Safeguarding and Child Protection Policy

 

Committee and Date Approved 01.09.2022
Category Statutory
Next Review Date Annually unless change in legislation – September 2023
Policy Availability Website
Officer Responsible Designated Safeguarding Officer – Sean Gardner

 

 

 

 

Introduction

This document is the Safeguarding and Child Protection Policy for Ask OLA to provide access to expert and on-demand online learning assistants (OLAs) and mental health professionals for students in afterschool hours and weekends. To facilitate a ‘high-dosage’ support systems so students receive the support they need, when they need it and improve/accelerate learning outcomes.

All communication between OLAs will be via the proprietary AskOla.io platform. This platform is a live chat facility with an enriched whiteboard. There will be no audio/video element to the programme.

 

To minimise any safeguarding risk, all OLAs will be fully anonymised. For example, a student will see that they are communicating with OLA (this will be represented via a cartoon-like character). All students will only have their first name displayed (so that OLAs may provide a personalised service).

 

How it works

This policy applies to all staff working for Ask OLA. It will be reviewed annually and is supported by Safeguarding Consultant Ella Savell-Boss Ltd.

 

Safeguarding and promoting the welfare of children is defined by the Department for Education as:

 

 

This Safeguarding and Child Protection Policy forms one part of the safeguarding responsibilities and should be read in conjunction with other key policies and information.

Ask OLA has a culture of vigilance and are committed to safeguarding children and young people, and we expect everyone who works in Ask Ola to share this commitment.

All adults take all welfare concerns seriously and encourage children and young people to talk to us about anything that worries them.

We will always act in the best interest of the child.

 

Terminology

 

Safeguarding and promoting the welfare of children refers to the process of protecting children from maltreatment, preventing the impairment of 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.

 

Child protection refers to the processes undertaken to protect children who have been identified as suffering or being at risk of suffering significant harm.

 

Staff refers to all those working for or on behalf of Ask OLA, full time or part time, temporary or permanent, in either a paid or voluntary capacity.

 

Child includes everyone under the age of 18.

 

Parent refers to all of the following: birth parents, stepparents, foster carers, and adoptive parents.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Purpose of Safeguarding Policy

 

3.Purpose of a Safeguarding and Child Protection Policy To inform all members of staff, parents, volunteers, and governors about the school’s responsibilities for safeguarding children and their responsibilities therein
Safeguarding Children’s Safeguarding Partnership (SCSP) We are aware of the procedures agreed by the individual Safeguarding Children’s Safeguarding Partnership (SCSP)
Working with School Staff & Volunteers Staff are well placed to observe the outward signs of abuse. The school will therefore:

Ensure that all staff and volunteers receive safeguarding children training, to help identify concerns.

Ensure that all staff are aware of this policy and those relating to the safeguarding of children.

Principles when working with pupils and their schools This organisation recognises its responsibility to protect and safeguard the welfare of the children and young people entrusted to its care by establishing a safe and trusting environment in which children can learn and develop. The policy applies to all children between the ages of 0-18 whose care and education comes within the remit of this school/college. (For some special schools this age range goes beyond 18).

 

The staff are committed to establishing and maintaining an environment where children feel secure, are encouraged to talk, and are listened to. We will ensure that children know there are adults in the school who they can approach if they are worried and that the principles of confidentiality are made clear to children and young people. Children need to be supported in approaching any member of staff they feel most comfortable in speaking with. The organisation promotes a positive, supportive, and secure ethos, giving pupils a sense of being valued.

 

To ensure children know that there are adults in the organisation or their school setting whom they can approach if they are worried.

 

This organistion also recognises its duty to work with other agencies in protecting children from harm and in responding to concerns about possible abuse, including the Police, Child and Adolescent Mental Health Services, Attendance & Prosecution Service, Inclusion Support Service and other agencies/services coming into the organisation to support individual pupils/groups of pupils.

 

To ensure that children who are subject to multi-agency plans are supported by the organisation as defined in that plan.

 

Schools Ask Ola will be working with, will be required to include training on the following areas:

 

To encourage pupils to respect the fundamental British values of democracy, the rule of law, individual liberty and mutual respect, and tolerance of those with different faiths and beliefs. We ensure that partisan political views are not promoted in the teaching of any subject in the school and where political issues are brought to the attention of the pupils, reasonably practicable steps have been taken to offer a balanced presentation of opposing views to pupils.

 

To contribute to children being healthy, safe, enjoying and achieving, making a positive contribution, and achieving economic well-being.

 

The school will ensure that parents have an understanding of the responsibility placed on staff for child protection by setting out its obligations in the school prospectus. The Safeguarding and Child Protection policy is made available to parents on request and published on the school website.

Implementation, Monitoring and Review of the Safeguarding and child protection Policy The DSO will ensure that the Safeguarding and Child Protection policy is put on the agenda of the senior management at least once a year for discussion, monitoring, review, and renewal.

 

The pilot of Ask OLA is within the West Midlands Child Protection Safeguarding Procedures

These child protection and safeguarding procedures are for nine Safeguarding Partnerships in the West Midlands and have been effective from 31st March 2017. http://westmidlands.procedures.org.uk/

 

Background

 

A project proposal was successfully submitted to DfE on behalf of the West Midlands Safeguarding Partnerships to develop regional safeguarding procedures.  It was felt that it would be sensible to move to a more regional approach to multi-agency working around safeguarding, especially in light of the fact that so many partner organisations (including Police, Probation, Health, and many others) span an area that crosses local authority boundaries.

 

 

How to use the manual

 

Use the link to the contents page to access the different sections of the regional procedures – Statutory Child Protection Procedures; Regional Safeguarding Guidance; Local Area Specific Safeguarding Information and Procedures

With respect to the Local Area Specific Safeguarding Information and Procedures please choose from the drop-down list to access the localised content for your respective area.

 

 

Child protection referrals

 

The pilot for Ask OLA is within Sandwell and Dudley Local Authority and in addition to this safeguarding and child protection policy, information is shared with the OLAs.

 

This information is available to all OLA working with a young person in the specific Local Authority they live in and go to school in.  Key contact information shared, includes:

 

LADO Local Authority Designated Officer
Emergency Services Police, Ambulance and Fire Services
MASH Multi-Agency Safeguarding Hub (part of Children’s Services)
DSL Designated Safeguarding Lead for the child’s school
DSO

for AskOla

Designated Safeguarding Officer for AskOla

Sean Gardner

 

 

Legislation and Statutory Guidance

 

This policy is based on the Department for Education’s statutory guidance Keeping Children Safe in Education (2021) and Working Together to Safeguard Children (2018), and the Governance Handbook. We comply with this guidance and the arrangements agreed and published by our 3 local safeguarding partners.

This policy is also based on the following legislation:

Working Together to Safeguard Children (2018) requires all schools / academies to follow the procedures for protecting children from abuse which are defined by the Local Children’s Safeguarding Partnership and have appropriate procedures in place for responding to all concerns of actual or suspected abuse including allegations against members of staff in a position of trust.

 

The best way to safeguard a child is through effective early help and prevention so it is important to carry out effective early help assessment and take on the role of the Lead Professional.

 

Multi-agency Threshold Documents explain early help and expectations more in depth.

“Working Together to Safeguard Children” (2018)

 

https://www.gov.uk/government/publications/working-together-to-safeguard-children–2?utm_source=1a6063c3-b0a1-4d64-8f00-05c6fb7470e2&utm_medium=email&utm_campaign=govuk-notifications&utm_content=immediate

 

Nothing is more important than children’s welfare. Children who need help and protection deserve high quality and effective support as soon as a need is identified.

 

We want a system that responds to the needs and interests of children and families and not the other way around. In such a system, practitioners will be clear about what is required of them individually, and how they need to work together in partnership with others.

 

Whilst it is parents and carers who have primary care for their children, local authorities, working with partner organisations and agencies, have specific duties to safeguard and promote the welfare of all children in their area.

 

The Children Acts of 1989 and 2004 set out specific duties: section 17 of the Children Act 1989 puts a duty on the local authority to provide services to children in need in their area, regardless of where they are found; section 47 of the same Act requires local authorities to undertake enquiries if they believe a child has suffered or is likely to suffer significant harm. The Director of Children’s Services and Lead Member for Children’s Services in local authorities are the key points of professional and political accountability, with responsibility for the effective delivery of these functions.

 

These duties placed on the local authority can only be discharged with the full cooperation of other partners, many of whom have individual duties when carrying out their functions under section 11 of the Children Act 2004 (see chapter 2). Under section 10 of the same Act, the local authority is under a duty to make arrangements to promote cooperation between itself and organisations and agencies to improve the wellbeing of local children (see chapter 1). This co-operation should exist and be effective at all levels of an organisation, from strategic level through to operational delivery.

 

The Children Act 2004, as amended by the Children and Social Work Act 2017, strengthens this already important relationship by placing new duties on key agencies in a local area. Specifically, the police, clinical commissioning groups and the local authority are under a duty to make arrangements to work together, and with other partners locally, to safeguard and promote the welfare of all children in their area.

 

Everyone who comes into contact with children and families has a role to play.

Safeguarding and promoting the welfare of children is defined for the purposes of this guidance as:

 

Keeping Children Safe in Education (2021) places the following statutory duties on all schools:

 

 

Safeguarding and promoting the welfare of children is defined for the purposes of this guidance as:

 

 

What to do if you’re worried a child is being abused 2015

 

Advice for practitioners is non-statutory advice which helps practitioners (everyone who works with children) to identify abuse and neglect and take appropriate action.

 

In the UK, more than 50,000 children are annually subject to a child protection plan. Research suggests that one child a week dies from abuse and one child in six is exposed to violence in the home. The prevalence of neglect continues to be a major concern and online abuse is increasing.  The sexual exploitation of children is a growing problem and disabled children are three times more likely to be abused and neglected.

 

Due to their day-to-day contact with pupils, school staff are uniquely placed to observe changes in children’s behaviour and the outward signs of abuse. Children may also turn to a trusted adult in school when they are in distress or at risk. It is vital that all school staff are alert to the signs of abuse and understand the procedures for reporting their concerns. The school will always act on identified concerns

 

The UK faces a severe and continuing threat from international terrorism. The Government is taking tough security measures to keep people safe but action at a local level is also essential to stop people becoming or supporting terrorists or violent extremists. Local authorities and the Police need to take a lead in ensuring that local partnerships have been clearly tasked with driving delivery of a jointly agreed programme of action.  From 1 July 2015 all schools must have regard to the statutory guidance around the Prevent Duty (this also applies to registered early years childcare providers and registered later year’s childcare providers). They are subject to a duty under section 26 of the Counterterrorism and Security Act 2015, in the exercise of their functions, to have “due regard to the need to prevent people from being drawn into terrorism”. This duty is known as the Prevent duty. It applies to a wide range of public-facing bodies.

The Designated Safeguarding Lead

The Designated Safeguarding Officer (DSO) for child protection will co-ordinate action on child protection within Ask OLA.  The DSO is to have the overall contact with the DSLs for the young people. This includes ensuring that all OLAs know who the Designated Safeguarding Officer is and that they are aware of their individual responsibility to be alert to the signs of abuse and to discuss any concerns with the Designated Safeguarding Officer.

 

Also, that they are aware of what happens once a concern has been raised.

 

The DSO for Safeguarding and Child Protection is a member of the Senior Management Team.

 

 

Key personnel

The Designated Safeguarding Officer (DSO) for child protection is: Sean Gardner

Contact details: email: sean.gardner@gluu.org.uk

Tel: +44 (0) 7795 835242

 

The deputy designated person(s) is/are Angelo Palyvos
email: a.palyvos@gluu.org.uk

Tel:  +44 (0) 7463272459

 

 

It is the role of the Designated Safeguarding Lead or DSO for Child Protection:

 

Ask OLA Procedures – OLA Responsibilities

All OLAs need to be alert to the potential abuse of children both within their families and from other sources, including members of the school community.

 

If any member of staff is concerned about a child, the DSO (or the rep in their absence) must be informed immediately. There is an absolute responsibility for all members of the school to respond to any suspected or actual abuse of a child in accordance with these procedures.

 

The member of staff must record information regarding the concerns and ensure the written record is passed to the DSO for Ask Ola as well as to the School DSL. The recording must be a clear, precise, factual account of the observations.

 

There may be emerging needs or adversities faced by children and their families that could be addressed through Early Help. The LA threshold documents will guide the DSO on what is the most appropriate level of support for families based on their level of need.  The additional guidance shared with the OLAs will provide the contact details and procedures for each school or academy and each local authority.

 

All staff and volunteers should be aware that the main categories of abuse are. See Appendix A:

 

All staff and volunteers should be concerned about a child if he/she presents with indicators of possible significant harm – see Appendix A for details.

Kooth

Ask Ola want to ensure they are providing not only the tutoring education and support to young people but also a response to any concerns about their emotional health and wellbeing. Kooth have partnered with Ask Old and is used as a signposting partner to support aspects of children’s mental health and wellbeing requirements.

 

The child can follow the link to Kooth.com to sign up.

 

Kooth is an online mental health platform for children and young people between 10 and 25 years. Kooth provides an anonymous, self-referral digital service that enables children and young people to ‘drop in’ and find fast, easy and free support that suits them. There are no waiting times, no referrals, no thresholds to meet and complete anonymity. The digital setting also helps reduce the stigma associated with accessing mental health services.

 

Kooth also offers safe and secure support from an online community of peers and a team of experienced, accredited counsellors, providing mental health and wellbeing support at the earliest opportunity before problems escalate.

 

Kooth is commissioned across 90% of England’s CCGs/Local authorities for children aged 10-25 (Age range subject to regional variance).

Safeguarding is the core principle that encompasses everything Kooth Digital Health Limited do (including the services for children, young people, and adults), and as such is a core value amongst their people, both staff and service users.

 

This includes any decisions made as an organisation, from front-line counsellors to IT teams, clinical and safeguarding teams. All staff are fully trained in Advanced Child Protection and safeguarding adults at risk, and actively promote the requirements to safeguard service users effectively under the Children Act (1989) and Care Act (2014). The learning and development team monitor when staff need to renew training.

 

The safeguarding team (including robust and expert clinical team) is the first point of contact for external agencies pursuing any safeguarding queries or investigations. Kooth Digital Health Limited staff respond to all concerns raised by service users, and online and face to face provision is guided by the Common Assessment Framework (CAF)and Early Help Assessment (EHA), which helps to ascertain support networks that service users have and identifies safeguarding risks and emotional robustness.

 

Kooth keep factual and comprehensive case notes for all interactions and these record decisions and actions taken in regard to safeguarding, with a safeguarding system that alerts responsible individuals and teams within the organisation. Safeguarding procedures include a thorough and clear safeguarding process flow chart. For Kooth, safeguarding online is a balance of skillful engagement, robust clinical governance arrangements, clear safeguarding protocols and guidance, risk management and a joined up seamless approach for working with other professionals and services.

 

Kooth workers conduct risk assessments and provide confidential spaces where service users engage and understand their duty to keep them safe from harm. Kooth will intervene where there are life threatening experiences which cause significant harm through robust processes, ensuring confidentiality and the limits of confidentiality are discussed with all service users. Kooth act in the best interests of the service user and consider all aspects of disclosed harm or abuse, conducting ongoing risk assessments, and decisions to not disclose externally may be made in the service user’s best interests, but that decision is not absolute.

Service users are encouraged to provide Kooth with their identifiable information where there is cause for concern, so Kooth can best work with partners and other services, though service users are not obliged to give this information. Kooth would continue to work with service users to keep them safe, and not stop working with them if they don’t give further details.

Kooth keep service users informed of intended actions, and every user has the right to use the complaints procedure. Consent is not always required for Kooth to share personal information externally if there is risk of serious harm, though disclosures should only be made with consent unless there is significant risk.

Good practice guidelines and staff code of conduct

To meet and maintain our responsibilities towards pupils we need to agree standards of good practice which form a code of conduct for all staff.

 

Good practice includes:

 

 

Please see Staff Code of Conduct Policy for more information

Abuse of position of Trust

All staff are aware that inappropriate behaviour towards pupils is unacceptable and that their conduct towards pupils must be beyond reproach.

 

In addition, staff should understand that, under the Sexual Offences Act 2003, it is an offence for a person over the age of 18 to have a sexual relationship with a person under the age of 18, where that person is in a position of trust, even if the relationship is consensual. This means that any sexual activity between a member of staff and a pupil under 18 may be a criminal offence, even if that pupil is over the age of consent.

Children who may be particularly vulnerable

 

Some children may have an increased risk of abuse. It is important to understand that this increase in risk is due more to societal attitudes and assumptions or child protection procedures that fail to acknowledge children’s diverse circumstances, rather than the individual child’s personality, impairment, or circumstances. Many factors can contribute to an increase in risk, including prejudice and discrimination, isolation, social exclusion, communication issues and a reluctance on the part of some adults to accept that abuse can occur.

 

To ensure that all of our pupils receive equal protection, we will give special consideration to children who are:

 

 

An individual will also be considered homeless if it is not reasonable for them to stay in their home, for example if:

 

 

Staff training

All staff members will undertake safeguarding and child protection training at induction, including on whistle-blowing procedures and online safety, to ensure they understand the safeguarding systems and their responsibilities, and can identify signs of possible abuse or neglect. Staff must understand their responsibilities in connection with education and understanding of sexual violence and sexual harassment.

 

This training will be regularly updated and will:

 

All staff will have training on the government’s anti-radicalisation strategy, Prevent, to enable them to identify children at risk of being drawn into terrorism and to challenge extremist ideas.

It is important that all staff receive training to enable them to recognise the possible signs of abuse, neglect, and exploitation and to know what to do if they have a concern.

Allegations of abuse made against other pupils

We recognise that children can abuse their peers. Abuse will never be tolerated or passed off as “banter”, “just having a laugh” or “part of growing up”, as this can lead to a culture of unacceptable behaviours and an unsafe environment for pupils.

We also recognise the gendered nature of peer-on-peer abuse. However, all peer-on-peer abuse is unacceptable and will be taken seriously.

Most cases of pupils hurting other pupils will be dealt with under the school’s behaviour policy, but this child protection and safeguarding policy will apply to any allegations that raise safeguarding concerns. This might include where the alleged behaviour:

 

Procedures for dealing with allegations of peer-on-peer abuse can be found by referring to the individual setting’s Safeguarding and Child Protection Policy and in KCSIE 2021.

Online Safety

Pupils increasingly use electronic equipment on a daily basis to access the internet and share content and images via social networking sites such as Facebook, Instagram and TikTok.

 

Unfortunately, some adults and young people will use these technologies to harm children. The harm might range from sending hurtful or abusive texts and emails, to grooming and enticing children to engage in sexually harmful conversations, webcam photography or face-to-face meetings.

 

Pupils may also be distressed or harmed by accessing inappropriate websites that promote unhealthy lifestyles, extremist behaviour and criminal activity.

 

The school’s Online Safety Policy explains how they try to keep pupils safe in the school and protect and educate pupils in the safe use of technology. Cyberbullying and sexting by pupils will be treated as seriously as any other type of bullying and will be managed through our anti-bullying procedures.  Serious incidents may be managed in line with our Sexual Exploitation policy or Safeguarding and Child Protection procedures.

 

Many pupils own or have access to handheld devices and parents are encouraged to consider measures to keep their children safe when using the internet and social media at home and in the community.

 

We recognise the importance of safeguarding children from potentially harmful and inappropriate online material, and we understand that technology is a significant component in many safeguarding and wellbeing issues.

The 4 key categories of risk

Our approach to online safety is based on addressing the following categories of risk:

 

 

 

 

Organisations for support

Organisation/Resource What it does/provides
thinkuknow NCA CEOPs advice on online safety
disrespectnobody Home Office advice on healthy relationships, including sexting and pornography
UK safer internet centre  Contains a specialist helpline for UK schools and colleges
swgfl Includes a template for setting out online safety policies
internet matters Help for parents on how to keep their children safe online
parentzone Help for parents on how to keep their children safe online
childnet cyberbullying   Guidance for schools on cyberbullying
pshe association Guidance and useful teaching resources covering online safety issues including pornography and the sharing of sexual images
educateagainsthate Practical advice for parents, teachers and governors on protecting children from extremism and radicalisation.
the use of social media for online radicalisation A briefing note for schools on how social media is used to encourage travel to Syria and Iraq
UKCCIS

We follow this guidance provided by the UK Council for Child Internet Safety about Sexting

The UK Council for Child Internet Safety’s website provides:

 

Sexting advice

Online safety: Questions for Governing Bodies

Education for a connected world framework

NSPCC NSPCC advice for schools and colleges
netaware NSPCC advice for parents
commonsensemedia Independent reviews, age ratings, & other information about all types of media for children and their parents
searching screening and confiscation Guidance to schools on searching children in schools and confiscating items such as mobile phones
lgfl Advice and resources from the London Grid for Learning

 

 

 

Confidentiality

 

Safeguarding children raises issues of confidentiality that must be clearly understood by all OLAs.

 

All staff have a responsibility to share relevant information about the protection of children with other professionals, particularly Children’s Social Care and the Police.

 

If a child wishes to confide in an OLA and requests that the information is kept secret, the member of OLA will tell the child, in an appropriate manner to the individual needs of the child, that they cannot promise confidentiality and may need to pass the information on to help keep the child or other children safe.

 

OLAs who receive information about children and their families in the course of their work should share that information within the expectations of the school’s confidentiality policy and other relevant policies e.g., the Safeguarding and Child Protection Policy, Local Children’s Safeguarding Partnership and inter-agency procedures.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX A: DEFINITIONS OF ABUSE AND NEGLECT

Physical Abuse

Physical abuse 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.

 

Signs of possible physical abuse

 

 

Possible effects of Physical Abuse

 

Physical abuse can lead directly to neurological damage, physical injuries, disability and in extreme cases death. Physical abuse has been linked to aggressive behaviour in children, emotional and behavioural problems and learning difficulties.

Emotional Abuse

 

Emotional abuse is 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 children 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 the 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 ill-treatment of another.

It may involve serious bullying (including cyberbullying),

 

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.

 

Signs of possible Emotional Abuse

 

 

Possible effects of Emotional Abuse

 

 

Sexual Abuse

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 non-penetrative 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, 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.

 

Signs of possible Sexual Abuse

 

 

Possible effects of Sexual Abuse

 

 

Child Sexual Exploitation

 

The statutory definition of Child Sexual Exploitation (CSE) can be found in the guidance document Child sexual exploitation: Definition and a guide for practitioners (DfE 2017)

 

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator.

 

The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.

 

Possible signs of child sexual exploitation

 

 

Possible effects

 

Although the following vulnerabilities increase the risk of child sexual exploitation, it must be remembered that not all children with these indicators will be exploited. Child sexual exploitation can occur without any of these issues.

 

 

More information can be found in:

Child sexual exploitation: Definition and a guide for practitioners (DfE 2017)

 

Child Criminal Exploitation

 

CCE is where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into any criminal activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial or other advantage of the perpetrator or facilitator and/or (c) through violence or the threat of violence.

 

The victim may have been criminally exploited even if the activity appears consensual. CCE does not always involve physical contact; it can also occur through the use of technology.

 

Possible signs of CCE

 

 

County Lines

 

County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs (primarily crack cocaine and heroin) into one or more importing areas [within the UK], using dedicated mobile phone lines or other form of “deal line”.’

 

Exploitation is an integral part of the county lines offending model with children and vulnerable adults exploited to move [and store] drugs and money. Offenders will often use coercion, intimidation, violence (including sexual violence) and weapons to ensure compliance of victims.

 

Children can easily become trapped by this type of exploitation as county lines gangs create drug debts and can threaten serious violence and kidnap towards victims (and their families) if they attempt to leave the county lines network.

 

Criminal Exploitation Hubs strive to coordinate intellegince by;

 

CSE Screening Tool MUST be completed for ALL children aged 10-18 who are subject to an Early Help Assessment or a MARF. For further information see guidance sheets regarding CSE support from CSE team within MASH.

 

Complete the CSE Screening Tool when completing a MARF or EHA

 

Use the online CSE Tool from Brook

https://www.brook.org.uk/our-work/cse-e-learning-tool

 

Neglect

 

Neglect is 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:

 

 

Signs of possible Neglect

 

 

 

 

Possible effects of Neglect

 

Neglect can seriously impair a child’s health, physical and intellectual growth and development, and can cause long term difficulties with social functioning, relationships and educational progress. Extreme cases of neglect can cause death.

Private Fostering

There is a mandatory duty on the school to inform the local authority of a private fostering arrangement they are aware of.

 

A private fostering arrangement is one that is made privately (without the involvement of a local authority) for the care of a child under the age of 16 years (under 18, if disabled) by someone other than a parent or close relative, in their own home, with the intention that it should last for 28 days or more.

 

A close family relative is defined as a ‘grandparent, brother, sister, uncle or aunt’ and includes half-siblings and stepparents; it does not include great-aunts or uncles, great grandparents or cousins.

 

Parents and private foster carers both have a legal duty to inform the relevant local authority at least six weeks before the arrangement is due to start; not to do so is a criminal offence.

 

Whilst most privately fostered children are appropriately supported and looked after, they are a potentially vulnerable group who should be monitored by the local authority, particularly when the child has come from another country. In some cases, privately fostered children are affected by abuse and neglect, or be involved in trafficking, child sexual exploitation or modern-day slavery.

 

The school has a mandatory duty to report to the local authority where they are aware or suspect that a child is subject to a private fostering arrangement. Although schools have a duty to inform the local authority, there is no duty for anyone, including the private foster carer or social workers to inform the school. However, it should be clear to the school who has parental responsibility.

 

Staff are trained to advise the DSL/DSO when they become aware of a change of living circumstances for any child. Staff should notify the DSL/DSO when they become aware of private fostering arrangements. The DSL /DSO will speak to the family of the child involved to check that they are aware of their duty to inform the LA. The school itself has a duty to inform the local authority of the private fostering arrangements.

 

On admission to the school, we will take steps to verify the relationship of the adults to the child who is being registered.

Forced Marriage (FM)

this is an entirely separate issue from arranged marriage. It is a human rights abuse and falls within the Crown Prosecution Service definition of domestic abuse. Young men and women can be at risk in affected ethnic groups. Whistleblowing may come from younger siblings.

 

Other indicators may be detected by changes in adolescent behaviours. Never attempt to intervene directly as a school or through a third party.

 

Forced marriage is a CRIME. It is a form of violence against women and men, domestic abuse, a serious abuse of human rights, and where a minor is involved, child abuse. ·

 

While it is important to have an understanding of the motives that drive parents to force their children to marry, these motives should not be accepted as justification for denying them the right to choose a marriage partner and enter freely into marriage. ·

 

A person’s capacity to consent can change. With the right support and knowledge, a person with a learning disability may move from a position of lacking capacity to consent to marriage, to having capacity. However, some children and adults with learning disabilities are given no choice and/or do not have the capacity to give informed consent to marriage and all it entails.

 

The Forced Marriage Unit (FMU) is a joint Foreign and Commonwealth Office and Home Office unit was which set up in January 2005 to lead on the Government’s forced marriage policy, outreach and casework. It operates both inside the UK, where support is provided to any individual, and overseas, where consular assistance is provided to British nationals, including dual nationals.

 

The FMU operates a public helpline to provide advice and support to victims of forced marriage as well as to professionals dealing with cases. The assistance provided ranges from simple safety advice, through to aiding a victim to prevent their unwanted spouse moving to the UK (‘reluctant sponsor’ cases), and, in extreme circumstances, to rescues of victims held against their will overseas.

 

The FMU undertake an extensive outreach and training programme of around 100 events a year, targeting both professionals and potential victims. The FMU also carry out media campaigns, such as 2015’s ‘right to choose’ campaign, where the FMU commissioned a short film to raise awareness amongst young people at risk of being forced into marriage, as well as potential perpetrators.

 

Contact

Telephone: +44 (0) 20 7008 0151

Email: fmu@fco.gov.uk

Email for outreach work: fmuoutreach@fco.gov.uk

Facebook: Forced Marriage page

Twitter: @FMUnit

Female Genital Mutilation (FGM)

It is essential that staff are aware of FGM practices and the need to look for signs, symptoms and other indicators of FGM.

 

What is FGM?

 

It involves procedures that intentionally alter/injure the female genital organs for non-medical reasons.

 

Types of procedure:

 

Type 1 Clitoridectomy – partial/total removal of clitoris

Type 2 Excision – partial/total removal of clitoris and labia minora

Type 3 Infibulation entrance to vagina is narrowed by repositioning the inner/outer labia

Type 4 all other procedures that may include: pricking, piercing, incising, cauterising and scraping the genital area.

 

When should a referral be considered?

Mandatory reporting 2015

 

Under 18 & FGM is ‘Known’

Seen

Disclosed

Report to POLICE

 

Suspected or At Risk?

 

Usual Safeguarding procedure

 

Worried about FGM?

 

Call the FGM helpline if you’re worried a child is at risk of, or has had, FGM.
It’s free, anonymous and we’re here 24/7.

 

0800 028 3550 or email fgmhelp@nspcc.org.uk

 

Useful Sources of Information:

 

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/469448/FGM-Mandatory-Reporting-procedural-info-FINAL.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/380125/MultiAgencyPracticeGuidelinesNov14.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/416323/Fact_sheet_-_FGM_-_

 

Why is it carried out? There is a belief that:

 

 

Is FGM legal? 

 

FGM is internationally recognised as a violation of human rights of girls and women.  It is illegal in most countries including the UK.

 

Circumstances and occurrences that may point to FGM happening

 

 

Signs that may indicate a child has undergone FGM:

 

 

 

The ‘One Chance’ rule

 

As with Forced Marriage there is the ‘One Chance’ rule. It is essential that settings take action without delay.

 

So-called ‘honour-based’ abuse (HBA) encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, this includes Female Genital Mutilation (FGM), forced marriage, and practices such as breast ironing. All forms of so called HBA are abuse (regardless of the motivation) and should be handled and escalated as such.

Where staff are concerned that a child might be at risk of HBA, they must contact the Designated Safeguarding Lead as a matter of urgency.

 

Mental Health

 

This policy covers the importance and responsbiltiy for safeguading young people and their physical and emotional health and wellbeing. This includes their mental health.

 

At ASK Ola we are committed to supporting children with mental ill health and all staff are aware that mental health can, in cases, be an indicator that a child has suffered abuse, neglect or exploitation.

 

We provide training to our staff in relation to the improtance of understanding and recoginsing mental health issues in young people as they are often best placed to be able to identify concerns and refer to the DSO for further support and referral.

Children missing from education

A child going missing from education, particularly repeatedly, can be a warning sign of a range of safeguarding issues. This might include abuse or neglect, such as sexual abuse or exploitation or child criminal exploitation, or issues such as mental health problems, substance abuse, radicalisation, FGM or forced marriage.

There are many circumstances where a child may become missing from education, but some children are particularly at risk. These include children who:

We will follow our procedures for unauthorised absence and for dealing with children who go missing from education, particularly on repeat occasions, to help identify the risk of abuse and neglect, including sexual exploitation, and to help prevent the risks of going missing in future. This includes informing the local authority if a child leaves the school without a new school being named and adhering to requirements with respect to sharing information with the local authority, when applicable, when removing a child’s name from the admission register at non-standard transition points.

Staff will be trained in signs to look out for and the individual triggers to be aware of when considering the risks of potential safeguarding concerns which may be related to being missing, such as travelling to conflict zones, FGM and forced marriage.

If a staff member suspects that a child is suffering from harm or neglect, we will follow local child protection procedures, including with respect to making reasonable enquiries. We will make an immediate referral to the local authority children’s social care team, and the police, if the child is suffering or likely to suffer from harm, or in immediate danger.

Domestic abuse

Children can witness and be adversely affected by domestic abuse and/or violence at home where it occurs between family members. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.

Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse and child/adolescent to parent violence and abuse. Anyone can be a victim of domestic abuse, regardless of gender, age, ethnicity, socioeconomic status, sexuality or background, and domestic abuse can take place inside or outside of the home.

Older children may also experience domestic abuse and/or violence in their own personal relationships.

Exposure to domestic abuse and/or violence can have a serious, long-lasting emotional and psychological impact on children.

If police are called to an incident of domestic abuse and any children in the household have experienced the incident, the police will inform the key adult in school (usually the designated safeguarding lead) before the child or children arrive at school the following day.

The DSO will provide support according to the child’s needs and update records about their circumstances.

The Domestic Abuse Act 2021 received Royal Assent and introduced a statutory definition for the first time.

Definition

The Domestic Abuse Act 2021 (Part 1) defines domestic abuse as any of the following behaviours, either as a pattern of behaviour, or as a single incident, between two people over the age of 16, who are ‘personally connected’ to each other:

(a) physical or sexual abuse.

(b) violent or threatening behaviour.

(c) controlling or coercive behaviour.

(d) economic abuse (adverse effect of the victim to acquire, use or maintain money or other property; or obtain goods or services); and

(e) psychological, emotional or other abuse.

People are ‘personally connected’ when they are or have been married to each other or civil partners; or have agreed to marry or become civil partners. If the two people have been in an intimate relationship with each other, have shared parental responsibility for the same child, or they are relatives.

The definition of Domestic Abuse applies to children if they see or hear, or experience the effects of, the abuse; and they are related to the abusive person.

(The definition can be found here: https://www.legislation.gov.uk/ukpga/2021/17/part/1/enacted)

Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse and child/adolescent to parent violence and abuse. Anyone can be a victim of domestic abuse, regardless of sexual identity, age, ethnicity, socio-economic status, sexuality or background and domestic abuse can take place inside or outside of the home.

 

The National Domestic Abuse helpline can be called free of charge and in confidence, 24 hours a day on 0808 2000 247.

APPENDIX G Safeguarding Guidance

PREVENT

 

Preventing radicalisation

The use or threat of terrorism must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious or ideological cause.

Schools have a duty to prevent children from being drawn into terrorism. The DSO will undertake Prevent awareness training and make sure that staff have access to appropriate training to equip them to identify children at risk.

We will assess the risk of children in our school being drawn into terrorism. This assessment will be based on an understanding of the potential risk in our local area, in collaboration with our local safeguarding partners and local police force.

We will ensure that suitable internet filtering is in place and equip our pupils to stay safe online at school and at home.

There is no single way of identifying an individual who is likely to be susceptible to an extremist ideology. Radicalisation can occur quickly or over a long period.

Staff will be alert to changes in pupils’ behaviour.

The government website Educate Against Hate and charity NSPCC say that signs that a pupil is being radicalised can include:

Children who are at risk of radicalisation may have low self-esteem or be victims of bullying or discrimination. It is important to note that these signs can also be part of normal teenage behaviour – staff should have confidence in their instincts and seek advice if something feels wrong.

If staff are concerned about a pupil, they will follow our procedures set out in section 7.5 of this policy, including discussing their concerns with the DSO

Staff should always take action if they are worried.

Further information on the school’s measures to prevent radicalisation are set out in other school policies and procedures, including [list any relevant policies here – for example you may cover this in your curriculum policy, behaviour policy, online/e-safety policy, and/or others].

Serious violence

Indicators which may signal that a child is at risk from, or involved with, serious violent crime may include:

Risk factors which increase the likelihood of involvement in serious violence include:

Staff will be aware of these indicators and risk factors. If a member of staff has a concern about a pupil being involved in, or at risk of, serious violence, they will report this to the DSO.

 

Definition:

 

In order for schools and childcare providers to fulfil the Prevent duty, it is essential that staff are able to identify children who may be vulnerable to radicalisation and know what to do when they are identified. Protecting children from the risk of radicalisation should be seen as part of schools’ and childcare providers’ wider safeguarding duties and is similar in nature to protecting children from other harms (e.g., drugs, gangs, neglect, sexual exploitation) whether these come from within their family or are the product of outside influences.

 

Physical and Behavioural Observations:

 

 

Action to be considered:

 

As explained above, if a member of staff in a school has a concern about a particular

young person they should follow the school’s normal safeguarding procedures, including discussing with the school’s Designated Safeguarding Lead for Child Protection, and where deemed necessary, with Children’s Social Care.

 

In Prevent priority areas, the local authority will have a Prevent lead who can also provide support.

You can also contact your local police force or dial 101 (the non-emergency number).

They can talk to you in confidence about your concerns and help you gain access to

support and advice.

 

The Department for Education has dedicated a telephone helpline (020 7340 7264) to enable staff and governors to raise concerns relating to extremism directly. Concerns can also be raised by email to counter.extremism@education.gsi.gov.uk

 

Please note that the helpline is not intended for use in emergency situations, such as a child being at immediate risk of harm or a security incident, in which case the normal emergency procedures should be followed

 

IF YOU HOLD THE INFORMATION, YOU HOLD THE RISK!

Appendix H: Peer on Peer Abuse

Peer-on-peer abuse is when children abuse other children. This type of abuse can take place inside and outside of school and online.

Peer-on-peer abuse is most likely to include, but may not be limited to:

Where children abuse their peers online, this can take the form of, for example, abusive, harassing, and misogynistic messages; the non-consensual sharing of indecent images, especially around chat groups; and the sharing of abusive images and pornography, to those who don’t want to receive such content.

If staff have any concerns about peer-on-peer abuse, or a child makes a report to them, they will follow the procedures set out in section 7 of this policy, as appropriate. In particular, section 7.8 and 7.9 set out more detail about our school’s approach to this type of abuse.

Sexual violence and sexual harassment between children in schools

Sexual violence and sexual harassment can occur:

Sexual violence and sexual harassment exist on a continuum and may overlap.

Children who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment and will be exacerbated if the alleged perpetrator(s) attends the same school.

If a victim reports an incident, it is essential that staff make sure they are reassured that they are being taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment. Nor should a victim ever be made to feel ashamed for making a report.

Some groups are potentially more at risk. Evidence shows that girls, children with SEN and/or disabilities, and lesbian, gay, bisexual and transgender (LGBT) children are at greater risk.

Staff should be aware of the importance of:

If staff have any concerns relating to sexual violence or sexual harassment, they will speak with the DSO immediately.

Further guidance can be found at:

https://www.gov.uk/government/publications/sexual-violence-and-sexual-harassment-between-children-in-schools-and-colleges

 

KCSIE 2018 revised version dated 19th September 2018 – Part 5 Updated 2021 version

 

https://www.gov.uk/government/publications/keeping-children-safe-in-education–2?mc_cid=b065197ed7&mc_eid=ddb5c47c98

 

Peer on peer abuse Children can abuse other children. This is generally referred to as peer-on-peer abuse and can take many forms.

 

This can include (but is not limited to).

 

 

Sexual violence and sexual harassment between children in schools and colleges.

 

Context Sexual violence and sexual harassment can occur between two children of any age and sex. It can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children.

 

Children who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment.

 

Sexual violence and sexual harassment exist on a continuum and may overlap, they can occur online and offline (both physical and verbal) and are never acceptable. It is important that all victims are taken seriously and offered appropriate support. Staff should be aware that some groups are potentially more at risk. Evidence shows girls, children with SEND and LGBT children are at greater risk.

 

Staff should be aware of the importance of:

 

 

What is Sexual violence and sexual harassment?

 

It is important that school and college staff are aware of sexual violence and the fact children can, and sometimes do, abuse their peers in this way.

 

When referring to sexual violence we are referring to sexual offences under the Sexual Offences Act 2003 as described below:

 

 

What is consent?

 

Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given to one sort of sexual activity but not another, e.g.to vaginal but not anal sex or penetration with conditions, such as wearing a condom.

 

Consent can be withdrawn at any time during sexual activity and each time activity occurs. Someone consents to vaginal, anal or oral penetration only if s/he agrees by choice to that penetration and has the freedom and capacity to make that choice.

 

Definition

 

There is no clear boundary between incidents that should be regarded as abusive and incidents that are more properly dealt with as bullying, sexual experimentation etc. This is a matter of professional judgement.

 

 

 

Upskirting

 

‘Upskirting’ typically involves 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. It is now a criminal offence.

Allegations of Abuse made against other Children

It is recognised that sometimes children are capable of abusing their peers. All children should be able to attend school and learn in a safe environment. When this is compromised by the actions or behaviours of their peers this will be dealt with through our behaviour policy.

 

Prevention is a fundamental method of minimising risks, and we will do this by:

 

Sometimes allegations are made of a specific safeguarding nature. These may include physical abuse, emotional abuse, sexual abuse and sexual exploitation. Some of the features of these could include:

 

 

Downblousing

The using of a mobile camera to take photos down one’s blouse, shirt, or dress. This is usually done without the persons knowledge or consent.

 

Guidance

 

Risks

 

Children are vulnerable to abuse by their peers. Such 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.

 

Professionals should be aware of the potential uses of information technology for bullying and abusive behaviour between young people.

 

Professionals should be aware of the added vulnerability of children and young people who have been the victims of violent crime (for example mugging), including the risk that they may respond to this by abusing younger or weaker children.

 

The alleged perpetrator is likely to have considerable unmet needs as well as posing a significant risk of harm to other children. Evidence suggests that such children may have suffered considerable disruption in their lives, may have witnessed or been subjected to physical or sexual abuse may have problems in their educational development and may have committed other offences. They may therefore be suffering, or at risk of suffering significant harm and in need of protection. Any long-term plan to reduce the risk posed by the alleged perpetrator must address their needs.

Protection and Action to be taken

 

It is not enough to respond to incidents as they arise: all agencies that work with children should strive to create an environment that actively discourages abuse and challenges the attitudes which underlie it.

 

Agencies should have a policy on bullying, and on sexual and racial harassment. They should also consider the effect of adult behaviour on children who may view them as role models.

 

Any professional who feels that a young person has abused another child or young person should notify children’s social care without delay. They will arrange Strategy Discussion through the MASH which will include the referring agency and the police.

 

In order to give priority to them, issues relating to the safety of victims and potential victims must be discussed first and completely separately from any issues relating to the needs of the alleged perpetrator. This will usually require separate meetings.

 

The strategy discussion will consider:

 

 

The Victim

 

The strategy discussion will consider what action is necessary to ensure the immediate safety of the identified victim(s) and what further enquiries are necessary to assess any further risk. A Child Protection Conference must be arranged unless the child does not appear to be at continuing risk of significant harm.

 

Where a young person has abused a sibling, planning must include consideration of the support needs of the parents. If victim and perpetrator are members of the same family/household, before making any arrangement to return the perpetrator to the family/household it is critical to ensure that the victim’s views have been heard and that they feel safe.

 

A Child Protection Conference may conclude that the victim is not in need of a child protection plan but may be a child in need of support to address her/his needs arising from the abuse – for example referral to The Children’s Society (formerly My Shield) Counselling Service, Beam, Krunch, Kooth, CAMHS or another victim support agency.

 

The Alleged Perpetrator

 

It is not always appropriate to initiate Section 47 Enquiries in respect of the alleged perpetrator unless there is information suggesting that they are at continuing risk of significant harm. However young people who abuse others frequently have considerable needs themselves, so an assessment of the alleged perpetrator’s needs should be carried out.

 

Any decision on action in respect of the alleged perpetrator must be based on the risk they pose to other children and what can be done to minimise this risk. If the alleged perpetrator is over the age of 10, consideration should also be given to whether action under the criminal justice system would be appropriate.

 

If there is evidence that the alleged perpetrator has also been the victim of abuse, the police will consider whether to initiate a separate criminal investigation relating to this.

 

The alleged perpetrator is likely to pose a continuing risk to others unless the opportunity for further abuse is ended and the young person and their family have agreed to work with relevant agencies to address the problem. It has also been proposed that the risk remains high unless the young person accepts responsibility for the abusive behaviour, but more recent research has suggested that in the case of sexually harmful behaviour, denial may be rooted in shame and a well-founded fear of consequences of admission. Consequently, while denial will have consequences for the treatment approach, it does not necessarily indicate that sexually harmful behaviour is likely to be repeated.

 

Assessment of an alleged perpetrator’s needs will include consideration of:

 

The nature and degree of the risk.

 

 

This meeting should be attended by:

 

 

It is important to keep the risk management / strategy meeting separate from any child protection conference. The purpose of the risk management meeting is to reduce the risk which the perpetrator poses to children and adults at risk both at present and in the longer term.

 

This will include:

 

 

The meeting will make recommendations and, where possible, will make commitments about action to be taken and resources to be provided for the safety of the children involved. Any recommendations should be based on the following assumptions:

 

A victim of abuse must not be left in contact with their abuser without adequate protection; and

Moving the perpetrator away from the victim to another place where there are children may not reduce the overall risk to potential victims and may actually increase it.

 

The long-term control of risk may depend on an addressing any unmet needs of the perpetrator. This will be coordinated by children’s social care.

 

Other children

 

The strategy discussion will consider:

 

 

Issues

 

Particular difficulties arise in responding to a child or young person who abuses another child because:

 

 

 

The guiding principles for dealing with these situations are:

 

 

Appendix I: Allegations of abuse made against staff

 

Section 1: allegations that may meet the harms threshold

This section is based on ‘Section 1: Allegations that may meet the harms threshold’ in part 4 of Keeping Children Safe in Education. Amend or add to this as applicable to reflect your own approach.

This section applies to all cases in which it is alleged that a current member of staff, including a supply teacher, volunteer or contractor, has:

We will deal with any allegation of abuse quickly, in a fair and consistent way that provides effective child protection while also supporting the individual who is the subject of the allegation.

A ‘case manager’ will lead any investigation. This will be the headteacher, or the chair of governors [in independent schools: proprietor] where the headteacher is the subject of the allegation. The case manager will be identified at the earliest opportunity.

Our procedures for dealing with allegations will be applied with common sense and judgement.

Suspension of the accused until the case is resolved

Suspension of the accused will not be the default position and will only be considered in cases where there is reason to suspect that a child or other children is/are at risk of harm, or the case is so serious that there might be grounds for dismissal. In such cases, we will only suspend an individual if we have considered all other options available and there is no reasonable alternative.

Based on an assessment of risk, we will consider alternatives such as:

If in doubt, the case manager will seek views from the school’s personnel adviser and the designated officer at the local authority, as well as the police and children’s social care where they have been involved.

Definitions for outcomes of allegation investigations

Procedure for dealing with allegations

In the event of an allegation that meets the criteria above, the case manager will take the following steps:

Early years providers add:

We will inform Ofsted of any allegations of serious harm or abuse by any person living, working, or looking after children at the premises (whether the allegations relate to harm or abuse committed on the premises or elsewhere), and any action taken in respect of the allegations. This notification will be made as soon as reasonably possible and always within 14 days of the allegations being made.

All schools continue with:

If the school is made aware that the secretary of state has made an interim prohibition order in respect of an individual, we will immediately suspend that individual from teaching, pending the findings of the investigation by the Teaching Regulation Agency.

Where the police are involved, wherever possible the school will ask the police at the start of the investigation to obtain consent from the individuals involved to share their statements and evidence for use in the school’s disciplinary process, should this be required at a later point.

Additional considerations for supply teachers and all contracted staff

If there are concerns or an allegation is made against someone not directly employed by the school, such as a supply teacher or contracted staff member provided by an agency, we will take the actions below in addition to our standard procedures.

When using an agency, we will inform them of our process for managing allegations, and keep them updated about our policies as necessary, and will invite the agency’s HR manager or equivalent to meetings as appropriate.

Timescales

We will deal with all allegations as quickly and effectively as possible and will endeavour to comply with the following timescales, where reasonably practicable:

However, these are objectives only and where they are not met, we will endeavour to take the required action as soon as possible thereafter.

Specific actions

Action following a criminal investigation or prosecution

The case manager will discuss with the local authority’s designated officer whether any further action, including disciplinary action, is appropriate and, if so, how to proceed, taking into account information provided by the police and/or children’s social care services.

Conclusion of a case where the allegation is substantiated

If the allegation is substantiated and the individual is dismissed or the school ceases to use their services, or the individual resigns or otherwise ceases to provide their services, the school will make a referral to the DBS for consideration of whether inclusion on the barred lists is required.

If the individual concerned is a member of teaching staff, the school will consider whether to refer the matter to the Teaching Regulation Agency to consider prohibiting the individual from teaching.

Individuals returning to work after suspension

If it is decided on the conclusion of a case that an individual who has been suspended can return to work, the case manager will consider how best to facilitate this.

The case manager will also consider how best to manage the individual’s contact with the child or children who made the allegation if they are still attending the school.

Unsubstantiated, unfounded, false or malicious reports

If a report is:

Unsubstantiated, unfounded, false or malicious allegations

If an allegation is:

Confidentiality and information sharing

The school will make every effort to maintain confidentiality and guard against unwanted publicity while an allegation is being investigated or considered.

The case manager will take advice from the LADO, police and children’s social care services, as appropriate, to agree:

Record-keeping

The case manager will maintain clear records about any case where the allegation or concern meets the criteria above and store them on the individual’s confidential personnel file for the duration of the case.

The records of any allegation that, following an investigation, is found to be malicious or false will be deleted from the individual’s personnel file (unless the individual consents for the records to be retained on the file).

For all other allegations (which are not found to be malicious or false), the following information will be kept on the file of the individual concerned:

In these cases, the school will provide a copy to the individual, in agreement with children’s social care or the police as appropriate.

Where records contain information about allegations of sexual abuse, we will preserve these for the Independent Inquiry into Child Sexual Abuse (IICSA), for the term of the inquiry. We will retain all other records at least until the individual has reached normal pension age, or for 10 years from the date of the allegation if that is longer.

References

When providing employer references, we will:

Learning lessons

After any cases where the allegations are substantiated, the case manager will review the circumstances of the case with the local authority’s designated officer to determine whether there are any improvements that we can make to the school’s procedures or practice to help prevent similar events in the future.

This will include consideration of (as applicable):

For all other cases, the case manager will consider the facts and determine whether any improvements can be made.

Non-recent allegations

Abuse can be reported, no matter how long ago it happened.

We will report any non-recent allegations made by a child to the LADO in line with our local authority’s procedures for dealing with non-recent allegations.

Where an adult makes an allegation to the school that they were abused as a child, we will advise the individual to report the allegation to the police.

Section 2: concerns that do not meet the harm threshold

The section is based on ‘Section 2: Concerns that do not meet the harm threshold’ in part 4 of Keeping Children Safe in Education. Amend or add to this as applicable to reflect your own approach.

This section applies to all concerns (including allegations) about members of staff, including supply teachers, volunteers and contractors, which do not meet the harm threshold set out in section 1 above.

Concerns may arise through, for example:

We recognise the importance of responding to and dealing with any concerns in a timely manner to safeguard the welfare of children.

Definition of low-level concerns

The term ‘low-level’ concern is any concern – no matter how small – that an adult working in or on behalf of the school may have acted in a way that:

Sharing low-level concerns

We recognise the importance of creating a culture of openness, trust and transparency to encourage all staff to share low-level concerns so that they can be addressed appropriately.

We will create this culture by:

[Add more detail about how you create an open culture.]

Responding to low-level concerns

If the concern is raised via a third party, the headteacher will collect evidence where necessary by speaking:

The headteacher will use the information collected to categorise the type of behaviour and determine any further action, in line with the school’s [staff behaviour policy/code of conduct].

[Add more detail about your procedures for responding to low-level concerns. Keeping Children Safe in Education also links to this report for more information Developing and implementing a low-level concerns policy: A guide for organisations which work with children]

Record keeping

All low-level concerns will be recorded in writing. In addition to details of the concern raised, records will include the context in which the concern arose, any action taken and the rationale for decisions and action taken.

Records will be:

Where a low-level concern relates to a supply teacher or contractor, we will notify the individual’s employer, so any potential patterns of inappropriate behaviour can be identified.

References

We will not include low-level concerns in references unless:

 

The guidance in KCSIE (Part Four) should be followed where it is alleged that anyone working in the school or college that provides education for children under 18 years of age, including supply teachers and volunteers has:

behaved or may have behaved in a way that indicates they may not be suitable to work with children.