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The school aims to ensure that:
- Appropriate action is taken in a timely manner to safeguard and promote children’s welfare
- All staff are aware of their statutory responsibilities with respect to safeguarding
- Staff are properly trained in recognizing and reporting safeguarding issues
This policy is based on the Department for Education’s statutory guidance Keeping Children Safe in Education (2020) and Working Together to Safeguard Children (2018), and the Governance Handbook. We comply with this guidance and the arrangements agreed and published by our 3 local safeguarding partners.
This policy is also based on the following Governmnet guidance and legislation:
- Part 3 of the schedule to the Education (Independent School Standards) Regulations 2014, which places a duty on academies and independent schools to safeguard and promote the welfare of pupils at the school
- The Children Act 1989 (and 2004 amendment), which provides a framework for the care and protection of children
- Section 5B(11) of the Female Genital Mutilation Act 2003, as inserted by section 74 of the Serious Crime Act 2015, which places a statutory duty on teachers to report to the police where they discover that female genital mutilation (FGM) appears to have been carried out on a girl under 18
- Statutory guidance on FGM, which sets out responsibilities with regards to safeguarding and supporting girls affected by FGM
- The Rehabilitation of Offenders Act 1974, which outlines when people with criminal convictions can work with children
- Schedule 4 of the Safeguarding Vulnerable Groups Act 2006, which defines what ‘regulated activity’ is in relation to children
- Statutory guidance on the Prevent duty, which explains schools’ duties under the Counter-Terrorism and Security Act 2015 with respect to protecting people from the risk of radicalisation and extremism
Safeguarding and promoting the welfare of children means:
- Protecting children from maltreatment
- Preventing impairment of children’s mental and physical 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
Child protection is part of this definition and refers to activities undertaken to prevent children suffering, or being likely to suffer, significant harm.
A Child in Need is defined under the Children Act 1989 as a child who is unlikely to achieve and maintain a reasonable level of health or development, or whose health and development is likely to be significantly or further impaired, without the provision of services; or a child who is disabled.
Abuse is a form of maltreatment of a child, and may involve inflicting harm or failing to act to prevent harm. Appendix 1 explains the different types of abuse.
Neglect is a form of abuse and is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Appendix 1 defines neglect in more detail.
Sexting (also known as youth produced sexual imagery) is the sharing of sexual imagery (photos or videos) by children
Uskirting typically when a photograph is taken under a person's clothing without them knowing, for sexual gratification or to cause the victim humiliation, distress or alarm.
Children includes everyone under the age of 18.
The following 3 safeguarding partners are identified in Keeping Children Safe in Education and will make arrangements to work together to safeguard and promote the welfare of local children, including identifying and responding to their needs:
- The Oldham local authority (LA)
- A clinical commissioning group for an area within Oldham LA
- The chief officer of police for a police area within the Oldham LA
Some children have an increased risk of abuse, and additional barriers can exist for some children with respect to recognising or disclosing it. We are committed to anti-discriminatory practice and recognise children’s diverse circumstances. We ensure that all children have the same protection, regardless of any barriers they may face.
We give special consideration to children who:
- Have special educational needs (SEN) or disabilities (see section 9)
- Are young carers
- May experience discrimination due to their race, ethnicity, religion, gender identification or sexuality
- Have English as an additional language
- Are known to be living in difficult situations – for example, temporary accommodation or where there are issues such as substance abuse or domestic abuse
- Are at risk of FGM, sexual exploitation, forced marriage, or radicalisation
- Are asylum seekers
- Are at risk due to either their own or a family member’s mental health needs
- Are looked after or previously looked after
Safeguarding and child protection is everyone’s responsibility. This policy applies to all staff, volunteers and governors in the school. Our policy and procedures also apply to extended school and off-site activities.
5.1 All staff
All staff will read and understand part 1 and Annex A of the Department for Education’s statutory safeguarding guidance, Keeping Children Safe in Education, and review this guidance at least annually. A signed record of completion is kept for all staff.
All staff will be aware of:
- Our systems which support safeguarding, including this child protection and safeguarding policy, the staff code of conduct policy, the role and identity of the designated safeguarding lead (DSL) and deputy DSL, the behaviour and anti-bullying policy, and the safeguarding response to children who go missing from education (Appendix 3)
- The early help process and their role in it, including identifying emerging problems and liaising with the DSL/deputy DSL
- The process for making referrals to local authority children’s social care and for statutory assessments that may follow a referral, including the role they might be expected to play supporting the DSL/deputy DSL
- What to do if they identify a safeguarding issue or a child tells them they are being abused or neglected, including specific issues such as FGM, and how to maintain an appropriate level of confidentiality while liaising with relevant professionals
- The signs of different types of abuse and neglect, as well as specific safeguarding issues, such as child sexual exploitation (CSE), indicators of being at risk from or involved with serious violent crime, FGM and radicalisation
All staff should also be aware that mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation. Staff are well placed to observe students day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one. Where abuse and neglect have been suffered, or other potentially traumatic adverse childhood experiences (ACES), this can have a lasting impact throughout childhood, adolescence and into adulthood. It is key that staff are aware of how these children’s experiences, can impact on their mental health, behaviour and education.
All staff should be aware that safeguarding incidents and/or behaviours can be associated with factors outside the school or college and/or can occur between children outside of these environments. (Contextual safeguarding)
Section 13 and appendix 3 of this policy outline in more detail how staff are supported to carry out their role.
5.2 The designated safeguarding lead (DSL)
The DSL is Ashley Travis, Vice Principal for Student and Staff Wellbeing. The DSL takes lead responsibility for child protection and wider safeguarding.
During term time, the DSL will be available during school hours for staff to discuss any safeguarding concerns. Out-of-school hours, the DSL can be contacted via the email (including Operation Encompass alerts) and phone number on page 2.
When the DSL is absent, Martina Hutton is deputy DSL and will act as cover.
If the DSL and deputy are not available, Mr Giles, Principal will act as cover (for example, during out-of-hours/out-of-term activities).
The DSL is given the time, funding, training, resources and support to:
- Provide advice and support to other staff on child welfare and child protection matters
- Take part in strategy discussions and inter-agency meetings and/or support other staff to do so
- Contribute to the assessment of children
- Refer suspected cases, as appropriate, to the relevant body (local authority children’s social care, Channel programme and/or police)
The DSL also keeps the Principal informed of any issues, and liaises with local authority case managers and designated officers for child protection concerns as appropriate.
The full responsibilities of the DSL and deputy are set out in their job description.
5.3 The Local governing body (LGB)
The LGB will approve this policy annually to ensure it complies with the law and hold the Principal to account for its implementation.
A Safeguarding lead governor has been appointed to monitor the effectiveness of this policy in conjunction with the LGB.
The chair of governors will act as the ‘case manager’ in the event that an allegation of abuse is made against the Principal, where appropriate.
All governors will read Keeping Children Safe in Education. Please also refer to section 13.
5.4 The Principal
The Principal is responsible for the implementation of this policy, including:
- Ensuring that staff (including temporary staff) and volunteers are informed of the systems which support safeguarding, including this policy, as part of their induction
- Communicating this policy to parents/carers when their child joins the school and via the school website
- Ensuring that the DSL has appropriate time, funding, training and resources, and that there is always adequate cover if the DSL is absent
- Ensuring that all staff undertake appropriate safeguarding and child protection training and update this regularly
- Acting as the ‘case manager’ in the event of an allegation of abuse made against another member of staff or volunteer, where appropriate
The Hathershaw College has the following principles with regards to sharing information within the College/Pinnacle Learning Trust, our 3 safeguarding partners and other educational providers:
- Timely information sharing is essential to effective safeguarding including for students moving onto College in order to ensure that the post 16 provider and their staff, know who these students are, understand their academic progress and attainment and maintain a culture of high aspirations for this cohort; supporting teaching staff to identify the challenges that students in this group might face and the additional academic support and adjustments that they could make to best support these students.
- Fears about sharing information must not be allowed to stand in the way of the need to promote the welfare, and protect the safety, of children
- The Data Protection Act (DPA) 2018 and GDPR do not prevent, or limit, the sharing of information for the purposes of keeping children safe
- Staff should never promise a child that they will not tell anyone about a report of abuse, as this may not be in the child’s best interests
- The government’s ‘Information Sharing Advice for Safeguarding Practitioners’ includes 7 ‘golden rules’ for sharing information, and will support the DSL/deputy DSL who have to make decisions about sharing information
- If staff are in any doubt about sharing information, they should speak to the designated safeguarding lead (or deputy)
- Confidentiality is also addressed in this policy with respect to record-keeping in section 12
Staff, volunteers and governors must follow the procedures set out below in the event of a safeguarding issue.
7.1 If a child is suffering or likely to suffer harm, or in immediate danger
Tell the DSL/deputy DSL immediately. The DSL/deputy DSL will then make a referral to children’s social care and/or the police if they believe a child is suffering or likely to suffer from harm, or is in immediate danger.
7.2 If a child makes a disclosure to you
If a child discloses a safeguarding issue to you, you should:
- Listen to and believe them. Allow them time to talk freely and do not ask leading questions
- Stay calm and do not show that you are shocked or upset
- Tell the child they have done the right thing in telling you. Do not tell them they should have told you sooner
- Explain what will happen next and that you will have to pass this information on. Do not promise to keep it a secret
- Type up your conversation as soon as possible in the child’s own words. Stick to the facts, and do not put your own judgement on it. Typed accounts should be documented on CPOMS or via email and should be signed and dated.
7.3 If you discover that FGM has taken place or a pupil is at risk of FGM
The Department for Education’s Keeping Children Safe in Education explains that FGM comprises “all procedures involving partial or total removal of the external female genitalia, or other injury to the female genital organs”.
FGM is illegal in the UK and a form of child abuse with long-lasting, harmful consequences. It is also known as ‘female genital cutting’, ‘circumcision’ or ‘initiation’.
Possible indicators that a pupil has already been subjected to FGM, and factors that suggest a pupil may be at risk, are set out in appendix 3.
Any teacher who discovers (either through disclosure by the victim or visual evidence) that an act of FGM appears to have been carried out on a pupil under 18 must immediately report this to the police, personally. This is a statutory duty, and teachers will face disciplinary sanctions for failing to meet it.
Unless they have good reason not to, they should also discuss the case with the DSL/deputy DSL who will then involve children’s social care as appropriate.
The duty for teachers mentioned above does not apply in cases where a pupil is at risk of FGM or FGM is suspected but is not known to have been carried out. Staff should not examine pupils.
Any member of staff who suspects a pupil is at risk of FGM or suspects that FGM has been carried out must speak to the DSL and document these concerns in the usual way.
7.4 If you have concerns about a child
Figure 1 on page 7 illustrates the procedure to follow if you have any concerns about a child’s welfare.
Where possible, speak to the DSL/deputy DSL first to agree a course of action.
If in exceptional circumstances the DSL/deputy DSL is not available, do not delay and speak to a member of the senior leadership team for advice.
If early help is appropriate, the DSL/deputy DSL will lead on liaising with other agencies and setting up an inter-agency assessment as appropriate.
The DSL will keep the case under constant review and the school will consider a referral to local authority children’s social care if the situation does not seem to be improving. Timelines of interventions will be monitored and reviewed.
If it is appropriate to refer the case to local authority children’s social care or the police, the DSL/deputy DSL will make the referral.
The local authority will make a decision within 1 working day of a referral about what course of action to take and will let the person who made the referral know the outcome. The DSL/deputy DSL must follow up with the local authority if this information is not made available ensuring outcomes are properly recorded.
If the child’s situation does not seem to be improving after the referral, the DSL/deputy DSL must follow local escalation procedures to ensure their concerns have been addressed and that the child’s situation improves.
7.5 If you have concerns about extremism
If a child is not suffering or likely to suffer from harm, or in immediate danger, where possible speak to the DSL first to agree a course of action. If in exceptional circumstances the DSL/deputy is not available, do not delay and speak to a member of the senior leadership team for advice.
Where there is a concern, the DSL will consider the level of risk and decide which agency to make a referral to. This could include Channel, the government’s programme for identifying and supporting individuals at risk of being drawn into terrorism, or the local authority children’s social care team.
The Department for Education also has a dedicated telephone helpline, 020 7340 7264, which the DSL/deputy DSL and governors can call to raise concerns about extremism with respect to a pupil. An email may also be sent to email@example.com, for emergencies only. Call 999 if:
- Think someone is in immediate danger
- Think someone may be planning to travel to join an extremist group
- See or hear something that may be terrorist-related
Figure 1: procedure if you have concerns about a child’s welfare
(Note – if the DSL/deputy DSL is unavailable, this should not delay action!)
NOTE: If staff have any concerns about a child’s welfare they should act on it. They should not assume a colleague or another professional will take action.
7.6 Concerns about a staff member or volunteer
If you have concerns about a member of staff or volunteer, or an allegation is made about a member of staff or volunteer posing a risk of harm to children, speak to the Principal. If the concerns/allegations are about the Principal, speak to the chair of governors.
The Principal/chair of governors will then follow the procedures set out in our Complaints Policy, if appropriate.
7.7 Allegations of abuse made against other pupils
We recognise that children are capable of abusing their peers. Abuse will never be tolerated or passed off as “banter”, “just having a laugh” or “part of growing up”.
We also recognise the gendered nature of peer-on-peer abuse (i.e. that it is more likely that girls will be victims and boys perpetrators). However, all peer-on-peer abuse is unacceptable and will be taken seriously.
Most cases of pupils hurting other pupils will be dealt with under our behaviour policy, but this child protection and safeguarding policy will apply to any allegations that raise safeguarding concerns. This might include where the alleged behaviour:
- Is serious, and potentially a criminal offence
- Could put pupils in the school at risk
- Is violent
- Involves pupils being forced to use drugs or alcohol
- Involves sexual exploitation, sexual abuse or sexual harassment, such as indecent exposure, sexual assault, upskirting or sexually inappropriate pictures or videos (including sexting)
If a pupil makes an allegation of abuse against another pupil:
- You must record the allegation and inform the DSL/deputy DSL, but do not investigate it
- The DSL/deputy DSL will contact the local authority children’s social care team and follow its advice, as well as the police if the allegation involves a potential criminal offence
- The DSL/deputy DSL will put a risk assessment and support plan into place for all children involved (including the victim(s), the child(ren) against whom the allegation has been made and any others affected) with a named person they can talk to if needed
- The DSL/deputy DSL will contact Healthy Young Minds (formerly CAMHS), if appropriate
We will minimise the risk of peer-on-peer abuse by:
- Challenging any form of derogatory or sexualised language or behaviour, including requesting or sending sexual images
- Being vigilant to issues that particularly affect different genders – for example, sexualised or aggressive touching or grabbing towards female pupils, and initiation or hazing type violence with respect to boys
- Ensuring our curriculum helps to educate pupils about appropriate behaviour and consent (Relationships and Sex Education RSE 2020)
- Ensuring pupils know they can talk to staff confidentially and can report this via various online systems (VLE/Epraise, CEOP)
- Ensuring staff are trained to understand that a pupil harming a peer could be a sign that the child is being abused themselves, and that this would fall under the scope of this policy
- Having a visible presence of staff on duty at break times, lunchtimes and before/after school
- Having a team of trained Student Ambassadors on duty over lunchtimes
Your responsibilities when responding to an incident
If you are made aware of an incident involving sexting (also known as ‘youth produced sexual imagery’), you must report it to the DSL immediately.
You must not:
- View, download or share the imagery yourself, or ask a pupil to share or download it. If you have already viewed the imagery by accident, you must report this to the DSL
- Delete the imagery or ask the pupil to delete it
- Ask the pupil(s) who are involved in the incident to disclose information regarding the imagery (this is the DSL’s responsibility)
- Share information about the incident with other members of staff, the pupil(s) it involves or their, or other, parents and/or carers
- Say or do anything to blame or shame any young people involved
You should explain that you need to report the incident, and reassure the pupil(s) that they will receive support and help from the DSL/deputy DSL.
Review of incident
Following a report of an incident, the DSL will determine:
- Whether there is an immediate risk to pupil(s)
- If a referral needs to be made to the police and/or children’s social care
- What further information is required to decide on the best response
- Whether the imagery has been shared widely and via what services and/or platforms (this may be unknown)
- Whether immediate action should be taken to delete or remove images from devices or online services
- Any relevant facts about the pupils involved which would influence risk assessment
- If there is a need to contact another school, college, setting or individual
- Whether to contact parents or carers of the pupils involved (in most cases parents should be involved)
The DSL will make an immediate referral to police and/or children’s social care if:
- The incident involves an adult
- There is reason to believe that a young person has been coerced, blackmailed or groomed, or if there are concerns about their capacity to consent (for example owing to special educational needs)
- What the DSL knows about the imagery suggests the content depicts sexual acts which are unusual for the young person’s developmental stage, or are violent
- The imagery involves sexual acts and any pupil in the imagery is under 13
- The DSL has reason to believe a pupil is at immediate risk of harm owing to the sharing of the imagery (for example, the young person is presenting as suicidal or self-harming)
If none of the above apply then the DSL, in consultation with the Principal and other members of staff as appropriate, may decide to respond to the incident without involving the police or children’s social care.
Further review of incident
If at the initial review stage a decision has been made not to refer to police and/or children’s social care, the DSL will conduct a further review holding interviews with the pupils involved (if appropriate) to establish the facts and assess the risks.
If at any point in the process there is a concern that a pupil has been harmed or is at risk of harm, a referral will be made to children’s social care and/or the police immediately.
The DSL will inform parents at an early stage and keep them involved in the process, unless there is a good reason to believe that involving them would put the pupil at risk of harm.
Referring to the police
If it is necessary to refer an incident to the police, this will be done through dialing 101 and/or reporting this crime online. The log number is to be recorded.
All sexting incidents and the decisions made in responding to them will be recorded. The record-keeping arrangements set out in section 12 of this policy also apply to recording incidents of sexting.
Pupils are taught about the issues surrounding sexting as part of our PSHE education and computing programmes. Teaching covers the following in relation to sexting:
- What it is
- How it is most likely to be encountered
- The consequences of requesting, forwarding or providing such images, including when it is and is not abusive
- Issues of legality
- The risk of damage to people’s feelings and reputation
Pupils also learn the strategies and skills needed to manage:
- Specific requests or pressure to provide (or forward) such images
- The receipt of such images
This policy on sexting is also shared with pupils so they are aware of the processes the school will follow in the event of an incident.
Where appropriate, we will discuss any concerns about a child with the child’s parents. The DSL/deputy DSL will normally do this in the event of a suspicion or disclosure.
Other staff, such as Year Managers or other members of the Senior Leadership Team, will only talk to parents about any such concerns following consultation with the DSL/deputy DSL.
If we believe that notifying the parents would increase the risk to the child, we will discuss this with the local authority children’s social care team before doing so.
In the case of allegations of abuse made against other children, the DSL/deputy DSL will notify the parents of all the children involved.
We recognise that pupils with special educational needs (SEN) and disabilities can face additional safeguarding challenges. Additional barriers can exist when recognising abuse and neglect in this group, including:
- Assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the child’s disability without further exploration
- Pupils being more prone to peer group isolation than other pupils
- The potential for pupils with SEN and disabilities being disproportionally impacted by behaviours such as bullying, without outwardly showing any signs
- Communication barriers and difficulties in overcoming these barriers
We offer extra pastoral support for pupils with SEN and disabilities including specialist work with our special Educational Needs Coordinator (SENCO) in the Learning Support base.
Staff are allowed to bring their personal phones to school for their own use, but will limit such use to non-contact time when pupils are not present. Staff members’ personal phones will remain in their bags or cupboards during contact time with pupils.
Staff will not take pictures or recordings of pupils on their personal phones or cameras.
The Hathershaw College follow’s the General Data Protection Regulation and Data Protection Act 2018 when taking and storing photos and recordings for use in the school.
All mobile phone use by students is banned and phones will be confiscated if used during the school day.
11.1 Complaints against staff
Complaints against staff that are likely to require a child protection investigation will be handled in accordance with our procedures for dealing with allegations of abuse made against staff (see Complaints Policy).
The College will consider whether any member of staff has behaved or may have behaved in a way that indicates they may not be suitable to work with children. This may include incidents of domestic abuse or other incidents not involving children.
Whilst schools and colleges are not the employer of supply teachers, at The Hathershaw College we will ensure all allegations are dealt with properly.
Where a staff member feels unable to raise an issue with the DSL or Principal, or feels that their genuine concerns are not being addressed, external whistleblowing channels are open to them:
The NSPCC whistleblowing helpline is available for staff who do not feel able to raise concerns regarding child protection failures internally. Staff can call: 0800 028 0285 – line is available from 8:00 AM to 8:00 PM, Monday to Friday and Email: firstname.lastname@example.org
All safeguarding concerns, discussions, decisions made and the reasons for those decisions, must be recorded in writing and using our online recording system CPOMS.
Non-confidential records will be easily accessible and available. Confidential information and records will be held securely on CPOMS and only available to those who have a right or professional need to see them.
Safeguarding records relating to individual children will be retained for 7 years after the child has left education. This is typically to the age of 25.
If a child for whom the school has, or has had, safeguarding concerns transfers to another school, the DSL will ensure that their child protection file is forwarded promptly and securely, and separately from the main pupil file. In addition, if the concerns are significant or complex, and/or social services are involved, the DSL will speak to the DSL of the receiving school and provide information to enable them to have time to make any necessary preparations to ensure the safety of the child.
The Hathershaw College shares information with other agencies when this is appropriate, in line with our local safeguarding procedures. Information shared via email is done so using the encryption service EGRESS and via CPOMS for schools that use this system.
- Appendix 2 sets out our policy on record-keeping specifically with respect to recruitment and pre-employment checks
13.1 All staff
All staff members undertake safeguarding and child protection training at induction, including on whistle-blowing procedures, to ensure they understand the school’s safeguarding systems and their responsibilities, and can identify signs of possible abuse or neglect. This training will be updated annually.
All staff will have training on the government’s anti-radicalisation strategy, Prevent, to enable them to identify children at risk of being drawn into terrorism and to challenge extremist ideas.
Staff also receive regular safeguarding and child protection updates (for example, through emails and staff briefing) as required.
Contractors will also receive a safeguarding information document on arrival to the College.
Volunteers will receive appropriate training, if applicable to their role.
13.2 The DSL and deputy DSL
The DSL/deputy DSL will undertake child protection and safeguarding training at least every 2 years.
In addition, they will update their knowledge and skills at regular intervals and at least annually (for example, through LSCB meetings/email group, Safeguarding and Wellbeing forum groups and keeping up-to-date with the latest safeguarding developments).
They will also undertake Prevent Awareness training.
All governors receive training about safeguarding, to make sure they have the knowledge and information needed to perform their functions and understand their responsibilities.
13.4 Recruitment – interview panels
At least one person conducting an interview for a post at the school has undertaken safer recruitment training. This ensures that as a minimum, the contents of the Department for Education’s statutory guidance and Keeping Children Safe in Education is covered, and is in line with local safeguarding procedures.
This policy will be reviewed annually by the Senior Leadership Team. After every review, it will be approved by the Local Governing Body (LGB).
This policy links to the following policies and procedures:
- Behaviour and Anti-Bullying
- Emotional and Mental Wellbeing
- Staff code of conduct
- Health and safety
- Attendance and punctuality
- Student ICT Acceptable use
- Equality Information Statement
- Relationship and Sex education
- Supporting pupils with medical conditions
- Educational Visits
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