| Applies to | All directors, staff, volunteers and contractors acting for HKB, throughout the UK, in person and online |
|---|---|
| Policy owner | Designated Safeguarding Lead |
| Approved by | The Board of HKB on 31 August 2026 |
| Version | 2.0 |
| Next full review | 31 August 2027 |
IF YOU ARE WORRIED ABOUT SOMEONE
Immediate danger, or a threat to life, call 999 now. Tell the Designated Safeguarding Lead afterwards.
Otherwise:
- Listen. Stay calm. Do not promise to keep it secret.
- Do not investigate. Do not question the person in detail, verify anything, or confront anyone.
- Report to the Designated Safeguarding Lead the same day. Contacts are in Annex A.
- Write it down within 24 hours using the form in Annex D, and send it by the secure route in Annex A.
If it involves harassment, threats, surveillance or coercion directed by a foreign state, it is also a police matter. Call 999 if urgent, otherwise 101. State threats can also be reported to Counter Terrorism Policing on 0800 789 321 or at gov.uk/ACT. Follow the same steps above and see Annex C.
If your concern is about the Designated Safeguarding Lead, report to the Safeguarding Director.
You may always report directly to the police or the local authority yourself. No one at HKB may tell you not to.
If you are unsure whether it is serious enough, raise it anyway.
Contents
- IF YOU ARE WORRIED ABOUT SOMEONE
- 1. Purpose and scope
- 2. Policy statement
- 3. Legal framework
- 4. Definitions
- 5. Roles
- 6. Principles
- 7. What to do if you have a concern
- 8. Transnational repression
- 9. Allegations against HKB personnel
- 10. Confidentiality and information sharing
- 11. Safer recruitment and training
- 12. Duty of care to HKB personnel
- 13. Breaches, complaints and review
- 14. Related documents
- Annex A. Contacts and reporting routes
- Annex B. Recognising abuse and neglect
- Annex C. Transnational repression
- Annex D. Safeguarding concern record
1. Purpose and scope
1.1 This policy sets out how HKB protects children and adults from abuse, neglect and other harm, and what everyone connected with HKB must do when they are worried about someone.
1.2 It applies to everyone acting for HKB. This means directors, employees, volunteers, sessional and freelance workers, interpreters, contractors, and anyone representing HKB. In this policy these people are called HKB personnel.
1.3 It protects everyone who comes into contact with HKB through its work. This includes people who use HKB’s services or take part in its activities, members and event attendees, children and young people who take part in HKB activities or are present where HKB personnel are working or whose parents or carers use HKB’s services, HKB personnel themselves, and members of the public encountered through HKB’s work.
1.4 It applies online as well as in person, including messaging groups, social media channels and remote services.
1.5 It applies throughout the United Kingdom. Safeguarding law and referral routes differ between England, Wales, Scotland and Northern Ireland. You must apply the framework for where the person is, not where you are.
1.6 It covers harm arising from transnational repression. HKB works with a community targeted by a foreign state. Where that targeting causes harm to individuals, or places HKB personnel at risk, it falls within this policy. See Section 8.
2. Policy statement
2.1 HKB will not tolerate abuse, neglect, exploitation, harassment or discrimination, whoever the perpetrator and whatever their position.
2.2 Safeguarding is everyone’s responsibility. Every person acting for HKB must be alert to signs of harm, take concerns seriously, and act without delay.
2.3 We recognise that many people we work with have arrived recently, may have limited English, may have insecure immigration status or no recourse to public funds, may be isolated from family and established networks, and may be reluctant to approach the authorities. Some are targeted by a foreign state. These circumstances do not make people inherently vulnerable, but they can make it harder to seek help and easier for others to exploit them.
2.4 We accept a duty of care to our own personnel, some of whom are themselves targeted, alongside our duty to the people we serve.
3. Legal framework
3.1 Apply the framework of the UK nation where the person is located. If unsure, contact the Designated Safeguarding Lead.
| Nation | Children | Adults |
|---|---|---|
| England | Children Acts 1989 and 2004, Working Together to Safeguard Children 2026 | Care Act 2014, s.42 |
| Wales | Social Services and Well-being (Wales) Act 2014, Wales Safeguarding Procedures | As for children |
| Scotland | Children (Scotland) Act 1995, National Guidance for Child Protection in Scotland | Adult Support and Protection (Scotland) Act 2007 |
| Northern Ireland | Co-operating to Safeguard Children and Young People in NI | Adult Safeguarding: Prevention and Protection in Partnership |
3.2 Other legislation engaged by HKB’s work includes the Domestic Abuse Act 2021, the Modern Slavery Act 2015, the Female Genital Mutilation Act 2003, the Sexual Offences Act 2003 (including the offence, in force since 6 February 2026, of creating or requesting a non-consensual intimate image, including a manipulated or AI-generated one), the Safeguarding Vulnerable Groups Act 2006, the Mental Capacity Act 2005, the Equality Act 2010, the Data Protection Act 2018 and UK GDPR, and the National Security Acts 2023 and 2026.
3.3 Mandatory reporting of child sexual abuse. The Crime and Policing Act 2026 creates a duty on people in regulated activity relating to children in England to report child sexual abuse where a child or perpetrator tells them about it, or they witness it, and an offence of deterring someone from reporting. The duty has received Royal Assent but is not yet in force. HKB’s expectation does not wait for commencement. Report immediately, under Section 7, without filtering. The Designated Safeguarding Lead will update this policy on commencement.
4. Definitions
4.1 Child. Anyone under 18, including a young person living independently, working, or a parent themselves.
4.2 Adult at risk. This is the statutory threshold for a local authority safeguarding enquiry. The test differs between the four nations, and you must apply the test for where the person is.
| Nation | Test |
|---|---|
| England and Wales | An adult who has needs for care and support, whether or not those needs are being met, who is experiencing or at risk of abuse or neglect, and who as a result of those needs is unable to protect themselves |
| Scotland | An adult who is unable to safeguard their own wellbeing, property, rights or other interests, who is at risk of harm, and who is more vulnerable to harm because they are affected by disability, mental disorder, illness, or physical or mental infirmity. Care and support needs are not required |
| Northern Ireland | An adult at risk of harm, or an adult in need of protection, as defined in Adult Safeguarding: Prevention and Protection in Partnership |
4.3 Person at heightened risk. HKB’s broader category, covering anyone whose circumstances make them more likely to be harmed, or less able to seek help, whether or not they meet 4.2. It includes people targeted by a foreign state, people with insecure immigration status or no recourse to public funds, recent arrivals and those with limited English, people facing destitution, people in mental health crisis, separated or unaccompanied young people, people isolated from family or community, and people experiencing domestic abuse or coercive control.
4.4 Many people HKB supports face serious risk but do not meet the statutory threshold at 4.2. A healthy adult with a bounty on their head is unlikely to meet it, and adult social care may not accept a referral on that basis alone. This does not reduce HKB’s duty of care. Category 4.3 triggers HKB’s own obligations, meaning risk assessment, support, and the routes in Section 7, even where no statutory route exists.
4.5 Safeguarding concern. Any worry about someone’s safety or wellbeing, however uncertain. It need not be proven, or even likely, before it is raised.
4.6 Allegation. A concern that a member of HKB personnel has harmed someone, may have done so, or has behaved in a way suggesting they may be unsuitable to work with children or adults at risk.
5. Roles
5.1 Everyone acting for HKB
You must complete the training for your role, know who the Designated Safeguarding Lead is, be alert to signs of harm, report concerns promptly, record them accurately, follow HKB’s Code of Conduct, and never promise to keep a disclosure secret.
You are not expected to decide whether abuse has occurred, to investigate, or to gather evidence. Notice, record, pass on.
5.2 Designated Safeguarding Lead
The Designated Safeguarding Lead receives concerns and decides what happens next, makes referrals, maintains the safeguarding record and Annex A, advises personnel, oversees training, and reports to the Board. The postholder must hold training at Designated Safeguarding Lead level, refreshed at least every two years.
HKB may appoint more than one Designated Safeguarding Lead where the volume, geographic spread or nature of its work requires it. Where there is more than one, a single named lead must be accountable for each individual case, and it must always be clear to personnel who that is.
5.3 Deputy Designated Safeguarding Lead
Acts with the full authority of the Designated Safeguarding Lead when that person is unavailable or has a conflict of interest, including where the concern relates to them.
5.4 Safeguarding Director
Holds the Board’s oversight of safeguarding. Does not routinely handle cases. Provides the route by which concerns about the Designated Safeguarding Lead, or about HKB’s handling of a case, reach the Board.
5.5 The Board
The Board retains ultimate responsibility and cannot delegate it away. It appoints the Designated Safeguarding Lead, the Deputy and the Safeguarding Director, and ensures they have the time, training and authority to act. It receives safeguarding reporting quarterly, covering concerns, actions, training completion and lessons identified. It considers safeguarding when approving new activities, funding and partnerships. It ensures HKB holds adequate insurance.
5.6 Activity leads
Anyone leading an HKB activity, project or event must ensure a proportionate safeguarding risk assessment is in place before it begins, that participants know how to raise a concern, and that everyone working on it has read this policy. The risk assessment is where activity-specific controls are set, including lone working and check-in arrangements, supervision of activities involving children, event security, and handling of participant data.
6. Principles
HKB applies the six statutory safeguarding principles.
- Empowerment. People are supported to make their own decisions. We ask what they want to happen.
- Prevention. It is better to act before harm occurs.
- Proportionality. We respond in the least intrusive way consistent with managing the risk.
- Protection. We support those in greatest need.
- Partnership. We work with local agencies and communities.
- Accountability. We keep records that allow our decisions to be understood and challenged.
Making Safeguarding Personal. Adult safeguarding is done with people, not to them. Where an adult has capacity and does not want a referral, that view carries substantial weight and must be recorded. It is not decisive. HKB will act without consent where there is a risk of serious harm, where a criminal offence may have been committed, or where a child is at risk. Where HKB acts against a person’s wishes, the Designated Safeguarding Lead must record why.
No political test. This policy exists to protect people. It will not be used to vet anyone for their political views, or to distinguish between those who are politically active and those who are not. HKB serves the whole community.
7. What to do if you have a concern
7.1 Immediate danger
Call 999. This includes a child or adult at immediate risk of serious harm, a person at immediate risk of taking their own life, a crime in progress, and a threat to life arising from transnational repression. Tell the Designated Safeguarding Lead as soon as you safely can.
7.2 If someone discloses something
Do: listen without interrupting, stay calm, reassure them they were right to tell you, explain early that you cannot keep it to yourself, ask what they would like to happen, and write it down afterwards.
Do not: promise confidentiality, ask leading questions or press for detail (you may compromise a later investigation), investigate or verify, confront or warn the alleged perpetrator, discuss it with anyone who does not need to know or in group chats, or delay because you are unsure it is serious enough.
7.3 Report
Report to the Designated Safeguarding Lead, the same day where possible and within 24 hours. If they are unavailable, report to the Deputy Designated Safeguarding Lead. If the concern is about the Designated Safeguarding Lead, report to the Safeguarding Director. If it is about a director or about the Board’s handling of a matter, report to the Safeguarding Director or, if that is not appropriate, directly to the local authority or the police.
You may report directly to the local authority or the police yourself at any time. Tell the Designated Safeguarding Lead that you have done so.
7.4 Record
Complete the form at Annex D within 24 hours. Record what you saw or were told, in the person’s own words where you can, and distinguish clearly between what you observed, what you were told, and what you think. Send it by the secure route in Annex A. Do not keep a personal copy.
Every concern must be recorded, including those not referred on. Records must be prompt, factual, complete and secure. Records of decisions not to act matter as much as records of referrals.
7.5 What the Designated Safeguarding Lead does
Records receipt, considers immediate safety, identifies the applicable nation and local authority, decides the route or routes, records the decision and reasons including any decision not to refer, informs the person who raised the concern, keeps the person concerned informed unless that would increase risk, and reviews and records the outcome.
| Concern | Route |
|---|---|
| Child at risk of harm | Local authority children’s services where the child lives. Police if a crime may have been committed or there is immediate danger |
| Adult meeting the definition at 4.2 | Local authority adult social care where the adult lives |
| A crime against any person | Police, 999 if immediate, otherwise 101 |
| Transnational repression | Police, 999 if immediate, otherwise 101. Counter Terrorism Policing on 0800 789 321 or gov.uk/ACT for state threat matters. In parallel, consider whether there is a child or adult safeguarding concern and run that route too (Annex C) |
| Modern slavery or trafficking | Police, and consider a National Referral Mechanism referral |
| Person at heightened risk (4.3) below a statutory threshold | HKB risk assessment and support, signposting to specialist services, and a record of the reasoning |
| Allegation against HKB personnel | Section 9 |
| Mental health crisis or risk of suicide | Annex B, section B3 |
7.6 If you are not satisfied with HKB’s response
Escalate to the Safeguarding Director. If still dissatisfied, go directly to the local authority or the police. HKB will not penalise anyone for doing so, and any attempt to do so is a disciplinary matter.
8. Transnational repression
8.1 HKB works with a community targeted by a foreign state. Hong Kong authorities have issued politically motivated arrest warrants and bounties against people living outside Hong Kong, and the UK Government has described this as transnational repression. Community members have reported threats made to relatives in Hong Kong, doxxing, coordinated online harassment, manipulated sexual imagery, and surveillance at events.
8.2 The Home Office describes transnational repression as crimes directed by a foreign state against individuals in the UK, whether physically or online. The defining feature is that a foreign state directs the activity. Counter Terrorism Policing leads the UK policing response to state threats of this kind.
8.3 Transnational repression is not a category of abuse under the Care Act or child protection guidance. It is a criminal and national security matter, and the route is the police rather than the local authority.
8.4 It nevertheless produces harms that fall squarely within safeguarding, including coercion applied through anyone connected to the person overseas, manipulated sexual imagery, financial coercion, and the use of children to pressure their parents. Annex C sets out how these map onto recognised categories.
8.5 HKB therefore runs two escalation routes, which may operate in parallel. Adult social care should not be the sole route for a transnational repression concern. It may not meet the statutory threshold for a safeguarding enquiry, and relying on it alone risks both delay and the loss of the person’s trust.
8.6 Notice and record, do not investigate. HKB personnel must not attempt to identify who is behind an approach, follow or confront anyone, or gather evidence in a way that puts anyone at risk. Government guidance to individuals at risk is explicit on this point, and it applies to us.
8.7 Proportionality and fairness. This policy must not become a mechanism for suspicion. HKB personnel must not treat people as risks on the basis of nationality, ethnicity, accent, origin, family connections or political views. Concerns about an individual must go to the Designated Safeguarding Lead, be recorded, be assessed on evidence, and, where they may affect that person’s involvement with HKB, be put to them with an opportunity to respond, unless that would create a risk to someone’s safety. Suspicion alone is never grounds for exclusion.
9. Allegations against HKB personnel
9.1 This section applies where a member of HKB personnel is alleged to have harmed a child or adult, may have done so, or has behaved in a way suggesting unsuitability. It applies whether the behaviour occurred at HKB or elsewhere, online or in person, recently or historically.
9.2 Report immediately to the Designated Safeguarding Lead, or to the Safeguarding Director if the allegation concerns the Designated Safeguarding Lead. Do not investigate. Do not discuss it with the person concerned.
9.3 The Designated Safeguarding Lead or Safeguarding Director will consider immediate safety, including removal from contact pending consideration. Suspension is a neutral act taken to protect everyone, including the person concerned, and is not a finding. They will refer to the Local Authority Designated Officer within one working day where a child is involved, or the equivalent in Scotland and Northern Ireland. They will refer to adult safeguarding where an adult at risk is involved, and to the police where a criminal offence may have been committed. Advice will be taken before any internal process begins, so as not to prejudice a statutory investigation. Every decision and its reasons will be recorded.
9.4 Duty to refer to the DBS. Where HKB removes someone from regulated activity, or would have done so had they not resigned, because they have harmed or pose a risk of harm, HKB has a legal duty under section 35 of the Safeguarding Vulnerable Groups Act 2006 to refer them to the Disclosure and Barring Service. Equivalent duties apply to Disclosure Scotland and AccessNI. A resignation does not discharge this duty, and HKB will not enter into any agreement preventing a referral.
9.5 The person concerned will be told what is alleged so far as possible without prejudicing a statutory investigation, supported, given an opportunity to respond, and may be accompanied at any meeting.
10. Confidentiality and information sharing
10.1 Safeguarding information is shared on a need-to-know basis. It is never discussed in community messaging groups.
10.2 Never promise confidentiality.
10.3 Data protection law does not prevent safeguarding information sharing. Where there is a risk of serious harm, consent is not required, and it should not be sought in a way implying the person can prevent the sharing. Wherever it is safe to do so, HKB will be open about what is shared, with whom, and why.
10.4 Security. Safeguarding records are held securely, with access restricted to the Designated Safeguarding Lead, the Deputy and the Safeguarding Director. Concerns are reported by the routes in Annex A, not through general or shared channels. HKB will not tell anyone that a communication channel is secure or encrypted unless it is. HKB collects the minimum personal data necessary and deletes it in line with its retention schedule. A membership or attendance list is a security asset and is treated as one.
10.5 Interpreting. Where language support is needed for a safeguarding matter, HKB will arrange an independent interpreter. Never use a child, family member, friend, another service user, or the person’s own community contacts. Using the wrong interpreter can silence someone, expose them, or place them at greater risk.
10.6 Mental capacity. Adults are presumed to have capacity. Where there is reason to doubt capacity for a specific decision, HKB will act in accordance with the capacity law that applies where the person is. This is the Mental Capacity Act 2005 in England and Wales, and the Adults with Incapacity (Scotland) Act 2000 in Scotland. In Northern Ireland the Mental Capacity Act (Northern Ireland) 2016 applies so far as it is in force, and the common law continues to apply otherwise. The Designated Safeguarding Lead will take advice where the position is unclear, and will record the position reached and the reasons for it.
10.7 Retention. Safeguarding records are kept longer than ordinary service records because of the possibility of later inquiry or proceedings. Adult safeguarding records are retained for a minimum of six years from closure. Records relating to a child are retained until that person’s 25th birthday. Records known to relate to allegations or cases of child sexual abuse are retained for 75 years, subject to periodic review, following the recommendation of the Independent Inquiry into Child Sexual Abuse. HKB will follow the Information Commissioner’s code of practice on these records once it is published.
11. Safer recruitment and training
11.1 HKB will not appoint anyone to a role involving contact with children or adults at risk without appropriate checks. For every role HKB will assess whether it amounts to regulated activity and apply the correct level of criminal records check through the Disclosure and Barring Service, Disclosure Scotland or AccessNI. Where a higher level is not available, HKB will consider a Basic check. HKB will verify identity, and will verify right to work where this is legally required, which will not normally include unpaid volunteers. HKB will take up at least two references and follow up gaps in history, require a self-declaration, ask about safeguarding at interview, and confirm that no one appointed as a director or senior manager is disqualified from acting as a company director.
11.2 Criminal record checks are one control among several and are never sufficient alone. Induction, supervision, a clear code of conduct and a culture of early reporting matter more.
11.3 Training requirements are as follows.
| Who | What | Refresh |
|---|---|---|
| All personnel | Safeguarding awareness, at induction and before any public-facing activity | Every 3 years |
| All personnel | Transnational repression awareness, at induction | Every 2 years |
| Designated Safeguarding Lead and Deputy | Designated Safeguarding Lead training | Every 2 years |
| Directors | Safeguarding for boards | Every 3 years |
| Activity leads | Risk assessment and context-specific training | Every 3 years |
11.4 Training must reflect current risks, including online harm, and should use realistic scenarios rather than definitions alone. The Designated Safeguarding Lead maintains a training record and reports completion to the Board.
12. Duty of care to HKB personnel
12.1 HKB’s personnel include people who are publicly identified, named in politically motivated arrest warrants or bounties, or otherwise targeted. HKB owes them a duty of care.
12.2 HKB will assess the risk arising from a person’s role and review it when circumstances change. HKB will support access to personal and cyber security guidance, including the National Cyber Security Centre’s services for individuals at heightened risk and National Protective Security Authority personal security guidance. HKB will provide a named person to whom personnel can raise concerns about their own safety, risk-assess events, support those experiencing harassment or the effects of sustained threat including access to wellbeing support, and recognise self-censorship, withdrawal and hypervigilance as harms to respond to rather than facts merely to note.
12.3 No one is expected to accept a level of personal risk they are unwilling to accept, and no one will be penalised for declining an activity on those grounds.
13. Breaches, complaints and review
13.1 Breach of this policy may lead to disciplinary action up to dismissal or removal from role, or to withdrawal of a volunteer role and exclusion from HKB’s activities. Failing to pass on a safeguarding concern is itself a breach.
13.2 Anyone may complain about HKB’s handling of a safeguarding matter under HKB’s Complaints Policy, addressed to the Safeguarding Director. Complainants may go direct to the local authority or the police at any time. HKB will not retaliate against anyone raising a concern in good faith.
13.3 HKB will notify its funders of serious safeguarding incidents as required by each funding agreement.
13.4 Review. The Board reviews this policy at least annually, and additionally on a significant change in law, a serious incident or near miss, a materially new area of activity, or a significant change in the threat environment. The Designated Safeguarding Lead may update Annexes A and C at any time without Board re-approval, reporting material changes to the next Board meeting.
13.5 Each review must produce a written record of what was considered, covering changes in law, concerns and near misses since the last review, training completion, and lessons identified. A review may conclude that no change is needed, but that conclusion must be evidenced.
14. Related documents
This policy should be read alongside:
- Code of Conduct
- Safer Recruitment and DBS Procedure
- Whistleblowing Policy
- Lone Working Procedure
- Online and Data Security Procedure
- Data Protection Policy and Retention Schedule
- Complaints Policy
- Event Risk Assessment Procedure
- Photography and Media Consent Policy
- Equality, Diversity and Inclusion Policy
- Staff Handbook
Annex A. Contacts and reporting routes
Maintained by the Designated Safeguarding Lead. Last checked: [date]. Check at least every six months.
A1. HKB safeguarding contact
Safeguarding address: hongkongersinbritain@protonmail.com
This address is monitored daily, including outside office hours. Access is restricted to the Designated Safeguarding Lead, the Deputy Designated Safeguarding Lead and the Safeguarding Director.
The people currently holding these three roles are named in the internal version of this annex. Their names are given to all HKB personnel at induction, and to any person using HKB’s services who asks.
Route for concern records. Send the completed form at Annex D to the safeguarding address, marked confidential. Do not send safeguarding information through group chats, personal accounts or community channels. This address is access-restricted, but it is not end-to-end encrypted for messages sent to or from other providers, so do not treat it as a secure channel for anything beyond routine safeguarding reporting.
Urgent concerns. Email is not a route for anything urgent. Where someone is in immediate danger, call 999. For a child or adult at risk outside office hours, you may also contact the relevant local authority emergency duty team.
A2. Emergency and specialist reporting
| Situation | Contact |
|---|---|
| Immediate danger, crime in progress, threat to life | 999 |
| Non-emergency police | 101 |
| Transnational repression and state threats | Police first, on 999 or 101. Counter Terrorism Policing, 0800 789 321 or gov.uk/ACT, as an additional route where appropriate |
| Suspected cyber incident affecting an individual | incidents@ncsc.gov.uk |
| NCSC protective services for individuals at heightened risk | individualsupport@ncsc.gov.uk |
A3. Finding the right local authority
Referrals go to the local authority where the person lives, not where HKB is based.
- Find their council at gov.uk/find-local-council.
- Search for the council name together with “report a safeguarding concern about an adult” or “report a safeguarding concern about a child”.
- Most councils publish a duty telephone number, an online referral form, and a separate emergency duty team number for out of hours.
- Record the authority, the route used, the date, the time, and any reference given.
A4. National support
| Need | Organisation |
|---|---|
| Concern about a child | NSPCC Helpline, 0808 800 5000 |
| Child or young person | Childline, 0800 1111 |
| Domestic abuse (England) | National Domestic Abuse Helpline, 0808 2000 247 |
| Emotional distress or suicidal thoughts | Samaritans, 116 123 |
| Modern slavery | Modern Slavery and Exploitation Helpline, 08000 121 700 |
| Eating disorder support | Beat, 0808 801 0677, or Beat Youthline, 0808 801 0711 |
| Transnational repression | GOV.UK, What to do if you think you are the victim of transnational repression |
| Personal security | National Protective Security Authority |
| Cyber security for high-risk individuals | National Cyber Security Centre |
Annex B. Recognising abuse and neglect
A prompt, not a diagnostic tool. You do not need to be sure. Raise it.
B1. Children, four categories
Physical abuse. Hitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating, or otherwise causing physical harm. It also covers fabricated or induced illness.
Emotional abuse. Persistent maltreatment causing severe adverse effects on emotional development. This includes conveying that a child is worthless or unloved, developmentally inappropriate expectations, causing a child to feel frightened, and exploitation or corruption. A child who sees, hears or experiences the effects of domestic abuse is a victim in their own right.
Sexual abuse. Forcing or enticing a child into sexual activity, whether or not they understand what is happening. It covers contact and non-contact activity, online and offline, and includes grooming, indecent images, and sexual exploitation.
Neglect. Persistent failure to meet a child’s basic physical or psychological needs, including food, clothing, shelter, protection from harm, supervision, medical care, and emotional responsiveness.
Also be alert to criminal exploitation including county lines, bullying including online, self-harm, female genital mutilation, forced marriage, so-called honour-based abuse, trafficking, radicalisation, and online harm including grooming, sextortion and manipulated intimate images.
Increased risk. Disabled children may have fewer social contacts, receive personal care from more people, have greater difficulty communicating, and be less likely to be believed.
In HKB’s context. A child may be used to pressure a parent who is politically active, face politicised bullying at school, be interpreting for adults in situations no child should be placed in, be at risk of removal from the UK, or be caught between a parent here and family in Hong Kong.
B2. Adults, ten categories
| Category | Includes |
|---|---|
| Physical | Assault, inappropriate restraint or sanctions, misuse of medication |
| Domestic abuse | Physical, sexual, psychological, emotional or economic abuse and coercive or controlling behaviour between people aged 16 or over who are personally connected. Includes so-called honour-based abuse and forced marriage |
| Sexual | Rape, sexual assault, and acts to which the person did not or could not consent or was pressured into consenting. Includes image-based sexual abuse |
| Psychological or emotional | Threats of harm or abandonment, humiliation, blaming, control, intimidation, coercion, harassment, isolation, withdrawal of support networks |
| Financial or material | Theft, fraud, exploitation, pressure over wills, property or inheritance, misuse of possessions or benefits |
| Modern slavery | Slavery, servitude, forced labour, trafficking |
| Discriminatory | Harassment, slurs or unequal treatment based on a protected characteristic |
| Organisational | Poor practice, neglect or mistreatment arising from an organisation’s structures or culture, including HKB’s own |
| Neglect and acts of omission | Ignoring care needs, failing to provide access to services, withholding necessities |
| Self-neglect | Neglect of hygiene, health or surroundings, and hoarding |
Possible indicators. Unexplained injuries. Changes in behaviour, mood or engagement. Fearfulness around a particular person. Withdrawal. Deterioration in appearance or health. Unexplained financial difficulty. A third party answering for the person or preventing them speaking alone. Reluctance to explain a situation.
In HKB’s context. Exploitation by employers or landlords where immigration status is insecure. Destitution arising from no recourse to public funds. Debt arising from migration costs. Coercion by family. Isolation following the loss of established networks.
B3. Suicide, self-harm and mental health crisis
If someone tells you they are thinking of ending their life, or you believe they may be at risk:
- take it seriously and stay with them if you can
- if there is immediate danger, call 999
- otherwise encourage and, if they wish, support them to contact their GP, NHS 111, or Samaritans on 116 123
- do not agree to keep it to yourself
- tell the Designated Safeguarding Lead the same day and record what was said
Do not attempt to assess risk yourself or work through checklists of questions. Respond with care, get help, pass it on.
Annex C. Transnational repression
Maintained by the Designated Safeguarding Lead. Reviewed at least every six months. Last reviewed: [date].
C1. How it maps onto safeguarding
| Tactic | Category engaged |
|---|---|
| Anyone connected to the person, such as relatives, friends or other contacts, in Hong Kong, China or elsewhere, visited, questioned, detained or otherwise pressured in order to force them to comply | Psychological abuse and coercive control. Domestic abuse where the person applying the pressure in the UK is a partner, former partner or relative |
| Doxxing, meaning publishing a home address, workplace or child’s school | Harassment, risk of physical harm, child safeguarding concern |
| Manipulated or AI-generated sexual imagery, and non-consensual intimate images | Image-based sexual abuse, and a criminal offence |
| Blocking or seizing assets, pension or property in Hong Kong, and abusive litigation | Financial and material abuse |
| Politically motivated arrest warrants and bounties | Threat to life and physical safety |
| Pressure on a young person because of a parent’s activity, and politicised bullying | Emotional abuse, child protection concern |
| Pressuring community members to inform on others | Exploitation and coercion |
| Abusive INTERPOL notices, misuse of consular processes, and pressure to return “voluntarily” | Risk of unlawful removal, risk to liberty when travelling |
C2. Indicators
These are prompts to record and raise, not to investigate.
Circumstances
- Anyone connected to them, such as relatives, friends or other contacts, in Hong Kong, China or elsewhere, visited, questioned, detained, or asked to pass on a message
- Sudden withdrawal from HKB activity, or a request to be removed from records, photographs or mailing lists, without explanation
- A request to take down a post or remove a name shortly after contact from someone connected to Hong Kong or PRC bodies
- Being named in, or expecting to be named in, a politically motivated arrest warrant or bounty
- Letters alleging criminality or offering a reward for information, sent to the person or to their neighbours, landlord or employer
- Pressure to attend a meeting at a consulate, trade office, or with an unidentified official
- Being urged to return to Hong Kong for a family matter
Online
- Coordinated abuse, mass reporting of accounts, or impersonation accounts
- Manipulated sexual or humiliating imagery
- Targeted phishing referring to HKB activities, events or people by name
- Unexpected password resets, unprompted multi-factor requests, or unfamiliar devices on accounts
Physical
- The same unfamiliar people or vehicles near a home, workplace or HKB event
- Being photographed or filmed by people who will not identify themselves
- Believing they are being followed
Approaches to HKB
- Requests from unknown parties for member lists, attendance lists, addresses, or names for research
- New volunteers or members pressing quickly for access to data, event logistics, or high-profile individuals
- Offers of funding or partnership conditional on who HKB works with or what it says
The chilling effect, which is a harm in itself
- Self-censorship, or declining to speak or be named
- Withdrawal from the community and isolation
- Anxiety, sleep disturbance, hypervigilance, low mood, or thoughts of suicide
- Family conflict where relatives urge silence
C3. What to do
Do
- Take it seriously and record it, including dates, times, places, what was said, descriptions, vehicle details, and any screenshots or original messages the person already holds
- Ask what they want to happen and explain the options
- Explain that they can report to the police on 101, or 999 if in immediate danger, regardless of their immigration status
- Explain that state threat matters can also be reported to Counter Terrorism Policing on 0800 789 321, or online at gov.uk/ACT, and that these reports can be made in confidence
- Offer to support them to report, including arranging independent interpreting
- Signpost the GOV.UK guidance for individuals, National Cyber Security Centre guidance and protective services, and National Protective Security Authority personal security guidance
- Escalate to the Designated Safeguarding Lead, and escalate immediately to the police where there is a threat to life
- Consider in parallel whether there is a child or adult safeguarding concern, and run that route too
Do not
- Do not tell the person to gather evidence, follow anyone, confront anyone, or photograph suspected surveillance
- Do not promise confidentiality you cannot deliver
- Do not discuss the case in group chats or on unsecured channels
- Do not attempt to identify who is behind an approach
- Do not assume someone is safe because the threat is only online
- Do not treat a person’s political activity, or their choice not to be politically active, as relevant to the support they receive
Annex D. Safeguarding concern record
Complete within 24 hours. Send to the Designated Safeguarding Lead by the secure route in Annex A. Do not keep a personal copy.
About you. Your name, your role, and the date and time of this record.
About the person you are concerned about. Name. Age or date of birth. Address or local authority area. Contact details. Language and interpreting needs. Whether they know you are making this record. Anyone else involved or at risk, including children in the household.
What happened. Date, time and place. Who else was present. What you saw, heard or were told, in the person’s own words where possible. Separate clearly what you observed, what you were told, and what you think.
Views, consent and capacity. What the person wants to happen. Whether they have consented to information being shared, and if not, why it is still being shared. Any reason to doubt their capacity to make this decision.
Immediate action. What you did straight away. Anyone contacted, whether 999, 101 or another service, when, and what was said.
For completion by the Designated Safeguarding Lead
Date and time received. Applicable nation and local authority. Decision and reasons, including reasons for any decision not to refer. Referral made to, with date, time and reference. Whether a parallel transnational repression route is required. Date the person who raised the concern was informed. Review date. Outcome. Signature and date.
End of policy.