2.6.4 Staff welfare and safeguarding

Wellcome aims to take a 'seen once' approach so far as is practicable.

Wellcome recognises the potential for risk of harm to staff wellbeing, from discussing or viewing material related to child sexual abuse. Prolonged exposure may also risk desensitisation. This could affect the ability of staff to objectively recognise CSAM.

Discussions related to child sexual abuse material

Content advisory statements should be made in advance of any staff meeting or discussion due to take place via email, agendas, and any other associated documentation.

Staff are free to opt to join in person, remotely, or not at all. There is no obligation for staff to be present or participate in discussions covering CSAM.

Members of staff across a range of teams and departments may come into contact with material that contains currently unidentified CSAM without prior warning.

This includes staff within Collections Development, Collections Information, Conservation and Collections Care, Research Development, Library Experience and Engagement, and Digital Engagement.

Main requirements for all staff when working with CSAM

• locate an appropriate workspace that reduces unnecessary exposure to other members of staff.

• ensure that there is another member of staff available and contactable for support.

• limit the amount of time working on such material in any given day, ensuring frequent breaks.

• be given clear instruction that no sharing, photographing or other means of copying is permitted, and may be unlawful.

At the point of survey or acquisition

Members of the Collections Development team may view potentially distressing material without prior warning. The point of acquisition or survey is likely to be the first point of contact Wellcome Collection staff have with new CSAM.

Members of staff are not required to continue to review material where they suspect or know that it contains child sexual abuse material.

When we accession a new collection, the due diligence process will identify legal issues. These issues will then be flagged within the accession documentation as well as with the Collections Information Manager and the Legal Business Partner and considered to fail due diligence unless risks can be resolved or managed on their assessment.

As part of collections information processes

At the point of cataloguing or inventory, members of the Collections Information team should read through all existing documentation available via the Collections File and the accession record.

The point of inventory or cataloguing may be the first point of contact Wellcome Collection staff have with CSAM within our existing collections.

Members of staff are not required to inventory or catalogue material of this nature and are given the choice to decline.

See procedure for cataloguing for further information.

At the point of digitisation

All collections material undergoing digitisation will have been scoped beforehand and any known CSAM flagged, discussed, and excluded as appropriate. Such material, if already identified, will be clearly marked in accordance with the procedure for cataloguing. Photography will only take place when there is a legitimate reason to do so. See digitisation page for further information.

It is also possible for CSAM to be identified in existing collections for the first time by staff undertaking the preparation of material prior to photography, or staff undertaking the photography itself.

Members of staff are not required to prepare or photograph material of this nature and are given the choice to decline.

All staff, whether Wellcome or contract staff, involved in the digitisation of collections material, will be clear that this risk exists, briefed on this CSAM procedure and the need to alert, and seek advice from the Safeguarding Lead and Collections Information Analyst before proceeding.

Where photography has been approved for a legitimate reason, staff agreeing to prepare or photograph material containing CSAM are subject to the requirements listed above to limit exposure and to safeguard themselves and others.

At the point of internal review

Where material suspected to be CSAM is identified within our collections, the Safeguarding Lead, Collections Information Analyst and other Internal Review Panel members will be required to consider the item in order to determine whether it does constitute CSAM.

Where possible, the Internal Review Panel will only be presented with a written and/or verbal assessment of the material's status by the Safeguarding Lead and Collections Information Analyst, as opposed to being required to view the material itself. This is to further limit their exposure.

Internal Review Panel members required to either view such material, or consider the facts of it, must follow the requirements listed above in order to safeguard themselves and others.

Resources available

Wellcome offers a range of resources to support staff wellbeing, both physical and mental, including counselling services, apps, occupational health, mental health first aid, and our employee assistance programme.