Safeguarding and PREVENT for Learners Policy

Last review date: 27th March 2024

Next review date: 27th March 2025

Objective

This Safeguarding policy applies to all staff, including senior managers, volunteers, learners, employers and anyone working on behalf of/with Raise the Bar (RTB).

At RTB we recognise the need for vigilant awareness of safeguarding issues. All staff have appropriate training so that they understand their roles and responsibilities and are confident in carrying them out and ensuring their own and learners’ safety and health. All individuals should feel secure that they could raise any issues or concerns about the safety or welfare of children, young people and adults at risk and know that they will be listened to and taken seriously. This will be achieved by demonstrating zero tolerance of abuse and other harmful behaviours, promoting the welfare of children, young people, adults at risk and protecting staff and learners.

Raise the Bar has a Designated Safeguarding Lead (DSL) who is responsible for the development and practice of safeguarding, the DSL reports directly to the Head of Apprenticeships and the Managing Director has overall responsibility.

Managing Director Becs Bridge
Telephone 0203 137 7353
Head of Apprenticeships Janette Healey
Telephone 0203 137 7353
Designated Safeguarding Lead Hayley Sinclair
Email safeguarding@raisethebar.co.uk
Telephone 0203 137 7353 & choose option 4
Safeguarding Officers Bev Harland, Luke Chapman, Lucy Jones
Email safeguarding@raisethebar.co.uk
Telephone 0203 137 7353
Careline Adult Services (Liverpool) 0151 233 3800
Police (Emergency) 999
Police (Non-Emergency) 101

The policy applies to, but not limited to:

  • All delivery and non-delivery staff employed by RTB
  • All external visitors whether online or personal attendance
  • The Executive Team
  • All Learners
  • All Employers engaged with RTB
  • Education personnel (For example Inspectors, Awarding body external verifiers)

Associated policies

Whistleblowing Policy

Peer on Peer Abuse

Sexual Abuse & Harassment

Bullying & Harassment

Safeguarding Commitment

This policy is based on the following principles:

  • Everybody has the right to live their life free from violence, fear and abuse.
  • Everybody has the right to be protected from harm and exploitation.
  • Everybody has the right to independence, which may involve a degree of risk.

Safeguarding is a term used to denote the duties and responsibilities that those providing health, social care, or education to carry out/perform to protect individuals from harm.

Safeguarding at RTB is defined as:

  • Protecting learners from maltreatment.
  • Preventing impairment of health or development.
  • Ensuring that learners are provided with a safe and effective environment and treatment.
  • Taking action to enable all learners to have the best life chances.
  • Protecting the rights of people to live in safety, free from abuse and neglect.
  • People and organisations working together to prevent and stop both the risks and experience of abuse or neglect.
  • People and organisations making sure that wellbeing is promoted, including taking into account (where appropriate) views, wishes, feelings and beliefs when making decisions on any actions to be undertaken.
  • Recognising that sometimes people have complex interpersonal relationships and may be ambivalent, unclear, or unrealistic about their personal circumstances and therefore have the potential to pose risks to their safety and/or wellbeing.

The promotion of a learner’s wellbeing is paramount within safeguarding; we acknowledge the need to act in the best possible interests of an individual without comprising their human rights. We therefore ensure we adopt the local authority approach known as MSP – Making Safeguarding Personal, whereby we work with learners to establish:
i) what they want to achieve, for example what outcome is being sought
ii) what it means to ‘be safe’ to that individual
iii) how the outcomes can be best achieved.

RTB are committed to providing a safer learning environment based upon positive wellbeing, personal safety and security of all staff and learners.

Recruitment

RTB has a safe recruitment process and ensures that all appropriate checks are carried out on new staff that will come into contact with our learners in line with the Disclosure and Barring Service requirements.

Expectations of Employees

Everyone at Raise the Bar has a responsibility to familiarise themselves with this safeguarding policy and the procedures that go with it.

To maintain staff and learners safety the following are strictly prohibited:

  • Befriending learners on personal social media sites
  • Distributing personal telephone numbers
  • Home visits or transporting learners to and from locations
  • Personal relationships with learners

It is also important to be mindful of the following:

  • Staff must not use sarcasm, insults or belittling comments towards learners.
  • Staff will naturally build a rapport with learners through the learner contact, and they may see that person as a confidant and support, staff must ensure that they maintain professional boundaries.
  • Staff must uphold confidentiality within certain remits when required by the situation and be careful not to promise to keep secrets or ask others to do so.
  • Staff should avoid spending time alone with learners in a closed environment. If this is unavoidable for example during a formal assessment/examination, staff must ensure someone on site is aware where they are and is monitoring this.
  • If at any point, a staff member feels unsafe in an apprentice’s company they must inform the learners manager, their line manager, the DSL and leave the call/premises immediately.

Training and support for staff

All staff will be given up to date information on Safeguarding through a clear induction programme, which includes Safeguarding systems, procedures and policies and the role of the designated safeguarding lead. This training will be refreshed annually. All staff will take part in appropriate Safeguarding and Prevent Training, in line with specific job roles. Safeguarding updates will be shared (for example, via email, newsletter, and staff meetings), as required. Staff will be provided with internal counselling / supervision where appropriate.

Reporting Safeguarding Risks/Concerns

All staff should receive an appropriate level of training to provide a shared understanding of the tasks, processes, principles, and roles and responsibilities for safeguarding.

Where a safeguarding incident occurs, or an individual has a safeguarding concern, the following procedure must be enacted:

  • Recognise the signs of abuse.
  • Respond and react accordingly.
  • Record the facts of the disclosure.
  • Report the disclosure to DSL as soon as possible/within 48 hours. All reports must be forwarded to the DSL as soon as possible/within 48 hours. The concern forms are located online via Teams Channel “Safeguarding”.
  • Refer (to the emergency services, through the Channel process and/or Careline) in situations where an individual may be at risk of immediate harm – This must be reported to DSL as soon as possible after the referral, always within 48 hours.

Definitions/ Guidance

Recognise

Signs of abuse can be recognised as a contrast to the individual’s usual behaviour or observed from a change in their physical appearance as mentioned below:

  • Physical: this could include lack of personal hygiene, self-harm, substance or drug abuse, noticeable signs of bruising or flinching when being touched, developed a speech disorder or learning difficulty that cannot be attributed to a physical or psychological cause.
  • Behavioural: this could include sudden changes in a person’s character, lack of confidence, low self-esteem, withdrawn or being aggressive or angry for no reason, becoming anxious or tearful.

Respond

People are often reluctant to talk about abuse. Listed below are some ways as to respond to issues or concerns:

  • Stay calm and listen carefully to what is being said
  • Reassure the person that they have done the right thing by telling you, but not that everything will be okay
  • Find an appropriate early opportunity to explain that it is likely the information will need to be shared with others, but that this will be on a need-to-know basis
  • Allow the person to continue at his/her own pace – asking questions for clarification only; try to ask “tell me, explain to me, describe to me” to avoid leading for a particular answer
  • Tell them what you will do next and with whom the information will be shared
  • Do not delay in discussing your concerns and if necessary, passing this information on
  • If you feel that is anyone is at immediate risk, please take any reasonable steps within your role to protect any person from immediate harm, for example:
    • Call an ambulance or a GP if someone needs medical attention
    • Call the emergency services/police if a crime is taking place or has taken place
    • Inform the DSL as soon as possible/within 48 hours
    • Separate the alleged perpetrator and victim, but only if it is safe to do so

If you are suspicious but no disclosure has taken place discuss your concerns with the DSL.

Record

  • A Safeguarding concern form must be completed.
  • Where a Safeguarding Concern Form is not readily available please ensure that the following information is noted:
    • Your details
    • Name of those involved
    • Date of incident(s) /disclosure/suspicion
    • Details of incident(s) / disclosure / suspicion
    • Background information
    • Actions taken

Whilst you can record observations, do not interpret, or give opinion as this may bias the information provided and jeopardise any future investigation into the allegation. The Safeguarding Report Concern should be kept securely and forwarded to the DSL.

Report

Any issues or concerns, allegations or suspicions relating to safeguarding must be taken seriously and reported to the DSL. If the DSL is not available, please contact the Deputy safeguarding officer or a senior manager.

Refer

Where required, the DSL will refer or support you with guidance on next steps and/or signposting the relevant external agency.

Any referrals to other external agencies must also be notified to the DSL.

Any concerns about an individual who is part of a programme that is externally linked should be relayed to the external institutions designated safeguarding representative also.

Confidentiality

The safety and well-being of the individual at risk is paramount. Staff may have access to confidential information about individuals to undertake their everyday responsibilities. In some circumstances, staff may be given highly sensitive or private information. They should never use confidential or personal information about an individual or his/her family for their own or others’ advantage. Information must never be used to intimidate, humiliate, or embarrass an individual.

The DSL will disclose personal information about an individual to other staff on a need-to-know basis only.

The DSL will make a judgement in each individual case about who needs and has a right to access information.

All staff must be aware that they have a professional responsibility to share information with other agencies to safeguard children, young people, and adults at risk, in consultation with the DSL.

All staff must be aware that they cannot promise a child/young person or adult at risk confidentiality which might compromise the safety or well-being of the individual or that of another.

Definitions of abuse

‘Abuse is a violation of an individual’s human civil rights by any other person/s’

Sexual Abuse Child: Forcing or enticing a child or young person, not necessarily involving a high level of violence to take part in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non- penetrative acts such as masturbation, kissing, rubbing and touching outside the clothing. They may include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.

Adult at risk: Sexual abuse is the direct or indirect involvement of the adult at risk in sexual activity or relationships, which they:

  • Do not want or have not consented to, cannot understand, and lack the mental capacity to be able to give consent to.
  • Have been coerced into because the other person is in a position of trust, power, or authority.

Neglect Child: The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in serious impairment of the child’s health and development. it may also include the neglect of, or unresponsiveness to, a child’s basic emotional needs.

Adult at risk: Neglect and acts of omission, including ignoring medical or physical care needs, failure to provide access to appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition, and heating.

Physical Abuse: May involve hitting, shaking, throwing, poisoning, burning, or scalding, drowning or suffocating, or otherwise causing physical harm to a child or adult at risk.

Emotional Abuse Child: The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may feature age or developmentally inappropriate expectations being imposed on children. It may involve seeing or hearing the ill treatment of others. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.

Adult at risk: Psychological abuse, including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or unreasonable and unjustified withdrawal of services or supportive networks.

Sexual Exploitation: Sexual exploitation of children and young people under 18 involves exploitative situations, contexts, and relationships where young people receive ‘something’ as a result of them performing, and/or other people performing on them, sexual activities. It can occur through the use of technology without the child’s immediate recognition. In all cases those exploiting young people have power over them by virtue of age, gender, intellect, physical strength and/or economic or other resources. Violence, coercion and intimidation are common, involvement in exploitative relationships being characterised mainly by the young person’s limited availability of choice resulting from their vulnerability. In an adult at risk sexual exploitation is either opportunistically or premeditated, unfairly manipulating someone for profit or personal gain.

Radicalisation & Extremism: The Counter Terrorism and Security Act, which received Royal Assent on 12th February 2015, places a duty on specified authorities, including local authorities and childcare, education and other children’s services providers, in the exercise of their functions, to have due regard to the need to prevent individuals from being drawn into terrorism (“the Prevent Duty”).

Female Genital Mutilation (FGM): Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a girl being at risk of FGM, or already having suffered FGM. There is a range of potential indicators that a child or young person may be at risk of FGM, which individually may not indicate risk but if there are two or more indicators present this could signal a risk to the child or young person. Victims of FGM are likely to come from a community that is known to practice FGM. Professionals should note that girls at risk of FGM may not yet be aware of the practice or that it may be conducted on them, so sensitivity should always be shown when approaching the subject. Staff have a responsibility to follow local safeguarding procedures, using existing national and local protocols for multi- agency liaison with police and other relevant agencies. Care and sensitivity should be shown to adults at risk who have been subject to FGM, and further support should be sought where required. As this differs from region to region this will be actioned by the DSL.

Forced Marriage: In forced marriage, one or both spouses do not consent to the marriage or consent is extracted under duress. Duress includes both physical and emotional pressure. A clear distinction must be made between a forced marriage and an arranged marriage. In arranged marriages, the families of both spouses take a leading role in choosing the marriage partner but the choice whether or not to accept the arrangement remains with the young people. It is a human rights abuse and falls within the Crown Prosecution Service definition of domestic violence. Young men and women can be at risk in affected ethnic groups.

Additional forms of abuse

Discriminatory: Including forms of harassment, bullying, slurs, isolation, neglect, denial of access to services or similar treatment; because of race, gender and gender identity, age, disability, religion or because someone is lesbian, gay, bisexual or transgender. This includes racism, sexism, ageism, homophobia or any other form of hate incident or crime.

Domestic abuse or violence: Includes an incident or a pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse, by someone who is, or has been, an intimate partner or family member regardless of gender or sexual orientation. This includes psychological/emotional, physical, sexual, financial abuse; so called ‘honour’ based violence, forced marriage or Female Genital Mutilation (FGM).

Financial or material: Including theft, fraud, internet scamming, exploitation, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions, or benefits.

Modern slavery: Encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive, and force individuals into a life of abuse, servitude, and inhumane treatment.

Organisational (sometimes referred to as institutional): Including neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example, or in relation to care provided in a person’s own home. This may range from one off incidents to on-going ill treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes, and practices within an organisation.

Self-neglect: Includes a person neglecting to care for their personal hygiene; health or surroundings; or an inability to provide essential food; clothing; shelter or medical care necessary to maintain their physical and mental health; emotional wellbeing and general safety. It includes behaviour such as hoarding.

Managing Allegations against Staff: All staff should take care not to place themselves in a vulnerable position with a child, young person or adult at risk and be aware of appropriate professional conduct. It is always advisable for interviews or work to be conducted in a visible arena in view of other adults. If we do receive complaints or allegations against a member of staff, it is important that a fair and balanced approach should be taken to ensure that both the complainant and the staff member are safeguarded. If such an allegation is made, the staff member receiving the information must take the issue seriously and should immediately inform their line manager, who will then immediately discuss the content of the allegation with the DSL and Head of Learnerships. If the allegation made to a staff member concerns their own line manager, the person receiving the allegation must immediately inform the DSL and/or Head of Learnerships, without notifying their manager. It is important that no further action is taken in respect of gathering statements from others or interviewing until directed by the DSL and Head of Learnerships.

British values

British values are of paramount importance to RTB, RTB view British Values as underpinning what it is to be a citizen in a modern and diverse Great Britain.

According to Ofsted, ‘Fundamental British values‘ comprise: democracy. the rule of law. individual liberty. mutual respect for and tolerance of those with different faiths and beliefs, and for those without faith.

DEMOCRACY    THE RULE OF LAW    INDIVIDUAL LIBERTY    MUTUAL RESPECT    TOLERANCE OF DIFFERENT FAITHS & BELIFES

RTB encourage staff to pass on these values to those they teach and support, and help our learners access relevant training and information.

RTB shares and promotes these values across all areas and have clear policies and procedures in place, RTB:

  • Help learners to become valuable and rounded members of society who treat others with respect and tolerance, regardless of background.
  • Promote the basic British values of democracy, the rule of law, individual liberty and mutual respect and tolerance for those of different beliefs and faiths.
  • Ensure understanding of the importance of respect.
  • Celebrate difference and promote diversity.
  • Encourage an understanding of the difficulties other cultures face where such values are not respected.
  • Resources are shared and discussed with Learners via monthly ‘Hot Topics’ on BUD system.
  • Learners are encouraged to discuss values and concerns with the relevant persons.
  • Employ a Designated Safeguarding Lead other staff alongside other staff with designated responsibility.
  • Ensure all staff and partners working for, or on behalf of RTB are subject to relevant.
  • Actively encourage learners, staff, and partners to raise any concerns they have.
  • Take all concerns seriously, act upon them, and offer full support through RTB and specialist services.
  • Train all staff in safeguarding.

Prevent

RTB safeguarding requirements include protecting susceptible individuals from the risk of radicalisation and extremism. This is called the ‘Prevent Duty’. Prevent is a government initiative aimed at stopping people becoming involved with or supporting violent extremism.

In accordance with the Government Prevent Strategy we use the following accepted Governmental definition of extremism which is:

‘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; and/or calls for the death of members of our armed forces, whether in this country or overseas’.

All staff have a legal responsibility under the Prevent Duty to make ensure that:

  • They have undertaken training in the Prevent Duty and CHANNEL as identified by the DSL.
  • They exemplify British values of “democracy, the rule of law, individual liberty and mutual respect and tolerance for those with different faiths and beliefs” into their practice.
  • Respond to the ideological challenge of terrorism and the threat we face from those who promote it.
  • Prevent people from being drawn into terrorism and ensure that they are given appropriate advice and support.

Radicalisation, Extremism and the PREVENT Duty

There is no place for extremist views of any kind within RTB, whether from internal sources; learners and/or staff, or external sources such as community, external agencies, partners or individuals.

As part of wider safeguarding responsibilities staff will be alert to:

  • Disclosures by learners of their exposure to the extremist actions, views or materials of others outside of their learning environment, such as in their homes or community groups, especially where learners have not actively sought these out.
  • Graffiti symbols, writing or artwork promoting extremist messages or images.
  • Learners voicing opinions drawn from extremist ideologies and narratives.
  • Use of extremist or ‘hate’ terms to exclude others or incite violence.
  • Intolerance of difference, whether secular or religious or, in line with our equality policy, views based on, but not exclusive to, gender, disability, homophobia, race, colour or culture.
  • Attempts to impose extremist views or practices on others.
  • Anti-Western or Anti-British views.

We fully adopt the PREVENT duty and ensure the following:

  • All staff undertake PREVENT and CHANNEL training.
  • All learners are made aware of PREVENT and CHANNEL awareness training and information; this is included in monthly ‘Hot Topics’.
  • All learners are given resources to ensure understanding.
  • Staff know when it is appropriate to refer PREVENT related concerns regarding colleagues or learners to the DSL.
  • RTB demonstrate, embrace and evidence within our delivery British Values: Democracy, Rule of Law, Individual Liberty and Mutual Respect and tolerance for those with different faiths and beliefs.

Prevent: to stop people becoming terrorists or supporting terrorism

Pursue: to stop terrorist attacks

Protect: to strengthen protection against a terrorist attack, and

Prepare: to mitigate the impact of a terrorist attack.

If there are concerns that an individual is becoming radicalised and/or involved in an organisation which could ultimately harm the individual and the community this is to be reported to the DSL immediately.

 

SAFEGUARDING POLICY FOR CHILDREN AND SUSCEPTIBLE ADULTS

Introduction

“Schools, colleges and Independent Training Providers and their staff are an important part of the wider safeguarding system for young people and vulnerable adults. Safeguarding and promoting the welfare of young people and vulnerable adults is everyone’s responsibility. Everyone who comes into contact with and their families has a role to play. In order to fulfil this responsibility effectively, all professionals should make sure their approach is child- centered. This means they should consider at all times, what is in the best interests of the child”.

(Keeping Children Safe in Education – DfE, September 2021)

Objective

This Safeguarding policy applies to all staff, including senior managers, volunteers, learners, employers and anyone working on behalf of/with Raise the Bar (RTB).

At RTB we recognise the need for vigilant awareness of safeguarding issues. All staff have appropriate training so that they understand their roles and responsibilities and are confident in carrying them out and ensuring their own and learners’ safety and health. All individuals should feel secure that they could raise any issues or concerns about the safety or welfare of children, young people and adults at risk and know that they will be listened to and taken seriously. This will be achieved by demonstrating zero tolerance of abuse and other harmful behaviours, promoting the welfare of children, young people, adults at risk and protecting staff and learners.

Raise the Bar has a Designated Safeguarding Lead (DSL) who is responsible for the development and practice of safeguarding, the DSL reports directly to the Head of Apprenticeships and the Managing Director has overall responsibility.

Managing Director Becs Bridge
Telephone 0203 137 7353
Head of Apprenticeships Janette Healey
Telephone 0203 137 7353
Designated Safeguarding Lead Lucy Jones
Email safeguarding@raisethebar.co.uk
Telephone 0203 137 7353 & choose option 4
Safeguarding Officers Charlotte Fotherby, Tanya Hudson, Laura Bennett, Bev Harland, Abz Salloum
Email safeguarding@raisethebar.co.uk
Telephone 0203 137 7353
Careline Adult Services (Liverpool) 0151 233 3800
Police (Emergency) 999
Police (Non-Emergency) 101
This element of the policy applies to: CHILDREN AND SUSCEPTIBLE ADULTS
Associated Policies
Whistleblowing Policy

Peer on Peer Abuse

Sexual Abuse & Harassment

Bullying & Harassment

The term “young people” refer to learners aged up to 18 and susceptible adults.

This Safeguarding Policy is for all staff, parents, employers and the wider RTB community. It forms part of the safeguarding arrangements at RTB and should be read along with the RTB’s policies.

RTB is committed to safeguarding young people and susceptible adults and to create a culture of vigilance in RTB. This policy should also be read in conjunction with Keeping Children Safe in Education (DfE, 2021).

Safeguarding and promoting the welfare of young people and susceptible adults is defined as:

  • Protecting young people and susceptible adults from maltreatment
  • Preventing impairment of young people and susceptible adults’ mental and physical health or development
  • Ensuring that young people and susceptible adults grow up in circumstances consistent with the provision of safe and effective care
  • Taking action to enable all young people and susceptible adults to have the best outcomes

Statutory framework

The Education Act 2002 Section 175, places a statutory responsibility on the governing body to have policies and procedures in place that safeguard and promote the welfare of young people and susceptible adults who are learners of the RTB.

RTB works in accordance with the following legislation and guidance:

Keeping Children Safe in Education 2023  (DfE June 2023)

Working Together to Safeguard Children

(HMG, 2023)

Education Act 2011 (gov.uk, 2011)

Counter-Terrorism and Border Security Act 2019 (gov.uk, 2019)

The Prevent duty Departmental advice for schools and childcare providers (DfE 2015)

Prevent Duty Guidance for Further Education Establishments in England and Wales (HMG 2015) Serious Crime Act 2015 (Home Office, 2015)

Sexual Offences Act 2003  (gov.uk, 2003)

Education (Pupil Registration) Regulations 2006 (gov.uk, 2006)

The Data Protection Act 2018 (gov.uk, 2018)

What to do if you’re worried a child is being abused (HMG, 2015)

Screening, Searching and Confiscation (DfE, 2022)

Children Act 1989

Children Act 2004

Children and Social Work Act 2017

Modern Slavery Act 2015

The Homelessness Reduction Act 2017

Preventing and Tackling Bullying (DfE, 2017),

Female Genital Mutilation Act 2003 (S. 74 – Serious Crime Act 2015)

Sexual violence and sexual harassment between children in schools and colleges (DfE, 2017)

Advice on Whistleblowing in Maintained Schools (DfE 2014)

The Voyeurism (Offences) Act 2019

RTB roles and responsibilities

All adults working with or on behalf of young people and susceptible adults have a responsibility to protect them and to provide a safe environment that enables them to learn and achieve their full potential. However, there are identified key adults in RTBs and in the Local Authority who have specific responsibilities under child protection procedures. The names of those in our RTB with these specific responsibilities are shown on the front cover sheet of this policy.

The Governing Body (The Executive Team)

The governing body has a responsibility to ensure that the policies, procedures and professional development and training in our RTB are effective and comply with the statutory requirements at all times.

It ensures that all required policies relating to the protection and safeguarding of young people and susceptible adults are in place and that the safeguarding policy reflects statutory and local guidance and is reviewed at least annually.

The governing body also ensures there is a named Designated Safeguarding Lead in place and that they have their safeguarding role explicitly in the job description and are trained for the role as set out in Keeping Children Safe in Education 2021.

The governing body ensures the RTB contributes fully to inter-agency working, in line with statutory and local guidance. It ensures that information is stored and shared appropriately and in accordance with the statutory requirements.

The governing body monitors to ensure that all staff members and volunteers undergo safeguarding training at induction and that it is then regularly updated. All staff members receive regular safeguarding updates, at least annually, to provide them with the relevant skills and up to date knowledge to keep our young people and susceptible adults safe. The governing body will also ensure that staff have the knowledge, skills and understanding of the additional vulnerabilities of looked after and previously looked after children to keep them safe.

The governing body ensures that young people and susceptible adults are taught to keep themselves safe, including online, ensuring that appropriate filters and monitoring systems for online usage are in place in RTB. RTB learners will be taught how to keep themselves safe through teaching and learning opportunities as part of a rich and balanced curriculum.

The governing body and RTB leadership team are responsible for robust safer recruitment procedures that help to deter, reject or identify people who may abuse young people and susceptible adults. It adheres to statutory responsibilities to check adults working with young people and susceptible adults and has recruitment and selection procedures in place (see the RTB’s ‘Safer Recruitment’ policy for further information). It also ensures that volunteers are appropriately supervised in RTB.

The RTB has a dedicated and experienced safeguarding Governor that monitors all RTB safeguarding activity regularly.

The Designated Safeguarding Lead

The Designated Safeguarding Lead (DSL) in RTB takes the lead responsibility for managing safeguarding referrals, safeguarding training and raising awareness of all safeguarding policies and procedures in RTB and that everyone in RTB, including temporary staff, volunteers, supply teachers/agency staff and contractors are aware of these procedures and that they are followed at all times. The role of the DSL at Raise the Bar is to help promote further education outcomes by sharing information about welfare, safeguarding protection issues that young people and susceptible adults are experiencing, or have experienced, with development coaches and RTB leadership staff. They are a source of advice and support to other staff on safeguarding matters and make sure that timely referrals are made in accordance with current regional Young People/Susceptible Adults Protection Procedures. The Head of Safeguarding (DSL) will collaborate with the local authority and other agencies as required. If for any reason the Head of Safeguarding is unavailable, Deputy Designated Safeguarding Officers will act in their absence.

All RTB staff

As outlined in the ‘Keeping Children Safe in Education’ Guidance it is everyone’s responsibility to provide a learning environment in which our young people and susceptible adults can feel safe to learn. All staff members are prepared to identify young people and susceptible adults who may benefit from early help and understand their role and responsibilities within this process. This includes identifying any emerging problems so appropriate support may be provided and in liaison with the Designated Safeguarding Lead (DSL) report any concerns. All staff members are aware of and follow RTB processes as set out in this policy and are aware of how to make a referral to the Newham Triage Team when there is a need to do so.

If the concern is brought to a staff member outside of the dedicated times above, then staff members can call the following partners and agencies for support.

If you feel a crime has been committed, please dial 101
If you feel yourself or someone else is in immediate danger, please dial 999.

Types of abuse / specific safeguarding issues

“Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly on-line, or technology may be used to facilitate offline abuse. They may be abused by an adult or adults or by another child or children.”

Keeping Children Safe in Education (DfE, 2021)

The four main types of abuse referred to in Keeping Children Safe in Education are:

  • Physical
  • Emotional
  • Sexual
  • Neglect

RTB is aware of the signs of abuse and neglect so we are able to identify young people and susceptible adults who may be in need of help or protection. Within those four main types of abuse there are specific types of abuse that RTB is alert to.

The ‘Keeping Children Safe in Education’ (2021) states that young people and susceptible adults can witness and be adversely affect by domestic abuse in the context of their home life where domestic abuse occurs between family members.

Peer on peer abuse

Sexual violence and harassment can occur between young people and susceptible adults of any age individually or in groups. Young people and susceptible adults who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing, and in all likelihood will adversely affect their educational attainment. RTB takes all victims seriously and they will be offered the appropriate support.

RTB has a dedicated Policy for Peer-on-Peer Abuse and Sexual Harassment.

Young people and susceptible adults missing from education

All young people and susceptible adults regardless of their age, ability, aptitude and any special education needs they may have been entitled to a full-time education. RTB recognises that a young people and susceptible adult missing education is a potential indicator of abuse or neglect and will follow the relevant procedures.

RTB will inform the local authority of any young people or susceptible adults who fail to attend regularly or have been absent for a continuous period of 10 days or more in line with the requirements for ‘Children Missing Education’ guidance.

Contextualised Safeguarding – Sexual Exploitation (CSE) of young people and susceptible adults

Sexual Exploitation of young people and susceptible adults is a type of abuse, which can happen to boys and girls from any background or community.

“Child Sexual Exploitation is a form of child sexual abuse. It occurs when an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.”

The Department of Education (DfE)

It is understood that a significant number of young people and susceptible adults who are victims of sexual exploitation go missing from home, care and education at some point. RTB is alert to the signs and indicators of a young people or susceptible adult becoming at risk of, or subject to, sexual exploitation and will take appropriate action to respond to any concerns. The Designated Safeguarding Lead (DSL) will lead on any concerns and work with other agencies as appropriate.

Contextualised Safeguarding – Criminal Exploitation (CCE) including County Lines

Criminal exploitation of young people and susceptible adults is a geographically widespread form of harm that is a typical feature of County Lines criminal activity: drug networks or gangs groom and exploit children and young people to carry drugs, weapons and money for them. Key to identifying potential involvement may be ‘missing episodes’ when the victim may have been trafficked for the purpose of transporting drugs, weapons or money.

Female Genital Mutilation (FGM)

Female Genital Mutilation comprises all procedures involving partial or total removal of the external female genitalia or other injury to female genital organs. It is illegal in the UK and a form of abuse.

From October 2015, the Serious Crime Act 2015 (Home Office, 2015) placed a duty on teachers to notify the police of any known cases of female genital mutilation where it appears to have been carried out on a girl under the age of 18. RTB will operate in accordance with the statutory requirements relating to FGM in line with Child Protection Procedures.

Forced marriage

A forced marriage is one that is entered into without the full consent of one or both parties. It is where violence, threats or other forms of coercion is used and is a crime. RTB staff understand how to report concerns where this may be an issue.

Prevention of radicalisation

Young people and susceptible adults can be susceptible to extremist ideology and extremism. Protecting children from this risk is similar to protecting them from other forms of harm and abuse. The Counter-Terrorism and Border Security Act 2019 places a duty on RTB in the exercise of their functions, to have “due regard to the need to prevent people from being drawn into terrorism”. This duty is known as the PREVENT duty.

Terrorism is an action that endangers or causes violence to 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 intimate the public and is made for the purpose of advancing its political, religious or ideological cause.

The Prevent Duty requires RTB to:

  • Teach a broad and balanced curriculum which promotes spiritual, moral, cultural, mental and physical development of learners and prepares them for the opportunities, responsibilities and experiences of life and must promote community cohesion;
  • Be safe spaces in which young people and susceptible adults can understand and discuss sensitive topics, including terrorism and the extremist ideas that are part of terrorist ideology, and learn how to challenge these ideas and;
  • Be mindful of their existing duties to forbid political indoctrination and secure a balanced presentation of political issues.

CHANNEL is a national programme which focuses on providing support at an early stage to people identified as susceptible to radicalisation and being drawn into terrorism. All staff members understand how to identify those who may benefit from this support and are aware of relevant agencies to contact in circumstances where an individual demonstrates indicators of concern.

Self-Harm and Suicide Risk

Mental health is the concern of the whole community, and we recognise that staff play a key part in this. RTB wants to develop and protect the emotional wellbeing and resilience of all young people and susceptible adults and staff. We understand that there are risk factors which increase someone’s vulnerability and protective factors that can promote or strengthen resiliency. The more risk factors present in an individual’s life, the more protective factors or supportive interventions are required to promote further growth and resilience. It is recognised that young people and susceptible adults that may be suffering from mental ill-health and are at risk of self-harm or suicide may present in RTB as making good progress and achieving well. It is therefore vital that we work in partnership with parents and carers to support the well-being of our learners. It is equally important that parents share any concerns about the well-being of their young people and susceptible adults with RTB, so appropriate support and interventions can be identified and implemented.

Where there are concerns that a young people or susceptible adult may be self- harming, it will be taken seriously as this may indicate an increased risk of suicide either intentionally or by accident. If a young people or susceptible adult discloses self-harm or is found to be self-harming the Designated Safeguarding Lead (DSL) or relevant key person will take the time to establish any underlying concerns.

Procedures

All staff members have a duty to identify and respond to suspected and actual abuse or disclosures of harm. Any member of staff, volunteer or visitor to our RTB who receives a disclosure or allegation of abuse, or suspects that abuse may have occurred must report it immediately to the DSL).

All action is taken in accordance with the following guidance:

  • Keeping Children Safe in Education (DfE, 2021)
  • Working Together to Safeguard Children (DfE, 2018)
  • PREVENT Duty – Counter-Terrorism and Security Act (HMG, 2015)

If, for any reason, the Head of Safeguarding (DSL) or Deputy Designated Safeguarding Officer is not available, this should not delay appropriate action being taken. Safeguarding contact details are displayed in the RTB to ensure that all staff members have unfettered access to safeguarding support, should it be required.

Training

The Designated Safeguarding Lead (DSL) and deputies undertake safeguarding training appropriate to the role at every two years as a minimum. Staff members and governors receive appropriate safeguarding training that is regularly updated. In addition, all staff members receive safeguarding updates as required, but at least annually, to provide them with relevant skills and knowledge to safeguard young people and susceptible adults effectively. A record of any safeguarding training undertaken is kept.

Professional confidentiality

Confidentiality is an issue that needs to be discussed and fully understood by all those working with young people and susceptible adults particularly in the context of safeguarding. A member of staff must never guarantee confidentiality to anyone about a safeguarding concern (including parents / carers or learners) or promise to keep a secret. In accordance with statutory requirements, where there is a safeguarding concern, this must be reported to the Designated Safeguarding Lead (DSL) or deputy and may require further referral and subsequent investigation by appropriate authorities.

Information on individual safeguarding cases may be shared by the DSL with other relevant staff members. This will be on a ‘need to know’ basis only and where it is in the young people or susceptible adult’s best interests to do so.

Records and information sharing

Where there are concerns about the safety of a young people or susceptible adult, the sharing of information in a timely and effective manner between organisations can reduce the risk of harm. Whilst practitioners must have due regard for the Data Protection Act 2018 and the General Data Protection Regulations (GDPR) it is not a barrier to sharing information. RTB is confident of the processing conditions that allow us to store and share information for safeguarding purposes. This allows us to share information without consent, if it is not possible to gain consent or if to gain consent would place a young people or susceptible adult at risk.

Well-kept records are essential to good safeguarding practice. RTB is clear about the need to record any concerns held about young people and susceptible adults within our RTB, the status of such records and when these records should be shared with other agencies.

Any member of staff receiving a disclosure of abuse or noticing signs or indicators of abuse, will record it as soon as possible, noting what was said or seen, if appropriate, using a body map to record, with the date, time and location. All records will be dated and signed, with the name printed and will include the action taken. This is then presented to the DSL) or, who will decide on the appropriate action and record it accordingly.

Any records related to safeguarding are kept in a safeguarding database which is password protected All safeguarding records are stored securely and confidentially.

Where a young person or susceptible adult transfers from RTB to another educational setting, their safeguarding records will be forwarded to the new educational setting. These will be marked ‘Confidential’ and for the attention of the receiving institution’s Designated Safeguarding Lead (DSL) with a return address on the envelope so it can be returned to us if it goes astray. We will obtain evidence that the paperwork has been received by the new institution and then destroy any copies held in our RTB.

Where a learner joins, we will request all safeguarding records from the previous educational establishment if none are received.

Interagency working

RTBs often hold crucial information and as such our RTB is an essential partner in strategy discussions, safeguarding conferences and core groups. The Head of Safeguarding (DSL) is the Chair of the Further Education Prevent Network for London and attends DSL network meetings with the London Borough of Newham and Safer Partnership Boards. Our RTB will be pro-active and prioritise inter-agency working to contribute to safeguarding young people and susceptible adults. It is the responsibility of the Head of Safeguarding (DSL) to ensure that the RTB is represented at and a report is submitted to any young people and susceptible adults’ protection conference or core group meeting. Where possible and appropriate, any report will be shared in advance with the parent(s) and/or carer(s). Whoever represents the RTB will be fully briefed on any issues or concerns the RTB has and will be prepared to contribute to the discussions at the meeting(s).

Local authorities should share the fact a young person or susceptible adult has a social worker, and the DSL should hold and use this information so that decisions can be made in the best interests of the person’s safety. Where the young person or susceptible adult needs a social worker, this should inform decisions about the safeguarding and about promoting welfare.

If a young people or susceptible adult is subject to a child protection or a child in need plan, DSL will ensure the young people or susceptible adult is monitored regarding their RTB attendance, emotional well-being, academic progress, welfare and presentation. Any concerns about the child protection plan and/or the young people or susceptible adult’s welfare will be discussed and recorded at the core group meeting, unless to do so would place them at further risk of significant harm.

Allegations about members of the workforce

The aim of RTB is to provide a safe and supportive environment that secures the well-being and best learning outcomes for young people and susceptible adults. All staff members are made aware of the boundaries of appropriate behaviour and conduct. These matters form part of staff induction and are outlined in the Code of Conduct and Professional Behaviour policy. We do, however, recognise that sometimes allegations of abuse are made and when they occur, they are distressing and difficult for all. We also understand that some allegations are genuine and that there are adults who deliberately seek to harm or abuse young people and susceptible adults. RTB takes all possible steps to safeguard our young people and susceptible adults and ensure that the adults in our RTB are safe to work with children.

We will always ensure that the procedures are adhered to and will seek appropriate advice from the Local Authority Designated Officer.

If an allegation is made or information is received about any member of staff who works with young people and susceptible adults has:

  • Behaved in a way that has harmed a young person or susceptible adults or may have harmed a; young people or susceptible adult.
  • Possibly committed a criminal offence against or related to a young people or susceptible adult.
  • Behaved towards a young people or susceptible adult in a way that indicates they may pose a risk of harm to them.
  • Behaved or may have behaved in a way that indicated they not be suitable to work with young people and susceptible adult.

The member of staff receiving the information should inform the DSL immediately, these concerns do not need to relate directly to a young person or susceptible adult.

Any member of staff or volunteer who does not feel confident to raise their concerns within the RTB should contact the LADO directly.

RTB has a legal duty to refer to the Disclosure and Barring Service (DBS) anyone who has harmed, or poses a risk of harm, to a young people or susceptible adult, or if there is reason to believe the member of staff has committed one of a number of listed offences, and who has been removed from working (paid or unpaid) in regulated activity, or would have been removed had they not left. The DBS will consider whether to bar the person from regulated activity. If these circumstances arise in relation to a member of staff at our RTB, a referral will be made as soon as possible after the resignation or removal of the individual in accordance with advice from the LADO and/or HR.

Whistleblowing

Whistleblowing is defined as ‘making a disclosure in the public interest’ and occurs when a worker (or member of the wider RTB community) raises a concern about danger or illegality that affects others, for example learners in the RTB or members of the public.

All staff members are made aware of the duty to raise concerns about the attitude or actions of staff in line with the RTB’s separate Code of Conduct and Whistleblowing policy.

We want everyone to feel able to report any safeguarding concerns.

Appendix

Appendix A  Safeguarding Risk Form.docx
Appendix B Safeguarding team contact info & reporting.docx