (including cyberbullying), Up skirting and abuse within intimate partner relationships 

Neglect: Ongoing failure to meet the basic needs of children. Neglect may involve; failing to provide adequate food, shelter including exclusion from home or abandonment, failing to protect them from physical and emotional harm or danger, or the failing to ensure access to appropriate medical care or treatment. It may also include neglect of or unresponsiveness to basic emotional needs. 

In an activity setting, it may involve failing to ensure that children are safe and adequately supervised or exposing them to unnecessary risks. 

Grooming: Grooming is defined as developing the trust of an individual and/or their family for the purposes of sexual abuse, sexual exploitation, or trafficking. Grooming can happen both online and in person. 

Female genital mutilation (FGM): Involves procedures that intentionally alter or injure female genital organs for non-medical reasons. The procedure has no health benefits for girls and women. The Female Genital Mutilation Act makes it illegal to practise FGM in the UK or to take girls who are British nationals or permanent residents of the UK abroad for FGM whether it is lawful in another country. 

Bullying: Repeated behaviour intended to intimidate or upset someone and/or make them feel uncomfortable or unsafe, for example, name calling, exclusion or isolation, spreading rumours, embarrassing someone in public or in front of their peers, threatening to cause harm, physically hurting someone, or damaging their possessions. 

Cyberbullying: The use of technology to harass, threaten, embarrass, humiliate, spread rumours, or target another person. It occurs among Children. When an adult is the victim, it may meet the definition of cyber harassment or cyberstalking. Bullying because of any form of discrimination: 

Bullying because of discrimination occurs when motivated by a prejudice against certain people or groups of people. This may be because of an individual’s ethnic origin, colour, nationality, race, religion or belief, gender, gender reassignment, sexual orientation, or disability. Actions may include unfair or less favourable treatment, culturally insensitive comments, insults, and ‘banter’. 

Hazing: Any rituals, initiation activities, action, or situation, with or without consent, which recklessly, intentionally or unintentionally endangers the physical or emotional well-being of Vulnerable Groups 

Infatuations: Vulnerable Groups may develop an infatuation with a member of Staff who works with them. Such situations should be handled sensitively to maintain the dignity and safety of all concerned. Staff should be aware that in such circumstances, there is a high risk that words or actions may be misinterpreted and that allegations could be made against Staff. Staff should therefore ensure that their own behaviour is above reproach. A member of Staff who becomes aware that a Child may be infatuated with him/ her, or with a colleague, should discuss this at the earliest opportunity with the Club Designated Safeguarding Officer (or the Club Senior Safeguarding Manager in his/her absence). 

‘honour-based’ abuse: ‘honour-based’ violence to include incidents or crimes committed to protect or defend the honour of the family and/or the community. Incorporates FGM, forced marriage, breast ironing and similar. Wider definition than the previous violence-based model similar to the shift in perception of domestic abuse rather than just domestic violence 

Domestic violence: Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence, or abuse between those aged sixteen or over, who are or have been intimate with partners or family members regardless of gender or sexuality. This can encompass but is not limited to psychological, physical, sexual, financial, emotional abuse and so called ‘honour’ based violence. All children can witness and be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members. Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result. 

Fabricate or induced illness: Fabricated or Induced Illness is easiest understood as illness in a child which is fabricated by a parent or person in loco parentis. The child is often presented for medical assessment and care, usually persistently, often resulting in multiple medical procedures. Acute symptoms and signs of illness cease when the child is separated from the perpetrator. 

Forced Marriage: A marriage in which one or both spouses do not (or in the case of some adults with learning or physical disabilities or children, cannot) consent to the marriage and duress is involved. Duress can include physical, psychological, financial, and sexual pressure. A Forced Marriage is different from an arranged marriage, which is a marriage entered into freely by both parties, although their families take a leading role in the choice of partner. The Anti-social Behaviour, Crime and Policing Act 2014 made it a criminal offence (which can result in a sentence of up to 7 years in prison) to force someone to marry. 

Private fostering: A privately fostered child is a child under 16 (or 18 if disabled) who is cared for by an adult who is not a parent or close relative where the child is to be cared for in that home for 28 days or more. Close relative is defined as “a grandparent, brother, sister, uncle or aunt (whether of the full blood or half blood or by marriage or civil partnership) or step-parent.” A child who is looked after by a local authority or placed in a children’s home, hospital or school is excluded from the definition. In a private fostering arrangement, the parent still holds Parental Responsibility and agrees the arrangement with the private foster carer. A child (as per definition above) placed with a host family for 28 days or more is in a private fostering arrangement and therefore Clubs with host families should inform and work with their local authority ensuring that they meet legislative and local procedural requirements. 

County Lines: County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs into one or more importing areas within the UK, using dedicated mobile phone lines or other form of “deal line”. They are likely to exploit children and adults at risk to move and store the drugs and money and they will often use coercion, intimidation, violence (including sexual violence) and weapons. Child Criminal Exploitation is common in county lines and occurs where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or young person under the age of 18. The victim may have been criminally exploited even if the activity appears consensual. Child Criminal Exploitation does not always involve physical contact; it can also occur using technology. Criminal exploitation of children is broader than just county lines and includes for instance children forced to work on cannabis farms or to commit theft. 

Non recent Abuse: Allegations of harm or abuse may be made some time after the event, e.g., by an adult who was abused as a child or by a member of staff who is still currently working with children.  Where such an allegation is made, we will follow the procedures as detailed in this policy and report the matter directly to the Police or Social Services.    

Hate Crime: A hate crime is any criminal offence which is perceived by the victim, or anybody else, to be motivated by hostility or prejudice towards someone’s race, religion, sexual orientation, transgender identity, or disability (protected characteristics). A hate crime can include verbal abuse, intimidation, threats, harassment, assault, and damage to property. Hate crimes not only harms victims, but children may also be impacted as a result of a hate crime against someone else in their family or a friend. The club has a Hate crime reporting policy which can be referred to for more information. 

Appendix 2 

Safeguarding Allegations against Staff Policy (version 2, August 2022) 

This policy sets out a framework on steps required if an allegation of child or adult abuse is made against a member of staff or a volunteer.  

This policy applies to all Bradford City Football Club and Academy staff and anyone working on behalf or undertaking work or volunteering for the football club.  It provides a framework to ensure appropriate actions are taken, 

regardless of whether they are made in connection to duties with the football club or if they fall outside of this such as in their private life or other capacity.  

This policy should be read alongside relevant BCAFC policies relating to safeguarding of individuals.  The purpose of this Policy is to provide a framework for managing cases where allegations are made about staff that indicate that children, young people, or adults at risk are believed to have suffered, or are likely to suffer, significant harm. Concern may also be raised if the staff member is behaving in a way which demonstrates unsuitability for working with children, young people, or adults at risk, in their present position, or in any capacity. The allegation or issue may arise either in the employee’s/professionals work or private life. 

Examples include: 

  • Behaving in a way that has harmed a child, or may have harmed a child /adult 
  • Possibly committing a criminal offence against/related to a child/adult. 
  •  Behaving towards a child in a way that indicates he or she would pose a risk of harm to children/adults at risk 
  • Failing to work collaboratively with social care agencies when issues about care of children, young people, or adults at risk of harm or abuse for whom they have caring responsibilities are being investigated. 
  • Behaving towards children, young people, or adults at risk, in a manner that indicates they are unsuitable to work with children, young people or adults at risk of harm or abuse. This includes unknown previous child abuse. 
  • Where an allegation or concern arises about a member of staff, arising from their private life such as perpetration of domestic violence or where inadequate steps have been taken to protect vulnerable individuals from the impact of violence or abuse. 
  • Where an allegation of abuse is made against a person closely associated with a member of staff, who puts a child or adult at risk 

This policy is focused on management of risk, based on assessment of harm and abuse. 

Definitions of harm as detailed in the Children Act 1989 / 2004, ‘No Secrets’ (2000), and the Care Act (2014) can be categorised as below 

There are four categories of Child abuse: 

  • Neglect 
  • Sexual 
  • Emotional  
  • Physical 

There are ten categories of abuse for adults: 

  •  Physical Abuse 
  • Sexual Abuse and Sexual Exploitation 
  • Psychological / Emotional Abuse 
  •  Financial / material 
  • Domestic abuse 
  • Modern slavery 
  • Neglect and Acts of omission  
  • Self-Neglect 
  • Discrimination 
  • Organisational 

Application and Scope 

This policy applies to all employees and contractors of the Football Club, including volunteers, students, honorary appointees, trainees, contractors, and temporary workers, including those working on an agency contract. This list is not exhaustive but encompasses all that work for and on behalf of BCAFC. 

For ease of reference, all employees and workers who fall under these groups will be uniformly referred to as “staff” in this document 

The policy covers allegations made against staff during their BCAFC duties and outside of this, including their private life and family home. 

Although managing safeguarding allegations against staff is required under the Children Act (1989 /2004), this policy also applies to adults at risk of harm or abuse as per the Care Act (2014). Working Together to Safeguard Children and Young People (2018) sets out expectations that all statutory organisations will have a procedure for managing allegations against staff. 

Managing Allegations – Immediate Actions 

Safety of child / adult at risk is a priority 

  • Assessment by Children/Adult Social Care, about whether a child/young person/ adult at risk of harm or abuse, needs protection or in need of services. 
  •  Referral to LADO Local Authority Designated Officer within 24 hours. 

The safety of the child, young person or an adult at risk is of paramount importance. 

  • Immediate action may be required to safeguard investigations and any other children, young people, or adults at risk. Any concern that children, young people or adults may be at risk of harm or abuse, must immediately be reported.  
  • Careful consideration of issues relating to wider reputational damage also needs to be considered. If reputational damage is of concern, advice may be sought from the EFL Safeguarding team. 
  • All staff must be familiar with referral procedures to protect an adult/child at risk. The concern must also be reported to the staff member’s line manager, who should take advice from the Safeguarding Team. 

The Club will have a Senior Safeguarding Senior Officer (SSO)of significant seniority to make decisions on behalf of BCAFC.  

Procedure for Reporting and Managing Allegations 

It is essential that every effort must be made to maintain confidentiality and manage communications while an allegation is being investigated. Information is shared on a need-to-know basis. 

On becoming aware of an issue of concern (as outlined in section one above) all staff have a duty to inform their Line Manager immediately who will inform the SSO who should: 

  • Ensure (if appropriate) that a child protection/adult at risk referral is made (or has been made) to the relevant Children/Adult Social Care Team. 
  • The referral must be put in writing to Children/Adult Social Care by the individual reporting the concerns within 24 hours or in the event of a weekend the earliest opportunity of the next working day. Where the issue is in relation to safeguarding children, the SSO will liaise with the Local Authority Designated Officer (LADO) within 24 hours, who will agree with the SSO any information that needs to be shared with other geographical areas depending on where the staff member lives. 
  • Immediate issues of investigation and management of the employee should be discussed and agreed at this time, including what information should be passed to the staff member who is suspected of an allegation. 

Where the issue is in relation to an adult at risk of harm or abuse, the SSO will discuss the case and allegations with the police and the relevant adult social care department manager and identify which agency will be leading on the investigation. 

In conjunction with the Director of Operations and the staff member’s line manager, decide whether suspension (neutral act) is appropriate during the period of investigation. The senior manager, or Director of Operations will advise on the authority levels and process requirements for this action. 

Director of Operations advice will be pertinent to staff who are agency, secondees, or self-employed staff working on behalf of the Club. 

Following notification to the LADO, children/adult Social Care and/or the Police if deemed necessary, the SSO should undertake an internal Crisis Planning Meeting (see separate policy) with the appropriate personnel to decide how to manage the allegation. This group should include the Line Manager and a senior member of staff from department 

concerned; Nominated Safeguarding Senior Officer; and Safeguarding Lead. Designated professionals may also be invited, as a safeguarding expert. 

Crisis Planning Meeting- (the following issues should be considered;) 

  •  Whether the child/young person/adult at risk of harm or abuse is safe from any further risk of harm or abuse 
  • The safety of the young child/person/adult at risk. 
  • Review action undertaken so far to ensure the safety of the victim. 
  • Decide the internal investigation strategy to be undertaken. The Police and / or 
  • Social Care should be consulted when they are involved in any on-going investigation and/or criminal proceedings are pending. 
  • A referral to the EFL and FA if appropriate. 
  • Decide how to present the allegations to the relevant staff member concerned and how to manage the investigatory process. Agreement should be reached with children/adult Social Care and the Police about what information should be passed to the staff member concerned. 
  • The Line Manager should be asked to provide appropriate support to the individual while the case is on-going and keep them regularly informed. 
  • Where police investigations are ongoing, any internal action could be delayed pending police findings. Engagement with the police will be required throughout this period. 
  • Further support may be considered necessary from Occupational Health. 
  • Decide how the person/child/ adult at risk of harm or abuse, or their nominated parent/guardian/nominated carer making the allegation is to be kept informed of what is happening to their allegation, whilst adhering to the requirements of maintaining confidentiality and observing the requirements of the Human Rights Act and the Data Protection Act. The sharing of information must not ‘contaminate’ any club, Police or children/adult Social Care investigations that are on-going. 
  • The CEO should provide additional support and advice in relation to the handling of any queries from the media concerning the allegation.  Decide the frequency and format of review meetings which need to be set up to manage the on-going investigation and the various actions required. 

Procedure for Reporting/Managing Allegations; Non-Directly Employed Staff 

The allegation must also be shared with their employer or the body that engaged them at the earliest opportunity. The following are examples of some potential scenarios that might arise, but this is not exhaustive. 

  •  Allegations made against agency workers must be reported to the appointing agency and the Club 
  • Allegations made against workers employed by external contractors should be referred to the contractor and the BCAFC lead employee responsible for managing the service level agreement with the contractor. 

Allegations made against volunteers undertaking duties for or on behalf of BCAFC must also be reported to the voluntary body the person is volunteering with. 

The SSO should be appointed for such allegations and undertake the duties set out above. 

The SSO will need to engage with the other relevant parties outlined above to decide how the allegation should be managed. These scenarios are likely to be 

complex and the SSO should take early advice from their local safeguarding leads. 

It is recommended that a meeting is held between BCAFC and the other party/parties at the earliest opportunity, noting the responsibility to report issues to the Police and/or Social Care teams within 24 hours of the allegation being received. Such parties should be asked to attend the crisis meeting. 

Even though allegations against such workers should be reported as above, BCAFC still retains a responsibility to consider how the allegations should be managed if the allegation has a connection with, or relevance to, the duties that the worker undertakes with the Club. All such allegations also need to be reported and escalated within the Club in accordance with this policy. 

Assumptions should not be made that the other party has referred the matter to the police or relevant other body – evidence needs to be promptly provided and if this is not forthcoming then the Safeguarding Senior Officer appointed to deal with the case should do so on behalf of the Club and advise the other party accordingly. 

FA Referral 

All concerns should be discussed with the FA safeguarding team via the online referral form. 

Disclosure and Barring Service (DBS) 

As an employer of staff in a ‘regulated activity’ BCAFC also has a responsibility to refer concerns to the DBS in accordance with the Safeguarding Vulnerable Groups Act 2006. Managers must report concerns to the safeguarding team. 

The following groups may be referred for information to the Disclosure and Barring Service: 

  •  If an employee or worker of the Club has been permanently removed from ‘regulated activity’ through dismissal or permanent transfer from ‘regulated activity’, or where they would have removed or transferred that person from regulated activity if they had not left, resigned, retired or been made redundant, and they believe the person has: 
  • engaged in ‘relevant conduct’ 
  • satisfied the ‘harm test’ (i.e., no action or inaction occurred but the present risk that it could occur was significant); or 
  • received a caution or conviction for a ‘relevant offence’ (see DBS website complaints). 

A referral to the DBS should be made following initial information gathering to establish whether there is cause for concern. A referral should be made even if the person in question has left BCAFC before an investigation and/or disciplinary process has been completed. However, it is important to note that the DBS has no investigatory powers and therefore relies upon evidence supplied to it. Managers therefore have a responsibility to complete investigations as far as possible, even where the individual leaves before investigations can be completed, so that the DBS has enough substantiated evidence on which it can base its decision. If additional information becomes available after making a referral this should also be provided to the DBS.  

The referral should be made using the DBS referral form and posted to the DBS enclosing all relevant information held. Please see further guidance and information at 

Record keeping 

The SSO will have the responsibility for ensuring the following records are kept: 

  •  The nature of the allegation/concern. 
  •  Who was spoken to as part of the process and what statements/notes were taken and when. 
  •  Any records that were seen and reviewed. 
  • What actions were considered and justification for specific decisions, including suspension and any actions taken under the Club Disciplinary Procedure. 
  • What alternatives to actions were explored? 
  • Minutes and actions of all meetings that take place. 
  • All documents must be accessed and retained in accordance with the requirements of 

General Data Protection Regulation (2018)  

  • All records should be saved in a secure area, on TOOT TOOT safeguarding software and on password protected drives as they may need to be accessed, the folder should be restricted to certain personnel on the shared drive. 

For these particular records. 

  •  Name the files appropriately. 
  •  Apply a retention period in accordance with the requirements of Records Management: 
  • Save in an agreed area and apply security measures to the records as they contain personal information 
  • Remember that emails can form part of records or can be seen as individual records, so if they are also a critical part of the investigation, they should also be securely stored in the file accordingly. 

Post Investigation Review 

Following the completion of the initial investigation, the Safeguarding Senior Officer will lead a review of the case and its actions. This will be passed to the CEO for review.  

Further actions may still be pending, including consideration of disciplinary matters or an ongoing criminal investigation. 

Any recommendations from the review will be implemented and information disseminated to the appropriate people within the organisation. 

As well as supporting the member of staff throughout the investigation, consideration must be paid to supporting the member of staff through integration back into the workplace should this be appropriate post-investigation.  

On-going support for the member of staff may be offered through the GP or Chaplain. 


  • The Club will monitor compliance of this policy. 
  • The SSO is responsible for the monitoring, revision and updating of this policy.  

Related Policies and Documents 

  • Safeguarding Children  
  • Safeguarding Adults at risk Policy 
  • Crisis management policy 

Managing allegations against a staff member flow chart 

If the allegation is against a non-employed individual, SSO to work with employer and unless provided evidence of referrals to directly refer to local authority   

Appendix 3 


A child is defined as under the age of 18 (The Children Act 1989).  However, for the purpose of the Club’s Safeguarding policies and practices for home match day supporters, when referring to a child, the policies refer to a person under 14 years of age. Supporters under 14 years of age are not allowed to enter the stadium without a qualifying adult (age 18-years and over). As a result, and in line with reasonable adjustments, any supporter who is under 14 years of age must attend with their parent or guardian. Supporters over 14 years and under 18 years are allowed to enter the stadium unaccompanied however they are not allowed to be responsible for another supporter. Only supporters aged 18 years and over can be responsible for a supporter under the age of 18 years.  

Adults at Risk are defined as an adult (person aged 18 or over) who is receiving one of the following services: health care; relevant personal care; social care work; assistance in relation to general household matters by reason of age, illness, or disability; relevant assistance in the conduct of their own affairs or conveying (due to age, illness or disability in prescribed circumstances). We have a separate adult at risk policy. 

Staff or employees is defined as any member of the workforce either paid or unpaid.  

Vulnerable Groups is defined as the collective term used when talking about or referring to children, young people, and adults at risk. We recognise that children with special educational needs and disabilities can face additional safeguarding challenges, and we have a risk assessment process in place for any such circumstances. 

Appendix 4 

Guidance for Dealing with a disclosure 

Through appropriate training, staff and volunteers will become more confident in dealing with concerns, allegations, and disclosures.  

The role of staff and volunteers is to:  

  1. Child or Adult makes a disclosure. Staff recognise signs of abuse Safeguarding concern is raised within a local community  
  1. Keep calm and reassure the child or adult Ask for further details Do not ask leading questions Explain you will have to pass the information on  
  1. Allow the child or adult to talk at their own pace Use their own language and listen attentively Do not pressure them into telling you things they don’t want to disclose Gather information  
  1. When a child or adult is at immediate risk of harm keep them at a safe place and make immediate contact with the Head of Safeguarding, Local authorities/police 
  1. Make a detailed factual report including times, dates, quotes and complete a referral to the Head of safeguarding and ensure the concern is recorded on TOOT TOOT (child protection online management system) 

Appendix 5 

Online safety links: 

These include: 

UK Safer Internet Centre 


Internet Matters 




Complaints Policy

Document Ref:     Complaints & Compliments Policy 
Date of version: August 2023 
Author: Paula Watson 
Approved by: Ryan Sparks        Signature:  
Confidentiality level: Internal, Public 

Amendment History 

Date Version Author Details of Amendment 
November 2018 Paula Watson Initial Release 
July 2019 Paula Watson Update to bring in line all policy annual reviews 
September 2020 Lee-Ann Brewer Annual Review and addition of compliments policy 
March 2021 Paula Watson New CEO 
August 2021 Marco Townson Appointment of a Supporters Liaison Officer & Customer Service Tiered System 
August 2022 Paula Watson Annual review  
August 2023 Paula Watson Annual Review 

Bradford City AFC welcomes comments and complaints from all members of the Clubs community. We use this process to improve our commitment to the players and staff (including volunteers) so we can provide a safe and enjoyable environment in which people can develop.

Bradford City AFC is committed to the continuous improvement of the services it provides. We recognise that, occasionally, mistakes will be made and this will not always meet the individual’s requirements or expectations. For these reasons it is Club policy that all complaints should be:

1.1 Received positively, treated seriously and in an open manner.

1.2Acknowledged immediately, preferably in writing.


1.4Resolved, wherever that is reasonably practical, within no longer than 13 working weeks.

1.5A source of learning with feedback used to ensure continuous improvement of the environment which the Club offers.

No complainant bringing a complaint under this procedure will be treated less favourably by any member of staff. If there is evidence to the contrary, the member of staff may be subject to disciplinary proceedings.

The policy applies to all members of the Club community but does not replace procedures for, staff grievances and disciplinary action; those procedures should be used where appropriate. 

Safeguarding Complaints 

 Any complaints or concerns raised which relate to an individual’s conduct or behaviour and have potential safeguarding implications for any individual (child or adult) will be directed to the Designated Safeguarding Officer or Senior Safeguarding Manager. Where appropriate, these concerns will then be managed through Bradford City AFC’s Safeguarding and Children Protection Policy or Safeguarding Adults Policy and procedures. To report directly to a member of the safeguarding team, please email 

Academy Complaints 

Any complaints or concerns raised with regards the Academy will be directed to Head of Academy, Mark Litherland or if regarding Mark the Senior Safeguarding Manager or CEO (marked as ‘FAO: CEO RYAN SPARKS’ and sent to

To report directly to Mark, please email  

To report directly to the senior safeguarding Officer please email Paula Watson  

3.1  The Club’s Supporter Liasion Officer (SLO) has responsibility for receiving complaints, escalating and involving appropriate persons where necessary, treating them seriously and dealing with them promptly and courteously in accordance with the procedure set out below 

3.2  ALL CLUB STAFF have responsibility for receiving complaints, treating them seriously and passing them to the supporter liaison officer, promptly and courteously in accordance with the procedure set out below 

3.3 The Club’s Designated Safeguarding Officer has responsibility for resolving a complaint and leading or contributing to an investigation into a complaint when this is considered appropriate 

3.4 The Academy Manager and/or Senior safeguarding Manager are responsible for resolving complaints that have not been resolved during the previous two stages. The decision made by the Academy Manager or Senior safeguarding manager is final.  

3.5 The Club Board is responsible for ensuring that the complaints policy and procedure are operating effectively and may become directly involved if a complaint is directed against the Designated Safeguarding Officer, Senior Safeguarding Manager or The Academy Manager.  

4.1 Tier One

The Club expects complaints to be made informally to a member of staff in the first instance. These concerns should be recorded by the member of staff and advice sought immediately if any safeguarding concerns are suspected or apparent. It is hoped that most complaints can be resolved at this level and any agreed action is captured in a record that is agreed by all parties.   

Where it is not possible to address issues informally with an appropriate manager or initial staff responses do not result in satisfactory resolutions, the complaint should be submitted in writing to the Club’s Supporter Liaison Officer, Marco Townson.   

Contact details:  


Phone:   01274 773355 ext 223 

The Club usually expects complaints to be made by the person concerned. BCAFC will, however, always consider complaints made by a parent or advocate as it is acknowledged that there are many reasons (including imbalances of power) that block people from making a complaint themselves.  

It is very difficult to investigate anonymous complaints as there will always be information that cannot be gathered or clarified. Any complaints relating to potential safeguarding risks will however be taken seriously, including those which fall under the umbrella of the club’s whistleblowing policy and procedures.  

The Supporter Liasion Officer will acknowledge receipt within one working week, and escalate to the relevant department or persons, or tier required.  

4.2 Tier Two

The allocated independent staff member will respond in writing within one working week explaining what has happened as a result of the complaint. Where this involves a member of staff, specific details of action taken will not be made available. This is to ensure that our employees are afforded appropriate confidentiality and respect for their dignity at work.  

If the complaint requires further investigation that cannot be carried out within the week, the investigating staff member shall keep the complainant informed and indicate the expected timescale for a response to be provided.   

4.3 Tier Three

If the complainant is dissatisfied with the relevant investigating staff member’s response, then the complaint will be forwarded to a member of the Club’s Senior Management to resolve.  

The Senior Manager will acknowledge receipt of the complaint and respond to the complainant within 8 working weeks to allow time for any further information gathering and investigations to be undertaken.

4.4 Tier Four

Complaints against the Supporter Liasion Officer, Designated Safeguarding Officer, Senior Safeguarding Manager or Academy Manager

Complaints against the Supporter Liasion Officer, Designated Safeguarding Officer, Senior Safeguarding Manager or Academy Manager should be marked as ‘FAO: CEO RYAN SPARKS’ and sent to 

4.5 Tier Five

If the complainant is still dissatisfied they have the right to follow the English Football League (EFL) complaints procedure   

Complaints should be made in writing and may be submitted by post to:  

The Independent Football Ombudsman  

Suite 49, 33 Great George Street, LEEDS LS1 3AJ.   

or by e-mail to:   

or via the website:  

5. Monitoring and evaluation

The club will maintain a confidential record of all complaints, appeals and outcomes and consider the learning from issues raised in order to assess what action if any would create a more positive experience and environment for those involved in participating in or providing club activities and to promote a safer environment. Themes and issues arising during each season will be collated and fed back to the Board to inform planning and priorities for the following season.

Compliments Policy

We value and encourage all kinds of feedback. Anyone who has a relationship with Bradford City AFC can compliment a member of staff, a team or the organisation. Compliments are passed on to staff and their line manager and are used to identify areas of good practice that we can learn from and further develop.

Compliments can be submitted verbally to any member of staff who will record and share this or can be submitted via email to or in writing to the stadium.

Compliments are used to enable service development and as part of individual performance development. Employees receiving compliments will be recognised appropriately.


Senior Safeguarding Officer:

Paula Watson


The SSO is the senior manager with primary responsibility for managing and reporting safeguarding concerns and for putting into place and monitoring policies, procedures and daily practice to safeguard children and adults at risk in the organisation.

The Match day Safeguarding contact at the club is Sian Nuttall

by text 07949814243 or to the control room

The Academy Safeguarding & Club DSO contact at the club is Lee-Ann Brewer 07949 814505. The DSO is the designated person with primary responsibility for managing and reporting safeguarding concerns and to ensure there is good daily practice to safeguard children and adults at risk in the organisation. The Academy Player Care officer is Tom Calvert 07963 080219

Bradford City FC Community Foundation DSO is Lizzie Saunderson 07469 234066

If you prefer to report an incident by email please contact

If there are any concerns about any of the above named people then any of the external agencies can be contacted or Ryan Sparks (CEO) can be contacted at

If you have serious concerns about the immediate safety of the child or young person contact the Police or Social Services.  Record the name of the person you spoke to and tell your DSO what you have done.

Bradford Council Children Safeguarding Services During Working Hours: Monday to Thursday 8:30am to 5:00pm, Friday 8:30am to 4:30pm First Contact Team:01274  437500– out of hours 01274 431010

Bradford Council Adult Safeguarding Services During Working Hours: Monday to Thursday 8:30am to 4:30pm, Friday 8:30am to 4:00pm First Contact Team:01274  431077– out of hours 01274 431010   

West Riding FA: out of hours 07912 309565

FL Child Protection Advisor: 01772 325 811/07795 628 379  

FA Safeguarding Team: 0800 169 1863 or via 

English Football League Trust on 07583491701

NSPCC Helpline number: 0808 800 5000/

Bradford City  

Safeguarding Commitment Statement 

August 2023: Version 2 

The purpose and scope of this Commitment statement 

Bradford City AFC recognises its duty of care to safeguard all children, young people and young players, vulnerable adults/groups involved in activities organised by ourselves from harm.  All children and adults at risk have the right to protection, and the needs of disabled children and others who may be particularly vulnerable must be taken into account.  We will do their utmost to ensure the safety and protection of all children/groups and adults at risk involved in activities through adherence to the safeguarding guidelines adopted by the Club.  

The purpose of this policy statement is:  

• to protect children and young people who interact with Bradford City AFC from harm. This includes the children of adults who use our services  

• to provide staff and volunteers, as well as children and young people and their families, with the overarching principles that guide our approach to child protection. This policy applies to anyone working on behalf of Bradford City Football Club, including senior managers and the board, paid staff, volunteers, sessional workers, agency staff, contractors and students. 

Legal framework  

This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in England. A summary of the key legislation and guidance is available in the safeguarding policy document.  


This policy covers all activities within the; Stadium, Training Ground, and Academy. The community foundation operate their own Safeguarding policies and processes in line with the code of capability.  

Supporting documents:  

This policy statement should be read alongside our organisational policies, procedures, guidance and other related documents:  

• role description for the designated and senior safeguarding officer  

• dealing with disclosures and concerns about a child or young person or adult at risk   

• managing allegations against staff and volunteers  

• low level concerns  

• code of conduct for staff and volunteers, players, and coaches  

• photography and sharing images guidance  

• safer recruitment  

• online safety  

• anti-bullying  

• managing complaints  

• whistleblowing  

• health and safety  

• induction, training, supervision and support  

• adult to child supervision ratios.  

We believe that:  

• children and young people and adults at risk should never experience abuse of any kind  

• we have a responsibility to promote the welfare of all children and young people and adults at risk, to keep them safe and to practise in a way that protects them. 

We recognise that:  

• the welfare of children and adults at risk is paramount in all the work we do and  

  • in all the decisions we take  

• working in partnership with children, young people, their parents, carers and  

• other agencies is essential in promoting young people’s welfare  

• all children, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have an equal right to protection from all types of harm or abuse  

 • extra safeguards may be needed to keep children who are additionally vulnerable safe from abuse.  

We will seek to keep children and young people safe by:  

• valuing, listening to and respecting them  

• appointing a Senior Safeguarding Officer, a designated Academy Safeguarding Officer and a lead board member for safeguarding  

• adopting child protection and safeguarding best practice through our policies, procedures and code of conduct for staff and volunteers  

• developing and implementing an effective online safety policy and related procedures • providing effective management for staff and volunteers through supervision, support, training and quality assurance measures so that all staff and volunteers know about and follow our policies, procedures and behaviour codes confidently and competently. 

• recruiting and selecting staff and volunteers safely, ensuring all necessary checks are made  

• recording and storing and using information professionally and securely, in line with data protection legislation and guidance [more information about this is available from the Information Commissioner’s Office:]  

• sharing information about safeguarding and good practice with children and their families via leaflets, posters, group work and one-to-one discussions  

• making sure that children, young people and their families know where to go for help if they have a concern  

• using our safeguarding and child protection procedures to share concerns and relevant information with agencies who need to know, and involving children, young people, parents, families and carers appropriately  

• using our procedures to manage any allegations against staff and volunteers appropriately  

• creating and maintaining an anti-bullying environment and ensuring that we have a policy and procedure to help us deal effectively with any bullying that does arise  

• ensuring that we have effective complaints and whistleblowing measures in place  

• ensuring that we provide a safe physical environment for our children, young people, staff and volunteers, by applying health and safety measures in accordance with the law and regulatory guidance  

• building a safeguarding culture where staff and volunteers, children, young people and their families, treat each other with respect and are comfortable about sharing concerns.  

Contact details  

Senior Safeguarding Officer:  

Paula Watson 


The SSO is the senior manager with primary responsibility for managing and reporting safeguarding concerns and for putting into place and monitoring policies, procedures and daily practice to safeguard children and adults at risk in the organisation.  

The Match day Safeguarding contact at the club is Sian Nuttall  

by text 07949814243 or to the control room 

The Academy Safeguarding & Club DSO contact at the club is Lee-Ann Brewer 07949 814505. The DSO is the designated person with primary responsibility for managing and reporting safeguarding concerns and to ensure there is good daily practice to safeguard children and adults at risk in the organisation. The Academy Player Care officer is Tom Calvert 07963 080219  

Bradford City FC Community Foundation DSO is Lizzie Saunderson 07469 234066 

If you prefer to report an incident by email please contact  

If there are any concerns about any of the above named people then any of the external agencies can be contacted or Ryan Sparks (CEO) can be contacted at 

If you have serious concerns about the immediate safety of the child or young person contact the Police or Social Services.  Record the name of the person you spoke to and tell your DSO what you have done. 

Bradford Council Children Safeguarding Services During Working Hours: Monday to Thursday 8:30am to 5:00pm, Friday 8:30am to 4:30pm First Contact Team:01274  437500– out of hours 01274 431010  

Bradford Council Adult Safeguarding Services During Working Hours: Monday to Thursday 8:30am to 4:30pm, Friday 8:30am to 4:00pm First Contact Team:01274  431077– out of hours 01274 431010     

West Riding FA: out of hours 07912 309565 

FL Child Protection Advisor: 01772 325 811/07795 628 379    

FA Safeguarding Team: 0800 169 1863 or via   

English Football League Trust on 07583491701 

NSPCC Helpline number: 0808 800 5000/  

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