safeguarding policy


APT Apprenticeships, (APT) which is a trading name of APT Health & Safety Training Solutions Ltd fully recognises its responsibilities in safeguarding learners. This policy is relevant to learners, employees, agencies and visitors who have access to our learners.

This policy has been developed in accordance with the principles established by the Children Acts 1989 and 2004; the Education Act 2002; and in line with government publications the Teachers’ Standards 2012, ‘Working Together to Safeguard Children’ 2015 and ‘Keeping Children Safe in Education’ 2015 (as amended)


This policy covers all learners, prospective learners, visitors, employees and stakeholders.


‘Young Person’ refers to someone who is over the school leaving age of 16 years and under 18 years.

‘Vulnerable Adult’ refers to a person who is aged 18 years and over, who is or may be, unable to take care of him or herself, or take steps to protect him or herself from significant harm or exploitation.


APT has a duty of care to all of its learners, but particular responsibilities to those under 18 years, and those who are vulnerable adults. There are four main elements to the policy:

1. Raising awareness of safeguarding issues and equipping young people and vulnerable adults with the skills needed to keep them safe;

2. Developing and implementing procedures for identifying and reporting safeguarding cases;

3. Supporting young people and vulnerable adults who have been identified as in need of early help or at risk of harm and those presenting safeguarding concerns.

4. Establishing a safe environment in which young people and vulnerable adults can learn and develop.


• Children Act 1989/2004

• Safeguarding Vulnerable Groups Act 2006

• The United Nations Convention on the Rights of the Child 1991

• The Human Rights Act 1998

• The Data Protection Act 1998

• The Education Act 1996/2002/2011

• The Protection of Freedoms Act 2012

(And their amendments)


Contact details

Name of Designated Safeguarding Lead (DSL): Martin Blakemore

Email address:

Postal address: Lakeview, Festival Way, Festival Park, Stoke-on-Trent, Staffordshire, ST1 5BJ

Contact number: 033 00 55 2756


‘Safeguarding’ is defined as:

• Protecting children/young people/vulnerable adults from maltreatment;

• Preventing impairment of children’s/young people’s/vulnerable adults health development;


• Ensuring that children/young people/vulnerable adults are growing up in circumstances consistent with the provision of safe and effective care;

• Undertaking a role so as to enable children/young people/vulnerable adults to have optimum life chances and to enter adulthood successfully;

• Taking action to enable all children/young people to have the best possible outcome.

APT has a duty of care to all of its learners, but has particular responsibilities to those under 18 years, and those who are vulnerable adults. This policy seeks to ensure the safety and welfare of all those learners under 18 years and those who are vulnerable adults.

Specifically, APT will seek to provide a safe environment for learners to study and to identify those suffering or likely to suffer significant harm and to take appropriate action to ensure that these learners are kept safe.

APT will:

• Establish and maintain a learning environment where young people and vulnerable adults feel secure, are encouraged to talk and are listened to;

• Ensure that young people and vulnerable adults know that there is a dedicated Safeguarding Lead whom they can approach if they are worried;

• Ensure that through their programme of study learners develop the skills they need to recognise and stay safe from abuse, including via the internet and other technologies.

Abuse may be physical, sexual or psychological. Whilst abusers may be relatives or friends of the family, some meet children, young people and vulnerable adults in other contexts, in a small minority of children/young people may be approached in a learning environment. Any incident where a Learner has grounds to believe that a member of staff has crossed the boundary of acceptable behavior should be reported. APT will ensure that the environment encourages learners and staff to make truthful reports of any inappropriate behavior. Handling allegations, particularly serious ones, is a complex and delicate process.

Any fears or worries that children, young people and vulnerable adults bring into the learning environment should not go unnoticed by staff but should be reported immediately and in confidence to the Designated Safeguarding Lead (DSL).


APT will take in to account the guidance issued by the Department for Education (DfE). APT will:

• Ensure that a senior member of staff is appropriately trained and has designated duties to act as the Designated Senior Lead for Safeguarding. This is the Operations Director. The DSL will ensure that Safeguarding policies and procedures are fully implemented and followed by all staff.

• Ensure that the DSL will co-ordinate action on safeguarding and promoting the welfare of young people and vulnerable adults ensuring that all staff, volunteers and visitors to APT know who the DSL is, understands their role and who acts in his/her absence.

• Ensure that staff and volunteers are aware of their responsibilities in being alert to the signs of abuse and neglect and of their responsibility to report and record any concerns to the DSL and that they may raise concerns directly with Children’s Social Care Services if they believe their concerns have not been listened to or acted upon.

• Ensure that the duty of care towards learners and staff is promoted by raising awareness of illegal, unsafe and risky behavior and assist staff to monitor their own standards and practice;

• Ensure that parents/guardians/employers have an understanding of safeguarding by publishing an overview of the policy on APT’s website.

• Ensure that partner organisations are aware of, and understand the need for compliance with our safeguarding guidelines and procedures.

• Be aware of and follow procedures set out by the DfE and the Staffordshire Safeguarding Children’s Board where an allegation is made against a member of staff or volunteer, including making a referral to the DBS and/or dismissed or removed due to safeguarding concerns, or would have been had they not resigned.

• Operate safer recruitment practice.

• Ensure that the Safeguarding policy and procedures are reviewed annually.


• When new employees commence employment with APT they will be informed of the safeguarding arrangements in place. They will be given a copy of this policy, Working Together to Safeguard Children (DfE 2015) and Keeping Children Safe in Education (DfE 2016) and informed who the DSL is.

• All Training Centre Staff are required to undertake a mandatory training session on safeguarding within their probationary period. The training programme will include basic child protection information relating to signs and symptoms of abuse, how to manage a disclosure from a young person or vulnerable adult, when and how to record a concern about the welfare of a young person or vulnerable adult, e-safety and advice on safe working practices. This will be updated at least every 3 years.

• All volunteers, agency staff and regular visitors to APT will be told where to access our policy, given the name of the DSL and informed of APT’s policy in reporting concerns.

• Staff with specific responsibility for safeguarding will undertake both single and inter-agency training at a level suitable to their role and responsibilities, updated every two years.


The Board will nominate a member to have responsibility for liaising with the DSL in matters relating to safeguarding to ensure that:

• Safeguarding policies are in place, are accessible via the website and are reviewed annually

• An annual report on the effectiveness of APT’s safeguarding procedures is presented to the board.

• Any weaknesses brought to it’s attention relating to safeguarding are remedied without delay.

The directors will ensure that the safeguarding policies and procedures are fully implemented and followed by all staff and that sufficient resources are allocated to enable the DSL and other staff to discharge their responsibilities with regard to child protection.

The DSL will co-ordinate action on safeguarding and promoting the welfare of young people and vulnerable adults within the education setting. The DSL is responsible for:

• Organising mandatory safeguarding training for all newly appointed staff and regular refresher training sessions to enable staff to update;

• Undertaking, in conjunction with the Managing Director, an annual audit of safeguarding procedures, using the County safeguarding checklist;

• Referring a young person or vulnerable adult to the Staffordshire Multi-Agency Safeguarding Hub, Children’s Social Care or Adult Social Care as appropriate, when there are concerns about possible abuse and neglect;

• Keeping written records of concerns about young people and vulnerable adults, even where there is no need to refer the matter immediately;

• Ensuring all child protection records are kept securely and in locked locations;

• Monitoring unauthorised absence, particularly where young people or vulnerable adults go missing on repeated occasions;

• Developing effective links with relevant agencies and other professionals and co-operate as required with their enquiries regarding safeguarding matters;


If a learner discloses directly to a member of staff, the following procedure will be followed:

• Listen carefully to what is said.

• Ask open questions such as:

• ‘Tell me what happened?”

• ‘Please explain what you mean when you say……?’

• ‘Can you describe the person?’ or ‘Can you describe the place?’

• Do not ask questions which may be considered to suggest what might have happened, or who has perpetrated the abuse, e.g. ‘Did your Dad hit you?’

• Do not force the learner to repeat what he/she said in front of another person.

• Do not begin an investigation.

• Report immediately to the Designated Senior Lead and complete Form C (Green Form) to log a concern about a learner’s safety and welfare using the learner’s words as far as possible.

• Where a learner discloses safeguarding allegations against another learner, the DSL should seek advice from Staffordshire Multi-Agency Safeguarding Hub 01785 277394 or the local agency for the region of the Learner’s domicile.


APT recognises that all matters relating to safeguarding are confidential. The DSL or Managing Director will disclose information regarding a learner to other staff on a need to know basis only.

• The Designated Safeguarding Lead will:

• Explain to young people, vulnerable adults and families at the beginning of any involvement openly and honestly what information is to be shared and why.

• Consider the safety and security of the young person when making a decision on whether to share information.

• Respect the views of the young person and family when consent is not given. However, the Senior Designated Person may need to override their wishes and share information whilst being honest in the interests of maintaining a working relationship.

• Seek advice if in doubt, especially where these relate to concern about significant harm to a child or serious harm to others. A cause, or possible cause, must not be ignored.

• A ‘breach of confidentiality’ only occurs where the sharing of information is not authorised by the individual who provided it and to whom it relates. Refusal of consent does not necessarily preclude the sharing of information. APT can lawfully justify the sharing of confidential information where:

• there is evidence that a young person/vulnerable adult is suffering or is at risk of suffering significant harm;

• where there is reasonable cause to believe that a young person/vulnerable adult may be suffering or is at risk of suffering significant harm;

• to prevent significant harm arising to a young person/vulnerable adult including through the prevention, detection and prosecution of serious crime – Keeping Children Safe in Education (DfE 2016)


Any member of staff receiving a disclosure of abuse from a young person or vulnerable adult, or noticing signs or symptoms of abuse, will make notes as soon as possible writing down exactly what was said using the individual’s own words as far as possible. All notes will be timed, dated and signed using a Form C (Green Form) to log a concern about a learner’s safety and welfare. All records of a safeguarding nature should be passed to the DSL within 24 hours of the incident, the DSL will complete a Staffordshire MASH Multi-Agency Referral Form (or appropriate local authority form for the learner’s domicile) when required. The DSL will record all safeguarding concerns in a Safeguarding log which is stored on a secured section of the server ‘APT Safeguarding’ where only the DSL has access; all paper documentation will be stored in accordance with APT’s Data Protection Policy.


We recognise that young people/vulnerable adults who are abused or witness violence may find it difficult to develop a sense of self-worth. They may feel helplessness, humiliation and some sense of blame. Engaging in training may be the only stable, secure and predictable element in the lives of some individuals at risk. APT will endeavour to support the learner through:

• The achievement of their qualification;

• Promoting a positive, supportive and secure environment and gives individuals a sense of being valued

• Liaison with other partner agencies such as Children’s Services, Child and Adult Mental Health Service (CAMHS) and other relevant voluntary agencies

• The use of Early Help Interventions, including the Early Help Assessment Framework when appropriate

• Notifying Children’s Social Care immediately there is a significant concern.

• Providing continuing support to individuals by ensuring that appropriate information is forwarded under confidential cover to any new provider.


All adults have a right to:

• Live free from violence

• Be protected from harm & exploitation

• Independence, which involves a degree of risk.

The term “vulnerable” adult refers to any person aged 18 years and over who is or may be in need of community care services by reason of mental or other disability, age, illness and who is or may be unable to take care of himself or herself, or unable to protect himself or herself against significant harm or serious exploitation.

‘Abuse’ is the inflicting of harm, or by failing to act to prevent harm.

Vulnerable learners may be abused within a dependent relationship or, more rarely, by a stranger. Abuse can be intentional or unintentional. There are 6 categories of abuse, which are physical, sexual, neglect, emotional or psychological and financial. It is not unusual for a vulnerable learner to suffer more than one kind of abuse.

Abuse may be a part of a pattern of behaviour or an isolated incident.

We should also be aware of those learners who might find themselves vulnerable due to circumstance. For example, those who have:

• Disabled or have special educational needs

• Young Carers

• Affected by parental substance misuse, domestic abuse and/or violence or parental mental health needs

• Asylum seekers

• Looked after by the Local Authority or otherwise living away from home

• Vulnerable to being bullied or engaging in bullying behaviors

• Living in temporary accommodation

• Living transient lifestyles

• Living in chaotic and unsupportive home situations

• Vulnerable to discrimination and maltreatment on the grounds of race, ethnicity, religion, disability or sexuality

• At risk of child sexual exploitation (CSE)

• Do not have English as a first language

• At risk of female genital mutilation (FGM)

• At risk of forced marriage

• At risk of being drawn into extremism

Staff should note that vulnerable people are not a homogenous group, and the vulnerable status of a learner can change constantly depending on their circumstances. If anyone suspects witnesses or hears of abuse they should immediately contact the DSL, Out of ‘normal working hours’, support can be obtained from Staffordshire Multi-Agency Safeguarding Hub 01785 277394, or the local safeguarding hub which is local to the learner’s domicile.

For more information about recognising the signs of abuse and neglect please refer to the Annexes within the Safeguarding Policy.


APT aims to provide a supportive environment that will help learners with mental health difficulties to realise their academic potential and meet course requirements. We also aim to facilitate and promote positive mental health and well-being.


If a learner is considered to be at serious risk of self-harm the matter should be reported to the DSL. There are varying levels of risk; inevitably personal judgment will be required as to the seriousness and urgency of the situation and the appropriate course of action.

The safety of the individual concerned and of those around them is paramount. Where there are clear indications that the learner is in imminent and serious danger the emergency services should be called.


APT endeavor to ensure that we do our utmost to employ ‘safe’ staff and allow ‘safe’ volunteers to work with children and vulnerable adults by following the guidance in Keeping Children Safe in Education. Safer Recruitment means that all applicants will:

• Complete an application form which includes their employment history and explains any gaps in that history

• Provide two referees

• Provide evidence of identity and qualifications

• Is offered employment, be checked in in accordance with the Disclosure and Barring Service (DBS) regulations as appropriate to their role

• If offered employment, provide evidence of their right to work in the UK

• Be interviewed by a panel of at least two, if shortlisted.

All new staff are required to undergo an induction which includes familiarisation with APT’s Safeguarding Policy and Staff Code of Conduct. All staff are required to sign to confirm that they have received a copy of the Safeguarding Policy and Staff Code of Conduct.


To meet and maintain our responsibilities towards learners, we agree to standards of good practice which forms a code of conduct for all staff. Good practice includes:

• Treating all learners with respect

• Setting a good example by conducting ourselves appropriately

• Involving learners in decisions that affect them

• Encouraging positive, respectful and safe behaviour among learners

• Being a good listener

• Being alert to changes in learner’s behaviour and to signs of abuse, neglect and exploitation

• Recognising that challenging behaviour may be an indicator of abuse

• Reading and understanding the Staff Code of Conduct

• Maintaining appropriate standards of conversation and interaction with and between learners and avoiding the use of sexualised or derogatory language

• Being aware that the personal and family circumstances and lifestyles of some pupils lead to an increased risk of abuse.

• Referring all concerns about learner safety and welfare to the DSL or if necessary directly to the Police of Children’s social care.

• Following the Use of Internet, Email & Social Media Usage Policy.


It is recognised that a learner may make an allegation against a member of staff. If such an allegation is made, the member of staff receiving the allegation will immediately inform the DSL and/or Managing Director, unless the allegations concern the Managing Director, in which case the APT Board will be informed immediately.

The DSL on all such occasions will discuss the content of the allegation with the Local Authority Designated Officer (LADO). APT will follow Local Authority procedures for managing allegations against staff.


It is recognised that learners cannot be expected to raise concerns in an environment where staff fail to do so. All staff should be aware of their duty to raise concerns, where they exist, about the attitude or actions of colleagues. Please refer to the Speak Up Policy for further guidance.


It is recognised that as adults working in education and training, we are in a relationship of trust with the learners in our care and acknowledge that it is a criminal offence to abuse that trust. We acknowledge that the principle of equality embedded in the legislation of the Sexual Offenders Act 2003 applies irrespective of sexual orientation: neither homosexual nor heterosexual relationships are acceptable within a position of trust. It is recognised that the legislation is intended to protect young people in education who are over the age of consent but under 18 years of age. However, it is important to note that staff should maintain appropriate boundaries with learners of all ages. Please refer to the Staff Code of Conduct for more information.


APT’s Health and Safety Policy reflects the consideration given to the safeguarding of learners. Risk assessments are undertaken and reviewed regularly, in respect of site security, risk of young people being drawn into terrorism or exposed to extremist behaviour, risk to and from young people displaying harmful behaviour. Please refer to APT’s Health and Safety Policy for further guidance.


The welfare and protection of our learners is paramount and consideration should always be given to whether the use of photography is a risk. For this reason consent is always sought when photographing learners and additional consideration given to photographing vulnerable learners, particularly Looked After Children or those known to be fleeing domestic violence. Consent must be sought from those with parental responsibility (this may include the Local Authority in the case of Looked After Children).


APT undertakes appropriate risk assessments and checks in respect of all equipment and of the buildings and grounds in line with local and national guidance and regulations concerning health and safety.

Visitors to APT are asked to sign in and are given an identity badge, which confirms that they have permission to be on site.

Visitor’s to APT’s learning environments, such a guest speakers or curriculum specialists will be appropriately checked and vetted, to ensure they are not linked to extremist groups or promoting extremist or other harmful material.


To safeguard learners from exposure to extremist views and to ensure avoidance of the learning environment becoming a platform for extremist views a Guest Speaker Risk Assessment Form needs to be completed on every occasion a guest speaker is presented to APT’s learners. APT will carefully consider whether the views likely to be expressed by the guest speaker constitute extremist views. If this is the considered opinion then the event will not proceed unless the Associate responsible for the activity is convinced that the risk can be fully mitigated by the extremist view being challenged with the opposing view at the same event, rather than in a separate forum.


The Use of Internet, Email & Social Media Usage Policy explains how APT explains how we try to keep learners safe in the educational setting and protect Learners in the safe use of technology.


APT encourages learners to respect the fundamental British Values of democracy, the rule of law, individual liberty and mutual respect, and tolerance of those with different faiths and beliefs. We ensure that partisan political views are not promoted in our training programmes.

We value freedom of speech and the expression of beliefs/ideology as fundamental rights underpinning our society’s values. Both learners and staff have the right to speak freely and voice their opinions. However, freedom comes with responsibility and free speech that is designed to manipulate the vulnerable or that leads to violence and harm of others goes against the moral principles in which freedom of speech is valued. Free speech is not an unqualified privilege; it is subject to laws and policies governing equality, human rights, we seek to protect children, young people and adults against the messages of all violent extremism including, but not restricted to, those linked to Islamist ideology, or to Far Right/Neo Nazi/White Supremacist ideology, Irish Nationalist and Loyalist paramilitary groups, and extremist Animal Rights movements.

Factors which may indicate vulnerability to extremism may include (but not limited to):

• Possession of literature regarding military training, skills and techniques

• Possession of violent extremist literature

• The expression of extremist views advocating violent actions and means

• Association with known extremists, seeking to recruit other to an extremist ideology or claims of involvement with organisations espousing extreme violence

• Exposure to an ideology that appears to sanction, legitimise or require violence

• A range of perceived grievance, real and some imagined, to which there seems to be no credible and effective non-violent response.

If staff believe that a Learner or a colleague is at risk then the member of staff needs to complete a Form C (Green Form) to log a concern about a learner/colleague’s safety and welfare, this form needs to be submitted to the Designated Safeguarding Lead (DSL) who will identify whether a referral needs to be made to Channel.


Attendance is monitored and when patterns of absence give rise to concern, we will discuss this further with the Learner and employer, and where appropriate the parents.


APT recognises that professional disagreements may arise between any agencies and resolving problems is an integral part of co-operation and joint working to safeguard young people/vulnerable adults.

As part of our responsibility for safeguarding, we acknowledge that we must be prepared to challenge each other if we feel that responses to concerns, assessments or the way in which plans are implemented are not safeguarding the young person/vulnerable adult and promoting their welfare.


Our Safeguarding policy and procedures will be monitored and evaluated by:

• Completion of an annual safeguarding report to the Board

• Quarterly review of the Safeguarding log by the DSL and Managing Director

• Discussions with Learners and staff

• Scrutiny of data and risk assessments

• Review of incidents


APT Senior Designated Lead Martin Blakemore, Head Office t:03300552756

NSPCC Helpline 0808 800 5000

Staffordshire Education Safeguarding Lead Roz Randall, t:07773791172

PREVENT Staffordshire t:01785 232054


This is extracted from WCSB guidance and therefore refers to pupils and schools but can be applied to the educational environment at APT.

Recognising abuse

To ensure that our pupils are protected from harm, we need to understand what types of behavior constitute abuse and neglect.

Abuse and neglect are forms of maltreatment. Somebody may abuse or neglect a child by inflicting harm, for example by hitting them, or by failing to act to prevent harm, for example by leaving a small child home alone, or leaving knives or matches within reach of an unattended toddler.

Abuse may be committed by adult men or women and by other children and young people.

There are four categories of abuse: physical abuse, emotional abuse, sexual abuse and neglect.


Physical abuse is a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child (this used to be called Munchausen’s Syndrome by Proxy, but is now more usually referred to as fabricated or induced illness).


Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.


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

Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.


Neglect 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. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:

• Provide adequate food, clothing and shelter (including exclusion from home or abandonment);

• Protect a child from physical and emotional harm or danger;

• Ensure adequate supervision (including the use of inadequate care-givers); or

• Ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Definitions taken from Working Together to Safeguard Children (HM Government, 2015).


Physical signs define some types of abuse, for example bruising, bleeding or broken bones resulting from physical or sexual abuse, or injuries sustained while a child has been inadequately supervised. The identification of physical signs is complicated, as children may go to great lengths to hide injuries, often because they are ashamed or embarrassed, or their abuser has threatened further violence or trauma if they ‘tell’. It is also quite difficult for anyone without medical training to categorise injuries into accidental or deliberate with any degree of certainty. For those reasons it is vital that staff are also aware of the range of behavioural indicators of abuse and report any concerns to the Designated Safeguarding Lead.

It is the responsibility of staff to report their concerns. It is not their responsibility to investigate or decide whether a child has been abused.

A child who is being abused or neglected may:

• Have bruises, bleeding, burns, fractures or other injuries;

• Show signs of pain or discomfort;

• Keep arms and legs covered, even in warm weather;

• Be concerned about changing for PE or swimming;

• Look unkempt and uncared for;

• Change their eating habits;

• Have difficulty in making or sustaining friendships;

• Appear fearful;

• Be reckless with regard to their own or other’s safety;

• Self-harm;

• Frequently miss school or arrive late;

• Show signs of not wanting to go home;

• Display a change in behaviour – from quiet to aggressive, or happy-go-lucky to withdrawn;

• Challenge authority;

• Become disinterested in their school work;

• Be constantly tired or preoccupied;

• Be wary of physical contact;

• Be involved in, or particularly knowledgeable about drugs or alcohol; and/or

• Display sexual knowledge or behaviour beyond that normally expected for their age and/or stage of development.

• Acquire gifts such as money or a mobile phone from new ‘friends’ or adults recently acquainted with the child’s family

Individual indicators will rarely, in isolation, provide conclusive evidence of abuse. They should be viewed as part of a jigsaw and each small piece of information will help the DSL to decide how to proceed.

It is very important that staff report all of their concerns, however minor or insignificant they may think they are – they do not need ‘absolute proof’ that the child is at risk.


The impact of child abuse, neglect and exploitation should not be underestimated. Many children do recover well and go on to lead healthy, happy and productive lives, although most adult survivors agree that the emotional scars remain, however well buried. For some children, full recovery is beyond their reach and the rest of their childhood and their adulthood may be characterised by anxiety or depression, self-harm, eating disorders, alcohol and substance misuse, unequal and destructive relationships and long-term medical or psychiatric difficulties.


Any child in any family in any school could become a victim of abuse. Staff should always maintain an attitude of “It could happen here”.

Key points for staff to remember when taking action are:

• In an emergency take the action necessary to help the child, for example, call 999;

• Report your concern to the DSL as quickly as possible – immediately when there is evidence of physical or sexual abuse and certainly by the end of the day;

• Do not start your own investigation;

• Share information on a need-to-know basis only – do not discuss the issue with colleagues, friends or family;

• Complete a record of concern, using a Form C (Green form); and

• Seek support for yourself if you are distressed or need to debrief.

If a member of staff or volunteer is concerned about a pupil’s welfare

There will be occasions when staff may suspect that a pupil may be at risk but have no ‘real’ evidence. The pupil’s behaviour may have changed, their artwork could be bizarre, they may write stories or poetry that reveal confusion or distress or physical but inconclusive signs may have been noticed. In these circumstances, staff will try to give the pupil the opportunity to talk. The signs they have noticed may be due to a variety of factors, for example a parent has moved out, a pet has died, a grandparent is very ill or an accident has occurred. It is fine for staff to ask the pupil if they are OK or if they can help in any way.

Staff should use the same record of concern Form C (Green form) to record these early concerns. If the pupil does begin to reveal that they are being harmed, staff should follow the advice below. Following an initial conversation with the pupil, if the member of staff remains concerned, they should discuss their concerns with the DSL. Concerns which do not meet the threshold for child protection intervention will be managed through the Early Help/CAF process as in section 7 of this policy.

If a pupil discloses to a member of staff or volunteer

It takes a lot of courage for a child to disclose that they are being abused. They may feel ashamed, particularly if the abuse is sexual. Their abuser may have threatened what will happen if they tell. They may have lost all trust in adults. Or they may believe, or have been told, that the abuse is their own fault. Sometimes they may not be aware that what is happening is abusive.

If a pupil talks to a member of staff about any risks to their safety or wellbeing, the staff member will need to let the pupil know that they must pass the information on – staff are not allowed to keep secrets. The point at which they tell the pupil this is a matter for professional judgement. If they jump in immediately the pupil may think that they do not want to listen but if left until the very end of the conversation, the pupil may feel that they have been misled into revealing more than they would have otherwise.

During their conversations with pupils staff will:

• Allow them to speak freely;

• Remain calm and not overreact – the pupil may stop talking if they feel they are upsetting their listener;

• Give reassuring nods or words of comfort – ‘I’m so sorry this has happened’, ‘I want to help’, ‘This isn’t your fault’, ‘You are doing the right thing in talking to me’;

• Not be afraid of silences – staff must remember how hard this must be for the pupil;

• Under no circumstances ask investigative questions – such as how many times this has happened, whether it happens to siblings too, or what does the pupil’s mother think about all this; (however, it is reasonable to ask questions to clarify understanding and to support a meaningful referral if that is required, e.g. when did this happen, where did this happen? )

• At an appropriate time tell the pupil that in order to help them, the member of staff must pass the information on;

• Not automatically offer any physical touch as comfort. It may be anything but comforting to a child who has been abused;

• Avoid admonishing the child for not disclosing earlier. Saying things such as ‘I do wish you had told me about this when it started’ or ‘I can’t believe what I’m hearing’ may be the staff member’s way of being supportive but may be interpreted by the child to mean that they have done something wrong;

• Tell the pupil what will happen next;

• Let them know that someone (either you or another named person, e.g. the DSL) will come to see them before the end of the day;

• Report verbally to the DSL;

• Write up their conversation as soon as possible on the record of concern form C (Green form) and hand it to the DSL; and

• Seek support if they feel distressed or need to debrief.

Notifying parents

APT will normally seek to discuss any concerns about a pupil with their parents. This must be handled sensitively and the DSL will make contact with the parent in the event of a concern, suspicion or disclosure.

However, if APT believes that notifying parents could increase the risk to the child or exacerbate the problem, advice will be sought first from Children’s Social Care.


While bullying between children is not a separate category of abuse and neglect, it is a very serious issue that can cause considerable anxiety and distress. At its most serious level, bullying can have a disastrous effect on a child’s well-being and in very rare cases has been a feature in the suicide of some young people.

All incidences of bullying, including cyber-bullying and prejudice-based bullying should be reported and will be managed through our anti-bullying procedures. All pupils and parents receive a copy of the procedures on joining the school and the subject of bullying is addressed at regular intervals in PSHE education.

If the bullying is particularly serious, or the anti-bullying procedures are deemed to be ineffective, the DSL will consider implementing early help (CAF) or child protection procedures.

Please also refer to issues in relation to children who are sexually harmful or abusive towards other children below.

Children with sexually harmful or inappropriate behaviour

Children may be harmed by other children or young people. Staff will be aware of the harm caused by bullying and will use the school’s anti-bullying procedures as above where necessary. However, there will be occasions when a pupil’s behaviour warrants a response under child protection rather than anti-bullying procedures. In particular, research suggests that up to 30 per cent of child sexual abuse is committed by someone under the age of 18.

Abusive behaviour by one child towards another will not be tolerated, minimised or dismissed as ‘banter’ or ‘part of growing up’.

When dealing with abuse of pupils by other pupils, staff will be mindful of the potential for prejudice-based bullying; racist, disability, homophobic and transphobic abuse; gender-based violence and teenage relationship abuse. Whilst mindful of the particular vulnerability of women and girls to violence, it is also recognised that boys as well as girls can be abused by members of the opposite as well as the same gender group.

Members of staff who become concerned about a pupil’s sexualised behaviour, including any known online sexualised behaviour, should record their concerns and report them to the DSL as soon as possible, as with any other safeguarding concern.

Youth produced sexual imagery (‘sexting’) The school will act in accordance with advice endorsed by DfE ‘Sexting in schools and colleges: responding to incidents and safeguarding young people’ (UK Council for Child Internet Safety 2016) – G_NCA_Sexting_in_Schools_WEB__1_.PDF

All incidents of youth produced sexual imagery (YPSI) will be dealt with as safeguarding concerns. The primary concern at all times will be the welfare and protection of the young people involved.

Young people who share sexual imagery of themselves or their peers are breaking the law. However, as highlighted in national guidance, it is important to avoid criminalising young people unnecessarily. The school will therefore work in partnership with external agencies with a view to responding proportionately to the circumstances of any incident.

All incidents of YPSI should be reported to the DSL as with all other safeguarding issues and concerns. Staff will not make their own judgements about whether an issue relating to YPSI is more or less serious enough to warrant a report to the DSL. What may seem like less serious concerns to individual members of staff may be more significant when considered in the light of other information known to the DSL, which the member of staff may not be aware of.

If staff become concerned about a YPSI issue in relation to a device in the possession of a student (e.g. mobile phone, tablet, digital camera), the member of staff will secure the device (i.e. it should be confiscated). This is consistent with DfE advice Searching, Screening and Confiscation – Advice for headteachers, school staff and governing bodies (DfE February 2014) , page 11 ‘After the search’. Staff will not look at or print any indecent images. The confiscated device will be passed immediately to the DSL (see ‘Viewing the imagery’ below).

The DSL will discuss the concerns with appropriate staff and speak to young people involved as appropriate. Parents/carers will be informed at an early stage and involved in the process unless there is good reason to believe that involving parents would put the young person at risk of harm.

If, at any point in the process, there is concern that a young person has been harmed or is at risk of harm a referral will be made to Children’s Social Care and/or the Police via the MASH immediately.

Aggravated incidents involve criminal or abusive elements beyond the creation, sending or possession of sexual images created by young people. These include possible adult involvement or criminal or abusive behaviour by young people such as sexual abuse, extortion, threats, malicious conduct arising from personal conflicts, or creation or sending or showing of images without the knowledge or against the will of a young person who is pictured.

Aggravated incidents of sexting will usually be referred to Staffordshire’s Multi-Agency Safeguarding Hub (MASH) for advice about whether or not a response by the Police and/or Children’s Social Care is required. This will facilitate consideration of whether:

• There are any offences that warrant a Police investigation

• Child protection procedures need to be invoked

• Parents/carers require support in order to safeguard their children

• A multi-agency sexual exploitation (MASE) meeting is required

• Any of the perpetrators and/or victims require additional support. This may require the

• initiation of a CAF and the offer of early help services

Examples of aggravated incidents include:

• Evidence of adult involvement in acquiring, creating or disseminating indecent images of young people (possibly by an adult pretending to be a young person known to the victim)

• Evidence of coercing, intimidating, bullying, threatening and/or extortion of students by one or more other students to create and share indecent images of themselves

• Pressure applied to a number of students (e.g. all female students in a class or year group) to create and share indecent images of themselves

• Pressurising a student who does not have the capacity to consent (e.g. due to their age, level of understanding or special educational needs) or with additional vulnerability to create and share indecent images of themselves

• Dissemination of indecent images of young people to a significant number of others with an intention to cause harm or distress (possibly as an act of so-called ‘revenge porn’, bullying or exploitation)

• What is known about the imagery suggests the content depicts sexual acts which are unusual for the young person’s developmental stage or are violent

• Sharing of indecent images places a young person is at immediate risk of harm, for example the young person is presenting as suicidal or self-harming

The DSL will make a judgement about whether or not a situation in which indecent images have been shared with a small number of others in a known friendship group with no previous concerns constitutes an aggravated incident; or whether the school is able to contain the situation in partnership with all parents of the students involved, arrange for the parents to ensure that all indecent images are deleted and that the young people involved learn from the incident in order to keep themselves safe in future.

In the latter instance, the DSL will usually consult with the Police and/or Children’s Social Care through the MASH to check that no other relevant information is held by those agencies and to ensure an agreed response is documented before proceeding.

Viewing the imagery

Adults should not view youth produced sexual imagery unless there is good and clear reason to do so. Wherever possible, the DSL’s responses to incidents will be based on what they have been told about the content of the imagery.

Sexual exploitation of children

Sexual exploitation involves an individual or group of adults taking advantage of the vulnerability of an individual or groups of children or young people. Victims can be boys or girls. Children and young people are often unwittingly drawn into sexual exploitation through the offer of friendship and care, gifts, drugs, alcohol and sometimes accommodation. Sexual exploitation is a serious crime and can have a long-lasting adverse impact on a child’s physical and emotional health. It may also be linked to the trafficking of children.

All staff are made aware of the indicators of sexual exploitation of children and all concerns are reported immediately to the DSL. The DSL will consider the need to make a referral to Children’s Social Care via the MASH (see section 33 below) as with any other child protection concern and with particular reference to Child Sexual Exploitation procedures. Parents will be consulted and notified as above.

So-called ‘honour based’ violence

So-called ‘honour-based’ violence (HBV) encompasses crimes which have been committed to protect or defend the honour of a family and/or community. Such crimes include Female Genital Mutilation (FGM), forced marriage, and practices such as breast ironing. Staff will be alert to the possibility of a child being at risk of HBV or already having suffered HBV.

All forms of so called HBV are abuse (regardless of the motivation) and staff will record and report any concerns about a child who might be at risk of HBV to the Designated Safeguarding Lead as with any other safeguarding concern. The DSL will consider the need to make a referral to the Police, and/or Children’s Social Care as with any other child protection concern; and may also contact the Forced Marriage Unit for advice as necessary.

Female genital mutilation

Female genital mutilation (FGM) is a form of child abuse. It is the collective name given to a range of procedures involving the partial or total removal of the external female genitalia for non-medical reasons or other injury to the female genital organs. It has no health benefits and harms girls and women in many ways. The practice, which is most commonly carried out without anaesthetic, can cause intense pain and distress and long-term health consequences, including difficulties in childbirth.

FGM is carried out on girls of any age, from young babies to older teenagers and adult women, so school staff are trained to be aware of risk indicators. Many such procedures are carried out abroad and staff should be particularly alert to suspicions or concerns expressed by female pupils about going on a long holiday during the summer vacation period.

In England, Wales and Northern Ireland, the practice is illegal under the Female Genital Mutilation Act 2003. Any person found guilty of an offence under the Female Genital Mutilation Act 2003 is liable to a maximum penalty of 14 years imprisonment or a fine, or both.

(See for further information)

If staff have a concern that a girl may be at risk of FGM, they will record their concern and inform the DSL as they would any other safeguarding concern.

Forced Marriage

A forced marriage is a marriage in which a female (and sometimes a male) does not consent to the marriage but is coerced into it. Coercion may include physical, psychological, financial, sexual and emotional pressure. It may also involve physical or sexual violence and abuse.

A forced marriage is not the same as an arranged marriage. In an arranged marriage, which is common in several cultures, the families of both spouses take a leading role in arranging the marriage but the choice of whether or not to accept the arrangement remains with the prospective spouses.

Children may be married at a very young age and well below the age of consent in England. School staff should be particularly alert to suspicions or concerns raised by a pupil about being taken abroad and not being allowed to return to England.

Since June 2014 forcing someone to marry has become a criminal offence in England and Wales under the Anti-Social Behaviour, Crime and Policing Act 2014.

Radicalisation and Extremism

Protecting children from the risk of radicalisation is part of the school’s wider safeguarding duties and is similar in nature to protecting children from other forms of harm and abuse.

Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism. The government defines extremism as vocal or active opposition to fundamental British values.

Even very young children have been exposed, in rare circumstances, to extremism at home and elsewhere including online.

As children get older, they look for adventure and excitement and they may start to ask questions about their identity and belonging. During that stage of their development they are vulnerable to extremist groups that may claim to offer answers, identity and a social network apparently providing a sense of belonging. Many of those extremist groups make sophisticated use of the internet and social media to target young people and spread their ideology, making young people more vulnerable to being influenced by extremist ideas.

The school has defined responsibilities to ensure that children are safe from terrorist and extremist material when accessing the internet in school.

During the process of radicalisation it is possible to intervene to prevent vulnerable people being radicalised. The school is committed to preventing pupils from being radicalised and drawn into any form of extremism or terrorism. The school promotes the values of democracy, the rule of law, individual liberty, mutual respect and tolerance of those with different faiths and beliefs by providing pupils with opportunities through the curriculum to discuss issues of religion, ethnicity and culture and learn how to discuss and debate points of view; and by ensuring that all pupils are valued and listened to within school.

School staff receive training that provides them with both the information they need to understand the risks affecting children and young people in this area; and a specific understanding of how to identify individual children who may be at risk of radicalisation and how to support them. Staff are trained to report all concerns about possible radicalisation and extremism to the DSL immediately as they would any other safeguarding concern.

The school recognises the importance of providing a safe space for children to discuss controversial issues; and building their resilience and the critical thinking skills they need in order to challenge extremist perspectives. However, the school will make appropriate referrals to the Police PREVENT team and Channel programme in respect of any pupil whose behaviour or comments suggest that they are vulnerable to being radicalised and drawn into extremism and terrorism in order to ensure that children receive appropriate support.

The school will discuss any concerns about possible radicalisation identified in school with a child’s parents/carers as with any other safeguarding or child protection issue unless there is reason to believe that doing so would place the child at risk; and will also support parents/carers who raise concerns about their children being vulnerable to radicalisation.

The school expects all staff, volunteers, governors, visiting professionals, contractors and individuals or agencies that hire school premises to behave in accordance with the school’s Staff Behaviour Policy (code of conduct), will challenge the expression and/or promotion of extremist views and ideas by any adult on school premises or at school events and, when necessary, will make appropriate referrals in respect of any such adult.

Parents and staff may find the website informative and useful. The website is designed to equip school and college leaders, teachers and parents with the information, tools and resources they need to recognise and address extremism and radicalisation in young people and how best to support them. The website provides information on training resources for teachers, staff and school and college leaders.

Private fostering arrangements

A private fostering arrangement occurs when someone other than a parent or a close relative cares for a child for a period of 28 days or more, with the agreement of the child’s parents. It applies to children under the age of 16, or under 18 if the child is disabled. Children looked after by the local authority or who are placed in a residential school, children’s home or hospital are not considered to be privately fostered.

Private fostering occurs in all cultures, including British culture and children may be privately fostered at any age.

Most privately fostered children remain safe and well but safeguarding concerns have been raised in some cases so it is important that schools are alert to possible safeguarding issues, including the possibility that a child has been trafficked into the country By law, a parent, private foster carer or other persons involved in making a private fostering arrangement must notify Children’s Social Care as soon as possible. When the school becomes aware of a private fostering arrangement for a pupil that has not been notified to Children’s Social Care, the school will encourage parents and private foster carers to notify Children’s Social Care and will share information with Children’s Social Care as appropriate.

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