The Disclosure Response Requirements
What has to be true before an organization can honestly say it is ready for the moment a child speaks. Free to read, free to implement, and free to comply with — you never have to pay us to meet it.
| Version | 1.0.0 |
|---|---|
| Status | Draft for expert review |
| Published | 2026-08-15 |
| Next review | 2027-08-15 |
| Structure | 28 requirements · 7 domains · 6 mandatory |
| Licence | Free to read, use, implement and cite. No fee, no registration, no login. |
How to read this
Each requirement has a weight from 1 to 3. Six are mandatory. An organization that fails any mandatory requirement does not reach any tier, whatever its total score — because a good score elsewhere cannot offset an unlawful reporting route or an emergency number nobody has dialled.
The evidence column is what an independent verifier examines. It is included here, in the free document, so that any organization can prepare for verification without buying anything from us, and so that anyone can check whether a verification was done properly.
| Tier | What it means |
|---|---|
| Not yet ready | A mandatory requirement is unmet, or too much of the remainder is missing. |
| Tier 1 — Prepared | Every mandatory requirement is met and the reporting route is lawful. |
| Tier 2 — Practised | Tier 1, plus training current within 24 months and rehearsed aloud. |
| Tier 3 — Accountable | Tier 2, plus a review cycle and accountability to the child after the report. |
A · The legal duty and reporting route
An organisation cannot respond lawfully to a disclosure if its own policy describes an unlawful route. This domain is first because an error here voids everything after it.
| Ref | Requirement | Weight | Evidence examined on verification |
|---|---|---|---|
| A1 Mandatory | The written procedure directs staff to report directly to the child protection authority themselves, rather than only to a manager or internal lead. | 3 | The procedure text. Any internal escalation flowchart. Staff interviews asking who they would call first. |
| A2 | The procedure names the specific statute and reporting threshold applicable where the organisation operates. | 2 | The procedure text, checked against the statute in force on the date of review. |
| A3 | Staff understand that the duty is triggered by suspicion, and does not require proof, certainty, or an explicit disclosure. | 2 | Training materials. Staff interviews establishing the threshold they believe applies. |
| A4 | The procedure states that a person reporting in good faith is protected from civil liability. | 2 | The procedure text. |
B · Named people and reachability
A procedure that cannot be acted on outside office hours is a procedure that fails at precisely the times children most often speak.
| Ref | Requirement | Weight | Evidence examined on verification |
|---|---|---|---|
| B1 Mandatory | The procedure names actual individuals — by name, not by role alone — as safeguarding lead and at least one alternate. | 3 | The procedure text. Confirmation that each named person knows they are named. |
| B2 Mandatory | The procedure gives a 24-hour telephone number for the child protection authority which has been dialled and confirmed within the preceding 12 months. | 3 | A dated record of the verification call. The verifier dials it independently. |
| B3 | The procedure states what a person does outside operating hours. | 3 | The procedure text. Interview with a volunteer or casual staff member. |
| B4 | Names and numbers are displayed where staff can reach them without permission or authentication. | 2 | Physical inspection of the premises. |
C · The written procedure
A safeguarding policy states principles. A disclosure procedure tells one person what to do in the next ninety seconds. Most organisations have only the first.
| Ref | Requirement | Weight | Evidence examined on verification |
|---|---|---|---|
| C1 Mandatory | A written disclosure-response procedure exists, distinct from the general safeguarding policy. | 3 | The document itself. |
| C2 | The procedure is dated, versioned, and reviewed at least every 12 months. | 2 | Version history. Minutes recording adoption and review. |
| C3 | The procedure states what an adult should say, and should not say, in the first ninety seconds. | 2 | The procedure text. |
| C4 | The procedure explicitly prohibits investigative questioning. | 2 | The procedure text. Training materials. |
| C5 | The portion needed in the moment is no longer than one page. | 1 | The action card or equivalent extract. |
D · Training and practice
A document is not a capability. This domain distinguishes organisations that have written something from organisations whose people can actually do it.
| Ref | Requirement | Weight | Evidence examined on verification |
|---|---|---|---|
| D1 Mandatory | All staff and volunteers with contact with children have completed disclosure-response training. | 3 | Training register cross-checked against the current staff and volunteer roster. |
| D2 | That training was completed within the preceding 24 months. | 3 | Dated training records. |
| D3 | Receiving a disclosure has been rehearsed aloud, not only read. | 2 | Records of rehearsal or scenario exercises. Staff interviews. |
| D4 | New staff and volunteers complete the training before first unsupervised contact with a child. | 2 | Induction records compared with start dates and rota records. |
E · Recording what was said
The child's own words are the most valuable and most perishable thing produced by a disclosure. Most of their value is destroyed by well-meant tidying.
| Ref | Requirement | Weight | Evidence examined on verification |
|---|---|---|---|
| E1 | The procedure requires the child's exact words to be recorded verbatim, in quotation marks. | 3 | The procedure text. The recording form or template. |
| E2 | The record is made before the receiving adult discusses the disclosure with anyone else. | 2 | The procedure text. Training materials. |
| E3 | Records are stored securely with defined access. | 2 | Physical or system inspection of the storage location and access list. |
| E4 | The procedure prohibits alteration of the original record and requires dated additions instead. | 2 | The procedure text. Inspection of any existing records for evidence of amendment. |
F · When the concern is about the organisation's own people
This is the domain where institutions fail, and it is the domain that ends up in public inquiries. Internal-first is the recurring finding.
| Ref | Requirement | Weight | Evidence examined on verification |
|---|---|---|---|
| F1 Mandatory | The procedure requires external reporting before any internal process begins. | 3 | The procedure text. Any HR or disciplinary policy that touches safeguarding, checked for a conflicting sequence. |
| F2 | The procedure prohibits notifying the person named, or seeking their account, before the authority advises it. | 3 | The procedure text. HR policy. Interviews with managers. |
| F3 | A defined route exists for concerns involving the safeguarding lead. | 2 | The procedure text. Governing body terms of reference. |
G · After the report
A child who tells and then hears nothing learns that telling does nothing. This domain is what distinguishes compliance from care.
| Ref | Requirement | Weight | Evidence examined on verification |
|---|---|---|---|
| G1 | A named person tells the child what happened next, in terms they can understand. | 2 | The procedure text. Records of past cases, appropriately redacted. |
| G2 | Support is available to the adult who received the disclosure. | 2 | The procedure text. Any employee assistance or supervision arrangement. |
| G3 | Records are retained where the authority declines to investigate. | 2 | Retention schedule. Inspection of closed files. |
| G4 | Children in the organisation's care can name more than one adult there they could tell. | 2 | Interviews with children, conducted by the verifier with consent and appropriate safeguards. This is the only requirement verified with the children themselves. |
What this standard does not cover
- Recruitment and screening. Police checks, references and probation are essential and are governed elsewhere.
- Supervision and codes of conduct. How adults and children are permitted to interact is a separate and larger question.
- Online safety. Platform moderation and image handling need their own standard.
- Anything after the report. Investigation, prosecution and therapeutic support belong to statutory bodies and clinicians, not to the organization.
This standard has not yet been reviewed by child-protection practitioners, lawyers, or survivors. It is published in draft so that it can be argued with. If a requirement here is wrong, tell us and it changes — corrections are logged publicly.