Child Protection & Safeguarding Policy

CONTENTS

Section 1 – Policy & Principles

• Policy Statement & Legal Requirements
• Principles
• Definitions
• Role of the Board, Chief Executive and Designated Safeguarding Lead

Section 2 – Guidance and awareness

• Knowledge
• Abuse of Trust
• Professional Responsibilities
• Informing DofE about serious safeguarding incidents
• Children who may be particularly vulnerable
• Preventing Radicalisation
• Sexual violence and sexual harassment between children
• Other specific safeguarding issues

Section 3 – Recruitment & Staff Training

• Safer Recruitment
• Staff Training
• Extended school, off-site arrangements, and external speakers
• Photography and images
• Online safety

Section 4 - CHILD PROTECTION

• Taking Action
• If you suspect a child has been harmed
• If a child discloses to you
• Notifying parents
• Referring to Children’s Services
• Concerns about colleagues
• Allegations against staff
• Section 5 – Record Keeping, Confidentiality and Information Sharing

• APPENDIX 1 – Children’s Services Contact Numbers - Including Vulnerable Adults, Channel referrals and if you suspect CSE (Child Sexual Exploitation)
• APPENDIX 2 – Steps to Dealing with a Disclosure
• APPENDIX 3 Legislation

Section 2 – Guidance and Awareness

Knowledge

To meet and maintain our responsibilities towards learners we work to standards of good practice which are aligned to national child protection, safeguarding and prevent guidance, which apply to all staff and cover all learners. Through induction, comprehensive and regular training, updates, communications, meetings, policy, procedure, leadership, and culture we will ensure that all adults working in or on behalf of Training 2000 will have the requisite knowledge to undertake their duty in respect of child protection, safeguarding and prevent.

As a minimum all staff will:

• recognise that everyone has a role to play in identifying concerns, sharing information, and taking prompt action
• understand the specific duty of care we have for children under 18
• provide a safe environment in which learners can learn, conduct themselves appropriately within professional boundaries and encourage positive and safe behaviour among learners
• be prepared to identify children who may benefit from early help and be alert to changes in learner’s behaviour and be particularly alert to the potential need for early help for a learner who has additional support needs / circumstances (e.g. disability, mental health need, young carer, family / home circumstances, is at risk of exploitation or radicalisation, is frequently absent, risk taking behaviours)
• be aware of systems, policies, and procedures (including KCSinEP1) which support safeguarding
• participate and engage in safeguarding and training updates
• understand the four categories of abuse: neglect, emotional abuse, sexual abuse, physical abuse and have the knowledge, skills, and expertise to recognise the signs and symptoms of all types of abuse
• be aware that technology is a significant component in many safeguarding and wellbeing issues
• Understand the expectations, applicable roles and responsibilities in relation to filtering and monitoring
• be aware of Child-on-Child abuse, Child Sexual Exploitation, Child Criminal Exploitation, Domestic Abuse, Female Genital Mutilation, Mental Health, and Serious Violence.
• understand that there are other safeguarding issues that can put a child at risk of harm and that certain behaviours linked to issues such as drug taking and/or alcohol misuse, missing education, and serious violence (including that linked to county lines) can be signs that learners are at risk.
• understand that regarding any concerns about female genital mutilation (FGM), there is a specific legal duty on teachers.
• be aware that mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.
• recognise and understand that behaviour can be a learner's way of communicating distress and changes to behaviour may be an indicator of abuse
• understand that safeguarding issues are not stand-alone issues, but they frequently overlap
• be aware that technology is a significant component in many safeguarding and wellbeing issues
• know what to do if a child tells them they are being abused, exploited, or neglected and how to maintain an appropriate level of confidentiality, reassure victims that they are being taken seriously and that they will be supported and kept safe
• involve young people in decisions that affect them and ensure the learners feelings and wishes are considered
• be aware and sensitive of different cultures and different communities
• share concerns immediately with the DSL/ DDSL/ DO(s); and in their absence make an immediate referral to Local Authority children’s services or other agencies (see APPENDIX 1)

The NSPCC website has advice about the signs, symptoms and effects of child abuse and neglect.

Abuse of Trust

• All staff will be made aware that inappropriate behaviour towards learners is unacceptable and that their conduct towards learners must be beyond reproach.
• In addition, staff should understand that, under the Sexual Offences Act 2003, it is an offence for a person over the age of 18 to have a sexual relationship with a person under the age of 18, where that person is in a position of trust, even if the relationship is consensual. This means that any sexual activity between a member of staff and a learner under 18 may be a criminal offence, even if that young person is over the age of consent.
• All staff read, understand, and abide by the Staff Use of Electronic Communication and social media (PR/GN.74).

Professional Responsibilities

Section 11 of the Children’s Act 2004 creates a statutory duty for all organisations that work with children, to share a commitment and responsibility to safeguard and promote their welfare.

• All staff have been presented with Part 1 of Keeping Children Safe in Education (KCSIE) and asked to acknowledge their understanding of its contents. It is very important to keep up to-date with current issues which can impact on a young person’s wellbeing and safety.
• Wherever possible we will communicate to staff to make them aware of the local and national picture which includes the Prevent agenda.

Informing DofE about serious safeguarding incidents

• The DofE includes safeguarding clauses in the funding agreements and contract. Whilst the local authority and the institution have primary duties in respect of safeguarding, the Secretary of State (SoS) has a general duty to promote the wellbeing of children in England under section 7 of the Children and Young Persons Act 2008.
• The DofE’s role is to provide assurance to the SoS, in meeting this general duty, that the right organisations are taking action to keep all learners safe. For this reason, the Training 2000 Chair, CEO or DSL must inform the DofE when Training 2000 is the subject of an investigation by the local authority or the police.
• In such circumstances, the Chair, CEO or DSL must email EFA@education.gov.uk with the name of the institution, the nature of the incident and confirmation that it is or is scheduled to be investigated by the local authority and/or the police. (There should be no requirement for any information that could be used to identify individuals or any information that will impact on our data protection duties.)

Information to be provided to DofE about Prevent referrals to channel panels

• The DofE will only require institutions to inform them when we, or one of our subcontractors, is the subject of an investigation by the local authority or the police in connection with a Prevent issue. In such circumstances, the Chair, CEO or DSL must email EFA@education.gov.uk

Children who may be particularly vulnerable

• Many factors can contribute to an increase in risk, including prejudice and discrimination, isolation, social exclusion, communication issues and reluctance on the part of some adults to accept that abuse can occur.
• To ensure that all of our learners receive equal protection, we will give special consideration to young people who are vulnerable to abuse because of their age, health, physical or mental abilities, race, ethnicity, religion, or sexuality; those being bullied or those regularly absent from learning.
• Children Missing from Education (CME) can be a potential sign of abuse or neglect including sexual exploitation, undergoing female genital mutilation, forced marriage, or travelling to conflict zones.
• ALL staff must follow procedures when a child misses’ education particularly on repeat occasions to help identify the risk of abuse and neglect
• The Learner Attendance and punctuality on Funded Programmes policy (PR/TR.34) is up to date, reviewed regularly and includes the reporting process for CME.

Training 2000 is committed to keeping our children safe from specific forms of abuse. We therefore ensure that ALL staff understand that there are specific and emerging ways in which children can be abused, such as:

Radicalisation - refers to the process by which a person comes to support terrorism and forms of extremism, there is no single way of identifying an individual who is likely to be susceptible to an extremist ideology.

• ALL staff will have 'due regard to the need to prevent people from being drawn into terrorism,’ known as the ‘Prevent Duty’
• ALL staff will have a general understanding of how to identify a child who may be at risk of radicalisation
• ALL staff will use professional judgement in identifying learners who might be at risk of radicalisation and act proportionately
• Training 2000 will ensure the safety of learners online by preventing their access to terrorist and extremist material when using the internet and that suitable filtering software is in place
• DSL/ DDSL/ DOs understand when it is appropriate to make a referral to the Channel Panel

Sexual violence and sexual harassment between children (young people) - Child on Child Abuse occurs when a young person is exploited, bullied and / or harmed by their peers who are the same or similar age; everyone directly involved in peer-on-peer abuse is under the age of 18.

• ALL staff will understand that children can abuse other children
• ALL staff will inform the DSL/DDSL/ DO of any child-on-child abuse concerns
• All staff will understand the importance of challenging inappropriate behaviours between children
• Child on child abuse will be taken as seriously as any other form of abuse
• Harmful sexual behaviour will be identified and managed with support and guidance from the DSL/DDSL/ DO
• Sexting will be managed on a case-by-case basis using national and local guidance and advice
• In cases of suspected or actual peer on peer abuse a risk assessment will be undertaken and appropriate and proportionate control measures put in place to manage and reduce risk. Seek advice from LCC Schools Safeguarding Officer
• Referrals to Children's Social Care, Police and/or other appropriate agencies will be made where necessary or otherwise managed under Training 2000's Behaviour and Disciplinary Policy

Modern Slavery

Modern Slavery and the National Referral Mechanism Modern slavery encompasses human trafficking and slavery, servitude and forced or compulsory labour. Exploitation can take many forms, including sexual exploitation, forced labour, slavery, servitude, forced criminality and the removal of organs. Further information on the signs that someone may be a victim of modern slavery, the support available to victims and how to refer them to the NRM is available in Statutory Guidance.

Modern slavery: how to identify and support victims - GOV.UK (www.gov.uk)

Child Sexual Exploitation & Child Criminal Exploitation

Both CSE and CCE are forms of abuse that occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into taking part in sexual or criminal activity, in exchange for something the victim needs or wants, and/or for the financial advantage or increased status of the perpetrator or facilitator and/or through violence or the threat of violence.

All staff should be aware of the indicators, which may signal children are at risk from, or are involved with, serious violent crime including those associated with county lines

Criminal exploitation of children and vulnerable adults: county lines - GOV.UK (www.gov.uk)

Female Genital Mutilation (FGM)

Whilst all staff should speak to the designated safeguarding lead (or a deputy) regarding any concerns about female genital mutilation (FGM), there is a specific legal duty on teachers. If a teacher, in the course of their work in the profession, discovers that an act of FGM appears to have been carried out on a girl under the age of 18, the teacher must report this to the police.

Mental Health

All staff should be aware that mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.

Additional information and support

Departmental advice What to Do if You Are Worried a Child is Being Abused

The NSPCC website also provides useful additional information on abuse and neglect and what to look out for.

Keeping Children Safe in Education Annex B contains important additional information about specific forms of abuse and safeguarding issues.

Staff should also know what to do when a child may or has been harmed and should follow guidance in section 4

Section 4 – Child Protection

Taking action - Key points for staff to remember for taking action are:

• in an emergency take the action necessary to help and protect the young person, for example, call 999
• report your concern to the DSL/DDSL/DO immediately; at Training 2000 a DSO will always be on duty during business hours, if in extreme circumstances the no-one is available contact Children’s Services or other appropriate agency (if concern relates to Prevent or CSE for example) Report child abuse - GOV.UK (www.gov.uk)
• do not start your own investigation
• share information on a need-to-know basis only – do not discuss the issue with colleagues, friends, or family
• complete a Cause for Concern form (FM/TR.177) or Child Protection Disclosure Form (FM/GN.190) if a disclosure has been made. NB It is understood that you may not have a copy of this form to hand or be able to obtain one immediately, if that is the case, please document the concern on paper or electronically and share with DSL/DDSL/ DSO
• seek support for yourself if you are distressed

If you suspect a young person is at risk of harm

There will be occasions when staff may suspect that a learner may be at risk of physical, emotional, sexual abuse or neglect (ref. Keeping children safe in education, part 1), but have no ‘real’ evidence. The learner’s behaviour may have changed, their work could be bizarre or concerning, or physical but inconclusive signs may have been noticed. In these circumstances, staff will give the learner the opportunity to talk. The signs they have noticed may be due to a variety of factors, for example, a parent has moved out, a pet has died, a grandparent is extremely ill. It is fine for staff to ask the learner if they are okay or if they can help in any way.

What to do if you think a child is being abused:

Stat guidance template (publishing.service.gov.uk)

If a young person discloses to you

It takes a lot of courage for a child to disclose that they are being abused. If a young person talks to a member of staff about any risks to their safety or wellbeing, the staff member will need to let the learner know that they must pass the information on – staff are not allowed to keep secrets.

The point at which they tell the learner this is a matter for professional judgement. If they jump in immediately the young person may think that they do not want to listen, if left until the very end of the conversation, the young person may feel that they have been misled into revealing more than they would have otherwise.

During their conversations with the young person staff will:

• allow them to speak freely
• remain calm and collected – the young person may stop talking if they feel they are upsetting their listener
• give reassuring nods or words of comfort – ‘I’m so sorry this has happened,’ ‘I want to help,’ ‘This is not your fault,’ ‘You are doing the right thing in talking to me’
• not be afraid of silences – staff must remember how hard this must be for the young person
• under no circumstances ask investigative questions – such as how many times this has happened, whether it happens to siblings too, or what does the young person’s mother think about all this
• tell the young person that in order to help them, the member of staff must pass the information on
• do not automatically offer any physical touch as comfort. It may be anything but comfort to a young person who has been abused
• avoid admonishing the child for not disclosing earlier.
• tell the young person what will happen next. The young person may agree to go to see the designated senior person. Otherwise, it is the duty of the member of staff to inform the DSL/DDSL/ DSO of what has been discussed. If the young person does agree to see the designated person, the staff member should inform the DSL/DDSL/DSO that the young person will be coming to see them at some point
• report verbally to the DSL/DDO/DSO even if the young person has promised to do it by themselves
• write up their conversation, using the same language as the young person (regardless of how explicit this was), as soon as possible on the CHILD PROTECTION DISCLOSURE FORM – FM/GN.190 and hand it to a designated person. Do not take a copy of the form. NB It is understood that you may not have a copy of this form to hand or be able to obtain one immediately, if that is the case, please document the concern on paper or electronically and share with DSL/DDSL/ DSO seek support if they feel distressed (See Appendix 2)

Notifying parents

Training 2000 will normally seek to discuss any concerns about a young person with their parents. This must be handled sensitively, and the DSL/ DSO will make contact with the parent in the event of a concern, suspicion, or disclosure. However, if Training 2000 believes that notifying parents could increase the risk to the young person or exacerbate the problem, advice will first be sought from children’s services (See Appendix 1); refer also to Section 5 Confidentiality and Information Sharing

Referral to children’s services

The DSL/ DSO will make a referral to children’s services (or appropriate agency) if it is believed that a young person is suffering or is at risk of suffering significant harm. The young person (subject to their age and understanding) and the parents will be told that a referral is being made, unless to do so would increase the risk to the young person.

Report child abuse - GOV.UK (www.gov.uk)

Staff will follow the reporting procedures outlined in the policy. However, they may also share information directly with children’s services, police, or the NSPCC if:

• The situation is an emergency and in the extreme circumstances that the DSL, DSO’s, the CEO, and the chair of the Board are all unavailable
• They are convinced that a direct report is the only way to ensure the young person’s safety.

Concerns about a Colleague

Staff that are concerned about the conduct of a colleague towards a learner should always act immediately and in the best interest of the child. They may worry that they have misunderstood the situation and they will wonder whether a report could jeopardise their colleague’s career.

• All staff must remember that the welfare of the young person is paramount and that they have a duty to respond and inform the Designated Safeguarding Lead (DSL).
• The Whistleblowing Policy (PR/GN41) is available on the intranet and enables staff to raise concerns or allegations in confidence and for a sensitive enquiry to take place. The whistle blowing policy can be used to raise concerns about any safeguarding practice at Training 2000.
• All concerns of poor practice or possible child abuse by colleagues should be reported to the DSL.
• Complaints about the DSL or CEO should be reported to the Board of Trustees.

Allegations against staff

When an allegation is made against a member of staff, set procedures must be followed. It is rare for a young person to make an entirely false or malicious allegation, although misunderstandings and misinterpretations of events do happen.

• A young person may also make an allegation against an innocent party because they are too afraid to name the real perpetrator. Even so, we must accept that some professionals do pose a serious risk to learners, and we must act on every allegation. Staff who are the subject of an allegation have the right to have their case dealt with fairly, quickly, and consistently and to be kept informed of its progress.
• Allegations against staff must be reported immediately to the DSL or in her absence the Deputy DSL, they will immediately inform the HR (Human Resources) Business Partner and it will be determined if the allegation needs to be referred to the LADO.
• Allegations that do not meet the LADO harm threshold will be investigated in accordance with the Disciplinary Procedures.
• Where an allegation relates to an employer or sub-contractor the DSL/DDSL/DSO must be notified immediately.

APPENDIX 1: LANCASHIRE – CONTACT NUMBERS

If a child is at immediate risk, contact the police on 999

Reporting abuse if the person is a vulnerable adult (over 18 years of age)

Lancashire Adult Social Care Services - Telephone 0300 123 6720

channelreferrals@lancashire.pnn.police.uk

For advice on preventing radicalisation or reporting concerns in Lancashire please email concern@lancashire.pnn.police.uk

Call our Prevent team on the number for advice or support: 01772 413398

channelreferrals@lancashire.pnn.police.uk

Or

• The police non-emergency number 101
• Anti-terrorism hotline 0800 789 321

More information can be found on the Lancashire Constabulary website

CSE – Contact Telephone numbers for Lancashire – dependent on which area

APPENDIX 2

CHILD PROTECTION & SAFEGUARDING

STEPS TO DEALING WITH A DISCLOSURE

APPENDIX 3

Statutory Guidance

• Education Act 2002: Section 175 of the Education Act 2002 requires local education authorities and the governors of maintained schools and further education (FE) colleges to make arrangements to ensure that their functions are carried out with a view to safeguarding and promoting the welfare of children.
• Working Together to Safeguard Children 2018: statutory guidance which sets out key roles for individual organisations and agencies to deliver effective arrangements for safeguarding
• Children and Young Persons Act 2008: section 11
• Keeping children safe in education: Statutory guidance for schools and colleges. This contains information on what schools and colleges should do and sets out the legal duties with which schools must comply
• What to do if you are worried a child is being abused
• Guidance for Safer Working Practice
• The Children Act 1989
• The Children Act 2004: section 11
• The Children and Families Act 2014
• Counterterrorism and Security Act 2015 (“the CTSA 2015”): section 26.
• Apprenticeships, Skills, Children and Learning Act 2009: Part 9
• Sexual Offences Act 2003
• The Modern Slavery Act 2015

Document Review

Review frequency: This document must be reviewed within 1 year of the approval date.

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