Statement of intent
GEM Hereford is committed to safeguarding and promoting the physical, mental and emotional welfare of every Student, both inside and outside of the school premises. We implement a whole-school preventative approach to managing safeguarding concerns, ensuring that the wellbeing of Student is at the forefront of all action taken.
This policy sets out a clear and consistent framework for delivering this promise, in line with safeguarding legislation and statutory guidance. It will be achieved by:
The DSL is Rachel Ballance (Headteacher). In the absence of the DSL, child protection matters will be dealt with by the deputy DSL’s, Justin Haines (Director, Business Manager & Teacher at GEM), Caroline Phillips (Director, Pastoral Lead & Teacher at GEM) and Beth Rogers (Lead teacher at GEM).
Definitions
The terms “children” and “child” refer to anyone under the age of 18.
For the purposes of this policy, “safeguarding and protecting the welfare of children” is defined as:
For the purposes of this policy, “consent” is defined as having the freedom and capacity to choose to engage in sexual activity. Consent may be given to one sort of sexual activity but not another, and can be withdrawn at any time during sexual activity and each time activity occurs. A person only consents to a sexual activity if they agree by choice to that activity, and has the freedom and capacity to make that choice. Children under the age of 13 can never consent to any sexual activity. The age of consent is 16.
For the purposes of this policy, “sexual violence” refers to the following offences as defined under the Sexual Offences Act 2003:
For the purposes of this policy, “sexual harassment” refers to unwanted conduct of a sexual nature that occurs online or offline, inside or outside of school. Sexual harassment is likely to violate a student’s dignity, make them feel intimidated, degraded or humiliated, and create a hostile, offensive, or sexualised environment. If left unchallenged, sexual harassment can create an atmosphere that normalises inappropriate behaviour and may lead to sexual violence.
Sexual harassment can include, but is not limited to:
For the purposes of this policy, “upskirting” refers to the act, as identified the Voyeurism (Offences) Act 2019, of taking a picture or video under another person’s clothing, without their knowledge or consent, with the intention of viewing that person’s genitals or buttocks, with or without clothing, to obtain sexual gratification, or cause the victim humiliation, distress or alarm. Upskirting is a criminal offence. Anyone, including Student and staff, of any gender can be a victim of upskirting.
For the purposes of this policy, the “consensual and non-consensual sharing of nude and semi-nude images and/or videos”, colloquially known as “sexting”, and collectively called “youth-produced sexual imagery” is defined as the creation of sexually explicit content by a person under the age of 18 that is shared with another person under the age of 18. This definition does not cover persons under the age of 18 sharing adult pornography or exchanging messages that do not contain sexual images.
“Deep fakes” and “deep nudes” refer to digitally manipulated and AI-generated nudes and semi-nudes.
For the purposes of this policy, “indecent imagery” is defined as an image which meets one or more of the following criteria:
Indecent images also include indecent “pseudo-images”, which are images have been created or manipulated using computer software and/or AI.
For the purposes of this policy, “abuse” is defined as a form of maltreatment of a child which involves inflicting harm or failing to act to prevent harm. Harm can include ill treatment that is not physical as well as the impact of witnessing the ill treatment of others – this can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse. Children may be abused in a family, institutional or community setting by those known to them or by others, e.g. via the internet. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by one or multiple adults or other children.
For the purposes of this policy, “physical abuse” is defined as a form of abuse which may involve actions such as hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical abuse can also be caused when a parent fabricates the symptoms of, or deliberately induces, illness in a child.
For the purposes of this policy, “emotional abuse” is defined as the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. This may involve conveying to a child that they are worthless, unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child the opportunities to express their views, deliberately silencing them, ‘making fun’ of what they say or how they communicate. It may feature age- or developmentally inappropriate expectations being imposed on children, such as interactions that are beyond their developmental capability, overprotection and limitation of exploration and learning, or preventing the child from participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying, including cyberbullying, causing the child to frequently 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, but it may also occur alone.
For the purposes of this policy, “sexual abuse” is defined as abuse that involves forcing or enticing a child to take part in sexual activities, not necessarily involving violence, and regardless of whether the child is aware of what is happening. This may involve physical contact, including assault by penetration, or non-penetrative acts, such as masturbation, kissing, rubbing, and touching outside of clothing. It may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can be perpetrated by people of any gender and age.
For the purposes of this policy, “neglect” is defined as the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in serious impairment of a child’s health or development. This may involve a parent or carer failing to provide a child with adequate food, clothing or shelter (including exclusion from home or abandonment); failing to protect a child from physical or emotional harm or danger; failing to ensure adequate supervision (including through the use of inappropriate caregivers); or failing to ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
Legal framework
This policy has due regard to all relevant legislation and statutory guidance including, but not limited to, the following:
Legislation
Statutory guidance
Non-statutory guidance
This policy operates in conjunction with the following school policies and documents:
Roles and responsibilities
All staff have a responsibility to:
Teachers, including the headteacher, have a responsibility to:
The governing board has a duty to:
The headteacher has a duty to:
The DSL has a duty to:
The designated teacher has a responsibility for promoting the educational achievement of LAC and PLAC, and for children who have left care through adoption, special guardianship or child arrangement orders or who were adopted from state care outside England and Wales.
Multi-agency working
The school contributes to multi-agency working as part of its statutory duty. The school is aware of and will follow the local safeguarding arrangements.
The school will be fully engaged, involved, and included in the child-centred approach towards local safeguarding arrangements. Once the school is named as a relevant agency by local safeguarding partners, it will follow its statutory duty to cooperate with the published arrangements in the same way as other relevant agencies.
The school will develop trusting relationships between families and agencies to protect the welfare of its student, through the early help process and by contributing to multi-agency plans to provide additional support.
Where a need for early help is identified, the school will allow access for CSCS from the host LA and, where appropriate, a placing LA, for that LA to conduct (or consider whether to conduct) a section 17 or 47 assessment.
The school will also be mindful of the importance of inter-agency working in identifying and preventing CSE.
The school will reflect the DfE’s expectations to secure strong multi-agency working by:
Information sharing
The school recognises the importance of proactive information sharing between professionals and local agencies in order to effectively meet Student’ needs and identify any need for early help.
Considering the above, staff will be aware that whilst the UK GDPR and the Data Protection Act 2018 place a duty on schools to process personal information fairly and lawfully, they also allow for information to be stored and shared for safeguarding purposes – data protection regulations do not act as a barrier to sharing information where failure to do so would result in the Student being placed at risk of harm.
Staff members will be made aware that safeguarding partners may take legal action against them if they do not share specified information when a request is made for the purposes of safeguarding.
Staff members will ensure that fear of sharing information does not stand in the way of their responsibility to promote the welfare and safety of Student. If staff members are in doubt about sharing information, they will speak to the DSL or deputy DSLs.
Early help
Early help means providing support as soon as a problem emerges, at any point in a child’s life. The school will be proactive in ensuring that every Student is able to access full-time education to aid their development and protect them from harm whilst utilising the unique position of having regular daily contact with Student to identify concerns as early as possible.
Any Student may benefit from early help, but in particular, staff will be alert to the potential need for early help for Student who:
The DSL will take the lead where early help is appropriate. This includes liaising with other agencies and setting up an inter-agency assessment as appropriate. The local early help process will be followed as required.
Staff may be required to support other agencies and professionals in an early help assessment, in some cases acting as the lead practitioner. Any such cases will be kept under constant review and consideration given to a referral to CSCS for assessment for statutory services if the student’s situation is not improving or is worsening.
Abuse and neglect
All staff will be aware of the indicators of abuse and neglect and understand that children can be at risk of harm inside and outside of the school, inside and outside of home, and online. All staff will be aware that abuse, neglect and other safeguarding issues are rarely standalone events that can be given a specific label, and multiple issues often overlap one another; therefore, staff will be vigilant and always raise concerns with the DSL. All staff, especially the DSL and deputy DSLs, will be aware that safeguarding incidents and/or behaviours can be associated with factors outside the school and/or can occur between children outside of these environments; this includes being aware that Student can at risk of abuse or exploitation in situations outside their families (extra-familial harms). All staff will be aware of the appropriate action to take following a student being identified as at potential risk of abuse and, in all cases, will speak to the DSL if they are unsure.
All staff will be aware that technology is a significant component in many safeguarding and wellbeing issues, including online abuse, cyberbullying, and the sharing of indecent images.
Specific safeguarding issues
There are certain specific safeguarding issues that can put children at risk of harm – staff will be aware of these issues.
Appendix A of this policy sets out details about specific safeguarding issues that student may experience and outlines specific actions that would be taken in relation to individual issues.
Child-on-child abuse
For the purposes of this policy, “child-on-child abuse” is defined as abuse between children. GEM School has a separate child-on-child abuse policy which further covers this area of safeguarding practice.
The school has a zero-tolerance approach to abuse, including child-on-child abuse, as confirmed in the Child Protection and Safeguarding Policy’s statement of intent.
All staff will be aware that child-on-child abuse can occur between Student of any age and gender, both inside and outside of school, as well as online. All staff will be aware of the indicators of child-on-child abuse, how to identify it, and how to respond to reports. All staff will also recognise that even if no cases have been reported, this is not an indicator that child-on-child abuse is not occurring. All staff will speak to the DSL if they have any concerns about child-on-child abuse.
All staff will understand the importance of challenge inappropriate behaviour between peers, and will not tolerate abuse as “banter” or “part of growing up”.
Child-on-child abuse can be manifested in many different ways, including:
The DSL will ensure they appropriately assess all instances of child-on-child abuse, including in cases of image-based abuse, to help determine whether the alleged perpetrator(s) is under the age of 18 or is an adult posing as a child. The DSL will immediately refer the case if it is found that a so-called child-on-child abuse incident involves an adult, e.g. where an adult poses as a child online to groom a child or young person.
All staff will be clear as to the school’s policy and procedures regarding child-on-child abuse and the role they have to play in preventing it and responding where they believe a child may be at risk from it.
Students will be made aware of how to raise concerns or make a report and how any reports will be handled. This includes the process for reporting concerns about friends or peers. Student will also be reassured that they will be taken seriously, be supported, and kept safe.
The school’s procedures for managing allegations of child-on-child abuse are outlined in the Child-on-child Abuse Policy. Staff will follow these procedures, as well as the procedures outlined in the school’s Anti-bullying Policy and Suspension and Exclusion Policy, where relevant.
Online safety and personal electronic devices
The school will adhere to the Online Safety Policy at all times.
As part of a broad and balanced curriculum, all students will be made aware of online risks and taught how to stay safe online.
Through training, all staff members will be made aware of:
The school will ensure that appropriate filtering systems are in place on school devices and school networks to prevent children accessing inappropriate material, in accordance with the school’s Cyber-security Policy. The school will, however, ensure that the use of filtering and monitoring systems does not cause “over blocking”, which may lead to unreasonable restrictions as to what Student can be taught online. The school will also ensure that it meets the filtering and monitoring standards published by the DfE (certificate of compliance from external supplier- BOSS will be kept on file).
Staff will be aware of the filtering and monitoring systems in place and will know how to escalate concerns where they are identified. Staff will be made aware of their expectations and responsibilities relating to filtering and monitoring systems during their induction.
Further information regarding the school’s approach to online safety can be found in the Online Safety Policy.
Communicating with parents
As part of the usual communication with parents, the school will reinforce the importance of Student being safe online and inform parents that they will find it helpful to understand what systems the school uses to filter and monitor internet use.
The school will also make it clear to parents what their children are being asked to do online for school.
Reviewing online safety
The school will carry out an annual review of its approach to online safety, supported by an annual risk assessment that considers and reflects the risks faced by Student.
Personal electronic devices
The use of personal electronic devices, including mobile phones and cameras, by staff and Student is closely monitored by the school, in accordance with the Staff ICT and Electronic Devices Policy and Student’ Personal Electronic Devices Policy.
Photographs and videos of Student will be carefully planned before any activity with particular regard to consent and adhering to the school’s Data Protection Policy and Photography and Images Policy.
The DPO (Justin Haines) will oversee the planning of any events where photographs and videos will be taken.
Where photographs and videos will involve Student who are LAC, adopted Student, or Student for whom there are security concerns, the headteacher will liaise with the DSL to determine the steps involved. The DSL will, in known cases of Student who are LAC or who have been adopted, liaise with the student’s social workers, carers or adoptive parents to assess the needs and risks associated with the student.
Staff will report any concerns about Student’ or other staff members’ use of personal electronic devices to the DSL, following the appropriate procedures.
Upskirting
Under the Voyeurism (Offences) Act 2019, it is an offence to operate equipment for the purpose of upskirting. “Operating equipment” includes enabling, or securing, activation by another person without that person’s knowledge, e.g. a motion-activated camera.
Upskirting will not be tolerated by the school. Any incidents of upskirting will be reported to the DSL, who will then decide on the next steps to take, which may include police involvement.
Consensual & non-consensual sharing of indecent images and videos
The school will ensure that staff are aware to treat the consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as “sexting” or youth-produced sexual images) as a safeguarding concern.
Staff will receive appropriate training regarding child sexual development and will understand the difference between sexual behaviour that is considered normal and expected for the age of the student, and sexual behaviour that is inappropriate and harmful. Staff will receive appropriate training around how to deal with instances of sharing nudes and semi-nudes in the school community, including understanding motivations, assessing risks posed to Student depicted in the images, and how and when to report instances of this behaviour.
Staff will be aware that creating, possessing, and distributing indecent imagery of children is a criminal offence, regardless of whether the imagery is created, possessed, and distributed by the individual depicted; however, staff will ensure that Student are not unnecessarily criminalised.
Staff will also be made aware that the laws imposed on the sharing of nudes and semi-nudes applies to digitally manipulated and AI-generated imagery.
Where a member of staff becomes aware of an incidence of sharing nudes and/or semi-nudes, they will refer this to the DSL as soon as possible. The DSL will work to support the affected student and inform them of the reporting routes to remove a nude or semi-nude that has been shared online or to prevent an image from being shared online.
The school’s full response to incidents of consensual and non-consensual sharing of indecent images and videos can be found in the Youth-produced Sexual Imagery Policy, including the appropriate reporting routes for both staff and Student.
Context of safeguarding incidents
Safeguarding incidents can occur outside of school and can be associated with outside factors. All staff, particularly the DSL and deputy DSLs, will always consider the context of safeguarding incidents. Assessment of student behaviour will consider whether there are wider environmental factors that are a threat to their safety and/or welfare. The school will provide as much contextual information as possible when making referrals to CSCS
Student potentially at greater risk of harm
The school recognises that some groups of students can face additional safeguarding challenges, both online and offline, and understands that further barriers may exist when determining abuse and neglect in these groups of Student. Additional considerations for managing safeguarding concerns and incidents amongst these groups are outlined below.
Student who need social workers
Students may need social workers due to safeguarding or welfare needs. These needs can leave a student vulnerable to further harm and educational disadvantage.
As a matter of routine, the DSL will hold and use information from the LA about whether a student has a social worker in order to make decisions in the best interests of the student’s safety, welfare, and educational outcomes.
Where a student needs a social worker, this will inform decisions about safeguarding, e.g. responding to unauthorised absence, and promoting welfare, e.g. considering the provision pastoral or academic support.
Home-educated children
Parents may choose elective home education (EHE) for their children. In some cases, EHE can mean that children are less visible to the services needed to safeguard and support them.
In line with the Education (Student Registration) (England) Regulations 2006, the school will inform the LA of all deletions from the admissions register when a student is taken off roll.
Where a parent has expressed their intention to remove a student from school for EHE, the school, in collaboration with the LA and other key professionals, will coordinate a meeting with the parent, where possible, before the final decision has been made, particularly if the student has SEND, is vulnerable, and/or has a social worker.
LAC and PLAC
Children most commonly become looked after because of abuse and/or neglect. Because of this, they can be at potentially greater risk in relation to safeguarding. PLAC, also known as care leavers, can also remain vulnerable after leaving care.
The governing board and board of directors will ensure that staff have the skills, knowledge and understanding to keep LAC and PLAC safe. This includes ensuring that the appropriate staff have the information they need, such as:
The DSL will be provided with the necessary details of Student’ social workers and the VSH, and, for PLAC, personal advisers.
Further details of safeguarding procedures for LAC and PLAC are outlined in the school’s LAC Policy.
Student with SEND
When managing safeguarding in relation to Student with SEND, staff will be aware of the following:
When reporting concerns or making referrals for students with SEND, the above factors will always be taken into consideration. When managing a safeguarding issue relating to a Student with SEND, the DSL will liaise with the school’s SENCO, as well as the student’s parents where appropriate, to ensure that the student’s needs are met effectively.
LGBTQ+ Students
The fact that a student may be LGBTQ+ is not in itself an inherent risk factor for harm; however, staff will be aware that LGBTQ+ Student can be targeted by other individuals. Staff will also be aware that, in some cases, a student who is perceived by others to be LGBTQ+ (whether they are or not) can be just as vulnerable as student who identify as LGBTQ+.
Staff will also be aware that the risks to these students can be compounded when they do not have a trusted adult with whom they can speak openly with. Staff will endeavour to reduce the additional barriers faced by these Student and provide a safe space for them to speak out and share any concerns they have.
Student requiring mental health support
All staff will be made aware that mental health problems can, in some cases, be an indicator that a student has suffered, or is at risk of suffering, abuse, neglect or exploitation.
Where the governing board or board of directors hires or rents out school facilities or the school premises to organisations or individuals, e.g. for providers to run community or extracurricular activities, it will ensure that appropriate safeguarding arrangements are in place to keep students safe.
At present GEM Hereford does not rent out facilities. This may change in the future as the school expands to a second site. Therefore, the following guidance has been included.
The school will refer to the DfE’s guidance on keeping children safe in out-of-school settings in these circumstances.
Where the governing board provides the activities under the direct supervision or management of school staff, child protection arrangements will apply. Where activities are provided separately by another body, this may not be the case; therefore, the governing board will seek assurance that the body concerned has appropriate safeguarding and child protection policies and procedures in place, including inspecting these as needed. The governing board will also ensure that there are arrangements in place to liaise with the school on these matters where appropriate. The governing board will ensure safeguarding requirements are included in any transfer of control agreement, i.e. a lease or hire agreement, as a condition of use and occupation of the premises and specify that failure to comply with this would lead to termination of the agreement.
Extracurricular activities and clubs
External bodies that host extracurricular activities and clubs at the school, e.g. charities or companies, will work in collaboration with the school to effectively safeguard students and adhere to local safeguarding arrangements.
Staff and volunteers running extracurricular activities and clubs are aware of their safeguarding responsibilities and promote the welfare of students. Paid and volunteer staff understand how they should respond to child protection concerns and how to make a referral to CSCS or the police, if necessary.
All national governing bodies of sport that receive funding from either Sport England or UK Sport must aim to meet the Standards for Safeguarding and Protecting Children in Sport.
The school will remain responsible for a student’s welfare during their time at an alternative provider.
When placing a student with an alternative provider, the school will obtain written confirmation that the provider has conducted all relevant safeguarding checks on staff.
When a student is sent on work experience, the school will ensure that the provider has appropriate safeguarding policies and procedures in place. Where the school has students conduct work experience at the school, an enhanced DBS check will be obtained if the student is over the age of 16.
School-arranged homestays in UK
Where the school is arranging for a visiting child to be provided with care and accommodation in the UK in the home of a family to which the child is not related, the responsible adults are considered to be in regulated activity for the period of the stay. In such cases, the school is the regulated activity provider; therefore, the school will obtain all the necessary information required, including a DBS enhanced certificate with barred list information, to inform its assessment of the suitability of the responsible adults.
Where criminal record information is disclosed, the school will consider, alongside all other information, whether the adult is a suitable host. In addition to the responsible adults, the school will consider whether a DBS enhanced certificate should be obtained for anyone else aged over 16 in the household.
School-arranged homestays abroad
The school will liaise with partner schools to discuss and agree the arrangements in place for the visit. The school will consider, on a case-by-case basis, whether to contact the relevant foreign embassy or High Commission of the country in question to ascertain what checks may be possible in respect of those providing homestay outside of the UK. The school will use its professional judgement to assess whether the arrangements are appropriate and sufficient to safeguard every child involved in the exchange. Students will be provided with emergency contact details to use where an emergency occurs, or a situation arises that makes them feel uncomfortable. This is covered in the updated trips and visits policy.
Privately arranged homestays
Where a parent or student arranges their own homestay, this is a private arrangement and the school is not the regulated activity provider.
Private fostering
Where a period of UK homestay lasts 28 days or more for a child aged under 16, or under 18 for a child with SEND, this may amount to private fostering under the Children Act 1989. Where the school becomes aware of a student being privately fostered, they will notify the LA as soon as possible to allow the LA to conduct any necessary checks.
If a member of staff has any concern about a student’s welfare, or a student has reported a safeguarding concern in relation to themselves or a peer, they will act on them immediately by speaking to the DSL or deputy DSLs.
Staff will be aware that a student may not feel ready or know how to tell someone that they are being abused, exploited or neglected, and/or they may not recognise their experiences as harmful. Staff will be aware that this must not prevent them from having professional curiosity and speaking to the DSL, or deputy DSL, if they have a concern about a student.
All staff members are aware of the procedure for reporting concerns and understand their responsibilities in relation to confidentiality and information sharing, as outlined in the communication and confidentiality section of this policy.
Where the DSL is not available to discuss the concern, staff members will contact the deputy DSLs with the matter. If a referral is made about a student by anyone other than the DSL, the DSL will be informed as soon as possible.
The LA will make a decision regarding what action is required within one working day of the referral being made and will notify the referrer. Staff are required to monitor a referral if they do not receive information from the LA regarding what action is necessary for the student. If the situation does not improve after a referral, the DSL will ask for reconsideration to ensure that their concerns have been addressed and that the situation improves for the student.
If early help is appropriate, the case will be kept under constant review. If the student’s situation does not improve, a referral will be considered. All concerns, discussions and decisions made, as well as the reasons for making those decisions, will be recorded in writing by the DSL and kept securely on ‘Safeguard my school’ (online safeguarding software).
If a student is in immediate danger, a referral will be made to CSCS and/or the police immediately. If a student has committed a crime, such as sexual violence, the police will be notified without delay.
Where there are safeguarding concerns, the school will ensure that the student’s wishes are always taken into account, and that there are systems available for a student to provide feedback and express their views. When responding to safeguarding concerns, staff members will act calmly and supportively, ensuring that the student feels like they are being listened to and believed.
An inter-agency assessment will be undertaken where a child and their family could benefit from coordinated support from more than one agency. These assessments will identify what help the child and family require in preventing needs escalating to a point where intervention would be needed.
The school will consider whether a family group decision-making forum is appropriate to determine the help and support the family network can provide for a student where concerns have been raised about their safety or wellbeing.
Managing referrals
The reporting and referral process outlined in the Reporting Safeguarding Concerns Flowchart will be followed accordingly.
All staff members, in particular the DSL, will be aware of the LA’s arrangements in place for managing referrals. The DSL will provide staff members with clarity and support where needed. When making a referral to CSCS or other external agencies, information will be shared in line with confidentiality requirements and will only be shared where necessary to do so.
The DSL will work alongside external agencies, maintaining continuous liaison, including multi-agency liaison where appropriate, in order to ensure the wellbeing of the student involved. The DSL will work closely with the police to ensure the school does not jeopardise any criminal proceedings, and to obtain help and support as necessary.
Where a student has been harmed or is in immediate danger or at risk of harm, the referrer will be notified of the action that will be taken within one working day of a referral being made. Where this information is not forthcoming, the referrer will contact the assigned social worker for more information.
The school will not wait for the start or outcome of an investigation before protecting the victim and other Student: this applies to criminal investigations as well as those made by CSCS. Where CSCS decide that a statutory investigation is not appropriate, the school will consider referring the incident again if it is believed that the student is at risk of harm. Where CSCS decide that a statutory investigation is not appropriate and the school agrees with this decision, the school will consider the use of other support mechanisms, such as early help and pastoral support.
At all stages of the reporting and referral process, the student will be informed of the decisions made, actions taken and reasons for doing so. Discussions of concerns with parents will only take place where this would not put the student or others at potential risk of harm. The school will work closely with parents to ensure that the student, as well as their family, understands the arrangements in place, such as in-school interventions, is effectively supported, and knows where they can access additional support.
Any concerns regarding the safeguarding practices at the school will be raised with the SLT, and the necessary whistleblowing procedures will be followed, as outlined in the Whistleblowing Policy. If a staff member feels unable to raise an issue with the SLT, they should access other whistleblowing channels such as the NSPCC whistleblowing helpline (0800 028 0285).
All allegations against staff, supply staff, volunteers and contractors will be managed in line with the school’s Allegations of Abuse Against Staff Policy, a copy of which will be provided to, and understood by, all staff. The school will ensure all allegations against staff, including those who are not employees of the school, are dealt with appropriately and that the school liaises with the relevant parties.
When managing allegations against staff, the school will recognise the distinction between allegations that meet the harms threshold and allegations that do not, also known as “low-level concerns”, as defined in the Allegations of Abuse Against Staff Policy. Allegations that meet the harms threshold include instances where staff have:
Low-level concerns will be handled in line with the schools’ Low-level Safeguarding Concerns Policy.
All child protection and safeguarding concerns will be treated in the strictest of confidence in accordance with school data protection policies.
Where there is an allegation or incident of sexual abuse or sexual violence, the victim is entitled to anonymity by law; therefore, the school will consult its policy and agree on what information will be disclosed to staff and others, in particular the alleged perpetrator and their parents. Where a report of sexual violence or sexual harassment is progressing through the criminal justice system, the school will do all it can to protect the anonymity of the student involved in the case.
Concerns will only be reported to those necessary for its progression and reports will only be shared amongst staff members and with external agencies on a need-to-know basis. During the disclosure of a concern by a student, staff members will not promise the student confidentiality and will ensure that they are aware of what information will be shared, with whom and why.
Where it is in the public interest, and protects student from harm, information can be lawfully shared without the victim’s consent, e.g. if doing so would assist the prevention, detection or prosecution of a serious crime. Before doing so, the DSL will weigh the victim’s wishes against their duty to protect the victim and others. Where a referral is made against the victim’s wishes, it is done so carefully with the reasons for the referral explained to the victim and specialist support offered.
Depending on the nature of a concern, the DSL will discuss the concern with the parents of the student involved. Discussions with parents will not take place where they could potentially put a student at risk of harm. Discussion with the victim’s parents will relate to the arrangements being put in place to safeguard the victim, with the aim of understanding their wishes in terms of support arrangements and the progression of the report. Discussion with the alleged perpetrator’s parents will have regards to the arrangements that will impact their child, such as moving classes, with the reasons behind decisions being explained and the available support discussed. External agencies will be invited to these discussions where necessary.
Where confidentiality or anonymity has been breached, the school will implement the appropriate disciplinary procedures as necessary and will analyse how damage can be minimised and future breaches be prevented.
Where a student is leaving the school, the DSL will consider whether it is appropriate to share any information with the Student’s new provider, in addition to the child protection file, that will allow the new provider to support the Student and arrange appropriate support for their arrival.
The school’s full policy and procedures for safer recruitment are outlined in the Safer Recruitment Policy.
An enhanced DBS check with barred list information will be undertaken for all staff members engaged in regulated activity. A person will be considered to be in ‘regulated activity’ if, as a result of their work, they:
The DfE’s DBS Workforce Guides will be consulted when determining whether a position fits the child workforce criteria.
The governing board and board of directors will conduct the appropriate pre-employment checks for all prospective employees, including internal candidates and candidates who have lived or worked outside the UK.
The appropriate DBS and suitability checks will be carried out for all governors, volunteers, and contractors.
The school keeps an SCR which records all staff, including agency and third-party supply staff, and teacher trainees on salaried routes, who work at the school.
All members of the proprietor body are also recorded on the SCR.
The following information is recorded on the SCR:
For agency and third-party supply staff, the school will also record whether written confirmation from the employment business supplying the member of staff has been received which indicates that all the necessary checks have been conducted (i.e. all the same checks the school would perform on any individual working in the school or who will be providing education on the school’s behalf, including through online delivery) and the date that confirmation was received.
If any checks have been conducted for volunteers, this will also be recorded on the SCR. If risk assessments are conducted to assess whether a volunteer should be subject to an enhanced DBS check, the risk assessment will be recorded.
Written confirmation that supply agencies have completed all relevant checks will also be included.
The school is free to record any other information it deems relevant.
The details of an individual will be removed from the SCR once they no longer work at the school.
Staff members will undergo safeguarding and child protection training at induction, which will be updated on a yearly basis and/or whenever there is a change in legislation.
The induction training will cover:
All staff members will also receive regular safeguarding and child protection updates as required, but at least annually. Training will cover, at a minimum:
Staff will receive opportunities to contribute towards and inform the safeguarding arrangements in the school.
The DSL and deputy DSLs will undergo child protection and safeguarding training, and update this training at least every two years. The DSL and deputy DSLs will also obtain access to resources and attend any relevant or refresher training courses, ensuring they keep up-to-date with any developments relevant to their role. This will include training to understand:
This policy is reviewed at least annually by the DSL, headteacher, governors and board of directors.
This policy will be updated as needed to ensure it is up-to-date with safeguarding issues as they emerge and evolve, including any lessons learnt.
Changes will be noted on the rubric on the front cover of this document.
This appendix sets out details about specific safeguarding issues that a student may experience and outlines specific actions that would be taken in relation to individual issues.
Here are the issues covered:
Domestic abuse
For the purposes of this policy, and in line with the Domestic Abuse Act 2021, “domestic abuse” is defined as abusive behaviour of a person towards another person (including conduct directed at someone else, e.g. the person’s child) where both are aged 16 or over and are personally connected.
“Abusive behaviour” includes physical or sexual abuse, violent or threatening behaviour, controlling or coercive behaviour, economic abuse, psychological or emotional abuse, or another form of abuse.
“Personally connected” includes people who:
The school will recognise the impact of domestic abuse on children, as victims in their own right, if they see, hear or experience the effects of domestic abuse. All staff will be aware of the signs of domestic abuse and follow the appropriate safeguarding procedures where concerns arise.
Homelessness
The DSL and deputy DSLs will be aware of the contact details and referral routes into the Local Housing Authority so that concerns over homelessness can be raised as early as possible.
Indicators that a family may be at risk of homelessness include:
Referrals to the Local Housing Authority do not replace referrals to CSCS where a child is being harmed or at risk of harm. For 16- and 17-year-olds, homelessness may not be family-based and referrals to CSCS will be made as necessary where concerns are raised.
Children absent from education
A child who is absent from school can be a vital warning sign of a range of safeguarding issues, including neglect, CSE and CCE, particularly county lines. The school will ensure that the response to children persistently being absent from education supports identifying such abuse and helps prevent the risk of Student becoming absent from education in the future. Staff will monitor Student that are absent from the school, particularly on repeat occasions and/or prolonged periods, and report them to the DSL following normal safeguarding procedures, in accordance with the Children Missing from Education Policy. The school will inform the LA of any Student who fails to attend regularly or has been absent without the school’s permission for a continuous period of 10 school days or more.
The school will follow the DfE’s guidance on improving attendance where there is a need to work with children’s services due to school absences indicating safeguarding concerns.
Admissions register
Students are placed on the admissions register at the beginning of the first day that is agreed by the school, or when the school has been notified that the student will first be attending. The school will notify the LA within 5 days of when a student’s name is added to the admissions register.
The school will ensure that the admissions register is kept up-to-date and accurate at all times and will inform parents when any changes occur. Two emergency contacts will be held for each Student where possible. Staff will monitor students who do not attend the school on the agreed date and will notify the LA at the earliest opportunity.
If a parent notifies the school that their child will live at a different address, the school will record the following information on the admissions register:
If a parent notifies the school that their child will be attending a different school, or is already registered at a different school, the following information will be recorded on the admissions register:
Where a student moves to a new school, the school will use a secure internet system to securely transfer Student’ data.
To ensure accurate data is collected to allow effective safeguarding, the school will inform the LA of any Student who is going to be deleted from the admission register, in accordance with the Education (Student Registration) (England) Regulations 2006 (as amended), where they:
The school will also remove a student from the admissions register where the school and LA has been unable to establish the student’s whereabouts after making reasonable enquiries into their attendance.
If a student is to be removed from the admissions register, the school will provide the LA with the following information:
The school will work with the LA to establish methods of making returns for Student back into the school. The school will highlight to the LA where they have been unable to obtain necessary information from parents, e.g. where an address is unknown. The school will also highlight any other necessary contextual information, including safeguarding concerns.
Child abduction and community safety incidents
For the purposes of this policy, “child abduction” is defined as the unauthorised removal or retention of a child from a parent or anyone with legal responsibility for the child. Child abduction can be committed by parents and other relatives, other people known to the victim, and strangers.
All staff will be alert to community safety incidents taking place in the vicinity of the school that may raise concerns regarding child abduction, e.g. people loitering nearby or unknown adults conversing with Student.
Students will be provided with practical advice and lessons to ensure they can keep themselves safe outdoors.
Child criminal exploitation (CCE)
For the purposes of this policy, “child criminal exploitation” is defined as a form of abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into taking part in criminal activity, for any of the following reasons:
Specific forms of CCE can include:
The school will recognise that Student involved in CCE are victims themselves, regardless of whether they have committed crimes, and even if the criminal activity appears consensual. The school will also recognise that a student of any gender are at risk of CCE.
School staff will be aware of the indicators that a student is the victim of CCE, including:
County lines
For the purposes of this policy, “county lines” refers to gangs and organised criminal networks exploiting children to move, store or sell drugs and money into one or more areas, locally and/or across the UK.
As well as the general indicators for CCE, school staff will be aware of the specific indicators that a student may be involved in county lines, including:
Staff will be made aware of Student with missing episodes who may have been trafficked for the purpose of transporting drugs. Staff members who suspect a student may be vulnerable to, or involved in, county lines activity will immediately report all concerns to the DSL.
The DSL will consider referral to the National Referral Mechanism on a case-by-case basis and consider involving local services and providers who offer support to victims of county lines exploitation.
Cyber-crime
For the purposes of this policy, “cyber-crime” is defined as criminal activity committed using computers and/or the internet. This includes ‘cyber-enabled’ crimes, i.e. crimes that can happen offline but are enabled at scale and at speed online, and ‘cyber-dependent’ crimes, i.e. crimes that can be committed only by using a computer. Crimes include:
All staff will be aware of the signs of cyber-crime and follow the appropriate safeguarding procedures where concerns arise. This may include the DSL referring Student to the National Crime Agency’s Cyber Choices programme.
Child sexual exploitation (CSE)
For the purposes of this policy, “child sexual exploitation” is defined as a form of sexual abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity, for any of the following reasons:
The school will recognise that CSE can occur over time or be a one-off occurrence, and may happen without the student’s immediate knowledge, e.g. through others sharing videos or images of them on social media. The school will recognise that CSE can affect any student who has been coerced into engaging in sexual activities, even if the activity appears consensual; this includes Student aged 16 and above who can legally consent to sexual activity. The school will also recognise that a student may not realise they are being exploited, e.g. they believe they are in a genuine romantic relationship.
School staff will be aware of the key indicators that a student is the victim of CSE, including:
All concerns related to CSE will be managed in line with the school’s Child Sexual Exploitation (CSE) Policy.
Where CSE, or the risk of it, is suspected, staff will discuss the case with the DSL. If after discussion a concern remains, local safeguarding procedures will be triggered, including referral to the LA. The LA and all other necessary authorities will then handle the matter to conclusion. The school will cooperate as needed.
Modern slavery
For the purposes of this policy, “modern slavery” encompasses human trafficking and slavery, servitude, and forced or compulsory labour. This can include CCE, CSE, and other forms of exploitation.
All staff will be aware of and alert to the signs that a student may be the victim of modern slavery. Staff will also be aware of the support available to victims of modern slavery and how to refer them to the National Referral Mechanism.
FGM
For the purposes of this policy, “FGM” is defined as all procedures involving the partial or total removal of the external female genitalia or other injury to the female genital organs. FGM is illegal in the UK and a form of child abuse with long-lasting harmful consequences.
All staff will be alert to the possibility of a student being at risk of FGM, or already having suffered FGM. If staff are worried about someone who is at risk of FGM or who has been a victim of FGM, they are required to share this information with CSCS and/or the police. The school’s procedures relating to managing cases of FGM and protecting Student will reflect multi-agency working arrangements.
As outlined in Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime Act 2015), teachers are legally required to report to the police any discovery, whether through disclosure by the victim or visual evidence, of FGM on a Student under the age of 18. Teachers failing to report such cases may face disciplinary action. Teachers will not examine Student, and so it is rare that they will see any visual evidence, but they must personally report to the police where an act of FGM appears to have been carried out. Unless the teacher has a good reason not to, they should also consider and discuss any such case with the DSL and involve CSCS as appropriate. NB: This does not apply to any suspected or at-risk cases, nor if the individual is over the age of 18. In such cases, local safeguarding procedures will be followed.
All staff will be aware of the indicators that a student may be at risk of FGM. While some individual indicators they may not indicate risk, the presence of two or more indicators could signal a risk to the student. It is important to note that a student may not yet be aware of the practice or that it may be conducted on them, so staff will be sensitive when broaching the subject.
Indicators that a student may be at heightened risk of undergoing FGM include:
Indicators that FGM may take place soon include:
All staff will be vigilant to the signs that FGM has already taken place so that help can be offered, enquiries can be made to protect others, and criminal investigations can begin. Indicators that FGM may have already taken place include the student:
FGM is included in the definition of so-called “‘honour-based’ abuse (HBA)”, which involves crimes that have been committed to defend the honour of the family and/or community. All forms of HBA are forms of abuse and will be treated and escalated as such. Staff will be alert to the signs of HBA, including concerns that a child is at risk of HBA, or has already suffered from HBA, and will consult with the DSL who will activate local safeguarding procedures if concerns arise.
Virginity testing and hymenoplasty
Under the Health and Care Act 2022, it is illegal to carry out, offer or aid and abet virginity testing or hymenoplasty in any part of the UK. It is also illegal for UK nationals and residents to do these things outside the UK.
Virginity testing - Also known as hymen, ‘2-finger’ or vaginal examination, this is defined as any examination (with or without contact) of the female genitalia intended to establish if vaginal intercourse has taken place. This is irrespective of whether consent has been given. Vaginal examination has no established scientific merit or clinical indication.
Hymenoplasty - A procedure which can involve a number of different techniques, but typically involving stitching or surgery, undertaken to reconstruct a hymen with the intent that the person bleeds the next time they have vaginal intercourse. Hymenoplasty is different to procedures that may be performed for clinical reasons, e.g. surgery to address discomfort or menstrual complications.
Virginity testing and hymenoplasty are forms of violence against women and girls and are part of the cycle of HBA, and can be precursors to child or forced marriage and other forms of family and/or community coercive behaviours, including physical and emotional control. Victims are pressurised into undergoing these procedures, often by family members or their intended husbands’ family to fulfil the requirement that a woman remains ‘pure’ before marriage. Those who ‘fail’ to meet this requirement are likely to suffer further abuse, including emotional and physical abuse, disownment and even honour killings.
The procedures are degrading and intrusive, and can result in extreme psychological trauma, provoking conditions such as anxiety, depression and PTSD, as well as physical harm and medical complications. Staff will be alert to the possible presence of stress, anxiety and other psychological or behavioural signs, and mental health support should be made available where appropriate.
Victims face barriers in coming forward, e.g. they may not know that the abuse was abnormal or wrong at the time, and may feel shameful, having been taught that speaking out against family and/or the community is wrong, or being scared about the repercussions of speaking out. The school will educate Student about the harms of these practices and dispel myths, e.g. the belief that virginity determines the worth of a woman, and establish an environment where Student feel safe enough to make a disclosure.
Student aged 13 and older are considered to be most at risk, but it can affect those as young as 8, and anyone with female genitalia can be a victim regardless of age, gender identity, ethnicity, sexuality, religion, disability or socioeconomic status. All staff will be aware of the following indicators that a student is at risk of or has been subjected to a virginity test and/or hymenoplasty:
The above list is not exhaustive, but if any of these indicators are identified, staff members will immediately raise concerns with the DSL. An assessment of the risk they face will be undertaken. If there is believed to be immediate danger, the police will be contacted without delay.
The school will not involve families and community members in cases involving virginity testing and hymenoplasty, including trying to mediate with family or using a community member as an interpreter, as this may increase the risk of harm to the student, including expediting arrangements for the procedure.
Forced marriage
Forced marriage is a crime. It is a form of abuse directed towards a child or vulnerable adult, including adults who are forced into marriage against their free will.
Forced marriage is a marriage where one or both spouses do not consent to the marriage but are coerced into it. Force can be physical, psychological, financial, sexual and emotional pressure. Forced marriage can be committed if a person lacks capacity, whether or not coercion plays a part.
Under the Anti-social Behaviour, Crime and Policing Act 2014 a person commits an offence if he or she uses violence, threats or any other form of coercion for the purpose of causing another person to enter into a marriage and believes, or ought reasonably to believe, that the conduct may cause the other person to enter into the marriage without free and full consent.
It is an offence to do anything intended to cause a child to marry before the child’s eighteenth birthday, whether or not the conduct amounts to violence, threats, or any other form of coercion or deception. This applies to non-binding, unofficial ‘marriages’ as well as legal marriages.
All staff will be alert to the indicators that a student is at risk of, or has undergone, forced marriage, including, but not limited to, the student:
Staff who have any concerns regarding a student who may have undergone, is currently undergoing, or is at risk of forced marriage will speak to the DSL or headteacher and local safeguarding procedures will be followed – this could include referral to CSCS, the police or the Forced Marriage Unit. The DSL or headteacher will ensure the student is spoken to privately about these concerns and further action taken as appropriate. Student will always be listened to and have their comments taken seriously.
It will be made clear to staff members that they should not approach the student’s family or those with influence in the community, without the express consent of the student, as this will alert them to the concerns and may place the student in further danger.
Advice will be sought from the Forced Marriage Unit following any suspicion of forced marriage among students.
If a student is being forced to marry, or is fearful of being forced to, the school will be especially vigilant for signs of mental health disorders and self-harm. The student will be supported by the DSL and senior mental health lead and referrals will be made on a case-by-case basis.
Staff members will make themselves aware of how they can support victims of forced marriage in order to respond to the victims needs at an early stage and be aware of the practical help they can offer, e.g. referral to social services and local and national support groups.
Local child safeguarding procedures will be activated following concerns regarding forced marriage – the school will use existing national and local protocols for multi-agency liaison with police and children’s social care.
The school will support any victims to seek help by:
The school will establish where possible whether Student at risk of forced marriage have a dual nationality or two passports.
The school will aim to create an open environment where Student feel comfortable and safe to discuss the problems they are facing – this means creating an environment where forced marriage is discussed openly within the curriculum and support and counselling are provided routinely.
The school will take a whole school approach towards educating on forced marriage in the school curriculum and environment – in particular, the school’s RSHE curriculum will incorporate teaching about the signs of forced marriage and how to obtain help. Appropriate materials and sources of further support will be signposted to the student. Student’s will be encouraged to access appropriate advice, information and support.
Teachers and other staff members will be educated through CPD about the issues surrounding forced marriage and the signs to look out for.
Radicalisation
For the purposes of this policy, “radicalisation” refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.
For the purposes of this policy, “extremism” refers to the vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty, and the mutual respect and tolerance of different faiths and beliefs. Extremism also includes calling for the death of members of the armed forces.
For the purposes of this policy, “terrorism” refers to an action that endangers or causes serious violence to a person or people, serious damage to property, or seriously interferes with or disrupts an electronic system. The use or threat of these actions must be designed to influence the government or intimidate the public, and be made for the purpose of advancing a political, religious or ideological cause.
Protecting Student from the risk of radicalisation is part of the school’s wider safeguarding duties. The school will actively assess the risk of Student being radicalised and drawn into extremism and/or terrorism. Staff will be alert to changes in Student’ behaviour which could indicate that they may need help or protection. Staff will use their professional judgement to identify Student who may be susceptible to extremist ideologies and radicalisation and act appropriately, which may include contacting the DSL or making a Prevent referral. The school will work with local safeguarding arrangements as appropriate.
The school will ensure that they engage with parents and families, as they are in a key position to spot signs of radicalisation. In doing so, the school will assist and advise family members who raise concerns and provide information for support mechanisms. Any concerns over radicalisation will be discussed with the student’s parents, unless the school has reason to believe that the child would be placed at risk as a result.
The DSL will undertake Prevent awareness training to be able to provide advice and support to other staff on how to protect Student against the risk of radicalisation. The DSL will hold formal training sessions with all members of staff to ensure they are aware of the risk indicators and their duties regarding preventing radicalisation.
The Prevent duty
Under section 26 of the Counter-Terrorism and Security Act 2015, all schools are subject to a duty to have “due regard to the need to prevent people from being drawn into terrorism”, known as “the Prevent duty”. The Prevent duty will form part of the school’s wider safeguarding obligations.
The school’s procedures for carrying out the Prevent duty, including how it will engage and implement the Channel programme, are outline in the Prevent Duty Policy.
Student with family members in prison
Students with a family member in prison will be offered pastoral support as necessary. They will receive a copy of ‘Are you a young person with a family member in prison?’ from Action for Prisoners’ Families where appropriate and allowed the opportunity to discuss questions and concerns.
Student required to give evidence in court
Student required to give evidence in criminal courts, either for crimes committed against them or crimes they have witnessed, will be offered appropriate pastoral support.
Student will be provided with the booklet ‘Going to Court and being a witness’ from HMCTS where appropriate and allowed the opportunity to discuss questions and concerns.
Mental health
All staff will be made aware that mental health problems can, in some cases, be an indicator that a student has suffered, or is at risk of suffering, abuse, neglect or exploitation.
Staff will not attempt to make a diagnosis of mental health problems – the school will ensure this is done by a trained mental health professional. Staff will, however, be encouraged to identify Student whose behaviour suggests they may be experiencing a mental health problem or may be at risk of developing one. Staff will also be aware of how Student’ experiences can impact on their mental health, behaviour, and education.
Staff who have a mental health concern about a student that is also a safeguarding concern will act in line with this policy and speak to the DSL or deputy DSLs.
The school will access a range of advice to help them identify student’s in need of additional mental health support, including working with external agencies.
In all cases of mental health difficulties, the school’s Social, Emotional and Mental Health (SEMH) Policy will be consulted and adhered to at all times.
Serious violence
Through training, all staff will be made aware of the indicators which may signal a student is at risk from, or is involved with, serious violent crime. These indicators include, but are not limited to:
Staff will be made aware of some of the most significant risk factors that could increase a student’s vulnerability to becoming involved in serious violence. These risk factors include, but are not limited to:
Staff members who suspect a student may be vulnerable to, or involved in, serious violent crime will immediately report their concerns to the DSL.
The school will cooperate with core duty holders when asked and ensure arrangements are in place to do so.
Adult involvement in youth-produced sexual imagery
The school’s full response to youth-produced sexual imagery (YPSI) is outlined below:
Sexually motivated incidents
The school will remain aware that not all instances of YPSI will be between children and young people, and in some cases may involve adults posing as a child for the purpose of obtaining nude and semi-nude images from persons under 18.
Staff will be aware of the signs that an adult is involved in the sharing the nude or semi-nude images.
These include:
Financially motivated incidents
Financially motivated incidents of YPSI involving adults may also be called “sextortion”, where the offender threatens to release nudes or semi-nudes of a child or young person unless they do something to prevent it, e.g. paying money. In these cases, offenders often pose as children and:
Staff will be aware of the signs of sextortion, which include:
