SAFEGUARDING POLICY FREEFRAME JULY 2026

Safeguarding Policy

FREEFRAME
Scottish Safeguarding Framework
Document date: 11 July 2026
Review date: 11 July 2027
Author and Safeguarding Lead: Angela Jackson

Document owner	Angela Jackson
Applies to	FREEFRAME staff, trainers, contractors, volunteers and learners
Jurisdiction	Scotland
Next review	11 July 2027

1. Relevant legislation

Adult Support and Protection (Scotland) Act 2007
Adult Support and Protection (Scotland) Act 2007: Code of Practice, revised 2022
National Guidance for Child Protection in Scotland 2021, updated 2023
Children (Scotland) Act 1995
Children and Young People (Scotland) Act 2014
Children (Scotland) Act 2020
Protection of Vulnerable Groups (Scotland) Act 2007
Disclosure (Scotland) Act 2020 and regulated roles requirements
Public Interest Disclosure Act 1998
Human Rights Act 1998
Equality Act 2010
Data Protection Act 2018 and UK GDPR
Mental Health (Care and Treatment) (Scotland) Act 2003
Adults with Incapacity (Scotland) Act 2000
Forced Marriage etc. (Protection and Jurisdiction) (Scotland) Act 2011
Domestic Abuse (Scotland) Act 2018
Modern Slavery Act 2015
Counter-Terrorism and Security Act 2015

2. Purpose

2.1 This policy aligns with Scottish safeguarding law, national guidance and local authority Adult Support and Protection and Child Protection procedures in Scotland. It sets out who is responsible and accountable for identifying, recording, escalating and reporting safeguarding concerns within this service.

2.2 Overall accountability for managing safeguarding concerns: Angela Jackson. Angela Jackson is responsible for governance, implementation and authorisation of this policy, including ensuring that FREEFRAME follows relevant Scottish statutory duties and local inter-agency procedures.

Safeguarding lead at this service: Angela Jackson

2.3 This policy sets out the key arrangements and systems that FREEFRAME has in place for safeguarding and promoting the welfare of children, young people and adults at risk in Scotland. For Adult Support and Protection purposes, an adult is a person aged 16 or over who meets the statutory three-point test.

2.4 This policy supports compliance with legal requirements relevant to the regulated activities that FREEFRAME is registered to provide.

As a mental health training provider operating in Scotland, FREEFRAME has a dual safeguarding responsibility:

To protect employees, trainers and learners during potentially triggering training sessions.
To respond appropriately where information indicates that a child, young person or adult at risk may be experiencing, or at risk of, harm.

Because mental health training can involve disclosures of distress, abuse, neglect, self-harm or immediate risk, FREEFRAME will maintain clear Scottish escalation routes, proportionate information-sharing procedures, secure incident recording and trainer guidance for live disclosures.

3. Objectives

Ensure all staff working for, or on behalf of, FREEFRAME understand their responsibilities in relation to safeguarding adults at risk, including who to escalate concerns to internally and externally when needed and appropriate.
Protect service users’ right to live in safety, free from abuse and neglect.
Maintain a clear, well-publicised zero-tolerance policy of abuse within FREEFRAME.
Identify lessons to be learned from cases where service users have experienced abuse or neglect.

4. Policy

4.1 What is safeguarding? FREEFRAME defines safeguarding as the actions taken to keep service users safe from harm and neglect.

4.2 Adult Support and Protection duties in Scotland

Under the Adult Support and Protection (Scotland) Act 2007, adult protection duties apply where a person aged 16 or over meets all three parts of the statutory test:

they are unable to safeguard their own wellbeing, property, rights or other interests;
they are at risk of harm; and
because they are affected by disability, mental disorder, illness or physical or mental infirmity, they are more vulnerable to being harmed than adults who are not so affected.

4.3 What safeguarding adults includes

Protecting adults’ right to live in safety, free from abuse and neglect.
Working together to prevent abuse or neglect, and to stop it when it occurs.
Promoting wellbeing and taking account of people’s views, wishes, feelings and beliefs.
Recognising that adults may have complex interpersonal relationships and may be ambivalent, unclear or unrealistic about their circumstances.

4.4 Promoting wellbeing

FREEFRAME will always promote service users’ wellbeing through its safeguarding arrangements. Staff will work with service users to establish what “being safe” means to them and how this can best be achieved and will avoid advocating “safety” measures that do not take account of individual wellbeing.

4.5 What constitutes abuse?

FREEFRAME recognises that children, young people and adults at risk may be vulnerable to abuse, neglect, exploitation or harm. Abuse is a violation of an individual’s human or civil rights by another person or persons and may involve acts, omissions or patterns of behaviour that place someone at risk of harm or negatively affect their health, wellbeing, safety, dignity or rights. Harm may be physical, sexual, psychological, financial, discriminatory, neglectful, exploitative or a combination of these. The signs of abuse are not always obvious, and a person may not disclose abuse or may not recognise it.

FREEFRAME governance processes support staff to recognise and respond in line with Scottish Adult Support and Protection guidance and Scottish child protection guidance.

4.6 Everyone’s responsibility

Everyone has the right to live free from harm and abuse. FREEFRAME recognises that safeguarding is everybody’s business and aims to ensure that individuals at risk of abuse or neglect are enabled to live, work, and be supported in an environment free from abuse, harassment, violence or aggression.

5. Scottish Adult Support and Protection principles

Benefit – intervention should provide benefit to the adult that could not reasonably be provided without intervening.

Least restrictive option – any action should be the least restrictive option likely to achieve protection from harm.

Participation – adults should be supported to participate as fully as possible in decisions affecting them.

Wishes and feelings – staff should take account of the adult’s present and past wishes and feelings, where these can be ascertained.

Respect and equality – adults at risk must not be treated less favourably without justification and their abilities, background and characteristics must be considered.FREEFRAME aims to provide services appropriate to the person and does not discriminate on the basis of disability, age, gender, sexual orientation, race, religion, culture or lifestyle.

FREEFRAME will support service users to express their wishes and make decisions to the best of their ability, recognising that self-determination may involve risk.

Staff will work with service users and others involved in their care to ensure they receive support and protection, are listened to, and are treated with respect (including their property, possessions and personal information), compassion and dignity.

Collaboration – safeguarding responses should be proportionate, timely and coordinated with relevant statutory and local partners.

FREEFRAME will work collaboratively to ensure that:

the needs, rights and interests of children, young people and adults at risk are respected and upheld;
human rights are respected and upheld;
responses are proportionate, timely, professional and ethical;
decisions and actions are taken in line with relevant Scottish law, including the Adult Support and Protection (Scotland) Act 2007, Adults with Incapacity (Scotland) Act 2000 and Mental Health (Care and Treatment) (Scotland) Act 2003 where applicable; and
the person is supported to maintain choice, control, safety, health, quality of life, dignity and respect as far as this is consistent with protection from harm.

6. Person-centred safeguarding

FREEFRAME is committed to person-centred safeguarding. Where safe and appropriate, people will be engaged in timely conversations about the response to their situation, supported to express their views and wishes, and involved in decisions while recognising that urgent protective action may be necessary where there is immediate or serious risk of harm.

7. Statutory Scottish compliance and information sharing

FREEFRAME will align its safeguarding arrangements with Scotland’s legislative and operational framework, including the Adult Support and Protection (Scotland) Act 2007, the revised Code of Practice, Scottish child protection guidance, local authority procedures, Police Scotland and NHS Scotland referral pathways.

Adult threshold in Scotland: Adult Support and Protection applies to people aged 16 and over who meet the statutory three-point test for an adult at risk.

Cross-border note: Where FREEFRAME delivers services to learners based outside Scotland, the relevant local safeguarding law and referral pathway must also be considered. For learners in England, adult safeguarding thresholds and referrals may differ.

Information sharing: FREEFRAME will share relevant, proportionate information without delay where this is necessary to protect a child, young person or adult at risk from harm, or where required or permitted by law.
Confidentiality limits: Trainers and staff must never promise absolute confidentiality. Learners must be told that information may need to be shared with the Designated Safeguarding Lead, Police Scotland, NHS Scotland or the relevant local authority Social Work service where there is risk of harm.
Three-point test: Trainers must be able to recognise when a person aged 16 or over may be unable to safeguard themselves, may be at risk of harm, and may be more vulnerable due to disability, mental disorder, illness or physical or mental infirmity.

8. Vetting and staff requirements (PVG Scheme)

Where a role involves regulated activity with children or protected adults in Scotland, FREEFRAME will assess whether PVG Scheme membership is required before the person starts that role.

PVG membership: Staff, trainers, contractors or volunteers carrying out regulated roles with children, protected adults or both must have the appropriate PVG Scheme membership before undertaking that role.
Regulated roles assessment: FREEFRAME will assess each role against the Scottish regulated roles framework, including whether contact is direct, remote, supervised or unsupervised and whether the activity forms a necessary part of the role.
Ongoing suitability: FREEFRAME will keep safeguarding suitability under review through safer recruitment, references, training, supervision, incident learning and prompt action if concerns arise.
Training standard: Staff and trainers will complete role-appropriate Scottish Adult Support and Protection and Child Protection learning, with refreshers at least every three years or sooner where law, guidance, local procedures or role requirements change.

9. Learner safeguarding and trigger protocols

Due to the intense nature of mental health, suicide prevention, and trauma training, our delivery model has inbuilt psychological safety buffers[1]

Live Disclosure Procedure: FREEFRAME will maintain a written procedure for responding to disclosures made during training. If a learner discloses an active crisis, self-harm, abuse or immediate risk, the trainer will be equipped to know how to respond safely and without delay.
Immediate response: FREEFRAME will pause the session if needed, move the conversation to a private space where possible, and avoid leaving the learner unsupported. During sessions that are likely to require extra support, we will have 2 trainers at all times with the safeguarding lead immediately available either in person or through telephone contact.
Escalation: contact FREEFRAME’s designated safeguarding lead or safeguarding officer immediately. This is Angela Jackson who will be available for immediate contact during all training sessions. As a qualified mental health nurse with significant safeguarding experience, the trainer will be offered immediate support during and post incident.
Emergency action: FREEFRAME will contact emergency services if there is an immediate risk to life, serious harm or urgent medical need.
Recording: FREEFRAME will document the disclosure, actions taken and any referrals made in line with FREEFRAME’s safeguarding recording procedure.

Recording procedure can be found here: https://freeframe.uk/recording-guidance-for-adult-and-child-safeguarding-freeframe/

Pre-Course Screening & Wellbeing Officers: Course registration will explicitly state that topics may be challenging, giving clear avenues for learners to opt out or request support. For intense courses (e.g., ASIST), FREEFRAME will have a designated wellbeing monitor or secondary worker available as best practice.

8. Essential corporate documentation required

To operate compliantly and secure contracts with Scottish local authorities, the NHS, or the third sector, FREEFRAME will maintain:

A Safer Recruitment Policy: Defining vetting criteria, PVG checks for contractors, and professional reference checks.

SAFER RECRUITMENT POLICY FREEFRAME JULY 2026

A Whistleblowing Policy: Allowing staff or learners to safely report unsafe or unethical training practices.

Whistleblowing policy FREEFRAME

10. Scottish-compliant learner terms and conditions clause

Purpose and use of this clause: This wording will be added to learner registration forms, booking terms and course agreements. It explains FREEFRAME’s safeguarding responsibilities, supports transparent information sharing, and makes clear that relevant concerns may need to be reported under Scottish law.

Safeguarding, Wellbeing, and Statutory Disclosure Policy (Scotland)

1. Participant Wellbeing & Psychological Safety:

Our mental health training courses explore sensitive topics—including suicide, self-harm, trauma, and psychological distress—which may act as emotional triggers. By registering, you acknowledge the nature of this content. We provide a supportive learning environment, and participants are encouraged to step away or notify the course facilitator if they require immediate support.

2. Confidentiality & Legal Limits:

While discussions within our training sessions are treated with strict professional confidentiality, confidentiality is not absolute. FREEFRAME has a duty to act where information suggests that a child, young person or adult at risk may be experiencing harm, may be at risk of harm, or may require urgent support.

If a participant makes a live disclosure, or if a facilitator has reasonable grounds to believe that a participant or another identifiable person is at immediate risk, is a child at risk, or may be an adult at risk under Scottish law, the facilitator must escalate the concern and may need to share relevant information without consent.

3. Information Sharing:
Where necessary and proportionate, FREEFRAME may share relevant personal and disclosure information with statutory bodies, including Police Scotland, NHS Scotland, emergency services or the relevant local authority Social Work department. Information will be recorded securely and handled in line with UK GDPR, the Data Protection Act 2018, vital interests, safeguarding obligations and any applicable legal duties.

11. Trainer escalation pathway: live disclosure protocol

Quick-reference pathway for trainers
This pathway should be issued to trainers for use during live training sessions, whether delivered online or in person. It explains what to do when a learner discloses immediate danger, self-harm, abuse or another safeguarding concern.

Identify the risk. Listen for any disclosure or behaviour indicating immediate danger, self-harm, abuse, neglect or another safeguarding concern.
Contain the situation safely. If needed, pause the session, ask a co-facilitator to support the group, or move the learner to a private space or breakout room. Do not leave the learner unsupported if there is an immediate risk.
Use calm, supportive wording. For example: “Thank you for sharing that. I want to make sure you are supported. Let’s talk privately.”
Check whether emergency action is needed. If there is immediate danger to life, serious harm or urgent medical need, call 999, request Police Scotland or ambulance support as appropriate, and stay with the person until help arrives where it is safe to do so.
Apply Scotland’s Adult Support and Protection threshold where relevant. If the person is aged 16 or over, consider whether they may be unable to safeguard themselves, may be at risk of harm, and may be more vulnerable because of disability, mental disorder, illness or physical or mental infirmity.
Escalate internally. Contact FREEFRAME’s Designated Safeguarding Lead immediately. Do not promise absolute secrecy or delay escalation while trying to resolve the concern alone.
Refer externally where required. The Designated Safeguarding Lead, or the trainer if the Designated Safeguarding Lead is unavailable and the risk cannot wait, must contact the relevant local authority Social Work department, Police Scotland, NHS Scotland or emergency services as appropriate.
Record securely within 24 hours. Complete the internal Safeguarding Incident Log, recording facts, exact words used where possible, dates, times, decisions, actions taken and agencies contacted. Store the record securely.