Safeguarding Policy

1. Policy Statement, Scope and Definitions

Vocal Excellence is committed to providing a safe, respectful, and professionally supervised environment for every participant.

The welfare of children and young people is our first priority. Every participant has the right to be protected from abuse, neglect, exploitation, bullying, discrimination, inappropriate conduct, and avoidable harm.

This policy covers all Vocal Excellence activities, including the Vocal Excellence School, the Summer Programme, the Vocal Excellence Choir, masterclasses, auditions, concerts, and any other activity we run or host. Where a rule applies to only one activity, the section says so.

It applies to all Vocal Excellence directors, faculty, staff, guest teachers, accompanists, volunteers, contractors, photographers, videographers, chaperones, and any other person working with or on behalf of Vocal Excellence.

In this policy:

• a child or minor means any participant under the age of 18;
• an adult member means a participant aged 18 or over. The Choir admits singers up to the age of 21, so adults and children rehearse together. Section 16 sets out what that means in practice;
• staff means anyone engaged by Vocal Excellence in any capacity, paid or unpaid, including volunteers and contractors;
• a guardian means a parent or legal guardian of a child participant.

Age ranges. The Vocal Excellence School teaches from the age of six, with no upper limit. The Summer Programme and the Vocal Excellence Choir both admit participants aged 11 to 21. The Masterclass Series admits participants aged 11 and over, with no upper limit. Six is therefore the youngest age at which any Vocal Excellence activity admits a participant, and this policy is written to cover it. Sections 14a, 15 and 15a set out the additional rules that apply to weekly individual teaching and to children under eight, because those are the circumstances this policy did not previously have to address.

2. Scope of Responsibility

Vocal Excellence provides supervision during scheduled, staff-led activities, including classes, coaching sessions, rehearsals, sectionals, workshops, auditions, supervised breaks, concerts, and official events.

When our responsibility begins and ends. For the Choir, Vocal Excellence becomes responsible for a singer when they are signed in at the rehearsal venue, and that responsibility ends when they are signed out to an authorised adult, or when a singer permitted to travel independently signs themselves out. Before sign-in and after sign-out, responsibility rests with the guardian. This boundary is given to every family in writing before the first rehearsal, and again whenever the venue or the timings change.

Unless expressly agreed in writing, Vocal Excellence does not provide 24-hour care, residential guardianship, accommodation supervision, airport supervision, independent travel supervision, or supervision outside scheduled activities.

Guardians remain responsible for participants outside scheduled activities, including travel to and from the venue, accommodation, meals outside the programme, free time, and any personal or family arrangements.

3. Designated Safeguarding Lead

The Designated Safeguarding Lead for all Vocal Excellence activities is:

The Designated Safeguarding Lead receives safeguarding concerns, keeps the records, coordinates our response, and contacts guardians, emergency services, the Police, Social Welfare Services, medical professionals or legal advisers where appropriate. The Lead is responsible for making any external referral promptly and confirming it in writing.

The Deputy Designated Safeguarding Lead is:

The Deputy holds the safeguarding role whenever the Lead is unavailable, and holds it independently where a concern is about the Lead himself (see section 3a). No session runs unless either the Lead or the Deputy is contactable throughout it.

3a. If Your Concern Is About the Designated Safeguarding Lead

The Designated Safeguarding Lead is the Founder of Vocal Excellence. That is normal in a small organisation and it creates an obvious problem: if your concern is about him, the ordinary route sends you to the person you are concerned about.

So do not use it. Where a concern relates to the Designated Safeguarding Lead, take it directly to any of the following, and you do not need to tell us first:

• Marisa Anastasiou, Deputy Designated Safeguarding Lead — marisa@vocalexcellence.cy
• Social Welfare Services, Limassol district office
• The Cyprus Police, or 112 in an emergency
• 1466, the national helpline for children in Cyprus
• The Commissioner for the Protection of Children’s Rights

Where a safeguarding concern relates to the Designated Safeguarding Lead, the Deputy Designated Safeguarding Lead will assume full authority for managing the matter and may introduce any immediate protective measures considered necessary, including temporarily removing the Lead from contact with participants. These measures cannot be overridden by the person concerned and will remain in place until the matter has been appropriately reviewed.

The Lead takes no part in handling such a concern and has no access to the record of it. Nobody who raises such a concern will be disadvantaged for doing so.

4. Reporting a Safeguarding Concern

Anyone may raise a concern: a participant, a guardian, a member of staff, a volunteer, a contractor, or a visitor. You do not need to be certain and you do not need proof. Deciding what it means is our job, not yours.

Concerns should be reported as soon as possible:

• In person to the Designated Safeguarding Lead or any member of staff
• By email: info@vocalexcellence.cy
• By telephone: +357 25 775 885

You do not have to come to us first. Anyone may contact the authorities directly at any time, and we will never treat that as going behind our backs.

Where we reasonably believe a child is at risk of significant harm, that an offence may have been committed, or that outside help is needed, we will refer the matter to the appropriate authority. We will do so whether or not the family agrees, if that is what the child’s safety requires.

No person raising a concern in good faith will be penalised or treated unfavourably for doing so, and that protection applies even if the concern turns out to be mistaken.

5. How Concerns Are Handled

All concerns are taken seriously. We will:

• Listen carefully and respectfully, and take what is said seriously
• Record the concern accurately, in the words used, as soon as possible
• Avoid asking leading or investigative questions
• Act promptly and proportionately
• Share information only with those who need it
• Escalate to guardians, emergency services, the Police, Social Welfare Services, medical professionals or legal advisers where appropriate
• Keep safeguarding records securely and separately from general participant records

We cannot promise absolute confidentiality where a child may be at risk, where an offence may have been committed, where medical help is needed, or where disclosure is necessary to protect someone or to comply with the law. We will say so honestly at the time rather than promise a secrecy we cannot keep.

6. Low-Level Concerns

Not every worry is an allegation. A low-level concern is any unease that an adult has behaved in a way that sits outside our Code of Conduct but is not serious enough to refer elsewhere. Examples include being over-familiar with a participant, having favourites, photographing participants on a personal phone, or speaking with a young person one-to-one behind a closed door.

“Low-level” does not mean unimportant. These are the observable precursors of more serious problems, and they are also things that happen innocently in a music school every week. We record them so that a pattern becomes visible at the time rather than being reconstructed later.

Low-level concerns are reported to the Designated Safeguarding Lead, recorded in writing with the date and the facts, and reviewed. Recording one is neither a disciplinary act nor an accusation.

7. Allegations Against Staff or Adults

If an allegation or serious concern is raised about a member of staff, faculty, a volunteer, a contractor, a guest teacher, a chaperone, a photographer, a videographer, an adult member of the Choir, or any other adult connected with our activities, Vocal Excellence may immediately remove that person from contact with participants while the matter is assessed.

This is a protective measure and does not imply guilt.

Where appropriate the matter is referred to the Police or Social Welfare Services. We do not conduct our own investigation into a matter that belongs to the authorities.

8. Safer Recruitment and Vetting

Cyprus law is strict about this, and so are we. Under section 22(6) of the Prevention and Combating of Sexual Abuse and Sexual Exploitation of Children and Child Pornography Law 91(I)/2014, an organisation must not engage a person in professional, organised or voluntary activities involving frequent contact with children unless that person has produced a certificate confirming they are not on the register kept under that law. Failing to make that check is a criminal offence.

Before beginning any role involving contact with children, every member of staff, faculty member, volunteer, contractor, accompanist, chaperone, photographer, videographer and guest teacher must produce:

• the Certificate of Non-Commission of Sexual Offences Against Children (Πιστοποιητικό μη Διάπραξης Σεξουαλικών Αδικημάτων σε Βάρος Παιδιών), which is the certificate section 22(6) requires; and
• a Clear Criminal Record Certificate (Πιστοποιητικό Λευκού Ποινικού Μητρώου). This second certificate is our own requirement rather than one imposed by section 22(6), and we ask for it because the Ministry of Education requires both of staff working at children’s camps and we hold ourselves to the same standard.

Both are obtained from the district Police Directorate. In addition we require identity verification, confirmation of qualifications or experience, reference checks, equivalent overseas checks for anyone who has lived outside Cyprus, a written declaration of suitability to work with children, and written acceptance of this policy and the relevant Code of Conduct.

No person begins a role, supervised or unsupervised, before both certificates have been seen and recorded. We keep a register of everyone engaged, recording name, date of birth, role, contact details and the issue date of each certificate. Certificates are re-checked at least every two years; that interval is our own standard rather than a legal minimum.

Vocal Excellence may refuse, suspend or end any appointment where a safeguarding concern arises.

9. Supervision

At least two vetted adults are present at every session, without exception. If two are not available, the session does not run. This is not an administrative preference: with one adult it is impossible to search for a missing child and stay with the rest of the group at the same time.

Supervision is heavier at arrival, during the break and at collection than during the rehearsal itself, because those are the moments when participants are dispersed, moving, and near corridors and exits used by other people.

Adult members of the Choir aged 18 to 21 are participants, not supervisors. They do not count towards the number of adults present, they are never left in charge, and no one under 18 is ever placed in charge of other participants.

For the Summer Programme, participants under 16 must have a guardian or nominated responsible adult present in Limassol for the duration of the programme, and participants aged 16 to 17 may attend unaccompanied only where written guardian consent has been given and we have accepted the arrangement in writing. A nominated responsible adult must be identified in writing in advance and authorised by the guardian to act in the participant’s welfare interests.

10. The Choir: Arrival, Collection and Late Collection

This section applies to Choir rehearsals, which run on Saturdays. The times below are fixed points in this procedure and do not move with the timetable; if the rehearsal hour ever changes, this section is rewritten deliberately rather than being allowed to drift.

Arrival. The venue opens fifteen minutes before the rehearsal begins. Every singer under 18 is signed in on arrival. No singer is left outside a locked venue: a singer who arrives early waits with staff.

Collection. Every singer under 18 is signed out to a named adult. Guardians give us, in writing and in advance, the names of the adults authorised to collect their child. We will not release a child to anyone who is not on that list. Changes must come from the guardian in writing; where that is impossible in an emergency, we verify the change by telephone with the guardian before releasing the child.

Singers who travel independently. A singer aged 14 or over may sign themselves out and travel home independently only where their guardian has given written permission. That permission may be withdrawn at any time. Singers under 14 are always collected.

If a child is not collected, we follow this procedure every time:

• 13:15: staff contact the guardian on the numbers held.
• 13:30: staff contact the emergency contacts held for the child.
• Throughout, two adults remain with the child. The child is never left alone, never left with a single adult, and never taken home in a private vehicle.
• 14:00: if no adult has been reached, the Designated Safeguarding Lead contacts Social Welfare Services or the Police for advice and follows it.
• Every late collection is recorded, with the time and the outcome.

Repeated late collection is treated as a welfare matter rather than an inconvenience, and is raised with the guardian by the Designated Safeguarding Lead. It is never handled as a billing matter.

11. Attendance Registers and Unexplained Absence

A register is taken at every session recording who attended, who was absent, and the time each child was signed in and signed out. The register is a safeguarding control rather than an administrative task: it is how we know who is in the building, and it is what we carry out with us if the building is evacuated.

Unexplained absence. Where a singer under 18 is absent and we have not been told in advance, staff contact the guardian during the same session. After three consecutive unexplained absences the Designated Safeguarding Lead contacts the guardian directly. Unexplained absence can be the earliest visible sign that something is wrong, which is why we follow it up every time.

That contact is always about welfare and never about fees. Membership and payment questions are handled separately, in a separate message. A member who stops attending without explanation is not treated as a lapsed subscription.

Absence of an adult member aged 18 or over is not followed up in this way.

12. Missing Participant

If a participant cannot be found we act immediately. One adult begins searching and another stays with the remaining participants. We will:

• Check the venue, the toilets and the surrounding supervised areas
• Check the register to confirm the participant was signed in
• Contact the participant directly where appropriate
• Contact the guardian or nominated responsible adult
• Inform venue staff or security
• Contact the Police without delay where the participant cannot be found quickly, where they are young, or where there is any particular reason for concern. We do not wait a fixed period before calling.

Searching continues until the participant is found or the Police take over. Every incident is recorded and reviewed afterwards.

13. Auditions

An audition is a young person, often a stranger to us, alone and under pressure, usually before any paperwork exists. It gets its own rules.

• Two adults are present at every audition of a person under 18. This is not an alternative to anything: the two-adult rule in section 9 applies to auditions exactly as it applies to rehearsals. In addition, the audition takes place in a room with a window or an open door, in sight of other staff.
• A guardian is welcome to be present at any audition of a child, and is told so in advance.
• Auditions are scheduled and recorded in advance, and are never held in a private or isolated space.
• Where an audition is recorded, the recording is made with written guardian consent, used only to decide the application, and deleted once that decision is made unless separate consent has been given.
• Where the singer is a child, the outcome is given to the guardian as well as the singer.

14. Physical Contact in Vocal Teaching

Singing is taught through the body, so this deserves a clear answer rather than silence. Our position:

Vocal technique is taught by explanation, demonstration and modelling. Physical contact is not our normal method and is avoided.

Where a teacher judges that a brief physical demonstration is genuinely necessary, for example to show where the breath is supported or to correct posture, all of the following must hold:

• Permission is asked first, and what will happen is explained first
• The singer may say no, or stop at any point, and nothing follows from refusing
• It happens in the open, in the rehearsal room, in view of others, and never one-to-one in a private space
• It is brief and purposeful, and never becomes a habit
• Contact stops immediately if the singer appears uncomfortable

Guardians are told at registration that this is our approach. Any concern about physical contact should be raised with the Designated Safeguarding Lead and will be recorded under section 6 even where nothing improper was intended.

No student under 13 is taught with hands-on breath support.Breathing is taught by self-monitoring, where the student places their own hands on their own ribs, and by imagery, modelling and movement. For students aged 13 and over, contact for breath or posture work is limited to the shoulders, the upper back and the sides of the rib cage, over clothing, never on the front of the torso, and it is offered rather than assumed.

No student is touched on the face, jaw, neck or throat.

14a. Physical Contact in Instrumental Teaching

Piano and guitar are taught through the hands, and the School teaches both from the age of six. Showing a hand position, a wrist angle, a seat height or the way an instrument is held sometimes needs brief contact. Silence here would leave every teacher to invent a rule, so this section states one.

Demonstration and description come first. Contact is used only where showing and telling have not worked.

Where contact is genuinely necessary, all of the following hold:

• The teacher says what they are about to do and why, and asks permission before touching
• Contact is limited to hands, wrists, forearms, shoulders and upper back. No other area is touched
• It lasts the shortest time needed, and the teacher checks the student is still comfortable
• A student may decline, at any time, without giving a reason. It never affects their lesson, their repertoire or their assessment
• It happens only in a room that can be seen into, and never when the teacher and the student are the only people on the premises

Well-intended gestures such as a hand on the shoulder or arm are avoided. Repeated, they invite questions and can make a student uncomfortable. This statement is given to every guardian at enrolment, so that contact is never a surprise to the student.

15. One-to-One Teaching and Contact

At the School, one-to-one is the normal shape of a lesson, not an exception. One adult and one child, in one room, every week, for years. That is a different risk from a group rehearsal and it is managed by making the room visible and the building populated, never by trusting to the individual.

The following apply to every individual lesson:

• No lesson takes place in a room that cannot be seen into from outside it. Every teaching room has a clear vision panel in the door, or the door stays open
• No teaching room is locked, or its vision panel obstructed, while a child is inside
• Any member of staff may enter any teaching room at any time, without notice and without knocking. Every teacher is told this in writing when they are appointed
• No lesson takes place in a private home, a teacher’s home, or any bedroom, including by video
• No lesson moves to a time or a place outside the published timetable without the guardian’s agreement and the knowledge of the School

Guardians may observe. A guardian may observe any or all of their own child’s lessons. They do not need the teacher’s permission or to give notice, and observation is not a request a teacher may decline. It may be paused only where a student is distressed, where a student is telling a member of staff something they need to tell them, or where another family’s lesson would be affected. A waiting area is provided and no guardian is asked to leave the building.

Where individual coaching or a short private conversation happens outside a timetabled lesson, staff must also:

• Arrange it in advance and tell another member of staff it is happening
• Use a room with a window or a glass panel, or leave the door open. A door closed for privacy is never locked
• Stay where others can see and hear
• Never sit or stand between the young person and the door
• Keep it short, and record that it took place
• Invite the young person to bring a friend if they would prefer

Rooms used for individual work are never bedrooms, never isolated, and never far from other people.

15a. Students Under Eight

The School teaches from six. A child of six cannot be left to wait, cannot be relied on to report discomfort, and cannot make their own way home. These rules exist because the rest of this policy was written for participants aged eleven and over.

• For every student under eight, a guardian or nominated adult remains on the premises for the whole lesson. No guardian leaves a child under eight with a teacher and goes out
• Students under 11 wait inside the building for collection. No student is asked to meet an adult outside the building
• Where a student under 11 has not been collected fifteen minutes after their lesson ends, a member of staff stays with them in a room visible from the corridor while the School contacts the guardian and then the nominated adult
• The enrolment record names at least one adult besides the guardian who may collect the child. No student under 11 is released to an adult who is not named on that record
• At least one member of staff on the premises during teaching holds a current paediatric first aid certificate

Vocal load is asked about at enrolment and at the start of each term, and counts singing and shouting at school, in other choirs, in drama and in sport, not only lessons here. Singing within a lesson is broken into short units with frequent short rests: a lesson hour is never an hour of continuous singing. Where hoarseness or loss of voice persists beyond about three weeks, the School raises it with the guardian and suggests a medical opinion. Staff do not diagnose, and do not raise it with the student alone.

16. Members Aged 18 to 21

The Choir admits singers up to 21, so legal adults and children sing together. This is one of the best things about the ensemble, and it is also the point at which most choir policies go quiet. Ours does not.

Adult members are members, not staff. They hold no authority over any other member, they are never asked to supervise, and they are never left in charge.

Every adult member signs a Code of Conduct for Adult Members on joining, or on turning 18 while a member. These rules protect the adult member as much as the child: they mean no adult member is ever alone with a child, so no adult member can ever face an accusation that cannot be answered. The Code requires that an adult member:

• is never alone with a child member in connection with the Choir, whether in a room, a corridor, a stairwell, a car or online;
• does not give lifts to a child member without the express written agreement of that child’s guardian;
• does not exchange private messages with a child member on personal accounts, and keeps Choir communication to group channels visible to staff;
• does not photograph or film other members in changing or warm-up areas, and does not post images of child members without consent;
• does not enter into any romantic or sexual relationship with a member under 18, regardless of the age of consent, and declares any pre-existing family or personal connection to the Designated Safeguarding Lead;
• takes no part in initiation, hazing, or the ranking of newer or younger members;
• understands that children are present at every rehearsal, and behaves accordingly in language and conduct;
• reports any safeguarding concern to staff.

Where an adult member takes on any role involving responsibility for children, they stop being treated as a member for that purpose and must be vetted under section 8 before beginning it.

Practical arrangements. Changing and warm-up spaces are arranged so that children and adults are not required to share them. Where a venue makes that impossible, adults and children use them at separate times.

Turning 18 during a season. A member who turns 18 mid-season becomes an adult member on their birthday. They sign the Code of Conduct for Adult Members at that point. Every consent their guardian gave for them, including photography and independent travel, lapses on that birthday, because a guardian cannot consent for an adult. We ask the member to give their own consents in their own name, and until they do we act as though consent has been withheld.

17. Staff Code of Conduct

All staff, faculty, volunteers, contractors, guest teachers, photographers, videographers, accompanists and chaperones must maintain professional boundaries at all times.

They must:

• Treat every participant with dignity and respect
• Avoid favouritism, humiliation, intimidation, bullying, sexualised comments or inappropriate personal remarks
• Use appropriate language and behaviour
• Follow sections 14 and 15 on physical contact and one-to-one work
• Use only official Vocal Excellence communication channels
• Report any safeguarding concern immediately
• Challenge behaviour by other adults that falls below this standard

They must not:

• Exchange private messages with a child through personal accounts
• Add a child participant on personal social media
• Transport a child alone. Where transport is genuinely unavoidable in an emergency, it is recorded at the time, and the guardian and the Designated Safeguarding Lead are told the same day
• Enter a participant’s private accommodation on the Summer Programme, except in an emergency and, where possible, accompanied by another adult
• Give personal gifts to individual children without approval
• Photograph, film or record participants on personal devices unless expressly authorised
• Develop a personal, romantic, sexual or exploitative relationship with any participant, of any age
• Consume alcohol or use drugs while responsible for participants
• Ignore, conceal or delay reporting a safeguarding concern

Any breach may result in removal and, where appropriate, referral to the authorities.

18. Participant Behaviour, Bullying and Harassment

Vocal Excellence does not tolerate bullying, harassment, discrimination, victimisation, sexual harassment, intimidation or abusive conduct, by anyone.

Harm between participants is a safeguarding matter, not a discipline matter. Where one participant harms another we respond to the needs of both, we record it, and we refer it where the conduct may be criminal or where a child may be at risk. Where one party is an adult member and the other is a child, it is always treated as a safeguarding matter.

Participants are expected to behave respectfully towards each other, faculty, staff, venues and members of the public, to follow reasonable safety instructions, and to arrive on time.

Vocal Excellence may remove a participant from an activity where their conduct creates a safeguarding, welfare, safety or serious disciplinary concern.

19. Photography, Filming and Recordings

Our activities may include photography, filming, rehearsal and audition recordings, interviews, and concert recordings.

For participants under 18, written guardian consent is required before any photography, filming or recording takes place, except where recording is strictly necessary for safety, security or legal reasons.

Rehearsals. Rehearsals are working sessions and are not routinely photographed or filmed. Where we do, it is announced beforehand and any family may decline for their child with no consequence.

Public concerts. A public concert is a public event and audience members may take photographs. We tell families in advance which performances are public so they can make an informed decision, and we do not claim to control what an audience does. Vocal Excellence’s own use of concert images still requires consent.

Consent for promotional photography, filming, testimonials, interviews and social media use is optional and separate from consent to take part. Refusing it changes nothing about a participant’s place, and consent may be withdrawn at any time.

Where appropriate we also ask the participant themselves before using their image, voice or performance. Participants do not transfer ownership of their performance rights by taking part. We will not knowingly publish images or recordings that are degrading, misleading, unsafe or likely to place a child at risk, and we do not publish a child’s full name alongside their image without specific consent.

20. Online Safety and Communications

Communication with participants and guardians takes place through approved Vocal Excellence channels. For children, important communications include the guardian.

Staff must not use private messaging apps, disappearing-message platforms, personal social media accounts or informal private channels to communicate with a child participant.

Where the Choir uses a group messaging channel it is administered by a member of staff, no child is in a channel without a member of staff present, and it is not used outside reasonable hours.

Online teaching, video calls and digital feedback involving children are conducted professionally and with guardian awareness.

20a. Online Masterclass Observation

Vocal Excellence Masterclasses may be observed remotely by registered Online Observers. This allows audience members to watch the educational work taking place in the studio live from outside Cyprus.

Where children or young people take part in a Masterclass, participants and, where applicable, their parents or guardians are informed in advance that the session may be viewed live by registered Online Observers.

Online Observer access is personal and non-transferable. Access details must not be shared with any other person.

Online Observers may not record, screen-record, photograph, screenshot, reproduce, stream, broadcast, distribute or otherwise capture any part of a Masterclass without the prior written permission of Vocal Excellence.

Remote access is provided through a controlled online environment. Where technically possible, observer microphones and cameras remain disabled, and any interactive features are moderated by Vocal Excellence.

Online Observers must not use the service to contact, identify, approach or communicate privately with a child or young person participating in a Vocal Excellence activity.

Vocal Excellence may remove an Online Observer immediately where there is suspected unauthorised recording, sharing of access, inappropriate behaviour, attempted contact with a participant, or any other safeguarding or privacy concern.

Any recording made separately by Vocal Excellence, including recordings supplied to Active Participants or used for promotional purposes, is governed by section 19 and the relevant participant permissions and media-consent arrangements, and is separate from the Online Observer live-access service.

Where an Online Observer is under 18, registration and payment may require the involvement or consent of a parent or guardian in accordance with Vocal Excellence’s applicable registration procedures.

21. Medical Information, First Aid and Emergencies

Guardians must provide accurate emergency contact details and disclose any relevant medical, allergy, access, medication or welfare information before a participant begins, and must tell us when anything changes. For the Choir we ask families to confirm this information at the start of each season.

No session runs without a person trained in first aid present and a first aid kit at the venue.

In a medical emergency we will attempt to contact the guardian immediately. If the situation is urgent or life-threatening we will call 112 and seek emergency medical assistance without waiting for approval.

Members aged 18 or over are adults. We hold an emergency contact for them with their own consent, and we cannot consent to treatment on their behalf.

Medical information is confidential and shared only with those who need it to protect the participant’s health and safety.

22. Venues

Before using any venue we carry out our own risk assessment for our activity, covering access, lighting, fire exits, the evacuation route and assembly point, the location of first aid, the arrival and collection area, and the position of the toilets relative to the rehearsal room. A venue’s own compliance does not replace ours.

Where other groups use the same building at the same time, we establish which spaces are ours for the session, we tell participants and families that the building has other users, we hold a contact for them and give them ours, and we brief participants not to leave the area we control. Adults we have not vetted may be present elsewhere in a shared building, and our arrangements assume that.

If the venue changes we carry out a new risk assessment and tell every family in writing before the change takes effect.

Concerts and performances away from the rehearsal venue are assessed in the same way, and in addition: families are told in writing where the performance is, what time we take responsibility for a participant and what time it ends, and whether a participant is to be collected from the venue or from the usual rehearsal venue. Sign-in and sign-out apply at performances exactly as they do at rehearsals. Backstage and dressing areas are supervised, children and adult members do not share them, and the register goes with us. Vocal Excellence does not arrange transport to performances; where a participant needs to travel, that is arranged by their guardian.

Where we use external contractors, photographers, videographers, guest teachers, accompanists or service providers, they must comply with this policy where they interact with participants, and we take reasonable steps to ensure they are suitable, briefed and supervised.

23. Records, Retention and Data Protection

Safeguarding records are kept accurate, secure, confidential and accessible only to those with a legitimate need to know. They are stored separately from general participant records.

We keep:

• Attendance registers and sign-in and sign-out records
• Consent forms, including photography and independent-travel permissions
• Emergency contacts, authorised collectors and medical information
• Safeguarding concerns, low-level concerns, and the action taken
• The staff vetting register

Personal data is handled in accordance with the General Data Protection Regulation and Cyprus Law 125(I)/2018. Under that law the age at which a child can consent on their own behalf to online services is 14, which is why a guardian registers on behalf of any singer under 14.

Safeguarding records are retained for as long as necessary for child protection, legal, insurance or risk-management reasons, which may be many years after a participant has left. Routine attendance and administrative records are kept for a shorter period. Our Privacy Policy sets out how we handle personal data and the rights available to you.

23a. Participants with Disabilities or Additional Needs

A child with a disability, a learning difference, a communication difference or an additional need is at greater risk of harm and less likely to be able to report it. We plan for that rather than treating it as an exception.

• We ask about access, communication and support needs at registration, and we ask again if anything changes. Nothing about a participant’s needs affects whether they are welcome.
• Where a participant needs support to take part, we agree with the guardian in advance what that support is, who provides it, and what it does not extend to. We do not provide intimate or personal care.
• Where a participant communicates differently, we agree how they will tell us if something is wrong, and we make sure more than one adult knows.
• Behaviour is not assumed to be a symptom. A change in a participant’s behaviour is considered as a possible safeguarding indicator in the same way it would be for any other participant.

23b. Complaints, Appeals and Whistleblowing

Complaints and appeals. If you disagree with a decision we have taken on a safeguarding or welfare matter, including a decision to remove a participant from an activity, you may ask for it to be reviewed. Write to us and we will reply in writing. A review is carried out by someone who did not take the original decision. Nothing in this process prevents you from going to Social Welfare Services, the Police, or the Commissioner for the Protection of Children’s Rights at any time, and doing so is not a step you have to earn by exhausting ours first.

Whistleblowing. Anyone working for or with Vocal Excellence, paid or unpaid, may raise a concern about how the organisation itself is behaving, including about the conduct of its most senior people. Almost everyone here depends on Vocal Excellence for work, and we recognise that this makes speaking up harder rather than easier.

A concern raised in good faith will not affect anyone’s engagement, hours, pay or standing, and that protection applies even if the concern turns out to be mistaken. Concerns may be raised with the Deputy Designated Safeguarding Lead rather than the Lead, and may be taken directly to the authorities listed in section 3a without telling us first. Deliberately suppressing or discouraging a safeguarding concern is itself a serious breach of this policy.

24. Training and Briefing

Everyone working with participants is briefed on this policy before they begin and confirms in writing that they have read and accepted it.

The Designated Safeguarding Lead and the Deputy undertake safeguarding training appropriate to the role and keep it current. Those with direct responsibility for children may be required to complete additional training or evidence relevant experience.

Adult members aged 18 to 21 are briefed on the Code of Conduct for Adult Members before their first rehearsal.

25. Insurance

Vocal Excellence does not run an activity for children without insurance in place. Before any season or programme begins we put in place public liability cover for that activity, together with employers’ liability cover wherever we engage anyone in a capacity that requires it under Cyprus law. We satisfy ourselves that the cover extends to performances at venues other than our usual rehearsal venue and to members aged 18 and over. Certificates are kept on file and any family may ask to see them.

26. Review

This policy is owned by the Designated Safeguarding Lead, who is responsible for keeping it current.

Version history. Version 1.0 (January 2026) covered the Summer Programme only, and described participants aged 12 to 17. Version 2.0 rewrote the policy to cover the Vocal Excellence Choir as well: singers from the age of eleven, adult members aged 18 to 21 rehearsing alongside children, and the weekly arrival, register and collection procedures that a recurring activity needs and a summer course does not. Version 3.0 extended it again to the Vocal Excellence School: the age floor moved to six, one-to-one teaching became the normal shape of a lesson rather than an exception, and the policy gained the rules on physical contact in instrumental teaching (§14a) and on children under eight (§15a).

Questions about this policy should be directed to: