|Document title:||Child Protection Policy 2020-2021|
|Audience:||All learners, Corporation members, staff, volunteers, partners working at all College campuses, other external facilities, in the workplace or by distance learning|
|Date approved:||October 2020|
|Date of next review:||September 2021|
|Document author(s):||Designated Safeguarding Lead|
|Date issued:||September 2020|
This policy provides guidance to all adults working or volunteering within the College whether paid or voluntary or directly employed by the College or by a third party.
The College is committed to safeguarding children and promoting children’s 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 by reporting anything that might suggest a child 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 children who are vulnerable or in need.
‘Safeguarding and promoting the welfare of children is everyone’s responsibility. Everyone who meets children and their families has a role to play. To fulfil this responsibility effectively, all practitioners should make sure their approach is child centred. This means that they should consider, at all times, what is in the best interests of the child.’ (KCSiE 2020)
A child includes anyone under the age of 18.
Child protection: ‘Part of safeguarding and promoting welfare. This refers to the activity that is undertaken to protect specific children who are suffering, or are likely to suffer, significant harm.’ Keeping Children Safe in Education (KCSiE 2020)
Safeguarding and promoting the welfare of children is defined as ‘protecting children from maltreatment; preventing impairment of children’s health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes.’ (KCSiE 2020)
The definitions of physical abuse, emotional abuse, sexual abuse, and neglect are set out in the DFE guidance, Part 1: Keeping Children Safe in Education 2020.
The Children Act 2004 requires each person or organisation to which the duties apply to have regard to any guidance given to them by the Secretary of State; specifically:
Section 175 (3) of the Education Act 2002 places a duty on the governing body of an institution within the further education sector to ‘make arrangements for ensuring that their functions relating to the conduct of the institution are exercised with a view to safeguarding and promoting the welfare of children receiving education or training at the institution.’
Colleges must have regard for DfE statutory guidance. This child protection policy should be read alongside Working Together to Safeguard Children (WT 2019) and ‘Keeping Children Safe in Education (2020) and all staff must read and understand Part 1 and Annex A of KCSiE (2020).
Working Together to Safeguard Children (2019) makes it clear that protecting children from harm and promoting their welfare depends upon a shared responsibility and effective joint working between different agencies:
‘Everyone who works with children has a responsibility for keeping them safe. No single practitioner can have a full picture of a child’s needs and circumstances and, if children and families are to receive the right help at the right time, everyone who comes into contact with them has a role to play in identifying concerns, sharing information and taking prompt action.’
In addition, Working Together to Safeguard Children also reinforces the need to take action to provide early help before statutory services are required:
‘Providing early help is more effective in promoting the welfare of children than reacting later. Early Help means providing support as soon as a problem emerges, at any point in a child’s life, from the foundation years through to the teenage years.’ (WT 2019)
The College therefore understands its responsibility to engage with other professionals in Early Help Assessments when a child’s needs according to the Local Safeguarding Children Partnership’s Responding to Need and Level of Needs framework sit below the requirement for a statutory assessment.
The Counterterrorism 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 2015). The guidance summarises the requirements of colleges in terms of four general themes: risk assessment, working in partnership, staff training and IT policies. Our 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 judgment in identifying children who might be at risk of radicalisation and act proportionately, which may include making a referral to the Channel programme. Equally, children will be made aware of the risks and support available to them. We will ensure that children are safe from terrorist and extremist material when accessing the internet in 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 people.
‘Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime Act 2015) places a statutory duty upon tutors along with regulated health and social care professionals in England and Wales, 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 tutors to see visual evidence, and they should not be examining students, 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. Information on when and how to make a report can be found at:
Tutors must personally report to the police cases where they discover that an act of FGM appears to have been carried out. Unless the tutor has a good reason not to, they should also still consider and discuss any such case with the College’s Designated Safeguarding Lead and involve children’s social care as appropriate. The duty does not apply in relation to at risk or suspected cases (i.e. where the tutor does not discover that an act of FGM appears to have been carried out, either through disclosure by the victim or visual evidence) or in cases where the woman is 18 or over. In these cases, tutors should follow local safeguarding procedures.’ DFE 2018
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:
In addition, the Sexual Offences Act 2003 makes it clear that all members of staff are in a position of trust and would therefore be committing a criminal offence to have a sexual relationship with a young person below the age of 18, even if that student is over the age of consent. In addition, it would be a breach of trust to have a relationship with any College student over the age of 18. This would result in the issue being addressed under the formal disciplinary procedure and may constitute gross misconduct.
The College will also take account of additional guidance including:
The College is committed to the principles of Working Together to Safeguard Children (2019) which states that a ‘child centred approach is fundamental to safeguarding and promoting the welfare of every child. A child centred approach means keeping the child in focus when making decisions about their lives and working in partnership with them and their families.’ (WT2019)
The following statement is available to parents/carers through the College’s website, so they are aware of the College’s responsibilities:
‘Our College is committed to safeguarding children and promoting children’s 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 by reporting anything that might suggest a child is being abused or neglected.’
The College also has a statutory responsibility to share any concerns it might have about a child in need of protection with other agencies and police, health, and children’s services. Colleges are not able to investigate child 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 children’s services or police that the parent/carer cannot be informed whilst they investigate the matter or make enquires. We understand the anxiety parents/carers understandably feel when they are not told about any concerns from the outset. The College follows legislation that aims to act in the interests of the child.
The College will always seek to work in partnership with parents and other agencies to ensure the best possible outcomes for the child and family.
The following notice is made available to all visitors in reception. In addition, all visitors are provided with additional safeguarding guidance.
‘Our College is committed to safeguarding children and promoting children’s 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 by reporting anything that might suggest a child is being abused or neglected. We would expect you to also report to the Strategic or Operational Designated Safeguarding Leads 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 names and photographs of the Designated Safeguarding Lead, Safeguarding Operational Lead, U16s Safeguarding Lead and Safeguarding Officer are displayed in each centre.
The Principal is: Elaine Bowker
The Chair of Governors is Tony Cobain
The Strategic Designated Safeguarding Lead for Child Protection is: Aamir Butt
The Operational Designated Safeguarding Lead for child protection is Steven Panter
Those trained to provide cover for the role of Designated Safeguarding Lead are:
Members of the Safeguarding Team and Safeguarding Duty Managers
The nominated Safeguarding / Child Protection Governor is Steve Sankson
The nominated governor for dealing with allegations against the Principal is: Tony Cobain
The Governing body should ensure that:
The Principal will ensure that:
The Principal will normally be informed of any allegations against staff and will ensure appropriate referrals to the Disclosure and Barring Service or Teaching Regulation Agency are made.
Designated Safeguarding Lead
The Designated Safeguarding Lead will quality assure the College’s child protection 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.
Keeping Children Safe in Education 2020 sets out the broad areas of responsibility for the Designated Safeguarding Lead:
The Designated Safeguarding Lead is expected to:
Work with Others
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 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 role outlined in Keeping Children Safe in Education 2020 the Designated Safeguarding Lead is also expected to ensure that:
All staff (and volunteers) should:
In addition to this child protection policy the College has procedures or policies in relation to other areas for safeguarding children including as examples:
0345 050 0148 (emergency duty team)
920 8234 (emergency duty team)
|St. Helens||(01744) 676600
0845 050 0148 (emergency duty team)
|Merseyside Police||709 6010 or 101
999 in emergencies
Part 1 of Keeping Children Safe in Education (DFE 2020) provides key flowcharts and guidance to support staff and volunteers’ understanding and decision making. This will support staff to make a referral themselves should that become necessary. The Safeguarding Team should be informed, as soon as possible, following the need for another member of staff to make a referral. Guidance is also available on the NSPCC website: https://www.nspcc.org.uk/preventing-abuse/
Concerns that a child 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 children 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 act. Concerns can also be taken directly to the Local Authority Designated Officer (L.A.D.O.), if needed, via Children’s Services. Section 4 of the DfE guidance Keeping Children Safe in Education (2020) provides further guidance.
LADO details and referrals
Ray Said -LADO
T: 0151 233 0840
Pauline Trubshaw – Deputy LADO
T: 0151 233 0846
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 (youth produced sexual imagery). Staff should recognise that children can abuse their peers. 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 children should never be passed off as ‘banter’ or ‘part of growing up’. The DfE states ‘peer on peer abuse should be taken as seriously as abuse by adults and should be subject to the same child protection procedures. Professionals should not dismiss abusive behaviour as normal between young people and should not develop high thresholds before taking action.’ (KCSiE 2020).
Children 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 children. Children who are LGBT or perceived to be, may also be targeted by their peers, and harassed or assaulted.
Victims of peer on peer harm will be supported by the College’s pastoral system and referred to specialist agencies including, as examples, ‘CAMHs’, ‘Brook’ and ‘Barnardo’s’. A risk assessment may need to be in place. The College curriculum will support young people to become more resilient to inappropriate behaviours towards them, risk taking behaviours and behaviours that children may be coerced into including ‘sexting’ or ‘initiation/hazing’ behaviours.
Additional guidance on protecting children from online abuse is available on the NSPCC website:
Staff should also report any concerns about sexting (youth produced sexual imagery) to the Safeguarding Team, Deputy Designated Safeguarding Lead or senior member of staff who will follow the guidance in: Sexting in schools and colleges: Responding to incidents and safeguarding young people (UK Council for Child Internet Safety) (https://www.gov.uk/government/groups/uk-council-for-child-internet-safety-ukccis provides clarity as to how staff should respond to these incidents).
The College’s online/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 children. The College will consider looked After Children (Children in Care) who might be put at risk by being included in publicity materials or College photographs.
The DfE highlights the risks of new technologies:
‘The use of technology has become a significant component of many safeguarding issues. Child 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 children themselves that may be risky or harmful.
Government guidance called; Teaching online safety in school (DfE, 2019c) added which outlines how schools can ensure pupils understand how to stay safe online. A protocol for video conferencing was produced at the start of lockdown to be included within the Acceptable User Policy.
A child missing from an education setting is a potential indicator of abuse or neglect including exploitation. Local Authority guidance and procedures will be followed for dealing with a child who is missing from education, particularly on repeated occasions. The College will follow the pan-Merseyside missing children protocol. Unauthorised attendance will be closely monitored. The attendance of children with known welfare and attendance concerns will be monitored closely, particularly those with chronic poor attendance or persistent absentees. Colleges should also scrutinise the attendance of off-site provision to ensure children are attending and are safe. Similarly, the attendance of children who are vulnerable or with known welfare and safeguarding concerns such as children who have a child protection plan, are children in need, are Children Looked After and/or SEN will be monitored on a regular basis.
The College will seek to ensure it has at least two emergency contacts for each family and consider what urgent action it may need to take when a vulnerable child and family are not contactable and the child has not attended College.
It is essential that all staff are alert to signs to look out for and the individual triggers to be aware of when considering the risks of potential safeguarding concerns such as travelling to conflict zones, Female Genital Mutilation and forced marriage.
Any child may benefit from early help, but all school and college staff should be particularly alert to the potential need for early help for a child who:
Detailed information on early help can be found in Chapter 1 of Working Together to Safeguard Children (2019). More information on statutory assessments is included at paragraph 48. Detailed information on statutory assessments can be found in Chapter 1 of Working Together to Safeguard Children 2019.
Both CSE and CCE are forms of abuse and both occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into sexual or criminal activity. 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. In some cases, the abuse will be in exchange for something the victim needs or wants and/or will be to the financial benefit or other advantage (such as increased status) of the perpetrator or facilitator. The abuse can be perpetrated by individuals or groups, males’ females, and children or adults.
The abuse 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. Victims can be exploited even when activity appears consensual and it should be noted exploitation as well as being physical can be facilitated and/or take place online. More information include definitions and indicators are included in Annex A. of Keeping Children Safe in education (2020)
The college takes instances of exploitation very seriously and takes immediate action to support students who are vulnerable.
Our College has a mandatory duty to report to the local authority if they believe a child is subject to a private fostering arrangement. (This does not include close family relatives e.g. grandparent, brother, sister, uncle, or auntie.) A private fostering arrangement is made without the knowledge of the local authority for the care of a child under the age of 16 years (under 18 for children with disabilities) whereby the child is in the care of someone other than their parent or close relative. Further guidance is available in Keeping Children safe in Education (DfE 2020). When a child is privately fostered a social worker must carry out an assessment to ensure the placement is appropriate and consider any support needed.
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)
Specific guidance is in force to support schools and colleges in recognising where students may be at risk from serious crime. The guidance sets out what we as a college staff look out for: “All staff are aware of indicators, which may signal that children are at risk from, or are involved with serious violent crime. These may include increased absence from college, 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” (DfE, 2019a) And what school and college staff need to know: “All staff are aware of the associated risks and understand the measures in place to measure these. Advice for schools and colleges is provided in the Home Office’s Preventing youth violence and gang involvement and its criminal exploitation of children and vulnerable adults: county lines guidance.” (DfE, 2019)
The Designated safeguarding leads are aware that the department has published detailed advice to support schools and colleges. The advice is available here:
Reports of sexual violence and sexual harassment are taken seriously by the college. These incidents are likely to be complex and require difficult professional decisions to be made, often quickly and under pressure. Preplanning, effective training and effective policies will provide us with the foundation for a calm, considered and appropriate response to any reports.
The guidance provides effective safeguarding practice and principles for schools and colleges to consider in their decision-making process.
Any decisions are for the college to make on a case-by-case basis, with the designated safeguarding leads taking a leading role and using our professional judgement, supported by other agencies, such as children’s social care and the police as required.
All staff are aware that mental health problems can, in some cases, be an indicator that a young person has suffered or is at risk of suffering abuse, neglect or exploitation.
Only appropriately trained mental health professionals in college attempt to make a diagnosis of a mental health problem. College staff, however, are well placed to observe young people 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 young people have suffered abuse and neglect, or other potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. Staff in college 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 is taken, following their child protection policy, and speaking to the designated safeguarding leads or a deputy.
The College will ensure that all appointments follow its recruitment policy and the guidance set out in Keeping Children Safe in Education (DfE 2020). 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 investigate relevant staff who fall within the scope of Disqualification under the Childcare Act 2006 and establish they are not disqualified. The criteria for disqualification under the 2006 Act and the 2018 Regulations includes inclusion on the Disclosure and Barring Service (DBS) Children’s Barred List or committing a relevant offence.
The College will ensure it has a curriculum map which sets out how to help children keep themselves safe from harm. Children will be supported to develop their understanding, at the appropriate age, of risks including using technology, the internet, and risks associated with grooming and radicalisation, gang and criminal exploitation and misusing drugs and alcohol. Children will also learn about the wider safeguarding curriculum which for children would include road safety, anti-bullying and know how to seek support when needed. The College will ensure the curriculum promotes British Values as set out in the Counter Terrorism and Security Act 2015.
The College understands the need to keep child protection and safeguarding records securely.
Where requested by a new provider, College will transfer records securely to the next setting and discuss the child’s needs. The College will retain records in keeping with Local Authority guidance and NSPCC guidelines:
This in turn references the Information and Records Management Society (IRMS) 2018 Information management toolkit for school’s version 6.0.
Staff cannot promise children confidentiality but must always act in the best interests of the child and share disclosures made by the child or others with the Safeguarding Team, who will work within the principles outlined in Information sharing: Advice for practitioners providing safeguarding services to children, young people, parents and carers (HMG, 2018)
Staff will be told of concerns about a child on a ‘need to know basis’.
The College will aim to seek consent of parents before sharing information with other agencies, however legislation states that colleges and other agencies can share information without the consent of a parent/carer circumstances.
Complaints about safeguarding should follow the College’s complaints policy.
The College and Local Authority also have whistleblowing procedures.
(The NSPCC whistleblowing helpline is available for staff who do not feel able to raise concerns regarding child protection failures internally. Staff can call: 0800 028 0285)