Introduction and Background

The Scottish Association of Change Ringers (SACR) is the representative body for bell ringers in Scotland. Membership is voluntary and open to any person, resident in Scotland, who can demonstrate a minimum competence in bell ringing or who has an interest in bell ringing, as specified in the Association’s constitution.

SACR is affiliated to the Central Council of Church Bell Ringers, which offers guidance on Protecting Vulnerable Groups (PVG) and safeguarding issues to all member organizations.

SACR represents all towers with change ringing bells, and all ringers who regularly practice change ringing in Scotland. Towers with change ringing bells belong to several different religious denominations and some non-religious entities all of which have their own safeguarding guidelines and policies. 

SACR usually sponsors six ringing events or meetings per year, and on most years runs a training course for a weekend. It runs a regular ringing practice. These are the regular activities of the Association that would be governed by this Policy. Other additional events organised by the Association that may occur from time to time would also be governed by this Policy. An Association event is characterised as being open to all members without restriction, and which is widely advertised as an Association event on the Association website at www.sacr.org. This Policy describes the procedures in the context of Association events.

Of these events, only the training weekend involves direct training or coaching of ringers. This includes course tutors, who lead group instruction in particular topics, and helpers, who are extra ringers to make up bands for practicing the subject of each tutorial session. Helpers, in this context, are not directly involved in education or training in a supervisory context. The training weekend may be hosted by different towers in the association. The type of sessions may include: group tutorial sessions, where a subject is taught and practiced by a group of students, led by a course tutor and with helpers offering practical ringing support; lectures; and one-to-one tutorials which teach basic skills or use a computerized simulator. The content of events in a training weekend varies from year to year and depends on the requirements of the students who plan to attend. Course tutors, lecturers and other direct trainers are drawn from the general membership of the Association, depending on what skills are required to be taught. This means that the role of ‘tutor’ or ‘education leader’ is not a role associated with only one person but is assigned occasionally to volunteers as the situation requires.

Other ringing activities that occur in Scotland are regular practices and service ringing in towers with change ringing bells, which are organised locally by the band of ringers at that tower, and casual ringing organised by individuals on an ad hoc basis. Ringing that is organized locally at towers is subject to the Safeguarding Procedures at that tower and is not governed by this policy. Casual ringing organized by individuals is also not governed by this Policy. However, this Policy does not knowingly conflict with any existing local Safeguarding Policy and will also stand as a ‘good practice’ guide for local bands of ringers seeking to establish their own Policies. 

There are approximately 200 members of the Association, including people of all ages. Attendance at Association events is usually 40-60 members. Children or vulnerable adults do not constitute a significant proportion of the membership and are not always in attendance at every meeting of the Association.

This Policy is designed to ensure that young people and vulnerable adults can be fully and safely involved with ringing activities. It reflects the need to cherish and defend the exceptional features of ringing, being an activity in which young and old meet and take part on an equal footing. This enriches those of all ages who know and respect each other, not only for their abilities as ringers but also as individuals. To protect children, protected adults, and adults who work with them it is necessary to create an open environment where neither the possibility of abuse nor a false allegation can occur. Abuse can be emotional, verbal, physical or sexual.

Disclosure Scotland

The Disclosure (Scotland) Act 2020 introduced ‘regulated roles’ to define if PVG scheme membership is required. A regulated role is where an individual is carrying out an ‘activity’ and has ‘contact’ with children (17 and under) or protected adults as a necessary part of their role, e.g. delivering training. A regulated role will also be where someone is making decisions of an operational or strategic nature that could have an impact on a number of children or protected adults such as committee members/trustees of the organisation. However, this is dependent on the governance and decision-making arrangements within each organization, e.g. a role which just involves raising money would not be considered a regulated role.

The activity must be a necessary part of the individual’s role. This can sometimes also be referred to as someone’s ‘normal duties’. For example, an activity can be something that the individual:

• is expected to do as a necessary part of their role on an ongoing basis (for example, it’s listed in their role description)
• can reasonably anticipate as being part of their role
• does not do on an ad hoc basis
• is designated to do as part of a pool of other people who are specifically available to assist

 Where an individual carries out a regulated role for a short duration but on an annual basis, it is still classed as their normal duties, as it is a necessary part of their role on an ongoing basis, and they would need a PVG check. This is also the case even if the parent of the child is present or other people. People helping the trainer on a regular basis would also need a PVG check.

If the volunteer is carrying out a ‘regulated role’, the PVG scheme requires that: 

• they must be a member of the PVG scheme for the group they will be working with (children and/or protected adults)
• the organisation the work is associated with must have received a PVG scheme disclosure for the volunteer (or employee), even if that individual is a PVG scheme member for children or protected adults for another organisation, for example employed or volunteering elsewhere as a teacher or scout leader. English DBS is not accepted.
• a PVG check must be renewed every 5 years.

However, PVG checks are only necessary if events are specifically targeted at children (or protected adults) and these are at least annual. If the event is

• part of a service that is intended to be open to all, as indicated by the location of an event, where it’s advertised and what the admission policy is
• attractive to a wide cross section of society
• not an activity involving contact with children or protected adults but either group are in the general vicinity when the individual is carrying out their role

then the activity involves incidental contact only. If contact is incidental, carrying out the activity for the child or protected adult will not amount to a regulated role and does not need PVG check. Deciding whether contact is ‘incidental’ is important in ensuring that membership of the PVG scheme is appropriately targeted and is proportionate. It is illegal to PVG check when it is not necessary as this would infringe GDPR (requesting/accessing personal information that is not needed). This means “just in case” checking of individuals is not acceptable.

To decide whether PVG regulation is required or whether contact is incidental only, consider who the service is intended for, whether that be the general population or, more specifically, for children and/or protected adults.

For example, a sports event is advertised on a website for the general public and may or may not appeal to some participants who are children or protected adults. Regardless of the level of actual participation of children and protected adults, the instructing of these groups in this situation is an incidental activity as the service is not particularly intended for children or protected adults. The trainer is not carrying out a regulated role so doesn’t need a PVG check.

If the sports event is targeted at, or more attractive to, children or protected adults, those carrying out activities as part of the event are carrying out a regulated role and should have a PVG check.

So, if you have a tower Open Day for anyone to attend and children as well as adults come along and have a go at ringing backstrokes, the organiser and helpers do not need PVG checks.

If, however, you decide to set up an event especially for children, such as learning to ring as part of the Duke of Edinburgh Award, and offer to teach these youngsters in a group, then the organiser and any helpers would need to have PVG checks in advance. Because this would be a role linked to the church, rather than SACR, it is the church safeguarding team that should organise and keep a record of the PVG check. Any other PVG check that a helper might have held for another organisation would not be valid.

The main points to note are:

1. If a tower event e.g. ‘Come and Learn to Ring’ is advertised to all and youngsters just happen to be some of those who come along and learn with the band (incidental) then you don’t need to be PVG checked and registered. 
2. If sessions are set up specifically for those 17 and under, then whoever is in charge and the helpers will need PVG registration at the start (even if parents attend).
3. Any PVG registration needed has to be linked to the organisation you are doing the training for and the role. For ringing events, the organisation will usually be your church or tower. A previous check may not count and you will need more than one if you work with more than one organisation. This applies to those with ART qualifications as the English DBS is no longer accepted. The local church will be able to organise a PVG check for you and may require those involved to undergo safeguarding training.
4. SACR does not itself currently organise events specifically for children, therefore its officers do not need PVG checks, and it is not allowed to apply for registration in the PVG scheme. A PVG check is not required by anyone acting as a trainer or organiser for SACR events - indeed, we must not do a PVG check.
5. If SACR in the future decided for example to change the format of training days with specific events aimed at children, or perhaps train a youth band for a competition, then this would change. 

Regardless of the legal position, SACR will still have as a priority the safeguarding of everyone at its events. Our PVG Policy is detailed below. It is important that the PVG scheme is used to support robust safeguarding policies and does not replace them.  

Policy

A. Definition and duties of the Protection of Vulnerable Groups Officer (PVG Officer)

1. Enforcement of this Policy is the role of the Association PVG Officer.
2. The Association PVG Officer is not an elected officer but is appointed by the President and ratified by any meeting of the Association. The PVG Officer reports directly and confidentially to the President of the Association. This appointment is reviewed annually.
3. The Association PVG Officer will advise on this Policy and ensure that it is kept up to date with current legislation.
4. The Association PVG Officer shall be able to demonstrate suitable and current protection of vulnerable groups awareness training. Where necessary and appropriate, the Association shall reimburse the costs of this training.  

B. Safeguarding at Association Events

5. Children or vulnerable adults present at an Association event should be accompanied by a parent or carer. The parent or carer has the primary duty of care and must act in a supervisory capacity throughout the event, including transport to and from the event. This is particularly important for attendance at a training weekend. The responsibilities of the Ringing Master and other Association officers preclude them from being able to adequately ensure the safety of any single ringer at all times.
6. In the absence of a parent or carer, another adult, preferably from the child’s or vulnerable adult’s local tower, may be nominated to supervise and assume the duty of care for the duration of the event, including travel to and from the event. The nominated person must be approved by the parent or carer in writing and the PVG Officer must be notified in advance. The nominated person must be able to produce this written consent at the event.
7. The PVG Officer may require the attendance of a parent or carer and not allow any other supervisor. This is to be judged on a case-by-case basis, as circumstance might dictate.

C. Privacy and protection of identity online

8. All members of the Association should act to protect the personal data of children and vulnerable adults above the requirements of the Data Protection Act (2018).
9. The Association will seek to avoid publishing photographs of children or vulnerable adults on the Association website or on social media.
10. If it is deemed desirable to publish a photograph, for example to promote a particular achievement, prior consent to publish must be obtained in writing or by email as appropriate.
11. Where photographs of children or vulnerable adults are published, the publication of full names in the caption should be avoided.
12. The publishing of full names, ages, and local tower affiliation together should always be avoided.
13. Contact details for children or vulnerable adults should never be published or supplied. The Association does not keep address records for its members.

D. Complaints

14. In the case of a complaint or incident, the PVG Officer should be informed as soon as possible. In the absence of the PVG Officer, a report may be made in confidence to the President of the Association.