Safeguarding Policy

1. Purpose and commitment

Genspect is committed to protecting every person who comes into contact with its work from abuse, exploitation, neglect and avoidable harm. Safeguarding is everyone’s responsibility. Concerns will be taken seriously, acted on promptly and handled with care, fairness and respect.

Genspect primarily provides services to adults. It does not provide clinical or support-group services to anyone under 18. Children may nevertheless come into contact with Genspect at public events, through family members, online, in research or in communications. This policy therefore covers both children and adults at risk.

This policy sets the minimum standard for Genspect’s work worldwide. Applicable law in the place where the person at risk is located, the alleged conduct occurred or the worker is regulated may impose additional duties. Those duties must be followed. A local rule may strengthen this policy but must not reduce its protections.

2. Scope

This policy applies to Board members, employees, contractors, facilitators, clinicians engaged by Genspect, volunteers, interns, speakers and anyone acting in Genspect’s name (collectively, “Genspect personnel”). It applies to work conducted in person, online, by telephone, through email or messaging, at events, in support groups, in research and through media or content projects.

It applies to Genspect and programmes it directly operates, including Beyond Trans. Independently governed national organisations or partner bodies should formally adopt this policy or maintain an equivalent policy. A therapist listed in a public directory is not, by that fact alone, Genspect personnel; concerns about a directory member will nevertheless be assessed, referred where appropriate and considered under the directory’s terms.

3. Definitions

4. Safeguarding principles

• Safety first. Immediate protection takes priority over reputation, programme continuity or internal process.
• Listen and take concerns seriously. A person does not need to prove abuse before Genspect acts on a reasonable concern.
• Do not investigate. Personnel establish only the minimum facts needed for safety and reporting. They do not confront an alleged perpetrator, seek corroboration or test a person’s account.
• No promise of secrecy. Information is shared only with those who need it to protect a person, comply with law or ensure a fair process.
• Respect and impartiality. Safeguarding decisions are based on conduct and risk, not a person’s beliefs, sex, race, disability, sexual orientation, religion, age or relationship with Genspect.
• Voice and choice. Adults are involved in decisions affecting them wherever possible, unless this would increase danger or conflict with a legal duty.
• No retaliation. No person will be penalised for raising a concern in good faith or cooperating with a safeguarding process.
• Minimum necessary information. Records and disclosures are accurate, relevant, secure and limited to what is needed.

5. Responsibilities

5.1 The Board

• Retains ultimate responsibility for safeguarding governance and organisational culture.
• Approves this policy, receives anonymised safeguarding assurance reports and ensures adequate resources, training and oversight.
• Appoints an alternative Board reporting contact who is independent of day-to-day management.
• Leads or appoints an independent person to oversee any allegation involving the Executive Director or Safeguarding Lead.

5.2 The Safeguarding Lead

• Receives concerns, assesses immediate risk and ensures prompt referral to the correct statutory, regulatory or emergency authority.
• Maintains secure safeguarding records and a decision log.
• Provides advice without preventing any person from making a direct report where required or appropriate.
• Coordinates support, internal action, learning and reports to the Board while preserving confidentiality.
• Keeps jurisdiction-specific reporting information reasonably current for places in which Genspect regularly operates.

5.3 All Genspect personnel

• Read, understand and follow this policy and the Code of Conduct.
• Complete required safeguarding training before undertaking relevant duties and at intervals set by Genspect.
• Report concerns promptly; uncertainty is not a reason to delay.
• Act within their competence and role. Genspect support groups are not emergency, medical or crisis services.

6. Safer recruitment and engagement

Genspect will assess the safeguarding risk of each role before appointment. Depending on the role, jurisdiction and lawful availability, proportionate checks may include identity and qualification checks, references, professional registration and standing, insurance, criminal-record or barred-list checks, interview questions about boundaries, and disclosure of relevant disciplinary findings.

No check replaces supervision and good practice. All personnel in roles involving direct contact with service users must sign the Code of Conduct. Facilitators must be appropriately qualified for the work, maintain any required registration and insurance, and receive suitable supervision. Contracts must permit Genspect to restrict or end duties where a safeguarding risk arises.

7. Code of Conduct

Genspect personnel must:

• Treat people with dignity, avoid humiliating or sexualised language, and challenge bullying, harassment and intimidation.
• Maintain clear professional boundaries. They must not begin a sexual or romantic relationship with a current service user, exploit a former service user, or use their role to seek emotional, social, political or financial benefit.
• Never request or share sexual images, engage in sexual communication with a service user, or make unnecessary enquiries into sexual experience.
• Not lend money to, borrow from, enter business arrangements with, or accept substantial gifts from service users.
• Use approved accounts and systems for Genspect work and avoid private, disappearing or secret communications with service users.
• Not record, photograph, livestream or publish identifying information about a service user without explicit authority and informed written consent.
• Avoid working while impaired by alcohol, illegal drugs, misused medication or any condition that makes safe practice impossible.
• Report boundary crossings, conflicts of interest, suspected grooming, retaliation and attempts to conceal a concern.

8. Online support groups and communications

• Genspect-operated support groups are for adults aged 18 and over. Eligibility and identity checks must be proportionate to the risk and privacy needs of the group.
• Participants receive clear group rules, including limits to confidentiality, before or at entry. No participant may record, photograph, screenshot or redistribute another participant’s contribution or identifying information.
• Hosts use available platform security controls, such as meeting passwords, waiting rooms and controlled admission. Recording is off by default. Private chat may be restricted where the group risk assessment requires it.
• Facilitators use professional contact routes and do not create undisclosed one-to-one therapeutic relationships through group messaging.
• At the start of work where a foreseeable crisis risk exists, Genspect may request the participant’s current country or region and an emergency contact, explaining why the information is requested and how it will be used.
• Threats, stalking, doxxing, sexual harassment, coercion, impersonation and attempts to identify or expose participants are safeguarding concerns and must be reported.
• If an unknown child enters an adult group, the facilitator will protect privacy, avoid substantive engagement, remove the child from the session and notify the Safeguarding Lead.

9. Contact with children

Genspect does not assume parental responsibility and does not provide therapy, case advice or support groups to children. Where children attend a public or family event, the parent, guardian, school or host organisation remains responsible for their supervision unless a written arrangement states otherwise.

• Personnel must not arrange to be alone with a child, move a child to a private online channel, provide private transport or accommodation, or exchange personal contact details with a child.
• Communication with a child must normally include the parent, guardian or responsible organisation, unless doing so may place the child at risk. Any exception must be reported immediately to the Safeguarding Lead.
• Images or recordings of children require the necessary written consent and a clear explanation of use. A child’s refusal must be respected even where an adult has consented.
• A concern about a child must be reported even if it arises outside a Genspect activity or is disclosed by an adult participant about a child in their family.

10. Adults at risk, distress and crisis

Adult participants may be distressed without meeting a legal definition of an adult at risk. Facilitators should respond compassionately while remaining within role. Genspect does not provide an emergency service and cannot guarantee continuous monitoring.

A disclosure of past harm does not always require emergency action, but it must be considered for current risk to the person or others. Credible imminent suicide risk, a serious medical event, current abuse, active domestic violence, trafficking or an immediate threat requires urgent action. Contact local emergency services when delay could increase harm.

An adult with decision-making capacity may decline help. The Safeguarding Lead must still consider whether reporting is required because a child or another adult is at risk, a crime is in progress, the alleged perpetrator holds a position of trust, or local law imposes a duty.

11. Responding to a concern or disclosure

1. Deal with immediate danger. Call the emergency services in the person’s location if serious harm may be imminent. Take reasonable steps to keep people safe without placing yourself or others at further risk.
2. Listen calmly. Allow the person to speak in their own words. Do not express disbelief, blame them, press for detail or ask leading questions.
3. Explain confidentiality honestly. Say that you will share the information only with people who need to help keep someone safe.
4. Establish only essential facts. If necessary, clarify what happened, when and where, who is involved, whether anyone is in immediate danger, and how the person can be contacted safely.
5. Preserve evidence. Do not delete messages, edit screenshots or ask others to obtain evidence. Do not confront the alleged perpetrator.
6. Make a written record promptly. Record date, time, setting, exact words where possible, observations, questions asked, action taken and who was contacted. Separate fact from opinion. Sign and date the record.
7. Report internally without delay. Send the record securely to the Safeguarding Lead on the same day. If the concern involves that person, report to the alternative Board contact. If both routes are implicated or unavailable, contact the appropriate external authority directly.
8. Make any external report promptly. The Safeguarding Lead will identify the relevant authority and record the reasons for reporting or not reporting. A person who is legally required to report must do so directly and must not wait for permission.
9. Follow up. The Safeguarding Lead will consider support, contact restrictions, referrals, communications, record security and organisational learning.

12. Allegations concerning Genspect personnel

Any allegation that Genspect personnel harmed, exploited, groomed or placed a person at risk must be referred immediately to the Safeguarding Lead and, where required, to statutory authorities, a professional regulator, insurer, funder or host organisation. If the allegation concerns the Safeguarding Lead or Executive Director, it must go directly to the alternative Board contact.

Genspect may temporarily change duties, restrict systems or participant contact, or suspend a person while risk is assessed. This is a neutral protective measure, not a finding of wrongdoing. The welfare of the person at risk, preservation of evidence, confidentiality and procedural fairness will all be considered. No internal inquiry will obstruct or precede a statutory investigation where authorities advise otherwise.

A knowingly false or malicious allegation may be addressed under conduct procedures, but an unsubstantiated or mistaken concern is not, by itself, misconduct. No one will be disadvantaged for reporting in good faith.

13. External reporting and cross-border cases

Safeguarding and mandatory-reporting rules differ between countries and, in some countries, between states or provinces. The Safeguarding Lead must identify the correct authority using current official sources and obtain specialist advice where duties are unclear. The starting point is normally the authority where the person at risk is physically located, while also considering where the conduct occurred and any professional or organisational reporting duties.

Internal reporting never replaces a legal duty or a person’s right to contact police, child protection, adult safeguarding, emergency services or a professional regulator directly. Consent should be sought from an adult where safe and appropriate, but lack of consent does not prevent a report when law or serious risk justifies it.

When Genspect works with a venue, school, conference organiser, partner or funder, personnel must also follow the host’s safeguarding procedure. Any conflict or gap must be referred to the Safeguarding Lead; the response that best protects the person and complies with law will be followed.

14. Confidentiality, records and data protection

• Safeguarding information is confidential but not secret. It is shared on a need-to-know basis for protection, reporting, legal advice and fair process.
• Safeguarding records are stored securely, separately from routine participant notes where practicable, with access limited to authorised people.
• Records must be factual, dated, attributable and tamper-evident. Email subject lines and shared documents should avoid unnecessary sensitive detail.
• Information is retained under Genspect’s retention schedule and applicable law, taking account of limitation periods, regulatory duties and the continuing needs of the person concerned. A request for deletion may be refused where lawful retention is necessary.
• Personal information may be disclosed without consent where this is necessary and lawful to protect life, prevent serious harm, report abuse or comply with a legal obligation. The minimum necessary information will be disclosed.
• A data breach involving a person at risk may also be a safeguarding incident and must be reported under both the data-breach and safeguarding procedures.

15. Support, complaints and whistleblowing

People affected by a safeguarding concern should be offered information about appropriate independent support, emergency help and complaint routes. Genspect will not promise therapy, legal representation, anonymity or a particular outcome that it cannot provide.

A complaint about service quality may reveal a safeguarding concern; if so, this policy takes priority. Personnel may raise concerns outside management through the alternative Board contact or an appropriate authority. Confidentiality clauses must never be used to prevent lawful safeguarding reports, protected disclosures or cooperation with regulators or police.

16. Training, monitoring and review

• Induction covers this policy, signs of abuse, boundaries, disclosures, suicide and self-harm escalation, online risks, record-keeping and local reporting duties relevant to the role.
• Personnel in higher-risk roles receive refresher training at least annually; others receive refresher training at intervals proportionate to their role and whenever procedures materially change.
• The Safeguarding Lead reviews incidents and near misses for recurring risks and reports anonymised themes and actions to the Board at least annually.
• This policy is reviewed every 12 months and sooner after a serious incident, a material service change, a change in law or evidence that the procedure is not working.

17. Related documents

• Safeguarding Incident Report Form
• Code of Conduct
• Beyond Trans Group Agreement and Facilitator Procedure
• Complaints Procedure
• Whistleblowing Policy
• Privacy Policy, Data Breach Procedure and Records Retention Schedule
• Recruitment, Vetting and References Procedure
• Research Ethics and Participant Protection Procedure
• Events Risk Assessment and Photography/Media Consent Procedure