Sport and leisure facilities

Facility operators need to address the challenges posed by unaccompanied children visiting (or left at) sports and leisure facilities.

Concerns about unaccompanied children

Concerns regarding unaccompanied children within facilities include:

• physical harm from inappropriate use or access to equipment
• contact with dangerous adults or others within the wider facility (potential for grooming or abuse)
• parents’ contact details and children’s medical information is not available in the event of an emergency
• staff being required to manage children’s unruly or dangerous behaviour

Safeguarding considerations for operators

To ensure that younger customers are safeguarded in these environments, facility operators must establish, review, develop and implement robust safeguarding policies.

This guidance is for facility managers, operators, and staff with responsibility for safeguarding of children within facilities. It's also for contracting, commissioning or overseeing bodies such as Local Safeguarding Partnerships (LSPs).

Parents' responsibilities

Primarily, it's a parent's or carer’s responsibility to judge whether it's safe and appropriate to allow their unaccompanied child to visit a sport or leisure facility.

This decision should be based on their understanding of:

• their child’s general developmental maturity
• their child's awareness of the potential risks
• the level of supervision and care provided within the facility

Many parents exercise their duty of care responsibly. However, there are parents who allow their children to go to, or be left at, facilities with no supervision at all. This may be due to an assumption about the level of supervision that staff will provide within the facility.

This is often an issue when children are booked in to sports or activity sessions but supervision arrangements haven't been considered or organised for the children before, during (for example, toilet or lunch breaks) and/or after the activity.

Facility operators' responsibilities

When children are given access to facilities, operators assume a duty of care for them. The level of their responsibility will vary depending on the specific context. For instance, whether the child is:

• alone and unsupervised at the venue
• with parents or carers
• attending an activity  
• attending an activity staffed by the facility
• attending a school group or club
• attending a public session

Operators therefore have a responsibility to put appropriate safeguarding arrangements in place that include promoting and implementing a policy for admitting unaccompanied children.

This will help to safeguard potentially vulnerable children, reduce safeguarding incidents and support the efficient working of the facility.

Age thresholds for admission

Facilities need to establish a threshold for admitting children to the facility as a basis criteria by which receptionists can operate. In most cases, this means identifying a lower age limit for unaccompanied children.

While the facility will set the lower age limit, it is for parents to judge if their child needs to be accompanied, even if the child is older than the facility’s imposed age limit.

Although there's no formally recommended or legislated age, many facilities currently use 8 years as their age limit.

This is based on CIMSPA's guidance regarding unaccompanied children attending swimming pools (Parental and operator guidance for child supervision policies in swimming pools, PDF). However, this guidance primarily focuses on physical, health and safety risks arising from a child being in the water, rather than child protection and wider safeguarding concerns within the facility.

In February 2015, the CPSU commissioned a report from Dr Vicky Lovett from Swansea University, Safeguarding children in leisure facilities. The report outlined a summary of child development ages 8-11 years for safeguarding children in sport and leisure

Dr Lovett concluded that there are no consistent developmental indicators on which to base a recommendation about whether the appropriate age should be 8, 9, 10 or 11 years. It's therefore up to facility operators to establish a policy that they believe will adequately safeguard younger customers at their venues.

Risk factors

Associated risks with being in the water (overseen by one lifeguard at least) differ significantly from those associated with being unsupervised in other public parts of the facility (such as changing rooms, toilets, and café and bar areas).

This has led to debate involving some safeguarding agencies and facility operators about:

• whether the age of 8 represents an appropriate basis for unaccompanied access to facility sites
• the importance of ensuring that any guidance is informed by a child safeguarding and child development focus
• how identifying and applying any minimum age for this purpose is necessarily a crude tool (given variations in children’s physical, psychological and emotional development)

Unaccompanied children policy – checklist

Facility operators should regularly review their current unaccompanied children policy.

Questions to ask

• What is the policy based on?
• Does it prioritise the safety and welfare of children?
• Is the policy clearly understood by staff?
• How are customers informed?
• Do staff feel supported?
• Is the policy operated effectively?
• What issues and challenges have arisen?
• Would there be value in a mini-campaign to inform (or remind) staff and all customers (particularly parents)?

Implementing an unaccompanied child policy

There are 4 key considerations for facility operators to bear in mind when developing safeguarding arrangements. These are intended to keep any young children using their facilities safe:

1. Communicate with parents and other patrons
2. Inform and train staff
3. Establish sound safeguarding practices
4. Create a policy for third-party use of the facility 

Each of these points is expanded upon with a series of actions below. 

1. Communicate with parents and other customers

• promote the facility's policy on admitting unaccompanied children to all users, particularly parents (consider targeting ‘drop off’ zones for particular attention)
• promote that the expectation is on parents to supervise their children within the facility
• provide information about the extent and limitations of the level of supervision provided to children in the facility (including in ‘high risk’ areas such as changing rooms and toilets)
• emphasise the need to be aware that supervision arrangements before or after any organised activities may not be the same as during the activity
• encourage parents to ensure that anyone providing organised activities for children has access to emergency contact details
• clarify how any safeguarding concerns arising within the facility should be reported
• if the facility intends to use a live video stream of leisure activities for parents, which is displayed in public areas, facilities should make sure that:
• all customers are aware
• images are not recorded
• footage is shown without sound (reduces potential identification of individuals)
• any cameras provide wide-angle, general views of the pool or court
• there are arrangements in place to respond to any concerns about anyone watching the stream whose behaviour gives cause for concern

2. Inform and train staff

• ensure that all staff with responsibility for making decisions about admitting children, particularly receptionists, understand the admission policy and their responsibilities regarding unaccompanied children within the facility
• provide support and guidance to implement the policy
• clarify what to do when questions about an unaccompanied child’s age arise
• involve the safeguarding lead when consideration is given to turning away an unaccompanied child from the facility:
• without someone to take responsibility for the child, sending them away may represent a greater risk than allowing the child admission to the facility
• on this basis the child is allowed to enter the facility, what additional supervision may be required?
• at what point do concerns about a child’s welfare in the absence of appropriate supervision and care require consultation with, or referral to, children’s social care services?

3. Establish sound safeguarding practices

• develop, implement and promote a safeguarding policy and related procedures to reduce the likelihood of incidents and issues arising
• establish and promote clear procedures for responding to any safeguarding concerns
• establish a safeguarding lead role, with responsibility for initiating appropriate action regarding concerns about the welfare of children and young people
• provide safeguarding training and information to assist staff to recognise and respond to concerns, including other issues arising around unaccompanied children

4. Create a policy for third-party use of the facility

• identify and communicate the minimum standards expected of third-party hirers:
• safeguarding policy and procedures
• supervision ratios
• qualifications
• safeguarding officer
• seek assurances that the third-party adheres to the requirements and guidelines of the relevant body (NGB, CSP or school), by:
• including this in contractual agreements and terms of hire
• requiring the completion of a specific safeguarding checklist
• require hirers to inform parents about the limits and extent of children’s supervision before, during and after activities and sessions
• require hirers to make sure parents know what is expected of them, including:
• details about leaving and collecting their children
• whether they need to remain with their children
• providing their emergency contact and their children's medical details

Third-party use of facilities

There are a few key points to consider when determining supervision levels and responsibilities for third-party users of facilities. These are:

• activity and session deliverers – such as clubs, instructors, swim teachers or schools – should ensure adequate supervision levels as part of fulfilling their duty of care
• NGBs and some venues provide key guidance or requirements for using third-party facilities
• supervision ratios will vary depending on the following:
• the age and ability of the participants
• the nature of the activity
• the competence of the participants
• the type of venue

Supervision ratios

Regardless of any agreed ratio of adults to children, it's strongly recommended that there are at least 2 adults with any group.

This ensures that if any situation arises that requires an adult’s attention, the group of children will not be left unsupervised.

• for more information, see our guidance regarding supervising children and young people's sport and activities 
  

Facility managers should advise third parties of the minimum supervision levels and safeguarding arrangements required – either written into their contract of hire, or in the facility's terms and conditions.

Facilities risk reputational damage should hirers fail to adopt appropriate safeguarding practices. For this reason, and more importantly to ensure young people's safety, staff should not ignore potential risks to children simply on the basis that there should be a responsible third party supervising a child.

Organisers' and deliverers' responsibilities

It's up to the organiser or deliverer of an activity to explain to parents the extent of supervision arrangements before and after sessions within the venue.

Depending on the age of the participants, or the nature of the facility, parents may be required to take responsibility for their children during these times.

Facility managers may seek assurance from those organising the activity that this has been communicated to parents.

Facility’s responsibilities

The facility should provide information for parents and other users – through signage, leaflets, web information or when booking – regarding the following:

• the facility’s unaccompanied children policy
• rules regarding the supervision of children within the facility (particularly in changing and showering areas, where safeguarding risks are potentially increased)

How to reduce potential risks

Facility managers should:

• clarify to third-party hirers and activity deliverers their minimum supervision requirements (including before, during and after the activities) at the time for booking or contracting
• address concerns about third parties failing to comply with the facility’s policies and procedures – these matters should be discussed directly with the third party
• develop and maintain guidance for responding to concerns about unsupervised children in the facility (including safeguarding and child protection, health and safety, and managing challenging behaviour)
• develop, maintain and promote a clear policy regarding the admission of unaccompanied children – see our guide to putting safeguards in place for advice on this

The following resources and guidance should prove useful in ensuring that sport and leisure facilities are properly safeguarded for use by children and young people. 

CPSU resources

• Safe use of changing facilities – a briefing on safeguarding young people when they're using sports changing facilities including recommended levels of adult supervision and examples of changing-room policies
• Supervising children and young people's sport and activities – a briefing on the appropriate staffing and supervision ratios of adults to children for sports activities
• Photography in changing rooms and showers – guidance on minimising the risks of mobile phones and cameras in these areas, and on responding to concerns 
• Pool lifeguards and DBS eligibility – a briefing outlining a consistent approach to decisions about the eligibility of pool lifeguards to have DBS checks

Wider NSPCC resources

• Staying safe away from home – a guide for parents as to when their child's old enough to be out on their own, and how to teach them to keep safe while they're away
• PANTS – The Underwear Rule – a simple way that parents can help keep children safe from sexual abuse, without using scary words or even mentioning sex
• Recommended adult to child ratios for working with children – guidance on appropriate levels of supervision for children and young people

Other resources

• Working Together to Safeguard Children (HM Government, 2018; PDF) – guidance published by the Government that identifies organisations' statutory safeguarding responsibilities in England
• CIMSPA professional standards library