HAMPTON SCHOOL TRUST
This policy is published on the websites of Hampton School and Hampton Pre-Prep & Prep School and is available to parents from the Bursary or the School Office at the respective schools upon request. It can be made available in large print or another accessible format as required.
his policy applies to the Hampton School Trust (‘the Trust’), which comprises Hampton School and Hampton Pre-Prep & Prep School – HPP&P - (together also referred to as ‘the School’), for children from the Early Years Foundation Stage (EYFS) to the Upper Sixth Form.
1. Key Personnel & Contact Details for Safeguarding at School
Safeguarding Role
Designated Safeguarding Lead (DSL)
Deputy DSL (DDSL
Deputy DSL (DDSL)
Deputy DSL (DDSL)(with responsibility for Looked After Children)
Deputy DSL (DDSL)
The Headmaster, Hampton School Trust
Designated Safeguarding Lead with responsibility for the EYFS (DSL)
Deputy DSL (DDSL)
Name
Position at the School
HAMPTON SCHOOL
Owen Morris (JOM) Deputy Head
Pippa Message (PZM)
Deputy
Mark Nicholson (MAN) Deputy Head
Polly Holmes (PAH)
Assistant Head (Pastoral)
Victoria Smith (VMS) Head of Year
Kevin Knibbs (KK) The Headmaster
HAMPTON PRE-PREP & PREP SCHOOL
Tammy Howard (TH)
Imogen Murphy (IM)
Hampton Pre-Prep & Prep Headmaster
Tim Smith (TS)
Deputy Head (Pastoral) Hampton Pre-Prep & Prep
Head of Pre-Prep
Headmaster, Hampton Pre-Prep & Prep
Contact Details
o.morris@hamptonschool.org.uk Extension : 4400
p.message@hamptonschool.org.uk Extension : 4005
m.nicholson@hamptonschool.org.uk Extension : 4227
p.holmes@hamptonschool.org.uk
Extension :1006
v.smith@hamptonschool.org.uk Extension : 1007
headmaster@hamptonschool.org.uk
t.howard@hamptonprep.org.uk Extension: 4461
i.murphy@hamptonprep.org.uk Extension : 4480
t.smith@hamptonprep.org.uk
Extension : 4461
Safeguarding concerns can be emailed to the School Safeguarding staff (the applicable DSL and DDSLs) at safeguarding@hamptonschool.org.uk or safeguarding@hamptonprep.org.uk
GOVERNORS
Chair of Governors & Nominated Lead Safeguarding Governor Andrew Munday Governor ahm@hamptonschool.org.uk
Nominated Safeguarding Governor -Hampton School Alice Yandle Governor avy@hamptonschool.org.uk
Nominated Safeguarding Governor – HPP&P Mat Chataway Governor mcc@hamptonschool.org.uk
SCHOOL COUNSELLORS
School Counsellor Michael Uccelli Counsellor m.uccelli@hamptonschool.org.uk Extension : 4032 /4030
School Counsellor Simeron Kaler Counsellor s.kaler@hamptonschool.org.uk Extension: 4032 /4030
School Counsellor Vicci Nagli Counsellor v.nagli@hamptonschool.org.uk Extension : 4032 /4030
2. Key External Agencies, Services and Professionals’ Contact Details
Single Point of Access Richmond and Kingston (SPA) (Achieving for Children)
Local Authority Designated Officer (LADO) Service
Police Child Abuse Investigation Team (CAIT)
Kingston and Richmond Safeguarding Children Partnership (KRSCP)
Guildhall 2 High Street Kingston upon Thames KT1 1EU
Feltham Police Station, 34 Hanworth Road, Feltham, TW13 5BZ
Call 020 8547 5008 from 8am to 6pm, Monday to Friday, or 020 8770 5000 out of hours E: spa@richmond.gov.uk
020 8891 7370; 07774 332675/07936 601423
E: LADO@achievingforchildren.org.uk
Kingston and Richmond Safeguarding Children Partnership (KRSCP)Education Safeguarding Support
Initial Response
44 York Street Twickenham TW1 3BZ
Daksha Mistry (Partnership Manager)
020 8247 6331
T: 07834 386459
E: Klscb-support@kingrichlscb.org.uk
Safeguarding: Kingston
E: kingstonclustersafeguarding@achievingforchildren.org.uk
Mobile : 07876 578076
Duty: T: 020 8547 6611
Safeguarding: Richmond E: richmondclustersafeguarding@achievingforchildren.org.uk
Mobile: 07935 014637
Duty: T: 020 8891 7380
E: lscb-support@kingrichlscb.org.uk
Daksha.Mistry@kingrichlscb.org.uk
Contact Details of Children’s Services (Social Care) covering the catchment area
Surrey 0300 470 9100 (out of hours 01483 517898)
Surrey North East 0300 123 1610 (Elmbridge, Epsom, Spelthorne)
Surrey North West
Surrey West
Windsor and Maidenhead
Hounslow
Ealing
Hammersmith and Fulham
0300 123 1630 (Woking)
0300 123 1640 (Guildford)
01628 683150
020 8583 6600
020 8825 8000
0208 753 6600
Merton
Wandsworth
NSPCC / Home Office Child Abuse Whistleblowing Helpline
020 8545 4226 (out of hours 0208 770 5000)
020 8871 6622 (out of hours 0208 871 6000)
0800 028 0285 help@nspcc.org.uk
Childline 0800 1111
Police
FGM Home Office line
‘Prevent’ Contacts
Anti-terrorist hotline
Forced Marriage Unit
Teaching Regulation Agency (TRA)
The Disclosure and Barring Services (DBS)
(Non-emergency point of contact) 101
999 (for urgent calls) or non-emergency 101
DfE contact: 020 7340 7264 counter.extremism@education.gsi.gov.uk
0800 789 321
020 7008 0151 fmu@fco.gov.uk
020 7593 5393 Misconduct.Teacher@education.gov.uk
03000 200 190 customerservices@dbs.gsi.gov.uk
3. Policy Statement
This policy applies to all schools within the Hampton School Trust (‘the Trust’ or ‘the School’) which includes the EYFS setting. This policy is reviewed and updates at least annually, or when changes to legislation are made, and is available on the School website or in printed form on request from the Bursar (bursary@hamptonschool.org.uk).
This policy has regard to the following legislation, guidance and advice:
• Keeping Children Safe in Education 2025 (KCSIE) KCSIE incorporates the additional statutory guidance Disqualification under the Childcare Act 2006 (September 2018)
• Working Together to Safeguard Children 2023
• Prevent duty Guidance: Guidance for specified authorities in England and Wales (December 2023). Prevent duty guidance is supplemented by non-statutory advice and a briefing note:
o The Prevent duty: Guidance for specified authorities in England and Wales (December 2023)
o The use of social media for on-line radicalisation (July 2015)
• Relationships education, relationships, and sex education (RSE) and health education (September 2021).
• Behaviour in Schools (February 2024)
• Working together to improve school attendance: statutory guidance for maintained schools, academies, independent schools and local authorities (February 2024).
• Keeping children safe in out of school settings (September 2023)
• Digital and technology standards in schools and colleges (May 2024)
• After school clubs, community activities, and tuition (safeguarding guidance for providers) (September 2023)
• The Charity Commission guidance: Safeguarding and protecting people for charities and trustees (June 2022)
4. Management of Safeguarding
The Designated Safeguarding Lead (DSL) at each school within the Trust will take lead responsibility for safeguarding and child protection matters. Should a DSL not be available, any safeguarding or child protection issue should be reported to one of the Deputy Designated Safeguarding Leads (DDSLs). A full list of contacts can be found on page 7 … of this policy.
It is the DSL’s responsibility to maintain an overview of safeguarding within the School, to open channels of communication with local statutory agencies, refer incidents to third parties as appropriates, to support staff in carrying out their safeguarding duties and to monitor the effectiveness of the School’s policies and procedures in practice. The DSL’s responsibility also includes online safety and understanding the filtering and monitoring systems and processes which the School has in place.
The DSL regularly reviews the School’s practices regarding safeguarding and welfare matters and during term time, the DSL (and/or a DDSL) will always be available in person during school hours. For any matters that occur outside normal school hours, staff can contact the DSL or a DDSL by referring to the contact list on page 59 (Appendix 11).
The DSL (or a DDSL) should liaise with safeguarding partners and work with other agencies. The National Police Chiefs Council’s guidance can assist the DSL (or DDSL) in understanding when they should consider calling the Police and what to expect when they do. https://www.npcc.Police.uk/SysSiteAssets/media/downloads/publications/publications-log/2020/when-to-call-thePolice guidance-for-schools-and-colleges.pdf
The DSL (or DDSL) will also be responsible for liaising with the mental health support team (School Counsellors) where any safeguarding matter is linked to mental health. The DSL (or DDSL) should be confident as to what local specialist support is available to support any pupil who is or has been involved in sexual violence and sexual harassment and be confident as to how to access this support when required.
Whilst the Headmaster and the Pre-Prep & Prep Headmaster are responsible for ensuring that policies and procedures are adopted, understood, and followed by all staff and the Governors are ultimately responsible for ensuring that staff are competent, supported, and regularly reviewed in relation to safeguarding the ultimate lead responsibility for safeguarding and child protection remains with the DSL, and this responsibility must not be delegated.
5. Safeguarding and Child Protection Training
• All staff and Governors, including The Headmaster and the Pre-Prep & Prep Headmaster, receive a copy of this policy and Part 1 and Annex B of KCSIE September 2025 and will be required to confirm that they have read these. The Trust has additional procedures in place to assist staff in understanding Part 1 of KCSIE, e.g. regular staff briefings on INSET days. All staff will be advised should Part 1 of KCSIE be updated at any time before the next policy review. The Trust has additional mechanisms to assist staff understanding of Part 1, for example through regular staff briefings on INSET.
• All staff and volunteers will undertake appropriate child protection training in accordance with the Kingston and Richmond Safeguarding Children Partnership’s guidance. Initially, they are trained when they take up their posts within the Trust and will then receive regular safeguarding and child protection training, including on the Prevent Duty and on-line safety (which, amongst other things, includes an understanding of the expectations, applicable roles and responsibilities in relation to the Trust’s filtering and monitoring procedures). This training will take place as required, but at least annually, with at least termly updates. This training will take place through face-to-face training led by the DSL/DDSLs, by online questionnaires to test understanding, by presentations by outside speakers, and by the annual completion of Educare safeguarding courses.
• All new staff have induction training which includes:
i. AI Acceptable Use Policy
ii. Behaviour, Rewards, Sanctions, Discipline and Exclusions Policy
iii. IT Acceptable Use Policy
iv. Missing Pupil Policy
v. Online Safety Policy
vi. Part 1 and Annex B of KCSIE
vii. Pupil Attendance Policy
viii. Safeguarding (Child Protection) policy.
ix. School Code of Conduct
x. Social Media Policy
xi. Staff Behaviour Policy
xii. The role and identity of the DSL and DDSLs.
xiii. Whistleblowing Policy
• The DSL receives updated child protection training at least every two years to provide them with the knowledge and skills required to carry out the role. Amongst other topics, this training includes local interagency working protocols, participation in child protection case conferences, training in the approach to Prevent duties and further in-depth training on extremist and terrorist ideologies and how to work with Channel panels.
6. Oversight of Safeguarding, including Arrangements for Reviewing Policies & Procedures
• The Chair of Governors (currently Mr Andrew Munday) takes the lead in relation to responsibility for safeguarding arrangements throughout the Trust.
• The Trust’s Safeguarding (Child Protection) Policy is reviewed at least annually. Where necessary, updates are made prior to the next scheduled review. This process also includes an evaluation of the effectiveness of the policy’s procedures and their implementation.
• The policy is available on both schools’ websites.
7. Equality Act
The School understands and recognises its obligations under the Equality Act and that it must not discriminate against pupils because of a protected characteristic including sex, race, disability, religion or belief, gender reassignment, pregnancy, maternity or sexual orientation. In the context of safeguarding, the School will consider how to support pupils with regard to particular protected characteristics in order to meet their specific needs. The School will also consider its duty to make reasonable adjustments for disabled pupils.
The School also complies with its legal duties under the Equality Act 2010, including putting special provision in place to support pupils who may not be able to communicate as they may want to, e.g. for those for whom English is not their first language.
8. Definitions of Child Protection and Safeguarding and Types and Signs of Abuse
Safeguarding and promoting the welfare of children is defined as providing help and support to meet the needs of children as soon as problems emerge; protecting children from maltreatment, whether that is within or outside the home, including online; preventing impairment of children’s mental and physical health or development; ensuring that children grown up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes.
Child protection is part of safeguarding and promoting the welfare of children and is defined as activity that is undertaken to protect children who are suspected to be suffering, or like to suffer, significant harm. This includes harm that occurs inside or outside the home, including online.
Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Harm can include ill treatment that is not physical as well as the impact of witnessing ill treatment of others. This can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by other (e.g. via the internet). Abuse can take place wholly online, or technology may be used to facilitate offline abuse. They may be abused by an adult or adults, or by another child or children. Abuse can be:
• physical abuse;
• Emotional abuse;
• Sexual abuse; and/or
• Neglect
Staff should refer to Appendix 2 of this policy for further information regarding the types of abuse and possible signs of abuse, as well as further information regarding specific safeguarding issues such as child criminal and/or sexual exploitation.
9. Procedures for Dealing with Concerns About a Child
The School has a duty to consider the best interest of the pupil at all times and to take action to enable all pupils to achieve the best outcomes. Safeguarding and promoting the welfare of children is everyone’s responsibility. The School adopts a ‘whole school’ approach to safeguarding, meaning involving everyone in the school and ensuring that safeguarding and child protection are at the forefront and underpin all relevant aspects of process and policy development.
The School has arrangements for listening to pupils and providing early help where required Situations may arise when the School may need to share information with children’s social care without parental consent, for example, where notifying parents could increase the risk to the pupil
If any member of staff suspects or hears of an allegation or complaint of abuse, exploitation or neglect from a pupil or any third party, they must act immediately and following the relevant procedure below. Staff should not assume that somebody else will act or share information that might be critical in keeping children safe.
The guidance Information Sharing: Advice for Practitioners Providing Safeguarding Services to Children, Young People, Parents and Carers click here supports staff who have to make decisions about sharing information. The School recognises the importance of information sharing between practitioners and local agencies, including ensuring arrangements for sharing information within the School and with local authority children’s social care, the safeguarding partners and other organisations, agencies and practitioners as required. Any fears regarding the sharing of information under the Data Protection Act 2018 (DPA) and the UK General Data Protection Regulation (UK GDPR) must not be allowed to prohibit safeguarding or the welfare of children; neither prevent the sharing of information for the purposes of keeping children safe. Should staff have any questions, they should refer to the Designated Safeguarding Lead (DSL) or one of the Deputy Designated Safeguarding Leads (DDSLs).
The School ensure that staff understand the relevant data protection principles which allow them to share (and withhold) personal information, including:
• Being confident of the processing conditions which allow staff to store and share information for safeguarding purposes, including information which is sensitive and person and which should be treated as ‘special category personal data’.
• Understanding that ‘safeguarding of children and individuals at risk’ is a processing condition which allows the sharing of special category personal data, including without consent where there is good reason to do so, for example if it is not possible to gain consent or gaining consent would place a child at risk.
• Not providing pupils’ personal data where the serious harm test is met.
All staff should:
• Listen carefully;
• Avoid asking leading questions;
• Observe a pupil’s behaviour;
• Reassure an individual that the allegation/complaint will be taken seriously and that they will be supported and kept safe;
• Ensure that the individual is not made to feel ashamed for making a report and neither should they be given the impression that by doing so, they are creating a problem.
• Not guarantee absolute confidentiality (as this may ultimately not be in the best interests of a child) and explain that the information needs to be passed to the appropriate person who will ensure that the correct action is taken;
• Be aware that the individual may not feel ready or know how to tell someone that they are being abused, exploited or neglected, and/or may not recognise their experiences as harmful. Staff should exercise professional curiosity and speak to the DSL if they have concerns.
• Determine how best to build trusted relationships with children and young people which facilitate communication.
All concerns, discussions and decisions (including the rationale for those decisions) made under these procedures should be recorded in writing. This includes instances where referrals were, or were not, made to another agency. This will help in any response to a complaint about the way a case has been handled. The record should include a clear and comprehensive summary of the concern, details of how the concern was followed up and resolved, and a note of any action taken including dates, times, locations of any conversations, and what was said/done by whom and in whose presence. The record should be stored securely, maintaining confidentiality and ensuring that it is only accessible to those who need to see it, and only shared in accordance with the guidance set out in KCSIE.
Where an allegation relates to harmful sexual behaviours, the disclosure should, if possible, be managed with two members of staff present, including the DSL or a DDSL.
Where there is a safeguarding concern, the School will ensure that the pupil’s wishes and feelings are considered when determining what action to take and what services to provide. This is particularly important in the context of harmful behaviours, such as sexual harassment and sexual violence. The School manages this by ensuring that systems are in place that are well promoted, easily understood and easily accessible for pupils, enabling them to confidently report any abuse knowing that they will be treated seriously and knowing that they can freely express their views.
10. Information from Previous Schools/Settings
• It is a legal requirement that schools should be informed of any safeguarding/child protection issues that may have arisen in a pupil’s previous school/setting. The Trust gathers this information before any new pupil joins Hampton School or HPP&P. This information allows the Trust to ensure any relevant measures are in place before a pupil arrives and that relevant staff are aware of any needs.
• In accordance with the Kingston and Richmond Safeguarding Child Partnership, the Trust informs the Local Authority of any pupils leaving or joining either school at a non-standard transition time.
11. Contextual Safeguarding
Safeguarding incidents and/or behaviours can be associated with factors, and can occur between children, outside the School. The DSL and DDSLs should consider the context within which such incidents and/or behaviours occur and the School will, as part of the wider assessment of children, consider whether environmental factors are present in a child’s life that are a threat to their safety and/or welfare. The School will share as much information as possible with Children’s Social Care as part of the referral process to enable consideration of all the available evidence and the full context of any abuse.
12. Preventing Radicalism
• The School has a duty, under the Counter-Terrorism and Security Act 2015, to have due regard to the need to prevent people from being drawn into terrorism (‘the Prevent Duty’).
• Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism. Further information can be found in Appendix 4.
• Protecting pupils from the risk of radicalisation is part of the Trust’s wider safeguarding duties, in the same way as protecting them from any other forms of harm or abuse.
• Staff should use their professional judgement in identifying pupils who may be at risk of radicalisation and refer any concerns to the DSL or a DDSL.
• Staff should follow the School’s referral processes when there are concerns about any pupil who may be susceptible to radicalisation and then terrorism. This may include a Prevent referral or a referral to children’s social care, depending on the level of risk. However, if a member of staff has concerns that there is an immediate/significant risk of a pupil being drawn into terrorism they should call 999 or the Prevent Officer (see page 7) and advise the DSL immediately.
• The Trust help to protect pupils from extremist views in a number of ways including PHSE/Life Skills lessons, staff training, online safety, filtering and monitoring and ensuring visiting speakers are suitable.
• The DSL oversees and co-ordinates the implementation of the Trust’s Prevent Duty. The DSL and DDSLs undertake Prevent-awareness training and are able to provide advice and support to other members of staff.
• A Prevent Risk Assessment has been compiled to identify potential risks and to establish appropriate measures in response. This can be found on SharePoint.
13. Early Help
Any child may benefit from early help, but all staff should be particularly alert to the potential need for early help for a pupil who:
• Is disabled or has certain health conditions and possible specific additional needs.
• Has special educational needs (whether or not they have a statutory education, health, and care plan);
• Has a mental health needs;
• Is a young carer;
• Is showing signs of being drawn in to anti-social or criminal behaviour, including gang involvement as association with organised crime groups, or county lines.
• Is frequently missing/goes missing from education, home or care.
• Has experienced multiple suspensions, is at risk of being permanently excluded from schools, or in Alternative Provision or a Pupil Referral Unit.
• Is misusing drugs and/or alcohol.
• Is at risk of modern slavery, trafficking, and/or sexual or criminal exploitation.
• Is in a family situation which presents challenges for the child, such as substance abuse, adult mental health problems or domestic abuse.
• Is at risk of being radicalises or exploited.
• Has a parent or carer in custody or is affected by parental offending.
• Is a privately fostered child.
• Is at risk of so-called ‘honour based’ abuse such as Female Genital Mutilation (FGM) or Forced Marriage.
Early help is support for children of all ages which improves resilience and outcomes or reduces the chance of a problem getting worse. Early help may be appropriate for children who have several needs or whose circumstances might make them more vulnerable.
The School has effective measures in place to identify emerging problems and potential unmet needs of individual pupils. All staff undertake appropriate training to ensure that they know when to share information with other agencies and what action to take to support early identification and assessments.
If a member of staff identifies a pupil who may benefit from early help, they should discuss this with the DSL. Where appropriate, the DSL will work with colleagues, including external partners, to undertake an assessment of the need for early help. The DSL will support staff in liaising with external agencies and professionals as appropriate. Further guidance on effective assessment of the need for early help can be found in Working Together to Safeguard Children (December 2023) click here
If early help is appropriate, the matter will be kept under review and consideration given to a referral to children’s social care if the pupil’s situation does not appear to be improving.
14. What Staff Should Do if they have Concerns about a Child
If any member of staff, or member of the School community (including governors, contractors, and volunteers) have any concerns about a pupil (as opposed to a pupil being in immediate danger) they should speak to the DSL (or a DDSL) to agree a course of action; staff can make a direct referral to children’s social care.
If a member of staff, or a member of the School community, discovers an act of Female Genital Mutilation (FGM) has been carried out, they should report this to the Police and, unless there is a very good reason not to, discuss the matter with the DSL and involve children’s social care as appropriate. Staff should refer to Appendix 1.
Staff should never assume that somebody else will act or share information that may be critical in keeping a child safe. Should any member of the School community, other than the DSL, make a referral, they should inform the DSL as soon as is practicably possible and if a pupil’s situation does not appear to be improving, the DSL should press children’s social care for reconsideration. Staff should challenge any inaction and follow it up with the DSL. All concerns, discussions and decisions made, and the reasons for those decisions, should be recorded in writing (see point 7 above).
15. What Staff Should Do if a Child is in Danger or at Risk of Harm
If a member of staff, or any member of the School community, believes that a child is in immediate danger or at risk of harm, they should make an immediate referral to children’s social care and/or the Police. A referral can be made by anybody and should be done immediately, or within 24 hours (one working day) of being made aware of the risk. Parental consent is not needed for referrals to statutory agencies such as the Police or children’s social care. Staff should make the DSL aware if they do make a referral. The local authority should acknowledge a referral within 24 hours and make a decision about the next steps. Staff should challenge any inaction. All concerns, discussions and decisions made, and the reasons for those decisions, should be recorded in writing. .
16. What staff should do if they have concerns that a pupil is at risk from or involved with serious violent crime
All staff should be aware of those indicators which may signal that a pupil is at risk from or is involved with serious violent crime. These may include increased absence from School, a change in friendship, or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, signs of assault or unexplained injuries.
If staff have any concerns about a child (as opposed to a child being in immediate danger), they should, where possible, speak to the DSL to agree a course of action although staff can make a direct referral to children’s social care.
17. How should staff respond to an incident of nudes and semi-nudes being shared by pupils?
All members of staff have a duty to recognise and refer any incidents involving nudes and semi-nudes and are equipped with the appropriate safeguarding training to enable them to recognise such concerns.
In the context of this policy, ‘sharing nudes/semi-nudes’ means the sending or online posting of nude or semi-nude images, videos or live streams by persons under the age of 18. This could be via one of the many social media platforms or chat apps and forums. It could also involve sharing between devices, e.g. via Apple AirDrop which works offline.
The term ‘nudes and semi-nudes’ may refer to (non-exhaustive):
• Youth-produced sexual imagery or ‘youth involved’ sexual imagery
• Indecent imagery. This is the legal term used to define nude or semi-nude images and videos of children and young people under the age of 18.
• ‘Sexting’ – some young people interpret sexting as ‘writing and sharing explicit messages with people they know’ rather than sharing images.
• Image-based sexual abuse. This term maybe used when referring to the nonconsensual sharing of nudes and semi-nudes.
Terms such as ‘revenge porn’ and ‘upskirting’ are also used to refer to specific incidents of nudes and semi-nudes being shared. However, these terms are more often used in the context of adult-to-adult non-consensual image sharing offences..
Terms such as ‘deep fake’ and ‘deep nudes’ may also be used by adults and young people to refer to digitally manipulated and AI-generated nudes and semi-nudes. Any direct disclosure by a pupil will be taken seriously and staff should ensure that in order to minimise further stress or trauma, the pupil is made to feel comfortable and that only appropriate, and sensitive, questions will be asked. Staff should refer any incident involving nudes or semi-nudes to the DSL as soon as possible who, in turn, will follow the DDMSC/UKIS (Department for Science, Innovation and Technology and UK Council for Internet Safety) advice which includes:
• Convening an initial meeting with appropriate staff (e.g. the staff member(s) who heard the disclosure or other members of the SLT or Safeguarding team).
• Interviewing (if appropriate) the pupil(s) involved.
• Informing parents or carers at an early stage and keeping them involved in the process unless it is felt that this would put the pupil at risk of harm. Any decision not to inform parents should be made in conjunction with other services – i.e. children’s social care or the Police.
• Carrying out a risk assessment to determine whether there is a concern that a pupil has been harmed or is at risk of immediate harm at any point during the process.
The School’s approach to sharing of nudes and semi-nudes is that if a member of staff becomes aware of an incident involving the sharing of nudes of or by a child, they should follow the safeguarding procedures set out in this policy and refer to the DSL as soon as possible. An immediate referral to the Police and/or children’s social care will be made if any of the following points apply:
• The incident involves an adult. Where an adult poses as a child to groom or exploit a child or young person, the incident may first present as a child-on-child incident.
• There is reason to believe that a pupil has been coerced, blackmailed or groomed, or there are concerns about their capacity to consent
• The images or videos suggest that the content depicts sexual acts which are unusual for the pupil’s developmental age or are violent.
• The images involve sexual acts, or involve a young person or young people under the age of 13.
• There is reason to believe a pupil is at immediate risk of harm owing to the sharing of nudes and seminudes – e.g. they are presenting as suicidal or self-harming.
If none of the above apply, the School may decide to respond to the incident without involving external services. All incidents relating to nudes and semi-nudes being shared need to be recorded, whether they have been referred externally or not. The decision to respond to an incident without involving the Police or children’s social care will only be made in cases where the DSL is confident that they have enough information to assess the risks to any pupil involved and that the risks can be managed within the School’s pastoral framework., Any such decision will be made by the DSL will be based on consideration of the best interests of the pupil. All such decisions will be recorded by the DSL and will be reviewed throughout the process of responding to an incident.
This guidance does not apply to the sharing of images of persons under 18 by an adult over 18; this constitutes child sexual abuse and any member of staff becoming aware of such an incident should immediately inform the DSL who in turn should inform the Police.
18. Pupils Absent from Education
Frequent or prolonged absenteeism can be a warning sign to a number of safeguarding issues including neglect and sexual or criminal exploitation.
The School has robust procedures to monitor unauthorised absence or repeated and prolonged absence. Staff should refer to policies C06 Pupil Attendance and C17 Missing Pupil which can be found on Cezanne in the relevant school’s Workspace. The School will endeavour to liaise with parents/carers regarding any instance of persistent absenteeism and any pupil who is absent without permission for a continuous period of 10 days or more will be reported to the local authority.
Should a pupil have a social worker, the DSL will be notified and this may inform decisions regarding absenteeism. At all times, decisions should be made in the pupil’s best interests and consideration given to promoting their welfare (e.g. provision of pastoral or academic support).
19. Safeguarding Concerns About Another Member of Staff
If a member of staff has a safeguarding concern about another member of staff or any member of the School community, including governors, volunteers, or contractors they should refer the matter to the Headmaster (or the Pre-Prep & Prep Headmaster, as appropriate). All allegations will be taken seriously. Staff should refer to Appendix 6 – Dealing with Allegations or Concerns about Members of Staff, the Headmaster, Governors, or Volunteers for further guidance.
Staff should also familiarise themselves with Appendix 10 – Low Level Concerns Policy (A32) which can be found on Cezanne (see point 20 below).
Staff should also be aware that any such disclosure is covered by the School’s Whistleblowing Policy (A17).
20. Safeguarding Concerns or Allegations About Organisations or Individuals Using School Premises
If the School receives an allegation or concern relating to an incident that has occurred on School premises but which involved an individual or organisation using the premises for the purposes of running activities for external groups, the School will follow its safeguarding policy and procedures, including informing the LADO.
External hirers of Trust properties are required to submit their own safeguarding policy as well as sign the School’s terms and conditions of hire. External providers are required to fully comply with the DfE guidance – After school clubs, community activities, and tuition (safeguarding guidance for provi8ders)) (September 2023) and the School will see assurance in this regard.
21. Allegations
Against Pupils: child -on-child abuse, including sexual violence and sexual harassment
Child-on-child abuse is abuse by one or more children against another child (see Appendix 3). Such abuse can manifest itself in many ways and can occur both inside and outside of school and online. Examples of such abuse include physical abuse (hitting, kicking etc.), cyber bullying, sexting, initiation/hazing type violence and rituals, upskirting, sharing of nudes and semi-nudes etc.
The School adopts a zero-tolerance approach to all forms of abuse. Abusive behaviour is taken seriously and must never be dismissed or minimised as ‘banter’, ‘just having a laugh’, or ‘part of growing up’.
Each School within the Trust follows its own Anti-Bullying Policy, which outlines how allegations of bullying or abusive behaviour are managed. Pupils are regularly taught about acceptable behaviour and the consequences of inappropriate conduct.
22. Dealing with Low-Level Concerns
A low-level concern is any concern where an adult working in, or on behalf of the School, may have acted in a way that:
• is inconsistent with the Staff Behaviour Policy, including behaviour outside of work, and
• does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the LADO
A low-level concern does not mean that the concern is insignificant. It may be no more than giving a sense of unease or a ‘nagging doubt’ and such behaviour can exist on a wide spectrum – from the inadvertent or thoughtless, or behaviour that may seem inappropriate but might not be in specific circumstances, to that which is ultimately intended to enable abuse (e.g. grooming).
Staff must share all concerns with the DSL or The Headmaster or Pre-Prep & Prep Headmaster as soon as possible so that it can be recorded and dealt with appropriately and in a timely manner. Should a low-level concern be raised about The Headmaster or Pre-Prep & Prep Headmaster. Staff are also encouraged to self-refer in the event they have found themselves in a situation that may be misinterpreted or appear compromising to others., or if they feel that they have behaved in a way that may be considered to fall below the expected professional standard. Any such concerns will be dealt with appropriately and proportionately. The School will also reflect on reported concerns in order to identfy any patterns of problematic or inappropriate behaviour and which may indicate a weakness in the School’s safeguarding protocols. Where necessary or appropriate, additional training may be given and School policies amended. All reported low-level concerns will be recorded in writing. These records will be held securely and kept confidential in compliance with the Data Protection Act 2018 and the UK GDPR regulations.
Where a low-level concern relates to a person not in the School’s employ but who works on School premises, the individual’s employer will be notified.
The School has a separate Low-Level Concerns Policy (A32) which is appended to this policy – Appendix 10 - and all staff should familiarise themselves with this.
23. Notifying Parents
In the event of any concern regarding a pupil, the DSL will normally make contact with the parent(s). However, if the School feels that there is a legitimate risk to a pupil by notifying parents, the DSL will first contact the Single Point of Access.
24. Safer Recruitment
The School’s Recruitment, Selection & Disclosure policy (A28) outlines the School’s protocols and procedures regarding staff recruitment.
The School is committed to safer recruitment processes to create a culture that safeguards and promotes the welfare of children in the School whilst deterring and preventing people who are unsuitable to work with children from applying or securing employment, or volunteering opportunities, within the School.
Members of the teaching and non-teaching staff at the School including part-time staff, temporary and supply staff, and visiting staff, such as musicians and sports coaches are subject to the necessary statutory child protection checks before starting work, for example, right to work checks, additional overseas checks (if necessary), verifying identity, taking up references, checking work history and confirming medical fitness for the role. For most appointments, an enhanced DBS check with “barred list” information will be appropriate. A DBS certificate will be obtained from the candidate before or as soon as practicable after appointment. Alternatively, if the applicant has subscribed to it and gives permission, the School may undertake an online update check through the DBS Update Service.
As part of the shortlisting process, the School will also consider carrying out an online search on shortlisted candidates as part of its due diligence. This may help to identify any incidents or issues that have happened and are publicly available online, which the School may want to explore with an applicant at interview. This forms part of the School’s wider safeguarding due diligence which aims to prevent and/or deter individuals who may be unsuitable to work with children from working in a school environment.
Full details of the School’s safer recruitment procedures are set out in the School’s Recruitment, Selection and Disclosure Policy & Procedure.
24.1
Visiting Speakers
The Trust ensures that all Visiting Speakers are suitable and appropriately supervised for the duration of their visit. Any member of staff wishing to invite a speaker must first complete a Visiting Speaker form which can be downloaded from SharePoint. Copies can also be found in the Common Room at Hampton and can be requested from the Office Manager at HPP&P. The request form should be submitted to either JOM or PZM at Hampton or TH or IM at HPP&P; they may decide that a written risk assessment is also required. See Appendix 7
24.2
External Contractors
The School’s protocols regarding contractors on site can be found in policy B29 Contractor Code of Practice.
25. Teaching Pupils about Safeguarding
• Safeguarding, including online safety, is covered as a topic in PHSE lessons at Hampton (Life Skills lessons at HPP&P). Through these lessons, pupils are helped to adjust their behaviour, both inside and outside of School, in order to reduce risks. This includes raising awareness of the risks of radicalisation and extremism; teaching pupils about the safe use of electronic equipment and the internet and the risks posed by adults or young people, who use the internet and social media to bully, groom, abuse or radicalise other people, especially children, young people and vulnerable adults. The Trust recognises that a “one size fits all” approach may not be appropriate for all children, and a more personalised or contextualised approach for more vulnerable children, victims of abuse and some children with SEND might be needed.
• The PHSE/Life Skills programme also covers other topics which play a part in safeguarding children; these topics include Relationships, Sex and Health Education, where relevant issues are taught in a sensitive and age-appropriate manner with regard to the statutory guidance; they also include Anti-Bullying and Online Safety among other topics.
• PSHE/Life Skills plays a crucial role in preventative education that prepares pupils and students for life in modern Britain and creates a culture of zero tolerance for prejudice. Teaching supports a clear set of values and standards that are also underpinned by the school/college’s behaviour policy and pastoral support system
• Pupils are encouraged to share any concerns they may have with their Form Tutor, Head of Year, Mentor, or any other member of staff. The School Counsellors and School Nurses are available on-site should any pupil wish to speak to them. They can be contacted directly:
School Counsellors : counselling@hamptonschool.org.uk
School Nurses : nurse@hamptonschool.org.uk
• Information regarding the identity of the DSL and DDSLs is displayed prominently around the School and a notice Where to go if you have a concern or need help is displayed in every form room at Hampton. Pupils can also raise a personal concern, or a concern regarding another person, by emailing safeguarding@hamptonschool.org.uk or safeguarding@hamptonprep.org.uk
26. Online Safety & Filtering and Monitoring
The Trust has put in place appropriate filters and monitoring systems to protect children while being mindful not to place unnecessary restrictions on their learning. Hampton Trust uses Smoothwall to filter the content on the School network and also uses Smoothwall Monitor to monitor the online behaviour of users of the network (and use of School-issued laptops), to safeguard children from potentially harmful and inappropriate online material. These systems aim to reduce the risk of children being exposed to illegal, inappropriate or harmful materials online for example: pornography, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation, extremism, misinformation, disinformation (including fake news) and conspiracy theories (content risk); reduce the risk of children being subjected to harmful online interaction with others including commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes (contact risk); restrict access to online risks such as online gambling, inappropriate advertising, phishing and/or financial scams (commerce risk); and help manage online behaviour that can increase a child’s likelihood of, or causes, harm for example making, sending and receiving explicit images e.g. consensual and non-consensual sharing of nudes and semi-nudes and/or pornography, sharing other explicit images and online bullying (conduct risk)
The School fully complies with the Department for Education’s published filtering and monitoring standards which set out that schools should:
• Identify and assign roles and responsibilities to manage filtering and monitoring systems.
• Review filtering and monitoring provision at least annually.
• Block harmful and inappropriate content without unreasonably impacting teaching and learning.
• Have effective monitoring strategies in place that meet their safeguarding needs.
The School has regard to the DfE’s guidance ‘Generative AI: product safety expectations’ when considering how the filtering and monitoring arrangements in place apply to the use of generative AI within education. The School ensures that any Generative AI products effectively and reliably prevent access to harmful and inappropriate content by pupils by:
• integrating the highest standards of filtering possible within the product, and
• applying the School's wider filtering and monitoring solutions to the use of AI tools.
The School has in place a separate AI Policy which sets out further detail in this regard.
In addition, the Trust has safeguarding screen-capture software that records and monitors key phrases and images to ensure content accessed via the School network is appropriate.
The filtering and monitoring software provides information and alerts on pupils’ activity and behaviour on the School network and School laptops. Safeguarding staff (the DSL(s) and DDSLs , along with Mr R. Davieson (Online Safety Officer at Hampton School) review this information at least daily (on School working days) and any potential concerns are evaluated to ensure that they are addressed appropriately. Alerts received outside School hours or in School holidays may not be picked up until the next School term time working day. The School’s filtering and monitoring systems are designed to support child safeguarding, but parents remain primarily responsible for supervising their child’s online activity outside School hours.
At Hampton School, the Online Safety Officer receives reports on pupil use of the School’s network and online activity and the Deputy Heads receive reports on teaching and support staff use of the School’s network and online activity. Should the need arise, the Safeguarding Team and Heads of Year are informed of any misuse. At HPP&P these protocols are carried out by the DSL and the DDSL.
Staff are reminded that should they have any concerns regarding the effectiveness of the filtering and monitoring system, they must report the matter to the DSL (or other member of the Safeguarding team) as soon as possible. Similarly, should they accidently access prohibited or inappropriate content, they should also report to the Safeguarding team.
If staff find that the system has inadvertently blocked access to websites that are used in school, they should report this to the IT Department via helpdesk@hamptonschool.org.uk.
Pupils are made aware that internet usage is monitored and they are advised that they must report any accidental access to unauthorised material to a member of the teaching staff. They should also report any websites that are normally used for school work should they be blocked.
Further information regarding the School’s procedures can be found in the Online Safety Policy and the Social Media Policy.
27. Security and Use of School Premises for non-School Activities
• All visitors to the School are required to sign in at Reception where they will be given a Visitors’ Badge.
• All visitors are accompanied by a member of staff for the duration of their visit.
• Third-party organisations wishing to hire the School’s facilities where services or activities are not under the direct supervision or management of the School are required to submit their own risk assessments and Safeguarding policies for review by the School prior to any contracts being agreed. This applies regardless of whether or not the children attending are on the School roll.
• The School will see assurance that any external hirer fully complies with the DfE guidance After school clubs, community activities, and tuition (safeguarding guidance for providers) (September 2023).
• The School will ensure that the DSL or a DDSL can be contacted at all times when the premises are in use, whether or not the activity is a School, or non-School, activity.
• Should the School receive notice of any safeguarding concern during an external hire, this will be managed in accordance with the School’s Safeguarding Policy and the LADO informed as required.
28. Photography and Images
• Staff and parents should refer to the detailed information regarding the Trust's use of images set out in the Policy on Taking, Storing and Using Images of Pupils; this is appended to the Trust's Privacy Notice which can be found on the School's websites.
• As set out in its Terms and Conditions, the Trust includes pupil images in online and print marketing material and communications. Such material will not include reference to pupils' full names without parental consent. Guidelines for staff taking images for these purposes are set out in the Staff Behaviour Policy.
• Parents who do not want their child's name or image to appear in online and print marketing material and communications must ensure their child knows this and must contact the School via bursary@hamptonschool.org.uk, requesting an acknowledgement of their request.
• Staff at Hampton Pre-Prep & Prep must only use the Schools' cameras and devices; they must not take images of pupils using their personal photographic equipment (including cameras, iPads or mobile phones) unless prior permission has been given by the Hampton Pre-Prep & Prep Headmaster.
• Parents or close family members may take images of their own children taking part in School events or activities as long as they follow the guidelines set out in the Policy on Taking, Storing and Using Images of Pupils (appended to the Trust's Privacy Notice). Such images are for personal use only and must be taken with consideration and courtesy. Parents should not take images of other pupils, except incidentally as part of a group shot, without the prior agreement of that pupil's parents. To respect the privacy of others, and in some cases for child protection purposes, any images taken should not be made accessible to others via the internet (for example on social media), or published in any other way.
29. Early Years Foundation Stage
• The lead member of staff responsible for safeguarding pupils in the early years setting (pupils under the age of eight) is Head of Pre-Prep (Imogen Murphy) who is also DDSL for HPP&P.
• All staff appointments in the EYFS are subject to the School’s Safer Recruiting protocols and checks will be made on all applicants as to whether, under the Childcare Act 2006, there is any reason for disqualification.
• There are additional responsibilities for the Trust as set out in the Statutory Framework for the Early Years Foundation Stage (EYFS). Registered providers must notify Ofsted within 14 days of receiving any allegation of serious harm or abuse by any person living with, working with or looking after a pupil, whether or not the alleged abuse was committed on School premises. The School will also inform the local Early Years’ Service as well as the SPA.
• In accordance with the Statutory Framework for EYFS, termly supervision meetings take place between the Head of Pre-Prep and the staff there.
• In accordance with HPP&P’s Terms and Conditions, parents consent to physical contact with their child where such contact is consistent with good practice and is appropriate and proper for the purposes of teaching and instruction, providing comfort to a pupil in distress, or, where necessary, ensuring the pupil’s health and welfare, safety, or the maintenance of good order. Please refer to the Restrictive Physical Intervention Policy for further information.
29.1 Use of cameras, mobile phones and other electronic devices in EYFS
• Members of staff at HPP&P are not permitted to use their own phones/cameras/ device in any School setting unless prior permission has been granted by the Hampton Pre-Prep & Prep Headmaster. The School has a number of cameras for use in School, or any other School setting.
• The use of mobile phones, cameras or any other electronic device with imaging and sharing capabilities is strictly forbidden in the EYFS area.
• Staff must comply with the Staff Behaviour Policy and the Staff IT Acceptable Use Policy.
• Refer to point 29 above.
30. Pupils Potentially at Greater Risk of Harm
i. Pupils with special educational needs (SEN) and disabilities
Pupils with special educational needs (SEN) and disabilities can face additional safeguarding challenges and staff should be aware that further barriers can exist when recognising abuse, neglect or exploitation in this group of pupils. For example:
a. Assumptions that indicators of possible abuse, such as behaviour, mood and injury, relate to the pupil’s disability without further exploration;
b. Pupils with SEN and disabilities can be disproportionally impacted by factors such as bullying or child-onchild abuse, without outwardly showing any signs.
c. Communication barriers and difficulties in overcoming these.
Staff should support such pupils in expressing any concerns they may have and will be particularly vigilant to any signs or indicators of abuse, discussing this with the DSL as appropriate.
ii. Children requiring mental health support
• Staff should be aware that mental health problems can, in some cases, be an indicator that a child has suffered, or is at risk of suffering, abuse, neglect or exploitation. There is no expectation on staff to diagnose a mental health condition but they may notice behaviours which could be of concern.
• If a member of staff has a mental health concern about a pupil which may also be a safeguarding concern, they should inform the DSL or one of the DDSLs. Staff can refer to the School’s Mental Health Policy for further details.
iii. Children who need a social worker
When a pupil has a social worker, it is an indicator that the child is more at risk than most pupils. It may mean that they are more vulnerable to further harm as well as facing barriers to attendance, learning, behaviour and poor mental health. The DSL will ensure that these needs are taken into account when making plans to support such a pupil.
iv. Looked After Children
• There are designated staff within the Trust who are responsible for any Looked After pupil – i.e. any pupil on roll who is being looked after by the local authority. At Hampton, this is Polly Holmes (Assistant Head & DDSL) and at HPP&P, Tammy Howard (Deputy Head & DSL).
• Looked After children are more vulnerable and can, therefore, be at greater risk of abuse, neglect or exploitation. Staff can refer to the School’s Looked After Children policy. The DSLs (or DDSLs) will provide appropriate assistance when making plans to support such children.
v. LGBT & Gender-Questioning Pupils
• A child or young person being lesbian, gay or bisexual is not in itself an inherent risk factor for harm, however, they can sometimes be targeted by other children. In some cases, a pupil who is perceived by their peers to be lesbian, gay or bisexual (whether they are or not) can be just as vulnerable as children who are.
• When supporting a gender questioning child, the School will take a cautious approach and consider the broad range of the pupils’ individual needs, in partnership with the parents (other than in the exceptionally rare circumstances where involving parents would constitute a significant risk of harm to the child), including any clinical advice that is available and how to address wider vulnerabilities such as the risk of bullying. The School will refer to (to the extent that it is reflected in KCSIE), the draft DfE guidance for schools and colleges in relation to Gender Questioning Children, when deciding how to proceed. Risks can be compounded where children lack trusted adults with whom they can be open. The School endeavours to reduce the additional barriers faced and create a culture where they can speak out or share their concerns with members of staff.
31. School Trips and Off-Site Arrangements
This policy applies during any School trip or off-site activity and should be read in conjunction with each school’s Educational Visits policy and with the Staff Behaviour policy.
32. Safeguarding Record Keeping
• Safeguarding records are kept securely on CPOMS (Child Protection Online Monitoring and Safeguarding System), including all reports, notes and correspondence referring to a pupil. Pupils who have a safeguarding file in addition to their normal School file have a sticker placed on the front of their normal School file with this information. Safeguarding information is confidential and should not be kept on the child’s School file. Parents do not have automatic access to the safeguarding file.
• Schools should be notified by children's social care when a child on the safeguarding register starts at the Trust, or if a pupil’s name has been placed on the register or removed from the register. If a safeguarding file has been started for a pupil who then moves school, the file should be sent to the receiving school/college. The information should be sent securely under separate cover, in a sealed envelope to the DSL of the receiving school/college, marked ‘Strictly Confidential’.
• Not all safeguarding information results in a referral. A record is made of any information, including hearsay and ‘nagging doubts’. So that all information can be kept together, this information should be passed to the DSL/DDSLs using the email address safeguarding@hamptonschool.org.uk or safeguarding@hamptonprep.org.uk (as appropriate). Alternatively, staff can fill in a Log of a Concern About a Child's Safety and Welfare (see Appendix 9) which can be found on SharePoint (for Hampton School) or in the Documents area (Safeguarding) on Cezanne for HPP&P.
Hampton School - click here
Hampton Pre-Prep & Prep - click here
• All safeguarding concerns, discussion and decisions should be recorded in writing. A record should include:
▪ A clear and comprehensive summary of the concern;
▪ Details of how the concern was followed up and resolved, including the rationale for any decisions made, and a note of any action taken, decisions reached and the outcome.
▪ If in doubt about the recording requirements, staff should discuss with the DSL.
• Access to safeguarding files: access to the information on file should be on a need-to- know basis among the staff. This can only be decided on a case-by-case basis. The confidentiality of the pupil and family should be respected as far as possible, but the welfare of the pupil is paramount.
• All information must be shared with children's social care and/or Police as appropriate, where there is concern that a pupil is at risk of significant harm. Safeguarding information should not ordinarily be shared with agencies other than these statutory agencies e.g. information should not be released to solicitors etc.
• The Data Protection Act 2018 and UK GDPR place duties on organisations and individuals to process personal information fairly and lawfully and to keep the information they hold safe and secure, but it does not prevent the sharing of information for the purposes of keeping children safe. For more guidance see“Information Sharing: Advice for practitioners providing safeguarding services to children, young people, parents and carers” (July 2018).
• Staff Guidelines – Retention of Documents outlines how long the Trust retains information relating to safeguarding matters.
Appendix 1 - The Designated Safeguarding Lead (DSL) and Deputy DSLs (DDSLs)
In accordance with Annex C of KCSIE September 2025, the main responsibilities of the DSL are set out below. These activities can be delegated to the Deputy DSLs (DDSLs), although the ultimate responsibility remains with the DSL. Within the Hampton Trust there are separate DSLs for Hampton School and HPP&P. During term time the DSL (or deputy) should always be available (during school hours) for staff to discuss any safeguarding concerns
Training
The DSL and Deputy DSLs are trained to the same standard and their job descriptions include the key activities of their role. They undertake child protection (Level 3) training and training in inter-agency working, and this is updated at two-yearly intervals. In addition, their knowledge and skills should be refreshed or updated (for example by e-bulletins, meeting with other DSLs etc.) at regular intervals, at least annually. This training is completed in order to:
• understand the assessment process for providing early help and intervention, for example through locally agreed common and shared assessment processes such as early help assessments;
• have a working knowledge of locally agreed procedures for child protection and inter-agency working, in particular how local authorities conduct a child protection case conference and a child protection review conference and be able to attend and contribute to these effectively when required to do so;
• ensure each member of staff has access to and understands the school’s Safeguarding Policy and procedures and the Staff Behaviour Policy;
• are alert to and support the specific needs of children in need, those with special educational needs and young carers;
• are able to keep detailed, accurate and secure written records of concerns and referrals;
• understand and support the school with regard to the requirements of the Prevent duty and are able to provide advice and support to staff on protecting children from the risk of radicalisation;
• obtain access to resources and attend any relevant or refresher training courses including training on harmful sexual behaviours in children; and
• encourage a culture of listening to children and taking account of their wishes and feelings, among all staff, in any measures the school may put in place to protect them.
In each School the DSL/DDSL responsibilities are as follows, as stipulated in KCSIE:
Managing referrals
• to take lead responsibility for referring cases of suspected abuse, neglect, or exploitation of any pupil within the School to children's social care, working with the Kingston and Richmond Safeguarding Children Partnership (including the Multi-Agency Threshold Document 2020), or other local authorities as appropriate. The DSL must be aware of pupils who have a social worker and ensure they are supported appropriately.
• to support staff who make referrals to children's social care.
• to take lead responsibility for making referrals to the Disclosure and Barring Service (DBS) where a member of staff is dismissed or resigns in circumstances where there has been actual harm, or risk of harm, to a pupil and the Teaching Regulation Agency (as appropriate).
• to take lead responsibility for making referrals to the Police where a crime may have been committed which involves a pupil.
• to act as a source of support, advice and expertise to staff on matters of safety and safeguarding and when deciding whether to make a referral by liaising with relevant agencies.
Working with others
• act as a point of contact with the safeguarding partners (particularly Achieving for Children and the Kingston and Richmond Safeguarding Children Partnership), having have a working knowledge of how local authorities conduct a child protection case conference and a child protection review conference and be able to attend and contribute to these effectively when required to do so; they attend the KRSCP DSL termly forums;
• liaising with The Headmaster in respect of Police investigations or investigations under section 47 of the Children Act 1989 that involve the Trust. This should include being aware of the requirement for children to have an Appropriate Adult;
• as required, liaise with the “case manager” (as per Part four) and the local authority designated officer(s) (LADO) for child protection concerns in cases which concern a staff member;
• liaise with staff (particularly key pastoral staff, School nurses, School Counsellors, the SEND department, mental health trainers) on matters of safety and safeguarding;
• promote supportive engagement with parents and/or carers in safeguarding and promoting the welfare of children;
Raising Awareness
• ensure this policy is reviewed annually and the procedures and implementation are updated and reviewed regularly, and work with the governing body regarding this;
• ensure this policy is available publicly;
• ensure that parents are aware that referrals about suspected abuse, neglect or exploitation may be made to children's social care and the trust’s role in this;
• maintain links with the Kingston and Richmond safeguarding children partnership to ensure staff are aware of training opportunities and the local policies on safeguarding;
• taking responsibility for online safety, understanding the unique risks associated with online safety and be confident that they have the relevant knowledge and capability to keep pupils safe online; they must understand the additional risks that pupils with SEN and disabilities (SEND) face online.
Information Sharing and Managing Child Protection Records
• ensure that child protection files are kept up to date and held confidentially and securely, keep detailed, accurate records of concerns and referrals;
• understand the importance of information sharing, both within the school and with other schools, as well as with safeguarding partners and other agencies;
• the DSL will ensure that when a pupil leaves the applicable school, the child protection file must be transferred to the new school or college as soon as possible (and within five days for an in-year transfer or within the first five days of the start of the new term). they should consider whether it would be appropriate to share information in advance of the pupil leaving, if that would assist putting support in place for when the pupil arrives.
Prevent
The DSL is responsible for ensuring that the Trust’s “Prevent” Duty is met. The DSL will complete appropriate “Prevent” awareness training. The DSL is expected to:
• refer cases to the Channel programme where there is a radicalisation concern;
• support staff who make referrals to the Channel programme.
Appendix 2 - Types and Signs of Abuse
All School staff should be aware that abuse, neglect, exploitation and safeguarding issues are rarely standalone events and cannot be covered by one definition or one label alone. In most cases, multiple issues will overlap with one another therefore staff should always be vigilant and always raise any concerns with the DSL (or DDSL). All staff should be aware that safeguarding incidents and/or behaviours can be associated with factors outside the school and/or can occur between children outside of these environments. All staff, but especially the DSLs and DDSLs, should consider whether children are at risk of abuse or exploitation in situations outside their families. Extra-familial harms take a variety of different forms and children can be vulnerable to multiple harms including (but not limited to) sexual exploitation, criminal exploitation, sexual abuse, serious youth violence and county lines. All staff should be aware that technology is a significant component in many safeguarding and wellbeing issues and should recognise that children are at risk of abuse online as well as face to face. In many cases abuse will take place concurrently online and in daily life. Staff should be aware that children can also abuse their peers online, this can take the form of abusive, harassing, and misogynistic messages, the non-consensual sharing of indecent images, especially around chat groups, and the sharing of abusive images and pornography, to those who do not want to receive such content. In all cases, if staff are unsure, they should always speak to the DSL (or DDSL).
Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning, or scalding, drowning, suffocating or otherwise causing physical harm to a child (including through corporal punishment). Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.
Sexual abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet)., Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.
Sexual abuse also includes sexual violence and sexual harassment (see below) which can occur between two children of any sex (also known as child-on-child abuse). This can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children. Sexual violence and sexual harassment are sexual offences under the Sexual Offences Act 2003, such as rape, sexual assault, and by penetration. Staff should be aware that sexual assault covers a very wide range of behaviour so a single act of kissing someone without consent or touching someone’s bottom/breasts/genitalia without consent, can still constitute sexual assault.
Sexual harassment: is ‘unwanted conduct of a sexual nature’ that can occur online and offline and both inside and outside of school. Sexual harassment is likely to violate a child’s dignity, and/or make them feel intimidated, degraded, or humiliated and/or create a hostile, offensive or sexualised environment. Sexual harassment can include sexual comments, such as telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance and calling someone sexualised names; sexual "jokes" or taunting; physical behaviour, such as deliberating brushing against someone, interfering with someone’s clothes, or upskirting, and sharing of unwanted explicit content (for example displaying pictures, photos or drawings of a sexual nature); and online sexual harassment, which might include consensual or non-consensual sharing of sexual images and videos (often referred to as the sharing of nudes/semi-nudes, or sexting – see below); inappropriate sexual comments on social media; exploitation; coercion and threats. Online sexual harassment may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence.
Child-on-child sexual violence and/or harassment: Sexual violence and sexual harassment can occur between two children of any age and sex, from primary through to secondary stage and into colleges. It can occur through a group of children sexually assaulting or sexually harassing a single child or group of children. It is more likely that girls will be the victims of sexual violence and harassment, and it is more likely that it will be perpetrated by boys. It can however occur between children of any sex. Sexual violence and sexual harassment exist on a continuum and may overlap; they can occur online and face to face (both physically and verbally) and are never acceptable. Children who are victims of sexual violence and/or sexual harassment wherever it happens, will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment and will be exacerbated if the alleged perpetrator(s) attends the same school or college.
Harmful sexual behaviour: problematic, abusive and violent sexual behaviour is developmentally inappropriate and may cause developmental damage. A useful umbrella term is “harmful sexual behaviour”. Harmful sexual behaviour can occur online and/or face-to-face and can also occur simultaneously between the two. Sexual behaviour between children can be considered harmful if one of the children is much older, particularly if there is more than two years’ age difference, or if one of the children is pre-pubescent and the other is not. However, a younger child can abuse an older child, particularly if they have power over them, for example, if the older child is disabled or smaller in stature.
Sharing of nudes and/or semi-nudes: the sending or posting of nude or semi-nude images, videos, or live streams online by young people under the age of 18. This could be via social media, gaming platforms, chat apps or forums. It could also involve sharing between devices via services like Apple’s AirDrop which works offline. The sharing of nudes and semi-nudes can happen publicly online, in 1:1 messaging or via group chats and closed social media accounts and may include images or footage of more than one child or young person.
Alternative terms used by children and young people may include ‘dick pics’ or ‘pics’ or may be referred to by adults or professionals as ‘youth produced/involved sexual imagery’, ‘indecent imagery’, ‘image based sexual abuse’ or ‘sexting’.
The motivations for taking and sharing nude and semi-nude images, videos and live streams are not always sexually or criminally motivated. Such images may be created and shared consensually by young people who are in relationships, as well as between those who are not in a relationship. It is also possible for a young person in a consensual relationship to be coerced into sharing an image with their partner. Incidents may also occur where:
• children and young people find nudes and semi-nudes online and share them claiming to be from a peer
• children and young people digitally manipulate an image of a young person into an existing nude online
• images created or shared are used to abuse young people e.g. by selling images online or obtaining images to share more widely without consent to publicly shame (often referred to as ‘sexploitation’)
For this reason, incidents can either be classified as 'aggravated' or 'experimental'. The DDCMS / UKIS guidance "Sharing nudes and semi-nudes: advice for education settings working with children and young people" sets out the classification of incidents, and how each should be handled.
Upskirting: is a criminal offence and typically involves taking a picture under a person’s clothing (not necessarily a skirt) without their permission and/or knowledge, with the intention of viewing their genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim humiliation, distress or alarm. Anyone of any sex can be a victim.
Neglect: the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate caregivers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
Serious violence: indicators which may signal that children are at risk from, or are involved with serious violent crime include increased absence from School, a change in friendships or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, or signs of assault or unexplained injuries. Unexplained gifts or new possessions could also indicate that children have been approached by, or are involved with, individuals associated with criminal networks or gangs and may be at risk of criminal exploitation. All staff should be aware of the associated risks which increase the likelihood of involvement in serious violence (for example, being male, frequent absence from school or permanently excluded from school, experienced child maltreatment or having been involved in offending) and understand the measures in place to manage these.
Specific safeguarding issues: behaviours linked to drug taking, alcohol abuse, truanting and sexting put children in danger. Safeguarding issues can also manifest themselves via child-on-child abuse, such as abuse within intimate partner relationships, bullying (including cyberbullying), gender-based violence/sexual assaults, sexting and upskirting. Safeguarding issues can also be linked to, for example, children missing or absent from education; child sexual exploitation; domestic violence; fabricated or induced illness; faith abuse (including ostracism of families); female genital mutilation; forced marriage; gangs and youth violence; gender-based violence / violence against women and girls; hate; mental health; preventing radicalisation; relationship abuse; sexting; consensual and nonconsensual sharing of nudes and semi-nudes; and trafficking.
Child sexual exploitation (CSE): CSE is a form of child sexual abuse (see above) which occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity (a) in exchange for something the victim needs or wants (for example, money, gifts or affection), and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources.
The victim may have been sexually exploited even if the sexual activity appears consensual. CSE does not always involve physical contact; it can also occur through the use of technology. CSE can affect any child or young person (male or female) under the age of 18 years (including 16 and 17 year olds who can legally consent to have sex) who has been coerced into engaging in sexual activities. It can include both contact (penetrative and non-penetrative acts) and non-contact sexual activity and may occur without the child or young person’s immediate knowledge (e.g. through others copying videos or images they have created and posted on social media). Some children may not realise they are being exploited e.g. they believe they are in a genuine romantic relationship.
CSE can be a one-off occurrence or a series of incidents over time and range from opportunistic to complex organised abuse. It can involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence.
The child criminal exploitation (CCE) indicators below an also be indicators of CSE, as can:
• children who have older boyfriends or girlfriends, and
• children who suffer from sexually transmitted infections, display sexual behaviours beyond expected sexual development or become pregnant.
The DfE has published guidance on this entitled "Child sexual exploitation: guide for practitioners". CSE may occur alone, or may overlap with CCE, and/or county lines, as well as other forms of abuse.
Child criminal exploitation (CCE): CCE is where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into any criminal activity (a) in exchange for something the victim needs or wants (for example, money, gifts or affection), and/or (b) for the financial or other advantage (such as increased status) of the perpetrator or facilitator and/or (c) through violence or the threat of violence. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources. The victim may have been criminally exploited even if the activity appears consensual. CCE does not always involve physical contact; it can also occur through the use of technology.
CCE can include children being forced to work in cannabis factories, being coerced into moving drugs or money across the country (county lines, see below), forced to shoplift or pickpocket. They can also be forced or manipulated into committing vehicle crime or threatening/committing serious violence to others.
Children can become trapped by this type of exploitation as perpetrators can threaten victims (and their families) with violence or entrap and coerce them into debt. They may be coerced into carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from others. Children can be exploited by adult males or females, as individuals or in groups. They may also be exploited by other children, who themselves may be experiencing exploitation – where this is the case, their vulnerability as victims is not always recognised by adults and professionals (especially when they are older children). It is important in these circumstances that the child perpetrator is also recognised as a victim.
• Some of the following can be indicators of CCE: children who appear with unexplained gifts, money, or new possessions
• children who associate with other children involved in exploitation
• children who suffer from changes in emotional well-being
• children who misuse drugs and alcohol
• children who go missing for periods of time or regularly come home late, and
• children who regularly miss school or education or do not take part in education.
The experience of girls who are criminally exploited can be very different to that of boys. The indicators may not be the same, however staff should be aware that girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.
CCE may occur alone, or may overlap with CSE, and/or county lines, as well as other forms of abuse. Children who have been exploited will need additional support to help maintain them in education.
County lines: County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs, using dedicated mobile phone lines or other form of “deal line”.
This activity can happen locally as well as across the UK - no specified distance of travel is required. Children and vulnerable adults exploited to sell drugs and move and store drugs and money. Offenders will often use coercion, intimidation, violence (including sexual violence) and weapons to ensure compliance of victims. Children can be targeted and recruited into county lines in a number of locations including schools (mainstream and special), further and higher educational institutions, pupil referral units, children’s homes and care homes. Children are increasingly being targeted and recruited online using social media. Children can easily become trapped by this type of exploitation as county lines gangs can manufacture drug debts which need to be worked off or threaten serious violence and kidnap towards victims (and their families) if they attempt to leave the county lines network.
A number of the ways of identifying indicators for CSE and CCE as detailed above may be applicable to where children are involved in county lines. Some additional specific indicators that may be present where a child is criminally exploited through involvement in county lines are children who:
• who go missing and are subsequently found in areas away from their home;
• that have been the victim or perpetrator of serious violence (e.g. knife crime);
• are involved in receiving requests for drugs via a phone line, moving drugs, handing over and collecting money for drugs;
• are exposed to techniques such as ‘plugging’, where drugs are concealed internally to avoid detection;
• are found in accommodation that they have no connection with, often called a ‘trap house or cuckooing’ or hotel room where there is drug activity;
• owe a ‘debt bond’ to their exploiters;
• have their bank accounts used to facilitate drug dealing.
Further information on the signs of a child’s involvement in county lines is available in guidance published by the Home Office.
Modern Slavery: Modern slavery encompasses human trafficking and slavery, servitude and forced or compulsory labour. Exploitation can take many forms, including sexual exploitation, forced labour, slavery, servitude, forced criminality and the removal of organs. Further information on the signs that someone may be a victim of modern slavery, the support available to victims and how to refer them to the National Referral Mechanism is available in the statutory guidance "Modern slavery: how to identify and support victims (June 2021)".
Cybercrime: is criminal activity committed using computers and/or the internet. It is broadly categorised as either ‘cyber-enabled’ (crimes that can happen off-line but are enabled at scale and at speed on-line) or ‘cyber dependent’ (crimes that can be committed only by using a computer). Cyber- dependent crimes include:
• unauthorised access to computers (illegal ‘hacking’), for example accessing a school’s computer network to look for test paper answers or change grades awarded;
• denial of Service (Dos or DDoS) attacks or ‘booting’. These are attempts to make a computer, network, or website unavailable by overwhelming it with internet traffic from multiple sources; and,
• making, supplying, or obtaining malware (malicious software) such as viruses, spyware, ransomware, botnets, and Remote Access Trojans with the intent to commit further offence, including those above.
Children with particular skill and interest in computing and technology may inadvertently or deliberately stray into cyber-dependent crime.
If there are concerns about a child in this area, the DSL (or a DDSL), should consider referring into the Cyber Choices programme. This is a nationwide police programme supported by the Home Office and led by the National Crime Agency, working with regional and local policing. It aims to intervene where young people are at risk of committing, or being drawn into, low level cyber-dependent offences and divert them to a more positive use of their skills and interests. Cyber Choices does not currently cover ‘cyber-enabled’ crime such as fraud, purchasing of illegal drugs on-line and child sexual abuse and exploitation, nor other areas of concern such as online bullying or general on-line safety.
Additional advice can be found at: Cyber Choices, ‘NPCC- When to call the Police’ and National Cyber Security Centre - NCSC.gov.uk.
Mental health: all staff should be aware that mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.
Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem. Staff, however, are well placed to observe children day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one.
Where children have suffered abuse and neglect, or potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. It is key that staff are aware of how these children’s experiences can impact on their mental health, behaviour, and education.
If staff have a mental health concern about a child that is also a safeguarding concern, immediate action should be taken, following this policy, and speaking to the DSL or a DDSL.
The DfE has published advice and guidance on Preventing and Tackling Bullying, and Mental Health and Behaviour in Schools. In addition, Public Health England has produced a range of resources to support secondary and senior school teachers to promote positive health, wellbeing and resilience among young people including its guidance Promoting Children and Young People’s Emotional Health and Wellbeing. Its resources include social media, forming positive relationships, smoking and alcohol.
So called ‘honour based’ abuse: encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation (FGM), forced marriage, and practices such as breast ironing.
Whilst Hampton School is a boys’ school, there are girls in the Pre-Prep. Staff may also become aware of a sibling or family member of a pupil being at risk of so called ‘honour based’ abuse; Hampton pupils and staff are also involved in activities involving girls at neighbouring schools.
Abuse committed in the context of preserving “honour” often involves a wider network of family or community pressure and can include multiple perpetrators. It is important to be aware of this dynamic and additional risk factors when deciding what form of safeguarding action to take.
FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. Guidance on the warning signs that FGM may be about to take place, or may have already taken place, can be found in the Multi-agency statutory guidance on FGM. To give an example of indications that a girl has already been subjected to FGM:
• A pupil may have difficulty walking, sitting, or standing and may even look uncomfortable.
• A pupil may have frequent urinary, menstrual or stomach problems or spend longer than normal in the bathroom due to difficulties urinating.
• There may be prolonged or repeated absences from School and/or noticeable behaviour changes (e.g. withdrawal or depression) on the pupil’s return.
• A pupil is reluctant to undergo medical examination.
If staff have a concern that a pupil may be at risk of FGM, they should speak to the DSL (or DDSL) who will (where appropriate) activate local safeguarding procedures, using existing national and local protocols for multi-agency liaison with Police and Children’s Social Care.
There is a statutory duty on teachers to personally report to the Police where they discover (either through disclosure by the victim or visual evidence) that FGM appears to have been carried out on a girl under 18. Unless the teacher has a good reason not to, they should still consider and discuss any such case with the DSL and involve children’s social care as appropriate. If the teacher is unsure whether this reporting duty applies, they should discuss their concerns with the DSL in accordance with this policy. Where a teacher suspects that a pupil is at risk (i.e. where the teacher does not discover that an act of FGM appears to have been carried out, either through disclosure by the victim or visual evidence) or it involves a pupil over 18, teachers should follow the School’s local safeguarding procedures.
Further information can be found in the Multi-agency statutory guidance on female genital mutilation and the FGM resource pack
Forced marriage: Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some communities use religion and culture as a way to coerce a person into marriage. Schools can play an important role in safeguarding children from forced marriage.
The Forced Marriage Unit (FMU) has crated: Multi-agency practice guidelines: handling cases of forced marriage and, Multi-agency statutory guidance for dealing with forced marriage. Both can be found at The right to choose: government guidance on forced marriage (www.gov.uk).
School staff can also contact the Forced Marriage Unit if they need advice or information: Contact: 020 7008 0151 or email fmu@fco.gov.uk.
Since February 2023 it has also been a crime to carry out any conduct whose purpose is to cause a child to marry before their eighteenth birthday, even if violence, threats or another form of coercion are not used. As with the existing forced marriage law, this applies to non-binding, unofficial ‘marriages’ as well as legal marriages
Radicalisation: Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism. A new definition of extremism was published by the Government in March 2024. Extremism is the promotion or advancement of an ideology based on violence, hatred or intolerance, that aims to:
1. Negate or destroy the fundamental rights and freedoms of others; or
2. Undermine, overturn or replace the UK’s system of liberal parliamentary democracy and democratic rights; or
3. Intentionally create a permissive environment for others to achieve the results in (1) or (2).
Simply put, extremism is vocal or active opposition to fundamental British values.. It can also call for the death of members of the armed forces, whether in this country or overseas. Terrorism is an action that endangers or causes serious violence to a person/people; causes serious damage to property; or seriously interferes or disrupts
an electronic system. The use or threat must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious, or ideological cause.
There is no single way of identifying whether a child is likely to be susceptible to an extremist ideology. Background factors combined with specific influences such as family and friends may contribute to a child’s susceptibility . Similarly, radicalisation can occur through many different methods (such as social media or the internet) and settings (such as within the home). As with other safeguarding risks, staff should be alert to changes in children’s behaviour, which could indicate that they may be in need of help or protection. Staff should use their judgement in identifying children who might be at risk of radicalisation and act proportionately, which may include making a Prevent referral. DSLs and other senior leaders in colleges should familiarise themselves with the Prevent duty guidance Staff should contact the DSL or the DDSL, who should be aware of the local procedures in place, before making a Prevent referral.
In the event of a child leaving, the DSL should consider, where appropriate, to share any information with the new school or college. For example, information that would allow the new school or college to continue supporting victims of abuse. For any incidents involving radicalisation, for example those who are currently receiving support through the ‘Channel’ programme or who have been previously referred due to concerns around radicalisation, then the DSL should share this information with the new school or college.
Channel is a voluntary, confidential support programme which focuses on providing support an early stage to people who are identified as being susceptible to being drawn into terrorism. An individual will be required to provide their consent before any support is provided.
Special educational needs and/or disabilities (SEND), or pupils with certain health conditions: Pupils with SEND or certain health conditions can face additional safeguarding challenges. These children may not outwardly show signs of abuse and/or may have difficulties in communication about abuse or neglect, or bullying. These can include:
• assumptions that indicators of possible abuse such as behaviour, mood and injury relate to
• the child’s condition without further exploration;
• the potential for children with SEND or certain health conditions being disproportionally impacted by behaviours such as peer group isolation or bullying (including prejudice-based bullying), without outwardly showing any signs; and
• communication barriers and difficulties in managing or reporting these challenges.
Staff will support such pupils in expressing any concerns they may have and will be particularly vigilant to any signs or indicators of abuse, discussing this with the DSL as appropriate.
Lesbian, gay, bisexual or trans ("LGBT"): A child or young person being lesbian, gay, or bisexual is not in itself an inherent risk factor for harm; however, children who are LGBT can be targeted by their peers. In some cases, a pupil who is perceived by their peers to be LGBT (whether they are or not) can be just as vulnerable as children who identify as LGBT.
Gender questioning children: When supporting a gender questioning child, schools should take a cautious approach and consider the broad range of their individual needs, in partnership with the child’s parents (other than in the exceptionally rare circumstances where involving parents would constitute a significant risk of harm to the child), including any clinical advice that is available and how to address wider vulnerabilities such as the risk of bullying.
Domestic abuse: The Domestic Abuse Act 2021 received Royal Assent on 29 April 2021. The Act introduces the first ever statutory definition of domestic abuse and recognises the impact of domestic abuse on children, as victims in their own right, if they see, hear, or experience the effects of abuse. The statutory definition of domestic abuse, based on the previous cross-government definition, ensures that different types of relationships are captured, including ex-partners and family members. The definition captures a range of
different abusive behaviours, including physical, emotional, and economic abuse and coercive and controlling behaviour. Both the person who is carrying out the behaviour and the person to whom the behaviour is directed towards must be aged 16 or over and they must be “personally connected” (as defined in section 2 of the 2021 Act).
Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse and child/adolescent to parent violence and abuse.
Anyone can be a victim of domestic abuse, regardless of gender, age, ethnicity, socio- economic status, sexuality or background and domestic abuse can take place inside or outside of the home. The government will issue statutory guidance to provide further information for those working with domestic abuse victims and perpetrators, including the impact on children.
All children can witness and be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members. Experiencing domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.
Young people can also experience domestic abuse within their own intimate relationships. This form of child-onchild abuse is sometimes referred to as ‘teenage relationship abuse’. Depending on the age of the young people, this may not be recognised in law under the statutory definition of ‘domestic abuse’ (if one or both parties are under 16). However, as with any child under 18, where there are concerns about safety or welfare, child safeguarding procedures should be followed and both young victims and young perpetrators should be offered support. The Act’s provisions, including the new definition, will be commenced over the coming months.
Domestic Abuse may lead to other safeguarding concerns and should therefore be managed under this policy.
Homelessness: Being homeless, or at risk of homelessness presents a real risk to a child's welfare. The School should be aware of potential indicators of homelessness including household debt, rent arrears, domestic abuse, and anti-social behaviour, as well as a family being asked to leave a property. If staff are made aware or suspect that a pupil may be at risk of homelessness they should talk to the DSL in the first instance. Whilst referrals to the Local Housing Authority should be progressed as appropriate, and in accordance with local procedures, this does not and should not replace a referral to local authority children’s social care where a child has been harmed or is at risk of harm.
Children who are absent from education: A child absent from School, particularly repeatedly and/or for prolonged periods is a potential indicator of a range of safeguarding issues including abuse, neglect, exploitation, sexual abuse, CSE and CCE. It can also be a sign of child criminal exploitation including involvement in county lines. It may indicate mental health problems, risk of substance abuse, risk of travelling to conflict zones, risk of FGM, so-called ‘honour’- based abuse or risk of forced marriage. Staff must follow the School’s procedures for dealing with children who go missing, particularly persistently. The School’s procedure for dealing with children who go missing can be found in the School’s Missing Pupil Policy. All unexplained absences will be followed up in accordance with this Missing Pupil Procedure.
The School shall inform the local authority of any pupil who is going to be added to or deleted from the School's admission register at non-standard transition points in accordance with the requirements of the Education (Pupil Registration) (England) Regulations 2006 (as amended). This will assist the local authority to:
a) fulfil its duty to identify children of compulsory school age who are missing from education, and b) follow up with any child who might be in danger of not receiving an education and who might be at risk of abuse, neglect or radicalisation.
School attendance registers are carefully monitored to identify any trends. The School will inform the local authority (and the local authority where the child is normally resident) of any pupil who fails to attend school
regularly or has been absent without the School’s permission for a continuous period of 10 school days.at such intervals as are agreed between the School and the local authority.
Action should be taken in accordance with this policy if any absence of a pupil from the School gives rise to a concern about their welfare. The School's policy supports identification of abuse and provides preventative measures against the risk of the child going missing in the future. This applies when issues are first emerging as well as where children are already known to the local authority children's social care and need a social worker.
Child abduction and community safety incidents: Child abduction is the unauthorised removal or retention of a minor from a parent or anyone with legal responsibility for the child. Child abduction can be committed by parents or other family members; by people known but not related to the victim (such as neighbours, friends, and acquaintances); and by strangers.
Other community safety incidents in the vicinity of a school can raise concerns amongst children and parents, for example, people loitering nearby or unknown adults engaging children in conversation.
As children get older and are granted more independence (for example, as they start walking to school on their own) it is important they are given practical advice on how to keep themselves safe. Many schools provide outdoor-safety lessons run by teachers or by local police staff.
It is important that lessons focus on building children’s confidence and abilities rather than simply warning them about all strangers. Further information is available at: www.actionagainstabduction.org
Children and the court system: Children are sometimes required to give evidence in criminal courts, either for crimes committed against them or for crimes they have witnessed. There are two age appropriate guides to support children 5-11 year olds and 12-17 year olds available on the gov.uk website. The guides explain each step of the process and support and special measures that are available. There are diagrams illustrating the courtroom structure and the use of video links is explained.
Making child arrangements via the family courts following separation can be stressful and entrench conflict in families. This can be stressful for children. The Ministry of Justice has launched an online child arrangements information tool with clear and concise information on the dispute resolution service. The School may refer some parents and carers to this service where appropriate.
Children with family members in prison: Approximately 200,000 children in England and Wales have a parent sent to prison each year. These children are at risk of poor outcomes including poverty, stigma, isolation, and poor mental health. The National Information Centre on Children of Offenders, NICCO provides information designed to support professionals working with offenders and their children, to help mitigate negative consequences for those children.
Appendix 3 - Arrangements For Dealing With Child-On-Child Allegations (Including Child-On-Child Sexual Violence And Harassment)
Child-on-child abuse is abuse by one or more children against another child. It can be standalone or as part of wider abuse and can happen both inside and outside of school, and online. It can manifest itself in many ways and can include abuse within intimate partner relationships, bullying (including cyber bullying, prejudice-based and discriminatory bullying), abuse within intimate partner relationships between peers, physical abuse (such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm), initiation/hazing type violence and rituals, upskirting, sexting, consensual and non-consensual sharing of nudes and/or semi-nudes, sexual assault, genderbased issues, sexual behaviours including child-on-child sexual violence and sexual harassment, causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party. It can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children.
These arrangements apply to all reports and concerns of child-on-child abuse, whether they have happened in school or outside of it, and/or online. Abuse that occurs online or outside of school should not be downplayed and should be treated equally seriously.
Staff will always address inappropriate behaviour (even if it appears to be relatively innocuous) to help prevent problematic, abusive and/or violent behaviour in the future. Abusive comments and interactions should never be passed off or dismissed as "banter" or "part of growing up". Nor will harmful sexual behaviours, including sexual comments, remarks or jokes and online sexual harassment, be dismissed as the same or "just having a laugh" or "boys being boys". Staff will also challenge physical behaviours (that are potentially criminal in nature), such as grabbing bottoms, breasts and genitalia, pulling down trousers, flicking bras and lifting up skirts. Dismissing or tolerating such behaviours risks normalising them. Staff will take a zero-tolerance approach to all forms of sexual harassment and will always challenge and report it.
The Trust acknowledges that even if there have been no reported cases of child-on-child abuse in relation to pupils within the School, such abuse may still be taking place but not being reported. The School will ensure that children are aware of how they can report abuse, and that they are aware of the procedures that the School will follow once a report has been made. These procedures will be well promoted and in a format that is easily accessible and easily understood by children.
The Trust recognises that a child is likely to disclose an allegation to someone they trust: this could be any member of staff. By making such a disclosure the pupil is likely to feel that the member of staff is in a position of trust. The School also recognises that children may not find it easy to tell staff about their abuse verbally and that instead they may show signs or act in ways they hope adults will notice and react to. It is also recognised that an incident may come to a member of staff's attention through a report of a friend, or by overhearing conversations. It is therefore important that all staff are clear on the School's policy and procedures with regards to child-on-child abuse and can recognise the indicators and signs of child-on-child abuse and know how to identify it and how to respond to reports.
The Trust recognises that a first disclosure to a trusted adult may only be the first incident reported. It is not necessarily representative of a singular incident. Staff will take all reports of abuse seriously regardless of how long it has taken for the child to come forward. Staff will act immediately and will support the victim when they raise a concern.
i. Children with special educational needs and disabilities (SEND)
The School recognises that children with special educational needs and disabilities (SEND) or certain health conditions can face additional safeguarding challenges and may be more prone to child-on- child group isolation or bullying (including prejudice-based bullying) than other children. The School will consider extra pastoral support for those children (and any vulnerable children), which includes monitoring through the pastoral systems of the School.
Additional learning support is provided for pupils with SEND. Pupils may also be referred for assessment by an Education Psychologist.
If staff members are unsure, they should always speak to the DSL or DDSL. The School also recognises that certain children may face additional barriers to reporting an incident of abuse because of their vulnerability, disability, sex, ethnicity and/or sexual orientation.
ii. Residential Settings
The School recognises that children can be particularly vulnerable in residential settings, for example when pupils are on School trips, and are alert to the potential for child-on-child abuse. This is due to increased risks associated with children sharing overnight accommodation.
iii. Steps to Minimise the Risk of Child-on-Child Abuse
The School takes the following steps to minimise the risk of child-on-child abuse:
• Educating all staff, pupils, and parents about this issue. This includes training staff on the nature, prevalence and effect of child-on-child abuse, and how to prevent, identify and respond to it, including: (a) Contextual Safeguarding; (b) the identification and classification of specific behaviours; and (c) the importance of taking seriously all forms of child-on-child abuse (no matter how low level they may appear) and ensuring that no form of child-on-child abuse is ever dismissed as horseplay or teasing.
• Educating pupils about the nature and prevalence of child-on-child abuse via PSHE and the wider curriculum. Pupils are frequently told what to do if they witness or experience such abuse, the effect that it can have on those who experience it and the possible reasons for it, including vulnerability of those who inflict such abuse. Pupils are regularly informed about the School's approach to such issues, including its zero tolerance policy towards all forms of child-on-child abuse.
• Ensuring that all child-on-child abuse issues are fed back to the DSL so that they can identify and address any concerning trends and pupils who may be in need of additional support.
• Working with staff, pupils and parents to address equality issues, to promote positive values, and to encourage a culture of tolerance and respect amongst all members of the School community.
• Creating a culture in which our pupils feel able to share their concerns openly, in a non- judgmental environment, and have them listened to; and responding to cases of child-on-child abuse promptly and appropriately.
• Actively referring concerns/allegations of child-on-child abuse where necessary to the Police and children’s social care.
iii. Procedures to be followed in the event of child-on-child abuse
Where an issue of pupil behaviour or bullying gives ‘reasonable cause to suspect that a child is suffering, or is likely to suffer, harm’, staff should follow the procedures below rather than the School’s Anti-Bullying and Behaviour policies:
a. Any report of child-on-child abuse will include a thorough investigation of the concerns/allegations and the wider context in which they may have occurred (as appropriate). The School will ensure a safeguarding response is in place for both the child who has allegedly experienced the abuse, and the child who has allegedly been responsible for it.
b. Unless it is considered unsafe to do so (for example, where a referral needs to be made immediately), the DSL will usually discuss the proposed action with the child/children and their parents and obtain consent to any referral before it is made. The DSL will manage the child/children's expectations about information sharing, and keep them and their parents informed of developments, where appropriate and safe to do so.
c. If a pupil is in immediate danger, or at risk of significant harm, a referral to children’s social care (if the pupil is aged under 18) and/or the Police, should be made immediately. Anyone can make a referral. Where referrals are not made by the DSL (or a DDSL) the DSL should be informed as soon as possible that a referral has been made.
d. If a member of staff thinks for whatever reason that a child may be at risk of or experiencing abuse by their peer(s), or that a child may be at risk of abusing or may be abusing their peer(s), they should discuss their concern with the DSL/DDSL without delay so that a course of action can be agreed.
e. The DSL/DDSL will discuss the concerns or allegations with the member of staff who has reported them and will, where necessary, take any immediate steps to ensure the safety of the child/all children affected.
f. The DSL/DDSL will use their professional judgement to determine whether it is appropriate for the alleged behaviour to be to be dealt with internally and, if so, whether any external specialist support is required. In borderline cases, the DSL will consult with children’s social care and/or any other external agencies on a no-names basis to determine the most appropriate response. Where the DSL considers or suspects that the behaviour in question might be abusive or violent (as opposed to inappropriate or problematic), the DSL will contact children’s social care immediately. The DSL will discuss the allegations/concerns with children’s social care and agree on a course of action, which may include:
• Manage internally with help from external specialists where appropriate and possible.
• Undertake/contribute to an inter-agency early help assessment, with targeted early help services provided to address the assessed needs of a child/children and their family.
• Refer child/children to children’s social care for a section 17 and/or 47 statutory assessment.
• Report alleged criminal behaviour to the Police
g. Where there is an incident of child-on-child abuse, the School will carry out a robust risk and needs assessment in respect of each child affected by the abuse. These risk assessments will:
• Assess and address the nature and level of risks that are posed and/or faced by the child;
• Engage the child's parents and draw upon local services and agencies to ensure that the child's needs are met in the long term.
• Consider whether any targeted interventions are needed to address the underlying attitudes or behaviour of any child; and
• Be reviewed at regular intervals in light of the child's on-going needs to ensure that real progress is being made which benefits the child.
h. If at any stage the child's needs escalate, the DSL (or DDSL) will refer the situation to children’s social care again to determine the appropriate course of action.
iv. Pupil suspension
A pupil against whom an allegation of abuse has been made may be suspended from the School during the investigation. The School will take advice from Kingston and Richmond Safeguarding Children Partnership on the investigation of such allegations and will take all appropriate action to ensure the safety and welfare of all pupils involved including the alleged victim and perpetrator(s). If it is necessary for a pupil to be interviewed by the Police in relation to allegations of abuse, the School will ensure that, subject to the advice of Kingston and Richmond Safeguarding Children Partnership, parents are informed as soon as possible and that the pupils involved are supported during the interview by an appropriate adult and until the investigation is completed. Confidentiality will be an important consideration for the School and advice will be sought as necessary from Kingston and Richmond Safeguarding Children Partnership and/or the Police as appropriate. The School will have regard to the procedures set out in KCSIE.
v. Police referrals
Police may be informed of any harmful sexual behaviours which are potentially criminal in nature. Where a report has been made to the Police, the School will consult the Police and agree what information can be disclosed to staff and others, in particular, the alleged perpetrator(s) and their parents or carers. If the DSL decides to make a referral to children’s social care and/or a report to the Police against a victim’s wishes, the reasons should be explained to the pupil and appropriate specialist support offered. The DSL may also decide that the children involved may benefit from early help and may make the necessary referral in accordance with the Kingston and Richmond Safeguarding Children Partnership referral process.
vi. Sharing of nudes and semi-nudes
The School’s approach to sharing of nudes and semi-nudes is set out in Section 17 of this policy.
Appendix 4 - The Prevent Duty: preventing radicalisation and extremism
The Prevent Duty: from 1 July 2015 specified authorities, including all schools as defined in the summary of this guidance, are subject to a duty under section 26 of the Counter-Terrorism and Security Act 2015 (“the CTSA 2015”), in the exercise of their functions, to have “due regard to the need to prevent people from being drawn into terrorism”. This duty is known as the Prevent Duty. Schools must have regard to statutory guidance issued under section 29 of the CTSA 2015 (“the Prevent guidance”). Paragraphs 57-76 of the Prevent guidance are concerned specifically with schools (but also cover childcare). The statutory Prevent guidance summarises the requirements by schools in terms of four general themes: risk assessment, working in partnership, staff training and IT policies.
• Schools are expected to assess the risk of pupils being drawn into terrorism, including support for extremist ideas that are part of terrorist ideology. This means being able to demonstrate both a general understanding of the risks affecting children and young people in the area and a specific understanding of how to identify individual children who may be at risk of radicalisation and what to do to support them. Schools and colleges should have clear procedures in place for protecting children and young people at risk of radicalisation. These procedures may be set out in existing safeguarding policies. It is not necessary for schools and colleges to have distinct policies on implementing the Prevent duty.
• The Prevent duty builds on existing local partnership arrangements. For example, governing bodies and proprietors of all schools should ensure that their safeguarding arrangements take into account the policies and procedures of Local Safeguarding Children Partnerships.
• The Prevent guidance refers to the importance of Prevent awareness training to equip staff to identify children at risk of being drawn into terrorism and to challenge extremist ideas. Individual schools are best placed to assess the training needs of staff in the light of their assessment of the risk to pupils at the School of being drawn into terrorism. As a minimum, however, schools should ensure that the DSL undertakes Prevent awareness training and is able to provide advice and support to other members of staff on protecting children and young people from the risk of radicalisation.
Schools must ensure that children and young people are safe from terrorist and extremist material when accessing the internet in schools. Schools should ensure that suitable filtering is in place; it is also important that schools teach pupils about online safety more generally.
Schools must ensure all visiting speakers are suitable and appropriately supervised. The procedures to be followed when visiting speakers are invited to School are outlined in Appendix 7 of this policy.
The Department for Education has also published advice for schools on the Prevent duty. The advice is intended to complement the Prevent guidance and signposts other sources of advice and support.
The Channel Programme: Channel is a voluntary, confidential programme which focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. It provides a mechanism for schools to make referrals if they are concerned that an individual might be vulnerable to radicalisation. An individual’s engagement with the programme is entirely voluntary at all stages. Schools and colleges that are required to have regard to Keeping Children Safe in Education are listed in the CTSA 2015 as partners required to cooperate with local Channel panels.
Indicators: (this is not an exhaustive list and vulnerability may manifest itself in other ways)
Vulnerability
• Identity Crisis - Distance from cultural/ religious heritage and uncomfortable with their place in the society around them.
• Personal Crisis – Family tensions; sense of isolation; adolescence; low self-esteem; disassociating from existing friendship group and becoming involved with a new and different group of friends.
• Personal Circumstances – Migration; local community tensions; events affecting country or region of origin; alienation from UK values; having a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy.
• Unmet Aspirations – Perceptions of injustice; feeling of failure; rejection of civic life.
• Criminality – Experiences of imprisonment; poor resettlement/ reintegration, involvement with criminal groups.
• Access to extremism / extremist influences
• Is there reason to believe that the child/young person associates with those known to be involved in extremism - because either they associate directly with known individuals, or because they frequent key locations where these individuals are known to operate?
• Is there evidence to suggest that they are accessing the internet for the purpose of extremist activity or that they possess extremist literature?
• Is there reason to believe that the child/young person has been, or is likely to be, involved with extremist/ military training camps/ locations?
• Does the young person sympathise with, or support illegal/illicit groups or articulate support for extremist causes or leaders?
• Experiences, Behaviours and Influences
• Is there evidence of extremist ideological, political or religious influence on the child/ young person from within or outside UK? Does the young person vocally support terrorist attacks, either verbally or in their written work? Do they justify the use of violence to solve societal issues? Do they use extremist narratives and a global ideology to explain personal disadvantage?
• Have international events in areas of conflict and civil unrest had a personal impact on the child/ young person resulting in a noticeable change in behaviour? It is important to recognise that many people may be emotionally affected by the plight of what is happening in areas of conflict.
• Has there been a significant shift in the young person’s behaviour or outward appearance that suggests a new social/political or religious influence?
• Has the young person come into conflict with family over religious beliefs/lifestyle/ dress choices?
• Has the young person witnessed or been the perpetrator/ victim of racial or religious hate crime or sectarianism?
• Is there a pattern of regular or extended travel within the UK or abroad, with other evidence to suggest that this is for purposes of extremist training or activity, or to locations known to be associated with extremism?
Social Factors
• Does the young person have experience of poverty, disadvantage, discrimination or social exclusion?
• Does the young person have any learning difficulties/ mental health support needs?
• Is the young person a foreign national, refugee or awaiting a decision on their immigration/ national status?
• Is there evidence that a significant adult or other in the young person’s life has extremist view or sympathies?
1 Action staff, Governors and volunteers must take
A member of staff, governor or volunteer suspecting or hearing a complaint of abuse:
i. must listen carefully to the child and keep an open mind. The individual receiving the disclosure should not take a decision as to whether or not the abuse has taken place;
ii. must not ask leading questions, i.e. a question which suggests its own answer;
iii. must reassure the child but not give a guarantee of absolute confidentiality. The individual receiving the disclosure should explain that they need to pass the information to the applicable DSL who will ensure that the correct action is taken; and
iv. must keep a sufficient written record of the conversation using a Log of Concern form (see Appendix 9) The record should include:
(a) the date and time;
(b) the place of the conversation; and
(c) the essence of what was said and done by whom and in whosepresence.
v. The record should be signed by the person making it and should use names, not initials. The record must be kept securely and handed to the DSL as soon as possible.
vi. All evidence, for example, scribbled notes, mobile phones containing text messages, clothing, computers, must be safeguarded and preserved and passed to a DSL.
All suspicions or complaints of abuse must be reported to the DSL as soon as possible, unless it is an allegation against a member of staff in which case the procedures set out in Appendix 5 should be followed. Any member of staff is able to make a referral directly to children’s social care: they are not required to report via the DSL or DDSLs. If there is a risk of immediate serious harm to a child and it is not possible to report to DSL, a referral should be made to children’s social care immediately.
Staff must be persistent in making referrals, and when they feel appropriate action has not been taken by the statutory agencies this should be recorded.
Appendix 6 - Dealing with allegations or concerns about members of staff, The Headmaster, Governors or volunteers
The School’s actions will be informed by reference to the Statutory Guidance from the Department for Education contained in Part 4 of KCSIE September 2025
All Trust staff should take care not to place themselves in a vulnerable position with a child. Guidance is given in the Staff Behaviour Policy.
The Trust’s procedures for dealing with allegations and concerns are enacted where the behaviour of a member of staff (including volunteers, supply staff and agency staff), The Headmaster, a Governor or volunteer meets any of the following criteria:
An allegation means an allegation that a staff member, volunteer or Governor has:
• behaved in a way that has harmed a child, or may have harmed a child; and/or
• possibly committed a criminal offence against or related to achild; and/or
• behaved towards a child or children in a way that indicates he or she would pose a risk of harm to children; and/or
• behaved or may have behaved in a way that indicates they may not be suitable to work with children.
Allegations/concerns that do not meet the harms threshold, hereafter referred to as ‘low level concerns
A low level concern does not mean that it is insignificant, it means that the behaviour towards child does not meet the threshold of an allegation. “A low level concern is any concern – no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ - that an adult working in or on behalf of the school or college may have acted in a way that:
• is inconsistent with the staff code of conduct, including inappropriate conduct outside of work; and
• does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the LADO.
Examples of such behaviour could include, but are not limited to:
• being over friendly with children;
• having favourites;
• taking photographs of children on their mobile phone;
• engaging with a child on a one-to-one basis in a secluded area or behind a closed door; or,
• using inappropriate sexualised, intimidating or offensive language.
All allegations and concerns will be taken seriously and a full procedure for dealing with such allegations can be found below.
Procedures Following an Allegation or Concern About a Member of Staff, The Headmaster, a Governor or a Volunteer’s Behaviour Towards a Child
1. Reporting an allegation or concern about a member of staff, TheHeadmaster, a Governor or a volunteer:
• Allegations/concerns about any member of staff (including the DSL or DDSL), or volunteer at Hampton School should be immediately reported to The Headmaster of the Hampton School Trust or in his absence to the Chair of Governors (chair@hamptonschool.org.uk). Where appropriate, The Headmaster will consult with the DSL. The allegation will be discussed immediately with the LADO and within one working day before further action is taken.
• Allegations/concerns about any member of staff (including the DSL or DDSL), or volunteer at HPP&P should be immediately reported to the Hampton Pre-Prep & Prep Headmaster, or in his absence, to The Headmaster, Hampton School Trust, or in his absence to the Chair of Governors. The allegation will be discussed immediately with the LADO and within one working day before further action is taken.
• If the allegation/concern relates to The Headmaster, the Pre-Prep & Prep Headmaster or a Governor, the Chair of Governors should be informed (chair@hamptonschool.org.uk) without notifying The Headmaster or the Pre-Prep & Prep Headmaster. Again, the allegation/concern will be discussed immediately with the LADO before further action is taken.
• Where there is a conflict of interest in reporting a matter to The Headmaster, this should be reported directly to the LADO.
• If it is not possible to report to The Headmaster, Hampton Pre-Prep & Prep Headmaster or Chair of Governors in the circumstances set out above, a report should be made immediately to the relevant DSL. The DSL will act in accordance with these procedures and will, as soon as possible, inform The Headmaster, Hampton Pre-Prep & Prep Headmaster or, where appropriate, the Chair of Governors.
• All allegations/concern about the Chair of Governors should be reported to the LADO without the Chair of Governors being informed.
• The person acting in accordance with the procedures in this Appendix is known as the ‘case manager’. Low level concerns will be handled as set out below in paragraph 8.
• In all cases, if the behaviour meets the established criteria of an allegation (see above), the case manager will contact the LADO without delay (within one working day). Advice from the LADO will be sought in borderline cases. In cases of serious harm, the Police will be involved from the outset. The Trust will not undertake its own investigation until after advice is sought from the LADO. Where an allegation relates to a member of supply staff (or contractor) provided by an agency, the agency should be fully involved after the matter is reported to the LADO. Parental consent is not required before reporting allegations to the LADO.
• Discussions with the LADO will consider the nature of the allegation and decide a course of action. Discussions should be recorded in writing.
• Any allegations not meeting this criterion will be dealt with in accordance with the Kingston and Richmond Safeguarding Children Partnership procedures.
2. The Local Authority Designated Officer (LADO):
The LADO can be contacted on 020 8891 7370; 07774 332675/07936 601423, LADO@achievingforchildren.org.uk
The LADO should initially be contacted via Richmond and Kingston Single Point of Access (SPA): 020 8547 5008 or 020 8770 5000 for out of hours; email: spa@richmond.gov.uk
3. Disclosure of information
• The Trust will observe the reporting restrictions that prevent the identification of a teacher who is subject to an allegation. The Trust has a duty of care towards its employees and unless advised otherwise by outside agencies, the Trust will inform the person against whom the allegation has been made as soon as possible after the LADO has been consulted and they will be kept informed of developments.
• Parents or guardians of a child concerned will be told about the allegation as soon as possible, if they do not already know, and will be kept informed of the progress of the case, including the outcome, but not the details of any disciplinary process.
• Where the LADO advises that a strategy discussion is needed, or the Police or children's social care need to be involved, the case manager will not inform the accused or the parents or carers until these agencies have been consulted and it has been agreed what information can be disclosed.
4. Further action to be taken by the Trust
• A school has a duty of care towards its employees and as such, it must ensure that effective support is provided for anyone facing an allegation. The Trust will act in accordance with Part 4 of Keeping Children Safe in Education 2025 and the Trust’s employment practices and procedures.
5. Ceasing to use staff
• If the Trust ceases to use the services of a member of staff or volunteer because they are unsuitable to work with children, a settlement/compromise agreement will not be used and a referral to the Disclosure and Barring Service (DBS) will be made as soon as possible if the criteria are met. Any such incidents will be followed by a review of the safeguarding procedures within the Trust, with a report being presented to the Governors without delay.
• If a member of staff or volunteer tenders his or her resignation, or ceases to provide his or her services, any child protection allegations will still be followed up by the Trust in accordance with this policy and a referral will be made to the Disclosure and Barring Service as soon as possible if the criteria are met.
• Where a teacher has been dismissed for serious misconduct or would have been dismissed had he / she not resigned (including by or from an agency), separate consideration must be given as to whether a referral to the Teaching Regulation Agency (TRA) should be made. Contact details for the DBS and TRA can be found on page 8.
6. Unsubstantiated, false or malicious allegations
• If a report is shown to be deliberately invented or malicious, the School should consider whether any disciplinary action is appropriate against the individual who made it as per the School’s own disciplinary and behaviour policies in place from time to time.
• For example - where an allegation by a pupil is shown to have been deliberately invented or malicious, the applicable Headmaster will consider whether to take disciplinary action in accordance with the Trust’s behaviour and discipline policies.
• Where a parent has made a deliberately invented or malicious allegation, the applicable Headmaster will consider whether to require that parent to withdraw their child or children from the Trust on the basis that they have treated the Trust or a member of staff unreasonably (in accordance with the Trust’s Terms and Conditions).
• Whether or not the person making the allegation is a pupil or a parent (or other member of the public), the Trust reserves the right to contact the Police to determine whether any action might be appropriate.
7. Record keeping
• Details of allegations found to be malicious will be removed from personnelrecords.
• For all other allegations, full details will be recorded on the confidential personnel file of the person accused. The record will be retained at least until the individual has reached normal retirement age or for a period of ten years from the date of the allegation, if this is longer.
• An allegation proven to be false, unsubstantiated or malicious will not be referred to in employer references.
8. Low Level Concerns
The aim of the Safeguarding Policy is to facilitate a culture in which the values and expected behaviours, which are set out in the Trust’s Staff Behaviour Policy, are practiced and reinforced by all staff For further guidance see the Low Level Concerns Policy, which is found in full in Appendix 10 of this policy and which can be downloaded from Cezanne.
The Low Level Concerns form can be found by following the links below:
Hampton School - click here
HPP&P - click here
Appendix 7 - Visiting Speakers
VISITING SPEAKER FORM
The Trust is required to maintain a register of all Visiting Speakers, i.e. visitors to the Trust who give talks, seminars, practical workshops etc. We need to ensure all speakers are suitable and appropriately supervised.
Members of staff organising the visit must complete and submit this form for every visiting speaker, no later than one week prior to the proposed visit. It should be passed to either JOM or PZM at Hampton School (TH or IM at HPP&P).
Staff responsible for a Visiting Speaker are reminded that all visitors to the Trust must be:
• Signed in and out and badged at Reception on arrival and their ID checked;
• Collected from Reception by a member of staff;
• Supervised at all times while on the School site by the member of staff responsible for the visit. In particular, Visiting Speakers must never be placed in a position of being alone with pupils.
Please complete the following for all visiting speakers:
Name of Visiting Speaker
Organisation the visiting speaker works for/represents
Subject/title of the talk/lecture/workshop
Will they be using online platforms (e.g. Mentimeter)? Please discuss with a member of SLT before agreeing with the speaker.
Member of staff responsible for visit
Date of Visit: Timings of Visit
Year Group/Class
Schools have a responsibility under the Prevent Duty to ensure a visiting speaker and presentation do not promote extremism or radicalisation. Please confirm that the speaker poses no risk in this regard.
Please confirm that the Visiting Speaker will be accompanied at all times by a member of staff will not be placed in a situation where he/she is a one to one situation with a pupil
To be completed by JOM or PZM at Hampton School or TH or IM at HPP&P
Approval is given forthe talk/lecture/workshop: Yes/No
A risk assessment is required? Yes/No
Appendix 8 - Related School Policies
• Anti-Bullying Policy
• Behaviour, Rewards, Sanctions, Discipline and Exclusions Policy (or the Policy toPromote Good Behaviour – Rewards – Sanctions – Exclusions at HPP&P)
• Dealing with Allegations of Against Staff or Volunteers Policy (Appendix 6)
• Online Safety Policy
• Health and Safety of Pupils on Educational Visits Policy (or HPP&P’s separate Educational Visits Policy
• Looked After Children Policy
• Mental Health Policy
• Missing Pupil Policy (or HPP&P’s Missing / Lost ChildPolicy)
• Low Level Concerns Policy
• Recruitment, Selection and Disclosure Policy
• Social Media Policy
• Staff Behaviour Policy
• Whistleblowing Policy
LOG OF A CONCERN ABOUT A PUPIL’S SAFETY AND WELFARE
Pupil’s Name: D.O.B.
Date: Time:
Name of person raising concern:
Position in School:
Note the reason(s) for recording the incident:
Record the following factually:
Offer an opinion where relevant (how and why might this have happened?)
Signature
Substantiate the opinion. Note any action taken, including names of anyone to whom your information was passed.
Appendix 10 - Low Level Concerns Policy
Introduction
This policy applies to the Hampton School Trust (the Trust or the School), which comprises Hampton School and Hampton Pre-Prep & Prep School (HPP&P), for children from the Early Years Foundation Stage (EYFS) to the Upper Sixth Form.
As part of their whole school approach to safeguarding, schools should ensure that they promote an open and transparent culture in which all concerns about all adults working in or on behalf of the school (including Governors, supply teachers, volunteers and contractors) are dealt with promptly and appropriately. Creating a culture in which all concerns about adults are shared responsibly and with the right person, recorded and dealt with appropriately, is critical. (See Part Four, section one of Keeping Children Safe in Education 2025 (KCSIE 2025 ) and Appendix 5 of the Hampton School Trust Safeguarding Policy for how to deal with allegations that might indicate a person will pose a risk of harm if they continue to work with children).
A low level concern is any concern – no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ - that an adult working in or on behalf of the School may have acted in a way that is inconsistent with the Staff Behaviour Policy, including inappropriate conduct outside of work. The term ‘low level’ concern does not mean that it is insignificant. Early identification and prompt management of all concerns about the behaviour of adults who work or volunteer with children is critical to effective safeguarding KCSIE 2025 requires low level concerns to be shared.
Staff are required to share low level concerns in this way:
• To ensure there is a formalised mechanism for reporting low level concerns;
• To allow staff to self-report to the School to protect themselves in situations where they may have found themselves compromised;
• To identify patterns of behaviour that are concerning; and
• To ensure the School continues to have a culture of safeguarding in which all staff understand their responsibility to raise concerns.
Staff should therefore
a) report any behaviour by another adult towards a pupil or another child that may have concerned them
b) self-report in any situation where they feel their behaviour towards a pupil, or another young person could be misinterpreted or misconstrued or leave them vulnerable
Concerns regarding the behaviour of another adult towards a child
A low level concern report should be used when a member of staff is concerned about the behaviour of another adult towards a pupil or another child. This is not just where it is clear that a professional boundary has been broken: anything which causes staff to have a ‘nagging doubt’ about the way in which other adults behave or interact with pupils should be notified, in order to protect both pupils and the members of staff involved. Such behaviour can exist on a wide spectrum, from the inadvertent or thoughtless, or behaviour that may look to be inappropriate.
Examples of such behaviour could include, but are not limited to:
• being over friendly with children;
• having favourites;
• taking photographs of children on a mobile phone;
• engaging with a child on a one-to-one basis in a secluded area or behind a closed door; or,
• using inappropriate sexualised, intimidating or offensive language.
Self-reporting
From time to time an individual may find him/herself in a situation which might appear compromising to others or which could be misconstrued. Equally, an individual may for whatever reason have behaved in a manner which on reflection he/she considers falls below the standard set out in the Trust’s Staff Behaviour Policy
Self-reporting in these circumstances is encouraged as it demonstrates both awareness of the expected behavioural standards and self-awareness as to the individual's own actions or how these might be perceived.
Almost always, there will be a perfectly innocent explanation for what has occurred, and staff should not feel awkward about making a report or being the subject of a report. Reporting these types of concerns is a neutral act and the Designated Safeguarding Lead (DSL) – Mr Owen Morris (Deputy Head) or Ms Tammy Howard (at HPP&P), or the Deputy Designated Safeguarding Leads (DDSL’s) – Ms Pippa Message (Deputy Head) and Mr Mark Nicholson (Deputy Head) at Hampton, or Mrs Imogen Murphy at HPP&P - will, on receiving a report, decide how to best approach the concern raised.
A member of staff who makes a low level concern, or a more serious allegation, in good faith will suffer no detriment as a result and will benefit from the protection set out in the Whistleblowing Policy. Some of the circumstances in which staff must make a low level concern report might be:
• any incident where s/he feels his/her actions or behaviour towards a pupil or that of another adult, may have been misinterpreted or may have given rise to a risk of misinterpretation
• any use by an adult of sexually inappropriate language, references or jokes to a pupil;
• any adult being overfriendly with pupils, allowing first names to be used, or encouraging the use of nicknames of staff or pupils;
• email, messaging, use of social media sites or other communication between adults and pupils outside agreed protocols;
• any incident of physical contact with a pupil when no one else is present, including when administering first aid or medical treatment (School medical staff are exempt from this requirement), and including physical demonstrations in one-to-one sports coaching, music lessons, etc;
• any incident where a staff member has been alone with a pupil or pupils in a vehicle where this has not been authorised in advance;
• any social contact with pupils outside of School (other than planned/authorised events, educational visits or trips, or insignificant incidents such as passing a pupil in the street or in a shop or noticing they are sitting, separately, in the same restaurant or cinema) particularly where the member of staff and/or pupil(s) is/are under the influence of alcohol;
• if a pupil becomes aware of and/or uses a staff members home address, mobile or home phone number, or non-school e-mail address other than in line with agreed protocols;
• the fact of, and explanation for, any one-to-one contact with a pupil on School trips, particularly if this takes place in a private space such as a bedroom;
• non-trivial illnesses or accidents of pupils on School trips;
• any incident where, for whatever reason, a member of staff has not complied with the Staff Behaviour Policy.
This is not an exhaustive list. Staff who are unsure of whether to complete a neutral notification are at liberty to discuss the matter with a member of the safeguarding team on a no-names basis. However, following such a discussion, should it be felt that the matter reaches the threshold for notification the member of staff will be expected to refer it. If in doubt, a referral should always be made.
Hampton School
Sharing a low level concern – the process
Low level concerns should be reported to the DSL. Alternatively, reports can be made to those members of SLT who are also DDSL’s, who will pass these reports to the DSL. All reports will be shared by the DSL with The Headmaster.
Where the low level concern relates to The Headmaster, or where there is a conflict of interest in reporting the matter to The Headmaster, this should be reported directly to the Chair of Governors (chair@hamptonschool.org.uk).
Low level concerns can be made in person, but staff are also encouraged to use the email address: lowlevelconcerns@hamptonschool.org.uk. Alternatively, they can download a Low Level Concerns Form (Appendix 1 of this Low Level Concerns policy) which is available via SharePoint (both for Hampton School and for HPP&P) - and send it to the email address above once completed.
Recording low level concerns
All low level concerns should be recorded in writing by the DSL. The record should set out the details of the concern, the context in which the concern arose and action taken. The name of the individual sharing their concerns should also be noted but if the individual wishes to remain anonymous that should be respected as far as possible. Records will be held securely by the DSL on a password protected file.
Low level concerns will be shared with The Headmaster. The Headmaster and DSL will review the records so that potential patterns of concerning problematic or inappropriate behaviour can be identified. They will consider whether the reported matter is a low level concern and whether it should be reclassified as an allegation and dealt with as outlined in Appendix 4 of the Safeguarding Policy. Where there is in any doubt whatsoever about the classification of a reported concern (whether a low-level concern in fact meets the harm threshold), The Headmaster, or DSL (as appropriate) will seek advice from the Local Authority Designated Officer (LADO).
Having established that the concern is low level, The Headmaster or DSL (as appropriate) will discuss it with the individual who has raised it and will take any other steps to investigate it as necessary. If the low level concern has been raised by a third party, in the investigation The Headmaster or DSL will speak to the individual who raised the concern, to any witnesses and to the person involved. Most low level concerns by their very nature are likely to be minor and will be dealt with by means of management guidance, training etc. This might lead to internal disciplinary procedures, referral of an individual to the LADO or the consideration of amendments to other policies and procedures that could be revised to minimise further risks. Low-level concerns will be recorded in writing. The record will include details of the concern, the context within which the concern arose, and details of the action taken. The name of the reporting individual should also be included, unless they have asked to remain anonymous, which will be respected as far as reasonably possible. The records will be retained and kept confidential, they will be held securely and in compliance with the Data Protection Act 2018 and the UK GDPR at all times.
Hampton Pre-Prep & Prep School
Sharing a low level concern – the process
Low level concerns should be reported to the Hampton Pre-Prep & Prep Headmaster or the Designated Safeguarding Lead (DSL).
Where the low level concern relates to the Hampton Pre-Prep & Prep Headmaster, of or where there is a conflict of interest in reporting the matter to the Headmaster, this should be reported directly to The Headmaster of the Trust.
Low level concerns can be made in person, but staff are also encouraged to use the email address: lowlevelconcerns@hamptonprep.org.uk.
A Low Level Concerns form can also be downloaded from SharePoint.
Recording low level concerns
Low level concerns at HPP&P will be dealt with in the same way as described above, but by the HPP&P DSL and the Hampton Pre-Prep & Prep Headmaster.
Low Level Concerns Form (Appendix 1)
This form should be used to share any concern – even if no more than a ‘nagging doubt’ – that an adult may have acted in a manner which:
• Is not consistent with the Hampton School Trust Staff Behaviour Policy, and/or
• relates to their conduct outside of work which, even if not linked to a particular act or omission, has caused a sense of unease about that adult’s suitability to work with children.
Once completed, staff should send the form to the appropriate email address for either Hampton School or HPP&P.
Staff should also self-report if they feel their behaviour towards a pupil or another young person could be misinterpreted or misconstrued or leaves them vulnerable.
All staff who work after the School day has ended, or at the weekends, need to be aware of their safeguarding responsibilities, as well as understanding the procedures to follow if they have concerns.
If a child wants to speak to a member of staff, these are the main guidelines to follow:
• Listen to the child and be supportive
• Never promise confidentiality
• If they mention anything that raises concerns about their safety or the safety of other children, report it to the Safeguarding staff (see below)
• Do not contact parents until it has been discussed with the Safeguarding staff
What to look out for: there isn’t a complete list, but common concerns would be if a pupil:
• Behaves unusually
• Appears distressed, confused or disturbed
• Does not want to go home
• Is left on their own at School
If you are concerned about the behaviour of an adult:
All staff are required to report any concern or allegation about the behaviour of colleagues which is likely to put pupils at risk of abuse or other serious harm. There will be no retribution against the reporter (covered by the Whistleblowing Policy and the NSPCC whistleblowing helpline – 0800 028 0285).
Please report low level concerns too; this is when an adult may have acted in a manner inconsistent with the Staff Behaviour Policy or there is unease about the adult’s behaviour towards, or around, children. Concerns about staff conduct should be reported to The Headmaster – headmaster@hamptonschool.org.uk.
What to do if you suspect that a child is at risk of harm:
Contact one of the Designated Safeguarding staff:
• Owen Morris (Designated Safeguarding Lead - DSL) or Pippa Message, Mark Nicholson, Polly Holmes or Victoria Smith (Deputy Designated Safeguarding Leads - DDSL)
• Phone: to contact a member of the Safeguarding staff at weekends or after the School day has ended, please use the keepers’ mobile phone (07825 428681) which holds key staff mobile numbers.
• For Hampton Pre-Prep & Prep – contact Tammy Howard (DSL) or Imogen Murphy (DDSL) - please use the Keepers’ mobile phone (07825 428681)
• E-Mail: safeguarding@hamptonschool.org.uk
• Contact Mike King (Bursar) or Verity Moria (Deputy Bursar) – they will be able to provide advice/contact others - please use the keepers’ mobile phone (07825 428681)
• Contact the appropriate authorities yourself. In most cases, staff should pass on concerns about a child to the Safeguarding staff; however, you should be aware that everyone who works with children shares a responsibility for ensuring children are safe: anyone can make their own referral to the Local Authority and must do so if a child is in risk: Richmond Single Point of Access (SPA)0208 547 5008 (out of hours 0208 770 5000); email: spa@richmond.gov.uk
• In an emergency dial 999
12 - Safeguarding Reporting Summary for Staff (Hampton School)
Appendix 13 - Safeguarding Reporting Summary for Staff (Hampton Pre-Prep & Prep)
