Updated: September 2023

1. Introduction

   Mammoth Screen is committed to safeguarding the welfare of children and young people.
   
   This policy establishes the responsibilities of everyone who works for Mammoth Screen, whether an employee or a freelancer and whether a member of the cast or crew, (together, Mammoth Staff) with regard to the protection of children and young people when working with or when brought into contact with children and young people.
   
   In the context of child protection, ‘children’ and ‘young persons’ refers to anyone under 18 years of age.
   
   This policy reflects the principles of both UK legislation and guidance and seeks to be consistent with 'Best Practice' within the field of child protection.
   
   This policy is also designed to adhere to the child protection standards established by UK broadcasters.
   
   The key principles are:

   •     The welfare of the child or young person is the paramount consideration and should be at the heart of the production.

   •     No child or group of children must be treated any less favourably than others in being able to access services which meet their particular needs.

   •      All children and young persons without exception have the right to protection from abuse regardless of gender, ethnicity, disability, sexuality or beliefs.
   •     It is the responsibility of all Mammoth Staff to promote the protection of children and young people and to comply with this policy. Mammoth Staff are always expected to maintain a sense of proportion, apply commonsense to situations and protect the child's welfare as a priority. If there are any concerns whether about a child’s welfare, anyone’s behaviour towards a child or young person, or any non-compliance of this policy and its principles, you have a responsibility to let a senior staff member know. The responsibility applies regardless of how and when the information, suspicion or concern came to your knowledge.
   

2. Principles of Good Practice

   Mammoth Screen undertakes to:

   •     Treat children and young people with care, respect and dignity;

   •     Recognise that those working for Mammoth Screen will be perceived by children and young people as trusted persons and therefore all Mammoth Staff must comply will this policy;

   •     Ensure communication with children and young people is open and clear so that the children and their parent/legal guardian can make an informed decision about being involved in the production;

   •     Assess the risks posed to children when undertaking activities;

   •     Ensure Mammoth Staff avoid physical contact with children and young people unless required as part of their jobs AND only when supervised by a designated chaperone OR for reasons of health and safety;

   •     Respond to any complaints by a child or young person promptly and fairly and implement a disciplinary processas appropriate; and

   •     Review this policy on a regular basis.
   

3. Recruitment and disclosure

   New appointments
   As part of Mammoth Screen’s recruitment and selection procedures, all staff recruited to work specifically with children will complete a Child Protection Self Disclosure form (in the form attached at Appendix B) to confirm that they have no previous record of any child-related offence.
   
   Where a position entails regularly caring for, training, supervising or being in sole charge of children then the offer of employment will be subject to such person providing promptly to Mammoth Screen a background check to reveal a person’s criminal history (DBS Check).
   
   The need for enhanced disclosure checks shall be a matter for Mammoth Screen to decide on a case by case basis.
   For more information regarding background checks, please see the PACT ‘Guidance on Filming with Children’: http://www.pact.co.uk/member-services/resourcelibrary.html?q=Children.
   
   All chaperones will be required to provide a current licence.
   
   Existing Mammoth Staff 
   Mammoth Staff, whose roles do not entail working with children, may on occasion work on projects that involve supervised contact with children. In such circumstances, they will be required to complete a Child Protection Personal Disclosure form. Staff who disclose that they have been convicted of any offence relating to children and young people and/or disciplinary action or sanction relating to children, will not be permitted to work on any production/project that involves children.
   
   In cases where a role entails regularly caring for, training, supervising or being in sole charge of children a DBS Check will be required before the role is undertaken. Such staff may require renewed basic disclosures in certain circumstances and as at regular intervals as required by the appointed Child Protection Officer.
   
   Disclosure Service
   The Disclosure Service is provided by the Disclosure and Barring Service (DBS) in England & Wales, Disclosure Scotland in Scotland and Access NI and provides a regulated checking process against official data sources. The Disclosure Service is aimed at helping organisations make more informed recruitment decisions by reducing the risk of appointing someone with an unsuitable background to particular types of work.
   
   Disclosure applications are checked against records of people banned from working with children held on the Police National Computer and by local police forces as well as other statutory lists.
   
   There are three levels of Disclosure:
   
   •     Basic Disclosures are completed by the applicant and should be used for post where contact with children is likely. This will disclose unspent convictions and conditional cautions.

   •     Standard Disclosures are primarily for posts that involve working with children and vulnerable adults. This will disclose spent and unspent convictions and adult cautions from the Police National Computer which have not been filtered in line with legislation.

   •     Enhanced Disclosures are for posts requiring a far greater degree of contact with children or vulnerable adults. In general the type of work would involve caring for, supervising, training or being in sole charge of such people. This will disclose the information contained in a standard disclosure, plus any information held by local police that is considered relevant to the role.
   
   Enhanced Disclosures should be sought for all Mammoth Staff (if any) whose role entails unsupervised contact with children.
   

4. Management responsibility – Child Protection Officer: 
   Jon Williams is Mammoth Screen’s Child Protection Officer. He will decide which positions require DBS Checks and is the focal point for all child protection issues.
   
   ITV also has Designated Safeguarding Officers and are the point of contact within ITV should you have any concerns regarding the welfare of children and can provide support dealing with any claims or suspicions of abuse or other safeguarding issues. The current Designated Safeguarding Officers at ITV are:
   
   Jane Baird, Head of Health & Safety Risk Management   
   Chelsea Ruffle, Senior Health & Safety Risk Adviser          
   Mikala Crawshaw, Senior Health & Safety Risk Adviser.
   
   The Designated Safeguarding Officers have all received safeguarding training from the NSPCC to equip them to take on this role.
   
   If any Mammoth Staff suspects, for whatever reason, that a child is or may be at risk of harm and/ or if anyone is told by a child or young person of a child welfare issue or if there are any concerns about an adult’s contact with children then that person must inform the Child Protection Officer or, in his absence, any other director of Mammoth Screen immediately. In addition, ITV’s Designated Safeguarding Officers should also be notified via safeguarding@itv.com. If urgent, please call ITV’s 24/7 Health and Safety emergency number 020 715 74000 (Option 3)
   
   The procedures for concerns regarding children and young persons under the Company’s control are set out in Appendix A.
   

5. Legal Requirements
   Mammoth Screen will be required to obtain a licence for working with children and young persons. If an exemption applies or if Mammoth Screen has chosen not to apply for a license, this decision should be documented.For more information on legal requirements when working with children, please be referred to Pact’s ‘Guidance on Filming with Children’.
   

6. Health and Safety
   Mammoth Screen’s Health and Safety policy gives guidance to those whose roles involve working with children and young persons.
   
   A full health and safety risk assessment will be completed before bringing any child onto a location or set. Where a child or young person is involved, the risk assessment must take account of their particular vulnerabilities and ways to protect them.
   
   The risk assessment should also set out what arrangements are in place for their care and supervision, e.g. by a school, parent, guardian or chaperone and how these arrangements will be communicated to the appropriate parties. It is recommended that during a production an appropriate person – a child “buddy” – is given responsibility to oversee, check and document the child’s welfare throughout and it is prudent that the child’s parent or guardian has access to this person throughout the production.
   
   Mammoth Screen will always work within statutory hours allowed for working with children; tutoring will be provided in line with current legislation as required. Particular attention will be given to scheduling in regular rest breaks and ensuring that refreshments are provided regularly. (See guide in Appendix C)
   
   Appropriate clothing and facilities will always be provided according to the conditions involved for filming, i.e. warm, dry shelter if filming in cold weather; water/sunscreen/shaded shelter from sun if filming in hot weather
   
   For more information on Risk assessments, please see section 11.7 in Pact’s ‘Guidance on Filming with Children’.
   

7. Chaperones
   A licensed chaperone must always be hired to accompany any child engaged to provide services to Mammoth Screen. Parents, or an official guardian, can accompany the child but they cannot act as their official chaperone.
   
   As a minimum, there will be one chaperone for every two children who have substantial acting roles in the applicable production.
   
   As a minimum, there will be one chaperone for every five children engaged as supporting artists. An exception may be made on large crowd days involving twenty children or more where LEA standard minimum ratios would apply.
   
   The producer and the line producer must review regularly the specific circumstances on their particular production and ensure sufficient supervision of all children. This might mean hiring more chaperones, if required.
   

8. Transport
   Children
   When children, regardless of whether they need a licence, are being transported on behalf of Mammoth Screen they should be accompanied by a parent, guardian, chaperone (if the child requires a licence then the chaperone should be the person named on the licence) or teacher. The producer or line producer should agree with the child’s parent at the time of booking who will accompany the child to/from set.
   
   In the very exceptional cases where a child who does not require a licence is to be transported unaccompanied by their parent, guardian, chaperone or teacher, this must be with taxi companies that provide drivers with suitable background checks and satisfactory DBS Checks (approved taxi companies), or by a member of staff who has a satisfactory DBS Check, and in either case only with the specific prior written consent of their parent or guardian.
   
   The producer or line producer shall request all approved taxi companies to provide child seats or booster seats appropriate to the age of the children being transported, and shall request that such children do not sit in the front passenger seat.
   
   Young Persons (A Young Person is someone who is over school leaving age, so does not require a licence or chaperone, but is under 18) Young persons engaged on productions who may travel unaccompanied, on behalf of Mammoth Screen should be transported by approved taxi companies or a member of staff who has a satisfactory DBS Check. Written parental/guardian consent should be sought for this.
   

9. Accommodation Children
   Any child will be accompanied by a registered LEA chaperone if required to stay overnight on any production. Should a parent prefer to accompany and stay overnight with their child then this wish should be respected.
   
   Young Persons
   Written parental/ guardian consent will be sought before a Young Person is asked to stay unaccompanied overnight in accommodation.
   

10. Other general welfare considerations set out under the Ofcom Broadcasting Code
    In addition to having in place appropriate essential Child Protection procedures, Mammoth Screen shall seek to comply with the general welfare obligations for children set out for broadcasters under the Ofcom Broadcasting Code. The Broadcasting Code sets out the following duties of care for broadcasters:
    
    •      Due care must be taken over the physical and emotional welfare and the dignity of people under eighteen who take part or are otherwise involved in programmes. This is irrespective of any consent given by the participant or by a parent, guardian or other person over the age of eighteen in loco parentis.
    •      Children under eighteen must not be caused unnecessary distress or anxiety by their involvement in programmes or by the broadcast of those programmes.
    
    •      Prizes aimed at children must be appropriate to the age range of both the target audience and the participants.
    
    In order to ensure compliance with the Code Mammoth Screen shall also seek to adhere to any guidance issued by Ofcom from time to time that underpins these broadcaster duties. (See www.ofcom.org.uk). In addition, the producer should also liaise closely with those editorially responsible for the programme and with the broadcaster’s compliance and legal officers, as appropriate. Discussions with the broadcaster’s designated compliance officer about scenes involving children must begin at script stage and continue as more information about how the relevant scenes are expected to be filmed becomes available.
    

11. Safeguarding Children online
    Abuse and exploitation of children can happen online through social networks, sharing of information, playing games online and so forth. We recognise that it is our responsibility to a reasonable extent to safeguard children and young persons in services we host online and on social platforms, such as photos, film, and through information in conjunction with our programmes/productions.
    
    For more information on how to keep children safe online, please visit this link: https://www.nspcc.org.uk/preventing-abuse/keeping-children-safe/online-safety/
    

12. Child Abuse and Neglect
    A child is abused or neglected when somebody inflicts harm, or fails to act to prevent harm. A child or young person up to the age of 18 years can suffer abuse or neglect and require protection.
    
    •     Physical Abuse - May involve hitting, shaking, throwing, poisoning, burning or scalding, drowning or suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates or induces illness in a child whom they are looking after.
    
    •     Sexual Abuse - Forcing or enticing a child/young person to take part in sexual activities, whether or not they are aware of what is happening, may involve: physical contact, including penetrative or non-penetrative acts; non-contact activities, such as involving children in looking at, or in the production of pornographic material or watching sexual activities; or encouraging children to behave in sexually inappropriate ways.
    
    •     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. It may involve a parent or carer failing to provide adequate food, shelter and clothing, failing to protect a child from physical harm or danger, or the failure to ensure access to appropriate care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
    
    •     Emotional Abuse - The persistent emotional ill-treatment of a child such as to cause severe and persistent adverse effects on the child’s emotional and behavioural development. It may involve conveying to the child that they are worthless or unloved, inadequate, or valued only in so far as they meet the needs of another person. It may feature age and developmentally inappropriate expectations being imposed on children. It may involve causing children to feel frightened or in danger, for example witnessing domestic abuse within the home or being bullied, or the exploitation or corruption of children.
    
    Some level of emotional abuse is involved in all types of ill treatment of a child, though it may occur alone
    
    Safeguarding and Raising a Concern
    It is not our responsibility to decide whether or not abuse has taken place, however it is still important to take the right action. If Mammoth Staff see or suspect abuse of a child, then that person must inform the Child Protection Officer or, in his absence, any other director of Mammoth Screen immediately and contact ITV’s Safeguarding Officer via safeguarding@itv.com. If urgent, please call ITV’s 24/7 Health and Safety emergency number 020 715 74000 (Option 3).
    
    Disclosure of Abuse
    If Mammoth Staff are told by a child that they or another child or young person is being abused, the individual should:-
    
    •     always stop and listen straight away, show that they take the child’s allegations seriously. If you are told something by a child you should always assume they are telling the truth;
    •     encourage the child to talk, but does not ask leading questions, interrupt or ask the child to repeat itself.
    •     never promise to keep what is said confidential or secret – explain to the child that if you are told something of concern that you will need to let someone know but that you will only tell the people who need to know and can help.
    •     ask if the child if they have told their parents/guardian (if the claim does not directly involve the parents/guardians) but do not make this decision for the child. Record the wishes of the child but do not act until you have spoken to a Safeguarding Officer.
    •     make an accurate record of the child’s allegations as soon as possible (the nature of any injury/abuse - who, how, when and where). Use the child‘s own words. Make a note of the time, location, whether anyone else present and of the child’s demeanour.
    •     ensure that the concerns are reported immediately to the Child Protection Officer (or, in his absence, any other director of Mammoth Screen immediately) and ITV’s Safeguarding Officer.
    •     not confront the alleged abuser.
    
    Handling Allegations
    •     If a child makes an allegation against a member of staff it must be reported as a matter of urgency to the Child Protection Officer and ITV Safeguarding Officer who will refer the matter in accordance with Appendix A. If the allegation is against the Child Protection Officer then the information should be reported to the ITV Safeguarding Officer, another director of Mammoth Screen or directly to Social Services department for Children’s Services. (This would generally be referred to the authority in which the alleged incident took place).
    •     The alleged perpetrator should not be made aware of the allegation at this point.
    
    Recording
    •     In all situations the details of allegation or reported incident must be recorded. Make accurate notes of time, dates, incident or disclosure, people involved, what was said and done and by whom, action taken to investigate, further action taken e.g. suspension of individual and if relevant: reasons why the matter was not referred to a statutory agency, name of person reporting and to whom it was reported
    •     The record must be stored securely and shared only with those who need to know, in accordance with Mammoth’s Data Protection Policy.
    
    DO NOT worry that you might be mistaken; Mammoth Staff have a responsibility to pass on any concerns following a disclosure. Never think abuse is impossible, or that an accusation about a person you know well and trust is bound to be wrong.
    
    IT IS YOUR DUTY TO REFER ON - NOT TO INVESTIGATE
    
    If a child or young person tells you that they or another child or young person is being abused:
    
    DO:

    •     Remain calm, accessible and receptive

    •     Listen carefully without interrupting

    •     Communicate with the child in a way that is appropriate to their age, understanding and preference – this is especially important for disabled children and for children whose preferred language is not English

    •     Be aware of the non-verbal messages you are giving

    •     Make it clear that you are taking them seriously

    •     Acknowledge their courage and reassure them that they are right to tell

    •     Reassure them that they should not feel guilty and say that you are sorry that this has happened to them

    •     Let them know that you are going to do everything you can to help them and explain what may happen as a result

    •     Make a note of what was said and who was present, using the child’s actual words wherever possible.
    
    DON’T:

    •     Allow your shock or distaste to show

    •     Probe for more information than the child offers

    •     Speculate or make assumptions

    •     Make negative comments about the alleged abuser

    •     Make any promises that you cannot keep, e.g. that “everything will be all right”

    •     Agree to keep the information a secret

    •     Delay getting emergency help if needed, e.g. medical help
    

13. Legislation
    Mammoth Screen will adhere to the relevant legislation when working with children and young people under the age of 18 years as outlined in the following:
    •     Children Act 1989
    •     Children Act 2004
    •     Working Together to Safeguard Children 2018, revised 2022
    

14. Data Protection
    We acknowledge that children’s data merits special protection under the retained EU law version of the General Data Protection Regulation (EU) 2016/679 (UK GDPR) and the Data Protection Act 2018 and may constitute special category data (depending on the circumstances). We take extra care when collecting and processing children’s and young persons’ data as they may be less aware of the risks involved in providing such data. We inform the children and young persons we work with, as well as their parent/ legal guardian, about their rights under the data protection legislation. More about how we collect and process data can be found in our privacy policy: http://www.mammothscreen.com/privacy/
    

15. Documentation and record-keeping
    Mammoth Screen will document all decisions taken in regard to safeguarding when filming with children and young persons. Jon Williams has the overall responsibility for this documentation.