Safeguarding & Child Protection Policy

Safeguarding and promoting the welfare of children is defined as:

• Protecting children from maltreatment.
• Preventing impairment of children’s mental and physical health or development.
• Ensuring that children are growing up in circumstances consistent with the provision of safe and effective care;
• Taking action to enable all children to have the best outcomes;

Children includes everyone under the age of 18.

This means that our organisation is committed to safeguarding and promoting the welfare of all its customers, including children. We believe that:

• Our children/young people have the right to be protected from harm, abuse and neglect
• Our children/young people have the right to experience their optimum mental and physical health 
• That every child has the right to an education and children/young people need to be safe and to feel safe in organisation
• children/young people need support that matches their individual needs, including those who may have experienced abuse
• Our children/young people have the right to express their views, feelings and wishes and voice their own values and beliefs
• Our children/young people should be encouraged to respect each other’s values and support each other
• Our children/young people have the right to be supported to meet their emotional, social and mental health needs as well as their educational needs. Our organisation will ensure clear systems and processes are in place to enable identification of these needs. Including consideration of when mental health needs may become a safeguarding need.
• Our organisation will contribute to the prevention of abuse, risk/involvement in serious violent crime, victimisation, bullying (including homophobic, biphobic, transphobic and cyber bullying), exploitation, extreme behaviours, discriminatory views and risk-taking behaviours.

All staff and visitors have an important role to play in safeguarding children/young people and protecting them from abuse and considering when mental health may become a safeguarding issue.

Organisations will fulfil their local and national responsibilities as laid out in the following documents:

• The most recent version of Working Together to Safeguard Children (DfE)

• The most recent version of Keeping Children Safe in Education: Statutory guidance for organisations and colleges (DfE Sept 2020)

• West Midlands Safeguarding Children Procedures 

• The Education Act 2002 s175 

• Sexting in Organisations & Colleges – responding to incidents and safeguarding young people (UKCCIS) 2016

• General Data Protection Legislation (2018) 

• Mental Health & Behaviour in Organisations 

• Birmingham Criminal Exploitation & Gang Affiliation Practice Guidance (2018)

• Safeguarding Children Partnership threshold guidance Right Help Right Time

• Multi-agency Statutory Guidance on Female Genital Mutilation, April 2016, HM Government

• Protecting Children from Radicalisation: The Prevent Duty, 2015 

• Relationships education, relationships and sex education (RSE) and health education

• Voyeurism offences act 2019

• Children missing education 

In our organisation the following people will take the lead in these areas:

Our Data Protection officer is:

Mr Chris Hudson

Our Rights Respecting link is:

Mrs Ruth Coalson

Our lead for Mental Health is:

Mrs Sumpa Paul

Our Safeguarding governor is:

Mr Zee Dinally

This policy will contribute to the protection and safeguarding of our pupils/students and promote their welfare by:

• Clarifying standards of behaviour for staff and pupils/students;
• Contributing to the establishment of a safe, resilient and robust ethos in the organisation, built on mutual respect and shared values;
• Introducing appropriate work within the curriculum.
• Encouraging pupils/students and parents to participate;
• Alerting staff to the signs and indicators that all may not be well;
• Developing staff awareness of the causes of abuse;
• Developing staff awareness of the risks and vulnerabilities their pupils/students face;
• Addressing concerns at the earliest possible stage;
• Reducing the potential risks pupils/students face of being exposed to multiple harms including violence, extremism, exploitation, discrimination or victimisation;
• Recognising risk and supporting online safety for pupils, including in the home.

This means that in our organisation we will:

• Identify and protect all pupils especially those identified as vulnerable 
• Identify individual needs as early as possible; and 
• Design plans to address those needs
• Work in partnership with pupils/students, parents/carers and other agencies.

Our policy extends to any establishment our organisation commissions to deliver education to our pupils/students on our behalf including alternative provision settings.

Our Governing Body/Trustees will ensure that any commissioned agency will reflect the values, philosophy and standards of our organisation. Confirmation should be sought from the organisation that appropriate risk assessments are completed, and ongoing monitoring is undertaken.

These are the seven guiding principles of safeguarding, as stated by Birmingham Safeguarding Children Partnership (found in Right Help Right Time):

• Have conversations and listen to children and their families as early as possible. 
• Understand the child’s lived experience.
• Work collaboratively to improve children’s life experience.
• Be open, honest and transparent with families in our approach. 
• Empower families by working with them.
• Work in a way that builds on the families’ strengths.
• Build resilience in families to overcome difficulties.

This means that in our organisation all staff will be aware of the guidance issued by Birmingham Safeguarding Children Partnership Right Help Right Time, and procedures for Early Help.

All staff will be enabled to listen and understand the lived experience of children and young people by facilitating solution focused conversations appropriate to the child/young person’s preferred communication style.  

All staff and visitors will:

• Be familiar with this Safeguarding & Child Protection Policy;
• Understand their role in relation to safeguarding.
• Be alert to signs and indicators of possible abuse (See Appendix 1 for current definitions and indicators);
• Record concerns and give the record to the DSL, or deputy DSL, and;
• Deal with a disclosure of abuse from a child in line with the guidance in Appendix 2 – you must inform the DSL immediately, and provide a written account as soon as possible;
• Be involved, where appropriate, in the implementation of individual organisation-focused interventions, Early Help Assessments and Our Family Plans, Child in Need Plans and inter-agency Child Protection Plans.

This means that in our organisation:

All our staff will receive annual safeguarding training and update briefings as appropriate. Key staff will undertake more specialist safeguarding training as agreed by the governing body. 

In recognition of the impact of COVID-19, additional disclosure training will be undertaken by all staff.

Our Governors/Trustees/IEB will be subjected to an enhanced DBS check and ‘Section 128’ check.

We will follow Safer Recruitment processes and checks for all staff. 

• The DSL will be a member of the Senior Leadership Team. Whilst the activities of the DSL can be delegated to appropriately trained deputies, the ultimate lead responsibility for safeguarding and child protection remains with the DSL. This responsibility should not be delegated.
• DSLs should help promote educational outcomes by working closely with their teachers about their welfare, safeguarding and child protection concerns.
• Governing bodies and proprietors should ensure that the DSL role is explicit in the role-holder’s job description and appropriate time is made available to the DSL and deputy DSL(s) to allow them to undertake their duties.

This means the DSL team in our organisation will be:

Lead: Zee Dinally

Deputies: Ruth Coalson

Any steps taken to support a child/ young person who has a safeguarding vulnerability must be reported to the lead DSL. 

Staff will be informed of relevant details only when the DSL feels their having knowledge of a situation will improve their ability to support an individual child and/or family.  A written record will be made of what information has been shared, with whom, and when.  

• Safeguarding and child protection information will be dealt with in a confidential manner.
• Our organisation will be clear as to who has parental responsibility for children on our roll, and report all identified private fostering arrangements to the Local Authority.
• Safeguarding records will be stored securely in a central place separate from academic records.  Individual files will be kept for each pupil/student: the organisation will not keep family files.  Files will be kept for at least the period during which the pupil/student is attending the organisation, and beyond that in line with current data legislation and guidance.
• If a pupil/student moves from our organisation, child protection and safeguarding records will be forwarded on to the DSL at the new organisation, with due regard to their confidential nature and in line with current government guidance on the transfer of such records.  Direct contact between the two organisations may be necessary, especially on transfer from primary to secondary organisations. 
• All in- year applications and transfers will also be reported to the Local Authority.

Because we store our records electronically on our Google server we do not hold paper files. 

We will not disclose to a parent any information held on a child/young person if this would put the child at risk of significant harm.

We will record where and to whom the records have been passed and the date.  This will allow the new setting to continue supporting victims of abuse and have that support in place for when the child/young person arrives. 

KCSiE 2020 writes about the importance of the context in which organisation safeguarding must be considered, including behaviours that are associated with factors outside the organisation which can occur between children outside of these environments i.e. where children are at risk of abuse and exploitation outside of their families.

In our organisation our DSLs will consider contextual safeguarding in their early working of safeguarding processes and give due regard to the effectiveness of the organisation safeguarding system and the wider system in which the child operates. This will be evidenced in:

• Informal and formal assessments of need/risk for the child;
• Case discussions in DSL supervision sessions. 

KCSiE 2020 also writes about the impact of abuse, neglect, or other potentially traumatic adverse childhood experiences on mental health, behaviour and education.

In our organisation this means that:

• All staff will be made aware that mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation;
• All staff will take immediate action and speak to a DSL if they have a mental health concern about a child that is also a safeguarding concern.

• The governing body must appoint a designated teacher (in non-maintained organisations and colleges an appropriately trained teacher should take the lead) and should work with local authorities to promote the educational achievement of registered pupils who are looked after. On commencement of sections 4-6 of the Children and Social Work Act 2017, our designated teachers will have responsibility for promoting the educational achievement of children/ young people who have left care through adoption, special guardianship or child arrangement orders or who were adopted from state care outside England and Wales.

• Birmingham Children’s Trust has ongoing responsibilities to the young people who cease to be looked after and become care leavers. That includes keeping in touch with them, preparing an assessment of their needs and appointing a personal adviser who develops a pathway plan with the young person. This plan describes how Birmingham Children’s Trust will support the care leaver to participate in education or training.

In our organisation the Designated Teacher is:

Name: *

Our Designated Teacher will:

• Work with the Virtual organisation to provide the most appropriate support utilising the pupil premium plus to ensure they meet the needs identified in the child’s personal education plan.
• Work with the virtual organisation head to promote the educational achievement of previously looked after children. In other organisations and colleges, an appropriately trained teacher should take the lead.

Our DSLs will keep the details of the Children’s Trust Personal Advisor appointed to guide and support the care leaver and will liaise with them as necessary regarding any issues of concern affecting the care leaver.

Governing bodies and proprietors should ensure that there are appropriate policies and procedures in place in order for appropriate action to be taken in a timely manner to safeguard and promote children’s welfare:

• The organisation operates “Safer Recruitment” procedures and ensures that appropriate checks are carried out on all new staff and relevant volunteers (including members of the governing body);
• The * and all other staff who work with children/young people undertake safeguarding training on an annual basis with additional updates as necessary within a 2-year framework and a training record maintainedTemporary staff and volunteers are made aware of the organisation’s arrangements for safeguarding & child protection and their responsibilities;
• The organisation remedies any deficiencies or weaknesses brought to its attention without delay;
• The governing body has a written policy and procedures for dealing with allegations of abuse against members of staff, visitors, volunteers or governors that complies with all BSCP procedures;
• The Nominated Governor is responsible for liaising with the * and DSL over all matters regarding safeguarding and child protection issues.  The role is strategic rather than operational – they will not be involved in concerns about individual pupils/students.

In our organisation this means that: 

• All governors must have read part 2 of “KCSIE-20” 
• Our nominated governor for safeguarding and child protection is: Mr Zee Dinally
• This governor will receive safeguarding training relevant to the governance role and this will be updated every 2 years.
• The governing body will review all policies/procedures that relate to safeguarding and child protection annually.
• A member of our governing body (usually the Chair) is nominated to be responsible for liaising with the Children’s Trust in the event of allegations of abuse being made against any member of our organisation.
• The Nominated Governor will liaise with the * and the DSL to produce a report at least annually for governors and ensure the annual Section 175 safeguarding self-assessment is completed and submitted on time.

The organisation should pay full regard to ‘Safer Recruitment’ practice including scrutinising applicants, verifying identity and academic or vocational qualifications, obtaining professional and character references, checking previous employment history and ensuring that a candidate has the health and physical capacity for the job.  

It also includes undertaking interviews and appropriate checks including disclosure & barring check, barred list checks and prohibition checks. Evidence of these checks must be recorded on our Single Central Record.

All recruitment materials will include reference to the organisation’s commitment to safeguarding and promoting the wellbeing of pupils. 

This means that in our organisation:

The following organisation staff have undertaken Safer Recruitment training:

1 *

2 *

3 *

4 *

And the following members of the Governing Body have also been trained:

1 – Mr Zee Dinally

2 – Mrs Sumpa Paul

One of these will be involved in all staff recruitment processes and sit on the recruitment panel.

All staff, especially staff who have been redeployed in response to COVID-19, must be aware of systems within their setting which support safeguarding, and these should be explained to them as part of staff induction. 

Recognising the impact of COVID-19, DSLs should be given additional time, particularly in the autumn term, to support staff and children regarding new safeguarding and welfare concerns. Regular safeguarding supervision will be offered to the Lead DSL within organisation usually offered half termly, safeguarding supervision may need to be offered more frequently and extended to other members of staff as deemed appropriate by the organisation. DSLs will be supported to access training as appropriate including training in behaviour and mental health.

Our staff induction process will cover:

• The Safeguarding & Child Protection policy;
• The Behaviour Policy;
• The Staff Behaviour Policy (sometimes called a Code of Conduct); 
• The safeguarding response to children who go missing from education; and 
• The role of the DSL (including the identity of the DSL and any deputies). 

Copies of policies and a copy of part one of the KCSIE-20 document is provided to staff at induction.

We recognise the importance of practice oversight and multiple perspectives in safeguarding and child protection work. We will support staff by providing opportunities for reflective practice including opportunity to talk through all aspects of safeguarding work within education with the DSL and to seek further support as appropriate.

There are circumstances when it is appropriate for staff in organisation to use reasonable force to safeguard children and young people. The term ‘reasonable force’ covers the broad range of actions used by staff that involves a degree of physical contact to control or restrain children/young people. This can range from guiding a child/young person to safety by the arm, to more extreme circumstances such as breaking up a fight or where a child/young person needs to be restrained to prevent violence or injury. 

‘Reasonable’ in these circumstances means ‘using no more force than is needed’. The use of force may involve either passive physical contact, such as standing between pupils or blocking a pupil’s path, or active physical contact such as leading a pupil by the arm out of the classroom. Departmental advice for ‘Use of Reasonable Force in Organisations’ organisations is available here.

This means in our organisation:

By planning positive and proactive behaviour support, the occurrence of challenging behaviour and the need to use reasonable force will reduce.

We will write individual behaviour plans for our more vulnerable children/ young people and agree them with parents and carers.

We will not have a ‘no contact’ policy as this could leave our staff unable to fully support and protect their pupils and students.

When using reasonable force in response to risks presented by incidents involving children/ young people including any with SEN or disabilities, or with medical conditions, our staff will consider the risks carefully.

This Safeguarding & Child Protection Policy cannot be separated from the general ethos of the organisation, which should ensure that pupils/students are treated with respect and dignity, taught to treat each other with respect, feel safe, have a voice, and are listened to. 

Safeguarding issues, including online safety, will be addressed through all areas of the curriculum including extra-familial harm (multiple harms).

This means that in our organisation:

All staff will be made aware of our organisation’s unauthorised absence and children missing from education procedures.

We will provide opportunities for pupils/students to develop skills, concepts, attitudes and knowledge that promote their safety and well-being. 

All our policies which address issues of power and potential harm, for example Anti-Bullying, Discrimination, Equal Opportunities, Handling, Positive Behaviour, will be inter-linked to ensure a whole organisation approach.

We also recognise the particular vulnerability of children who have a social worker.

Where unmet needs have been identified for a child/young person utilising the Right Help Right Time (RHRT) model but there is no evidence of a significant risk, the DSL will oversee the delivery of an appropriate Early Help response. 

The child/young person’s voice must remain paramount within a solution-focused practice framework.

The primary assessment document is the 2019 Early Help Assessment (EHA).

Should it be felt that a Think Family or social care response is needed to meet the unmet safeguarding need, the DSL will initiate a Request for Support, seeking advice from Children’s Advice and Support Service (CASS) as required.

The DSL will then oversee the agreed intervention from organisation as part of the multiagency safeguarding response and ongoing organisation-focused support. 

This means that in our organisation we will: implement Right Help Right Time.

All Staff will notice and listen to children and young people, sharing their concerns with the DSL in writing.

Safeguarding leads will assess, plan, do and review plans.

Senior leaders will analyse safeguarding data and practice to inform strategic planning and staff CDP.

The DSL will generally lead on liaising with other agencies and setting up the Our Family Plan. This multi-agency plan will then be reviewed regularly, and progress updated towards the goals until the unmet safeguarding needs have been addressed. 

In our organisation although any member of staff can refer a situation to CASS, it is expected that the majority are passed through the DSL team.

With effect from 1st July 2015, all organisations are subject to a duty to have “due regard to the need to prevent people being drawn into terrorism” (section 26, Counter Terrorism and Security Act 2015).  This is known as The Prevent Duty.

The current threat from terrorism in the United Kingdom may include the exploitation of vulnerable people, to involve them in terrorism or in activity in support of terrorism.  The normalisation of extreme views may also make children and young people vulnerable to future manipulation and exploitation. 

Definitions of radicalisation, terrorism and extremism, and indicators of vulnerability to radicalisation are in Appendix 4.

This means that our organisation:

• Values freedom of speech and the expression of beliefs and ideology as fundamental rights underpinning our society’s values.
• acknowledges that pupils/students and teachers have the right to speak freely and voice their opinions.

However, freedom comes with responsibility and free speech that is designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued.  Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, community safety and community cohesion. 

The organisation governors, Safeguarding Lead and the DSL will assess the level of risk within the organisation and put actions in place to reduce that risk.  Risk assessment may include consideration of the organisation’s RE curriculum, SEND policy, assembly policy, the use of organisation premises by external agencies, integration of pupils/students by gender and SEN, anti-bullying policy and other issues specific to the organisation’s profile, community and philosophy. To this end, open source due diligence checks will be undertaken on all external speakers invited to our organisation. An example of this can be found here.

The setting is required to identify a Prevent Single Point of Contact (SPOC) who will be the lead within the organisation for safeguarding in relation to protecting individuals from radicalisation and involvement in terrorism: this will normally be the DSL. The responsibilities of the SPOC are described in Appendix 5.

The organisation will monitor online activity within the organisation to ensure that inappropriate sites are not accessed by pupils/students or staff. 

The organisation has a duty to cooperate with the Channel programme in the carrying out of its functions, and with the Police in providing information about an individual who is referred to Channel (Section 38, Counter Terrorism and Security Act 2015).

Channel is a multi-agency approach to provide support to individuals who are at risk of being drawn into terrorist related activity. It is led by the West Midlands Police Counter-Terrorism Unit, and it aims to:

• Establish an effective multi-agency referral and intervention process to identify vulnerable individuals;
• Safeguard individuals who might be vulnerable to being radicalised, so that they are not at risk of being drawn into terrorist-related activity; and
• Provide early intervention to protect and divert people away from the risks they face and reduce vulnerability.

Further guidance about duties relating to the risk of radicalisation is available in the Advice for Organisations on The Prevent Duty.

We are clear that this exploitation and radicalisation must be viewed as a safeguarding concern and that protecting children from the risk of radicalisation from any group (including, but not restricted to, those linked to Islamist ideology, or to Far Right/Neo-Nazi/White Supremacist, Domestic Terrorism, Irish Nationalist and Loyalist paramilitary groups, and extremist Animal Rights movements) is part of our organisation’s safeguarding duty. 

The SPOC for our organisation is:

Name: *

All staff within our organisation will be alert to changes in a child/young person’s behaviour or attitude which could indicate that they are in need of help or protection.

We will use specialist online monitoring software, which in this organisation is called *.

Our organisation will make referrals to Channel if we are concerned that an individual might be vulnerable to radicalisation.

With effect from October 2015, all organisations are subject to a mandatory reporting requirement in respect of female genital mutilation (FGM).  When a teacher suspects or discovers that an act of FGM is going to be or has been carried out on a girl aged under 18, that teacher has a statutory duty to report it to the Police. 

Failure to report such cases will result in disciplinary sanctions.  

The teacher will also discuss the situation with the DSL who will consult Birmingham Children’s Trust before a decision is made as to whether the mandatory reporting duty applies.

This means that in our organisation we ensure:

Our staff are supported to talk to families and local communities about sensitive concerns in relation to their children and to find ways to address them together wherever possible.

All staff are up to date on the latest advice and guidance provided to assist in addressing specific vulnerabilities and forms of exploitation around;

• Forced marriage
• FGM
• Honour based abuse
• Trafficking
• Criminal exploitation and gang affiliation

Our staff will be supported to recognise warning signs and symptoms in relation to each specific issue, and include such issues, in an age appropriate way, in their lesson plans.

A child going missing and or patterns of unauthorised absence, particularly repeatedly, can act as a vital warning sign of a range of safeguarding risks, including abuse and neglect, which may include sexual abuse or exploitation; child criminal exploitation; mental health problems; substance abuse and other issues. Early intervention is necessary to identify the existence of any underlying safeguarding risks and to help prevent the risk of them going missing in future.

Work around attendance and children missing from education will be coordinated with safeguarding interventions.

The organisation must notify the Local Authority of any pupil/student who has been absent without the organisation’s permission for a continuous period of 5 days or more after making reasonable enquiries

The organisation (regardless of designation) must also notify the Local Authority of any pupil/student who is to be deleted from the admission register under any of the prescribed regulations outlined in the Education (Pupil Registration) (England) Regulations 2016 amendments.

This means that in our organisation we will: 

Hold two or more emergency contact numbers for each pupil.

All our attendance work will liaise closely with the DSL.

We will adapt our attendance monitoring on an individual basis to ensure the safety of each child/young person at our organisation.

Our organisation will demonstrate that we have taken reasonable enquiries to ascertain the whereabouts of pupils/students that would be considered ‘missing’.

We will work closely with the CME Team, Organisation Admissions Service, Education Legal Intervention Team and the Elective Home Education Team.

It is important that organisation and college can recognise that children are capable of abusing their peers, and that this abuse can include bullying, physical abuse, sexting, initiation/ hazing, upskirting, sexual violence and harassment. The organisation’s values, ethos and behaviour policies provide the platform for staff and students to clearly recognise that abuse is abuse and it should never be tolerated or diminished in significance. It should be recognised that there is a gendered nature to peer-on-peer abuse i.e. that it is more likely that girls will be victims and boys’ perpetrators.

Organisations should recognise the impact of sexual violence and the fact children/young people can, and sometimes do, abuse their peers in this way. When referring to sexual violence this policy is referring to sexual offences under the Sexual Offences Act 2003 as described below: 

• Rape: A person (A) commits an offence of rape if: there is intentional penetration of the vagina, anus or mouth of another person (B) with his penis, (B) does not consent to the penetration and (A) does not reasonably believe that (B) consents. 
• Assault by penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina, anus or mouth of another person (B) with a part of her/his body or anything else, the penetration is sexual, (B) does not consent to the penetration and (A) does not reasonably believe that (B) consents. 

• Sexual assault: A person (A) commits an offence of sexual assault if: s/he intentionally touches another person (B), the touching is sexual, (B) does not consent to the touching and (A) does not reasonably believe that (B) consents.

This means that in our organisation:

We will not tolerate instances of peer-on-peer abuse and will not pass it off as “banter”, “just having a laugh” or “part of growing up”. We will recognise that “child-on-child abuse” can occur between and across different age ranges.

We will follow both national and local guidance and policies to support any children/young people subject to peer-on-peer abuse, including sexting (also known as youth produced sexual imagery) and gang violence. 

We will follow the guidance on managing reports of child-on-child sexual violence and sexual harassment in organisations.

We will utilise the Children who pose a Risk to Children Organisation Safety Plan produced by the local authority.

Our DSL will follow local guidance to enable provision of effective support to any child/young person affected by this type of abuse.

Both CSE and CCE are forms of abuse and both occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into sexual or criminal activity.

This means that in our organisation we will: 

• Notice and listen to children/ young people showing signs of being drawn in to anti-social or criminal behaviour, use the risk assessment screening tool to support our referrals to CASS for any children in our organisation we are concerned about.
• Be aware of and work with the Police and local organisations to disrupt as much as possible criminal exploitation activity within our organisation.