safeguarding children Policy

Devon County Council have requested that all Early Years Settings demonstrate how seriously Safeguarding children in the Early Years is taken by providers. At Oak Trees and Acorns, I (Frances Rogers,) am responsible for safeguarding and providing a safe route to raise concerns. I hope parents find it reassuring that I place the care of the children who attend here right at the top of our agenda.

safeguarding children Policy

The policy is informed by the following legislation:

Statutory Framework for the Early Years Foundation Stage 3.3 states: Providers must take all necessary steps to keep children safe and well.

https://assets.publishing.service.gov.uk/media/65aa5e29ed27ca001327b2c6/EYFS_statutory_framework_for_childminders.pdf

Purpose and Aims

The purpose of this safeguarding and child protection policy is to provide a secure framework in safeguarding and promoting the welfare of those children/young people who attend this childminding setting. The policy aims to ensure that: 

• All our children are safe and protected from harm. 
• Other elements of provision and policies are in place to enable children to feel safe and adopt safe practices
• Children, parents, visitors, childminding assistants, are aware of the expected behaviours and the setting's legal responsibilities in relation to the safeguarding and promoting the welfare of all of our children. 

This policy has been developed in accordance with the principles established by Working together to safeguard children - GOV.UK (www.gov.uk)  a guide to inter-agency working to safeguard and promote the welfare of children.

As a registered Childminder I take seriously my responsibility to ensure the safety and promote the welfare of children in my care in line with the procedures laid out by the Devon Children and Families Partnership (DCFP). I have developed a structured procedure to be followed in the case of suspected abuse, which is regularly reviewed and updated.

As the Designated Safeguarding Lead for my Childminding setting, I work with other agencies to ensure I have adequate arrangements in place to identify, assess, and support those children who are suffering harm or are at risk of suffering significant harm. I can be contacted on: 01752 896599 or 07305 152263 during the following hours: Monday to Friday 8:00 am – 4:00 pm.

I attended Group 2 Safeguarding Training on 20^th February 2023 and I receive regular updates on safeguarding issues via the Early Years and Childcare Services Digest and the DSCP website.

Recognising concerns, signs and indicators of abuse

Any child, in any family, in any community setting could become a victim of abuse. As a childminder I always maintain an attitude of "It could happen here". I also recognise that abuse, neglect and safeguarding issues are complex and are rarely standalone events that can be covered by one definition or label.

• Abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in the family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. They may be abused by an adult or adults or by another child or children.
• Abuse and neglect may also take place outside of the home, contextual safeguarding, and this may include (but not limited to), female genital mutilation (FGM) sexual exploitation criminal exploitation, radicalisation, serious youth violence.
• I am aware that behaviours linked to parental drug taking, alcohol abuse, mental ill health and domestic abuse can put children at risks and that safeguarding issues can manifest themselves via child-on-child abuse.

Further information about the four categories of abuse; physical, emotional, sexual and neglect, (familial and contextual) and indicators that a child may be being abused can be found in appendices 1 & 2.

Online
Technology itself will not present the greatest risk, but the behaviours of individuals using such equipment will. The witnessing of abuse can have a damaging effect on those who are party to it, as well as the child/adult subjected to the actual abuse, and in itself will have a significant impact on the health and emotional well-being of the child. The Safeguarding children and protecting professionals in early years settings: Online Safety Considerations' document identify the responsibilities for me with regards to online safety for the children 

'You play an essential role in helping young children learn the foundations of safe online behaviour. Even if children don't have access to technology within your setting, they may be using it at home, with their friends or in other public spaces. Children are naturally curious in understanding the world we live in; it is our responsibility to enable them to do so, including helping them to recognise the value of technology and use it safely. Role modelling safe use of the internet should become part of our everyday practice'. (2019) 

I am aware that these abuse descriptors are not a definitive list although children's poor behaviour maybe a sign that they are suffering harm or that they have been traumatised by abuse, some children may present poor behaviour for reasons other than abuse.

Children who have special educational needs and/or disabilities 

All children have the right to be safe, yet research shows that disabled children are three times more likely to be abused. A number of factors have been identified as to reasons why these children are more at risk (see bullet points) and as a childminder I am aware of these and endeavour to protect all children.

• a general reluctance of people to believe that disabled children are abused
• limited opportunities to seek help from someone else
• a skills gap between disability and child protection workers
• inadequate teaching about personal safety skills e.g. NSPCC pants campaign
• issues relating to the child's specific disability or special educational need, e.g. difficulties in communicating or an inability to understand what is happening.

How I aim to keep the children in my care safe:

I update my safeguarding training as necessary.

I provide a caring, positive, safe and stimulating environment that promotes the social, physical and moral development of the individual child. I support the children's development in ways that will foster security, confidence and independence. I recognise that it is especially important for children who are unable to communicate e.g. babies and very young children, to have strong attachment to their care givers.

I am alert to circumstances when a child and family may need access to early help 

I take responsibility for ensuring the acceptable and safe use and storage of all camera technology, images, mobile devices (i.e. smart watches, tablets etc) and phones.

I provide an environment in which children and young people feel valued and respected, and are confident to approach me if they are in difficulties, believing they will be effectively listened to.

If a parent tells me that they are / have been suffering from Domestic Abuse I will provide them with information and phone numbers for support via the Devon Domestic Abuse Helpline

A copy of What to do if you're worried a child is being abused March 2015 is kept with this policy and an additional copy is available for parents / carers to read if required. Or parents can access it independently at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/419604/What_to_do_if_you_re_worried_a_child_is_being_abused.pdf This sets out the guidelines for recording any incidents and disclosures and the procedures I must follow.

MASH (Multi Agency Safeguarding Hub) Information is available for parents / carers

I have regard to the Fundamental British Values of democracy, rule of law, individual liberty, mutual respect and tolerance for those with different faiths and beliefs, which are embedded in the Early years foundation stage (EYFS) statutory framework for Childminders - GOV.UK (www.gov.uk). This is alongside my awareness of the need to prevent people from being drawn into terrorism, and adhere to the Protecting children from radicalisation prevent duty

If I have reason to believe that any child in my care needs protection in any way I will:

• Refer a child, if there are concerns about possible abuse, to the Children and Young People Services Multi Agency Safeguarding Hub (MASH). Enquiries will either be made by completing the DCC - Request for support (outsystemsenterprise.com) a telephone call. Telephone enquiries will be followed by written enquiry within 48 hours of the call. Under these circumstances I will share information relating to your child with MASH and the Police if requested. If the concern relates to me or another adult in my setting, I will follow my 'Allegations of Abuse' procedure.
• Keep written records of concerns about a child, even if there is no need to make an 

    immediate enquiry. I will ensure that all such records are kept confidentially and securely,

    separate from a child's records. Child protection records will be kept until the child

    reaches the age of 21 years.

• Liaise with other agencies and professionals.
• Attend case conferences, or other multi-agency planning meetings, as necessary.
• Ensure that any child currently with a child protection plan who is absent without explanation is referred to their Social Worker / Social Care Team.
• I will notify my local child protection agency (MASH and LADO) and Ofsted of any

serious accident, illness or injury to or death of any child whilst in my care. Ofsted must be

informed within 14 days.

If a child confides in me, I will:

• Show that I have understood what they are saying and that I take their allegations seriously.
• Encourage the child to talk, without asking leading questions or interrupting when a child is recalling a significant event. I will use the tell Me, explain to me and describe to me type of questions. 
• Record the concern and the child's comments in writing, in their own words as far as possible. The record will contain:

                    Ø The child's name.

                    Ø   The child's date of birth.

                    Ø   The date the record is made

                    Ø   A note of the child's non-verbal behaviour.

                    Ø   A body map, if appropriate, to record any visible injuries or marks.

                    Ø   My name and signature.

• Inform the child that I cannot promise not to share this information but that everything I do will be in the interest of their safety.
• Seek advice from MASH Consultation line and, if necessary, make an enquiry.

Confidentiality

• I recognise that all matters relating to safeguarding are confidential. I will disclose any information about a child on a need-to-know basis only, referring to What to do if you're worried a child is being abused and Information Sharing - Advice for practitioners providing safeguarding services to children 
• I am aware that I have a professional responsibility to share information with other agencies in order to safeguard children.
• I am aware that I cannot promise a child that I will keep secrets which might compromise their safety and wellbeing.
• I will always undertake to share our concerns with parents and guardians and their consent is sought in accordance with Early help and MASH procedures unless doing so would increase the risk of harm to the child. If in doubt regarding sharing information with parents and guardians, I will consult with the MASH consultation team or the Early Years and Childcare Services locality team.

Visitors to my home

• Children are not left unsupervised with visitors, and I have a procedure in place for checking the identity of all visitors to my home whilst I have minded children in my care:
• I record all visitors to my home during Childminding hours with the time and nature of visit. The record is signed by the visitor.
• If the visitor is unknown to me, I ask for proof of identification and, if appropriate, which organisation they work for. e.g. identity badge; driving licence. If I need further verification, I will contact the phone number of their organisation and ask to be put through to the visitor's manager. I record that ID has been checked.
• If I know the visitor, they must have a valid reason for visiting during Childminding hours. 

Allegations of Abuse

I will take precautions to protect myself from allegations of abuse against myself; my

household members and staff (if applicable). I will aim to prevent this from happening

by:

• Ensuring all household members aged 16 and over have DBS.
• Ensuring all visitors to the house are recorded as above, and do not have unsupervised access to the children under any circumstances. Ensuring, where possible, that no workmen/women are in the childminding space within the house during minded hours, unless it is to repair an emergency service or for health and safety reasons.
• Documenting every accident and incident that occurs whilst children are in my care, informing parents of such events and requesting them to sign my records.
• Noting any noticeable marks/pre-existing injuries on the children when they arrive and asking parents to inform me of any accidents that have occurred whilst outside my care.
• Ensuring the children are within sight and/or hearing at all times according to the child's age and ability.
• Ensuring that any occasion where physical intervention is used to manage a child's behaviour is recorded as an incident and parents are informed about it on the same day.
• Checking the behaviour of adults - for example inappropriate sexual comments; excessive one-to-one attention beyond the requirements of their usual role and responsibilities; inappropriate sharing of images. Keeping Children Safe in Education provides advice on this:

However, if an allegation of serious harm or abuse is made against me as a Childminder or anyone living or working on the premises, I will then follow the procedure detailed below in order to gain support and professional advice:

Inform:

• The Local Authority Designated Officer (LADO) immediately to discuss the nature of the allegation and the appropriate action to be taken: 01392 384964.
• Ofsted as soon as possible but within 14 days to advise them of the allegation: 0300 123 1231.

Contact:

• My Insurance Company.
• Relevant Legal Advice Line or Family Solicitor.

I will write a detailed record of all related incidents, including what was said and by

whom, with times and dates.

After seeking advice/approval from the LADO I will ask witnesses (if there were any) to also write a statement detailing the incident they witnessed and giving their contact details in case it needs to be followed up by the authorities.

Use of Electronic Devises with imaging sharing capacities.

I understand that if I am processing personal information electronically for the provision of childcare – including taking photos of children in my care using a digital device I must register with Information Commissioner's Office (ICO) for General Data Protection Regulations (GDPR)

Mobile and devices with imaging sharing capabilities

As a registered Childminder I recognise that it is important for me to be able to communicate with parents instantly. I understand that mobile phones are an everyday part of life for parents and childminders. Mobile phone technology has developed significantly to include internet access and wireless connections as well as camera, video and sound recording and sending and receiving messages. They are now an extremely effective method of communication, which can be an advantage regarding Safeguarding children. However, I understand that there is a need to balance the advantages with the potential for misuse, and intend to protect the children in my care with the following procedures.

I use a combination of my landline and a designated business mobile phone at home (as the mobile signal is very poor indoors) and the designated business mobile phone when we are out.

• To safeguard children, myself and assistants I will refer to Safeguarding children and protecting professionals in early years settings: online safety guidance for practitioners - GOV.UK (www.gov.uk)
• I will ensure my mobile phone or other mobile devices are with me at all times in case of emergencies
• I will seek parents' permission to take photographs on my mobile devices for the purpose of recording your children's progress and sharing activities with their parents.
• All photographs taken will be deleted after emailing to parents.
• I will not publish any photographs of your child on any social networking sites or share with any other person without your permission.
• Visitors to my setting are not permitted to use their electronic devices whilst on my premises, except in exceptional circumstances, when the devices must be used away from the children.
• I will ensure that ALL visitors to my home during Childminding hours are asked to leave their mobile phone and electronic device in their bag or briefcase and switch off their mobile phone and electronic device, for example smart watch.
• I will ensure my devices are kept out of the reach of children.
• If your child has an electrical device that they wish to bring into the setting please let me know, so that we can work together to ensure the safety of all children in my care
• I will permit children from the age of 11 years (agreed with parents) to have their electronic devices about their person. However, it must not be used to take photos or access the internet.
• I have registered with the Information Commissioners Office as a data controller in line with the GDPR

If you have any concerns regarding this policy, I will be happy to meet and discuss them with you.

Childminder's signature: F. G. Rogers                                                                                      Date: 25th January 2024

Phone Numbers 

For Immediate Referrals: DCC - Request for support (outsystemsenterprise.com)

MASH:                                                                                                                                  0345 155 1071

                                                                                                        e-mail: mashsecure@devon.gov.uk

Out of hours: (5pm-9am; weekends; public holidays)   

CYPS Emergency Duty Service                                                                                         0845 6000 388

In the case of an Allegation:

LADO (Local Authority Designated Officer)                                                                           01392 384964

For Advice & Guidance:

MASH Consultation line for professionals:                                                                         01392 388428

Devon Early Years Locality Manager:     

Exeter East & Mid Devon and Northern Devon                                     Nikki Phillips     01392 385394

South, West & Teignbridge                                                                       Sue Bolt           01392 384046 

Holiday Activities and Food Programme Co-ordinator                        Melissa Filby    01392 388461                     

Devon Children and Families Partnership                                                                       01392 386067

Devon Domestic Abuse Support Services                                                                       0345 155 1074       

                                                                                                           (Ask for Domestic Abuse Helpline)

                             Website Devon Domestic Abuse Helpline

Early Help Hub In each of the four localities – Northern, Exeter, East and Mid, and Southern – there are Early Help Hubs, where the Early Help Locality Officers and Family Intervention Teams information on these hubs is available from –  Devon Safeguarding Children Partnership, or Devon SCP for short.

Useful Contacts: 

Devon Children and Families Partnerships 

South West Child Protection Procedures  

Devon Early Years and Childcare Service 

Child Exploitation and Online Protection Agency  

NSPCC 

CHILDWISE - a leading specialist in research with children and young people - ABOUT 

Annexe 1 Categories of Abuse   

Categories of Abuse: 

• Physical Abuse
• Emotional Abuse (including Domestic Abuse)
• Sexual Abuse (including child sexual exploitation)
• Neglect 

Signs of Abuse in Children: 

The following non-specific signs may indicate something is wrong: 

• Significant change in behaviour
• Extreme anger or sadness
• Aggressive and attention-needing behaviour
• Suspicious bruises with unsatisfactory explanations
• Lack of self-esteem
• Self-injury
• Depression and/or anxiousness
• Age-inappropriate sexual behaviour
• Child Sexual Exploitation
• Criminality
• Substance abuse
• Mental health problems
• Poor attendance 

Neglect - The persistent failure to meet a child's basic physical and psychological needs, likely to result in the serious impairments of the child's health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: 

• provide food, clothing and shelter;
• protect a child from physical and emotional harm or danger; 
• ensure adequate supervision; 
• ensure access to appropriate medical care or treatment. 

Possible indicators of Neglect Obvious signs of lack of care including: 

Problems with personal hygiene, constant hunger, inadequate clothing, emaciation, lateness or non-attendance at the setting, poor relationship with peers, untreated medical problems, compulsive stealing and scavenging, rocking, hair twisting, thumb sucking, running away, low self-esteem, etc.

Physical Abuse - May involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces illness in a child. 

Possible Indicators Physical signs that do not tally with the given account of occurrence conflicting or unrealistic explanations of cause repeated injuries delay in reporting or seeking medical advice. 

Sexual abuse and exploitation

Sexual abuse - involves forcing or enticing a child or young person to participate in sexual activities, whether or not the child is aware of what is happening, and does not necessarily involving a high level of violence. This may include physical contact, both penetrative and non-penetrative, or viewing pornographic material online or watching sexual acts. 

Possible indicators of Sexual Abuse  Sudden changes in behaviour, displays of affection which are sexual and age inappropriate, tendency to cling or need constant reassurance, allegations or disclosures, genital/anal soreness, sexually transmitted diseases, and inappropriate sexualised behaviour, including words, play or drawing. Tendency to cry easily, regression to younger behaviour – e.g. thumb sucking, acting like a baby, unexplained gifts or money, depression and withdrawal, wetting/soiling day or night, fear of undressing for PE etc. 

Emotional Abuse - The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child's emotional development. It may involve conveying to children that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. 

Possible Indicators of Emotional Abuse Rejection, isolation, child being blamed for actions of adults, child being used as carer for younger siblings, affection and basic emotional care giving/warmth, persistently absent or withheld. 

Annexe 2 Current Safeguarding Issues 

(This section highlights optional extras that Settings may consider adopting to accompany their Safeguarding policy) 

The following Safeguarding issues are all considered to be child Protection issues and should be referred immediately to the most relevant agency. The issues featured below are linked to guidance and local procedures which can be found on the South West Child Protection Procedures  

E-Safety Children and young people can be exploited and suffer bullying through their use of modern technology such as the internet, mobile phones and social networking sites. In order to minimize the risks to our children and young people Oak Trees and Acorns Childcare will ensure that we have in place appropriate measures such as security filtering, and an acceptable use policy linked to our E-Safety policy. We will ensure that staff are aware of how not to compromise their position of trust in or outside of the setting and are aware of the dangers associated with social networking sites. 

Our E-safety policy will clearly state that mobile phone, camera or electronic communications with a child or family at our setting is not acceptable other than for approved setting business. Where it is suspected that a child is at risk from internet abuse or cyber bullying, we will report our concerns to the appropriate agency. 

Child sexual exploitation (CSE) The sexual exploitation of children and young people under 18 involves exploitative situations, contexts and relationships where young people, (or a third person or persons) receive something, (e.g. food, accommodation, drugs, alcohol, cigarettes, affections, gifts, money) as a result of them performing and/or others performing on them, sexual activities. Child sexual exploitation can occur through the use of technology without the child’s immediate recognition; for example, being persuaded to post sexual images on the internet/mobile phones without immediate payment or gain. In all cases those exploiting the child/young person have power over them by virtue of their age, gender, intellect, physical strength and/or economic or other resources. Violence, coercion and intimidations are common, involvement in exploitative relationships being characterised in the main by the child’s or young person’s limited availability of choice, resulting from their social/economic and/or emotional vulnerability. 

Good practice – Individuals Recognise the symptoms and distinguish them from other forms of abuse 

• Treat the child/young person as a victim of abuse
• Understand the perspective / behaviour of the child/young person and be patient with them
• Help the child/young person to recognise that they are being exploited
• Collate as much information as possible
• Share information with other agencies and seek advice / refer to Social Care 

Good practice – Organisations 

• Ensure robust safeguarding policies and procedures are in place which cover CSE
• Promote and engage in effective multi-agency working to prevent abuse
• Work to help victims move out of exploitation
• Cooperate to enable successful investigations and prosecutions of perpetrators 

Peer on Peer Abuse Children can abuse other children, and this is referred to as ‘peer on peer abuse’ this can take many forms including those listed in the table above as well as bullying, sexual violence and harassment etc. Staff will raise concerns when there are issues of peer-on-peer abuse and DSL’s will consider what support might be needed for both the victim and perpetrators. 

Forced marriages (FM) FM is now a specific offence under s121 of the Anti-Social Behaviour, Crime and Policing Act 2014 that came into force on 16 June 2014. 

A FM is a marriage conducted without the valid consent of one or both parties, and where duress is a factor Forced marriage is when someone faces physical pressure to marry (e.g. threats, physical violence or sexual violence) or emotional and psychological pressure (e.g. if someone is made to feel like they’re bringing shame on their family). This is very different to an arranged marriage where both parties give consent.

FM is illegal in England and Wales. This includes: 

• taking someone overseas to force them to marry (whether or not the forced marriage takes place)
• marrying someone who lacks the mental capacity to consent to the marriage (whether they’re pressured to or not) 

Under-age Marriage In England, a young person cannot legally marry until they are 16 years old (without the consent of their parents or carers) nor have sexual relationships.

Female Genital Mutilation (FGM) FGM is child abuse and a form of violence against women and girls, and therefore should be dealt with as part of existing child safeguarding/protection structures, policies and procedures. 

FGM is illegal in the UK. In England, Wales and Northern Ireland, the practice is illegal under the Female Genital Mutilation Act 2003. 

Other than in the excepted circumstances, it is an offence for any person (regardless of their nationality or residence status) to: 

• perform FGM in England, Wales or Northern Ireland (section 1 of the Act);
• assist a girl to carry out FGM on herself in England, Wales or Northern Ireland (section 2 of the Act); and
• Assist (from England, Wales or Northern Ireland) a non-UK person to carry out FGM outside the UK on a UK national or permanent UK resident (section 3 of the Act). 

Ritualistic Abuse Some faiths believe that spirits and demons can possess people (including children). What should never be considered is the use of any physical or psychological violence to get rid of the possessing spirit. This is abusive and will result in the criminal conviction of those using this form of abuse even if the intention is to help the child.

Sexually Active under Eighteen years old It is acknowledged by those working with young people that most young people under the age of 18 will have an interest in sex and sexual relationships. The Protocol for Sexually Active Young People under 18 years old has been designed to assist those working with children and young people to identify where these relationships may be abusive, and the children and young people may need the provision of protection or additional services. 

Safer Recruitment and Selection It is a requirement for all agencies to ensure that all staff recruited to work with children and young people are properly selected and checked. We will ensure that we have a member on every recruitment panel who has received the appropriate recruitment and selection training. That all of our staff are appropriately qualified and have the relevant employment history and checks to ensure they are safe to work with children in compliance with the Key Safeguarding Employment Standards.

Honour Based Violence Honour based violence’ is a crime or incident, which has or may have been committed to protect or defend the honour of the family and/or community’. It is important to be alert to signs of distress and indications such as self-harm, absence from setting, infections resulting from female genital mutilation, isolation from peers, being monitored by family, not participating in setting activities, unreasonable restrictions at home. Where it is suspected that a child/young person is at risk form Honour based violence we will report those concerns to the appropriate agency in order to prevent this form of abuse taking place.

Trafficked Children Child trafficking involves moving children across or within national or international borders for the purposes of exploitation. Exploitation includes children being used for sex work, domestic work, restaurant/ sweatshop, drug dealing, shoplifting and benefit fraud. Where we are made aware of a child is suspected of or actually being trafficked/exploited we will report our concerns to the appropriate agency.

Domestic Abuse The Government defines domestic abuse as “Any incident of threatening behaviour, violence or abuse (psychological, physical, sexual, financial or emotional) between adults who are or have been intimate partners or family members regardless of gender or sexuality”. 

Staff need to understand what is required of them if children are members of the household where domestic abuse is known or suspected to be taking place. Our policy includes action to be taken regarding referrals to the Police and Children and Young People’s Services and any action to be taken where a member of staff is the alleged perpetrator or victim of domestic abuse. At Oak Trees and Acorns we will follow our safeguarding policy and report any suspected concerns regarding Domestic Abuse to the relevant agency.

Private Fostering Private fostering is an arrangement made between the parent and the private foster carer, who then becomes responsible for caring for the child in such a way as to safeguard and promote his/her welfare.

A privately fostered child means a child under the age of 16 (18 if a disabled child) who is cared for and provided with accommodation by someone other than:

• A parent.
• A person who is not a parent but has parental responsibility.
• A close relative.
• A Local Authority. 

for more than 28 days and where the care is intended to continue. It is a statutory duty for us to inform the Local Authority via MASH where we are made aware of a child or young person who may be subject to private fostering arrangements.

                                                                                                                                                             Date: January 2024 

Review Date: When advised by DCC, Support Services or when regulations change