Safeguarding Children and Vulnerable Adult Protection Policy

Safeguarding Children and Vulnerable Adult
Protection Policy

This policy was created by ELT as follows:

Creator: Programme Director
Approver: Operations Director
Date of Most Recent Review and approval: 24.03.2024

Next Review: 01.09.2024 – against potential KCSIE updates. If there are legislative or regulatory changes in the interim, this policy will be reviewed before the aforementioned date. Should KCSIE 2024 be released after the first, this policy will be reviewed once released to reflect the updates. Should no substantive changes be required at that point, the policy will move to the next review cycle.

Liberty Tuition are thoroughly committed to safeguarding and protecting children and vulnerable adults from abuse and harm. We follow all national guidelines to ensure that the highest levels of safeguarding and child and vulnerable adult protection are maintained by all staff. We do this by:

Following DfE ‘Keeping Children Safe in Education’ September 2023 and DBS Guidelines on the recruitment and selection of agency staff including regular Enhanced DBS Disclosure with Children’s Barred List checks.
Ensuring that agency workers confirm they have read part 1 of KCSIE and will keep up to date with any changes and understand their duties and responsibilities to keep children safe.
Following Welsh Governments ‘keeping Learners Safe’ Guidance
Sending out Safeguarding newsletters to educators regarding any relevant changes to legislation and guidance
Ensuring that all staff are aware of Liberty Tuition’s Child and Vulnerable Adult Protection policy and procedures, and that staff are trained on the issues.
Ensuring DfE and DBS guidelines on dealing with allegations regarding agency staff are followed.
Making the company’s policies on Child and Vulnerable Adult Protection, Procedures for Managing Allegations and Complaints accessible to all schools and agency workers.
Regular reminder emails are sent to our agency workers requesting they complete the (free) Safeguarding Children training we offer on an annual basis (level 2, online CPD).

Legislation and Regulation

This policy is based on the Department for Education’s (DfE) statutory guidance: Keeping Children Safe in Education and Working Together to Safeguard Children together with the GOV guidance Governance Handbook. We comply with this guidance and the procedures set out by our local safeguarding partners

Key Principles

All children and vulnerable adults have a right to protection from abuse
All allegations of abuse will be taken seriously and responded to swiftly and appropriately within DfE and DBS recommended guidelines.
All allegations of abuse will be taken seriously and responded to swiftly and appropriately within DfE and DBS recommended guidelines.
Adults aged 18 and over have the potential to be vulnerable (either temporarily or permanently) for a variety of reasons and in different situations. An adult may be vulnerable if he/she:

All children and vulnerable adults have a right to protection from abuse
All allegations of abuse will be taken seriously and responded to swiftly and appropriately within DfE and DBS recommended guidelines.
Anyone under the age of 18 should be considered as a child for the purposes of this document
Adults aged 18 and over have the potential to be vulnerable (either temporarily or permanently) for a variety of reasons and in different situations. An adult may be vulnerable if he/she:

Has a learning or physical disability
Has a physical or mental illness, chronic or otherwise, including an addiction to alcohol or drugs
Has a reduction in physical or mental capacity
Is in the receipt of any form of healthcare
Is detained in custody
Is receiving community services because of age, health or disability
Is living in sheltered or residential care home
Is unable, for any other reason, to protect himself/herself against significant harm or exploitation.

Policy review

The Head of Quality and Compliance will keep Liberty Tuition’s Child and Vulnerable Adult Protection Policy under annual review and/or if there have been any relevant legislative changes.

Safeguarding Leads:

Liberty Tuition’s designated safeguarding leads are:

Alexander Scott (DSL)	Roury Hinds (DDSL)
Alex@LibertyTuition.co.uk	Roury@LibertyTuition.co.uk

Alexander Scott (DSL)
Alex@LibertyTuition.co.uk

Roury Hinds (DDSL)
Roury@LibertyTuition.co.uk

The role of the Designated Safeguarding Lead is to take responsibility for any child protection issues which may be raised by the staff of Liberty Tuition or its temporary workers who are placed in our client settings. All our designated leads have completed relevant DSL/DSO safeguarding training to undertake the role.

Definitions of Abuse, Harm and Neglect

Somebody may abuse or neglect a child or vulnerable adult by inflicting harm, or by failing to act to prevent harm. Children and vulnerable adults may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by a stranger, for example via the internet. They may be abused by an adult or adults, or another child or children. Abuse may be physical, emotional, sexual, domestic or a form of neglect.

Neglect is the persistent failure to meet a child’s or vulnerable adult’s basic physical, educational, emotional or medical needs, likely to result in the serious impairment of the child or vulnerable adult’s health or development .

Early Help and Safeguarding issues

All staff should be prepared to identify children who may benefit from early help. Early help means providing support as soon as a problem emerges at any point in a child’s life, from the foundation years through to the teenage years.

All staff should have an awareness of safeguarding issues that can put children at risk of harm. Behaviours linked to issues such as drug taking and or alcohol misuse and deliberately missing education can be signs that children are at risk.

Professional curiosity

All staff should be aware that children may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/or they may not recognise their experiences as harmful. For example, children may feel embarrassed, humiliated, or threatened. This could be due to their vulnerability, disability and/or sexual orientation or language barriers. This should not prevent staff from having a professional curiosity and speaking to the DSL if they have concerns about a child. It is also important that staff determine how best to build trusted relationships with children and young people which facilitate communication.

Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE).

Both CSE and CCE are forms of abuse that occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into taking part in sexual or criminal activity, in exchange for something the victim needs or wants, and/or for the financial advantage or increased status of the perpetrator or facilitator and/or through serious violence or the threat of violence. CSE and CCE can affect children, both male and female and can include children who have been moved (commonly referred to as trafficking) for the purpose of exploitation.

Female Genital Mutilation (FGM)

FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs for non-medical reasons. Further guidance and resources can be found on this link https://www.gov.uk/government/publications/female-genital-mutilation-resourcepack

Child on Child abuse

All staff should be aware that children can abuse other children (often referred to as peer on peer abuse). And that it can happen both inside and outside of school or college and online. It is important that all staff recognise the indicators and signs of peer on peer abuse and know how to identify it and respond to reports.

Peer on peer abuse is most likely to include, but may not be limited to bullying, physical abuse, sexual violence, sexual harassment, consensual and non-consensual sharing of nudes and semi nudes images/videos and up-skirting.

If staff have any concerns regarding peer on peer abuse, they should speak to their designated safeguarding lead in school/college.

Domestic Abuse

Domestic abuse can encompass a wide range of behaviours and may be a single incident or a 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.

Mental Health

All staff should be aware that mental health problems can, in some cases, be an indicator that a child or vulnerable adult has suffered or is at risk of suffering abuse, neglect or exploitation.

Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem. Education staff, however, are well placed to observe children and vulnerable adults regularly and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one.

More information can be found at https://www.gov.uk/government/publications/mental-health-andbehaviour-in-schools–2

Radicalisation and Extremism

Radicalisation is defined as the act or process of making a person more radical or favouring extreme or fundamental changes in political, economic or social conditions, institutions or habits of the mind.

The prevent guidance has since been updated for 2024 (December, 2023) which will ensure that Prevent is well-equipped to counter the threats that we face and the ideologies underpinning them. We as a company have endeavoured to ensure these updates are reflected in our practices.

Extremism is defined as the holding of extreme political or religious views. Staff have a duty to report concerns about pupils in line with the Prevent guidance, if they suspect that a
child is at risk of radicalisation. These concerns should be passed to the Designated Safeguarding Lead in the school.

GOV.UK provide training in which those taking the course will learn about:

We ensure all tutors and personnel have taken this course at the appropriate level.https://www.gov.uk/guidance/prevent-duty-training

The Home office has produced key resources, workshops and training programmes to help you understand Prevent and how to keep students safe from extremism and radicalisation this can be found on the following link: https://educateagainsthate.com/teachers/prevent-training/ and https://www.support-peoplevulnerable-to-radicalisation.service.gov.uk/prevent-duty-training-learn-how-support-people-vulnerableradicalisation

Liberty Tuition will refer any member of its workforce who they believe has attempted to radicalise pupils or preach extremist ideals to either the Local Authority or the Police.

Online Safety

The breadth of issues classified within online safety is considerable, but can be categorised into four areas of risk:

content: being exposed to illegal, inappropriate or harmful content, for example: pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation and extremism.
contact: being subjected to harmful online interaction with other users; for example: peer to peer pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes’.
conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example, making, sending and receiving explicit images(e.g. consensual and non-consensual sharing of nudes and semi-nudes and/or pornography, sharing other explicit images and online bullying; and
commerce - risks such as online gambling, inappropriate advertising, phishing and or financial scams. If you feel your pupils, students or staff are at risk, please report it to the Anti-Phishing Working Group (https://apwg.org/).

Agency workers should ensure that they establish safe and responsible online behaviours, working to local and national guidelines.
Contact with children and vulnerable adults both in the ‘real’ world and through web based and telecommunication interactions should take place within explicit professional boundaries. This includes the use of computers, tablets, phones, texts, e-mails, instant messages, social media such as Facebook, Instagram, Twitter, TikTok, OnlyFans, chatrooms, forums, blogs, websites, gaming sites, digital cameras,videos, webcams and other handheld devices. (Given the ever changing world of technology it should be noted that this list gives examples only and is not exhaustive.)

Agency workers should not request or respond to any personal information from children and vulnerable adults other than which may be necessary in their professional role. They should ensure that their communications are open and transparent and avoid any communication which could be interpreted as ‘grooming behaviour’.

Agency workers should not give their personal contact details to children and vulnerable adults, for example; e-mail address, home or mobile telephone numbers, social media account details etc. If children and vulnerable adults locate these by any other means and attempt to contact or correspond with the Agency workers, they should not respond and must report the matter to their line manager. The child or vulnerable adult should be firmly and politely informed that this is not acceptable.

The UK Safer Internet Centre has produced some further information about Online Safety: https://www.saferinternet.org.uk/advice-centre/teachers-and-school-staff

The Liberty Tuition Online Tutoring Policy and Guidance contains relevant information and various links to other resources which Educators should familiarise themselves with.

Identifying Abuse

The following list outlines ways in which abuse may be identified. It is not intended that this is an exhaustive list and it is not the agency workers sole responsibility to determine if abuse is occurring, but to report their concerns:

Changes in behaviour; immediate or over a length of time
Increased absence
A change in friendships or relationships with older individuals
A significant decline in performance
Signs of self-harm
Bruises and injuries that do not reflect the activity the child is involved in and where the explanation does not confirm with the injuries
Fear of certain adults
Being involved in offending
Unexplained gifts or new possessions could also indicate that a child has been approached by or involved with individuals associated with criminal networks or gangs
Use of sexually explicit language and actions
The child or vulnerable adult tells you that they are being abused
A third party tells you that the child or vulnerable adult is being abused
A child or vulnerable adult seems to be a loner and does not integrate with the group
A child or vulnerable adult whose appearance deteriorates hygienically and or physically

Some disabled, young children or vulnerable adults may feel more vulnerable in making others aware of the abuse due to them relying on the abuser.

Whilst it is important that a partnership approach is adopted to ensure the safety and the welfare of children and vulnerable adults, it is of equal importance that all concerned are confident that the information they provide will only be disclosed where it is in the best interests of the child or vulnerable adult to do so.

General conduct when working with young people and vulnerable adults

Liberty Tuition expects its agency workers to fulfil their duty to keep children and vulnerable adults safe and to protect them from physical, emotional, and sexual harm. All agency workers are expected to contribute to:

All Liberty Tuition staff are encouraged to demonstrate exemplary behaviour in order to safeguard Children and to protect themselves from allegations of abuse. Stated below are the standards of behaviour required of Liberty Tuition staff in order to fulfil their roles to ensure that a positive culture and climate is created during all activities involving contact with young people and vulnerable adults.

Always work in an open environment (e.g. avoiding private or unobserved situations and encouraging an open environment eg no secrets)
Treat all young people and vulnerable adults with respect and dignity
Maintain a safe and appropriate distance from young people and vulnerable adults.
Build balanced relationships based on mutual trust
Ensuring that during any residential events, adults do not enter young people and vulnerable adults rooms or invite young people and vulnerable adults to their rooms unless there are exceptional reasons for doing so
Be an excellent role model – this includes not smoking or drinking alcohol in the company of young people and vulnerable adults or using inappropriate language
Give enthusiastic and constructive feedback rather than negative criticism
To refrain from taking any photographs, videoing or audio recording of pupils or vulnerable adults without prior written consent.

Unacceptable practices

The following should never be sanctioned:

Spending excessive amounts of time alone with young people or vulnerable adults away from others
Making personal contact with young people or vulnerable adults by email, telephone, post or any means without parental consent
Taking young people or vulnerable adults to your home where they will be alone with you
Allowing young people or vulnerable adults to travel on their own with you in a vehicle
Engaging in rough, physical or sexually provocative games including horseplay
Sharing a room with a young person or vulnerable adult
Engaging a toilet with young people or vulnerable adults unless another adult is present or permission is given. Agency staff should avoid using toilets that are used by school pupils or vulnerable adults.
Allowing or engaging in any form of inappropriate contact
Allowing or encouraging abusive peer activities
Allowing young people to use inappropriate language unchallenged
Making sexually suggestive comments to or within hearing of a young person or vulnerable adult even in fun
Reducing a young person or vulnerable adult to tears as a form of control
Allowing allegations made by a young person or vulnerable adults to go unchallenged, unrecorded or not acted upon
Doing things of a personal nature for young people or vulnerable adult that they can do for themselves
Physically restraining a young person or vulnerable adults unless the restraint is to:

Allegation Disclosure

The following guidelines should be used when an allegation is disclosed by a young person to a member of Liberty Tuition staff:

1. Listen and reassure

Maintain confidentiality but do not make promises that you cannot keep, and explain that the information will have to be passed on and what action you will be taking in this regard
Be calm
Be reassuring and make it clear that you are glad that they have told you
Show that you are taking the child or vulnerable adult seriously and that you understand and believe them
Keep questions to a minimum; if you have to ask questions keep them open and not leading

Points to note when dealing with a disclosure

Try not to display any kind of shock or disapproval
Do not jump to conclusions
The young person or vulnerable adult may regard the experience as either bad or painful, they may not feel guilty or angry
Be aware of your own feelings which may be different to those of the young person or vulnerable adult
Take care of yourself by ensuring that you have an opportunity to discuss your feelings with someone at a later stage
Do not destroy any evidence as it may be used later in a court of law
Initial disclosure even if retracted must still be referred

2. In an emergency (ie a serious incident, the child is in need of medical attention or a crime may have occurred) call 999.

3. Recording Information
It is essential that the details of the alleged abuse be recorded correctly and legibly as this will be critical later on in the proceedings. This should be done immediately and certainly within 24 hours.

4. Informing the appropriate contacts
If abuse has been disclosed to you or you suspect that it is happening you must inform the relevant Designated Safeguarding Officer within a school/organisation (for agency workers ) or to the Designated Safeguarding Officer (for internal Liberty Tuition staff).

5. Referral to Relevant Authorities
Cases where Liberty Tuition have ceased to use the services of an educator or might have ceased to use those services had the educator not ceased to provide them, for reasons of child and vulnerable adult protection, will be referred to the Disclosure and Barring Service and the Teaching Regulation Agency or
Education Workforce Council (for those working in Wales) where necessary

Referrals will be made by the Designated Safeguarding Leads.

Filtering and Monitoring

The use of particular software and websites have become central in facilitating student learning across most subjects, and as such, it is important for tabs to be kept on which sites pupils are using, visiting, or trying to visit – as per the latest KCSIE guidance (2023).

At Liberty Tuition, we do not provide devices or software for students to use, and so there aren’t any filtering and monitoring processes we have to carry out directly. However there are instances where students are using school based computers or laptops to partake in their tutoring. As these may be used while students are directly engaging with our services, we are inclined to ensure we too are doing our best to keep in line with the guidance. As such:

The designated safeguarding lead is directly responsible for understanding the filtering and monitoring systems and processes in place at partner schools in which students are provided devices to use, as part of their remit. Upon new partnerships, the DSL will request these policies and procedures from the IT departments so as to understand how they maintain the safeguarding of their children in these circumstances .
All staff are given training on the importance of, expectations, and applicable roles and responsibilities in relation to filtering and monitoring as part of their safeguarding and child protection training at induction. This is also refreshed annually. While staff at Liberty Tuition are directly involved in the filtering and monitoring, it is important for all staff to know what it entails and what it is for, so that they can enforce the importance of proper online etiquette to students as part of their due diligence and safeguarding responsibility during their lessons.
We request information on how filtering and monitoring technology on partner school devices and school networks form part of its work in this area. We request access to the data (to include any websites visited that are a cause for concern) for students using school devices during their tuition with us.

Student absence/missing from school:

The careful monitoring of attendance is key to improving the overall performance of pupil outcomes, but it is equally important in keeping children safe. Knowing who is absent or missing and why, is fundamental to effective safeguarding. Non-Attendance to tutoring – whether an after school provision, or an alternative provision with us can result in safeguarding action. This is because persistent absenteeism and sudden changes in patterns of attendance and pupil behaviour, are a key indication that something is wrong and a
sign of a range of safeguarding concerns including sexual abuse, sexual exploitation or child criminal exploitation; this could lead to sudden extended absences. As an educational provider, we have a duty of care to take action.

We therefore scrutinise pupil absence, investigate the reasons for this and ensure our procedures are followed. For example:

Children who become withdrawn, or who start acting differently in class and who are then absent, would be flagged as a safeguarding concern to the Designated Safeguarding Leads and investigated
Absences may well be due to illness, but they could equally be linked to safeguarding issues such as bullying, family break-ups, domestic abuse, involvement in county lines or online grooming

The key to early intervention, of course, is good communication between us, our school partners, and strong links with parents. Liberty Tuition action will include:

Monitoring of attendance with accurate record keeping
Speaking to parents/carers who we make aware that the procedures are rigorous and that absences will always be questioned. Our staff do their best to maintain relationships and trust
Where there are causes for concern, we make contact with the school and their DSL

At Liberty Tuition, attendance is closely monitored, staff are well trained, we maintain positive communication links with parents and have effective systems in place to deal with any attendance issues quickly and sensitively, so that we are well equipped to keep children safe.

Parents/carers should ensure that if their child is unwell, we are contacted at the first instance, after which we will communicate this to the school partner.

Allegations made by partner schools againstLiberty Tuition or its staff:

KCSIE 2023 makes it clear that as with any safeguarding allegation, schools and colleges should follow their safeguarding policies and procedures, including informing the LADO [local authority designated officer] where there is an allegation against an agency or individual when using school premises. At Liberty Tuition our policies and procedures are in support of this, with each partner school having access to our complaints forms, policies and procedures in which we will work with them to resolve the issue at hand.

Other relevant policies and guidance may include:

Online Tutoring Policy and Guidance, Lone Working Policy, Student Behaviour Policy, Procedures for Managing Allegations Against Agency Workers, Equal Opportunities and Diversity Policy, Child Protection Information, Recruitment and Selection Policy, Guidance for Safer Working Practice for Adults who work with Children and Young People in Education 2019 , Keeping children safe in out-of-school settings: code of practice and DFE Keeping Children Safe in Education.

Coronavirus (COVID-19) Addendum:

Although Coronavirus is not prevalent as it once was, we still need to be mindful that the situation can change. To keep up to date with the latest government guidance on Coronavirus (COVID-19):
https://www.gov.uk/coronavirus and https://www.gov.uk/coronavirus/education-and-childcare

Procedures for Liberty Tuition staff dealing with a disclosure of abuse

Training

The Designated Safeguarding Lead will undergo training to provide them with the knowledge and skills required to carry out the role. This training should be updated at least every two years.

The Designated Safeguarding Lead will undertake Prevent awareness training.

The DSL will keep up-to-date with latest information about safeguarding so that their knowledge and skills are refreshed (this might be via e-bulletins, meeting other designated safeguarding leads, or simply taking time to read and digest safeguarding developments).

The DSL will:

understand the assessment process for providing early help and statutory intervention, including local criteria for action and local authority children’s social care referral arrangements
have a working knowledge of how local authorities conduct a child protection case conference and a child protection review conference and be able to attend and contribute to these effectively when required to do so
ensure each member of staff has access to, and understands, Liberty Tuition’s child protection policy and procedures, especially new and part time staff
are alert to the specific needs of children in need, those with special educational needs and young carers
are able to keep detailed, accurate, secure written records of concerns and referrals
understand and support the company with regards to the requirements of the Prevent duty and are able to provide advice and support to staff on protecting children from the risk of radicalisation
are able to understand the unique risks associated with online safety and be confident that they have the relevant knowledge and up to date capability required to keep children safe whilst they are online
can recognise the additional risks that children with SEN and disabilities (SEND) face online, for example, from online bullying, grooming and radicalisation and are confident they have the capability to support SEND children to stay safe online
obtain access to resources and attend any relevant or refresher training courses;and
encourage a culture of listening to children and taking account of their wishes and feelings, among all staff, in any measures Liberty Tuition may put in place to protect them.

Raise Awareness

The Designated Safeguarding Lead will:

ensure the Liberty Tuition child protection policy is known, understood and used appropriately and is reviewed annually (as a minimum) and the procedures and implementation are updated and reviewed regularly
ensure the child protection policy is available publicly and parents are aware of the fact that referrals about suspected abuse or neglect may be made and the role of the Liberty Tuition in this

Next Review Date:

1st September 2024