Club Policies

Document Ref:	Complaints & Compliments Policy
Version:	7
Date of version:	August 2023
Author:	Paula Watson
Approved by:	Ryan Sparks, CEO
Confidentiality level:	Internal, Public

Amendment History

Date	Version	Author	Details of Amendment
November 2018	1	Paula Watson	Initial Release
July 2019	2	Paula Watson	Update to bring in line all policy annual reviews
September 2020	3	Lee-Ann Brewer	Annual Review and addition of compliments policy
March 2021	4	Paula Watson	New CEO
August 2021	5	Marco Townson	Appointment of a Supporters Liaison Officer & Customer Service Tiered System
August 2022	6	Paula Watson	Annual review
August 2023	7	Paula Watson	Annual Review

1) Policy Statement

Bradford City AFC welcomes comments and complaints from all members of the Clubs community. We use this process to improve our commitment to the players and staff (including volunteers) so we can provide a safe and enjoyable environment in which people can develop.

Bradford City AFC is committed to the continuous improvement of the services it provides. We recognise that, occasionally, mistakes will be made and this will not always meet the individual’s requirements or expectations. For these reasons it is Club policy that all complaints should be:

1.1 Received positively, treated seriously and in an open manner.

1.2 Acknowledged immediately, preferably in writing.

1.3 Investigated

1.4 Resolved, wherever that is reasonably practical, within no longer than 13 working weeks.

1.5 A source of learning with feedback used to ensure continuous improvement of the environment which the Club offers.

No complainant bringing a complaint under this procedure will be treated less favourably by any member of staff. If there is evidence to the contrary, the member of staff may be subject to disciplinary proceedings.

2) Scope

The policy applies to all members of the Club community but does not replace procedures for, staff grievances and disciplinary action; those procedures should be used where appropriate.

Safeguarding Complaints

Any complaints or concerns raised which relate to an individual’s conduct or behaviour and have potential safeguarding implications for any individual (child or adult) will be directed to the Designated Safeguarding Officer or Senior Safeguarding Manager. Where appropriate, these concerns will then be managed through Bradford City AFC’s Safeguarding and Children Protection Policy or Safeguarding Adults Policy and procedures. To report directly to a member of the safeguarding team, please email safeguarding@bradfordcityafc.com

Academy Complaints

Any complaints or concerns raised with regards the Academy will be directed to Head of Academy, Mark Litherland or if regarding Mark the Senior Safeguarding Manager or CEO (marked as ‘FAO: CEO RYAN SPARKS’ and sent to helpdesk@bradfordcityafc.com)

To report directly to Mark, please email mark.litherland@bradfordcityafc.com

To report directly to the senior safeguarding Officer please email Paula Watson paulawatson@bradfordcityafc.com

3) Responsibilities

3.1 The Club’s Supporter Liasion Officer (SLO) has responsibility for receiving complaints, escalating and involving appropriate persons where necessary, treating them seriously and dealing with them promptly and courteously in accordance with the procedure set out below.

3.2 ALL CLUB STAFF have responsibility for receiving complaints, treating them seriously and passing them to the supporter liaison officer, promptly and courteously in accordance with the procedure set out below.

3.3 The Club’s Designated Safeguarding Officer has responsibility for resolving a complaint and leading or contributing to an investigation into a complaint when this is considered appropriate.

3.4 The Academy Manager and/or Senior safeguarding Manager are responsible for resolving complaints that have not been resolved during the previous two stages. The decision made by the Academy Manager or Senior safeguarding manager is final.

3.5 The Club Board is responsible for ensuring that the complaints policy and procedure are operating effectively and may become directly involved if a complaint is directed against the Designated Safeguarding Officer, Senior Safeguarding Manager or The Academy Manager.

4) Action to Implement and Develop Policy

4.1 Tier One

The Club expects complaints to be made informally to a member of staff in the first instance. These concerns should be recorded by the member of staff and advice sought immediately if any safeguarding concerns are suspected or apparent. It is hoped that most complaints can be resolved at this level and any agreed action is captured in a record that is agreed by all parties.

Where it is not possible to address issues informally with an appropriate manager or initial staff responses do not result in satisfactory resolutions, the complaint should be submitted in writing to the Club’s Supporter Liaison Officer, Marco Townson.

Contact details:

Email: marcotownson@bradfordcityafc.com

Phone: 01274 773355 ext 223

The Club usually expects complaints to be made by the person concerned. BCAFC will, however, always consider complaints made by a parent or advocate as it is acknowledged that there are many reasons (including imbalances of power) that block people from making a complaint themselves.

It is very difficult to investigate anonymous complaints as there will always be information that cannot be gathered or clarified. Any complaints relating to potential safeguarding risks will however be taken seriously, including those which fall under the umbrella of the club’s whistleblowing policy and procedures.

The Supporter Liasion Officer will acknowledge receipt within one working week, and escalate to the relevant department or persons, or tier required.

4.2 Tier Two

The allocated independent staff member will respond in writing within one working week explaining what has happened as a result of the complaint. Where this involves a member of staff, specific details of action taken will not be made available. This is to ensure that our employees are afforded appropriate confidentiality and respect for their dignity at work.

If the complaint requires further investigation that cannot be carried out within the week, the investigating staff member shall keep the complainant informed and indicate the expected timescale for a response to be provided.

4.3 Tier Three

If the complainant is dissatisfied with the relevant investigating staff member’s response, then the complaint will be forwarded to a member of the Club’s Senior Management to resolve.

The Senior Manager will acknowledge receipt of the complaint and respond to the complainant within 8 working weeks to allow time for any further information gathering and investigations to be undertaken.

4.4 Tier Four

Complaints against the Supporter Liasion Officer, Designated Safeguarding Officer, Senior Safeguarding Manager or Academy Manager

Complaints against the Supporter Liasion Officer, Designated Safeguarding Officer, Senior Safeguarding Manager or Academy Manager should be marked as ‘FAO: CEO RYAN SPARKS’ and sent to helpdesk@bradfordcityafc.com

4.5 Tier Five

If the complainant is still dissatisfied they have the right to follow the English Football League (EFL) complaints procedure

Complaints should be made in writing and may be submitted by post to:

The Independent Football Ombudsman

Suite 49, 33 Great George Street, LEEDS LS1 3AJ.

or by e-mail to: contact@theifo.co.uk

or via the website: www.theifo.co.uk

5. Monitoring and evaluation

The club will maintain a confidential record of all complaints, appeals and outcomes and consider the learning from issues raised in order to assess what action if any would create a more positive experience and environment for those involved in participating in or providing club activities and to promote a safer environment. Themes and issues arising during each season will be collated and fed back to the Board to inform planning and priorities for the following season.

Compliments Policy

We value and encourage all kinds of feedback. Anyone who has a relationship with Bradford City AFC can compliment a member of staff, a team or the organisation. Compliments are passed on to staff and their line manager and are used to identify areas of good practice that we can learn from and further develop.

Compliments can be submitted verbally to any member of staff who will record and share this or can be submitted via email to helpdesk@bradfordcityafc.com or in writing to the stadium.

Compliments are used to enable service development and as part of individual performance development. Employees receiving compliments will be recognised appropriately.

EQUAL OPPORTUNITIES POLICY

Document Ref:	Equal Opportunities Policy – to be read in conjunction with commitment statement
Version:	6
Date of version:	July 2023
Author:	Paula Watson
Approved by:	Ryan Sparks
Confidentiality level:	Internal, Public

Amendment History

Date	Version	Author	Details of Amendment
Unknown	1	unknown	Initial Release
July 2019	2	Paula Watson	Annual review
July 2020	3	Lee-Ann Brewer	Annual review
March 2021	4	Paula Watson	New CEO
March 2022	5	Paula Watson	Annual Review
July 2023	6	Paula Watson	Annual Review and to bring in line with updated EFL Guidance

The English Football League is responsible for setting the standards, values and expectations of all Clubs in relation to equality, inclusion and diversity. Football is for everyone; it belongs to, and should be enjoyed by anyone who wants to participate in it, whether as a player, official, staff member, volunteer or spectator.

The aim of the Bradford City AFC Equality Policy is to promote our own equality objectives and in doing so, help to ensure that everyone is treated fairly and with respect. All Bradford City AFC representatives should abide and adhere to this Policy and to the requirements of the Equality Act 2010. In doing so, we are working towards being legally compliant in relation to equality legislation.

Bradford City AFC’s commitment is to promote inclusion and to confront and eliminate discrimination whether by reason of age, gender, gender reassignment, sexual orientation, marital status or civil partnership race, nationality, ethnicity (race), religion or belief, ability or disability, pregnancy and maternity and to encourage equal opportunities. These are known as ‘protected characteristics’ under the Equality Act 2010.

This Policy is fully supported by the Board of Bradford City AFC and the senior officer Paula Watson is responsible for the implementation of this policy.

Bradford City AFC will ensure that it treats everyone fairly and with respect and that it will provide access and opportunities for all members of the community to take part in, and enjoy, its activities. Every staff member, Board member, official, spectator, fan and visiting teams an be assured of an environment in which their rights, dignity and individual worth are respected, and in particular that they are able to work and watch football in an environment without the threat of intimidation, victimisation, harassment or abuse.

Complaints and compliance

Bradford City AFC regards all of the forms of discriminatory behaviour, including (but not limited to) behaviour described in the Appendix as unacceptable, and is concerned to ensure that individuals feel able to raise any bona fide grievance or complaint related to such behaviour without fear of being penalised for doing so. Appropriate disciplinary action will be taken against any employee, member or volunteer, spectator or fan who is found, after a full investigation, to have violated the Equality Policy.

Positive Action and Training

Bradford City AFC is committed to equality inclusion and anti-discrimination as part of The English Football League’s Code of Practice. Bradford City AFC will commit to a programme of raising awareness and educating, investigating concerns and applying relevant and proportionate sanctions, campaigning, widening diversity and representation and promoting diverse role models, which we believe are all key actions to promote inclusion and eradicate discrimination within football. This Equality Policy will be reviewed and updated, if required, on an annual basis.

Contact Details

Board Lead: Ryan Sparks – hello@bradfordcityafc.com

Lead Officer: Paula Watson – paulawatson@bradfordcityafc.com

APPENDIX – Relevant legislation and forms of unacceptable discrimination

Legal rights

Discrimination has been legally defined through a series of legislative acts, including the Race Relations Act, the Sex Discrimination Act, the Disability Discrimination Act and the Equality Act 2006.

In April 2010, the Equality Act 2010 received Royal Assent. The Equality Act 2010 is a new law which harmonises where possible, and in some cases extends, protection from discrimination. It applies throughout the UK and came into force in October 2010.

Discrimination refers to unfavourable treatment on the basis of particular characteristics, which are known as the ‘protected characteristics’. Under the Equality Act 2010, the protected characteristics are defined as age (employment only until 2012), disability, gender reassignment, marital or civil partnership status (employment only), pregnancy and maternity, race (which includes ethnic or national origin, colour or nationality), religion or belief, sex (gender) and sexual orientation.

Under the Equality Act 2010, individuals are protected from discrimination ‘on grounds of’ a protected characteristic1. This means that individuals will be protected if they have a characteristic, are assumed to have it, associate with someone who has it or with someone who is assumed to have it.

Forms of discrimination and discriminatory behaviour include the following:

Direct discrimination

Direct discrimination can be described as less favourable treatment on the grounds of one of the protected characteristics.

Indirect discrimination

Indirect discrimination occurs when a provision, criterion or practice is applied to an individual or group that would put persons of a particular characteristic at a particular disadvantage compared with other persons.

Discrimination arising from disability

When a disabled person is treated unfavourably because of something connected with their disability and this unfavourable treatment cannot be justified, this is unlawful. This type of discrimination only relates to disability.

Harassment

Harassment is defined as unwanted conduct relating to a protected characteristic that has the purpose or effect of violating a person’s dignity, or which creates an intimidating or hostile, degrading, humiliating or offensive environment for that person.

Victimisation

It is unlawful to treat a person less favourably because he or she has made allegations or brought proceedings under the anti-discrimination legislation, or because they have helped another person to do so. To do so would constitute victimisation.

Bullying

Bullying is defined as a form of personal harassment involving the misuse of power, influence or position to persistently criticise, humiliate or undermine an individual.

EQUALITY STATEMENT OF COMMITMENT

Bradford City, in partnership with our Academy and Community Foundation works across the city to be inclusive and anti discriminatory and work closely with the EFL, The FA, Kick it Out and Level Playing Field.

We want to ensure that the Club is a place that is child and family friendly, free from discrimination and unfair behaviour and will do everything we realistically can in order to achieve these objectives.

Bradford City Football Club is committed to promoting equality by treating people fairly and with respect; by recognising inequalities exist, by taking steps to address them and by providing access and opportunities for all members of the community.

Our commitment is to eliminate discrimination on the basis of gender, sexual orientation, marital or civil partnership status, gender reassignment, race (which includes colour, nationality, ethnic or national origin), religion or belief, disability, pregnancy and maternity or age. These are the protected characteristics of the Equality Act 2010.

We will ensure that we treat people fairly and with respect and that we will provide access and opportunities for all members of the community to take part in, and enjoy, our activities.

We will not tolerate harassment, bullying, abuse or victimisation of any individual, which for the purposes of this statement and the actions and sanctions applicable is regarded as discrimination, whether physical or verbal. This includes any form of 'Hate Crime' which is a crime targeted at a person because of hostility or prejudice towards that person's disability, ethnicity, religion, sexual orientation or transgender identity. The Club will work to ensure that such behaviour is met with the appropriate action in whatever context it occurs, including inappropriate posts through social media.

Bradford City Football Club is committed to promoting equality of opportunity for all staff and job applicants and requires all staff to abide and adhere to the equality legislation, Equality Act 2010, as well as any amendments to this act.

We commit to the immediate investigation of any claims, when it is brought to their attention, of discrimination on the above grounds and where such is found to be the case, a requirement that the practice stop and sanctions imposed as appropriate.

On matchdays we expect all fans to adhere to the EFL Ground Regulations and our ticket terms and conditions. Abusive or discriminatory language and behaviour is not acceptable.

The content of this statement applies equally to the treatment of our staff, customers, supporters, clients and suppliers and is fully supported by the Board of Bradford City Football Club.

If you have a complaint or witness an incident of discrimination, harassment or bullying it can be reported to Bradford City Football Club via our complaints procedure or to Kick it Out.

The senior inclusion officer leads the internal and external equality, inclusion and diversity strategy and steering group. All objectives, progress and any incidents are then reported to board level via email or in person. An annual report will be produced at season end and presented to the Chairman.

Key Contacts

Senior Inclusion Lead: Paula Watson paulawatson@bradfordcityafc.com / 01274 773355

Confidential Matchday Helpline: 07949 814243

Kick It Out Online Reporting at www.kickitout.org, freephone 0800 169 9414, or email report@kickitout.org or by downloading their app.

ENVIRONMENTAL SUSTAINABILITY POLICY

Version	Date	Author	Review Date	Signed
V1	June 2022	Lizzie Saunderson	September 2022	Lizzie Saunderson

Policy Statement

Bradford City Football Club (BCAFC) in partnership with Bradford City Community Foundation (BCCF) acknowledges its responsibility to act sustainably across all of its provisions and recognises its role as an ambassador in sustainable practices. BCCF, along with Bradford City Football Club, are committed to managing its activities and estates to promote environmental sustainability, create a positive culture of change within the workplace, educate and influence our users to think about their environmental impact, prevent environmental pollution and bring about a continual improvement in its environmental performance. This policy outlines the measures that the BCCF and Bradford City Football Club will take to embed sustainability into our provisions, identifies methods of delivery and ways of communicating the policy to staff and users to make them aware of and support best practice procedures.

Scope

This policy applies to all staff and volunteers of BCAFC and BCCF and includes any agency, or visiting professionals employed to provide services on our behalf.

Definitions

“Environmental sustainability” - aims to improve the quality of human life without putting unnecessary strain on the earth's supporting ecosystems. It’s about creating an equilibrium between consumerist human culture and the living world (Inspire 2021).

“Organisation” - any business that uses the Club’s badge.

“Users” - Encompasses any individual or person that accesses the services of the Foundation or the Club such as fans, participants, contractors or community members.

Policy Aims & Objectives

Together our aims are to:

Be considered an example of good practice for the delivery of sustainability as an active and respected CCO part of the EFLT network
Assess the environmental impact and risk across the whole organisation against the UN Sustainable Development Goals and our Local Authority’s Zero Carbon strategy and identify solutions to tackle these through setting SMART goals.
Look at the whole agenda more holistically to understand the root cause of some of the issues we face e.g. how we repurpose our match day waste?
Create a culture within the workplace where all staff are aware of the environmental policy and their impact on the environment through work activities.
Champion environmental sustainability both across the whole organisation, and within partnered organisations to maximise impact and promote shared environmental agendas, such as local authority diversity initiatives.
Educate, influence and support our users to think about their environmental impact on the district and build advocacy in this area of activity.
Identify appropriate channels of communication to promote good practice in relation to the promotion of environmental sustainability.
Achieve EFL Green Status

Responsibilities

BCCF have appointed a Trustee to be responsible for the oversight and promotion of environmental sustainability goals. They will ensure that this becomes a standing item as part of meeting agendas whilst helping us to review our strategy from an environmental perspective. The Trustee will also be responsible for signing off the action plan created by the Head of Compliance, Safeguarding and Performance from the Foundation and the Director of Operations from the club, and will monitor the implementation of this action plan.

The Head of Compliance, Safeguarding and Performance and Director of Operations will act as the environmental sustainability lead within both senior management team. They will be responsible for delivering the three year action plan and reviewing the policy yearly.

Collaboration Between the Foundation and the Club

This is a joint policy between the Foundation and the Club in order to promote environmental sustainability across organisations that share the same badge. This will be done by:

Working together on the EFL Green Clubs accreditation
Creating a joint working group that attends monthly to discuss the agenda
Taking responsibility for environmental sustainability where we have the scope to do so, and collaborating on areas where the Club leads

Procedure

BCCF and Bradford City Football Club will deliver the aims and objectives of the policy through the following key areas under Section15 of the CCOP:

Environmental Policy Management:

Develop and review targets
Monitor energy consumption against past performance
Communicate and promote environmental and sustainability procedures to the workforce and users
Encourage and facilitate feedback and suggestions from stakeholders and uses to improve good practice and communicate to the Green Club Steering Group
Exchange best practice with industry experts, local authorities, CCO’s and Football Clubs
Integrate environmental and sustainability principles into operational procedures and decision making processes
Encourage sustainable procurement, encouraging where practical the use of locally sourced products, services and suppliers which do not cause harm to the environment
Actively promote sustainable operations with users
Work towards achieving Carbon Trust Accreditation

Energy

Develop a carbon management plan setting clear targets to become carbon neutral
Implement working practices to ensure the efficient use of energy across BCCF and Bradford City Football Club sites
Improve the energy efficiency of existing buildings
Manage clean, ground and waste water efficiency including recovery and recycling opportunities
Maintain and develop central and group procurement plans to ensure economic and sustainable purchasing

Transport

Minimise carbon emissions through effective energy and transport management
Encourage sustainable transport practises across all provisions
Encourage the use of public transport, walking, cycling and vehicle sharing

Food

Minimise waste and reduce consumption
Minimise the environmental impact of waste through appropriate reuse and recycling
Measure and monitor waste
Segregate waste to ensure efficient recycling and limit waste to landfill

Nature

Enhance biodiversity across BCCF and Bradford City Football Club that do not affect operations of delivery and complement the clean air zone priorities

We are committed to protecting the environment, preventing pollution, and fulfilling all of our compliance obligations.

Organisational Responsibilities

The Environmental and Sustainability Policy will be monitored and implemented by the Green Club steering group which includes representatives from both BCCF and Bradford City Football Club.

Contact

BCCF Head of Compliance, Safeguarding and Performance

Lizzie Saunderson

lizzie.saunderson@bcfccommunity.co.uk

07469 234066

BCAFC Director of Operations

Paula Watson

paulawatson@bradfordcityafc.com

Actions Identified

Energy and Utilities

Focus on improving water waste and irrigation system to reduce water usage, or repurpose water waste around the ground
Change lamps to LED and motioned censored where practical
Change taps to those with time limiter
Look at sustainable energy companies
When upgrading any equipment, look at installing those with green credentials e.g. a new lift

Food & Wastage

Limit food waste through companies such as Too Good To Go
Change disposal system that prioritises recycling and install a waste compactor
Install recycling bins around the stadium to encourage recycling of plastics, and promote recycling campaigns of suppliers
Install biodegradable cleaning products within the water system to limit use of harsh chemicals
Create reusable merchandise that can be purchased and used on match days such as cups as we can also serve drinks in plastic bottles/cups
Continue to collect old playing kits and gift these to charity organisations across the globe

Nature

Install living wall on the outside of the stadium to encourage insects and bees which help the clean air zone
Deliver environmental educational sessions in primary schools where students can create a bug hotel that will be installed in the foundations community garden

Transport

Establish partnership with First Group to provide discounted bus tickets to fans for match days
Investigating a park and ride initiative to alleviate traffic around the club but also contribute towards the clean air zone
Install EV charging points around the ground

Policy Management

Partnered with Green Street for funded consultancy to improve the sustainability of the Club
Partnered with environmental courses at local University and submitted a dissertation proposal that will assess our green/sustainability credentials against the benchmark and provide a basis for change that can be discussed with Trustees

HEALTH AND SAFETY POLICY

Document Ref:	Health & Safety Policy
Version:	6
Date of version:	July 2022
Author:	Paula Watson
Approved by:	Ryan Sparks - Chief Executive Officer
Confidentiality level:	Internal, Public

Amendment History

Date	Version	Author	Details of Amendment
Unknown	1	James Mason	Initial Release
February 2019	2	Paula Watson	Update following recommendations and working with Nebosh consultant, and change in senior leadership
July 2019	3	Paula Watson	to bring annual review in line with season
October 2020	4	Paula Watson	Annual review
July 2021	5	Paula Watson	Annual review
July 2022	6	Paula Watson	Annual review

Statement of Intent

1.1 The Board is committed to continually ensuring the health and safety of staff and anyone affected by our business activities, and to providing a safe and suitable environment for all those attending our premises whether on match days, for business or any other purpose.

There is a commitment to continual improvement in H&S performance. This is regularly reviewed in senior team meetings.

1.2 Our statement of general policy is:

to provide adequate control of the health and safety risks arising from our work activities, to our own employees and also to others who may be affected by them;

to consult with our employees on matters affecting their health and safety;
to provide and maintain safe plant and equipment;
to ensure the safe handling and use of substances;
to provide information, instruction and supervision for employees;
to ensure all employees are competent to do their tasks, and to give them adequate training;

to prevent accidents and cases of work-related ill-health;
to maintain safe and healthy working conditions;
to make available adequate resources for managing and controlling health and safety; and
to review and revise this policy, as necessary, and at least annually.

1.3 This statement does not form part of any employee's contract of employment and the Board may amend it at any time. The Board will continue to review this policy to ensure it is achieving its aims.

1.4 This statement applies to the Club and its parent company and all subsidiary companies. It applies to all locations owned or operated by the Club including satellite academies.

RESPONSIBILITY FOR HEALTH AND SAFETY MATTERS

2.1 Stefan Rupp, the Chairman has overall responsibility for health and safety and the operation of this statement. The Director of Operations reports directly to the Chief Executive Officer and will report regularly to the Board on any key health and safety issues. The Health and Safety Consultant works alongside the Director of Operations who has day to-day responsibility for health and safety matters. The Safety Officer reports directly to the Chairman and CEO, as well as a reporting line into the Director of Operations and has responsibility for safety at the Stadium on match and event days and will ensure the directive of Operational Plan of Safety Certificate is adhered to.

2.2 The Director of Operations will ensure that this statement is reviewed as a minimum annually and more frequently if deemed necessary in consultation with the internal health and safety committee. Recommendations for any amendments are reported to the Board.

YOUR RESPONSIBILITIES

3.1 Staff at all levels of the organisation share responsibility for achieving safe working conditions and individually you must take care of your own health and safety and that of others, observe applicable safety rules and follow instructions for the safe use of equipment.

3.2 You should report any health and safety concerns immediately to your line manager or the Director of Operations.

3.3 You must co-operate with managers on health and safety matters, including the reporting and investigation of any incident including near misses.

3.4 You should be involved in implementing solutions and adhere to the rules and procedures, law and litigation.

3.5 Failure to comply with this statement may be treated as misconduct and dealt with under our Disciplinary Procedure.

INFORMATION AND CONSULTATION

4.1 The Club will inform and consult with the health and safety committee or directly with all staff (as appropriate) regarding health and safety matters. A key element of health and safety management is sharing best practice with other clubs and lessons learnt from incidents in order to prevent recurrence.

4.2 The Club will ensure any health and safety representatives receive the appropriate training to carry out their functions effectively.

4.3 The Director of Operations is responsible for informing and consulting employees about health and safety matters.

TRAINING

5.1 The Club will ensure that you are given adequate training and supervision to perform your work competently and safely.

5.2 Staff will be given a fire induction and provided with appropriate safety training, including as applicable, control of substances hazardous to health (COSHH), and the use of personal protective equipment (PPE).

EQUIPMENT

6.1 You must use equipment in accordance with any instructions given to you. Any equipment fault or damage must immediately be reported to your line manager.

6.2 No member of staff should attempt to repair equipment unless trained to do so.

6.3 The Director of Operations and the Head of Maintenance are responsible for ensuring equipment safety and maintenance.

ACCIDENTS AND FIRST AID

7.1 Details of first aid facilities and the names of trained first aiders are displayed on the notice boards.

7.2 All near misses, accidents and injuries at work, however minor, should be reported to the director of Operations and recorded in the Accident Book which is kept in the commercial offices.

7.3 The Director of Operations is responsible for investigating any injuries or work related disease, preparing and keeping accident records, and for submitting reports to the relevant authorities if required under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).

FIRE SAFETY

8.1 All staff should familiarise themselves with the fire safety instructions, which are displayed on notice boards and near fire exits in the workplace. The Club has in place a separate Fire Policy and Procedures.

8.2 If you hear a fire alarm, leave the building immediately by the nearest fire exit and go to the fire assembly point shown on the fire safety notices. Do not stop to collect belongings and do not use the lifts. Fire wardens will assist in the evacuation of the building and you must follow their instructions. Do not re-enter the building until told to do so.

8.3 If you discover a fire do not attempt to tackle it unless it is safe and you have been trained or feel competent to do so. You should operate the nearest fire alarm and, if you have sufficient time, call reception and report the location of the fire.

8.4 Nominated individuals will be trained in the correct use of fire extinguishers.

8.5 You should notify your manager or the Head of operations if there is anything (for example, impaired mobility) that might impede your evacuation in the event of a fire. A personal evacuation plan will be drawn up and brought to the attention of the relevant fire wardens and colleagues working in your vicinity.

8.6 Fire drills will be held at least every 12 months and must be taken seriously.

8.7 The Director of Operations is responsible for ensuring fire risk assessments are undertaken and implemented, and for ensuring regular checks of fire extinguishers, fire alarms, escape routes and emergency lighting.

RISK ASSESSMENTS AND MEASURES TO CONTROL RISK

9.1 The Club carry out general workplace risk assessments periodically. The purpose is to assess the risks to health and safety of employees, visitors and other third parties as a result of our activities, and to identify any measures that need to be taken to control those risks.

9.2 Measures will be taken to avoid or reduce the need to lift or carry items which could cause injury (manual handling) and to provide training on manual handling as necessary.

9.3 The use of hazardous substances at work will be avoided wherever possible and less hazardous alternatives will be used where available. Training on the control of substances hazardous to health (COSHH) will be provided as necessary.

9.4 Personal protective equipment (PPE) is provided where there are risks that cannot be adequately controlled by other means, free of charge.

9.5 The Health and Safety Officer is responsible for workplace risk assessments and any measures to control risks.

9.6 The club regularly reviews the health and safety risk profiles and updates the board regularly.

COMPUTERS AND DISPLAY SCREEN EQUIPMENT

10.1 If you use a computer screen or other display screen equipment (DSE) habitually as a significant part of your work:

(a) You should try and organise your activity so that you take frequent short breaks from looking at the screen.

(b) You are entitled to a workstation assessment.

10.2 You should contact your line manager to request a workstation assessment or an eye test. Eye tests should be repeated at regular intervals as advised by the optician, usually every two years. However, if you develop eye problems which may be caused by DSE work (such as headaches, eyestrain, or difficulty focusing) you can request a further eye test at any time.

10.3 The Club will not normally pay for glasses or contact lenses.

10.4 Further information on the use of DSE can also be obtained from the Director of Operations

LONE WORKING

11.1 The club carries out lone worker risk assessments to assess the risks involved with lone working. This also applies if you're working for the club as a contractor, a freelancer or are self-employed.

11.2 The Club has a policy detailing

support and training
how the lone worker keeps in contact with the line manager

how to prevent work-related violence

11.3 It is important that you take care of your own health and safety and that of others who may be    harmed by your actions at work.

11.4 If you're concerned about health and safety risks to you as a lone worker, talk to:

your employer
a manager or supervisor

a health and safety representative

DRIVING AT WORK

12.1 Drivers of company cars or those driving their own cars on company business, must drive responsibly and in adherence with the current legislation governing the highways. Any employee who has been issued with a company vehicle or driving their own car on company business must adhere to the above and the regulations detailed in the company vehicle policy.

GROUNDS MAINTENANCE

13.1 Bradford City AFC will operate in compliance with all grounds maintenance health and safety and environmental legislation.

13.2 Grounds maintenance risk assessments are periodically reviewed

13.3 Grounds machinery is routinely inspected.

CONTRACTORS

14.1 Every Contractor working with Bradford City AFC has to be approved to ensure that all liabilities are fully mitigated.

14.2 The approved contractor list will identify contractors who have:

Passed vetting against certain key criteria;
Identified types of work that they can undertake;
Identified the areas in which they will undertake work; and
Identified the value of contracts which they consider they may be capable of undertaking.

14.3 No work should be booked in without prior vetting. As part of the vetting procedure for checking contractors, Bradford City Football Club will undertake checks which include the following:

Checking Identity
A copy of a contractor’s certificate of incorporation as a company will be obtained and checked against Companies House.
For sole traders, we will ask to see personal ID such as a passport or driving Competency
Checks will be undertaken to satisfy a contractor’s competency. This will depend upon the work to be done and the skills and experience required.

Copies of the contractor’s current insurance policies will be checked and as a minimum we will need to see evidence of public liability and employer’s liability if the contractor has staff.
A check will also be undertaken to ensure that the insurance held by the contractor is suitable for the work to be carried out.

QUERIES

If you have any queries in relation to this statement please direct them to the Health and Safety Consultant or the Director of Operations

This document is reviewed periodically and at least annually to

1.ensure compliance with the Legislative requirements defined by law, where appropriate.

to set and review health and safety objectives

Director of Operations, Paula Watson

Bradford City AFC is committed to protecting the privacy and security of your personal information.

We are a data controller. This means we are responsible for deciding how we hold and use personal information about you.

This notice explains to you what decisions we have taken in relation to that information.

Our contact details are as follows:

Bradford City Football Club Limited

University of Bradford Stadium

Valley Parade

Bradford

West Yorkshire

BD8 7DY

Telephone: 01274 773355

Document Ref: Privacy Notice

Version: 1

Date of Version: February 2019

Author: Paula Watson

Confidentiality Level: Public

This notice tells you what to expect in relation to personal information about you which is collected, handled and processed by Bradford City Association Football Club ('the club', 'BCAFC' or 'we') as Data Controller.

We are committed to protecting your data and respecting your privacy.

We aim to be clear when we collect your data and not do anything you wouldn’t reasonably expect with your data.

We handle and process data in accordance with the General Data Protection Regulation 2018 (GDPR) and the Privacy and Electronic Communications Regulations 2003.

This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR).

We encourage you to read this notice carefully, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

It applies to all employees, volunteers, and contractors. We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice.

If you have any questions about this privacy notice or how we handle your personal information, please contact the Chief Executive Officer, at the organisational address and contact details above.

As a data controller, we are responsible for deciding how we hold and use personal information about you.

This notice explains to you what decisions we have taken in relation to that information. General data protection principles in collecting and processing your personal information, we will comply with the data protection law in force at the time.

WHO WE ARE

Information We May Collect

You give us information when you contact us with an enquiry, use or register on the website, purchase a ticket or merchandise, fill out a survey or other form, request us to provide you with information, enter a competition or prize draw or engage in a promotion or survey, post information to public areas of the website, book an event or hospitality, by phone or email or online via our website or update preferences on our website, contact us via email, or when posting on or communicating via our social media platforms, become a sponsor or advertiser, become a mascot or provide content for our matchay programme or by communicating with us via any other channel.

The information we may collect, hold and process about you, provided by you, may include:

Name
Address
Email address
Telephone number(s)
Bank details and/or payment details
Gender
Dietary requirements
Health and genetic information
Billing information
Vehicle registration number, make and model
Details of other people within your group booking including name and age
Purchase/transaction and ticketing history
Encrypted record of login password
Your preference for how we communicate with you about our activities
Photographs
IP address
Information gathered by use of cookies in your web browser
Information that is available publicly, including social media username if you interact with us through social media channels
Record of accidents and treatment received We maintain a record of your transaction history, but we never store your payment information. We keep a record of the emails we send you, and we may track whether you receive or open them so we can make sure we are sending you relevant information. We may track subsequent online actions such as ticket or retail purchases and enquiries. With regard to each of your visits to our Website we collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer/device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number. Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site.

Your image and vehicle number plate may be recorded by CCTV when you visit any of our sites for safety and security purposes and to improve the service we can provide to you.

This footage may also be used to exercise and defend our legal rights. Where necessary this footage will also be shared with the authorities for law enforcement purposes.

How We Use Your Information

The above information is used to:

Provide our services to you and enable us to process, administer and manage your orders, contracts, accounts
Create an account so that we understand and respect your preferences
Establish dietary requirements and provide suitable catering options for you and your guests (where applicable)
Inform you about changes to our products and services or new products and services
Inform you about renewals and additional matches to which you may have the opportunity to purchase tickets
Communicate information about any agreement you may have with us or have enquired about
Inform you about offers, events and promotions that may be of interest to you
Improve the services the club offers you (which may sometimes include undertaking customer research)
Keep a record of your relationship with us and how you prefer to be contacted
Analyse your personal information to create a profile of your interests and preferences so we can contact you with information most relevant to you
To ensure content from our website is presented in the most effective manner for you and for your computer
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
To administer prize draws and competitions you have entered
To allow you to participate in interactive features of our service, when you choose to do so
As part of our efforts to keep our site safe and secure
To resolve an enquiry or progress a complaint
Comply with legal and regulatory obligations placed on the club.

We use profiling and segmentation to ensure communications are relevant to you. For this purpose we may analyse geographic, demographic and other information relating to you to enable us to understand your preferences.

The club and/or its media partners may from time to time create images and/or audio-visual footages of you and your guests at the ground. The club is the owner of all rights in such footages and shall be entitled to use such footage on any media platform for the following purposes:

Promotional, marketing and commercial purposes
Training for Club employees and third parties who work with the club
Broadcasting and editorial purposes

How We Keep Your Information Safe

All personal information we hold is stored on our secured servers in the UK and EU.

Access to our information is strictly controlled. We may disclose your details to police, regulatory bodies, local authorities, football governing bodies and the Independent Football Ombudsman or legal advisors if so required.

If any of the organisations to which we disclose your personal information is situated outside the European Economic Area (EEA) we would take reasonable steps to ensure that your information is properly protected including safeguards such as using contractual provisions to ensure your information is properly protected.

Disclosure of Your Information

We do not share your information with any third party without your agreement, unless we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of purchase and other agreements; or to protect the rights, property, or safety of BCAFC, our customers, or others.

This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Any third party providers used by us to fulfil our contractual obligations to you will only collect, use, store and disclose your information in the manner and to the extent necessary for them to provide their services to us.

We have written agreements in place with each third party to ensure that your information is kept securely, is not used for any other purpose and is deleted when no longer required. Such third party providers may include:

Ticketing system provider
Email distribution service
Mailing house
Marketing service provider
Online audio and video player
IT companies who support our website and other business service
Professional advisors and insurers
Analytical provider to assist us with the improvement or optimisation of our website and services;
Credit reference agency for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. We may share personal information with other organisations such as the Premier League, the English Football League, the Football Association and other governing bodies to assist with research and reporting on attendance and improve strategic planning and business decisions. We never sell personal information to third parties. Our website may, from time to time, contain links to and from the websites of our commercial partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

What is the Legal Basis for Processing the Information

The legal basis for collecting and processing your data may be:

Consent: You may have given us your consent to use your data for example when you tick a box to receive marketing emails, offers and newsletters. You can withdraw your consent at any time.
Contractual obligation: To enter into a contract with us we need your personal information (including financial information) to process and fulfil the contract for example to purchase a ticket or view digital content.
Legal obligation: If required by law to process personal information for example to comply with health and safety and equality obligations or to provide information to the police to prevent fraud or criminal activity.
Legitimate interest: For a genuine business reason that does not override your rights, freedom or interests for example administrative purposes, or using your purchase history to send you personalised offers.

Children and Young People's Privacy Notice

We understand children and young people under the age of 14 years old ('children) may visit our website or otherwise interact with us.

Children may need their parent or guardian’s permission to use or access certain areas of our website or receive certain information through the website.

Children may also be asked to confirm they have that permission and we reserve the right to verify parental or guardian consent where required.

We do not actively market to children. We do not share children’s personal information for any commercial purpose.

Your Rights

You have the right at any time to ask for a copy of the information we hold about you and confirmation of how it is being processed.

You will be required to verify your identity when making a request.

If you would like to make a request for information please:

E-mail: dpo@bradfordcityfc.co.uk

Send a request in writing to: Data Protection Officer, Bradford City Football Club Ltd., University of Bradford Stadium, Valley Parade, Bradford, BD8 7DY.

You also have the right to:

Request we correct inaccuracies to your information. You must notify us of any updates, amendments or corrections to previously collected personal information in writing to the club or by email or by updating your single sign on account online at our website. We encourage you to keep the personal information we hold on you up to date and accurate.
Request we delete some or all of your personal information for example if it is no longer necessary for us to hold it for the purpose it was provided and we have no legal basis to retain it.
Request we stop or limit the processing of your information where you think the information we hold is inaccurate (until the accuracy is proved or updated), if you have objected to the processing (when it was necessary for legitimate interests), if you have consented to the use of it, or if it is no longer necessary for us to hold it for the purpose it was provided and we have no legal basis to retain it.
(In certain circumstances) Move, copy or transfer your personal information to another organisation or to yourself. This applies only to personal information you have provided us with and is being processed by us with your consent or for performance of a contract and is processed automatically.
(In certain circumstances) You have the right to object to certain types of processing of your personal information when it is based on legitimate interests, when it is processed for direct marketing including profiling, or when it is processed for the purpose of statistics.

How Long Do We Keep Your Information?

Your personal information will be retained for no longer than is necessary to fulfil the purpose for which we collected it or as required to satisfy any legal or reporting obligation or to resolve a dispute or enforce an agreement.

When we no longer require your personal information, we will dispose of it in line with approved company processes.

If personal data is retained for legal or reporting obligations it will be archived and reduced to the minimum.

Withdrawing Consent

If you have provided us with your consent to process your personal information, you have the right to withdraw this at any time.

In order to do so, contact us by emailing dpo@bradfordcityfc.co.uk.

Contact Us

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us by contacting: Data Protection Officer, University of Bradford Stadium, Valley Parade, Bradford, BD8 7DY. OR dpo@bradfordcityfc.co.uk.

You also have the right to contact the Information Commissioners Office at https:\\ico.org.uk\concerns\.

Changes to This Notice

Our policies are constantly under review and this Privacy Notice may be changed by us at any time.

Any changes shall be posted on the website and we recommend that you check regularly to review the latest version.

This document is reviewed periodically and at least annually to ensure compliance with the following prescribed criteria.

General Data Protection Regulation
Legislative requirements defined by law, where appropriate

Director of Operations: Paula Watson

SAFEGUARDING COMMITMENT STATEMENT

Bradford City Safeguarding Commitment Statement

August 2023: Version 2

The purpose and scope of this Commitment statement

Bradford City AFC recognises its duty of care to safeguard all children, young people and young players, vulnerable adults/groups involved in activities organised by ourselves from harm. All children and adults at risk have the right to protection, and the needs of disabled children and others who may be particularly vulnerable must be taken into account. We will do their utmost to ensure the safety and protection of all children/groups and adults at risk involved in activities through adherence to the safeguarding guidelines adopted by the Club.

The purpose of this policy statement is:

to protect children and young people who interact with Bradford City AFC from harm. This includes the children of adults who use our services
to provide staff and volunteers, as well as children and young people and their families, with the overarching principles that guide our approach to child protection. This policy applies to anyone working on behalf of Bradford City Football Club, including senior managers and the board, paid staff, volunteers, sessional workers, agency staff, contractors and students.

Legal framework

This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in England. A summary of the key legislation and guidance is available in the safeguarding policy document.

Scope:

This policy covers all activities within the; Stadium, Training Ground, and Academy. The community foundation operate their own Safeguarding policies and processes in line with the code of capability.

Supporting documents:

This policy statement should be read alongside our organisational policies, procedures, guidance and other related documents:

role description for the designated and senior safeguarding officer
dealing with disclosures and concerns about a child or young person or adult at risk
managing allegations against staff and volunteers
low level concerns
code of conduct for staff and volunteers, players, and coaches
photography and sharing images guidance
safer recruitment
online safety
anti-bullying
managing complaints
whistleblowing
health and safety
induction, training, supervision and support
adult to child supervision ratios.

We believe that:

children and young people and adults at risk should never experience abuse of any kind
we have a responsibility to promote the welfare of all children and young people and adults at risk, to keep them safe and to practise in a way that protects them.

We recognise that:

the welfare of children and adults at risk is paramount in all the work we do and
in all the decisions we take
working in partnership with children, young people, their parents, carers and
other agencies is essential in promoting young people’s welfare
all children, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have an equal right to protection from all types of harm or abuse
extra safeguards may be needed to keep children who are additionally vulnerable safe from abuse.

We will seek to keep children and young people safe by:

Contact details

Senior Safeguarding Officer:

Paula Watson

E: paulawatson@bradfordcityafc.com

The SSO is the senior manager with primary responsibility for managing and reporting safeguarding concerns and for putting into place and monitoring policies, procedures and daily practice to safeguard children and adults at risk in the organisation.

The matchday Safeguarding contact at the club is Sian Nuttall - by text, 07949814243, or to the control room

The Academy Safeguarding & Club DSO contact at the club is Lee-Ann Brewer 07949 814505. The DSO is the designated person with primary responsibility for managing and reporting safeguarding concerns and to ensure there is good daily practice to safeguard children and adults at risk in the organisation. The Academy Player Care officer is Tom Calvert 07963 080219

Bradford City FC Community Foundation DSO is Lizzie Saunderson 07469 234066

If you prefer to report an incident by email please contact safeguarding@bradfordcityafc.com

If there are any concerns about any of the above named people then any of the external agencies can be contacted or Ryan Sparks (CEO) can be contacted at ryansparks@bradfordcityafc.com

If you have serious concerns about the immediate safety of the child or young person contact the Police or Social Services. Record the name of the person you spoke to and tell your DSO what you have done.

Bradford Council Children Safeguarding Services During Working Hours: Monday to Thursday 8:30am to 5:00pm, Friday 8:30am to 4:30pm First Contact Team:01274 437500– out of hours 01274 431010

Bradford Council Adult Safeguarding Services During Working Hours: Monday to Thursday 8:30am to 4:30pm, Friday 8:30am to 4:00pm First Contact Team:01274 431077– out of hours 01274 431010

West Riding FA: out of hours 07912 309565

FL Child Protection Advisor: 01772 325 811/07795 628 379

FA Safeguarding Team: 0800 169 1863 or via safeguarding@thefa.com

English Football League Trust on 07583491701

NSPCC Helpline number: 0808 800 5000/ www.nspcc.org.uk/inform/cpsu

SAFEGUARDING CONTACTS

Useful Contact Details

Senior Safeguarding Officer:

Paula Watson

E: paulawatson@bradfordcityafc.com

Bradford City FC Community Foundation DSO is Lizzie Saunderson 07469 234066

If you prefer to report an incident by email please contact safeguarding@bradfordcityafc.com

If there are any concerns about any of the above named people then any of the external agencies can be contacted or Ryan Sparks (CEO) can be contacted at ryansparks@bradfordcityafc.com

Bradford Council Children Safeguarding Services During Working Hours: Monday to Thursday 8:30am to 5:00pm, Friday 8:30am to 4:30pm First Contact Team: 01274 437500 – out of hours 01274 431010

Bradford Council Adult Safeguarding Services During Working Hours: Monday to Thursday 8:30am to 4:30pm, Friday 8:30am to 4:00pm First Contact Team:01274 431077– out of hours 01274 431010

West Riding FA: out of hours 07912 309565

FL Child Protection Advisor: 01772 325 811/07795 628 379

FA Safeguarding Team: 0800 169 1863 or via safeguarding@thefa.com

English Football League Trust on 07583491701

NSPCC Helpline number: 0808 800 5000/ www.nspcc.org.uk/inform/cpsu

SAFEGUARDING POLICY

December 2023

Bradford City Football Club is passionate about creating an enjoyable, safe, and secure environment for all. We are fully committed to the safeguarding and welfare of children, young people, and young players, and expects all staff, players, and volunteers to share this commitment. We have a separate Adults at risk policy available on the shared drive.

Policy Statement

Ryan Sparks, CEO “Bradford City AFC recognises its duty of care to safeguard all children, young people and young players, involved in activities organised by us from harm. All children have the right to protection, and the needs of disabled children and others who may be particularly vulnerable must be considered. We will do their utmost to ensure the safety and protection of all children/groups involved in activities through adherence to the safeguarding guidelines adopted by the Club.”

Principles and purpose of the policy

Bradford City Football Club seek to ensure safety of all children who engage with the club, this equally applies to the safety and security of those working with and responsible for children’s activities. This policy applies to all activities within the Stadium, Training Ground, and Academy. The community foundation operates their own Safeguarding policies and processes in line with the code of capability. All third parties working within the stadium must adhere to and sign our safeguarding SLA.

Aims

Provide children, young people, young players, adults at risk, (vulnerable groups) with appropriate safety and protection whilst in our care.
Undertake to provide relevant safeguarding training, delivered by appropriate training providers as appropriate to their role for staff, players, and volunteers.
Allow staff/volunteers to know the reporting lines to Paula Watson as Senior Safeguarding Officer or Lee-Ann Brewer as Designated Safeguarding Officer
Allow the safeguarding team to make informed and confident responses to specific safeguarding issues.
Give the safeguarding team the knowledge and understanding when to report to LADO, the FA, and other external agencies.
Provide education and awareness raising to young players and parents to understand their role in safeguarding.

Key Principles

The welfare of children is paramount.
All children, whatever their age, culture, disability, gender, language, racial origin, religious belief and/or sexual identity have the right to safety and protection from abuse and harm.
Prevent policies and processes are in place for the protection of vulnerable groups from radicalisation.
All suspicions and allegations of abuse will be taken seriously and responded to swiftly and appropriately.
All staff, players and volunteers working for the club have a responsibility to report concerns to the Senior Safeguarding Manager and Designated Safeguarding Officers.
Safeguarding is everyone’s responsibility; the club aims through its policy and practises to create a culture of vigilance and ensuring all concerns are reported.
Working in partnership with other organisations, children and their parents/carer is essential

Safer Recruitment and Disclosure

Bradford City Football Club have put in place a recruitment process to reduce the risk to all children and adults at risk from those the organisation employs either paid, third party contractors or volunteers. As part of the Club’s safer recruitment and selection process, offers of work for positions which involve ‘regulated activity’ when working with children are subject to a satisfactory Enhanced Disclosure Barring Service (DBS) check and appropriate references.

All offers of work are subject to a satisfactory outcome to the screening process and until a satisfactory disclosure has been confirmed, the individual concerned will not be permitted to commence work. Volunteers may work alongside another suitably assessed member of staff if a Risk assessment is carried out and signed off by the senior safeguarding officer.

All new employees, workers, consultants, third party contractor staff and volunteers working with children at the Club will be required to complete a self-declaration on commencement of duties.

All employees, workers, consultants, third party contractor staff and volunteers engaged in ‘regulated activity’ will be required to undergo regular DBS disclosure clearances, normally every 3 years or earlier if requested. Pending DBS clearance and obtaining references from previous employers they will not have unsupervised access to children and adults at risk during their time with the Club.

Should an individual’s DBS check reveal any convictions the Club will consider whether the nature of the offence/ offences renders the person concerned unsuitable for working with children and adults at risk. In such circumstances, when the nature of any disclosure must be considered, a risk assessment will be carried out to assess the information contained within the disclosure certificate.

The individual may also be asked to attend an interview prior to a recruitment decision being made. The Club will ensure that all third-party contractor staff and consultants working with children in ‘regulated activity’ are subject to a satisfactory Enhanced DBS disclosure and sign a self-declaration form prior to engagement

Employee/Volunteer Training

All staff and volunteers will receive an annual safeguarding training. The DSO and SSO will attend EFL training. There will be a training needs analysis and safeguarding workforce plan for all employees who directly work with children.

All staff working directly with young people should also read Keeping Children Safe in Education (2023) Guidance https://assets.publishing.service.gov.uk/gov and should all sign and understand the Club’s Staff code of conduct.

Position of Trust & Duty of Care

The Club acknowledges its responsibility to safeguard the welfare of every child who has been entrusted to its care and is committed to working to provide a safe environment. All employees, workers, consultants, agency staff and volunteers (workers) are accountable for the way in which they exercise authority, manage risk, use resources, and protect children from discrimination and avoidable harm.

To always ensure best practice staff must be fully aware of this safeguarding policy and procedures and their responsibilities. All staff have a duty of care to keep children safe; this can be exercised through the development of considered, respectful, caring, and professional practice between adults and children. Workers must demonstrate integrity, maturity and good judgement whilst working with children and adults at risk. Any person responsible for a child, whether solely or jointly, is in a position of trust which requires behaviour to be in accordance with this policy.

Examples of positions of trust include (but are not limited to)

A head of a department,
Team manager,
Scout,
Physiotherapist,
Driver,
Learning mentor/tutor,
Staff engaged in matchday activity involving children and adults at risk, including supervising mascots, stewards, hosts/hostesses, catering personnel and photographers.

Protecting Children with disabilities

Children with disabilities are at an increased risk of abuse and that the greater the disability the greater the risk. There are a number of factors that contribute to this, and these include:

Lack of friends and peer group to support and protect.
Intimate/physical and or invasive medical care required. This can make it difficult for the child and adult at risk to know what an acceptable and unacceptable ‘touch’ is.
Lack of speech or limited communication, this makes it harder to report abuse.
Multiple parent/responsible persons – making it harder to identify who may be abusing.
History of being told what to do and not given choices.
Being dependent on the abuser for a service or basic need.
Having medical conditions that are used to explain injuries.

Children with disabilities may also be less valued than their peers and poor care may be observed but tolerated by others. This might include such things as not speaking directly to the child; not offering choices, not moving and handling them safely, not respecting their privacy and dignity, not treating them according to their age; allowing physical restraint to occur or using derogatory language.

There is no one way to ensure that children with disabilities are fully protected but the safest environments are those that assist children by helping them to speak out. Everyone must do their best to stop abuse from happening and take responsibility for observing, challenging, and reporting poor practice and suspected abuse.

Poor Practice and Abuse

This takes place whenever staff or volunteers fail to fulfil the highest standards of care and support in their working practice. Poor practice which is allowed to continue can cause harm and can become abuse. Poor practice is unacceptable and will be treated seriously with appropriate action. If appropriate this may be dealt concurrently with the club’s Disciplinary, Grievance and Harassment Policy.

An individual may not be aware that poor practice or abuse is taking place, as they may deem the behaviour as ‘acceptable’.

Poor practice is defined as

When insufficient care is taken to avoid injuries (e.g., by excessive training or inappropriate training for the age, maturity, experience, and ability of players)
Allowing abusive or concerning practices to go unreported (e.g., a coach who ridicules and criticises players who make a mistake during a match)
Allowing hazing practices to go unreported
Placing children or young people in potentially compromising and uncomfortable situations with adults (e.g., inappropriate use by a coach of social media with a young player(s))
Ignoring health and safety guidelines (e.g., allowing young players to set up goal posts unsupervised by adults)
Failing to adhere to the club’s codes of conduct practice (e.g., openly verbally abusing the referee)
Giving continued and unnecessary preferential treatment to individual

Practices to be avoided

The following should be avoided except in emergencies (this list is not exhaustive):

Never taking children to your home where they will be alone.

The following should never be sanctioned. You should never:

Share a room with any under 18s.
Engage in rough, physical, or sexually inappropriate games, including horseplay.
Allow or engage in any form of inappropriate touching.
Allow children to use Inappropriate language unchallenged.
Make sexually suggestive comments to a child, even in fun.
Reduce a child to tears as a form of control.
Allow allegations made by a child to go unacknowledged, unchallenged, unrecorded, or not acted upon.
Do things of a personal nature for children or vulnerable adults that they can do for themselves
Staff should avoid taking on any caring responsibilities for which you are not appropriately trained, and for which consent forms have been obtained.

If cases arise where these situations are unavoidable, they should only occur with the full knowledge and consent of someone in the safeguarding team or the child’s parents/guardian. For example, a child sustains an injury and needs to go to hospital, or a parent fails to arrive to pick a child up at the end of a training session/match.

Abuse Categories

Physical

Physical abuse indicators can include an explanation which is inconsistent with an injury, several different explanations provided for an injury, unexplained delay in seeking treatment or reluctance to give information or mention previous injuries.

Neglect

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development.

Sexual

Sexual abuse is when adults, of either sex, or other children, use children to meet their own sexual needs. It involves forcing or enticing a child to take part in sexual activities, including prostitution, whether or not the child is aware of what is happening.

Emotional

Emotional abuse may be difficult to recognise. It is the persistent emotional ill-treatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development

For more information see appendix 1 for information on types on abuse

Responding to allegations or suspicions of abuse

It is not the responsibility of anyone employed by Bradford City Football Club, in a paid or unpaid capacity to decide whether the alleged harm or abuse has taken place.

All staff and volunteers have a responsibility to ensure the safety and welfare of children including taking appropriate steps (including those set out in this procedure) to ensure that suspicions and allegations of abuse and poor practice are taken seriously and reported immediately and appropriately. Bradford City Football Club will assure all staff and volunteers that it will fully support and protect anyone, who in good faith reports his or her concern that a colleague or another is, or may be, abusing a child.

Children are likely to disclose abuse, or radicalisation to those they trust and how one responds to a disclosure is crucial. Deal with the disclosure as it happens and ensure that the child’s immediate needs are met and that they feel supported.

When a disclosure is made, it is most important to understand that you must not investigate the disclosure yourself. The disclosure must always be taken seriously and dealt with according to the guidance in this Policy, even if the truth of the disclosure is uncertain. You are not expected to act as a social worker, counsellor, judge, jury, or avenge the abuser; you are expected to act in the best interest of the child who may be at risk.

RECOGNISE

Recognising abuse or harm is often not easy. You need to act when you suspect Harm or Abuse is or has taken place, not just when you are sure that harm has occurred. You may not have proof, but it doesn’t mean you are jumping to conclusions, it simply means you don’t have ethe poof that the abuse is taking place. As soon as you suspect any kind of Abuse or Harm you should raise the concern

RESPOND

Responding to abuse is vital, and you have a responsibility to report any concerns you have to the safeguarding team and your line manager. You may need to find out the basic facts, ensure you allow the individual to speak without interruption, do not make any judgement. Reassure them and let them know that you are going to have to speak to somebody to ensure that they are safe.

REFER/REPORT

Contact your safeguarding officer or the Head of Safeguarding, if you can’t reach them contact your line manager, you should also consider contacting local authorities. For example, the police or social services.

RECORD

You should also make sure you make a note of any disclosure so that this can be recorded on the clubs TOOT TOOT system. We will ensure that all staff/volunteers are fully supported and protect anyone, who in good faith, reports his/her concern that a colleague is, or may be, harming or abusing a child.

See appendix for further guidance on dealing with disclosures

Creating a positive culture

All personnel are encouraged to demonstrate exemplary behaviour to safeguard children, to report any concerns about the welfare of a child and to protect themselves from allegations.

We endeavour to:

Always respond to any request to complete or update your DBS Criminal Records Check
Always inform the HR Department in respect of your behaviour regarding any investigation, allegation or arrest which may have an impact upon the role you have in working with children or vulnerable groups.
Always work in an open environment; for example, avoid private or unobserved situations and encourage an open environment, i.e., no secrets.
Treating all young people/young players/groups according to their needs and with respect and dignity.
Always putting the welfare of each young person first before winning and achieving goals.
Always maintaining a professional relationship with young people and players; for example, never have an intimate relationship with a child U18 (even if they are over 16 years old) when you are responsible for their supervision, care, support, or coaching.
Building balanced relationships based on mutual trust which empowers children to share in the decision-making process.
Recognise children with social workers may continue to be vulnerable and be educationally disadvantaged in attendance, learning, behaviour and mental health and to use this information to inform the response to further safeguarding concerns (e.g., absence, missing) and support
Making football fun, enjoyable and promoting fair play.

Coaching Contact:

Use of photography

The Club takes its guidance on the use of images from guidelines issued by The FA and EFL.

All images are taken by Club officials who have been briefed by a Club Head of Safeguarding or by a member of the Communications and Marketing Department responsible for the activity being photographed or filmed.

Before taking images of children or adults at risk, parental consent must be sought in writing, at the start of the season or prior to the event.
Parents/responsible person are responsible for informing the Club of any change of circumstances within the season which may affect consent.
Parents/responsible person will be informed of how the image will be used. The Club will not allow an image to be used for something other than that for which it was initially agreed.
All children featured in Club publications will be appropriately dressed.
If possible, the image will focus on the activity taking place and not a specific child.
Where appropriate, images will represent the broad range of people participating safely in the event.
Club photographers will, where applicable, undertake a DBS check and attend an FA Safeguarding Children workshop; and in any case will be personally responsible for keeping up to date with the latest guidelines on the ‘Use of Images’ policies. Club identification will be always worn.
Children who are the subject of a court order will not have their images published in any Club document.
No images of children featured in Club publications will be accompanied with personal details such as their home address.
Recordings of children for the purposes of legitimate coaching aids will only be filmed by Club officials and stored safely and securely at the Club’s premises.
Mobile phone cameras are not to be used in changing rooms.
Any instances of inappropriate images in football should be reported to a Safeguarding Manger.
The Club does not put young player profiles with images and personal information on its website.

E-safety

It is important that both players and parents are aware of the help and support available should they be concerned about something they have seen or experienced online. Appendix 5 provides links for parent/carer further information and support.

Lone working and one and one time

A lone worker, for the purpose of this Policy, is defined as a member of Staff who is engaged in activities which place them in a situation without direct contact with other Staff or without direct supervision (including online meetings)

Staff responsibilities:

Work in an open and transparent way and avoid conduct which could raise concern or place Children and at Risk of harm.
Under no circumstances should Staff and Partners visit Children in their homes outside agreed work arrangements. Nor should they invite Children to their own home or to that of a family member, colleague, or friend.
Ensure that contact by whatever means and meetings with Children outside agreed working arrangements never take place without the knowledge and agreement of Bradford City AFC.

Supervision ratios

Staff are expected to provide appropriate supervision of the Children in their care, always. The level of supervision required will vary between activities.

Ratios for each Activity should be determined by taking the following into consideration:

The age, needs, abilities and behaviour of the Children, Young People participating. Please see the FA guide for suitable ratios.
The competence and experience of Staff and Partners involved.
The nature and duration of the Activity.
Risk assessments and/or intelligence identifying potential behavioural or other issues and risks.
Staff must work with Bradford City AFC Club Safeguarding Team when planning activities to ensure that appropriate ratios and supervision arrangements are carefully considered

Confidentiality

Employees, workers, consultants, agency staff and volunteers may have access to confidential information about children and adults at risk in order to undertake their responsibilities. In some circumstances, employees, workers, consultants, agency staff or volunteers may be given highly sensitive or private information. They should never use confidential or personal information about a child and adult at risk or his/her family for their own or others’ advantage.

Information must never be used to intimidate, humiliate, or embarrass children. Confidential information about a child should never be used casually in conversation or shared with any person other than on a need to know basis. In circumstances where the child identity does not need to be disclosed, the information should be used anonymously.

There are some circumstances in which an employee, worker, consultant, agency staff or volunteer may be expected to share information about a child, for example when abuse is alleged or suspected. In such cases, individuals have a duty to pass information on without delay, but only to those with designated safeguarding responsibilities.

If an employee, worker, consultant, agency staff or volunteer is in any doubt about whether to share information or keep it confidential, they should seek guidance from the Club’s Safeguarding team. Any media or legal enquiries should in the first instance be referred to the Senior Safeguarding officer.

The storing and processing of personal information about children is governed by the Data Protection Act, 1998. For further information on the Club’s (and your) obligations under the Data Protection Act 1998, please see the Club’s Data Handling & Protection Policy, available on the Club’s shared drive.

This means that employees, workers, consultants, agency staff and volunteers:

Are expected to treat information they receive about children/adults at risk in a discreet and confidential manner.
Should seek advice from the Senior Safeguarding Officer if they are in any doubt about sharing information they hold, or which has been requested of them

Matchday

Searching Children and Young People

To ensure the safety and security for all club activities all children and young people may be subject to our search processes. Children and young people must always be asked to self-search as the preferred method to try to avoid any unnecessary contact being made with them. However, should the club suspect that the child or young person may be concealing a prohibited item, consent will be sought from their parent or carer before a suitably trained steward or member of the Security team of the same sex conducts a search of the child while being observed by a supervisor. No search of a child or young person must ever be carried out in a one-to-one situation.

Lost or Missing Children and Young People

During club activities every effort is made to ensure children and young people remain with their parents, carers or the activity leaders. Should a child or young person become lost or go missing during a club activity every effort will be made to locate the child or young person as quickly as possible. Should the child or young person not be located within a reasonable timeframe, contact will be made immediately with their parents or carers and the police to file a missing child/young person’s report. In the event of any such report being made the issue must also be reported to the Safeguarding team at the earliest possible opportunity. Please see the lost child policy for further guidance.

Ticketing Strategy

Any supporter under 14 years old must be accompanied by, and seated with a qualifying adult, parent, or guardian, (age 18 years and over). Where seats directly together are not available, the Club will decide based on the proximity of the nearest seat, and the decision is not negotiable.

A maximum of two under 11s season/match tickets can be purchased with an adult’s season/match ticket. The club may use its discretion to judge each case on an individual basis where supporters request for more than 2 under 11s season/match tickets per adult. Please contact ticketingsupport@bradfordcityfc.co.uk if you want us to consider such a request.

Babes in Arms policy: Children under 2 who do not occupy a seat are admitted free of charge. Children aged 2 and over are -required to hold a match day or season ticket. The responsibility for the infant or baby’s welfare, comfort and safety always lie entirely with the parent during the match, pre- and post-match activities and always while on the footprint of the Stadium or any facilities on the periphery of the stadium whether that area is controlled by the football club. Specifically, parents must be aware there are risks to consider including, for example, the danger associated with a ball travelling at speed into the crowd, the impact of crowd noise on your baby and the potential for adverse weather. Therefore, the Club would recommend that infants and babies are not taken into sections of the stadium that are directly behind the goal in the North Stand Kop or South Stand or in the lower section of the West Stand. Within the West Stand, access to banqueting rooms may be allowed with one parent if the child becomes fractious or unsettled by the behaviour of the crowd or the noise while the match takes place. The Club has only limited baby-changing facilities available within the stadium. The Club is unable to offer any storage facilities for prams or buggies. Bradford City Football Club confirms that admittance of an infant or baby to a match is entirely at the discretion of the parents who make an informed decision in this regard following the outlining of the risk factors to them. We accept no liability in the event of a child being harmed in any way by one of the risk factors listed above or any other incident in the stadium.

Where many children are in attendance the safety officer will look at stewarding levels and the stewarding experience assigned to those areas of the ground. This will be covered off in the event specific risk assessments.

At every match there is a matchday safeguarding officer in attendance who will support in any instances where there are unaccompanied children, or in the case of any child been denied access to the ground.

Safeguarding Allegations Against Staff

Bradford City Football Club will always take concerns and allegations about employees and volunteers seriously and will respond in a way that places the protection and needs of children, young people, and adults at risk first.

The procedure will always be followed in respect of all cases where it is alleged that an employee or a volunteer has:

The full policy can be found in Appendix 2

Prevent

Radicalisation & Extremism

The following definitions are taken from the HM Government Prevent Strategy 2011. Radicalisation is defined as the process by which people come to support terrorism and extremism and, in some cases, to then participate on terrorist activity.

During the process of ‘radicalisation’ it is possible to intervene to prevent vulnerable people being drawn into terrorist-related activity.

Extremism is vocal or active opposition to fundamental British values including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. We also include in our definition of extremism calls for the death of members of the armed forces.

Please note that being drawn into terrorism includes not only violent extremism but also non-violent extremism. Extremism can take several forms, including Islamist extremism, far right and animal rights extremism for example.

The Prevent Duty is part of the UK Counter Terrorism Strategy (CONTEST), based on the Counter Terrorism and Security Act of 2015. It requires public bodies, including local authorities, the police, prisons, providers of probation services, schools, colleges, and universities to act to prevent people from being drawn into terrorism, ensuring awareness of risks of terrorism. The Prevent duty applies to those bodies, which include, for example, children’s homes and independent fostering agencies and bodies exercising local authority functions whether under voluntary delegation arrangements or via the use of statutory intervention powers. These bodies should ensure they are part of their local authorities’ safeguarding arrangements, and that staff are aware of and know how to contribute to Prevent-related activity in their area where appropriate.

The Club recognises that some children and young people are more vulnerable to radicalisation, including those who may be isolated/marginalised in society (through mental health or disability) and may have no other support. Children who attend sports activities are not immune from this risk and therefore the Club ensure that all staff who work with children and young people are equipped at identifying potential indicators of abuse regarding radicalisation and extremism.

There are often no obvious signs of extremism. There are frequent requests for a list of signs. but although changes in behaviour and dress are often cited as signs of extremism these will often be signs of perfectly normal behaviour, particularly among young people in their late teens and early 20s. There are some physical signs that would indicate concerns relating to extremism such as the tattoos that far right organisation supporters will sometimes display. You are not expected to be aware of the significance of tattoos but if you are worried about someone with what you think may be far right tattoos you should pass the details on to a Safeguarding officer. They can contact local Prevent coordinators for help if needed.

You should follow the Notice, Check, share approach used by provider organisations.

Notice: you should be aware of any behaviour which leads to any safeguarding concerns including Prevent duty related ones.

Check: you should check what their concerns.

Share: you should refer any concerns to the safeguarding officer or team. Any concerns you have will usually be like other Safeguarding concerns. These may include changes in behaviour; you should use your judgement to decide when these are worrying and when they are within the normal range.

There are concerns which should always be passed on such as:

evidence of sharing of extremist websites
evidence of homophobic.
religion based or racist bullying

It is your own judgement which will lead you to decide to refer a Safeguarding concern whether that relates to extremist exploitation or any other kind of exploitation It should be noted that individuals taking their religion more seriously, choosing to grow a beard or wearing a headscarf for religious reasons are NOT signs of extremism

Late collection of children

It is the parent/carer’s responsibility to ensure that their child is dropped off and collected by a responsible person if it is not safe for the child to walk home unsupervised. Unless written permission has been given for the child to walk home alone or to be picked up by another individual, coaches should not discharge the child from their responsibility. Whether a child has participated in a training session, fixture or is arriving back from a trip or tour, when collected parents must use the designated waiting area. Staff have a responsibility to ensure that they have signed all children out appropriately.

For Academy activities the following applies: Only players who have been given prior written permission to walk home alone may do so. These players must still sign out on the register; and Any player being collected by their parent/carer who does not have permission to walk home alone must be signed out by parent/carer before they leave. All parents / carers are made aware that their children should be met no later than 15 minutes after an activity has finished. Should a child not be collected within 15 minutes, coaching staff have emergency contact numbers and should communicate with the phase lead to seek alternative numbers if necessary.

If a child is not collected on time, a minimum of 2 coaching staff and/or responsible adults will wait at the venue until the parent / carer arrives. A young person should not be left alone with member of staff unless it is unavoidable and in this instance a manager or safeguarding lead should be notified immediately.

Whistleblowing

If you’re worried about poor or unsafe safeguarding practices, or potential failures in the club or Academy, talk to the Designated safeguarding Lead, any senior leader, or the CEO. The complaints policy details this further. If you feel unable to talk to someone in the club, you can call the NSPCC whistleblowing helpline on 0800 028 0285 or email: help@nspcc.org.uk.

Amendment History

Date	Version	Author	Details of Amendment
Unknown	1	James Mason	Initial Release
February 2019	2	Paula Watson	update following EFL audit visits
July 2019	3	Paula Watson	Annual Review
November 2019	3b	Paula Watson	to comply with EFL checklist
September 2020	4	Paula Watson	To update to comply with KCSIE 2020
March 2021	4b	Paula Watson	New CEO, add in of whistleblowing paragraph
September 2021	5	Paula Watson	Updated following feedback from the Barnados Safeguarding Audit
September 2022	6	Paula Watson	Annual Review
Nov 22	6b	Paula Watson	Update following review by local Authority
Dec 23	7	Paula Watson	Annual Review

Appendices

List of Appendices

Appendix 1 - signs and indicators of abuse

Appendix 2 - Safeguarding allegations against staff policy

Appendix 3 – definitions

Appendix 4 - Guidance for dealing with a disclosure

Appendix 5 – online safety links

Appendix 6 - Other applicable Club Policies:

Bullying & Harassment Policy (Employment Policy).
Data Handling and Protection Policy.
Disciplinary Policy (Employment Policy).
Equal Opportunities Policy (Employment Policy).
Grievance Policy (Employment Policy).
Health & Safety Policy.
Complaints Policy.
PREVENT Guidance.
Staff Safeguarding Allegations
Lost Child process

Policy Relevant Legislation/Regulations:

Children Act 1989.
Children Act 2004.
Crime and Disorder Act 1998.
Data Protection Act 1998.
FA Safeguarding Children Rules.
FA Respect Codes of Conduct.
Human Rights Act 1998.
Police Act 1997.
EFL Guide for Safer Working Practice.
EFL Rules.
Protection of Children Act 1999.
Protection of Freedoms Act 2012.
Rehabilitation of Offenders Act 1974.
Safeguarding Vulnerable Groups Act 2006.
Sex Offenders Act 1997.
Sexual Offences Act 2003.
Youth Evidence & Crime Evidence Act 1999.
Working Together 2022
Keeping Children Safe in Education 2022

Please note that these lists are not exhaustive

Appendix 7

Useful Contact Details

Senior Safeguarding Officer safeguarding@bradfordcityafc.com T: 07494 209130

If there are any concerns about the above-named person, then any of the external agencies can be contacted or Ryan Sparks (CEO) can be contacted via hello@bradfordcityafc.com

Bradford Council Children Safeguarding Services (Integrated Front Door) During Working Hours: Monday to Thursday 8:30am to 5:00pm, Friday 8:30am to 4:30pm First Contact Team:01274 435600– out of hours 01274 431010

Police - 101 or 999 in an emergency

FA NSPCC – 0808 800 5000 Child Line – 0800 1111

Appendices

Appendix 1

Information about types of abuse

Children may be abused or suffer neglect through the infliction of harm, or through the failure to act to prevent harm. Abuse can occur in a family or an institutional or community setting. The perpetrator may or may not be known to the child.

Abuse can happen to a child regardless of their age, gender, race or ability. Abusers can be adults (male or female) and other young people and are usually known to and trusted by the child and family.

Physical abuse: Any deliberate act causing injury or trauma to another person, for example, hitting, slapping, pushing, kicking, burning, giving a person medicine that they do not need and/or that may harm them or application of inappropriate restraint measures.

Emotional abuse: Any act or other treatment which may cause emotional damage and undermine a person’s sense of well-being, including persistent criticism, denigration or putting unrealistic expectations on vulnerable groups, isolation, verbal assault, humiliation, blaming, controlling, intimidation or use of threats.

Sexual abuse: Any act which results in the exploitation of children and adults at risk, whether with their consent or not, for the purpose of sexual or erotic gratification. This may be by an adult or by a young person who is intellectually, emotionally, physically or sexually more mature than the victim. This includes non-contact activities, such as indecent exposure, involving children or adults at risk in witnessing sexual acts, looking at sexual images/pornography or grooming them in preparation for abuse (including via the internet). Whilst legally Children aged sixteen have reached the age of consent for sexual activity, it is unacceptable for any member of Staff to abuse their relationship of trust for sexual gratification.

Child exploitation & Child sexual exploitation:

CSE and CCE are forms of abuse and both occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into sexual or criminal activity. Missing education can also be a sign of CCE, including involvement in County Lines

Peer-on-peer abuse: Children and young people can be taken advantage of or harmed by adults and by other Children. Peer-on-peer abuse is any form of physical, sexual, emotional and financial abuse, and coercive control, exercised between Children and within Children’s relationships (both intimate and non- intimate). All incidents of this and Sexting will be followed up. there is an inappropriate images policy in place at the club. Definition now widened to include Bullying (including cyberbullying), Up skirting and abuse within intimate partner relationships

Neglect: Ongoing failure to meet the basic needs of children. Neglect may involve; failing to provide adequate food, shelter including exclusion from home or abandonment, failing to protect them from physical and emotional harm or danger, or the failing to ensure access to appropriate medical care or treatment. It may also include neglect of or unresponsiveness to basic emotional needs.

In an activity setting, it may involve failing to ensure that children are safe and adequately supervised or exposing them to unnecessary risks.

Grooming: Grooming is defined as developing the trust of an individual and/or their family for the purposes of sexual abuse, sexual exploitation, or trafficking. Grooming can happen both online and in person.

Female genital mutilation (FGM): Involves procedures that intentionally alter or injure female genital organs for non-medical reasons. The procedure has no health benefits for girls and women. The Female Genital Mutilation Act makes it illegal to practise FGM in the UK or to take girls who are British nationals or permanent residents of the UK abroad for FGM whether it is lawful in another country.

Bullying: Repeated behaviour intended to intimidate or upset someone and/or make them feel uncomfortable or unsafe, for example, name calling, exclusion or isolation, spreading rumours, embarrassing someone in public or in front of their peers, threatening to cause harm, physically hurting someone, or damaging their possessions.

Cyberbullying: The use of technology to harass, threaten, embarrass, humiliate, spread rumours, or target another person. It occurs among Children. When an adult is the victim, it may meet the definition of cyber harassment or cyberstalking. Bullying because of any form of discrimination:

Bullying because of discrimination occurs when motivated by a prejudice against certain people or groups of people. This may be because of an individual’s ethnic origin, colour, nationality, race, religion or belief, gender, gender reassignment, sexual orientation, or disability. Actions may include unfair or less favourable treatment, culturally insensitive comments, insults, and ‘banter’.

Hazing: Any rituals, initiation activities, action, or situation, with or without consent, which recklessly, intentionally or unintentionally endangers the physical or emotional well-being of Vulnerable Groups

Infatuations: Vulnerable Groups may develop an infatuation with a member of Staff who works with them. Such situations should be handled sensitively to maintain the dignity and safety of all concerned. Staff should be aware that in such circumstances, there is a high risk that words or actions may be misinterpreted and that allegations could be made against Staff. Staff should therefore ensure that their own behaviour is above reproach. A member of Staff who becomes aware that a Child may be infatuated with him/ her, or with a colleague, should discuss this at the earliest opportunity with the Club Designated Safeguarding Officer (or the Club Senior Safeguarding Manager in his/her absence).

‘honour-based’ abuse: ‘honour-based’ violence to include incidents or crimes committed to protect or defend the honour of the family and/or the community. Incorporates FGM, forced marriage, breast ironing and similar. Wider definition than the previous violence-based model similar to the shift in perception of domestic abuse rather than just domestic violence.

Domestic violence: Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence, or abuse between those aged sixteen or over, who are or have been intimate with partners or family members regardless of gender or sexuality. This can encompass but is not limited to psychological, physical, sexual, financial, emotional abuse and so called ‘honour’ based violence. All children can witness and be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members. Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.

Fabricate or induced illness: Fabricated or Induced Illness is easiest understood as illness in a child which is fabricated by a parent or person in loco parentis. The child is often presented for medical assessment and care, usually persistently, often resulting in multiple medical procedures. Acute symptoms and signs of illness cease when the child is separated from the perpetrator.

Forced Marriage: A marriage in which one or both spouses do not (or in the case of some adults with learning or physical disabilities or children, cannot) consent to the marriage and duress is involved. Duress can include physical, psychological, financial, and sexual pressure. A Forced Marriage is different from an arranged marriage, which is a marriage entered into freely by both parties, although their families take a leading role in the choice of partner. The Anti-social Behaviour, Crime and Policing Act 2014 made it a criminal offence (which can result in a sentence of up to 7 years in prison) to force someone to marry.

Private fostering: A privately fostered child is a child under 16 (or 18 if disabled) who is cared for by an adult who is not a parent or close relative where the child is to be cared for in that home for 28 days or more. Close relative is defined as “a grandparent, brother, sister, uncle or aunt (whether of the full blood or half blood or by marriage or civil partnership) or step-parent.'' A child who is looked after by a local authority or placed in a children’s home, hospital or school is excluded from the definition. In a private fostering arrangement, the parent still holds Parental Responsibility and agrees the arrangement with the private foster carer. A child (as per definition above) placed with a host family for 28 days or more is in a private fostering arrangement and therefore Clubs with host families should inform and work with their local authority ensuring that they meet legislative and local procedural requirements.

County Lines: County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs into one or more importing areas within the UK, using dedicated mobile phone lines or other form of “deal line”. They are likely to exploit children and adults at risk to move and store the drugs and money and they will often use coercion, intimidation, violence (including sexual violence) and weapons. Child Criminal Exploitation is common in county lines and occurs where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or young person under the age of 18. The victim may have been criminally exploited even if the activity appears consensual. Child Criminal Exploitation does not always involve physical contact; it can also occur using technology. Criminal exploitation of children is broader than just county lines and includes for instance children forced to work on cannabis farms or to commit theft.

Non recent Abuse: Allegations of harm or abuse may be made some time after the event, e.g., by an adult who was abused as a child or by a member of staff who is still currently working with children. Where such an allegation is made, we will follow the procedures as detailed in this policy and report the matter directly to the Police or Social Services.

Hate Crime: A hate crime is any criminal offence which is perceived by the victim, or anybody else, to be motivated by hostility or prejudice towards someone’s race, religion, sexual orientation, transgender identity, or disability (protected characteristics). A hate crime can include verbal abuse, intimidation, threats, harassment, assault, and damage to property. Hate crimes not only harms victims, but children may also be impacted as a result of a hate crime against someone else in their family or a friend. The club has a Hate crime reporting policy which can be referred to for more information.

Appendix 2

Safeguarding Allegations against Staff Policy (version 2, August 2022)

This policy sets out a framework on steps required if an allegation of child or adult abuse is made against a member of staff or a volunteer.

This policy applies to all Bradford City Football Club and Academy staff and anyone working on behalf or undertaking work or volunteering for the football club. It provides a framework to ensure appropriate actions are taken,

regardless of whether they are made in connection to duties with the football club or if they fall outside of this such as in their private life or other capacity.

This policy should be read alongside relevant BCAFC policies relating to safeguarding of individuals. The purpose of this Policy is to provide a framework for managing cases where allegations are made about staff that indicate that children, young people, or adults at risk are believed to have suffered, or are likely to suffer, significant harm. Concern may also be raised if the staff member is behaving in a way which demonstrates unsuitability for working with children, young people, or adults at risk, in their present position, or in any capacity. The allegation or issue may arise either in the employee’s/professionals work or private life.

Examples include:

Behaving in a way that has harmed a child, or may have harmed a child /adult
Possibly committing a criminal offence against/related to a child/adult.
Behaving towards a child in a way that indicates he or she would pose a risk of harm to children/adults at risk
Failing to work collaboratively with social care agencies when issues about care of children, young people, or adults at risk of harm or abuse for whom they have caring responsibilities are being investigated.
Behaving towards children, young people, or adults at risk, in a manner that indicates they are unsuitable to work with children, young people or adults at risk of harm or abuse. This includes unknown previous child abuse.
Where an allegation or concern arises about a member of staff, arising from their private life such as perpetration of domestic violence or where inadequate steps have been taken to protect vulnerable individuals from the impact of violence or abuse.
Where an allegation of abuse is made against a person closely associated with a member of staff, who puts a child or adult at risk

This policy is focused on management of risk, based on assessment of harm and abuse.

Definitions of harm as detailed in the Children Act 1989 / 2004, ‘No Secrets’ (2000), and the Care Act (2014) can be categorised as below

There are four categories of Child abuse:

Neglect
Sexual
Emotional
Physical

There are ten categories of abuse for adults:

Application and Scope

This policy applies to all employees and contractors of the Football Club, including volunteers, students, honorary appointees, trainees, contractors, and temporary workers, including those working on an agency contract. This list is not exhaustive but encompasses all that work for and on behalf of BCAFC.

For ease of reference, all employees and workers who fall under these groups will be uniformly referred to as “staff” in this document

The policy covers allegations made against staff during their BCAFC duties and outside of this, including their private life and family home.

Although managing safeguarding allegations against staff is required under the Children Act (1989 /2004), this policy also applies to adults at risk of harm or abuse as per the Care Act (2014). Working Together to Safeguard Children and Young People (2018) sets out expectations that all statutory organisations will have a procedure for managing allegations against staff.

Managing Allegations – Immediate Actions

Safety of child / adult at risk is a priority

Assessment by Children/Adult Social Care, about whether a child/young person/ adult at risk of harm or abuse, needs protection or in need of services.
Referral to LADO Local Authority Designated Officer within 24 hours.

The safety of the child, young person or an adult at risk is of paramount importance.

Immediate action may be required to safeguard investigations and any other children, young people, or adults at risk. Any concern that children, young people or adults may be at risk of harm or abuse, must immediately be reported.
Careful consideration of issues relating to wider reputational damage also needs to be considered. If reputational damage is of concern, advice may be sought from the EFL Safeguarding team.
All staff must be familiar with referral procedures to protect an adult/child at risk. The concern must also be reported to the staff member’s line manager, who should take advice from the Safeguarding Team.

The Club will have a Senior Safeguarding Senior Officer (SSO)of significant seniority to make decisions on behalf of BCAFC.

Procedure for Reporting and Managing Allegations

It is essential that every effort must be made to maintain confidentiality and manage communications while an allegation is being investigated. Information is shared on a need-to-know basis.

On becoming aware of an issue of concern (as outlined in section one above) all staff have a duty to inform their Line Manager immediately who will inform the SSO who should:

Ensure (if appropriate) that a child protection/adult at risk referral is made (or has been made) to the relevant Children/Adult Social Care Team.
The referral must be put in writing to Children/Adult Social Care by the individual reporting the concerns within 24 hours or in the event of a weekend the earliest opportunity of the next working day. Where the issue is in relation to safeguarding children, the SSO will liaise with the Local Authority Designated Officer (LADO) within 24 hours, who will agree with the SSO any information that needs to be shared with other geographical areas depending on where the staff member lives.
Immediate issues of investigation and management of the employee should be discussed and agreed at this time, including what information should be passed to the staff member who is suspected of an allegation.

Where the issue is in relation to an adult at risk of harm or abuse, the SSO will discuss the case and allegations with the police and the relevant adult social care department manager and identify which agency will be leading on the investigation.

In conjunction with the Director of Operations and the staff member’s line manager, decide whether suspension (neutral act) is appropriate during the period of investigation. The senior manager, or Director of Operations will advise on the authority levels and process requirements for this action.

Director of Operations advice will be pertinent to staff who are agency, secondees, or self-employed staff working on behalf of the Club.

Following notification to the LADO, children/adult Social Care and/or the Police if deemed necessary, the SSO should undertake an internal Crisis Planning Meeting (see separate policy) with the appropriate personnel to decide how to manage the allegation. This group should include the Line Manager and a senior member of staff from department

concerned; Nominated Safeguarding Senior Officer; and Safeguarding Lead. Designated professionals may also be invited, as a safeguarding expert.

Crisis Planning Meeting- (the following issues should be considered;)

Whether the child/young person/adult at risk of harm or abuse is safe from any further risk of harm or abuse
The safety of the young child/person/adult at risk.
Review action undertaken so far to ensure the safety of the victim.
Decide the internal investigation strategy to be undertaken. The Police and / or
Social Care should be consulted when they are involved in any on-going investigation and/or criminal proceedings are pending.
A referral to the EFL and FA if appropriate.
Decide how to present the allegations to the relevant staff member concerned and how to manage the investigatory process. Agreement should be reached with children/adult Social Care and the Police about what information should be passed to the staff member concerned.
The Line Manager should be asked to provide appropriate support to the individual while the case is on-going and keep them regularly informed.
Where police investigations are ongoing, any internal action could be delayed pending police findings. Engagement with the police will be required throughout this period.
Further support may be considered necessary from Occupational Health.
Decide how the person/child/ adult at risk of harm or abuse, or their nominated parent/guardian/nominated carer making the allegation is to be kept informed of what is happening to their allegation, whilst adhering to the requirements of maintaining confidentiality and observing the requirements of the Human Rights Act and the Data Protection Act. The sharing of information must not ‘contaminate’ any club, Police or children/adult Social Care investigations that are on-going.
The CEO should provide additional support and advice in relation to the handling of any queries from the media concerning the allegation. Decide the frequency and format of review meetings which need to be set up to manage the on-going investigation and the various actions required.

Procedure for Reporting/Managing Allegations; Non-Directly Employed Staff

The allegation must also be shared with their employer or the body that engaged them at the earliest opportunity. The following are examples of some potential scenarios that might arise, but this is not exhaustive.

Allegations made against agency workers must be reported to the appointing agency and the Club
Allegations made against workers employed by external contractors should be referred to the contractor and the BCAFC lead employee responsible for managing the service level agreement with the contractor.

Allegations made against volunteers undertaking duties for or on behalf of BCAFC must also be reported to the voluntary body the person is volunteering with.

The SSO should be appointed for such allegations and undertake the duties set out above.

The SSO will need to engage with the other relevant parties outlined above to decide how the allegation should be managed. These scenarios are likely to be complex and the SSO should take early advice from their local safeguarding leads.

It is recommended that a meeting is held between BCAFC and the other party/parties at the earliest opportunity, noting the responsibility to report issues to the Police and/or Social Care teams within 24 hours of the allegation being received. Such parties should be asked to attend the crisis meeting.

Even though allegations against such workers should be reported as above, BCAFC still retains a responsibility to consider how the allegations should be managed if the allegation has a connection with, or relevance to, the duties that the worker undertakes with the Club. All such allegations also need to be reported and escalated within the Club in accordance with this policy.

Assumptions should not be made that the other party has referred the matter to the police or relevant other body – evidence needs to be promptly provided and if this is not forthcoming then the Safeguarding Senior Officer appointed to deal with the case should do so on behalf of the Club and advise the other party accordingly.

FA Referral

All concerns should be discussed with the FA safeguarding team via the online referral form.

Disclosure and Barring Service (DBS)

As an employer of staff in a ‘regulated activity’ BCAFC also has a responsibility to refer concerns to the DBS in accordance with the Safeguarding Vulnerable Groups Act 2006. Managers must report concerns to the safeguarding team.

The following groups may be referred for information to the Disclosure and Barring Service:

If an employee or worker of the Club has been permanently removed from ‘regulated activity’ through dismissal or permanent transfer from ‘regulated activity’, or where they would have removed or transferred that person from regulated activity if they had not left, resigned, retired or been made redundant, and they believe the person has:
- engaged in ‘relevant conduct’
- satisfied the ‘harm test’ (i.e., no action or inaction occurred but the present risk that it could occur was significant); or
- received a caution or conviction for a ‘relevant offence’ (see DBS website www.gov.uk/disclosure-and-barring-service-criminal-record-checks-referralsand- complaints).

A referral to the DBS should be made following initial information gathering to establish whether there is cause for concern. A referral should be made even if the person in question has left BCAFC before an investigation and/or disciplinary process has been completed. However, it is important to note that the DBS has no investigatory powers and therefore relies upon evidence supplied to it. Managers therefore have a responsibility to complete investigations as far as possible, even where the individual leaves before investigations can be completed, so that the DBS has enough substantiated evidence on which it can base its decision. If additional information becomes available after making a referral this should also be provided to the DBS.

The referral should be made using the DBS referral form and posted to the DBS enclosing all relevant information held. Please see further guidance and information at https://www.gov.uk/government/publications/dbs-referrals-form-andguidance

Record keeping

The SSO will have the responsibility for ensuring the following records are kept:

The nature of the allegation/concern.
Who was spoken to as part of the process and what statements/notes were taken and when.
Any records that were seen and reviewed.
What actions were considered and justification for specific decisions, including suspension and any actions taken under the Club Disciplinary Procedure.
What alternatives to actions were explored?
Minutes and actions of all meetings that take place.
All documents must be accessed and retained in accordance with the requirements of

General Data Protection Regulation (2018)

All records should be saved in a secure area, on TOOT TOOT safeguarding software and on password protected drives as they may need to be accessed, the folder should be restricted to certain personnel on the shared drive.

For these particular records.

Name the files appropriately.
Apply a retention period in accordance with the requirements of Records Management:
Save in an agreed area and apply security measures to the records as they contain personal information
Remember that emails can form part of records or can be seen as individual records, so if they are also a critical part of the investigation, they should also be securely stored in the file accordingly.

Post Investigation Review

Following the completion of the initial investigation, the Safeguarding Senior Officer will lead a review of the case and its actions. This will be passed to the CEO for review.

Further actions may still be pending, including consideration of disciplinary matters or an ongoing criminal investigation.

Any recommendations from the review will be implemented and information disseminated to the appropriate people within the organisation.

As well as supporting the member of staff throughout the investigation, consideration must be paid to supporting the member of staff through integration back into the workplace should this be appropriate post-investigation.

On-going support for the member of staff may be offered through the GP or Chaplain.

Monitoring

The Club will monitor compliance of this policy.
The SSO is responsible for the monitoring, revision and updating of this policy.

Related Policies and Documents

Safeguarding Children
Safeguarding Adults at risk Policy
Crisis management policy

Managing allegations against a staff member flow chart

If the allegation is against a non-employed individual, SSO to work with employer and unless provided evidence of referrals to directly refer to local authority

Appendix 3

Definitions

A child is defined as under the age of 18 (The Children Act 1989). However, for the purpose of the Club’s Safeguarding policies and practices for home match day supporters, when referring to a child, the policies refer to a person under 14 years of age. Supporters under 14 years of age are not allowed to enter the stadium without a qualifying adult (age 18-years and over). As a result, and in line with reasonable adjustments, any supporter who is under 14 years of age must attend with their parent or guardian. Supporters over 14 years and under 18 years are allowed to enter the stadium unaccompanied however they are not allowed to be responsible for another supporter. Only supporters aged 18 years and over can be responsible for a supporter under the age of 18 years.

Adults at Risk are defined as an adult (person aged 18 or over) who is receiving one of the following services: health care; relevant personal care; social care work; assistance in relation to general household matters by reason of age, illness, or disability; relevant assistance in the conduct of their own affairs or conveying (due to age, illness or disability in prescribed circumstances). We have a separate adult at risk policy.

Staff or employees is defined as any member of the workforce either paid or unpaid.

Vulnerable Groups is defined as the collective term used when talking about or referring to children, young people, and adults at risk. We recognise that children with special educational needs and disabilities can face additional safeguarding challenges, and we have a risk assessment process in place for any such circumstances.

Appendix 4

Guidance for Dealing with a disclosure

Through appropriate training, staff and volunteers will become more confident in dealing with concerns, allegations, and disclosures.

The role of staff and volunteers is to:

Child or Adult makes a disclosure. Staff recognise signs of abuse Safeguarding concern is raised within a local community
Keep calm and reassure the child or adult Ask for further details Do not ask leading questions Explain you will have to pass the information on
Allow the child or adult to talk at their own pace Use their own language and listen attentively Do not pressure them into telling you things they don’t want to disclose Gather information
When a child or adult is at immediate risk of harm keep them at a safe place and make immediate contact with the Head of Safeguarding, Local authorities/police
Make a detailed factual report including times, dates, quotes and complete a referral to the Head of safeguarding and ensure the concern is recorded on TOOT TOOT (child protection online management system)

Appendix 5

Online safety links:

These include:

UK Safer Internet Centre https://reportharmfulcontent.com/

CEOP https://www.ceop.police.uk/safety-centre/

Internet Matters https://www.internetmatters.org/

NetAware https://www.net-aware.org.uk/

ParentInfo https://parentinfo.org/

ThinkuKnow https://www.thinkuknow.co.uk/

SANCTIONS AND BANNING POLICY

Details about sanctions & appeals can be found below.

Matchday banning process

If the Club feels your conduct is unacceptable on a matchday you may be ejected from The University of Bradford Stadium. Where the police are involved, the duty police officer will advise you at this point if you will be arrested for the alleged incident. In addition, your season ticket will be confiscated. 

If your ejection warrants a police enquiry, the Club will provide reasonable assistance to West Yorkshire Police for the purposes of their investigation. Your season ticket will be suspended, pending the police investigation. 

If your ejection falls within the direct remit of Bradford City Football Club, the Club’s Sanctions & Appeals Committee will be presented with evidence in relation to your ejection within five working days of the match and will decide what action, if any, should be taken. 

Where appropriate, Bradford City AFC will liaise with the away club when carrying out an investigation, to identify the individual/s suspected of engaging in the relevant conduct. 

Social media banning policy

Bradford City Football Club’s Social Media Banning Policy states that any individuals or groups observed to be making discriminatory or abusive comments on the official social media channels should be banned using each social network’s reporting/banning mechanism. 

Any online conduct deemed to be a Hate Crime reported to the Police.

Bradford City AFC is a family club and is connected online with supporters of all ages from a wide variety of backgrounds. As such, the Club’s social media accounts should harbour an environment and community that is welcoming and free of inappropriate messages/ behaviour. 

The Club’s Media Department regularly monitor posts for such behaviour where possible and when it is reported to the Football Club, to action the banning policy upon finding the post. 

Banning offences include swearing, threatening messages, any post that discriminates against protected characteristics and other behaviour that the Club deems inappropriate on its channels. This includes, but is not limited to, general spam and the posting of links to illegal match streams. 

Protected Characteristics (Equality Act 2010):

Age
Disability
Gender reassignment 
Marriage and civil partnership
Pregnancy and maternity
Race
Religion or belief 
Sex
Sexual orientation 

Social networks include, but are not limited to: Facebook, X, YouTube, Instagram and TikTok. 

All banned/blocked accounts from BCAFC media channels are made at the Media Department’s discretion. Bradford City AFC does not tolerate online abuse in any form and if you are a Season Ticket Holder, Member, or match by match purchaser of tickets to club fixtures, you will receive automatic match bans and will be referred to the Sanctions & Appeals Committee. You will be advised of the length of your matchday ban within 10 working days of the offence. 

If you use online abuse on non-BCAFC media channels, towards the Club, our players, or staff, you will be reported to the social network company and if you are a Season Ticket Holder, Member, or match by match purchaser of tickets to Club fixtures, you will receive automatic match bans and will be referred to BCAFC Sanctions & Appeals Committee. You will be advised of the length of your matchday ban within 10 working days of the offence. 

Persistent standing

Supporters who have been ejected form the stadium for not adhering to persistent standing regulations will be subject to a club follow up meeting and sanctions (as per the process outline din this document).

Sanctions

Depending on the severity and nature of your conduct/offence, the Club may issue sanctions as it sees fit. A non-exhaustive list of possible sanctions is below: 

Acceptable Behavioural Contract – this is a contract you sign in the presence of the clubs safety officer and/or the Police whereby you agree to behavioural standards at all home and away games. Further indiscretions would then lead to one of the below sanctions been imposed. For any under 18s we would ask for a parent/guardian to be present for any meetings.

Education or restorative Justice

Written warning 
One home match ban 
Three home match ban 
Six home match ban 
Twelve home match ban 
Season ban 
Indefinite ban 

If you were not ejected from the stadium on the matchday but information is passed to the Club after the game, we will endeavour to contact you as soon as we are able to following the reported alleged offence/incident. 

SECOND OFFENCES WILL AUTOMATICALLY CARRY A LENGTHIER BAN. 

Appeals process

Supporters who wish to appeal must lodge their appeal via a letter addressed to Supporter Sanctions Appeal Board, Bradford City Association Football Club, The University of Bradford Stadium, Valley Parade, Bradford, BD8 7DY or via email to hello@bradfordcityafc.com stating the reason for their appeal, within seven working days of the date of their sanction. 

Your appeal will be brought before the Club’s Appeals Committee* and you will be advised of the outcome within 14 working days. 

Should you be dissatisfied with the response from the Club in relation to a Matchday Club Banning Order, you may contact: Independent Football Ombudsman, Suite 49, 57 George Street, Leeds, LS1 3AJ or alternatively email contact@theifo.co.uk or telephone 0800 588 4066. 

*The Appeals Committee would usually comprise of a senior staff member not involved in the initial sanctioning decision, the SLO, and where practical a nominated supporter representative.

The club reserves the right to change who sits on the appeals committee at any point with no notice required

SPECTATOR SAFETY POLICY

Document Ref:	Spectator Safety Policy
Version:	2
Date of version:	March 2023
Author:	Paula Watson
Approved by:	Stefan Rupp Ryan Sparks
Confidentiality level:	Internal, SGSA, SAG

Policy Statement

This Spectator Safety Policy is compliant with the requirements and principles of The Equality Act 2010, particularly in respect of Part 7, dealing with ‘associations’ and membership.

It also complements, and operates in conjunction with, Information Sharing Agreements held between Bradford City Football Club and the Police, Football Authorities and other Football Clubs and relevant venues and in compliance with GDPR.

This Policy will be applied fairly, equally, and consistently to all persons, irrespective of age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation or any other unjustifiable grounds.

Purpose

Bradford City Football Club requires a clear and concise Spectator Safety Policy to demonstrate the Club’s responsibilities for a ‘Specified Activity’, to clarify where lines of accountability exist and to outline the operational arrangements in place.

A ‘Specified Activity’ is an activity authorised by the General Safety Certificate to be held at Valley Parade Stadium.

Underpinning Procedures

Allocation of Responsibilities

The Chairman of Bradford City Football Club undertakes to ensure that all the activities that take place at Valley Parade, for which they are responsible, are conducted in such a way that the safety of every person at the stadium is maximised.

Overall Executive responsibility for Spectator Safety remains with the Chairman. The CEO is appointed to assume strategic responsibility for safety.

This individual should:

lead any discussion on safety matters at a strategic level, which, forms a standing item on the agenda of every executive, board or management meeting
report to the executive on safety issues
ensure that no decisions are made at a senior level that might compromise safety during events
support the work of the Safety Officer

During an event, the responsibility for tactical and operational decisions rest with the Safety Officer, unless or until the seriousness of an incident calls for external agencies, such as the police or fire service, to share or assume control, as laid down in the management's Event Safety and/or the Statement of Intent.

Operational responsibility for Spectator Safety is held by the Matchday Safety Officer.

The Club's operational delivery of this responsibility is managed through the Club Director of Operations, the Club Safety Officer, deputy and officials, staff and stewards who will be trained, qualified as appropriate, briefed and deployed in such a manner as to ensure the safety of those attending the stadium for a ‘Specified Activity’. There is a duty upon all employees to ensure that the Spectator Safety Policy is fully adhered to at all times.

Safety policy is reviewed at regular intervals by the Club Safety Officer and Director of Operations, and at least on an annual basis.

Safety Management Structure & Chain of Command

Arrangements for Communicating the Safety Policy

This policy will be distributed and explained to all matchday staff, contractors, and third party agencies at induction and annually.

Arrangements for Monitoring Policy

The following methods are used to monitor the Spectator Safety Policy.

a) Daily basis:

Information on stadium safety issues are reported on a daily basis through contractors or Club staff to the Director of Operations. Any remedial action is actioned in accordance with the assessed level of priority.

b) Match Day:

Pre-match & event site checks are conducted by Club employees and supervisors, with any associated reports being submitted to the Club Safety Officer; Pre-match & event site searches and visual examinations are made by stewards and supervisors before the ground is opened to the public; Constant surveillance of the facility is conducted throughout the event and any identified issues are immediately reported through landlines or radio to the Stadium Control Room; Post-match & event site searches are conducted by stewards and supervisors, with any identified deficiencies being reported to the Club Safety Officer for the attention of the Director of Operations or Head of Maintenance; A full debrief of all steward Area Supervisors is conducted by the Club Safety Officer; Comprehensive post-event reports are compiled by each steward supervisor and submitted for the attention of the Club Safety Officer.

c) Periodic Independent Monitoring:

A delegation appointed by the Safety Advisory Group enters the stadium on an annual basis to examine the site against the Club’s Safety Certificate, and reports its findings and recommendations to the Club Safety Officer;

The Safety Advisory Group will commission an individual event report on a regular basis. The findings will be communicated to the Safety Advisory Group members and any recommendations discussed and actioned;

The Sports Group Safety Authority will conduct periodic assessments against the Club’s discharge of its responsibilities towards spectator safety and, where appropriate, will produce a written report with accompanying recommendations for the attention of the Club Safety Officer.

Consultation

All supporter complaints will be logged and will be reviewed at post match autopsies (Safety Officer Led). All matchday staff, contractors and volunteers will be encouraged to report (via matchday briefings) any safety issues via the matchday reporting forms or via the text and email channels to the safety officer.

Crowd Management

Entry and exit of spectators to the stadium:

The means of ingress and the gangways within the stadium are at all times kept unobstructed whilst spectators are within the stadium for a ‘Specified Activity’;

All floor surfaces and steps throughout the stadium, which are available for use by spectators, are kept unobstructed, unrestricted and free from trip hazards;

The entrances to, and exits from, the stadium, and the means of access to those entrances and exits, are as specified in the plan which forms part of the Safety Certificate;

Bradford City Football Club shall ensure that during the performance of a ‘Specified Activity’, spectators are not permitted to stand in a gangway for the purpose of viewing that activity;

No vehicles may be left within the stadium complex, except in specifically designated and marked locations;

No equipment, goods or mobile sales staff shall be positioned during a ‘Specified Activity’

so as to obstruct any exit route;

Bradford City Football Club shall arrange for the flow rate of each turnstile to be measured and thereafter for periodic tests to be made to ensure that the anticipated rate of flow is achieved. Flow rates should be reviewed whenever admission arrangements are amended. Details of the reviews will be recorded and any variation in flow rates notified, in writing, to the council. Management of spectators in the stadium:

Trained stewards and supervisors who are placed strategically throughout the stadium will carefully monitor all spectators whilst they are present inside the stadium.

The Stewarding Plan for each event outlines the specific steward deployment locations.

Coordination with other Agencies

At least 28 days before the ‘Specified Activity’ takes place, the Local Authority, Police, Fire Brigade and Ambulance service will be notified in writing of the ‘Specified Activity’.

Either the Club Safety Officer or Deputy will attend any pre-match briefings to all partner agencies. Information will be gathered from all sources and disseminated.

The Club Safety Officer or Deputy will Chair any required match-day briefings to all agencies and ensure post-match feedback is carried out.

Police

Bradford City Football Club shall arrange for the attendance at a ‘Specified Activity’ of as many Police Officers within the stadium as the Club and Police consider adequate to secure safe, orderly and decent behaviour within the stadium.

The General Safety Certificate gives discretion to the Police to vary the mandatory positions of stewards in the event of potential or actual public disorder.

Fire

Any item of a flammable, explosive, toxic or corrosive nature held within the stadium, together with its dispensing apparatus, is securely stored in locked areas clearly marked with warning signs and labels, and subject to a risk assessment. Only the minimum quantity required for frequently occurring activities or that required for use during one shift is ever present on the stadium site. Bradford City Football Club do not permit the storage of such items in such quantities that they require specific permits or authorities.

Bradford City Football Club shall at all times maintain the stadium in a clean condition and not permit any accumulations of rubbish or any other materials, whether combustible or not. All receptacles provided for this purpose are made of non-combustible materials.

Bradford City Football Club will arrange with qualified third party providers for the training of all stewards in the procedures of general fire prevention.

Clear notices giving instructions for action in case of fire are provided in such positions as recommended in the Fire Risk Assessment

Fire-fighting equipment and locations will be found in the General & Special Safety Certificate.

Medical Services

Bradford City Football Club shall ensure, to the satisfaction of the Safety Advisory Group, the provision and maintenance at the stadium of a suitably equipped First Aid Room.

The Club shall also arrange for the attendance of such number of qualified First Aid Attendants as its Medical Plan determines and as may be required by the Safety Advisory Group.

The Attendants' duties shall only relate to the administering of First Aid and they should be located as prescribed within the Medical Plan. First Aid Attendants shall be present at the stadium two hours prior to the start of the event and remain at the stadium until the public have egressed at the end of the event.

First Aid Rooms should have heating, lighting, emergency lighting, ventilation, hot/cold running water, electric sockets and telephone allowing internal and external communication. The First Aid Room should be sign-posted throughout the stadium and in such a position that is accessible to spectators, staff and stewards, along with ready access for emergency vehicles.

Bradford City Football Club shall ensure that the equipment and medical supplies within the First Aid Room are available for use at all times during a ‘Specified Activity’.

Bradford City Football Club shall employ one Medical Practitioner (in addition to any medical practitioner employed to treat players) to be present at each ‘Specified Activity’ and available to deal with any medical exigency at the stadium

He/she shall be trained and competent in advanced First Aid. He/she shall be present at the stadium before the public are admitted and at least one and a half hours before commencement of the ‘Specified Activity’ and must remain until half-an-hour after the end of the ‘Specified Activity’. The Medical Practitioner must be immediately contactable and his/her whereabouts known to Stadium Control Room.

Bradford City Football Club shall arrange with the appropriate Ambulance Service for the attendance of at least one Paramedic crew and one fully equipped Paramedic ambulance, along with the attendance of an Ambulance Officer at a ‘Specified Activity’ where between 5,000 and full capacity spectators are expected.

Contingency Plans

In conjunction with the Safety Advisory Group, Bradford City Football Club will develop contingency plans to deal with all foreseeable emergencies. These plans will identify appropriate individuals together with their respective tasks and will include precautions against electrical or mechanical failure.

Maintaining of Records

All documentation in respect of safety and duty of care will be maintained by Bradford City Football Club and made available for inspection by the Safety Advisory Group for a minimum period of six years.

TICKETING STRATEGY

This policy is written is produced and written to outline Bradford City AFC's ticketing strategy with the aim that it assists the safety management operation, and that commercial considerations alone do not compromise the efforts of the safety management team.

Document Ref:	Ticketing Policy
Version:	5
Date of version:	June 2022
Author:	Paula Watson, Marco Townson
Approved by:	Ryan Sparks - Chief Executive Officer
Confidentiality level:	Internal

Amendment History

Date	Version	Author	Details of Amendment
February 2019	1	Paula Watson	Initial Release
July 2019	2	Paula Watson	To bring in line annual July review
August 2021	4	Marco Townson	Inclusion of Direct Debit Scheme & e-tickets
June 2022	5	Paula Watson	Comp Ticket Policy added in

Overview

All sections of the ground, aisle, rows and individual seats will be clearly marked or numbered as per the ground plan and ticketing information. This will be inspected annually and reviewed wherever brought to our attention.

The ticketing strategy will be discussed at every pre match meeting held with safety, operational, and commercial teams before every fixture. Any amendments will be done on a risk assessed basis.

Concessions

The Club takes its responsibility for the safeguarding of children seriously, therefore any supporter under 14 years old must be accompanied by, and seated with, a qualifying adult, parent or guardian, (age 18 years and over). Where seats directly together are not available, the Club will decide based on the proximity of the nearest seat, and the decision is not negotiable.

A maximum of two under 11s season/match tickets can be purchased with an Adults season/match ticket. The club may use its discretion to judge each case on an individual basis where supporters request for more than 2 under 11s season/match tickets per adult. Please contact hello@bradfordcityafc.com if you want us to consider such a request.

Babes in Arms policy: Children under the age of 2 years of age will be admitted free of charge into the stadium subject to one child under 2 per full paying adult. The responsibility for the infant or baby’s welfare, comfort and safety always lie entirely with the parent during the match, pre and post-match activities and always while on the footprint of the Utilita Energy Stadium or any facilities on the periphery of the stadium whether or not that area is controlled by the football club. Specifically, parents must be aware there are risks to consider including, for example, the danger associated with a ball travelling at speed into the crowd, the impact of crowd noise on your baby and the potential for adverse weather. Therefore, the Club would recommend that infants and babies are not taken into sections of the stadium that are directly behind the goal in the North Stand Kop or South Stand or in the lower section of the West Stand.  Within the West Stand, access to banqueting rooms may be allowed with one parent if the child becomes fractious or unsettled by the behaviour of the crowd or the noise while the match takes place. The Club has only limited baby-changing facilities available within the stadium. The Club is unable to offer any storage facilities for prams or buggies. Bradford City Football Club confirms that admittance of an infant or baby to a match is entirely at the discretion of the parents who make an informed decision in this regard following the outlining of the risk factors to them. We accept no liability in the event of a child being harmed in any way by one of the risk factors listed above or any other incident in the stadium. Children aged over 2 are required to hold a season ticket or match ticket.

Where a large number of children are in attendance the safety officer will look at stewarding levels and the stewarding experience assigned to those areas of the ground.

At every match there is a matchday safeguarding officer in attendance who will support in any instances where there are unaccompanied children, or in the case of any child being denied access to the ground.

Ticket Redistribution/ third party sales

Conditions of use for tickets are readily available at the ticket office and online on both the club website and the ticketing website.

Season/Match Tickets are issued for your personal use and you shall not resell, dispose of, assign, (save as set out in clause 3.2 below) transfer or lend or otherwise deal with the Season Ticket or the benefit of it to any other person without the prior written consent of the Club. Further you shall not use the Season/match Ticket for any commercial purpose. The reference to reselling the Season/match Ticket includes reference to offering to sell a Season/match Ticket (including, without limitation, via any website or online auction site), exposing a Season Card for sale, making a Season/match Ticket available for sale by another person and advertising that a Season/match Ticket is available for purchase. For the avoidance of doubt (and by way of example only) this Season/match Ticket may not be offered as a prize in any promotion or competition nor transferred, lent or sold to any third party as part of a hospitality or travel package, given to a third party who agrees to buy another good or service, or used for any other commercial purpose or disposed of in any other way, save as expressly authorised by The Football League or the Club.

All concessionary Season/match Tickets must be used by a person of the age/concession category to which the Season Ticket is assigned in accordance with Clause 6. In the event of a person entering the Ground, or attempting to enter the Ground, with a concessionary Season/match Ticket for which he/she does not qualify the Season/match Ticket and relevant Season/match Ticket purchasing account will be suspended in accordance with Club policy and no refund will be given. The Club shall have the right to terminate the Season/match Ticket without liability and the Season/match Ticket holder may be refused future access to the Ground at the Club’s discretion. Further, any Season/match Ticket issued free of charge to a companion of a disabled or vulnerable supporter to enable such disabled or vulnerable supporter to attend Matches is only valid if the disabled or vulnerable person is present at the time and point of entry and throughout the duration of the Match. Concessionary Season Tickets may be upgraded for use by a Guest on a single match basis subject to availability, but such upgrade must be completed prior to the Season Ticket being presented at a turnstile.

You may only resell or transfer the Season/match Ticket to a Guest with the express written consent of the Club given at the Club’s absolute discretion. No such resale or transfer will be permitted except where the same takes place in respect of an individual match and in consideration of no payment or benefit in excess of the face value of a ticket to that Match and such transfer does not take place during the course of any business or for the purpose of facilitating any third party’s business save for any secondary ticketing operator expressly approved by the Club. Such resale or transfer to any Guest is hereby provided to be subject to the Terms and Conditions of Entry which will (save for any rights to transfer under this clause) apply to that Guest as if he/she was the original purchaser of the Season/match Ticket (and you must inform the Guest of this).

The unauthorised sale or disposal of tickets (including Season Tickets) is a criminal offence under section 166 of the Criminal Justice and Public Order Act 1994, as amended by the Violent Crime Reduction Act 2006. The Club will inform the police if it becomes aware that Season Tickets are being sold or disposed of illegally and will press charges against those breaking this law. If you are convicted of a ticket touting offence, or we reasonably suspect you have committed a ticketing offence, we will notify the relevant Football Authority who may in turn notify other Premier League/Football League Clubs and/ or the relevant law enforcement authorities. The information that we share may include your personal data, information about the offence and about ticket purchases (including payment details). We will use this to identify and prevent ticketing offences and disorder at matches.

The Season/match Ticket will always remain the property of the Club and must be produced together with evidence of your identity if required to do so by any official, steward or employee of the Club or any police officer. The Club reserves the right to require the immediate return of the Season/match Ticket.

Any Season/match Ticket obtained or used in breach of the Terms & Conditions of Entry shall be automatically void and all rights conferred or evidenced by such Season Ticket shall be nullified. Any person seeking to use a Season/match Ticket in breach of the Terms and Conditions of Entry in order to gain entry to the Ground or remain at a Match will be a trespasser and will be refused entry to, or ejected from, the Ground in respect of a Match and/or the cancellation, suspension or withdrawal of this Season Ticket. In the event of any cancellation, suspension or withdrawal in accordance with this clause

Physical ticket information and design

The reverse of the ticket shows ground plans, with names of stands and blocks and turnstile numbers.

The front of the ticket shows block numbers and corresponding turnstile entrances. This information is on the ticket part which is retained after entrance to the ground.

Additionally the front of the ticket contains a QR code which is individually numbered and can be blocked where required.

Ground maps are situated around the ground perimeter and all turnstiles are clearly labelled.

‘e-ticket’ information and design

The ‘e-ticket’ is sent via electronic mail to the purchasing customer's email address and contains a QR code to gain access to the stadium. The QR code is individually numbered and can be blocked where required.

You will not receive a physical copy of the ‘e-ticket’

It is the responsibility of any supporter who decides to print their ‘e-ticket’ that it is easily readable by the Clubs access control system.

Season Tickets on Direct Debit Scheme

If a season ticket is purchased under the direct debit scheme, failure to keep direct debit payments up to date may result in your season ticket being cancelled. The club reserves the right to re-sell your allocated seat should you default on payments.

Your season ticket will not be activated unless all requested Direct Debit Payments have been honoured. Should any Direct Debits be returned to us unpaid by the bank, your season ticket will be immediately deactivated. Your season ticket will only be reactivated after all outstanding payments have been resolved.

You may be refused season ticket benefits should your direct debit payments not be up to date. These benefits include but are not limited to away priority on away or cup ticket purchases, and loyalty points.

If any of your direct debits are not honoured when presented for payment the Club reserves the right to charge a fee of £20 ("Late Payment Fee") and you will be contacted for payment. A replacement payment for the amount of the direct debit not honoured together with the Late Payment Fee must be received within fourteen days of notification. If your direct debit fails for a third time in a season, the option to pay by direct debit may be withdrawn. If you wish to carry on with your season ticket then you will have to pay the balance remaining in full.

In the event that there are any behind closed doors fixtures or that there are any restrictions on capacity due to social distancing, or the season ends without all scheduled league games having been played, you must keep up with your direct debit payments. If there are any pro-rata refunds or credits to be made to your Bradford City AFC ‘on-Account’ then these will be completed separately from your season ticket payments.

No Deposits, Direct Debit payments or Late Payment Fees will be refunded under any circumstances during a non-restricted season. This doesn’t affect the terms and conditions set out in point 5 above regarding pro-rata refunds and credits for matches which have been played behind closed doors, under social distanced restrictions or if the season ends without all scheduled games having been played.

Any notice or other information we may need to send to you under the terms of this instalment offer will be sent by second class post to the address you have completed in the application form or that which we have registered on the ticketing system.

Postponed or Cancelled Event

All spectators at every game will have match tickets; fans should be informed to retain their tickets and observe the Club’s website the following day for an announcement.

Season ticket holders will be unaffected as their season tickets will apply for the rearranged game.

Persons who have purchased seat tickets should retain their ticket portion for the rearranged game.

The PA announcer will advise over the Public Address system:

“Ladies and gentlemen, could I please have your attention. Unfortunately due to circumstances beyond our control tonight’s/today’s event has been cancelled/abandoned (REPEAT MESSAGE).

“I would advise you that the date for the rescheduled game will be advertised and broadcast on the Club’s website, in the local media and further information regarding tickets etc. may be obtained for your point of purchase. Spectators who have purchased match tickets for this game should retain their portion of the ticket and consult the website for further details about the rearranged fixture.”

Full condition of use for season/match tickets available on the ticketing website.

This policy will be reviewed and updated at least annually by the owner, and more frequently if necessary.