Merlin’s Magic Wand (MMW) is committed to delivering unique, magical and memorable experiences to children facing challenges of serious illness, disability or adversity through its 3 core programmes – Magical Days Out, Merlin’s Magic Spaces and Magic On Tour. 

Given our commitment to health, safety, and welfare we must ensure that our beneficiaries can enjoy themselves in safe and secure environments and are not harmed in any way through contact with MMW. We must take all reasonable and practical steps to ensure that this is the case. 

Having safeguards in place not only protects and promotes the welfare of children and vulnerable persons but also enhances the confidence of trustees, employees, volunteers, parents, and the general public.

MMW believes that:

• The welfare of a child is paramount, and all children have a right to equal protection from all types of harm or abuse. 

• The best interests of the child are paramount in all considerations about their welfare and protection, including when to maintain confidentiality and when to share information.

• Safeguarding is everyone’s responsibility, and everyone has a role to play in safeguarding children.

• Concerns or allegations that employees have abused or neglected a child will be taken extremely seriously and managed sensitively and fairly in accordance with this policy, relevant legislation, and guidance.

• Working together with children, their parents, and authorities is essential in promoting welfare and ensuring the protection of children at risk. In some limited circumstances, it will not be appropriate to engage with parents in order to protect a child at risk.

• As part of working together, MMW expects the relevant authorities to act on our concerns. We will escalate our concerns, if necessary, in our efforts to be satisfied that our concern has been taken seriously and the child at risk has been protected. 

This policy has been developed with reference to the government's statutory guidance, Working Together to Safeguard Children (2026) and reflects the responsibilities of charities and voluntary organisations working with children.

A child - As stated in the Children Acts 1989 and 2004, a child is anyone who has not yet reached their 18th birthday.  In this document ‘children’ is taken to include young people up to 18 and also includes any child or vulnerable person - namely someone who is unable to take care of themselves or protect themselves from exploitation - benefitting from a service or activity provided by MMW.

Business Partners - means any third party that MMW works with who comes into contact with children during the course of the relationship with MMW.

Safeguarding is defined in ‘Working Together to Safeguard Children 2026’, issued by HM Government to include:

• providing help and support to meet the needs of children as soon as problems emerge
• protecting children from maltreatment, whether that is within or outside the home, including online
• preventing impairment of children’s mental and physical health or development
• ensuring that children grow up in circumstances consistent with the provision of safe and effective care
• taking action to enable all children to have the best outcomes in line with the outcomes set out in the Children’s Social Care National Framework

Employees means employees of any entity within the Merlin Entertainments Group.

Volunteers means anyone who completes activities in the name, or on behalf, of MMW in a voluntary capacity.

Parent/(s) means any parent, guardian, or carer.

The policy is essential because it provides a clear process for employees, business partners, volunteers or parents. This ensures everyone is clear about roles, responsibilities and expectations to protect children at risk from harm.  This document applies to all activities and services offered by MMW. The Charity Manager has overall responsibility for safeguarding and governance at MMWCC and is the Designated Safeguarding Officer (DSO) of the children’s charity in the UK and all other Merlin territories outside of the United States of America (USA). The Foundation Manager has overall responsibility for safeguarding and governance at MMWF and is the Designated Safeguarding Officer (DSO) of the foundation in the USA.

This policy applies to all employees, business partners, volunteers and parents.

The work carried out by MMW is diverse and involves working with multiple parties. Our business partners, employee and volunteers should adhere to this safeguarding policy at all times and where relevant, when working with business partners any of their equivalent policies, should also be followed. 

We require that our business partners, (when in contact with children) share our commitment to safeguarding. We will expect them to demonstrate this to us by having their own safeguarding policy and procedures in place that are ‘fit for purpose’ before any partnership agreement is agreed and continued. If the business partner does not have their own safeguarding policy the business partner must agree to adhere to the MMW policy.

In addition to this policy, when MMW beneficiaries visit a Merlin Entertainments Group attraction, the Merlin Group’s Child Safeguarding Policy will also apply. In all cases, the age definition within the MMW policy will supersede the age definition of the Merlin Group’s Child Safeguarding Policy. 

Employees and volunteers are subject to the MMW Code of Conduct referred to in section 10 and appendix A and should familiarise themselves with the same.

To ensure the successful implementation of this policy it is essential that MMW communicate to staff, volunteers, business partners, children, and their parents our commitment to safeguarding. 

Access to the policy is available via the MMW website. This ensures people have access to this information and are able to understand both how the policy will be implemented and the process they should follow should an issue arise. Any feedback or queries about the policy should be directed to mmw.charity@merlinsmagicwand.org.

The implementation of procedures will be regularly monitored on an annual basis using up-to-date NSPCC guidance and reviewed by the Designated Safeguarding Officer (DSO) immediately following any incident where procedures are required to be followed. The charity also maintains a Risk Register and a report of any incidents, including a summary of resulting learnings and actions, is provided to the charity trustees on an annual basis.

The policy will be reviewed every year or whenever there is a major change in the organisation or in relevant legislation and/or good practice guidelines.

As MMW has a close association with Merlin and has frequent access to the attractions, an annual declaration from Merlin is required to confirm that the Merlin Group’s Child Safeguarding Policy is adhered to in all locations.

All employees, business partners, volunteers and parents have a responsibility to identify and share safeguarding concerns. 

It is NOT the responsibility of employees, business partners, volunteers, or parents to make judgements about whether or not abuse is taking place. It is however their responsibility to act if they have concerns about the welfare of a child, as explained in section 17 – Responding to suspicious or allegations of child abuse.

This policy is concerned with protecting children from harm, and specifically from abuse and neglect. 

There are several categories of abuse, namely:

Physical abuse: This is where someone physically hurts or injures a child deliberately, for example by hitting, shaking or by giving them alcohol or inappropriate drugs.

Emotional abuse: The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on their emotional development, including deliberately trying to scare, humiliate, isolate or ignore a child.

Sexual abuse: Sexual abuse involves forcing, tricking or manipulating a child to take part in sexual activities (which includes abuse involving physical contact and abuse where there is no contact with the child), whether or not the child is aware of or understands what is happening.

Neglect: Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of health or development, for example leaving a child hungry or dirty, or without proper clothing, shelter, supervision or health care.

Online abuse: Online abuse is any type of abuse that happens on the internet. It can happen across any device that's connected to the web, and it can happen anywhere online, including social media, text messages and messaging apps, emails, online chats, online gaming and live-streaming sites. Online abuse can also involve image-sharing.

Grooming: Grooming is when someone builds a relationship, trust and emotional connection with a child or young person so they can manipulate, exploit and abuse them.

Domestic abuse: Domestic abuse is any type of controlling, bullying, threatening or violent behaviour between people who are or have been in a relationship. It can also happen between adults related to one another. It can seriously harm children and young people, and experiencing domestic abuse is child abuse.

Child trafficking: Child trafficking and modern slavery are types of child abuse. Trafficking is where children and young people are tricked, forced or persuaded to leave their homes and are moved or transported and then exploited, forced to work or sold. Many children and young people are trafficked into and/or around the country.

There is further information around types of abuse on the NSPCC website.

It is worth noting that children may face multiple harms simultaneously.

It is important that employees are vigilant and take action when they become aware of a possible case of abuse, or of a child who is acting in an agitated manner, or a parent who appears to be in a distressed state. Employees also need to be alert to a child being approached by an obvious stranger, or for any signs of inappropriate behaviour patterns by a colleague when children are close by.

Employees also need to take care that they do not place themselves in a situation with children which could be potentially compromising.

MMW recognises that effective safeguarding depends on timely and appropriate escalation and multi-agency working. Where safeguarding concerns arise, MMW will work cooperatively with relevant safeguarding partners, including local authorities, the police, health services and other appropriate agencies, in accordance with statutory guidance.

Where MMW has shared a safeguarding concern with another agency and believes that the response has been insufficient to protect a child, the concern will be escalated in line with local safeguarding procedures. Escalation may include raising concerns with senior managers within the relevant agency or making a further referral where necessary to safeguard the child (or children).

Where a safeguarding matter meets the threshold of a “serious incident”, MMW will ensure that the matter is reported promptly to the Charity Commission, in accordance with its requirements.

This outlines the conduct expected of all employees and volunteers. The code will serve to safeguard and protect children. It will also help everyone to maintain appropriate standards of behaviour and reduce the possibility of allegations of abuse being made against them.

It is important that employees and volunteers are aware that they may be seen as role models by children and therefore must behave in an appropriate manner at all times by upholding the MMW’s code of conduct. They should also be mindful that their behaviour should reflect the spirit of the code of conduct in their personal life as well and should not behave in a way that would undermine the reputation of MMW be it in a professional or personal capacity.

Further detail in this regards can be found in Appendix A.

In some circumstances MMW requests permission to use photographs, videos and quotes provided by young people and families for whom MMW have arranged a MMW experience, in promotional materials and in internal communications. This could include using information in posters, leaflets, reports, newsletters, on websites (including social media sites such as Facebook), in promotional videos and in newspaper articles. 

Where content involving MMW beneficiaries is being captured during an activity or service being provided by MMW and/or MMW volunteers, only designated members of the marketing team and/or a contracted photographer and/or a contracted videographer will be permitted to capture imagery/video for the purposes of the activity. No other employees or volunteers present will be permitted to capture imagery/video of the MMW beneficiaries or any other children present.

Where imagery/quotes are requested the appropriate supervising adult is required to complete a MMW Media Release Form. If the signed consent form is not received, no imagery/quotes are permitted to be used by MMW for any purpose.

Safeguarding and promoting the welfare of children is a broad concept. Accordingly, all policies and procedures that support safeguarding must be adhered to where relevant, including the Merlin Group's Whistleblowing Policy and Child Safeguarding Policy, which are available to Merlin employees via the company intranet.

Our policy is underpinned by English legislation and statutory guidance which includes:

UN Convention on the Rights of the Child 1991

Data Protection Act 2018

Children Act 1989 and 2004

Sexual Offences Act 2003

Working Together to Safeguard Children (HM Government 2026)

What to do if you are Worried a Child may be being Abused (HM Government 2015)

MMW is committed to implementing a thorough recruitment system that helps to ensure that unsuitable people are not employed in the first instance.  These standard procedures include for all positions:

• Confirmation of identity and home address
• Confirmation of the right to work in the country in question, where the applicant is not a national
• Checking of references and employment history
• Checking of qualifications, where appropriate
• A question requiring confirmation as to whether or not the applicant has any unspent convictions (where it is legal to ask such a question)
• A declaration related to working with children.

All of the above is carried out upon making an offer of employment and not during the interview or recruitment process itself.

A Disclosure and Barring Service (DBS) check in the UK, or local equivalent overseas ‘disclosure’ where available, must be taken for all roles where a specific job might have regular unsupervised contact or close contact with children, such as members of our charity programmes team who will visit partner sites for the planning of Merlin’s Magic Spaces projects, run a Magic on Tour programme activity, or accompany a Magical Day Out visit.  Enhanced DBS checks are completed for all MMW team members as standard. For further information on the level of checks to be carried out please refer to local recruitment policies and procedures.  For the UK please refer to the Disclosure and Barring Service Policy.

Where an existing employee moves into one of these designated posts from an area which does not require disclosure then the Disclosure process above will be carried out.

All volunteers participating in or providing MMW activities or services must read and abide by our Safeguarding Policy and Code of Conduct in advance of any volunteering activities.

If the DBS check indicates that an individual has had a caution in connection with a child or has committed an offence of abuse against a child, then that person will not be considered for employment of any kind within MMW – whether existing employees or new recruits.  Where a report indicates that some other offence has been committed, whether for new recruits or existing employees, this will be considered individually, based on the nature of the job role, the working environment and specific application.

This is in line with offender rehabilitation laws/practice, such as the UK Rehabilitation of Offenders Act and overseas equivalent laws.

Each Merlin venue that MMW sends children to has a procedure for dealing with lost children and investigation of suspected cases of child/young person abuse, including procedures for involvement of the appropriate authorities should an allegation or potential case of abuse come to light. The management team on site has the responsibility for ensuring that these procedures are in place and that they are communicated effectively. 

MMW is satisfied that all Merlin attractions have this in place as it is part of the Merlin Operations Manual that all sites follow, and we are also in receipt of a letter written to MMW from Merlin’s SVP Health, Safety & Security and Sustainability on an annual basis which recognises Merlin’s role in safeguarding the welfare of children and young people whilst they are on Merlin property, and cites the relevant policies and procedures that the company and all attractions follow in order to fulfil their duty of care responsibilities. Merlin also has an audit and action plan procedure, overseen by the Health and Safety committee to globally monitor it.

Please refer to Appendix C for Designated Safeguarding Officer reporting information.

General Considerations

Considerations to be taken into account when developing training and procedures include:

• Respect children/young people at all times, regardless of their age, gender, ethnicity, disability or sexual identity
• Remember that children look up to adults as role models. Behaviour, language and gestures must therefore be appropriate at all times
• Do not engage in or tolerate inappropriate physical activity involving children/young people
• Take suitable action if you become aware of anyone behaving in an inappropriate way towards a child or young person. Call for assistance if needed.
• Never let allegations by a child go unreported, including any made against you. (These may be ‘mischievous’ or even ‘malicious’ allegations and pre-emptive reporting can help further investigation) 
• Do not engage in or tolerate any bullying of a child, either by an adult or by other children
• Avoid unobserved situations of one-to-one contact with a child/young person. If it is unavoidable, try to do so in the open or if indoors, always keep a door open and ensure that you are within the hearing of other adults
• When providing days out ensure that adequate tickets are made available to enable an appropriate ratio of adults to accompany children and that those adults are made aware of their responsibilities towards the children
• Never enter a room where an unaccompanied child/young person may be changing their clothes, without first clearly getting their consent to enter. (In such cases, also try to be accompanied by another adult).
• Ensure that there is a procedure for alerting the Police or Social Services (or local equivalent) where there is a suspicion of abuse towards a child or young person. (See also section 8).
• Exercise care to avoid physical contact with children and others 
• Monitor lone adults behaving suspiciously in child-oriented attractions; and 
• Do not administer first-aid involving the removal of clothing unless their parent/guardian or others are present
• Do not use any type of physical punishment in order to discipline a child. Shouting should also be avoided if possible other than where necessary in a safety critical situation.

Allegations or complaints of abuse must be dealt with in a sensitive way, and there are resources available via the NSPCC which provide guidance on how to manage allegations against staff or volunteers. Management and employees are not responsible for deciding whether or not a child has been subject to abuse. However, they are responsible for reporting suspicions to the police.

Where a child/young person makes an allegation or confides in an employee about abuse either at the location or elsewhere, employees should show that they believe the child and that they take the allegation very seriously. Where an allegation is about an employee of the Group, any such allegation will be fully investigated, in cooperation with the authorities and standard HR policies and procedures will be followed.

What to do if there are concerns:

In such situations, or where concern exists, any suspicion, allegation or incident of abuse must be reported to an immediate line manager. The MMW Charity Manager is responsible for reporting to the relevant authorities. Please refer to Appendix C for Designated Safeguarding Officer reporting information.

As per Merlin’s policy, please note the do’s/don’t’s referenced below:

Do:

• If the child is hurt or ill, seek medical attention if necessary.
• Stay calm and offer reassurance.
• Respect the child’s right to personal privacy but never agree to keep any information relating to the harm of a child confidential.
• Be honest about your own position, who you have to tell and why
• Tell the child what you are doing and when and keep them up to date with what is happening.
• Take further action (e.g. report situation to the senior duty manager or call the police and seek advice if unsure)

Don’t:

• Make promises you cannot keep.
• Interrogate the child. It is not your responsibility to carry out an investigation/interview. This will be the responsibility of the Police and/or local authority safeguarding professionals who have experience and are specifically trained to sensitively manage the disclosure.
• Counsel or lead the child with questions as this may hinder any subsequent legal action.
• Cast doubt on what the child has told you. Try not to interrupt or change the subject.
• Say anything that makes the child feel responsible for the abuse.
• Promise to keep secrets or keep the information confidential.

Allegations against staff or volunteers must be referred to a Designated Safeguarding Officer.

Recording Information

All information shall be treated as confidential, and a record kept of all aspects of an incident within the charity’s Incident Log, should include at least:

• the nature of the allegation
• a description of the alleged occurrence and person involved
• the location
• a description of any visible injuries
• all times and dates, including when the authorities were notified

Whilst giving support, and clarifying the circumstances, employees should never counsel or lead the child with questions as this may hinder any subsequent legal action. Interviews must be left to the Police or Social Services. MMW will deploy control actions stated in the charity Risk Register to mitigate any potential reputational risks, should this be required.

Information will be shared on a need‑to‑know basis and in accordance with data protection legislation. 

Consider the seven golden rules for sharing information in a safeguarding situation (per the government’s guidance), in particular that the GDPR and the Data Protection Act 2018 do not prevent the sharing of personal information where it is necessary and proportionate to safeguard a child, and that consent is not required to share a child’s data for safeguarding purposes, where doing so might put them at increased risk of harm. 

Decisions to share, or not share, information will be recorded, including the reasons for the decision and with whom information has been shared.

MMW understands that training is an important part of the safeguarding process.

All MMW employees receive annual safeguarding training, regardless of how often they come into contact with children during the course of their work.

At attraction level, Merlin employees complete a health & safety induction when they join and this includes safeguarding essentials such as Lost Children and Interacting with Minors.

Ahead of any MMW activity, the local organiser (an employee volunteer) is responsible for ensuring all colleagues who are also participating in or providing the activity have read and agree to abide by the MMW Safeguarding Policy and our Code of Conduct, and a log of names is completed to confirm this in advance of the activity.

APPENDIX A – MMW CODE OF CONDUCT FOR EMPLOYEES AND VOLUNTEERS 

All Employees and Volunteers MUST:

• Treat all children equally, respectfully, with warmth and empathy, and listen to their wishes and feelings
• Encourage a non-discriminatory environment
• Behave in a calm, positive, supportive and encouraging way with children
• Ensure you report on any suspicions, concerns, allegations or disclosures made by a child or parent including poor practice. This includes any suspicions about ‘grooming’ behaviour you must report such concerns and allegations.
• Ensure that the focus of your relationship with a child (including their family in some cases) that you have met through MMW remains professional at all times. The aim should never be to develop the relationship into a friendship or intimate relationship.
• Endeavour to plan activities that involve more than one other person being present, or at least within sight of others.
• Respect a child’s right to personal privacy but never agree to keep any information relating to the harm of a child confidential.
• Ensure that dangerous or otherwise unacceptable behaviour, including bullying is challenged and addressed.
• Be aware that children can develop infatuations (crushes) towards adults. If this is happening, you should tell your line manager and then respond to the situation in a way that maintains the dignity of all concerned.
• Ensure that if a child needs physical comfort that this is done in a way that is both age appropriate and respectful of their personal space. Never act in a way which may be perceived as threatening or intrusive. Always check out with a child before you act to make sure they are comfortable with you touching them. Physical contact should not be done in a hidden or secretive way that could be misconstrued by the child or anyone else observing it. Physical contact should be limited to a hug or touch of the arm/hand.
• Ensure that if any kind of physical support is required during any activities, it is provided only when necessary, in relation to the activity and that you are doing this in a way that other colleagues can observe you.

You must not:

• Conduct a sexual relationship with a child or indulge in any form of sexual contact with a child regardless of the age of consent. This would constitute a breach of a position of trust and is never acceptable even if the child is aged 16 years or above and can legally consent to a sexual relationship in the UK.
• Swear or make sarcastic, insensitive, derogatory or sexually suggestive comments or gestures to or in front of children.
• Engage in or allow any sexually provocative games involving or observed by children, whether based on talking or touching.
• Show favouritism or gossip about children.
• Rely on your reputation, position or MMW to protect you.
• Ask a child questions which may be construed as sensitive without first consulting with the person responsible for the child.
• Let any allegations of abuse or poor practice go unchallenged or unreported.
• Maintain confidentiality about sensitive information to safeguard a child.
• Work under the influence of alcohol or drugs.
• Smoke, vape or drink alcohol in front of children.
• Discuss your own personal/ sexual relationships in front of children.
• Give or receive gifts and/or substances such as drugs, alcohol, cigarettes, and e-cigarettes from or to a child or their family.
• Use any type of physical punishment in order to discipline. Shouting at children should also be avoided whenever possible and only if alternative forms of discipline have failed.
• Do things of a personal nature that the child can do for themselves.
• Steal, or condone someone else’s stealing, regardless of the value the stolen item.
• Photograph or film children for which no prior consent has been sought.
• Administer first aid involving the removal of clothing unless in the presence of their parents or others.
• Show any audio and/or visual material (CDs, DVDs, videos, photos, films, computer, or games etc.) that has inappropriate content for children.
• Arrange to meet a child outside of your work context where the purpose is one of friendship or an intimate relationship.
• Provide your own or seek social media identifying information or contact information for a child or their family members, nor privately message or attempt to contact a child or their family members via any means.

APPENDIX B – MMW MEDIA RELEASE FORM - AVAILABLE UPON REQUEST

APPENDIX C – DESIGNATED SAFEGUARDING OFFICER (DSO) RESPONSIBILITIES

All staff and volunteers who may encounter children or their families/carers, in-person or online, should be aware of their responsibilities for safeguarding and protecting children from harm, how they should respond to child protection concerns and how to make a referral to Safeguarding Partners if necessary (Department for Education, 2023).

The Charity Manager (UK & ROW) and the Foundation Manager (USA) are the senior members of staff who hold overall responsibility for the organisation’s safeguarding arrangements, which includes supervision, development, and decision-making in conjunction with the Designated Safeguarding Officer role. At MMW, there is an additional Designated Safeguarding Officer and point of contact in the team – our Global Operations Manager. We also have a charity Trustee acting as our Trustee Safeguarding Lead.

The Charity Manager (UK & ROW) and the Foundation Manager (USA) fulfil the role of the Designated Safeguarding Officer (DSO) in their respective regions, with the responsibility of providing safeguarding guidance and support across the organisation. This includes, but is not limited to:

• Ensuring that the voice of children is heard, understood; and underpins all safeguarding practice and development.
• Ensuring that all staff and volunteers receive necessary safeguarding training applicable to their respective roles and subject to necessary updates in line with best practice.
• Ensuring that safeguarding policies and practice are adhered to and reflect up to date legislation and guidance.
• Working alongside Merlin volunteers to uphold safeguarding practices.
• Ensuring that Safe Recruitment practices are upheld across the organisation.
• Ensuring that an annual declaration is received from Merlin’s Group Health, Safety and Security Director to confirm that the Merlin Group’s Child Safeguarding Policy is adhered to in all locations.

All staff and volunteers who participate in a MMW activity have a responsibility to safeguard children, and to report any concerns about their welfare. In the case of MMW activities being held at a Merlin Entertainments site or in a local community site, at least one Merlin employee volunteer - ideally the site’s existing Designated Safeguarding Officer, or individual with responsibilities thereof - should be identified as the Safeguarding Lead for the activity. This individual should be fully briefed on the Safeguarding Policy and ensure that all volunteers have read and signed the MMW Code of Conduct in Appendix B. This person is also responsible for informing a MMW DSO of any safeguarding concerns that arise in the first instance.

It is recognised that any member of staff or volunteer can make contact with emergency services and/or a Local Authority Safeguarding Officer (LADO) in the event of concern arising if there is reasonable cause to suspect a child may come to significant harm if this contact is delayed. In the unlikely event of this occurrence, the DSO should be informed at the first available opportunity after contact is made with emergency services/a LADO.

If an individual has a concern relating to the activity’s Safeguarding Lead, they should make direct contact with the MMW Safeguarding Lead. If an individual has a concern relating to the MMW Safeguarding Lead, they should make direct contact with that person’s line manager or the Trustee Safeguarding Lead.