SAFEGUARDING AND
CHILD PROTECTION POLICY
Minninnooka Polo & Riding School
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Policy owner: Kirstie Otamendi, Designated Safeguarding Lead
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Deputy: Joshua Leiva, Deputy Safeguarding Lead
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Applies from: 7 September 2026
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Review due: 7 September 2027, or sooner after an incident or guidance change
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Applies to: All staff, coaches, apprentices, contractors, volunteers, riders, clients, parents, carers, family members, guests and spectators
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Safeguarding comes before reputation, convenience or competitive success.
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If anyone believes a child is in immediate danger, call 999. A concern does not need to be proved before it is reported.
Quick response: what to do:
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Immediate danger or urgent medical need: call 999, then inform the Designated Safeguarding Lead (DSL).
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A child discloses something: listen, stay calm, do not promise secrecy, do not ask leading questions and write down the child's own words.
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Any other concern: report it to the DSL as soon as possible on the same day.
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Concern about the DSL: report it to the Deputy DSL or directly to Surrey Children's Services/LADO, police, HPA or The Pony Club safeguarding team.
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Do not investigate, confront the person involved, delete messages or share information beyond those who need to know.
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Owner: Kirstie Otamendi | Version 2.0 | September 2026
MINNINNOOKA POLO & RIDING SCHOOL | SAFEGUARDING
1. Purpose and principles
Minninnooka Polo & Riding School is committed to providing a safe, positive and inclusive environment for every child and young person taking part in riding, polo, coaching, yard activities, camps, competitions, trips, online activity and social events connected with Minninnooka.
For this policy, a child is anyone under 18. The welfare and best interests of the child are the first consideration. All children have the same right to protection, regardless of ability, disability, sex, race, religion or belief, sexual orientation, gender identity, family circumstances or background.
Safeguarding is everyone's responsibility. Concerns will be listened to, recorded and acted on fairly. No person will be criticised for raising a genuine concern in good faith.
2. Scope
This policy applies whenever a person is taking part in, working at, visiting, representing or communicating in connection with Minninnooka, whether on the yard, at another venue, during transport, at a competition, online or outside normal hours.
The term staff includes employees, apprentices (including those under 18), coaches, contractors, freelancers, work-experience students, volunteers and regular helpers.
3. Responsibilities
Designated Safeguarding Lead
Kirstie Otamendi - 07557 343355 - kirstie@minninnooka.co.uk
Deputy: Joshua Leiva - 07455 011410 - josh@minninnooka.co.uk
The DSL receives concerns, decides the appropriate next step, makes referrals, keeps safeguarding records, supports those involved and ensures staff understand this policy. The DSL will seek advice whenever the correct threshold or response is unclear.
Everyone connected with Minninnooka
Behave safely and respectfully around children.
Report concerns promptly; do not assume somebody else will report them.
Follow staff instructions and the rules in this policy.
Respect privacy and do not discuss safeguarding matters in the yard, social groups or online.
4. Expected behaviour and professional boundaries
Staff should be warm, encouraging and approachable, but must remain in a professional role. A staff member must not become a client's secret-keeper, peer, personal relationship adviser or exclusive source of emotional support.
Treat children fairly and avoid favouritism, humiliation, sexualised comments, bullying, threats or inappropriate jokes.
Never enter a sexual or romantic relationship with a child or use a position at Minninnooka to create an inappropriate relationship.
Do not ask a child to keep contact, conversations, gifts or activities secret.
Do not give personal gifts, money, special privileges or private invitations without approval and parental knowledge.
Do not consume alcohol or illegal drugs while responsible for children, or work when impaired.
Report any accidental boundary crossing or situation that could be misunderstood to the DSL promptly.
5. Phones, messaging and social media
The simple rule
Staff must not privately message a client under 18 through a personal phone number, WhatsApp, Snapchat, Instagram, TikTok or any other personal account.
Do not add, follow or privately communicate with under-18 clients through personal social-media accounts.
Do not use disappearing-message services for Minninnooka communication.
Necessary messages must use an authorised Minninnooka channel and include a parent/carer or another appropriate adult.
Do not give private advice about relationships, sex, family disputes or other sensitive matters. Be kind, explain the boundary and refer the child to the DSL or another suitable adult.
If a child messages privately, do not continue a social conversation. Retain the message, redirect them to the approved channel and notify the DSL if it is personal, concerning or repeated.
Do not delete relevant messages. Never download, copy or forward a suspected sexual image of a child.
These rules apply to apprentices and other staff under 18. The fact that two people are close in age does not remove the staff/client boundary created through Minninnooka. A genuine pre-existing family or social relationship must be declared to the DSL so that proportionate arrangements can be agreed.
6. Safe working at the yard and during activities
Supervision and one-to-one situations
Activities must be appropriately staffed and risk assessed for the riders' age, ability, horses, location and conditions.
One-to-one coaching should take place in an observable or interruptible area. Another adult should know where it is taking place.
Avoid unnecessary isolation with a child. If unavoidable because of illness, injury or an emergency, remain visible where possible and record what happened.
A staff member or apprentice under 18 must not be left with sole responsibility for supervising children or managing safeguarding matters.
Physical contact
Physical contact must be necessary for safety, first aid or instruction; explained beforehand where possible; proportionate; and respectful of the child's wishes. Staff should use verbal explanation and demonstration first. Any contact that causes concern or could be misunderstood must be reported.
Changing, toilets and personal care
Adults must respect privacy and must not enter changing or toilet areas used by children unless necessary for immediate safety. Any personal-care arrangements must be agreed in advance with the child and parent/carer and recorded in an individual plan.
Transport, trips and competitions
Transport must be authorised, insured and agreed with the parent/carer.
Avoid transporting one child alone wherever reasonably possible. If unavoidable, obtain approval, tell another adult the route and timing, and record the journey.
Trips, camps and overnight stays require appropriate consent, emergency contacts, sleeping arrangements, supervision and risk assessment.
Horse and yard welfare
Unsafe coaching, dangerous supervision, mistreatment of horses in front of children, asking a child to perform beyond their competence, or using fear or humiliation as instruction must be reported. Health and safety incidents should be managed under Minninnooka's health and safety procedures as well as this policy where a child's welfare may be affected.
7. Parents, carers, family, friends and spectators
Parents, carers, family members, friends, clients and spectators are expected to support a safe environment. They must follow staff instructions, behave respectfully and report concerns.
Visitors must not take responsibility for, coach, transport or be alone with another person's child unless authorised.
Adults must not privately contact, photograph, film or post identifiable images of other children without appropriate permission.
Bullying, abusive language, threatening behaviour, sexualised comments, discrimination and online harassment are not accepted.
Adults must not pressure children to train, compete, ride or continue an activity when staff have raised a safety or welfare concern.
Minninnooka may ask anyone whose behaviour creates a safeguarding risk to leave, restrict their access or refer the matter externally.
8. Recognising safeguarding concerns
A concern may arise from something seen or heard, a change in behaviour, an injury, an online message, a disclosure, a pattern of smaller incidents or a feeling that a boundary is being crossed. It may relate to home, school, the community, sport, online activity or Minninnooka.
Concerns may include physical, emotional or sexual abuse; neglect; domestic abuse; bullying or cyberbullying; child-on-child abuse; grooming; exploitation; coercive relationships; sexual harassment; harmful sexual behaviour; intimate-image sharing; self-harm; suicide risk; radicalisation; trafficking; county lines; discrimination or unsafe professional practice.
9. If a child tells you something
Listen and stay calm.
Take the child seriously and reassure them that they did the right thing by telling you.
Do not promise confidentiality. Explain that you must share the information with somebody who can help.
Do not investigate, ask leading questions or press for details. Ask only what is necessary to understand immediate safety.
Do not contact the person alleged to be responsible.
Write a factual record as soon as possible, using the child's own words where possible. Include the date, time, place, people present and action taken.
Report to the DSL immediately. If a child is in immediate danger, call 999 first.
10. Reporting and referral
All concerns must be reported to the DSL on the same day. Staff may contact Surrey Children's Services or the police directly if the DSL is unavailable, the concern involves the DSL, delay could place a child at risk or the staff member believes appropriate action has not been taken.
The DSL will consider immediate safety, early help, parental involvement, referral to Surrey Children's Services, police or LADO, and notification to HPA, The Pony Club, a referring school, apprenticeship provider or Alternative Provision commissioner where applicable.
Parents/carers will normally be informed unless doing so may place a child or another person at greater risk, interfere with an investigation or conflict with advice from statutory agencies.
11. Concerns about staff, coaches, volunteers or other adults
Any concern about an adult or person working with children must be taken seriously, handled fairly and reported to the DSL. This includes behaviour at work, outside work or online that may affect their suitability to work with children.
The DSL will consult Surrey LADO where a person may have:
Behaved in a way that harmed or may have harmed a child.
Possibly committed a criminal offence against or related to a child.
Behaved towards a child in a way indicating that they may pose a risk of harm.
Behaved in a way indicating that they may not be suitable to work with children.
The DSL will not carry out a full internal investigation before seeking LADO or police advice. Necessary protective measures may be taken without assuming guilt. Concerns about Kirstie Otamendi should be reported to Joshua Leiva or directly to Surrey LADO, Children's Services, police, HPA or The Pony Club.
12. Low-level concerns and boundary breaches
A low-level concern is behaviour that is inconsistent with this policy or the expected code of conduct but does not appear to meet the LADO threshold. It may include over-familiarity, favouritism, private messaging, personal social-media contact, unauthorised lifts or one-to-one contact, inappropriate comments or failure to report a disclosure.
Low-level does not mean unimportant. The DSL will record the concern, speak to those involved as appropriate, consider any pattern and decide whether guidance, training, supervision, a management instruction, disciplinary action or external advice is required.
13. Concerns involving children
Safeguarding concerns can arise between children. They will not be dismissed as banter, friendship, teenage behaviour or part of sport. This includes bullying, coercion, harassment, harmful sexual behaviour, online abuse, image sharing and exploitation.
Both children will be treated as children who may need support. Minninnooka will consider age, understanding, consent, vulnerability, repetition and any difference in authority or responsibility, including where one child is also an apprentice or young worker.
14. Photography, video and publicity
Obtain appropriate consent before using identifiable images of a child for Minninnooka publicity.
Use authorised devices/accounts where practicable and store images securely.
Do not photograph children in changing areas or in a state of undress.
Do not include unnecessary personal information, live location or private schedules.
Respect a child's or parent's request not to be photographed, subject to any necessary event or safety arrangements explained in advance.
15. Safer recruitment, training and supervision
Recruitment will include identity, reference and right-to-work checks and an appropriate assessment of suitability.
Minninnooka will obtain the legally appropriate level of DBS check for eligible roles, including a Children's Barred List check where the role is regulated activity.
DBS status will be reviewed through the Update Service where available and consented to, or by requesting a new check according to risk and governing-body requirements.
Staff receive safeguarding induction before unsupervised work, formal refresher training at suitable intervals and safeguarding updates at least annually or whenever risks and guidance change.
Young workers and apprentices receive age-appropriate supervision, clear boundaries and a named adult to whom they can raise concerns.
16. Records, confidentiality and information sharing
Safeguarding information is confidential but not secret. Information will be shared only when necessary and proportionate to protect a child, support decision-making or meet a legal or contractual duty.
Records must be factual, dated, timed and signed or attributable to the author.
Record what was seen or heard, the child's words, decisions, advice received, action taken and the reasons for action or inaction.
Keep safeguarding records securely and separately from routine rider records, with access limited to those who need it.
Do not store the only copy on a personal phone or personal account.
Retain records in accordance with legal, insurance, governing-body and local safeguarding requirements.
17. Alternative Provision and referring organisations
Where a child is placed or referred by a school, local authority, Alternative Provision service or another organisation, Minninnooka will also follow the safeguarding, attendance, notifiable-event and information-sharing requirements in the relevant agreement. This includes timely liaison with the referring body's designated safeguarding lead and Surrey commissioning contacts where required.
Contract-specific email addresses and notification rules will be checked at least annually rather than relied upon indefinitely in this policy.
18. Complaints, whistleblowing and consequences
A person who believes a concern has not been handled appropriately may contact the Deputy DSL, Surrey Children's Services, Surrey LADO, police, HPA or The Pony Club. Nobody will be disadvantaged for raising a genuine safeguarding concern in good faith.
A breach of this policy may result in guidance, closer supervision, removal from an activity, restriction of access, disciplinary action, termination of engagement or referral to a governing body, statutory agency or the Disclosure and Barring Service, as appropriate.
19. Key contacts
Kirstie Otamendi | 07557 343355 | kirstie@minninnooka.co.uk
Deputy DSL: Joshua Leiva | 07455 011410 | josh@minninnooka.co.uk
Surrey Children's Single Point of Access: 0300 470 9100 | cspa@surreycc.gov.uk
Surrey LADO: Use the current Surrey Safeguarding Children Partnership LADO referral route
NSPCC Helpline: 0808 800 5000 | help@nspcc.org.uk
Childline: 0800 1111
Hurlingham Polo Association: 01367 242 828 | enquiries@hpa-polo.co.uk | ask for safeguarding
The Pony Club: 02476 698300 | enquiries@pcuk.org | ask for safeguarding
20. Legal and procedural framework
This policy should be read alongside current versions of:
Children Act 1989 and Children Act 2004
Safeguarding Vulnerable Groups Act 2006 and Protection of Freedoms Act 2012
Sexual Offences Act 2003
Data Protection Act 2018 and UK GDPR
Working Together to Safeguard Children 2026
Keeping Children Safe in Education, where applicable to school-referred or Alternative Provision pupils
Surrey Safeguarding Children Partnership procedures
Current HPA and The Pony Club safeguarding policies and codes of conduct
21. Approval and review
This policy will be reviewed annually and sooner after a safeguarding incident, material organisational change or relevant guidance update. Approved by Kirstie Otamendi, Owner / Designated Safeguarding Lead, on 7 September 2026.
