Safeguarding Policy
Version 1.0 · Effective from Monday 31 August 2026
Version. 1.0
Effective from. Monday 31 August 2026
Review. Annually, or sooner on incident.
Published at. bonsai.law/circle/safeguarding
Named safeguarding lead. Rebekah Manning (Vanessa Challess deputy).
1. Why we have this policy
The Bonsai Circle is built on the assumption that its members will meet each other - often one to one, sometimes in private settings, always on the strength of the Circle's introduction. That assumption places a duty on us. This policy sets out how we discharge it.
We publish it because an organisation whose product is private meetings between strangers ought to.
2. Scope
This policy applies to:
- everyone we vet, admit or refuse;
- every Circle meeting, in person or online;
- all one-to-one contact between members that arises from a Circle introduction;
- all activity on the Circle forum and member area;
- the founders, any Circle staff, and any invited guests.
3. Who is the safeguarding lead
Named safeguarding lead: Rebekah Manning.
Deputy: Vanessa Challess.
If a concern is about the safeguarding lead, raise it directly with the deputy. If a concern is about both founders, the Complaints, Concerns and Removal Procedure describes the recusal and joint-decision rules that then apply. Bonsai Law Ltd is a regulated firm; complaints about the conduct of Bonsai Law Ltd may in the last resort be raised with the Solicitors Regulation Authority at sra.org.uk/consumers or with the Legal Ombudsman at legalombudsman.org.uk.
Contact: bonsai.circle@bonsai.law, subject line "Safeguarding".
4. Our safeguarding commitments
We commit to:
- vet every member as set out in the Vetting Standard;
- run every meeting under the Confidentiality Regime;
- provide a clear route to raise a concern about a member's conduct that has nothing to do with referral quality;
- take every concern seriously, respond within one working day, and investigate proportionately;
- suspend a member immediately where continued participation would present a risk;
- support any member or third party affected by another member's conduct;
- respect the reporting person's confidentiality within the limits of the law;
- publish, annually, in anonymised summary form: applications received, refusals, complaints received, complaints upheld, removals.
5. One-to-one meeting guidance for members
You are grown adults doing professional work. This is guidance, not policing.
- Default to a professional venue. Coffee shops, offices, restaurants, business lounges. First meeting on the strength of a Circle introduction is not the moment for a private home or a hotel room.
- Tell someone where you are. A colleague, a partner, an assistant. Not the Circle. Just someone.
- Take account of comfort as well as safety. If a proposed venue or time makes you uncomfortable, propose an alternative. A member who is offended by that is not a member you want to work with.
- The founders' offices are available. By arrangement, and by prior booking, Bonsai Law's Kent offices are available for members to hold one-to-one Circle meetings. Free of charge. Coffee provided.
- Report predatory behaviour. Not "he asked me for coffee". Behaviour that gives you reason to think you or someone else is at risk. Use the concerns process at bonsai.law/circle/concerns.
6. Meetings - logistics and safety
- Venue risk-assessed by the chair for accessibility, safety, and appropriate hospitality.
- Attendance list held by the chair, matched against forum sign-ups.
- Guests permitted only with chair's advance approval.
- Founders always identifiable in the room and online.
- Online meetings held on Microsoft Teams under Bonsai Law's tenant, recording disabled at tenant level, waiting-room enabled, participants admitted by name.
- Safeguarding lead has a five-minute check-in with any new member after their first meeting.
7. Raising a concern
A concern is anything you think we should know about a member's conduct in or around Circle activity. It includes but is not limited to:
- unwanted physical or sexual conduct;
- coercive, threatening or bullying behaviour;
- discriminatory behaviour contrary to the Equality Act 2010;
- misuse of the confidentiality regime - for example, recording, screenshotting, or attributing Circle discussion externally;
- misuse of another member's information, contacts, or vulnerabilities;
- financial impropriety, whether or not it results in loss;
- conduct that would give a reasonable member cause to withdraw from the Circle if they knew of it.
Route to raise a concern: bonsai.law/circle/concerns, or by email to bonsai.circle@bonsai.law with subject line "Concern".
You may raise a concern:
- (a) about a member you have met through the Circle;
- (b) whether or not you are yourself a member;
- (c) anonymously (we will take an anonymous concern as seriously as any other, but our ability to investigate will be constrained);
- (d) at any time, before or after leaving the Circle.
The full concerns procedure is in the Complaints, Concerns and Removal Procedure.
8. What we do when a concern is raised
Full procedure in the Complaints, Concerns and Removal document. In summary:
- Acknowledge within one working day.
- Assess whether an interim suspension is necessary. Suspension is protective, not punitive.
- Investigate proportionately, respecting confidentiality.
- Where necessary, refer to the police, the regulator (yours or theirs), or another authority.
- Decide, and communicate the outcome to the reporting person and the member concerned.
- Where the member is removed, they are removed. We do not paper over.
9. Working with statutory authorities
Where we consider that a matter should be reported to the police, we will report it, whether or not the person affected is willing to do so themselves. We will tell you before we do so, save where doing so would compromise the investigation or increase risk to you or others.
Where a regulatory obligation applies to us or the member concerned, we will comply with it. That includes SRA reporting obligations on Vanessa's part as a solicitor.
10. Data protection
Safeguarding information is sensitive personal data. Full detail is in the Privacy Notice and the Appropriate Policy Document. In summary:
- We hold safeguarding records under Article 6(1)(f) legitimate interests and, where they include Article 9 or Article 10 data, under Schedule 1 Part 2 DPA 2018 paragraphs 10, 12 or 18 as applicable.
- Records are held for seven years after closure.
- Access is restricted to the founders and, where necessary, our professional advisers.
- The person who raised a concern will be told the outcome. They will not be told details of any disciplinary action beyond the fact and headline outcome, except where a court order or statutory requirement compels wider disclosure.
11. Training and review
- Founders undertake an annual refresher on adult safeguarding and on data protection.
- This policy is reviewed at least annually and immediately after any incident of substance.
- Lessons learned are recorded and applied.
- The annual transparency summary is published at bonsai.law/circle/transparency.