POLICY 12 - SAFEGUARDING

Policy 12 - Safeguarding

Excellence in Learning, Development and

CONTENTS 1

Introduction, Definitions and Responsibilities

2

Objectives of the Safeguarding Policy

3

Statutory Framework

4

The Designated Senior Person and the Governing Body

5

Staff Training

6

LD Training Procedures 6.1 General 6.2 Reporting Abuse and Neglect 6.3 Allegations Against a Member of Staff 6.4 Work Placement and Work Experience 6.5 Apprentices and Work Based Learning 6.6 Adult and Community Learning

7

LD Training Visitors

8

Confidentiality

9

Communications with Parents

10

LD Training Publications

POLICY 12 – SAFEGUARDING (JANUARY 2017) 1

APPENDICES

A

Issues Covered Under the Safeguarding Agenda

B

Indicators of Possible Significant Harm - Possible Signs of Physical Abuse - Possible Signs of Emotional Abuse - Possible Signs of Sexual Abuse - Possible Signs of Neglect - Possible Signs of Radicalisation - Possible Signs of Forced Marriage

C

Safeguarding Referral Flowchart

D

Example of completed Safeguarding Proforma

E

Safer Recruitment and Employee Security (DBS) Policy

F

Visitor Policy

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1. INTRODUCTION, DEFINITIONS AND RESPONSIBILITIES

This Policy is focused on recognising the roles that LD Training staff, workers and students have to play in safeguarding the welfare of young people and adults at risk, and preventing their abuse and is focused on protection from abuse and neglect.

The procedures outlined below should be followed in the circumstances defined in this policy.

This Safeguarding Policy forms part of a suite of documents and policies, which relate to the safeguarding responsibilities of LD Training. These can all be found on LD Training Student Wall and server. Hard copies are available within the Head Office and on request.

Hertfordshire Safeguarding Children Board LD Training follows the procedures established by Inter-agency Child Protection and Safeguarding the Hertfordshire and Harrow Safeguarding Children Procedures Children Board; a guide to procedure and practice for agencies working with children and their families.

Definition of Safeguarding The term ‘safeguarding’ describes the broader preventative and precautionary approach to planning and procedures that are necessary to be in place to protect children and young people from any potential harm or damage. This is also true for adults at risk.

Safeguarding means: • Protection from abuse and neglect • Promotion of health and development • Ensuring safety and care • Ensuring optimum life chances

For a more comprehensive list of issues that can be covered by “safeguarding” please see appendix A.

Definition of child or young person An individual is considered to be a child or young person up to their 18th birthday (as defined by the UN convention of the Rights of the Child).

Definition of an adult at risk An adult who has needs for care and support (whether or not the authority is meeting any of those needs) and • is experiencing, or is at risk of, abuse or neglect and • as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it

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Definition of abuse

Definition of abuse of adults at risk

Responsibilities of LD Training Staff & Volunteers

Abuse is behaviour towards a person that either deliberately or unknowingly causes a person harm, or endangers their life or their human or civil rights. It can be passive, e.g. failing to take action to care for someone, or failing to raise the alert about abuse; or active, e.g. hitting, stealing or doing something that causes harm.

It can also be financial abuse, e.g. exerting improper pressure to sign over money. Abuse can be a one-off or something that is repeated.

Abuse is a violation of an individual’s human and civil rights by another person or persons. Abuse may consist of single or repeated acts. It may be physical, verbal or psychological, it may be an act of neglect or omission to act, or it may occur when a person is persuaded to enter into a financial or sexual transaction to which he/she has not consented, or cannot consent.

Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it.

All LD Training staff have a responsibility to provide a safe environment in which children can learn.

LD TRAINING staffs are particularly well placed to observe outward signs of abuse, changes in behaviour and failure to develop because they have daily contact with children.

All LD Training staff will receive appropriate safeguarding children training (which is updated regularly – Hertfordshire Safeguarding Children Board advises every 3 years), so that they are knowledgeable and aware of their role in the early recognition of the indicators of abuse or neglect and of the appropriate procedures to follow. It is good practice for the Designated Senior Person to deliver an annual update.

The Designated Senior Person will make temporary staff and volunteers aware of the safeguarding policies and procedures.

Staff should consider how students may be taught about safeguarding, including online, through teaching and learning opportunities, as part of providing a broad and balanced curriculum.

Staffs are advised to maintain an attitude of ‘it could happen here’ where safeguarding is concerned. When concerned about the welfare of a student, staff members should always act in the interests of that student.

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Related policies and statements

Data Protection Policy Health and Safety Policy Confidentiality Statement Staff and student email and internet policies Staff and Student Disciplinary Procedures Student Anti-Bullying Procedure Complaints, Compliments and Suggestions Procedure • HR Recruitment Policy • Staff Code of Conduct • Public Interest Disclosure Policy (Whistleblowing) • Prevent Strategy

The DSO and Director will review the policy annually. It will be implemented through LD Training staff development programme, and as part of day-to-day practice. Compliance with the policy will be monitored by Director, the Designated Senior Person and through staff performance measures.

• • • • • • •

Implementation, Monitoring and Review of the Child Protection Policy

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2. OBJECTIVES OF THE SAFEGUARDING POLICY

This policy aims to:

• Establish and maintain an environment where young people and adults at risk feel secure, are encouraged to talk, and are listened to when they have a worry or concern.

• Ensure young people and adults at risk know that there are adults in LD Training whom they can approach if they are concerned.

• Include opportunities in the tutorial programme for young people and adults at risk to develop the skills they need to recognise and stay safe from abuse • Inform staff and others working at LD Training, parents, employers, partners, and stakeholders and governors about LD Training’s responsibilities for safeguarding young people and adults at risk • Enable everyone to have a clear understanding of how these responsibilities should be carried out.

• Establish and maintain an environment where staff and volunteers feel safe, are encouraged to talk and are listened to when they have concerns about the safety and wellbeing of a child.

• Ensure that children who have been abused will be supported in line with a child protection plan, where deemed necessary.

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3. STATUTORY FRAMEWORK In order to protect young people and adults at risk from harm LD Training will act in accordance with the following legislation and guidance:

• The Children Act 1989 • The Children Act 2004 • Education Act 2002 (section 175) • Hertfordshire Safeguarding Children Board Inter-agency Child Protection and Safeguarding Children Procedures (Electronic) • Harrow Local Safeguarding Children Board (LSCB) • Keeping Children Safe in Education (DFE 2014) • Keeping Children Safe in Education: information for all school and LD Training staff (DFE 2014) – APPENDIX 2 • Working Together to Safeguard Children (DfE 2015) • The Education (Pupil Information) (England) Regulations 2005 • Hertfordshire Safeguarding Adults Board - Safeguarding adults at risk. The multi-agency policy, procedure and practice for working with adults at risk of abuse or neglect in Hertfordshire, June 2014, Issue 8 • Safeguarding Vulnerable Groups Act 2006 • Protection of Freedoms Act 2012 • Ofsted. Safeguarding children and young people and young adults at risk policy (2015) • Counter Terrorism and Security Act 2015 (Section 26)

LD Training follows the procedures established by the Hertfordshire and Harrow Safeguarding Children Boards and those established by Hertfordshire Safeguarding Adults Board. LD Training has appropriate procedures in place for responding to situations in which they believe that a child or vulnerable adult has been abused or are at risk of abuse, which also cover circumstances in which a member of staff, volunteer or other worker is accused of, or suspected of, abuse.

LD Training will also follow guidance in relation to the specific safeguarding issues outlined in “Keeping Children Safe in Education” (DfE, 2015). This will include the Prevent Duty Guidance 2015, in the exercise of their functions, to have due regard to the need to prevent people from being drawn into terrorism. Furthermore Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime Act 2015) will place a statutory duty upon teachers, along with social workers and healthcare professionals, to 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. It will be rare for LD Training staff to see visual evidence, and they should not be examining pupils, but the same definition of what is meant by “to discover that an act of FGM appears to have been carried out” is used for all professionals to whom this mandatory reporting duty applies.

Furthermore Keeping Children Safe in Education (DFE, 2015) advises that all schools and Colleges including LD TRAINING should be aware of the following responsibilities: • Staff should be aware of and follow the procedures established by the Hertfordshire and Harrow Safeguarding Children Boards • Staff should be alert to signs of abuse and know to whom they should report any concerns or suspicions • LD TRAINING should have procedures (of which all staff are aware) for handling suspected cases of abuse of students, including procedures to be followed if a member of staff is accused of abuse, or suspected of abuse • A Designated Senior Person (referred to in ‘Keeping Children Safe in Education (DFE, 2015 ) as Designated Safeguarding Lead') should have responsibility for co-ordinating action within the school and liaising with other agencies • Staff with the designated safeguarding lead (known as DSP) should undergo updated child protection training every two years. This is also followed by staff with Deputy DSP roles.

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Keeping Children Safe in Education (DfE 2015) also states:

“Governing bodies and proprietors should ensure there is an effective child protection policy in place together with a staff behaviour policy (code of conduct). Both should be provided to all staff – including temporary staff and volunteers – on induction. The child protection policy should describe procedures which are in accordance with government guidance and refer to locally agreed inter-agency procedures put in place by the LSCB, be updated annually and be available publicly either via the school or college website or by other means.”

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4. THE DESIGNATED PERSON AND GOVERNING BODY (Referred to in ‘Keeping Children Safe in Education (DFE, April 2015) as Designated Safeguarding Lead') and the Governing Body • Ensuring that LD Training is a safe and secure environment is the responsibility of the Director.

The Senior Management Team member with specific strategic responsibility for safeguarding is Sara Green, Centre Manager •

The Director should ensure that the school or College designates an appropriate senior member of staff to take lead responsibility for child protection. This person should have the status and authority within the school to carry out the duties of the post including committing resources and, where appropriate, supporting and directing other staff.

•

The Designated Senior Person (DSP) for Safeguarding for is: Sara Green – Centre Manager: Student Safeguarding Mobile: 07531 906937 Phone: 07813 4091727 Office: 020 8616 2234

•

Where the DSP is not available one of the Deputy DSPs (DDSP) act in their absence. The DDSPs in LD Training are as follows: Name Le-Ann Kurland Linda Johnson

Role Deputy DSP Deputy DSP

Mobile 07920 117148 07766 002396

General welfare concerns, which do not involve abuse or neglect, should be referred to Sara Green The broad areas of responsibility for the DSP are: •

Managing referrals

•

Refer all cases of suspected abuse to the local authority children’s social care and:

•

Police (cases where a crime may have been committed).

•

Liaise with senior staff as appropriate to inform them of issues especially on-going enquiries under section 47 of the Children Act 1989 and police investigations

•

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

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Training •

The DSP should receive appropriate training carried out every two years 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 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 LD Training’s safeguarding policy and procedures, especially new and part time staff

•

Be alert to the specific needs of children in need, those with special educational needs and young carers

•

Be able to keep detailed, accurate, secure written records of concerns and referrals

•

Obtain access to resources and attend any relevant or refresher training courses

•

Encourage a culture of listening to children and taking account of their wishes and feelings, among all staff, in any measures LD Training may put in place to protect them

Raising Awareness •

The DSP, with the strategic lead, should ensure LD Training’s policies are known and used appropriately:

•

Ensure LD Training’s safeguarding policy is reviewed annually and the procedures and implementation are updated and reviewed regularly, and work with governing bodies or proprietors regarding this

•

Ensure the safeguarding policy is available publicly and parents are aware of the fact that referrals about suspected abuse or neglect may be made and the role of LD Training in this

•

Link with the local safeguarding children board and safeguarding adult board to make sure staff are aware of training opportunities and the latest local policies on safeguarding

Proprietors Proprietors must ensure that they comply with their duties under legislation. They must also have regard to this guidance to ensure that the policies, procedures and training in LD Training are effective and comply with the law at all times. The nominated for safeguarding is Sara Green.

The responsibilities placed on governing bodies and proprietors include:

•

their contribution to inter-agency working, which includes providing a coordinated offer of early help when additional needs of children are identified

•

ensuring that an effective safeguarding policy is in place, together with a staff behaviour policy [Code of Conduct]

•

appointing a designated safeguarding strategic lead and operational DSP who should undergo child protection training every two years

•

prioritising the welfare of children, young people and adults at risk and creating a culture where staff are confident to challenge senior leaders over any safeguarding concerns

•

making sure that students are taught about how to keep themselves safe.

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5. Policy Statement Mandatory training is given for all staff in Safeguarding. It is necessary for all staff to take refresher training every three years. Training will be followed up with appropriate roles relating to their relevant issues. In between 3-year visits, new staff will receive interim in-house training from designated staff or on-line approved courses. Staff are also required to undertake mandatory training relating to the Prevent agenda and recognising radicalisation.

The DSP and team will liaise to ensure staff are aware of their training requirements and are notified in a timely manner when it is due for renewal.

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6. LD TRAINING PROCEDURES 6.1 General LD Training takes its duty of pastoral care seriously and will be proactive in seeking to prevent young persons and adults at risk becoming the victims of abuse or neglect. It will do this in a number of ways: •

Through the creation of an open culture which respects all individuals’ rights and discourages bullying and discrimination of all kinds.

•

By identifying a member of the SMT who will lead and have overall responsibility for safeguarding young people/adults at risk and a DSP to take responsibility for safeguarding issues. The DSP and team of deputy DSPs will have training in this field and act as a source of advice and support to other LD Training staff.

•

By informing young people and adults at risk of their rights to be free from harm and encouraging them to talk to LD Training staff if they have any concerns.

•

Through the tutorial programme and support, at an appropriate level, to promote self-esteem, social inclusion and address the issue of safeguarding children, young people and adults at risk in the wider context.

Schools are required to send any child protection data to LD Training on their commencement/transfer to one of our courses. The DSP will liaise with the local schools in the autumn term as a timely reminder of this data transfer. All staff, volunteers and others working with LD Training students should be aware that the main categories of abuse for children are: •

Physical abuse

•

Emotional abuse

•

Sexual abuse

•

Neglect

•

Also, bullying, financial abuse, domestic violence and radicalisation

All staff and volunteers should be concerned about a child/vulnerable adult if he/she presents with indicators of possible significant harm. Staff will be provided with further information relating to this topic in the mandatory training.

A safeguarding referral flowchart is attached at Appendix C.

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6.2 Identifying and Reporting Concerns, Abuse and other Safeguarding Issues General welfare concerns, which do not involve abuse or neglect, should be referred to the Director or Centre Manager However, all reports of abuse or neglect should be referred using the procedure detailed below.

All staff, others working at LD Training and volunteers should be concerned about a young person or vulnerable adult if he or she displays signs of abuse and neglect, or where they may have disclosed harm to others such as class-mates. A summary of indicators of significant harm is attached at Appendix B. Concern about safeguarding issues should include any area where the health or physical and emotional wellbeing of a young person or vulnerable adult is at risk. This could include alcohol dependency, bullying etc.

If a student discloses to a member of staff that he or she has been abused in some way, the member of staff, volunteer or other person working at LD Training should:

•

Listen to what is being said without displaying shock or disbelief

•

Accept what is being said

•

Allow the student to talk freely

•

Reassure the student, but not make promises which it might not be possible to keep

•

Not promise confidentiality – it might be necessary to refer to Children’s Services: Safeguarding and Specialist Services

•

Reassure him or her that what has happened is not his or her fault

•

Stress that it was the right thing to tell

•

Listen, only asking questions when necessary to clarify

•

Not criticise the alleged perpetrator

•

Explain what has to be done next and who has to be told

•

Make a written record (see below)

•

Pass information to the Designated Senior Person without delay

•

When a student has made a disclosure, the member of staff/volunteer should:

•

Make brief notes as soon as possible after the conversation. Use the full cause for concern sheet wherever possible. This is available in the Safeguarding portal on SharePoint under Reporting

•

Not destroy the original notes in case they are needed by a court

•

Record the date, time, place and any noticeable non-verbal behaviour and the words used by the student making the disclosure

•

Draw a diagram to indicate the position of any injuries

•

Record statements and observations rather than interpretations or assumptions

•

All records need to be given to the Designated Senior Person promptly. No copies should be retained by the member of staff or volunteer.

The Designated Senior Person will ensure that all safeguarding records are managed in accordance with the Education (Pupil Information) (England) Regulations 2005.

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The member of staff must record information regarding the concerns on the same day. The recording must be a clear, precise, factual account of the observations. A standard pro-forma for recording concerns is available in the LD Training office. An email marked confidential can be used to send an immediate alert to the DSP and Primary Deputy DSP. The email address sara@ldtraining.org.uk is restricted to maintain security and confidentiality.

See Appendix D for a sample concern form.

The DSP will determine what action to take and will decide whether the concerns should be referred to Children’s Services or Adult Care Services. If it is decided to make a referral to Children’s Services: Safeguarding and Specialist Services this will be done with prior discussion with the parents, unless to do so would place the child at further risk of harm. Particular attention will be paid to the attendance and development of any student about whom LD Training has concerns, or who has been identified as being the subject of a child protection plan (formerly referred to as the Child Protection Register) and a written record will be kept.

If a student who is/or has been the subject of a child protection plan changes establishment, the Designated Senior Person will inform the social worker responsible for the case and transfer the appropriate records to the Designated Senior Person at the receiving institution, in a secure manner, and separate from the child’s academic file.

The Designated Senior Person is responsible for making the senior leadership team aware of trends in behaviour that may affect pupil welfare. If necessary, training will be arranged.

As a person who works with children, staff have a duty to refer child protection safeguarding concerns to the designated senior person.

However if: •

concerns are not taken seriously by an organisation or,

•

action to safeguard the child is not taken by professionals and the child is considered to be at continuing risk of harm,

then staff should speak to LD Training lead, Sara Green, Le-Ann Kurland, or Linda Johnson or contact Hertfordshire Children’s Services (including out of hours) on 0300 123 4043.

If, at any point, there is a risk of immediate serious harm to a child a referral should be made to children’s social care immediately. If the child’s situation does not appear to be improving the staff member with concerns should press for re-consideration. Concerns should always lead to help for the child at some point.

If the allegations raised by the staff member are against other children the school should follow section 4.3 of the Hertfordshire Safeguarding Children Board Procedures Manual - Children Who Abuse Others In emergency situations (e.g. where there is the risk or occurrence of severe physical injury), where immediate action is needed to safeguard the health or safety of the individual or anyone else who may be at risk, the emergency services should be involved. Where a crime is taking place, has just occurred or is suspected, the police must be contacted immediately and the Deputy Director informed.

Where an allegation is made regarding a 14 – 16 year old student, members of staff should follow the same procedures as outlined above. The Designated Senior Person for LD Training will liaise with the DSP from the relevant school, ensuring that the student is informed of this process.

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Mandatory Reporting Duty

Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime Act 2015) will place a statutory duty upon teachers, along with social workers and healthcare professionals, to 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. Those failing to report such cases will face disciplinary sanctions. It will be rare for teachers to see visual evidence, and they should not be examining pupils, but the same definition of what is meant by “to discover that an act of FGM appears to have been carried out” is used for all professionals to whom this mandatory reporting duty applies.

Dealing with a disclosure from a student, or a Child Protection or Adult Care case, is likely to be a stressful experience. The member of staff/person working at LD Training/volunteer should therefore consider seeking support for him/herself and discuss this with the Designated Senior Person or the Director.

6.3 Allegations against a member of staff An allegation is any information which indicates that a member of staff/volunteer may have: •

Behaved in a way that has, or may have harmed a young person/adult at risk

•

Possibly committed a criminal offence against/related to a young person/ adult at risk

•

Behaved in a way which indicates s/he would pose a risk of harm if they work regularly or closely with young people/adults at risk

This applies to any student the member of staff/volunteer has contact within their personal, professional or community life.

To reduce the risk of allegations, all staff should be aware of safer working practice and should be familiar with the guidance contained in staff policies, training materials or Government document ‘Guidance for Safer Working Practice for Adults who work with Children and Young People in Education Settings’.

The person learning of the allegation should record the nature of the allegation using the informant's words - including time, date and place where the alleged incident took place, brief details of what happened, what was said and who was present and any other relevant information. S/he should not investigate or ask leading questions if seeking clarification; it is important not to make assumptions.

Confidentiality should not be promised and the person should be advised that the concern will be shared on a 'need to know' basis only.

The written record should be signed and dated and immediately reported to the Centre Manager(DSP) or Director. The DSP will immediately inform the Director or, in his/her absence, the SMT lead for Finance.

If the concerns are about the Director, then the Centre Manager or Finance Officer should be contacted. The Centre Manager is Sara Green. The Finance Officer Chris Kasabi. .

The Director, in consultation with the appropriate LD Training managers to decide whether to invoke LD Training Disciplinary Procedure which may include suspension. The DSP and the Director will assess whether it is necessary to refer to Children’s Services, in consultation with the Local Authority Designated Officer – Frazer Smith.

Children’s Services – 03001234043 SOOHS (Out of Hours Service-Children’s Services) - 03001234043 If the allegation meets any of the three criteria set out at the start of this section, contact should always be made with the Local Authority Designated Officer without delay.

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6.4 Work Placement and Work Experience Employers and training organisations will be asked to cooperate with LD Training in putting in place and subscribing to appropriate safeguards.

Where a placement is long term or meets the criteria laid out in “Safeguarding Children and Safer Recruitment in Education 2006, DCSF” LD Training will ensure that additional safeguards are in place, these may include: •

Staff arranging placements will have had training in safeguarding and child protection

•

Training organisations will be asked to make a commitment to safeguarding learners’ welfare by endorsing an agreed statement of principles.

•

Vetting and DBS checking any person whose normal duties will include regular caring for, training, looking after or supervising a child in the workplace where that person has been specifically designated to have responsibility for such activities

It is important to note that ultimate responsibility still sits with LD Training as the educational provider.

6.5 Apprentices and Work-based learning Apprentices are employed from the start of their programme. This policy is provided to apprentices as part of their induction programme. The review process, carried out approximately every 8 weeks with the employer and apprentice, includes safeguarding. This is to increase their awareness, give them a greater understanding of safeguarding issues and policies, and provide opportunity to uncover and address concerns.

LD Training ensures that, where an Apprentice is placed with an employer, the employer understands their responsibilities for safeguarding. We will undertake a health and safety risk assessment and ensure that all employers have equality and diversity and health and safety policies in place. Where a learner is working 1-1 with a member of the employer's staff on a regular basis LD Training will create a risk assessment with the employer. Appropriate measures will be put in place as fitting to the setting and individual requirements of that particular case.

6.6 Adult and Community Learning ACL courses adopt LD Training policies and procedures ensuring materials reflect the local situation when external venues are used. In particular the ACL work will include appropriate risk assessment, safeguarding compliance, health and safety checks and training for all staff

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7. LD TRAINING VISITORS LD Training ensures that visitors are booked in at reception areas, collected on arrival, and made aware of LD Training safeguarding and health and safety requirements. On arrival visitors leaflet detailing key LD Training information including safeguarding (See appendix F)

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8. CONFIDENTIALITY Child Protection raises issues of confidentiality that must be clearly understood by all staff/volunteers in LD Training, as follows:

•

All staff, both teaching and non-teaching, have a responsibility to share relevant information about the protection of young people with other professionals, particularly the investigative agencies (Children’s Services: Safeguarding and Specialist Services and the Police, Adult Social Care)

•

If a student confides in a member of staff/person working at LD Training/volunteer and requests that the information is kept secret, it is important that this person tells the student in a manner appropriate to the student’s age/stage of development that they cannot promise complete confidentiality – instead they must explain that they may need to pass information to other professionals to help keep the student or other students or children safe.

•

Staff/workers/volunteers who receive information about young people and their families in the course of their work should share that information only within appropriate professional contexts.

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9. COMMUNICATION WITH PARENTS LD Training will: •

Ensure the safeguarding policy is available publicly either via LD Training website or by other means.

•

Parents should be informed prior to referral, unless it is considered to do so might place the child at increased risk of significant harm by: o

The behavioural response it prompts e.g. a child being subjected to abuse, maltreatment or threats / forced to remain silent if alleged abuser informed;

o

Leading to an unreasonable delay;

o

Leading to the risk of loss of evidential material;

o

Placing a member of staff from any agency at risk.

Ensure that parents have an understanding of the responsibilities placed on LD Training and staff for safeguarding children.

•

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10. LD TRAINING PUBLICATIONS LD Training will include details of its Safeguarding procedure in all future key LD Training documents and materials. This will include: •

Apprenticeship Literature

•

LD TRAINING website

•

Information sheets

•

Recruitment literature for staff vacancies

•

Staff induction materials

•

Referring to safeguarding duties in all job descriptions

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A. APPENDIX A – ISSUES COVERED UNDER THE SAFEGUARDING AGENDA •

Child Protection

•

Vetting and barring scheme – safer recruitment of staff

•

Checking identity and qualifications of all staff/people working at LD Training/volunteers

•

DBS disclosures

•

Health and safety

•

Health and wellbeing

•

Bullying

•

Drug abuse

•

Alcohol abuse

•

Personal safety

•

Forced marriages

•

Missing young person notifications

•

Runaway young people

•

Children in care and care leavers

•

Firework safety

•

Knife crime

•

Internet safety

•

Financial security

•

Private fostering

•

Child death review process

•

Safeguarding child performers

•

Accident prevention and home safety

•

Prevention of involvement in extremist groups/activities

•

Female Genital Mutilation

•

Fabricated or Induced Illness

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B. APPENDIX B – INDICATORS OF POSSIBLE SIGNIFICANT HARM •

All staff and volunteers should be aware that the main categories of abuse are:

•

Physical abuse

•

Emotional abuse

•

Sexual abuse

•

Neglect

•

All staff and volunteers should be concerned about a student if he/she presents with indicators of possible significant harm.

•

Full details about indicators can be found in the training booklet that accompanies the safeguarding training session. This can be accessed on the Safeguarding portal via the front page of SharePoint.

•

Generally, in an abusive relationship the student may:

•

Appear frightened of the parent/s or other household members e.g. siblings or others outside of the home

•

Act in a way that is inappropriate to her/his age and development (full account needs to be taken of different patterns of development and different ethnic groups)

•

Display insufficient sense of ‘boundaries’, lack stranger awareness

•

Appear wary of adults and display ‘frozen watchfulness’

POSSIBLE SIGNS OF PHYSICAL ABUSE • • • • • • • • • • • • • • • •

Unexplained injuries or burns, particularly if they are recurrent Injuries not typical of accidental injury Frequent injuries even with apparently reasonable explanations Improbable or conflicting explanations for injuries Refusal to discuss injuries Admission of punishment which appears excessive Fear of parents/carers being contacted Bald patches Withdrawal from physical contact Arms and legs kept covered in hot weather Fear of returning home Fear of medical help / parents not seeking medical help Self-destructive tendencies Aggression towards others Chronic running away Frequently absent from LD Training

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POSSIBLE SIGNS OF EMOTIONAL ABUSE Probably the most difficult type of abuse to recognise.

• An emotionally abused person is often withdrawn, introverted and depressed • Admission of punishment which appears excessive • Over-reaction to mistakes • Sudden speech disorders • Fear of new situations • Inappropriate emotional responses to painful situations • Neurotic behaviour (e.g. rocking, hair twisting, thumb sucking) • Self mutilation • Fear of parents/carers being contacted • Extremes of passivity or aggression • Drug/solvent abuse • Chronic running away • Compulsive stealing • Scavenging for food or clothes • Continual self depreciation • Air of detachment – ‘don’t care’ attitude • Social isolation – does not join in and has few friends • Desperate attention-seeking behaviour • Eating problems, including over-eating or lack of appetite • Depression, withdrawal POSSIBLE SIGNS OF SEXUAL ABUSE

• Demonstrate sexual knowledge or behaviour inappropriate to age/stage of development, or that is unusually explicit • Wetting or other regressive behaviours e.g. thumb sucking • Inexplicable changes in behaviour, such as becoming aggressive or withdrawn • Stop enjoying previously liked activities • Be reluctant to undress for PE • Become fearful of, or refuse to see, certain adults for no apparent reason; show dislike of a particular tutor, support worker, carer, relative or other adult • Draw sexually explicit pictures • Urinary infections, bleeding or soreness in the genital or anal areas • Soreness or bleeding in the throat • Chronic ailments, such as stomach pains or headaches • Take over the parental role at home; seem old beyond their years • Develop eating disorders, such as anorexia or bulimia • Depression, suicidal thoughts • Poor self-image, self-harm, self-hatred • Physical discomfort • Use drugs or drink to excess • Unexplained pregnancy • Memory loss • Frequent running away • Restricted social activities • Find excuses not to go home or to a particular place • Have recurring nightmares/be afraid of the dark • Be unable to concentrate; seem to be in a world of their own • Have a ‘friend who has a problem’ and then tell about the abuse of the friend • Sudden changes in college work habits, become truant • Withdrawal, isolation or excessive worrying • Outbursts of anger or irritability • Unexplained sums of money • Act in a sexually inappropriate/harmful or seductive way towards others

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POSSIBLE SIGNS OF NEGLECT • • • • • • • • • • • • • •

Constant hunger Poor personal hygiene Inappropriate clothing, clothing in a poor state of repair Frequent lateness or non-attendance at college Untreated medical problems Low self-esteem Poor social relationships Compulsive stealing Constant tiredness Emaciation Destructive tendencies.

Neurotic behaviour (e.g. rocking, hair twisting, thumb sucking) Chronic running away Scavenging for food or clothes

Child Sexual Exploitation

Child sexual exploitation (CSE) involves exploitative situations, contexts and relationships where young people receive something (for example food, accommodation, drugs, alcohol, gifts, money or in some cases simply affection) as a result of engaging in sexual activities. Sexual exploitation can take many forms ranging from the seemingly ‘consensual’ relationship where sex is exchanged for affection or gifts, to serious organised crime by gangs and groups. What marks out exploitation is an imbalance of power in the relationship. The perpetrator always holds some kind of power over the victim which increases as the exploitative relationship develops. Sexual exploitation involves varying degrees of coercion, intimidation or enticement, including unwanted pressure from peers to have sex, sexual bullying including cyberbullying and grooming. However, it also important to recognise that some young people who are being sexually exploited do not exhibit any external signs of this abuse.

(Keeping Children Safe in Education – DfE, 2015) Indicators in the Child

•

Physical presentation

•

Urinary infections, bleeding or soreness in the genital or anal areas

•

Recurrent pain on passing urine or faeces

•

Blood on underclothes

•

Sexually transmitted infections

•

Vaginal soreness or bleeding

•

Pregnancy in a younger girl where the identity of the father is not disclosed and/or there is secrecy or vagueness about the identity of the father

•

Physical symptoms such as injuries to the genital or anal area, bruising to buttocks, abdomen and thighs, sexually transmitted disease, presence of semen on vagina, anus, external genitalia or clothing

•

Emotional/behavioural presentation

•

Makes a disclosure.

•

Demonstrates sexual knowledge or behaviour inappropriate to age/stage of development, or that is unusually explicit

•

Inexplicable changes in behaviour, such as becoming aggressive or withdrawn

•

Self-harm - eating disorders, self-mutilation and suicide attempts

•

Poor self-image, self-harm, self-hatred

POLICY 12 – SAFEGUARDING (JANUARY 2017) 19

•

Reluctant to undress for PE

•

Running away from home

•

Poor attention / concentration (world of their own) / Depression

•

Sudden changes in school work habits, become truant

•

Withdrawal, isolation or excessive worrying

•

Inappropriate sexualised conduct

•

Sexually exploited or indiscriminate choice of sexual partners

•

Wetting or other regressive behaviours e.g. thumb sucking

•

Draws sexually explicit pictures

•

Indicators in the parents

•

Comments made by the parent/carer about the child.

•

Lack of sexual boundaries

•

Wider parenting difficulties or vulnerabilities

•

Grooming behaviour

•

Parent is a sex offender

•

Indicators in the family/environment

•

Marginalised or isolated by the community.

•

History of mental health, alcohol or drug misuse or domestic violence.

•

History of unexplained death, illness or multiple surgery in parents and/or siblings of the family

•

Past history of childhood abuse, self-harm, somatising disorder or false allegations of physical or sexual assault or a culture of physical chastisement.

•

Family member is a sex offender

In addition to all the above signs a child or vulnerable adult may disclose an experience in which he/she may have been harmed, or there may be any other cause to believe that a child or vulnerable adult may be suffering harm.

POSSIBLE SIGNS OF RADICALISATION LD Training also has a duty of care to identify and refer possible signs of radicalisation to extremist groups. These may include: •

Experience of poverty, disadvantage or social exclusion

•

Conflict with family over religious beliefs and/or lifestyle choices/extreme political views

•

An event or series of traumatic events

•

Change in behaviour and/or appearance as a result of new influences

•

Rejected by peer, faith or social group or family

•

Victim or witness to race or religious hate crime

•

Unexplained absence, particularly for prolonged periods

•

May possess literature related to extreme views

•

Greater detail relating to these will be made available to staff through mandatory training and through LD Training Prevent strategy

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POSSIBLE SIGNS OF FORCED MARRIAGE The tradition of arranged marriages has operated successfully within many communities and many countries for a very long time. A clear distinction must be made between a forced and an arranged marriage. In arranged marriages, the families of both spouses take a leading role in choosing the marriage partner, but the choice whether or not to accept the arrangement remains with the young people. In forced marriage, one or both spouses do not consent to the marriage or consent is extracted under duress. Duress includes both physical and emotional pressure.

Possible Indicators of Forced Marriages: •

Truancy

•

Decline in performance or punctuality

•

Low motivation

•

Being withdrawn from LD Training by those with parental responsibility

•

Not allowed to attend extracurricular activities

•

If anyone is concerned that a student is being forced to marry, they should immediately contact the DSP or one of the Deputies.

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POLICY 12 – SAFEGUARDING (JANUARY 2017) 21

No

Concerned person

reports matter to

designated senior

person or a Deputy DSP and makes a

written record

No

DSP or DDSP

discusses matter with

targeted advice service, Adult

social care or Yes prevent team

to confirm if referral should

be made

No

Monitoring put in place with if further Refer relevant staff. issues arise

Member of Staff or Student has Concerns about serious Safeguarding Issue

C. APPENDIX C – SAFEGUARDING REFERRAL CHART Yes Designated person reports matter to head of Human Resources and makes a written record

Does the incident /Information involve an allegation against a member of staff?

Head of Human Resources will refer to the Principal if necessary

DSP or DDSP takes steps considered necessary to ensure the safety of the child in question and any other child or vulnerable adult that may be a risk

Is it a straight forward referral?

Yes DSP or DDSP contacts CSF Social services, Adult Social Care or Prevent team to make a referral

DSP or DDSP makes accurate records and informs Deputy Principal and relevant staff involved with student where appropriate

Support team created as appropriate for student

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A Summary monitoring report will be sent on a termly basis to SMT. Directors and corporation Governors with an annual report at the end of the Summer-term.

D. APPENDIX D – EXAMPLE OF COMPLETED CAUSE FOR CONCERN PRO-FORMA CONCERN FORM Child’s Name : William Shakespeare Child’s DOB : 26.04.1993 Male/Female : Ethnic Origin : Disability Y/N : Religion : Male White British None Not given Date and Time of Concern : 14.01.10 15.30 Your Account of the Concern : (what was said, observed, reported and by whom) A Tutor asked William “if he was ok” after the lesson. He disclosed that he’d had a fight with his Dad. He said he had bruises on his arms stating his Dad had grabbed him during their argument Additional Information : (your opinion, context of concern/disclosure) William disclosed to tutor that he was upset following an argument. He also disclosed physical bruising (did not show the bruises) stating that they were from his Dad. He said that this had never happened before and his Dad had been very upset about it all.

Your Response : (what did you do/say following the concern) This is William’s 2nd year and he has not expressed concern or mentioned such instances in the past. Dad has good contact with tutors and has been very supportive throughout William’s course.

Tutor explained to William that the information would need to be passed on to the DSP owing to the nature of what he had disclosed. Tutor explained that we were there to support him as aLD Training and would keep him informed of any actions we take.

Concern form completed and passed directly to DSP Your Name : A Tutor Your Signature :

Your Position in LD Training : Basket weaving lecturer Date and Time of this Recording : 14.01.10 16.30 Action and Response of DSP / HT

Name: ………………………………………………………..Date:………………………..

PLEASE PASS THIS FORM TO YOUR DESIGNATED SENIOR PERSON FOR SAFEGUARDING (SARA GREEN) OR A DEPUTY DSP (FULL DETAILS AVAILABLE ON SHAREPOINT)

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E. APPENDIX E – SAFER RECRUITMENT AND EMPLOYEE SECURITY (DBS) PROCEDURE Policy Statement LD Training has a duty to provide a secure and safe environment in which learners and staff can obtain the best possible benefit from studying or working at LD Training. This procedure complies with safeguarding guidance and legislation.

Part of LD Training’s duty is to ensure that it does not employ or make use of the services of a person who has a criminal conviction or record of behaviour that could pose a threat to the safety and wellbeing of learners and staff. This procedure will ensure that appropriate checks are made on LD Training employees, agency workers and those carrying out services for LD Training and volunteers, as required.

Should a new member of staff commence their employment prior to the completion of his/her DBS clearance, his/her line manager will be required to undertake a safeguarding risk assessment and return a copy of this form to Human Resources SAFER RECRUITMENT AND INDEPENDENT SAFEGUARDING AUTHORITY REGULATIONS Duty to Refer LD Training complies with the duty to refer any employee or volunteer who poses a risk to children or adults at risk. If LD Training removes someone who is employed or a volunteer, or if they leave under investigation for allegedly causing harm or posing a risk of harm, the Director or Centre Manager will be responsible for referring this information to the Independent Safeguarding Authority.

Regulated and Controlled Activity LD Training is not a designated RAP (Regulated Activity Provider). Staff work in both in regulated and controlled activity.

LD Training has defined regulated activity in its situation as follows: Those workers involved in contact with children or adults at risk of a specified nature for teaching, training, care, supervision, advice, treatment or transport and are frequently intensively and/or overnight. Frequently means once a month or more, 3 or more occasions in a single 30 day period or overnight (2am to 6am).

All tutors, trainers, assessors and those involved in learning support are in regulated jobs at LD Training.

Some staff in Student Services are also in regulated jobs.

LD Training has defined controlled activity in its situation as follows: Workers involved in frequent or intensive support work in LD Training, such as caretakers, cleaners, and receptionists. Also, those workers with access to sensitive records about learners.

Frequent or intensive has the same definition as above.

Compliance with Safer Recruitment LD Training will pay for all relevant, employed staff to have an enhanced DBS disclosure.

LD Training has a single central record that records details of staff identity, DBS disclosures, qualifications, overseas DBS checks, List 99 and right to work in the UK details. The Centre Manager is responsible for the maintenance of this record. The record also includes details of contractors, consultants, and volunteers. References are taken for all workers to check identity and ask specific questions relating to safeguarding.

LD Training currently checks List 99 details before offering employment to new candidates.

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Volunteers

Occasionally individuals approach LD Training to indicate they wish to gain experience in an area: this may be teaching experience or assisting in a specific specialism such as IT or admin. Volunteer helpers are not employees of LD Training and do not receive any form of payment for the services they provide.

LD Training reserves the right to stop any volunteer’s placement at any time for any reason.

The Volunteer Registration form must be completed and authorised by the Linda Johnson, Sara Green or Chris Kasabi prior to the commencement of the volunteering activities. This form must be completed and sent to Chris Kasabi even if the period of volunteering is only for a few hours.

Volunteers cannot to be used as substitute staff and may not have sole responsibility for a student or group of students at any time.

Volunteers will not commence work or other activities at LD Training without first meeting with a designated member of SMT who will check their identity and qualifications and ensure List 99 and DBS checks are undertaken. The Safer Recruitment and Employee Security (DBS) Procedure will apply in the same way as for permanent employees at LD Training.

Agency workers Agency workers may be provided through specialist agencies that supply LD Training with a list containing all the required information relating to identification, qualifications and DBS disclosures.

Where an agency does not provide this service the agency contact and arrangements for meeting the new worker should, in the first instance, be engaged through Human Resources to ensure compliance with the DBS processes.

Disclosure and Barring Service (DBS) Disclosure and Barring Service (DBS) disclosure is a facility whereby an employer can request that a check is carried out on a person to confirm his/her suitability for certain types of work, involving contact with children (under 18) or adults at risk.

Where a DBS check is required the individual will be asked to complete a DBS Disclosure Application (on-line) and to produce evidence of identity to one of LD Trainings counter-signatories The DBS check may take several weeks to complete. When completed the DBS sends the disclosure certificate to the individual who has applied. The disclosure will give details of criminal record or other related matter that has been recorded. LD Training may require the individual to present the DBS disclosure certificate on request.

Recruitment Of New Employees

It will be a condition of all offers of employment made by LD Training that a satisfactory enhanced DBS disclosure is obtained. All applicants for posts at LD Training will be informed of the necessity of a check through the DBS disclosure system. At interview all applicants will be told that a refusal to agree to such a check being carried out, or the outcome of the check being unsatisfactory, will lead to any offer being withdrawn. This will be reiterated when a conditional offer is made.

LD Training will require a DBS enhanced disclosure for all new academic staff and business support staff, due to the nature of LD Training’s business.

All new casual staff and new agency workers will be required to have a satisfactory DBS disclosure.

Voluntary workers will also be required to have obtained a satisfactory DBS disclosure.

Procedure For DBS Checks: New Appointments All new appointees will be required to complete the DBS disclosure application online and to provide evidence of identity in accordance with DBS requirements. The completed online DBS disclosure application and evidence will be checked by a counter-signatory who will then process the DBS check in accordance with DBS procedures.

When completed the DBS sends the disclosure certificate to the individual who has applied. LD TRAINING will be notified by the DBS when the check has been completed. If there are issues raised in the disclosure the Director will invite the individual to meet to discuss the disclosure and its content.

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In determining if the employment should commence/continue the following factors will be taken into account: •

whether the conviction or other matter revealed is relevant to the post offered

•

the seriousness of any offence or other matter revealed

•

the length of time since the offence or other matter occurred

•

whether the individual has a pattern of offending behaviour or record that relates to another relevant matter

•

whether the individual’s circumstances have changed since the offending behaviour

•

the circumstances surrounding the offence or other matter and the explanation offered by the individual

If it is determined that the employment should not commence, or should not continue, the individual will be given written reasons for this. If the individual has not commenced employment the Director or Centre Manager will write to him/her withdrawing the offer and explaining the reasons. Where the individual has commenced employment pending the DBS check, the Director will write to the Centre Manager and/or Finance Officer if dismissal is recommended. There will be an opportunity for the individual to write to the Director setting out his/her reasons why he/she believes he/she should not be dismissed.

Agency lecturers and support workers will not be employed unless they have registered with an agency used by LD Training, which ensures that all its lecturers and support workers have a satisfactory DBS check.

PROCEDURE FOR DBS CHECKS: EXISTING EMPLOYEES LD Training requires all existing employees to hold an enhanced DBS disclosure.

Existing employees may be required to undertake a re-check at any time during their employment. If this is required then the online DBS disclosure application and guidelines will be sent to all existing employees.

The employee will be required to complete the online application and provide evidence of identity in accordance with DBS requirements. A counter signatory who will then process the DBS check in accordance with DBS procedures will check the evidence.

Refusal to agree to the disclosure process may result in the employee being unable to continue in his/her employment.

Once the disclosure has been obtained from the DBS the SMT will consider if the disclosure is satisfactory, taking the following factors into account: •

whether the conviction or other matter revealed is relevant to the post

•

the seriousness of any offence or other matter revealed

•

the length of time since the offence or other matter occurred

•

whether the individual has a pattern of offending behaviour or record that relates to another relevant matter

•

whether the individual’s circumstances have changed since the offending behaviour

•

the circumstances surrounding the offence or other matter and the explanation offered by the individual

•

If it is not considered satisfactory the employee will be invited to a meeting with the Head of Human Resources and his/her line manager. The employee may be accompanied by a trade union representative or a work colleague.

26 POLICY 12 – SAFEGUARDING (JANUARY 2017)

If, following the meeting held in accordance with 5.4 above, the SMT believe that the current employment should not continue the Director will write setting out the reasons for this. The individual will have the opportunity to present his/her case to the Director and may be accompanied a work colleague at the meeting. The SMT will also be present at this meeting. The Director may decide on any of the following courses of action: •

that the employee may continue in his/her current post

•

that the duties of the employee’s post may be amended to enable continuation in his/her current post

•

that the employee should be transferred to another LD Training post which does not involve working with children or adults at risk

•

that the employee shall be dismissed

The Director will notify the employee in writing of his/her decision within two working days of the meeting taking place. If the Director’s decision is that the employee shall be dismissed there will be the right of appeal to a panel of governors. Any appeal must be in writing, and received by the SMT within 10 working days of receiving the Director’s decision to dismiss.

LD Training reserves the right to request a new DBS check from existing employees where there may be concerns about an employee’s behaviour or LD Training receives notification that criminal proceedings are taking place.

PROCEDURE FOR DBS CHECKS: LD Training SMT All LD Training SMT are required to have a satisfactory enhanced DBS disclosure.

The online DBS disclosure application and guidelines will be sent to all SMT, who will be required to complete the application and provide evidence of identity in accordance with DBS requirements. The completed disclosure application and evidence will be checked by a counter-signatory who will then process the DBS check in accordance with DBS procedures.

When completed the DBS sends the disclosure certificate to the individual who has applied. LD TRAINING will be notified by the DBS when the check has been completed. If there are issues raised in the disclosure the Director will invite the individual to meet to discuss the disclosure form and its content.

The Director will ensure that the following factors will be taken into account in determining if the individual is appropriate to act, or to continue to act as part of the LD Training SMT: •

whether the conviction or other matter revealed is relevant to the post offered

•

the seriousness of any offence or other matter revealed

•

the length of time since the offence or other matter occurred

•

whether the individual has a pattern of offending behaviour or record that relates to another relevant matter

•

whether the individual’s circumstances have changed since the offending behaviour

•

the circumstances surrounding the offence or other matter and the explanation offered by the individual

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POLICY 12 – SAFEGUARDING (JANUARY 2017) 27

F. APPENDIX F – LD TRAINING VISITORS All visitors will be required to adhere to the following procedures at all times: On arrival at LD Training, use the main LD Training entrance and report to the Reception desk.

Visitors must sign in on arrival and sign out again when they leave the premises Take note of any Health and Safety and safeguarding guidance you may be given as part of your visit Wait in the seated area in reception, until you are collected by the relevant member of staff Check out at reception on leaving LD Training On arrival ensure you are aware of the nearest fire exit to the meeting rooms you will be using during your visit. These are clearly displayed around LD Training. Should there be a fire evacuation whilst you are visiting LD Training please follow the directions given by LD Training staff.

Visitors meeting with staff

If you have arranged for a visitor to meet with yourself or another member of staff, please ensure that: You enter all details of the visit onto the office diary prior to the visit. Please note that 48 hours’ notice is required to reserve a parking space.

You have corresponded with your visitor prior to the visit, drawing attention to the following: On arrival at LD Training, to use the main LD Training entrance and report to the reception desk to sign in, collect their safeguarding booklet To wait in reception until they are collected by yourself Show your visitor the nearest fire exit to the meeting room At the end of the visit you accompany the visitor to the reception desk to check out

28 POLICY 12 – SAFEGUARDING (JANUARY 2017)