Safeguarding Policy and Procedure for Children and Adults

SAFEGUARDING POLICY AND PROCEDURES (CHILDREN AND ADULTS AT RISK)

2025-2026

VERSION CONTROL

SCL EDUCATION GROUP

VERSION

AUTHOR

DATE

COMMENTS

Version 1.0

Group Director of Safeguarding May 2023 Group Director of Safeguarding March 24

1.0 1.0 2.0 3.0

Group Director of Safeguarding Group Director of Safeguarding Group Director of Safeguarding

June 24 April 25 April 25

Added Child to opening Statement Added clause regarding contractors and reporting Prevent and sexual violence allegations to DFE Updated in line with KCSIE 2025 Removed Active Updated flowcharts Updated managing allegations section

Final version 4.0

Group Director of Safeguarding

Sept 25

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 OWNERS

ACCOUNTABLE EXECUTIVE

Group Director of Safeguarding

APPROVAL CONTROL Approval of this Policy and subsequent amendments is by the Board DATE APPROVED

APPROVED REQUIRED BY

Stuart Allen CEdO

18.9.25 24.9.25

Carole Carson (Link Governor)

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CONTENTS Internal Key Contacts ..............................................................................................................................................4 External Key Contacts .............................................................................................................................................4 SECTION ONE ............................................................................................................................................................. 5 SCL POLICY COMMITMENT .................................................................................................................................... 5 Purpose and Scope................................................................................................................................................... 5 Equality Diversity and Inclusion .......................................................................................................................... 6 Provision Overview .................................................................................................................................................. 6 Associated Policies................................................................................................................................................... 7 Legal Framework ...................................................................................................................................................... 8 Key Definitions........................................................................................................................................................... 8 SECTION TWO .......................................................................................................................................................... 10 ROLES AND RESPONSIBILITIES .......................................................................................................................... 10 Safeguarding Roles and Responsibilities........................................................................................................ 10 Safeguarding Training, Safer Recruitment and Prevent Duty.................................................................. 11 Confidentiality and Information Sharing .........................................................................................................12 SECTION THREE: PROCEDURES ..........................................................................................................................13 REPORTING CONCERNS REGARDING LEARNERS .........................................................................................13 Early Help and Additional Needs ........................................................................................................................13 Barriers to Reporting ............................................................................................................................................. 14 Reporting and Responding to Concerns..........................................................................................................15 Online Safety, AI and Digital Behaviour .......................................................................................................... 17 SECTION FOUR: PROCEDURES ........................................................................................................................... 19 REPORTING ALLEGATIONS RELATING TO STAFF AND LOW LEVEL CONCERNS................................ 19 Purpose ...................................................................................................................................................................... 19 How Allegations or Concerns May Arise ...................................................... Error! Bookmark not defined. Reprting and Initial Action ............................................................................... Error! Bookmark not defined. Escation Pathway and Whistleblowing ....................................................... Error! Bookmark not defined. Emergancy Response ......................................................................................... Error! Bookmark not defined. Initial Consideration and Planning ................................................................ Error! Bookmark not defined. Statutory Notification ......................................................................................... Error! Bookmark not defined. Low Level Concerns ............................................................................................. Error! Bookmark not defined. Reporting Low Level Concerns and Allegations About Staff Flowchart Error! Bookmark not defined.

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Internal Key Contacts

Title

Role

Contact Email

Safeguarding Support Line and Email

Advice, support and to report a concern

Safeguarding@wearescl.co.uk 0800 368 8745 (9am – 5pm Mon-Fri excluding BH) Saira.Bashir@wearescl.co.uk Janice.gerard@wearescl.co.uk

Director of Safeguarding Safeguarding Assurance Manager (Prevent and Residential Lead) Regional Safeguarding Officer NORTH Regional Safeguarding Officer MIDLANDS Regional Safeguarding Officer SOUTH

Designated Safeguarding lead (DSL) Deputy Designated Safeguarding Lead (DDSL) and acting DSL Deputy Designated Safeguarding Lead (DDSL) Deputy Designated Safeguarding Lead (DDSL) Deputy Designated Safeguarding Lead (DDSL)

Tricia.egan@wearescl.co.uk

Justin.thornberry@wearescl.co.uk

Sheree.aldridge@wearescl.co.uk

External Key Contacts

Title

Role

Contact Email and Telephone

Local authority Children’s Social Care (England) Local authority Adult’s Social Care (England)

https://www.gov.uk/report-child-abuseto-local-council

See website

https://www.gov.uk/report-abuse-of-older-person

See website

NSPCC Helpline

10am – 8pm Monday to Friday for advice safeguarding for professionals and to report abuse 24-hour helpline for children and young people Advice can be sought from NSPCC if Whistleblowing Procedure has not resolved the concern 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

0808 800 5000, 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

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Safeguarding and Policy and Procedures (Children and Adults at Risk) | 2025-2026 SECTION ONE SCL POLICY COMMITMENT Purpose and Scope At SCL, safeguarding and wellbeing are central to everything we do. We are committed to creating a safe, supportive, and inclusive environment where all learners (children, young people, and adults at risk sometimes referred to as vulnerable adults) are respected, valued, and protected from harm, including online. This policy applies to all staff and stakeholders (employees, contractors, partners external staff, and third parties) and sets out our collective moral and statutory responsibility to safeguard and promote welfare. We operate a zero-tolerance approach to abuse , including child-on-child abuse, and adopt preventative, early help, and responsive measures in learners’ best interests. Through clear roles, responsibilities, and reporting processes, SCL ensures staff know how to act if they have concerns about a learner or staff. Our dedicated safeguarding team provides support, oversight, and escalation to statutory partners where needed. We promote a culture where safeguarding is everyone’s responsibility, learners’ voices are heard, and professional curiosity underpins practice. Staff are expected to act with the mindset: “it is my responsibility,” “it could happen here,” and to remain professionally curious at all times. Concerns should be reported to Safeguarding@wearescl.co.uk , with internal and external contact details available at the front of this policy. All staff are required to follow this policy as part of their contractual obligations with SCL. Breaches will be dealt with promptly and may lead to formal action, including dismissal or exclusion. Where necessary, referrals will also be made to external authorities or regulators.

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Equality Diversity and Inclusion SCL is committed to creating an inclusive culture where all learners and staff are valued, respected, and supported. Everyone has the right to live and work free from fear, prejudice, or discrimination based on protected characteristics under the Equality Act 2010. Any concerns about safety or exclusion will be addressed promptly, and learners will be informed how to report issues and have their views taken seriously. Provision Overview SCL delivers a range of educational services across 100+ centres nationwide. Our provision includes sport, performing arts, adult learning, apprenticeships, and higher education, offered both face-to-face and remotely. Programmes are delivered directly by SCL or in partnership with employers and local providers. An overview can be found in the table below and more detailed information can be found here; https://scleducation.co.uk/.

PROVISIONS SCL College

SERVICES

Ofsted-regulated 16–19 study programmes, delivered across campuses and partnerships to develop skills for further education, training, or employment. Alternative route for vulnerable 16–18-year-olds not in education, employment, or training (NEET), including those with complex needs or SEND/EHCPs. Small classrooms and tailored support help learners re- engage with education and skills development. Apprenticeships across different sectors, including, Sport, Retail, and Hospitality for learners 16+, delivered nationally. Short programmes in enterprise, self-employment, and digital skills to upskill adults quickly and support employability and career progression. Ofqual-recognised End-Point Assessment provider in different sectors, independent assessments delivered at workplaces or online.

Core Skills

SCL Professional Apprenticeships SCL Professional Adults

DNA

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Associated Policies 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

2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026 2025-2026

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 Staff Disciplinary and Dismissal Procedures

Staff Grievance Procedures

Staff Low Level concerns and Codes of Conduct Policy

Staff Use of Personal Devices Requirements

Learner Remote Learning Policy Parent/Carer Behaviour Policy

Trips Policy

Transport and Minibus Policy Visitors and Guest Speaker Policy

Residential Learner Arrangements Policy and Procedures

Work experience (WEX) Policy SEND Policy Statement Bursary Policy Statement

Welcome to SCL – Learners Handbook Disciplinary and Behavioural Policy (Learners)

Reasonable Adjustment and Extra Exam Arrangements Policy

Wellbeing Policy for Staffs

Search, Screening and Confiscation Policy for Learners

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Legal Framework This policy is based on current legislation, regulations and statutory guidance that seek to protect children and adults at risk, including but not limited to: • Convention on the Rights of the Child (ratified 1991) • Children Act 1989 & Children Act 2004

• Children and Families Act 2014 • Children and Social Work Act 2017 • Care Act 2014

• Keeping Children Safe in Education 2025 (statutory guidance) • Working Together to Safeguard Children 2023 (statutory guidance) • Equality Act 2010 • Human Rights Act 1998 • Mental Capacity Act 2005 • Safeguarding Vulnerable Groups Act 2006, the Protection of Freedoms Act 2012, and the DBS regime • Education and Training (Welfare of Children) Act 2021 • Prevent Duty / Counter-Terrorism Act duties and revised guidance • Online Safety Act 2023 (if relevant) • Modern Slavery Act 2015 • Relevant data protection law: Data Protection Act 2018 & UK GDPR Key Definitions Child (Legal Definition) Anyone under 18 years old, as defined by the Children Acts 1989 and 2004. Adult at Risk An individual aged 18 or over who may be at risk of harm, including abuse, neglect, exploitation, grooming, or mental health difficulties. Safeguarding Actions taken to promote welfare and protect children and vulnerable adults from harm. This includes: • Protecting from abuse and maltreatment • Preventing harm to health or development • Ensuring safe and effective care • Enabling the best possible outcomes Child Protection A specific part of safeguarding focused on protecting children at risk of, or

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suffering, significant harm. It involves clear procedures for responding to concerns. Learners All children, young people and adults, as students in SCL’s education programmes All Staff All SCL employees, Non-SCL staff such as contractors, partners, and third parties. Residential Learners Learners living away from home in private residential arrangements (e.g., host families, student accommodation).

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SECTION TWO ROLES AND RESPONSIBILITIES

Safeguarding Roles and Responsibilities Further information on roles can be found in KCSIE 2025 Part 2 and Annex C. KCSIE 2025.

TITLE

ROLE

RESPONSIBILITY SUMMARY

Investment Board

Overall Governance

Strategic governance and oversight; ensure compliance and safe environments. Scrutiny and challenge; ensure compliance, share findings with Shareholders Board. External scrutiny; liaises with CEdO/DSL; ensures all compliance and statutory responsibilities are met. Strategic oversight; manage high-risk/reputational issues; report lessons learned to Boards. Oversees safeguarding systems and processes; supports DSL with serious incidents. Manages safeguarding allegations against staff with DSL, ensures safer recruitment and disciplinary compliance.

Quality Governance Board

Scrutiny strategic governance oversight External scrutiny, and oversight Strategic Safeguarding and Governance Strategic Safeguarding Oversee allegations against staff and safer recruitment Designated Safeguarding Lead (DSL) Deputy Designated Safeguarding Lead (DDSL) and acting DSL Deputy Designated Safeguarding Lead (DDSL)

Safeguarding Governor

CEO

Chief Education Officer (Cedo) Director of People Team

Director of Safeguarding

Leads safeguarding strategy, policy, systems and operations; manages serious incidents with CEdO/People Director.

Safeguarding Assurance Manager

Manages operational casework, external reporting, supporting policy and process and leads on Prevent and online safety and residential First contact for safeguarding concerns; handle operational cases and escalate as needed. Leads on Looked After Children, Care Leavers, and PEPs; escalates concerns. Support learners with EHC plans; escalate concerns. Know policy and process to report concerns, remain vigilant, escalate to Police/Social Care if urgent. Raise concerns, via Safeguarding@wearescl.co.uk or Safeguarding Concern Line 0800 368 8745 (9am – 5pm Mon to Fri exc. BH) If urgent, as a child, call Childline on: 0800 1111 or the Police and for adults, Report child abuse to a local council - GOV.UK (www.) or call the Police.

Regional Safeguarding Officers (all regions)

Designated Teacher Group Director Learner Services

SEND Leads

Group Director Learner Services Head of Learning Services Reporting safeguarding concerns

All Staff

Child or Adult accessing SCL Services and Parents/Guardians/ Carers

Report concerns

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Safeguarding Training, Safer Recruitment and Prevent Duty

Training SCL ensures that staff at every level receive role-appropriate safeguarding training in line with Keeping Children Safe in Education 2025 (KCSIE). This includes online safety, child on child abuse, filtering and monitoring, and Prevent Duty. Training and ongoing CPD, termly and regular fortnightly updates at briefings, are tailored to the context of SCL provisions and delivered through a range of methods such as toolbox sessions, workshops, briefings, and online modules via the SCL platform, including the KCSIE Knowledge Check. We consider local and national priorities, best practice, and the voices of staff, and learners. Training plans are regularly reviewed, with updates shared through newsletters and the Safeguarding Hub. Safer Recruitment As part of SCL’s wider safeguarding approach, we operate a robust Safer Recruitment process to ensure all staff are suitable to work with learners. This includes due diligence checks and maintenance of a Single Central Record (SCR) covering DBS, right to work, references, and safeguarding training. Prevent In line with section 26 of the Counter Terrorism and Security Act 2015 , SCL fulfils its Prevent Duty by identifying and reducing risks of learners being drawn into extremism. We have designated Prevent leads and Single Point of Contact (SPOC) to manage concerns, with referrals to Channel made where early multi- agency support is needed. Safeguarding Training, Supervision and CPD All staff must receive regular, role-appropriate safeguarding training, including updates on KCSIE changes, Prevent, low-level concerns, and online safety. Training completion is monitored, and non-compliance may be addressed through performance processes. Staff involved in safeguarding cases are offered appropriate wellbeing and mental health support. DSL, DDSLs and staff with safeguarding duties receive regular, documented supervision to support reflection, ensure accountability, and maintain compliance with statutory guidance. Ongoing professional development is provided to ensure safeguarding knowledge and practice remain current.

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Confidentiality and Information Sharing The Data Protection Act 2018 and UK GDPR do not prevent sharing information to keep learners safe. Concerns about data sharing must never override the need to protect welfare. Learners must be reassured that reporting was the right thing to do and will be taken seriously. Never promise confidentiality, as information may need to be shared in their best interests. Wherever possible, keep them informed of decisions and actions. Further guidance can be found in: • Working Together to Safeguard Children, (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 Learners Seek consent to share information where possible, unless it increases the risk of harm. Parents/guardians/carers (and the learner if appropriate) should normally be informed of referrals to SCL’s safeguarding team, Social Care, or Police, unless doing so places them, you, or others at further risk. If unsure, consult SCL’s safeguarding team or Social Care.

Safeguarding Adults at Risk The same principles apply under the Care Act 2014. Adults with capacity may refuse consent, but if their vital interests are at stake or there is immediate risk of serious harm to them or others, a referral to statutory services will likely be necessary following a risk assessment. Again, if in doubt check it out with the Safeguarding Team or Social Care.

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SECTION THREE: PROCEDURES REPORTING CONCERNS REGARDING LEARNERS Early Help and Additional Needs SCL has a statutory duty to provide help that strengthens families, prevents problems from escalating, and supports learners, and those with SEND or an EHCP. We use a coordinated, early help approach when additional needs are identified. All staff must know the signs of abuse and report concerns immediately to the safeguarding team. Further guidance: • KCSIE 2025 • NSPCC – Signs of Abuse • SCIE – Adult Safeguarding Additional Vulnerabilities may include (not exhaustive): disability/SEND, mental health needs, young carers, looked-after children, risk of radicalisation, criminal or gang involvement, or persistent absence from education. Child-on-Child Abuse Children can abuse peers on- and offline. SCL has zero tolerance, never dismissing behaviour as “banter.” Abuse may include bullying, physical or sexual violence, harassment, image sharing, racism, upskirting, or initiation rituals. Staff receive training to identify and respond appropriately. SCL have a Disciplinary Policy for learners which addresses issues of Child on Child Abuse and details sanctions and course of action. See: Addressing Child-on-Child-Abuse a Resource for Schools and Colleges. Contextual Safeguarding SCL recognises that harm can occur in contexts beyond the home or education setting. Risks may arise in peer groups, online environments, neighborhoods, or community settings. Staff must consider these wider influences when assessing risk and work with external agencies to address extra-familial harm, including exploitation, county lines, gang involvement, harmful sexual behaviour, and online abuse.

Mental Health Mental health issues can indicate safeguarding concerns. Staff must act

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immediately and report to the safeguarding team. More info: NSPCC – Child Mental Health.

Missing in Education Unexplained or persistent absence may indicate safeguarding concerns, including neglect, exploitation, or other risks to learner welfare. Early identification and intervention are essential. All staff should follow the SCL Attendance and Missing in Education Policy 2025–26 and the Behaviour Policy, ensuring these are applied through a safeguarding lens. Any concerns must be reported immediately to the safeguarding team. Non-Recent Abuse Abuse may be disclosed long after it occurred. All disclosures, whether by children or vulnerable adults, must be recorded and reported in the same way as any safeguarding concern. Physical Restraint Physical restraint may be considered a safeguarding matter, as it directly impacts learner safety, dignity, and rights. In SEND or High Needs provisions, the use of restraint may be more likely and should always be linked to individual support plans, EHCPs, and inclusive practice. For detailed guidance, please refer to the Physical Restraints Policy 2025. Barriers to Reporting Many learners are reluctant to seek help because they feel they have no one to turn to, or past negative experiences have discouraged them. Reasons learners may not seek help include: • Fear of not being believed. • Embarrassment about personal issues. • Worry their concerns will not be taken seriously. • Doubts about confidentiality or trust in parents/carers or services. • Fear of consequences or that the situation may worsen. At SCL we encourage learners to seek support through: • Clear signposting and guidance on how and who to report concerns to. • Induction information including safeguarding contacts (internal and external). • Safeguarding policy published on the website.

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• A culture of respect, compassion, and dignity, validating learners’ emotions and views. • Encouragement to share experiences of safety and risk.

Reporting and Responding to Concerns Concerns may arise from (not exhaustive): • A learner disclosing risk (direct or indirect). • Staff raising a concern. • Signs or indicators of abuse or neglect. • Reports from parents, carers, employers, visitors, or other learners. • Concerning behaviour by an adult towards a learner. • Online or digital risks, including Prevent concerns. • Disclosures of non-recent abuse. • Wider contextual factors such as peer, community, or environmental risks.

If a learner makes a direct disclosure (including Prevent or Residential concerns):

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

 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 5 R’s below as an easy step by step guide to help remember what to do if you have a concern. See also flowchart below for a quick guide to reporting a safeguarding concern.

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Online Safety, AI and Digital Behaviour Online Safety

Refer to SCL’s Online Safety Policy for full details. Additional guidance is available Guidance for meeting-digital-and-technology-standards-in-schools-and-colleges. Staff must follow SCL’s Online Safety Policy, maintaining professional boundaries online and adhering to the Staff Code of Conduct. All safeguarding concerns related to online behaviour or digital contact must be reported immediately to the DSL, following the process in the flowchart. Record Keeping All safeguarding concerns are recorded in MyConcern, a secure system compliant with GDPR. Records must be accurate, timely, and complete, supporting monitoring, action plans, and statutory reporting (e.g., Police, Local Authority, Prevent). DSL and DDSL oversee the concerns and system. Filtering and Monitoring SCL provides robust filtering and monitoring on all devices to protect learners from harmful content, identify risks, and highlight inappropriate behaviour. Guidance : Safer Internet Centre. Digital Behaviour and AI • Learners receive education on safe digital use, including AI, with emphasis that AI cannot replace professional safeguarding guidance. • Staff must report any AI-related safeguarding concerns immediately to the DSL/DDSL or Prevent Lead https://saferinternet.org.uk/guide-and-resource/teachers-and-school- staff/appropriate-filtering-and-monitoring Multi-Agency Working Staff must cooperate fully with statutory authorities, including social care, police, and regulatory bodies, as required. Internal gathering information and making an assessment (not investigating) never replace statutory investigations. Guidance from external agencies must be followed, and staff must provide all relevant information promptly. Whistleblowing and Escalation • Staff may raise concerns internally first, or externally if necessary, and will be protected from reprisal when acting in good faith.

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• External reporting options include the NSPCC Whistleblowing Advice Line (0800 028 0285). • Staff must feel supported and safe to escalate concerns without fear of negative consequences. Partners, Contractors, and Third-Party Safeguarding Compliance • All partners, contractors, and external agencies must comply with SCL safeguarding policy and procedures. • Prior to engagement, SCL must verify and carry out due diligence checks: o DBS, references, and safeguarding training are up to date. o Awareness of SCL safeguarding procedures and reporting routes. • Any safeguarding concerns or allegations relating to partners/contractors must be reported immediately using the same escalation process as for SCL staff outlined in Section Four of this policy. • All partners are required to comply with safeguarding responsibilities, reporting obligations, and supervision requirements as set out in contracts, agreements, and service level agreements.” Record-Keeping and Retention Learner Safeguarding Records • Document all concerns, disclosures, incidents, actions, and outcomes accurately and store securely. • Access is restricted to authorised staff (DSL, DDSLs, others as necessary), maintaining confidentiality and data protection compliance. • Retain records until the learner reaches 25 years of age, or longer if statutory guidance requires. • Do not destroy records while investigations, appeals, or statutory requirements are ongoing. • DSLs/DDSLs should regularly review records for completeness, accuracy, and patterns or emerging risks. Staff Safeguarding Records: • Accurately document allegations, low-level concerns, and investigations, storing securely. • Access is restricted to authorised staff (DSL, People Director, or others as necessary) with confidentiality and data protection compliance. • Retain records until normal retirement age, or 10 years from the allegation if younger. • Do not destroy records while investigations, appeals, or statutory requirements are ongoing.

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SECTION FOUR: PROCEDURES REPORTING ALLEGATIONS RELATING TO STAFF AND LOW LEVEL CONCERNS

Purpose These procedures are to ensure:

• learners, and staff are protected and supported following any low-level concern or allegation of abuse by an adult working for or on behalf of SCL. • A fair, consistent, and robust response to all safeguarding allegations, including non-recent ones. • Appropriate assessment of concerns, whether recent, or non-recent, or prior to SCL involvement. • SCL fulfils its duty of care to staff subject to investigation. For a quick guide on what to do if you have a concern regarding a member of staffs conduct or behaviour or an allegation is made, please refer to the flowchart below in this section. See also Staff Code of Conduct & Low Level Concern Policy, including the DOs/DON’Ts in the Code of conduct section and the Low level concern reporting workflow . – Definitions • Low-Level Concern : Behaviour that does not meet the threshold for an allegation but indicates poor judgement, blurred boundaries, or breach of the Code of Conduct.

• Allegation / Harm Threshold (KCSIE 2025 Part Four): : Behaviour suggesting that a staff member may have: o Harmed or potentially harmed a learner.

o Committed a criminal offence against or related to a learner. o Behaved in a way that indicates unsuitability to work with children or vulnerable adults. o Engaged in sexual misconduct, abuse, or exploitation (including online or digital).

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o Behaved in a way that breaches the Code of Conduct or raises a Prevent concern. o Been involved in incidents concerning their own child/family that suggest unsuitability. o Any non-recent allegations must also be treated with statutory rigor. How Allegations or Concerns May Arise Concerns or safeguarding allegations may arise from a variety of sources (not exhaustive): • Direct allegation from a learner, parent, or carer. • Observation of behaviour causing concern. • Complaints, grievances, or disciplinary processes within SCL. • Notification from police, local authority, or other statutory agencies. • Information from DBS checks or renewal processes indicating possible offences or risks. • Self-disclosure by a member of staff regarding harm to a learner or related offences. • Information shared by colleagues, training delegates, visitors, or members of the public. • Communications received via email, phone, letter, or social media. • Behaviour outside of work that may make a staff member unsuitable to work with learners. All concerns must be reported without delay to the DSL and/or People Team. Procedures must be followed consistently, regardless of how the allegation arises or the source. Reporting and Initial Action • Immediate Reporting: All staff must report concerns, low-level concerns, or allegations to the DSL and/or People Team on the same day. • Categorisation : DSL and People Team review and determine the appropriate response. • Case Manager: o Normally, the DSL + People Director act as case manager for investigations. o If there is a conflict of interest or other reasons, the case manager role may be delegated to the Principal, Deputy Principal, CEdO or CEO.

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o The case manager leads the investigation, supported by DSL and People Team. • Action: May include supervision, training, disciplinary procedures, or referral to external agencies (LADO, DBS, TRA, other regulatory bodies). • Recording : All cases, decisions, and rationale must be documented securely and monitored for patterns. Escalation Pathway and Whistle blowing The following pathway outlines how safeguarding concerns, low-level concerns, or allegations should be escalated at SCL, including guidance if the concern involves a line manager or senior staff: • Staff concern about a colleague (not line manager/DSL/CEdO/CEO) → report to Line Manager, DSL, or People Team. • Staff concern about a Line Manager → report directly to DSL or People Team. • Staff concern about DSL or DDSL → report to People Team/ CEdO. • Staff concern about CEdO → report to CEO. • Staff concern about CEO → report to Link Governor / Board. SCL promotes openness and expects concerns to be raised internally first. Staff raising concerns in good faith will not be penalised. If not possible, staff may use the Whistleblowing Policy or the NSPCC helpline: NSPCC Whistleblowing Advice Line. Inform parents/carers that urgent help is being sought. • Immediate action is focused solely on protecting the learner. Further planning is considered separately. Initial Considerations and Planning Beyond an immediate emergency, the DSL and People Director (case managers) agree an initial plan; the CEdO may be involved if appropriate. • Determine whether the allegation meets the safeguarding threshold . • If it does not meet the threshold , assess whether it constitutes breaches of codes of conduct or poor practice/low level concern and follow the disciplinary process as required. Emergency Response If a learner is at immediate risk: • Call emergency services. •

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• All decisions, rationale, and planned actions must be recorded securely on the colleague’s file. The initial plan should consider the following four strands: Strands 1. Social care : child protection enquiries and assessment about whether learner needs protection or services. 2. Police : A police investigation if a criminal offence may have been committed. 3. Employer : Consideration by an employer of disciplinary action in respect of the individual. 4. Referrals : Disclosure & Barring Service and/or professional/regulatory bodies.

Statutory Notifications • All LADO referrals must be made within 1 working day .

• Internal investigations do not replace statutory external investigations. • SCL (as contractor) must notify the DfE via the Customer Help Portal when referrals are made for sexual violence or staff abuse to social care, police, or LADO and/or incidents or referrals relate to Prevent duty concerns. • Regulatory notifications (DBS etc) must be completed when statutory thresholds are met. Low Level Concerns SCL is committed to the highest professional standards to safeguard learners and maintain a safe, respectful culture. This section provides a summary only, of Low Level Concerns process and should be read in conjunction with the Code of Conduct & Low-Level Concerns Policy (2025–26) which provides detailed step by step procedures. Purpose: • Protect learners and staff where concerns arise about staff behaviour. • Ensure a fair, transparent, and robust process for managing concerns, LLCs, and safeguarding allegations. • Promote early intervention, accountability, and a safer culture across all SCL provisions. Examples of Low-Level Concerns: • Inappropriate jokes or language. • Minor boundary breaches or unprofessional contact.

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• Sharing inappropriate online content. • Behaviour undermining professional authority. Process • Report immediately: All staff must report to the DSL and/or People Team the same day. • Categorisation: DSL and People Team review and determine response. • Action: May include supervision, mentoring, training, or disciplinary action. • Recording: All cases documented securely, monitored for patterns, and retained according to policy. Whistleblowing If staff cannot report internally, they may use the Whistleblowing Policy or contact the NSPCC Whistleblowing Advice Line . NSPCC Whistleblowing Advice Line. Key Principle Resignation, dismissal, or behaviour occurring outside work does not remove SCL’s duty to gather information, investigate, and refer where necessary. • LLCs may indicate emerging patterns and should always be monitored to prevent escalation to more serious concerns .

See process flowchart below for reporting low level concerns and allegations about staff.

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Decision-Making, Suspension, Post Investigation Actions and Outcomes The DSL together with the Director of People (PD) and, if appropriate, the CEdO, decides on action when an allegation is reported. If the allegation meets the statutory threshold, referral to the LADO must be made within 1 working day considering: • Immediate safety of any learner involved. • What, when, and with whom information should be shared, including the individual subject to the allegation and other employers. • Whether suspension is required pending investigation. • Securing relevant records or removing equipment from the individual. • Referral criteria to the Local Authority and/or Police. • Additional information needed for clarity. • Who is aware of the allegation and who has been spoken to. • Whether advice should be sought from the Local Authority or NSPCC. • Managing information sharing, speculation, leaks, or media interest.

SCL EDUCATION GROUP

Referral Referral to the LADO must occur within 1 working day of the allegation being identified, regardless of whether the alleged individual is still in employment, to: • LADO in the child’s or adult’s local authority if the allegation concerns a specific victim. • LADO (or equivalent) in the alleged’s local authority if no identifiable victim. The LADO will: • Discuss and obtain details of the allegation. • Check for evidence that the allegation is false or unfounded. Serious allegations require immediate referral to Local Authority and Police. Investigations by external authorities take precedence over internal procedures. Suspension does not indicate guilt and must be considered carefully. Non recent allegations must be treated with the same statutory rigour as current allegations. The DSL must ensure referral to the LADO within 1 working day regardless of when the alleged incident occurred A learner may be at risk of significant harm. • The allegation warrants Police investigation or could lead to dismissal. • The individual may interfere with witnesses. The decision rests with the DSL and PD, in discussion with CEdO and considering Police/Local Authority advice. Feedback to the individual reporting or receiving the allegation and others who need to know is the responsibility of the DSL and PD. Suspension is a neutral act and does not imply guilt. Record-keeping All allegations, including non-recent and low-level concerns, must be securely recorded and retained until the individual reaches normal retirement age, or 10 years from the date of the allegation if younger, aligning with KCSIE 2025. Post-Investigation Actions Following external investigation, the DSL and LADO will review the outcome and decide further actions, which may include: • Reintegrating the staff member. • Alerting other employers. Suspension Consider suspension if: •

SCL EDUCATION GROUP

• Referral to regulatory bodies, Ofsted, TRA, other and DBS : P.O. Box 181, Darlington, DL1 9FA, Tel: 01325 953795. And other regulatory bodies must happen even if the employee resigns. Outcome Definitions • Substantiated: Sufficient evidence proves the allegation. • False: Evidence disproves the allegation. • Malicious: Evidence disproves the allegation and shows intent to deceive. • Unsubstantiated: Insufficient evidence to prove or disprove. Every effort should be made to conclude investigations, even if the individual refuses to cooperate, resigns, or is deceased. SCL will not use settlement agreements to bypass DBS referrals. Referrals to Social Care if a learner was involved. • Police advice if the allegation was deliberately invented by an adult. • Disciplinary action as needed. • Support needs for the accused and survivors of past abuse. Feedback to the investigated individual must be provided in writing within five working days . Support and Lessons Learned SCL recognises that staff involved in safeguarding concerns, low-level concerns, or allegations may experience stress or emotional impact. Support is provided for: • Person making the allegation: Guidance, reassurance, and access to wellbeing support. • Alleged victim: Emotional support, practical help, and safeguarding measures. • Alleged perpetrator: Fair treatment, clarity on the process, and impartial support via a designated person not involved in the investigation. Support may include counselling, occupational health services, or access to other mental health resources. Staff may raise support needs with their Line Manager, DSL, People Team, or case manager (usually DSL + People Director unless a conflict exists). DSL and People Director review cases to identify lessons from actions and support provided. Learning informs updates to policy, procedures, and safeguarding training to improve practice and safeguard learners and staff. If false or malicious, consider: •

SCL EDUCATION GROUP

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