SAFEGUARDING POLICY



Policy Name Safeguarding Children and Young People Policy (Under 18s)
Section General
Date Created October 2021
Date Effective if Different from Approval Date
Last Approved October 2022
Next Review Scheduled September 2023

1. POLICY STATEMENT

Ergo Education regards the health, safety and welfare of all children and young people engaged in its activities, regardless of where they live, as one of its highest priorities. The organisation recognises and fully accepts its moral and statutory duty to safeguard and promote the welfare of children and young people and its duty to protect staff from unfounded allegations of abuse.

This Policy should be read in conjunction with the Policy for Safeguarding Vulnerable Adults, Staff Code of Conduct, Student Behaviour Code, Health and Safety Policy and Whistleblowing Policy.

Ergo Education believes everyone has the right to live free from abuse or neglect regardless of age, ability or disability, sex, race, religion, ethnic origin, sexual orientation, marital or gender status. Those in a position of trust must do everything they can to foster and protect these rights, to promote the welfare of all children and young people involved in Ergo Education programmes and keep them safe from harm. Ergo Education is committed to protecting both the participants we work with and our staff.

The purpose of this policy is to ensure that all staff working for Ergo Education understand:

  1. The legislation and guidance which relate to safeguarding children and young people.
  2. Ergo Education’s policy for safeguarding children and young people.
  3. Their role and responsibility for safeguarding children and young people.

2. SCOPE

Whilst this policy refers to UK legislation and guidance, Ergo Education understands that culture and safeguarding policy and guidance varies in each country and as such reporting and referral processes may also differ. Additional guidance from non-UK countries will be sought as required. The principles of this policy will however apply to all children, regardless of their nationality.

This policy applies to all individuals employed by or representing Ergo Education, including managers, paid staff, self-employed tutors and volunteers, hereafter collectively referred to as staff.

Ergo Education staff are expected to read this policy and understand the standards expected of them with regards to safeguarding.

This policy will be reviewed annually to ensure it is up to date with the relevant legislation and best practice.


3. PRINCIPLES OF SAFEGUARDING AT ERGO EDUCATION

We will ensure:

  1. A safe environment for all participants and staff.
  2. Those suffering or at risk of suffering significant harm or abuse are identified and referred to the necessary agencies as appropriate.
  3. All staff learn about safeguarding, the organisation’s policies and procedures and how to keep themselves and others safe. We will do this by:
  4. Appointing and training a Designated Safeguarding Lead (DSL) and Deputy (DDSL) to lead on and manage all safeguarding matters.
  5. Raising awareness of issues relating to the welfare and safeguarding of children and young people. (See Appendix 1)
  6. Ensuring all staff understand and adhere to our Code of Conduct.
  7. Engaging with stakeholders to ensure their commitment to safeguarding.
  8. Ensuring staff recognise the signs of abuse or that an individual may be at risk of significant harm.
  9. Working with other agencies as appropriate where an individual is being, or at risk of being, significantly harmed. (e.g., children and young people ’s services, schools and colleges, the police)
  10. Providing a framework for reporting and dealing with concerns and disclosures.
  11. Establishing clear procedures for the reporting and handling of allegations of abuse against staff.
  12. Requiring staff to undertake regular safeguarding training as appropriate.

4. LEGISLATIVE FRAMEWORK

The legislative frameworks and guidance that underpin this policy are:

The Children’s Act 1989/2004 which sets out that all people working with children have a responsibility to help safeguard children and promote their welfare https://www.legislation.gov.uk/ukpga/2004/31/contents

Working Together to Safeguard Children 2018, which reaffirms safeguarding as everyone’s responsibility and the importance of sharing information between agencies. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/a ttachment_data/file/942454/Working_together_to_safeguard_children_inter_age ncy_guidance.pdf

Keeping Children Safe in Education 2022, which requires all staff to understand their responsibilities if engaged in ‘regulated’ activities with young people. Keeping children safe in education 2022 (publishing.service.gov.uk)

The Sexual Offences Act 2003, which deems a relationship between a person in a position of trust with a participant as a criminal offence. https://www.legislation.gov.uk/ukpga/2003/42/contents

Safeguarding Vulnerable Groups Act 2006, was passed to help avoid harm, or risk of harm, by preventing people who are deemed unsuitable to work with children and vulnerable adults from gaining access to them through their work. https://www.legislation.gov.uk/ukpga/2006/47/contents

Regulated Activity with Children in England - Disclosure and Barring Service, which explains the definition of Regulated Activity including who is eligible for a barred list check. https://assets.publishing.service.gov.uk/government/uploads/ system/uploads/atta chment_data/file/739154/ Regulated_Activity_with_Children_in_England.pdf

Keeping Children Safe in Out of School Settings, Department for Education Guidance on safeguarding for all out of school settings such as community activities, tuition or after-school clubs for children

Keeping children safe: code of practice (publishing.service.gov.uk)

Safeguarding and Child Protection for Tutors – NSPCC Guidance Safeguarding and child protection for tutors | NSPCC Learning


5. DEFINITIONS

Safeguarding – protecting children and young people from maltreatment, preventing impairment of their mental and physical health or development and ensuring they are growing up in circumstances consistent with the provision of safe and effective care.

Child Protection – any activity that is undertaken to protect specific children and young people who are suffering, or are likely to suffer, significant harm.

Child/Young Person - anyone who has not yet reached their 18th birthday.

Position of Trust is a legal term that refers to certain roles and settings where an adult has regular and direct contact with children. Examples of positions of trust include teachers, care workers, social workers.

Regulated activity refers to certain roles that involve working with children. This includes unsupervised, face to face, teaching, training or instruction, care or supervision of a child under the age of 18 for more than 3 days in a 30-day period.

Physical Abuse - may involve hitting, shaking, throwing, poisoning, burning, scalding, drowning or suffocating. It may be done deliberately or recklessly or be the result of a deliberate failure to prevent an injury occurring.

Neglect - the persistent or severe failure to meet a child’s, young person’s or vulnerable adult’s physical and/or psychological needs, which may result in serious impairment of their health or development.

Sexual Abuse involves a child, young person or vulnerable adult being forced or coerced into participating in or watching sexual activity of any kind. Any apparent consent or awareness is irrelevant.

Emotional Abuse – persistent emotional ill treatment or rejection; includes abusive or offensive electronic communications. This causes severe and adverse effects on behaviour and emotional development, resulting in low self-esteem. Some degree of emotional abuse is present in all forms of abuse.

Significant Harm – The Children and Young People’s Act introduced the concept of significant harm as the threshold that justifies compulsory intervention in family life in the best interest of the child. Some children and young people may be in need of help because they are suffering or likely to suffer significant harm.


6. ROLES AND RESPONSIBILITIES

Safeguarding is everyone’s responsibility and all staff involved in the organisation’s activities have a role to play. Ergo Education will ensure that staff undergo basic safeguarding training at induction, advanced training as appropriate and will take part in the annual staff development programme where safeguarding updates/refreshers will be programmed. The Designated Safeguarding Lead (DSL) is Susan Lowndes Marques The Deputy Designated Safeguarding Lead (DDSL) is Shivani Johnsson The DSL and DDSL will be responsible for:

  1. Managing the referral of cases of suspected abuse or allegations to the relevant agencies.
  2. Keeping detailed, accurate, secure written records of concerns and referrals.
  3. Maintaining secure and accurate records of any child protection concern, referral, complaint or allegation.
  4. Communication of the policy and arrangements to all relevant parties including but not limited to partners, stakeholders and staff.
  5. Ensuring that staff receive safeguarding training appropriate to their roles and update this annually.
  6. Maintaining accurate and up to date employment records of all staff including DBS checks where it is confirmed that the member of staff is involved in regulated activity.
  7. Maintaining safeguarding training records.
  8. Safety of all participants, including when it becomes apparent that a child is absent or missing from a session, without explanation and/or where there are concerns about their welfare.
  9. Providing periodic reports to the board about safeguarding incidents or referrals as well as policy implementation.
  10. Act as a source of support, advice and expertise for staff.

7. SAFE RECRUITMENT OF STAFF

Ergo Education operates safer recruitment and employment practices. Staff

checks and critical process undertaken include:
  1. Enhanced Disclosure and Barring Service (DBS) check where the member of staff is involved or likely to be involved in ‘regulated’ activity.
  2. Where a conviction is recorded, the DSL will carry out a risk assessment and decide whether to confirm or reject the individual’s appointment. (Anyone that is barred from working with vulnerable adults will NOT be appointed)
  3. Two employment/education references including the most recent employment.
  4. Check on gaps in work history.
  5. Evidence of identity is obtained, including the right to work in the UK.
  6. Qualifications are checked and verified with original certificates.
  7. Areas of concern in the CV or application will be addressed during the interview.
  8. Applicants sign the application form to declare the information they have provided is true.

8. ALLEGATIONS AGAINST STAFF

The primary concern in the event of an allegation is to ensure the safety of the child or young person. In all cases, action will be taken quickly, confidentially and professionally, with all parties clear that suspension is not an indicator of guilt, but a required part of a process.

Where an allegation is made, the Managing Director and the DSL will meet to discuss the required action. In order that a full and fair investigation can be carried out, consideration must be given to suspending the member of staff. Where it is clear that a criminal offence may have occurred, the matter must be reported to the police.

The DSL must report any concerns that meet the ‘harms threshold’ to the Local Authority Designated Officer (see KCSIE 2022) Any subsequent dismissal must be reported to the Disclosure and Barring Service and the Local Authority Designated Lead. (LADO)

In the event that a member of staff suspects any other member of staff of abusing a child or young person, it is their responsibility to report these concerns to the Designated Safeguarding Lead (or Deputy), except when they are the person against whom the allegation is being made. In this instance, the report should go to the Managing Director.


9. ONLINE SAFETY

Ergo Education conducts many of its programmes using online platforms to expand our reach and serve a greater number of individuals from across the UK.

We believe that:

  1. Children and young people should never experience online abuse of any kind.
  2. Children and young people should be able to use the internet for education. and personal development, but safeguards need to be in place to ensure they are kept safe at all times.

We recognise that:

  1. The online world provides everyone with many opportunities; however, it can also present risks and challenges.
  2. We have a duty to ensure that all children and young people involved in our organisation are protected from potential harm online.
  3. We have a responsibility to help keep participants safe online, whether or not they are using Ergo Education’s network and devices.

We will seek to keep participants safe by:

  1. Appointing an Online Safety Coordinator - the same person as our Designated Safeguarding Lead.
  2. Tracking all official online activities for review where necessary - these recordings will be stored securely for a period of 12 months following the completion of the programme.
  3. Providing clear and specific directions to staff on how to behave online through our code of conduct.
  4. Supporting and encouraging participants using our service to follow our student behaviour code and use the internet, social media and mobile phones in a way that keeps them safe and shows respect for others.
  5. Developing clear and robust procedures to enable us to respond appropriately to any incidents of inappropriate online behaviour, whether by an adult or a child/young person.
  6. Reviewing and updating the security of our information systems regularly.
  7. Ensuring that usernames, logins, email accounts and passwords are used effectively.
  8. Ensuring personal information about participants who are involved in our organisation is held securely and shared only as appropriate.
  9. Ensuring that images of participants are used only after their written permission has been obtained, and only for the purpose for which consent has been given.
  10. Providing supervision, support and training for staff about online safety.
  11. Examining and risk assessing any social media platforms, e.g., WhatsApp, Twitter, Instagram and any other new technologies before they are used on behalf of the organisation, ensuring that they are only used for the purposes of education and in accordance with the code of conduct.

If online abuse occurs, we will respond to it by:

  1. Having clear and robust safeguarding procedures in place.
  2. Providing support and training for all staff on dealing with all forms of abuse, including bullying/cyberbullying, emotional abuse, sexting, sexual abuse and sexual exploitation.
  3. Making sure our response takes the needs of the child experiencing abuse, any bystanders and our organisation, into account.
  4. Reviewing the plan developed to address online abuse at regular intervals, in order to ensure that any problems have been resolved in the long term.

10. PROCEDURE FOR DEALING WITH CONCERNS AND DISCLOSURES

If any member of staff is concerned about the welfare or safety of a child or young person, they must report their concerns to the DSL or DDSL as soon as practicably possible.

Written notes of the disclosure or concern should be made by the member of staff, and these will be held in a secure location and shared with the relevant agencies as appropriate.

Staff will receive regular training on how to deal with disclosures made by a child, or vulnerable adult.


11. WHO TO CONTACT

In the first instance, contact the Designated Safeguarding Lead (DSL). If you are unable to make phone contact or receive an out of office reply, please contact the Deputy DSL. If your concern relates to a member of the Ergo Education team, please contact the Managing Director on admin@ergo-education.com


Appendix 1


Types of Abuse

Abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting; by those known to them or, more rarely, by a stranger. They may be abused by an adult(s) or another child or children.

In addition to the stated types of abuse, there are many other risks that are faced by children, young people and vulnerable adults on a day-today basis. It is important that all adults involved with Ergo Education understand these risks and recognise the signs that a leaner may be in need of support.

Physical abuse - Physical abuse 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.

Emotional Abuse - 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 children that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond the 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 causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.

Sexual Abuse - Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, including prostitution, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative or non-penetrative acts. They may include non-contact activities, such as involving children in looking at, or in the production of, pornographic material or watching sexual activities, or encouraging children to behave in sexually inappropriate ways.

Neglect - 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 and clothing, shelter including exclusion from home or abandonment, failing to protect a child from physical and emotional harm or danger, failure to ensure adequate supervision including the use of inadequate carers, or the failure to ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Child Sexual Exploitation - Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator.

Criminal Exploitation - Criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity: drug networks or gangs groom and exploit children and young people to carry drugs and money from urban areas to suburban and rural areas, market and seaside towns.

Extremism and Radicalisation – Extremism is defined as “vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs; and/or calls for the death of members of our armed forces, whether in this country or overseas.” Radicalisation is defined as “the way in which a person comes to support terrorism and encourages other people to believe in views that support terrorism”

Child-on-Child Abuse - Children can abuse other children. This is generally referred to as peer-on-peer abuse and can take many forms. This can include (but is not limited to) bullying (including cyberbullying); sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; Up skirting, sexting, and initiating/hazing type violence and rituals.

Sexual Harassment and Violence – Staff that work in education must understand and acknowledge that sexual harassment and violence can take place in an education environment between children. Staff must take all reports seriously and follow the attached procedures for reporting the matter.

Domestic Abuse - Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. Witnessing domestic abuse is considered to be emotional abuse in itself. Forced Marriage – describes a marriage in which one or both of the parties are married without their consent or against their will. Different from an arranged marriage, in which both parties’ consent.

Female Genital Mutilation - all procedures involving partial or total removal of the external female genitalia for nonmedical reasons. FGM is illegal in England and Wales under the FGM Act 2003.

Mental Health - all staff should be aware that mental health problems can, in some cases, be an indicator that a child or a vulnerable adult has suffered or is at risk of suffering abuse, neglect or exploitation. Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem. Where children have suffered abuse and neglect, or other potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. It is important that staff are aware of how these early experiences, can impact on their mental health, behaviour and education.