SAFEGUARDING POLICY
Introduction
The Charity’s objects are to advance knowledge and improve
skills in financial capacities and capabilities, in particular but
not exclusively through the provision of grants and promotion of
research and dissemination of such research.
The
Charity will work in partnership with organisations and charities
that fulfil its charitable objectives. The Charity itself will not
have direct regular contact with children or vulnerable people,
therefore, when identifying potential partners the Charity will
check their safeguarding policies, records and practice.
Safeguarding is defined as the range of measures in place to
protect people in the Charity or those it comes into contact with
from abuse or maltreatment of any kind.
- The Charity is committed to ensuring that it provides a safe
and trusted environment which safeguards and promotes the
welfare and wellbeing of anyone who comes into contact with
the Charity, including its consultants, employees, Trustees
and other volunteers, partners, donors and beneficiaries, and
other stakeholders.
- The Trustees recognise that they are ultimately responsible
for ensuring that those benefiting from, or working with, the
Charity, are not harmed through contact with it and are
treated in a safe, respectful, and appropriate manner. This
responsibility relates in particular to young people (i.e.
those under 18 years of age) and vulnerable persons including
the elderly and adults at risk.
Scope
- This safeguarding policy (the Policy) applies
to all consultants, employees, Trustees and other volunteers,
as well as any other person associated with the Charity.
- This Policy aims to deter, minimise and remove opportunities
for the abuse of those who come into contact with the Charity
and its work, in particular children, young people and adults
at risk; and provide consultants, employees, Trustees and
other volunteers with the overarching principles that guide
the Charity’s approach to safeguarding.
- The Chairperson of the Charity, and the *Designated
Safeguarding Lead (DSL) Trustee are required to undergo a
Disclosure and Barring Service (DBS check).
- The Charity has an administrative services level agreement
(SLA) in place with the Chartered Institute for Securities &
Investment (CISI).
Other policies
- This Policy should be read in conjunction with any other
applicable operational policies, which may be adopted by the
Charity from time to time.
- The Charity’s policies are located on the CISI’s local
network.
Summary of Key Safeguarding Responsibilities
- The Charity acknowledges the importance of the Charity
Commission’s guidance on safeguarding and the following
safeguarding requirements:
- providing a safe and trusted environment which safeguards
consultants, employees, Trustees and other volunteers and
any other person associated with the Charity,
- setting an organisational culture that prioritises
safeguarding, so that it is safe for those affected to
come forward and report incidents and concerns with the
assurance they will be handled sensitively and properly;
- having adequate safeguarding policies, procedures and
measures to protect people; and
- providing clarity as to how incidents and allegations will
be handled should they arise, including reporting to the
relevant authorities, such as the Charity Commission.
- The Trustees recognise that it is their responsibility to set
the overarching principles and governance strategies that
guide the Charity’s approach to safeguarding.
Policy Statement
- Safeguarding and promoting well-being and welfare means
protecting the rights of persons to live in safety, free from
abuse and neglect.
- The Charity believes that all persons, without exception, have
the right to protection from bullying, harassment (including
sexual harassment), physical or emotional abuse and
exploitation and takes a zero-tolerance approach to these
behaviours. Discrimination, prejudice or oppressive behaviour
or language in relation to any of the following are not
acceptable: race, colour, sex, gender, language, religion,
political or other opinion, national, ethnic or social origin,
property, disability, birth or other status.
- The Charity acknowledges that safeguarding does not encompass
only the prevention of physical abuse but also the protection
of people from harm generally, including neglect, emotional
abuse, exploitation and the consequences of the misuse of
personal data.
Partner Organisations
- As part of its due diligence in relation to potential partner
organisations with which the Charity may fund or partner, the
Charity will seek confirmation that such organisations have in
place adequate safeguarding arrangements, including
appropriate policies and mechanisms to provide assurance on
compliance.
- All partners working with the Charity are required to comply
with this Policy.
- The Charity is committed to supporting Grantees in
safeguarding issues but may refuse / withdraw funding in the
most serious cases of failure of safeguarding.
Procedures
- The Trustees will ensure there are adequate Safeguarding,
Confidentiality and Speak Up and Listen Up policies and
procedures in place for the Charity and its work and will
review these, along with their application, regularly.
- If a consultant, employee, Trustee or other volunteers have or
are made aware of a safeguarding concern, this should be
raised with the Chairperson of the Charity, or the DSL, who
will follow the Charity’s reporting procedure to make a formal
record and obtain advice on the action required.
- The Charity’s **Manager is delegated responsibility for the
day to day implementation of this policy, together with the
DSL who will review the policy and report to the Board of
Trustees annually.
- Where applicable, in relation to the Charity’s grant making
activities, the Charity will:
- include in its standard grant Terms and Conditions a
requirement to confirm that the grant recipient have in
place adequate safeguarding arrangements, including
appropriate policies and mechanisms to provide assurance
on compliance; and
- establish and enforce clear lines of responsibility and
reporting between the grant recipient and the Charity.
Serious Incident Reporting
- The Charity will respond to all suspicions, allegations and
safeguarding incidents swiftly and appropriately and take
professional advice where appropriate. This may include
reporting to the appropriate entities, including police
forces, any relevant national authorities and the Charity
Commission for England and Wales (Charity Commission).
- The Trustees acknowledge the Charity Commission’s guidance on
how to report a serious incident and in the safeguarding
context, their duty to make a serious incident report to the
Charity Commission in the event:
- of an incident where someone has been, or has alleged to
have been, abused or mistreated and this is connected with
the Charity’s activities;
- a beneficiary(ies) has been, or is alleged to have been,
abused or mistreated while under the Charity’s
supervision, or by someone connected with the Charity, for
example, a Trustee; and/or
- the Charity’s procedures or policies relating to
safeguarding matters have been breached and this has
placed beneficiaries at risk.
Implementation of Policy
- This Policy will be provided to all consultants, employees,
Trustees and other volunteers as part of their induction and
they will be required to confirm by email that they have read
and understood the policy. Training will be provided annually
on this Policy to Trustees.
- Failure to comply with this Policy will be considered as gross
misconduct and potentially grounds for removal.
Monitoring and Review
- This Policy will be reviewed at least annually by the Trustees
or more frequently should circumstances dictate or when
relevant legislation changes.
*Designated Safeguarding Lead: Responsible for the implementation
of the Safeguarding and Speak Up & Listen Up policies and
reviewing the policies on an annual basis
**Manager: Responsible for administration matters concerning
routine meetings, Board papers for discussion, expenses and
travel, authorising Level 2 to commit to spend payments, and any
ad hoc tasks bestowed by the Board.
Last reviewed by the Board: 22/04/2024
SPEAK UP & LISTEN UP POLICY
Introduction
The Speak Up & Listen Up Policy (the
Policy) sets out the framework for dealing with
concerns of illegal and improper conduct.
The Charity is committed to the highest standards of transparency,
probity, integrity and accountability.
This Policy is intended to provide a means of raising concerns
about standards, conduct, financial irregularity or possible
unlawful action, in a way that will ensure confidentiality and
protect those raising such concerns in the reasonable belief that
it is in the public interest to do so from being victimised,
discriminated against or disadvantaged.
This Policy is intended to ensure that the Charity complies with
its duty under the Public Interest Disclosure Act 1998.
Scope
This policy applies to the Trustees as well as any other
person associated with the Charity.
This Policy
applies to, but is not limited to, concerns about any of the
following:
- Conduct which is an offence or breach of the law
- Alleged miscarriage of justice
- Serious Health and Safety risks
- The unauthorised use of public funds
- Possible fraud and corruption
- Sexual, physical or verbal abuse, or bullying, or harassment,
or intimidation of employees, or customers or service users
- Abuse of authority
- Other unethical conduct
This Policy should be read in conjunction with any other
applicable operational policies, which may be adopted by the
Charity from time to time.
The Charity’s policies are
located on the Chartered Institute for Securities & Investment
(‘CISI’) local network.
Reporting
Contact Details for Reporting (in writing):
Nick
Swales (Chairperson) or Debbie Clarke (*Designated Safeguarding
Lead)
CISI Future Foundation
20 Fenchurch Street
London
EC3M 3BY
The Charity recognises
that the decision to raise a concern can be difficult. However,
those who speak up in the reasonable belief that it is in the
public interest to do without fear of victimisation or
discrimination because they are doing their duty either to the
Charity and/or to those for whom the Charity are providing a
service for.
The Charity will take appropriate action
to protect anyone who speaks up in the reasonable belief that it
is in the public interest to do so from any reprisals, harassment
or victimisation.
Confidentiality
All concerns will be treated in confidence and every effort
will be made not to reveal the identity of the individual who
raised the concern unless the individual requests otherwise.
However, this may not always be possible if the matter is
subsequently dealt with through other Charity policies.
Similarly, if the concern results in court
proceedings, then the individual may have to give evidence in open
court if the case is to be successful.
The Charity
will not, without the individual’s consent, disclose the identity
of said individual to anyone other than a person involved in the
investigation/concern.
Anonymous Concerns
This Policy encourages those who speak up to put their name
to a concern wherever possible as anonymous concerns may often be
difficult to substantiate/prove. Concerns made anonymously are
much less powerful but anonymous concerns will be considered at
the discretion of the Charity Chairperson / Board of Trustees.
In exercising discretion to accept an anonymous
concern the factors to be taken into account:
- The seriousness of the issue raised
- The credibility of the concern; and
- Whether the concern can realistically be investigated from
factors or sources other than the complainant
Untrue Concerns
No action will be taken against an individual who speaks up
and raises a concern in the reasonable belief that it is in the
public interest to do so even if the concern is not substantiated
by an investigation. However, action may be taken against an
individual who speaks up and raises a concern without reasonable
belief that it is in the public interest to do so (e.g. raising a
concern frivolously, maliciously or for personal gain where there
is no element of public interest).
Procedure for Raising a Concern
It is preferable for concerns to be made to the Charity
Chairperson. However, this may depend on the seriousness and
sensitivity of the issues involved and who is suspected of the
malpractice. For example, if the individual who speaks up believes
that the Chairperson is involved it would be inappropriate to
raise it directly with them. The individual may then raise the
concern directly with the Designated Safeguarding Lead (DSL).
If either of the above are notified of a concern, they
will consider the concern and may discuss it with the other
Trustees. The Chairperson (or either/or both) of the above, after
consideration, will discuss the concern with the individual who
spoke up to determine if they wish to proceed with the concern and
an investigation.
Concerns
Whether a written or oral report is made it is important
that relevant information is provided including:
- The name of the person raising the concern and a contact point
(if not anonymous).
- The background and history of the concern (giving relevant
dates and names and positions of those who may be in a
position to have contributed to the concern);
- The specific reason for the concern. Although someone raising
a concern will not be expected to prove the truth of any
concerns, they will need to provide information to the person
they have reported to, to establish that there are reasonable
grounds for the concern.
Someone raising a concern may be accompanied by another person of
their choosing during any meetings or interviews in connection
with the concern. However, if the matter is subsequently dealt
with through another policy, the right to be accompanied will at
that stage be in accordance with the relevant policy.
Action on receipt of a concern
The Chairperson and/or the DSL will record details of the
concern, gathering as much information as possible, (within 5
working days of receipt of the concern) including:
- The record of the concern:
- The acknowledgement of the concern;
- Any documents supplied by the individual speaking up
The Chairperson and/or the DSL will ask the individual speaking up
for their preferred means of communication and contact details and
use these for all communications with the individual in order to
preserve confidentiality.
If the concern relates to
fraud, potential fraud or other financial irregularity the
Chairperson and/or the DSL will be informed within 5 working days
of receipt of the concern. The Chairperson and/or the DSL will
determine whether the concern should be investigated and the
method of investigation.
If the concern discloses
evidence of a suspected criminal offence, it will immediately be
reported to the Board of Trustees and a decision will be made as
to whether to inform the Police. If the concern involves suspected
harm to children and/or vulnerable adults, the Safeguarding Policy
should be referred to.
Timetable
An acknowledgement of the concern in writing within 10
working days with:
- An indication of how the Charity propose to deal with the
matter
- An estimate of how long it will take to provide a final
response
- An indication of whether any initial enquiries have been made
- Information on support mechanisms for the individual speaking
up
- Indication whether further investigations will take place and
if not, why not
The Chairperson and/or the DSL will aim to keep the individual
speaking up informed of the progress of the investigation and its
likely timescale. However, sometimes the need for confidentiality
may prevent them giving specific details of the investigation or
any action taken as a result.
Where the concern has
been made anonymously the Charity will be unable to communicate
what action has been taken.
Support
The Charity will take steps to minimise any difficulties
which may be experienced as a result of raising a concern. For
instance, if the individual speaking up is required to give
evidence in criminal or disciplinary proceedings the Charity will
arrange for them to receive advice about the procedure and advise
on the support mechanisms that are available.
The
Charity accepts that those speaking up need to be assured that the
matter has been properly addressed. Thus, subject to legal and/or
confidentiality constraints, we will inform those raising concerns
of the outcome of any investigation.
Responsibility for the Policy
The **Manager and the DSL have overall responsibility for
the operation of this Policy and for determining the
administrative processes to be followed and the format of the
records to be kept.
Monitoring
A Register will record the following details:
- The name and status (e.g. supplier) of the individual speaking
up
- The date on which the concern was received
- The nature of the concern
- Details of the person who received the concern
- Whether the concern is to be investigated and, if yes, by whom
- The outcome of the investigation
- Any other relevant details
The Register will be confidential and only available for
inspection by the Board of Trustees.
The Manager will
report annually to the Board of Trustees on the operation of the
Policy and on any concerns raised during the period covered by the
report. The report will be in a form which does not identify those
speaking up.
*Designated Safeguarding Lead: Responsible for the implementation
of the Safeguarding and Speak Up & Listen Up policies and
reviewing the policies on an annual basis
**Manager: Responsible for administration matters concerning
routine meetings, Board papers for discussion, expenses and
travel, authorising Level 2 to commit to spend payments, and any
ad hoc tasks bestowed by the Board.
Last reviewed by the Board: 22/04/2024
PRIVACY NOTICE
Who we are
The Charity is registered in England and Wales (number
1201304) and is a company limited by guarantee and registered in
England and Wales (number 13918024).
The Charity’s
objectives are:
The advancement of education for the public benefit by advancing
knowledge and improving skills in financial capacities and
capabilities, in particular but not exclusively through the
provision of grants and promotion of research and dissemination of
such research.
The Charity is also affiliated with the
Chartered Institute for Securities & Investment (‘CISI’),
headquartered at 20 Fenchurch Street, London, EC3M 3BY.
CISI is the leading professional body for securities,
investment, wealth and financial planning professionals. Formed in
1992 by London Stock Exchange practitioners, it has a global
community in over 100 countries. Each year more than 40,000 CISI
exams are sat in 80 countries, 15,000 outside the UK.
Your data privacy
The Charity is a data controller and committed to protecting
the rights of individuals in line with data protection
legislation.
This Privacy Notice was created in view
of the requirements of the UK General Data Protection Regulation
(‘UK GDPR’) and all other relevant privacy legislation. We may
change this policy from time to time to reflect changes in the law
or in the provision of our services.
The Charity has
an appointed *Data Protection Representative who can be contacted
by email via
futurefoundation@cisi.org.
What information we may collect about you
We process a limited amount of personal information which is
outlined below.
| Type | Description |
|---|
| Personal and Contact | Name, date of birth, gender, your address, and contact
details for your Directors and/or Trustees and/or senior
management
|
| Identification | Copies of photographic legal identification documents for
your Directors and/or Trustees and/or senior management to
support grant applications.
|
| Socio-Economic | Details of any financial interest held by your Directors
and/or Trustees and/or senior management that may present
a Conflict of Interest with your grant application.
|
| National Identifier | A reference given to your Directors and/or Trustees and/or
senior management by a regulated body to identify who you
are, such as a Charity number.
|
Why we collect personal information
In order to fulfill our legal and regulatory obligations,
and for us to conduct appropriate due diligence for recipients of
our grants, we require you to provide personal information to
allow us to:
- Verify the identities of your Directors and/or Trustees and/or
senior management;
- Identify and query any Conflicts of Interest there may be in
your grant application;
- Provide updates relating to your grant applications;
- Provide granted funds upon the success of an application.
Failure to provide required information may mean that we cannot
appropriately scrutinise your grant application and may result in
your application being rejected.
Where we collect personal information from
We may collect information about you from these sources:
Data you give to us:
- When you make contact with us by email;
- When you talk to us on the phone
- When you complete a grant application form;
- In surveys.
Data that is publicly available:
- Data relating to your entity that is available on Companies
House or the Register of Charities;
- Information that is available through your entity’s website;
- Information that is made available through social media;
- Information that has been published in physical or digital
media.
How we use your personal information
We may use personal information to:
- To validate your registered entity;
- To evaluate your registered entity in the interest of due
diligence;
- To validate the information provided by you about your
registered entity;
- To validate the information provided by you about your
registered entity’s Directors and/or Trustees and/or senior
management;
- To contact you to query, progress, and deliver a decision upon
your grant application.
Our legal bases for using your personal information
- Where it is in our legitimate interests to do so;
- To comply with our legal obligations;
- With your consent.
Who we share your personal information with
- CISI, acting as a data processor, in order to process grant
applications and respond to any queries that you may raise;
- Companies you ask us to share your data with;
- Any relevant Regulator, where there is a lawful basis to do
so.
International data transfers
The Charity operates internationally, therefore we may
transfer information to countries outside the United Kingdom for
the purposes described in this policy where necessary, relevant
and proportionate.
Where we are required to do so in
order to fulfil our objectives, we will ensure that such transfers
are conducted in a lawful and transparent manner and that such
transfers are essential for provision of our services and
fulfilment of our objectives.
Marketing
We may, with your consent, publish case studies with limited
personal data of your Directors and/or Trustees and/or senior
management on our website and/or the CISI’s website and social
media presence in describing the awarding of grants to your firm.
In addition to UK data privacy laws, marketing
communications are additionally subject to the Privacy and
Electronic Communications Regulations (PECR).
How long we keep your personal information
We will keep your personal information for the duration of
the application process and thereafter. Following the outcome of
your grant application, we may keep your data for one of these
reasons:
- To respond to any questions or complaints;
- To maintain records according to rules and regulations that
apply to us.
We may keep your data if we cannot delete it for legal or
regulatory reasons, and we may also keep it for statistical
purposes. If we do, we will make sure that your privacy is
protected and your data is only used for those purposes.
Information security
All systems and services upon which personal data is stored
are owned and operated by CISI, and subject to strict access
controls.
We have ensured that there are appropriate
technical and organisational measures to safeguard the personal
information we collect in connection with our services.
Your rights under data protection laws
As a data subject you have certain rights under data
protection laws:
- The right to be informed
- The right to request access to your personal information
- The right to have your personal information corrected
- The right to object to certain processing of your personal
information
- The right to restrict processing of your personal information
- The right to have your personal information erased
- The right to move, copy or transfer your personal information
- Rights in relation to automated decision-making.
Please note that under certain circumstances, your right to have your personal information erased may be limited.
We ask that you keep us informed if your personal information changes during your relationship with us.
How to get a copy of your personal information
You can access the personal information we hold on you by
emailing
futurefoundation@cisi.org
or by writing to us at this address:
Data Protection
Representative
CISI Future Foundation
20 Fenchurch
Street
London
EC3M 3BY
If you have any queries about the Charity and Data Protection, please feel free to contact the Data Protection Representative.
You also have the right to contact the Information Commissioner’s Office (see ico.co.uk).
*Data Protection Representative: Responsible as the point of contact for internal and external queries relating to data protection and for facilitating any and all necessary compliance with data protection legislation.
Last reviewed by the Board: 22/04/2024