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Club Policies

The Adult price for each area of the ground is the full price for admission.

Concessionary prices are offered in all areas of the ground and these are in fact discounts on the full admission price.

In regards to the date for purchasing Season Tickets the date for determining age categories will be the 1st September in the season in which the Season Ticket will operate.

In regards to the date for purchasing individual match tickets either on or before the day of the game, or for cash admissions on the day, your age on the day of the game will determine which age category that you come under.

AGE CATEGORIES * There will be two categories of junior supporters

Junior* 2 and Under
Junior* 16 and Under
Young Persons 21 and Under
Adults 22 to 65
Senior Over 65

Where the club offers a concessionary price, the club reserves the right to request proof of age and it is the responsibility of the person claiming the concessionary price to provide the required proof, if adequate proof is not provided when requested the full admission price will be charged.

Photographic ID, which contains the Date of Birth (example: Passport – Driving License) is required for all Young Persons and a ticket must be purchased from the ticket office.

Rochdale AFC strongly recommends that anyone who may appear to look older than they actually are carries photographic ID, which also contains their date of birth in order to claim a discount, this advice is particularly relevant to ALL TEENAGERS.

The majority of matches at the Crown Oil Arena are a mixture of ticket and cash admissions. Separate turnstiles apply to Adults, Concessions and Juniors but the club recognises that some adults may wish to have their children go through the same turnstile, to accommodate this club requests that the adult purchases a ticket for their child from the ticket office.

Disabled concessionary prices are only available to disabled supporters who are in need of the use of a wheelchair and these concessionary prices are only available in the wheelchair bays. The club reserves the right to request proof of disability and if requested it the responsibility of the disabled person to provide the required proof, if adequate proof is not provided when requested the full admission price will be charged.

Persons requiring a full time carer to accompany them to the match can get a carer ticket, which is free of charge. A carer ticket will only be issued if the person can show evidence of full time carer status, we will also accept a letter showing that disability allowance is in the middle or higher band.

Updated July 2017

Rochdale AFC works across the borough of Rochdale to be inclusive and anti-discriminatory and works closely with the EFL, The FA and Kick it Out.

Football Clubs should be accessible to everyone and so it is important that the right culture is promoted. Rochdale AFC want to ensure that the Club is a place that is child and family friendly, free from discrimination and unfair behaviour and will do everything they can in-order to achieve these objectives.

Rochdale AFC is currently looking to achieve the required standard for the ELF's Inclusion and Anti-Discrimination Code of Practice and undergoing a complete review of all areas of its business.

Rochdale AFC is committed to promoting equality by treating people fairly and with respect; by recognising inequalities exist, by taking steps to address them and by providing access and opportunities for all members of the community. It is about changing the culture and structure of our Football Club to ensure it becomes equally accessible to everyone in society.

Rochdale AFC's commitment is to eliminate discrimination on the basis of gender, sexual orientation, marital or civil partnership status, gender reassignment, race (ethnic or national origin) pregnancy or maternity, religion or belief, disability or age (the protected characteristics). We will ensure that we treat people fairly and with respect and that we will provide access and opportunities for all members of the community to take part in, and enjoy our activities.

Rochdale AFC will not tolerate harassment, bullying, abuse or victimisation of any individual, which for the purposes of this statement and the actions and sanctions applicable is regarded as discrimination, whether physical or verbal. This includes any form of 'Hate Crime' which is a crime targeted at a person because of hostility or prejudice towards that person's disability, race or ethnicity, religion or belief, sexual orientation or transgender identity. The Club will work to ensure that such behaviour is met with the appropriate action in whatever context it occurs including inappropriate posts through social media.

Rochdale AFC is committed to promoting equality of opportunity for all staff and job applicants and requires all staff to abide and adhere to the equality legislation, Equality Act 2010, as well as any amendments to this act.

Rochdale AFC commits itself to the immediate investigation of any claims, when it is brought to their attention, of discrimination on the above grounds and where such is found to be the case, a requirement that the practice stop and sanctions imposed as appropriate.

The content of this statement applies equally to the treatment of our staff, customers, supporters, clients and suppliers and is fully supported by the Board of Rochdale AFC.

If you have a complaint or witness an incident of discrimination, harassment or bullying we would ask you to report it direct to David Bottomley, Rochdale AFC CEO & Club Equality Champion and Kick it Out.


The English Football League is responsible for setting the standards, values and expectations of all Clubs in relation to equality, inclusion and diversity. Football is for everyone; it belongs to, and should be enjoyed by anyone who wants to participate in it, whether as a player, official, staff member or spectator.

The aim of Rochdale AFC Equality Policy is to promote our own equality objectives and in doing so, help to ensure that everyone is treated fairly and with respect. All Rochdale AFC representatives should abide and adhere to this Policy and to the requirements of the Equality Act 2010. In doing so, we are working towards being legally compliant in relation to equality legislation.

Rochdale AFC commitment is to promote inclusion and to confront and eliminate discrimination whether by reason of age, gender, gender reassignment, sexual orientation, marital status or civil partnership race, nationality, ethnicity (race), religion or belief, ability or disability, pregnancy and maternity and to encourage equal opportunities. These are known as ‘protected characteristics’ under the Equality Act 2010.

This Policy is fully supported by the Board of Rochdale AFC and David Bottomley CEO is responsible for the implementation of this policy.

Rochdale AFC will ensure that it treats everyone fairly and with respect and that it will provide access and opportunities for all members of the community to take part in, and enjoy, its activities. Every staff member, Board member, official, spectator, fan and visiting teams an be assured of an environment in which their rights, dignity and individual worth are respected, and in particular that they are able to work and watch football in an environment without the threat of intimidation, victimisation, harassment or abuse.

Complaints and compliance
Rochdale AFC regards all of the forms of discriminatory behaviour, including (but not limited to) behaviour described in the Appendix as unacceptable, and is concerned to ensure that individuals feel able to raise any bona fide grievance or complaint related to such behaviour without fear of being penalised for doing so. Appropriate disciplinary action will be taken against any employee, member or volunteer, spectator or fan who is found, after a full investigation, to have violated the Equality Policy.

Positive Action and Training
Rochdale AFC is committed to equality inclusion and anti-discrimination as part of The Football League’s Code of Practice. Rochdale AFC will commit to a programme of raising awareness and educating, investigating concerns and applying relevant and proportionate sanctions, campaigning, widening diversity and representation and promoting diverse role models, which we believe are all key actions to promote inclusion and eradicate discrimination within football. This Equality Policy will be reviewed and updated, if required, on an annual basis.

APPENDIX – Relevant legislation and forms of unacceptable discrimination

Legal rights
Discrimination has been legally defined through a series of legislative acts, including the Race Relations Act, the Sex Discrimination Act, the Disability Discrimination Act and the Equality Act 2006.

In April 2010, the Equality Act 2010 received Royal Assent. The Equality Act 2010 is a new law which harmonises where possible, and in some cases extends, protection from discrimination. It applies throughout the UK and came into force in October 2010.

Discrimination refers to unfavourable treatment on the basis of particular characteristics, which are known as the ‘protected characteristics’.

Under the Equality Act 2010, the protected characteristics are defined as age (employment only until 2012), disability, gender reassignment, marital or civil partnership status (employment only), pregnancy and maternity, race (which includes ethnic or national origin, colour or nationality), religion or belief, sex (gender) and sexual orientation.

Under the Equality Act 2010, individuals are protected from discrimination ‘on grounds of’ a protected characteristic . This means that individuals will be protected if they have a characteristic, are assumed to have it, associate with someone who has it or with someone who is assumed to have it.

Forms of discrimination and discriminatory behaviour include the following:

Direct discrimination
Direct discrimination can be described as less favourable treatment on the grounds of one of the protected characteristics.

Indirect discrimination
Indirect discrimination occurs when a provision, criterion or practice is applied to an individual or group that would put persons of a particular characteristic at a particular disadvantage compared with other persons.

Discrimination arising from disability
When a disabled person is treated unfavourably because of something connected with their disability and this unfavourable treatment cannot be justified, this is unlawful. This type of discrimination only relates to disability.

Harassment is defined as unwanted conduct relating to a protected characteristic that has the purpose or effect of violating a person’s dignity, or which creates an intimidating or hostile, degrading, humiliating or offensive environment for that person.

It is unlawful to treat a person less favourably because he or she has made allegations or brought proceedings under the anti-discrimination legislation, or because they have helped another person to do so. To do so would constitute victimisation.

Bullying is defined as a form of personal harassment involving the misuse of power, influence or position to persistently criticise, humiliate or undermine an individual.

Notice: Entry to the Ground is expressly subject to acceptance by the visitor of these Ground Regulations and the rules and regulations of FIFA, UEFA, The Football Association, The Premier League and The English Football League (EFL) in respect of the relevant competition. The Ground Regulations incorporate the Club’s Customer Charter (if any). Entry to the Ground shall constitute acceptance of the Ground Regulations.

“Ground” means this football stadium and all locations owned, occupied or utilised by the Club.

“Club” means this football club.

“Match” means any association football match (or any part or aspect of such a match) taking place at the Ground.

“Material” means any audio, visual and/or audio-visual material and/or any information or data.

“Football Authority” means each of The English Football League (EFL) League, The Premier League, The Football Association, the Football Association of Wales, FIFA, UEFA and any other relevant governing body of association football.

1. Notwithstanding possession of any ticket the Club, any police officer or authorised steward may refuse entry to (or eject from) the Ground any person:

1.1. that fails (or in the Club’s reasonable opinion is likely to fail) to comply with these Ground Regulations or any reasonable instruction issued by a police officer or authorised steward or officer of the Club; and/or

1.2. whose presence within the Ground is, or could (in the Club’s reasonable opinion), constitute a source of danger, nuisance or annoyance to any other person.

2. On no account will admission be granted to a person who is the subject of a current Banning Order under the Football Spectators Act 1989 (as amended) or has been convicted of ticket touting offences under the Criminal Justice and Public Order 1994 (as amended).

3. The Club excludes to the maximum extent permitted by law any liability for loss, injury or damage to persons/property in or around the Ground.

4. No guarantees can be given by the Club that a Match will take place at a particular time or on a particular date and the Club reserves the right to reschedule the Match without notice and without any liability whatsoever, save only to the extent provided pursuant to paragraph 5.

5. In the event of the postponement or abandonment of the Match, refunds (if any) will be made in accordance with the Club’s Customer Charter. The Club will have no further liability whatsoever, including (but not limited to) any indirect or consequential loss or damage, such as (but not limited to) loss of enjoyment or travel costs.

6. All persons seeking entrance to the Ground acknowledge the Club’s right to search any person entering the Ground and to refuse entry to or eject from the Ground any person refusing to submit to such a search.

7. The following articles must not be brought within the Ground - knives, fireworks, smoke canisters, air-horns, flares, weapons, dangerous or hazardous items, laser devices, bottles, glass vessels, cans, poles and any article that might be used as a weapon and/or compromise public safety. Any person in possession of such items will be refused entry to the Ground.

8. Further, you may not bring into the Ground:

8.1. any sponsorship, promotional or marketing materials save in respect of official club merchandise and/or other football related clothing worn in good faith;

8.2. any flags or banners larger than those maximum dimensions permitted by the Club from time to time (or, in the absence of such stipulations, 2 metres x 1 metre) and/or of an offensive nature;

8.3. nor may you offer (either free or for sale by any person) any goods(including literature) of any nature,

Without the express written approval of Club’s Management.

9. The use of threatening behaviour, foul or abusive language is strictly forbidden and will result in arrest and/or ejection from the Ground. The Club may impose a ban for one or more Matches.

10. Racial, homophobic or discriminatory abuse, chanting or harassment is strictly forbidden and will result in arrest and/or ejection from the Ground. The Club may impose a ban for one or more Matches.

11. The following acts are offences under the Football (Offences) Act 1991 (as amended):

11.1 The throwing of any object within the Ground without lawful authority or excuse.

11.2 The chanting of anything of an indecent or racialist nature.

11.3 The entry onto the playing area or any adjacent area to which spectators are not generally admitted without lawful authority or excuse.

Conviction may result in a Banning Order being made.

12. All persons entering the Ground may only occupy the seat allocated to them by their ticket and must not move from any one part of the Ground to another without the express permission or instruction of any steward, officer of the Club and/or any police officer.

13. Nobody may stand in any seating area whilst play is in progress. Persistent standing in seated areas whilst play is in progress is strictly forbidden and may result in ejection from the Ground.

14. The obstruction of gangways, access ways, exits and entrances, stairways and like places is strictly forbidden. Nobody entering the Ground shall be permitted to climb any structures within the Ground.

15. EFL stadia are smoke-free and smoking is not permitted inside the Ground.

16. Mobile telephones and other mobile devices are permitted within the Ground PROVIDED THAT (i) they are used for personal and private use only (which, for the avoidance of doubt and by way of example only, shall not include the capturing, logging, recording, transmitting, playing, issuing, showing, or any other communication of any Material for any commercial purposes); and (ii) no Material that is captured, logged, recorded, transmitted, played, issued, shown or otherwise communicated by a mobile telephone or other mobile device may be published or otherwise made available to any third parties including, without limitation, via social networking sites.

17. Under the Sporting Events (Control of Alcohol etc.) Act 1985 (as amended), the following are offences for which a person can be arrested by a police officer and conviction could result in a Banning Order being made:

17.1 Attempting to enter the Ground or being inside the Ground whilst drunk;

17.2 Being in possession of any intoxicating liquor, or bottle, can or other portable container and which could cause damage or personal injury, when entering the Ground or in a public area of the Ground from which the event can be directly viewed.

18. Any individual who has entered any part of the Ground designated for the use of any group of supporters to which he does not belong may be ejected from the Ground either for the purposes of his own safety or for any other reason.

19. Save as set out in paragraph 16 above, no person (other than a person who holds an appropriate licence) may capture, log, record, transmit, play, issue, show or otherwise communicate (by digital or other means) any Material in relation to the Match, any players or other persons present in the Ground and/or the Ground, nor may they bring into the Ground or use within the Ground (or provide to, facilitate or otherwise assist another person to use within the Ground) any equipment or technology which is capable of capturing, logging, recording, transmitting, playing, issuing, showing or otherwise communicating (by digital or other means) any such Material.

20. The copyright, database rights and any other intellectual property rights in and to all Material that you produce at the Ground in relation to the Match, any players or other persons present in the Ground and/or the Ground (whether produced in breach of paragraph 19 above, or pursuant to paragraph 16 above, or otherwise) is hereby assigned (including by way of present assignment of future copyright pursuant to section 91 of the Copyright, Designs and Patents Act 1988) to the Club and the EFL. You further agree (if and whenever required to do so by the Club and/ or the EFL) to promptly execute all instruments and do all things necessary to vest the right, title and interest in such rights to the Club and the EFL absolutely and with full title guarantee.

21. No goods (including literature) of any nature may be offered either free or for sale by any person within the Ground without the express written permission of the Club.

22. Tickets are not transferable and may not be offered for sale without the prior written permission of the Club or otherwise in accordance with the relevant ticket terms and conditions. Any tickets that are transferred are transferred subject to these Ground Regulations. Any tickets offered for sale may be confiscated by any steward, officer of the Club or any police officer. The Club reserves the right to refuse admission to or eject from the Ground, and/or “blacklist”, any person who has offered for sale or transferred his/her ticket in contravention of the relevant ticket terms and conditions (and/or the holder of any ticket that has been transferred in contravention of the relevant ticket terms and conditions). Tickets remain the property of the Club at all times.

23. CCTV cameras are in use around and in the Ground. Body worn video cameras recording video and/or audio may also be used as appropriate, to record images or audio which identifies you as an individual, for example to record prohibited behaviours as referenced in paragraphs 9 and 10. The Club may itself use or pass to the police or any Football Authority or other clubs, any recordings for use in any proceedings.

24. At all times whilst present in the Ground, persons must comply with any and all instructions of any steward or officer of the Club and/or any police officer. Failure to comply with any instruction may lead to immediate ejection from the Ground.

25. By entering the Ground, all persons are acknowledging that photographic images and/or audio, visual and/or audio-visual recordings and/or feeds (and/or stills taken therefrom ) may be taken of them and may also be used, by way of example and without limitation, in televised coverage of the game and/or for promotional, training, editorial or marketing purposes by the Club, the EFL or others (including commercial partners and accredited media organisations) and entry into the Ground constitutes consent to such use. You further acknowledge that photographic images and/or audio, visual and/or audio-visual recordings and/or feeds (and/or stills taken therefrom) may be used (by the Club or by a third party, such as a law enforcement body) to identify you as an individual, where permitted by data protection laws, for the purposes of preventing or detecting crime, or any breach of these Ground Regulations. Information about the Club’s use of your personal data will be brought to your attention by the Club (see for example any applicable privacy policy, signage and/or other forms of announcement in or around the ground). For further information please contact the Club.

26. All ticket holders agree that the Matches for which the tickets have been purchased are public, and that their appearance and actions inside and in the perimeter of the Ground where a Match occurs are public in nature, and that they shall have no expectation of privacy with regard to their actions or conduct at Matches.

27. Further to paragraph 25, if such person is under 18 years of age, the parent, guardian, or responsible adult who is accompanying them into the Ground shall be deemed to have provided consent on their behalf.

28. Refused entry to (or ejection from) the Ground may lead to further action by the Club including, but not limited to, the withdrawal of any season ticket (without reimbursement), Club Membership and other benefits.

Published by the EFL – Season 2018/19

Rochdale Association Football Club

Safeguarding Policy (Updated September 2020) 



Rochdale Football Club will appoint a Senior Safeguarding Officer who will be a member of the Board, together with a Designated Safeguarding Officer to support having in place arrangements that reflect the importance of safeguarding and promoting the welfare of children. (See App B)

All Rochdale AFC Departments which make provision for children, young people and vulnerable adults must ensure that:


  • The welfare of the child or vulnerable adult is paramount. The policy recognises that the welfare and interests of children and vulnerable adults are paramount in all circumstances. It aims to ensure that regardless of age, ability or disability, gender reassignment, race, religion or belief, sex or sexual orientation, socio-economic background, all children and vulnerable adults
  • have a positive and enjoyable experience of sport at Rochdale AFC in a safe environment
  • are protected from abuse whilst participating in the activity provided by Rochdale AFC or outside of the activity.
  • All children and vulnerable adults, whatever their age, ability or disability, gender reassignment, race, religion or belief, sex or sexual orientation, socio-economic background have the right to protection from abuse
  • All suspicions and allegations of abuse will be taken seriously and responded to swiftly and appropriately
  • All staff (paid/unpaid) working at Rochdale Association Football Club have a responsibility to report concerns to the appropriate officer.

Staff/volunteers are not trained to deal with situations of abuse nor decide if abuse has occurred.


Policy Statement

Rochdale Association Football Club has a duty of care to safeguard all children and vulnerable adults involved from harm. All children and vulnerable adults have a right to protection, and the needs of disabled children and others who may be particularly vulnerable must be taken into account. Rochdale Association Football Club will ensure the safety and protection of all children involved through adherence to the following Child Protection and Vulnerable Adults guidelines.

A child is defined as under 18 – The Children’s Act 1989 and The Children Act 2004.


The core definition of “vulnerable adult” from the 1997 Consultation “Who Decides?” issued by the Lord Chancellor’s Department, is a person:
“Who is or may be in need of community care services by reason of disability, age or illness; and is or may be unable to take care of unable to protect him or herself against significant harm or exploitation”.  This definition of an Adult covers all people over 18 years of age.


Anti-Radicalisation Policy Statement

Radicalisation is a form of grooming or exploitation whereby people come to support forms of extremism and extremist ideology which in some cases leads to participation in terrorist groups and activities. There is no clear profile of who is likely to become radicalised however staff should be aware of changes in behaviours which may indicate help or protection is needed and have a general understanding of some key indicators which may make an individual more susceptible to exploitation and which for example may include:

  • Identity or personal crisis
  • Unemployment/ underemployment
  • Underachievement
  • Isolation / exclusion


These factors would be considered in conjunction with the circumstances of an individual rather than individually. Many of our staff have completed the Channel Training module which is part of the Government’s PREVENT strategy.


Rochdale AFC is fully committed to safeguarding and promoting the welfare of all its pupils. As a school we recognise that safeguarding against radicalisation is no different from safeguarding against any other vulnerability. At Rochdale Development Centre all staff are expected to uphold and promote the fundamental principles of British values, including democracy, the rule of law, individual liberty and mutual respect, and tolerance of those with different faiths and beliefs.


Policy Aims

The aim of Rochdale Association Football Club Safeguarding Policy is to promote good practice:

  • Providing children, young people and vulnerable adults with appropriate safety and protection whilst in the care of Rochdale Association Football Club
  • Allow all staff/volunteers to make informed and confident responses to specific protection issues.


Promoting Good Practice with Young People and Vulnerable Adults


Abuse, particularly sexual abuse, can arouse strong emotions in those facing such a situation. It is important to understand these feelings and not allow them to interfere with your judgement about any action to take. Abuse can occur within many situations including the home, school and the sporting environment. Some individuals will actively seek employment or voluntary work with young people and vulnerable adults in order to harm them. A coach, instructor, teacher, official or volunteer may have regular contact with young people and vulnerable adults and can be an important link in identifying cases where a young person or vulnerable adult needs protection. All suspicious cases of poor practice should be reported following the guidelines in this document. When a child or vulnerable adults enters the club having been subjected to abuse outside the sporting environment, sport can play a crucial role in improving self esteem. In such instances the club must work with the appropriate agencies to ensure the child or vulnerable adult receives the required support.

Specific Considerations for Vulnerable Adults

Individual rights

Every person has the right to a lifestyle which maintains personal independence, safeguards privacy, offers genuine and informed choices, provides opportunities to enjoy and contribute to society and enables them to have their social, cultural and individual needs met. They also have the right to protection from harm or exploitation.

Positive aspects of risk taking

The vast majority of vulnerable adults live active and independent lives.

This inevitably involves varying degrees of risk taking as a normal part of day to day living, and without which there would be a significant reduction in quality of life.

Risk taking therefore needs to be viewed positively in those circumstances where people can make reasonable, informed, and calculated decisions involving risk taking and safety.


Types of risk

There are many and varied circumstances in which vulnerable adults might be considered at risk requiring a response.

These fall into two broad categories:

  • People at risk because of self-neglect or because of their own behaviour or lifestyle.

Through direct contact with a vulnerable adult a member of staff or volunteer may become concerned about potential risk that may require action.

  • People at risk because of the actions or behaviours of others.


Risk arising from self-neglect or a person’s own behaviour or lifestyle.

A vulnerable person may require assessment or investigation from an appropriate agency (Health or Social Services) where:

  • They are unable to provide adequate care for themselves.
  • They are unable to obtain care necessary for their needs.
  • They are unable to make reasonable decisions because of their state of mental health.
  • They are living in insanitary/unsafe accommodation or are homeless.
  • They have refused essential services, without which their health and safety needs cannot

be met.

  • Their behaviour is such that it presents a real or potential threat of harm to their own

health, safety or well being or to that of others.


While many risk situations will come to attention through one significant incident that may involve immediate physical danger, equally serious situations develop more slowly through marginal changes or gradual deterioration in an individual’s circumstances which

can be more difficult to identify. For example, people suffering from dementia may need consideration due to the progressive nature of their condition.

The following are typical of some of the risk factors which might be identified:

  • Physical accidents including fire malnutrition, hypothermia, neglect, and alcohol or

drug misuse, including prescribed medication.

  • Mental health-depression, dementia, fears, guilt, paranoia, and suicidal tendencies.
  • Social-social isolation, exploitation, antagonism, marital difficulties, relationship

problems, sexual inhibition.

  • Psychological trauma arising from experience of abuse, serious accident or

sudden loss.


Risk arising from the behaviour of others.

A few vulnerable adults are at risk because of the actions or behaviours of other people, either intentionally or unintentionally.

The main categories of abuse are listed below, although this is not exhaustive.

Abuse exists in the context of the relationship and means that both the behaviour of the abuser and the effects on the abused come into the definition.


Physical abuse

Typical examples of physical abuse are slapping, hitting, physical restraint, over-use of medication, pushing, forcing people to do things against their will and depravation of care including food and medication.

Typical effects of the physical abuse are bruises, burns, fractures, pressure stores, malnutrition, or impaired health.

Examples of physical abuse that may occur in sport may include be when the nature and

intensity of training and competition exceeds the capacity of the athlete.

Psychological abuse

This can be referred to as emotional abuse, mental abuse, and verbal abuse.

Typical examples of behaviours are blame, insults, humiliation, swearing, threats, neglect and denying a person of the right to make their own decisions.

Typical effects are mental anguish, fear and depression.

Psychological abuse in sport may occur if athletes are subjected to constant criticism, name-calling, and sarcasm, bullying or unrealistic pressure to perform to high expectations.

Financial abuse

This is sometimes referred to as material abuse and financial exploitation.

Typical examples of behaviour are theft or misuse of property, possessions, and insurance, blocking the access of a person to their assets, and extortion.

Typical examples of effects are having inadequate money to pay bills including rent, having a “disappearing pension” and losing control of one’s financial affairs.


Sexual abuse

This can be any form of sexual exploitation, ranging from the inappropriate use of sexually explicit language that causes offence to forced penetration and includes the involvement of adults in sexual activities they do not fully comprehend or to which they have not given

their consent or which violates the sexual taboos or family roles.

Typical examples of effects are emotional distress, feelings of guilt or shame and withdrawn behaviour.


Social abuse

Typical examples of behaviour are confining a person to a room on their own, preventing them from seeing friends or relatives or having other social contact, denying access to services and refusal of transportation.

Typical examples of effects are withdrawn behaviour, prolonged loneliness, sense of isolation and depression.


Further circumstances where abuse may be prevalent


There are many additional categories linked with abuse. The list is not exhaustive. Further information will be found in Local Safeguarding Partnership Guidelines and Keeping Children Safe in Education 2018, but below is an outline of some of the specific categories.


Child Sexual Exploitation involves exploitative situations, contexts, and relationships where young people may receive something such as gifts, food, accommodation, drugs, alcohol, even affection in return for engaging in sexual activities. The perpetrator will groom the victim over a pro-longed period and exert power which increases as the relationship develops. Sexual exploitation involves a degree of coercion, intimidation, enticement, cyberbullying, and grooming. Young people may be tricked into believing they are in a loving consensual relationship and do not necessarily see themselves as a victim and so do not always exhibit external signs of abuse.


Bullying is behaviour that is intended to hurt someone physically or emotionally. It is often persistent or repeated over a long period of time and is hostile and intimidating. It can be name-calling, isolation, and exclusion, pushing, spreading rumours, threatening behaviour, constant criticism and undermining. Indicators may include, physical injuries such as unexplained bruises, being afraid to go school, training sessions, matches, mysterious illnesses, a dip in performance, problems eating or sleeping, loss of confidence, withdrawal.


Grooming is when someone builds an emotional or transactional connection with a child to gain their trust for the purpose of sexual abuse or criminal exploitation. Children can be groomed on-line or by a stranger or someone they know, for example a family member friend or professional. Groomers can ‘groom’ family members to gain access to a child. They can be male or female or any age. Many children, young people do not understand they have been groomed or that it is abuse and so do not recognise themselves as being a victim.


Radicalisation is a form of grooming or exploitation whereby people come to support forms of extremism and extremist ideology which in some cases leads to participation in terrorist groups and activities. There is no clear profile of who is likely to become radicalised however staff should be aware of changes in behaviours which may indicate help or protection is needed and have a general understanding of some key indicators which may make an individual more susceptible to exploitation and which for example may include:

  • Identity or personal crisis
  • Unemployment/ underemployment
  • Underachievement
  • Isolation / exclusion


These factors would be considered in conjunction with the circumstances of an individual rather than individually. Many of our staff have completed the Channel Training module which is part of the Government’s PREVENT strategy.


Modern Slavery and Trafficking encompasses human trafficking, slavery, forced labour and domestic servitude. Victims can be coerced, deceived, forced into a life of abuse and inhumane treatment. Section 52 of the Modern Slavery Act 2015 places a duty on public authorities to notify the National Crime Agency if there are signs or intelligence has been received or there are reasonable grounds to believe there is an indication that a person may be a victim of slavery or human trafficking.


Female Genital Mutilation (FGM) is a form of child abuse which involves intentionally altering or injuring female genital organs for non-medical reasons and is illegal in this country (Female Genital Mutilation Act 2003). It is also illegal to take girls who are British Nationals or permanent residents of the UK abroad for FGM whether or not it is lawful in another country. Staff need to be alert to the possibility of when a female may be at risk of FGM or if it has happened. There is a statutory duty to report these cases the police. It is for the police to investigate the circumstances and to conduct enquiries into any alleged offence.


Forced Marriage - There is a clear difference between a forced marriage and an arranged marriage. In arranged marriages the families of both spouses take a leading role in arranging the marriage but the choice of whether to accept the arrangement remains with the two people.

In a forced marriage, one or both spouses do not consent to the arrangement of the marriage and some elements of duress are involved. This can involve physical, psychological, financial, sexual and emotional pressure. Forced marriage is an abuse of human rights, and where a child is involved, an abuse of the rights of the child. Further information can be found at


Hate Crime is an incident of crime that is motivated by hostility or prejudice based on a victim’s disability, race, religion or belief, sexual orientation or transgender identity.


Peer on peer abuse - Children can abuse other children – generally referred to a peer on peer abuse. All staff should be aware that safeguarding issues can manifest themselves via peer on peer abuse. This can include, but is not limited to bullying (including cyberbullying), physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm, sexual violence and sexual harassment, sexting (also known as youth produced sexual imagery); and initiation/hazing type violence and rituals.

Hazing is any action or situation, with or without the consent of participants which recklessly intentionally or unintentionally endangers the mental, physical, or emotional wellbeing of a child or young person. It will not be tolerated. An example would be a group initiation ceremony where a child is forcibly encouraged to consume alcohol.


Domestic Violence is an important indication of risk at ham to children who may be affected directly or indirectly if they are connected to a household where there is domestic violence. It can have a damaging effect on health and development. Many of the signs will be those related to physical and emotional abuse.


Child Criminal Exploitation: county lines- criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity: drug networks or gangs groom and exploit children and young people to carry drugs and money from urban areas to suburban and rural areas, market and seaside towns. Key to identifying potential involvement are missing episodes when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism should be considered. Like other forms of abuse and exploitation, county lines exploitation:

  • Can affect any child or young person (male or female) under the age of 18 years.
  • Can affect any adult at risk over the age of 18 years.
  • Can still be exploitation even if the activity appears consensual.
  • Can involve force and / or enticement-based methods of compliance and is often accompanied by violence or threats of violence
  • Can be perpetrated by individuals or groups, males or females, and young people or adults; and
  • Is typified by some form of power imbalance in favour of those perpetrating the exploitation. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, cognitive ability, physical strength, status, and access to economic or other resources.

Honour-based violence is an internationally recognised term used to describe cultural justifications for violence and abuse. It justifies the use of certain types of violence against children, women and men and crosses all communities, cultures, faith groups, nationalities transcending national and international boundaries. It is domestic abuse, child abuse and a crime. It encompasses incidents or crimes which have been committed to protect or defend the honour of the family and/or the community including female genital mutilation (FGM) forced marriage and practices such as breast ironing. Abuse committed in the context of preserving ‘honour’ often involves a wider network of family or community pressure and can include multiple perpetrators. It is important to be aware of this and the additional risk factors when deciding on what action to take.


Good Practice Guidelines


All personnel should be encouraged to demonstrate exemplary behaviour in order to protect themselves from false allegations. The following are common sense examples of how to create a positive culture and climate within Rochdale Association Football Club:


Good practice means:


  • Always working in an open environment (e.g. avoiding private or unobserved situations and encouraging an open environment i.e. no secrets).
  • Treating all young people/vulnerable adults equally, and with respect and dignity.
  • Always putting the welfare of each young person or vulnerable adults first, before winning or achieving goals.
  • Maintaining a safe and appropriate distance with children or vulnerable adult (e.g. it is not appropriate to have an intimate relationship with a child or to share a room with them).
  • Building balanced relationships based on mutual trust which empowers children or vulnerable adult to share in the decision-making process.
  • Playing sports fun, enjoyable and promoting fair play.
  • Ensuring that if any form of manual/physical support is required, it should be provided openly and according to guidelines provided by the Coach Education Programme. Care is needed, as it is difficult to maintain hand positions when the child or vulnerable adult is constantly moving. The Young Person or vulnerable adult should always be consulted, and their agreement gained. Some parents/carers are becoming increasingly sensitive about manual support and their views should always be carefully considered.
  • Keeping up to date with the technical skills, qualifications, and insurance in sport.
  • Involving parents/carers wherever possible (e.g. for the responsibility of their children in the changing rooms). If groups have to be supervised in the changing rooms, always ensure parents/teachers/coaches/officials work in pairs.
  • Ensuring that if mixed teams are taken away, they should always be accompanied by a male and female member of staff. (NB however, same gender abuse can also occur).
  • Ensuring that at tournament or residential events, adults should not enter children’s rooms or invite children into their rooms.
  • Being an excellent role model – this includes not smoking or drinking alcohol in the company of young people.
  • Giving enthusiastic and constructive feedback rather than negative criticism.
  • Recognising the developmental needs and capacity of young people and vulnerable adults – avoiding excessive training or competition and not pushing them against their will.
  • Securing parental consent in writing to act in loco parentis, if the need arises to give permission for the administration of emergency first aid and/or other medical treatment.
  • Keeping a written record of any injury that occurs, along with the details of any treatment given.
  • Requesting written parental/carer consent if club officials are required to transport young people and vulnerable adults in their cars.


Practice to be avoided


The following should be avoided except in emergencies. If cases arise where these situations are unavoidable, they should only occur with the full knowledge and consent of someone in charge in the club or the child’s parents. For example, a child sustains an injury and needs to go to hospital, or a parent fails to arrive to pick a child up at the end of a session:


  • Avoid spending excessive amounts of time alone with children and vulnerable adults away from others.
  • Avoid taking children and vulnerable adults to your home where they will be alone with you.
  • Desisting from any Social Media contact with children. (See Social Media Policy)


Practice never to be sanctioned


The following should never be sanctioned. You should never:


  • Engage in rough, physical, or sexually provocative games, including horseplay.
  • Share a room with a child or vulnerable adult.
  • Allow or engage in any form of inappropriate touching.
  • Allow children or vulnerable adults to use inappropriate language unchallenged.
  • Allow verbal bullying or derisory comments from one person to another.
  • Make sexually suggestive comments to a child or vulnerable adult, even in fun.
  • Reduce a child or vulnerable adult to tears as a form of
  • Allow allegations made by a child or vulnerable adult to go unchallenged, unrecorded, or not acted upon.
  • Do things of a personal nature for children or vulnerable adult, that they can do for themselves.
  • Invite or allow children or vulnerable adult to stay with you at your home unsupervised.


  1. It may sometimes be necessary for staff or volunteers to do things of a personal nature for children, particularly if they are young or disabled. These tasks should only be carried out with the full understanding and consent of parents/cares and the children and vulnerable adult involved. There is a need to be responsive to a person’s reactions. If a person is fully dependent on you, talk with him/her about what you are doing and give choices where possible. This is particularly so if you are involved in any dressing or undressing of outer clothing, or where there is physical contact, lifting or assisting a child to carry out activities. Avoid taking on the responsibility for tasks for which you are not appropriately trained.


If any of the following occur, you should report this immediately to another colleague and record the incident. You should also ensure the parents/carers of the child or vulnerable adult are informed.


  • If you accidentally hurt a player.
  • If he/she seems distressed in any manner.
  • If a player appears to be sexually aroused by your actions.
  • If a player misunderstands or misinterprets something you have done.


Guidelines for Use of Photographic Filming Equipment at Sporting Events

There is evidence that some people have used sporting events as an opportunity to take inappropriate photographs or film footage of young and disabled sportspeople in vulnerable positions. It is advisable that all clubs be vigilant with any concerns to be reported to the Designated Safeguarding Officer.

Videoing as a coaching aid: there is no intention to prevent club coaches and teachers using video equipment as a legitimate coaching aid. However, performers and their parents/carers should be aware that this is part of the coaching programme and care should be taken in the storing of such films. (See Images and Filming Policy)


Recruitment and selecting staff and volunteers

The club recognises that anyone may have the potential to abuse children in some way and that all reasonable steps are taken to ensure unsuitable people are prevented from working with children. When undertaking pre-selection checks the following should be included:

  • All volunteers/staff should complete an application form. The application form will elect information about an applicant’s past and self-disclosure about any criminal record.
  • Consent should be obtained from an applicant to conduct a DBS search
  • Two confidential references, including one regarding previous work with children. These references must be taken up and confirmed through telephone contact.
  • Evidence of identity (passport or driving licence with photo).
  • Should RAFC buy in services it will ensure that the organisation and/or individual has the appropriate clearances in place prior to working with the children, young people and vulnerable adult in the group.


Responding to suspicions or allegations

It is not the responsibility of anyone working at Rochdale Association Football Club, in a paid or unpaid capacity to take responsibility to decide whether abuse has taken place. However, there is a responsibility to act on any concerns through contact with the appropriate authorities.

The club will assure that all staff/volunteers that it will fully support and protect anyone, who in good faith reports his or her concern that a colleagues is, or may be, abusing a child or vulnerable adult.

Where there is a complaint against a member of staff there may be three types of investigation


  • A criminal investigation,
  • A child protection investigation,
  • A disciplinary or misconduct investigation.

The results of the police, child protection, social services investigation well may influence the disciplinary investigation, but not necessarily.


Action if there are concerns

The following action should be taken if there are concerns (See Appendix A):


Poor Practice

  • If following consideration, the allegation is clearly about poor practice; the Designated Safeguarding Officer will deal with it as a misconduct issue.
  • If the allegation is about poor practice by the, or if the matter has been handled inadequately and concerns remain, it should be reported to the relevant officer who will decide how to deal with the allegation and whether or not to initiate disciplinary proceedings.


Suspected Abuse

  • Any suspicion that a child has been abused by either a member of staff or a volunteer should be reported to the Designated Safeguarding Officer Nicola Toolan on 07734961927, who will take such steps as considered necessary to ensure the safety of the child in question and any other child who may be at risk.

If the club Designated Safeguarding Office is unavailable, you should contact David Bottomley on 01706644648.


  • The Designated Safeguarding Officer (Academy is Roy Thickett) will refer the allegation to the social services department who may involve the police or go directly to the police if out-of-hours.
  • The parents or carers of the child or vulnerable adult will be contacted as soon as possible following advice from the social services department.
  • The Designated Safeguarding Officer should also notify the relevant officer who in turn will inform the Football Association Child Protection Officer who will deal with any media enquiries.
  • If the Designated Safeguarding Officer is the subject of the suspicion/allegation, the report must be made to the appropriate Manager or in his/her absence the Football Association Children Services Officer who will refer the allegation to Social Services.



Every effort should be made to ensure that confidentiality is maintained for all concerned.

Information should be handled and disseminated on a need to know basis only. This includes the following people:



  • The parents/carers of the person who is alleged to have been abused.
  • The person making the allegation.
  • Social services/Police.
  • The alleged abuser (and parents/carers if the alleged abuser is a child) *

* Seek social services advice on who should approach alleged abuser.


Information should be stored in a secure place with limited access to designated people, in line with data protection laws (e.g. that information is accurate, regularly updated, relevant and secure).


Internal Enquiries and Suspension

  • The Rochdale Association Football Designated Safeguarding Officer in consultation with the CEO, will make an immediate decision about whether any individual accused of abuse should be suspended pending further police and social services inquiries.

  • Irrespective of the findings of the social services or police inquiries Rochdale Association Football Club Board will assess all individual cases to decide whether a member of staff or volunteer can be reinstated and how this can be sensitively handles. This may be a difficult decision; particularly where there is insufficient evidence to uphold any action by the police. In such cases, Rochdale Association Football Club Board must reach a decision based upon the available information which could suggest that in a balance of probability; it is more likely than not that the allegation is true. The welfare of children should always remain paramount.


Support to Deal with the Aftermath

  • Consideration should be given about what support may be appropriate to children, parents and members of staff. Use of Helplines, support groups and open meetings will maintain an open culture and help the healing process. The British Association of Counselling Directory may be a useful resource. (Available from The British Association for Counselling, 1 Regent Place, Rugby CV21 2PJ, Tel: 01788 550899, Fax: 01788 562189, E-mail:, Internet: Additional numbers are in Appendix B
  • Consideration should be given about what support may be appropriate to the alleged perpetrator of the abuse.


Allegations of Previous Abuse

Allegations of abuse may be made some time after the event (e.g. by an adult who was abused as a child or by a member of staff who is still currently working with children). Where such an allegation is made, the club should follow the procedures as detailed above and report the matter to the social services or the police. This is because other children, either within or outside Rochdale Association Football Club, may be at risk from this person. Anyone who has a previous criminal conviction for offences related to abuse is automatically excluded from working with children. This is reinforced by the details of the Protection of Children Act 1999 and subsequent updates.


Action if Bullying is Suspected

All forms of bullying are not to be tolerated and must be addressed immediately when observed, suspected or notification is received. All settings in which children are provided with services or are living away from home should have rigorously enforced anti-bullying strategies in place.


Action to Help the Victim and Prevent Bullying in Sport:

  • Take all signs of bullying very seriously.
  • Encourage all children or vulnerable adult to speak and share their concerns (it is believed that up to 12 children per year commit suicide as a result of bullying, so if anyone talks about or threatens suicide, seek professional help immediately). Help the victim speak out and tell the person in charge or someone in authority. Create an open environment.
  • Investigate all allegations and take action to ensure the victim is safe. Speak with the victim and the bully/bullies separately.
  • Reassure the victim that you can be trusted and will help them, although you cannot promise to tell no one else.
  • Keep records of that is said (what happened, by whom, when).
  • Report any concerns to the Designated Safeguarding Officer or the school (wherever the bullying is occurring).


Action towards the Bully/Bullies:

  • Talk with the bully/bullies, explain the situation, and try to get the bully/Bullies to understand the consequences of their behaviour. Seek an apology to the victim(s).
  • Inform the bully’s parents/carers.
  • Insist on the return of the borrowed items and that the bully/bullies compensate the victim.
  • Provide support for the leader of the victim.
  • Impose sanctions, as necessary.
  • Encourage and support the bully/bullies to change behaviour.
  • Hold meetings with the families to report on progress.
  • Inform all organisation members of action taken.
  • Keep a written record of action taken.



The policy will be reviewed a year annually or in the following circumstances:

  • changes in legislation and/or government guidance
  • as required by the Local Safeguarding Children Board, UK Sport and/or The FA or EFL.
  • because of any other significant change or event.




What to do if there are concerns

Information passed to the social services or the police must be as helpful as possible, hence the necessity for making a detailed record at the same time of the disclosure/concern. Information should try to include the following, but not every question needs an answer:


  • Name of child or vulnerable adult
  • Age of child or vulnerable adult and date of birth
  • Home address and telephone number
  • Is the person making the report expressing their own concerns or those of someone else?
  • What is the nature of the allegation? Include dates, times, any special factors, and other relevant information.
  • Make a clear distinction between what is fact, opinion, or hearsay.
  • A description of any visible bruising or other injuries. Behavioural signs indirect signs?
  • Witnesses to the incidents.
  • The child’s or vulnerable adults account, if it can be given, of what has happened and how any bruising or other injuries occurred.
  • Have the parents/carers been contacted?
  • If so, what has been said?
  • Has anyone else been consulted? If so, record details.
  • If it is not the child or vulnerable adult making the report has the child or vulnerable adult concerned been spoken to? If so, what was said?
  • Has anyone been alleged to be the abuser? Record details.


(This must be completed at time of observation)


Name of Player:


Date of Birth:


Name of Staff:


Job title:


Date and time of observation:






App B


Designated Persons for Safeguarding

Rochdale Football Club will appoint a Senior Safeguarding Officer who will be a member of the Board, together with a Designated Safeguarding Officer to support having in place arrangements that reflect the importance of safeguarding and promoting the welfare of children.  





















Designated Person Specification and Suitability Checklist


When appointing a designated person, ensure that you have considered their appropriateness for this role by checking them against the following criteria.



Skills, Qualifications and Experience relevant to the Role


Working regularly with children and young people in a lead or supervisory role where the incumbent has had sole responsibility for the welfare of the children and young people.

Completion of an Enhanced DBS clearance which is deemed suitable.

Attendance at appropriate and authorised Safeguarding children training.

Willingness to update skills and knowledge

Know what to do if concerned that a child may be abused, or a person may pose a risk to a child.

Be familiar with The Club’s policies and procedures and reporting lines.

Knowledge of and positive attitudes to equal opportunities

Make considered judgements about how to act to safeguard and promote a child’s welfare.

Commitment to treat all children as individuals and with equal concern


Always puts the child’s welfare FIRST!

Is a good communicator.

Has a common-sense approach.

Is enthusiastic and professional.

Is willing to learn and seek advice.

Is a good team member.

Has attention to detail.


Previous experience of working with children.

Knowledge of safeguarding issues.

Knowledge of safeguarding legislation.














Designated Persons Responsibilities


To support in promoting the moral and legal responsibilities in implementing procedures to provide a duty of care for children, safeguard their wellbeing and protect them from abuse and poor practice. 


Ensuring that all issues of Safeguarding Children are dealt with in compliance with Football Club Safeguarding Policy, Procedures and Guidelines and with the requirements of Rochdale MBC Safeguarding Procedures.


Ensuring that all staff appointed have been checked by the DBS and are suitable and safe adults to work with children.


Ensure that all staff receive initial Safeguarding Training.


To record and refer on to CSO all incidents, concerns, allegations, evidence of poor practice and evidence of best practice, in confidence, and in line with Data Protection legislation.


To handle sensitively, in confidence, any Safeguarding concerns raised within the department and support staff where necessary.


To attend regular Company Designated Persons meetings with CWO, and undertake any actions raised at meetings/CPD events to keep up to date with current Safeguarding guidelines and legislation for compliance.


To take responsibility for the day to day management of Safeguarding issues and pro-active promotion of Safeguarding awareness and implementation within the specified department.


To be available, at all reasonable times, as a first contact for staff, parents, children, and if appropriate, external agencies regarding information or referral of Safeguarding matters within the Club.




Children’s Services Officer


Football Club will appoint an appropriately qualified and experienced Designated Safeguarding Officer (DSO), in accordance with Ruling O.


Children’s Services Officer Specification and Suitability Checklist


When appointing a Children’s Services Officer, ensure that you have considered their appropriateness for this role by checking them against the following criteria.

















Skills, Qualifications and Experience relevant to the Role



Knowledge of safeguarding children and/or vulnerable group’s legislation.

Ability to deal constructively with people’s emotions (e.g. upset, distress, conflict, animosity).

Capacity to handle confidential data sensitively.

Ability to work unsupervised and on own initiative

Experience of managing meetings/projects/events

Evidence of influencing skills/negotiating skills/presenting to management/staff/parents/players.


Always puts the child’s welfare FIRST!

Good leadership skills.

Good resource management skills

Is enthusiastic and professional.

Is willing to learn and seek advice.

Is a good team member.


Experience of implementing policies, protocols, and guidance.

Experience of writing reports and compiling case file information.

Knowledge and understanding of the culture and structure of football.


Children’s Service’s Officer Responsibilities


Ensuring that the Rochdale Football Club Safeguarding Policy and Procedures are updated and in line with current legislation and regulations.


Promote the moral and legal responsibility to implement procedures to provide a duty of care for children, safeguard their wellbeing and protect them from abuse and poor practice – across all areas of The Club.


Promote and deliver Safeguarding Training at Rochdale Football Club.


Supervise and support Rochdale Football Club’s Designated Persons for Safeguarding.


  Ensure Club has full compliance with Premier League Rules and EFL Sections N & O.


To provide leadership in Safeguarding of Children across the Club, maintaining key relationships with Club Senior Management, Premier League Safeguarding Team, Club Safeguarding Officers, NSPCC and The FA


Representing the Club as Lead Case Manager when co-operating with/reporting directly to external statutory agencies; the Police, Children’s Services, Local Safeguarding Children Board and Local Authority Designated Officer for the Management of allegations against professionals (LADO)

Internal & External Contacts:

(The initial internal contact is the Children Services Officer within the group)




External Contacts:

(This would be the agency to which referrals would be made i.e. Social Services)


Child Protection Officer

Lancashire County FA

01772 624000



NSPCC Helpline






Rochdale Social Services

0300 303 0440


Rochdale MBC LADO

Tel: 01706 647474



Appendix C - Legislation and statutory guidance


Working Together to Safeguard Children 2018

The Children Act 1989 and 2004

Keeping Children Safe in Education 2018

Health and Safety at Work Act 1974

Management of Health and Safety at Work Regulations 1999

Modern Slavery Act 2015

Counter Terrorism and Security Act 2015

Private Fostering Regulations 2005

Female Genital Mutilation Act 2003

General Data Protection Regulations 2018

































Public Interest Disclosure Policy

(Whistleblowing Policy) 

Update July 2019


The Public Interest Disclosure Act 1999 gives legal protection to employees against victimisation for publicly disclosing legitimate concerns.  This policy is designed to enable employees to raise concerns internally about malpractice or wrongdoing within the organisation, without fear of reprisals. 

Employees should raise concerns if they suspect:

  • financial impropriety or fraud
  • failure to comply with legal obligations
  • criminal activity
  • dangers to health & safety
  • improper conduct or unethical behaviour
  • actions contrary to Company policies, procedures or instructions


This policy and procedure are not intended to be a mechanism for staff to challenge decisions with which they disagree or to settle personal scores, but is reserved for raising serious concerns about malpractice.

The Public Interest Disclosure Act sets the following rules:

  • The disclosure must be made in the public interest
  • There must be a reasonable belief that it is substantially true
  • Employees must not act maliciously or make false allegations
  • Employees must not seek any personal gain


No action will be taken against individuals making allegations in good faith which are found to be untrue after investigation.  If, however, the allegations are judged to be malicious, disciplinary action may be taken against the individual.


Procedure for making a protected disclosure

Concerns should initially be reported to an appropriate manager or director.  If necessary, employees may be supported by a fellow worker or trade union representative.


The complaint will be investigated as speedily as possible and the individual informed of what action, if any, is to be taken.



Employees making a protected disclosure in good faith will not suffer any detriment and all disclosures will be treated in a confidential manner.  Employees are encouraged to make signed statements of any disclosures they may make, but the identity of the individual will normally be kept confidential unless he or she agrees otherwise.  However, for example in the case of criminal activity where the police may become involved, it may not be possible to guarantee anonymity.


Data Protection Policy

In the course of your work you may come into contact with or use confidential information about other employees or business associates, for example their home addresses. The General Data Protection Act 2018 (GDPR) contains principles affecting employees’ and other personal records. Information protected by the Act includes not only personal data held on computer but also certain manual records containing personal data, for example employee personnel files that form part of a structured filing system. The purpose of these rules is to ensure that you do not breach the Act.


You should be aware that, under the Act, you are personally accountable for your actions and can be held criminally liable if you knowingly, or recklessly, breach it. Any serious breach of data protection will also be regarded as misconduct and will be dealt with under the Company’s disciplinary procedures. If you access another employee’s personnel records without authority, this constitutes a gross misconduct offence and could lead to your summary dismissal.

The data protection principles

There are eight data protection principles that are central to the Act. In brief, the principles say that personal data must be:

  • Processed fairly and lawfully and must not be processed unless certain conditions are met in relation to personal data and additional conditions are met in relation to sensitive personal data. The conditions are either that the employee has given consent to the processing, or the processing is necessary for the various purposes set out in the Act. Sensitive personal data may only be processed with the explicit consent of the employee and consists of information relating to:


  • race or ethnic origin
  • political opinions and trade union membership
  • religious or other beliefs
  • physical or mental health or condition
  • sexual life
  • criminal offences, both committed and alleged.


  • Obtained only for one or more specified and lawful purposes, and not processed in a manner incompatible with those purposes.


  • Adequate, relevant and not excessive. The Company will review personnel files on an annual basis to ensure they do not contain a backlog of out-of-date information and to check there is a sound business reason requiring information to continue to be held.


  • Accurate and kept up-to-date. If your personal information changes, for example you change address, you must inform your manager as soon as practicable so that the Company’s records can be updated. The Company cannot be held responsible for any errors unless you have notified us of the relevant change.


  • Not kept for longer than is necessary. The Company will keep personnel files for no longer than six years after termination of employment. Different categories of data will be retained for different time periods, depending on legal, operational and financial requirements. Any data which the Company decides it does not need to hold for a period of time will be destroyed after one year. Data relating to unsuccessful job applicants will only be retained for a period of one year.


  • Processed in accordance with the rights of employees under the Act.


  • Safeguarded by appropriate measures against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data. Personnel files are confidential and are stored in locked filing cabinets. Data held on computer will be stored confidentially by means of password protection, encryption or coding. The Company has network backup procedures to ensure that data on computer cannot be accidentally lost or destroyed.


  • Not transferred to a country or territory outside the European Economic Area unless that country ensures an adequate level of protection for the processing of personal data.


Your consent to personal information being held

The Company holds personal data about you. By signing your contract of employment, you have consented to that data being processed by the Company. Agreement to the Company processing your personal data is a condition of your employment. The Company also holds limited sensitive personal data about its employees and, by signing your contract of employment, you give your explicit consent to the Company holding and processing that data, for example sickness absence records and health needs.


Your obligations in relation to the personal information of others

You should ensure you comply with the following guidelines at all times:


  • do not give out confidential personal information without the prior consent of a director. In particular, personal information should not be given to anyone unless the data subject has given their explicit consent to this.
  • be aware that those seeking information sometimes use deception in order to gain access to it. Always verify the identity of the data subject and the legitimacy of the request, particularly before releasing personal information by telephone.
  • only transmit personal information between locations by fax or e-mail if a secure network is in place, for example, a confidential fax machine or encryption is used for e-mail.
  • if you receive a request for personal information you should forward this to a director.
  • ensure any personal data you hold is kept securely, either in a locked filing cabinet or, if computerised, it is password protected.
  • compliance with the Act is your responsibility. If you have any questions about the interpretation of these rules, please contact a director.


Rochdale AFC Complaints Procedure

To help supporters complain if they have been the victim of abuse or have witnessed an incident of discrimination or harassment, Rochdale AFC has a reporting helpline number (0844 826 1907, option8).

Should you feel the necessity to report the incident to Kick It Out rather than the Club, supporters should ring Freephone number (0800 164 9414).

All complaints received by Kick It Out will be recorded and details of the incident forwarded to Rochdale AFC and the Football Association, with the complainants’ anonymity guaranteed if requested.

Rochdale AFC ensures that all complaints are dealt with sensitively and appropriately to help supporters feel comfortable with the process and are confident that the club is taking any issues seriously. 

Should any Customer (Supporter) not be satisfied with any part of the Clubs Complaint Procedure then they have the right to direct the matter to the Independent Football Ombudsman (IFO) in line with the IFO procedure.

Complaints to The IFO should be made in writing and may be submitted by post to:

The Independent Football Ombudsman,
Suite 33,
Great George Street,


by e-mail to:


via the website:

You may initially register your concerns by phone and may wish to leave a message on the IFO Voicemail 0800 588 4066.

You should submit a summary of your complaint, to include details of your concerns and your desired outcome. This should be supported by any documentary evidence available, including correspondence to and from the provider. This may be submitted either in hard copy or electronically. You may communicate with the IFO and the provider online if you wish. You will be given sufficient time to submit full documentation in order for the IFO to consider a complete case file.