|Adults at Risk Protection Policy
|All adult learners, Corporation members, staff, volunteers, partners working at all College campuses, other external facilities, in the workplace or by distance learning
|18 October 2023
|Date of next review:
|Designated Safeguarding Lead
|Date last reviewed:
Monitoring and review
This policy will be reviewed by the Corporation at least every year.
This policy provides guidance to all adults working within the College whether paid or voluntary or directly employed by the College or by a third party.
The College is committed to safeguarding adults at risk and promoting their welfare and expects all staff, governors, volunteers and visitors to share this commitment and maintain a vigilant and safe environment. Everyone has a responsibility to act, without delay, to protect adults at risk by reporting anything that might suggest an adult at risk is being abused or neglected. It is our willingness to work safely and challenge inappropriate behaviours that underpins this commitment. The College seeks to work in partnership with families and other agencies to improve the outcomes for adults at risk who are vulnerable or in need.
In preparing this guidance we have consulted with, referred to, and worked within the Liverpool Safeguarding Adults’ Board Inter-agency Safeguarding Adults Procedures. This policy has been updated to include referrals to Channel in compliance with the Prevent Duty.
The College further reinforces their duty of care to all students, irrespective of age or vulnerability, within all relevant training, guidance, policies and procedures, deriving from:
‘An adult at risk of abuse or neglect is defined as someone who has needs for care and support, who is experiencing, or at risk of, abuse or neglect and as a result of their care needs – is unable to protect themselves.’ Care Act 2014
The Care Act 2014 sets a clear framework for how local authorities should protect adults at risk of abuse or neglect. The Act places a duty on local authorities to make enquiries, or cause others to do so, if it believes that an adult:
‘Where an adult at risk is suffering significant harm, or is likely to do so, action should be taken to protect that adult at risk.’
‘Where an adult at risk is suffering significant harm, or is likely to do so, action should be taken to protect that adult at risk.’
6. Legislation and Guidance:
The Counter-Terrorism and Security Act 2015 places a duty upon local authorities and educational providers to ‘have due regard to the need to prevent people from being drawn into terrorism’ (CTSA 2015). ‘The fundamental aims of Prevent, as part of the revised 2018 Contest Strategy are, “to safeguard vulnerable people to stop them becoming terrorists or supporting terrorism.” (Work Based Learners and the Prevent Statutory Duty 2018). The DfE has provided statutory guidance for colleges and childcare providers: ‘Revised Prevent Duty Guidance: England and Wales’ (DfE 2019). The guidance summarises the requirements of colleges in terms of four general themes: risk assessment, working in partnership, staff training and IT policies. The College will ensure that staff are aware of the indicators
of extremism and radicalisation and know how to respond in keeping with local and national guidance. Staff will use their judgement in identifying adults who might be at risk of radicalisation and act proportionately which may include making a referral to the Channel programme. Equally, adults at risk will be made aware of the risks and support available to them. We will ensure that adults at risk are safe from terrorist and extremist material when accessing the internet in the College. The Government has developed an ‘educate against hate’ website providing information and resources for colleges and parents to support them to recognise and address extremism and radicalisation in young and/or vulnerable people.
The Teaching Standards (DfE 2013) also requires all tutors to ‘uphold public trust in the profession and maintain high standards of ethics and behaviour, within and outside College, including:
The College will also take account of additional guidance and legislation including:
The Equality Act 2010
SEN Code of Practice: 0 to 25 years Statutory guidance for organisations which work with and support children and young people who have special educational needs or disabilities (DfE 2015)
Criminal Exploitation of children and vulnerable adults: County Lines Guidance (DFE, 2017)
Information sharing: Advice for practitioners providing safeguarding services (HMG, 2018)
Revised Prevent Duty Guidance: for England and Wales (DfE, 2019)
How social media is used to encourage travel to Syria and Iraq (DFE Briefing note for colleges).
The College is committed to the principles of safeguarding where a person-centred approach is fundamental to safeguarding and promoting the welfare of every adult at risk. An adult at risk centred approach means keeping them in focus when making decisions about their lives and working in partnership with them and their families.’
The following statement is made available to parents/carers through the College website so they are aware of the College’s responsibilities:
‘The College is committed to safeguarding adults at risk and promoting their welfare and expects all staff, governors, volunteers and visitors to share this commitment and maintain a vigilant and safe environment. Everyone has a responsibility to act, without delay, to protect adults at risk by reporting anything that might suggest an adult at risk is being abused or neglected.’
The College also has a statutory responsibility to share any concerns it might have about a child or adult at risk in need of protection with other agencies and in particular police, health and social services. Colleges are not able to investigate child or adult at risk protection concerns but have a legal duty to refer them. In most instances the College will be able to inform the parents/ carers of its need to make a referral; however, sometimes the College can in certain circumstances share information without the consent of the family and may be advised by adult services or the police that the parent/carer cannot be informed whilst they investigate the matter or make enquires. The College follows legislation that aims to act in the interests of the child or adult at risk.
The College will always seek to work in partnership with parents and other agencies to ensure the best possible outcomes for the child or adult at risk and family.’
The following notice is made available to all visitors in reception. In addition, all visitors are provided with additional safeguarding guidance.
‘The College is committed to safeguarding children and adults at risk and promoting their welfare and expects all staff, governors, volunteers and visitors to share this commitment and maintain a vigilant and safe environment. Everyone has a responsibility to act without delay to protect children and adults at risk by reporting anything that might suggest they are being abused or neglected. We would expect you to also report to the Designated Safeguarding Lead or Principal any behaviours of any adults working in the College that may concern you. By signing our visitors’ book, you are agreeing to follow the College’s safeguarding advice to visitors and where appropriate the code of conduct for staff and volunteers.’
The details of the Designated Safeguarding Lead, Safeguarding Operational Lead and Safeguarding Officers are displayed in each centre.
The Principal is: Elaine Bowker
The Chair of Governors is: Tony Cobain
The Designated Safeguarding Lead is: Aamir Butt
The nominated Safeguarding Governor is: Louise Barry
The nominated governor for dealing with allegations against the Principal is: Tony Cobain
Those trained to provide cover for the role of Designated Safeguarding Lead are:
The Governing body should ensure that:
Governing bodies are accountable for ensuring that the College has effective policies and procedures in line with local and national guidance, and for monitoring the College’s compliance with them. Neither the Governing Body nor individual governors have a role in dealing with individual cases or the right to know the detail of cases (except when exercising their disciplinary functions in respect of allegations against a member of staff or investigating a complaint brought to their attention).
The Principal will ensure that:
Designated Safeguarding Lead
The Designated Safeguarding Lead will quality assure the College’s adult at risk practices including the auditing of safeguarding records and the supervision of the Safeguarding Operational Lead, Safeguarding Officer and other members of the safeguarding team to ensure that actions and decisions are reviewed appropriately and that staff’s emotional needs are met.
Whilst the activities of the designated safeguarding lead can be delegated to appropriately trained deputies, the ultimate lead responsibility for safeguarding and child protection, as set out above, remains with the designated safeguarding lead. This responsibility should not be delegated.
The latest safeguarding legislation sets out the broad areas of responsibility for the Designated Safeguarding Lead:
The Designated Safeguarding Lead is expected to:
The Designated Safeguarding Lead (and any deputies) should undergo training to provide them with the knowledge and skills required to carry out the role. This training should be updated at least every two years.
The Designated Safeguarding Lead should undertake Prevent awareness training.
In addition to the formal training set out above, their knowledge and skills should be refreshed (this might be via e-bulletins, meeting other Designated Safeguarding Leads, or simply taking time to read and digest safeguarding developments) at regular intervals, as required, but at least annually, to allow them to understand and keep up with any developments relevant to their role so that they:
The Designated Safeguarding Lead should:
During term time the Designated Safeguarding Lead (or a deputy) will be available (during College hours) for staff in the College to discuss any safeguarding concerns.
The Designated Safeguarding Lead will arrange adequate and appropriate cover arrangements for any out of hours/out of term activities.
Additional duties of the Designated Safeguarding Lead
In addition to the above the Designated Safeguarding Lead is also expected to ensure that:
Director of Human Resources should:
In addition to this policy, the College has procedures or policies in relation to other areas for safeguarding adults at risk including, as examples:
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Concerns that an adult at risk is being radicalised should follow the normal safeguarding referral mechanism, with an additional Channel referral being made to the Local Authority’s Prevent and Channel team.
All staff and volunteers must report any concerns about a member of staff’s behaviour towards adults at risk to the Principal. Concerns can also be discussed with the Designated Safeguarding Lead. Concerns about the Principal should be raised with Chair of Governors or nominated governor. The College’s policy and procedures will support everyone to take action.
College should ensure strict compliance of the Staff Code of Conduct. There may be times when the concern raised against a member of staff does not meet the reporting threshold (Low-level concern). College, through its safeguarding training and induction inform all staff (permanent, casual, volunteers and agency) about their responsibility to report even the small concerns they may have about another member of staff. HR should record all concerns and investigate them thoroughly to ensure that any of the reported concerns are addressed and dealt with appropriately. Designated Safeguarding Lead should be consulted when making these decisions. In most cases these concerns will be addressed through conversation with concerned staff, appropriate training and reminder of professional behaviour as per the Staff Code of conduct. However, in some cases there will be a need for formal action. The guiding principle should be the potential of harm to ’adults at risk’ in the College.
All concerns must be reported and discussed with the Safeguarding Team (or Designated Safeguarding Lead or Duty Manager). This is most likely to include, but not limited to: bullying (including cyber bullying), gender-based violence/sexual assaults and sexting (sexual imagery). Staff should recognise that adults at risk are capable of abusing other students. Staff must challenge any form of derogatory and sexualised language or behaviour. Staff should be vigilant to sexualised/aggressive touching/grabbing particularly towards girls. Behaviours by adults at risk or others should never be passed off as ‘banter’.
Adults at risk with special educational needs and disabilities are more vulnerable to sexual violence and harassment and staff should be aware that additional barriers can exist when recognising abuse in these adults at risk. Adults at risk who are LGBT or perceived to be, may also be targeted by their peers and harassed or assaulted.
Victims of sexual abuse will be supported by the College’s student support system and referred to specialist agencies. A risk assessment may need to be in place. The College curriculum will support all students to become more resilient to inappropriate behaviours towards them.
Staff should also report any concerns about any inappropriate use of technology to the Safeguarding Team, Deputy Designated Safeguarding Lead or senior member of staff.
The College’s on-line/E-safety/ Acceptable User policy clearly outlines the way in which the College uses technology and the measures in place to ensure safe and responsible use by all. There is a clear code of conduct for staff and volunteers which sets out the use of new technologies, mobile phones and personal photographic equipment around adults at risk. A protocol for video conferencing was produced at the start of lockdown to be included within the IT Acceptable User Policy.
The DfE highlights the risks of new technologies: ‘The use of technology has become a significant component of many safeguarding issues. Sexual exploitation; radicalisation; sexual predation – technology often provides the platform that facilitates harm. The breadth of issues classified within online safety is considerable, but can be categorised into three areas of risk:
Staff should bring immediately to the attention of the Safeguarding Team any behaviours by adults or adults at risk themselves that may be risky or harmful.
All staff are aware that mental health problems can, in some cases, be an indicator that an adult at risk has suffered or is at risk of suffering abuse, neglect or exploitation.
Only appropriately trained mental health professionals can make a diagnosis of a mental health issues. College staff, however, are well placed to observe individual students 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 the adults at risk have suffered abuse and neglect, or other potentially traumatic adverse experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. Staff in the College are aware of how these experiences, can impact on their mental health, behaviour and education.
If staff have a mental health concern about a student that is also a safeguarding concern, immediate action needs to be taken, and referral should be made to the safeguarding team following established procedures.
All staff are made aware that ‘up skirting’ is now a criminal offence. A definition has been included which describes up skirting as, “taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm” (DfE, 2020)
The College will ensure that all appointments follow its recruitment policy and the guidance set out in its Safeguarding Policy. At least one member of the appointments panel will have undertaken safer recruitment training. The College will undertake all the required DFE pre-employments checks and where appropriate record these checks on the single central record and retain evidence in personnel files. The College will seek written confirmation that third-party organisations including contractors and alternative education providers have undertaken appropriate checks.
The College is required to make all relevant checks including the Disclosure and Barring Service (DBS) checks to ensure that staff recruited are appropriate for an educational environment. Appropriate action will be taken against staff (in service) who have committed a relevant offence. This includes reporting them to Disclosure and Barring Service.
The College will ensure it has a curriculum map which sets out how its students keep themselves safe from harm. Adults at risk will be supported to develop their understanding, where appropriate, of risks including: when using technology, the internet, and risks associated with grooming and radicalisation, gang and criminal exploitation and misusing drugs and alcohol. The College will ensure the curriculum promotes British Values as set out in the Counter Terrorism and Security Act 2015.
Staff will be told of concerns about an adult at risk on a ‘need to know basis’. The College understands the need to keep its safeguarding records securely.
The College Safeguarding team will ensure that all safeguarding records are transferred to the educational provider where a student destination is known or where records are requested by a new provider. College will transfer records securely to the next setting and discuss the individual’s needs
The College will retain records in keeping with legal guidelines.
Staff cannot promise confidentiality to adults at risk but must always act in their best interest and share disclosures made by the adult at risk or others with the Safeguarding Team.
The College will aim to seek consent of individual or their carers before sharing information with other agencies, however legislation states that colleges
The Designated Safeguarding Lead is responsible for reporting safeguarding data and analysis to the governing body each term. Governors are presented with 3 reports every year. The reports will provide assurance to governors about the College’s compliance status with regards to its legal obligations as well as safeguarding records for relevant terms along with an analysis. The reports also highlight any prevalent issues and trends that require College’s attention.
The designated Safeguarding Lead, through termly meetings of “Safeguarding and Wellbeing Strategy Group” seek assurances from all stakeholders around compliance with the safeguarding requirements: The membership of the group include Deputy Principal, Designated Safeguarding Governor, Director of HR, Head of IT, Deputy Safeguarding Lead, Director of Progression, Head of Student Services and Director of Estates. Groups seeks assurance around DBS checks, Safeguarding training compliance, web and online filtering and monitoring, digital safety and digital education, site safety and security etc.
Complaints about safeguarding should follow the College’s complaints policy.
The College also has whistle-blowing procedures to allow people to raise concerns.