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Guide · Charity governance

The safeguarding trustee

A safeguarding trustee, usually called the lead trustee for safeguarding, is the member of a charity's board who leads the board's oversight of safeguarding – strategy, assurance, challenge and the response to serious cases – while the operational safeguarding lead handles concerns day to day; the Charity Commission holds every trustee responsible for safeguarding, and, in England, Working Together to Safeguard Children 2026 expects organisations working with children, charities among them, to have "a senior board level lead".

By ComplyChatPublished 13 minute read

The lead safeguarding trustee of a youth circus charity talks with the charity’s safeguarding officer at the edge of its training hall, teenagers practising on aerial silks out of focus high behind them

The role is a governance role, not a second safeguarding lead. Its value is that one trustee knows the subject well enough to ask the right questions, and makes sure every other member of the board understands safeguarding too. This guide covers what the role is for, what it does and does not include, how to appoint and support the trustee, and the record that shows the board's oversight was real.

01

The rule: every trustee is responsible, and one leads

The Charity Commission's guidance Safeguarding and protecting people for charities and trustees makes safeguarding a duty of the whole board: "As part of fulfilling your trustee duties, whether working online or in person, you must take reasonable steps to protect from harm people who come into contact with your charity." It covers "people who benefit from your charity's work", staff, volunteers and others who come into contact with the charity through its work, not only children and adults at risk of abuse or neglect. In that guidance "must" means "a legal or regulatory requirement or duty that trustees must comply with". The Commission adds that "Every trustee should have clear oversight of how safeguarding and protecting people from harm are managed within their charity", and that the charity should have "a balanced trustee board" that "does not let one trustee dominate its work".

No statute creates a post called safeguarding trustee. The role comes from good practice and, for charities working with children in England, from statutory guidance. Paragraph 259 of Working Together to Safeguard Children 2026 lists the arrangements that organisations under the section 11 duty of the Children Act 2004 should have in place, including "a senior board level lead with the required knowledge, skills, and expertise or sufficiently qualified and experienced to take leadership responsibility for the organisation's or agency's safeguarding arrangements" and, separately, "a designated practitioner" for child safeguarding. Paragraph 359 then says: "Every VCSE, faith-based organisation and private sector organisation or agency should have in place the arrangements described in this chapter." NSPCC Learning's guidance for charity trustees puts the general position in one line: "It's best practice to also have a trustee who is responsible for overseeing safeguarding and child protection."

Appointing a lead does not move the duty. The Commission's The essential trustee (CC3) says trustees "cannot delegate their overall responsibility" and "always remain collectively responsible for all decisions that are made and actions that are taken with their authority". The lead trustee helps the board discharge a duty it still holds.

02

The safeguarding trustee and the safeguarding lead are different jobs

Most confusion about the role comes from mixing it up with the operational one. The Commission expects a charity that works with children or adults at risk to "appoint a safeguarding lead to work with your local authority safeguarding partnerships or boards": the person who receives concerns, decides on referrals and keeps the safeguarding log. The lead trustee oversees how that is done. NCVO's guidance on the responsibilities of a lead trustee for safeguarding says boards should "distinguish between the strategic, advisory and governance role of a lead trustee and the day-to-day operational designated safeguarding lead", which is "especially important – and may be a statutory requirement – where you work with children and adults at risk".

  • The safeguarding lead (often called the designated safeguarding lead) is operational: receives concerns, makes child protection and adult safeguarding referrals to children's or adults' social care, the police or the local authority designated officer, keeps case records, advises staff and volunteers, and arranges training.
  • The lead trustee for safeguarding is strategic: makes sure the board receives and understands safeguarding reports, checks that policy, training, vetting and risk management work in practice, challenges the executive, oversees allegations against staff and volunteers alongside the chief executive and safeguarding lead, and is a route for anyone who thinks a concern has not been acted on.
  • The board decides: approves the policy, owns the risk register, decides whether a serious incident is reported to the Commission, and answers for all of it.

In a very small charity with no staff, one trustee may also be the safeguarding lead, because there is nobody else. That is lawful, but it removes the independent check, so the board should say so in the policy, name a second trustee to whom concerns about the lead can go, and look harder at the reports. NCVO adds a warning that applies at every size: "If you appoint a lead trustee, it should be clear that they are not to be the only person among the trustees who understands safeguarding."

03

What the lead trustee for safeguarding does

NCVO groups the lead trustee's work into three sets of duties: strategic, effective policy and practice, and creating the right culture. Read with the Commission's list of what trustees can use for assurance, a workable role description covers:

  1. Strategy and risk. Checking that the charity's plans reflect the safeguarding legislation, regulations and statutory guidance that apply to its activities, and that the risk register sets out safeguarding risks and how they are managed. The Commission expects each charity to keep "a risk register which is regularly reviewed".
  2. Reports to the board. Making sure safeguarding is "a standing agenda item" (one of the Commission's suggested checks), that the safeguarding lead's report gives numbers and themes as well as reassurance, and that trustees ask questions about it. The Commission asks trustees to "monitor your performance, not just using statistics, but with supporting information, such as qualitative reports".
  3. Policy and review. Making sure the policy and procedures are reviewed "always following a serious incident and at least once a year", that the review is reported to the board, and that templates fit the charity.
  4. Checking practice. Visiting activities, speaking to staff, volunteers and beneficiaries about how they would raise a concern, and "reviewing a sample of past concerns to identify any lessons to be learnt and make sure they were handled appropriately", in the Commission's words.
  5. Allegations and escalation. Overseeing allegations against staff or volunteers with the chief executive and safeguarding lead, and being the named point of contact for anyone who thinks a concern has not been acted on – including a concern about the chief executive or the safeguarding lead.
  6. Serious incidents. Making sure the board decides promptly whether an incident is reportable to the Commission, and that other reports (local authority, police, DBS, other regulators) have been made by the right person.
  7. Safer recruitment, vetting and training. Checking that recruitment includes references and interviews, that the charity knows which roles are eligible for which DBS checks, that trustees as well as staff and volunteers are trained, and that the training is evaluated rather than only recorded.
  8. Culture. Championing safeguarding, and gathering what staff, volunteers and beneficiaries say about it so the board hears it unfiltered.

What the role does not include matters as much. The lead trustee does not take referrals, interview children or investigate allegations, and should not become the person staff go to instead of the safeguarding lead. A trustee who does the operational work cannot also check it.

04

Appointing, supporting and checking the trustee

The board appoints the lead trustee by resolution, minuted, against a written role description. NCVO says it is good practice for the role to be "described in writing, agreed by the Board and reviewed regularly", including "the scope of any formal decision making authority delegated to them and how they should report to the Board". CC3 says the same of any delegation: trustees "should set out in writing the limits of any delegated authority" and "put clear reporting procedures in place".

The trustee needs knowledge, not a qualification. Working Together asks for "the required knowledge, skills, and expertise" or someone "sufficiently qualified and experienced"; NCVO notes the lead trustee may be "a volunteer who starts without knowledge, but is willing to undertake the necessary training". The chair's part, in NCVO's words, is to make sure the lead trustee "either has the required knowledge, skills, and experience or is supported to develop these", with regular meetings between the lead trustee, the chief executive and the safeguarding lead, and enough time at board meetings for a full report.

Checks apply to the lead trustee as to any trustee. CC3 says that if "you are a trustee of a charity that provides 'regulated activity' for children or adults, you should expect your charity to request an enhanced DBS check on you", including a barred list check where the role is eligible. Every trustee must also not be disqualified from acting, and the Commission's guidance covers the checks to make.

Finally, avoid making the role a single point of failure. Name a deputy or second trustee, rotate the role at an agreed interval so the knowledge spreads, and make sure that safeguarding training for the whole board is booked, not only for the lead. The Commission expects charities to have "trained staff/volunteers/trustees".

A trustee of a homelessness charity walks with the night shelter coordinator between camp beds being made up in a church nave at dusk, a volunteer unfolding blankets beyond them
05

The board's record of safeguarding oversight

When something goes wrong, the Commission's question is how the trustees acted, and it "can hold trustees to account if things go wrong and can check that trustees followed this guidance and the law". The answer is in the board's own papers, which are different from the operational safeguarding log. The lead trustee should make sure these exist:

  • The appointment: the minute appointing the lead trustee, the role description, and its review date.
  • The standing item: at each board meeting, the safeguarding report received, the questions trustees asked, the answers and any actions, minuted rather than "report noted".
  • The annual review: the minute approving the reviewed policy and procedures, with the date, and any review after a serious incident.
  • Visits and sampling: a short note of each visit, conversation or case sample the lead trustee carried out, and what it found.
  • Serious incident decisions: every incident considered, whether it was reported to the Commission and why. The Commission's serious incident guidance says decisions made by others "should be reported back to trustees (particularly where incidents were 'borderline' and making a report was considered but it was decided not to make one)".
  • Trustee checks and training: DBS checks where eligible, disqualification declarations and trustees' safeguarding training, with dates. Our guide to safeguarding training records covers what to keep.
  • The risk register entries for safeguarding, with the date each was last reviewed by the board.

Two dates sit behind all of this. The Commission says a serious incident should be reported "promptly", meaning "as soon as is reasonably possible after it happens, or immediately after your charity becomes aware of it". And a charity with income over £25,000 must sign a declaration in its annual return "confirming there were no serious incidents during the previous financial year that should have been reported to the Commission but were not"; the guidance notes that giving false or misleading information to the Commission is an offence under section 60 of the Charities Act 2011. A board that cannot show when it learned of an incident cannot show it reported promptly.

06

The oversight that happens by text

Most of a lead trustee's real work is not at board meetings. The safeguarding lead texts on a Sunday afternoon: "FYI – disclosure at the youth session yesterday, referred to children's services, will update." A volunteer who is uneasy about a session leader messages the lead trustee directly, because the role description says they can. The chair and the lead trustee agree in a two-person chat that an allegation against a volunteer is "probably borderline" for the Commission and that they will wait for the local authority. Each of those is the board's oversight happening, and each is on a trustee's personal phone.

Then the board's record has a gap where the decisions were. The minute of the next meeting says the board "noted" the safeguarding report; the decision not to report the incident to the Commission, which the guidance expects to be reported back to trustees, exists only as a message. If the Commission, the local authority or a later review asks when the trustees first knew and what they decided, the charity has to ask two volunteers to search their phones, and a trustee who has stepped down takes the messages with them.

The answer is partly discipline: anything decided between meetings goes into a short written note to the board and the next minutes. It is also about where the conversation happens. Messages between the lead trustee, the chair and the safeguarding lead belong in a channel the charity controls, with everyone in it told it is on the record and access limited to those who need to know – not in a group with the whole board, and never as a substitute for the safeguarding procedure or an urgent phone call. ComplyChat is designed for that: trustees and volunteers without a charity account join with a mobile number verified by SMS, messages are recorded on the server as they are sent, and on paid plans the lasting record files into the charity's own Microsoft 365 once its tenant is connected. It is not a safeguarding log or a case management system.

A question for the next board meeting: if the Commission asked how the trustees reached their last decision not to report an incident, would the answer be in the minutes, or in a chat between two trustees?

07

Questions people ask

What does a safeguarding trustee do?

A safeguarding trustee leads the board's oversight of safeguarding: making sure the board receives and challenges safeguarding reports, that policies are reviewed at least once a year and after a serious incident, that risks are on the risk register, that allegations and serious incidents are handled and reported properly, and that people can escalate a concern that has not been acted on. The operational safeguarding lead, not the trustee, handles individual concerns and referrals.

Do trustees need safeguarding training?

Yes, in proportion to the charity's work. The Charity Commission expects every charity to have "enough resources, including trained staff/volunteers/trustees for safeguarding" and suggests "setting training plans for trustees, staff and volunteers", and NSPCC Learning says "Trustees need training to ensure they understand their safeguarding and child protection responsibilities". The lead trustee usually needs more than the rest of the board.

What qualifications does a safeguarding trustee need?

No formal qualification is required. Working Together to Safeguard Children 2026 asks for a board level lead "with the required knowledge, skills, and expertise or sufficiently qualified and experienced" to lead the organisation's safeguarding arrangements, and NCVO's guidance accepts a trustee who starts without that knowledge but "is willing to undertake the necessary training".

What are the roles and responsibilities of a trustee?

The Charity Commission's CC3 sets out six main duties: to ensure the charity is carrying out its purposes for the public benefit, comply with its governing document and the law, act in the charity's best interests, manage its resources responsibly, act with reasonable care and skill, and ensure it is accountable. Safeguarding sits within them, and our guide to charity trustee responsibilities covers each duty.

08

Official guidance and your next step

The primary sources are the Charity Commission's Safeguarding and protecting people for charities and trustees (last updated 1 June 2022, with its ten safeguarding actions for trustee boards), its serious incident reporting guidance (last updated 16 January 2026) and CC3, and, for work with children in England, chapter 4 of Working Together to Safeguard Children 2026. NCVO's lead trustee guidance (last reviewed in December 2018) and NSPCC Learning's pages for trustees are the most useful practical material. Quotations are from those pages as read on 3 October 2026. The Commission's guidance still links to the 2023 edition of Working Together; use the 2026 edition. Our guide to a charity safeguarding policy covers the policy itself.

This guide covers charities in England and Wales. Charities in Wales follow the Wales Safeguarding Procedures; in Scotland the Scottish Charity Regulator and in Northern Ireland the Charity Commission for Northern Ireland publish their own guidance. It is a practical summary, not legal advice.

Then do one thing: write the lead trustee's role description on one page – the eight duties above, the limits of any delegated authority, and how the trustee reports to the board – and bring it to the next meeting for approval and a minute.

Why we publish this

We build ComplyChat for the work conversations organisations need to keep. A lead safeguarding trustee is usually a volunteer with a day job, and much of the oversight the Commission asks about happens in messages between meetings. The organisational record described here is on paid plans; Free is personal messaging with one private group, direct messages and three calendar months of recent history, and it is not a way to meet a retention duty.

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Sources

Every document this guide quotes or links to, in the order it first cites them.

  1. Safeguarding and protecting people for charities and trustees gov.uk
  2. Working Together to Safeguard Children 2026 gov.uk
  3. Charity trustees learning.nspcc.org.uk
  4. The essential trustee (CC3) gov.uk
  5. Responsibilities of a lead trustee for safeguarding ncvo.org.uk
  6. Serious incident guidance gov.uk