Investigators' toolkit

Complaints are concerns that relate to a specific situation, event, volunteer or staff member. These can cover a wide range of topics including inclusion, communication, GO records and local events.    

Any concern that is feedback directed towards Girlguiding as an organisation is handled by the volunteer support team, for example a parent is unhappy with a particular Girlguiding policy. These concerns don’t require a local investigation. 

Complaints managed by the complaints and compliance team are usually raised by parents or carers, young members, volunteers or members of the public. These concerns can be investigated by local guiding to see if resolutions can be found. Investigations provide an opportunity to see what can be learnt from the situation.   

At this initial stage, complaints cases don’t meet the criteria for a compliance or safeguarding case. However, as the investigation progresses it may become clear that further action is necessary. At this point, HQ will consider what sanctions may be required in response to your investigation findings and recommendations.   

Compliance concerns are usually communicated to HQ by commissioners who have concerns about the conduct of a volunteer in their team. They may also be highlighted as the result of an investigation into a complaint. Compliance concerns refer to situations where a volunteer may have breached our volunteer code of conduct.  

When a compliance case has opened, it may be appropriate to suspend the volunteer concerned. This is a temporary measure that prevents an adult volunteer from carrying out their Girlguiding roles while the investigation is taking place.   

Once an investigation is complete, the investigator may feel that additional support and guidance would help the volunteer. In these cases an improvement plan would be recommended. For cases where no additional support is identified but a reminder of Girlguiding’s expectations is needed, formal advice may be used. This will also be recorded on the volunteer’s GO record. If the investigation concludes that a sanction is required then a role restriction may be recommended. In more serious cases the volunteer’s membership or roles may be withdrawn.  

The recruitment and vetting of our volunteers is managed by the complaints and compliance team. They make sure that each of our volunteers have completed the required vetting for their role and have completed a safe space or safer guiding training to the appropriate level.  

If a Girlguiding member or a person enquiring to become a member fails to meet the requirements, we may need to refuse or withdraw their membership.   

The complaints and compliance team are also responsible for overseeing investigations under the whistleblowing policy. If Girlguiding volunteers, members or staff have a serious concern about something taking place within the organisation related to volunteers, they can raise it with this team.  

Safeguarding cases focus on concerns, allegations or disclosures relating to an adult or child’s safety or welfare. Cases may also be about the potential risk a person may pose, or abuse or harm that has happened in the past.  

The team work closely with statutory agencies to ensure the safety and wellbeing of everyone who’s a part of Girlguiding. Sometimes safeguarding investigations are carried out by other organisations that also work with the volunteer or young person involved. These organisations could be employers, statutory agencies such as children’s services, the police or other voluntary organisations like the Scouts. This is because they’re in a better position to lead and address the concerns.  

If required, safeguarding investigations may result in further support or guidance, sanctions or withdrawals. It may also be necessary to refer concerns, allegations or disclosures on to statutory agencies, such as the local authority designated officer (LADO) or equivalent, children services or police to carry out further actions.  

• Any safeguarding concern.  
• Significant concerns about conduct, such as bullying, harassment or unsafe behaviour. 
• A case where someone has been injured or harmed. 
• Any concerns regarding theft, fraud or unlawful activity. 
• Where we have enough evidence to suggest criminal activity and reporting this to the police is necessary. 
• Barred list disclosures.  
• A case where a volunteer has been refused.  

Concerns where a policy or procedure has allegedly been breached but does not meet red case threshold.

For example:

• Concerns with ratios at unit meeting or residentials. 
• Poor conduct that may affect an upcoming unit meeting or event.
• Financial mismanagement not yet ready to report to police.
• Roles added on to restricted members' GO records. 

Low-level concerns where no policy or procedure was breached.

For example:  

• A concern relating to a joining enquiry. 
• Issues surrounding organisation or running of meetings, but no policy was breached nor was anyone harmed. 

Before starting an investigation 

Remember that it's okay to say no! 

If a case has been passed to you for investigation and you don’t have the capacity to take the case on, please say so. Ask the relevant HQ team or country or region team to pass the case on to someone else.  
If you feel you need additional support to complete an investigation, please get in touch with the relevant HQ team. We can help you create an investigation plan or help manage the expectations of those involved with the case.  

Be honest if you feel it wouldn't be appropriate for you to investigate

It's important investigators are able to remain objective throughout the process. We know that Girlguiding has a wonderfully connected community and culture, but this can make investigating concerns about other volunteers challenging!

If you know the person you’ll be investigating too well, please do let the relevant HQ team or country or region teams know so we can reassign the case.  

Acknowledge receipt of the case as soon as you can

Before doing anything else, please respond to the HQ team and country or region team to indicate whether you’ll be able to investigate the case. Highlight any concerns you might have about being impartial.  

Maintain confidentiality

During the investigation, it’s important to keep things confidential. For more guidance on this, please visit the data protection section of this toolkit. 

Consider your personal boundaries

You might find that people involved with the investigation try to contact you at inconvenient times or for inappropriate reasons. You may wish to use a separate email address for your investigation to keep this communication separate. Consider using a separate phone or hiding your number when making calls to the parties involved.  More details of keeping yourself safe can be found in the data protection section of this toolkit.  

It’s often best practice to discuss and agree boundaries with the people you’re in contact with from the outset of the investigation. This will give you the opportunity to let them know how and when they can reach out to you. 

Keep clear and factual records

Throughout the investigation make sure you take accurate and concise notes of the work you’ve carried out. It’s important these records are factual and free from personal opinions.  
This will make it easier when you write your investigation report and will help if there’s an appeal. You can find more information about this in the report writing section of this toolkit.  
Remember that all written communication regarding an individual must be submitted if they put in a subject access request (SAR). Bear this in mind when communicating about this case.

Consider perception and unconscious bias

This means being aware of our own views, beliefs and opinions. It’s important to be aware of what you feel or think, especially if you’re listening to a disclosure, or someone’s reporting an allegation or concern to us. Conflicts with our own beliefs, values and opinions could prompt a personal struggle, which might delay effective action. 

It's important to remain objective and focus on the facts you’re told, rather than personal opinion or perspective. It’s your responsibility to listen, record, gather all the facts and pass on concerns to the relevant HQ team.

Contact the person who raised the concerns as soon as possible 

This contact should be made within 5 working days of receipt of the case. Discuss how you plan to carry out the investigation and when they can expect to next hear from you. 

Make sure the person who’s subject of the investigation has been told there was a complaint raised in respect to them

If a volunteer’s conduct is being investigated their commissioner should discuss this with them. The relevant HQ staff member will guide you to decide if this needs to be done as soon as possible or once you’ve spoken to the complainant. It may be important to consider when the next guiding meeting or event is and make sure they’ve been informed before this takes place. 

If you aren’t the volunteer’s commissioner, check that this conversation has taken place before you start the investigation.

Be clear with your communication

Keep your communication clear so there are no misunderstandings. It’s also helpful to set out a clear timeline for when they can expect things to happen. This’ll help them feel more supported and manage expectations. 

Pick the right communication method

 It can be helpful to ask for the person’s preferred method of communication, as it shows sensitivity to their individual needs. Some people may not like to be contacted over the phone, while others may struggle with long emails.

When making contact, use their preferred method if you know what this is. It’s better to have any challenging or sensitive conversations face-to-face where possible. 

Arrange conversations in advance

Before speaking with the individual, establish what their availability is and work out a time that works for both of you. Scheduling conversations in advance gives the person time to prepare what they want to say. It will also help them find a private setting to take the call.  

Bear in mind confidentiality, personal safety and accessibility when meeting

Your meeting place should ideally be a neutral ground (preferably not an individual’s home) where all parties feel safe and able to discuss matters. The chosen location should be free from noise, distraction or being overheard.  

This also applies to meetings that take place virtually. Consider the environment you’re in and remind the parties involved that they may want to do the same thing. It’s important they’re in a space where they feel safe to speak openly and honestly. 

When setting up the meeting, think about who should attend. You should ask someone else to take notes. Let everyone involved know who else will be there and what their role is.

Let them know that support is available

When outlining the purpose of the conversation the person may indicate that they’d like someone to join them. They may wish to ask for a friend to be with them to support their wellbeing, or they may ask for a safe practice liaison volunteer to help them feel more comfortable. Let them know this is fine and support is available if they need.

Take care when leaving voice messages

If you can only make contact by phone, consider what message you’d leave as a voicemail if the person you want to speak with isn't available. Be aware that other members of the household may not be aware of the situation. 

Set deadlines for responses

It can sometimes be a challenge to contact the people you need to. If you’ve done all you can and still haven’t received a response, you can send an email or letter with a deadline for them to contact you.

Once this deadline has passed, send them a final email or letter to inform them that the case is now closed or further actions are required without their involvement. Let the HQ team and country or region team know that this is what you’ve done and include these details in your final report. 

Keep in regular contact with those involved in the investigation

It’s important those involved in the investigation are kept informed, understand what the concerns are and what action is going to be taken. Include timeframes so they know when they expect to hear from you again. 

If the investigation requires more time to reach a conclusion, make sure you update the relevant parties at least once a month. The investigation report has reminders on it to help you remember to do this.

Keep in regular contact with the safeguarding, complaints and compliance and country or region teams

It’s essential you send updates of an ongoing investigation. 

If the investigation is taking a long time, make sure you update HQ and country or region teams at least once a month.

Follow up on any agreed actions

At the end of an investigation there may be actions that were agreed upon. Please follow these up in a timely way. If this hasn’t been possible highlight to the HQ or country or region team (depending on who the action’s for) so they can be followed up. You could incorporate them into your meeting notes or assign someone to monitor the actions separately. 

Honest conversations  

There may be times when you need to have conversations that are challenging or involve sensitive matters. We appreciate this can be a demanding part of the role, so if you need support please don't hesitate to discuss this with your commissioner, country or region team or HQ. 

It may be a volunteer who’s had a concern raised about them, so it’s important to have conversations to establish their side of the story. Investigations may also require you to have honest conversations with people outside of Girlguiding. This could include a parent, carer or even a member of the public who’s raised a concern.

• Take a look at our approaching sensitive conversations page for guidance.
• Use our honest conversations template. 

During the conversation

Although you may have a plan of what needs to be discussed during your conversation, it's important to remember that the person you're speaking with needs to have their say and be listened to. 

If speaking with a volunteer about their conduct, they need to have the opportunity to contribute to the discussion and influence the outcomes. If speaking with a complainant, remember to consider and note what their desired outcomes of the investigation would be. Manage their expectations if required.  

Consider the terminology and language you use for the conversation. Pitch your conversation to the person you’re talking with so there’s an understanding of what has been agreed. It’s also important to think about if there are any reasonable adjustments that need to be made that may require extra consideration when you speak.

Please remember to make notes of any key points raised and any agreed actions during your conversation. The other party must receive a written copy of meeting notes or their statements so they can confirm what they said.

If a volunteer has disclosed information about their health or a disability, this is strictly confidential and mustn’t be shared with anyone else without the volunteer's permission.

However, if a disclosure is revealed as part of the conversation and you feel a girl or volunteer may be at risk of harm, or at risk of harming others, then full confidentiality can’t always be maintained. If you have a concern about a girl or volunteer and need support, please contact the HQ safeguarding team. 

After the conversation  

Make sure you keep a record of the conversations you’ve had as part of the investigation process. Share the confirmed conversation notes, including the agreed actions and outcomes, with the relevant HQ team when you complete and submit your report.   

Remember to follow up on any actions you agreed to and continue to keep the parties involved updated with the process as appropriate. 

If you have cause for concern following any conversation you have as a result of an investigation, please refer to the support section of this toolkit. Support is available for you, as well as individuals involved in an investigation, so please don’t hesitate to reach out. 

3 key things to remember

• Pick the right moment.
• Be prepared.
• Keep an open mind throughout.

Before you send your finalised investigation report to the relevant HQ staff member, you’ll need to consider the following questions: 

Have you spoken to all the relevant parties? 

If you did, have you confirmed the accuracy of your conversation notes with the parties? 

If you didn’t, why wasn’t this possible and are you able to comfortably share this justification in the outcome report?  

Have you reviewed all relevant physical evidence? 

This includes paper documents, photographs, emails, texts, social media posts and any relevant Girlguiding policies and procedures. 

Have you given the person who raised the concerns a second opportunity to respond or discuss anything new that has come up during the investigation? 

This isn’t always a necessary step, but if the person raising concerns is being accused of something it will be helpful to talk it through with them before writing the report.

Do you need any additional information from Girlguiding HQ? 

This may be guidance from a specific team on issues like insurance or equality and diversity. It may even be legal advice. 

If the concerns raised are connected to an insurance issue it may be useful to gather additional information about the risk assessment or the steps that the Insurance team have already taken.  

The purpose of an investigation report is to give the HQ teams a full overview of the formal investigation you’ve conducted. You should have the collated evidence and statements to form the basis of your decisions about the concerns. Your rationale underpins the suggested outcomes.

Keeping an accurate record of the steps you’ve taken throughout the investigation will make writing your report much easier. Completing all the sections in the investigation report will help you with this.

Accurate reports will allow the HQ teams to consider any appeal requests without having to ask you significant additional questions. It also means that you can confidently delete any remaining information you have at the end of the investigation once the appeal period has passed.   

Although the report won’t be shared with the parties involved with the case, it should still be written in as factual a way as possible. So don’t include opinions or personal feelings. Your suggested outcome needs to be based on evidence, and we need to be able to understand how you reached your outcome.

Once finalised, the report needs to be sent to the relevant HQ team. The HQ staff member who's been supporting you may ask you for more information so that they’re satisfied that the investigation and report have met all objectives.  

We recommend that you arrange to speak with the relevant HQ team before submitting your report. We’re keen to help and can offer advice if you feel stuck or unsure.  

The relevant HQ staff member will write the outcome letter once the investigation report has been submitted and the outcome discussed.

Outcome letters, or emails, are required for complaints and compliance investigations to provide the relevant parties with a full and clear outcome to the investigation you've completed. 

In most cases the people who require an outcome letter include:

• Any person subject to investigation.
• The person who raised the concern. Any sanction put in place will be confirmed in writing by the relevant team. 

We don’t share details of any sanctions or management actions taken against volunteers with the person who raised the concern, and they don’t have the right to appeal any decision regarding a sanction.  

Investigations can be a stressful process for everyone involved with the investigation, particularly for volunteers under investigation.

Each situation will be different and should be treated as such. When addressing concerns with adult members, remember that the individual is likely to feel upset by the situation. It’s important that everything is done fairly, openly and reasonably. 

If a volunteer has been suspended, this needs to be reviewed every 4 months. Make sure this is followed up.

Reasonable adjustments

Girlguiding is an inclusive organisation. This means that no member or volunteer should be disadvantaged or experience less favourable treatment as a result of the protected characteristics included in our equality and diversity policy.

This also applies to investigations. It’s important to consider if there’s anything that may act as a barrier when carrying out your work. For example, if there are cultural differences it may be relevant to take extra care with language that’s used in your communication.

There may be times when someone involved with an investigation has additional needs. When we talk about additional needs, we refer to those with physical disabilities, learning difficulties, sensory disabilities and people with mental health conditions.

If a volunteer or member who’s involved with an investigation tells you about their additional needs, please ask them if they need anything to make the process more manageable. It’s important not to assume what reasonable adjustments they’ll need, they themselves will be in the best position to let you know if they need extra support.

If the person has a visual impairment,  they may prefer to have communications in text format. This is so it can be read by a screen reader when they need to refer back to this information. An adjustment you could make as an investigator would be to ensure there’s a note-taker present at all meetings who can type up what’s been said and send this across to all parties following the meeting.

For more information about making reasonable adjustments please check our advice on making adjustments. If you have questions about inclusion or would like specific advice please email our volunteer support team at [email protected]. 

Safe practice liaison volunteer (SPLV)

Not everyone has someone they know who can support them through investigations. This is where the SPLV role comes into place. SPLV’s can be given to all volunteers including those who don’t have someone they know who can help them. The SPLV will be a volunteer with specific skills and experience to perform this function. 

They aren’t able to contribute to the investigation but can be there to ensure a fair representation and allow the meeting to feel more comfortable for the person being investigated.

Mental health support 

Investigations can sometimes be very challenging for those involved. Difficult feelings may come up and this unfortunately can have a negative impact on mental health.  
If you think it might be helpful, there is a wellbeing action plan for volunteers. 

This provides an outline of what you can discuss with the volunteer about what support they may need if their mental health is being affected. It gives the volunteer the opportunity to explore what they’re finding hard and what their support network, including local guiding, can do to help them through this time.

If you’d like to further your understanding of mental health and inclusion there is an e-learning on our learning platform. It goes through practical examples of what you can do to create an inclusive environment and what you can do if you recognise someone is struggling with their mental health.

Please remember that it's not your role to be a mental health professional during Girlguiding investigations. If you feel a situation requires external specialist support, there’s information below about where you can go.

If you have concerns about a volunteer's mental health, please contact our safeguarding team for advice. If the situation is urgent and the volunteer poses a risk to themselves or others, please reach out to the relevant emergency service.

Signposting to additional support 

Sometimes you might need external support, particularly if you feel the investigation may be having a negative impact on a volunteer’s mental health.

We have access through Wisdom (formerly Health Assured) to an assistance programme for our volunteers. This includes a range of confidential support services such as counselling. This is provided by Girlguiding and is free for the volunteer to access.  Please get in touch with the safeguarding, safety and wellbeing teams so they can share more details with you about how you can access this. 

On our support organisation page you can find some additional information about who can support volunteers, girls and their families to cope with challenges like child protection, mental health and sexuality.

These organisations can be helpful if you think specific expertise would help a situation. If you’d like any further advice on external support or signposting, please reach out to the safeguarding team who can chat through different options with you. 

We understand that being an investigator can be a difficult role. Sometimes these cases will ask you to look into complex situations. Not only can this be stressful, it can also be upsetting.   

If you need support with any part of your role, please don’t hesitate to reach out. The safeguarding, safety and wellbeing team at HQ, the safeguarding and complaints and compliance lead volunteers, the country or region teams and fellow commissioners would be happy to help with something you’re finding difficult. They can offer advice if you’re feeling stuck, ask another volunteer to support with your workload or take the case off your hands.  

Additional support  

We’re able to signpost volunteers to a free confidential service that can offer you someone to talk to, support, and counselling sessions if needed. Please enquire with the one of the safeguarding, safety and wellbeing teams if you’d like to access this service.  

Keeping yourself safe  

Never put yourself in danger to deal with a safeguarding, complaint or compliance issue. Girlguiding does not expect you to do so.

If you’re worried about your own safety, seek help from your local leadership team as soon as you can. There may be occasions where you feel you aren’t the right person to manage a concern because of the nature of the concern.

You are not alone. Ask for help and support from your team or the HQ teams.  

Moving on after an investigation  

Following an investigation, relationships between volunteers might be damaged, people might be feeling hurt, and it can seem difficult to move on as a team. If the volunteer who was under investigation remains active in Girlguiding, there are some things that may help moving forward easier.  

Top tips for moving on  

• Communicate what’s happened and that the situation has been addressed: ensure that the outcomes and learning have been discussed with all the adults involved in the investigation. This can be done together or by meeting individuals, whichever’s most appropriate. Make it clear that this particular concern has been addressed and won’t be discussed further.  
• Celebrate success: continue to highlight great guiding and the contribution of all individuals to local guiding. This will help other volunteers feel appreciated despite any difficult situations that may have happened. 
• Focus on the positives that have come from the investigation: investigations can often highlight a need for things to change. For example, you may need to recruit more volunteers to a team or try a different way of doing things. 
• Encourage volunteers to look forward:  keep team communications positive and look forward to what you’re going to achieve in the future.  

However, sometimes the most supportive thing you can do to help a volunteer move on is to help them find a new unit. This should only be explored if this is something the volunteer has asked for themselves or relationships within the unit have broken down beyond repair. The volunteer may be more comfortable having a fresh start somewhere new.   

Personal data (or personal information) is information that allows you to identify an individual. Personal data includes information about an identifiable individual. Examples include name, address, date of birth, email address, social media handle, photos and videos. Personal data also includes things like a person’s religion, beliefs, health issues and gender identity.

The managing information procedure outlines how best to manage personal data. You must follow this so you can be sure that all the information held by Girlguiding is protected, and that you’re following data protection legislation. 

The reporting a data breach procedure outlines what a data breach is and how to report one. If a volunteer has caused a breach by not following Girlguiding policies and procedures or selling data on, this is a breach of the code of conduct and may affect their membership. However, if the breach was the result of an accident, the data protection team will do their best to help.

Privacy notice for investigations

It’s important that anyone involved in an investigation understands what happens to any data that they share with us. To make this as clear as possible we have a privacy notice for investigations. 
 
At the start of an investigation the link to this privacy notice will be shared with everyone involved. The relevant HQ staff member will make sure that you’re supported to do this as part of the investigation process.

Email addresses

We recommend commissioners use generic emails for their roles that can then be passed on once this role has ended. This means that if a case hasn’t closed, the volunteer who takes over from you can continue the investigation.

Having a generic email address will also protect your own personal data as it’s likely you’ll be using this account to contact volunteers, parents or carers and sometimes people outside of Girlguiding. 

Anonymity 

Sometimes complaints cases will be passed on for investigation anonymously. This means that the details of the complainant will be removed from the information sent across to you. The investigation process would be the same for these cases. The only difference is you won’t need to speak with the complainant or provide them with a final outcome once the investigation has finished.

Girlguiding can’t stay anonymous when making a safeguarding referral, but the safeguarding staff member won’t give the name or details of the referrer unless required by law. Again, the safeguarding practitioner will advise the referrer of their action.

Confidentiality 

During investigations, important case details are only shared on a need-to-know basis. You’ll probably be handling a lot of personal data, so take care with your communications relating to the case. The volunteer code of conduct asks volunteers to ’respect privacy in line with our policies and guidance’ – this applies to investigations too.

Sensitive information must remain confidential. Information should be disclosed only on a need-to-know basis. In most circumstances, the details of a confidential matter should not be disclosed below county level. For example, avoid disclosing to parents, carers or other volunteers why a person is no longer carrying out a role in guiding. It’s fine to say that someone suspended is on a break.

However, it’s important to note that confidentiality can’t always be promised. If a disclosure is revealed as part of the investigation and you feel a girl or volunteer may be at risk of harm, or at risk of harming others, then full confidentiality can’t be maintained.

If you have a concern about a girl or volunteer and need advice or support then contact the HQ safeguarding team. 

Storing and sharing investigation files

Keep the investigation information on a secure device that’s password protected and shared with only those who need to see it. 

When reporting to HQ, make sure you’re not overheard by anyone around you. This could compromise the security of the personal information.

When reporting via email, please make sure you’re not using a public computer. Make sure that any emails are sent securely and to the intended recipient. And delete any emails after you’ve received and read them.

To protect personal data as much as possible, please use initials instead of full names in your correspondence. 

It’s also best practice to password protect reports. This reduces the risk of a data breach when you email them. Please send over the password (usually your own membership number) in a separate email. Or just let us know that this is what you’ve used so we can look this up on GO.

Archiving investigation files

Once a case has been closed, please confirm with the relevant HQ staff member that you’ve sent us all the relevant records. When we have all these records and have confirmed the case is closed, please destroy or delete any copies you have. The relevant HQ staff member will make sure that an appropriate record is kept at HQ in line with our retention framework.