Safeguarding Children & Vulnerable Adults and Prevent Policy

Responsible Manager Safeguarding Manager
Publish Date MAR-23
Last Review Date FEB-24
Next Scheduled Review Date FEB-25
Policy available SharePoint  /  Website
Authorised by People Manager. Learning Services Manager.

Contents

 

Flowchart – Safeguarding Concern Reporting For NMT Employees

Safeguarding Concern Reporting (Staff) Flowchart
Safeguarding Incident Reporting (Staff) Flowchart

1.    Introduction

  • New Meaning Training (NMT) acknowledges its duty of care to safeguard and promote the well-being of all learners, staff and visitors. NMT are committed to providing a safe and secure environment and to promoting an atmosphere that is conducive to learning and personal development.
  • This policy is aligned with national legislation, including but not limited to:
  • Buckinghamshire Council
  • Buckinghamshire Children’s Safeguarding Partnership
  • Buckinghamshire Safeguarding Adults Board Procedures,
  • Working Together to Keeping Children Safe in Education (KCSIE) 2023
  • The Children Act 1989 (and 2004 amendment), as amended by the Children and Social Work Act 2017.
  • Care Act 2014
  • Working Together to Safeguard Children 2018
  • Education Act 2002 section 157
  • Education and Training (Welfare of Children) Act 2021
  • Schedule 4 of the Safeguarding Vulnerable Groups Act 2006
  • Statutory guidance on the Prevent duty under the Counterterrorism and Security Act 2015.
  • The Equality Act 2010 and the Special educational needs and disability (SEND) code of practice: HM Government 2014
  • Data Protection Act 2018 and General Data Information Protection Regulations
  • Through this policy NMT aims to:
  • Ensure that the college provides a physically and emotionally safe environment for all learners, staff and visitors.
  • Adhere to national and local legislation, regulations, and guidelines related to safeguarding, ensuring the centres practices follow legal standards.
  • Establish and communicate clear roles and responsibilities.
  • Encourage Reporting and Disclosure in line with policies and procedure.
  • Ensure that individuals who report concerns are provided with appropriate support and assistance, and that investigations are conducted with sensitivity and confidentiality.
  • Encourage collaboration among learners, staff, parents, and external partners to build a network of support and expertise for safeguarding initiatives.
  • Ahere to Safe Recruitment policy and procedures.
  • Provide ongoing training and support to ensure all NMT staff are knowledgeable regarding safeguarding issues and equipped to report and respond appropriately.
  • Regularly review and evaluate the effectiveness of safeguarding policies and practices, adjusting appropriately to ensure continuous improvement.
  • Uphold the well-being of learners and staff by addressing both physical safety, mental health concerns, emotional well-being, and social development.

2.    Safeguarding Roles and Responsibilities

 

2.1 All NMT Staff

  • NMT will ensure safe recruitment policy and procedure are followed for all employees.
  • L2 Safeguarding training for all new employees (renewed every 3 years)
  • Prevent Duty training for all new employees (renewed every 2 years)
  • Safeguarding reporting software training for all new employees
  • Ongoing safeguarding training (all staff training days once per half term)
  • Keep all staff updated with emerging safeguarding themes and provide specific training accordingly.

2.2 Designated Safeguarding Team

  • The Safeguarding manger is the Designated Safeguarding Lead (DSL) who is assisted by a team of Additional Designated Safeguarding Leads (ADSLs), to make up the senior safeguarding team. All understand and fulfil their safeguarding responsibilities which include:
  • Create and maintain a strong, positive culture of safeguarding within NMT, including a zero-tolerance approach to abuse.
  • Acting as a focal point for staff and learners to discuss and share concerns.
  • Ensure this policy reflects the unique features and needs of the community NMT serves.
  • Review and amend the policy as appropriate, annually as a minimum.
  • Be available to provide advice and support to staff on Safeguarding and Prevent issues.
  • Hold a DSL level 4 certificate and attend refresher training every 2 years.
  • Refresh knowledge and skills regularly for continual professional development.
  • Maintain safe and effective recruitment and disciplinary policies.
  • Ensure robust filtering and monitoring systems are in place for online activities.
  • Maintain up to date records, stored safely, securely confidentially.
  • Meet bi-monthly as a team to share oversight of safeguarding provision within the setting, to monitor performance and to develop plans for continued professional development.
  • It is the duty of the NMT DSL, to notify and liaise with the Local Authority Designated Officer (LADO) where there are allegations made against any NMT employee. In the absence of the DSL, this responsibility will fall to another member of the safeguarding team. There will always be an internal investigation when there is an allegation against any member staff. Should there be an allegation against the People’s Manager, this duty falls to the NMT CEO. If an issue is not progressing in an expedient manner, contact:  safeguarding@buckscollegegroup.ac.uk

3.    Learner Support and Well-being

  • NMT will provide a supportive and confidential environment for learners to discuss concerns about their well-being. Tutors are responsible for monitoring the progress and well-being of the learners, and reporting concerns. Learners can self-refer to the senior safeguarding team either in person or via the contact telephone number 07746 218 834 or email safeguarding@newmeaning.co.uk These details are displayed in each centre and are provided at enrolment in the learner handbook. All safeguarding concerns will be recorded on CPOMS.

4         Reporting Procedures

  • All staff members must report safeguarding concerns using the CPOMS portal at the earliest opportunity. All NMT employees are provided with training as to who incidents are to be assigned on CPOMS. For any areas of uncertainty, a call should be made to the Area Manager or DSL.
  • All concern/referral forms/emails will be added to and assigned to the Area Manager on CPOMS. This will alert the Senior Safeguarding Team. All reports should include information detailed in Appendix 1.
  • The Senior Safeguarding Team will assess concerns, fact find, take appropriate action, and update the incident record.
  • NMT will work in partnership with external agencies to ensure the best outcomes for learners.
  • Where any learner is absent tutors will contact parent/carer on the first day of absence.
  • Where any learner is absent for two consecutive education days, without communication or satisfactory explanation, the Area Manager or Administrator try to locate the learner / establish their whereabouts. This will be reported on CPOMS.
  • Where any learner is absent and uncontactable for ten consecutive education days, this will be reported to the Local Authority as a Child Missing in Education (CME).
  • For learners under 16 who remain on roll with a secondary school while working with NMT, the overall responsibility for their safeguarding remains with the school. For learners under 16 who’s place with NMT is directly funded by the Local Authority, the overall responsibility for their safeguarding remains with the Local Authority. Neither of these circumstances negate the responsibility placed on NMT staff to act immediately and appropriately if a disclosure is made or a concern is raised. The school/Local Authority must be informed immediately to ensure a collaborative and transparent approach. The first point of contact is the Area Manager who will escalate the concern.

5         Prevent Duty

  • The Prevent Duty is part of NMTs wider safeguarding obligations. The Safeguarding Team should familiarise themselves with the revised Prevent Duty guidance: for England and Wales, especially paragraphs 57-76, which are specifically concerned with schools (and also covers childcare).
  • The guidance is set out in terms of four general themes: risk assessment, working in partnership, staff training, and IT policies. There is additional guidance – Prevent Duty guidance: for further education institutions in England and Wales, that applies to Further Education.
  • All extremists aim to develop destructive relationships between different communities by promoting division, fear and mistrust of others based on ignorance or prejudice, thereby limiting the life chances of young people. Education is a powerful weapon against this; equipping young people with the knowledge, skills and critical thinking, to challenge and debate in an informed way.
  • NMT Staff are aware of the Prevent Duty to protect young people from radicalisation, idealisation and extremism. At NMT this is recognised as a safeguarding matter, as such NMT will take action and report via local authority Prevent referral. NMT will ensure that procedure is followed as directed by the Local Authority, Prevent Co-Ordinator, Police, Social Care and any other agency necessary to safeguard that learner and others. NMT employees receive Prevent training annually. DLSs have Safeguarding and Prevent training which includes procedures for reporting via local authority Prevent referral form.
  • Details of the measures in place at NMT regarding attempts made to view material potentially relating to radicalisation, idealisation and extremism can be found in the Filtering and Monitoring Policy.

6         Confidentiality

  • For the purposes of keeping learners safe, the Data Protection Act 2018 and GDPR do not prevent the sharing of information. Fears about sharing information must not be allowed to stand in the way of the need to safeguard, protect, promote the welfare and protect the safety of learners. NMT hold all personal information securely.

 

7         Communication and Awareness

 

  • NMT will make this Safeguarding & Prevent Policy and processes flowchart available to all. NMT will raise awareness of safeguarding and prevent issues through training, information campaigns, and other relevant means. There will be bimonthly safeguarding meetings for all members of the senior safeguarding team, bimonthly online update meetings with each centre and regular in person visits by the DSL to all NMT sites.

 

 

 

 

 

Appendix 1

CPOMS Report Guidance

Our CPOMS entries for learners outline any concerns we may have; this is primarily in relation to safeguarding, behaviour, attendance, medical needs and SEND needs. This all falls under the ‘safeguarding umbrella’.

As such, other agencies may be given access to CPOMS reports (for example courts, solicitors, Ofsted, the local authority. Parents/carers may also submit a request to view any and all information pertaining to the learner that we hold on our systems.
It is therefore vital that CPOMS reports align with the following criteria:

  • a timely log is created – information is added as soon as possible;
    the correct date and time are included – time/date of the incident, and not when the entry is being created;
    the correct categories are selected – to ensure accurate analysis of reports can be completed and patterns of incidents can be determined. If you are unsure which category to select, please file under ’cause for concern’
  • the correct learner’ is ‘linked’ – all learner’ mentioned within the report should be ‘linked’ so that the report appears under their name. Subsequent actions pertaining to an individual learner (e.g. conversations with that specific learner’s parents/carers) should be added as an action to their report only.
  • appropriate and professional language is used – formal language, free from opinion/bias with a focus on the facts of the incident and the avoidance of any form of emotive/‘loaded’ language (e.g. ‘kicked off’, ‘having a tantrum’, ‘he really hurt me’, ‘she couldn’t care less’) unless directly quoting an individual;
    use the learner’s own words – where information has been shared, directly quote the individual
    professional interpretations should be backed up with evidence – ‘general interpretation’ could be classed as opinion; reasonable evidence is required to ensure a ‘professional interpretation’ is formed (e.g. ‘The way the learner presented suggests they did not want to go home: they became tearful at home time and remained at the back of the line out of sight of their parent’);
    accurate use of names/job roles
    – staff to be logged as initial full name followed by job role egg Susan Lloyd, Tutor
    – learner to be logged using forename (full name will appear as a tag);
    – other professionals to be logged as full name followed by job role egg Jane Doe, social worker
  • the report is proof read before being submitted to ensure it is clear – the report needs to make sense to any external agencies who may access it;
  • relevant documents are added – this may include correspondences from external agencies, official school documents or handwritten notes from a meeting/investigation. If there is a ‘linked learner’ on a report, thought needs to be given as to whether the document needs adding to the main entry or as a subsequent action
  • Who to assign to – assign to your Area Manger. The senior safeguarding team will automatically be alerted to this incident.
  • the ‘safeguarding loop’ is closed – in addition to reporting the incident, we must report the subsequent actions. What was the outcome of the incident? What was the consequence? Who has information been passed on to? Who else has been informed (i.e.. parents/external agencies)? What additional support are you going to put in place?

 

 

What a bad report looks like:

Date: 12.12.__
Time: ______

Last week Aaron was kicking off. He has been told time and time again about his behaviour, but he just ignores me and does it anyway. He began to flip over the chairs in the classroom and the other learner were really frightened and started crying. He started shouting at me as well, so I told him he had to stop that straight away. He flew out of the classroom and began running up and down the corridor, not bothered about who he was bumping into me and booting the wall which really upset me! In the end I had to call for SLT because he was absolutely wild.

X Not completed in a timely manner
X Emotive/unprofessional language used
X Who, what, where, when and why not clear
X No mention of ongoing or subsequent support
X No actions/follow up identified

What a good report looks like:
 

Date: 07.12.2023
Time: 09.30

In Maths, Aaron displayed dysregulated behaviour. The trigger for this was that he didn’t want to engage in a maths lesson. Behaviours shown included shouting and tipping over classroom chairs. Aaron said “My mum said I can call her and go home when we do maths”. The other learner in the class were showing signs of being scared, so were calmed by  Mike Ward, LSA, whilst Susan Lloyd, Tutor, supported Aaron. Strategies to support Aaron included firm direction, distraction techniques and opportunity to work in a quiet area. Aaron left the classroom and was followed by Susan Lloyd ,Tutor, to support. Aaron became physically aggressive, so additional support was requested.

Actions:
– Susan Lloyd, Tutor, to inform Aaron’s mum at the end of the school day, including asking whether she had agreed for Aaron to go home.
– Aaron to be invited to have 1:1 maths support
– Jane Doe, Social Worker, to be informed of the incident.

✓ Completed in a timely manner, with accurate date/time cited
✓ Professional and supportive language used throughout
✓ Includes the who, what, why, where and when
✓ Support/strategies used clearly identified
✓ Subsequent actions identified
✓ Actual words used by child included where relevant

 

Appendix 2

Abuse and Related Issues of Safeguarding

The definitions and types of abuse and neglect detailed are taken from Keeping Children Safe in Education Statutory guidance for schools and colleges (September 2023):

Abuse: a form of maltreatment of a person. Somebody may abuse or neglect a child or vulnerable adult by inflicting harm, or by failing to act to prevent harm.

Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning, or scalding, drowning, suffocating or otherwise causing physical harm. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a learner or vulnerable adult.

Emotional abuse: the persistent emotional maltreatment of a learner or vulnerable adult such as to cause severe and adverse effects on their emotional development. It may involve conveying to a learner that they are worthless or unloved, inadequate. It may include not giving them opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate.

Sexual abuse: involves a learner at risk being forced or coerced into participating in or watching sexual activity. It is not necessary for the learner at risk to be aware that the activity is sexual and the apparent consent of the student or adult at risk is irrelevant. It also relates to sexual abuse in terms of e-safety and child sexual exploitation, such as inappropriate images, film and evidence of grooming.

Neglect: the persistent failure to meet a learner at risk of basic physical and/or psychological need, likely to result in the serious impairment of their health or development

Mental Health: NMT staff should be aware that mental health problems can, in some cases, be an indicator that a learner or adult has suffered or is at risk of suffering abuse, neglect or exploitation.

Grooming:  is when someone builds an emotional connection with a child to gain their trust for the purposes of sexual abuse, sexual exploitation or trafficking. Young people can be groomed online or face-to-face, by a stranger or by someone they know – for example a family member, friend or professional.

Child sexual exploitation (CSE):  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.

Child Criminal Exploitation (CCE) and County Lines: Child Criminal Exploitation of children is a form of abuse where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into taking part in criminal activity. Some specific forms of CCE can include children being forced or manipulated into transporting drugs or money through county lines, working in cannabis factories, shoplifting, or pickpocketing. They can also be forced or manipulated into committing vehicle crime or threatening/committing serious violence to others.

Children who are missing in education: Children missing in education for prolonged periods and/or on repeat occasions can act as a vital warning sign to a range of safeguarding issues including neglect, child sexual and child criminal exploitation – particularly county lines. It is important the school or college’s response to persistently absent learners missing education supports identifying such abuse, and in the case of absent pupils, helps prevent the risk of them becoming a child missing education in the future.

Domestic abuse: Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender of sexuality. Domestic abuse can be, but is not limited to, psychological, physical, sexual, financial, or emotional. Children can be victims of domestic abuse.

Financial or material abuse: Financial abuse is the misuse of a person’s funds and assets; obtaining property and funds without his/her knowledge and full consent, or in the case of a person who is not competent, not in his/her best interests. This is also known as material abuse. Financial or material abuse can involve the theft or misuse of a person’s money or property.

Radicalisation, idealisation and extremism: Radicalisation and idealisation refer to the process of supporting terrorism and extremist ideologies and, in some cases, to then participate in terrorist activity. Extremism is defined as vocal or active opposition to fundamental British values including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.

Terrorism: Terrorism is an action that endangers or causes serious violence to a person/people, causes serious damage to property or seriously interferes or disrupts an electronic system. The use or threat must be designed to influence the government or to intimidate the public and is made for advancing a political, religious or ideological cause.

Female Genital mutilation (FGM) is a criminal offence – it is abuse and a form of violence against women and girls. Female genital mutilation comprises all procedures involving the partial or total removal of the female external genitalia or other injury to the female genital organs for non- medical reasons.

Forced marriage: is a criminal offense in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some communities use religion and culture as a way to coerce a person into marriage.

So Called ‘Honour’ based Abuse: This can be a form of abuse that may be linked to certain practices that are related to culture, faith, beliefs and may put learners at risk of abuse.

Homelessness: Being homeless or being at risk of becoming homeless presents a real risk to a learner’s welfare. The DSL, and any deputies, should be aware of contact details and referral routes into the Local Housing Authority so they can raise/progress concerns at the earliest opportunity.

Child on child abuse: Children can abuse other children. This can include (but is not limited to) bullying (including cyberbullying); sexual violence and sexual harassment; abuse in intimate personal relationships, physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexting and initiating/hazing type violence and rituals.

Child on child Sexual Violence & Sexual Harassment: 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.

Consent: is about having the freedom and capacity to choose. 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.

Serious Violence: There are indicators, which may signal that a young person is at risk from, or involved with serious violent crime. These may include increased absence from school, a change in friendships or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, signs of assault or unexplained injuries. Unexplained gifts or new possessions could also indicate young people have been approached by, or are involved with, individuals associated with criminal networks or guns. All staff should be aware of the associated risks and understand the measure in place to manage these. Advice is provided in the Home Office’s Preventing Youth Violence and Gang Involvement and Criminal Exploitation of Children and Vulnerable Adults: County Lines Guidance.

Appendix 3

Glossary of terms

Safeguarding  –  is a term, which is broader than “child protection” and relates to the action taken to promote the welfare of children and young people and adults and protect them from harm. Safeguarding is everyone’s responsibility.

Designated Safeguarding Lead – part of the senior safeguarding team with overall responsibility for safeguarding within NMT.

Senior Safeguarding Team – a team withing NMT who have received DSL level 4 training, who will take responsibility for safeguarding incidents and concerns.

Duty of Care – the duty which rests upon an individual or organisation to ensure the safety of a child or young person involved in any activity or interaction for which that individual or organisation is responsible.

External Agencies – professionals working outside of NMT who provide a service. Including, but not limited to Buckinghamshire Safeguarding Board, Police, Social Care etc.

LADO  –  Local Authority Designated Officer. LADO is responsible for managing allegations against adults who work with children. This involves working with police, children’s social care. employers and other involved professionals. The LADO does not conduct investigations directly, but rather oversees and directs them to ensure thoroughness, timeliness and fairness.

CPOMS  – Safeguarding reporting software that monitors Child Protection, Safeguarding, pastoral and welfare concerns for pupils.

CAMHS – Child Adolescent Mental Health Service.

Child in Need (CIN) – A young person under the age of 18, based on a social worker assessment determines that the chid is in need under Section 17 of the Children’s Act 1989. It provides support for the child and the family.

Child Protection Order – Section 47 Enquiry under the Children’s Act 1989. This is the highest level of child protection for children likely to suffer significant harm.

Appendix 4

Assessment Framework (Taken from Working Together to Safeguard Children, July 2018)

Every assessment should draw together relevant information gathered from the child and their family and from relevant practitioners including NMT staff, health practitioners, the Police and children’s social care.

Every assessment of a learner should reflect the unique characteristics of the learner within their family and community context.

Each learner whose referral has been accepted by children’s social care should have their individual needs assessed, including an analysis of the parental capacity to meet those needs, whether they arise from issues within the family or the wider community.

Frequently, more than one child from the same family is referred and siblings within the family should always be considered.

Equality Impact Statement

New Meaning Training have a duty to consider the impact of changes on groups with Protected Characteristics (race, disability, age, sexual orientation, religion or belief, gender reassignment, pregnancy and maternity, marriage and civil partnership).

What are the overall aims of the change? Why are you proposing it? The aim of this policy is to provide a framework to ensure that the guidelines are in place to support all stakeholders.
Given the aims of your proposal, what issues does your data/information highlight? Everybody is included within this policy, and all groups are given equability regarding their needs and provisions.
How could the proposed change affect positively/negatively on groups with protected characteristics? This has a positive impact on all groups with protected characteristics, as they are ensured equal treatment and provision based on their needs. Risk assessments may be carried out to ensure that this is the case and provisions maybe altered to accommodate specific needs.
What actions will you take to mitigate any negative impact? No negative impact to having this policy.
Is there any potential negative impact justified considering wider benefits of the proposal? No negative impact to having this policy.
Recording final decision. This policy requires CEO approval.
Has the policy taken into consideration the requirements of GDPR regulations?

Are there any actions that need addressing, e.g. data sharing agreement; have data consent and data retention timescales been considered?

GDPR regulations have been considered and actions comply with data protection requirements.

POLICY AGREEMENT

Visit the link below and confirm you have read, understood and agree to adhere to this policy:

https://forms.office.com/e/cHK3hyWGTE

Should you experience any issues accessing the agreement, please contact Learning Services.