8.3 Allegations Against Persons who Work/Volunteer with Children

This policy is currently under review following the publication of Working Together 2023.

Every Local Authority has a statutory duty to provide and manage the safeguarding process that considers any allegations made in respect of workers, and those in positions of trust such as volunteers, who work with children within their area. The Local Authority Designated Officer (LADO) is responsible for leading on and facilitating the overall safeguarding process which is delivered in conjunction with employers/agencies and other relevant safeguarding partners such as Education, Police, Health, Faith Groups, Voluntary Agencies and Sports Groups.

For the purposes of this protocol, the following definitions apply:

A child is anyone under the age of 18
An employee is anyone working with children, be it in an employed (all sectors and settings) or voluntary capacity
An employer is anyone working with or providing services to children (all sectors and settings).

1. Scope

All allegations of abuse of children by those who work and/or volunteer with them, such as a paid employee, unpaid volunteer, child-minder, approved foster carer or prospective adopter, must be taken seriously. The allegation/s may relate to the person’s behaviour at work, at home or in another setting.

The scope of this multi-agency procedure is not limited to allegations involving Significant Harm, or suffering or likely to suffer Significant Harm, to a child. The procedure should be applied in all situations where it is alleged that a person who works, or volunteers, with children has:

Behaved in a way which has harmed a child, or may have harmed a child
Possibly committed a criminal offence against or related to a child
Behaved towards a child or children in a way that indicates they may pose a risk of harm to children; or
Behaved in a way that indicates they may not be suitable to work with children.

It can be difficult to determine what behaviours may fall into the category of “unsuitable to work with children or adults at risk”. The employer/agency should consider whether the subject of the allegation or concern has:

Been the subject of criminal procedures that indicate a risk of harm to a child or adult at risk
Caused harm or possible harm to a child or vulnerable adult at risk and there is a risk in the working, volunteering, or caring environment
Contravened or continued to contravene their agency’s Safeguarding Policy and Procedures
Failed to understand or comply with the need for clear personal and professional boundaries in the workplace
Behaved in a way in their personal life which could put children and vulnerable adults at risk of harm
Behaved in a way that undermined the trust placed in them by virtue of their position
Children who the individual parents who themselves are subject to Child Protection Procedures
Has caring responsibilities for an adult who is subject to Adult Protection Procedures

The LADO safeguarding process must consider transferable risk for all children. If there are concerns about the behaviour or conduct of a person in their private life who is working or volunteering with children, the LADO must consider the transferable risk to those children.

Whilst some behaviours may not constitute a criminal offence, and some may not reach the threshold of Significant Harm, consideration will need to be given as to whether such behaviours may indicate unsuitability to work with children. Any such behaviour should be considered within the context of the four categories of abuse i.e. physical, sexual and emotional abuse and neglect.

These include concerns relating to inappropriate relationships with children or young people:

Having a sexual relationship with a child under 18 if in a position of trust in respect of that child, even if consensual
Grooming, i.e. meeting a child under 16 with intent to commit a relevant offence (see Section 16-19 Sexual Offences Act 2003)
Other ‘grooming’ behaviour giving rise to concerns of a broader child protection nature e.g. inappropriate text/email messages or images, gifts, socialising etc (see Section 15 Sexual Offences Act 2003)
Possession of indecent photographs/pseudo-photographs of children
Qualified/unqualified staff becoming involved in a relationship with an ex-pupil under the age of 18, who is no longer at the school
Sexual Exploitive behaviour
Inappropriate Physical restraint or physical harm to a child

In the context of this procedure, the term “employer” means the organisation that has a working relationship with the person against whom the allegation has been made and includes voluntary organisations, employment agencies, fostering services, child minder services, youth clubs and others.

Allegations of historical abuse should be responded to in the same way as current concerns. Anyone over the age of 18, making a historical allegation of abuse needs to contact the Police in the first instance, it will then be the Police who refer to the LADO as per procedures. In such cases, it is important to find out whether the person against whom the allegation is made is still working with children, the current employer is not informed until the LADO has discussed and agreed with the Police what information will need to be shared.

Where concerns arise about a person’s behaviour in relation to their own children, the current employer is not informed until this is agreed with Children’s Services Social Care and/or the Police. There may be a need to contact the current employer to assess whether there may be implications for children with whom the person has contact at work, in which case this procedure will apply.

2. Key Roles and Responsibilities

2.1 Local Authority Designated Officers

(Working Together to Safeguard Children 2018 now refer to LADO’s as Designated Officers). The Local Authority must appoint a Designated Officer(s). In Norfolk the title of LADO remains in use.

PLEASE NOTE: The LADO will:

Not undertake any investigation regarding the events of concern
Not have direct communication with the person subject of the allegation
Not provide advice and support to the person subject of the allegation
Not provide advice in respect of suspension or dismissal of a person subject of an allegation.

The LADO’s responsibilities are:

To quality assure and have oversight of the safeguarding investigation undertaken
To be involved in the management and oversight of individual cases from all partner agencies of the NSCP which fall within this LADO procedure
To provide advice and guidance to employers and agencies about the operation of this procedure, and their role and responsibilities within it
To provide advice to parents and members of the public who contact the LADO Service as to which agencies/people to contact should they have concerns about the safety and welfare of a child / young person
To liaise with all applicable agencies and organisations in respect of each safeguarding LADO process; including monitoring the progress of cases and ensuring each is dealt with as quickly as possible, in a thorough and fair process
To keep records of all advice given, actions taken, and decisions made
To chair all LADO Meetings, initial, review and final
Liaise with chairs of Complex Abuse Strategy Meetings and any other relevant safeguarding meeting process
To contribute to Norfolk Safeguarding Children Partnership inter agency safeguarding training programmes and awareness raising events
To liaise with the Police and the Crown Prosecution Service, Ofsted and other regulatory bodies as necessary
To maintain information databases in relation of all allegations and produce qualitative and quantitative reports for the NSCP and Department for Education

2.2 Named Senior Officer (Employer/Agency)

Each employer / agency will appoint a Named Senior Officer to have overall responsibility for ensuring that their agency operates procedures for dealing with allegations against those who work with children in accordance with the guidance set out in Working Together to Safeguard Children 2018.

The responsibilities of the Named Senior Officer include:

Ensuring that their organisation complies with the standards identified and agreed by the NSCP for managing allegations as outlined within the Working Together to Safeguard Children 2018.
Ensuring that this NSCP procedure for managing allegations is reflected and implemented within their own agency procedures.
Ensuring that the work force is aware of and implements this procedure in relation to all allegations against those who work with or on behalf of children.
Ensuring that the organisation has systems in place to review cases and identify and implement any changes, therefore improving procedures and practice.
Resolving any inter-agency issues which impede the implementation of this NSCP procedure.
Ensuring that the key roles of Named Senior Officer, Local Authority Designated Officer and Senior Manager (employer) are reflected in their agency policy and procedure.
Ensuring that effective reporting and recording arrangements within their agencies are in place.

2.3 Senior Manager (Employer/Agency)

Each employer / agency will appoint a Senior Manager who has overall responsibility for ensuring that this safeguarding procedure is followed at an operational level (this may the same senior officer as detailed in section 2.2 above).

The responsibilities of the Senior Manager include:

Ensuring that this procedure is properly applied and implemented
Providing advice, information, and guidance for staff within their organisation in relation to safe working practice
Being the senior manager within their organisation to whom all allegations or concerns are reported.
Referring allegations in accordance with this procedure and those of their organisation.
Liaising with the Local Authority Designated Officer (LADO) as required under this procedure.
Gathering all additional information which may have a bearing on the safe management of the allegation and the safeguarding of children, e.g. previous known concerns about a workers behaviours, care and control incidents, etc.
Undertaking the employer’s duty of care in relation to the person subject to the allegation; providing them with information as to where they can obtain support, including signposting to the union or professional body.
Attending LADO Meetings on behalf of their organisation.
Ensuring timely liaison with their organisations’ Human Resources service; including, where needed, dialogue regarding employment activities for the individual while the investigation and associated LADO process is progressed.
Ensuring that workplace / work task risk assessments are undertaken where deemed necessary.
Should the allegation be found to be malicious, considering in consultation with the LADO, the need to make a referral to Children’s Social Care Services or to the Police for further consideration.
Ensuring that effective reporting and recording systems are in place in their organisation which enable the tracking of allegations through to the final outcome.
Providing reports and information to the LADO when requested, as required by this procedure.
Raising the awareness of the need to empower children and young people who are in vulnerable positions by ensuring their organisation has an effective and accessible whistle blowing and complaints procedures for all children.
Ensuring appropriate and relevant training programmes are in place for and accessed by all staff.
Ensuring relevant support programmes are in place for children/young people, parents, and staff.

The employer must also identify an alternative person to whom reports should be made in the absence of the nominated Senior Manager, or in cases where that person is the subject of an allegation or concern.

2.4 The Police – Key Officers

The Chief Superintendent (or designated deputy) of the Safeguarding and Investigations Command will:

Have strategic oversight of the local police arrangements for managing allegations against staff and volunteers.
Proactively liaise with the Norfolk Safeguarding Children Partnership in respect of this safeguarding procedure and all other applicable safeguarding children’s procedures.
Ensure compliance with this procedure and all other applicable safeguarding children’s procedures.

The Safeguarding and Investigations Command should designate a Detective Inspector (or designated deputy – This may be an officer from another unit where they lead on the investigation) to:

Liaise with the LADO Service on an ongoing basis.
Take part in the LADO Meeting process, where applicable.
Review the progress of cases in which there is a Police investigation.
Share information, as appropriate, on completion of an investigation or related prosecution.

3. Responding to Allegations

All organisations which provide services to children, or provide staff or volunteers to work with or care for children, should operate a procedure for managing allegations, that fall within this procedure, in a way which is consistent with the guidance set out in Working Together to Safeguard Children 2018; Keeping Children Safe in Education (2022); Keeping children safe during community activities, after-school clubs and tuition: non-statutory guidance for providers running out-of-school settings (2020).

Where such allegations are made, consideration must be given to the following strands:

The police investigation of a possible criminal offence
An internal investigation by the agency/employer if there is not a criminal investigation
Enquiries and assessment by Children’s Social Care Services as to whether the child is in need of protection or in need of services
Consideration by an employer of disciplinary action in respect of the individual.

4. Initial Considerations

All allegations, as detailed within this procedure, that come to the employer’s attention should be notified to the Local Authority Designated Officer (LADO) within one working day by completing the LADO referral form found on the NSCP website.

Contact with the LADO needs to be made before any contact is made either with the person subject to the allegation or the child and parent/carer. This is to ensure that the correct action is taken which will not impede any investigative or disciplinary processes.

The LADO will discuss the matter with the employer and where necessary obtain further details of the allegation and the circumstances in which it was made.

If the LADO criteria and threshold is not met, the LADO will confirm the reason why this is so and, where appropriate, may offer advice and guidance to the employer/agency; the referral will then be closed as a consultation.

It remains the employer/agencies’ responsibility to inform the person subject of the referral that there was a consultation dialogue with the LADO Service.

The Police should be consulted, in any case where a criminal offence may have been committed, or where a parent wishes the allegation to be reported to the Police, as soon as practicable. In such circumstances, the LADO will liaise with the MASH Police and/or the Children’s Advice and Duty Service (CADS) to ensure that all necessary safeguarding or investigative procedures are implemented.

If there is reasonable cause to suspect that a child is suffering or is likely to suffer Significant Harm, the responsible person or employer must immediately refer the concerns around the child to CADS, whilst at the same time referring the safeguarding matters around the adult of concern to the to the LADO Service. Wherever possible the LADO should be included in the Section 47 strategy discussion to consider whether the allegation/concern against the person of concern meets the LADO criteria.

In any case where there is a Section 47 Joint Investigation or a live Police investigation the Police should be represented at the initial LADO meeting.

In other cases, the Police should be consulted pre or post meeting as appropriate on any identified criminal concern.

When an allegation is against a residential children’s home practitioner and the threshold for the safeguarding LADO process is met, the LADO Service will notify and update the Commissioning and Service Development Manager (Sufficiency) as appropriate. Consideration will also be given to notifying other Local Authorities and Ofsted, and alerting senior managers about any systemic concerns.

Where involvement from Children’s Social Care is not required as the child is not believed to be suffering or likely to suffer significant harm but a police investigation will continue, the LADO should convene an initial meeting/discussion as appropriate to agree the agency’s response and actions needed, whilst the police investigation is ongoing.

Where a decision is made that neither Children’s Social Care nor the Police are required to continue any involvement, the LADO should discuss the next steps with the employer’s senior manager about what further investigations are necessary, who will do this investigation and how this will be fed back into the safeguarding LADO process.

It is the responsibility of the employer/agency to inform the person of concern, that they are the subject of a formal safeguarding LADO process. The timing of that dialogue may be directed by the Police when there is a criminal investigation. In order that the person of concern understands the LADO process we ask that the employer/agency provides them with the information leaflet for people referred to the LADO Service .

In the event of a LADO Meeting being held, then this should be convened as soon as possible and include the LADO as chair and the Senior Manager for the organisation the referral is about.

5. Initial LADO Meeting

Where the threshold for a LADO safeguarding process is met, the process will always include information sharing and action planning with relevant agencies in respect of the allegation and the safeguarding of children. Such a dialogue/meeting will always include a representative from the employer/agency and may take the form of a formal meeting, face to face or virtually, but on occasions a telephone discussion may be justified. The LADO chairs the meeting/dialogue, including any follow up meetings, ensuring that all relevant people are invited to participate to ensure that the full scope of the enquiry can be effectively addressed.

Attendance and participation at these meetings must be prioritised as part of your organisations safeguarding responsibilities.

The following is a list of possible participants:
(anyone implicated or potentially implicated in the allegation will not be involved)

The LADO
The Referrer
Designated Senior Manager for the employer / agency concerned
[All agency types / sectors, inc. Education, Social Care, Health, Voluntary/Charitable, Not for Profit, Sports, Faith Groups, Transport, Scouting and Early Years]
Police – Sergeant or Inspector rank
Social Worker / Social Work Manager for the child, if applicable
Supervising Social Worker / Social Work Manager when an allegation is made against a foster carer
Where a child from another local authority is placed or resident in Norfolk where the alleged incident took place, the child’s social worker and/or manager
Representation from Governor Services and/or Academy Trust where allegations are about a Head Teacher or School Governor
Those responsible for regulation and inspection where applicable
Designated Safeguarding Leads for Health, where appropriate
Human Resources representative for the employer / agency concerned
Complaints officer if the concern has risen from a complaint

Notifications will be required to be made to OFSTED by the employer/agency, regarding day care and child-minders, residential staff, foster carers and prospective adopters.

The Initial LADO Meeting / dialogue will:

Share all relevant information about the person who is the subject of the allegation and about the alleged child victim
Consider the current allegation in the context of any previous allegations or concerns
Check whether there are any diversity or equality issues/special needs to consider for either the victim or the person of concern
Consider whether any other children are affected by the allegations, e.g. the persons own children or other children in the agency setting for example children placed with foster carers, child-minders, a youth club, grandchildren, residential unit;
Determine any action that needs to be taken in respect of any other children identified including discussions with CADS about a Section 47 Enquiry
Plan the investigation/enquiries of the LADO safeguarding process and set timescales for tasks to be undertaken
Where the allegation concerns a residential or fostering setting, the safeguarding dialogue will consider the implications of the allegations for any other children in placement
The matter of contact between the person subject of the allegation and children will be reviewed regularly within the LADO process as the understanding of safety for children may change as the investigation progresses
Decide how regular information and support will be provided to the child and family and by whom including the outcome of the process
Ensure that there is consideration to the employer/agency’s responsibility to the person who is the subject of the allegation to be kept informed and supported as part of the agency/employer’s duty of care
Consider whether any parallel disciplinary process can/will take place and agree protocols for sharing information. Parallel disciplinary processes are the employer’s decision, however there will be a clear understanding that the information from the employer/agency process will be shared within the safeguarding LADO process to inform decision-making
Consider issues for the attention of senior management e.g. media interest, resource implications, systemic concerns impacting on commissioning of services;
Consider whether a Complex Abuse investigation is applicable, to be managed by the relevant social care service, i.e. fostering, commissioning, residential, front-line social care, etc. linked to the setting/service of concern.

6. On-going LADO Involvement and Outcome of the Safeguarding LADO Process

The progress of the investigation and associated enquiries will be reviewed by the LADO on a regular basis. The LADO is not able to set a confirmed timescale for completion of an investigation as the process depends on several factors including the nature/complexity of the concerns. The LADO will however, endeavour to minimise unnecessary delays by liaising regularly with the agency undertaking the investigation. Agencies are required to keep the LADO informed of the progress of the investigation, including the conclusion of any investigation in order that a final LADO Meeting can be held in respect of the safeguarding concerns and the allegation/s.

The Police or the Crown Prosecution Service (CPS) should inform the employer’s Senior Manager and Local Authority Designated Officer (LADO) as soon as practicable when a criminal investigation and any subsequent trial are complete, or if it is decided to close an investigation without charge, or not to prosecute after the person has been charged.

The final LADO meeting is held to ensure all tasks agreed in the initial LADO Meeting action plan have been completed and to enable an adjudication to be made on the outcome of the allegation/s. Where appropriate, an action plan for future practice based on lessons learnt may be identified and agreed.

The essential people to attend the final LADO meeting are:

The referrer where relevant or appropriate (as agreed with the LADO)
Senior representatives from the employer/agency
Person/s representing the voice of the child. If this is not possible, the LADO will ensure that the voice of the child is represented through other means
Investigator and/or person overseeing the investigation
All other persons attending will be agreed with the LADO in advance of the meeting

When the agency investigation has been completed, a written report of the investigation must be shared with the LADO (four working days) prior to the final LADO meeting. The investigation report is important to inform the LADO meeting adjudication and safeguarding outcomes.

It is the employer/agency’s responsibility to ensure that the views of the person subject of the LADO process are obtained and represented in the final LADO meeting.

In summarising the information shared from the investigation, the LADO will give clear direction in terms of the adjudication options that are relevant to the outcome. The LADO has the deciding adjudication where there is a split decision, or if the LADO does not believe that the decision was appropriate, fair, or proportionate.

The record of the LADO meeting is not verbatim, it is a factual summary of the meeting that enables decisions and actions to be recorded.

Where there is no admittance by the person of concern, or caution or conviction, in respect of the allegations, meeting participants will make a decision considering all the information shared in the process. The adjudication is an informed professional decision based on the balance of probability, which is a lower threshold than beyond all reasonable doubt that is used in a court of law.

It is the employer/agency’s responsibility to share the outcome of the Safeguarding LADO Process with their employee/volunteer who had been subject of the LADO referral.

There is no appeal to the outcome of the Safeguarding LADO Process.

The Norfolk County Council Complaints Process should be followed if the person considers the allegations procedures as set out in this document was not followed.

Where there is a substantiated LADO process outcome, and when both the harms test has been met and the person has been dismissed/resigned/removed from regulated activity, it is a legal requirement as set out in Working Together 2018, that a referral to the Disclosure and Barring Service (DBS) is made by the employer or volunteer manager. The National DBS will consider whether the person will be ‘barred’ from working/volunteering with children. ‘Barring’ is not an automatic consequence of a referral to the National DBS.

In these circumstances the person subject of the LADO process should be made aware, by the employer/agency, that the details of the allegation and outcome of the safeguarding LADO referral and LADO process could be disclosed on an enhanced DBS certificate if there has been a s.47 strategy discussion, police involvement, child protection procedures and/or if the local and/or national DBS contact the LADO service to request information.

A further possible action where there is a substantiated LADO process outcome, is that the employer will also make a referral to a relevant Regulatory or Registration body for certain professions, i.e. teachers, social workers, nurses, doctors etc. Where there is no employer, the LADO, or other agreed agency representative who took part in the final LADO Meeting, may make a referral to the DBS or relevant regulatory/ registration body.

7. Cross Boundary Issues

Where a child makes an allegation in a setting or placement which is outside their own local authority, the lead responsibility for the safeguarding LADO process lies with the LADO for the area where the alleged abuse occurred, i.e. if an alleged incident happens in Norfolk it is the responsibility of the Norfolk LADO to lead the process regardless of where the employer or employment agency is based, or where the child originates from. In these circumstances, the Norfolk LADO and the child’s social worker will liaise with the relevant LADO for that area and agree a joint strategy.

Where the referral relates to a child from another Local Authority temporarily placed in an establishment located within Norfolk Local Authority Area’s area, for example a boarding school or holiday activity centre etc, the Local Authority Designated Officer should liaise with the child’s home authority about the roles and responsibilities in carrying out this procedure.

NB: In some circumstance the Norfolk LADO will discuss and negotiate with the LADO from the other local authority as to who is best placed to facilitate the LADO process.

8. Restrictions on identifying Teachers against whom Allegations of Criminal Misconduct have been made

With effect from 1 October 2012, the Education Act 2011 introduced reporting restrictions preventing the publication of any material that may lead to the identification of a teacher who has been accused by, or on behalf of, a pupil from the same school (where that identification would identify the teacher as the subject of the allegation). The reporting restrictions apply until the point that the accused person is charged with an offence, or until the Secretary of State publishes information about an investigation or decision in a disciplinary case arising from the allegation. The reporting restrictions also cease to apply if the individual to whom the restrictions apply effectively waives their right to anonymity by going public themselves or by giving their written consent for another to do so or if a judge lifts restrictions in response to a request to do so. Breaching the reporting restrictions is a criminal offence.

The Headteacher/Chair of Governors should take advice from the LADO, police and children’s social care services to agree the following:

Who needs to know and, importantly, exactly what information can be shared
How to manage speculation, leaks and gossip
What, if any information can be reasonably given to the wider community to reduce speculation; and
How to manage press interest if and when it should arise. Please note that this provision applies only to teachers, not to other staff in educational establishments.

9. Resignations and Compromise Agreements

The fact that a person resigns, or ceases to provide their service, must not prevent the allegations being followed up in accordance with these procedures. It is important that every effort is made to reach a conclusion in all cases of safeguarding allegations bearing on the safety or welfare of children, including any in which the person concerned refuses to cooperate with the process, having been given a full opportunity to answer the allegation and make representations.

Compromise agreements must not be agreed whilst the safeguarding process is ongoing.

10. Confidentiality and Record Keeping

Under the General Data Protection Regulations and Data Protection Act 2018, any information shared in a LADO meeting/process is strictly confidential and cannot be shared with anyone outside of this meeting without the permission of the LADO who chaired the meeting.

Information shared without explicit written consent of the LADO may be treated as a breach of Data Protection.

Every effort should be made to maintain confidentiality and guard against publicity while an allegation is being considered or investigated.

Each agency should not provide any information to the press or media that might identify an individual who is under investigation, unless or until the person is charged, except in exceptional circumstances where this is agreed by all parties within a safeguarding plan of action, e.g. an appeal to trace a suspect. In such cases, the reasons should be documented, and partner agencies should have been consulted beforehand.

The outcome of the Safeguarding LADO Process is confidential to the person subject to the allegation or concern and cannot be shared with anyone unless agreed by the LADO.

The person subject of the allegation has a right under section 7 of the Data Protection Act to have access to information about themselves. This does not however give them a right to access information about others, even though they may be the person of concern and subject of the LADO process; or the victim or the parent or carer of the victim making the allegation in the LADO process.

The HR service or the Designated Manager of the employee in question must keep a clear and comprehensive record of any allegations made.

Each agency must take great care to ensure that the records they keep respect the confidentiality of the victim and/or the alleged person of concern i.e. the child’s file should contain limited information about the person of concern and the their (his/her) file should contain limited information about the child victim.

The details of the LADO process, including outcome must not be included on a child’s Social Care record. Only that a Safeguarding LADO process has taken place and that the Norfolk LADO can be contacted for further details. The victim, or the parent or carer of the victim, making the allegation in the LADO process will also not be given access to the LADO records as this is confidential to the person subject of the LADO process.

11. Learning Lessons

The employer/agency and the LADO should review the circumstances of the case to determine if there are any improvements to be made to the organisations procedure or practice.

In some cases, a Serious Case Review may be appropriate. This will be discussed at a Lessons Learnt meeting and appropriate referral/discussion had with the Chair of the Serious Case Review Group.

12. Guidance on Retention of Records

HR or the Senior Manager of the employee in question should keep a clear and comprehensive summary of any allegations made, details of how the allegations were followed up and resolved, and of any action taken and decisions reached. These should be kept in a person’s confidential personnel file and a summary should be given to the individual by the employer.

Please note that the record of LADO meetings must not be given to the person subject of the process. They may apply for access to the record through the Norfolk County Council Information Management Service.

The purpose of maintaining a record that a LADO process has taken place in respect of the individual, is to enable accurate information to be given in response to any future request for a reference under safer recruitment procedures. It will provide clarification in cases where a future DBS disclosure reveals (from Police records), that an allegation was made, but did not result in a prosecution or a conviction. It will also prevent unnecessary re investigation if, as sometimes happens, allegations resurface after a period of time.

Guidance from the Independent Investigation into Child Sexual Abuse (IICSA) advises all organisations to retain all documents, notes, emails and all other information – however held – which contains or may contain content pertaining directly or indirectly to the sexual abuse of children or to child protection care. Children relates to any person under the age of 18. This remains in force.

8.2

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