Introduction

West Country Surf School Ltd (Westcountry Surf / School) is a supplier of surfing activities available on website surfingschool.co.uk operating at locations, Top Field Car Park, Watergate Bay, Newquay, TR8 4AA and Layback Coffee & Surf Shop, 28A Crantock Street, Newquay TR7 1JR. 

Westcountry Surf acknowledges their legal responsibility to ensure operating practices are delivered to support the welfare of young people and vulnerable adults that is paramount when in our care.

As part of this process, Westcountry Surf shall commit to work together with our partners on the beach, the local community and if necessary statutory authorities.

Westcountry Surf shall appoint a qualified and experienced surf instructor (instructor) to be the teacher for a surf lesson. These lesson types can be either with just one student or a group of students.

The students can be a mixture of 18 year olds and over (adults) and young persons (under 18 years old) of which some could be vulnerable persons.

References to words importing the plural shall include the singular, and vice versa.

Responsibility and Ownership

Her Majesty’s Government states, ‘safeguarding is everyone’s responsibility’ and this policy places an expectation upon all employees and volunteers of our School to understand their individual responsibility, and respond to safeguarding concerns or allegations, ensuring any response is appropriate and proportionate to the circumstances (See below a list of the legislation and Government guidance that Westcountry Surf follows).

Overall ownership for the implementation of the policy remains with the Safeguarding Lead who will appoint suitable deputies when required.

The Safeguarding Lead is: Joel Bishop, on email address: westcountrysurfschool@gmail.com

The UK Safeguarding Lead will:
- Manage, coordinate, record and investigate all safeguarding concerns;
- Develop and maintain safeguarding policies and procedures;
- Coordinate with outside agencies where necessary; and
- Review company policy on an annual basis

Identified Risks / How We Manage Them

In November 2020 an independent review of our working practices and operating sites identified the following safeguarding risks to the School during the delivery of surf lessons, hiring of equipment and engagement with young people from our local community.

Changing
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The risks are:
- Surf instructors helping students change into wetsuits presents a risk of inappropriate touching or misinterpretation; and
- Students changing into swimwear or wetsuits in a public open site environment presents a risk of voyeurism.

Managing the risk:
- Instructors continue with the established practice of encouraging students to arrive at the School already changed into their swimwear; and
- If a student needs assistance, parents or guardians are encouraged to help their child. Instructors will only assist students in public view preferably in the presence of a parent or guardian.

Photography
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We do not discourage the taking of photographs; capturing the achievements of young and vulnerable persons is important to share success with family and friends improving self-esteem and overall confidence.

However, we do operate in an open site public space and this environment provides opportunity for others to capture images for sinister reasons.

The risks are:
- Using the image to identify for future grooming purposes;
- Adapting images for inappropriate use and sharing online; and
- A photo or image of a young or vulnerable person becomes a part of their public image. This image, especially if altered, could have an immediate or future adverse effect.

Managing the risk:
Instructors and beach lifeguards will continue their vigilance for those who seek to capture images for inappropriate purposes and carefully monitor nearby beach users with any photographic equipment.

Any such incidents will be reported to the police.

Meeting Place For Young Persons

For many years the Surf School has been used as a meeting place for young people to spend time on the beach with their friends.

Just like taking photographs we do not discourage young people gathering at the School as there are benefits, such as an introduction to a healthy activity / sport and exposure to positive role models.

Several current surf instructors use the school as a meeting place and report favourably on the influence of older peers and the opportunity for seasonal employment.

It is also important to recognise the risks:
- A young person becoming fixated on a surf instructor; and
- Young persons exposed to adult related activities; for example perceived underage employment. Young people often help with washing wetsuits and general cleaning duties for a reward of free access to a popular hire surfboard.

Managing the risk:
- Surf instructors will remain vigilant for young person's seeking to spend excessive time with staff members and advise the Safeguarding Lead;
- Young persons will be asked to leave the School if adult related activities are planned or spontaneously implemented;
- No young person under the age of 13 will be paid; and
- The provision of a free hire surfboard to enjoy will be at the discretion of the School.

Sitting Out / Leaving Lesson

Surfing can be a highly demanding sport and sometimes students can feel tired or overwhelmed. Our instructors do not discourage anyone who feels that they need to step out of the water and take a moment to sit down on the beach.

It is also important to recognise the risks:
- Students could be under 18 and, therefore, need to be under the watchful eye of an adult;
- Students who are resting on the beach and taking some time out could be approached by members of the public attracting unwanted attention;
- Students could feel lost and disorientated; and
- Students could be having a medical issue which may need urgent treatment.

Managing the risk:
The surf instructor teaching the lesson will remain vigilant on students who have decided to leave the water and sit on the beach.

The students shall be advised by the surf instructor to sit and remain on the beach in front of the lesson. From time-to-time, the surf instructor will check-in on how the students are feeling.

The surf instructor will be unable to leave the water due to the other students still in the lesson in the water, however, they have a duty of care to keep a watchful eye on those students who are sitting on the beach.

Inappropriate touching

The sea is an unpredictable natural environment. The conditions can quickly change requiring instructors to respond for the safety of students. The opportunity for an instructor to exploit changing circumstances in the water and inappropriately touching a student in a sensitive area of their body, or for an incident to be misinterpreted or used by the student to make a malicious allegation, is a risk to both parties.

Managing the risk:
In the event that a sensitive area of the body is touched an explanation however obvious will be provided to the student and the instructor will check that they are comfortable to remain in the water.

The instructor should create a record of the incident and report to the Safeguarding Lead. The Safeguarding Lead should advise the parent or guardian of the incident and provide an explanation.

If a student makes an allegation against an instructor, the receiving staff member or Safeguarding Lead will comply with the Safeguarding Guidance document.

If an instructor is concerned about the behaviour of a colleague towards a student, the Safeguarding Lead will be advised and any response shall comply with the Safeguarding Guidance document.

Safe Recruitment

The school operates in a small community. Naturally, such a community allows for recruitment, and as mentioned previously, local young people seek to commence their employment with the School. There are undeniable advantages to employing from the local community.

The School can observe the character and attitude of potential staff and instructors and a likely longer-term relationship with parents/guardians can facilitate the understanding of working expectations, practices & hours.

As the demand for services increases year-on-year, employment of freelance instructors is necessary for the busier periods.

There is no room for complacency with recruiting locally or freelance. A person seeking employment with the School as a freelance for sinister reasons will not declare this interest and any staff or instructor local or not, with convictions can be equally as secretive.

Risks:
- Unknowingly employing a freelance instructor with an intention or offending pattern indicating they are a risk to young or vulnerable persons; and
- An absence of knowledge of the behaviour or sexual preferences of local persons seeking employment.

Managing the risk:
All staff will submit annual DBS (enhanced) checks. The school shall retain copies of these DBS certificates in compliance with DPA and GDPR.

In addition, instructors will be required to produce two acceptable forms of identification - for example a driving licence and/or passport, utility bill and/or council tax bill. The School shall also retain copies of these identity documents.

The School shall undertake previous employers' checks for all new instructors.

Training For All Freelance Coaches

Westcountry Surf and full-time staff shall arrange suitable training to improve the understanding and awareness of wider safeguarding issues relevant to the School to freelance instructors.

Communication

Effective communication of safeguarding principles and how we manage our risks is pivotal to embedding this policy into our working practices.

Embedment makes this policy meaningful to our staff, freelancers and customers and reassuring them that the welfare and safety of our community at the School is paramount.

Embedment will be encouraged by:
- Publishing this policy on our website for openness and transparency;
- Appropriate use of social media to reinforce key messages in this policy;
- The Safeguarding Lead and deputies to remind instructors to deliver key safeguarding messages during water safety briefings;
- Safeguarding Lead and deputies to monitor compliance through dip sample of water safety briefings delivered by instructors; and
- Display a willingness to listen to staff, freelancers and customers considering the importance of non-verbal communication and seek to understand how underlying behaviour or messages may relate to a safeguarding experience or concern.

Waiver | Indemity Form

When you have a Surfing Lesson with Westcountry Surf, you have signed a waiver / indemnity form (Form), and even if you haven’t, it shall be deemed that you have signed, and not under duress.

The signing of the Form confirms that neither Westcountry Surf, nor its staff or freelancers, shall be held responsible for injury, loss, bereavement, or in the most serious cases, death, caused by unforeseen circumstances as a result of negligence by the surfers, or close proximity individuals who are also surfing, whether directly or indirectly.

Unforeseen circumstances include, but are not limited to, situations caused by sea riptides, sea creatures, sea craft, force majeure, tsunami, or such like natural disasters that can occur from time-to-time as a result that we live on an unpredictable & dangerous planet.
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Conclusion

The purpose of this policy is to identify our key safeguarding risks relevant to the working practices unique to Westcountry Surf. Every surf school and water-based activity business will have unique risks varying according to their working practices, their location and operating premises.

We recognise there are many aspects to safeguarding; implementing and embedding this policy enables us to manage our key risks. It will also increase our collective awareness to identify and respond appropriately to incidents or concerns this policy has not recorded.
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Legislation Framework

To safeguard and promote the welfare of children, Westcountry Surf shall follow all legislation and government guidance in England & Wales:
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- Children and Social Work Act 2017
- Working Together to Safeguard Children 2023
- The United Nations Convention on the Rights of the Child (UNCRC)     1989
- Safeguarding Vulnerable Groups Act 2006
- The European Convention on Human Rights 1950
- Police Act 1997
- Data Protection Act 2018
- Freedom of Information Act 2000
- Sexual Offences (Amendments) Act 2003
- Protection of Freedoms Act 2012
- Care Act 2014 - implemented March 2015
- Information Sharing Advice - March 2015
- What to do if you’re worried a child is being abused. - March 2015
- Procedures set out by the local Safeguarding Children Boards
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Please see the privacy policy for further information like our company details, and our contact details are shown on our website, surfingschool.co.uk.