SCL CHILD PROTECTION AND SAFEGUARDING POLICY AND PROCEDURE FOR CHILDREN AND VUNERABLE ADULTS JUNE 2024 | VERSION 1
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VERSION CONTROL VERSION AUTHOR
TITLE
DATE
COMMENTS
Draft 1.0 Saira Bashir Director of Safeguarding March 24 Final 1.0 Saira Bashir Director of Safeguarding June 24
Version control is to be employed for any amendments to the content which result in substantive changes to the meaning, intent or outcome of the policy or process described within and must be approved by the Executive Committee. Spelling mistakes or other typographical errors are not required to be subject to Version Control.
POLICY OWNER POLICY OWNER
ACCOUNTABLE EXECUTIVE
Saira Bashir
Stuart Allen, CEdO
APPROVAL CONTROL Approval of this Policy and subsequent amendments is by the Board DATE APPROVED APPROVED REQUIRED BY
POLICY
ACCOUNTABLE EXECUTIVE
DATE OF REVIEW APPROVED REQUIRED BY
REVIEWER Director of Safeguarding
June 25 June 25
CedO
Safeguarding Governor
CEO
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CONTENTS INTERNAL KEY CONTACTS ..............................................................................................................................................................4 EXTERNAL KEY CONTACTS .............................................................................................................................................................5 SECTION ONE - POLICY COMMITMENT..................................................................................................................................6 Purpose .....................................................................................................................................................................................................7 Scope .........................................................................................................................................................................................................7 Breaches ..................................................................................................................................................................................................8 Equality, Diversity & Inclusion ...................................................................................................................................................8 SCL Provisions .......................................................................................................................................................................................9 Associated Policies and Procedures ................................................................................................................................ 10 Legal and Statutory Guidance ................................................................................................................................................11 Key Definitions.................................................................................................................................................................................... 12 Overview of Safeguarding Roles and Responsibilities ........................................................................................ 13 Mandatory Training ...................................................................................................................................................................... 15 Safer Recruitment ...........................................................................................................................................................................16 Prevent Duty ........................................................................................................................................................................................16 Confidentiality and Information Sharing....................................................................................................................... 17 Electronic Systems and Online Safety ............................................................................................................................. 18 SECTION TWO - SAFEGUARDING PROCEDURES ............................................................................................................19 Early Help and Additional Vulnerabilites ......................................................................................................................20 Child on Child Abuse .........................................................................................................................................................20 Mental Health ........................................................................................................................................................................... 21 Missing in Education ........................................................................................................................................................... 21 Non Recent Abuse ................................................................................................................................................................ 21 Barriers to Reporting ................................................................................................................................................................... 22 Responding and Reporting Concerns - 5 R's ............................................................................................................ 22 What To Do If You Are Concerned About a Child or Vulnerable Adult - Flowchart......................24 SECTION THREE - SAFEGUARDING PROCEDURES ........................................................................................................25 Aim .....................................................................................................................................................................................................26 Defining A Safeguarding Allegation Against Colleagues................................................................................ 27
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Initial Considerations...................................................................................................................................................................28 Safeguarding Allegations or Behaviour Related To Poor Practice............................................................28 Lower-Level Concerns ................................................................................................................................................................28 Flowchart – What To Do If An Allegation Is Made About A Colleague, Including A Lower – Level Concern....................................................................................................................................................................................30 Managing An Allegation Once Reported ...................................................................................................................... 31
INTERNAL KEY CONTACTS
Title
Role
Contact Email
Safeguarding Support Line and Email Director of Safeguarding
Advice, support and to report a concern
Safeguarding@wearescl.co.uk 0800 368 8745 (9am – 5pm) Saira.Bashir@wearescl.co.uk Lesley.hurst@wearescl.co.uk Andrew.cooper@wearescl.co.uk
Senior Designated Safeguarding lead
Head of Safeguarding
Designated Safeguarding Lead
Safeguarding Prevent Lead
Deputy Designated Safeguarding Lead
Safeguarding Residential Lead Regional Safeguarding Officer NORTH Regional Safeguarding Officer MIDLANDS Regional Safeguarding Officer SOUTH
Deputy Designated Safeguarding Lead
Chelsea.evans@wearescl.co.uk
Deputy Designated Safeguarding Lead
Tricia.egan@wearescl.co.uk
Deputy Designated Safeguarding Lead
Sheree.aldridge@wearescl.co.uk
Deputy Designated Safeguarding Lead
Justin.thornberry@wearescl.co.uk
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EXTERNAL KEY CONTACTS
Title
Role
Contact Email and Telephone
Local authority Children’s Social Care (England) Local authority Adult’s Social Care (England)
See website
Use the following website to find out the details: https://www.gov.uk/report-child-abuseto-local-council
Use the following website to find out the details https://www.gov.uk/report-abuse-of-older-person 10am – 8pm Monday to Friday helpline for advice on child protection matters for professionals and vulnerable adults and to report abuse 24-hour helpline for children and young people Advice can be sought from NSPCC if using SCL Whistleblowing Procedure has not resolved the concern Provides advice for professionals and responds to reports about sexual abuse images of children online Investigates inappropriate online behaviours such as grooming online or sexual exploitation
See website
NSPCC Helpline
0808 800 5000, emailing help@NSPCC.org.uk
ChildLine
800 1111
Whistle blowing advice line (external) The UK Safer Internet Centre Child Exploitation and Online Protection Centre (CEOP) Disclosure and Barring Service (DBS)
0800 028 0285
0844 381 4772
0870 000 3344
Advice line for criminal records checks
03000 200 190
Ofsted
Report to regulator about a complaint
enquiries@ofsted.gov.uk 0300 123 4666
HEADING
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SECTION ONE POLICY COMMITMENT
CONTENT
PAGE
Purpose
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Scope
7-8
Breaches
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Equality, Diversity, and Inclusion
8-9
SCL Provisions
9-10 10-11 11-12 12-13 13-15 15-16
Associated Policies and Procedures Legal and Statutory Guidance
Key Definitions
Overview of Safeguarding Roles and Responsibilities
Mandatory Training Safer Recruitment
16 16
Prevent Duty
Confidentiality and Information Sharing Electronic Systems and Online Safety
17-18
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PURPOSE
At SCL, we provide diverse national programmes where we serve and positively impact on the prospects of millions of children and vulnerable adults. We do this through delivering high quality education, inspired by sport, E Sport, creative arts and other provisions, with their safety and wellbeing at the forefront of everything we do. Therefore, it is important that all colleagues working for or on behalf of SCL, recognise their moral and statutory responsibility to safeguarding and promoting the welfare of everyone we come into contact with, whether that is inside or outside of SCL, including online. The purpose of implementing this policy and procedure is to provide a safe and supportive environment where everyone is respected, valued, and has a voice. We believe, no individual should ever experience abuse or harm of any kind and we are therefore fully committed to practising in way that keeps them safe and protected. SCL provide holistic co-ordinated approach to safeguarding, offering early help and preventative and responsive approaches, in the best interest of children and vulnerable adults. This Policy and Procedure contains the following: • Section One : Policy Commitment - Information relevant to the provisions SCL offer, safeguarding roles and responsibilities and what systems and processes SCL have in place to ensure everyone’s safety and wellbeing. • Section Two : Procedures - What to do if you are concerned about child or vulnerable adult. • Section Three : Procedures – What to do if an allegation is made about a colleague, including a lower-level concern.
SCOPE
Throughout the policy and procedures, the terms Learner/Learners are described to refer to all our children and vulnerable adults in education. The terms Child/Children are referred to for those accessing our Active provision which provides wrap around care from Holiday Clubs and Term Time Services for 4–11-year-olds. This policy and procedure applies to all colleagues , this is an all-inclusive term to refer to, employees, the term stakeholders refers to non SCL colleagues such as Subcontractor, Contractor, External Staff and Third Parties. For the purpose of this policy, when referring to all colleagues , this will be inclusive of employed colleagues and non SCL colleagues/stakeholders. These policy and procedures give a clear direction to al about expected behaviours, in line with our statutory and legal responsibility to safeguarding and promote the welfare of all
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children and learners accessing our provisions alongside geographical Local Authority safeguarding arrangements. We have a specialist dedicated safeguarding team to who support colleagues to ensure all those on our programmes are safe. Our governance and various boards, follow an ethos and promote a culture where everyone feels safe, comfortable to be heard and know they will be listened to. The voice of the child and learner is of upmost importance and therefore their wishes and feelings are considered when a safeguarding concern arises. SCL have systems and processes in place which promote and are easily accessible for children and learners to directly and confidently report a safeguarding issues or abuse, knowing they can safely express their views and give feedback. It is the responsibility of all colleagues to act if there is a cause for concern in relation to the poor behaviour and misconduct in relation to colleagues towards a child or learner. However, it is not the responsibility of colleagues to determine if abuse or harm has occurred. Colleagues are required to act and report to the dedicated safeguarding team, who will assess the situation and decide whether to escalate to the appropriate authorities, monitor, or take other action. This may be done in collaboration with colleagues and with their ongoing support and input. Concerns can be reported here Safeguarding@wearescl.co.uk. Internal and external safeguarding contact details are provided at the front of this policy and procedure. All colleagues are advised to maintain an attitude of ‘it is my responsibility’, ‘it could happen here’ and ‘professional curiosity’ where safeguarding is concerned.
BREACHES
All colleagues are obliged to comply with these policies and procedures as specified and agreed within their employment contract or other contractual agreements with SCL. Failure to comply will be addressed without delay and may result in formal action, dismissal, or exclusion as per SCL’s Colleagues Disciplinary and Dismissal Procedures. If appropriate, a referral to relevant authorities and regulatory bodies will also be made.
EQUALITY, DIVERSITY & INCLUSION
SCL promotes and works with children and learners from a diverse range of backgrounds and needs and as such, we are committed to equality of opportunity in every aspect of our activities. We believe everyone has the right to live without fear, prejudice, or discrimination regardless of their protected characteristics of race, age, gender, disability, sexual orientation, social class, religion, and belief, as defined by the Equality Act 2010.
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We are committed to creating a positive inclusive culture, showing respect and equality of human rights, regardless of differences in order that everyone can reach their full potential, feel valued, respected and have a sense of belonging. As such, we will take necessary steps and action if our children and learners don’t feel protected, safe, and included.
SCL PROVISIONS
SCL provides a diverse range of provisions across multiple sites nationally, working with several partners to maximise opportunities. This includes, wrap services for 4–11-year-olds, adult leaning, apprenticeships, work experience and enrichment programmes. SCL offer face to face and remote learning. The table below provides an overview of SCL provisions however, more information can be found here: https://www.wearescl.co.uk/about-us/. PROVISIONS SERVICES SCL Active Active is Ofsted registered and provides a choice of wrap around care from Holiday Clubs and Term Time Services for 4–11-year-olds in Surrey, Hampshire, and Berkshire, through engaging experiences for children to have fun, learn more, and move more.
SCL Sports College
SCL Education is an Ofsted regulated provider which offers 16-19 study programmes nationally. Learners study subjects including and not limited to, Sport, Performing Arts, Business, Psychology, Physical Education, Personal Training and Employability Programmes. Many of our programs run within various sporting clubs and Trusts to maximize the reach and impact of our offer. SCL Creative is an Ofsted regulated provider, a 16-18 provision for Learners within the Creative and Performing Arts. Study programmes are delivered across England at a variety of professional, vocational, SCL Creative college campuses, with some of the industry's leading teachers. SCL E&S offers an alternative routeway for young vulnerable adults aged 16 -18 not wishing or ready to progress post year 11/12 into college or employment/apprenticeship. SCL provides a safe space with smaller classrooms for our Learners, many of whom have barriers to learning and have found it challenging in previous educational settings they have attended. SCL Professional offers apprenticeship that delivers different apprenticeship standards predominantly in the Sport Education, Retail and Hospitality sectors. Most of the apprentices are over 18, however some are, or were when they started 16-18 years of age. DNA is an Ofqual-recognised provision carrying out End-Point Assessments within Sport, Outdoor, Business and Commercial Sectors. DNA partner with Training Providers who register their apprentices on programmes with SCL, and
SCL Creative College
Business, Employability and Skills (E&S)
SCL Pro
DNA
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we provide an Independent End-Point Assessor to complete the assessment at their workplace, or online, over web conferencing.
SCL Enigmaz Esport SCL Enigmaz is the home of our esports where most of the learners, are between 16-18 years of age and will undertake work experience within the organisation in different roles. Kick Off Kick Off is an Adult Skills provision that delivers a range of short programmes and qualifications for vulnerable adults, predominately in enterprise, self- employment, and digital skills. These programmes are specifically designed to up-skill vulnerable adults in a short space of time to support their employability, self-employability, and career prospects.
ASSOCIATED POLICIES & PROCEURES
SCL’s Policies and Procedures which contribute to safeguarding are listed below and should be followed in conjunction with this policy and procedure.
POLICY AND PROCEDURE TITLE
VERSION DATE
SCL Recruitment & Selection Policy & Procedures
2024-2025 2024-2025 2024-2025 2024-2025 2024-2025 2024-2025 2024-2025 2022-2023 2022-2023 2022-2023 2022-2023 2024-2025 2023-2024 2024-2025 2024-2025 2024-2025 2024-2025 2024-2025 2024-2025 2023-2024
Prevent Policy and Procedures
Attendance and Missing in Education Policy
Online Safety Policy
IT Acceptable Usage Policy
Whistleblowing Policy Health & Safety Policy
GDPR/Data Protection Policy
Equality Diversity and Inclusion Policy
Colleagues Disciplinary and Dismissal Procedures
Colleagues Grievance Procedures Colleagues Codes of Conduct
Colleagues Use of Personal Devices Requirements
Learner Remote Learning Policy Parent/Carer Behavior Policy
Overnight and International Trips Policy Transport and Minibus Policy Visitors and Guest Speaker Policy
Residential Learner Arrangements Policy and Procedures
Work experience (WEX) Policy
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SEND Policy Statement Bursary Policy Statement
2023-2024 2023-2024 May 2023 May 2023 2023-2024 2024-2025 2024-2025
Welcome to SCL – Learners Handbook
Disciplinary and Behavioural Policy (Learners)
Reasonable Adjustment and Extra Exam Arrangements Policy
Wellbeing Policy for Colleagues
Search, Screening and Confiscation Policy for Learners
LEGAL AND STATUTORY GUIDANCE
This policy and procedure has been developed based on the legislation and guidance that seeks to protect children and vulnerable adults, namely: UN Conventions of the Rights of the Child 1991. Children’s Act 1989 and 2004.
Keeping Children Safe in Education (KCSIE) 2023. Keeping Children Safe in Education (KCSIE) 2024. Working Together to Safeguard Children 2023. Working Together to Safeguard Children 2018.
Children and Families Act 2014. Children and Social Work Act 2017. Education Inspection Framework 2019 updated 2023. Sexual Offences Act 2003 (amended to include The Voyeurism (Offences) Act 2019). Data Protection Act 1998. GDPR 2018. Human Rights Act 1998. Equality Act 2010. Public Sector Equality Duty. Care Act 2014. Safeguarding Vulnerable Groups Act 2006. Disclosure and Barring Service 2013. Mental Capacity Act 2005. Protection of Freedom Act 2012. Serious Crime Act 2015. Revised Prevent duty guidance 2023: for England and Wales: on the duty of schools and other providers in the Counter Terrorism and Security Act 2015. Modern Slavery Act 2015. Safeguarding Children and Young People from Knife Crime (Ofsted) 2019. Education and Training (Welfare of Children) Act 2021.
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Digital and Technology Standards in Schools and Colleges’ 2022, updated January 2024. Cyber Security Standards in Schools and Colleges 2022’.
Safeguarding and Remote Education Guidelines 2021. Children Missing from Education 2013. Children who Run Away and Go Missing from Home or Care 2014. Missing Children and Adults strategy 2011.
KEY DEFINITIONS
Below are some key terms used on a day-to-day basis at SCL, however, more general safeguarding related terms and definitions can be found here: Child Protection and Safeguarding Related Terms and Definitions. Legal Definition-Child: Anyone who has not yet reached their 18 th birthday. In this document a child or children is taken to include young people up to 18, as defined by the Children Act 1989 and 2004. Vulnerable Adult: Any person who is aged 18 and over who may be at risk of abuse, neglect, exploitation, grooming or other forms of harm including mental health difficulties. Safeguarding: Safeguarding is the action that is taken to promote the welfare of children and vulnerable adults to protect them from harm. Safeguarding means:
Protecting children from abuse and maltreatment. Preventing harm to children’s health or development.
Ensuring children grow up with the provision of safe and effective care. Action enables all children and young people to have the best outcomes.
Child Protection: Child protection is part of the safeguarding process. It focuses on protecting individual children identified as suffering or likely to suffer significant harm. This includes child protection procedures which detail how to respond to concerns about a child.
Learners: This term are used to describe all children, vulnerable adults and students participating in our education programmes outside of the Active 4–11-year-old provision.
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Child/Children: Are referred to those accessing our Active provision which provides wrap around care from Holiday Clubs and Term Time Services for 4–11-year-olds.
Colleagues: The term colleagues is all-inclusive term to refer to all employees.
Stakeholders – Refers to all non SCL employed colleagues, contractors , subcontractors, partners and third parties. (However, for the purpose of this policy, the term colleague is used to refer to employees and stakeholder). Residential Learners: Refers to any Learners who are living away from home in a residential arrangement which has been arranged privately between them/parents and the residential arrangement type/person. Residential Arrangements: Refers to any arrangement where the Learner resides away from home arranged privately between them/parents and the residential provider. This can be the form of a host families, student accommodation or other. SCL, do not take any responsibility for sourcing these arrangements.
OVERVIEW OF SAFEGUARDING ROLES & RESPONSIBILITIES
The table below provides an overview of the key safeguarding roles and responsibilities across SCL. Further information on the detailed role of a DSL can be found in KCSIE 2024 Annex C, here: KCSIE 2024.
TITLE
ROLE
RESPONSIBILITY SUMMARY
Shareholders Board
Strategic oversight and Governance
Ensure compliance with legislation and statutory guidance, provide a safe environment for children and learners and consider lessons learnt. Ensure compliance with legislation and statutory guidance. Provide challenge, scrutiny, support, consider lessons learned. Feed findings to the Shareholders Board. Responsible for liaising with the CEdO and Senior Designated Safeguarding lead, (SDSL) ensuring policies and procedures are up to date and adhered to, including training. Have strategic oversight and provide scrutiny and challenge as a critical friend. Responsible for oversight of strategic safeguarding, high risk and reputational issues, consider lessons learned to feed to the boards described above.
Safe and Sound Board
Scrutiny, challenge, and strategic governance oversight External scrutiny, challenge, and strategic governance oversight
Safeguarding Governor
CEO
Strategic Safeguarding and Governance
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Chair
Strategic Safeguarding and Governance
Acting as a safeguarding sponsor, responsible for oversight of strategic safeguarding and reporting any high risks and lessons learned to the boards described above. Responsible for the oversight of strategic and operational safeguarding systems and processes, managing and supporting the SDSL with serious incidents relating to risk management of children, learners and colleagues conduct, including reporting to the CEO. Responsible for working alongside the SDSL in decision making relating to safeguarding allegations against colleagues, ensuring safer recruitment, disciplinary policies and external referrals are followed, where appropriate. Responsible for strategic safeguarding and operational oversight of safeguarding systems and processes, managing serious incidents relating to risk management of children, learners and colleagues conduct with the DSL and reporting and making decisions with the CEdO and People Director. Responsible for training, operational management of the Regional Safeguarding Officers (RSO’s) with case management, external reporting, managing and reporting lower-level incidents relating to colleagues conduct with the SDSL. First point of contact and responsible for dealing with safeguarding issues at operational level, supporting colleagues and reporting where necessary to the DSL/SDSL and external agencies. Responsible for strategic and operational safeguarding Prevent issues, supporting colleagues and reporting where necessary to the DSL/SDSL and external agencies. Responsible for strategic and operational safeguarding issues relating to residential arrangements and residential learners, supporting colleagues and Leaners, and reporting where necessary to the DSL/SDSL and external agencies. First point of contact and responsible for Looked After Children (LAC), Care Leavers and those on a Personal Education Plan (PEP), reporting any safeguarding concerns to the DDSL’s/DSL.
Chief Education Officer (Cedo)
Strategic Safeguarding
Director of People Team
Oversee allegations against colleagues and ensure safer recruitment Senior Designated Safeguarding Lead (SDSL) Designated Safeguarding Lead (DSL) Deputy Designated Safeguarding Lead (DSL) Deputy Designated Safeguarding Lead (DSL) Deputy Designated Safeguarding Lead (DSL) Annual Review (AR) and Personal Education Plan (PEP) Coordinator
Director of Safeguarding
Head Of Safeguarding
Regional Safeguarding Officers (North, Midlands, and South) Safeguarding Prevent & Training Lead Safeguarding Residential Lead
Designated Teacher
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SEND Leads
Group Director of Learner Services and Learning Support Manager Being vigilant to signs and indicators and reporting safeguarding concerns
Responsible for SEND children and learners who are on Education Health Care Plans (EHC) reporting any safeguarding concerns to the DDSL’s/DSL. All colleagues must: Be familiar with SCL Safeguarding Policy and Procedure and understand their role and responsibilities. Identify, respond, report, and record all safeguarding concerns within the same day on MyConcern where relevant notify the DSL/DDSL’s. If colleagues believe a child or learner may be at risk of immediate and/or severe harm and no DSL/DDSL’s can be contacted, the colleague’s member should contact the Police or Social care as per contact details at the beginning of this policy and procedure. As per contractual arrangements with SCL, all safeguarding issues relating to SCL children and learners and allegations against colleagues, will be reported to SCL safeguarding. If a child or vulnerable adult has a concern about themselves or someone else, they can send an email to: Safeguarding@wearescl.co.uk or call the Safeguarding Concern Line on 0800 368 8745 (9am – 5pm) and specialist colleagues will be there to listen, give advice and support. If it is urgent and you can’t contact someone from SCL, as a child, you can call Childline on: 0800 1111 or the Police and for vulnerable adults, contact someone through Report child abuse to a local council - GOV.UK (www.) or call the Police.
All Colleagues
Stakeholders (Non SCL colleagues’ Contractors/par tners/Third parties) Child or Vulnerable Adult accessing SCL Services and Parents/Guardia ns/Carers
Being vigilant to signs and indicators and reporting safeguarding concerns
Report concerns
MANDATORY TRAINING
SCL ensures colleagues at all levels from shareholders, governors and operational colleagues, receive the appropriate level of training to their role, which includes online safety, filtering and monitoring, and Prevent, in line with KCSIE. Safeguarding training is both developed and delivered to meet the context of SCL provisions and roles, and further training is also completed, through SCL LEARN online platform, including KCSIE Knowledge
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Check. At SCL we ensure we not only meet minimal statutory requirements in relation to safeguarding training but also consider requirements based on local and national need, best practice, colleagues, child and learner focussed needs. As such, SCL capture colleagues, child and learner voice which informs all training and this is delivered through a range of methods from, toolbox short training, workshops and briefings. This training plan is regularly reviewed and updated as per needs and requirements. In addition, all colleagues, children and learners receive regular updates through newsletters and the Safeguarding Hub.
SAFER RECRUITMENT
SCL are committed to building a safer safeguarding culture and therefore, as part of our whole college approach and wider safeguarding duties and responsibilities, we have a robust Safer Recruitment Policy which sets out our commitment and a set of practices to help makes sure our colleagues are suitable to work with children and learners and we undertake due diligence and best practice approaches when recruiting and retaining colleagues. As part of a key requirement for safer recruitment and KCSIE 2023, SCL keeps a Single Central Record (SCR) of recruitment and vetting checks, such as DBS, right to work in the UK, references, and safeguarding training. Please refer to the safer Recruitment Policy for more information.
PREVENT DUTY
SCL is subject to a duty under section 26 of the Counter Terrorism and Security Act 2015 in exercising their duties to prevent children and learners being drawn to terrorism. This duty Is known as the Prevent Duty. SCL have dedicated Prevent colleagues and a Single Point of Contact (SPOC) who managers any risks posed by children and learners who are vulnerable to extremism. The SPOC may refer to the Channel , a multi-agency panel which is a confidential support programme that focusses on early support for those identified as susceptible to being drawn to terrorism. Please refer to the Safeguarding Prevent Policy and Procedure in addition to the below: • Prevent Duty Guidance: England and Wales 2023 • Prevent Duty Guidance for Further Education Institutions England and Wales • Channel and Prevent Multi-Agency Panel Guidance
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CONFIDENTIALITY AND INFORMATION SHARING
The Data Protection Act 2018 and UK GDPR do not prevent the sharing of information for the purpose of keeping children and learners safe. Any worries or fears about sharing information must not be allowed to hinder the need to safeguarding, protect and promote the welfare of children and learners. Colleagues should reassure the child or learner that they have done the right thing reporting and will be taken seriously. Never promise a child or learner that they will not inform anyone about what they have shared, as this may not be in their best interest and wherever possible, a child or learner should be kept informed of decisions and actions. Further details on information sharing and transferring child protection files can be found: In Chapter one of Working Together to Safeguard Children, which includes a myth-busting guide to information sharing. At Information Sharing: Information Sharing Advice for Safeguarding Practitioners Providing Safeguarding Services to Children, Young People, Parents and Carers. The seven golden rules for sharing information will be especially useful. At The Information Commissioners Office (ICO) which includes information about your obligations and how to comply, including protecting personal information. In Data Protection in Schools Toolkit 2023 updated 2024 to support schools with data protection activity, including compliance with the UK GDPR. Safeguarding and Child Protection It is best practice to seek consent to share information, if possible, as long as it does not increase the risk of harm to the child or learner. In most instances, parents/guardians/cares and the child or learner, depending on their age, should be informed that you are referring to the safeguarding team at SCL and/or a referral to Social Care or Police, unless this puts them further at-risk danger, or where it is suspected the parent/guarding/carer may be directly harming the child or learner, or may put you or other colleagues or Learners in danger. If in doubt speak to the safeguarding team at SCL in the first instance or consult with Social Care. Safeguarding and Vulnerable Adult Protection In instances of vulnerable adult protection, the principles in relation to children also apply to vulnerable adults. The Care Act 2014 governs the information sharing arrangements for those over 18 years of age. Where an adult who can give consent to information being passed on to a statutory safeguarding authority refuses to do so, we will consider whether their ‘vital interests’ are at stake under the terms of the Data Protection Act/GDPR and carry out a risk assessment.
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In such circumstances a referral to statutory services is the likely option, if the adult is at immediate risk of serious harm or another person is.
ELECTRONIC SYSTEMS & ONLINE SAFETY
Please refer to SCL’s Online Safety Policy alongside this policy and procedure for more information. In addition, further information can also be found here Guidance for meeting- digital-and-technology-standards-in-schools-and-colleges. SCL use an electronic system, MyConcern to store and record safeguarding concerns relating to children and vulnerable adults. All safeguarding data is stored and retained in line with GDPR Privacy standards.
MyConcern Record Keeping
As per statutory guidance, SCL are required to be able to keep detailed, accurate secure written records of all concerns, discussions and decisions made, including any rationale for decisions. For example, where referrals to statutory agencies such as the Police or Local Authority were or were not made, or referrals relating to Prevent. SCL use MyConcern, an electronic safe and secure system for this to record and manage all safeguarding concerns. The SDSL and DSL are responsible for managing the system and having oversight of the safeguarding concerns and colleagues are expected to use MyConcern to record and report safeguarding concerns in a timely manner as well as use the system to monitor, review and manage concerns to reduce risks and support with action plans. Filtering and Monitoring As part of SCL’s statutory responsibility outlined in KCSIE 2023, to ensure schools and colleges have appropriate filtering and monitoring systems in place, SCL have robust systems to protect our children and vulnerable adults from harmful and inappropriate content while using the internet. SCL use SensoCloud which protects children and learners by monitoring SCL devices and indicating online safety concerns to the relevant colleagues. Senso Cloud flags users who may be vulnerable or at-risk and users who may pose a risk to others, as well as any inappropriate or harmful behaviour. Additional guidance can be found here: https://saferinternet.org.uk/guide-and-resource/teachers- and-school-staff/appropriate-filtering-and-monitoring.
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SECTION TWO SAFEGUARDING PROCEDURES WHAT TO DO IF YOU HAVE A CONCERN ABOUT A CHILD OR VULNERABLE ADULT
CONTENT
PAGE 20-21
Early Help and Additional Vulnerabilities Child on Child Abuse Mental Health
Missing In Education Non-Recent Abuse Barriers To Reporting
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Responding and Reporting Concerns – 5 R’s
22-23
What to do if your Concerned about a Child or Vulnerable Adult Flowchart
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EARLY HELP AND ADDITIONAL VULNERABILITIES
SCL recognise their statutory duty to provide help and support for children and learners of all ages that improves a family’s resilience and outcomes or reduces the chance of a problem getting worse. SCL also provides support for special needs and disabilities (SEND) for those who have disabilities or additional needs who may be on an Education Health Care (EHC) plan, requiring additional support. As part of our responsibilities for safeguarding, we provide a coordinated approach and early help when additional needs are identified. SCL ensure all colleagues are aware of the signs and indicators of abuse and neglect for both children and learners and in the event, concerns relating to vulnerabilities arise, these should be reported to the safeguarding team immediately. Additional information on definitions of abuse and neglect and signs and indicators can be found here: Keeping Children Safe in Education. https://learning.nspcc.org.uk/media/1188/definitions-signs-child-abuse.pdf https://www.scie.org.uk/safeguarding/adults/introduction/types-and-indicators- of-abuse/ Additional vulnerabilities may include (this is not an exhaustive list) if a child or learner: Is disabled and has specific additional needs. Has special education needs or has an Education Health Care plan (EHC). Has mental health needs. Is a young carer or has caring needs. Looked after child or learner, child in need or care leaver. Is showing signs of being drawn into terrorism or radicalisation. Is showing signs of anti-social, criminal behaviour or gang involvement. Is a child or learner who is absent from education missing. Child on Child Abuse All colleagues should recognize that children are capable of abusing other children on and offline and SCL have a zero-tolerance approach to abuse, and this will not be passed off as ‘banter’. SCL ensures colleagues receive training and support on how to recognize different forms of child-on-child abuse and know how to respond to these. Child on Child abuse is most likely to include but not limited to: Bullying, including cyber bullying and discriminatory bullying. Abuse in intimate personal relationships.
Physical abuse. Sexual violence. Sexual harassment. Causing someone to engage in sexual activity without consent.
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Consensual and non-consensual sharing of nude, semi-nude images or videos. Racism. Upskirting. Initiation/haze type violence and rituals. More information, resources and a practical guide on how to prevent , identify early and respond appropriately to child on child abuse can be found here: Addressing Child-on- Child-Abuse a Resource for Schools and Colleges. Mental Health All colleagues should recognize mental health issues, as in some cases, this can be an indicator of safeguarding issues for a child or learner. As such colleagues can often be best placed to identify signs and indicators that may suggest someone is experiencing mental health issues or a mental illness. In such cases colleagues will be expected to take immediate action and report these concerns to the safeguarding team. Further information can be found here https://learning.nspcc.org.uk/child-health- development/child-mental-health. Missing in Education Colleagues should be alert to learners unexplained and persistent absence from education as this can be a vital warning sign of a range of safeguarding issues. Therefore, early intervention is important to identify any underlying safeguarding issues to prevent further absence or them going missing. Due to the increased risk and growing concern nationally in this area, where a learner may have experienced numerous suspensions, may be at risk of being excluded, the SCL Behaviour and Disciplinary Policy for Learners, should be viewed through a safeguarding lens. Refer to SCL Attendance and Missing in Education Policy 2024-2025 for more information. Non-Recent Abuse There may be occasions where a child or learner may report abuse that occurred in the past, known as non-recent abuse and sometimes referred to as historical abuse. Some people report non-recent abuse to stop the offender abusing others. Some find that reporting gives them a sense of closure and helps them to start moving on. If the person in question decides to disclose or report it, the authorities will deal with this in the same way as any other safeguarding or child protection concerns, no matter how long ago it happened. Any non-recent abuse if disclosed by a child or learner will need to be reported and recorded in the same way as any safeguarding concern . If a vulnerable adult discloses non recent abuse, they can report this to the authorities or give you consent to report this.
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BARRIERS TO REPORTING
Many children and learners are reluctant to seek help because they feel that they do not have anyone that they can turn to for support. They may have sought help in the past and had a negative experience, which makes them unlikely to do so again. In an NSPCC study of child maltreatment (2000), only a quarter of the people that had experienced sexual abuse as a child had told anyone at the time. Being unable to tell someone that you are being abused can be very stressful and may leave a child or learner at risk of continuing or further abuse. LGBT children and learners may face additional barriers because they fear ‘outing’ themselves; have experienced discrimination or bullying because of their sexual identity and do not trust others to be supportive. Children and learners (including vulnerable adults) may not seek help because: Fear not being believed. Feel too embarrassed to talk about a private or personal problem. Worry that their concern will not be taken seriously. Worry about confidentiality and lack trust in both the people around them (including parents/carers) and in the services provided to help them. Fear the consequences of asking for help. Fear the situation could become worse. How SCL encourages children and learners to seek support: There are signposts on walls and children and learners are told about who and how to report concerns about themselves or others. Every child and learner are informed as part of their induction to SCL, with contact emails and numbers, internal and external. Our full safeguarding policy is available on our website. Our ethos is to treat all children and learners with respect, compassion, and dignity, and in doing so we always strive to validate their emotions and views. We actively encourage the sharing of experiences of safety and risk.
RESPONDING & REPORTING CCONCERNS 5 R’s
The following 5 R’s set out the principles which colleagues at SCL are expected to follow in relation to reporting safeguarding concerns about children and learner (including vulnerable adults).
REPORT
RECOGNISE
RESPOND
RECORD
REVIEW
Report the concern to a DDSL/DSL if serious, require advice or immediate attention.
Respond appropriately to what the child or learner is telling you.
The signs and indicators that something might wrong, or there has been abuse and harm.
22 Record the concern on MyConcern without delay.
Monitor cases, close, and consider lessons learned for continuous improvement.
Concerns may arise because of: A child or learner at risk telling someone at SCL. Colleagues reporting a concern. Signs and indicators of abuse being recognised or identified.
Someone reports a concern face to face or by means of other communication. The behaviour of an adult towards a child or learner gives cause for concern. A disclosure of non-recent abuse is made directly to someone at SCL. The following guidelines should be followed if a child or learner makes a direct disclosure about their experience: DO DO NOT
X React strongly – for instance saying, “that’s terrible” X Jump to conclusions especially about the abuser X Tell them you will keep this a secret X Ask leading questions X Make promises you cannot keep X Stop them from speaking freely X Tell them to stop talking so that you can locate a DDSL/DSL
Be accessible and receptive Listen carefully Take it seriously Reassurance them they did the right thing telling you Explain what will happen next and that you will need to share this with the DDSL/DSL for their and may be others safety
If in doubt, check it out with someone in the safeguarding team. See flowchart below for a quick guide to reporting a safeguarding concern.
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SECTION THREE SAFEGUARDING PROCEDURES WHAT TO DO IF AN ALLEGATION IS MADE ABOUT A COLLEAGUE, INCLUDING A LOWER-LEVEL CONCERN
CONTENT
PAGE
Aim
26 27
Defining A Safeguarding Allegation Against Staff
Initial Considerations
28
Safeguarding allegation or behavior related poor practice
28
Lower-Level Concerns
28 - 29
Flowchart - What To Do If an Allegation is Made About a Colleague, Including a Lower-Level Concern
30
Managing an allegation once reported
31 - 34
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AIM
T he aim of these procedures is to ensure that: Children and learners (including vulnerable adults), and colleagues are protected and supported following an allegation that there may have been abuse by an adult working for, or on behalf of, SCL. There is a fair, consistent, and robust response to any safeguarding allegation made, including those that are non-recent. An appropriate level of investigation into concerns or allegations, whether they are said to have taken place recently, at any time the person in question has been employed or contracted by SCL, or prior to the person’s involvement with SCL. SCL continues to fulfil its responsibilities towards the member of colleagues who may be subject to such investigations. For a quick guide for colleagues on what to do if you an allegation is made about a colleague, including lower-level concern are concerned please refer to this section, Flowchart titled ‘what to do if you an allegation is made about a colleague, including lower-level concern are concerned’. Escalation: The following process will apply where the concerns may relate to specific safeguarding roles within SCL. Deputy Designated Safeguarding Lead (DDSL) Designated Safeguarding Lead (DSL) Senior Safeguarding Lead (SDSL) Chief Education Office (CedO) and Chief
Executive Officer (CEO) If concern relates to: DDSL report to SDSL. DSL report to SDSL. SDSL report to CedO. CedO report to CEO.
Whistleblowing SCL has an open-door policy and encourage transparency, a culture of listening and in the first instance expect colleagues to raise a concern internally. However, if someone feels that they have tried this and not been heard or will not be listened to if they report a dangerous or illegal activity, or wrongdoing, then colleagues can use the Whistleblowing Policy to anonymously report. In addition, the NSPCC have a whistleblowing helpline where someone can seek advice as well as report. https://www.nspcc.org.uk/keeping-children- safe/reporting-abuse/dedicated-helplines/whistleblowing-advice-line/
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DEFINING A SAFEGUARDING ALLEGATION AGAINST A COLLEAGUE
This is where a person is alleged to have: a) Behaved in a way that has harmed a child or learner or might lead to a child or vulnerable adult being harmed. b) Possibly committed or be planning to commit a criminal offence against a child or learner. c) Behaved towards a child or learner in a way that indicates s/he is, or would be, unsuitable to work with children or learners.
The allegation may: Involve a child(ren), or learner(s) or both.
Not directly have a known child or learner victim. For example, if a member of colleagues is accessing abusive images of children online or using the internet to groom children with the intent to harm in future. Be about any type of abuse. Concern a breach of SCL’s safeguarding code of conduct. Relate to a colleague’s member who has left SCL, known as a non-recent allegation. Concern a son, daughter, child of a colleague. A safeguarding allegation may arise when: A child, learner or parent/carer makes a direct allegation against a colleague. There is a direct observation of behaviour that is cause for concern. SCL receives a safeguarding allegation from any individual during another internal procedure, for example a disciplinary or complaint. SCL is informed by the Police or Local Authority that an individual is the subject of a child or learner protection and/or criminal investigation. Information emerging from the renewal of a DBS check that a colleagues may have committed an offence or been involved in an activity that could compromise the safety of a child or learner. A colleague informs SCL that they have been the subject of allegations, have harmed a child or learner or committed an offence against or related to a child learner. A training delegate may share information which gives rise to a concern. A member of the public may contact us with an enquiry and reveal information which raises concern. The procedures must be followed consistently in all instances, regardless of how the safeguarding allegation arises or from whom; or whether it is shared with SCL by email, face-to-face contact, social networking, telephone, or letter.
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