Who should be our safeguarding lead, and what should trustees do?

England and Wales: partly covered — what the board is expected to do is well evidenced; what a safeguarding lead is, what training they need and who may hold the role is not defined by any official source, and this page does not fill that in. Scotland: partly covered, with the same gap — OSCR does not define the role either, and trustee oversight rests on the general trustee duties. Northern Ireland: partly covered, and further along — the Volunteer Now standard CCNI points to names the role and its core job, but says nothing on training, on who may hold it, or on a concern about the lead.

Two questions, and only one of them has an answer

The trustees’ half of this question is well evidenced. The safeguarding lead’s half is not. This step is for the trustees, the chair and the safeguarding lead, in England and Wales, Scotland and Northern Ireland. The Charity Commission’s position comes first, then OSCR’s and CCNI’s.

It assumes a safeguarding policy is written or in draft; this page is about who keeps it working.

• What the trustees should do. This is well evidenced. In one inquiry, the Commission found safeguarding almost absent from the board’s minutes, and disqualified the trustees.
• Who the safeguarding lead is, and what they do. This is not. The Commission uses the phrase once. No official source in any of the three nations says what authority the role has or what training it needs. None says whether a trustee may hold it, or what happens when the concern is about the lead.

Most sector material answers both questions with the same confidence. This page does not, because the second answer would have to be made up.

The board’s half: on the agenda, in the minutes, every time

The duty sits with all the trustees. Safeguarding, in the Commission’s sense, is taking reasonable steps to protect the people who come into contact with the charity through its work from harm. In the Commission’s words, trustees “must take reasonable steps to protect the people who come into contact with their charity through its work from harm”.

That must is the Commission’s, under its own key. The Commission addresses it to the trustees as a body. Naming one person as lead does not move it off anyone else.

What the Commission then checks is whether the board kept watch. In the SPAC Nation inquiry, the concern was stated plainly:

“The inquiry was concerned about the trustees’ oversight of safeguarding, which was not an agenda item on the trustee board minutes provided to the inquiry apart from once where a policy review was listed. It is difficult to see how the trustees could be assured those coming into contact with the charity were adequately protected if safeguarding oversight was not discussed regularly at trustee meetings.”

Archive status: this report was published in August 2024 and was marked withdrawn on 28 August 2026 under the Commission’s archiving policy. The quotation was re-read against the withdrawn page on 19 September 2026.

So the test is simple to state: whether safeguarding recurs in your minutes. Not once a year when the policy is reviewed, but as a standing item.

No source sets how often the board must meet on it. The inquiry’s word is “regularly”.

In practice that means three things:

1. A standing agenda item at every board meeting, even when the answer is “nothing to report”. Setting the agenda itself is covered on set your meeting rhythm and quorum.
2. A named trustee with safeguarding in their portfolio, who makes sure the item is not skipped.
3. A short report to each meeting from whoever handles concerns day to day: how many, what kind, what was done, anything outstanding.

What the Commission says about a safeguarding lead

The Commission’s core safeguarding guidance uses the phrase “safeguarding lead” once. It appears only in the section addressed to charities working with children or adults at risk, and it is a should:

“should… appoint a safeguarding lead to work with your local authority safeguarding partnerships or boards.”

Three things follow from that sentence. It is good practice, not a legal requirement. It is aimed at charities working with children or adults at risk, not at every charity. And it says what the lead is for, which is working with the local safeguarding partnership or board, but nothing more.

The Commission does not define:

• the lead’s authority within the charity
• the competence or training standard the lead should meet
• whether a trustee may hold the role
• what happens if a concern is about the lead themselves

This guide checked for each of these and found nothing in official guidance. That is an established absence, not a gap in the reading.

Nobody else defines it either

The obvious places to look have been checked, and each comes back empty for a general charity.

• The Charity Governance Code. The 2025 edition was read in full. It never mentions a safeguarding lead, a lead trustee or a designated safeguarding lead. Safeguarding appears only as a policy and training item under its ethics and culture principle.
• Working Together to Safeguard Children. The current edition is the 2026 one, published by the Department for Education in March 2026. It replaces the 2023 edition, so any guidance still citing 2023 is out of date. It applies in England. It binds the statutory safeguarding partners and named agencies, not charities. Including voluntary organisations in local arrangements is at the partners’ discretion. Its references to a designated safeguarding lead are about schools and early years.
• The Department for Education’s out-of-school settings guidance. Working Together points general charities to it. It is expressly non-statutory, and this guide has not read it. It may say more.

A designated safeguarding lead, in sector usage, is the operational person who receives and handles concerns. A lead trustee for safeguarding is the board member who oversees them. Sector material often separates the two, and that is a sensible way to organise.

This guide has not found an official source that sets out this split for a general charity. So treat it as a choice you make, not a rule you follow.

Where a specific sector, such as a school, has its own statutory rules about a designated lead, those apply on their own terms. Which sectors those are is not set out here.

Scotland and Northern Ireland

Scotland. OSCR does not define a safeguarding lead any more closely than the Commission does. The board’s half rests on the general trustee duties under the Charities and Trustee Investment (Scotland) Act 2005, and OSCR says so directly:

“Any failure by charity trustees to manage safeguarding risks adequately can be a failure in charity trustee duties and would be of serious regulatory concern to OSCR. We may consider this to be misconduct in the administration of the charity.”

That is the same shape of exposure as in England and Wales. No named Scottish enforcement case was found to set beside the Commission’s inquiries.

Northern Ireland. This is the one nation where the role is named. CCNI points charities to Volunteer Now’s safeguarding standards, and Standard 4.4 says:

Standard 4.4: "There is a named Designated Officer and Adult Safeguarding Champion (or appointed person) who has responsibility for dealing with safeguarding concerns which come to light within the organisation."

That answers “who”. It does not answer whether a trustee may be that person, what training they need, or what happens when the concern is about them. Volunteer Now is a sector body, and its standards carry official weight only through CCNI’s own cross-reference to them.

What to set up now

Set up the half that is defined, and write down the half that is not.

1. Make safeguarding a standing item on the board agenda, starting at the next meeting.
2. Name a trustee with safeguarding in their portfolio, and minute the appointment.
3. If you work with children or adults at risk, name an operational lead to receive concerns and work with the local safeguarding partnership or board. In Northern Ireland, name the Designated Officer and Adult Safeguarding Champion the standard asks for.
4. Decide who hears a concern about the lead. No source tells you, so the board has to. Write it into the policy.
5. Record what you decided and why, including that the role’s content is your own choice, not a regulator’s specification.

Template: Standing agenda (planned).

With oversight set up, the next step covers what to do when a concern arrives: respond to a disclosure or a concern.

Common mistake: appointing a lead and treating safeguarding as delegated

A named person looks like the problem solved. It is not. The Commission’s must on reasonable steps is addressed to the trustees, all of them. Appointing a lead does not remove that duty from the rest of the board. Nor does it make the lead the only person who needs to understand the subject.

Common mistake: treating “the safeguarding lead” as one role

Both the overseeing trustee and the person who handles concerns get called “the safeguarding lead”. They are different jobs, and in a charity with staff they are usually different people. Decide which one you mean each time the phrase appears in your policy. This guide does not set out whether a particular sector gives the operational role a legal basis.

Common mistake: safeguarding missing from the board minutes

It gets discussed informally, or left to the lead. In SPAC Nation, safeguarding appeared on the minutes once, for a policy review. The inquiry said it was “difficult to see how the trustees could be assured” people were protected. Trustees were disqualified.

Common mistake: a named person who receives concerns and does not pass them on

Concerns often arrive piecemeal, and each one can seem minor. At Ampleforth, the acting superior received concerns on at least four occasions and did not refer them to the safeguarding co-ordinator. Children were put at risk for months, and he was disqualified as a trustee. The section “What is at stake” gives the detail and its archive status.

Worked example

Tollgate Youth CIO has one employee, who runs its youth sessions. The board wants to name her as safeguarding lead and leave it with her.

The chair splits the question in two. For the board’s half, she adds safeguarding as a standing agenda item and names one trustee to hold it. The employee will give a short report to every meeting, even if there is nothing to report.

For the operational half, Tollgate works with young people, so the Commission’s should applies. The employee is named as the person who receives concerns and works with the local safeguarding partnership.

Then the board hits the open question: who hears a concern if it is ever about the employee. No source says. The trustees decide it goes to the named trustee, and they write that into the policy. They minute the whole arrangement, including a line saying the role’s content is their own decision because no official definition exists.