Safeguarding & Child Protection Policy

10. Specific safeguarding issues

For more information relating to specific safeguarding issues, please see Appendix B.  For more information about child-on-child abuse, please see Appendix A. 

10.1 Female Genital Mutilation (FGM)

Any teacher who discovers (either through disclosure by the victim or visual evidence) that an act of FGM appears to have been carried out on a pupil under 18 must immediately report this to the police, personally. This is a statutory duty, and teachers will face disciplinary sanctions for failing to meet it. Unless they have good reason not to, they should also discuss the case with the DSL and involve children’s social care as appropriate. Any other member of staff who discovers that an act of FGM appears to have been carried out on a pupil under 18 must speak to the DSL and follow our local safeguarding procedures.

The duty for teachers mentioned above does not apply in cases where a pupil is at risk of FGM or FGM is suspected but is not known to have been carried out. Staff should not examine pupils.

Any member of staff who suspects a pupil is at risk of FGM or suspects that FGM has been carried out [if relevant, insert: or discovers that a pupil age 18 or over appears to have been a victim of FGM] must speak to the DSL and follow our local safeguarding procedures.

DSL will inform the police if FGM is suspected.

10.2 Radicalisation and extremism

 All schools are subject to a duty under section 26 of the Counter-Terrorism and Security Act 2015 in the exercise of their functions to have “due regard” to the need to prevent people from being drawn into terrorism. In the event that concerns are raised relating to radicalisation and extremism, the DSL should be informed immediately. 

We adhere to the Prevent Duty statutory guidance (2023). 

We promote tolerance and cohesion in all of our sessions.

10.3 Children potentially at greater risk of harm

LTC recognises that some children need a social worker due to abuse, neglect, exploitation or family circumstances and that abuse and trauma can leave children vulnerable to further harm, as well as educational disadvantage. 

The DSL will hold information relating to social workers working with children at the school/college. This information will inform decisions about safeguarding and promoting welfare (including the provision of pastoral and/or academic support).

We will also take action to promote the educational outcomes of and to protect; 

• Children missing education;
• Children missing from home or care.

There are other familial issues that can have a detrimental impact on children. We work with other agencies in line with KCSIE (2024) to support children and families in the following circumstances:

• Children facing the court procedures and/or children in the court system.
• Children with family members in prison.
• Children who are homeless.
• Children who need a social worker.

10.4 Mental health

Mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation. 

Staff will be alert to behavioural signs that suggest a child may be experiencing a mental health problem or be at risk of developing one.  Where children have suffered abuse, neglect and exploitation, or other potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. It is key that staff are aware of how these children’s experiences, can impact on their mental health, behaviour and education. 

If staff have a mental health concern about a child we will respond to the concern, inform and discuss our concerns with parents/carers and seek ways to support the child in and out of school.

If you have a mental health concern about a child that is also a safeguarding concern, take immediate action by following the steps in Section 9. 

If you have a mental health concern that is not also a safeguarding concern, speak to the DSL to agree a course of action. 

Only appropriately trained professionals should attempt to make a diagnosis of a mental health concern.  However, LTC will provide information and signposting services to children and parents and assist with the teaching of emotional health and wellbeing to children in our curriculum

Information regarding pupil mental health concerns will be immediately fed back to the school DSL.

Refer to the Department for Education guidance on mental health and behaviour in schools11 for more information.

10.5 Child on child abuse 

LTC takes all reports and concerns about child-on-child abuse, including child on child sexual violence and harassment, very seriously. This includes any reports or concerns that have occurred outside of the AP premises, or online. 

In order to ensure that our policy on child-on-child abuse is well-promoted, easily understood and accessible, we have included information about our approach to minimising and responding to child-on-child abuse as an appendix. Full details of how the school prevents, responds to and supports victims of child-on-child abuse can be found at Appendix A. 

11 https://www.gov.uk/government/publications/mental-health-and-behaviour-in-schools–2 

10.6 Online safety, including filtering and monitoring

All staff are made aware of LTC policy on online safety, which sets our expectations relating to:

• creating a safer online environment – including training requirements, filters and monitoring;
• what staff should be alert to, what to report and how staff should report any concerns – including those related to the efficacy of filtering and monitoring systems;
• giving everyone the skills, knowledge and understanding to help children and young people stay safe on-line;
• inspiring safe and responsible use and behaviour;
• safe use of mobile phones both within school and on school trips/outings;
• safe use of camera equipment, including camera phones; and
• what steps to take if you have concerns and where to go for further help.

Staff must read the Online Safety Policy in conjunction with our Code of Conduct in relation to personal online behaviour. 

Any concerns related to children’s safety online (either safeguarding or technical) should be reported to the DSL immediately. 

Pupil mobile phones 

Pupils will be asked to hand in mobile phones at the start of each session.

11. Pupils with special educational needs and disabilities (SEND)

 We recognise that pupils with special educational needs (SEN) and disabilities can face additional safeguarding challenges. Additional barriers can exist when recognising abuse, neglect and exploitation in this group, including;

• assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the child’s disability without further exploration;
• pupils being more prone to peer group isolation than other pupils;
• the potential for pupils with SEN and disabilities being disproportionally impacted by behaviours such as bullying, without outwardly showing any signs; and/or
• communication barriers and difficulties in overcoming these barriers.

More information can be found about support for children with SEND here:

• Specialist SEND support services in West Northants13

• Specialist SEND support services in North Northants1

12. Pupils with a social worker and those that have previously needed a social worker

Pupils may need a social worker due to safeguarding or welfare needs. We recognise that a child’s experiences of adversity and trauma can leave them vulnerable to further harm as well as potentially creating barriers to attendance, learning, behaviour and mental health. We work with the local authority to ensure that we are providing effective support for this group of children. 

The role of virtual school head now includes a non-statutory responsibility for oversight of the attendance, attainment and progress of children with a social worker and children in kinship care. 

The DSL and all members of staff will work with and support social workers to help protect vulnerable children.

Where we are aware that a pupil has a social worker, the DSL will always consider this fact to ensure any decisions are made in the best interests of the pupil’s safety, welfare and educational outcomes. For example, it will inform decisions about;

• responding to unauthorised absence or missing education where there are known safeguarding risks; and
• the provision of pastoral and/or academic support. 

13. Looked after and previously looked after children

We will ensure that staff have the skills, knowledge and understanding to keep looked-after children and previously looked-after children safe. In particular, we will ensure that: 

Appropriate staff have relevant information about children’s looked after legal status, contact arrangements with birth parents or those with parental responsibility, and care arrangements. The DSL has details of children’s social workers and relevant virtual school heads. 

• We have appointed a designated teacher, Louise Herbert, who is responsible for promoting the educational achievement of looked-after children and previously looked-after children in line with statutory guidance.
• The designated teacher is appropriately trained and has the relevant qualifications and experience to perform the role.
• As part of their role, the designated teacher will:
• Work closely with the DSL to ensure that any safeguarding concerns regarding looked after and previously looked-after children are quickly and effectively responded to.
• Work with virtual school heads to promote the educational achievement of looked after and previously looked-after children, including discussing how pupil premium plus funding can be best used to support looked-after children and meet the needs identified in their personal education plans.

We will ensure that staff have the skills, knowledge and understanding to keep looked-after children and previously looked-after children safe. In particular, we will ensure that: 

• Appropriate staff have relevant information about children’s looked after legal status, contact arrangements with birth parents or those with parental responsibility, and care arrangements
• The DSL has details of children’s social workers and relevant virtual school heads
• We have appointed an appropriately trained teacher, Louise Herbert, to take the lead on promoting the educational achievement of looked-after and previously looked-after children.

As part of their role, they will:

• Work closely with the DSL to ensure that any safeguarding concerns regarding looked-after and previously looked-after children are quickly and effectively responded to
• Work with virtual school heads to promote the educational achievement of looked after and previously looked-after children

14. Record-keeping

All safeguarding concerns, discussions and decisions made and the reasons for those decisions must be recorded in writing. This includes instances where referrals were or were not made to another agency. If in doubt about recording requirements staff should discuss this with the DSL. 

When a child has made a disclosure, the member of staff/volunteer should;

• record as soon as possible after the conversation. Use the school record of concern sheet wherever possible;
• not destroy the original notes in case they are needed by a court;
• record the date, time, place and any noticeable non-verbal behaviour and the words used by the child;
• draw a diagram to indicate the position of any injuries if relevant; and
• record statements and observations rather than interpretations or assumptions

All records need to be given to the DSL promptly. No copies should be retained by the member of staff or volunteer.

The Designated Safeguarding Lead will ensure that all safeguarding records are managed in accordance with the Education (Pupil Information) (England) Regulations 2005. All concerns, discussions and decisions made, and the reasons for those decisions, should be recorded in writing. Information should be kept confidential and stored securely.

Records will include: 

• a clear and comprehensive summary of the concern;
• details of how the concern was followed up and resolved; and • a note of any action taken, decisions reached and the outcome.

Non-confidential records will be easily accessible and available. Confidential information and records will be held securely and only available to those who have a right or professional need to see them. We will hold records in line with our records retention schedule. 

If a child for whom the LTC has, or has had, safeguarding concerns ceases to attend LTC, the DSL will ensure that their child protection file is forwarded promptly and securely, and separately from the main pupil file. 

In addition, if the concerns are significant or complex, and/or social services are involved, the DSL will speak to the DSL of the receiving school and provide information to enable them to have time to make any necessary preparations to ensure the safety of the child. 

15. Relationships, sex and health education (RSHE)

Promoting safeguarding and welfare in the curriculum

At LTC we promote healthy relationships and aim to education pupils in what healthy relationships look like.

LTC plays a crucial role in preventative education. This is in the context of a holistic approach to preparing pupils for life in modern Britain, and a culture of zero tolerance

Commented [ER6]: This section remains in line with guidance as of July 2024. 

We will not tolerate any incidents of sexism, misogyny/misandry, homophobia, biphobia and sexual violence/harassment. This will be underpinned by our:      

• Student code of conduct
• Pastoral support system

Staff will challenge and address

• Stereotyping, prejudice and equality.
• Body confidence and self-esteem.
• How to recognise an abusive relationship (including coercive and controlling behaviour).
• The concepts of, and laws relating to, sexual consent, sexual exploitation, abuse, grooming, coercion, harassment, rape, domestic abuse, so-called honour-based violence such as forced marriage and female genital mutilation (FGM) and how to access support.
• What constitutes sexual harassment and sexual violence and why they are always unacceptable.

16. Safer working practice

We work to create and embed a culture of openness, trust and transparency, in which LTC’s values and expected behaviour (as set out in the staff code of conduct) are constantly lived, monitored and reinforced by all staff.

We expect all staff to act with professionalism at all times. To reduce the risk of unsafe or harmful practice, all staff should receive training on safer working practice and should be familiar with the guidance contained in the staff handbook/school code of conduct/staff behaviour policy and Safer Recruitment Consortium document Guidance for safer working practice for those working with children and young people in education settings (September 2022).16

The proprietor and senior leaders will ensure that this policy is adhered to by:

• ensuring staff are clear about what appropriate behaviour is, and are confident in distinguishing expected and appropriate behaviour from concerning, problematic or inappropriate behaviour, in themselves and others through effective training;
• empowering staff to share any low-level safeguarding concerns;
• addressing unprofessional behaviour and supporting the individual to correct it at an early stage; and
• providing a responsive, sensitive and proportionate handling of such concerns when they are raised.

16 https://www.saferrecruitmentconsortium.org/ 

Governors/proprietors will help to identify any weakness in the school or college’s safeguarding system.

Staff are expected to adhere to the staff Code of Conduct at all times. In the event of any concerns or allegations, the school will deal with them promptly, in line with local guidance and KCSIE (2024). 

16.1 Staff use of mobile phones and smart technology

Staff are allowed to bring their personal phones to LTC for their own use but will limit such use to non-contact time when pupils are not present. Staff members’ personal phones will remain in their bags or cupboards during contact time with pupils. Staff will not take pictures or recordings of pupils on their personal phones or cameras. 

We will follow the General Data Protection Regulation and Data Protection Act 2018 when taking and storing photos and recordings for use in the school. 

17. Safeguarding concerns about and allegations against members of staff

 17.1 Allegations that may meet the harms threshold  

In the event that there is an allegation of abuse against a member of staff, we will adhere to Part 4, Section 1 of KCSIE (2024) and Northamptonshire Safeguarding Children Partnership guidance. See Appendix D for more details. 

Allegations that may indicate that a person would pose a risk of harm if they continue to work in their present position or in any capacity with children in a school or college include: 

• staff having behaved in a way that has harmed a child, or may have harmed a child;
• staff possibly committing a criminal offence against or related to a child;
• staff behaving towards a child or children in a way that indicates they may not be suitable to work with children; and/or
• staff behaving or possibly behaving in a way that indicates they may not be suitable to work with children.

This includes behaviour or incidents that have occurred both in and outside of LTC.

Allegations against the proprietor

If an allegation is made against the proprietor, it must be reported to LADO.

Allegations against staff

If a concern or allegation of abuse arises against any member of staff or volunteer other than the proprietor, it must be reported to the proprietor without delay. This includes supply staff, volunteers and anyone working in or on behalf of LTC, whether paid or unpaid.  Allegations of abuse against staff must be reported to the proprietor and DSL  and not discussed directly with the person involved. 

The proprietor and DSL should consider if the concern or allegation meets the threshold for Designated Officer intervention. 

Allegations against staff relating to a position of trust issue will be referred to the Local Authority designated officer within 24 hours. If a child has suffered or may have suffered abuse or harm, a MASH referral will also be made and the police will be contacted if necessary. 

A referral to the Disclosure and Barring Service will be made if a member of staff is dismissed or removed from their post as a result of safeguarding concerns, or would have been removed if they had not have resigned.

Staff who are concerned with the behaviour of other staff should immediately inform the proprietor.

17.2 Safeguarding concerns that do not meet the harm threshold (low level concerns)

In the event that there is a safeguarding concern about a member of staff, we will adhere to guidance outlined in Part 4, Section 2 of KCSIE (2024) and Northamptonshire Safeguarding Children Partnership guidance.  

The term ‘low-level’ concern does not mean that it is insignificant, it means that the behaviour towards a child does not meet the harms threshold. A low-level concern is any concern – no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ – that an adult working in or on behalf of the school or college may have acted in a way that: 

• is inconsistent with the staff code of conduct, including inappropriate conduct outside of work; and
• does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the LADO.

It is essential that low level concerns are reported. Such behaviours can exist on a wide spectrum, from the inadvertent or thoughtless, or behaviour that may look to be inappropriate, but might not be in specific circumstances, through to that which is ultimately intended to enable abuse.

Examples of such behaviour could include, but are not limited to:

• Being overly friendly with children
• Having favourites
• Taking photographs of children on their mobile phone
• Engaging with a child on a one-to-one basis in a secluded area or behind a closed door
• Humiliating pupils

We will act quickly, proportionately and appropriately in the event of a low level concern, to prevent abuse or harm of a child and to promote a culture of safeguarding. Dealing with low level concerns also protects those working in or on behalf of schools and colleges from potential false allegations or misunderstandings.

Staff will receive training about what may constitute a low-level concern. More information can be found in Part 4 of KCSIE (2024). 

Reporting low level concerns

Low level concerns should be reported to the proprietor. 

All low-level concerns should be recorded in writing. The record should include details of the concern, the context in which the concern arose, and action taken. The name of the individual sharing their concerns should also be noted, if the individual wishes to remain anonymous then that should be respected as far as reasonably possible. These records will be kept <insert your arrangements for how they are kept here.

The proprietor may: 

• Speak directly to the person who raised the concern (unless it has been raised anonymously).
• Speak to the individual involved and/or witnesses.

The proprietor will then categorise the type of behaviour and decide on an appropriate course of action. This will be recorded, along with rationale for any decisions made and details of action taken. 

Records will be reviewed so that potential patterns of concerning, problematic or inappropriate behaviour can be identified. In the event that patterns and/or wider cultural issues within the school are identified, the school will either:

• take action through our disciplinary procedures;
• refer behaviour to the local authority designated officer/s where a pattern of behaviour moves from a concern to meeting the harms threshold; and/or
• revise policies or implement extra training as appropriate, to minimise the risk of behaviour happening again.

We will retain low level concerns information for a period of 12 months.

17.3 Supply staff 

Although LTC does not directly employ supply staff, we will ensure that any concerns or allegations against supply staff are handled properly. We will never cease to use a supply teacher for safeguarding reasons without finding out the facts and liaising with the Local Authority Designated Officer to reach a suitable outcome. 

The proprietors will liaise with the supply agency to determine whether to suspend or redeploy the supply staff whilst they carry out their investigation. 

LTC will inform supply agencies of its process for managing allegations and will take account of the agency’s policies and their duty to refer to the DBS as personnel suppliers. Informing supply agencies of our process for managing allegations includes inviting the agency’s human resource manager (or equivalent) to meetings and regularly updating agencies on relevant school policies.

18. Complaints and concerns about school safeguarding policies

18.1 Complaints against staff

Complaints against staff that are likely to require a child protection investigation will be handled in accordance with our procedures for dealing with low level concerns or allegations of abuse made against staff (see Section 17). 

18.2 Other complaints

Complaints should be emailed to info@limitlesstrainingclub.com and will be responded to via email within 7 working days.

22. Policy implementation, monitoring and review

The policy will be reviewed annually by the DSL team. It will be implemented through LTC’s induction and training programme, and as part of day to day practice.  Compliance with the policy will be monitored by the Designated Safeguarding Lead and through staff performance measures.

 Appendix A: Child on child abuse

 Child on child abuse is any abuse of a child or children that is perpetrated by another child or children. This includes all forms of sexual harassment, sexual violence and abuse. We strive to create a culture of safety, where children are free from harassment or abuse of any kind. We take a zero-tolerance approach to sexual violence and sexual harassment – it is never acceptable and it will not be tolerated. 

We know that even if we do not receive any reports relating to child on child abuse, it does not mean that it is not happening. We support and encourage anyone – especially our pupils – to come forward to share any concerns about child on child abuse so that we can take action to keep all children safe. 

Child on child abuse is most likely to include, but may not be limited to: 

• bullying (including cyberbullying, prejudice-based and discriminatory bullying);
• abuse in intimate personal relationships between children (sometimes known as ‘teenage relationship abuse’);
• physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse);
• sexual violence, such as rape, assault by penetration and sexual assault (this may include an online element which facilitates, threatens and/or encourages sexual violence);
• sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of abuse;
• causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party;
• consensual and non-consensual sharing of nudes and semi nude images and or videos (also known as sexting or youth produced sexual imagery);
• upskirting, which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm; and
• initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an online element).

All children are capable of abusing their peers and we recognise that girls are more likely to be the victims of child on child abuse and boys’ perpetrators. All child on child abuse is unacceptable and will be taken seriously.

Harmful sexual behaviour (HSB)

 We recognise that children’s sexual behaviour exists on a wide continuum, ranging from normal and developmentally expected to inappropriate, problematic, abusive and violent. We refer to problematic, abusive and violent sexual behaviour as ‘harmful sexual behaviour’. 

When responding to HSB, we will:

• Consider the behaviours in a child protection context;
• Consider the ages and developmental stages of the children involved;
• Take action in line with local thresholds and pathways guidance and relevant statutory guidance; and
• Seek specialist support as required.

We will take action at the earliest possible point, to safeguard children and to prevent problematic, abusive and/or violent behaviour in the future. 

We recognise that children displaying HSB have often experienced their own abuse and trauma and we will offer support as required. 

Staff training

All staff are made aware that children can abuse other children, that this can happen online or in person, at school or outside of school. All staff will receive training so that they can confidently recognise the indicators and signs of child on child abuse in order to identify it and respond appropriately to reports. All staff will be made aware of the school or college’s policy and procedures with regards to child on child abuse and the crucial role that they play in preventing it and responding to it as necessary. It will be made clear that addressing inappropriate behaviour (even if it appears to be relatively innocuous) can be an important intervention that helps prevent problematic, abusive and/or violent behaviour in the future.

In order to minimise opportunities for child-on-child abuse, and to establish a safe environment for all children, we:

• have a robust student code of conduct, which makes it clear that we have a zero tolerance approach to any kind of child on child abuse;
• ensure staff understand what is meant by child-on-child abuse and the school policy on child on child abuse by <insert details here>;
• train staff thoroughly so that they challenge inappropriate behaviour (even if it appears to be relatively innocuous);
• train staff thoroughly so that they are confident to challenge inappropriate behaviours between peers, that are actually abusive in nature;
• never downplay certain behaviours, for example dismissing sexual harassment as “just banter”, “just having a laugh”, “part of growing up” or “boys being boys”, as this can lead to a culture of unacceptable behaviours, an unsafe environment for children and in worst case scenarios a culture that normalises abuse leading to children accepting it as normal and not coming forward to report it; and
• recognise that sexual harassment and sexual violence, as well as other forms of child on child abuse, may be happening even if they are not reported.

We ensure that our systems for reporting all safeguarding concerns are well promoted, easily understood and easily accessible for children to confidently report abuse, knowing their concerns will be treated seriously.

Additional Vulnerabilities

We recognise that some children may be more vulnerable to child-on-child abuse than others. For example, children who have already experienced abuse, those that have special educational needs or disabilities (SEND), children living in care and children who are LGBTQ+, may be more likely to face child on child abuse than other children. We recognise that girls are more likely to be the victims of child-on-child abuse than boys. Some children may face additional barriers to telling anyone about abuse because of their vulnerability, disability, sex, ethnicity and/or sexual orientation. We work to protect children with additional vulnerabilities by

• Promoting inclusivity and zero tolerance of any form of abuse.

How to report concerns

Our pupils

If a young person witnesses or experiences any form of child-on-child abuse, we strongly encourage them to speak to a trusted member of staff, parent or trusted adult about it. If a child discloses to an adult outside of school, the adult should contact the Designated Safeguarding Lead without delay to report the issue. 

All victims will be taken seriously, regardless of how long it has taken them to come forward and they will be supported and kept safe. Abuse that occurs online or outside of the school will be treated equally seriously. A victim will never be given the impression that they are creating a problem by reporting child on child abuse, including sexual violence or sexual harassment. A victim will never be made to feel ashamed for making a report or have their experience minimised.

In the event that a pupil reports or discloses child on child abuse, we will take their report seriously, take prompt action to respond and to safeguard the child or children involved and we will ensure that we are listening to the voice of the child when deciding on the best course of action to take. We will always act in the best interests of children. Following any disclosures or reports of child on child abuse, we will review our systems, training and policies to determine if any learning can be derived from the situation to further strengthen our approach to this issue. We will always encourage our pupils to safely express their views and give feedback on how they have been supported following a safeguarding concern. 

Our staff

Any member of staff that has concerns about child on child abuse should follow the procedure set out in Section 9 and must report concerns immediately. 

Others 

We encourage everyone to report any form of abuse or harm perpetrated by or against our pupils. Any concerns should be reported to the Designated Safeguarding Lead, using the details on the front page of this policy. 

Wider concerns 

We strive to create a safe and welcoming environment for all children. If you have any concerns about our culture of safeguarding, policy or procedures, please direct these to the safeguarding lead immediately, or follow our Complaints Policy.  

What happens when an allegation of child on child abuse is made?

• The allegation will be thoroughly investigated and pupils will be spoken to individually.
• Records will be kept of the conversations.
• School will be informed immediately and parents will be spoken to as appropriate.
• In the event of repeated child-on-child abuse, the pupil will be withdrawn from the AP.
• We will adhere to Keeping Children Safe in Education (2024) when responding to incidents of child on child abuse. The school takes child on child abuse seriously and will respond to all concerns or disclosures of child on child abuse, including those that have occurred outside of school and online, immediately.

Upon receiving a concern, report or disclosure of abuse, the Designated Safeguarding Lead will decide what further action is necessary. 

Our starting point regarding any report of child on child sexual harassment or violence should always be that there is a zero tolerance approach, it is never acceptable and it will not be tolerated. It is especially important not to pass off any sexual violence or sexual harassment as “banter”, “just having a laugh”, “part of growing up” or “boys being boys” as this can lead to a culture of unacceptable behaviours and an unsafe environment for children. 

The subsequent action taken will vary depending on the type of child on child abuse and the severity of the incident/s disclosed. The Designated Safeguarding Lead will take contextual factors into account when managing the report. 

The Designated Safeguarding Lead will always consider the following; 

• the wishes of the victim in terms of how they want to proceed. The victims will be given as much control as is reasonably possible over decisions regarding how any investigation will be progressed and any support that they will be offered;
• the nature of the alleged incident(s), including: the level of coercion or threat, whether a crime may have been committed and consideration of harmful sexual behaviour;
• both the chronological ages and developmental stages of the children involved;
• any power imbalance between the children, including consideration of the age of children and whether children have special educational needs or disabilities;
• the impact on the victim;
• that sexual violence and sexual harassment can take place in intimate personal relationships between children;
• if the alleged incident is a one-off or a sustained pattern of abuse;
• if are there ongoing risks to the victim, other children, adult students or school or college staff; and
• Other related issues and wider context, such as links to child criminal or child sexual exploitation.

Depending on the nature of the incident/s, the Designated Safeguarding Lead may

• Seek further information from those involved and witnesses.
• Undertake a risk assessment and needs assessment to ascertain steps necessary to safeguard the victim, alleged perpetrator, adults and other children.
• Decide to manage the concern internally.
• Organise a meeting with relevant staff and agencies to assess risk and agree a safety plan.
• Refer the victim and/or the perpetrator to local services for Early Help.
• Refer the case to Children’s Services via a MASH referral.
• Liaise with social workers working with children involved (if applicable).
• Make a report to the police.
• Liaise with specialist services.

In the event of a disclosure of child on child sexual violence, we will make an immediate risk and needs assessment. The risk and needs assessment will consider: 

• the victim, especially their protection and support (this will include considering school transport as a potentially vulnerable place for a victim or alleged perpetrator(s);
• whether there may have been other victims,
• the alleged perpetrator(s); and
• all the other children, (and, if appropriate, adult students and staff) at the school or college, especially any actions that are appropriate to protect them from the alleged perpetrator(s), or from future harms.

More information about these options in relation to sexual violence and sexual harassment can be found in Part 5 of KCSIE (2024). 

Recording procedures

Memmbers of staff will follow the procedures for recording a disclosure as outlined in Section 9 of this policy.  

How we support victims of child on child abuse

LTC recognises that child on child abuse has a significant impact on young people and victims are likely to need ongoing support. Children who are victims of sexual violence and sexual harassment wherever it happens, will likely find the experience stressful and distressing. Appropriate support will be put in place for victims of child-on-child abuse whilst investigation is taking place and following the initial response. Support will continue for as long as it is needed and will be reviewed regularly to ensure the victim is receiving appropriate care. The school will do everything we can to maintain the victim’s normal routine. We will do everything we can to protect the victim from further bullying, harassment or abuse as a result of their disclosure.  

If a victim of child on child abuse moves to a new setting, the Designated Safeguarding Lead will share the necessary information to ensure that support for the child continues. 

 Local Safeguarding Arrangements and making referrals 

 LTC adheres to local safeguarding arrangements, as outlined by the Northamptonshire Safeguarding Children Partnership. 

For further details of how LTC  works with partner agencies in responding to safeguarding incidents (including incidents of child on child abuse), please see the main body of this policy. 

Parents

 Parents will be informed of incidents unless sharing information puts a child at greater risk of harm. Children will always be encouraged to speak to parents about child on child abuse unless it puts them at greater risk of harm. 

LTC response

We will keep detailed records of any incidents of child on child abuse and will look out for potential patterns of concerning, problematic or inappropriate behaviour. Where a pattern is identified, we will take appropriate action. Consideration will be given to whether there are wider cultural issues that enabled the inappropriate behaviour to occur and in order to minimise it happening again, we may: 

• Dedicate more teaching time to a particular issue or topic;
• Deliver additional staff training
• Ensure that all staff are sharing information

 Appendix B: Types of abuse

 This appendix is based on the advice in Annex B of Keeping Children Safe in Education 2024 – you will need to adapt it to reflect your context and any locally agreed procedures. 

Abuse, including neglect, and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases, multiple issues will overlap. 

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 is the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Emotional abuse 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
• Not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate
• 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
• Seeing or hearing the ill-treatment of another
• Serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children

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 nonpenetrative acts such as masturbation, kissing, rubbing and touching outside of clothing
• 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)
• Ensure access to appropriate medical care or treatment
• It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Children who are absent from education and children missing from education

Children being absent from education for prolonged periods and/or on repeat occasions can act as a vital warning sign to a range of safeguarding issues. This might include abuse or neglect, such as sexual abuse or exploitation or child criminal exploitation (particularly county lines), or issues such as mental health problems, substance abuse, radicalisation, FGM or forced marriage. 

There are many circumstances where a child may become missing from education, but some children are particularly at risk. These include children who:

• Are at risk of harm or neglect.
• Are at risk of forced marriage or FGM.
• Come from Gypsy, Roma, or Traveller families.
• Come from the families of service personnel.
• Go missing or run away from home or care. • Are supervised by the youth justice system.
• Cease to attend a school.
• Come from new migrant families.

We will follow our procedures for unauthorised absence, dealing with persistently absent pupils and children missing education to help identify the risk of abuse, neglect and exploitation and to help prevent the risks of going missing in future. This includes when problems are first emerging but also where children are already known to local authority children’s social care and need a social worker (such as a child who is a child in need or who has a child protection plan, or is a looked after child), where being absent from education may increase known safeguarding risks within the family or in the community.

We will always follow up with parents/carers when pupils are not at school.  This means we need to have at least two, up to date, contacts for parents/carers.  Parents/carers should remember to update the school as soon as possible where these contact details change.  

This includes informing the local authority if a child leaves the school without a new school being named, and adhering to requirements with respect to sharing information with the local authority, when applicable, when removing a child’s name from the admission register at nonstandard transition points. 

Staff will be trained in signs to look out for and the individual triggers to be aware of when considering the risks of potential safeguarding concerns which may be related to being missing, such as travelling to conflict zones, FGM and forced marriage. 

If a staff member suspects that a child is suffering from harm or neglect, we will follow local child protection procedures, including with respect to making reasonable enquiries. We will make an immediate referral to the local authority children’s social care team, and the police, if the child is suffering or likely to suffer from harm, or in immediate danger.

Child criminal exploitation 

 Child criminal exploitation (CCE) is a form of abuse where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into criminal activity, in exchange for something the victim needs or wants, and/or for the financial or other advantage of the perpetrator or facilitator, and/or through violence or the threat of violence. 

The abuse can be perpetrated by males or females, and children or adults. It can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse.

The victim can be exploited even when the activity appears to be consensual. It does not always involve physical contact and can happen online. Some specific forms of CCE can include children being forced or manipulated into transporting drugs or money through county lines, working in cannabis factories, shoplifting or pickpocketing. They can also be forced or manipulated into committing vehicle crime or threatening/committing serious violence to others.

Children can become trapped by this type of exploitation as perpetrators can threaten victims (and their families) with violence, or entrap and coerce them into debt. They may be coerced into carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from others. As children involved in criminal exploitation often commit crimes themselves, their vulnerability as victims is not always recognised by adults and professionals, (particularly older children), and they are not treated as victims despite the harm they have experienced. They may still have been criminally exploited even if the activity appears to be something they have agreed or consented to. 

It is important to note that the experience of girls who are criminally exploited can be very different to that of boys. The indicators may not be the same, however professionals should be aware that girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.

Indicators of CCE can include a child:

• Appearing with unexplained gifts or new possessions
• Associating with other young people involved in exploitation
• Suffering from changes in emotional wellbeing
• Misusing drugs and alcohol
• Going missing for periods of time or regularly coming home late
• Regularly missing school or education
• Not taking part in education

If a member of staff suspects CCE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate.

County Lines

 County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs (primarily crack cocaine and heroin) into one or more importing areas [within the UK], using dedicated mobile phone lines or other form of “deal line”.

Exploitation is an integral part of the county lines offending model with children and vulnerable adults exploited to move [and store] drugs and money. Offenders will often use coercion, intimidation, violence (including sexual violence) and weapons to ensure compliance of victims.

Children can easily become trapped by this type of exploitation as county lines gangs create drug debts and can threaten serious violence and kidnap towards victims (and their families) if they attempt to leave the county lines network.

Serious violence

Signs that a child is at risk from, or involved with serious violent crime include:

• include increased absence from school;
• a change in friendships or relationships with older individuals or groups;
• a significant decline in performance;
• signs of self-harm or a significant change in wellbeing;
• signs of assault or unexplained injuries; and/or
• unexplained gifts or new possessions, which could also indicate that children have been approached by, or are involved with, individuals associated with criminal networks or gangs and may be at risk of criminal exploitation.

There are a range of risk factors which increase the likelihood of involvement in serious violence, such as 

• being male;
• having been frequently absent or permanently excluded from school; and/or
• having experienced child maltreatment and having been involved in offending, such as theft or robbery.

If a member of staff suspects a child is involved in or at risk of serious violent crime, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate. 

Child sexual exploitation

Child sexual exploitation (CSE) is a form of child sexual abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity, in exchange for something the victim needs or wants and/or for the financial advantage or increased status of the perpetrator or facilitator. It may, or may not, be accompanied by violence or threats of violence.

The abuse can be perpetrated by males or females, and children or adults. It can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse. 

CSE can affect any child, who has been coerced into engaging in sexual activities. This includes 16 and 17 year olds who can legally consent to have sex. Some children may not realise they are being exploited e.g. they believe they are in a genuine romantic relationship.

Children and young people often trust their abuser and may be tricked into believing they are in a loving, consensual relationship. 

CSE can include both physical contact (penetrative and non-penetrative acts) and non-contact sexual activity. It can also happen online. For example, young people may be persuaded or forced to share sexually explicit images of themselves, have sexual conversations by text, or take part in sexual activities using a webcam. CSE may also occur without the victim’s immediate knowledge, for example through others copying videos or images.

In addition to the CCE indicators above, indicators of CSE can include a child:

• Having an older boyfriend or girlfriend
• Suffering from sexually transmitted infections or becoming pregnant

If a member of staff suspects CSE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate. 

Child abduction and community safety incidents

 Child abduction is the unauthorised removal or retention of a minor from a parent or anyone with legal responsibility for the child. Child abduction can be committed by parents or other family members; by people known but not related to the victim (such as neighbours, friends and acquaintances); and by strangers. Other community safety incidents in the vicinity of a school can raise concerns amongst children and parents, for example, people loitering nearby or unknown adults engaging children in conversation.

Pupils will only be collected by an adult who is authorised to collect them or by their school.

In the event that anyone has concerns about child abduction or community safety incidents, they should speak to the Designated Safeguarding Lead immediately. 

Cybercrime

Cybercrime is criminal activity committed using computers and/or the internet. It is broadly categorised as either ‘cyber-enabled’ (crimes that can happen off-line but are enabled at scale and at speed on-line) or ‘cyber dependent’ (crimes that can be committed only by using a computer). 

Cyber-dependent crimes include; 

• unauthorised access to computers (illegal ‘hacking’), for example accessing a school’s computer network to look for test paper answers or change grades awarded;
• denial of Service (Dos or DDoS) attacks or ‘booting’. These are attempts to make a computer, network or website unavailable by overwhelming it with internet traffic from multiple sources; and,
• making, supplying or obtaining malware (malicious software) such as viruses, spyware, ransomware, botnets and Remote Access Trojans with the intent to commit further offence, including those above.

Children with particular skill and interest in computing and technology may inadvertently or deliberately stray into cyber-dependent crime. If we have concerns about a child and possible risk of being drawn into cyber crime, the designated safeguarding lead (or a deputy) will consider referring into the Cyber Choices programme. This is a nationwide police programme supported by the Home Office and led by the National Crime Agency, working with regional and local policing. We may also <include positive interventions/early help> and will refer to children’s social care if we think a child is suffering or is at risk of suffering harm. 

Domestic abuse 

Domestic abuse is 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. 

Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse (abuse in intimate personal relationships between children) and child/adolescent to parent violence and abuse.

The abuse can encompass, but is not limited to: psychological; physical; sexual; financial; and emotional.

All children can witness and be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members. Domestic abuse can impact on children through seeing, hearing or experiencing the effects of domestic abuse and/or experiencing it through their own intimate relationships. Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.

Anyone can be a victim of domestic abuse, regardless of gender, age, ethnicity, socioeconomic status, sexuality or background, and domestic abuse can take place inside or outside of the home. Children who witness domestic abuse are also victims.

Older children may also experience domestic abuse and/or violence in their own personal relationships. See Appendix A: Child on child abuse for more details. 

All information sharing and resulting actions will be undertaken in accordance with the ‘NSCP Protocol for Domestic Abuse – Notifications to Schools’. We will record this information and store this information in accordance with the record keeping procedures outlined in this policy.

The DSL will provide support according to the child’s needs and update records about their circumstances. 

Homelessness

Being homeless or being at risk of becoming homeless presents a real risk to a child’s welfare.  The DSL [and deputy/deputies] will be aware of contact details and referral routes into the local housing authority so they can raise/progress concerns at the earliest opportunity (where appropriate and in accordance with local procedures). 

Where a child has been harmed or is at risk of harm, the DSL will also make a referral to children’s social care.

So-called ‘honour-based’ abuse (including FGM and forced marriage)

So-called ‘honour-based’ abuse (HBA) encompasses incidents or crimes committed to protect or defend the honour of the family and/or community, including FGM, forced marriage, and practices such as breast ironing. 

Abuse committed in this context often involves a wider network of family or community pressure and can include multiple perpetrators. 

All forms of HBA are abuse and will be handled and escalated as such. All staff will be alert to the possibility of a child being at risk of HBA or already having suffered it. If staff have a concern, they will speak to the DSL, who will activate local safeguarding procedures.

Female Genital Mutilation

 The DSL will make sure that staff have access to appropriate training to equip them to be alert to children affected by FGM or at risk of FGM.

Section 10 of this policy sets out the procedures to be followed if a staff member discovers that an act of FGM appears to have been carried out or suspects that a pupil is at risk of FGM.

Indicators that FGM has already occurred include:

• A pupil confiding in a professional that FGM has taken place
• A mother/family member disclosing that FGM has been carried out
• A family/pupil already being known to social services in relation to other safeguarding issues
• A girl:
• Having difficulty walking, sitting or standing, or looking uncomfortable.
• Finding it hard to sit still for long periods of time (where this was not a problem previously).
• Spending longer than normal in the bathroom or toilet due to difficulties urinating.
• Having frequent urinary, menstrual or stomach problems.
• Avoiding physical exercise or missing PE.
• Being repeatedly absent from school, or absent for a prolonged period.
• Demonstrating increased emotional and psychological needs – for example, withdrawal or depression, or significant change in behaviour.
• Being reluctant to undergo any medical examinations.
• Asking for help, but not being explicit about the problem.
• Talking about pain or discomfort between her legs.

Potential signs that a pupil may be at risk of FGM include:

• The girl’s family having a history of practicing FGM (this is the biggest risk factor to consider)
• FGM being known to be practiced in the girl’s community or country of origin
• A parent or family member expressing concern that FGM may be carried out
• A family not engaging with professionals (health, education or other) or already being known to social care in relation to other safeguarding issues
• A girl:
• Having a mother, older sibling or cousin who has undergone FGM
• Having limited level of integration within UK society
• Confiding to a professional that she is to have a “special procedure” or to attend a special occasion to “become a woman”
• Talking about a long holiday to her country of origin or another country where the practice is prevalent, or parents stating that they or a relative will take the girl out of the country for a prolonged period
• Requesting help from a teacher or another adult because she is aware or suspects that she is at immediate risk of FGM
• Talking about FGM in conversation – for example, a girl may tell other children about it (although it is important to take into account the context of the discussion)
• Being unexpectedly absent from school
• Having sections missing from her ‘red book’ (child health record) and/or attending a travel clinic or equivalent for vaccinations/anti-malarial medication

The above indicators and risk factors are not intended to be exhaustive.

Forced marriage

Forcing a person into marriage is a crime. 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. Since February 2023 it has also been a crime to carry out any conduct whose purpose is to cause a child to marry before their eighteenth birthday, even if violence, threats or another form of coercion are not used. Forced marriage legislation applies to non-binding, unofficial ‘marriages’ as well as legal marriages. 

Threats can be physical or emotional and psychological. Staff will receive training around forced marriage and the presenting symptoms. We are aware of the ‘one chance’ rule, i.e. we may only have one chance to speak to the potential victim and only one chance to save them. 

If a member of staff suspects that a pupil is being forced into marriage, they will speak to the pupil about their concerns in a secure and private place. They will then report this to the DSL.

The DSL will:

• Speak to the pupil about the concerns in a secure and private place.
• Activate the local safeguarding procedures and refer the case to the local authority’s designated officer.
• Seek advice from the Forced Marriage Unit on 020 7008 0151 or fmu@fco.gov.uk if required.
• Refer the pupil to an education welfare officer, pastoral tutor, learning mentor, or school counsellor, as appropriate.

Private Fostering

 A private fostering arrangement is one that is made privately (without the involvement of a local authority) for the care of a child under the age of 16 years (under 18, if disabled) by someone other than a parent or close relative, in their own home, with the intention that it should last for 28 days or more.

A close family relative is defined as a ‘grandparent, brother, sister, uncle or aunt’ and includes half-siblings and step-parents; it does not include great-aunts or uncles, great grandparents or cousins.

Parents and private foster carers both have a legal duty to inform the relevant local authority at least six weeks before the arrangement is due to start; not to do so is a criminal offence.

Whilst most privately fostered children are appropriately supported and looked after, they are a potentially vulnerable group who should be monitored by the local authority, particularly when the child has come from another country. In some cases, privately fostered children are affected by abuse, neglect and exploitation, or be involved in trafficking, child sexual exploitation or modern-day slavery. 

Schools have a mandatory duty to report to the local authority where they are aware or suspect that a child is subject to a private fostering arrangement. Although schools have a duty to inform the local authority, there is no duty for anyone, including the private foster carer or social workers to inform the school. However, it should be clear to the school who has parental responsibility.

School staff should notify the designated safeguarding lead when they become aware of private fostering arrangements. The designated safeguarding lead will speak to the family of the child involved to check that they are aware of their duty to inform the LA. The school itself has a duty to inform the local authority of the private fostering arrangements.

On admission to the school, we will take steps to verify the relationship of the adults to the child who is being registered.

Preventing radicalisation

Radicalisation refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups. Children may be susceptible to radicalisation into terrorism. 

Extremism is vocal or active opposition to fundamental British values, such as democracy, the rule of law, individual liberty, and mutual respect and tolerance of different faiths and beliefs.

This also includes calling for the death of members of the armed forces.

Terrorism is an action that: 

• Endangers or causes serious violence to a person/people;
• Causes serious damage to property; or
• Seriously interferes or disrupts an electronic system

The use or threat of terrorism must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious or ideological cause. Schools have a duty to prevent children from being drawn into terrorism. The DSL will undertake Prevent awareness training and make sure that staff have access to appropriate training to equip them to identify children at risk. 

We will assess the risk of children in our school being drawn into terrorism. This assessment will be based on an understanding of the potential risk in our local area, in collaboration with our local safeguarding partners and local police force. We will ensure that suitable internet filtering is in place, and equip our pupils to stay safe online at school and at home.

There is no single way of identifying an individual who is likely to be susceptible to an extremist ideology. Radicalisation can occur quickly or over a long period. 

Staff will be alert to changes in pupils’ behaviour. The government website Educate Against Hate19 and the charity NSPCC20 say that signs that a pupil is being radicalised can include:

• Refusal to engage with, or becoming abusive to, peers who are different from themselves
• Becoming susceptible to conspiracy theories and feelings of persecution
• Changes in friendship groups and appearance

19            https://educateagainsthate.com/signs-of-radicalisation/ 

20            https://www.nspcc.org.uk/keeping-children-safe/reporting-abuse/dedicated-helplines/protecting-children-from-radicalisation/ 

Children who are at risk of radicalisation may have low self-esteem, or may be victims of bullying or discrimination. It is important to note that these signs can also be part of normal teenage behaviour – staff should have confidence in their instincts and seek advice if something feels wrong. If staff are concerned about a pupil, they will follow our procedures set out in Section 9 of this policy, including discussing their concerns with the DSL. Staff should always take action if they are worried.

Further information on the school’s measures to prevent radicalisation are set out in other school policies and procedures, including [list any relevant policies here – for example you may cover this in your curriculum policy, behaviour policy, online/e-safety policy, and/or others].

Missing pupils

 Our procedures are designed to ensure that a missing child is found and returned to effective supervision as soon as possible. If a child goes missing, we will: 

• Contact the school and family immediately.
• Contact the police

• Children missing education in West Northants.21

• Children missing education in North Northants.2

Non-collection of children

If a child is not collected at the end of the session, we will: contact the school where the pupil is on role.

21            https://www.westnorthants.gov.uk/attendance-and-behaviour-support-schools/tracking-children-and-their-families-who-havegone-missing 

22            https://www.northnorthants.gov.uk/attendance-behaviour-and-home-schooling/tracking-children-and-their-families-who-havegone-missing 

Appendix C: Safer recruitment 

 We adhere to Part 3 of Keeping Children Safe in Education at all times. We consider safeguarding throughout the recruitment process, including when defining and advertising roles.  

We will record all information on the checks carried out in the school’s single central record (SCR). Copies of these checks, where appropriate, will be held in individuals’ personnel files. We follow requirements and best practice in retaining copies of these checks, as set out below.

Pre-appointment safer recruitment

We will include the following in all job advertisements:

• our commitment to safeguarding and promoting the welfare of children;
• clear confirmation that safeguarding checks will be undertaken;
• the safeguarding responsibilities of the post as per the job description and personal specification; and
• whether the post is exempt from the Rehabilitation of Offenders Act 1974 and the amendments to the Exceptions Order 1975, 2013 and 2020.

Where a role involves engaging in regulated activity relevant to children, we will include a statement in the application form or elsewhere in the information provided to applicants that it is an offence to apply for the role if the applicant is barred from engaging in regulated activity relevant to children.

All applicants will be provided with: 

• a copy of our child protection policy

Applicants 

We require applicants to provide:

• personal details, current and former names, current address and their national insurance number;
• details of their present (or last) employment and reason for leaving;
• full employment history, (since leaving school, including education, employment and voluntary work) including reasons for any gaps in employment;
• qualifications, the awarding body and date of award;
• details of referees/references; and
• a statement of the personal qualities and experience that the applicant believes are relevant to their suitability for the post advertised and how they meet the person specification.

We will not accept copies of curriculum vitae in place of an application form.

Shortlisting and selection

Shortlisted candidates will be asked to complete a self-declaration of their criminal record or information that would make them unsuitable to work with children. For more details of what this will contain, please see Part 3 of Keeping Children Safe in Education (2024). 

At least two people will carry out shortlisting and they will explore any potential concerns, including inconsistencies and/or gaps in unemployment. 

We will seek references on all shortlisted candidates, including internal candidates, before interview. We will scrutinise these and resolve any concerns before confirming appointments. The references requested will ask specific questions about the suitability of the applicant to work with children. 

When asked to provide references, we will ensure the information confirms whether we are satisfied with the applicant’s suitability to work with children and provide the facts of any substantiated safeguarding allegations. 

As part of due diligence checks, we will also consider carrying out an online search on shortlisted candidates to help identify any incidents or issues that are publicly available online that we may wish to explore with candidates at interview. 

New staff

When appointing new staff, we will:

• verify a candidate’s identity. This includes demonstrating an awareness for the potential for individuals changing their name. Best practice is checking the name on their birth certificate, where this is available;
• obtain (via the applicant) an enhanced DBS check (including children’s barred list information, for those who will be engaging in regulated activity with children);
• obtain a separate children’s barred list check if an individual will start work in regulated activity with children before the DBS certificate is available;
• verify the candidate’s mental and physical fitness to carry out their work responsibilities;
• verify the person’s right to work in the UK, including EU nationals;
• If the person has lived or worked outside the UK, make any further checks the school or college consider appropriate;
• verify professional qualifications, as appropriate; and
• ensure that an applicant to be employed to carry out teaching work is not subject to a prohibition order.
• Check that candidates taking up a management position are not subject to a prohibition from management (section 128) direction made by the Secretary of
•  
• Carry out further additional checks, as appropriate, on candidates who have lived or worked outside of the UK. These could include, where available:
  • For all staff, including teaching positions: criminal records checks for overseas applicants.
  • For teaching positions: obtaining a letter from the professional regulating authority in the country where the applicant has worked, confirming that they have not imposed any sanctions or restrictions on that person, and/or are aware of any reason why that person may be unsuitable to teach.

Existing staff

If we have concerns about an existing member of staff’s suitability to work with children, we will carry out all the relevant checks as if the individual was a new member of staff. We will also do this if an individual moves from a post that is not regulated activity to one that is. 

We will refer to the DBS anyone who has harmed, or poses a risk of harm, to a child or vulnerable adult where:

• We believe the individual has engaged in relevant conduct; or
• The individual has received a caution or conviction for a relevant offence, or there is reason to believe the individual has committed a listed relevant offence, under the Safeguarding Vulnerable Groups Act 2006 (Prescribed Criteria and Miscellaneous Provisions) Regulations 2009; or
• The ‘harm test’ is satisfied in respect of the individual (i.e. they may harm a child or vulnerable adult or put them at risk of harm); and
• The individual has been removed from working in regulated activity (paid or unpaid) or would have been removed if they had not left

Agency and third-party staff

We will obtain written notification from any agency or third-party organisation that it has carried out the necessary safer recruitment checks that we would otherwise perform. We will also check that the person presenting themselves for work is the same person on whom the checks have been made.

Contractors

We will ensure that any contractor, or any employee of the contractor, who is to work at the school has had the appropriate level of DBS check. This will be:

• An enhanced DBS check with barred list information for contractors engaging in regulated activity.
• An enhanced DBS check, not including barred list information, for all other contractors who are not in regulated activity but whose work provides them with an opportunity for regular contact with children.
• We will obtain the DBS check for self-employed contractors.
• We will not keep copies of such checks for longer than 6 months.
• Contractors who have not had any checks will not be allowed to work unsupervised or engage in regulated activity under any circumstances.
• We will check the identity of all contractors and their staff on arrival at the school.
• They will not be left alone with any pupils.

Volunteers / work experience

 We will:

• Never leave an unchecked volunteer unsupervised or allow them to work in regulated activity.
• Obtain an enhanced DBS check with barred list information for all volunteers who are new to working in regulated activity.
• Carry out a risk assessment when deciding whether to seek an enhanced DBS check without barred list information for any volunteers not engaging in regulated activity. We will retain a record of this risk assessment.

Staff working in alternative provision settings

 As an alternative provision provider, we will provide schools with written confirmation that we have carried out the appropriate safeguarding checks on individuals working there that schools would otherwise perform.

Checking the identity and suitability of visitors

All visitors will be required to verify their identity to the satisfaction of staff and to leave their belongings, including their mobile phone(s), in a safe place during their visit.

If the visitor is unknown to the setting, we will check their credentials and reason for visiting before allowing them to enter the setting. Visitors should be ready to produce identification. Visitors are expected to sign the visitors’ book and wear a visitor’s badge.

Visitors to the school who are visiting for a professional purpose, such as educational psychologists and school improvement officers, will be asked to show photo ID and the organisation sending the professional, such as the LA or educational psychology service, will provide annually written confirmation that an enhanced DBS check with barred list information has been carried out.

All other visitors, including visiting speakers, will be accompanied by a member of staff at all times. We will not invite into LTC any speaker who is known to disseminate extremist views, and will carry out appropriate checks to ensure that any individual or organisation using school facilities is not seeking to disseminate extremist views or radicalise pupils or staff.

Adults who supervise pupils on work experience 

When organising work experience, we will ensure that policies and procedures are in place to protect children from harm.

We will also consider whether it is necessary for barred list checks to be carried out on the individuals who supervise a pupil under 16 on work experience. This will depend on the specific circumstances of the work experience, including the nature of the supervision, the frequency of the activity being supervised, and whether the work is regulated activity. 

Appendix D: How the school responds to allegations that may meet the harms threshold

This section of this policy applies to all cases in which it is alleged that a current member of staff, including a supply teacher, volunteer or contractor, has:

• behaved in a way that has harmed a child, or may have harmed a child, or
• possibly committed a criminal offence against or related to a child, or
• behaved towards a child or children in a way that indicates he or she may pose a risk of harm to children, or
• behaved or may have behaved in a way that indicates they may not be suitable to work with children.

It applies regardless of whether the alleged abuse took place in the school or elsewhere. Allegations against a teacher who is no longer teaching and historical allegations of abuse will be referred to the police. 

If we’re in any doubt as to whether a concern meets the harm threshold, we will consult out local authority designated officer (LADO).

We will deal with any allegation of abuse against a member of staff or volunteer quickly, in a fair and consistent way that provides effective child protection while also supporting the individual who is the subject of the allegation. Our procedures for dealing with allegations will be applied with common sense and judgement.

For more information about how the school responds to low-level concerns (concerns do not meet the harms threshold) please see Section 17 of this policy (link to any other relevant policy here too). 

Suspension of the accused until the case is resolved

 Suspension will not be the default position, and will only be considered in cases where there is reason to suspect that a child or other children is/are at risk of harm, or the case is so serious that it might be grounds for dismissal. In such cases, we will only suspend an individual if we have considered all other options available and there is no reasonable alternative. We will seek views from our personnel adviser, the local authority designated officer/s, the police and/or Children’s Social Care (as appropriate). 

Based on an assessment of risk, we will consider alternatives such as:

• Redeployment within LTC so that the individual does not have direct contact with the child or children concerned.
• Providing an assistant to be present when the individual has contact with children
• Temporarily redeploying the individual to another role in a different location, for example to an alternative school or other work for the [local authority/academy trust].

Definitions for outcomes of allegation investigations

• Substantiated: there is sufficient evidence to prove the allegation
• Malicious: there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive
• False: there is sufficient evidence to disprove the allegation
• Unsubstantiated: there is insufficient evidence to either prove or disprove the allegation (this does not imply guilt or innocence)
• Unfounded: to reflect cases where there is no evidence or proper basis which supports the allegation being made

Procedure for dealing with allegations

In the event of an allegation that meets the criteria above, the proprietor – will take the following steps:

• Immediately discuss the allegation with the designated officer at the local authority. This is to consider the nature, content and context of the allegation and agree a course of action, including whether further enquiries are necessary to enable a decision on how to proceed, and whether it is necessary to involve the police and/or children’s social care services. (The case manager may, on occasion, consider it necessary to involve the police before consulting the designated officer – for example, if the accused individual is deemed to be an immediate risk to children or there is evidence of a possible criminal offence. In such cases, the case manager will notify the designated officer as soon as practicably possible after contacting the police).
• Inform the accused individual of the concerns or allegations and likely course of action as soon as possible after speaking to the designated officer (and the police or children’s social care services, where necessary). Where the police and/or children’s social care services are involved, the case manager will only share such information with the individual as has been agreed with those agencies.
• Where appropriate (in the circumstances described above), carefully consider whether suspension of the individual from contact with children at the school is justified or whether alternative arrangements such as those outlined above can be put in place. Advice will be sought from the designated officer, police and/or children’s social care services, as appropriate.
• If immediate suspension is considered necessary, agree and record the rationale for this with the designated officer. The record will include information about the alternatives to suspension that have been considered, and why they were rejected. Written confirmation of the suspension will be provided to the individual facing the allegation or concern within 1 working day, and the individual will be given a named contact at the school and their contact details.
• If it is decided that no further action is to be taken in regard to the subject of the allegation or concern, record this decision and the justification for it and agree with the designated officer what information should be put in writing to the individual and
• by whom, as well as what action should follow both in respect of the individual and those who made the initial allegation.
• If it is decided that further action is needed, take steps as agreed with the designated officer to initiate the appropriate action in school and/or liaise with the police and/or Children’s Social Care services as appropriate.
• Provide effective support for the individual facing the allegation or concern, including appointing a named representative to keep them informed of the progress of the case and considering what other support is appropriate. [Add further information here about the support available to individuals in your context, such as who they can turn to for advice – trade union representatives, or a colleague, for example – and any school/local authority/trust arrangements for welfare counselling or medical advice]
• Inform the parents or carers of the child/children involved about the allegation as soon as possible if they do not already know (following agreement with children’s social care services and/or the police, if applicable). The case manager will also inform the parents or carers of the requirement to maintain confidentiality about any allegations made against teachers (where this applies) while investigations are ongoing. Any parent or carer who wishes to have the confidentiality restrictions removed in respect of a teacher will be advised to seek legal advice
• Keep the parents or carers of the child/children involved informed of the progress of the case and the outcome, where there is not a criminal prosecution, including the outcome of any disciplinary process (in confidence)
• Make a referral to the DBS where it is thought that the individual facing the allegation or concern has engaged in conduct that harmed or is likely to harm a child, or if the individual otherwise poses a risk of harm to a child
• If LTC is made aware that the Secretary of State has made an interim prohibition order in respect of an individual, we will immediately suspend that individual from teaching, pending the findings of the investigation by the Teaching Regulation Agency.
• Where the police are involved, wherever possible theproprietor will ask the police at the start of the investigation to obtain consent from the individuals involved to share their statements and evidence for use in the school’s disciplinary process, should this be required at a later point.

Additional considerations for supply staff and all contracted staff

 If there are concerns or an allegation is made against someone not directly employed by LTC, such as supply staff provided by an agency, we will take the actions below in addition to our standard procedures. 

We will never cease to use a supply teacher for safeguarding reasons without first finding out the facts and liaising with the Local Authority Designated Officer to reach a suitable outcome. The governing board will discuss with the agency whether it is appropriate to suspend the supply teacher, or redeploy them to another part of the school, while the school carries out the investigation.

We will involve the agency fully, but the school will take the lead in collecting the necessary information and providing it to the local authority designated officer as required.

We will address issues such as information sharing, to ensure any previous concerns or allegations known to the agency are taken into account (we will do this, for example, as part of the allegations management meeting or by liaising directly with the agency where necessary).

When using an agency, we will inform them of our process for managing allegations, and keep them updated about our policies as necessary, and will invite the agency’s HR manager or equivalent to meetings as appropriate.

Timescales

• Any cases where it is clear immediately that the allegation is unsubstantiated or malicious will be resolved within 1 week.
• If the nature of an allegation does not require formal disciplinary action, we will institute appropriate action within 3 working days.
• If a disciplinary hearing is required and can be held without further investigation, we will hold this within 15 working days.

Specific actions

Action following a criminal investigation or prosecution

The case manager will discuss with the designated officer whether any further action, including disciplinary action, is appropriate and, if so, how to proceed, taking into account information provided by the police and/or children’s social care services.

Conclusion of a case where the allegation is substantiated

 If the allegation is substantiated and the individual is dismissed or the school ceases to use their services, or the individual resigns or otherwise ceases to provide their services, the case manager and the school’s personnel adviser will discuss with the designated officer whether to make a referral to the DBS for consideration of whether inclusion on the barred lists is required. If they think that the individual has engaged in conduct that has harmed (or is likely to harm) a child, or if they think the person otherwise poses a risk of harm to a child, they must make a referral to the DBS. 

If the individual concerned is a member of teaching staff, the case manager and personnel adviser will discuss with the designated officer whether to refer the matter to the Teaching Regulation Agency to consider prohibiting the individual from teaching.

Individuals returning to work after suspension

If it is decided on the conclusion of a case that an individual who has been suspended can return to work, the case manager will consider how best to facilitate this.

The case manager will also consider how best to manage the individual’s contact with the child or children who made the allegation, if they are still attending the school.

Unsubstantiated or malicious allegations

If an allegation is shown to be deliberately invented, or malicious, the headteacher, or other appropriate person in the case of an allegation against the headteacher, will consider whether any disciplinary action is appropriate against the pupil(s) who made it, or whether the police should be asked to consider whether action against those who made the allegation might be appropriate, even if they are not a pupil.

Confidentiality     

The school will make every effort to maintain confidentiality and guard against unwanted publicity while an allegation is being investigated or considered.

The case manager will take advice from the local authority’s designated officer, police and children’s social care services, as appropriate, to agree:

• Who needs to know about the allegation and what information can be shared.
• How to manage speculation, leaks and gossip, including how to make parents or carers of a child/children involved aware of their obligations with respect to confidentiality.
• What, if any, information can be reasonably given to the wider community to reduce speculation.
• How to manage press interest if, and when, it arises.

Record-keeping

 The case manager will maintain clear records about any case where the allegation or concern meets the criteria above and store them on the individual’s confidential personnel file for the duration of the case. Such records will include:

• A clear and comprehensive summary of the allegation.
• Details of how the allegation was followed up and resolved.
• Notes of any action taken and decisions reached (and justification for these, as stated above).

If an allegation or concern is not found to have been malicious, the school will retain the records of the case on the individual’s confidential personnel file, and provide a copy to the individual. 

Where records contain information about allegations of sexual abuse, we will preserve these for (insert details here). We will retain all other records at least until the individual has reached normal pension age, or for 10 years from the date of the allegation if that is longer. The records of any allegation that is found to be malicious will be deleted from the individual’s personnel file. 

References

 When providing employer references, we will not refer to any allegation that has been proven to be false, unsubstantiated or malicious, or any history of allegations where all such allegations have been proven to be false, unsubstantiated or malicious.

Learning lessons

 After any cases where the allegations are substantiated, we will review the circumstances of the case with the local authority’s designated officer to determine whether there are any improvements that we can make to the school’s procedures or practice to help prevent similar events in the future. 

This will include consideration of :

• Issues arising from the decision to suspend the member of staff.
• The duration of the suspension.
• Whether or not the suspension was justified.
• The use of suspension when the individual is subsequently reinstated. We will consider how future investigations of a similar nature could be carried out without suspending the individual.

For referrals regarding adults in education and other information on the role of the

Designated            Officer    (formerly                LADO)    please    visit:

http://www.northamptonshirescb.org.uk/schools/referrals-eha/designated-officer/

Multi-Agency Safeguarding Hub:  0300 126 7000 (Option 1)

If it is decided that the allegation does not meet the threshold for safeguarding, it will be handed back to the employer for consideration via the school’s internal procedures.