The procedure every appointed investigator must follow when looking into a concern
Last reviewed: 6 July 2022
If an adult volunteer’s behaviour doesn’t meet Girlguiding’s expectations, we need to investigate to find out what happened.
The investigation will decide whether the concerns are upheld, or for safeguarding cases whether they’re substantiated.
Who is this procedure for and when is it used?
All investigators appointed to look into a concern by one of our Safe Practice teams at Girlguiding HQ or by a country or region must use this procedure.
Investigators look into concerns raised under one of our policies, such as our:
- Complaints policy
- Managing concerns about adult volunteers policy
- Safeguarding policy
- Whistleblowing policy
This procedure doesn’t apply if a statutory agency, like the police or children’s services, is investigating safeguarding or any other concerns.
What does Girlguiding mean by an investigation?
An investigation is the formal process of thoroughly looking into and examining something to gather all available information and become fully informed about it.
Investigations are objective and impartial. They should be done without a specific outcome or conclusion in mind.
When someone first reports a concern to HQ or a country or region, an appropriate member of staff or volunteer will decide what the best way forward is and whether a full investigation is needed. In some circumstances an informal resolution may be a quicker and more efficient way to resolve the issue.
If the concern is low-level or doesn’t involve a breach of our policies or procedures, it may be appropriate to resolve the issue informally. Please note that all safeguarding concerns must be reported to the HQ Safeguarding team, even if they are low-level, so the team can advise what to do.
Complaints that might be resolved informally include concerns about joining enquiries, waiting lists or how activities are run.
Where it’s decided that an informal resolution is the best way forward, we’ll pass the concern on to a senior volunteer, like a commissioner, who will give advice on next steps. The concern can later be investigated formally if necessary.
If an issue is resolved informally the senior volunteer looking into the concern doesn’t need to write an investigation report. But they must still speak to all parties and send a written notice confirming the concern has been resolved. The senior volunteer may also share a copy of any relevant meeting notes with those involved, if appropriate. If the concern was originally reported to HQ, the senior volunteer must send a copy of the written notice detailing the informal resolution to the relevant Safe Practice team.
If an informal resolution isn’t possible or appropriate, a formal investigation will start.
Advice must be sought from the relevant team at HQ and your country or region before a formal investigation begins.
A formal investigation will always be needed if:
- we need to gather more information, clarity or evidence from others.
- there may have been a breach of our policies or procedures. This could include using abusive or inappropriate language, poor financial account management, or inappropriate posts on social media.
- someone may have committed a criminal offence, for example, theft of unit funds.
The HQ team or country or region office will inform the person who raised the concern that a formal investigation is beginning, and give them the name of the investigator. They’ll also notify the relevant designated commissioner within the country, region or county.
Once it’s been decided that a formal investigation needs to happen, the relevant Girlguiding staff member or country or region volunteer will appoint an investigator. All staff and volunteer investigators need to have completed A Safe Space level 4.
Country or region volunteers with relevant safeguarding experience will investigate safeguarding cases. We may appoint an investigator from a different country or region if there are concerns about impartiality.
In most other cases, the investigator will be the local commissioner. If they’re involved in the concern, or unable to remain impartial and unbiased due to their relationships with people involved, the relevant Girlguiding staff member or country or region volunteer will appoint someone else to investigate. This could be a local commissioner from another area, or a volunteer experienced in doing investigations.
In more complex cases, the relevant Safe Practice team at HQ may ask an external professional to investigate.
As an investigator you must:
- meet our expectations as set out in our volunteer code of conduct
- read the relevant policy and procedure the concern was reported under
- follow the investigation process as laid out below, including sticking to timeframes
- complete the objectives set out in the Terms of Reference for your investigation, if you’ve been given these
- keep the relevant commissioner, country or region volunteer or member of staff up to date on your progress
- keep a record of your actions, including who you’ve been in contact with and when. This should be factual as you’ll need to include it in your final investigation report, and other people involved may ask to see it
- keep information relating to the investigation safe and secure, as set out in our Managing information policy and procedures
- report any further safeguarding concerns to our HQ Safeguarding team as soon as you come across them
The relevant HQ team, or volunteer at country or region level, will give you access to a toolkit with extra guidance and resources to help you do your investigation. They can also give you more advice and support at any point. But they won’t take on your role, or any of your responsibilities, without agreeing this first.
If your investigation relates to an appeal, your approach, remit and timeframe may be different to what’s laid out below. This’ll be agreed between you and the relevant team or volunteer before you get started.
Step 1: Formal investigation begins
Once you’re appointed as investigator by the HQ staff team, or country or region, they’ll give you the details of the concern. They’ll also let you know which policy or procedure may have been breached.
For all safeguarding investigations, and some complex investigations, the relevant team at HQ will create a Terms of Reference setting out the rationale for and parameters of the investigation. Terms of Reference are a statement of purpose and a set of instructions. They’ll give you a framework for the investigation, setting out what you should look into, who will do what and when, and how you should present and use the information you gather.
An adult volunteer being investigated should be told this verbally, preferably in person by their commissioner. This must happen before the investigation goes any further.
If appropriate, HQ or the country or region will offer the volunteer being investigated support from a safe practice liaison volunteer within seven working days of telling them about the investigation. The safe practice liaison volunteer’s role is to offer emotional support during the investigation, acting as a sounding board and going to meetings with the person when needed.
If at any point you or the assigned safe practice liaison volunteer feel the volunteer under investigation would benefit from more support, please contact the relevant HQ team or signpost them to appropriate support organisations.
Step 2: Doing the investigation
You must contact the person who made the complaint within five working days of being appointed as investigator to let them know you’ve received their concern.
You need to talk to the person who made the complaint before contacting the person under investigation or any witnesses. You can do this in person, by phone or in an online meeting. You must do this separately to any meeting you hold with people under investigation or witnesses.
During your conversation with the person who raised the concern, you should:
- try to get a good understanding of their concern
- let them know how you propose to deal with their complaint
- ask if they have a resolution in mind, if this is appropriate
- let them know you’ll keep them updated on how the case is progressing.
After speaking to the person who raised the concern, you need to speak with the person under investigation. You must give them an honest and fair outline of the concerns, and an opportunity to respond.
You can use our guidance on how to approach sensitive conversations to prepare for these meetings.
Anyone invited to come to a meeting as part of an investigation has the right to be accompanied by another person. This could be a safe practice liaison volunteer, a family member or friend. We ask anyone who comes to meetings to treat what’s discussed confidentially.
If you’re unable to get in contact with the person who raised the concern, or they don’t answer you in good time, get in touch with the relevant HQ team or country or region office. Depending on the concern and the information you already have, the investigation may be able to continue without their input. If this isn’t possible we may close the case.
Your investigation will involve gathering all the relevant facts from the person raising the concern, the person under investigation and any witnesses. This could include:
- Interviews or statements – you should interview everyone involved or collect written statements. If you interview someone, you should write up a statement of what they said. The person under investigation’s statement must include details of the behaviour or conduct being investigated.
- Emails or letters sent and received – this may include emails or letters sent between the person complaining, the person under investigation and witnesses, as well as emails or letters you’ve received from them.
- Emails confirming statements – if you write a statement after meeting with someone, you must send them a copy so they can approve it. You should confirm or amend the statement within 10 days of doing the interview.
- Other physical evidence – this could include attendance registers, photos and videos, forms or payment records.
- Evidence collected – you should offer everyone involved an opportunity to give you any more evidence.
You must update everyone involved on the progress of the investigation regularly. We recommend sending an email update at least once a month. You should also send these updates to the relevant team at HQ or your country or region.
If at any time during your investigation new information emerges which suggests that there could be a safeguarding issue, you must contact our Safeguarding team immediately. You don’t need to be certain that there’s a safeguarding risk. A suspicion is enough to suspend the investigation until you take advice. Our Safeguarding team will advise and support you on next steps, including letting everyone involved know about any changes to the investigation.
If you think a crime has been committed, you must contact the relevant Safe Practice team. Again, a suspicion is enough to suspend the investigation until you take advice.
Step 3: Report produced
After collating evidence and statements, use these to make decisions about the concerns and whether they’re upheld or not. Or for safeguarding cases, whether they’re substantiated or unsubstantiated.
You must then write a final report detailing how you did your investigation and your findings. This must be factual and should follow Girlguiding’s report template, available in the investigator’s toolkit.
If you make any recommendations or identify any learnings, you should share these with the HQ staff team or your country or region as part of the report. They may share these with other people in Girlguiding.
Step 4: Report reviewed
Once you’ve finalised your report, you need to present it to the relevant HQ or country or region team. They must confirm they’re satisfied that your investigation and report have met all objectives.
If the concerns have been upheld or substantiated, even partially, HQ or the country or region may put a sanction in place, in line with our Managing Concerns about Adult Volunteers policy. You can recommend a sanction in your investigation report but those reviewing the report will make the final decision.
Step 5: Findings shared
HQ or the country or region will share the outcome of the investigation with the relevant designated commissioner in the country, region or county.
If the investigation has addressed concerns about a volunteer’s conduct or actions, the local commissioner, or another appropriate volunteer, must contact the volunteer within 2-3 days of HQ or the country or region agreeing the report. This should preferably happen face to face, but could also be by phone or in an online meeting. This must happen before the person who raised the concern is informed of the outcome.
The commissioner must let the volunteer know during this conversation if a risk assessment or sanction, including withdrawal of membership, will be put in place. The relevant team at HQ will then confirm this in writing.
If an investigation into a safeguarding concern identifies further risks, the county commissioner and Safeguarding team will follow up to make sure a risk assessment form is completed.
Once the volunteer under investigation knows about the outcome, the person who raised the concern must also be informed. This should be within seven days of the final report being agreed. If they’re informed by letter, the relevant Safe Practice team at HQ, the local commissioner or the investigator will send this.
The person raising the concern won’t be informed about the details of any sanctions or management actions taken against volunteers. They don’t have the right to appeal any decision about a sanction.
We won’t share recommendations about Girlguiding’s working practices with any of the parties involved.
Step 6: Case closed
After the person who raised the concern knows the outcome, the case will be closed. If an appeal is likely or there are recommendations to be implemented, this may be delayed.
Once the case has been closed, you must make sure to pass on all correspondence and relevant information to the relevant Safe Practice team at HQ for secure storage. After HQ have confirmed they’ve received this, you must destroy any information you hold on paper and delete files and emails within 14 days. HQ will keep appropriate information in line with our relevant retention schedule and our Managing Information policy.
If the person who has been investigated isn’t satisfied with the outcome or how the concern was handled, they can ask for an appeal in line with our Appeals and review procedure.