Safeguarding Policy and Procedure including the Prevent Duty - June 2020
INTRODUCTION AND PURPOSE
As well as needing to provide a safe and secure environment under UK law, New Directions is committed to helping all learners achieve their best by making sure they feel comfortable and safe in all learning locations, including those of our subcontractors and other delivery partners. The Safeguarding Policy tells everyone how this is going to be achieved. It also gives certain people responsibilities and tasks to make sure it happens. The Policy applies to all staff, sub-contractors, delivery partners, learners, volunteers and regular visitors. New Directions will do everything it can to protect young people and vulnerable adults from:
- Neglect, physical abuse, sexual abuse, emotional abuse, psychological abuse
- bullying, including online bullying and prejudice-based bullying
- racist, disability and homophobic or transphobic abuse
- gender-based violence/violence against women and girls
- radicalisation and/or extremist behaviour
- child sexual exploitation and trafficking
- domestic violence
- female genital mutilation
- forced marriage
- financial or material abuse
- Modern slavery
- Self-neglect – this covers a wide range of behaviour neglecting to care for one’s personal hygiene, health or surroundings and includes behaviour such as hoarding.
- Other issues not listed here but that pose a risk to young people and vulnerable adults.
It is hoped that learners will feel free to discuss any concerns they have which may affect successful learning and will view New Directions as a safe place if there are any difficulties elsewhere in their lives.
The Prevent duty is the duty in the Counter-Terrorism and Security Act 2015 on specified authorities, in the exercise of their functions, to have due regard to the need to prevent people from being drawn into terrorism. This policy outlines how New Directions will aim to achieve this.
DEFINITION OF SAFEGUARDING
Although New Directions predominantly offers Adult and Community Learning to those over the age of 19, it has recently started delivering Apprenticeships to a small number (less than 10) of young people under the age of 18 and therefore this policy has been written to include safeguarding for young people as well as adults.
Young People: In relation to children and young people, safeguarding and promoting their welfare is defined in ‘Working together to safeguard children’ as:
- protecting children from maltreatment
- preventing impairment of children’s health or development
- ensuring that children grow up in circumstances consistent with the provision of safe and effective care
- taking action to enable all children to have the best outcomes
There is a different legislative and policy base for responding to adults’ safeguarding needs. The Care Act 2014 provides a legal framework for how local authorities and other parts of the health and care system should protect adults at risk of abuse or neglect. However, most of the principles and procedures that apply are the same as those for safeguarding children and young people.
Adult Safeguarding is defined as ‘protecting an adult’s right to live in safety, free from abuse and neglect.’ (Care and Support Statutory Guidance, Chapter 14.) Adult safeguarding is about preventing and responding to concerns of abuse, harm or neglect of adults. Staff should work together in partnership with adults so that they are:
- Safe and able to protect themselves from abuse and neglect;
- Treated fairly and with dignity and respect;
- Protected when they need to be;
- Able easily to get the support, protection and services that they need.
New Directions must also ensure that children are safeguarded. If we suspect that children around or associated to an adult are at risk of harm, we must act to protect them.
In addition to typical safeguarding definitions, there are many other broader aspects of safeguarding that must be considered as part of this policy and our wider work at New Directions. Other elements of safeguarding include:
- Dealing with bullying
- Whistle Blowing
- Allegations against staff
- Prevent Strategy
- Curriculum and Safety
- A listening college
- Media and E-Safety
- Health and Safety
- Safe recruitment and selection
- Staff Conduct
- Relationships and behaviours
- Student Induction
New Directions has a statutory and moral duty to ensure that we promote the welfare of young people and vulnerable adults receiving education and training with us; or under the auspices of New Directions.
Where reference is made to ‘young people’ the term is used to mean those under the age of 18. New Directions recognises that some adults (age 19+) are also vulnerable to abuse and these procedures have been developed to apply to the protection of vulnerable adults, and allegations of abuse of this nature, as well as those under the age of 18.
New Directions promotes an ethos where everyone feels secure, are encouraged to talk and are listened to. Due to the duty to protect learners from harm, when concerns are raised we will not make promises we cannot keep and we will not keep secrets. Every learner will normally be told by the member of staff they have chosen to talk to, what will happen next.
New Directions recognises the positive contribution it can make towards protecting its learners from radicalisation towards violent extremism. Through Learner Voice and the tutorial programme, it will continue to help the learners to create communities that are resilient to extremism and protect the wellbeing of particular learners who may be vulnerable to being drawn into violent extremism or crime. It will also continue to promote the development of spaces for free debate where shared values can be reinforced.
New Directions is committed to ensuring:
- A safe environment for young people and vulnerable adults to learn in;
- That young people and vulnerable adults who are suffering, or are likely to suffer significant harm are identified;
- That we will take appropriate action to see that such young people and vulnerable adults are kept safe at New Directions; and
- Appropriate measures are implemented to keep learners safe from radicalisation and promote British values.
To achieve these aims New Directions will annually review the policy and procedure with the aim of:
- Raising awareness of issues relating to the welfare of children, young people and vulnerable adults and the promotion of a safe environment for them to learn within New Directions;
- Aiding the identification of children, young people and vulnerable adults at risk of significant harm, providing procedures for reporting concerns;
- Discharging the institutions statutory duties with regard to the PREVENT strategy;
- Establishing procedures for reporting and dealing with allegations of abuse against members of staff; and
- The safe recruitment of staff
In developing the policy and procedure New Directions will consult with, and take account of, guidance issued by the Department for Education and other relevant bodies and groups.
It is not New Directions' responsibility to investigate abuse. Nevertheless, it must act if there is cause for concern and must notify the appropriate agencies so that they can investigate and take the necessary action.
New Directions will refer concerns that a child, young person or vulnerable adult might be at risk of significant harm to the Local Authority Social Services or other appropriate agencies.
New Directions has strong links with the Local Authority for Safeguarding Matters.
Appropriate New Directions staff will contact the LA Safeguarding Teams as required. They have full knowledge of the local authority safeguarding procedures and have contact with the Local Authority Designated Officer (LADO).
The Principal and all staff working with young people and vulnerable adults will receive training adequate to familiarise them with safeguarding issues and their responsibilities within New Directions’ policy and procedures; with refresher training annually. A member(s) of the Senior Management Team will have special responsibility for safeguarding issues.
The Designated Senior Safeguarding Manager who has lead responsibility for safeguarding in the Assistant Principal – Business Support. Senior managers will ensure that there is a mechanism in place to assist staff to understand and discharge their responsibilities in respect of Safeguarding young people and vulnerable adults. Staff will receive regular Safeguarding updates via the intranet News Items and monthly staff bulletins.
STAFF WITH SPECIFIC SAFEGUARDING RESPONSIBILITIES
The staff listed below have specific responsibilities:
- Assistant Principal – Business Support
(Designated Senior Safeguarding Manager)
- Principal and Deputy Principal
(Deputy Senior Safeguarding Managers)
- Curriculum Managers
ROLES AND RESPONSIBILITIES
The Designated Senior Safeguarding Manager with lead responsibility for safeguarding issues is the Assistant Principal – Business Support. This person is a senior member of the New Directions management team. They have a key duty to take lead responsibility for raising awareness across all staff of issues relating to the welfare of young people and vulnerable adults learning within New Directions.
The Assistant Principal has received training in safeguarding issues and inter-agency working and will receive refresher training annually. The AP also has specific additional training focused on the PREVENT strategy and aspects of FGM, Forced Marriage and so-called Honour Based Abuse. This is included in L3 Training.
The Assistant Principal is supported in their Safeguarding responsibilities by the Principal and Deputy Principal, and other appropriate staff.
These designated staff members are responsible for:
- Overseeing the referral of cases of suspected abuse or allegations to the relevant investigating agencies;
- Providing advice and support to other staff on issues relating to safeguarding;
- Maintaining a proper record of any child protection referral, complaint or concern (even where that concern does not lead to a referral);
- Ensuring that parents of young people within New Directions are aware of New Directions’ safeguarding policy;
- Liaising with the Local Authorities and other appropriate agencies;
- Liaising with employers and training organisations that receive young people from New Directions on long term placements i.e. Apprenticeships to ensure that appropriate safeguards are put in place;
- Ensuring that staff receive basic training in safeguarding issues appropriate to their roles and are aware of New Directions safeguarding procedures; and keeping and maintaining a central record of this; and
- All learners, including off site learners or learners on excursions or trips
The designated senior member of staff will provide an annual report setting out how New Directions has discharged its duties. They are responsible for reporting deficiencies in procedure or policy identified to the senior management team.
Other Designated Staff Members
Other members of staff with specific responsibility for safeguarding issues are:
- Principal and Deputy Principal
- Curriculum Managers
These designated staff:
- Know how to make an appropriate referral within New Directions;
- Are available to provide advice and support to staff on issues relating to safeguarding;
- Are available to listen to young people and vulnerable adults studying at New Directions
- Deal with individual cases, including attending case conferences and review meetings as appropriate; and
- Have been trained in safeguarding issues and receive refresher training annually.
All staff at New Directions must be familiar with this policy and must undertake relevant Safeguarding and Prevent training in line with their role. This includes volunteers.
SUBCONTRACTORS AND DELIVERY PARTNERS
This policy applies across all provision delivered by New Directions, this includes provision delivered by partners and subcontractors. As such this policy is shared with all all partners and subcontractors and it is the expectation of New Directions that the policy will be implemented in full by these partner organisations.
In addition, New Directions will expect all subcontractors to demonstrate the following:
- All staff have recently undergone accredited Safeguarding training (within the last 2 years) and have evidence of such and will have annual refresher training.
- All staff have recently undergone accredited Prevent training (within the last 2 years) and have evidence of such and will have annual refresher training.
- Every provider has a designated Safeguarding Lead who has had the appropriate training to carry out the role
- All learners are informed of at least 3 ways of reporting a safeguarding or Prevent concern (e.g. to a tutor, a manager or a number to call) and learners are protected and feel safe.
New Directions expects partners and subcontractors to be able to demonstrate that they meet all regulations and duties for the purposes of the safeguarding as part of the contract and performance management. This will be checked through annual safeguarding checks carried out by the Assistant Principal. Failure to comply with the legal duty for Safeguarding will result in termination of the contract.
DEALING WITH A DISCLOSURE OF ABUSE AND PROCEDURE FOR REPORTING CONCERNS
Where a young person/vulnerable adult discloses abuse to a member of staff the member of staff should report the disclosure to their line manager and at least one of the designated safeguarding staff at New Directions (contacts listed below) within 2 hours of hearing the allegation. Failure to do so may result in disciplinary action or in the case of subcontractors – termination of contract. They should also make a record using the report form. This must be provided as soon as possible and no later than 2 hours after the disclosure. The member of staff concerned should follow the guidelines outlined when hearing the allegation.
KEY CONTACTS AT NEW DIRECTIONS:
Andrea Wood – Principal and Designated Safeguarding Officer
Mobile: 07811 685 850
Landline: 0118 937 4053
A. If a Young Person or Vulnerable Adult Tells You About Possible Abuse:
- Listen carefully and stay calm.
- Do not interview them, but question normally and without pressure, in order to be sure that you understand what the individual is telling you;
- Do not put words in their mouth.
- Reassure, that by telling you, they have done the right thing.
- Inform the learner that you must pass the information on, but only to those that need to know about it will be told. Inform them who you will report the matter to.
- Note the main points carefully – notes as taken should be submitted and not edited.
- Make a detailed note of the date, time, place and what the learner said, did and your questions.
Where a member of staff suspects that a young person or vulnerable adult is being abused the member of staff should not investigate concerns or allegations themselves but should report them immediately to a designated person who will determine the appropriate action.
Information relating to actual, suspected or alleged abuse should be treated with the utmost care. The designated member of staff should ensure that information is shared only with those staff that need to be aware of it. No one should be given more information than is necessary to support the young person or vulnerable adult.
B. Reporting and dealing with allegations of abuse against a member of staff:
In rare instances, staff in educational institutions has been found to be responsible for child abuse. Because of their frequent contact with children and young people, staff may have allegations made against them. New Directions recognises that an allegation of child abuse made against a member of staff may be for a variety of reasons and that the facts of the allegation may or may not be true.
New Directions recognises that the Children’s Act 1989 states that the welfare of the child is of paramount concern and will deal with any allegations of this nature sensitively and will act in a careful and measured way.
Where an allegation is made about another member of staff the allegation should be reported immediately to the Assistant Principal Business Support and Principal unless they or the Principal are the person(s) the allegation has been made against; in which case the Assistant Director of Economic Growth and Neighbourhood Services should be informed.
In the first instance, the Principal, or where the Principal is the subject of an allegation, the Assistant Director of DEGNS, in the role of ‘case manager’ should immediately discuss the allegation with the Designated Senior Safeguarding Manager. The purpose of this initial discussion is for the safeguarding manager and the case manager to consider the nature, content and context of the allegation and agree a course of action. The safeguarding manager may ask the case manager to provide or obtain relevant additional information, such as previous history, whether the young person or their family have made similar allegations previously and the individual’s current contact with young people/vulnerable adults. There may be situations when the case manager will want to involve the police immediately, for example if the person is deemed to be an immediate risk to children/yp/vulnerable adults or there is evidence of a possible criminal offence. Where there is no such evidence, the case manager should discuss the allegations with the safeguarding manager in order to help determine whether police involvement is necessary.
If it is agreed an internal investigation should take place the Assistant Principal will:
- Inform the young person/vulnerable adult or parent/carer making the allegation that the investigation will take place and what the likely process will involve;
- Ensure that the parents/carers of the young person/vulnerable adult making the allegation have been informed that the allegation has been made and what the likely process will involve;
- Make arrangements with Case Manager to inform the staff member against whom the allegation was made of the fact that the investigation is taking place and what the likely process will involve, including considering, with the Human Resources staff, if a period of suspension from work is warranted;
- Where a strategy discussion is needed, or police or social care services need to be involved, advise the case manager not to inform the staff member until those agencies have been consulted, and have agreed what information can be disclosed to the accused.
- Keep a written record of the action taken in connection with the allegation.
The investigation and any action arising from the investigation will be conducted in accordance with the existing staff disciplinary procedures. If a member of staff is dismissed or resigns before the disciplinary process is completed, he/she should be informed of New Directions’ statutory duty to report Safeguarding concerns under the Disclosure and Barring Services Barred Lists procedures.
As a result of any investigation of this nature the Assistant Principal will review the process and identify whether there are any matters arising from it that could lead to the improvement of New Directions’ procedures including training needs of staff, and report any recommendations to the Principal.
STATUTORY DUTIES – PREVENT, including the promotion of British Values
Prevent is 1 of the 4 elements of CONTEST, the government’s counter-terrorism strategy. It aims to stop people becoming terrorists or supporting terrorism. The PREVENT strategy:
- responds to the ideological challenge we face from terrorism and aspects of extremism, and the threat we face from those who promote these views;
- provides practical help to prevent people from being drawn into terrorism and ensure they are given appropriate advice and support;
- works with a wide range of sectors (including education, criminal justice, faith, charities, online and health) where there are risks of radicalisation with which we need to deal.
The strategy covers all forms of terrorism, including far right extremism and some aspects of non-violent extremism.
Recognising its statutory duties, New Directions is committed to supporting vulnerable learners through its safeguarding agenda in order to prevent potential radicalisation. All staff, governors, partners and subcontractors must undertake training on Prevent and understand the notice, check and share approach. Notice: They should be aware of any behaviour which leads to any safeguarding concerns including Prevent duty related ones. Check: they should check the concerns. Share: they should refer any concerns to the safeguarding officer. All Prevent concerns will be treated as safeguarding concerns and will be dealt with accordingly.
RADICALISATION AND THE PREVENT DUTY
Radicalisation is the process by which individuals come to support terrorism or violent extremism. There is no typical profile for a person likely to become involved in extremism, or for a person who moves to adopt violence in support of their particular ideology. Although a number of possible behavioural indicators are listed below, staff should use their professional judgement and discuss with other colleagues or external partners if they have any concerns:
- Use of inappropriate language
- Possession of violent extremist literature
- Behavioural changes
- The expression of extremist views
- Advocating violent actions and means
- Association with known extremists
- Seeking to recruit others to an extremist ideology
In addition to reporting Prevent concerns to the necessary authorities, New Directions has a duty to use opportunities in the curriculum to challenge extremism and to promote British values.
Extremism is defined as: 'Vocal or active opposition to fundamental British values and calls for the death of members of our armed forces, whether in this country or overseas'.
British values are defined as: 'Democracy, the rule of law, individual liberty and mutual respect and tolerance for those with different faiths and beliefs'.
New Directions will aim to integrate British values and preventing the exploitation of vulnerable individuals into curriculum areas in the following ways:
- Use of opportunities in the curriculum e.g. the teaching of health and safety law and employment law in vocational areas
- Discussion about the impact of democracy in topics taught e.g. health and safety and employment law
- Rules for effective classroom behaviour which demonstrate tolerance and mutual respect for faiths and beliefs
- Discussion of individual freedom in relation to careers and education
- Critical analysis of online content
- Staff to develop critical thinking approaches to all teaching
- Support apprentices to see how British values e.g. mutual respect and tolerance are relevant to their workplace experience
- Support a positive environment to discuss challenging and current issues with students
- Provide positive encouragement to students to engage in activism and politics but avoid extremism.
If anyone has any significant concerns about a learner beginning to support terrorism and/or violent extremism, they should discuss the individual with the Designated Safeguarding Officer.
OTHER RELEVANT POLICIES AND PROCEDURES
New Directions has established recruitment and selection procedures for staff that support safeguarding and promote the welfare of young people and vulnerable adults. These procedures ensure that New Directions has robust background checks to assess the suitability of applicants to work in an environment of young people and vulnerable adults.
The recruitment and selection procedures are reviewed annually and meet the criteria for safe recruitment and address the legislative responsibilities overseen by the Disclosure and barring service. All New Directions College Staff will be subject to Enhanced DBS checks.
MANAGEMENT OF VISITORS
Visitors to New Directions are to be directed to the Reception area at any delivery site. The member of staff meeting visitors is required to enter the visitor's name in the Visitors’ Book held at the Reception counter. The visitor will be issued with an identification badge which must be worn at all times whilst on the premises. Visitors must be met at the Reception area by a member of staff and accompanied to the arranged activity by them.
On completion of the activity, the visitor should be accompanied back to Reception to facilitate them being booked out and returning their visitor’s badge. Staff are encouraged to make their visitors aware of the necessary emergency procedures on arrival at New Directions to ensure they are provided with a Safeguarding leaflet. Reception staff must receive prior notification of visitors in order to provide the appropriate response.
TRAINING FOR VOLUNTEERS
New Directions recognises that some individuals wish to gain work experience or contribute to the community through unpaid volunteering activities from time to time. Whilst New Directions supports the opportunities that volunteering provides to both parties, it is important that appropriate consideration is given to the suitability of the volunteer in relation to the voluntary work in advance of the commencement of voluntary work.
The standard recruitment process will be used to approve a voluntary work opportunity and ensure the suitability of the volunteer worker. Whilst volunteers undertaking unpaid work are under no obligation to provide services to New Directions, they will be asked to sign a Volunteer Handbook prior to commencement, which sets out the expectations that New Directions has and the basis upon which the voluntary work is provided.
As part of New Directions’ expectations volunteers will be required to undertake induction and familiarisation, mandatory training, including: Safeguarding & PREVENT; Health & Safety; and Equality & Diversity.
MONITORING AND REVIEW
The Senior Management Team will monitor and evaluate the implementation of the policy. The policy will be reviewed annually.
The following steps are taken to ensure that all learners and visitors are able to report any suspected abuse:
- Adult Safeguarding Posters in all classrooms & Centre Receptions
- Leaflets available at Centre Receptions
- New Directions Learner Handbook has details on how to report abuse and PREVENT awareness.
- PREVENT resources available on Moodle to allow for embedding in schemes of work.
- Summary of British Values present in all classrooms and embedded in schemes of work.
Review due: 16.05.2020
APPENDIX A Guidelines for Staff and Volunteers
Guidance for staff, volunteers and partners dealing with Disclosures of Abuse and Procedures for Reporting Concerns
If a learner tells you that he/she has been physically, sexually, emotionally or psychologically abused in any way you should:
- Listen to their story without any prompting or leading questions.
- Reassure the learner that what they are telling you is being taken very seriously.
Do not promise the learner that what they are telling you will be kept totally confidential. Explain that in order for you to help them you will need to discuss what you have been told with a designated ‘Safeguarding’ member of staff.
Question. What are some of the symptoms of abuse? It must be stressed that every young person or vulnerable adult is different and symptoms will vary from individual to individual.
Answer. If abuse starts happening to a young person or vulnerable adult their behaviour is likely to change, a calm person may become loud and disruptive; a lively person may become quiet and withdrawn.
The young person or vulnerable adult may:
- Present with bruises and injuries that they have difficulty explaining or that are in places where it is difficult to hurt yourself accidentally, i.e. neck, cheeks, eyes, shoulders and the top of the arms
- Be scared, tearful and may present unusual, difficult or strange behaviour
- Self-harm or place themselves in risky situations, even attempt suicide
Question. What if a young person or vulnerable adult tells you that they are being abused?
Answer. Take them seriously; it will have taken a lot of courage to tell someone. Reassure them that they have done the right thing in telling someone. Do not promise to keep what they tell you a secret, if the young person/vulnerable adult ask you to, tell them that you may have to tell someone else to get further help and to keep them safe. Thank them for telling you and follow the procedures.
Question. What if you suspect a young person or vulnerable adult is being abused?
Answer. It is not your job to establish whether or not the young person or vulnerable adult is telling the truth. It is your job to pass on your concerns:
- Listen carefully and stay calm;
- Do not interview the young person, but question normally and without pressure, in order to be sure you understand what you are being told;
- Write down what is being said using the young person’s words;
- Do not put words into the young person’s mouth;
- Reassure them that by telling you, they have done the right thing;
- Stress that information given will be treated confidentially and inform the young person that you must pass the information on but that only those who need to know about it will be told. Inform them of to whom you will report the matter.
- Ensure that the parents or carers are kept informed – notwithstanding the above
You should not investigate concerns or allegations yourself but should report them immediately to one of the New Directions Safeguarding members of staff.
All information disclosed to you should be treated as confidential and must not be passed on to personal tutors or other New Directions employees, except within the New Directions Safeguarding structure.
Where concerns and or allegations involve a member of staff you should report them immediately to the senior member of staff with lead responsibility for Safeguarding, the Assistant Principal – Business Support, or the Deputy Principal. These senior managers will ensure that the Principal is notified.
If for any reason you feel unable to raise an issue with managers or where you perceive that your genuine concerns are not being addressed, you should follow the Reading Borough Council’s Whistleblowing procedures. As a last resort, where internal channels might be inappropriate the government backed NSPCC Whistleblowing Helpline is available from 08:00 to 20:00, Monday to Friday, on 0800 028 0285. Out of hours you can use their email address: firstname.lastname@example.org. You can also write to:
42 Curtain Road
APPENDIX B SAFEGUARDING REPORT FORM
|Learner TERMS ref:||Staff Member:|
|Date of disclosure:||Time of disclosure:|
|Record of details|
|Immediate advice and guidance offered||Emergency action already taken|
Please forward this to:
Andrea Wood – Principal and Designated Safeguarding Officer
Mobile: 07811 685 850
Landline: 0118 937 4053
APPENDIX C CODE OF CONDUCT
Code of Conduct for Staff and Volunteers working with Young Learners and Vulnerable Adults
This code has been drawn up to assist in maintaining entirely proper and professional relationships with young learners and vulnerable adults. It is stressed that this code is not a legal document but is intended to provide guidance to employees in carrying out their responsibilities. However, a breach of the code by a member of staff may result in disciplinary action, which in some cases could lead to dismissal.
Individuals should be prudent about their own conduct and vigilant about the conduct of others, so that their relationships with young learners and vulnerable adults remain and are seen to remain entirely proper and professional. It is recognised that when working with children or adults, individuals are vulnerable to the possible consequences of their close professional relationships with young learners and to the potential for malicious and misplaced allegations being made by young learners or vulnerable adults, either deliberately or innocently, arising from the normal proper associations that staff may have with them.
Code for all Relevant Staff and Volunteers
- As a general principle, individuals should not have unnecessary physical contact with their young learners or vulnerable adults. There may be very limited occasions when a learner needs comfort or reassurance, which may include physical comforting. Any such comforting gestures must always be acceptable to the young person concerned i.e. there should be no unwanted physical contact, however well intentioned. However, be aware that any physical contact may be misconstrued by a learner, parent/carer or observer.
Such contact can include well-intentioned informal and formal gestures such as putting a hand on the shoulder or arm, which, if repeated with an individual young learner, could lead to serious questions being raised.
- Some individuals are likely to come into physical contact with young learners and vulnerable adults from time to time in the course of their training activities, for example when showing a young learner or vulnerable adult how to use a piece of apparatus or equipment. You should give a clear explanation of the intended activity and ask the young person or vulnerable adult if it is alright to proceed. Individuals should be aware of the limits within which such contact should properly take place and should consider the possibility of such contact being misinterpreted by the young learner or vulnerable adult.
- Any form of physical punishment of young learners or vulnerable adults is unlawful, as is any form of physical response to misbehaviour unless it is by way of restraint. It is particularly important that employees understand this both to protect their own position and that of the organisation and the educational establishment.
- There may be occasions where it is necessary to physically restrain a young learner or vulnerable adult to prevent him/her from inflicting injury to himself/herself or others. In such cases only the minimum force necessary must be used and any action taken must be to restrain a young learner or vulnerable adult. Where an individual has taken action to restrain a young learner or vulnerable adult he/she should report the matter to their manager and should complete an incident report form.
The Practice of Physical Restraint
- Restraint can be defined as the reasonable application of the minimum necessary force to overpower a young person or vulnerable adult with the intention of preventing them from harming themselves or others, or from causing serious damage to property.
- Restraint should only be used exceptionally, when unavoidable and in keeping with the incident leading to it. It should be primarily for the benefit of the young person/s and, though immediate, should, as far as possible, be a considered response.
- Restraint should not be used as a form of punishment or, in normal circumstances, to enforce compliance with instructions. It should not be attempted where the member of staff is put at undue risk.
- Incidents of restraint should, in appropriate circumstances, be subject to debriefing for staff and volunteers involved and lead to a review of strategies for managing the behaviour of young learners and vulnerable adults between relevant parties, e.g. manager, teacher, parent/carer, trainer etc. All incidents should be recorded, in writing, with witness statements etc. Please refer to the
- Where staff or volunteers are the subject of physical attack by young learners or vulnerable adults or their parents/carers, they should refer to the guidance provided by New Directions and report the incident immediately to their manager or the duty officer.
Sexual Contact (in relation to young people under 18 and vulnerable adults)
- There is NO acceptable behaviour that involves either explicit sexual acts or innuendos. Any such behaviour will always be treated as extremely serious and must be reported immediately.
Meetings with Young Learners
- Staff and volunteers should be aware of the potential risks which may arise from interviewing individual young learners and vulnerable adults in private. It is recognised that there will be occasions when confidential interviews must take place but, where possible, such interviews should be conducted in a room with visual access or with the door open, or in a room or area which is likely to be frequented by other people. Meetings with young learners and vulnerable adults away from educational or business premises normally utilised e.g. home or off-side visits should not take place unless specific approval has been obtained from those responsible for the learner (e.g. Line Manager).
- Where such conditions cannot apply, staff and volunteers are advised to ensure that another adult knows that the interview is taking place.
- If it is necessary to detain a young learner or vulnerable adult for any length of time after the end of normal hours, prior warning must be given to the young learner’s or vulnerable adult’s parents/carers.
- If a young person or vulnerable adult complains of injury or sickness, he/she should be referred to a person qualified in first aid or advised to see his/her own doctor. The young learner’s or vulnerable adult’s parents/carers should also be informed, if appropriate. Where there is a potential threat to life, or the possibility of a significant deterioration in a learner’s condition over time, professional medical support must be sought by dialling 999 or 111, as appropriate.
- Staff or volunteers that have to administer first aid (normally a trained First Aider) should ensure, wherever possible, that another adult is present, if they are in any doubt as to whether necessary physical contact could be misconstrued.
- Another adult should accompany staff or volunteers who have to help young learners and vulnerable adults with personal care and young learners and vulnerable adults should, wherever possible, be encouraged to deal with such matter themselves.
- Where it is necessary to assist with/supervise dressing or undressing, staff must be of the appropriate gender and be careful to protect the dignity of the young person or vulnerable adult.
- Male staff or volunteers should not, as a general rule, enter female toilets nor should female staff enter male toilets, except in extreme situations such as fire, or where there may be a threat to life or limb.
- All first aiders must have a DBS check – their qualifications are to be updated on a regular basis.
Provision of Advice and Guidance
Staff or volunteers may be approached by young learners or vulnerable adults for advice. Young learners or vulnerable adults may also appear distressed and staff may feel the need to ask if all is well. In such cases staff must judge whether it is appropriate for them to offer counselling and advice or whether to refer the young learner to a member of staff or another gender or to one with acknowledged expertise, experience or responsibility for that young learner or vulnerable adults. Staff and volunteers must, in these circumstances, use their discretion to ensure that any probing for details cannot be construed as unjustified intrusion.
Staff and volunteers are advised never to stop a free-flowing account/disclosure of abuse but to make sure that at an appropriate point they inform the young person or vulnerable adult that they cannot keep such information confidential and need to tell someone else to get help. Example “Thank you for telling me, I now need to tell (where possible give the name and position of who will be told) so that we can get some help for you”.
- A young learner or vulnerable adult may ask a member of staff or volunteer to “keep a secret”, or to promise not to tell other people what they are about to tell them, where this happens the member of staff must explain that they are not able to promise confidentiality as they need to tell someone else if they are to help the young person.
- Where a young person or vulnerable adult is told by a member of staff or volunteer that they cannot promise confidentiality the young person may decide not to continue telling. If a young person starts to say something and then stops, the member of staff needs to try to leave it open for the young person to come back to the discussion; the member of staff must act, following the Safeguarding Procedures and inform one of the Safeguarding Officers.
- Social contact with young learners and vulnerable adults, other than that which is based at New Directions or formally organised by New Directions, should be positively resisted.
- It is recognised that there may be occasions when accidental or reasonable social contact may be unavoidable e.g. meeting young learners and vulnerable adults at social venues open to the general public or in shops or at private parties. In such circumstances staff should be mindful at all times of their professional relationship with young learners and vulnerable adults.
- Increasingly staff or volunteers may contact young learners and vulnerable adults via use of technology e.g. the Internet, social sites and mobile phones. When using these forms of communication, staff should be careful in their use of language/terminology or images that may be misconstrued or perceived to be inappropriate.
- All digital communications with learners must be carried out in line with the New Directions Acceptable Use policies and be professional in tone and content at all times. Online communication with learners may carry risk and therefore, should only be conducted through New Directions hosted networks. The use of social networking sites and other sites not hosted by New Directions may be used only where a risk assessment has been completed by the member of staff and prior permission has been obtained from an appropriate manager.
- Staff must not accept social media ‘friend’ requests from learners without line manager approval except where the member of staff has a connection with the learner beyond the context of the institution.
General Relationships with Young Learners and Vulnerable Adults
- Staff or volunteers should ensure that their relationships with young learners and vulnerable adults are appropriate to the age and gender of the young learner or vulnerable adult, taking care that their conduct does not give rise to comment or speculation. Attitudes, demeanour and language all require care and thought, particularly when dealing with adolescents.
- Comments by staff or volunteers to young learners or vulnerable adults, either individually or collectively, can be misconstrued. As a general principle, staff must not make unnecessary comments to and/or about young learners and vulnerable adults which could be construed to have a sexual connotation. It is also unacceptable for staff to introduce or to encourage debate amongst young learners and vulnerable adults in a class, training situation or elsewhere, which could be construed as having a sexual connotation that is unnecessary given the context of the training session or the circumstances. However, it is recognised that a topic raised by a young learner or vulnerable adult is best addressed rather than ignored.
- Staff and volunteers should be careful in their use of language and/or terminology that may be misconstrued.
- The systematic use of insensitive, disparaging or sarcastic com comments is unacceptable.
- If staff or volunteers, at any time, feel that their relationship with a young learner or vulnerable adult is developing into one that would be in appropriate between a member of staff/volunteer and a young learner or vulnerable adult, it is their responsibility to discuss the situation with their line manager.
Learners must not be transported as passengers in a member of staff’s private vehicle at any time; except with the explicit sanction of SMT
Reporting of Incidents
- Following any incident where a member of staff or volunteer feels that his/her actions have been, or may be, misconstrued, the member of staff should report the matter to their manager.
- Such reporting is especially important in any case where a member of staff or volunteer has been obliged to restrain a young person or vulnerable adult physically to prevent him/her from inflicting injury to others or themselves, or where he/she has been personally attacked by another young learner, parent or carer.
APPENDIX D Arrangements for Visiting Groups & Speakers
Section 21 of the Counter-Terrorism and Security Act 2015 (the Act) places a duty on certain bodies, listed in Schedule 3 to the Act, to have “due regard to the need to prevent people from being drawn into terrorism”. The Act states that the authorities (including Further Education and Skills institutions) subject to the provisions must have regard to this guidance when carrying out the duty.
New Directions takes seriously its responsibility to exclude those promoting extremist views that support or are conducive to terrorism. Outside speakers who are deemed to have extremist views are not to be invited into New Directions.
New Directions has a robust system for assessing and rating risks associated with any planned events and visiting speakers, providing evidence to suggest whether an event should proceed, be cancelled or whether mitigating action is required (for example a member of staff alerting the further education Prevent coordinators to concerns in relation to a guest speaker). At the outset, organisers must satisfy themselves that the proposed title or theme of the event does not present a potential risk that views/opinions expressed by speakers may be in breach of the law.
All instances where Groups or individuals have been invited to a New Directions site to interact with learners must be entered on TERMS; selecting ‘Visiting Speaker’ as either the primary or secondary purpose. Event organisers will be required to provide answers to the following questions:
- Do any of the subjects likely to be covered by the visiting speaker or group have the potential to affect any particular group of learners either positively or negatively?
- Is the invited speaker or group known to hold any extremist views, whether violent or non-violent?
- Briefly outline the arrangements you have put in place to supervise the visiting speaker or group during their time on New Directions premises
A generic risk assessment is available which highlights the Safeguarding factors which must be taken into account during visits by groups or speakers. Curriculum Managers are responsible both for approving such visits and ensuring appropriate mitigation are in place to counter any associated risks.
All visiting speakers are to be supervised by a member of New Directions staff, who are expected to interject or stop an event if they feel that the speaker is promoting extremist views or inequality in any form. Staff are required to book events using the TERMS system, with sufficient notice to allow the Senior Management Team to undertake checks and for cancellation to take place if necessary.
External Speaker Code of Conduct
It is the responsibility of the event organiser to ensure that:
- this Code of Conduct is communicated to all external speakers (once approved and confirmed via TERMS)
- that all reasonable steps are taken to ensure that the requirements within it are upheld during the running of the event or activity.
Freedom of speech is a fundamental right. However, whilst the law promotes and protects freedom of speech, it also places limits on those freedoms in order to maintain public order and safety and to ensure that there is no breach of the law. New Directions recognises that in this context a conflict exists between the laws which promote freedom of speech and those which restrict it and consequently acknowledges that it has a legal responsibility to create a balance between minimising the possibility that extremism or unlawful conduct will arise on site and ensuring that it meets its legal obligations in relation to securing freedom of speech. New Directions expects external speakers to act in accordance with the law and not to breach the lawful rights of others. Segregation by sex is not permitted in any events, lectures or meetings provided for students, or at events attended by members of the public or employees of New Directions. Segregation is therefore not permissible for any event involving external speakers or groups and covered by this Code of Conduct. The only exception to this is events that are for the purpose of collective religious worship.
Set out below are some examples of New Directions’ expectations however, this is not intended to be an exhaustive list of unacceptable conduct by external speakers. New Directions reserves the right to not permit an external speaker to speak at or attend an event, to refuse to permit an event and/or to halt an event at any time if it reasonably considers there may be a breach of any legal obligation.
During the course of the event at which he or she participates, no speaker shall:
- Act in breach of the criminal law.
- Incite hatred or violence or any breach of the criminal law.
- Encourage or promote any acts of terrorism or promote individuals, groups or organisations that support terrorism.
- Spread hatred and intolerance.
- Discriminate against or harass any person or group on the grounds of their sex, race, nationality, ethnicity, disability, religious or other similar belief, sexual orientation or age Defame any person or organisation.
- Raise or gather funds for any external organisation or cause without express permission of the Senior Management Team.
During the course of the event at which he or she participates, all speakers are to:
- Comply with the New Directions External Speaker Code of Conduct
- Present ideas and opinions, in particular those that may be contentious or potentially offensive, in the spirit of academic debate, being open to challenge and question.
- Follow New Directions policy on and instructions relating to health and safety.
Appendix E – What to do if you are worried about a child in Reading
Worried About a Child?
If you are a professional or volunteer and are concerned about a child you should discuss this with your safeguarding lead or manager in your agency and together agree the most appropriate course of action. This may be speaking with the family about the concerns and undertaking an early help assessment or signposting to appropriate services to address the family’s needs.
Any adult who is concerned that the situation is urgent or a child is at risk of suffering significant harm should consult or refer to the Children's Single Point of Access, Tel: 0118 937 3641, 9am to 5pm, Monday to Friday (excluding bank holidays). Outside these hours, contact the Emergency Duty Team on 01344 786543
If a child is at immediate risk dial 999 and ask for Police assistance.
You may find it helpful to use our thresholds guide (link on the right of the page) to inform the most appropriate course of action.
Safeguarding children is everyone's responsibility and it is important to act on concerns in a timely manner to ensure that children and their families get the right help at the right time to prevent problems escalating.
Follow this link to the Reading Borough Council website to find out more: RBC Concerned about a child
Where do I go for help?
The Children's Single Point of Access is how to raise a concern about a child (pre-birth to 18 years old) in Reading, including safeguarding and child protection. It is a single point of contact for all early help and children’s social care services, including disabled children.
There are 3 ways to contact the team:
- Using a web form, which is the most secure and effective way of requesting help for a child. The form can be found at: www.reading.gov.uk/childrensreferralform
- Calling the team on 0118 937 3641
- Emailing the team on ChildrensSinglePointofAccess@reading.gcsx.gov.uk
The Children's Single Point of Access is available 9am to 5pm, Monday to Friday (excluding bank holidays). Outside these hours, contact the Emergency Duty Team on 01344 786543.
Appendix F – Berkshire Safeguarding Adults Outline Guide