Safeguarding and Prevent This policy should be read in conjunction with the College’s: Public Interest Disclosure (Whistleblowing) Policy and Prevent Strategy 1. Purpose - Introduction, Definitions and Responsibilities This Policy is focussed on recognising the roles that College staff and students have to play in safeguarding the welfare of young people and vulnerable adults. It further focusses upon protection from abuse and neglect. The procedures outlined below should be followed in the circumstances defined in this policy. The policy also links to the Prevent Strategy and how the College will respond to any Prevent issues and or concerns. Definition of The term ‘safeguarding’ describes the broader preventative and precautionary approach to Safeguarding 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 vulnerable adults. 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 Prevent The Prevent strategy has been re-focused following a review. The strategy now contains three objectives: to respond to the ideological challenge of terrorism and the threat from those who promote it; to prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support; and to work with sectors and institutions where there are risks of radicalization that we need to address. Regulated Activity Regulated activity relating to children The definition of regulated activity (Protection of Freedoms Act 2012) relating to children comprises only: (i) Unsupervised activities: teach, train, instruct, care for or supervise children, or provide advice/guidance on well-being, or drive a vehicle only for children; (ii) Work for a limited range of establishments (‘specified places’), with opportunity for contact: for example, schools, children’s homes, childcare premises. Not work by supervised volunteers; Work under (i) or (ii) is regulated activity only if done regularly. We are providing statutory Safeguarding /Prevent Policy P104 Last review date April 2016 Status Live Next review date April 2017 Post-holder responsible: Director of HR Last EqIA date April 2016 Approval required from: Directorate / HR Committee guidance about supervision of activity which would be regulated activity if unsupervised. (iii) Relevant personal care, for example washing or dressing; or health care by or supervised by a professional; Regulated Activity for adults The definition of Regulated Activity for adults (Protection of Freedoms Act 2012) defines the activities provided to any adult as those which, if any adult requires them, will mean that the adult will be considered vulnerable at that particular time. An adult is a person aged 18 years or over Adults are no longer labelled as ‘vulnerable’ because of the setting in which the activity is received, nor because of the personal characteristics or circumstances of the adult being provided for by the activities. There are six categories (described in detail in Schedule 4 of the Safeguarding Vulnerable Groups Act 2006) within the definition of Regulated Activity (Protection of Freedoms Act 2012): 1. Providing healthcare – provision by a healthcare professional or under the direction or supervision of one. This may include psychotherapy and counselling, first aid administered on behalf of an organisation established for the purposes of providing first aid. This does not include workplace first aiders, members of peer support groups or life coaching. 2. Providing personal care – physical assistance with eating or drinking, going to the toilet, washing or bathing, dressing, oral care or care of skin, nails or hair (but not where this involves only cutting hair) because of the adult’s age, illness or disability. This also includes anyone who trains, instructs or provides advice on the provision of personal care or those who prompt and then supervise an adult to do one of the above. 3. Providing social work. 4. Assisting with general household matters – assistance with managing a person’s cash, paying a person’s bills or shopping on their behalf because of the adult’s age, illness or disability. 5. Assisting in the conduct of people’s own affairs. 6. Conveying adults to, from, or between places, where they receive healthcare, relevant personal care or social work because of their age, illness or disability. This includes hospital porters, patient transport service drivers and assistants, ambulance technicians and emergency care assistants but does not include taxi or licensed private hire drivers. The frequency test has been removed and an individual only need to engage in a defined activity once to be carrying out Regulated Activity and the definition removes the word ‘vulnerable’ when describing Regulated Activity relating to adults. Certain establishments are specified as regulated activity establishments. The following is Page 2 of 29 Establishment the list of specified establishments as defined by the Protection of Freedoms Act 2012: For Regulated an educational institution which is exclusively or mainly for the provision of full-time Activity education to children Definition of child or young person Definition of a vulnerable adult Responsibilities pupil referral units or short-stay schools providing education for children or compulsory school age who because of illness, exclusion or other reasons cannot attend a school academies which do not fall within the definition of a school nurseries exclusively or mainly providing full-time or part-time education for children who have not reached compulsory school age children’s detention centres children's homes providing care and accommodation wholly or mainly for children children's centres managed by or on behalf of, or under arrangements made with an English local authority securing early childhood services for their area childcare premises An individual is considered to be a child or young person up to their 18th birthday. A person is described as an adult from the age of 18. Under the Protections of Freedom Act 2012, the definition of a vulnerable adult was removed and replaced with guidance which relates to the activity as opposed to labelling the person. Please see above in regards to regulated activity. All staff and volunteers are particularly well placed to observe outward signs of abuse, changes in behaviour and failure to develop because they have daily contact with children, young people and vulnerable adults. They should be aware of the important role the College has in the early recognition of the signs and symptoms of abuse or neglect and the appropriate referral process. For details of the Senior Designated Professional see section four below. Page 3 of 29 Related policies and statements 2. Health and Safety Policy Student Discipline Policy Dealing with Harassment and Bullying Complaints Policy Disciplinary, Capability and Grievance Policy Harassment and Bullying Disclosure and Barring Service Policy (DBS) Recruitment and Selection Policy Code of Conduct Policy Public Interest Disclosure Policy Social Networking Policy Computer Policy Prevent Strategy Scope - Objectives of the Safeguarding / Prevent Policy Easton and Otley College aim to: 2.1 Establish and maintain an environment where young people and vulnerable adults feel secure, are encouraged to talk, and are listened to when they have a worry or concern. Ensure young people and vulnerable adults know that there are adults in the College whom they can approach if they are concerned. Students are made aware campuses are open and not all adults on site will have been through the College’s checks and training procedures. This point is reinforced at induction and tutorials. 2.2 Include opportunities in the tutorial programme for young people and vulnerable adults to develop the skills they need to recognise and stay safe from abuse. A key priority within this policy is to ensure we develop all individual’s personal level of awareness about how to maintain their own safety; how to recognise inappropriate behaviour or circumstances; and how to report their concerns. Encouraging students, staff, volunteers and visitors to take responsibility is very important. 2.3 Inform staff and others working at the College, parents, volunteers, employers, partners, stakeholders and governors about the College’s responsibilities for safeguarding young people and vulnerable adults. 2.4 Enable everyone to have a clear understanding of how these responsibilities should be carried out. 2.5 In addition to the Safeguarding of students and staff as described within the policy. The policy will also recognise, respond, report, record and refer and Prevent disclosures or concerns captured by the Safeguarding and Prevent procedure. As with any Safeguarding concern any Prevent concerns will be captured within the weekly safeguarding summary and discussed at the Directors operational group on a weekly basis. This process will drive a group response and responsibility. Page 4 of 29 Prevent Strategy1 The College will hold British values at the heart of everything they strive to achieve. These are defined as: 1. Democracy 2. The rule of law 3. Individual liberty 4. Mutual respect and tolerance for those with different faiths and belief The College will train all staff and students in relation to the Prevent agenda. In addition the College has a Prevent risk assessment that considers areas of College life such as hosting external speakers, letting out buildings and monitoring the use of IT. Such will be regularly monitored. Prevent will be a standard agenda item on the weekly Safeguarding meeting. 3. Statutory Framework In order to protect young people and vulnerable adults from harm the College will act in accordance with the following legislation and guidance: Rehabilitation of Offenders Act 1974 Law Education Act (2002), section 175 Sexual Offences Act 2003 The Children Acts 1989 and 2004 Safeguarding Vulnerable Groups Act 2006 Safeguarding Children and Safer Recruitment in Education (2007) Protection of Freedoms Act (2012) HM Government 'Working Together to Safeguard Children’ (2013) Keeping Children Safe in Education (2014) The College has appropriate procedures in place for responding to situations in which they believe that a young person or vulnerable adult has been abused or are at risk of abuse, which also cover circumstances in which a member of staff, volunteer or visitor is accused of, or suspected of, abuse. Abuse in relation to ‘children’ is categorised into four areas: Physical abuse Emotional abuse Sexual abuse Neglect Abuse in relation to ‘adults’ is categorised into seven areas: Physical abuse Sexual abuse Psychological and emotional abuse Prevent is part of the Government’s counter-terrorism strategy, CONTEST. Its aim is to stop people becoming terrorists or supporting terrorism. Further details available https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/97976/prevent-strategy-review.pdf 1 1 Page 5 of 29 Financial abuse Neglect & acts of omissions Discriminatory Institutional abuse neglect and poor practice The College complies with the following responsibilities: Staff are trained to recognise signs of abuse and know to whom they should report any concerns or suspicions Procedures (of which all staff are aware) are in place 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 Senior Designated Professional (SDP) has responsibility for coordinating action within the College and for liaising with other agencies Staff with designated responsibility for Safeguarding receives appropriate training. This policy is designed to ensure the following guidance is met in full: DfES guidance Safeguarding Children and Safer Recruitment in Education (2007) states that “All parents need to understand that schools and FE Colleges have a duty to safeguard and promote the welfare of children who are their pupils or students, that this responsibility necessitates a child protection policy and procedures, and that a school or FE College may need to share information and work in partnership with other agencies when there are concerns about a child’s welfare.” 4. The Designated Professional and the Governing Body The Senior Designated Professional for Safeguarding and Prevent in this College is: The Director of Curriculum Student Services and Support Where the Senior Designated Professional is not available the Deputy Senior Designated Professionals (DSDP) listed below will act in his / her absence. The DSDP for Safeguarding are: Student Services Managers. It is the role of the Senior Designated Professional (SDP) for Safeguarding and Prevent to: Promote positive safeguarding and prevent procedures and practice To promote and ensure staff and students have an awareness of British values Receive information and offer advice about safeguarding and prevent concerns, maintain secure records and take appropriate action Be familiar with national and local safeguarding and prevent guidance and referral procedures Assess the development needs of staff and co-ordinate training Keep all staff and volunteers informed of good practice and development Monitor safeguarding and prevent cases in the organisation Report all Safeguarding and Prevent issues to the Senior Leadership Team Report all Safeguarding and Prevent issues relating to the Principal to the Chair of Governors Page 6 of 29 Provide a Safeguarding and Prevent report to the Corporation The more specific duties are: Ensure that they receive refresher training at appropriate intervals to keep their knowledge and skills up to date Ensure that all staff who work with young people and vulnerable adults undertake appropriate training to equip them to carry out their responsibilities for child protection / protection of vulnerable adults effectively and that this is kept up to date by refresher training at three yearly intervals Ensure that newly appointed staff receive Safeguarding and Prevent training as part of the induction process Ensure that temporary staff and volunteers are made aware of the College’s arrangements for child protection / protection of vulnerable adults Ensure that the College operates within the legislative framework and recommended guidance Ensure that all staff and volunteers are aware of safeguarding and child protection / protection of vulnerable adults procedures Ensure that appropriate training and support is provided to all staff Ensure that the Senior Leadership Team (SLT) is kept fully informed of any concerns Develop effective working relationships with other agencies and services Decide whether to take further action about specific concerns (e.g. refer to Children, Schools and Families or Adult Care Services) Liaise with the Local Authority Designated Officer (LADO) over suspected cases of child abuse Ensure that accurate records relating to individual children are kept separate from the academic file in a secure place and marked 'Strictly Confidential' Submit reports to, and ensure the College’s attendance at child protection and vulnerable adult conferences Ensure that the College effectively monitors young people and vulnerable adults about whom there are concerns Provide guidance to students, parents, staff, governors, others working at the College and partners, about obtaining suitable support. It is the role of the College Governing Body to check that: The College has a safeguarding and prevent policy and procedures in place that are in accordance with local authority guidance and locally agreed inter-agency procedures, that the policy is made available on request and is reviewed annually The College operates safe recruitment procedures and makes sure that all appropriate checks are carried out on staff and volunteers who work with children and vulnerable adults The College has procedures for dealing with allegations of abuse against staff and volunteers that comply with guidance from the local authority and locally agreed interagency procedures A member of the College’s Director Team is designated to take lead responsibility for child protection and Prevent. Staff undertake appropriate safeguarding and Prevent training The College remedies, without delay, any deficiencies or weaknesses regarding safeguarding arrangements Page 7 of 29 5. The Chair of Governors is aware of their responsibilities for liaising with the Local Authority and / or partner agencies in the event of allegations of abuse being made against the Principal Training is provided for all Governors on a regular basis Where services or activities are provided on the College premises by another body, the body concerned have appropriate policies and procedures in place in regard to safeguarding and liaises with the College on these matters where appropriate Staff Training Mandatory training is given for all staff to raise awareness of Safeguarding and the Prevent agenda. It is necessary for all staff to take refresher training for Safeguarding and Prevent every three years. Introduction to Safeguarding and Prevent training will be followed up, where appropriate, with appropriate one-to-one sessions and specific work with departments relating to their relevant issues. In addition every interview panel for recruitment to staff vacancies will contain at least one member of staff trained in Safer Recruitment practices. 6. 6.1 College Procedures General The College takes its duty of pastoral care seriously and will be proactive in seeking to prevent young persons and vulnerable adults 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. The SDP and DSDP will have training in this field and act as a source of advice and support to other College staff. By informing young people and vulnerable adults of their right to be free from harm and encouraging them to talk to College staff if they have any concerns. Through the tutorial programme and support, at an appropriate level, to promote selfesteem, social inclusion and address the issue of safeguarding children, young people and vulnerable in the wider context. By ensuring that the residential areas of the College are kept secure at all times and access is restricted to residential students, designated staff and approved visitors only. Schools are required to send any child protection data to College on their commencement / transfer to one of our courses. The SDP will liaise with the local schools in the summer break as a timely reminder of this data transfer. All staff, volunteers and others working with College students should be aware that the main categories of abuse are: Physical abuse Emotional abuse Sexual abuse Neglect Also, bullying financial abuse and domestic violence Page 8 of 29 All staff and volunteers should be concerned about a young person / vulnerable adult if they present with indicators of possible significant harm. There is a safeguarding and prevent referral flowchart attached at Appendix C. The following advice should be noted: 6.2 Local Authority and Police must lead any investigation in to any allegation regarding safeguarding Child protection and safeguarding referrals should be made to the MASH and followed up in writing, preferably on an NSCB1 within 24 hours. o Telephone 0344 800 8020 o Referral forms sent to:o Email: [email protected] o Fax: 01603 762445 o Post: The MASH Team Manager, Floor 5, Vantage House, Fisher’s Lane, Norwich NR2 1ET For specialist Police advice you can contact the Duty Detective Sergeant within the MASH. o Email : [email protected] o Call : Direct dial 01603 27(6151) Professional consultations can be sought via the MASH on 0344 8008020 Identifying and Reporting Concerns, Abuse and other Safeguarding and Prevent Issues General concerns should be referred to ones direct Line Manager. However, all reports of abuse should be referred using the procedure detailed below. All staff, others working at the College and volunteers should be concerned about a young person or vulnerable adult if he or she displays signs of abuse and or 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 they have been abused in some way, the member of staff, volunteer or other person working at the College 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 for a referral to be made Reassure him or her that what has happened is not his or her fault Stress that it was the right thing to tell Listen, rather than ask direct questions Page 9 of 29 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 Senior Designated Professional without delay 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; please see Appendix D for a sample concern form. The SDP will carry out a risk assessment to determine what action to take and will decide whether the concerns should be referred to Children’s Services / Local Authority Designated Officer (LADO). The SDP will seek support and guidance from the Local Authority Designated Officer (LADO) as necessary. If it is decided to make a referral to the LADO / Children’s 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 child about whom the College 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. 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 Principal 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 Senior Designated Professional will liaise with the CPO (Child Protection Officer) from the relevant school, ensuring that the student is informed of this process. 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 the College / volunteer should therefore consider seeking support for themselves and discuss this with the Senior Designated Professional or the HR Director. 6.3 Allegations against a member of staff Where an allegation is made against a member of staff, volunteer or someone working with College students identifying that they have: Behaved in a way that has, or may have harmed a young person or vulnerable adult Possibly committed a criminal offence against / related to a young person or vulnerable adult Behaved toward a young person or vulnerable adult in a way which indicates they are unsuitable to work with children or vulnerable adults The person learning of the allegation should record the nature of the allegation and any other relevant information and immediately report it to the HR Director, or to the SDP or the DSDP. The SDP or Deputy will immediately inform the HR Director. Page 10 of 29 The LADO will be informed within 24 hours of the allegation being made. A written record will be submitted to the LADO within a further 24 hours. Norfolk LADO can be contacted on (01603) 223473, Suffolk LADO can be contacted on (01473) 263112. The HR Director will, in consultation with the appropriate College managers / senior manager, decide whether to invoke the College Disciplinary Procedure which may include suspension. The SDP and the HR Director will assess whether it is necessary to refer to the DBS (Disclosure and Barring Service) and Children’s’ Services, in consultation with the Local Authority Designated Officer. 6.4 Work Placement and Work Experience Employers and training organisations will be asked to cooperate with the College 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 2007, DCSF” the College 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 students’ welfare by endorsing an agreed statement of principles. It is important to note that ultimate responsibility still sits with the College as the educational provider. Appendix F provides further guidance in relation to work experience placements for students. 6.5 Apprentices and Work-based Learning Apprentices are considered as having employed status from day one. The College ensures that, where an Apprentice is placed with an employer, the employer understands their responsibilities for safeguarding. The College will undertake a health and safety risk assessment and ensure that all employers have equality and diversity and health and safety policies in place. 6.6 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 Page 11 of 29 Being withdrawn from College 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 SDP the Deputy. 7. College Visitors The College ensures that visitors are booked in at reception areas, collected on arrival, and aware of College safeguarding and health and safety requirements. On arrival visitors are given a temporary visit pass and Visitors Information leaflet covering areas such as Health and Safety, No Smoking, Fire Evacuation and First Aid. 8. Confidentiality Child Protection raises issues of confidentiality that must be clearly understood by all staff / volunteers in Colleges, as follows: All staff have a responsibility to share relevant information about the protection of young people with other professionals, particularly the investigative agencies (Children’s Services and the Police) If a student confides in a member of staff / person working at the College / 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. 9. College Publications The College will include details of its Safeguarding procedure and Prevent in all future key College documents and materials. This will include: Full-time prospectus Part-time prospectus All course listing promotional documents College website Information sheets for providers Marketing Strategy Recruitment literature for staff vacancies Staff induction materials Referring to safeguarding duties in all job descriptions Student Induction Material This policy will be regularly reviewed by the Safeguarding Committee which meets each term. Page 12 of 29 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 the College/volunteers DBS referrals and 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 Prevent agenda – prevention of radicalisation Page 13 of 29 Appendix B Indicators of possible significant harm 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 College 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 Page 14 of 29 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 Stops enjoying previously liked activities Be reluctant to undress for sport Become fearful of, or refuse to see, certain adults for no apparent reason; shows dislike of a particular tutor, support worker, carer, relative or other adult Draws 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 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. Page 15 of 29 Neurotic behaviour (e.g. rocking, hair twisting, thumb sucking) Chronic running away Scavenging for food or clothes In addition to all the above signs a young person 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. Page 16 of 29 Appendix C – Safeguarding and Prevent Referral Flowchart Member of Staff or Student has concerns about Safeguarding and Prevent Issue Concerned person makes a written record of relevant information / incident on a Cause for Concern form (found on Safeguarding and Prevent Portal on SharePoint) No Yes Concerned person reports matter to Senior Designated Professional (SDP) or Deputy SDP Does the incident/ information involve an allegation against a member of staff? Concerned person reports matter to Human Resources Director Human Resources Director will refer to appropriate manager/ senior managers/LADO team within 24 hours SDP or DSDP takes steps considered necessary to ensure the safety of the young person or vulnerable adult in question and any other child or vulnerable adult that may be at risk Is it a straight forward referral? No SDP or DSDP discusses matter with MASH for guidance No Monitoring put in place with relevant staff. Re-refer if further issues arise Yes Yes SDP or DSDP contacts MASH to make a referral SDP or DSDP makes accurate records and informs Principal and relevant staff involved with student Support team created as appropriate for student A summary monitoring report will be sent on an annual basis to SLT, and Corporation Governors N.B. Local Authority and Police must lead any investigation in to any allegation regarding safeguarding Page 17 of 29 Appendix D - Recording Form for Safeguarding and Prevent Concerns Staff, volunteers and regular visitors are required to complete this form and pass it to the Director Curriculum – Student Services and Support if they have a safeguarding and prevent concern about a child in our College. Full name of student Date of Birth Tutor/Form group Your name College and position in Nature of concern/disclosure Please include where you were when the student made a disclosure, what you saw, who else was there, what did the child say or do and what you said. Was there an injury? Describe the injury: Yes / No Did you see it? Yes / No Have you filled in a body plan to show where the injury is and its approximate size? (please see body plans below) Yes / No Was anyone else with you? Who? Has this happened before? Did you report the previous incident? Who are you passing this information to? Name: Position: Your signature: Date: Page 18 of 29 Date: Time: Action taken by SDP □ Referred to…? LADO Police Occupational Health Counsellor Social Services External agency Parents informed? Yes / No (If No, state reason) Feedback given to…? Pastoral team Tutor Student Person who recorded disclosure Full name: SDP Signature: Page 19 of 29 Parents Other Body Map Page 20 of 29 Older Child Page 21 of 29 Appendix E Please refer to Policy P104 Human Resources Disclosure Barring Service2 (DBS) policy Safer Recruitment and Employee Security (DBS) procedure 1 2 Policy statement 1.1 Easton and Otley College has a duty to provide a secure and safe environment in which students and staff can obtain the best possible benefit from studying or working at the College. This procedure complies with safeguarding guidance and legislation. 1.2 Part of the College’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 well being of students and staff. This procedure will ensure that appropriate checks are made on College governors, employees and those carrying out services for the College and volunteers, as required. Safer Recruitment and the Disclosure Barring Service Duty to Refer From 12 October 2009, the College complied with the duty to refer any employee or volunteer who poses a risk to young people or vulnerable adults. If the College 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 College designated person will be responsible for referring this information to the Disclosure Barring Service (DBS). Compliance with DBS Scheme and Safer Recruitment All staff, whatever their job role, have an enhanced DBS disclosure as all staff are employed in a ‘Regulated (specified) Establishment and have the potential to come into contact with young people and vulnerable adults. The College will pay for all staff to have an enhanced disclosure check. The College has a central single record which records details of staff identity, DBS / CRB disclosures, qualifications, overseas DBS / CRB checks, Barred List checks and right to work in the UK details. The HR Director is responsible for the maintenance of this record. The record also includes details of governors, contractors, consultants, volunteers and onsite service providers. References are taken for all employees to check identity and ask specific questions about safeguarding. The College makes random checks to confirm the status of the originator of written references. 2 With effect from 1st December 2012 the Criminal Record Bureau will be known as the Disclosure and Barring Service Page 22 of 29 The College HR recruitment and selection policy includes details of the safer recruitment processes including, face to face assessments for all employees, interview questions and application processes Contractors, Consultants Where a sub contracted training provider is used to deliver any aspect of training, the College checks that they have robust safeguarding procedures in place. That staff have undertaken appropriate checks and are trained in safeguarding. When third party locations are used, premises are risk assessed with appropriately qualified staff undertaking risk assessments. This information will be held by the department working with the partner/ contractor, with a copy held in Human Resources to be held alongside the Central List. Other contractors whose staff are engaged in regulated activity or who work on a regular basis in College premises or with College students will provide evidence of appropriate checks, vetting and training. Volunteers Often individuals approach the College to indicate they wish to gain experience in an area: this may be teaching experience or assisting in a specific specialism such as Horticulture. Volunteer helpers are not employees of the College and do not receive any form of payment for the services they provide. The College 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 line manager prior to the commencement of the volunteering activities. This form must be completed and sent to Human Resources even if the period of volunteering is only for a few hours. Volunteers cannot to be used as substitute staff and should not have sole responsibility for a student or group of students at any time. Volunteer helpers must be registered with Human Resources prior to undertaking any work, and Human Resources must be notified when a volunteer ceases undertaking work at or for the College. Volunteers will not commence work or other activities at the College without first meeting with HR, who will check their identity and qualifications and ensure Barred List and DBS checks are undertaken. The Employee DBS Policy will apply in the same way as for all other employees at the College. 3 Disclosure and Barring Service Disclosure (previously known as the Criminal Records Bureau Disclosure) 3.1 The Disclosure and Barring Service (DBS) (previously known as CRB) 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 vulnerable adults. Page 23 of 29 4 3.2 Where a DBS check is required the individual will be asked to complete an online Application Form, and to produce evidence of identity to a nominated member of the Human Resources Department. 3.3 The DBS check may take several days to complete, and weeks in exceptional circumstances. When completed the DBS will send the disclosure to the individual who has applied. A copy will not be sent to the employer, the HR team will, however, be able to track process via the on-line tracking process. The disclosure will give details of criminal record or other related matter which has been recorded. Recruitment of New Employees It will be a condition of all offers of employment made by the College that a satisfactory enhanced disclosure is obtained. All applicants for posts at the College 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 an offer is made. The College will require a DBS enhanced disclosure for all new academic staff, business support staff, volunteers and casual staff due to the nature of the College’s business. 5 Procedure for DBS Checks: New Appointments The DBS disclosure will be completed electronically. The prospective employee will be required to complete the electronic application and provide evidence of identity in accordance with DBS requirements. Once the disclosure has been obtained from the DBS the Human Resources Director will consider if the disclosure is satisfactory to enable the prospective employee to commence their employment with the College. If the individual has already commenced employment and there are issues raised in the disclosure the Human Resources Director will invite the individual to meet to discuss the disclosure form and its content. 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 the honesty and openness with which the matter was originally discussed with the College Page 24 of 29 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 Human Resources Director will write to him/her withdrawing the offer and explaining the reasons. Where the individual has commenced employment pending the DBScheck, Human Resources Director and SMT Manager will advise the Principal if dismissal is recommended. There will be an opportunity for the individual to write to the Principal setting out his/her reasons why he/she believes he/she should not be dismissed. 6 Procedure for DBS Checks: Existing Employees Following guidance issued by OFSTED in November 2012, the College took the strategic decision to cease re-checking existing employees unless a specific concern or notice of a change in circumstances was received. Where a re-check reveals matters of interest are disclosed the College will follow a risk assessment process and take appropriate action which may include action up to dismissal of employment. 7 Procedure for DBS Checks: College Governors 7.1 All College governors are required to have a satisfactory enhanced disclosure check. 7.2 Governors will be required to complete the electronic application and provide evidence of identity in accordance with DBS requirements. 7.3 Once the disclosure has been obtained from the DBS the result will be considered in accordance with 5 above. If there are issues raised in the disclosure the Human Resources Director will inform the Principal and Clerk to the Corporation, who will invite the individual to meet to discuss the disclosure form and its content. 7.4 The Principal or Clerk to the Corporation 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 a College governor: 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 the honesty and openness with which the matter was originally discussed with the College. Page 25 of 29 8 Steps to safer recruitment: The College recruitment process ensures safeguarding is at the forefront of the recruitment process. The following statement appears on the application form: Disclosure of Criminal Convictions and Police Cautions, Warnings and Reprimands including spent times Unless documentation provided in this pack states to the contrary, this post is exempt from the provisions of section 4(b) of the rehabilitation of offenders act by virtue of the rehabilitation 1974 (exemptions) order 1975 because of the nature of work involved. The amendments to the Exceptions Order 1975 (2013) provide that certain spent convictions and cautions are 'protected' and are not subject to disclosure to employers, and cannot be taken into account. Guidance and criteria on the filtering of these cautions and convictions can be found on the Disclosure and Barring Service website. It therefore follows that you are not entitled to withhold relevant information and in the event of employment, any failure to disclose non-protected convictions could result in dismissal or disciplinary action. We will be required to obtain a Disclosure Barring Service Check for individuals appointed to certain posts. Please refer to the attached “Guidance for applicants on disclosure of criminal record information”. Disclosure and Barring Service checks are completed for all employees and volunteers. In addition the College ensures that any gaps in the employment history are explored in full. Ideally the College seeks a minimum of 10 years history. The College seeks two references from all applicants, the following statement is included on the application form: Please provide details of two people who will each provide a work-related or academic reference. One of these referees must be your current or most recent employer. If you do not have a current or recent employer, please provide details of your lecturer/course tutor/unpaid work employer etc. To validate the references the HR office will, on a random basis, make a telephone call to check the validity of the author and the content. If any concerns are raised at any point within the recruitment process such will be addressed on an individual basis. Page 26 of 29 Appendix F Work Experience Placements There is no requirement to DBS check all staff who may come into contact with a student on a placement. Only a member of staff with day to day responsibility for the student or as part of their job description – this could be the manager, a supervisor/mentoring employee – should be required to have a DBS check. In the vast majority of placements – as the employer/employees involved will not have regular unsupervised access to young people at work – there is no need for DBS checks to take place. Around 550,000 work experience placements take place annually in Norfolk alone, and it is estimated that DBS checks take place for just one per cent of these. However, DBS checks must be considered in all the following cases: 1) Students identified by the College as vulnerable for educational, medical, behavioural or home circumstance reasons, including those who have special educational needs 2) Students on placements lasting more than 15 days over an extended period, especially where these involve: regular lone working with an employer over long periods (rule of thumb would suggest anything over half a day at a time) placements located in particularly isolated environments with 1:1 working placements involving a high degree of travelling on a 1:1 basis 3) Any work placements which include a residential element. The fact that a particular placement falls into one of the above categories does not necessarily mean that a DBS check will be required. Such a decision will depend on an assessment of the overall potential risks posed to a young person and will take into account any systems in place to minimise these risks – including the Health & Safety visit report and any Risk Assessments required by the nature of the placement If any of the above cases apply, additional safeguards should be put in place. These include: College staff or other partners who arrange, vet or monitor the work placements should have training in child protection Employers, supervisors or training providers hosting students should be asked to endorse a child protection / safeguarding policy or statement of principles College and local authority policies and procedures should define what actions need to be taken by whom and when if any child protection issues are raised, before, during or after the placement Students should also be given clear advice and a point of contact in the College in case of any problems Page 27 of 29 Appendix G What is abuse and neglect? A form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults, or another child or children. Physical abuse A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. Emotional abuse The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the illtreatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone. Sexual abuse Involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or nonpenetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. Neglect The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. Page 28 of 29 It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs. Safeguarding and promoting the welfare of children Defined for the purposes of this guidance as: protecting children from maltreatment; preventing impairment of children's health or development; ensuring that children are growing up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best life chances. 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. Taken from Working Together 2013. Page 29 of 29
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