Safeguarding & Welfare

POLICIES & PROCEDURES:
SAFEGUARDING & WELFARE

SECTION 1

1. INTRODUCTION

This policy outlines the responsibilities of Crosby Training in reference to the safeguarding and promotion of wellbeing of all of their learners.

Crosby Training believes:

We believe therefore, that we have a duty of care to: 

Working Together to Safeguard Children 2023 outlines safeguarding children as:

The Care Act 2014 outlines the aims of safeguarding adults as to:

1a. DEFINITIONS

Child – a learner who is under 18 years of age

Vulnerable Adult – a learner over 18 years old “who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of themselves, or unable to protect themselves against significant harm or exploitation” (DH, 2000)

Staff – a member of Crosby Training staff or learner helper employed to assist with an activity

Event – any activity organised by Crosby Training where we are primarily responsible for the delivery. Examples include Community Projects, Mentoring, etc

For ease during this document, the term learner will be used to describe both children and adults.

2. SAFEGUARDING POLICY STATEMENT

Crosby Training is committed to safeguarding and promoting the welfare of all learners and expect all staff and volunteers to share this commitment. As a result, Crosby Training has done the following to meet the company ethos as described above:

Crosby Training will continue to strive to ensure that:

3. LEGAL FRAMEWORK

This policy is developed as per the following legislation and guidance:

SECTION 2

1. THRESHOLDS OF NEEDS FOR CHILDREN

Level 1 – Universal Services: These are children and young people who make good overall progress in all areas of development. All children and young people are entitled to receive support from these services which are available to everyone, irrespective of their needs. This includes GP’s, health visitors and school nurses, schools, youth service, leisure and play facilities and housing. 

Level 2 – Additional Support: Some children/young people require support beyond that provided by their families and universal services. Their life chances would be improved with effective, single agency support. Any practitioner working with a child/young person or their family may identify, in the presentation or behaviour of a child/young person, that they have additional needs, which could be met by a single agency or service. The thresholds of need will help determine whether or not the child’s needs can be addressed within one’s own agency or from other services. If these needs can be met in a co-ordinated manner by the single agency service, there is no need to do anything else. Informal or formal consultation may help at this point. 

Level 3 – Targeted Support: Some children/young people will have more complex needs. Their life chances will be almost certainly improved by effective multi-agency support. If a practitioner believes that a multi-agency response may be required, and appropriate consent has been given, he/she should complete a referral to Targeted Services. This referral should focus on the strengths as well as the areas in which families need to make changes. The referral should be discussed with child, young person and/or their parent/carer and consent obtained in respect of both the referral and information sharing. The referral will be considered by multi agency managers at a Locality meeting and the most appropriate lead professional will be identified, to carry out the family assessment. 

Level 4 – Statutory Services (Section 17, Child in Need, Section 47, Looked After Children). Where a child is at risk of significant harm or has experienced significant harm a referral must be made to Social Care without delay. 

Upon making a referral to any agency the following will be required: 

2. ABUSE & ADULTS

As with children, abuse towards adults can take place in a variety of settings such as, a person’s own home or in the workplace. Unfortunately, those being abused are often the least likely to bring the situation to anyone’s attention.

Abuse towards adults may look like:

3 CHILD/ADULT CONCERN AND DISCLOSURES

Concern: When you have seen or heard something that concerns you. For example, a learner appears unusually tired recently, self-harm marks or a colleague has given learners their personal contact details. Recognising concerns and reporting them is vital for early help.

If you have a concern about a learner or staff member:

Actions may include –

Disclosure: When a learner or staff member tells you that something has happened or might happen to themselves, or someone else, that is unsafe or distressing.

If a learner makes a disclosure you should follow this guidance: 

4. CHILDREN (Potentially at Greater Risk of Harm)

Child in Need and Child Protection Plans

Crosby Training operates as a sub-contractor for RIVERSIDE College and, as such, will uphold all Safeguarding policies as per the main contractor. To this end Crosby Training will follow all local authority procedures relating to children who need a social worker due to safeguarding or welfare needs including sharing of information under existing duties of local authorities. Where children require a social worker, this should inform decisions about safeguarding (for example, responding to unauthorised absence or missing education, where there are known safeguarding risks) and about promoting welfare, including pastoral support, alongside action by statutory services.

Looked After Children and Previously Looked After Children

Crosby Training will ensure that the appropriate staff have the information they need in relation to a child’s looked after status (whether they are looked after under voluntary arrangements with consent of parents, or on an interim or full care order) and the child’s contact arrangements with birth parents or those with parental responsibility. The appropriate staff will also have information about the child’s care arrangements and the levels of authority delegated to the carer by the authority looking after the child. The Designated Safeguarding Lead will have details of the child’s social worker and the name of the virtual school head in the authority that looks after the child. The appropriate staff, including the Designated Safeguarding Lead, will work alongside the relevant agencies to ensure prompt action is taken to safeguard these children, who are a particularly vulnerable group.
Crosby Training will liaise with the Local Authority Personal Advisor who has been appointed to guide and support children who have ceased to be looked after and have become care leavers. Crosby Training will report any areas of concern affecting the care leaver to the Personal Advisor as soon as concerns arise.

Children With Special Educational Needs, Disabilities or Physical Health Issues

Children with special educational needs or disabilities (SEND) or certain health conditions face additional safeguarding challenges. Staff need to be aware of the indicators when recognising abuse and neglect in this group of children. These can include;

Children Missing from Education

All staff should be aware that children missing from education, particularly persistently, could be an indicator of a range of safeguarding issues including, neglect, sexual abuse and child sexual and criminal exploitation. Crosby Training will ensure that all staff are trained to report any incidences of non-attendance, especially in relation to LAC, to the Designated Safeguarding Lead.

Dealing with a disclosure from a learner and safeguarding issues can be stressful. Consider seeking support for yourself and discuss this with the Safeguarding Lead.

5. ROLES & RESPONSIBILITIES

Company Safeguarding staff with contact emails:

Beth Representative at the Board of Directors for Safeguarding and matters concerning the Safeguarding Lead or other staff in the Manager’s absence.

Lisa Sumner Designated Safeguarding Lead: Matters relating to learners, staff and processes

Caroline Grundy Deputy Safeguarding Officer: Matters relating to learners

Sarah Owens Deputy Safeguarding Officer: Matters relating to learners

James Fearon Deputy Safeguarding Officer: Matters relating to learners

6. DUTIES OF THE DESIGNATED SAFEGUARDING PERSON RECEIVING DISCLOSURE

SECTION 3

1. THE PREVENT DUTY

Crosby Training is committed to providing a secure environment for learners and staff where people feel safe and are kept safe. It is recognised that extremism and exposure to extremist materials and influences can lead to poor outcomes for learners. It is further acknowledged that if we fail to challenge extremist views, we are failing to protect our learners from potential harm. As such, the Prevent agenda will be addressed as safeguarding concern.

Crosby Training has adopted the Prevent Duty in accordance with legislative requirements. However, it will endeavour to incorporate the relevant duties so as not to:

1. Stifle legitimate discussions, debate, or learner engagement activities in the local communities; or
2. Stereotype, label or single out individuals based on their origins, ethnicity, faith and beliefs or any other characteristic protected under the Equality Act 2010.

2 BACKGROUND INFORMATION

Prevent is one of the four strands of the Government’s counter terrorism strategy – CONTEST (2018). The UK currently faces a range of terrorist threats. Terrorist groups who pose a threat to the UK seek to radicalise and recruit people to their cause. Therefore, early intervention is at the heart of the Prevent Duty which aims to divert people away from being drawn into terrorist activity.

Prevent happens before any criminal activity takes place by recognising, supporting, and protecting organisations and seeks to:

3. DEFINITIONS

The following are commonly agreed definitions within the Prevent agenda:

4. AIMS

As per the Prevent Duty requirements, Crosby Training will ensure the following:

Leadership and Values

To create and maintain an ethos that upholds core values of shared responsibility and wellbeing for all learners, staff and visitors whilst promoting respect, equality and diversity and understanding.

This will be achieved through:

Teaching and Learning

To provide a curriculum that promotes British Values, knowledge, skills and understanding, to build the resilience of learners by undermining extremist ideology and supporting the learner voice.

This will be achieved through:

Learner Support

To ensure that staff take preventative and responsive steps.

This will be achieved through:

5. ROLES AND RESPONSIBILITIES

Board of Directors

All of the Directors have a legal responsibility under the Prevent Duty to make sure they have undertaken training in the Prevent Duty. Additionally, they must ensure that:

Designated Safeguarding Lead

The Designated Safeguarding Lead is also the Prevent Lead with responsibility for ensuring that the Prevent Strategy is implemented across the organisation and that any concerns are shared with relevant organisations. The Safeguarding Lead also completes and reviews the company Prevent Self-Assessment and Risk Assessment.

Senior Leadership Team Meetings

These meetings are held monthly, and any concerns raised under the Prevent agenda or changes to the Duty that affect Crosby Training are discussed.

All staff

All staff at Crosby Training have a responsibility to:

6. MANAGING RISKS AND RESPONDING TO EVENTS

Crosby Training will ensure that it monitors risks and is ready to deal appropriately with issues which arise through the following:

SECTION 4

1. SAFER RECRUITMENT

Crosby Training takes responsibility for its recruitment processes seriously and follows the legal guidelines set out for schools, academies and colleges in relation to the Single Central Register. Crosby Training ensures the following information is recorded on the SCR:

Identity checks which include:

Crosby Training will ensure that the documents seen for evidence of ID are the originals and will never accept photocopies. Photographic evidence of identity is the ideal but, in instances where this is not available, at least one additional form of ID, such as required for a DBS check, will be requested.

Crosby Training will ensure that all staff are properly vetted and it will be recorded on the SCR whether relevant staff have been informed of their duty to disclose relevant information under the childcare disqualification arrangements. Where information does not apply to an individual, this will be recorded as N/A on the SCR.

Crosby Training will demonstrate compliance with Keeping Children Safe in Education and OFSTED standards.

SECTION 5 – STAFF

1. ALLEGATIONS TOWARDS STAFF

The majority of people who work within education act professionally and aim to provide a safe and supportive environment for learners. However, sometimes the behaviour of adults who work or volunteer with children and adults can result in allegations of harm being made against them. When an allegation is made against a member of staff, set procedures must be followed.

Staff who are subject to an allegation have the right to have their case dealt with fairly and to be kept informed of the progress. Suspension is not automatic; however, it may be deemed appropriate in some cases to ensure learners are protected. Allegations against the Safeguarding Lead are to be reported to the Chair of Governors.

2. STAFF CONDUCT

Staff should always be aware of the needs of learners and be vigilant for any possible signs of abuse.

Meetings with individual learners should take place as openly as possible. If privacy is needed, the door should be left partly open and other staff present or informed of the meeting where possible.

Staff should not have unnecessary physical contact with learners. There may be occasions when physical contact is unavoidable or positively desirable or necessary, such as providing comfort or reassurance, or for physical support. Contact may also take place during sports. Physical contact should, however, only take place with the consent of the learner and the purpose of the contact should be made clear. 

Staff should not contact or meet with learners outside of organised activities.

Staff should never:

3. STAFF TRAINING

Crosby Training ensures its commitment to protecting children and adults from the risk of harm or abuse by ensuring mandatory training is completed by all staff. This equips all staff to have the necessary skills and knowledge to protect and safeguard all individuals whom they are responsible for. Staff training will include:

Crosby Training will regularly review and update safeguarding training to reflect current legal duties and the evolving nature of safeguarding practices.

Records of attendance for all staff will be kept, along with feedback to ensure the effectiveness of the training provided.

GDPR

Crosby Training handles enormous amounts of Data pertaining to the participants who enrol on a course. To ensure compliance with the legal duties placed on Crosby Training, the following will apply:

Regular updates whenever legislative changes or internal process modifications occur.

Crosby Training will maintain records of training completion and ensure that staff can demonstrate their understanding of GDPR principles and procedures. This is essential for compliance especially in relation to a Data breach.

LOW LEVEL CONCERNS

A separate policy covers low level concerns – you can read it here.

SECTION 6

ONLINE SAFETY

Crosby Training will ensure compliance with the statutory guidance Keeping Children Safe in Education (KCSIE) when carrying out their duties to safeguard and promote the welfare of children and adults in relation to Online Safety, including the use of AI and Monitoring and Filtering.

The Department of Education’s guidance on the safe and effective use of AI in education provides clear guidance on the capabilities and features that generative AI products and systems should meet to be considered safe for users in educational settings. Key areas of the guidance include: Content filtering; Activity monitoring; Security; Data protection; Intellectual Property; Transparency and accountability.

The UK’s Online Safety Act places new duties on social media companies and search services to make them more responsible for their users’ safety but it is important to remember that safeguarding is everyone’s responsibility.

APPENDIX

ABUSE & OTHER SPECIFIC SAFEGUARDING ISSUES 

Abuse: maltreatment of a child or vulnerable adult. This may be from somebody inflicting harm or failing to act to prevent harm. This may be in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). Abuse can be peer on peer.

Physical abuse: may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Can also include fabrication of or induced illness by a parent or carer.

Emotional abuse: persistent emotional maltreatment of a child or vulnerable adult. Examples include, making someone feel worthless or unloved, not giving someone opportunity to express themselves or their views, having inappropriate expectations of a person’s emotional capacity, seeing or hearing abuse on others and bullying (including cyber bullying). There is likely to be some form of emotional abuse apparent when other abuse is found.

Harmful sexual behaviour: Sexual behaviours expressed by children and young people under the age of 18 years old that are developmentally inappropriate, maybe harmful towards self or others, or abusive towards another young person or adult.

Sexual abuse: forcing or enticing a child or vulnerable adult to take part in sexual activities, not necessarily involving a high level of violence, whether or not they are aware of what is happening. The activities may or may not involve physical contact, for example, forcing a child or vulnerable adult to watch sexual activities or online grooming. Sexual abuse is not solely perpetrated by adult males but also by females and peers.

Neglect: the persistent failure to meet a basic physical and/or psychological need, likely to result in the serious impairment of a child or vulnerable adult’s health or development.

Financial abuse: acquiring money or property by deception or using other people’s money contrary to their wishes or the best interests of the individual. This may include theft of money/possessions, encouraging people to spend money when they do not want to, misuse of benefits/allowances.

Psychological Abuse: the wilful infliction of mental suffering. The ‘No Secrets’ guidance defines psychological abuse, in relation to vulnerable adults, as emotional abuse and includes other factors such as, threats of harm, punishment or abandonment and isolation, withdrawal of basic rights and needs, humiliation and reminding them of their inadequacies and inabilities, verbal abuse including bullying, swearing, or shouting, intimidation and coercion.

Homelessness: not having a home. A home is a place that provides security, privacy, and links to a community and support network. It needs to be decent and affordable. Under the law, even if someone has a roof over their head, they can still be homeless. This is because they may not have any right to stay where they live, or their home may be unsuitable to live in.

Hate Crime: a criminal offence motivated by prejudice based on the individual’s disability, race, religion or belief, sexual orientation, or transgender identity. Some examples include, name calling or drawing attention to a person’s differences or disabilities, ethnic origin or cultural differences in negative ways. It can be a physical or non-physical.

Domestic Abuse: an incident of threatening behaviour, violence or abuse (psychological, physical, sexual, financial or emotional) between adults who are or have been intimate partners of family members regardless of gender or sexuality.

Female Genital Mutilation (FGM): all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. There is a statutory duty upon teaching staff to report to the police where they discover that FGM appears to have been carried out on a girl under 18.

Forced marriage: a forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (e.g. if they have learning disabilities).

Honour-based violence: where a person is being punished by their family or community for actually or allegedly undermining what they believe to be the correct code of behaviour. By not conforming it may be perceived that the person may have brought shame or dishonor to the family.

Modern slavery: encompasses slavery, human trafficking, forced labour and domestic servitude.

Radicalisation: the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.

Child Sexual Exploitation: is a form of sexual abuse where children are sexually exploited for money, power or status. It can involve violent, humiliating and degrading sexual assaults. In some cases, young people are persuaded or forced into exchanging sexual activity for money, drugs, gifts, affection or status. Consent cannot be given, even where a child may believe they are voluntarily engaging in sexual activity with the person who is exploiting them. Child sexual exploitation does not always involve physical contact and can happen online.

Child Criminal Exploitation: Criminal exploitation of children and vulnerable adults is a geographically widespread form of harm that is a typical feature of county lines activity. County lines is the term for urban gangs supplying drugs to suburban areas and market and coastal towns using dedicated mobile phone lines or “deal lines”. Gangs use children and vulnerable people to move drugs and money.

Peer on Peer abuse: Peer-on-peer abuse is any form of physical, sexual, emotional, financial, and/or coercive control exercised between children and young people; this includes intimate and non-intimate relationships. Examples include (but are not limited to) bullying (online and offline), gender-based violence, sexual assaults, and sexting.

Fabricated or Induced Illness: can include the parent/carer fabricating signs and symptoms of illness, falsification of hospital charts and records of specimens of bodily fluids as well as letters and documents or the induction of illness by a variety of means.

Private Fostering: when a child is cared for by someone other than their parent/carer due to a private arrangement, without the involvement of the local authority.

Sexual Violence: such as rape, assault by penetration and sexual assault.

Sexual Harassment: Such as sexual comments, remarks jokes and online sexual harassment which may be stand alone or part of a broader pattern of abuse.

Up skirting: Typically involves taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification or to cause the victim humiliation, distress, or alarm. 

Sexting: Sending, receiving, or forwarding sexually explicit messages, photographs, or videos primarily between mobile phones, of oneself to others. It may also include th3e use of a computer or other digital device.

Online abuse: Any type of abuse which happens on the internet. It can happen on any device connected to the web like computers, tablets and mobile phones. It can happen anywhere online including social media, text messaging and messaging apps, emails, online chats, online gaming and live streaming sites. Children can be at risk of online abuse from people they know or strangers. It might be part of other abuse which is taking place offline, like bullying or grooming, or the abuse might only happen online.

You can view a copy of our Logging a Concern form here.

It will be the responsibility of the named Safeguarding Officers to review and monitor the procedures and to seek the advice of the local authority’s social service department annually.This policy document forms part of the Crosby Training Safeguarding Handbook. The Crosby Training PREVENT Action Plan supports this policy.

This policy has been written in consultation with a number of organisations and with reference to the following documents:

Keeping Children Safe in Education 2015, Education and Training ( Welfare of children) Act 2021, Safeguarding Vulnerable Groups Act 2006 as amended by the Protection of Freedoms Act 2012, Care Act 2014, Mental Capacity Act 2005, Counter Terrorism and Security Act 2015.

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