Safeguarding & Child Protection Policy
Including prevent duty
The terms ‘safeguarding’ and ‘child protection’ mean different things to different people. The Welsh Government has defined the terms as follows:
Safeguarding and promoting the welfare of children includes:
• protecting children from abuse and neglect;
• preventing impairment of their health or development;
• ensuring they receive safe and effective care, to enable them to have optimum life chances.
(All Wales Child Protection Procedures 2008, p20)
Child protection is a part of safeguarding and promoting welfare. It refers to the activity, which is undertaken to protect specific children who are suffering or are at risk of suffering significant harm as a result of abuse or neglect (All Wales Child Protection Procedures 2008)
There are three main elements specifically regarding the safeguarding of children:
• prevention through the teaching and pastoral support offered to pupils;
• procedures for identifying and reporting cases, or suspected cases, of abuse. Because of our day-to-day contact with children, school staff are well-placed to observe the outwards signs of abuse;
• providing support to pupils who may have been abused.
There are other related policies and procedures that should be read alongside this document so as to help keep our pupils safe in a variety of circumstances (see list of related policies)
For the purpose of clarity, any reference to ‘staff’ within this document includes all adults who work for or with the School in any capacity.
This policy applies to all pupils in our School (including our Early Years Foundation Phase). It is addressed to all Governors, teaching and non-teaching staff (including School medical and nursing staff), volunteers working in the School and further or higher education students on placement, and will be given to parents and pupils on request. It is also included in the New Pupils’ Handbook in the Senior School and is available on the School’s website.
As well as applying to the list of people set out above, this policy imposes personal obligations upon them.
‘It is a fundamental principle that the protection of children from harm is the responsibility of all individuals working with children.’ (All Wales Child Protection Procedures 2008)
SAFEGUARDING EMBEDDED – A POSITIVE ETHOS
All children have the right to be safe in society; we have a duty to ensure that arrangements are in place for safeguarding and promoting the welfare of all children by creating a positive school atmosphere through:
• our teaching and learning, pastoral support and care for both pupils and School staff;
• establishing strong, positive relationships with parents which allow us to work in partnership to provide the best possible support for each pupil in our care;
• ensuring that all adults who work within the School are aware of, and committed to, their responsibilities regarding safeguarding and child protection;
• providing a safe and caring environment in which pupils can thrive and develop into confident, healthy, well-balanced and resilient individuals.
We are committed to maintaining an ethos where children and parents feel secure in being able to talk confidently to School staff about any concerns they may have, knowing that they will be taken seriously and treated with sensitivity.
Every pupil should feel safe and protected from any form of abuse. The safety and protection of pupils is the responsibility of all School staff and volunteers. We acknowledge that children can be abused physically, emotionally, sexually or by neglect. Keeping Learners Safe (Statutory Guidance for Wales) outlines safeguarding responsibilities in specific circumstances, including Radicalisation under the Prevent Duty (Appendix ii). It is our duty to report any concerns that we have of child abuse, as the health, safety and protection of all children is paramount.
Safeguarding against radicalisation and extremism is no different from safeguarding against any other vulnerability / abuse in today’s society. The Prevent Duty Guidance for England and Wales emphasises that the duty to have due regard for the need to prevent children from being drawn into terrorism is an aspect of safeguarding.
FGM is child abuse and is an illegal act, affecting girls particularly from North African countries, including Egypt, Sudan, Somalia and Sierra Leone. Although we consider girls in our School to be safe from FGM, we will continue to review our policy and to assess the risks annually.
On a practical day-to-day basis, safeguarding encompasses (but not exclusively) issues such as:
health and safety, medical and health care, first aid, School security, off-site visits, staff recruitment, visitors to the School, e-safety, anti-bullying, peer-on-peer abuse, drugs and substance misuse and physical contact with pupils etc. (see related Safeguarding Policies list – page 20).
Colleagues are referred to the guidance document for ‘Safeguarding responsibilities in specific situations’, chapter 4, which lists the circumstances of which to be mindful. Guidance can be found on the corresponding pages:
The School’s curriculum deals with safeguarding through activities and opportunities in PSHE / Citizenship and other subjects such as RS, English, Drama and ICT that will equip the pupils with the necessary skills and awareness to stay safe from abuse and to know to whom to turn for help. The School seeks to ‘educate against hate’, and all members of staff have a duty ‘actively to promote’ the ‘Fundamental British Values’ of democracy, the rule of law, individual liberty, and mutual respect and tolerance of those with different faiths and beliefs. These values were first set out by the government in the ‘Prevent’ strategy in 2011.
The aims of this policy are:
• to have in place procedures to ensure that we meet our responsibilities for safeguarding and promoting the welfare of children, and protecting them from abuse (including the Prevent Duty);
• to ensure that all School staff are aware of their duty, and what action to take when dealing with any child protection issue;
• to outline our commitment at Rydal Penrhos to take all reasonable measures to safeguard and promote the welfare of each pupil in our care.
We aim to do this by implementing procedures and systems:
• to raise awareness of this policy so as to ensure that all staff are aware of their responsibilities;
• to protect each pupil from any form of abuse, including peer-on-peer abuse;
• to train all staff to be alert to signs of abuse and to those pupils who may be vulnerable;
• to deal appropriately with every disclosure or suspicion of abuse;
• to support children who have been victims of abuse and / or exploitation;
• to work with others to provide the best level of care for those in need of additional support;
• to ensure that, where abuse is suspected by another child, child protection procedures are applied to both children;
• to address any other safeguarding issues which may be specific to an individual pupil or our local area, assessing the risk of radicalisation, FGM and also Breast Ironing;
• to operate robust and sensible Health & Safety measures;
• to take all practicable steps to ensure that School premises are as secure as circumstances permit;
• to operate clear and supportive policies on drugs, alcohol and substance misuse;
• to operate clear policies and robust measures relating to e-safety;
• to deliver a curriculum which promotes safety and wellbeing;
• to prevent unsuitable staff and volunteers from working with children and young people (including informing the appropriate bodies if it is discovered that any person connected to the School is considered to be unsuitable to work with children);
• to ensure that staff are aware of the expected code of professional conduct;
• to deal appropriately with any allegation of abuse by a member of staff, whether they took place on the School premises or elsewhere;
• to enable staff who have concerns about the conduct of any adult working in school to share this information;
• to ensure that teachers and others who are innocent are not prejudiced by false allegations.
Every complaint or suspicion of abuse from within or outside the School will be acted upon and will be referred to an external agency such as SSD, the CPU or the NSPCC, in accordance with the procedures published by Conwy and Denbighshire LSCB. Where there are concerns relating to radicalisation, this must be referred to the area Prevent Coordinator of the North Wales Police for advice.
Rydal Penrhos School has a statutory duty under section 175/157 of the Education Act 2002 to safeguard and promote the welfare of children. Under this duty, the School follows the guidance set out in:
• Keeping Learners Safe 158/2015 (the role of local authorities, governing bodies and proprietors of independent schools under the Education Act 2002);
• Safeguarding Children: Working Together Under the Children Act 2004;
• The Independent Schools Standards (Wales) Regulations 2003, as amended from time to time.
The procedures within this document take into account the All Wales Child Protection Procedures 2008, and give due regard to the statutory documents linked to all aspects of safeguarding within Wales and England.
• Welsh Office circular 158/2015 Keeping Learners Safe (which supplements the guidance in Safeguarding Children: Working Together Under the Children Act 2004);
• the Independent Schools Standards (Wales) Regulations (2003), Standard 3;
• the National Minimum Standards for Boarding Schools (2003);
• Welsh Government Circular No: 009/2014 Safeguarding Children in Education – Handling allegations of Abuse against teachers and other staff;
• the Counter-Terrorism and Security Act (2015 – Section 26, The Prevent Duty);
• the Social Services & Wellbeing Act, Wales (2014);
• Disqualification under the Childcare Act (2006 - Guidance published 2015);
• the Serious Crime Act (2015);
• the Female Genital Mutilation Act (2003);
• other requirements followed by the Welsh Government in its commitment to safeguard children and young people are those of:
o the Education Act (2002) s175/175;
o the Children Act (1989, as amended 2004, section 52);
o the United Nations Convention on the Rights of the Child (UNCRC) 1989, articles 12, 19, 28 and 29;
o the Equality Act (2010);
o the Rights of Children & Young Persons Measure, Wales (2011).
Additional reference material – England
• Keeping Children Safe in Education - DfE Statutory Guidance, (England - revised September 2016), especially Annex A;
• Guidance for Safer Working Practice for Adults who work with Children and Young People in Education (Safer Recruitment Consortium September 2015);
• Information sharing Advice for practitioners providing safeguarding services to children, young people, parents and carers, July 2018, HM Government.
The Governing Body:
The School’s Governing Body will ensure that:
• the School has in place a child protection policy and other related procedures that are:
o in accordance with local authority guidance and locally agreed inter-agency procedures;
o inclusive of services that extend beyond the school day;
o reviewed at least annually;
o made available to parents or carers on request;
o available in a format appropriate to the understanding of children.
• the School operates safe recruitment procedures that take account of the need to safeguard children and young people, including appropriate reference checks on new staff and volunteers who will work with children, including the relevant DBS checks;
• the School has in place procedures to deal with allegations of abuse against members of staff and volunteers, and that member(s) of the Governing Body are nominated for liaising with the Local Authority and other agencies as appropriate, in the event of allegations of abuse being made against the Principal / Head;
• the Principal / Head and all other permanent staff and volunteers who work with children have undertaken appropriate training necessary effectively to carry out their responsibilities with regard to safeguarding and protecting children, and that this is kept up-to-date by means of regular refresher training;
• temporary staff and volunteers providing short-term cover and who will be working with children and young people receive clear guidance regarding the School’s arrangements for child protection and their responsibilities;
• it remedies without delay any deficiencies or weaknesses in regard to child protection arrangements that are brought to its attention;
• the DSLs and the Designated Governors undertake basic and refresher training to keep their knowledge and skills up to date;
• the Principal / Head provides termly reports on safeguarding pupils in the School;
• a site safeguarding risk assessment is completed annually, in line with Health and Safety procedures;
• these policies and procedures are monitored for compliance.
The Designated Governors:
Two Governors have been designated to take responsibility for scrutinising the School’s Child Protection Policy and Procedures, including Prevent, alongside Safer Recruitment and other related policies, so as to ensure compliance with national and local regulations, arrangements and guidance.
The Designated Governors will:
• ensure that the Governing Body reviews the School’s safeguarding related policies and procedures and how those duties have been discharged annually (by means of reviews and audits);
• meet with the DSLs at least twice a year to review and to gain an insight into the practice and challenges facing the School on a practical level in relation to safeguarding matters, and to check annual safeguarding audits;
• take responsibility for the oversight of procedures relating to handling allegations against School staff and volunteers;
• undertake safeguarding training at least every three years.
The Principal / Head:
He or she will:
• ensure that there are DSLs who have undertaken the appropriate, enhanced training and support required for the role;
• provide adequate resources for the DSL to undertake his / her role;
• ensure that there is always a DSL available to deal with any safeguarding / child protection issues (including arrangements for holiday periods);
• work closely with the DSLs and Designated Governors for child protection;
• work with all members of the Governing Body to understand and to fulfil its responsibilities;
• monitor the effectiveness of this policy and report annually to the Governing Body on this matter;
• have read and fully understood the Welsh Government Guidance: circular No: 009/2014 – Safeguarding Children in Education – Handling allegations of abuse against teachers & other staff;
• ensure that DBS and / or other required checks are undertaken for everyone working (or volunteering) in the school;
• ensure that the procedures outlined in this document are implemented and followed;
• follow the procedure set out in the Welsh Government guidance circular: 009/2014 - (Handling allegations of abuse against teachers and other staff), when an allegation is made against a member of staff;
• ensure that the recruitment and selection procedures are made in accordance the requirements of National Minimum Standards for Boarding Schools (CSSIW 2003) – Standard 38, with Welsh Government Circular: 158/2015 Chapter 5 (Safer Recruitment Practice);
The Principal / Head will ensure that all staff (including Governors, supply teachers and volunteers):
• are aware of the School’s Safeguarding & Child Protection Policy and procedures, and related policies;
• know the names and contact details of the DSLs (and Deputy DSLs);
• know the names of the Designated Governors for Safeguarding & Child Protection;
• know that they have a legal duty and an individual responsibility to refer child protection concerns to the DSL within agreed timescales (or to a Deputy DSL, if the DSL is unavailable);
• know that they have a duty to follow up concerns and to make a referral to Social Services if necessary;
• can access sufficient resources to enable them to discharge their responsibilities;
• feel able to raise concerns about poor or unsafe practice (and will ensure that such concerns are addressed sensitively and effectively in accordance with the School’s Whistleblowing Policy);
• are provided with the School’s policy and procedures as part of their induction;
• undertake training in child protection procedures as part of their induction, and receive training and updates in safeguarding and child protection regularly (formally, at least every 3 years) and to meet statutory training requirements).
The Principal / Head will ensure that parents have an understanding of the responsibility placed on the School and staff for child protection by setting out its obligations in the School prospectus, website, handbooks and other such documents or leaflets.
The Designated Safeguarding Leads:
The school has appointed three senior members of staff (Designated Safeguarding Leads / DSLs) and at least two Deputy DSLs to be responsible for matters relating to child protection and welfare.
The DSLs will deputise for each other if either is absent from School.
The Designated Safeguarding Leads will:
• be trained in child protection policy and procedures, and renew the enhanced training required for this role at least every two years, and will undertake other activities to update their knowledge / understanding at least annually;
• undergo Prevent / WRAP or other appropriate training as required and will keep up to date with all new guidance on safeguarding children;
• be available on the School site, or ensure that appropriate arrangements are in place in their absence, to ensure safeguarding / child protection issues are dealt with by a trained and named Deputy DSL;
• work with other DSLs to help keep all School staff up to date with any changes to procedures;
• assist with the organisation of appropriate training for School staff and governors (including Prevent awareness);
• work with other DSLs to help maintain an ongoing training programme for all School employees, including induction (to include Prevent);
• annually review the policy with the Principal / Head, DSLs and Designated Governors;
• ensure the implementation of this policy and that everyone connected with the School is aware of this policy;
• familiarise School staff with the policy and procedures;
• ensure that pupils are made aware of:
o basic safeguarding procedures in School, such as visitors signing in and wearing visitor badges;
o how to keep themselves safe in various situations (including online / Internet safety and responding to bullying);
o opportunities in forums such as the School Council to review the Anti-Bullying Policy and the School Rules, and to raise safeguarding concerns;
• coordinate the child protection procedures within their department in the School;
• be a point of contact for pupils, teaching and non-teaching staff, parents, and external agencies in all matters of child protection and the Prevent Duty, and act as a source of advice within their department;
• advise and act upon all cases of suspected or actual problems associated with child protection (including radicalisation) which are reported to him / her;
• provide support for any child at risk;
• ensure all incidents are recorded, reported and kept confidential, and monitor the keeping, confidentiality and storage of records relating to child protection in locked locations;
• make and record child protection referrals (including those under the Prevent Duty);
• keep a confidential Child Protection Register of all those pupils known to be at risk;
• transfer the child protection file of any pupil leaving to join another school;
• ensure that the transfer of a child protection file for any pupil joining their department in School is requested upon entry;
• work closely with the Principal / Head and the Designated Governors and keep them informed as to all actions, unless the Principal / Head is the subject of a complaint;
• liaise and seek advice from the Duty Social Services’ Team or LADO (equivalent) when the need arises;
• liaise with local Prevent Coordinators, North Wales Police, and local authorities and through existing multi-agency forums, including referrals to the Channel Police Practitioner when required.
In order to establish strong, positive partnerships with parents, the DSL will also:
• ensure that parents have access to this policy;
• respect parents’ and children’s need for privacy and deal with all concerns with sensitivity and confidentiality (as appropriate);
• respect families from different backgrounds and cultures, as long as it does not put the child at risk;
• when making a referral, share all information with parents unless there is potential for this to place the child at risk. (Advice may be sought from the SSD or Prevent contacts of the North Wales Police before making a referral.)
The Deputy DSL will undertake appropriate training and will attend refresher training at 2-yearly intervals.
School Staff & Volunteers:
All staff have a legal duty to record and report any child protection problems, concerns or suspicions to the DSL as soon as it is identified and practically possible, and in any case within 24 hours to Social Services. This is not a matter of individual choice. There is a legal duty to record and report your concerns on the day the allegation / concern has been raised.
School staff and volunteers should:
• understand their role and responsibilities to safeguard and promote the welfare of children;
• be familiar with the School’s procedures and protocols for safeguarding and promoting the welfare of children;
• have access to and comply with the All-Wales Child Protection Procedures;
• understand the principles and practice contained in Keeping Learners Safe 2015 and the Social Services and Wellbeing Act 2014/2016;
• know whom to contact to express concerns about a child’s welfare;
• know when and how to refer any suspected case of harm or abuse to the DSL;
• know when and how to refer any suspected case of harm or abuse to Social Services or the police;
• undertake appropriate training regularly to a level commensurate with their role, including updates and formal refresher training at 3-yearly intervals to identify signs of harm and abuse, including indicators of vulnerability to radicalisation and how to respond to a child;
• know that it is their legal duty to ensure that any knowledge, concerns or suspicions that a child is, has or is likely to be at risk of harm is referred to Social Services or the Police, who have statutory duties and powers to make enquiries and intervene when necessary;
• know that a child, parent, caregiver, relative or member of the public who expresses concerns about a child’s welfare to a professional and / or agency employee must never be asked to make a self-referral to Social Services or the Police. The professional and / or agency employee (staff member or school) must make the referral;
• be alert at all times to the indicators of abuse or neglect and the risks which individual abusers or potential abusers may pose to children;
• be aware of the impact and effects of abuse and neglect on children;
• work co-operatively with the parents, unless this is inconsistent with the need to ensure the child’s safety;
• recognise when a parent or carer has problems which may affect their capacity to provide effective or appropriate care, or which may mean they pose a risk of harm to a child;
• share and help to analyse information so that an informed assessment can be made of the child’s needs and circumstances;
• contribute, as necessary, at all stages of the Child Protection process;
• contribute to the regular review of the outcomes for the child, against specific shared objectives;
• be committed to full co-operation with all other agencies in the interests of safeguarding children;
• ensure that they conduct themselves correctly at all times and do not put themselves at risk.
This is not a matter for individual choice. The suspected abuse of a child must be reported to Social Services or the Police, who are the agencies, together with the NSPCC, with statutory powers to investigate suspected abuse. The School must not undertake its own internal child protection enquiries, but should refer its concerns. If the concern involves a member of staff, procedures must be followed as per the Welsh Government Circular No: 009/2014 Safeguarding Children in Education – Handling allegations of abuse against teachers and other staff.
Pupils must be made aware of:
• basic safeguarding procedures in School, such as visitors signing in and wearing visitor badges;
• what they should do and to whom they can talk if they have any concerns or worries;
• how to keep themselves safe in various situations (including online / Internet safety and responding to bullying) (see PSHE Policy and Programme).
Awareness is raised through the PSHE curriculum, School assemblies, sessions with the School Liaison Police Officer and posters around the School.
The School will ask the views of all pupils by issuing a questionnaire and asking age-appropriate questions such as:
• do they feel safe in School?
• are they aware of basic safeguarding procedures in School/ who to talk to if they are worried or upset at school?
• do they know to whom they should go if they are concerned about their own safety or that of others?
• does the school help them to understand and respect people who are different from them?
• are they aware of e-safety?
• are they aware of how to keep themselves safe?
• do they know how to keep themselves safe outside School?
• do they know how to keep themselves safe when using the Internet?
• asked to work in partnership with the School in order to establish excellent home-school relationships by sharing all information which will help to promote the welfare of their child;
• made aware that we have a responsibility for the welfare of all our pupils;
• made aware that we have a duty to involve Social Services if we have any concerns about a child;
• made aware they will be informed of our actions (either by the DSL or SSD, depending on the circumstances surrounding the referral).
Through a parental questionnaire, annually we will ask parents if:
• they have concerns about the safety of their child when in School;
• enough time is given for children to learn how to keep safe;
• they know to whom to talk if they have any concerns;
• their views are listened to and acted upon.
EARLY IDENTIFICATION & INTERVENTION
A proactive approach to identifying and providing early help and support for children is more effective in promoting their welfare and providing for their needs than reacting later. We are particularly alert to the potential requirement for early help for vulnerable children, such as those who are disabled or have specific additional needs or those who show signs of engaging in antisocial or criminal behaviour or whose family circumstances present particular challenges (e.g. substance abuse, adult mental health, domestic violence, and/or who is showing early signs of abuse and / or neglect).
Staff must work together (and with other agencies when required) in order to provide children with the best possible help and support systems (see Appendix 1 for types and signs of abuse and neglect).
Knowing what to look for is vital to the early identification of abuse and neglect. If staff members are unsure and have any concerns (no matter how insignificant they may feel these could be), they should always speak to the DSL, or in their absence, the Deputy DSL. It may be that their observation is one amongst a set of observations being passed to the DSL which are starting to piece together a bigger ‘picture’ of concern for an individual (see Referral Process Flowchart 1 AWCPP, at Appendix 6.)
All staff must read and understand the procedures set out in this policy which reflect the AWCPP. If it is thought that a crime has been committed and / or a child is at immediate risk, the police should be notified without delay.
An important aspect of keeping children safe in School is the maintenance of a positive culture which supports early identification of abuse and neglect, so that cases of children who may be in need of help or protection are responded to as early as possible. Staff are advised to maintain an attitude of, ‘It could happen here’. To this end, we also have clear whistleblowing procedures to which reference is made in staff training, including induction, along with our Staff Code of Conduct.
These processes are in place to ensure that issues about safeguarding and promoting the welfare of children are addressed in our School by all staff who must feel able to raise concerns, and feel supported in their safeguarding roles.
GUIDANCE & PROCEDURES FOR REPORTING & RECORDING CONCERNS
The School will comply with the All Wales Child Protection Procedures (AWCPP) 2008 that have been endorsed by the LSCB. A copy of these procedures can be found on the School’s intranet at T:\Whole School\Policies\Pastoral\Child Protection Policy and Related Documents\All-Wales-Child-Protection-Procedures-2008 (1).pdf
A. A PUPIL MAKES DISCLOSURE – if a pupil informs a member of staff that they or another young person are being abused:
- Do show the pupil that you have heard what he / she is saying and that their allegations are being taken seriously.
- Do encourage the pupil to talk and reassure them that they are doing the right thing in telling someone.
- Do explain what actions will be taken / how you are going to help in a way that is appropriate to the age and understanding of the pupil.
- Do ask the DSL what action he / she intends to take and record the response. If you are not satisfied with the action taken, challenge the decision or consult with Social Services.
- Do write down as soon as you can (no later than 24 hours) what you have been told in the form of a “Contemporaneous Note”, using the exact words if possible (making note of the date, time, place and people who were present at the discussion, including what you did and the response that you received).
- Do make sure the relevant emergency service is informed (if the pupil is in danger or needs medical attention).
- Do review any action taken.
- Do not interrupt when the pupil is recalling significant events, ask leading questions, or make the pupil repeat their account.
- Do not promise to keep what they have been told secret or confidential. (Adults have a responsibility to disclose information to those who need to know: reporting concerns is not a betrayal of trust.)
- Do not investigate or make judgments. To do so could create serious problems at later stages of any legal proceedings.
- Do not allow any shock or distaste to show.
- Do not confront the alleged abuser.
- Do not worry that you may be mistaken. Concerns will always be taken seriously by Social Services. It is better to have discussed it with somebody with the experience and responsibility to make an assessment
- Do not ask the pupil to remove or adjust clothing if bruises are observed.
- Do not delay emergency action to protect a young person - a failure to act may lead to a more serious outcome.
RESPOND, RECORD, REPORT AND REVIEW
B. A MEMBER OF STAFF SUSPECTS ABUSE – if he or she has concerns about a child or suspects that a child may be a victim of abuse then they should:
Make a record in an accurate, concise and clear form.
INFORM THE DSL
Immediately inform the DSL (or as soon as practical, provided the child is not at immediate risk of danger).
Submit a CPOMS alert (or appropriately completed ‘Cause for Concern Form’ if not registered on CPOMS) to the DSL as soon as practical, by the end of the same day, and no later than 18 hours after the concerns were raised, if this was towards the end of a day or in the evening.
The DSL will usually decide whether to make a referral to Social Services.
It is important to note: any staff member can refer their concerns to Social Services directly, (e.g. in an emergency or if there is a concern that the appropriate action has not been taken by the DSL).
The DSL will immediately refer to Social Services in cases where it is considered a child:
a) has suffered significant harm or is likely to do so;
b) may have suffered abuse.
The DSL will review the action taken and feed back to the member of staff who submitted an alert or CfC on the procedure followed / action taken.
In the case of suspicion of radicalisation, the DSL will refer to the Prevent Coordinator, North Wales Police and to Social Services
In the case of suspected or disclosed FGM, this will be reported to the Police and Social Services immediately.
In the case of suspected or disclosed peer-on-peer abuse, the School will refer to the Anti-Bullying Policy and to the guidance document on peer-on-peer abuse.
C. A PARENT MAKES A DISCLOSURE - if he or she makes a disclosure to the School, the Designated Safeguarding Lead:
DSL MEETS WITH PARENT
DSL will assure the parent that the School will take the matter seriously and explain
that he / she will have to take advice from the Duty Social Services Team about the disclosure.
DSL RECORDS DETAIL
DSL will log this onto CPOMS.
DSL SEEKS ADVICE FROM SOCIAL SERVICES
DSL follows their advice and the AWCPP
DSL CONTACTS PARENT
DSL informs them of the advice and the decision / action to be taken.
REPORTING TO THE DESIGNATED SAFEGUARDING LEAD
If staff members are unsure, they should always speak to the DSL. In exceptional circumstances, such as in an emergency where there is a risk of immediate serious harm to a child or a genuine concern that appropriate action has not been taken, staff members can speak directly to Social Services.
The DSL, in consultation with the Head of the School, will usually decide whether to make a referral to Social Services, but it is important to note that any staff member can refer their concerns to Social Services directly. If the child’s situation does not appear to be improving, the staff member with concerns should press for reconsideration of a referral. Concerns should always lead to help for the child.
GUIDANCE & PROCEDURES FOR REPORTING INFORMATION
All concerns about child protection (including those relating to suspected radicalisation) must be reported in writing (via CPOMS, or by using a Cause for Concern Form or Radicalisation & Extremism Cause for Concern Referral, as appropriate):
• if a disclosure is made by a child, the adult must make an appropriate written record of the conversation;
• any record should include the date, time and place of the conversation, and the essence of what was said and done by whom and in whose presence;
• observed injuries or bruises, if applicable, should be noted on the written record or CPOMS form;
• the record should be dated and signed by the person making it, and should use names rather than initials;
• any paper record must be kept securely and handed to the DSL;
• all information should be treated confidentially and sensitively;
• the DSL may seek advice from the Duty Social Services Team, LADO / Area Manager or Prevent Coordinator, North Wales Police;
• any paper records will be kept securely and / or uploaded to related CPOMS records.
ACTION BY THE DESIGNATED SAFEGUARDING LEAD
The action to be taken will take into account the procedures in the All Wales Child Protection Procedures 2008, Keeping Learners Safe; and Working Together Under the Children Act 2004, as published by the Welsh Assembly Government.
The School will not undertake its own child protection inquiry, but will refer the disclosure or concerns. If the matter involves a member of staff, the School must not make its own internal decision about whether it is a disciplinary issue or a child protection matter.
If there is room for doubt as to whether a referral should be made, the DSL may consult with the SSD or other appropriate professionals on a no-name basis without identifying the family. However, as soon as a problem, suspicion or concern about a pupil becomes apparent, a referral will be made without delay, and certainly within 24 hours.
If the initial referral is made by telephone, the DSL will confirm the referral in writing to SSD within 48 hours. If no response or acknowledgement is received within 3 working days, the Designated Safeguarding Lead must contact Social Services again (see flowchart for the referral process, All Wales Child Protection Procedures 2008).
INVOLVEMENT OF PARENTS OR CARERS
The School will discuss any concerns about a child’s welfare with the family and, where possible, seek their agreement to making a referral to Social Services. However, this will not be done where it would put the child at risk.
The child’s views should be considered in deciding whether to inform the family, particularly where the pupil is sufficiently mature to make informed judgements about the issues.
Where there are doubts or concerns about involving the family, the DSL will clarify with the external agencies as to whether and how the family should be told about the referral.
SUPPORT & COUNSELLING
Mechanisms are in place for any child who is at risk, to support and help build their self-esteem and confidence.
School staff and volunteer helpers who feel distressed as a result of being involved with a case or incident will / may receive support and counselling.
The School has a Counselling Service in which the welfare of pupils is the over-riding consideration. Any pupil who is worried about their work, activities or relationships is encouraged to seek counselling help.
Appropriate people from whom pupils may seek support are:
- Housemaster / Housemistress
- Head of Key Stage;
- Form Tutor
- the Health Centre
- another teacher
- the Chaplain;
- the Deputy Head or Head of Pastoral Care
- the School’s Independent External Counsellor
- the Principal / Head of Senior School / Head of Prep School;
THE SEVEN GOLDEN RULES FOR INFORMATION-SHARING
(Advice for the DSL or anyone needing to make a referral.)
1. Remember that the General Data Protection Regulation (GDPR), Data Protection Act 2018 and human rights law are not barriers to justified information sharing, but provide a framework to ensure that personal information about living individuals is shared appropriately.
2. Be open and honest with the individual (and / or their family where appropriate) from the outset about why, what, how and with whom information will, or could be shared, and seek their agreement, unless it is unsafe or inappropriate to do so.
3. Seek advice from other practitioners, or your information governance lead, if you are in any doubt about sharing the information concerned, without disclosing the identity of the individual where possible.
4. Where possible, share information with consent, and where possible, respect the wishes of those who do not consent to having their information shared. Under the GDPR and Data Protection Act 2018, you may share information without consent if, in your judgement, there is a lawful basis to do so, such as where safety may be at risk. You will need to base your judgement on the facts of the case. When you are sharing or requesting personal information from someone, be clear of the basis upon which you are doing so. Where you do not have consent, be mindful that an individual might not expect information to be shared.
5. Consider safety and well-being: base your information sharing decisions on considerations of the safety and well-being of the individual and others who may be affected by their actions.
6. Necessary, proportionate, relevant, adequate, accurate, timely and secure: ensure that the information you share is necessary for the purpose for which you are sharing it, is shared only with those individuals who need to have it, is accurate and up to-date, is shared in a timely fashion, and is shared securely.
7. Keep a record of your decision and the reasons for it – whether it is to share information or not. If you decide to share, then record what you have shared, with whom and for what purpose.
HM Government: Information-Sharing Advice for practitioners providing safeguarding services to children, young people, parents and carers - July 2018
CONFIDENTIALITY & SECURITY OF INFORMATION
It is imperative that confidentiality is observed at all times, as the protection, health and wellbeing of the child are paramount. However, the duty of confidentiality is not absolute and may be breached where this is in the best interests of the child and in the wider public interest.
School staff have a professional responsibility to share information with other professionals who are investigating a case.
A child, when confiding information to a member of staff, must be made aware that, for the child’s own sake, this information cannot be kept secret if the child is at risk of or suffering significant harm.
All child protection records are regarded as confidential and will be kept in a secure place.
All evidence (for example, scribbled notes, and mobile ‘phones containing text messages, clothing, and computers), must be safeguarded and preserved. Whilst notes can be uploaded / logged on to CPOMS, original written notes of evidence must be preserved. Ideally, it is recommended that contemporaneous notes be taken.
PUPILS TRANSFERRING TO ANOTHER SCHOOL
The following procedures will take place if a pupil on the child protection register transfers to another school:
• the case social worker will be contacted by the Designated Safeguarding Lead;
• child protection records will be passed on to the Designated Safeguarding Lead at the receiving school, but only if that school is in the same Local Authority;
• if the child is moving to another Local Authority, then information will only be passed on with outline details of case conferences, but not with minutes of conferences;
• the School will request any relevant information upon transfer.
In-house training is organised or delivered by a DSL who has received accredited NSPCC training. Other appropriate accredited agencies will be brought in to deliver more comprehensive, higher-level or focused training sessions to School staff, volunteer helpers and governors when required.
Training is provided:
• on induction to the School (including during NQT induction);
• at appropriate times throughout the academic year to keep staff up to date with current safeguarding matters.
All School staff must undertake appropriate training at least every three years in:
• recognising the signs of abuse;
• handling disclosures;
• specific child protection issues including Prevent training;
• restraint training (as required).
Staff will have access to relevant updates and refreshers at least annually; this may include e-learning, staff bulletins, departmental meetings, etc.. We ensure that all School staff have equal access to relevant training. In addition, pupils who offer guidance and support to younger pupils, for example Peer Mentors and Prefects, also receive basic safeguarding awareness training.
DEALING WITH ALLEGATIONS AGAINST SCHOOL STAFF, VOLUNTEERS OR THE PRINCIPAL / HEAD
The School has procedures to deal with allegations against staff (and volunteers who work with children) that aim to strike a balance between the need to protect children from abuse and the necessity to protect staff and volunteers from false or unfounded allegations which are in line with Welsh Government Circular No: 009/2014 Safeguarding Children in Education – Handling allegations of Abuse against teachers and other staff. In addition, staff should be familiar with the RPS Whistleblowing Policy.
What is an allegation?
An allegation is any behaviour where an adult who is a member of the school staff is alleged to have:
• behaved in a way that has harmed a child, or may have harmed a child;
• possibly committed a criminal offence against or related to a child;
• behaved towards a child or children in a way that indicates that he or she could pose a risk of harm to children.
An allegation may be triggered by one specific incident or by a pattern of behaviour by the adult, or by low-level concerns which, when considered, collectively amount to an allegation.
Reporting an allegation
Any allegation about a staff member should be reported to:
• the Principal / Head or DSL (unless the allegation is against the DSL);
• the Principal / Head and the Chair of Governors, if the allegation is against the DSL;
• the Chair of Governors and the General Secretary of the Methodist Independent Schools Trust (MIST), if the allegation is against the Principal / Head;
• the Principal / Head and the Chair of Governors, if the allegation is against a Governor.
The General Secretary of MIST will be informed of all allegations against staff and volunteers.
The adult to whom the concern or allegation relates should not be informed.
Suspension will not be an automatic response to an allegation. Full consideration will be given to all of the options, subject to the need to ensure:
• the safety and welfare of the pupil or pupils concerned;
• the need for a full and fair investigation.
How will allegations be handled?
Allegations will be handled in line with:
• “Safeguarding children in education: handling allegations of abuse against teachers and other staff” – Welsh Government Circular 009/2014;
• “Disciplinary and dismissal procedures for school staff” – Welsh Government Circular 002/2013 (see Appendix 8 for a summary of procedures for handling allegations).
Allegations against a teacher who is no longer teaching should be referred to the police.
DEALING WITH ALLEGATIONS AGAINST ANOTHER PUPIL
The management of the conduct of pupils is explained within our School anti-bullying and behaviour policies and procedures (the latter including sanctions and rewards), and also within our peer-on-peer abuse guidance.
When an allegation is made by one pupil against another pupil, members of staff should consider whether the complaint raises a safeguarding concern. If there is a safeguarding concern, the Designated Safeguarding Lead should be informed, for example in incidences of threats and intimidation, blackmail, indecent touching or sexual assault, photography of inappropriate content or filming, sexting and violence, particularly when this may be a criminal offence or may present risks to other children.
A factual record of the allegation should be made. However, the school staff should not investigate the matter until specialist advice has been sought from Social Services via the DSL. The DSL will follow through the outcomes of the discussion and make a Social Services referral where appropriate (records of peer on peer incidents should be placed on both pupils’ files).
If a referral is required, then there will be separate strategy discussions held regarding both the alleged perpetrator and the alleged victim. Where it is not considered that the support of outside agencies is required, the School will investigate the allegation internally.
In situations where the School considers a safeguarding risk to be present, a risk assessment should be prepared along with a preventative and supervisory plan.
It must be remembered that children who engage in abusive behaviour may have been subject to abuse from other children or adults, so additional sensitivity will be required beyond the normal School disciplinary code.
The age and understanding of the alleged perpetrator must be considered throughout all decision-making. Staff will need to distinguish between behaviour appropriate to a child’s developmental stage, as distinct from sexually harmful or sexually problematic behaviour or peer-on-peer abuse, and consideration will be given to elements of coercion, violence and any disparity in the ages between the abusing and the abused child. However, allegations of peer-on-peer sexual abuse must be referred to Social Services.
The Principal / Head will ordinarily ensure that the children involved are kept separate until enquiries are complete, so as to avoid collusion or intimidation. The School will not talk to the children about the incident, other than initially establishing what is alleged to have taken place, but will keep a log of actions, discussions and decisions. The School will contact the parents of the children involved, and will request that parents do not discuss the matter with each other until Social Services have completed their enquiries.
If the situation should warrant it, for example as a result of local interest or press coverage, the School should send a letter to all parents / carers of children in the School, giving appropriate information about the situation in the light of legal advice. The wishes of the abused child and their parents should be appropriately considered in any decision-making.
Depending upon the nature of the allegation, a pupil against whom an allegation of abuse has been made may be excluded from the School during the investigation, and as a result of following the School’s policy on behaviour, discipline and sanctions (see Behaviour Policy & Anti-Bullying Policy).
RELATED SAFEGUARDING POLICIES, PROCEDURES & GUIDANCE
All related policies (or guidance documents) below must be read and complied with alongside this policy.
It is also a term of this policy that risk assessments be documented and securely stored in relation to any activities (or persons) as required in the following policies:
- Anti-Bullying Policy;
- PSHE Policy, including Promoting Fundamental British Values;
- Attendance Policy;
- Peer-on-Peer Abuse Guidance;
- Behaviour, Rewards and Sanctions Policy;
- Pastoral Care Statement
- Breast Ironing Guidance;
- Policy on the Photographing and Filming of Pupils
- Missing Child / Pupil Policy;
- Safer Recruitment Policy;
- DBS Disclosure Checks Policy;
- School Staff Code of Conduct;
- Disciplinary Procedure (Staff);
- Sex and Relationships Education Policy;
- Equal Opportunities Policy;
- Sick Child Policy;
- E-Safety Policy;
- Additional Learning Needs Policy;
- Female Genital Mutilation Guidance;
- School Staff and Volunteer Induction Policy;
- Health and Safety Policy;
- Uncollected Child Policy;
- Acceptable Use Policy (ICT);
- Use of Physical Force / Restraint Policy;
- Medical and First Aid Policy;
- Visitors & Contractors Policy;
- Prevent Duty Guidance;
- Whistleblowing Policy
Under the Equality Act 2010, we have a duty not to discriminate against people on the basis of their age, disability, gender, gender identity, pregnancy or maternity, race, religion or belief and sexual orientation.
We believe that this policy is in line with the Equality Act 2010, as it is fair, it does not prioritise or disadvantage any pupil, and it helps to promote equality at this School.
MONITORING THE EFFECTIVENESS OF THIS POLICY
The Designated Safeguarding Leads will monitor the operation of this policy and its procedures, and will make an annual report to the Governing Body.
Annually (or when the need arises), the effectiveness of this policy will be reviewed by the DSLs, the Principal / Head and the Nominated Governors. Any necessary recommendations for improvement will be made to the Governors.
OTHER INFORMATION AND USEFUL LINKS: