1.0 Policy

• The Children Act 1989 an 2004

• Education Act 2002

• The Education (Health Standards) (England) Regulations 2003

• The Further Education (Providers of Education) (England) (Regulations) 2006

• The School Staffing (England) Regulations 2009 as amended by SI 2012/1740 and SI 2013/1940

• The Education (School Teachers' Appraisal) (England) Regulations 2012

• The Children and Families Act 2014

• Safeguarding Vulnerable Groups Act 2006

• Serious Crime Act 2015

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UK Council for Child Internet Safety (UKCCIS) published in August 2016: 'Sexting in schools and colleges, responding to incidents, and safeguarding young people.'

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1.1 Purpose

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The purpose of this policy is to clarify roles, responsibilities and procedures for TSL staff with respect to the safeguarding of children and vulnerable adults who are learners at TSL.

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1.2 Scope

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The following policy and reporting procedures apply to all personnel working in and on behalf of the TSL (including volunteers, contracted employees and sub-contracted provision and off-site delivery partners). TSL acknowledges that promoting safeguarding is the responsibility of all the staff. It will specifically focus on:

• Child protection

• Protection of vulnerable adults (PoVA)

• Safer recruitment

• Dealing with allegations and suspicions

• Dealing with an abuse of trust

• Safeguarding

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1.3 Background

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TSL is committed to the well-being and development of all its learners. TSL recognises its contribution and duties towards safeguarding all its learners, especially those who are vulnerable. At TSL we are committed to safeguarding our learners and we expect all our staff to share this commitment. Our staff take welfare concerns seriously and we encourage our learners to discuss concerns. We have developed an ethos of care and concern for our learners and staff.

Safeguarding is a term used to describe the overall safety and well-being of an individual and for the purposes of this policy and set of procedures includes:

• Protecting children, young people and vulnerable adults from maltreatment and exploitation

• Preventing the impairment of children and young peoples’ health and wellbeing

• Ensuring that children and young people are growing up in circumstances consistent with the provision of safe and effective care

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TSL will strive to:

• Develop and support a trusting TSL ethos, so that learners communicate well with staff

• Be proactive in ensuring the safety of young people and vulnerable adults

• Provide clear guidelines and procedures for all staff so that they can respond appropriately to safeguarding concerns

• Develop and deliver a staff training package which keeps all staff up-to-date with procedures and safeguarding issues and evaluate its effectiveness in meeting this objective

• Offer support to staff and learners who have any safeguarding concerns(including referral to external agencies where this is deemed appropriate)

• Act promptly and diligently on any safeguarding concerns

• Liaise with the appropriate key partners and develop collaborative working practices which facilitate and promote the safeguarding of children and vulnerable adults both within TSL and within the wider community

 

This policy will be revised, monitored and implemented in following consultation with partners and will be reviewed annually.

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2.0 Linked Policies and/or Procedures

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Staff should also be aware of TSL’s:

• Learner Anti-Bullying Policy

• Health and Safety Policy

• Confidentiality and Disclosure Policy

• Acceptable Use Policy

• Staff Whistleblowing Procedure

• Data Protection Policy

• Equality and Diversity Policy

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3.0 Definitions

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3.1 Any reference to a child in this policy includes, in addition to a person under the age of 18, a person aged 18, 19 or 20 who (a) has been looked after by a local authority at any time after attaining the age of 16 or (b) has a learning disability. This complies with recommendations given in the DfES document “Safeguarding Children in Education” (2004) Paragraph 9 (2)

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3.2 A Vulnerable Adult is someone who is aged 18 or over and:

• Is unable to protect him or herself against significant harm or exploitation

• Is or may be in need of community care services by reason of mental or other disability, increasing frailty or illness 

• Is or may be unable to take care of him or herself

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3.3 TSL also acknowledges that specific social or cultural groups of people may also be at greater risk of harm and will therefore be more vulnerable, such as (but not exclusively):

• Those young people who are in or leaving public care

• Asylum seekers who are under 18 and/or who are independent from their parents

• Those who are under the supervision of the youth offending or probation service

• Individuals with protected characteristics under the Equality Act 2010 Age, Disability, Sex, Race, Religion, Sexual orientation, Gender reassignment, Marriage/civil partnership, Pregnancy/maternity

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3.4 Categories of Abuse or Harm for children and vulnerable adults are listed in Appendix 6

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4.0 TSL Commitment

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TSL will ensure the following commitments are made on behalf of learners and staff:

4.1 Staff will be informed that procedures are in place and that these must be followed if they become aware of a safeguarding issue.

4.2 Copies of the Safeguarding Policy and related Procedures will be made easily accessible and will be available both electronically and in paper format.

4.3 Appropriate reporting documentation will be easily accessible in both electronic and in paper format.

4.4 A member of staff will be nominated to act as a link person for co-ordinating and liaising with other agencies. Other staff will be named as key contacts with regard to safeguarding issues and these names will be circulated to all staff and will be easily accessible. These staff will receive specific training and guidance.
 

4.5 Appropriate training will be delivered to all staff to ensure they are aware of the procedures to be followed, as well as the importance of the TSL’s Confidentiality and Disclosure Policy and other related policies named on page 2 of this document.
 

4.6 Training will also ensure that all staff are aware of a range of safeguarding issues, including health-related risky behaviours and will seek to develop the skills of staff in identifying and supporting learners with these issues
 

4.7 Thorough risk assessments will take place which cover the range of TSL activities
 

4.8 Resources will be allocated to improve the personal safety of learners and to improve their awareness of these issues through curriculum and enrichment activities

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5.0 Information Sharing

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TSL Confidentiality and Disclosure Policy will provide full guidance. However the following act as general principles.

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5.1 TSL staff cannot offer absolute confidentiality to learners

5.2 Information may need to be shared only with nominated members of staff, if:

• a young person or vulnerable adult is at risk of harm or of harming others

• a young person or vulnerable adult has made a clear serious breach of TSL Acceptable Behaviour Procedure

• there is information that a learner under the age of 18 is being abused

• there is information that a learner with a learning difficulty or disability of any age is being abused

• an individual may present a risk to children, young people or a vulnerable adult

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5.3 If a member of staff finds themselves in a "disclosure" situation with a learner they should inform the learner as soon as possible that they have a duty to follow TSL procedures and inform an appropriate person.
 

5.4 If at any time a member of staff is unsure of who they can share confidential information with, they should discuss this with one of TSL Designated Safeguarding Officers.

 

5.5 TSL keeps information about staff, learners and other parties to allow it to operate as a successful organisation and meet its legal obligations. To comply with the Data Protection Act 1998 (“the Act), information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully. To do this, TSL must comply with the Data Protection Principles in the Act.

 

Further details about TSL Data Protection Policy can be provided on request.

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5.6 Where there are concerns that a child, young person or vulnerable adult is, or may be, at risk of significant harm, their needs must always come first. The priority must always be to safeguard the child, young person or vulnerable adult.

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6.0 Safer Recruitment of Staff

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TSL is committed to safeguarding and promoting the welfare of children and young people and expects all staff, sub-contractors and volunteers to share this commitment. Three staff have been trained in Safer Recruitment Procedures.

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6.1 The Recruitment Procedure is designed to assist managers to recruit and select the best candidates for a vacancy and takes account of all relevant legislation including the Safeguarding Children and Safer Recruitment in Education Guidance. These Policy and Procedures will be regularly updated as vetting and barring arrangements develop in order to ensure we not only meet our legal duties, but go beyond compliance whenever possible to further reduce the risk of harm.

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A copy of the Recruitment Procedure can be found on the TSL Intranet or provided on request. The key safeguarding-related points of this document are:

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Prior to Interview

All candidates are required to complete the TSL Application Form, including reasons for any gaps in employment.

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Interview Stage

All candidates are required to complete and hand in a Disclosure and Barring Service (DBS) form prior to interview. Identity is checked at this stage and Right to Work in the UK documentation.

In addition to assessing the applicant’s suitability for the particular post, the interview panel will also ensure that the candidate understands the requirement for a DBS check and will explore:

• The candidate’s attitude towards children and young people

• Gaps in employment history

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Confirmation of offer
Verbal confirmation regarding the outcome of the interview will be communicated within 48 hours of interview and should the interview fall on a Friday, notification will be within 72 hours.

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Confirmation will be made in writing to the successful candidate within three working days. The following will take place:

• DBS Barred List checks (subject to role) (formerly known as CRB and List 99 checks)

• DBS application form sent to DBS

• References requested from the successful candidate’s referees

All job offers will be conditional subject to obtaining two satisfactory references, a satisfactory DBS clearance , medical clearance, qualifications check, right to work check and a three, six, nine or twelve month probationary period depending upon whether it is a business support or lecturing position.

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6.2 Where the candidate is found to:

• be barred from working with children or adults

• have provided false information, on or in support of, his or her application or

• there are serious concerns about an applicant’s suitability to work with children, young people or vulnerable adults,

• the facts will be reported to the Disclosure and Barring Service.

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6.3 Record Keeping

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TSL will:

• Keep clear, detailed, written records of concerns about children, young people or vulnerable adults (noting the date, event and action taken) even where there is no need to refer the matter to Children’s or Adult’s Social Care (where applicable)

• Ensure all records clearly indicate statements of fact, opinion and second or third hand information

• Ensure all records are kept secure and in locked locations

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6.4 TSL will keep all safeguarding records, including those for vulnerable adults, as advised by the latest guidelines of the Information and Records management Society. Its Records management Toolkit for Schools Version 4 may 2012 outlines a schedule for record keeping in schools as follows. 

• Basic File Description - Child Protection Files, and Pupil Files

• Data Protection Issue - Yes

• Statutory Provisions - Education Act 2002, s175, related guidance, 'Safeguarding Children in Education' Sept 2004

• Retention Period (Operational) - DOB + 25 years

• Action at the end of the administrative life of the record - Shred - Child Protection information must be copied and sent under separate cover to new school/TSL whilst the child is still under 18 (i.e. the information does not need to be sent to a university for example)

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7.0 Levels of Need Framework and Liaison with other Agencies

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7.1 In order to effectively contribute to the Levels of Need Framework, TSL will actively participate in and contribute to the development of a common assessment of the needs of a child/young person/family.

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7.2 TSL will work to develop effective links with other services and agencies and co-operate as required with their enquiries regarding child and vulnerable adult protection matters. This includes attendance at case conferences, core groups, strategy meetings, review conferences and the submission of written reports where required.

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8.0 Monitoring

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8.1 A formal report will be submitted to the Executive Team of Directors on a termly basis detailing the number of interventions and, if appropriate, outcomes of interventions. The report will be limited in its content to ensure the protection of those involved.

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8.2 As a minimum, a summary report will be submitted to Executive Team of Directors on an annual basis and will provide:

• an overview of the interventions for the previous year

• a summary of staff development activities and attendance at events

• a summary of activities which promote safeguarding themes to learners and raise their awareness

• key safeguarding-related developments for the previous year

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9.0 Procedures

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9.1 Dealing with a Child or Vulnerable Adult Protection Issue

All staff must be vigilant in matters relating to safeguarding learners. Staff may find themselves having a suspicion about a learner’s safety or may have to deal with an actual disclosure.

For the purposes of these procedures, a suspicion is considered to be based on serious concerns about an individual’s well-being. This might include changes in an individual’s behaviour (including becoming withdrawn, displaying extremes of emotion, inappropriate behaviour and language) and appearance (including bruising, marks, weight loss, generally looking unkempt).

A disclosure would be a situation where you are presented with an allegation or information which gives you reason to believe that an individual is or is likely to be at risk of significant harm.

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TSL has identified key personnel who will provide guidance.

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9.2 Designated Safeguarding Officers

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Roles:

 

To provide clear, concise and accurate advice to staff with safeguarding concerns.
To deal with safeguarding issues and concerns in line with procedures:

1. Vicky Deakin as Lead Safeguarding Officer

2. Sam Lowe as Deputy Safeguarding Officer

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The Designated Safeguarding Lead is responsible for safeguarding and child protection at Training Strategies Ltd. The key role of the Designated Safeguarding Lead is to:

• manage referrals from school staff or any others from outside the school;

• work with external agencies and professionals on matter of safety and safeguarding;

• undertake training;

• raise awareness of safeguarding and child protection amongst the staff and parents

 

Staff who have a safeguarding concern should contact a Designated Safeguarding Officer. The staff member will be given advice about safeguarding relating to the case and guidance on how to accurately and factually record the allegation or suspicion.

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Training

The key training elements are:

• Induction Training - Mandatory

• DSLs - attend training every two years; and in addition to formal training, their knowledge and skills should be refreshed at regular intervals, at least annually.

• All other staff - will receive regular safeguarding and child protection updates as required, but at least annually, to provide them with relevant skills and knowledge to safeguard children effectively.

Safer Recruitment training is available to all relevant staff and senior managers whoa re involved in the recruitment process.

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9.3 Dealing with Allegations made about a Member of Staff

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Allegations against a member of staff must be taken seriously.

Any allegation against a member of staff must be reported directly to the Managing Director immediately and must not be discussed with any other member of staff or person outside TSL. In the Managing Director’s absence, contact can be made with any other member of the SLT. Please see Appendix 4 which provides full guidance on the procedures to follow.

Where an allegation is unfounded or is a matter for disciplinary action, then TSL's own procedures will be followed.

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9.4 Dealing with other Safeguarding Issues

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In the first instance, any other safeguarding concerns should be discussed
with your line manager.

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If you require any further information or need to get in touch, please contact the safeguarding officers on

safeguarding@trainingstrategies.co.uk