Company Protection & Data Protection Policy​

Rebel Roots Theatre Company is committed to protecting the personal data, privacy, safety, and wellbeing of all individuals it works with, including children, young people, staff, freelancers, volunteers, audiences, and partners. This policy supports the Company’s duty of care and should be read in conjunction with the Company’s Safeguarding Policy.

This policy is implemented in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and relevant safeguarding legislation and guidance. Where a conflict arises between data protection requirements and safeguarding responsibilities, the Company will always prioritise the safety and protection of children, young people, and vulnerable individuals, in line with legal guidance.

Rebel Roots Theatre Company is registered with the Information Commissioner’s Office (ICO) as a data controller. Details of this registration, including the Company’s registration status, can be viewed on the ICO’s public register by searching for “Rebel Roots Theatre Company” at www.ico.org.uk. This registration confirms the Company’s compliance with its legal obligations in relation to data protection.

Rebel Roots Theatre Company may collect and process personal data where it is necessary for legitimate organisational purposes. This may include names, contact details, dates of birth, emergency contact information, medical or accessibility information, safeguarding records, images and recordings, and employment, contractual, or financial information. Special category data, including medical and safeguarding information, will only be collected where it is lawful, necessary, and proportionate.

Personal data is collected and used solely for purposes connected to the Company’s work. These purposes include safeguarding and welfare, ensuring safe participation in rehearsals, workshops, performances, and agency activity, meeting legal and regulatory obligations, managing contracts and finances, and communicating with individuals about Company activity. Personal data will not be used for unrelated or inappropriate purposes.

All personal and safeguarding information is stored securely, either digitally or in physical form. Access is restricted to authorised Company Representatives and relevant Staff Members only. Safeguarding records are stored separately and handled in line with the Company’s Safeguarding Policy. Digital records are protected through appropriate security measures, and reasonable steps are taken to prevent loss, misuse, unauthorised access, or disclosure.

The Company will only share personal data where consent has been given, where it is necessary to safeguard a child or young person, or where disclosure is required by law, including to local authorities, the police, licensing bodies, or safeguarding partners. Any information shared for safeguarding purposes follows the information-sharing principles set out in the Safeguarding Policy and is recorded appropriately.

Personal data is retained only for as long as necessary. Safeguarding records are kept in line with legal and best-practice guidance, and financial or contractual records are retained in accordance with HMRC and regulatory requirements. When data is no longer required, it is securely deleted or destroyed.

Company Representatives are responsible for overseeing compliance with this policy. All Staff Members, freelancers, and volunteers are expected to handle personal data responsibly and confidentially. Any actual or suspected data breach, loss of information, or unauthorised disclosure must be reported immediately to a Company Representative. Failure to comply with this policy may result in disciplinary action.

This policy will be reviewed annually by the Company’s Directors and Members, alongside the Safeguarding Policy, to ensure it remains legally compliant, effective, and appropriate for the Company’s activities.

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Safeguarding Policy

1. Commitment to Safety

 

Organisational Structure Statement
Rebel Roots Youth Academy operates as a programme and subdivision of Rebel Roots Theatre Company. Rebel Roots Theatre Company is the legal entity responsible for all safeguarding, administration, governance, and compliance. Any reference in this policy to “Rebel Roots”, “the Company”, or “we/us” includes both Rebel Roots Theatre Company and Rebel Roots Youth Academy.

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a.) Rebel Roots Theatre Company and Rebel Roots Youth Academy work actively to prevent harm and promote the welfare of all children and young people that we interact with. This Safeguarding Policy applies to individuals referred to as ‘Beneficiaries’.

b.) The Company is committed to ensuring the safety and well-being of all Beneficiaries, free from discrimination based on age, disability, race, religion, sexual orientation, gender identity, or any protected characteristics.

c.) This Safeguarding Policy adheres to the latest safeguarding laws of England, Wales, Northern Ireland and Scotland, including relevant government guidance. Where any conflict arises between this Policy and safeguarding law, Rebel Roots Theatre Company will always prioritise legal compliance.

d.) This Safeguarding Policy is implemented in fulfilment of our obligations as an organisation working with children and young people, including within our activities as an acting/talent agency representing individuals 25 and under.

e.) For any questions relating to this policy, please contact info@rebelrootstheatre.com

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2. Safeguarding Policy Scope

a.) This Policy applies to all individuals working for, volunteering with, or representing Rebel Roots Theatre Company and Rebel Roots Youth Academy in any capacity, including contractors, freelance practitioners, guest artists, and interns (collectively ‘Staff Members’).

b.) This policy is separate from any employment or engagement contracts. Rebel Roots Theatre Company may revise the policy at any time to maintain legal compliance and operational effectiveness.

c.) This Policy outlines the Company’s approach to preventing harm to Beneficiaries through safe conduct, safe environments, and responsible organisational processes.

d.) This Policy applies to all Rebel Roots Theatre Company and Rebel Roots Youth Academy activities involving children and young people under the age of 25.

e.) This Policy applies to both in-person and online activity, including digital auditions, remote workshops, social media interactions, and digital communications.

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3. Safeguarding Definition

a.) ‘Safeguarding’ refers to the systems, behaviours, and procedures designed to protect vulnerable individuals from harm or potential harm. This includes emotional, physical, psychological, and sexual safety. This Policy primarily covers child safeguarding, defining a child as anyone under 18, while also recognising the vulnerabilities of young adults aged 18–25 represented in our agency.

b.) This Policy outlines Rebel Roots’ responsibility to protect Beneficiaries from harm caused by:
• Rebel Roots’ own activities, procedures, or the conduct of Staff Members
• External individuals or situations, where Staff Members know, ought to know, or reasonably suspect that a safeguarding risk exists

c.) A ‘safeguarding concern’ is any suspicion, observation, behaviour, disclosure, or information that suggests risk or potential risk to a Beneficiary’s safety or well-being.

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4. Code of Conduct (Staff and Beneficiaries)

a.) All Staff Members must maintain professional boundaries at all times, avoiding behaviour that could be misinterpreted or place a Beneficiary at risk.

b.) Staff must not show favouritism, or engage in private social relationships with Beneficiaries.

c.) Staff must use only official communication channels for work-related contact and must not use personal messaging or social media accounts with Beneficiaries.

d.) Beneficiaries are expected to treat others with respect, follow Staff instructions, and contribute to a safe and inclusive environment.

e.) Bullying, harassment, discrimination, or abusive behaviour will not be tolerated and will be dealt with promptly.

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5. Lone Working and One-to-One Interaction

a.) Staff should avoid being alone with a child in isolated or private spaces wherever possible.

b.) Where one-to-one interaction is unavoidable (e.g. agency meetings, coaching sessions), these should take place in open, observable environments.

c.) If an unavoidable one-to-one session occurs, a record should be made including time, location, and purpose.

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6. Physical Contact Policy

a.) Physical contact should only occur when necessary for the activity (e.g. safe movement, choreography) and must always be explained beforehand.

b.) Beneficiaries have the absolute right to decline physical contact at any time.

c.) Physical contact must be appropriate, consent-based, and proportionate to the task.

d.) Staff must be aware of the increased sensitivity around physical contact in performance settings and ensure transparency at all times.

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7. How Rebel Roots Protects Its Beneficiaries: Key Safeguarding Measures

a.) Prioritising the safety of children and young people by following local safeguarding arrangements set by local authorities, police services, and safeguarding partnerships.

b.) All permanent Staff Members will receive training on identifying and reporting safeguarding concerns.

c.) Creating a safe and accessible environment for all Staff Members to raise safeguarding concerns confidentially and professionally.

d.) Maintaining secure records of all safeguarding concerns, investigations, and decisions, stored in accordance with GDPR and the Data Protection Act 2018.

e.) Ensuring that Beneficiaries are never left unsupervised in unsafe or inappropriate environments, including during rehearsals, workshops, performances, or agency-related activity.

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8. Supervision Ratios, Arrival and Collection

a.) Rebel Roots will maintain appropriate supervision ratios in all activities, generally following recommended sector guidance (e.g. 1:10 for ages 10+, 1:6 for under 10s).

b.) Children under 16 must be collected by a parent/guardian, and their collection must be observed by a Rebel Roots Staff Member. Individuals aged 16 and over will be allowed to make their own way home.

c.) Parents/guardians must inform Rebel Roots if someone else is collecting their child.

d.) If a child is not collected, Staff will follow escalation procedures, including attempts to contact parents and, if necessary, contacting safeguarding authorities.

e.) In the absence of prior written consent for a child under 16 to make their own way home, Rebel Roots will not release the child at the end of an activity. The child will remain under staff supervision until collected by a parent, guardian, or other authorised adult.

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9. Transport Policy

a.) Staff members will not transport beneficiaries in personal vehicles unless agreed in writing.

b.) Where transport is provided by external organisations (e.g., production companies), they must demonstrate appropriate safety measures.

c.) Beneficiaries must never be left unattended during travel arrangements organised by external partners.

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10. Use of External Venues, Pubs, and Public Spaces

a.) Rebel Roots will conduct risk assessments for all external spaces and venues.

b.) Under-18s will not be taken into venues deemed inappropriate for minors and will always be supervised.

c.) Staff will ensure all locations used for rehearsals, performances, and meetings are safe, accessible, and suitable for young people.

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11. Safeguarding Responsibilities within Rebel Roots Youth Academy

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11.1 Child Performance Licensing Responsibilities

a.) We ensure children under 16 do not undertake regulated performance without a legal Child Performance Licence issued by the appropriate local authority, or without confirming eligibility for a licence exemption.

b.) Production companies, casting directors, and employers must evidence that the necessary licence or exemption is in place before a child can participate in any performance or paid activity.

c.) Rebel Roots Youth Academy may help facilitate this by supplying required documents, but we are not the licence applicant and cannot submit licence applications on behalf of parents.

d.) If a production company is unable or unwilling to obtain the legally required licence, Rebel Roots Youth Academy will not allow our young performer to take part and we will not work with that company.

e.) We actively choose to collaborate only with organisations shown to uphold robust safeguarding standards.

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11.2 General Safeguarding Responsibilities

a.) Tyler Pickles is the designated lead for safeguarding policies and procedures within Rebel Roots Theatre Company and Rebel Roots Youth Academy.

b.) Following safe recruitment processes, including:
• A valid DBS check required before appointment
• Mandatory safeguarding and first aid training for permanent staff

c.) Providing training to Staff Members appropriate to their roles, including:
• Recognising signs of abuse
• Active listening and safe responses
• Confidentiality and information-sharing principles
• Reporting procedures
• Awareness of external safeguarding bodies

d.) Treating all safeguarding information with confidentiality, in accordance with GDPR and the Data Protection Act 2018.

e.) Creating a culture of openness and awareness, ensuring beneficiaries and parents/guardians understand our safeguarding approach and how to report concerns.

f.) Regularly reviewing safeguarding policies and procedures to ensure compliance with law and suitability for the organisation.

g.) Ensuring safe digital practice, including appropriate conduct on social media, secure sharing of audition materials, and supervised online sessions where required.

 

12. Staff Members’ Responsibilities

a.) All Staff Members must promote the safety and well-being of Beneficiaries by following this Policy and all relevant UK safeguarding laws.

b.) Staff Members should actively participate in training, ask questions where needed, and take personal responsibility for maintaining a safe environment.

c.) Staff Members must not take any action or neglect any action that could place Beneficiaries at risk, including failure to report concerns.

d.) Staff Members must report safeguarding concerns immediately, whether those concerns relate to:
• Another Staff Member
• A Beneficiary
• A parent or guardian
• A production company or external partner

e.) Staff Members must maintain appropriate professional boundaries at all times, including avoiding unsupervised one-to-one situations in isolated or inappropriate settings.

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13. Procedures: Reporting

a.) All individuals working on behalf of Rebel Roots Theatre Company or Rebel Roots Youth Academy will receive safeguarding guidance appropriate to their role and will be expected to recognise potential concerns, including abuse, neglect, emotional harm, exploitation, unsafe working environments, or inappropriate conduct by external parties.

b.) If the person receiving the concern cannot follow the usual reporting pathway (for example, due to a conflict of interest, lack of independence, or personal discomfort), they must seek an alternative appropriate route. This may include consulting an alternative senior representative within Rebel Roots (where available) or, in situations of immediate or serious risk, reporting directly to emergency services or the relevant safeguarding authority.

c.) All concerns must be documented factually and stored securely. Reports must not include assumptions or personal opinions.

d.) Beneficiaries and parents/guardians will be informed of safeguarding concerns only where appropriate and legally permissible.

e.) Staff induction requirement: all new Staff Members must read and sign a confirmation that they have understood this Policy and their safeguarding responsibilities.

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14. Procedures: Investigation and Response

a.) All safeguarding concerns will be taken seriously and addressed promptly by trained personnel following legal and organisational procedures.

b.) Staff Members who report concerns will be kept informed of the progress of the investigation where appropriate.

c.) Any Staff Member found to have breached this Policy may face disciplinary action, including dismissal, depending on the severity and circumstances.

d.) External referrals (e.g., police, local authority, LADO, regulatory bodies) will be made where required, following data protection regulations.

e.) Where a concern involves the Safeguarding Lead, the matter must be reported directly to the local authority, LADO, or emergency services.

f.) Whistleblowing cross-reference: concerns regarding malpractice, poor practice, or the Safeguarding Lead may also be raised through the Company’s whistleblowing procedure.

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15. Use of Images, Media & Social Media

a.) Rebel Roots will obtain written consent before using images, videos, self-tapes, or promotional media featuring beneficiaries.

b.) Consent will specify where and how media may be used (e.g. website, marketing, casting submissions).

c.) Staff must not engage in private social media communication with beneficiaries.

d.) All media will be stored securely and shared only through approved channels.

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16. Medical Information, Additional Needs & Emergencies

a.) Rebel Roots will request relevant medical, accessibility, and emergency information to ensure safe participation.

b.) Information will be stored securely and only shared where necessary.

c.) Staff will follow emergency procedures including contacting emergency services when required.

d.) Staff will not administer medication unless legally permitted and agreed in advance.

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17. Anti-Bullying and Behaviour Management

a.) Rebel Roots has zero tolerance for bullying, harassment, or discrimination by Staff or Beneficiaries.

b.) Reports of bullying will be investigated promptly and appropriate action taken.

c.) Behaviour management will be positive, supportive, and never involve humiliation, shouting, or punitive measures.

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18. Prevent Duty Statement

a.) Where applicable, Rebel Roots complies with the Prevent Duty and will take action where concerns arise relating to radicalisation or extremist views.

b.) Staff will report any concerns about extremist language, behaviour, or influence to the Safeguarding Lead, who will escalate to the local authority if required.

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19. Legislation References

a.) This Policy is implemented in line with, but not limited to, the following legislation and guidance: Children Act 1989, Children Act 2004, Working Together to Safeguard Children 2018, Keeping Children Safe in Education 2024, GDPR and Data Protection Act 2018.

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20. Annual Review

a.) This Safeguarding Policy will be formally reviewed at least annually by the Safeguarding Lead and the Company directors to ensure ongoing compliance, effectiveness, and suitability for all activities.

b.) Any amendments will be communicated to all Staff Members, and records of the review will be retained.

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21. Emergency Contacts & Escalation Flow

a.) A one-page emergency contacts flow will be maintained and displayed for Staff Members, including: local authority safeguarding contacts, police, LADO, and relevant internal contacts.

b.) In all cases of immediate risk, emergency services will be contacted first, followed by the Safeguarding Lead or alternative senior representative.