Document Title  Safeguarding Policy
  Version  2.6
  Status  Final
  Author  SMT
  Reviewed  January 2021
  Reviewed by  Richard Jenkins CEO
  Review details  January 2022

The policy has undergone an Equality Impact Assessment (EQIA) confirming that there are no negative consequences in the case of this policy.

Previous VersionDateActionAmendments
2.5Jan 2021AddReference to Sub-contractor (Devon and Cornwall Police)
RemoveScope   This policy applies to all staff who come into contact with learners, at any time, in particular with learners that could be classed as children, young people or adults at risk.
ReplacePA to CEO with ESAO


Introduction

Education + Training Skills (ETS) is committed to the principle of Safeguarding within its employment practices and in the learning activities it delivers. As a government funded organisation ETS recognises that it needs to set an example for others in the field and for the business organisations that it works with. ETS recognises that it must ensure that it is able to recruit, develop and retain a workforce that is critically aware of and wholeheartedly promotes the principles of Safeguarding. ETS must ensure that its staff are confident enough to report any Safeguarding concerns they may have to the relevant person within the organisation and do this though training and encouragement. It also needs to ensure that the organisations that it works with also work to these standards and learners are re-assured that they are protected and can report any concerns to ETS through their TFs or through the 24 hour help line and the safeguarding@etsgroup.co.uk e-mail. ETS strives to go beyond compliance and to be at the forefront of embracing Safeguarding. ETS intends to promote good practice whilst being sensitive to the specific needs of its employees, learners, subcontractor, partners, stakeholders and their communities.

Scope

This policy applies to all employees who work under a Contract of Employment with ETS, its subcontractor (Devon and Cornwall Police), consultants who work under Contracts of Services to ETS and associated learners, employers and customers who engage with ETS. Failure to meet the required standards and commit to the policy by any associate of ETS will lead to termination of contracts and agreements.

Policy Statement

ETS is strongly committed to practices that protect children, young people and adults at risk from abuse, neglect or significant harm. All staff are trained through mandatory CPD to recognise and accept their responsibility to develop the awareness of the risks and issues involved in safeguarding and under the Prevent Duty.

ETS also recognises that it has a responsibility to protect its staff from unfounded allegations of abuse and the Safeguarding Lead will undertake necessary investigation into allegations if required.

ETS is committed to continuing to work with its local Child Safeguarding, Adult Safeguarding Boards and other health and social care partnerships to ensure the safeguarding of its learners. Having these close relationships re-assures learners that they can be protected and demonstrates ETS’ commitment to their safety concerns.

ETS supports the Government’s Prevent Policy, the aim of which is to create and maintain a safe, healthy and supportive learning and working environment for our learners, staff and visitors. ETS recognises that extremism and exposure to extremist materials and influences can lead to poor outcomes for learners. ETS staff are trained and encouraged to challenge extremist views in order to protect its learners from potential harm. As such Prevent is an agenda item covered by the Quarterly Safeguarding Board Meeting.

The ETS Safeguarding Lead will refer safeguarding concerns to the MASH or in cases of radicalisation to the Channel scheme or police as appropriate.

Purpose

This policy is designed to inform and direct staff of appropriate conduct when working with children, young people and adults at risk and to describe measures in place that protects and minimises the risk of harm to children, young people and adults at risk.

It is also intended that this policy will inform and educate staff, alongside their mandatory training, of the procedures and processes and cement their commitment to safeguarding learners.

It sets out ETS’s approach to safeguarding and promoting the welfare of children and adults at risk. It applies to all aspects of our work and to everyone working for or with ETS, including permanent and temporary employees, consultants, learners, employers and customers.

Definition

For the purposes of this policy and procedure children are defined as in the Children Act of 1989 as a person under the age of 18 years. The Safeguarding Vulnerable Groups Act 2006 definition of ‘vulnerable adult’ has been repealed with the effect from September 2012 under the Care Act 2014 and replaced by the term ‘adult at risk’. An “Adult at Risk” is defined as any person aged 18 years and over who is or may be in need of community care services by reason of mental health issues, learning or physical disability, sensory impairment, age or illness and who is or may be unable to take care of him/herself or unable to protect him/herself against significant harm or serious exploitation.

For the purpose of this policy and procedure, radicalisation refers to any individual who is being radicalised to commit a crime, which may or may not include terrorist activities.

Accountability and Responsibility

ETS has 5 committed and trained Safeguarding Officers one of which is the Lead Prevent Officer (General Manager) and one who is Home Office accredited Prevent Train the Trainer Trained and the other is a Chief Inspector from the Devon and Cornwall Police safeguarding and PREVENT Board. The Safeguarding Lead is accountable to the Chief Executive and Trustee Board. The Trustee Board also have a qualified Safeguarding Officer who attends all Safeguarding meetings. Incidents or concerns are reported to a member of the Safeguarding Team (this ensures that confidentiality is maintained).

The Safeguarding team are responsible for monitoring and managing incidents or concerns and liaising with safeguarding agencies to protect its learners and staff. In respect of suspected radicalisation the team will liaise with authorities via the Channel scheme or police directly if needed. The ETS Trustee Board is committed to review respond to an annual report on safeguarding within the company and they ensure all ETS staff are committed to promoting the policy appropriately and are preventing opportunities of abuse to its apprentices. On behalf of the Trustees the Safeguarding team promote this policy through staff mandatory training, via the website, social media the ETS Wellbeing Newsletter shared with Trustees, staff, employers and learners, apprentice workshops and 1 to 1 sessions.

As part of ETS’ commitment to protecting its learners it operates a 24 hour confidential helpline and has a specific safeguarding e-mail for learners wanting to report concerns.

Employer’s responsibility

ETS’s responsibility as an employer is not just to comply with the letter and spirit of the law on Safeguarding and Prevent but is also to demonstrate that it is a fully committed to Safeguarding. This is promoted through a zero tolerance which is designed to enforce full commitment to this policy, provides emergency helpline and emergency e-mail facilities, challenges and reports behaviours of concern has a code of conduct and operates lockdown drills.

ETS has a statutory duty to implement and monitor Safeguarding schemes in all respects. These are reviewed at the monthly management meetings under the Safeguarding and PREVENT agenda items.

To embrace good practice in all of ETS policies and procedures and to act to eliminate Safeguarding and Radicalisation issues wherever possible. All staff encourage anyone to come forward with safety concerns and the staff will respect and follow the ETS processes procedures that they have been taught accordingly.

At the quarterly Safeguarding Meetings staff review how ETS values the Safety of its staff, learners, employers and customers enabling all to reach their full potential. This is directed from the Board of Trustees and policed by the SMT.

To monitor the application of the Safeguarding policy and work towards eliminating any Safeguarding or Prevent issues. Quarterly Safeguarding Meetings take place where all activity is reviewed, scrutinised and if necessary improved to make its systems more robust.

ETS provides its staff as a minimum with annual Safeguarding and Prevent training during the January CPD week and at induction.  Learners receive a Safeguarding and Prevent workshop and discuss these topics at their regular one to one reviews with their TF.

ETS must provide its staff, apprentices and learners with information advice and guidance on how they can access support from ETS to protect and keep them safe. The ETS Safeguarding team has set up and publicise the 24 hour safeguarding contact details on the website, on learner portfolios and within learner handbooks. A Safeguarding newsletter is also published monthly. All communications include how staff, apprentices and learners can get the support and guidance they need from ETS if they have Safeguarding concerns.

Employees’ responsibility

  • ETS staff all attend the mandatory Safeguarding and Prevent annual and in year training offered so as to understand how to implement the spirit of the policy into their daily work activities. Staff must attend.
  • ETS’s staff must recognise and commit to their responsibilities to adhere to and comply with the letter and spirit of this policy. Failure to do so may result in serious disciplinary action or dismissal.
  • ETS staff are guided by SMT through meetings, updates and training as to how they can ensure that there is no negative behaviour towards Safeguarding or Prevent within their areas of responsibility. Staff must adhere to the good practice.
  • ETS staff are trained on how to inform managers/co-ordinators if they suspect any Safeguarding or Prevent issues are taking place or that the policy is not being adhered to. Staff must comply appropriately to issues or concerns.
  • ETS staff co-operate with management in the application of any measures introduced to ensure Safeguarding and Prevent is met. Failure to do so may result in disciplinary action or dismissal. 
  • ETS staff must co-operate with senior management in the elimination of any discriminatory practices which may be identified. Failure to do so may result in disciplinary action or dismissal.
  • ETS staff inform learners and other stakeholders of our expectations of them on the matter of Safeguarding and Prevent and how they can commit to and implement in their own organisation and personal lives

Manager’s/Co-ordinator’s responsibility

Managers are responsible for the practical application of the policy and in particular to ensure that:

  • All staff, learners businesses, organisations and contractors, under their control, are aware of the policy and their responsibilities to adhere to and comply with the letter and spirit of this policy. This is done through sharing the policy or signposting to the policy on the website as well as discussing during visits and meetings.
  • There is no negative Safeguarding or Prevent issues in any of their decisions or behaviour. Managers and Coordinators undertake the necessary training during their CPD week to prevent this type of activity. Failure to commit to and meet the standards required may result in disciplinary action and dismissal.
  • Commitment to proper levels of safer recruitment are undertaken and maintained – Managers and Coordinators are mandated by ETS to undertake the safer recruitment training via the ETF CPD portal. 
  • All coordinators and managers have a 24/7 open line of communication for Safeguarding and Prevent issues to be raised and this is communicated to the learners at the start of their program, in thier learner handbook, on the website and at their one to one reviews.
  • Measures that are introduced to ensure Safeguarding and Prevent are fully embedded in all that we do.
  • All staff are mandated to attend all ETS training offered concerning Safeguarding and Prevent. Failure to do so may result in disciplinary action.
  • Managers and co-ords Promote and comply with our Safeguarding and Prevent Policies by implicitly including it in any contract or agreement when working with third parties.

Senior Management responsibility

Senior Management will be responsible for:

  • Advising on and developing a Safeguarding and Prevent policy which mirrors good practice. SMT are all trained and mandated to sit on the Safeguarding Committee. They keep up to date with Safeguarding and Prevent issues via attending specific network groups and via weekly bulletins from the Police, Local Authorities, DfE and Cabinet Office. This is then shared weekly at team meetings with staff and via e-mail and our publically available newsletter and website.
  • Providing a detailed review of progress on the policy
  • Providing and promoting the mandated Safeguarding and Prevent annual training across ETS to ensure that all staff and management are aware of their responsibilities and committed to meeting them.
  • Collating and reporting on Safeguarding and Prevent matters and data.  This is done at the Monthly management meetings and Quarterly Safeguarding Committee Meetings where the actions to keep learners and staff safe are further reviewed.  
  • Senior managers will be responsible for holding quarterly Safeguarding and Prevent meetings and reporting findings to the CEO and Board of Trustees – These meetings are held on the morning of the Trustees Quarterly Meeting so that the trustee in attendance can share with the board to consider.
  • Review and update this policy on an annual basis as a minimum.
  • Overseeing the promotion of the policy through all means necessary eg. Interviews, Appraisals, 1 to 1’s, via the website, posters, newsletters and training with staff to include how to implement the policy across their daily activities.

Training

The company has a duty to promote safeguarding issues and measures to staff and ensure they:

  • Analyse their own practice against established good practice, and assess risk to ensure their practice is likely to protect them from false allegations
  • Recognise their responsibilities and report any concerns about suspected poor practice or possible abuse or radicalisation by following the Code of Behaviour (appendix 1)
  • Follow the guidelines for staff – Quick Guide (appendix 2)
  • Undertake induction and relevant training on safeguarding and Prevent Duty to raise awareness of current issues and legislation and commit to the policy intentions and keeping children and others safe in education.

As a minimum annual mandatory training is provided to all ETS staff. Additional monthly updates and hot topics are distributed for personal and training purposes. External speakers are invited in to Core days to brief all ETS staff on safeguarding and Prevent latest updates and how staff should implement what they have learnt into their daily practices.

Staff Recruitment

ETS is responsible for its safe recruitment and employment practices, having in place a Safer Recruitment Policy to ensure that recruitment procedures are fair, and ensure that the highest priority is given to issues relating to the protection of all learners on ETS programmes. The CEO and ESAO have both undertaken project Argus training for safer recruitment. The CEO, Mangers and Coordinator are expected as a minimum to be ETF safer recruitment trained. New Coordinators and Managers must completed ETF safer recruitment training within 3 months of joining ETS.

Disclosure and Barring Service Checking

All new and existing staff whether or not have frequent or intensive working relations with children, young people and adults at risk in training, supervision, advice, and transport are to be checked through the Home Office for criminal record information. New staff will not work unsupervised in regulated activity until the Enhanced DBS check has been processed and received.  

The Disclosure and Barring Service

The DBS role is to help prevent unsuitable people from working with children and adults at risk. ETS is committed to following procedures for referrals to DBS wherever concerns are raised that a member of staff has caused harm or poses a future risk of harm to children, young people or adults at risk or is found to be engaging in any form of radicalisation of learners or other members of staff.

  • DBS Application Procedure – Applicants/new employees/associates are instructed to bring with them the relevant original documents required to confirm identity in accordance with the DBS rules currently in force, as defined in the Accepted Identification Documents list and are informed that these documents may be photocopied.

An authorised DBS counter-signatory completes the standard ID document checklist contained on the DBS application form and the applicant/new employee/associate completes the additional details as required.

A record is kept of the serial number of the disclosure application form, the date on which it was issued and to whom.

ETS will pay for the check to be conducted.

The EDBS check for new employees will be funded by the ETS. The new employee is expected to register for the EDBS update service within the timescale dictated by the DBS.

On receipt of their certificate from the DBS, applicants/employee/associates must bring it to ESAO where a copy will be made. A note of the date of issue of forms placed on the record. A decision is made on the basis of the information contained on the certificate as follows:

  • No Convictions or Further Information Disclosed: If no convictions or further information are disclosed, the disclosure form is disposed of after six months via shredding.
  • Convictions and/or Further Information are disclosed: If the disclosure contains information about convictions or is accompanied by further information, the DBS Risk Assessment Procedure will be triggered.
  • Appeals against a Decision to Rescind the Offer of a Place on the Course or offer of employment

An applicant has the right to appeal against any decision by ETS resulting in the offer of employment or contract of services being rescinded. The appeal is dealt with by the SMT. The investigation may include obtaining external professional opinion on individual cases, for example from a professional or regulatory body or other appropriate agency.

  • Storage and Access – Disclosure information is never kept on an applicant’s/employees/associates file and is always kept separately and securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to see it as part of their duties.
  • Handling – In accordance with Section 124 of the police Act 1997, Disclosure information is only passed to those who are authorised to receive it in the course of their duties. This includes the Authorised Counter-signatory, SMT and CEO. We maintain a record of all those to whom DBS certificate information has been revealed and we recognise that it is a criminal offence to pass this information on to anyone who is not entitled to receive it.
  • Usage – Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s/student’s full consent has been given.
  • Retention – Once an application decision has been made, we do not keep DBS certificate information for any longer than is absolutely necessary. This is generally for a period of up to six months, to allow for the consideration and resolution of any disputes or complaints. If, in very exceptional circumstances, it is considered necessary to keep DBS certificate information for longer than six months, we will consult the DBS and inform the applicant before doing so.
  • Disposal – Once the retention period has elapsed, we will ensure that any DBS certificate is immediately and suitably destroyed by secure means, i.e. by shredding.

While awaiting destruction, certificates will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack).

We will not keep any photocopy or other image of the certificate or any copy or representation of the contents of a certificate. However, notwithstanding the above, we keep a record of the date of issue of a certificate, the names of the subject, the type of certificate requested, the role for which the certificate was requested, the unique reference number of the certificate and the details of the application decision taken.

Staff Call Monitoring

For the protection of learners and staff; staff calls will be monitored to identify any trend of continuous out of hour calls to learners’ telephone numbers. Any trends will trigger a discussion with the member of staff concerned.

Staff e-mail Usage Monitoring

For the protection of learners and staff, staff out of hours emails will monitored to identify any trend of continuous out of hour contact with learners. Any trends will trigger a discussion with the member of staff concerned.

IT Usage Monitoring

For the protection of learners and staff, staff IT usage will monitored by classroom staff (learners are not to be unsupervised) and AME (external IT support team) to identify any undesirable trends eg visiting self-harm and terrorist activity sites. Any trends are to be immediately reported directly to the Safeguarding lead who will conduct and investigation and escalate if deemed necessary.

Statutory Framework – Context

ETS aims to meet legislative requirements and good practice in safeguarding. The

Statutory framework under which we operate includes the Children Act 1989. This provides the legal framework for the protection of children and young people in the UK.  The Protection of Children Act 1999 requires employers to carry out Disclosure and Barring Checks before employees are allowed to come into contact with children. The Care Act 2104 sets out the type of activity in relation to children and adults at risk for which employers and individuals will be subject.

ETS is committed to abiding by legislation laid down within the Children Acts 1989 and 2004 and therefore to supporting the aims and outcomes set out within Keeping Children Safe in Education guidance (2015) which includes:

• child missing from education
• child missing from home or care
• child sexual exploitation (CSE) 
• bullying including cyberbullying
• domestic violence
• drugs
• fabricated or induced illness
• faith abuse
• female genital mutilation (FGM)
• forced marriage
• gangs and youth violence
• gender-based violence/violence against women and girls (VAWG)
• mental health
• private fostering
• preventing radicalisation
• sexting
• teenage relationship abuse
• trafficking

In respect of safeguarding individuals from radicalisation ETS works to the Prevent element of CONTEST the Government’s Counter Terrorism Strategy (July 2011), and where deemed appropriate seeks external support and guidance for learners through referrals to the Channel Programme. This programme aims to work with the individual to address their specific vulnerabilities, preventing them becoming further radicalised and possibly entering the criminal justice system because of their actions. It is recognised that radicalisation can occur to an individual from any section of society and is not particular to any racial, ethnic or social group. It is further recognised that in many instances the process of radicalisation is essentially one of grooming by others.

Review

ETS’ Safeguarding Policy will be reviewed annually and its provisions monitored by the Trustee Board and Senior Management Team. The review process includes analysis of monitoring data, consultation with and feedback from learners, clients, staff and other stakeholders to determine the impact of the policy and any action required.

Relevant Documents

This policy and procedure should be read in conjunction with the Code of Behaviour for Staff (appendix 1); Quick Guide for Staff (appendix 2); the Safeguarding Poster for learners. Staff training for Safeguarding and Prevent Duty which will be made available and is a mandatory element of CPD for all staff. A very useful reference guide for staff is Safer Practice, Safer Learning from the National Institute of Adult and Continuing Education (NIACE) www.niace.org.uk.

Associated Policies

  • Safer Recruitment Policy
  • Child Protection Policy
  • Equality and Diversity Policy
  • Health and Safety Policy
  • Anti-Harassment and Bullying Policy
  • Whistle Blowing Policy
  • ICT Acceptable Use Policy
  • Online Safety Guide
  • Data Protection Policy
  • Lone Working Policy
  • Learner Handbook
  • Employer Handbook
  • Employer Guide to Safeguarding Learners

Appendix 1

Safeguarding Code of Behaviour (protecting and preventing abuse towards apprentices, learners and staff)                                    

  • Staff should not spend excessive amounts of time alone with individual young people or adults at risk, away from others. Meetings with individual young people and adults at risk should be avoided or take place within sight of others. If privacy is needed, the door should remain open and other staff should be aware of the meeting.
  • Staff are advised not tomake unnecessary physical contact with young people and adults at risk. However, there may be occasions when physical contact is unavoidable, e.g. providing comfort at times of distress. In all such cases contact should only take place with the consent of the person.
  • It is not good practiceto take young people and/or adults at risk alone in a car, however short the journey. Where this is unavoidable, it should be with the full knowledge and consent of the parent(s) or carer(s).
  • Staff should not meet young people and/or adults at risk outside of the work environment. (Staff should ensure that they declare and existing relationships with learners).
  • Staff should not start an investigation or question anyone after an allegation or concern has been raised. This is the job of the authorities. You should record the facts and report these to a member of the Safeguarding Team.
  • Staff should never (even in fun) –
  • Initiate or engage in sexually provocative conversations or activity;
  • Allow the use of inappropriate language to go unchallenged;
  • Do things of a personal nature for young people or adults at risk that they can do themselves;
  • Allow any allegations made by a young person or adult at risk to go unchallenged without being reported and addressed;
  • Trivialise or exaggerate young person or adult at risk abuse issues;
  • Make promises to keep any disclosure confidential from relevant authorities.
  • Staff should not show favouritism to any one young person or adult at risk, nor should they issue or threaten any form of physical punishment.
  • Staff must respect young people and adults at risk’ rights to privacy and encourage young people and adults at risk to feel comfortable enough to report attitudes or behaviour they do not like.
  • Staff will be expectedto act with discretion with regards to their personal relationships. They should ensure their personal relationships do not affect their leadership role within the organisation. All pre-existing relationships between staff and young people and/or adults at risk must be declared.
  • All staff should be aware of our procedures for reporting concerns or incidents, and should familiarise themselves with the contact details of the Safeguarding
  • Officers and Safeguarding/Prevent Lead (SPOC).
  • If a member of staff finds themselves to be the subject of inappropriate affection or attention from a young person or adult at risk, they must make their line manager aware of this.
  • If a member of staff has any concerns relating to the welfare of a young person or adult at risk in their care, be it concerns about actions/behaviours of another staff member or concerns based on any conversation with the young person or adult at risk; particularly where the young person or adult at risk makes an allegation, they must report this to a Safeguarding Officer/Manager.

Procedure for responding to an allegation of abuse or radicalisation

To protect and prevent abuse towards apprentices and learners this procedure must be followed whenever an allegation is made that a child or adult at risk has been abused or when there is a suspicion that a child or adult at risk has or is at risk of being abused or radicalised.

Do not make promises regarding confidentiality. Explain to the person at the outset that you will need to report the disclosure and share the information with an ETS Safeguarding Officer. The Safeguarding Officer will, where possible, respect the wishes of the individual; however, information will be shared with external agencies where it is judged that a person is at risk of suffering significant harm or becoming in danger of being radicalised.

The member of staff or learner who has concerns about possible abuse or neglect or radicalisation should raise their concerns with a Safeguarding Officer as soon as possible for advice and support. A record of the incident or concern should be made on the Incident and Concerns Reporting Form (Appendix 3). If the complainant is the young person or adult at risk themselves, investigative questions should be kept to the minimum necessary to understand what is being alleged and leading questions should be avoided. The use of leading questions can cause problems for the subsequent investigation and court proceedings.

The Safeguarding Lead must report the matter to the local Social Services Department or Channel Scheme, as a matter of urgency for them to investigate the concerns further, whether or not they feel this action is justified in the particular circumstances of the case. The matter will be reported over the telephone to the duty social worker (or such other person as required by the local Area Child Protection Committee (ACPC) procedures). In the unlikely event that social services cannot be reached they will contact the relevant police child protection team for the area and where relevant (ie if radicalisation is suspected) the Channel Scheme via  email prevent Devon and Cornwall or use the Anti Terrorist Hotline 0800 789321.

A written record of the report will be retained by the Safeguarding Lead. The written record will include the date and time of the report and must include the name

and position of the person to whom the matter is reported. The Safeguarding Officer/Manager should discuss with the Social Services Department/Channel Panel what action will be taken to inform the parents/guardian of the young person or adult at risk and a note of that conversation should be made.

Allegations against a Member of Staff

In the event that there is any suspicion, allegation or apparent abuse or radicalisation of a young person or adult at risk by a member of staff the matter should be reported to a Safeguarding Officer, the Safeguarding Lead, or Chief Executive as soon as possible. On being notified of any such matter the responsible person shall:

  • Take such steps as they consider necessary to ensure the Online Safety of the young person or adult at risk in question;
  • Liaise with the person who reported the original concern and ensure that a report of the matter is completed;
  • Report the matter to the local social service department or Channel scheme in accordance with the procedure set out above if they have not already done so;
  • Notify ETS’s CEO.

If the Safeguarding Officer or Safeguarding Lead is the subject of the allegation or complaint the matter must be reported directly to the ETS’s CEO. If a complaint has been made against the ETS’s CEO the matter must be reported to the Chair and Board of Trustees.

All staff should be aware of the fact that allegations may be made against them, and that the allegation may have grounds for substantiation or not. Any such notification may result in immediate suspension of the member of staff, and may result in the application of the company’s disciplinary procedure where it is considered appropriate.

ETS Safeguarding Team

Laura Osborne – Safeguarding Officer laura@etsgroup.co.uk
Adele Brayley-Duncan – Safeguarding Officer adele@etsgroup.co.uk
Simon Mills – Safeguarding Lead simon@etsgroup.co.uk  
Chief Executive Officer – Richard Jenkins richard@etsgroup.co.uk
Trustee – Sarah Yeo sarah.yeo@btinternet.com
Safeguarding contact number (24hrs) 07756 147275 or email keepsafe@etsgroup.co.uk
Sarah Pope – Devon and Cornwall Police

Appendix 2

Safeguarding Children and Adults at risk – a quick guide for staff

It is important that children, young people and adults at risk are protected from abuse, neglect or significant harm including radicalisation. It is the responsibility of all Education + Training Skills (ETS) employees to safeguard and promote the welfare of children, young people and adults at risk participating on ETS training programmes and/or activities. Employees should report any allegations or concerns regarding the welfare of these groups using the following guidelines.

The Safeguarding poster which accompanies these guidelines conveys in words and pictures what constitutes abuse.

What is abuse and when is a person at risk:

For children, young people this includes:

  • physical abuse which may involve hitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating or otherwise causing physical harm;
  • emotional abuse which is the persistent emotional maltreatment so as to cause severe and persistent adverse effects on their emotional development;
  • sexual abuse which involves forcing or enticing a child or young person to take part in sexual activities, including prostitution, whether or not the child/young person is aware of what is happening;
  • neglect consisting of the persistent failure to meet a child’s or young person’s basic physical and/or psychological needs, which is likely to result in the serious impairment of their health or development.

For adults at risk abuse can mean:

  • physical abuse including hitting, slapping, punching, kicking, misuse of medication, restraint or inappropriate sanctions;
  • sexual abuse including rape, sexual assault, or sexual acts to which the victim has not consented, could not consent to or was pressurised into consenting to;
  • psychological abuse including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, verbal abuse, isolation, or withdrawal of services or supportive networks;
  • discriminatory abuse including racist, sexist, religious abuse or abuse that is based on a person’s disability;
  • financial abuse including fraud, exploitation, pressure in connection with wills, property, inheritance or financial transactions or the misuse or misappropriation of property, possessions or benefits;
  • neglect including ignoring physical or medical care needs, failure to provide access to appropriate services or the withholding of necessities of life.

What to do if you notice abuse:

You may become aware of potential abuse in two main ways:

  • You may observe signs in a learner that lead you to suspect that they have been physically, emotionally or sexually abused or suffer severe neglect, or are becoming radicalised; or in addition in the case of an adult at risk, they may be experiencing financial, discriminatory or institutional abuse.
  • The examples given below may indicate that an individual is being abused. In addition to these a person may be abused by virtue of their race, gender, age, disability or sexual orientation which would indicate discriminatory abuse. Similarly, any of the examples listed may be an indication of institutional abuse if the individual is in receipt of organised care.
  • The learners themselves may disclose to you that they have been abused.
Possible signs of physical abuse include:
Unexplained injuries or burns, particularly if they are recurrentRefusal to discuss injuriesImprobable explanations for injuriesUntreated injuries or lingering illness not attended to Admission of punishment which appears excessive Shrinking from physical contactFear of returning home or of parents being contactedFear of Undressing.Fear of medical help Aggression/bullying Over compliant behaviour or a ‘watchful’ attitude Running away Significant change in behaviour without explanationDeterioration of work Unexplained pattern of absence which may service to hide bruises or other physical injuries  
Possible signs of Female Genital Mutilation include:
A family arranging a long break abroad during the summer holidaysUnexpected, repeated or prolonged absence from work/programmeApprenticeship work sufferingHave difficulty walking, standing or sittingSpend longer in the bathroom or toiletrelative or cutter visiting from abroada special occasion or ceremony to ‘become a woman’ or get ready for marriageAppear withdrawn, anxious or depressedHave unusual behaviour after an absence from school or collegeBe particularly reluctant to undergo normal medical examinationsAsk for help, but may not be explicit about the problem due to embarrassment or feara long holiday abroad or going ‘home’ to visit familya female relative being cut – a sister, cousin, or an older female relative such as a mother or aunt.  
Possible signs of emotional abuse include:
Continual self-deprecationFear of new situationsInappropriate emotional responses to painful situationsSelf-harm or mutilationCompulsive stealing/scroungingDrug/solvent abuseDepression, withdrawal  ‘Neurotic’ behaviour – obsessive rocking, thumb-sucking, and so on Air of detachment – ‘don’t care’ attitude Social isolation – does not join in and has few friendsDesperate attention-seeking behaviourEating problems, including overeating and lack of appetite  
Possible signs of sexual abuse include:
Bruises, scratches, burns or bite marks on the bodyScratches, abrasions or persistent infections in the anal or genital regionsSexual awareness inappropriate to the person’s age – shown, for example, in drawings, vocabulary, games and so onFrequent public masturbationAttempts to teach others about sexual activity Refusing to stay with certain people or to go to certain placesAggressiveness, anger, anxiety, tearfulnessWithdrawal from friends  Promiscuity, prostitution, provocative sexual behaviourSelf-injury, self-destructive behaviour, suicide attemptsPregnancy – particularly in the case of young adolescents who are evasive concerning the identity of the fatherRecoiling from physical contactEating disordersTiredness, lethargy, listlessnessOver-compliant behaviourGenital discharge/irritationSleep disturbanceUnexplained gifts of moneyDepressionChanges in behaviour  
Possible signs of neglect include:
Constant hungerPoor personal hygieneInappropriate clothingFrequent lateness or non-attendance at College  Low self-esteemPoor social relationshipsCompulsive stealing or scroungingConstant tiredness Untreated medical problems
Possible signs of financial abuse include:
Loss of jewellery and personal propertyA bill not being paid when money is entrusted to a third partyUnexplained withdrawal of cash  Lack of money to purchase basic itemsMisuse of benefitsInadequate clothingTheft of propertyOver protection of money or propertyLoss of money from a wallet or purse
Possible signs of radicalisation include:
The individual’s views become increasingly extreme regarding another section of society or government policyThe individual becomes increasingly intolerant of more moderate viewsThe individual expresses a desire/intent to take part in or support extremist activity  They are observed downloading, viewing or sharing extremist propaganda from the webThey become withdrawn and focused on one ideologyThe individual may change their appearance, their health may suffer (including mental health) and they may become isolated from family, friends, peers or social groups.

If a learner discloses to you that they (or indeed another learner/person) has been or are being abused/radicalised:

Do:

  • Do listen very carefully to what they tell you;
  • Do take what is said seriously and accept what you are told;
  • Do stay calm and reassure the learner that they have done the right thing in talking to you;
  • Do write down as soon as you can exactly what you have been told;
  • Do tell them that you must pass this information on but that only those that need to know will be told. Tell them to whom you will report the matter.

Do not:

  • Do not panic;
  • Do not promise to keep things secret. You have a duty to refer a child/young person or adult at risk who is at risk;
  • Do not lie or say that everything will be fine now that they have told someone;
  • Do not criticise the abuser, especially if it is a parent/carer;
  • Do not ask lots of detailed or leading questions such as: ‘What did he do next?’ instead ask open question such as: ‘Do you have anything else to tell me?’, ‘Yes’ or ‘And…?’ do not press for answers the learner is unwilling to give.

Take the disclosure seriously and never dismiss the allegation of abuse or radicalisation. Provide a quiet and supportive environment to help the person feel at ease. Remember that an allegation of abuse, neglect or radicalisation may lead to a criminal investigation and asking leading questions or attempting to investigate the allegations yourself may cause problems for any subsequent court proceedings.

Do not make promises regarding confidentiality. Explain to the person at the outsetthat you will need to report the disclosure and share the information withan ETS Safeguarding Officer. The Safeguarding Officer will, where possible, respect the wishes of the individual; however, information will be shared with external agencies where it is judged that a person is at risk of sufferingsignificant harm.

It is important the person to whom disclosure is made does not investigateor question the person concerned except to clarify what they have heard. This is particularly important in cases of sexual abuse.

It is very important to record, as accurately as possible, what was said to you when you received the disclosure of abuse/radicalisation. Clearly written records should be handled confidentially and if emailed they should be password protected.

Report the disclosure to a Safeguarding Officer immediately or by telephoning 07756 147275 (24hrs). Complete the Incident and Concern Reporting Form and forward to a Safeguarding Officer within 24 hours. The Safeguarding Officer or Safeguarding Lead will identify the appropriate next steps and keep in contact with you to ensure that our Duty of Care is fulfilled.

What to do if:
You are concerned a young person or adult may be at risk:

  • Contact a member of the Safeguarding Team for advice and guidance;
  • Make and keep a record of your concerns and forward to the Safeguarding Officer within 24 hours;
  • Discuss your concerns with the young person if appropriate.

If a learner (child/young person or adult at risk discloses to you that they or another learner/person has been abused/radicalised, or if you suspect from what you observe that they are being abused/radicalised, you MUST REPORT THIS.

What to do if:
A young person or adult at risk accuses you or another member of staff of abuse:

  • Contact the Safeguarding Lead for advice and guidance;
  • Make and keep a record of the accusation and actions taken and forward to the Safeguarding Lead within 24 hours.

For further information in respect of the ETS Safeguarding Policy contact Simon Mills simon@etsgroup.co.uk or Laura Osborne laura@etsgroup.co.uk or telephone 01392 445444.

Safeguarding Incident and Concerns reporting form and Report procedure

Appendix 4

Useful Contact Numbers

Plymouth Social Services Advice and Assessment Team, Ballard House
Tel: 01752 308600
Plymouth Police Child Protection Unit
Tel: 01752 284522
NSPCC Help line Tel: 0808 800 5000 – 24 hours, Freephone
Child Line (NI) Tel: 0800 1111 – 24 hours, Freephone

Social Services Contacts (excluding Plymouth & Cornwall):
To report child protection incidents, please contact your local Social Services Office (see Child Protection – Local Offices)

Emergency Duty Team – Tel: 084506000388 (low- call rate)
For Child Protection Register enquiries please ring:
South and West Devon
Totnes District Office – Tel: 01392 386080
Exeter and East Devon
Ivybank, Exeter –Tel: 01392 384972
North and Mid Devon
Civic Centre, Barnstaple – Tel: 01271 388667

Child Protection Local Offices (excluding Plymouth & Cornwall):
Civic Centre, Barnstaple, EX31 1EE
e-mail: North Devon: barnstapleccchildrensteam-mailbox@devon.gov.uk
Tel: 01271 388660 – Fax: 01271 388721
George Street, Exeter, EX1 1DA
e-mail: ssexeter@devon.gov.uk
Tel: 01392 384444 – Fax: 01392 384439
Teign House, Kingsteignton Road, Newton Abbot, TQ12 2QG
e-mail: ssteign@devon.gov.uk
Tel: 01392 384900 – Fax: 01392 384903
St. Saviours, Exeter Road, Ottery St. Mary, EX11 1RE
e-mail: ssedev3@devon.gov.uk
Tel: 01392 384444 – Fax: 01392 385953
Abbey Rise, Whitchurch Road, Tavistock, PL19 9AS
e-mail: sswdevon@devon.gov.uk
Tel: 01822 614121 – Fax: 01392 386748
Tiverton Business Park, Tiverton, EX16 6TGL
e-mail: ssmdevon@devon.gov.uk
Tel: 084480 805 838 – Fax: 01392 384157
Parkers Barn, Parkers Way, Totnes, TQ9 5UF
e-mail: ssshams@devon.gov.uk
Tel: 01803 869300 – Fax: 01392 386003

Plymouth:

Contact                  
Advice and Assessment Service

Mail:           
Children’s Services
Plymouth City Council
Plymouth  PL1 2AA
e-mail: adviceandassessment@plymouth.gov.uk
Tel: 01752 308600 – Fax: 01752 308601

Office Location

Advice and Assessment Service
Ballard House
West Hoe Road
Plymouth
PL2 3BH
Ballard House

Office Hours:
Monday to Thursday inclusive 9am to 5pm
Friday 9am to 4pm

Out of hours:

Tel: 01752 346984

Torbay:

Contact
Advice and Assessment Service
Children’s Services

Mail:
Plymouth City Council
Plymouth PL1 2AA
e-mail: adviceandassessment@plymouth.gov.uk
Tel: 01752 308600 – Fax: 01752 308601

Cornwall:

Multi-agency Referral Unit: 0300 123 1116
Out of Hours Service: 01208 251300

Isles of Scilly:

Children’s Social Care:  01720 424354
Out of Hours Service:  01720 422699
or
The police on 101

Prevent Duty referrals

For referrals in Devon and Cornwall contact: prevent@devonandcornwall.pnn.police.uk

For referrals in Avon, Somerset and Wiltshire contact: channelsw@avonandsomerset.pnn.police.uk

Anti-terrorist hotline on 0800 789 321