Taunton Deane Bowling Club Safe Use of Changing Facilities and Toilets

Introduction

This policy has been developed using the Safe Use of Changing Facilities (CPSU Briefing) – NSPCC Child Protection in Sport Unit (the cpsu.org.uk).

As Taunton Deane Bowling Club has changing and toilet facilities which are shared by adults (over 18) and children (under 18) consideration has to be made as part of the club’s duty of care to children and its safeguarding responsibilities for vulnerable adults.

Leisure facilities have established guidelines that any child below the age of 8 years must be accompanied, however there is no specific legal requirements regarding the use of changing facilities.

Separate changing and toilet facilities must be available for males and females. Gender neutral toilets, which are increasingly provided in many settings, are acceptable.

If mixed use of changing facilities by adults and children is unavoidable, at least 2 members of the club, of the same gender as the children/vulnerable adults should supervise the group.

Or if adults and children/vulnerable adults need to share a changing facility the club must have consent from parents/carers that their child(ren) can share a changing facility with adults.

Supervision in the changing facilities may also be necessary when:

· The individual(s) are too young to be left alone (under 8 years old) or are unable to change themselves.

· The individual(s) require additional support and assistance.

· There are concerns about bullying, fighting or other harmful behaviours taking place that need to be managed.

· There are concerns about the prospect of photographs being taken.

Parents and carers are often involved in supervising children or vulnerable adults during sports activities, where they are responsible only for their own child/children (or by agreement their relatives or friends’ children) this activity constitutes a private arrangement outside the responsibility of the club or club representatives.

However, when parents/carers undertake a formal supervisory role at the request of the club, or club representative, which includes having responsibility for other people’s children this becomes the club’s responsibility. There should be 2 members supervising, of the same gender and who are suitable for the role. It is the club’s responsibility to ensure these members are suitable, this can be done with DBS checks, self-declaration or references from recent employment when working with

children. Good practice would include a role description outlining the boundaries of the role and a signed code of conduct clarifying the standards of behaviour expected by club members in this role.

Boundaries of role

There should be careful balance of the needs for supervision with the rights of the child/vulnerable adult to privacy in this context.

There should be 2 supervisors, so if one has to leave there is still someone present.

It is preferable these volunteers have a current, valid DBS.

Supervisors should not continually enter and exit the changing facilities; they should be vigilant but not overly focussed on the children/vulnerable adults thus preventing privacy.

Mobile phones and cameras in changing rooms

There has been a growing number of reported incidents involving inappropriate or illegal photography of children and vulnerable adults in changing areas.

Some incidents clearly involve an individual with bad intent deliberately targeting vulnerable children and adults with the intent of misusing the images. These images can be uploaded to social media, shared with other likeminded individuals or groups motivated by sexual interest. On occasions these types of images have been used to threaten and force the individual into unwanted and illegal sexual activity.

Upskirting, where a picture is taken under an individual’s clothing without their permission or knowledge is a criminal offence in England, Wales and Northern Ireland.

Taking and sharing images can form a wider bullying of the targeted individual motivated by a wish to cause humiliation and embarrassment. Even without abusive intent the taking and sharing of inappropriate images may constitute a serious offence and risk criminal prosecution.

As it can be difficult to be sure whether someone using a mobile phone is actually taking a picture or video, many facilities have banned the use of mobile phones and other equipment capable of taking images from changing areas.

Transgender and transitioning children

In most cases, children who are able to identify as transgender are also able to articulate their wishes effectively. There are several factors to consider when addressing the needs of transgender or transitioning children with regard to changing and toilet facilities.

These include:

• the child’s feelings and preferences about which gendered changing room/toilet they would like to use

• the privacy of the child

• supervision

• any risks of bullying or unwanted behaviour towards that child.

If a child self-identifies as a gender that differs from the gender they were assigned at birth, they may ask for privacy or ask to start changing with other children of the same gender identity. This area of inclusion for adults and children is covered by documentation from the Government Equalities Office. It states: ‘A trans person should be free to select the facilities (such as toilets or changing rooms) appropriate to the gender in which they present.’ The Equality Act 2010 identifies gender reassignment as a protected characteristic.

Clubs and other bowls organisations should plan to educate other children/adults on gender identity and celebrating difference reducing the risk of misunderstanding, bullying or distress.

Policy contents

Taunton Deane Bowling Club have agreed the following to minimise risks to children and vulnerable adults in the Clubs changing and toilet facilities.

· Where possible children/vulnerable adults should come to the club changed and ready to play so reducing the need for changing facilities.

· Children/vulnerable adults should be encouraged to use the Inclusive toilets rather than the communal facilities.

· If mixed use of changing facilities by adults and children is unavoidable, parents of the children involved should supervise them.

· If adults and children/vulnerable adults need to share a changing facility but the parents/carers are not present the club must have written consent from parents/carers that their child(ren) can share a changing facility with adults.

· If the children/vulnerable adults are present at the Clubs request then at least 2 members of the club, of the same gender as the children/vulnerable adults should supervise them. It is preferable these staff have a current, valid DBS.

· It has been agreed that for the safety of children and vulnerable adults and the protection of all Club members that the use of mobile phones is banned in the changing areas. Clear signage to this effect will be put in place.

 

 

First Issued
Date of review