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Statement of purpose
1. Turnstyle (the Organisation, we, our or us) is committed to preventing and responding to
risks of harm to and promoting the welfare of all children that we work with (i.e. as
Turnstyle's clients). These individuals are referred to as the
'Beneficiaries' of this Safeguarding Policy.
2. We recognise the importance of this commitment to safety and welfare and, further, are
committed to safeguarding all Beneficiaries without discrimination due to an individual's
age, disability, race, religion or belief, sex, gender reassignment, pregnancy or maternity
leave status, marriage or civil partnership status, or sexual orientation.
3. This Safeguarding Policy is based on the safeguarding laws of England, Wales, and
Scotland, including related guidance issued by the UK Government and relevant
governmental departments, agencies, and public bodies. If this Policy is at any time
inconsistent with this body of law, Turnstyle will act to meet the requirements of up-to-date
safeguarding laws in priority to the requirements set out in this Policy.
4. Turnstyle has implemented this Safeguarding Policy in order to meet its obligations as
an organisation working with children.
5. Any questions in relation to this Policy should be referred to Daniel Williams in the first
instance, by emailing or by contacting +447930819884

Scope of this Safeguarding Policy

6. This Policy explains key aspects of how Turnstyle prevents harm in relation to its
Beneficiaries via its practices and its
Staff Members' conduct.
7. This Safeguarding Policy covers the organisation and operation of all of Turnstyle's
activities involving children (i.e. our Relevant Activities). These primarily include:
A- Providing lectures and interactive lessons for young people.
B- Delivering combat sports sessions to those under 18 years of age.
8. This Policy's guidelines and obligations apply to all individuals working for or acting on
behalf of Turnstyle in the UK at all levels, including senior managers, officers, employees,
consultants, trainees, homeworkers, part-time and fixed-term workers, casual workers,
agency workers, volunteers, and interns (collectively 'Staff Members').
9. This Policy does not form part of any contract of employment or similar and Turnstyle
may amend it at any time at our absolute discretion.

Defining safeguarding

10. 'Safeguarding' is an umbrella term that refers to work refers to work (e.g. practices and
procedures) aimed at preventing or responding to harm or risks of harm posed to
vulnerable individuals, and at promoting these individuals' wider welfare.
Safeguarding is particularly important for children and adults at risk. Most safeguarding
legal obligations relate to the care of these groups. This Safeguarding Policy specifically
deals with safeguarding children. For safeguarding purposes, children are individuals
younger than 18 years old.
11. The commitments and practices contained in this Safeguarding Policy apply to the
safeguarding of Turnstyle's
Beneficiaries from harm caused by either:
A- The activities and practices of Turnstyle and any conduct of its Staff Members, or
B- People and situations outside of Turnstyle’s and its Staff Members' control, where
Turnstyle’s Staff Members are aware of, ought to be aware of, or reasonably suspect the
risks posed by a situation.
12. For the purposes of this Policy, a 'Safeguarding Concern' is any conduct or situation
that is known or reasonably suspected by a Staff Member or another party that risks
violating the safeguarding commitments set out above.

Key measures that Turnstyle is committed to implementing and maintaining to
safeguard its beneficiaries

13. Ensuring that Staff Members are trained to, and encouraged to, report any
Safeguarding Concerns that they identify. Staff Members will be encouraged to follow
Turnstyle’s safeguarding reporting procedures as closely as possible when reporting
concerns (set out below under the heading Procedures: Reporting').
14. Ensuring that all Staff Members listen to all safeguarding-related queries and concerns
raised by other Staff Members, Beneficiaries, or relevant other parties, with respect and
professionalism. Staff Members should be trained how to, and encouraged to, then assist
with reporting any such concerns via Turnstyle’s regular reporting procedures.
15. Ensuring that all reported Safeguarding Concerns are dealt with by appropriate
individuals and teams and in accordance with Turnstyle’s relevant procedures (set out
below under the heading Procedures: Investigation and Response).
16. Implementing and maintaining comprehensive, accessible, fair, and efficient
procedures for Staff Members to use when reporting and dealing with Safeguarding
Concerns. These procedures will be made known and easily accessible to all Staff
A- Procedures will be designed to ensure all safeguarding issues are dealt with fairly and
objectively even when allegations are made against one of Turnstyle's Staff Members. Any
such allegations will be treated in a manner that takes into account the gravity of the
accusations, but which does not vilify or presume the guilt of an accused individual without
a fair investigation.
B- Any reports that qualify as protected disclosures under whistleblowing law will be
treated securely and in a protected manner in line with whistleblowing law.
17. Appointing to hold responsibility for managing safeguarding policies and procedures
within Turnstyle.
18. Following appropriate recruitment processes when recruiting new Staff Members,
including volunteers. This includes:
A- Conducting all appropriate pre-employment checks (e.g. Disclosure and Barring Service
(DBS) criminal record checks).
B- Ensuring new Staff Members take part in, and understand the content of, all necessary
safeguarding training before having any contact with Turnstyle's Beneficiaries.
C- Following Turnstyle’s policies and procedures on hiring and recruitment.
19. Providing appropriate safeguarding training for all relevant Staff Members. Every Staff
Member should be provided with, and required to undertake, training that is appropriate to
their role, responsibilities, and degree and type of contact with Beneficiaries. This should,
where appropriate, include training on:
A- How to define and identify potential signs of different types of abuse, including physical
abuse, emotional abuse, sexual abuse and exploitation, neglect, and others.
B- How to listen to and respond to concerns or disclosures about safeguarding issues
during an initial conversation (e.g. how to explain when information can and cannot be
kept confidential).
C- How to use Turnstyle’s safeguarding reporting procedures and when doing so is
D- Which additional resources (e.g. policies, other supporting documents, or external
educational resources) are available to ensure Staff Members remain informed about
20. Ensuring that all information related to Safeguarding Concerns, including the content of
reported concerns as well as the personal data of anybody involved, is handled safely and
securely. This involves:
A-Following the requirements set out by the UK's data protection laws, including The UK
General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
B- Following Turnstyle’s data protection policies and procedures.
C- Providing Staff Members with training on data protection and privacy, where
D- Ensuring Staff Members always have an identifiable point of contact for questions or
concerns about data protection and privacy. This is currently Daniel Williams, who can be
contacted by emailing or at +447930819884
E- Only sharing information about a Safeguarding Concern internally as far as is
necessary to manage the concern for the relevant Beneficiary's benefit.
20. Ensuring transparency and awareness regarding safeguarding information and
procedures. For example, by:
A- Providing information to Beneficiaries about our safeguarding procedures so that they
are aware of how to raise any concerns.
B-Ensuring all Staff Members are aware of safeguarding laws, Turnstyle’s safeguarding
commitments and procedures, and Staff Members' responsibilities in relation to these.
21. Regularly reviewing all safeguarding policies and procedures to ensure that they are
up-to-date with safeguarding law and that they remain suitable for Turnstyle's Relevant
Activities and workforce, and meeting any review and evaluation requirements specific to
Turnstyle's industry and organisation type.

Staff members' responsibilities

22. All Staff Members have a responsibility to promote the safety and wellbeing of all of
Turnstyle ' Beneficiaries. This means that all of Turnstyle ' policies and procedures relevant
to safeguarding and all UK laws relevant to safeguarding must be followed at all times.
23. All Staff Members must contribute to upholding the key measures that Turnstyle has
committed to taking to safeguard its beneficiaries (set out above) to an extent that is
appropriate for their role, responsibilities, and degree and type of contact with
Beneficiaries. Specific ways that Staff Members should do this will be clarified during
training. If a Staff Member is uncertain as to their responsibilities, it is their responsibility to
raise this with Daniel Williams.
24. Staff Members must actively participate in all safeguarding training they are assigned
and, if they do not understand any aspects of their training, must raise this with Daniel
25. Staff Members must never do anything to actively risk the safety or wellbeing of any of
Turnstyle's Beneficiaries. This includes, but is not limited to:
A-Subjecting them to or facilitating abuse of any sort.
B- Engaging in any sexual activity with children (i.e. anybody under the age of 18).
C- Participating in or facilitating any activities that may commercially exploit Beneficiaries.
For example, failing to report suspected child labour or trafficking.
26. Staff Members must report all Safeguarding Concerns that they have regarding
beneficiaries, regardless of whether the concerns relate to potential wrongdoing of other
Staff Members, other beneficiaries, or external parties (e.g. parents, teachers, other
organisations, or members of the public).

Procedures: Reporting

27. Staff Members will receive safeguarding training that should enable them to identify
Safeguarding Concerns (e.g. suspected abuse, neglect, or threats to wellbeing) relevant to
Turnstyle’s beneficiaries.
28. If a Staff Member identifies a Safeguarding Concern, to report it they should:
A- Immediately contact Turnstyle's designated safeguarding lead officer.
28. If a Staff Member feels unable to follow the above steps, they should report their
Safeguarding Concern in a reasonable alternative manner. This may the case if, for
A- Following the above procedure would require disclosing the concern to somebody who
is implicated in the Safeguarding Concern or who the Staff Member is otherwise
uncomfortable contacting about this concern, or
B- The matter is time sensitive and involves a risk of serious harm to somebody, in which
case contacting an external agency (e.g. the police, the ambulance service, or a mental
health crisis line) or a more senior member of Turnstyle's staff first may be more

Procedures: Investigation and response

29. Reported Safeguarding Concerns will be dealt with promptly by appropriate individuals
within Turnstyle, in accordance with our safeguarding response procedures and
safeguarding laws. Details of these procedures are available on request from
Daniel Williams
30. Staff Members who report a Safeguarding Concern will be kept informed about the
progression of the matter they reported to an appropriate degree. Note that, depending on
the nature of the concern and consequent investigations, some information about matters
may be kept confidential and not shared with the reporter.
31. If a Staff Member is found to be in breach of this Safeguarding Policy or safeguarding
law in general, they will be treated fairly and will only be dismissed if appropriate in the
circumstances and in accordance with employment law.
32. Referrals or notifications to external organisations (e.g. police services, local
authorities, or regulatory bodies) will be made when, and only when, this is appropriate,
and will always be made in accordance with the law (e.g. data protection law).

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