Anyone receiving or investigating a concern must follow the investigation procedure
When Girlguiding considers that an adult volunteer may not have met our expectations, an investigation into those concerns must be carried out, to establish the circumstances and whether those concerns are dismissed or upheld.
Who is this procedure for?
This procedure is designed to be used by an investigator appointed by Girlguiding. The investigator will be asked to look into a concern raised under our safeguarding, complaints, managing concerns about adult volunteers or whistleblowing procedures.
An investigator can be a senior volunteer or independent person. In all cases they must be impartial and unbiased.
Where an investigation is in relation to an appeal, the approach, remit and timeframe will be agreed with the investigator.
Anyone receiving or investigating a concern must follow the below procedure. This should be read together with the relevant policy and procedure mentioned above.
Anyone who is involved in an investigation must follow Girlguiding expectations as set out in our volunteer Code of Conduct.
Please note, this procedure does not apply to safeguarding cases being led, and investigated, by statutory agencies.
'Audit trail' - a complete record of all the actions, communications, evidence and other activities that take place as part of the investigation.
'Subject' - refers to a person/people of interest or an incident.
'Complainant/referrer' - refers to a person/people who raised the issue or concern. This can be an adult volunteer, young member, parent, commissioner, Girlguiding staff, statutory agency, third-party organisation or member of the public.
'Investigation' - the formal process of thoroughly looking into and examining something in order to gather all available information and become fully informed about it. Investigations are objective and impartial and should be undertaken without a specific outcome or conclusion in mind other than the presentation of the information.
'Investigator' - the person who has been appointed to undertaking the Investigation.
'Evidence' - anything tangible that you might come across whilst undertaking an investigation that contributes further information. This could include; letters, emails, attendance registers, photographs, video, forms, payment records and many others.
'Case Log' - a summary outline of every single action and communication that takes place relating to a case.
'Terms of Reference' - essentially a statement of purpose and a set of instructions. They provide a framework for the investigation and sets out what will be looked into, who will do what and when and how the information gathered will be presented and used.
'Safe practice liaison volunteer' - an individual within Girlguiding who is assigned to provide support to someone taking part in or a volunteer who is the subject of an investigation.
How do you manage an investigation?
As an investigator, it is important to follow our procedures and timeframes as outlined below when any concern is being investigated.
Although the investigation is carried out by the appointed investigator, they must keep the relevant commissioner or member of staff up to date. Any safeguarding concerns must be reported to the HQ safeguarding team who will keep in regular contact with the appointed investigator.
The relevant HQ team and/or region lead can offer advice and support at any point of the investigation but will not take on the role, or any related responsibilities, of an investigator, unless with prior agreement.
You should feed back your findings of the investigation to the relevant commissioner, region team and/or relevant Girlguiding HQ team.
After a discussion with whoever has raised the concern, a relevant Girlguiding member of staff or volunteer will make a decision as to the most appropriate way forward and whether a full investigation is required. For safeguarding concerns the assessment will be made by the HQ Safeguarding team.
If an investigation is identified as the appropriate action, an investigator will be appointed by a relevant Girlguiding staff member or county/region volunteer, and an investigation will be initiated (see step 1).
Some concerns or feedback may be resolved informally. The concern will be referred to the relevant senior volunteer for further resolution, support and learning. The concern can later be referred to the investigation stage if required.
Although an informal resolution does not need an investigation report, all parties involved must still be spoken to and sent a written closure and/or copy of any relevant meeting notes. If it was referred by HQ, a copy of the informal resolution must be sent to the relevant team.
Undertaking the investigation
Circumstances where an informal resolution may not be appropriate include:
- Where further information, clarity or evidence needs to be gathered from others
- Where there is evidence to suggest a serious breach of Girlguiding policy and procedure
- Where there is a concern that a criminal offence has taken place, for example theft
Step 1: Investigation initiated
The concern will be sent on to the most appropriate person for investigation, as set out in the relevant policy or procedures. For all safeguarding investigations and some complex investigations, a Terms of Reference will be created to set out the rationale and parameters of the investigation.
An adult volunteer who is subject to investigation should be told so verbally, preferably in person by their commissioner.
If appropriate, the volunteer will be allocated a safe practice liaison volunteer within seven days of being informed of the investigation. If you feel the volunteer would benefit from additional support please contact the relevant HQ team and signpost them to appropriate support organisations.
Step 2: Carrying out the investigation
The investigator must speak to the person raising the concern before contacting any accused party or relevant witness. The Investigator must meet with or talk to the person raising the concern separately to any accused party or relevant witnesses.
The investigator must give an honest and fair outline of the concern(s) to the accused party and give them an opportunity to respond.
You can find guidance about approaching honest conversations.
The investigator should:
- Acknowledge/inform that the concern has been received
- Indicate how they propose to deal with the matter
- Give an estimate of how long it will take to provide a final response
Any individual who is invited to attend a meeting as part of an investigation has the right – if they so wish – to be accompanied by a safe practice liaison volunteer.
The investigation will involve gathering all the relevant facts from the person raising the concern, any accused party and relevant witnesses. This includes statements and documentary material as outlined below.
- Emails sent and received: this will include any contact the investigator has with relevant parties, as set out above.
- Evidence collected: relevant parties should be offered an opportunity to contribute any additional evidence.
- Interviews/statements: the investigator will interview and/or collect written statements. If an interview took place a ‘statement’ is completed for each person interviewed.
- Emails confirming statements: where a statement is written by the investigator following a meeting the individual, that individual must be sent a copy in order to get their formal agreement on its content. Statements must be confirmed or amended within 10 days of the interview being conducted.
Statements for the accused party must include details of the behaviour or conduct being investigated.
The investigator will regularly keep all parties up to date on the progress of the investigation. We recommend that all parties receive an email update at least once a month.
Where the concern has been referred by HQ, the relevant team must also receive updates.
If at any time during the course of an investigation new information emerges that suggests there could be a safeguarding issue or that a crime has been committed, the investigator must contact the Safeguarding team immediately. You don’t need to be certain that there is a safeguarding risk or criminal activity – a suspicion is enough to suspend the investigation until you have taken advice. The Safeguarding team will advise and support on next steps, including informing those involved.
Step 3: Report produced
The investigator uses the collated evidence and statements to form the basis of their decisions about the allegations.
- Produce report: the investigator will produce a final report detailing actions taken and their findings. The report should follow Girlguiding’s report template (available on request).
Step 4: Report reviewed
- Once finalised, the report is presented to the relevant HQ/country/region team. They must confirm whether they are satisfied that the investigation and report have met all objectives before an outcome letter will be produced for relevant parties.
Step 5: Findings shared
- Commissioner contacts any accused party: where the investigation has addressed concerns regarding a volunteer’s conduct or actions, that volunteer must be contacted by their local commissioner within 2-3 days of the report being agreed. This must be done prior to any outcome letter being sent to the individual(s) who raised a concern. Contact is preferably made face to face or via telephone.
If a sanction or risk assessment must be put in place, the volunteer will be informed as part of this conversation.
Any risk assessment should be discussed with the volunteer to identify risks and any subsequent actions, using the Risk Assessment form. This must be completed within 14 days of the outcome being shared.
If a serious sanction, such as instant withdrawal or restriction, is put in place this contact will be sooner. Any sanction put in place will be confirmed in writing by the relevant team at HQ.
- Outcome letter sent to the person who raised the issue: this is sent by the investigator/relevant team at HQ to inform them of the outcome. This should be sent within 7 days of the final report being agreed.
We do not share with complainants’ details of any sanctions or management actions taken against volunteers, and a complainant does not have the right to appeal any decision regarding a sanction.
We do not share with any of the parties above any recommendations specific to Girlguiding’s working processes.
Step 6: Case closed
- Retention: the investigator will confirm all correspondence and relevant information has been passed on to HQ for secure storage and deleted from their own device. HQ will retain all relevant information in line with the relevant retention policy.
- Identify measurements for improvement: if any recommendations have been made as part of the investigation, these will be passed on to HQ and/or country/region for review.
- Ensuring confidentiality and following Girlguiding’s Information Management Policy: Girlguiding share and store information in line with the Data Protection Act 2018 and GDPR. All investigators are subject to these laws and must follow Girlguiding’s managing information policy.
Investigators must ensure the following:
- Keep information (including emails, information collected during interviews and any meeting notes) on a secure device that is password-protected and shared only with those required to view it. Alternatively, this can be stored away in a locked cupboard with restricted access to those that are required to view the information.
- When reporting to HQ, make sure any phone conversation cannot be overheard by anyone else as this could compromise the security of the personal information.
- If reporting via email, do not use a public computer. Make sure that the email is sent securely and to the intended recipient.
- Any information/evidence collected during an investigation must be sent to the relevant HQ team at the end of the investigation alongside the outcome report. The investigator should then safely destroy any copies held by themselves within 14 days.