Support and resources to help you carry out Safe Practice investigations for Girlguiding
Investigations can take a lot of work and time.
So we’ve created extra guidance, resources and support to help you carry out Safe Practice investigations for Girlguiding. This guidance here applies to all Complaints and Compliance investigations and Safeguarding investigations that aren’t being led and investigated by statutory agencies.
Working with the Safe Practice department
Investigations carried out for Girlguiding sit within our Safe Practice department. The department is made up of the Complaints and Compliance team, the Safeguarding team and the Safe Practice team. Together we make sure Girlguiding is a safe and fair environment for our young members and volunteers.
When Girlguiding considers that an adult volunteer may not have met our expectations, an investigation must be carried out to establish whether those concerns are dismissed or upheld.
The Safe Practice department oversee investigations into matters raised about specific events, incidents or concerns. We work closely with investigators, usually Girlguiding commissioners, who help us get to the bottom of what happened, what the next steps need to be and what we can change to prevent a similar situation from reoccurring and improving what we do.
Which type of investigation is needed?
The Safe Practice teams will let you know what type of investigation would be required when we send a case over to you for investigation. However, if you receive a concern directly, it can be helpful to know what team it would be best placed to support you. Below we’ve included some information to help you identify where a concern may sit:
Are there concerns that a young member and/or vulnerable adult is experiencing, or is at risk of experiencing, harm?
- Yes: refer the concern to the Safeguarding team. They will begin an investigation in line with safeguarding policy and managing concerns about adult volunteers policy.
- No: refer the concern to the Complaints and Compliance team. They will begin an investigation in line with the complaints, whistleblowing and managing concerns about adult volunteers policies. The team will place any sanctions required.
Any Safe Practice concern can come from an adult member, volunteer, commissioner, young member, parent/carer, member of the public or statutory agency.
Remember that the Safeguarding team should be informed if there is ever a concern that a young member and/or vulnerable adult is experiencing, or is at risk of experiencing, harm.
Sometimes a complaint may be received regarding an ongoing investigation, or interventions to manage a volunteers' code of conduct. It may be necessary for an investigation to be assigned to look into both this complaint and the initial concern. The Complaints and Compliance team will advise the investigator if this is required.
Complaints are concerns that relate to a specific situation, event, volunteer or staff member. These can cover a wide array of topics including inclusion, communication, GO records and local events.
Any concern that is commentary directed towards Girlguiding as an organisation is handled by the Volunteer Support team, as this does not require local investigation. These cases are categorised as feedback.
Complaints are usually raised by parents/carers, young members, volunteers or members of the public. These have the scope to 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 do not 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 we will consider what sanctions may be necessary.
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 temporary measure that prevents an adult volunteer from carrying out their Girlguiding roles while the investigation is taking place. This is a neutral act to ensure young members and volunteers are protected while the case is ongoing.
Once an investigation is complete, it may be necessary to put a sanction in place like an improvement plan, formal advice or a role restriction. In more serious cases, the volunteer’s membership may need to be withdrawn.
The recruitment and vetting of our volunteers is managed by the Complaints and Compliance team. They ensure that each of our volunteers have completed the required vetting for their role and have completed A Safe Space training to the appropriate level.
If a Girlguiding member, or a person enquiring to become a member, fails to meet the requirements it may be necessary to refuse or withdraw their membership.
The Complaints and Compliance team are also responsible for overseeing investigations under the Whistleblowing policy. Girlguiding staff, volunteers and members can raise it with this team if they have a serious concern about something taking place within the organisation.
Safeguarding cases focus on concerns, allegations or disclosures relating to an adult’s or child’s safety or welfare. Cases may also be about the potential risk a person may pose, or relate to 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 is a part of Girlguiding. Sometimes safeguarding investigations are carried out by other organisations that also work with the volunteer or young person involved (like The Scouts Association) as they are in a better position to lead and address the concerns.
If required, safeguarding investigations may result in sanctions or withdrawals. It may also be necessary to refer concerns, allegations or disclosures on to statutory agencies, like the local authority designated officer (LADO), children services or police to carry out further actions.
The Safe Practice team will assess the risk of each case and categorise them using our traffic light system. Red cases are the most serious, then amber and finally green. All Safeguarding concerns are categorised as red, but Complaints and Compliance concerns can sit within any of the three categories.
By categorising our cases it helps us keep track of the concerns that come through, and what needs to be prioritised. Below you’ll find an explanation of what defines each of these categories.
- 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/procedure has allegedly been breached but does not meet red case threshold.
- Concerns with ratios at unit meeting or residential in the past
- Poor conduct that may affect an upcoming unit meeting or event
- Financial mismanagement (not yet ready to report to police)
- Roles added on restricted members (once assessed)
- No policy/procedure was breached
- A very low-level concern
- A concern relating to a joining enquiry
- Issues surrounding organisation or running of meetings, but no policy was breached nor was anyone harmed
Although all concerns need to be taken seriously, it’s sometimes helpful to bear in mind what risk category the case has been assigned to.
Red and Amber cases will require a formal investigation and, therefore, would require an investigation report from you. For these cases the Safe Practice teams may also provide you with a Terms of Reference, which will set out the rationale and parameters of the investigation. If you’ve not received a Terms of Reference and you feel this would be helpful, please reach out to the member of staff who passed the case onto you and ask them to provide this.
Many green cases will not require a formal investigation and an informal resolution will do. Find out about informal resolutions in the Investigation procedure.
There are sometimes instances where concerns raised do not require a formal investigation. These cases generally have the green risk category so an informal resolution may be appropriate. These concerns will be passed on 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
- There is evidence to suggest a serious breach of Girlguiding policy and procedure
- There is a concern that a criminal offence has taken place, for example theft
If a case cannot be resolved informally then the case must be addressed following the process as outlined in the Investigation procedure.
Take a look at the full Investigation procedure.
The Investigation procedure must be followed by any Girlguiding appointed investigator who is asked to look into a complaint, compliance or safeguarding concern. These are concerns that are raised under our Complaints, Managing concerns about adult volunteers, Safeguarding and Whistleblowing procedures.
An investigator can be a senior volunteer or independent person. In all cases they must be impartial and unbiased. This procedure does not apply to safeguarding cases being led, and investigated, by statutory agencies.
Resources to help with the investigation procedure
Use these documents to help you with your investigation:
Advice on reports and outcome letters
Before you produce an investigation report and outcome letters you will need to consider the following questions:
Were the concerns raised investigated formally or informally?
If the investigation was informal then you do not need to produce a formal report. A short email, phone call or letter outlining the outcome (and offering the right to appeal, if appropriate) will be sufficient.
If you formally investigated, then you should produce a full investigation report. This will vary considerably in detail and length depending on the complexity of the concern.
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 rebut or discuss anything new that has come up during the investigation?
This is not 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 an outcome.
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 Safe Practice teams a full overview of the formal investigation you have conducted. You should have the collated evidence and statements to form the basis of their decisions about the allegations.
Keeping an accurate record of the steps you have taken throughout the investigation will make writing your report much easier. We recommend you refer to the Investigation timeline in this toolkit to aid you with your record keeping.
Accurate reports will allow the Safe Practice 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.
Once finalised, the report needs to be sent to the relevant Safe Practice team and country/region team. They must confirm they are satisfied that the investigation and report have met all objectives before an outcome letter will be produced for relevant parties.
Remember that you can always arrange to speak with the HQ Safe Practice teams before submitting your report. We’re keen to help and can offer advice if you feel stuck.
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 have completed.
In most cases the people who require an outcome letter include:
Any person subject to investigation
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.
An outcome letter sent to any subject of investigation must be sent within 7 days of the meeting taking place or final report being agreed.
Any sanction put in place will be confirmed in writing by the relevant Safe Practice team.
The person who raised the issue
If a complainant is involved with the concern, then they should receive an outcome letter. This is sent by the investigator/Safe Practice team to inform them of the outcome. This should be sent within 7 days of the final report being agreed.
The outcome letter should always be written in a way that can be shared with the person who raised the concerns, or the volunteer(s) investigated as appropriate.
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.
It’s very important to include the right to appeal as a part of the outcome letter. This makes it clear what the next steps are for everybody involved. Once the outcome letters have been sent, any further communication can be passed straight over to the relevant Safe Practice team at HQ.
You can include the below text in your letter to explain the appeals process:
If you're not satisfied with the proposed resolution you can contact the HQ Complaints and Compliance team to request an appeal. You must submit your request in writing within 28 days of the investigation outcome letter.
You can find more information about the appeals process in our Appeals and review procedure.
The only times that we will accept an appeal are when:
- New information or evidence is brought forward that may change the outcome
- Our policy, procedure or investigation process has not been followed
We respond to appeal requests within 14 calendar days of receiving them. In complex situations we may extend this timescale – but we will let you know if this is the case.
For more information, please visit the Appeals and review procedure pages of our website.
Sharing your findings
Formal investigation findings should always be communicated in writing (by email or letter).
You can also arrange to meet or talk with the parties to explain the contents of the email or letter, but this is not always needed.
General investigation tips
Carrying out a Girlguiding investigation can be challenging at times. This section of the toolkit will provide some general guidance that investigators should bear in mind during the investigation process.
Take a look at our Managing challenging behaviour in adults page for guidance for dealing with difficult situations.
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 Safe Practice team and/or country/region team to delegate the case on to someone else.
Alternatively, if you feel you need an extension to the investigation timeframes set out, please get in touch with the HQ teams and we can help you create an investigation plan and/or help to 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 unbiased throughout the process. We know that Girlguiding has a wonderfully connected community and culture, but this can make investigating concerns about other volunteers quite challenging!
If you know the person you’ll be investigating too well, please do let the HQ teams or country/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 Safe Practice team and country/region team to indicate whether you’ll be able to investigate the case. Highlight any concerns you might have about being impartial.
Throughout the investigation
During the investigation it’s important confidentiality is maintained. For more guidance on this please visit the GDPR and 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 Girlguiding work to keep this communication separate. Consider using a separate phone, or hiding your number, when making calls to the relevant investigation parties. More details of keeping yourself safe can be found in the GDPR and Data Protection section of this toolkit.
It is often best practice to discuss and agree boundaries with the people you are 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 have carried out. It is important these records are factual and free from personal opinions.
This will make it easier when you write your report and if there is an appeal against your recommendations and decisions. You can find more information about this in the report writing section of this toolkit.
Consider perception and unconscious bias
This means being aware of our own views, beliefs and opinions. It is important to be aware of what we feel or think, especially if we are listening to a disclosure, or someone is reporting an allegation or concern to us. Conflicts with our own beliefs, values and opinions could prompt a struggle, which might delay us acting.
It's important to remain objective and focus on the facts we are told, rather than personal opinion or perspective. It is all our responsibility to listen, record, gather all the facts and pass on concerns to the relevant Safe Practice 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.
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 will 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 initial contact, use their preferred method. 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 allow them to find a confidential setting to take the call.
When carrying out investigation meetings bear in mind confidentiality, personal safety and accessibility
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.
If appropriate, let them know that support is available
When outlining the purpose of the conversation the person may indicate that they would 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 Support liaison volunteer to ensure to help them feel more comfortable.
Take care when leaving voice messages
If you can only make contact by phone, consider what message you would leave with another person or 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 have done all you can, and still have not received a response, you can send an email or letter stating a deadline for them to contact you.
Once this deadline has passed, send them a final email and/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/region team know that this is what you’ve done and include these details in your final report.
Make sure the person who is 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 as soon as possible. It may be important to consider when the next Guiding meeting or event is and make efforts to inform them before this takes place.
If you are not the volunteer’s commissioner, check that this conversation has taken place before you speak with the volunteer yourself.
Let those involved in the investigation prepare for meetings
Notifying people in advance of when you’re due to meet and letting them know what they can expect from the meeting, will allow them time to prepare. This will, usually, lead to a more productive meeting.
Keep in regular contact with those involved in the investigation.
It is 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.
Keep in regular contact with the Safe Practice and country/region teams
It is essential you send updates of an ongoing investigation every 2 weeks.
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 has not been possible highlight to the HQ/region team so they can be followed up. You could incorporate them into your meeting notes or assign someone to monitor the actions separately.
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/region team or HQ.
It may be a volunteer who has had a concern raised about them, so it is important conversations are had 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 has 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 code of 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 are talking with so there is an understanding of what has been agreed. It is 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 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 and/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 must not 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 advice or support, then 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 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 pages of this document. Support is available for you, as well as individuals involved in an investigation, so please don’t hesitate to reach out.
Three things to remember
- Pick the right moment
- Be prepared
- Keep an open mind throughout
Support for those involved with investigations and investigators
Investigations can be a stressful process for others 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 is 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.
Girlguiding is an inclusive organisation and this means that no member or volunteer should be disadvantaged by unjustifiable conditions or requirements, or experience less-favourable treatment because of any of the protected characteristics of the Equality Act 2010.
This also applies to investigations. It’s important to consider if there is 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 is 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 problems.
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 some extra support.
If the person has a visual impairment it may be the case that they would prefer to have communications in text format 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 is a note taker present at all meetings who can type up what has been said and send this across to all parties following the meeting.
For more information about making reasonable adjustments please visit the Making reasonable adjustment pages of our website. If you have questions about Inclusion or would like specific advice on how to make reasonable adjustments please email our Volunteer Support team at [email protected].
In exceptional circumstances, where the volunteer may have additional needs, it might be suitable for their role to be changed to supported volunteer.
This means the volunteer would not have any safeguarding responsibilities and would be assigned an individual volunteer supporter who would provide them with individually tailored support. This will help the volunteer continue to be a part of Girlguiding in an enjoyable and safe way.
If you feel you need any further information you can contact [email protected] for bespoke advice from our HQ inclusion team.
Support liaison officer
Not everyone has someone they know who can support them through investigations. This is where the supporter role comes into place. Support liaison volunteers should create a group of volunteers who may provide support if a volunteer doesn’t have someone they know who can help them. These will be volunteers with specific skills and experience to perform this function.
They are not able to contribute to the investigation but can be there to ensure a fair representation and allow the meeting to feel more comfortable for person being investigated.
Mental health support
Safe Practice 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 would like to further your understanding of mental health and inclusion there is an e-learning. 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 is 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.
Sign-posting to additional support
Sometimes external support may be necessary, particularly if you feel the investigation may be having a negative impact on a volunteer’s mental health.
We have secured access through Health Assured and another provider who offers an employee/volunteer 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 Safe Practice teams so they can share further details with you about how you can access this.
On our Support organisation pages you can find some additional information about who can support volunteers, girls and their families cope with challenges like child protection, mental health and sexuality.
These organisations can often be helpful if you think specific expertise would help a situation. If you would 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 a Safe Practice investigator can be a difficult role. Sometimes these cases will ask you to look into complex situations. Not only can this be stressful, but it can also be upsetting.
If you need support with any part of your role, please don’t hesitate to reach out for support. The Safe Practice staff at HQ, the Safeguarding lead volunteers, the country/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, they can ask another volunteer to support you with your workload or they can take the case off your hands.
We are able to signpost volunteers to a confidential service that can offer you someone to talk to, help and support and counselling sessions if needed. Please enquire with the one of the Safe Practice teams should you need further information and wish to access this free 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 are 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 are not the right person to manage a concern because of your own personal relationships or experiences, or 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 volunteer team in the future. 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 has happened and move on: ensure that the outcomes and learning have been discussed with all the adults involved in the investigation. This can be done altogether or by meeting individuals, whichever is most appropriate. Make it clear that once this particular concern has been addressed and will not be discussed further.
- Celebrate success: continue to highlight great guiding and the contribution of all individuals to local guiding. This will help other volunteers to 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 looking forward to what you are going to achieve in the future.
Sometimes, however, the most supportive thing you can do to help a volunteer move on from the negative impact of an investigation 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.
Protection personal data
The UK Data Protection Act 2018 gives everyone more control over how their data is used and how they are contacted.
As a Girlguiding investigator you will use personal data when looking into Safe Practice cases. It’s important to know how to manage personal information safely and legally.
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 are 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, which may affect their membership. However, if the breach was the result of an accident, the Data Protection team would do their best to help you.
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 work.
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/carers and sometimes people external from Girlguiding.
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 that you will not need to speak with the complainant or provide them with a final outcome once the investigation has finished.
Girlguiding cannot stay anonymous when making a safeguarding referral, but the safeguarding practitioner won’t give the name or details of the referrer unless required to do so by law. Again, the safeguarding practitioner will advise the referrer of their action.
During investigations important case details are only shared on a need-to-know basis. You will 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 the reason why a person is no longer carrying out a role in guiding. It is sufficient to say that someone suspended is on a break.
However, it’s important to reiterate that confidentiality cannot 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 information on a secure device that is password protected and shared with only 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 ensure you are not overheard by anyone around you as this could compromise the security of the personal information.
If reporting via email, please ensure you are not using a public computer. Make sure that the email is sent securely and to the intended recipient and delete after received.
To ensure personal data is protected as much as possible please use initials instead of full names in your correspondence.
It is also best practice to password protect reports so when you email them across there is a reduced risk of a data breach. 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 and we can look this up on GO.
Reporting to HQ
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.
Archiving investigation files
Once a case has been closed please confirm with the relevant HQ team that you have 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 within 14 days. The case officer at HQ will ensure that an appropriate record is kept at HQ, in line with our retention framework.
For more information
If you feel you, or a volunteer subject to an investigation, may benefit from some additional training there is an e-learning available online called Keeping information safe training.