Policies

Applicability

This policy applies to all trustees, volunteers, employees, contractors, and third-party representatives of Discobility. Its requirements should be reflected in other policies, procedures, agreements, and contracts, as necessary.

You Must

• Act with integrity, honesty, and respect, always.
• Ensure you are aware of and comply with Discobility’s policies and safeguarding procedures.
• Undertake any necessary training for your role, including safeguarding and inclusion awareness.
• Listen to and respect trustees, staff, volunteers, SEND adults, parents, guardians, carers, and other stakeholders.
• Promote relationships based on openness, trust, and respect.
• Treat everyone fairly and without prejudice or discrimination.
• Use inclusive, appropriate language that is never offensive or discriminatory.
• Ensure any equipment (e.g., sound systems, lighting, disco props) is used safely and for its intended purpose.
• Challenge unacceptable behaviour and report any breaches of this Code of Conduct or concerns without delay to a trustee.
• Report any allegations or suspicions of abuse, neglect, or fraud.
• Respect everyone’s right to personal privacy and ensure that any personal information is kept secure and not disclosed.
• Honour commitments made to volunteering duties; if you are unable to attend, inform Discobility as soon as possible.

You Must Not

• Allow concerns or allegations to go unreported.
• Develop inappropriate relationships with SEND adults or beneficiaries. Note: At Discobility events, SEND adults are always accompanied by a parent, guardian, or carer, and staff/volunteers must never be left alone with them.
• Share personal contact details (mobile number, email, or address) or engage with SEND adults via personal social media accounts.
• Make sarcastic, insensitive, derogatory, or sexually suggestive comments or gestures to or in front of anyone.
• Act in a way that could be perceived as threatening, intrusive, or intimidating.
• Make inappropriate promises to SEND adults or vulnerable people, particularly regarding confidentiality.

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Statutory Guidance

This Code of Conduct aligns with:

• Gov.UK – Workplace Bullying & Harassment
• Charity Commission: Serious Incident Reporting
• Charity Commission: Safeguarding and Protecting People for Charities and Trustees
• Gov.UK: Whistleblowing for Employees
• Charity Commission: Safeguarding duties of charity trustees
• Charity Commission: How to protect vulnerable groups

Disclaimer & Legal

This document is adapted for Discobility. It is intended as a guiding framework and must be reviewed regularly to ensure compliance with Charity Commission requirements and safeguarding best practice. Trustees remain responsible for ensuring the policy meets the charity’s needs and legal obligations.

Discobility is committed to providing safe, inclusive, and enjoyable disco events for adults with SEND. We value feedback and recognise that concerns may arise. This policy sets out how complaints will be handled fairly, transparently, and in line with our governance responsibilities.

1. Immediate Concerns

• If a situation arises where someone’s safety is at immediate risk, appropriate action will be taken straight away (e.g., contacting emergency services).
• Safeguarding concerns will always be escalated in line with our safeguarding policy.

2. Informal Complaints

• Anyone with a concern should raise it with a member of the Discobility team at the time of the event.
• We will seek to resolve the issue promptly and reasonably.
• If resolution is not possible, the following will be noted:
  • Complainant’s name and contact details (if provided).
  • Nature of the concern and desired outcome.
  • Circumstances, including when and where it occurred, actions taken, and who was involved.
• The complainant will be advised that their concern will be passed to the trustees.

3. Formal Complaints

Where an individual wishes to make a formal complaint:

• They will be given the contact details of the nominated lead trustee for complaints and/or our registered address. Correspondence should be marked Private and Confidential.
• A copy of this policy will be provided.

Formal complaints should include:

• Name, organisation (if relevant), address, telephone number, and email.
• Preferred method of contact (if any restrictions apply).
• Detailed information: what happened, where, when, who was present, and any actions taken.
• Why the situation was unsatisfactory.
• What outcome is sought.

Process:

• Receipt will be acknowledged within 7 working days.
• Investigation will be carried out, with specialist advice sought if necessary.
• A response will be provided within 14 working days. If this is not possible, a holding reply will be sent with an estimated completion date.
• The response will explain findings and actions taken, subject to data protection requirements.

Appeals:

• If dissatisfied, the complainant may appeal to the Chair of Trustees within 28 days of the response.
• Appeals must specify why the decision was wrong and provide supporting facts.
• A final decision will be issued within 28 days.

4. Wider Action

Following any complaint, trustees will consider:

• Whether statutory reporting is required (e.g., Charity Commission, Police, regulators).
• Whether policies, procedures, or training should be updated to prevent recurrence.

5. Anonymous Complaints

• Anonymous complaints will be recorded and investigated where possible.
• We will remain mindful that anonymous complaints can sometimes be malicious.
• Individuals are encouraged to provide contact details so we can update them on outcomes.

6. Data Protection Complaints

In line with ICO guidance and the Data (Use and Access) Act 2025:

• A clear process exists for raising data protection complaints.
• Receipt will be acknowledged within 30 calendar days.
• Investigations will be carried out without undue delay, with updates provided.
• Outcomes will be communicated clearly.
• If dissatisfied, individuals may escalate to the Information Commissioner’s Office (ICO).

7. Potential Compensation Claims

• If a complaint may lead to a claim for compensation (e.g., damage to property, personal issue), our insurers will be notified.

8. Confidentiality

• Complaints will be treated as confidential.
• All communication will comply with data protection legislation.

9. Availability

• This policy will be publicly available and provided to anyone wishing to submit a complaint.

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Disclaimer

This policy is intended as a framework for Discobility and should be reviewed regularly to ensure compliance with Charity Commission and other regulatory requirements. Trustees remain responsible for ensuring the policy meets the charity’s needs.

Purpose

Discobility is committed to safeguarding the interests of the charity and the SEND adults we serve. Trustees, staff, and volunteers must ensure that decisions are made solely in the best interests of the charity, free from undue influence or personal gain. This policy sets out how conflicts of interest will be identified, declared, and managed.

Types of Conflict of Interest

• Financial conflicts – where a trustee, staff member, volunteer, or connected person could benefit financially or materially from a decision made by Discobility. This does not include reimbursement of legitimate expenses.
• Loyalty conflicts – where a trustee, staff member, or volunteer may be influenced by their loyalty to another organisation, group, or individual, rather than acting solely in the best interests of Discobility.

Conflicts may arise when individuals have connections to other organisations or people with whom Discobility has a financial or working relationship, such as:

• Family connections – e.g., partner, child, or close relative.
• Organisational connections – e.g., serving as a trustee, board member, employee, or volunteer elsewhere.

Related Parties

Discobility values collaboration with other organisations that share our mission of inclusion and celebration for SEND adults. However, these organisations are independent legal entities. Trustees and staff with close personal or professional relationships with such organisations must declare these as potential conflicts of interest.

This applies to any organisation with which Discobility has a contractual or financial relationship.

Meetings

• Conflicts of interest will be a standing item on all board and committee agendas.
• At the start of each meeting, the Chair will remind trustees to declare any interests.
• Any declared interest will be recorded in the minutes, including the nature of the conflict and the decision made.

Specifically:

• If a trustee is directly or indirectly interested in a proposed transaction or arrangement, they must declare the nature and extent of that interest.
• If a declaration becomes inaccurate or incomplete, it must be updated promptly.
• Declarations must be made before Discobility enters into any transaction or arrangement.
• Trustees who declare a conflict will normally be asked to leave the meeting during discussion of the relevant item.

Potential Conflicts of Interest

Discobility may, in exceptional circumstances, pay or provide material benefits to trustees for services beyond their normal trustee duties, if the board reasonably believes this is in the charity’s best interests. Such arrangements will:

• Be considered on a case-by-case basis.
• Comply with Discobility’s governing document and Charity Commission guidance.
• Be transparently recorded in board minutes.

Even where no direct conflict exists, the perception of bias may arise. Trustees must therefore act with transparency to protect Discobility’s reputation and independence.

Managing Conflicts of Interest

When considering potential conflicts, the Board will ask:

• Is this the best use of Discobility’s limited resources?
• Could another provider deliver the service more appropriately?
• Who offers the best value in terms of cost, quality, and availability?

Recording Decisions

All conflicts of interest will be recorded in the minutes, with sufficient detail to explain the issue, the discussion, and the basis for the decision. This ensures transparency and accountability.

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Regulatory Guidance

This policy aligns with Charity Commission guidance, including:

• Conflicts of interest: a guide for trustees
• Payment to trustees
• Selling/leasing to someone connected with the charity
• Trustee disqualification
• Examples of personal benefit

Disclaimer

This policy is tailored for Discobility but should be reviewed regularly to ensure compliance with current Charity Commission guidance and best practice. Trustees remain responsible for ensuring decisions are made in the charity’s best interests.

Introduction and Scope

Discobility is committed to protecting the personal data of our members, supporters, trustees, staff, and volunteers. We comply with the UK Data Protection Act, UK GDPR, and guidance from the Information Commissioner’s Office (ICO). This policy ensures that all personal data is processed lawfully, fairly, and transparently, and that the rights of data subjects are respected.

This policy applies to everyone working on behalf of Discobility, including trustees, staff, and volunteers.

Data Protection Lead

Discobility will appoint a Data Protection Lead responsible for:

• Overseeing compliance with data protection legislation.
• Investigating and reporting any data incidents.
• Ensuring staff and volunteers receive induction and ongoing training on data protection responsibilities.

Key Definitions

• Data Controller: Discobility, determining how and why personal data is processed.
• Data Processor: Any third party processing data on behalf of Discobility.
• Data Subject: An individual whose personal data is processed.
• Personal Data: Information identifying a living individual (e.g., name, address, email).
• Special Category Data: Sensitive data requiring extra protection (e.g., health information, ethnicity).
• Processing: Any operation on personal data, including collection, storage, use, or disclosure.
• Valid Consent: Freely given, specific, informed consent that can be withdrawn at any time.
• PECR: Privacy and Electronic Communications Regulations governing electronic marketing.

Data Protection Principles

Discobility ensures that personal data is:

• Lawful, fair, and transparent – collected only with a valid legal basis, such as consent.
• Purposelimited – used only for specified, legitimate purposes (e.g., event registration, safeguarding).
• Dataminimised – only the information necessary for our activities is collected.
• Accurate and up to date – records are checked and corrected promptly.
• Storagelimited – retained only for as long as necessary (see retention section).
• Secure – protected against unauthorised access, loss, or damage through physical and digital safeguards.

Individual Rights

Discobility recognises the rights of individuals under UK GDPR, including:

• Right to be informed.
• Right of access.
• Right to rectification.
• Right to erasure.
• Right to restrict processing.
• Right to data portability.
• Right to object.

Use of Imagery and Video

Our ticket purchasing T’s & C’s clearly state that when you attend our events you give Discobility permission to use photographs or videos from events to celebrate our community and promote our work. We will:

• Obtain consent where images identify individuals or small groups.
• Take particular care with images of children or vulnerable adults.
• Ensure individuals are informed of how images will be used.
• Respect optout requests.

Data Breach

A data breach includes accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access to personal data.

• All breaches will be investigated promptly.
• Where required, the ICO will be notified within 72 hours.
• Individuals affected will be informed if the breach is likely to result in harm (e.g., discrimination, financial loss, reputational damage).

Complaints

Discobility provides a clear process for data protection complaints:

• Complaints can be submitted in writing or electronically.
• Acknowledgement will be sent within 30 days.
• Investigations will be carried out promptly and transparently.
• Outcomes will be communicated clearly.
• If unresolved, individuals may escalate to the ICO.

Fundraising and Marketing

Discobility complies with ICO and Fundraising Regulator guidelines.

• Donor privacy and contact preferences are respected.
• Requests to cease contact are acted upon promptly.
• Electronic marketing complies with PECR.

Artificial Intelligence

Where AI tools are used (e.g., for administration or creative campaigns), Discobility follows the Charity AI Ethics & Governance Framework and ICO guidance.

• Data Protection Impact Assessments (DPIAs) are carried out before AI systems process personal data.
• AI use is transparent, fair, and accountable.

Data Retention

Discobility retains data only as long as necessary:

• Financial and accounting records: 6 years after the relevant accounting year.
• Event registration and participation records: retained only for the period required to administer the event and comply with safeguarding.
• Personal records: not kept longer than necessary.
  Retention periods are reviewed regularly, balancing legal requirements, compliance, and storage considerations.

CrossReferences

This policy should be read alongside Discobility’s:

• Safeguarding Policy.
• Document Retention Policy.
• Fundraising Policy.

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Disclaimer

This policy is tailored for Discobility but is not legal advice. Trustees remain responsible for ensuring compliance with all applicable laws and regulations.

1. Purpose

This policy sets out how Discobility manages the retention, storage, and disposal of documents and personal data. It ensures compliance with the UK GDPR and Data Protection Act 2018, which require organisations to keep personal data only for as long as necessary for the purposes for which it was collected¹.

2. Scope

This policy applies to:

• All trustees, staff, volunteers, and contractors.
• All records created, received, or maintained by Discobility in any format (paper, digital, audio, video, email, messaging platforms, cloud storage).

3. Legal & Regulatory Framework

This policy is informed by:

• UK GDPR & Data Protection Act 2018 (storage limitation principle)¹
• ICO Accountability Framework guidance on retention schedules²
• Sectorspecific statutory requirements (e.g., HMRC, Companies Act, employment law) as referenced in UK retention guidance³.

4. Principles

Discobility adheres to the following principles:

🔹 Storage Limitation

Personal data must be kept for the shortest time possible, based on:

• The purpose for which it was collected.
• Legal obligations requiring minimum retention periods (e.g., tax, safeguarding, employment)¹.

🔹 Data Minimisation

Only data necessary for operational or legal purposes will be retained.

🔹 Security

All retained data must be stored securely, with access restricted to authorised personnel.

🔹 Transparency

Retention periods are documented and available to data subjects upon request.

🔹 Regular Review

Retention schedules must be reviewed at least annually to ensure they remain appropriate and lawful².

5. Retention Schedule

Discobility maintains a retention schedule that outlines:

• Categories of data
• Purpose of processing
• Retention period
• Legal basis
• Disposal method

The schedule is based on business need, statutory requirements, and best practice guidance²³.

Example Retention Periods (to be customised):

6. Data Disposal

When data reaches the end of its retention period, it must be disposed of securely and irreversibly. Acceptable methods include:

• Crosscut shredding (paper)
• Secure digital erasure
• Certified destruction by an approved contractor

Disposal decisions must be documented.

7. Roles & Responsibilities

• Trustees: Ensure compliance and oversight.
• Data Protection Lead: Maintain retention schedule, conduct reviews, and ensure secure disposal.
• All Staff & Volunteers: Follow retention rules and report any concerns.

8. Review & Updates

This policy must be reviewed annually or sooner if:

• Legislation changes
• New data types are introduced
• Risks or incidents highlight a need for revision

The ICO notes that retention guidance may change following new legislation, so regular review is essential².

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9. Related Policies

• Data Protection Policy
• Safeguarding Policy

Discobility is committed to encouraging equality, diversity and inclusion across all aspects of our charity’s work, and to eliminating unlawful discrimination. We aim to ensure that our discos and community activities for adults with Special Educational Needs and Disabilities (SEND) are welcoming, inclusive, and respectful spaces where everyone can thrive.

Our vision is for Discobility to be truly representative of the diverse communities we serve, and for every participant, volunteer, and staff member to feel valued, respected, and empowered to contribute their best.

Purpose of this Policy

This policy exists to:

1. Provide equality, fairness, and respect for all involved in Discobility, whether as participants, volunteers, or staff.
2. Ensure that no one is unlawfully discriminated against because of the Equality Act 2010 protected characteristics:
   • Age
   • Disability
   • Gender reassignment
   • Marriage and civil partnership
   • Pregnancy and maternity
   • Race (including colour, nationality, and ethnic or national origin)
   • Religion or belief
   • Sex
   • Sexual orientation
3. Oppose and avoid all forms of unlawful discrimination in:

1. Access to events and activities
2. Volunteer recruitment and participation
3. Training and development opportunities
4. Decision-making processes
5. Interactions with participants, carers, families, and the wider community

Our Commitments

Discobility commits to:

1. Promote equality, diversity, and inclusion as core values that strengthen our community and enhance the experiences of SEND adults and their families.
2. Create safe, respectful, and inclusive environments at all discos and activities, free from bullying, harassment, victimisation, and unlawful discrimination. We celebrate individual differences and recognise the contributions of all participants, volunteers, and staff.
3. Provide training and guidance to volunteers and staff about their rights and responsibilities under this policy, ensuring they understand how to support equality and inclusion in practice.
4. Take seriously all complaints of bullying, harassment, victimisation, or unlawful discrimination. Such complaints will be addressed under Discobility’s grievance and disciplinary procedures, with appropriate action taken. Serious complaints may constitute gross misconduct and result in removal from volunteering or employment.
5. Ensure equal access to opportunities for training, development, and participation, encouraging everyone to reach their full potential.
6. Base decisions on merit, except where lawful exemptions under the Equality Act apply.
7. Review practices and procedures regularly to ensure fairness, compliance with legislation, and alignment with best practice.
8. Monitor diversity and inclusion outcomes, including feedback from participants, carers, volunteers, and staff, to assess how well this policy is working in practice. Reviews will be conducted annually, with action taken to address any issues.

Agreement and Support

This Equality, Diversity and Inclusion Policy is fully supported by Discobility’s trustees and senior management, and has been developed in consultation with volunteers and community representatives.

Grievance and Disciplinary Procedures

Details of Discobility’s grievance and disciplinary procedures can be found in our internal governance documents. These outline how concerns should be raised and addressed, usually through a line manager or trustee representative.

Use of grievance or disciplinary procedures does not affect an individual’s right to make a claim to an employment tribunal within three months of the alleged 

discrimination.

Discobility is proud to celebrate individuality, inclusivity, and community. This policy ensures that our discos remain safe, welcoming, and empowering spaces for SEND adults and their families.

Part 1: Statement of Intent

Discobility is committed to ensuring the health, safety, and welfare of all participants, volunteers, staff, and visitors at our events. We aim to provide a safe and enjoyable environment for adults with Special Educational Needs and Disabilities (SEND) through our discos and community activities. We will manage health and safety proactively, comply with all relevant legislation, and continually improve our practices.

This policy will be reviewed annually and signed by the Chair of Trustees.

Part 2: Responsibilities for Health and Safety

• Overall and final responsibility for health and safety: Chair of Trustees
• Day-to-day responsibility for ensuring this policy is put into practice: Operations Lead

To ensure health and safety standards are maintained and improved, the following responsibilities are allocated:

• Policy review and updates: Safeguarding & Compliance Officer
• Risk assessments: Event Coordinator
• Training: Volunteer Manager
• Equipment maintenance: Venue Liaison Officer
• Emergency procedures (fire, evacuation, first aid): Event Safety Officer
• Consultation with volunteers and staff: Trustee Board Representative
• Work-related wellbeing: Volunteer Manager

Everyone involved with Discobility must:

• Co-operate with supervisors and managers on health and safety matters.
• Take reasonable care of their own health and safety.
• Report all health and safety concerns to the designated responsible person.

Part 3: Arrangements for Health and Safety

• Health and safety law poster: Displayed at event entrance.
• First-aid box: Located at the DJ booth and reception desk.
• Accident book: Located at reception desk.

Risk Assessment

• Risks are assessed before each event, updated regularly, and recorded in a master risk register reviewed by trustees.

Training

• All staff and volunteers receive induction training covering safeguarding, emergency procedures, and safe use of equipment.
• Refresher training is provided annually.

Equipment

• Venue equipment (lighting, sound systems, electrical appliances) is checked before each event.
• Portable appliances are tested annually.

Consultation

• Volunteers and staff are consulted regularly through meetings and feedback forms.

Evacuation

• Evacuation plans are in place for each venue and tested annually.
• Fire exits are clearly marked and unobstructed.

Accessibility and Inclusion

• Venues are assessed for accessibility, including ramps, toilets, and safe spaces.
• Adjustments are made to meet the needs of SEND participants.

International Activities

• Not applicable at present. If future international activities are planned, Charity Commission and FCO guidance will be followed.

Annual Review

• An annual health and safety review is conducted, with findings reported to the Board.

Part 4: Recording and Reporting

• All incidents are recorded in the accident book and reported to the Board.
• Serious incidents are reported to the Health and Safety Executive (HSE) under RIDDOR and to the Charity Commission if required.

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Attachments

• Risk Assessment Matrix
• Risk Assessment Template
• Useful Links:
  • HSE: Charities
  • HSE: Getting Started Toolkit
  • HSE: Made Simple
  • HSE: Policy Guidance
  • HSE: Toolbox

Disclaimer & Legal

This document is provided as a draft policy for Discobility and must be tailored to meet specific organisational needs. Professional advice should be sought to ensure compliance with all relevant legal and regulatory requirements.

Approved by: Chair of Trustees
Date: December 2025

Applicability

This policy applies to all trustees, volunteers, employees, contractors, and third-party representatives of Discobility. Its requirements should be reflected in other policies, procedures, agreements, and contracts, as necessary.

Separation of Duties

• No one person may both authorise and pay any payment or transfer.
• For example, an online banking payment or credit card transaction must involve separate individuals.

Conflict of Interest

• No individual may authorise or make changes to their own pay or personnel entitlements.
• Payments or contracts with family members or organisations in which they have an interest are prohibited.

Contracting

• Major contracts must be openly tendered, subject to board scrutiny and approval, and retendered every 3–5 years.
• Contracts and agreements are recorded in a contracts register and reviewed annually.

Budgeting

• The Board scrutinises and approves an annual budget.
• Budgets must include prudent income forecasts tested for reasonable expectation of funding.

Financial Reporting

• Up-to-date financial reports are submitted to the Board regularly.
• Reports must:
  • Use clear, simple language.
  • Explain Discobility’s current and future financial position.
  • Highlight key risks, actions taken, and expected outcomes.
  • Identify significant deviations from budget or funding shortfalls.

Financial Management

• Budget holders review financial reports and investigate variances.
• Significant issues must be reported to the Board.

Cash Handling

• Cash is secured under lock and key.
• Access is restricted to authorised individuals.
• Cash limits are set within insurance limits.
• Cash and cheques are banked regularly and recorded gross.
• Cash is never mixed with personal money.
• Significant sums are escorted by two individuals and transported by car.
• Cash payments are avoided wherever possible.

Banking

• Bank accounts may only be opened with written Board approval.
• Accounts are reconciled monthly.
• Reconciliations are cross-checked by someone independent of the original recording.
• Bank mandates, signatories, and e-banking access are reviewed annually.
• Cheques must be fully completed, secured, and used sequentially.
• Non-standard payment requests require codewords or multi-channel verification.
• International transfers must comply with FATF, HMRC, and local regulations, with Board approval.

Income

• Records of cash and cheques received must match bank paying-in slips.
• Paying-in slips must equate with bank statements.
• Transfers and direct payments must be verified against paperwork.
• Restricted funds are accounted for separately.
• Multi-year funding is managed to prevent premature expenditure.
• Anonymous or suspicious donations are subject to due diligence.

Expenditure

• Each budget line has a nominated budget holder.
• Expenditure beyond delegated limits requires line management approval.
• CEO approval is required for projects exceeding set thresholds or overspending budgets.
• Authorising officers must check invoices against orders and confirm receipt of goods/services.
• Finance staff must reject unauthorised invoices.
• Electronic payments require cyber security awareness, including vigilance against AI voice scams.
• Payroll must be checked monthly, reconciled against staff lists, and monitored for irregularities.
• Leave and sick records must be maintained.
• Payment systems (cheques, credit cards, online banking) must be safeguarded.
• Novel or contentious expenditure requires prior Board approval.

Assets

• Fixed assets with a life expectancy beyond one year are capitalised.
• A fixed asset register is maintained and reviewed annually.
• Assets are coded, insured appropriately, and not removed without approval.

Cryptoassets

• Donations of cryptoassets will be assessed for risks and benefits before acceptance.
• Relevant expertise must be sourced if cryptoassets are accepted.

Fraud and Bribery

• Suspected fraud must be reported immediately to the Board.

Hospitality

• Hospitality or gifts worth less than a set threshold may be accepted but must be declared in the Hospitality Book.
• The Hospitality Book is reviewed annually by the Chair.

Losses

• Losses must be investigated and approved for write-off by the Board.
• Records of investigation and approval are retained for audit.

Records

• Cashbooks and prime books of account are retained for 7 years.
• Supporting vouchers are retained for 18 months.
• Records are archived securely and organised for easy retrieval.

Experience and Training

• References and qualifications are checked on appointment.
• Staff are trained and briefed on financial responsibilities.
• Financial policies are included in the Staff Handbook and job descriptions.

IT and Online Security

• Security software is kept up-to-date.
• Access controls are enforced.
• Software updates are installed promptly.
• Passwords are strong, changed regularly, and not shared.
• Data is backed up remotely and disaster recovery procedures tested.
• Sensitive financial information must not be entered into Large Language Model AI systems.
• Shared drive access is restricted.
• Online purchasing follows security procedures.
• Accounts are disabled when individuals leave Discobility.

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Regulatory Guidance

• Charity Commission E&W: Charities, fraud and financial crime
• CC8: Internal Financial Controls
• Charity Governance Code: Decisions, Risk, Control
• Charity Digital: Anti-fraud resources
• NCSC: Password Guidance

Disclaimer

This policy is tailored for Discobility and intended as an internal governance document. It must be reviewed regularly to ensure compliance with Charity Commission guidance and relevant legal requirements.

Introduction

Discobility recognises the importance of effective risk management to achieve its charitable objectives. As a charity dedicated to providing inclusive disco events for adults with Special Educational Needs and Disabilities (SEND), we are committed to identifying, assessing, and managing risks to ensure the safety, enjoyment, and wellbeing of our participants, their families, and our volunteers.

Purpose

The purpose of this policy is to establish a framework for identifying, assessing, prioritising, and managing risks associated with Discobility’s activities. It ensures a systematic and proactive approach to risk management, protecting the charity, its beneficiaries, and stakeholders while supporting our mission of creating safe, inclusive, and enjoyable social opportunities.

Scope

This policy applies to all trustees, employees, volunteers, and stakeholders involved in Discobility’s work. It covers all aspects of our operations, including event delivery, safeguarding, finances, reputational risk, and governance. Where necessary, we will create additional relevant policies, such as safeguarding, health & safety, and financial controls.

Charity Commission Guidance

The Charity Commission strongly recommends that charities have a clear risk management policy and process to identify and manage all types of risks and embed risk management into the charity’s work. CC26 provides guidance.

Risk Management Cycle

Risk is managed through a cycle of identification, quantification, management, and review:

• Identification: Identify risks that may arise during events, fundraising, or governance.
• Quantifying: Assess and quantify these risks based on likelihood and impact.
• Managing: Take appropriate action to manage risks:
  • Avoidance: Prevent risks where possible (e.g., venue safety checks).
  • Mitigation: Reduce the impact of risks (e.g., clear safeguarding procedures, trained volunteers).
  • Buying Out: Use insurance to cover unavoidable risks.
  • Accepting: Recognise that some risks cannot be eliminated entirely, balancing safety with opportunity.
• Reviewing: Risks are reviewed regularly, particularly before and after events, and at trustee meetings.

Responsibilities

• Board of Trustees: Holds overall responsibility for ensuring appropriate systems of control are in place and working effectively. This includes:
  • Approving strategic and annual plans.
  • Reviewing financial results and variances.
  • Delegating authority and ensuring segregation of duties.
  • Overseeing risk management.
• Staff and Volunteers: Responsible for identifying and reporting risks within their areas of involvement, particularly during events.

Risk Identification and Assessment

• Risks are identified through regular assessments conducted at least annually and before major events.
• Risks are assessed based on likelihood and impact to determine priority.
• Risks are categorised as strategic, operational, financial, reputational, or compliance-related.

Risk Mitigation and Management

• High-priority risks are addressed with clear mitigation strategies.
• Mitigation plans are assigned to responsible individuals with timelines.
• Progress is monitored and reported to trustees.

Reporting and Communication

• A risk register is maintained and regularly reviewed by the Board of Trustees.
• Key risks and mitigation efforts are communicated to stakeholders where appropriate.
• The annual report will include steps taken to manage risk, demonstrating accountability to beneficiaries, donors, funders, and the public.

Review and Continuous Improvement

• The risk management policy and processes are reviewed annually or as needed.
• Lessons learned from events or incidents are used to improve practices.

Training and Awareness

• Staff and volunteers receive training on risk management principles and practices.
• Regular communication raises awareness of the importance of risk management.

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Useful Links

• Charity Governance Code: Decisions, Risk, Control
• HSE: Charities Guidance
• CFG: Charity Fraud Guide
• ICAEW: Risk Management
• Gov.uk: Data Protection Act
• Charity Commission Guidance CC26

Disclaimer & Legal

This document is provided as an example policy for Discobility and should be reviewed regularly to ensure compliance with regulatory and legal guidance. Professional advice should be sought where necessary to ensure the policy meets the charity’s needs.

1. Introduction and Commitment to Safeguarding

Discobility is committed to creating a safe and enjoyable environment for all SEND adults and all other attendees at our events. We recognise our responsibility to safeguard and promote the welfare of adults at risk and to protect them from abuse, neglect, and exploitation. We acknowledge the legal duties under the Care Act 2014 and the Charities Act 2011. We acknowledge the duty of trustees to ensure safeguarding is embedded in our charity’s governance and operations. Trustees will actively oversee and monitor safeguarding practices.

2. Definition of an Adult at Risk

For the purpose of this policy, an adult at risk is defined as someone aged 18 or over who has care and support needs and is experiencing, or is at risk of, abuse or neglect as a result of those needs. This includes SEND adults who may be particularly vulnerable. This definition is based on Section 42 of the Care Act 2014. The trustees will ensure safeguarding processes recognise and protect all individuals who may be considered at risk, in line with current legislation and Charity Commission guidance.

3. Principles of Safeguarding

Our safeguarding principles are:
Governance & Accountability: Trustees will oversee safeguarding practices to ensure compliance with charity laws.
Prevention: Taking proactive steps to prevent abuse and neglect from happening.
Proportionality: Ensuring that any action taken is the least intrusive and most appropriate for the situation.
Protection: Providing support and representation for those who need it.
Partnership: Working collaboratively with individuals, their families, carers, relevant agencies, and other organisations.
These principles reflect the six key safeguarding principles outlined by the Care Act.

4. Roles and Responsibilities

All safeguarding roles and responsibilities will be clearly communicated to staff and volunteers.
Trustees will ensure safeguarding is regularly reviewed, risk-assessed, and embedded across operations.
The Board of Trustees/Management Committee has overall responsibility for ensuring that the charity operates in a safe and legal manner and for approving and reviewing this policy.
Designated Safeguarding Lead (DSL) – Neil Harrington is responsible for overseeing and implementing this policy, being the first point of contact for any safeguarding concerns, and liaising with external agencies.
All Staff and Volunteers have a responsibility to be aware of this policy, promote a safe environment, and report any concerns they may have about the welfare of an adult at risk.

5. Creating a Safe Environment

We will create a safe environment by:
Conducting formal risk assessments and recording safeguarding risks, reviewed annually or as needed.
Ensuring that all staff and volunteers undergo appropriate recruitment checks, including:

• Right to work check
  
• Identity check
  
• Employment history & references
  
• Criminal record check (DBS)
  

Providing regular safeguarding training and awareness sessions to all staff and volunteers, tailored to the specific needs of SEND adults.
Developing clear codes of conduct for staff and volunteers that emphasise respectful and professional interactions with attendees.
Ensuring appropriate staff-to-attendee ratios to provide adequate support and supervision.
Conducting risk assessments of our events and venues to identify and mitigate potential safeguarding risks. These assessments will be formally recorded as part of ongoing risk management.
Having clear procedures for managing challenging behavior in a way that prioritises the safety and well-being of everyone.
Having clear procedures for the safe handling of personal information in accordance with data protection legislation, including the UK GDPR.

6. Recognising and Responding to Concerns

A structured internal escalation process will be established and documented, ensuring prompt reporting to the DSL and trustee oversight where required.
Concerns involving potential criminal activity will be promptly reported to the relevant external safeguarding bodies, including the Police or Adult Social Care.

7. Reporting Procedures

The Designated Safeguarding Lead (DSL) will:

• Take all reports of suspected abuse or neglect seriously.
  
• Ensure trustees are informed of serious incidents and that these are recorded appropriately.
  
• Follow the charity’s internal procedures for recording and managing safeguarding concerns.
  
• Assess the information and determine the appropriate course of action, which may include:
  
  • Offering support to the individual.
    
  • Discussing the concern with relevant colleagues.
    
  • Contacting external agencies such as the Local Authority Adult Social Care services, Kent County Council on 03000 41 91 91 , or the Police, in line with local safeguarding procedures.
    
• Keep accurate and confidential records of all safeguarding concerns and actions taken.
  
• Liaise with the relevant authorities and cooperate fully with any investigations.
  
• Ensure any serious safeguarding concerns are reported to the Charity Commission, as part of serious incident reporting obligations.
  

8. Confidentiality and Information Sharing

We will maintain confidentiality in accordance with data protection legislation.
Information will only be shared on a need-to-know basis and when it is necessary to safeguard an adult at risk.
A formal confidentiality and data handling policy will be implemented, reviewed annually, and aligned with safeguarding best practices.
Any decision to share information without consent will be carefully considered and made in line with legal and safeguarding guidance.

9. Training and Support for Staff and Volunteers

Trustees will ensure safeguarding training is embedded as a mandatory requirement for all roles.
All staff and volunteers will receive induction training that includes an overview of this policy and their safeguarding responsibilities.
Regular safeguarding training will be provided, tailored to their roles and responsibilities.
Refresher training will be conducted at least every two years.
The charity will provide ongoing support to staff and volunteers who may be dealing with safeguarding concerns.

10. Review of this Policy

This policy will be reviewed every two years or sooner if there are changes in legislation or best practice. The review will be led by the trustees, ensuring strategic oversight.
The review will involve consultation with relevant stakeholders.
Any changes made to the policy will be documented, and updated versions will be made accessible to all staff and volunteers.

11. Contact Information

Designated Safeguarding Lead (DSL): Neil Harrington
Deputy Designated Safeguarding Lead: Karen Lightwood
Police (Non-Emergency): 101
Police (Emergency): 999

By implementing this safeguarding policy, Discobility aims to create a safe, supportive, and empowering environment where SEND adults can attend our events free from harm. This policy is designed to align with best practices outlined by the Charity Commission and sector-wide safeguarding standards.

12. Visitor and External Contractor Responsibilities

Discobility recognises that visitors and external contractors (including DJs, performers, venue staff, carers, family members, and partner organisations) play an important role in our events. To ensure safeguarding is consistently applied, the following responsibilities apply:

1. Awareness  

All visitors and contractors must be made aware of this safeguarding policy and the charity’s code of conduct before attending or working at events. A short briefing will be provided where appropriate.

1. Conduct  

Visitors and contractors are expected to act respectfully towards SEND adults and all attendees, avoiding any behaviour that could be discriminatory, exploitative, or unsafe. They must not take photos, videos, or personal information without explicit consent and safeguarding approval.

3    Reporting Concerns  

Any safeguarding concerns must be reported immediately to a staff member or the Designated Safeguarding Lead (DSL). Visitors and contractors must not attempt to investigate concerns themselves.

1. Access Control  

Visitors and contractors must remain in designated areas and follow staff instructions. Unsupervised contact with attendees is not permitted unless authorised by the DSL.

1. Privacy and Data Protection  

Visitors must respect confidentiality and data protection requirements. No personal information about attendees may be shared outside the event.

1. Compliance Checks  

Regular or contracted visitors (such as DJs, security staff, or venue employees) may be required to undergo Disclosure and Barring Service (DBS) checks and agree to safeguarding clauses in contracts or partnership agreements.

1. Consequences of Breach  

Any visitor or contractor who fails to comply with safeguarding responsibilities may be asked to leave the event, excluded from future activities, and referred to relevant authorities if behaviour poses a safeguarding risk.

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Policy Statement

Discobility is committed to safeguarding and promoting the welfare of adults with Special Educational Needs and Disabilities (SEND). We operate a Safer Recruitment policy to ensure that all our staff and volunteers understand our commitment to safeguarding and the processes in place to support this.

Introduction

Creating safe, inclusive environments is essential for promoting wellbeing and protecting adults with SEND. The purpose of safer recruitment policies is to deter, reject, prevent, and detect individuals who may pose a risk or are unsuitable to work within our charity.

The four key principles of safer recruitment are:

• Deter: Make references to safeguarding policies within job advertisements and throughout the application process to deter unsuitable applicants.
• Reject: Identify and reject those who are unsuitable for the role during application and interview stages.
• Prevent: Ensure robust risk management and establish appropriate standards of behaviour during recruitment and induction.
• Detect: Encourage a safe working culture by identifying unwanted behaviour or abuse quickly and responding appropriately.

Policy Aims

The aims of Discobility’s Safer Recruitment policy are to:

• Ensure compliance with safeguarding legislation, recommendations, and guidance, including those published by the Disclosure and Barring Service (DBS).
• Recruit staff and volunteers of the highest standard based on skills, abilities, experiences, values, and suitability for the position.
• Uphold our commitment to safeguarding and promoting the welfare of adults with SEND.

Recruitment and Selection Procedures

Advertisement

All advertisements will:

• Make clear Discobility’s commitment to safeguarding.
• Reference our values, beliefs, and expected behaviours.
• State that recruitment involves a robust selection process, including DBS checks.
• Confirm that applicant documentation will be treated in accordance with the Data Protection Act and GDPR (2018).

Job Description and Person Specification

Job descriptions will include:

• Organisation name and location.
• Job title, working hours, and pay/salary.
• Main duties of the role.
• Training opportunities.
• Safeguarding responsibilities attached to the role.
• Pre-employment checks required (e.g., DBS).
• Closing date for applications.

Person specifications will outline:

• Necessary skills and experience.
• Required attitudes and values.

Application Form

A standard application form will be used to ensure consistency. It will include:

• Personal details.
• National Insurance number.
• Education and training history.
• Employment history.
• Referees.
• Personal statement.
• Signed declaration.

References

• At least two references will be obtained, excluding friends and family.
• References must be objective, verifiable, and checked thoroughly.
• Referees must confirm the applicant’s suitability, conduct, and any safeguarding concerns.

Shortlisting

• Anomalies or gaps in employment history will be clarified.
• More than one person will be involved in shortlisting.

Interview

• Interviews will assess both capability and suitability for working with adults with SEND.
• More than one interviewer will be present, with at least one trained in safer recruitment.
• Questions will be linked to the job description and person specification.
• Pre-employment checks will be reiterated.

Conditional Offer

Offers will be conditional upon:

• Two or more satisfactory references.
• Relevant DBS check.

Pre-Employment Checks

Pre-employment checks will include:

• Identity verification.
• Right to work in the UK.
• Enhanced DBS checks and barred list checks where applicable.
• Qualification verification.
• Professional status checks.
• Overseas checks if relevant.

Regulated Activity

Discobility recognises regulated activities as defined by the DBS, including:

• Providing healthcare.
• Providing social work.
• Providing personal care.
• Conveying individuals to care or social work settings.
• Assistance with household matters.
• Assisting with personal affairs.

It is a criminal offence for a barred individual to seek or undertake regulated activity, and for employers to knowingly employ them.

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Final Statement

Discobility is fully committed to the safe recruitment of all staff and volunteers. This policy will be reviewed regularly to ensure compliance with safeguarding standards and best practice.

1. Purpose

Discobility uses social media to celebrate individuality, promote inclusivity, and engage with the SEND community. This policy ensures that all online activity reflects our values, protects our community, and complies with safeguarding and charity governance standards.

2. Scope

This policy applies to all trustees, staff, volunteers, and representatives of Discobility who contribute to or are featured in our social media activity.

3. Principles

• Respect and Inclusion: All content must promote dignity, respect, and inclusivity for SEND adults and their families.
• Safeguarding First: Protecting the welfare of our community is paramount. No content should compromise safety or privacy.
• Transparency: Communications must be honest, accurate, and aligned with Discobility’s charitable objectives.
• Celebration: Posts should highlight achievements, events, and positive stories that showcase the joy of our discos.

4. Content Guidelines

• Positive Representation: Share content that celebrates SEND adults’ participation, creativity, and individuality.
• Consent: Obtain written consent from parents, guardians, or carers before posting any photos, videos, or personal stories.
• Privacy: Do not share personal details (addresses, phone numbers, medical information, etc.).
• Appropriate Language: Use inclusive, respectful, and accessible language at all times.
• Event Promotion: Posts should focus on upcoming discos, fundraising initiatives, and community engagement opportunities.

5. Conduct Online

• Professionalism: Trustees, staff, and volunteers must uphold Discobility’s reputation when engaging online.
• Boundaries: Personal accounts should not be used to represent Discobility unless explicitly authorised.
• Respectful Engagement: Respond to comments and messages politely, avoiding arguments or negative exchanges.
• No Endorsements: Avoid promoting external organisations, products, or services unless approved by trustees.

6. Safeguarding on Social Media

• Moderation: All platforms must be monitored regularly to remove inappropriate or harmful content.
• Reporting: Any safeguarding concerns identified online must be reported immediately to the Designated Safeguarding Lead.
• Images and Videos: Only share content that has explicit consent and portrays SEND adults positively.

7. Governance and Compliance

• Trustees oversee the implementation of this policy to ensure compliance with Charity Commission guidelines.
• Breaches of this policy may result in disciplinary action, including removal of content or withdrawal of posting privileges.

8. Review

This policy will be reviewed annually to ensure it remains relevant, effective, and aligned with Discobility’s mission.

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Introduction

Discobility welcomes volunteers from all backgrounds who share our commitment to creating safe, inclusive, and enjoyable disco events for adults with Special Educational Needs and Disabilities (SEND). We particularly encourage applications from individuals with lived experience of disability, and from diverse communities, to reflect and celebrate the inclusivity at the heart of our charity.

This policy sets out how we recruit, select, and support volunteers to ensure they feel valued, confident, and able to contribute meaningfully to our mission.

Promotion

We promote volunteering opportunities through:

• Our website and social media channels.
• Local community groups, SEND networks, and partner charities.
• Posters and flyers in community spaces such as libraries, churches, mosques, GP surgeries, and shops.
• Word of mouth via carers, families, and statutory services who support SEND adults.

Where appropriate, we provide information in accessible formats, including alternative languages and disability-friendly materials.

Recruitment

All potential volunteers will be interviewed to ensure suitability for roles. We follow safer recruitment practices by:

• Informing candidates of our commitment to safeguarding.
• Planning recruitment timelines to allow thorough vetting.
• Explaining that volunteers must undergo vetting before appointment.
• Carrying out pre-engagement checks, including DBS, references, identity, and (where relevant) qualification checks.
• Ensuring volunteers receive training appropriate to their duties.

Volunteers in professional or specialist roles must maintain up-to-date training and undertake refresher training every two years.
We encourage all volunteers to complete safeguarding training at Level 1 or 2.

Induction

Volunteers will receive a structured induction covering:

• Charity policies and procedures.
• Safeguarding responsibilities and relevant checks.
• Identity and right-to-volunteer verification.
• Introduction to Discobility’s mission and values.
• Role-specific training, including health & safety, fire procedures, and event protocols.
• Ongoing support, mentoring, and refresher training as required.

Selection

Mandatory Requirements

• Commitment to Discobility’s mission and values.
• Desire to support SEND adults with kindness and respect.
• Sufficient time and flexibility to fulfil the role.
• Professional qualifications or licences where legally required (e.g., first aid, food handling).

Training Requirements

• First Aid: Emergency First Aid at Work (EFAW) minimum; refresher training as necessary.
• Health & Safety: IOSH Working Safely or equivalent; refresher training encouraged.
• Food Handling: Level 2 Food Safety for handlers; Level 3 for supervisors/managers.

Discobility will provide or facilitate access to relevant training and refresher courses.

Desirable Skills

• Experience in charity work or event support.
• Strong interpersonal skills and ability to work as part of a team.
• Good communication skills and a positive approach to engaging with SEND adults, carers, and families.

Exceptions

We welcome all who wish to volunteer, but there may be circumstances where this is not possible, such as:

• Lack of right to volunteer in the UK.
• Roles requiring specific professional skills or legal requirements not met.

Where possible, we will seek alternative roles to enable participation.

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Regulatory Guidance

• Charity Commission: Managing volunteers.
• Fundraising Regulator: Volunteers.
• Health & Safety Executive: Volunteering – managing risks.
• Gov.UK: DBS checks guidance.

Disclaimer

This policy is provided as guidance for Discobility and must be reviewed regularly to ensure compliance with current law and regulatory requirements. Trustees are responsible for ensuring the policy remains fit for purpose.