Child Protection and Safeguarding Policy and Procedures
1. Overview
1.1 Important contacts and local authority safeguarding protocols
1.2 Related policies
1.3 Statutory and non-statutory guidance
1.4 Review of the Safeguarding Policy
2. Identifying vulnerable students and signs of abuse
3. Procedures for handling concerns about a student
4. Procedures for handling low-level concerns and/or allegations against staff members
5. Procedures for dealing with concerns regarding the safeguarding practices in the College
6. Management of safeguarding
7. Roles and responsibilities in managing safeguarding
8. Specific safeguarding issues
Appendix 1: Signs and types of abuse
Appendix 2: Role of the Designated Safeguarding Lead (DSL)
Appendix 3: Role and duties of the Nominated Safeguarding Director (NSD)
Appendix 4: External contacts
Appendix 5: Local authority safeguarding protocols and procedures
Appendix 6: Important definitions
Appendix A: Vulnerable students with an EHCP
1. Overview
This policy has been authorised by the Principal and is addressed to all members of the Ashbourne community (staff, visitors, parents, guardians, volunteers and students). Ashbourne is a small community with approximately 300 students, ranging from the ages 14 to 21. The policy applies wherever members of the Ashbourne community are working with students, even when this is away from the College’s premises, for example on an educational visit.
Safeguarding and student welfare
Ashbourne recognises safeguarding and promoting the welfare of students as defined by Department for Education guidance, Working Together to Safeguard Children:
Acting in the best interests of the child
This policy is underpinned by one of Ashbourne’s core stated values that ‘Students Come First’. The College has a duty to consider at all times the best interests of the student and take action to enable all students to achieve the best outcomes. Every student should feel safe and protected from any form of abuse. Ashbourne firmly believes that providing excellent safeguarding support can also have a significant positive impact on student performance.
Attendance
The College has a strict attendance policy, well-established procedures and a senior attendance champion in place to help students maintain good attendance and guard against repeated or prolonged periods of absence from becoming children missing education; staff are also trained to be alert to absence in terms of potential safeguarding concerns. See 2.2, 6, 8.1, Attendance Policy.
Children in need and children at risk: referrals
The College recognises and is prepared to act promptly when a child is in need and/or when a child is at risk, as defined in sections 17 and 47, respectively, of the Children Act 1989. See section 3 for further details.
Designated Safeguarding Lead (DSL) role and responsibility
The DSL takes a lead responsibility for safeguarding and child protection (including online safety and understanding the filtering and monitoring systems and processes in place) at the College and ensures all staff undergo required training at induction with regular updates. See 6.1 and 6.2 and Appendix 2.
Early Help
Early help is support for children of all ages that improves a family’s resilience and outcomes or reduces the chance of a problem getting worse.The College prepares staff to be able to identify students who may need early help, know what help is available within the College and externally, and the procedures required to take further action. See section 6.5 for further details.
Equal Opportunities
Ashbourne is committed to the promotion and development of equality and diversity. We believe that all students, regardless of age, gender, ability, culture, ethnicity, race, language, religion, beliefs, caste, disability or sexual identity, have equal rights to protection: to feel safe, secure, valued and respected, and feel confident, and know how to approach adults if they have any concerns. No student or group of students must be treated any less favourably than another in being able to access support and services which meet their particular needs. This policy will be implemented in accordance with the Equal Opportunities Policy, and decisions/actions taken in relation to potential safeguarding or child protection incidents will not be influenced by the background or situation of any persons involved. Each case will be dealt with on its own merits.
External providers
Ashbourne is aware that it should seek assurance from external service providers, used for college activities, that they have appropriate safeguarding and child protection policies in place. The College undertakes risk assessments including for trips and activities outside of the college premises. See section 6.7 and the College Risk Assessment policies.
Forced Marriage
The College is aware that it is a crime to carry out any conduct whose purpose is to cause a child to marry before their eighteenth birthday. See 8.2.2.
‘It could happen here’
Staff are made aware that child-on-child/peer-on-peer sexual abuse and/or harassment may be taking place whether or not it has been reported. The College takes a zero-tolerance approach to any form of harassment and/or abuse however casual it may be considered. It should be noted that the College acts to support both alleged victims and alleged perpetrators where sexual harassment and/or abuse is reported. Section 8.7 and the Child-on-child/Peer-on-peer Abuse Policy provide further details.
Mental Health
Ashbourne promotes and values healthy relationships, positive mental health and wellbeing among all members of the College community. All Personal Tutors and full time staff complete mental health awareness training and are supported by the College’s appointed Mental Health Lead. The College also provides a counselling service and/or makes referrals for those in need of further support. See section 2.32 and Mental Health Policy.
Online safety, filtering, monitoring and security
The College keenly manages these important aspects of safeguarding and is aware of requirements to carry out risk assessments for Prevent Duty, filtering and monitoring and cyber security. See section 6.6, e-Safety Policy and Prevent Duty Policy
Partnership
The College is aware of relevant Child Protection and safeguarding partners. It maintains close contact with key local safeguarding agencies and remains up to date with their protocols and procedures, as set out in section 1.1.2.
Safer recruitment
Child Protection and safeguarding are paramount in the recruitment of staff at the College. The College is aware that it should inform candidates shortlisted for employment about online searches. See section 6.12 and the Safer Recruitment Policy for further details.
Signs of abuse
All staff are made aware of how to spot possible signs of abuse, including understanding who may be considered more vulnerable and those with SENDs, as well as the procedures for taking action. See section 2 and Appendix 1 for further details.
Training
All staff, students and management undertake training in Child Protection and safeguarding issues and procedures, including online safety and student attendance, and receive regular updates and briefings. See sections 6.1 and 6.2 for further details.
1.1 Important contacts at Ashbourne
Ashbourne’s small size (fewer than 300 students) and the low number of referrals that the College makes to the Local Safeguarding Board (LSGB) at the Royal Borough of Kensington & Chelsea (RBKC) each year means that the DSL is able to manage all of the correspondence from Ashbourne to the relevant contacts at the council in a timely manner. Nevertheless, the College recognises that safeguarding and promoting the welfare of students is the responsibility of everyone in the Ashbourne community. It is, therefore, the Ashbourne community’s responsibility to understand how to recognise, respond to, report, record and refer any concerns about the welfare of an individual student as appropriate.
The College works closely with the RBKC’s Local Safeguarding Board and other relevant agencies to assess, identify, and support students who could benefit from early help, are suffering harm or who may suffer harm without intervention. Such agencies may include the Police, Children’s Social Care (CSC) and health services.
1.1.2 Important external contacts and local authority safeguarding protocols and procedures
1.1.2.1 Important external contacts
Further contact details are provided in Appendix 4.
1.1.2.2 Local authority safeguarding protocols and procedures
The College works closely with the RBKC’s Local Safeguarding Board and other relevant agencies to assess, identify and support students who could benefit from early help, are suffering harm or who may suffer harm without intervention. The College also works with these agencies with respect to concerns relating to staff. These agencies include the Police, Children’s Social Care (CSC), the LADO and other health services. Ashbourne is aware of the local protocols and procedures for referrals. Full details are provided in Appendix 5.
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1.2 Related policies
This policy works closely with a number of other important College policies, which include the following:
1.3 Statutory and non-statutory guidance
This policy has been developed having regard to a number of different guidance documents and legislation, with particular focus on the following Department for Education (DFE) guidance: Keeping Children Safe in Education (KCSIE) and Working Together to Safeguard Children.
Full list of Statutory and non-statutory guidance.
The Human Rights Act 1988 (HRA) as it pertains to the European Convention of Human Rights (ECHR) that are deemed to apply to the UK. Under the HRA, it is unlawful for any schools or colleges to act in a way that is incompatible with the ECHR, in particular Articles 3, 8 and 14 and Protocol 1, Article 2. These include the right to freedom from inhuman and degrading treatment, the right to respect for private and family life including a duty to protect individuals’ physical and psychological integrity and requires all rights and freedoms therein to be protected and applied without discrimination; and protect the right to education. Being subjected to harassment, violence and/or abuse, including of a sexual nature, may breach these rights.
Under the Equality Act 2010, schools and colleges must not unlawfully discriminate against pupils on the basis of protected characteristics, which are outlined in Ashbourne’s Equal Opportunity Policy. KCSIE encourages schools and colleges to carefully consider how they can support the safeguarding the needs of students with regard to protected characteristics including taking positive action and making reasonable adjustments.
1.5 Review of the Child Protection and Safeguarding Policy
The DSL will ensure that this policy, as well as other related safeguarding policies, are reviewed at the annual Safeguarding meeting that takes place each June. The NSD and Principal will attend this meeting and changes will require their approval.
Throughout the academic year the DSL consults with staff either directly or indirectly through our safeguarding database and intranet (behaviour share). During these discussions there will be opportunities for staff to contribute to shape safeguarding arrangements. The DSL will also consider changes required as a result of any safeguarding incidents, new legislation or new guidance. This may lead to updates of the Child Protection and Safeguarding Policy throughout the academic year and reporting to the staff where appropriate.
All child protection incidents at the College will be followed by a review of these procedures by the DSL and a report will be made available to the Principal and the NSD. Where an incident involves a member of staff, the DSL will determine whether any improvements can be made to the College’s procedures. Any deficiencies or weaknesses in regard to child protection arrangements will be addressed and remedied.
2. Identifying vulnerable students and signs of abuse
2.1 Types and signs of abuse
2.2 Awareness of vulnerable students
2.3 Categories with additional focus:
2.31 SEND
2.32 Mental Health
2.33 Family member in prison
2.34 Lesbian, Gay, Bi-sexual, Transsexual or Queer (LGBTQ+)
2.35 Homelessness
2.1 Types and signs of abuse
To ensure that students are protected from harm, it is very important that the Ashbourne community understands what type of behaviour constitutes abuse. Abuse is a form of maltreatment of a student. Somebody may abuse or neglect a student by inflicting harm or by failing to act to prevent harm. Students may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Students may be abused by an adult or adults or by another student or students. Abuse can include:
Further details of the types of abuse and possible signs of abuse are shown in Appendix 1. In addition, types of abuse and indicators relating to child-on-child/peer-on-peer abuse are outlined in section 8.7 below and in the Child-on-Child/Peer-on-Peer Abuse Policy.
2.2 Awareness of vulnerable students
Some students may be at increased risk of significant harm as a result of neglect, exploitation and/or physical, sexual or emotional abuse. Many factors can contribute to an increase in risk. The College will give special consideration and attention to any student who:
2.3 Categories with additional focus
It is important to highlight a few categories in greater detail.
2.31 SEND – Students with a SEND may not outwardly show signs of abuse and/or may have difficulties relating any abuse or neglect they suffer. These can include:
2.32 Mental Health – in some cases, mental health problems can be an indicator that a student has suffered or is at risk of suffering abuse, neglect or exploitation. It is important to recognise that experiences of abuse, neglect or other trauma can have a lasting impact on mental health and behaviour.
Although staff are well placed to identify behaviour that may suggest mental health issues or the onset thereof, only trained professionals should attempt to make a diagnosis. Nonetheless, staff should speak with the DSL or deputy immediately if they have any safeguarding concerns about a student with respect to mental health issues.
Ashbourne follows the DfE’s Mental health and behaviour in schools guidance. The College facilitates mental health training awareness courses for staff.
All staff will be made aware of the importance of Mental Health issues for students through Inset Day training and regular Safeguarding Training updates throughout the year.
Key Staff, such as Personal Tutors and the DSL and DDSLs will have additional training on Mental Health awareness via online courses delivered by MHFA England or in person via the DSL.
Students will have Mental Wellbeing awareness delivered as part of the Personal Tutoring system and PSHEE Curriculum, and as a key focus on the first Inset Day of the year.
2.33 Family member in prison – Approximately 200,000 children have a parent sent to prison each year. These children are at risk of poor outcomes including poverty, stigma, isolation and poor mental health. NICCO provides information designed to support professionals working with offenders and their children, to help mitigate negative consequences for those children.
2.34 Lesbian, Gay, Bi-sexual, Transsexual or Queer (LGBTQ+) – Students who identify as LGBTQ+ can be targeted by their peers. In some cases, a student who is perceived by their peers to be a member of the LGBTQ+ community, whether they are or not, can be just as vulnerable as students who identify as LGBTQ+.
2.35 Homelessness – Being homeless, or at risk of homelessness presents a real risk to a student’s welfare. The College should be aware of potential indicators of homelessness including: household debt, rent arrears, domestic abuse and anti-social behaviour, as well as a family being asked to leave a property. If staff become aware, or suspect that a student may be at risk of homelessness they should talk to the DSL in the first instance. Whilst referrals to the Local Housing Authority should be progressed as appropriate, and in accordance with local procedures, this does not and should not replace a referral to the LADO where a student has been harmed or is at risk of harm.
3. Procedures for handling concerns about a student
3.1 What staff should do if they have a concern about a student
3.1.1 DSL follow-up to a concern being raised
3.1.2 How is the DSL alerted to these concerns
3.1.3 Level of concern
3.2 What staff should do if a student is in danger or at risk of harm; circumstances for referring to the Police
3.3 The referral
3.4 Advice for staff when meeting with students
3.5 Respecting the student’s wishes; age and circumstances in which authorities must be alerted
3.6 Context
3.7 Safeguarding supersedes Data Protection
3.8 Confidentiality
3.9 Notifying parents; age and student data protection
3.10 Peer-on-peer/child-on-child abuse, including bullying, cyberbullying, sexual violence and sexual harassment
3.11 Safeguarding record
3.11.1 Keeping records
3.11.2 Disclosing records
It is important that a student at risk or in need receives the right help at the right time to address risks and prevent issues escalating. It is therefore important that all staff understand their responsibility to: identify, act on and refer early signs of abuse, neglect and exploitation; keep clear written records; listen to the views of the student; reassess concerns when situations do not improve; share information quickly and challenge inaction. All staff at the College are expected to comply with statutory guidance Working Together to Safeguard Children unless exceptional circumstances arise. In particular, staff are expected to appreciate that effective safeguarding systems are those where:
3.1 What staff should do if they have a concern about a student
If staff have any concerns about a student (as opposed to a student being in immediate danger), they should initially log these concerns using the secure Safeguarding Share option in the FileMaker database system, which will automatically move the information into the secure FileMaker Safeguarding database. Information should include:
The information that is uploaded onto the Safeguarding database is secure and is only accessible to the DSL and the DDSLs. The DSL and DDSLs will also receive an email notification, without details of the incident, alerting them to check the Safeguarding database when a staff member logs an entry. If staff are to meet with the students individually, they should refer to point 3.3 for additional advice about how to handle these conversations.
All staff should be aware that students may not feel ready or know how to tell someone they are being abused, exploited or neglected, and they may not recognise their experiences as being harmful, for whatever reason. Any concerns should be discussed with the DSL.
Staff should not assume that somebody else will take action and share information that might be critical to keeping students safe. If a student’s situation does not appear to be improving, it is the legal duty for the staff member to challenge any inaction and follow this up with the DSL.
If the staff member continues to stay involved in the process to support the student, they must ensure that concerns, discussions and decisions made, and the reasons for those decisions, are recorded and stored in the Safeguarding database.
Members of staff also have a legal duty to make a direct referral to CSC should circumstances demand. Ashbourne’s small size, and the few referrals made by the College to the RBKC each year, mean the College has the resources to ensure that all correspondence to the local council comes directly, except in exceptional circumstances, from the DSL or DDSL in a timely manner. However, if anyone other than the DSL makes a referral, they should inform the DSL as soon as possible that a referral has been made. In these cases, after the referral has been made the DSL will follow things up.
3.1.1 DSL follow-up to a concern being raised
Initially this happens when a student registers at the College and has declared a previous safeguarding issue concern. This could be related to SEND, medical or vulnerability issues. The DSL must then ensure that all appropriate contacts have provided a complete and comprehensive set of documents relating to this safeguarding issue. The DSL will then make an entry on the safeguarding database allocating the student a grade from 0 to 4 on the Ashbourne safeguarding scale (see below).
After a staff member has logged their concerns about an individual student on the Ashbourne Safeguarding database, the DSL will read through the concern.
3.1.2 How is the DSL alerted to these concerns
The DSL may also decide to meet with the staff member who logged the concern to gain a better understanding of the situation. Irrespective of the concern raised, the DSL will ensure that a follow up meeting is organised with the student. In most cases this meeting will be with the DSL. However, the College understands that students may respond better to different individuals, and, therefore, the DSL may well involve another member of staff to meet with the student. In these cases the DSL will follow-up with the member of staff to ensure a clear understanding of the concerns raised and that all information is logged onto the Safeguarding database.
3.1.3 Level of concern
During the individual meetings with the student, the DSL must decide whether a referral to CSC, early help or other support is appropriate, which must be done in accordance with the referral thresholds set by the LSCB. In addition, the College has five levels of concern which it uses to categorise students on the Safeguarding database. The DSL will ascertain what level of need the student is at presently, and will take the appropriate action accordingly. The levels of concern are as follows:
0 – No concern
1 – Mild concern
2 – Moderate concern
3 – High concern
4 – Referral
With each level, the DSL will put in place different action plans, which are detailed below:
0 – No concern
If the DSL deems it necessary, a note will be sent to the teachers of this particular student to update them on the student’s situation and, where appropriate, relevant information will be shared.
The Safeguarding Team will no longer monitor the students progress as a result of the concern being raised.
The DSL will ensure that all notes are updated on the Safeguarding database. Reasons will be given as to why this student is no longer deemed a concern.
1 – Mild concern
At the initial assessment meeting, or possibly thereafter, appropriate support will be put in place to support the student.
If the DSL deems it necessary, a note will be sent to the teachers of this particular student to update them on the student’s situation and, where appropriate, relevant information will be shared.
A follow up meeting will be organised at another point in the year to assess the student’s progress. Usually at this point, unless further concerns are raised, the student will be moved from Mild Concern to the No Concern category.
The DSL will ensure that all notes are updated on the Safeguarding database.
2 – Moderate concern
At the initial assessment meeting, or possible thereafter, appropriate support will be put in place to support the student.
If the DSL deems it necessary, a note will be sent to the teachers of this particular student to update them on the student’s situation and, where appropriate, relevant information will be shared.
At minimum, a follow up meeting will be organised once per term.
At the subsequent follow-up meetings, the DSL will consider what additional support is required or whether the student needs to change into a different category.
The DSL will ensure that all notes are updated on the Safeguarding database.
3 – High concern
At the initial assessment meeting appropriate support will be put in place to support the student.
If the DSL deems it necessary, a note will be sent to the teachers of this particular student to update them on the student’s situation and, where appropriate, relevant information will be shared.
At minimum, a follow up meeting will be organised once per half-term.
At the subsequent follow-up meetings, the DSL will consider what additional support is required or whether the student needs to change into a different category.
The DSL will ensure that all notes are updated on the Safeguarding database.
4 – Referral
At the initial assessment meeting appropriate support will be put in place to support the student.
If the DSL deems it necessary, a note will be sent to the teachers of this particular student to update them on the student’s situation and, where appropriate, relevant information will be shared.
This case will be followed up by the DSL on a daily basis to ensure that the College has completed all of the things that have been agreed to support this student. This may involve checking attendance, and communicating with external agencies, teachers, peers and family members who are involved in the situation.
The DSL will ensure that all notes are updated on the Safeguarding database.
If the DSL deems that a referral to the CSC is required, the DSL will take additional steps, which are outlined in 3.3. It should be noted that as a general policy at Ashbourne, whenever the DSL has a concern that a student is in immediate danger, the CSC would be contacted; depending on the situation the initial discussion may be on a no-names basis to seek guidance.
3.2 What staff should do if a student is in danger or at risk of harm; circumstances for referring to the Police
If staff believe that a student is in immediate danger or at risk of harm, they must ensure that an immediate referral is made to the CSC and/or the Police. If there is an immediate, urgent and extreme risk, members of staff are legally obliged to make such a referral; however the College has a very robust Safeguarding Team in place to handle these types of situations and, in almost all circumstances, the member of staff should immediately see the DSL or DDSL to facilitate this process; only in exceptional circumstances should the individual staff member make a referral to the CSC without the DSLs involvement. Staff are legally obliged to challenge any inaction and follow this up with the DSL and CSC as appropriate. The DSL and DDSLs liaise with safeguarding partners and other agencies in line with Working Together to Safeguard Children and follow NPCC guidance When to call the police.
3.3 The referral
A referral for a student who is in immediate danger or at risk of harm must be made immediately and in any event within 24 hours (one working day) of staff being aware of the risk. Parental consent is not needed for referrals to statutory agencies such as the police and CSC. If anyone other than the DSL makes a referral, they should inform the DSL as soon as possible that a referral has been made.
The local authority social worker should acknowledge receipt to the referrer within 24 hours and make a decision about the next steps and type of response required. Staff are legally obliged to challenge any inaction and follow this up with the DSL and the CSC as appropriate; the DSL should challenge any inaction with the CSC.
In addition, if after a referral the student’s situation does not appear to be improving the DSL should press for re-consideration to ensure their concerns have been addressed and, most importantly, that the student’s situation improves.
The DSL will continue to review the student’s case and determine whether the student needs to stay within Ashbourne’s Safeguarding Referral category (see 3.11). Irrespective of whether the student’s situation improves, once a student has met the criteria to be referred to the CSC, the DSL will continue to monitor the student’s progress throughout their time at Ashbourne. However, as the student continues to improve their Safeguarding category is likely to change, and, as a result, the frequency in which the DSL organises a check-in meeting with the individual will reduce. The DSL and Director of Studies meet once per week to update the Safeguarding database. Nonetheless for all safeguarding the DSL is alerted as the situation demands.
Anyone involved in this process must ensure that concerns, discussions and decisions made, and the reasons for those decisions, are recorded and stored in the Safeguarding database.
Referrals following an allegation against a member of staff will be dealt with in accordance with the procedures set out in point 4.
3.4 Advice for staff when meeting with students
It takes a lot of courage for a student to disclose that they are being neglected and/or abused. They may feel ashamed, particularly if the abuse is sexual, their abuser may have threatened what will happen if they tell, they may have lost all trust in adults, or they may believe, or have been told, that the abuse is their own fault. To help ensure the effectiveness of such interactions with students, the College encourages staff to do the following:
3.5 Respecting the student’s wishes; age and circumstances in which authorities must be alerted
Where there is a safeguarding concern, the College will ensure the student’s wishes and feelings are taken into account when determining what action to take and what services to provide. This is particularly important in the context of harmful behaviours, such as sexual harassment and sexual violence. The College always operates its processes with the best interests of the student at heart, to enable the student to achieve the best outcome. The DSL will consider carefully how to manage the student so that they are able to express their views and give feedback in the most supportive environment, and, therefore, the College respects that students may feel comfortable expressing their thoughts with different members of staff. However, depending upon the age of the individual and the information being shared, the College may have to take action that is against the student’s wishes. In these cases the DSL will ensure they consult with CSC to ensure that the decisions made by the College are the most appropriate to support the student.
3.6 Context
All staff, but especially the DSL and DDSLs, will consider the contexts in which safeguarding incidents and behaviour occur, how they can be associated with factors outside the College, and/or occur between children outside of the College. Assessments of students should consider whether and/or how wider environmental factors in a student’s life are a threat to their safety and/or welfare. This includes students being at risk of abuse or exploitation in situations outside their families such as (but not limited to) sexual exploitation, criminal exploitation and serious youth violence. The College will share as much information with CSC as possible as part of the referral process to enable consideration of all the available evidence and the full context of any abuse.
3.7 Safeguarding supersedes Data Protection
Ashbourne spends a lot of time to ensure that it protects the data of individuals. For more information about how this works, please view the College’s Data Protection Policy. Nevertheless, in cases relating to Safeguarding it is important to note that Safeguarding supersedes Data Protection when it comes to important decisions; safeguarding trumps data protection.
The guidance, Information Sharing: Advice for Practitioners Providing safeguarding Services to Children, Young People, Parents and Carers, supports staff who have to make decisions about sharing information. Fears regarding sharing information under the Data Protection Act 2018 and the GDPR should not stand in the way of the need to maintain welfare and protect the safety of students. If in doubt about what information can and should be shared, staff should speak to the DSL.
The College will co-operate with police and CSC to ensure that all relevant information is shared for the purposes of child protection investigations under section 47 of the Children Act 1989 in accordance with the requirements of Working together to safeguard children.
3.8 Confidentiality
All staff understand that any matter relating to Safeguarding or child protection issues warrants a high level of confidentiality, not only out of respect for the student and staff involved but also to ensure that information being released into the public domain does not compromise evidence.
Staff must not promise the confidentiality of the information shared by the student and must always act in the best interests of the student. Concerns raised must be shared with the DSL and CSC where appropriate.
Staff should only discuss concerns directly with the DSL or DDSLs or Principal. The Safeguarding Team will then decide who else needs to have access to the information and they will disseminate it on a ‘need-to-know’ basis.
3.9 Notifying parents; age and student data protection
The College will normally seek to discuss any concerns about a student with their parents. This must be handled sensitively and the DSL will normally make contact with the parent in the event of a concern, suspicion or disclosure.
However, if the College believes that notifying parents could increase the risk to the student or exacerbate the problem, then advice will first be sought from CSC. If the allegation involves a member of staff, the parents should only be informed with the LADO’s consent.
For the avoidance of doubt, referrals to CSC or the LADO do not require parental consent. Staff must act in the best interests of the student, even if this means making a referral against the parents’ wishes.
3.10 Child-on-child/Peer-on-peer abuse, including bullying, cyberbullying, sexual violence and sexual harassment
All staff should be aware that safeguarding issues can often manifest themselves as child-on-child/peer-on-peer abuse. Please refer to point 8.7 for further information relating to child-on-child/peer-on-peer abuse.
3.11 Safeguarding records
3.11.1 Keeping records
All concerns, discussions and decisions made, and the reasons for those decisions, will be recorded in writing. Information will be kept confidential and stored securely.
Records should include:
Records kept until a student’s 25th birthday
We will keep a student’s file as ongoing until their 25th birthday in the following cases:
After their 25th birthday the student’s record will be deleted.
Records kept until a student’s 21st birthday
We will keep a student’s file as ongoing until their 21st birthday in the following cases:
In this instance, concerns about welfare are usually focused on students who have had a history of self-harm or eating disorders for which they have required medical intervention. The college will not keep ongoing files for students who have received private counselling.
After their 21st birthday the student’s record will be deleted.
Records kept until a student leaves the college
We will keep a student’s file as ongoing until they leave the college in the following cases:
1. They have had a record created on the Ashbourne Safeguarding Database.
Their record will be deleted on the last Friday in August after they have completed their studies. As soon as a student leaves the college their Safeguarding category will become “no concern”.
3.11.2 Disclosing records
If students are on the Ashbourne Safeguarding Database and it is deemed that future institutions would benefit from having access to the notes we have made on this database, the following will apply:
1. If the student is under the age of 18 when they leave the college, Ashbourne will proactively find out where they are studying and send on any Child Protection Files or relevant safeguarding notes to the new DSL. These files will be deleted from the college system in line GDPR regulations once receipt of the files are confirmed by the new school.
2. If the student is over the age of 18, Ashbourne will only forward notes onto the DSL at the new education provider when we are requested for a reference. The college will typically provide this information in consultation with the student.
4. Procedures for handling low-level concerns and/or allegations against staff members, including supply teachers, volunteers and contractors
Ashbourne aims to create a secure environment for everyone in the College community and a culture of openness, trust and transparency. This enables any member of the community to raise concerns, however small they may consider them, including about themselves, so that potentially concerning, problematic and inappropriate behaviour can be identified early in order to reinforce what is expected acceptable behaviour and to minimise the risk of abuse.
All staff members should understand what constitutes good practice (7.1.2), what abuse of trust and inappropriate relationships look like (7.1.1) and be familiar with expected behaviour as set out in the Staff Code of Conduct.
The College’s Low-level Concerns and Allegations Against Staff Policy sets out what constitutes risk of harm, low-level concerns and the guidance and procedures for sharing, handling and recording any concerns and/or allegations about a member of staff in relation to their behaviour with students.
Advice will be sought from the LADO, on a no-names basis if necessary, when there is any doubt whether a concern about a staff member’s behaviour may pose a risk of harm to a student.
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5. Procedures for dealing with concerns regarding the safeguarding practices in the College
5.1 Whistleblowing
5.2 Complaints about safeguarding practices from students and parents
When a member of the Ashbourne community has concerns about poor or unsafe practices and potential failures in the College’s safeguarding systems, these should be initially raised directly to the DSL or DDSLs.
5.1 Whistleblowing
If staff feel unable to raise an issue with the staff members detailed above or feel that their genuine concerns are not being addressed, they should refer to the whistleblowing procedures which are set out in the College’s Whistleblowing Policy. This may result in the staff member using other whistleblowing channels, such as the NSPCC whistleblowing advice line (see Appendix 6).
There will be no disciplinary action taken against a member of staff for raising such a concern provided that it is done in good faith.
5.2 Complaints about safeguarding practices from students and parents
All complaints and concerns will be considered carefully by the College and appropriate action will be taken in line with the College’s Complaints Policy. Where parental or student complaints raise safeguarding concerns about a member of staff, the person to whom the complaint was initially communicated must follow the procedure set out in point 4.3, as well as follow the relevant procedures set out within the Complaints Policy.
Every student should feel able to raise concerns with a member of staff whom they trust. Staff who hear about concerns, suspicions or allegations from a student must relay the concerns immediately to the DSL or DDSL.
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6. Management of safeguarding
6.1 Induction
6.1.1 Staff induction
6.1.2 Student induction
6.2 Training
6.2.1 Staff training
6.2.2 Student Council training
6.3 Meetings
6.3.1 Bi-annual safeguarding meetings
6.3.2 Weekly safeguarding meetings
6.3.3. Personal Tutor meetings
6.3.4 Head of Faculty meetings
6.3.5 Daily meetings and communication
6.3.6 Safeguarding must be an agenda point at all meetings
6.4 Positive promotion
6.5 Early intervention
6.5.1 Half-termly reports – feedback about student progress
6.5.2 Structure of the College
6.6 E-Safety/online safety including social media
6.7 Educational visits
6.8 Photography and images
6.9 Premises
6.9.1 Security
6.9.2 Natural light
6.10 Safeguarding education
6.11 Looked after children
6.12 Safer recruitment
6.13 Monitoring attendance
6.14 Risk assessments for students
6.15 Counselling
6.16 Students with SEND
6.17 Overseas and independent living students
The College aims to create an environment where students are safe to learn and develop. This section looks at what pro-active measures Ashbourne takes to ensure that the College safeguards its students effectively.
6.1 Induction
6.1.1 Staff induction
To manage the students effectively, as part of their induction new members of staff will meet with the DSL to:
New staff will also have to complete the following training before the end of their first two terms of employment at the College:
6.1.2 Student induction
To ensure that students know what support Ashbourne offers. During their induction they will meet with either the DSL or a DDSL and will be informed about:
6.2 Training
The DSL takes a lead responsibility for safeguarding and child protection at the College and ensures all staff undergo required training at induction with regular updates. The DSL is also responsible, in consultation with the Principal and DDSLs, for planning and delivering training.
6.2.1 Staff training
It is important that all staff have training to enable them to recognise the possible signs of abuse, neglect and mental health issues to know what to do if they have a concern. In addition to the training they receive at induction, the DSL will ensure that all staff are given the necessary training to be able to fulfil their duties. This will include:
6.2.2 Student Council training
The College believes it is critically important for the students to take an active role in safeguarding. To help facilitate this, in the Autumn Term the DSL will organise for all members of the Student Council to receive safeguarding training.
6.3 Meetings
There are a number of meetings that take place throughout the year that help to ensure that the College is taking pro-active measures to safeguard students.
6.3.1 Bi-annual safeguarding meetings
Representatives from all academic and non-academic departments within the College meet with the DSL, DDSL, NSD, Principal and other members of the Safeguarding Team on a bi-annual basis (December/January and June). During these meetings, which are chaired by the DSL, there will be a review of any safeguarding issues or concerns that have arisen in the previous six months.
6.3.2 Weekly safeguarding meetings
The Principal, DSL and Director of Studies (also DDSL) have a weekly meeting to review all aspects of the College with safeguarding as a key agenda point.
6.3.3 Personal Tutor meetings
Each week a Personal Tutor meeting takes place between each of the Year 12 Personal Tutors. During this meeting a variety of issues are discussed to help support students, and safeguarding is a key agenda point. The Heads of Sixth Form who chair these meetings, will ensure that at the end of the meeting any safeguarding concerns are immediately communicated to the DSL.
6.3.4 Head of Faculty meetings
Regularly throughout the academic year, a Head of Faculty meeting takes place with heads from each of the eight facilities at the College. During these meetings a variety of issues are discussed to help support teachers to improve the provision of education offered to students. The DSL will attend these meetings to get updates on any safeguarding issues that are raised. The Leader of Faculties who chairs these meeting, will ensure that, on occasions when the DSL is unable to attend, at the end of the meeting any safeguarding concerns are immediately communicated to the DSL.
6.3.5 Daily meetings and communication
The DSL and Director of Studies (DDSL) communicate on a daily basis to discuss relevant safeguarding concerns.
6.3.6 Safeguarding must be an agenda point at all meetings
The person responsible for chairing any meetings that take place at Ashbourne is expected to have safeguarding as one of the agenda points. At the end of the meeting, if any safeguarding concerns are highlighted these must be immediately communicated to the DSL.
6.4 Positive promotion
Safeguarding will be promoted positively throughout College in a number of ways, including:
6.5 Early intervention (early help)
Early help is the timely identification of students who are struggling academically or personally, assessing their needs and implementing appropriate support.
Any student may benefit from early intervention but all staff should be particularly alert to the potential need for early help for a student who fits into the categories noted in section 2 above.
Early intervention can take many forms, such as:
At Ashbourne, early intervention mainly involves College-based programmes and mentoring schemes. This involves providing support as soon as a problem emerges, and consultation with the local authority Early Help Team. All staff should be aware of the early intervention process, and understand their role in it. This could include: identifying emerging problems, for example dramatic weight loss, liaising with the DSL, sharing information with other professionals to support early identification and assessment and, in some cases, acting as the lead professional in undertaking an early help assessment. As stated previously in this policy, Ashbourne has a relatively small student body and therefore the DSL has the capacity to manage all of the early intervention programmes; however, the DSL may well delegate individual students to a DDSL, Personal Tutor or in certain cases teachers. In the case when the DSL delegates this responsibility to manage early intervention to another member of staff, she will continue to monitor that individual to ensure that she is confident that the student’s case is being managed effectively.
All staff should be prepared to identify students who may benefit from early help, be aware of the early help process and understand their role in it. This is part of the intervention procedure at Ashbourne. If early help is appropriate, the DSL should support staff in liaising with other agencies and setting up an inter-agency assessment as appropriate. If early help or other support is appropriate, the case should be kept under constant review and consideration given to a referral to CSC if the student’s situation does not appear to be improving.
Initially, staff who consider that a student may benefit from early intervention should discuss this with the College’s DSL, by logging their concern using the Safeguarding Share option on the FileMaker database, which the DSL will then follow up and consider what type of additional support should be offered to the individual.
Effective early intervention relies upon:
Where a student and their family would benefit from coordinated support from more than one agency (e.g. education, health, police) there should be an inter-agency early help assessment. This should identify what help the student and their family require to prevent needs escalating to a point where intervention would be needed via a statutory assessment under the Children Act 1989. If Early Intervention is appropriate and where they are not taking the lead, the DSL will support the member of staff liaising with other agencies and setting up inter-agency Early Intervention assessment as appropriate.
Decisions as to who performs this role will be taken on a case-by-case basis and the College will consider carefully which member (s) of staff will be most effective for the individual student and their family.
For an Early Intervention assessment to be effective:
Effective early intervention involves the College (under the guidance of the DSL) providing high quality support as soon as possible, in cooperation with or coordinating with other agencies as appropriate, to help address the assessed needs of the student and their family, in order to significantly improve the outcomes for the student. However, each case should be kept under constant review, and consideration should be given to a referral to CSC if the student’s situation does not appear to be improving.
6.5.1 Half-termly reports – feedback about student progress
Each student and their parents receive reports from each of the relevant teachers four times throughout the year. These reports enable the College to see if students are underperforming and then seek to understand the reasons why that is the case. The DSL may liaise with all teachers to get updates and to identify whether any students are eligible for early intervention. In particular the DSL will work closely with the Deputy Head of Administration who proof reads all reports.
6.5.2 Structure of the College
Ashbourne’s small class sizes (no more than 10 students) enable teachers to better understand their students and to identify any concerns in relation to safeguarding, in particular those students that are suitable for early intervention.
6.6 E-Safety/online safety including social media
The College adopts a whole-school, holistic approach to online safety which (a) captures the range and complexity of the risks and of student’s experiences of those risks; (b) seeks to mitigate those risks as far as possible without depriving students of the significant benefits provided by technology and the internet; and (c) handles all cases of online harm appropriately and with sensitivity.
The DSL is responsible for providing robust advice regarding online safety, including when accessing online information when away from the college, for the whole Ashbourne community – students, staff and parents.
The College will do all it reasonably can to limit students’ exposure to risk when using the IT systems, by having in place appropriate filters and monitoring systems which are designed to protect students from online abuse without “over blocking” or imposing unreasonable restrictions as to what students can be taught through online education. The filters and monitoring systems in place are regularly reviewed by the Principal in conjunction with the DSL and Facilities Manager.
Please refer to the College’s E-Safety Policy for further information.
The College’s Staff Code of Conduct and Acceptable Use of ICT Agreement explain the responsibilities of staff in relation to keeping students safe in College.
If there is a concern that a student may be at risk of or suffering from online harm, follow the procedures set out in section 3 of this policy and discuss any concerns with the DSL immediately so that an agreed course of action can be taken in accordance with the procedures set out in this policy.
6.7 Educational visits
The Educational Visits procedures are set out in the College’s Risk Assessment for Educational Visits Policy, and reflect the consideration given to the protection of our students when they are involved in educational trips and visits outside of the College’s premises.
Where extended College activities are provided by and managed by the College, the procedures set out within this policy apply. Where other organisations provide services or activities on our site the member of the College’s staff responsible for arranging the services or activities will check that the service or activity providers have appropriate procedures in place, including relevant risk assessments and safer recruitment procedures.
When our students attend off-site activities, including those abroad on educational trips, the College will check that effective child protection arrangements are in place. All staff are bound by the College’s Risk Assessment for Educational Visits Policy, when arranging and organising off-site trips.
The DSL closely monitors the conduct of students and how staff manage these trips. Students and staff are asked for feedback following every trip that involves an overnight stay.
Please refer to the College’s Risk Assessment for Educational Visits Policy, for further information.
6.8 Photography and images
The vast majority of people who take or view photographs or videos of children do so for entirely innocent, understandable and acceptable reasons. Sadly, some people abuse children through taking or using images, so we must ensure that we have appropriate safeguards in place. To protect students, we will:
Further guidance for staff on the taking and storing of photographs and images of students is contained in the Managing Images of Children Policy and the Staff Code of Conduct.
From time to time professional photographers are invited onto the College to take group photographs or pictures of significant events; any professional photographers hired by the College will be subject to appropriate vetting checks.
6.9 Premises
The College will take all practicable steps to ensure that the College premises are as secure as circumstances permit.
6.9.1 Security
Visitors are to report to reception where they will sign in and be handed a red lanyard with a Visitor ID card. Safety of our students, staff and visitors is a key priority and the lanyards and ID cards play a key role in keeping all members of the community safe at all times. All members of the Ashbourne Community receive a photo ID card with their name and picture, which must be clearly displayed and worn at all times whilst on the College premises. The College’s use of lanyards and ID cards allows staff and students to ascertain at a glance whether persons on site are members of the Ashbourne community. The College imposes a duty on all members of the Ashbourne community to immediately report any persons not wearing their lanyard to the relevant reception on site.
The Facilities Manager has also ensured that CCTV is installed on every floor. This enables the Reception Team to monitor the College premises more effectively and increases the chances of identifying those individuals not wearing a lanyard and ID card.
For further information, please visit the College’s Lanyard and ID Policy.
6.9.2 Natural light
The College has been designed in such a way where lots of natural light comes into each classroom, which we believe helps to facilitate the learning experience. This also enables staff members to feel more comfortable having one-to-one meetings with students, and enables staff members to easily be able to see what students are doing in a room if left unattended.
6.10 Safeguarding education
Students are taught how to keep themselves safe and build resilience to key issues (including radicalisation) through the Year 11 PSHEE and Year 12 Personal Tutoring classes.
As well as offering the students valuable support with their university application and A-Level studies, these programme allow the students to gain a greater depth of understanding and awareness about the following:
With online safety, cyber-bullying by students, via texts, direct messages, social media or email, will be treated as seriously as any other type of bullying and will be managed through our Anti-bullying Policy. Students are educated about the risk of online harm – including youth produced sexual imagery, and the ways to mitigate those risks. The PT and PSHEE lessons will also aim to develop critical thinking and assessment skills to further enhance the students’ own ability in making safer, more informed decisions as to the material they access online and its validity.
The College produces blogs for both the PSHEE and Personal Tutoring classes, which are accessible to students and parents on the College website and in the Student and Parent Portals.
Through these sessions teachers will ensure that the students are reminded of the College’s Safeguarding procedures and the support available to them.
6.11 Looked after children
The College is aware of the vulnerability of looked after children and will ensure that staff are updated appropriately on any issues that may arise.
6.12 Safer recruitment
The College is committed to operating safer recruitment procedures in compliance with relevant legislation and guidance and in accordance with the College’s Safer Recruitment and Selection of Staff Policy.
Ashbourne spends a significant amount of time to ensure the right type of individual is selected to work at the College. This may include online searches about shortlisted candidates, who will be made aware these searches are being carried out. In addition to mandatory checks, different members of the SLT will meet with potential staff members to ensure that the College is confident that the individual can carry out their duties to a high standard and are suitable to work with young individuals.
The College ensures that all staff, including volunteers, have an appropriate DBS and other relevant checks to meet the requirements of the Single Central Record (SCR). For further information, please visit the College’s Safer Recruitment and Selection of Staff Policy.
6.13 Monitoring attendance
The College’s Attendance Officer follows up carefully with student attendance each day. The Attendance Officer will follow-up on absences four times throughout the day, and report any concerns with regard to students in which she has safeguarding concerns directly to the DSL. Attendance meetings take place every two weeks, which are also attended by the DSL and at least one of the DDSL’s. For further information about how the College monitors attendance, please visit the College’s Attendance Policy.
6.14 Risk assessments for students
The DSL will carry out risk assessments for the following types of students:
Each of these students will be met individually by the DSL, or another appropriate staff member selected by the DSL, and the information will be stored on Ashbourne’s Safeguarding database. As a result of these meetings, further tasks may need to be completed. Ordinarily these meetings will lead to the DSL to assign the student to either the ‘no concern’ or ‘mild concern’ category on our Safeguarding database (see 3.11). Where appropriate the DSL may also decide to inform the subject teachers with more information about these students.
If a student making an application discloses a safeguarding concern, the DSL or DDSLs will immediately take steps to ensure that the college may properly accommodate the student. This would involve surveying any document provided by the previous school(s), professionals (doctors, psychologists etc) and the relevant Local Authority if a referral has been made to CSC.
It is imperative that each party is confident that Ashbourne may offer a proper provision, making any reasonable adjustments. The student and their family should agree with the college’s provision for the student.
This means that the DSL will be informed of all new registrations to ensure there are no safeguarding concerns or, if these exist, they or one of the DDSLs will commence appropriate investigations.
In order to ensure that all students are suitably supported and in the environment best suited to their wellbeing, Ashbourne insists that all safeguarding issues which may affect any student are disclosed from the very beginning of the Registration process for the college. Ashbourne’s Admissions Policy makes clear that failure to disclose known safeguarding issues during the Registration process may lead to the withdrawal of the offer of a place at the college.
6.15 Counselling
Ashbourne works with a counsellor who provides support to both our students and staff members in a confidential setting. The information shared during these meetings are not discussed with the College. If staff or students wish to receive counselling, they must contact the DSL to take this forward.
For contact details of this counselling service, please refer to Appendix 6.
6.16 Students with SEND
The DSL works closely with the access arrangements team, which includes the deputy DSL and the Specialist SEND Assessor and Advisor to ensure that appropriate support is provided to those students who have a SEND.
For more information about the support Ashbourne provides to SEND students please refer to the College’s SEND and Access Arrangements Policy.
6.17 Overseas and independent living students
Overseas and Independent Living Students are considered as a potentially vulnerable group. Additional support meetings are organised for these students to address key issues related to safety and living in London including practical help and advice such as registering with a GP. These sessions are co-ordinated by the DSL. Due to the potential vulnerability of these students living on their own they are initially registered on Ashbourne’s Safeguarding database as a level 1 concern (see 3.11). After an initial meeting with the DSL, unless major concerns are raised, students will generally be moved to a level 0 concern and their performance and general welfare will be monitored by their Personal Tutor.
In addition, the College, as part of its responsibility as a Tier 4 sponsor, ensures the following in relation to students whose visa it sponsors:
6.17.1. Parents must send the College a signed letter confirming the full address of where their child will be living whilst studying in the UK. This will also include details of who else will be living at the same property.
6.17.2. Where students under the age of 18 will not be living with a responsible family member, the parent must confirm further information about the person/people their child will be living with, including their age, occupation, contact details, nationality and relationship to the student.
6.17.3. Ashbourne will not issue the Confirmation of Acceptance for Studies (CAS) required for visa applications if the family does not disclose the information highlighted in points 6.17.1 and 6.17.2.
6.17.4. To ensure that any changes to living arrangements prior to the visa application continue to meet our requirements, when assisting our students with their Tier 4 visa applications and other preparations prior to relocating to the UK we will ask them once more about their proposed living arrangements in the UK. This will include asking about who they will live with and the nature of their relationship with those individuals.
6.17.5. Within six weeks of their arrival in the UK, all Tier 4 students are required to provide the College with proof of their address to confirm that the information provided in 6.17.1 above is accurate. To ensure that this happens, the College will ensure that students register with their local GP and a copy of a letter confirming their Doctor registration, including details of the students’ address, will be kept on file at the College.
6.17.6. If a student under the age of 18 changes their address, the College will require another parental consent letter including the details highlighted in points 6.17.1 and 6.17.2.
6.17.7. As with all other Ashbourne students, to ensure we have accurate details about living arrangements, the College asks students to confirm their address, contact details and next of kin details twice per academic year.
7. Roles and responsibilities in managing safeguarding
7.1 All staff
7.1.1 Abuse of trust and inappropriate relationships
7.1.2 Good practice guidelines for staff
7.1.3 Meeting students on a one-to-one basis
7.2 DSL and DDSLs
7.3 Students
7.4 Parents
7.5 Nominated Safeguarding Director (NSD)
7.1 All staff
All staff are required to:
7.1.1 Abuse of trust and inappropriate relationships
As a result of their knowledge, position and/or the authority invested in their role, all adults working with students are in positions of trust. A relationship between a member of staff and a student cannot be a relationship between equals. There is potential for exploitation and harm of vulnerable young people and all staff have a responsibility to ensure that an unequal balance of power is not used for personal advantage or gratification.
Staff should note that it is an offence for a person aged 18 or over and in a position of trust to (a) intentionally touch a child in a sexual way; (b) have a sexual relationship with a child, even if the relationship is consensual; (c) cause or incite a child to engage in sexual activity; (d) intentionally engage in sexual activity in the presence of a child; or (e) for the purposes of sexual gratification cause a child to watch a third person engaging in a sexual activity or look at an image or any person engaging in a sexual activity. A position of trust could arise even if the member of staff does not teach the student. A student for these purposes is a person under the age of 18. Note that Ashbourne does not condone any relationship between a member of staff and a student currently in education at the College, that involves the points (a) to (e) highlighted above, irrespective of the student’s age.
7.1.2 Good practice guidelines for staff
In addition to their responsibilities, we have also highlighted the following Good Practice guidelines for staff:
7.1.3 Meeting students on a one-to-one basis
All staff are aware of the potential risks (i.e. false allegations against staff) of meeting a young person alone, particularly if the young person has had an experience of sexual/emotional abuse. Due to the number of academic interventions that take place at the College to improve student performance, one-to-one meetings are likely to be an integral part of a staff member’s role and they must exercise their own professional judgement and a degree of caution in these situations. All staff should try to ensure that they do not place themselves in any compromising situations, where allegations could potentially be made against them.
Suggested protective measures to consider include:
7.2 DSL and DDSLs
The DSL takes lead responsibility for safeguarding and child protection (including online safety) at the College. As a member of the SLT, the DSL has the appropriate status and authority within the College to carry out the duties of this post. The DSL is given the time, funding, training, resources and support to provide advice and support to other staff on student welfare and child protection matters, to take part in strategy discussions and inter-agency meetings, and/or to support other staff to do so, and to contribute to the assessment of students.
The role principally involves:
The DSL is ably supported by DDSLs. The DSL ensures that the DDSLs are trained to the same standard as the DSL. Whilst the activities of the DSL can be delegated to her deputies, the ultimate lead responsibility for child protection, as set out above, remains with the DSL; this lead responsibility should not be delegated.
For further information about the DSL’s role, please refer to Appendix 2.
7.3 Students
Students have a key responsibility in terms of wearing a lanyard and ID card at all times when on the College premises. The lanyard should be worn around the neck, on the front of the body and on the outermost piece of clothing.
In addition, if a student identifies another individual on Ashbourne’s premises who is not wearing a lanyard and ID card, they must ask them to report to the reception of that building immediately. This is particularly true for students who are members of the Student Council, who must set an example for other students to follow.
Students are encouraged to raise any safeguarding concerns directly with the College. In the first instance they should contact either the DSL or DDSLs. If students do not feel that their concerns are being taken seriously, they are welcome to contact outside agencies where appropriate (refer to contact details in Appendix 4).
7.4 Parents
Parents should raise any safeguarding concerns directly with the College. In the first instance they should contact either the DSL or DDSLs. If parents do not feel that their concerns are being taken seriously, they are welcome to contact outside agencies where appropriate (refer to contact details in Appendix 4).
7.5 Nominated Safeguarding Director (NSD)
The NSD takes leadership of the College’s safeguarding arrangements on behalf of the Senior Leadership Team (SLT) and liaises with external agencies where this is required, including in the event of allegations of abuse made against the Principal.
The NSD will play an essential role in ensuring students are kept safe from harm. If the NSD is unavailable, her role and duties will be carried out by the Principal, except in a case where an allegation of abuse is made against the Principal himself. In these cases, the LADO will undertake this responsibility.
The NSD, Principal and Director of Studies will undertake appropriate training in accordance with the Local Safeguarding Children Board’s recommendations to fulfil the role and duties. The DSL will ensure that this takes place within the required timelines.
For a full description of the role and duties of the NSD, please refer to Appendix 3.
8. Specific safeguarding issues
8.1 Students missing education
8.1.1 Informing parents
8.2 ‘Honour based’ abuse
8.2.1 Female Genital Mutilation
8.2.2 Forced marriage
8.3 Radicalisation
8.3.1 What staff should do if a child is seen as at risk of radicalisation
8.4 Child Sexual Exploitation (CSE)
8.5 Private fostering
8.6 Domestic abuse
8.7 Peer-on-peer/child-on-child allegations of sexual violence and sexual harassment
8.7.1 Whole-school approach
8.7.2 Sexual violence and sexual harassment
8.7.3 Who is most at risk of sexual violence and sexual harassment?
8.7.4 How students can raise concerns and/or allegations about their own experiences and/or those of others
8.7.5 Responding to concerns and/or allegations
8.8 The sharing of youth produced sexual imagery (sexting)
8.9 Child criminal exploitation (county lines)
8.10 Children and the court system
8.11 Children with harmful behaviour
8.12 Upskirting
All staff should have an awareness of specific safeguarding issues, some of which are covered within this section. Staff should be aware that behaviours linked to the likes of drug taking, alcohol abuse, truanting and sexting put students in danger.
8.1 Students missing education
Students missing education, particularly unexplainable and/or persistent absences from education, is a potential indicator of abuse or neglect, which may include sexual abuse or exploitation, child criminal exploitation including involvement in county lines, mental health problems, risk of substance abuse, risk of travelling to conflict zones, risk of female genital mutilation or risk of forced marriage.
The College’s procedures for unauthorised absence and for dealing with students missing education are set out within the College’s Student Behaviour and Exclusions Policy and Attendance Policy.
Where reasonably possible, Ashbourne will hold more than one emergency contact number for each student to provide the College with additional options to make contact with a responsible adult particularly when a student is absent from College for an extended period of time.
The College shall inform the local authority of any student who is going to be added to or deleted from the College’s admission register at non-standard transition points in accordance with the requirements of the Education (Pupil Registration) (England) Regulations 2006 (as amended). This will assist the local authority to:
Attendance registers are carefully monitored to identify any trends on a daily basis. The College will report to the RBKC a student who fails to attend regularly or has been absent from College without permission for a continuous period of 10 College days or more. For further information about Ashbourne’s attendance procedures, please visit the College’s Student Behaviour and Exclusions Policy.
8.1.1 Informing parents
Parents will normally be kept informed as appropriate of any action to be taken under these procedures. However, there may be circumstances when the DSL will need to consult the Principal, CSC and/or the police before discussing details with parents.
Legislation recognises a child’s (legally, any student under the age of 18) right to make decisions about their own information and to express their wishes and preferences. Students 18 years of age and above have an absolute right to prohibit sharing their own personal information with their parents. If any other student requests that their parent/carer is not informed of action to be taken under these procedures we will consider their request bearing in mind the following:
In relation to Channel referrals, the DSL will consider seeking the consent of the student (or their parent/guardian) when determining what information can be shared. Whether or not consent is sought will be dependent on the circumstances of the case but may relate to issues such as the health of the individual, law enforcement or protection of the public.
8.2 ‘Honour based’ abuse
So-called ‘honour-based’ violence (HBA) encompasses crimes that have been committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation (FGM), forced marriage, and practices such as breast ironing. All forms of so-called HBA are abuse (regardless of the motivation) and should be handled and escalated as such. If in any doubt, staff should speak to the DSL. Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a student being at risk of HBA, or already having suffered HBA.
There is a range of potential indicators that a student may be at risk of HBA. Guidance on the warning signs that FGM or forced marriage may be about to take place, or may have already taken place, can be found in the Multi agency statutory guidance on FGM and also in the Multi-agency guidelines: ‘Handling cases of forced marriage’.
To give an example of indications that a student has already been subjected to FGM:
8.2.1 Female Genital Mutilation
FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long-lasting harmful consequences.
There is a range of potential indicators that a student may be at risk of FGM. Guidance on the warning signs that FGM may be about to take place, or may have already taken place, can be found on pages 38-41 of the Multi-agency statutory guidance on FGM (pages 59-61 focus on the role of schools).
There is a mandatory reporting duty for all staff members in respect of FGM. Where a staff member discovers (either through disclosure by the victim or visual evidence) that an act of FGM appears to have been carried out on a girl who is aged under 18, they must ensure that the matter is reported to the police. Therefore, members of staff must immediately inform the DSL or a DDSL and follow up to ensure that the matter has been reported to the police. Those failing to ensure that such cases are reported to the police will face disciplinary sanctions. It will be rare for a staff member to see visual evidence, and they should not examine students in this regard.
See the Home Office guidance for the Mandatory Reporting of FGM – procedural information for further details about the duty.
8.2.2 Forced marriage
Forcing a person into a marriage is a crime in England and Wales. A forced marriage is where one or both people do not or cannot consent to the marriage and pressure or abuse is used to force them into the marriage. Since February 2023, it is a crime to carry out any conduct, whether it includes pressure and/or abuse or not, whose purpose is to cause a child to marry before their eighteenth birthday.
A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some communities use religion and culture as a way to coerce a person into marriage. Ashbourne can play an important role in safeguarding students from forced marriage.
There are a range of potential indicators that a student may be at risk of forced marriage. The Forced Marriage Unit (FMU) has created Multi-agency practice guidelines: handling cases of forced marriage and, Multi-agency statutory guidance for dealing with forced marriage; staff can contact the Forced Marriage Unit if they need advice or information.
If staff have a concern regarding a student that might be at risk they must also refer to the guidance in point 3.2 of this policy.
8.3 Radicalisation
Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism. Terrorism is defined as 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 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.
Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs. It can also call for the death of members of the armed forces, whether in this country or overseas.
There is no single way of identifying an individual who is likely to be susceptible to an extremist ideology. Background factors may contribute to vulnerability which are often combined with specific influences such as family, friends or online, and with specific needs for which an extremist or terrorist group may appear to provide an answer. The internet and the use of social media in particular have become major factors in the radicalisation of young people. As with other safeguarding risks, staff should be alert to changes in student’s behaviour, which could indicate that they may be in need of help or protection. Staff should use their judgement to identify students who might be at risk of radicalisation and act proportionately, which may include making a referral to the Channel programme.
In accordance with the Department for Education Statutory Guidance 2015: Prevent Duty, the College recognises its duty to have due regard to the need to prevent students from being drawn into terrorism and adopts appropriate protocols to minimise the risk. The DSL is the designated Prevent Duty person responsible for co-ordinating action within the College and liaising with other agencies. Although the College assesses the risk to be low at present, the College will implement prevention measures such as applying appropriate restrictions to internet sites likely to promote terrorist and extremist materials, discussing these dangers with Students when appropriate in suitable forums, and undertaking Prevent awareness staff training periodically to ensure that staff are able to identify students at risk and know how to intervene.
The DSL will also assess and manage appropriately any risks identified in the vicinity of the College, including those posed by any visiting speakers. All staff must undergo Prevent training.
8.3.1 What staff should do if a child is seen as at risk of radicalisation
Staff should follow the College’s normal referral processes when there are concerns about students who may be at risk of being drawn into terrorism, as set out above (see section 3). This may include a referral to Channel or CSC depending on the level of risk. The DSL, in recognition that students may be at risk of being drawn into terrorism or other forms of extremism, will ensure that the College carries out appropriate risk assessments (following consultation with local partners, such as the Police) of the potential risks in the local area. Such risk assessments are discussed with the Principal, NSD and DDSLs to ensure the College’s safeguarding arrangements are sufficiently robust to help prevent and protect students from being drawn into terrorism, and are regularly revised.
8.4 Child Sexual Exploitation (CSE)
CSE is a form of sexual abuse where children are sexually exploited for money, power or status. It can involve violent, humiliating and degrading sexual assaults. In some cases young people are persuaded or forced into exchanging sexual activity for money, drugs, gifts, affection or status. Consent cannot be given, even where a child may believe they are voluntarily engaging in sexual activity with the person who is exploiting them. Child sexual exploitation does not always involve physical contact and can happen online. A significant number of children who are victims of sexual exploitation go missing from home, care and education at some point. What marks out exploitation is an imbalance of power in the relationship. The perpetrator always holds some kind of power over the victim which increases as the exploitative relationship develops. Sexual exploitation involves varying degrees of coercion, intimidation or enticement, including unwanted pressure from peers to have sex or sexual bullying including cyberbullying and grooming. However, it also important to recognise that some young people who are being sexually exploited do not exhibit any external signs of this abuse. Some of the following signs may be indicators of sexual exploitation:
Any concerns that a student is being or is at risk of being sexually exploited should be communicated without delay to the DSL. The College is aware that a student may not be able to recognise the coercive nature of the abuse and may not see themselves as a victim. Consequently, the student may resent what they perceive as interference by staff. However, staff must act on their concerns as they would for any other victim of abuse.
8.5 Private fostering
Children being privately fostered are required by law to be seen by a social worker. The College is aware of this requirement and will ensure protocols are followed where applicable.
8.6 Domestic abuse
Domestic abuse can encompass a wide range of behaviours and may be a single incident or pattern of incidents. That abuse can be, but is not limited to, psychological, physical, sexual, financial or emotional. Children can be victims of domestic abuse. They may see, hear, or experience the effects of abuse at home and/or suffer domestic abuse in their own intimate relationships (teenage relationship abuse). All of which can have a detrimental and long-term impact on their health, well-being, development and ability to learn.
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. 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.
Domestic Abuse may lead to other safeguarding concerns, and should therefore be managed under this policy.
8.7 Peer-on-peer/child-on-child allegations of sexual violence and sexual harassment
8.7.1 Whole-school approach
Ashbourne has a zero-tolerance approach to child-on-child/peer-on-peer abuse of any kind and takes all concerns and allegations very seriously.
Ashbourne is committed to safeguarding all students including those not legally defined as children, i.e. students over 18 years old. The college’s zero-tolerance approach therefore applies to child-on-child and peer-on-peer abuse.
It is vital that all staff understand the importance of challenging inappropriate behaviour between students, even if it appears relatively innocuous or takes place online and/or outside of the College environment. This is not only to prevent escalation and/or ongoing abuse but also to create a culture of accountability and responsibility. It is important to:
Dismissing or tolerating such behaviour risks normalising it.
Staff should assume that child-on-child/peer-on-peer abuse is taking place even where no concerns or allegations have been raised. Students may not find it easy to report abuse directly or at all, and so staff must remain vigilant and alert to any signs of abuse or potential abuse and inform the DSL or DDSL of any concerns, however seemingly small. Where staff have ‘reasonable cause to suspect that a student is suffering, or is likely to suffer, significant harm’, they should immediately follow the procedures set out in section 3 of this policy. All staff should be clear on the College’s policy and procedures as set out in the Peer-on-Peer/Child-on-Child Abuse Policy, which includes child-on-child abuse, and be familiar with part 5 of KCSIE.
The College’s whole-school approach to safeguarding aims to mitigate against the risk of child-on-child/peer-on-peer abuse and also includes educating students to understand and recognise unacceptable behaviour and what to do about it, as well as the laws and Safeguarding Partnerships there to support and protect them, through the Year 11 PSHEE programme and the Year 12 Personal Tutoring programme. Within the scheme of work for these taught classes, lessons include: Consent and Healthy Relationships, as per RSHE education guidance, child-on-child/peer-on-peer abuse, anti-bullying and online risk and safety awareness.
8.7.2 Sexual violence and sexual harassment
Sexual violence and sexual harassment can occur between two students of any age and gender. It can also occur through a group of students sexually assaulting or sexually harassing another student or group of students. Students who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment too. Sexual violence and sexual harassment exist on a continuum and may overlap, they can occur online and offline (both physical and verbal), inside or outside the College, and are never acceptable.
8.7.2.1 Consent
Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given to one sort of sexual activity but not another. Consent can be withdrawn at any time during sexual activity and each time activity occurs. Someone consents to sexual activity only if he/she agrees by choice to that particular sexual act and has the freedom and capacity to make that choice.
8.7.2.2 Sexual violence
Sexual violence, which includes rape, sexual assault and assault by penetration, are criminal offences under the Sexual Offences Act 2003 for which perpetrators may face criminal investigation and charges.
8.7.2.3 Sexual harassment
Sexual harassment is ‘unwanted conduct of a sexual nature’ that can occur online and offline. It is likely to violate a student’s dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment. Sexual harassment may also lead to criminal investigations and charges, as per the Sexual Offences Act 2003.
Whilst not intended to be an exhaustive list, sexual harassment can include:
8.7.3 Who is most at risk of sexual violence and sexual harassment?
Any report of sexual violence or sexual harassment must be taken very seriously. Staff should be aware, however, that some groups are potentially more at risk to sexual violence and sexual harassment. Evidence shows girls, students with SEND and students who identify as members of the LGBTQ+ community are at greater risk.
The DSL, who works closely with the access arrangements team, ensures that all SEND students are on the safeguarding database and that they receive the appropriate level of support. For more information about the support Ashbourne provides to SEND students please refer to the College’s SEND and Access Arrangements Policy.
Staff should also be aware that perpetrators of sexual violence and sexual harassment are more likely to be boys, and should be alert to related safeguarding factors that may lead them to behave in such a way.
8.7.4 How students can raise concerns and/or allegations about their own experiences and/or those of others.
All concerns and/or allegations of sexual violence and sexual harassment will be taken seriously and dealt with sensitively, with appropriate and timely action and support.
8.7.5 Responding to concerns and/or allegations
In the event of disclosures about child-on-child/peer-on-peer abuse, all students involved (both alleged victim and alleged perpetrator) will be treated as being at risk, and safeguarding procedures in accordance with this policy will be followed. Victims will be supported by the DSL and support from external agencies will be sought, as appropriate.
When there has been a report of sexual violence, the DSL will make an immediate risk and needs assessment. Where there has been a report of sexual harassment, the need for a risk assessment should be considered on a case-by-case basis. The risk and needs assessment should consider:
Risk assessments will be recorded and kept under review. In relation to a report of sexual violence or sexual harassment, the DSL will reassure any victim that they are being taken seriously and that they will be supported and kept safe. The victim will never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment; nor would a victim ever be made to feel ashamed for making a report. The DSL will consider the risks posed to students and put adequate measures in place to protect them and keep them safe. This may include consideration of the proximity of the victim and alleged perpetrator and considerations regarding shared classes, and sharing College premises.
A student against whom an allegation of abuse has been made may be neutrally suspended from the College during the investigation. The College will take advice from CSC on the investigation of such allegations and will take all appropriate action to ensure the safety and welfare of all students involved including the alleged victim and perpetrator. If it is necessary for a student to be interviewed by the Police in relation to allegations of abuse, the College will ensure that, subject to the advice of CSC, parents are informed as soon as possible and that the students involved are supported during the interview by an appropriate adult and until the investigation is completed. Confidentiality will be an important consideration for the College and advice will be sought as necessary from CSC and other external agencies (e.g. the Police) as appropriate.
Where an allegation of sexual abuse, exploitation or grooming is made against a student, both the victim and the alleged perpetrator will be treated as being at risk and safeguarding procedures in accordance with this policy will be followed.
8.8 The sharing of youth produced sexual imagery (sexting)
The practice of students sharing images and videos via text message, email, social media or mobile messaging apps has become commonplace. However, this online technology has also given students the opportunity to produce and distribute sexual imagery in the form of photos and videos. Such imagery involving anyone under the age of 18 is illegal.
Sexting refers to both images and videos where:
All incidents of this nature should be treated as a safeguarding concern and in line with the UKCCIS guidance ‘Sexting in schools and colleges: responding to incidents and safeguarding young people’.
Cases where sexual imagery of people under 18 has been shared by adults and where sexual imagery of a person of any age has been shared by an adult to a child is child sexual abuse and should be responded to accordingly.
If a member of staff becomes aware of an incident involving sexting they should follow the safeguarding procedures outlined in section 3 above and refer this information immediately to the DSL. The member of staff should confiscate the device involved and set it to flight mode or, if this is not possible, turn it off. Staff should not view, delete, copy or print the imagery.
The DSL should hold an initial review meeting with appropriate staff members and subsequent interviews with the students involved (if appropriate). Parents should be informed at an early stage and involved in the process unless there is reason to believe that involving parents would put the student at risk of harm. At any point in the process if there is concern a young person has been harmed or is at risk of harm, staff should refer to the DSL who contact CSC to make referrals where appropriate.
Immediate referral at the initial review stage should be made to CSC if:
If none of the above applies then the DSL will use their professional judgement to assess the risk to students. This may involve consultation with CSC, other external agencies (e.g. the Police) and members of the Safeguarding Team.
In applying judgement the DSL will consider if:
If any of these circumstances are present the situation will be escalated according to our safeguarding procedures, including reporting to the police or CSC. Otherwise, the situation will be managed within the College.
The DSL will log all incidents of sexting, including both the actions taken, actions not taken, reasons for doing so and the resolution, onto Ashbourne’s Safeguarding database.
8.9 Child criminal exploitation (county lines)
Criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity: organised criminal networks or gangs groom and exploit children and young people to carry illegal drugs and money from urban areas to suburban and rural areas, market and seaside towns. Key to identifying potential involvement in county lines are missing episodes, when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism should be considered. Like other forms of abuse and exploitation, county lines exploitation:
County Lines Toolkit For Professionals are available from The Children’s Society in partnership with Victim Support and National Police Chiefs’ Council.
8.10 Children and the court system
Students are sometimes required to give evidence in criminal courts, either for crimes committed against them or for crimes they have witnessed. There are age appropriate guides to support students (12-17 year olds) available on the gov.uk website.
The guides explain each step of the process and support and special measures that are available. There are diagrams illustrating the courtroom structure and the use of video links is explained.
Making child arrangements via the family courts following separation can be stressful and entrench conflict in families. This can be stressful for children. The Ministry of Justice has launched an online child arrangements information tool with clear and concise information on the dispute resolution service. The College may refer some parents and carers to this service where appropriate.
8.11 Children with harmful behaviour
There will be occasions when students’ behaviour warrants a response under child protection rather than anti-bullying procedures. All such instances must be reported to the DSL and will be dealt with in accordance with the procedures set out in point 3.
The management of children and young people with harmful behaviour (including sexually harmful behaviour) can be complex and the College will work with other relevant agencies to maintain the safety of the whole College community. Young people who display such behaviour may be victims of abuse themselves and the child protection procedures will be followed for both victim and perpetrator – i.e. all students involved will be treated as being “at risk”.
Students against whom an allegation of abuse has been made may be neutrally suspended from the College during the investigation. The College will take advice from CSC on the investigation of such allegations and will take all appropriate action to ensure the safety and welfare of all students involved including the students accused of abuse.
If it is necessary for a student to be interviewed by the police in relation to allegations of abuse, the College will ensure that, subject to the advice of CSC, the student’s parents are informed as soon as possible and that the student is supported during the interview by an appropriate adult. In the case of students whose parents are abroad, subject to separately satisfied risk assessments for the student and an identified Education Guardian, the student’s Education Guardian will be requested to provide support to the student and to accommodate them if it is necessary to suspend them during the investigation.
8.12 Upskirting
‘Upskirting’ became a specific criminal offence under the Voyeurism (Offences) Act 2019 on 12 April 2019.
It typically involves taking a photograph under a person’s clothing (not necessarily a skirt) without their permission or knowledge, with the intention of viewing their genitals or buttocks (with or without underwear) for sexual gratification or causing humiliation, distress or alarm. Anyone of any gender can be a victim. The revised version of Keeping Children Safe in Education lists upskirting as one example of child-on-child/peer-on-peer abuse of which school staff should be aware.
Appendix 1 – Signs and types of abuse
A1.1 Physical abuse
A1.2 Emotional abuse
A1.3 Sexual abuse
A1.4 Neglect
A1.5 Psychological abuse
A1.6 Self-neglect
A1.7 Discriminatory abuse
A1.8 Teenage relationship abuse
All College staff should be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. In most cases, multiple issues will overlap with one another.
A1.1 Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
A1.2 Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.
A1.3 Sexual abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. Sexual abuse also includes sexual violence and sexual harassment which can occur between two children of any sex. They can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children. Sexual violence are sexual offences under the Sexual Offences Act 2003, such as rape, sexual assault and assault by penetration. Sexual harassment is ‘unwanted conduct of a sexual nature’ that can occur online and offline. Sexual harassment is likely to violate a child’s dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment. Sexual harassment can include sexual comments, such as telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance and calling someone sexualised names; sexual “jokes” or taunting; physical behaviour, such as deliberating brushing against someone, interfering with someone’s clothes and displaying pictures, photos or drawings of a sexual nature; and online sexual harassment, which might include non-consensual sharing of sexual images and videos and sharing sexual images and videos (both often referred to as sexting); inappropriate sexual comments on social media; exploitation; coercion and threats. Online sexual harassment may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence.
A1.4 Neglect: the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
A1.5 Psychological abuse – includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse or isolation.
A1.6 Self-neglect – is not a direct form of abuse but staff need to be aware of it in the general context of risk assessment/risk management and to be aware that they may owe a duty of care to a vulnerable individual who places him/herself at risk in this way. Risk to self and/or others – This may include but is not exclusive to self-harm, suicidal tendencies or potential risk of harming others, which may or may not include children. This may be as a consequence of an individual experiencing a significant level of personal, emotional trauma and/or stress and mental health issues.
A1.7 Discriminatory abuse – includes racism, sexism or discrimination based on a person’s disability. Financial or material abuse – includes theft, fraud, exploitation, pressure in connection with wills, property, enduring power of attorney, or inheritance or financial transactions, or the inappropriate use, misuse or misappropriation of property, possessions or benefits. Safeguarding – includes promotion of health and well-being as well as protection of specific individuals.
A1.8 Teenage relationship abuse – Teenage relationship abuse is a pattern of actual or threatened acts of physical, sexual, and/or emotional abuse, perpetrated by an adolescent (between the ages of 13 and 18) against a current or former partner. Abuse may include insults, coercion, social sabotage, sexual harassment, threats and/or acts of physical or sexual abuse. The abusive teen uses this pattern of violent and coercive behaviour, in a heterosexual or same gender relationship, in order to gain power and maintain control over the partner. This abuse may be child sexual exploitation.
Appendix 2: Role of the Designated Safeguarding Lead (DSL)
A2.1 Designated Safeguarding Lead
A2.2 Deputy Designated Safeguarding Lead (DDSL)
A2.3 DSL key responsibilities
A2.3.1 Managing referrals
A2.3.2 Work with others
A2.3.3 Training
A2.3.4 Raising awareness
A2.3.5 Keeping safeguarding information secure: child protection file
A2.3.7 Availability
When compiling this role, the College has referred directly to the KCSIE document.
A2.1 Designated Safeguarding Lead
The Designated Safeguarding Lead (DSL) at Ashbourne College takes responsibility for all safeguarding and child protection (including online safety) issues at the College. As a member of the Senior Leadership Team (SLT), the DSL has the appropriate status and authority within the College required to carry out the duties of this post. The DSL is given the time, funding, training, resources and support necessary in order to provide advice and support to other staff on student welfare and child protection matters, to take part in strategy discussions and inter-agency meetings, and/or to support other staff to do so, and to contribute to the assessment of students.
A2.2 Deputy Designated Safeguarding Lead (DDSL)
The DSL is supported the Deputy Designated Safeguarding Lead who is trained to the same standard as the DSL. Whilst the activities of the DSL can be delegated to deputies, the ultimate lead responsibility for child protection, as set out in this policy, remains with the DSL; this lead responsibility should not be delegated.
A2.3 DSL key responsibilities:
A2.3.1 Managing referrals
The DSL is expected to:
The DSL has the discretionary powers to contact the Local Authority Designated Officer on any matter the DSL considers cannot be properly dealt with internally, as well as to seek external advice from appropriate companies or legal services.
A2.3.2 Work with others
The designated safeguarding lead is expected to:
A2.3.3 Training
The DSL, and any deputies, will undergo training to provide them with a good understanding of their own role, and the processes, procedures and responsibilities of other agencies, particularly children’s social care, so they have the knowledge and skills required to carry out the role. The DSL will also undertake Prevent awareness training. Such training, which will be updated at least every two years, will enable the DSL (and deputies) to:
In addition to the formal training set out above, their knowledge and skills should be refreshed (this might be via e-bulletins, meeting other DSLs or simply taking time to read and digest safeguarding developments) at regular intervals, as required, and at least annually, to allow them to understand and keep up with any developments relevant to their role.
A2.3.4 Raising awareness
The DSL should:
A2.3.5 Keeping safeguarding information secure: child protection file
Throughout the academic year the DSL will maintain detailed, accurate and secure written records of concerns and referrals on the safeguarding database.
Where children leave the College the DSL should ensure their Child Protection File is transferred to the new school or college as soon as possible. This should be transferred separately from the main student file, ensuring secure transit, and confirmation of receipt should be obtained. These files will then be deleted. Receiving schools and colleges should ensure key staff such as DSLs and SENDCos or the named person with oversight for SEND in colleges, are aware as required.
In addition to the child protection file, the DSL should also consider if it would be appropriate to share any information with the new school or College in advance of a child leaving. For example, information that would allow the new school or college to continue supporting victims of abuse and have that support in place for when the child arrives.
In line with our Data Protection Policy, all child protection files will be held by the College until the student’s 25th birthday, after which the files will be destroyed.
A2.3.7 Availability
During term time the DSL (or a deputy) should always be available (during College hours) for staff in the College to discuss any safeguarding concerns. Whilst generally speaking the DSL (or deputy) would be expected to be available in person there may be occasions and circumstances where communication can be made via phone or other secure and acceptable online communication media.
Ashbourne’s regular safeguarding support takes place during term time only. However, in order to offer clear guidance to our students and their families/carers we advise them on where to access emergency support, if required, during school holidays and out of hours. During all official holidays, the Out of Hours Statement is clearly displayed on the College website.
Appendix 3: Role and duties of the Nominated Safeguarding Director
The NSD takes leadership of the College’s safeguarding arrangements on behalf of the Senior Leadership Team and liaises with external agencies where this is required, including in the event of allegations of abuse made against the Principal.
The NSD will play an essential role in ensuring students are kept safe from harm. If the NSD is unavailable the role and duties will be carried out by the Principal, except in a case where is an allegation of abuse made against the Principal. In these cases, the LADO will undertake responsibility.
The NSD and the Principal will undertake appropriate training in accordance with the Local Safeguarding Children Board’s recommendations to fulfil the role and duties.
The main role and duties of the Nominated Safeguarding Director are to:
The Nominated Safeguarding Director will liaise with the Principal and the local authority regarding all confidential child protection issues involving allegations against staff.
Where there is an allegation of abuse against the Principal, the Nominated Safeguarding Director will take the lead in liaising with the local authority and/or other partner agencies including:
Appendix 4: Additional external contacts
CEOP – Child Exploitation and Online Protection Command
CCE – Child Criminal Exploitation
Child – Relevant legislation and guidance consistently makes reference to ‘child’ or ‘children’. As noted earlier, Ashbourne has students up to the age of 21. Therefore, where any statute or guidance makes reference to ‘child’, this policy will refer to ‘student’ as a reference to Ashbourne’s commitment to safeguarding all students.
However, when handling individual safeguarding cases the DSL will always consider carefully the age of the student in terms of any safeguarding decisions made. In these cases, the following shall be noted in reference to ‘child’, ‘ Young people aged 18+’ and ‘ Vulnerable Adult’:
If the College receives information about an adult student (18 plus) which suggests that he/she has been abused or that it is likely they may be abused, it has a duty to refer these concerns to Adult Services and/or the Police. If the College is unsure whether a referral is necessary, the DSL will consult with appropriate agencies, which is usually Adult Care Services.
CSC – Children’s Social Care
CSE – Child Sexual Exploitation
DSL – Designated Safeguarding Lead
DDSL – Deputy Designated Safeguarding Lead
LADO – Local Authority Designated Officer
Low-level concerns – concerns that do not meet the harms threshold yet require investigation
LSCB – Local Safeguarding Children Board
MASH Team – Multi-Agency Safeguarding Hub
NSD – Nominated Safeguarding Director
PT – Personal Tutor
RBKC – Royal Borough of Kensington and Chelsea
SEND – Special educational needs and disability
SLT – Senior Leadership Team
Staff Members – This refers to any employee at the College, whether that be the Principal or other including supply staff, volunteers, contractors or NSD.
RSE – Relationship and Sex Education
TRA – Teaching Regulation Agency
UKCCIS – UK Council for Child Internet Safety
Appendix A: Vulnerable students with an EHCP