Statement of intent

Danebrook House School committed to safeguarding and promoting the physical, mental, and emotional welfare of every student, both inside and outside of the school premises. We implement a whole-school preventative approach to managing safeguarding concerns, ensuring that the wellbeing of students is at the forefront of all action taken.

This policy sets out a clear and consistent framework for delivering this promise, in line with safeguarding legislation and statutory guidance. It will be achieved by:

• Ensuring that members of the board, the Headteacher and staff understand their responsibilities under safeguarding legislation and statutory guidance, are alert to the signs of child abuse, and know to refer concerns to the DSL (Designated Safeguarding Lead).
• Teaching students how to keep safe and recognise behaviour that is unacceptable.
• Identifying and making provision for any student that has been subject to, or is at risk of, abuse, neglect, or exploitation.
• Creating a culture of safer recruitment by adopting procedures that help deter, reject, or identify people who might pose a risk to children.

• Ensuring that the Headteacher and any new staff and volunteers are only appointed when all the appropriate checks have been satisfactorily completed.

The DSL is Lee Cambray. In the absence of the DSL, child protection matters will be dealt with by the deputy DSL  Natalie Howe

Acronyms

This policy contains several acronyms used in the Education sector. These acronyms are listed below alongside their descriptions.

Definitions

The terms “children” and “child” refer to anyone under the age of 18.

For the purposes of this policy, “safeguarding and protecting the welfare of children” is defined as:

• Protecting students from maltreatment.
• Preventing the impairment of students’ mental and physical health or development.
• Ensuring that students grow up in circumstances consistent with the provision of safe and effective care.
• Taking action to enable all students to have the best outcomes.

For the purposes of this policy, “consent” is defined as having the freedom and capacity to choose to engage in sexual activity. Consent may be given to one sexual activity but not another and can be withdrawn at any time during sexual activity and each time activity occurs. A person only consents to a sexual activity if they agree by choice to that activity and has the freedom and capacity to make that choice. Children under the age of 13 can never consent to any sexual activity. The age of consent is 16.

For the purposes of this policy, “sexual violence” refers to the following offences as defined under the Sexual Offences Act 2003:

• Rape: A person (A) commits an offence of rape if they intentionally penetrate the vagina, anus, or mouth of another person (B) with their penis, B does not consent to the penetration, and A does not believe that B consents.
• Assault by penetration: A person (A) commits an offence if they intentionally penetrate the vagina or anus of another person (B) with a part of their body or anything else, the penetration is sexual, B does not consent to the penetration, and A does not believe that B consents.
• Sexual assault: A person (A) commits an offence of sexual assault if they intentionally touch another person (B), the touching is sexual, B does not consent to the touching, and A does not believe that B consents.
• Causing someone to engage in sexual activity without consent: A person (A) commits an offence if they intentionally cause another person (B) to engage in an activity, the activity is sexual, B does not consent to engaging in the activity, and A does not believe that B consents. This could include forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party.

For the purposes of this policy, “sexual harassment” refers to unwanted conduct of a sexual nature that occurs online or offline, inside, or outside of school. Sexual harassment is likely to violate a student’s dignity, make them feel intimidated, degraded, or humiliated, and create a hostile, offensive, or sexualised environment. If left unchallenged, sexual harassment can create an atmosphere that normalises inappropriate behaviour and may lead to sexual violence.

Sexual harassment can include, but is not limited to:

• Sexual comments, such as sexual stories, lewd comments, sexual remarks about clothes and appearance, and sexualised name-calling.
• Sexual “jokes” and taunting.
• Physical behaviour, such as deliberately brushing against someone, interfering with someone’s clothes, and displaying images of a sexual nature.
• Online sexual harassment, which may be standalone or part of a wider pattern of sexual harassment and/or sexual violence. This includes:
  • The consensual and non-consensual sharing of nude and semi-nude images and/or videos.
  • Sharing unwanted explicit content.
  • Up skirting.
  • Sexualised online bullying.
  • Unwanted sexual comments and messages, including on social media.
  • Sexual exploitation, coercion, and threats.

For the purposes of this policy, “up skirting” refers to the act, as identified the Voyeurism (Offences) Act 2019, of taking a picture or video under another person’s clothing, without their knowledge or consent, with the intention of viewing that person’s genitals or buttocks, with or without clothing, to obtain sexual gratification, or cause the victim humiliation, distress, or alarm. Up skirting is a criminal offence. Anyone, including students and staff, of any gender can be a victim of up skirting.

For the purposes of this policy, the “consensual and non-consensual sharing of nude and semi-nude images and/or videos,” colloquially known as “sexting,” is defined as the sharing between students of sexually explicit content, including indecent imagery. For the purposes of this policy, “indecent imagery” is defined as an image which meets one or more of the following criteria:

• Nude or semi-nude sexual posing
• A child touching themselves in a sexual way.
• Any sexual activity involving a child.
• Someone hurting a child sexually.
• Sexual activity that involves animals

1. Legal framework

This policy has due regard to all relevant legislation and statutory guidance including, but not limited to, the following:

Legislation

• Children Act 1989 (and 2004 amendment)
• Education (ISS) Regulations 2014
• Serious Crime Act 2015
• Children Act 2004
• Safeguarding Vulnerable Groups Act 2006
• Sexual Offences Act 2003
• Female Genital Mutilation Act 2003 (as inserted by the Serious Crime Act 2015)
• Human Rights Act 1998 (ECHR, European Convention on Human Rights)
• Equality Act 2010
• Counterterrorism and Security Act 2015
• The Rehabilitation of Offenders Act 1974
• The UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018
• Voyeurism (Offences) Act 2019
• Domestic Abuse Act 2021
• Anti-social Behaviour, Crime and Policing Act 2014

Statutory guidance

• DfE (2015) ‘The Prevent duty’
• DfE (2023) ‘Working Together to Safeguard Children’
• DfE (2018) ‘Disqualification under the Childcare Act 2006’
• DfE (2023) ‘Keeping children safe in education 2023’.
• HM Government (2020) ‘multi-agency statutory guidance on female genital mutilation’
• HM Government (2021) ‘Channel Duty Guidance: Protecting people vulnerable to being drawn into terrorism’.
• Home Office and Foreign, Commonwealth and Development Office(2022) ‘multi-agency statutory guidance for dealing with forced marriage and multi-agency practice guidelines: Handling cases of forced marriage’.

Non-statutory guidance

• DfE (2015) ‘What to do if you’re worried a child is being abused’.
• DfE (2017) ‘Child sexual exploitation’
• DfE (2018) ‘Information sharing’
• DfE (2020) ‘Sharing nudes and semi-nudes: advice for education settings working with children and young people’.
• DfE (2021) ‘Teachers’ Standards’
• DfE (2022) ‘Recruit teachers from overseas’

This policy operates in conjunction with the following school policies:

• Children Missing Education Policy
• Anti-bullying Policy
• Suspension and Exclusion Policy
• Online Safety Policy
• Data Protection
• Whistleblowing Policy
• Allegations of Abuse Against Staff Policy
• Safer Recruitment Policy
• Behaviour Policy

2. Roles and responsibilities

All staff have a responsibility to:

• Consider, always, what is in the best interests of the student.
• Maintain an attitude of ‘it could happen here’ where safeguarding is concerned.
• Provide a safe environment in which students can learn.
• Be prepared to identify students who may benefit from early help.
• Be aware of the school’s systems which support safeguarding, including any policies, procedures, information, and training provided upon induction.
• Be aware of the role and identity of the DSL and deputy DSLs (Designated Safeguarding Lead).
• Undertake safeguarding training, including online safety training, during their induction – this will be regularly updated.
• Receive and understand child protection and safeguarding (including online safety) updates, e.g., via email, as required, and at least annually.
• Be aware of the local early help process and understand their role in it.
• Be aware of, and understand, the process for making referrals to CSCS, as well as for making statutory assessments under the Children Act 1989 and their role in these assessments.
• Make a referral to CSCS and/or the police immediately, if at any point there is a risk of immediate serious harm to a child.
• Support social workers in making decisions about individual children, in collaboration with the DSL.
• Be aware of and understand the procedure to follow if a child confides they are being abused, exploited, or neglected.
• Be aware that a student may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/or may not recognise their experiences as harmful.
• Maintain appropriate levels of confidentiality when dealing with individual cases.
• Reassure victims that they are being taken seriously, that they will be supported, and that they will be kept safe.
• Speak to the DSL if they are unsure about how to handle safeguarding matters.
• Be aware of safeguarding issues that can put students at risk of harm.
• Be aware of behaviours that could potentially be a sign that a student may be at risk of harm.

Teachers, including the Headteacher, have a responsibility to:

• Safeguard students’ wellbeing and maintain public trust in the teaching profession as part of their professional duties, as outlined in the ‘Teachers’ Standards.’

The Executive Director has a duty to:

• Take strategic leadership responsibility for the school’s safeguarding arrangements.
• Ensure that the school complies with its duties under the above child protection and safeguarding legislation.
• Guarantee that the policies, procedures, and training opportunities in the school are effective and always comply with the law.
• Guarantee that the school contributes to multi-agency working in line with the statutory guidance ‘Working Together to Safeguard Children.’
• Confirm that the school’s safeguarding arrangements consider the procedures and practices of the LA as part of the inter-agency safeguarding procedures.
• Understand the local criteria for action and the local protocol for assessment and ensure these are reflected in the school’s policies and procedures.
• Comply with its obligations under section 14B of the Children Act 2004 to supply the local safeguarding arrangements with information to fulfil its functions.
• Ensure that staff working directly with children read at least Part one of KCSIE.
• Ensure that staff who do not work directly with children read either Part one or Annex A of KCSIE. NB: Individual schools assess which guidance will be most effective for their staff to safeguard and promote the welfare of children.
• Ensure that mechanisms are in place to assist staff to understand and discharge their role and responsibilities regarding safeguarding children.
• Appoint a member of staff from the SLT to the role of DSL as an explicit part of the role-holder’s job description.
• Appoint one or more deputy DSLs to provide support to the DSL and ensure that they are trained to the same standard as the DSL and that the role is explicit in their job descriptions.
• Facilitate a whole-school approach to safeguarding; this includes ensuring that safeguarding and child protection are at the forefront and underpin all relevant aspects of process and policy development.
• Where there is a safeguarding concern, ensure the child’s wishes and feelings are considered when determining what action to take and what services to provide.
• Ensure systems are in place, children to confidently report abuse, knowing that their concerns will be treated seriously, and they can safely express their views and give feedback; these systems will be well-promoted, easily understood, and easily accessible.
• Ensure that staff have due regard to relevant data protection principles that allow them to share and withhold personal information.
• Ensure that a member of the Executive Director is nominated to liaise with the LA and/or partner agencies on issues of child protection and in the event of allegations of abuse made against the Headteacher or the Executive Director
• Guarantee that there are effective and appropriate policies and procedures in place.
• Ensure all relevant persons are aware of the school’s local safeguarding arrangements, including the Executive Director itself, the SLT and DSL.
• Make sure that students are taught about safeguarding, including protection against dangers online (including when they are online at home), through teaching and learning opportunities, as part of providing a broad and balanced curriculum.
• Adhere to statutory responsibilities by conducting pre-employment checks on staff who work with children, taking proportionate decisions on whether to ask for any checks beyond what is required.
• Ensure that staff are appropriately trained to support students to be themselves at school, e.g., if they are LGBTQ+.
• Ensure the school has clear systems and processes in place for identifying possible mental health problems in students, including clear routes to escalate concerns and clear referral and accountability systems.
• Guarantee that volunteers are appropriately supervised.
• Make sure that at least one person on any appointment panel has undertaken safer recruitment training.
• Ensure that all staff receive safeguarding and child protection training updates, e.g., emails, as required, but at least annually.
• Ensure that all Executive Director receive appropriate safeguarding and child protection training upon their induction and that this training is updated regularly.
• Certify that there are procedures in place to handle allegations against staff, supply staff, volunteers, and contractors.
• Confirm that there are procedures in place to make a referral to the DBS and the Teaching Regulation Agency (TRA), where appropriate, if a person in regulated activity has been dismissed or removed due to safeguarding concerns or would have been had they not resigned.
• Guarantee that there are procedures in place to handle students’ allegations against other students.
• Ensure that appropriate disciplinary procedures are in place, as well as policies pertaining to the behaviour of students and staff.
• Ensure that procedures are in place to eliminate unlawful discrimination, harassment, and victimisation, including those in relation to child-on-child abuse.
• Guarantee that there are systems in place for students to express their views and give feedback.
• Establish an early help procedure and ensure all staff understand the procedure and their role in it.
• Appoint a designated teacher to promote the educational achievement of CLA and ensure that this person has undergone appropriate training.
• Ensure that the SENDCo works with the VSH to discuss how the student premium funding can best be used to support CLA.
• Introduce mechanisms to assist staff in understanding and discharging their roles and responsibilities.
• Make sure that staff members have the skills, knowledge and understanding necessary to keep CLA safe, particularly with regard to the student’s legal status, contact details and care arrangements.
• Put in place appropriate safeguarding responses for students who go missing from school, particularly on repeat occasions, to help identify any risk of abuse, neglect, or exploitation, and prevent the risk of their disappearance in future.
• Ensure that all members of the Board have been subject to an enhanced DBS check.
• Create a culture where staff are confident to challenge senior leaders over any safeguarding concerns.
• Be aware of their obligations under the Human Rights Act 1998, the Equality Act 2010 (including the Public Sector Equality Duty), and the local multi-agency safeguarding arrangements.

The Headteacher has a duty to:

• Ensure that the policies and procedures adopted by the Executive Director, particularly concerning referrals of cases of suspected abuse and neglect, are followed by staff.
• Provide staff with the appropriate policies and information upon induction.

The DSL has a duty to:

• Take lead responsibility for safeguarding and child protection, including online safety.
• Provide advice and support to other staff on child welfare, safeguarding and child protection matters.
• Take part in strategy discussions and inter-agency meetings, and/or support other staff to do so.
• Contribute to the assessment of children, and/or support other staff to do so.
• During term time, be available during school hours for staff to discuss any safeguarding concerns. NB: Individual schools, working with the DSL, define what “available” means and whether, in exceptional circumstances, availability via phone, videocall, or other media is an acceptable substitution for in-person availability.
• Arrange, alongside the school, adequate and appropriate cover for any activities outside of school hours or terms.
• Refer cases:
  • To CSCS where abuse and neglect are suspected, and support staff who make referrals to CSCS.
  • To the Channel programme where radicalisation concerns arise, and support staff who make referrals to the Channel programme.

• To the DBS where a person is dismissed or has left due to harm, or risk of harm, to a child.
• To the police where a crime may have been committed, in line with the National Police Chiefs’ Council (NPCC) guidance.
• Act as a source of support, advice, and expertise for all staff.
• Act as a point of contact with the safeguarding partners.
• Liaise with the Headteacher to inform them of issues, especially regarding ongoing enquiries under section 47 of the Children Act 1989 and police investigations.
• Liaise with the deputy DSLs to ensure effective safeguarding outcomes.
• Liaise with the case manager and the LA designated officers (LADOs) for child protection concerns in cases concerning staff.
• Liaise with staff on matters of safety, safeguarding and welfare, including online and digital safety.
• Liaise with staff when deciding whether to make a referral by liaising with relevant agencies so that children’s needs are considered holistically.
• Liaise with the senior mental health lead and, where available, the mental health support team, where safeguarding concerns are linked to mental health.
• Promote supportive engagement with parents in safeguarding and promoting the welfare of children, including where families may be facing challenging circumstances.
• Work with the Headteacher and relevant strategic leads, taking lead responsibility for promoting educational outcomes by knowing the welfare, safeguarding and child protection issues that children in need are experiencing, or have experienced, and identifying the impact that these issues might be having on their attendance, engagement, and achievement at school. This includes:
  • Ensuring that the school knows which students have or had a social worker.
  • Understanding the academic progress and attainment of these students.
  • Maintaining a culture of high aspirations for these students.
  • Supporting teachers to provide additional academic support or reasonable adjustments to help these students reach their potential.
  • Helping to promote educational outcomes by sharing the information about the welfare, safeguarding and child protection issues these students are experiencing with teachers and the SLT.
• Ensure that child protection files are kept up-to-date and only accessed by those who need to do so.
• Ensure that a student’s child protection file is transferred as soon as possible, and within five days, when transferring to a new school, and consider any additional information that should be shared.
• Ensure each member of staff has access to and understands the school’s Child Protection and Safeguarding Policy and procedures – this will be discussed during the staff induction process.
• Work with the Executive Director to ensure the school’s Child Protection and Safeguarding Policy is reviewed annually, and the procedures are updated and reviewed regularly.
• Ensure the school’s Child Protection and Safeguarding Policy is available publicly, and parents are aware that the school may make referrals for suspected cases of abuse or neglect, as well as the role the school plays in these referrals.
• Link with safeguarding partner arrangements to make sure that staff are aware of the training opportunities available and the latest local policies on safeguarding.
• Undergo training and update this training at least every two years.
• Obtain access to resources and attend any relevant or refresher training courses.
• Encourage a culture of listening to children and taking account of their wishes and feelings; this includes understanding the difficulties students may have in approaching staff about their circumstances and considering how to build trusted relationships that facilitate communication.
• Support and advise staff and help them feel confident on welfare, safeguarding and child protection matters specifically, to ensure that staff are supported during the referrals processes; and to support staff to consider how safeguarding, welfare and educational outcomes are linked, including to inform the provision of academic and pastoral support.
• Understand the importance of information sharing, including within school, with other schools, and with the safeguarding partners, other agencies, organisations, and practitioners.
• Understand relevant data protection legislation and regulations, especially the Data Protection Act 2018 and the UK GDPR.
• Keep detailed, accurate, secure written records of concerns and referrals, and understand the purpose of this record-keeping.

The designated teacher has a responsibility for promoting the educational achievement of CLA, and for children who have left care through adoption, special guardianship, or child arrangement orders or who were adopted from state care outside England and Wales.

3. Multi-agency working

The school contributes to multi-agency working as part of its statutory duty. The school is aware of and will follow the local safeguarding arrangements.

Danebrook House School will be fully engaged, involved, and included in local safeguarding arrangements. Once the school is named as a relevant agency by local safeguarding partners, it will follow its statutory duty to cooperate with the published arrangements in the same way as other relevant agencies. The school will act in accordance with the safeguarding arrangements.

The school will work with CSCS, the police, health services and other services to protect the welfare of its students, through the early help process and by contributing to multi-agency plans to provide additional support.

Where a need for early help is identified, the school will allow access for CSCS from the host LA and, where appropriate, a placing LA, for that LA to conduct (or consider whether to conduct) a section 17 or 47 assessment.

The school also recognises the particular importance of inter-agency working in identifying and preventing CSE.

Information sharing

Danebrook House School recognises the importance of proactive information sharing between professionals and local agencies in order to effectively meet students’ needs and identify any need for early help.

Considering the above, staff will be aware that whilst the UK GDPR and the Data Protection Act 2018 place a duty on schools to process personal information fairly and lawfully, they also allow for information to be stored and shared for safeguarding purposes – data protection regulations do not act as a barrier to sharing information where failure to do so would result in the student being placed at risk of harm.

Staff members will ensure that fear of sharing information does not stand in the way of their responsibility to promote the welfare and safety of students. If staff members are in doubt about sharing information, they will speak to the DSL or deputy DSLs.

4. Early help

Early help means providing support as soon as a problem emerges, at any point in a child’s life. Any student may benefit from early help, but staff will be alert to the potential need for early help for students who:

• Are disabled, have certain health conditions, or have specific additional needs.
• Have SEND, regardless of whether they have a statutory EHC plan.
• Have mental health needs.
• Are young carers.
• Show signs of being drawn into anti-social or criminal behaviour, including gang involvement and association with organised crime groups or county lines.
• Are frequently missing or going missing from care or from home.
• Are at risk of modern slavery, trafficking, or sexual or criminal exploitation.
• Are at risk of being radicalised or exploited.
• Have family members in prison or are affected by parental offending.
• Are in a family circumstance presenting challenges for them, such as drug and alcohol misuse, adult mental health problems, or domestic abuse.
• Misuse drugs or alcohol.
• Have returned home to their family from care.
• Are at risk of HBA, such as FGM or forced marriage.
• Are privately fostered.
• Are persistently absent from education, including persistent absences for part of the school day.
• Show early signs of abuse and/or neglect in other ways.

The DSL or pastoral lead will take the lead where early help is appropriate. This includes liaising with other agencies and setting up an inter-agency assessment as appropriate. The local early help process will be followed as required.

Staff may be required to support other agencies and professionals in an early help assessment, in some cases acting as the lead practitioner. Any such cases will be kept under constant review and consideration given to a referral to CSCS for assessment for statutory services if the student’s situation is not improving or is worsening.

5. Abuse and neglect

For the purposes of this policy, “abuse” is defined as a form of maltreatment of a child which involves inflicting harm or failing to act to prevent harm. Harm can include ill treatment that is not physical as well as the impact of witnessing the ill treatment of others – this can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse. Children may be abused in a family, institutional or community setting by those known to them or by others, e.g., via the internet. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by one or multiple adults or other children.

For the purposes of this policy, “physical abuse” is defined as a form of abuse which may involve actions such as hitting, shaking, throwing, poisoning, burning, or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical abuse can also be caused when a parent fabricates the symptoms of, or deliberately induces, illness in a child.

For the purposes of this policy, “emotional abuse” is defined as the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. This may involve conveying to a child that they are worthless, unloved, inadequate, or valued only as far as they meet the needs of another person. It may include not giving the child the opportunities to express their views, deliberately silencing them, ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children, such as interactions that are beyond their developmental capability, overprotection and limitation of exploration and learning, or preventing the child from participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying, including cyberbullying, causing the child to frequently 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, but it may also occur alone.

For the purposes of this policy, “sexual abuse” is defined as abuse that involves forcing or enticing a child to take part in sexual activities, not necessarily involving violence, and regardless of whether the child is aware of what is happening. This may involve physical contact, including assault by penetration, or non-penetrative acts, such as masturbation, kissing, rubbing, and touching outside of clothing. It may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can be perpetrated by people of any gender and age.

For the purposes of this policy, “neglect” is defined as the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in serious impairment of a child’s health or development. This may involve a parent or carer failing to provide a child with adequate food, clothing, or shelter (including exclusion from home or abandonment); failing to protect a child from physical or emotional harm or danger; failing to ensure adequate supervision (including through the use of inappropriate caregivers); or failing to ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

All staff will be aware of the indicators of abuse and neglect and understand that children can be at risk of harm inside and outside of the school, inside and outside of home, and online. All staff will be aware that abuse, neglect, and other safeguarding issues are rarely standalone events that can be given a specific label, and multiple issues often overlap one another; therefore, staff will be vigilant and always raise concerns with the DSL. All staff, especially the DSL and deputy DSLs, will be aware that safeguarding incidents and/or behaviours can be associated with factors outside the school and/or can occur between children outside of these environments; this includes being aware that students can at risk of abuse or exploitation in situations outside their families (extra-familial harms). All staff will be aware of the appropriate action to take following a student being identified as at potential risk of abuse and, in all cases, will speak to the DSL if they are unsure.

All staff will be aware that technology is a significant component in many safeguarding and wellbeing issues, including online abuse, cyberbullying, and the sharing of indecent images.

6. Specific safeguarding issues

There are certain specific safeguarding issues that can put children at risk of harm – staff will be aware of these issues.

Appendix A of this policy sets out details about specific safeguarding issues that students may experience and outlines specific actions that would be taken in relation to individual issues.

7. Child-on-child abuse

For the purposes of this policy, “child-on-child abuse” is defined as abuse between children.

The school has a zero-tolerance approach to abuse, including child-on-child abuse, as confirmed in the Child Protection and Safeguarding Policy’s statement of intent.

All staff will be aware that child-on-child abuse can occur between students of any age and gender, both inside and outside of school, as well as online. All staff will be aware of the indicators of child-on-child abuse, how to identify it, and how to respond to reports. All staff will also recognise that even if no cases have been reported, this is not an indicator that child-on-child abuse is not occurring. All staff will speak to the DSL if they have any concerns about child-on-child abuse.

All staff will understand the importance of challenge inappropriate behaviour between peers and will not tolerate abuse as “banter” or “part of growing up.”

Child-on-child abuse can be manifested in many different ways, including:

• Bullying, including cyberbullying and prejudice-based or discriminatory bullying.
• Abuse in intimate personal relationships between peers – sometimes known as ‘teenage relationship abuse.’
• Physical abuse – this may include an online element which facilitates, threatens and/or encourages physical abuse.
• Sexual violence – this may include an online element which facilitates, threatens and/or encourages sexual violence.
• Sexual harassment, including online sexual harassment, which may be standalone or part of a broader pattern of abuse.
• Causing someone to engage in sexual activity without consent.
• The consensual and non-consensual sharing of nude and semi-nude images and/or videos.
• Up skirting.
• Initiation- and hazing-type violence and rituals, which can include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an online element.

All staff at Bridge House will be clear as to the school’s policy and procedures regarding child-on-child abuse and the role they have to play in preventing it and responding where they believe a child may be at risk from it.

Students will be made aware of how to raise concerns or make a report and how any reports will be handled. This includes the process for reporting concerns about friends or peers. Students will also be reassured that they will be taken seriously, be supported, and kept safe.

The school’s procedures for managing allegations of child-on-child abuse are outlined in the Child-on-child Abuse Policy. Staff will follow these procedures, as well as the procedures outlined in the school’s Anti-bullying Policy and Suspension and Exclusion Policy, where relevant.

8. Online safety and personal electronic devices

Danebrook House School will always adhere to the Online Safety Policy.

As part of a broad and balanced curriculum, all students will be made aware of online risks and taught how to stay safe online.

Through training, all staff members will be made aware of:

• Student attitudes and behaviours which may indicate they are at risk of potential harm online.
• The procedure to follow when they have a concern regarding a student’s online activity.

The school will ensure that suitable filtering systems are in place on ICT equipment to prevent children accessing inappropriate material, in accordance with the school’s Data and Cyber-security Breach Prevention and Management Plan. The school will, however, ensure that the use of filtering and monitoring systems does not cause “over blocking,” which may lead to unreasonable restrictions as to what students can be taught online.

Staff will be aware of the filtering systems in place and will know how to escalate concerns where they are identified.

Further information regarding the school’s approach to online safety can be found in the Online Safety Policy.

Communicating with parents

As part of the usual communication with parents, the school will reinforce the importance of students being safe online and inform parents that they will find it helpful to understand what systems the school uses to filter and monitor online use.

The school will also make it clear to parents what their children are being asked to do online for school.

Reviewing online safety

The school will carry out an annual review of its approach to online safety, supported by an annual risk assessment that considers and reflects the risks faced by students.

Personal electronic devices

The use of personal electronic devices, including mobile phones and cameras, by staff and students is prohibited, in accordance with the Staff ICT and Electronic Devices Policy and Students’ Personal Electronic Devices Policy.

Photographs and videos of students will be carefully planned before any activity with regard to consent and adhering to the school’s Data Protection Policy and Photography Policy. Teachers will oversee the planning of any events where photographs and videos will be taken.

Where photographs and videos will involve students who are CLA, adopted students, or students for whom there are security concerns,

the Headteacher will liaise with the DSL to determine the steps involved. The DSL will, in known cases of students who are CLA or who have been adopted, liaise with the students’ social workers, carers or adoptive parents to assess the needs and risks associated with the students.

Staff will report any concerns about students’ or other staff members’ use of personal electronic devices to the DSL, following the appropriate procedures.

Up skirting

Under the Voyeurism (Offences) Act 2019, it is an offence to operate equipment for the purpose of up skirting. “Operating equipment” includes enabling, or securing, activation by another person without that person’s knowledge, e.g., a motion-activated camera.

Up skirting will not be tolerated by the school. Any incidents of up skirting will be reported to the DSL, who will then decide on the next steps to take, which may include police involvement.

9. Consensual and non-consensual sharing of indecent images and videos

The school will ensure that staff are aware to treat the consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth produced sexual images) as a safeguarding concern.

Staff will receive appropriate training regarding child sexual development and will understand the difference between sexual behaviour that is considered normal and expected for the age of the student, and sexual behaviour that is inappropriate and harmful. Staff will receive appropriate training around how to deal with instances of sharing nudes and semi-nudes in the school community, including understanding motivations, assessing risks posed to students depicted in the images, and how and when to report instances of this behaviour.

Staff will be aware that creating, possessing, and distributing indecent imagery of children is a criminal offence, regardless of whether the imagery is created, possessed, and distributed by the individual depicted; however, staff will ensure that students are not unnecessarily criminalised.

Where a member of staff becomes aware of an incidence of sharing nudes and/or semi-nudes, they will refer this to the DSL as soon as possible.

The school’s full response to incidents of consensual and non-consensual sharing of indecent images and videos can be found in the Youth-produced Sexual Imagery Policy.

10. Context of safeguarding incidents

Safeguarding incidents can occur outside of school and can be associated with outside factors. All staff, particularly the DSL and deputy DSLs, will always consider the context of safeguarding incidents. Assessment of students’ behaviour will consider whether there are wider environmental factors that are a threat to their safety and/or welfare. The school will provide as much contextual information as possible when making referrals to CSCS.

11. Students potentially at greater risk of harm

The school recognises that some groups of students can face additional safeguarding challenges and understands that further barriers may exist when determining abuse and neglect in these groups of students. Additional considerations for managing safeguarding concerns and incidents amongst these groups are outline below.

Students who need social workers

Students may need social workers due to safeguarding or welfare needs. These needs can leave students vulnerable to further harm and educational disadvantage.

As a matter of routine, the DSL will hold and use information from the LA about whether a student has a social worker in order to make decisions in the best interests of the student’s safety, welfare, and educational outcomes.

Where a student needs a social worker, this will inform decisions about safeguarding, e.g., responding to unauthorised absence, and promoting welfare, e.g., considering the provision pastoral or academic support.

Home-educated children

Parents may choose elective home education (EHE) for their children. In some cases, EHE can mean that children are less visible to the services needed to safeguard and support them.

In line with the Education (Student Registration) (England) Regulations 2006, the school will inform the LA of all deletions from the admissions register when a student is taken off roll.

Where a parent has expressed their intention to remove a student from school for EHE, the school, in collaboration with the LA and other key professionals, will coordinate a meeting with the parent, where possible, before the final decision has been made, particularly if the student has SEND, is vulnerable, and/or has a social worker.

CLA

Children most become looked after because of abuse and/or neglect. Because of this, they can be at potentially greater risk in relation to safeguarding. The board will ensure that staff have the skills, knowledge and understanding to keep CLA safe.

This includes ensuring that the appropriate staff have the information they need, such as:

• Looked after legal status, i.e., whether they are looked after under voluntary arrangements with consent of parents, or on an interim or full care order.
• Contact arrangements with parents or those with parental responsibility.
• Care arrangements and the levels of authority delegated to the carer by the authority looking after the student.

The DSL will be provided with the necessary details of students’ social workers and the VSH.

Further details of safeguarding procedures for CLA are outlined in the school’s CLA Policy.

Students with SEND

When managing safeguarding in relation to students with SEND, staff will be aware of the following:

• Certain indicators of abuse, such as behaviour, mood, and injury, may relate to the student’s disability without further exploration; however, it should never be assumed that a student’s indicators relate only to their disability.
• Students with SEND can be disproportionally impacted by issues such as bullying, without outwardly showing any signs.
• Communication barriers may exist, as well as difficulties in overcoming these barriers.

When reporting concerns or making referrals for students with SEND, the above factors will always be taken into consideration. When managing a safeguarding issue relating to a student with SEND, the DSL will liaise with the school’s SENCO, as well as the student’s parents where appropriate, to ensure that the student’s needs are met effectively.

LGBTQ+ students

The fact that a student may be LGBTQ+ is not in itself an inherent risk factor for harm; however, staff will be aware that LGBTQ+ students can be targeted by other individuals. Staff will also be aware that, in some cases, a student who is perceived by others to be LGBTQ+ (whether they are or not) can be just as vulnerable as students who identify as LGBTQ+.

Staff will also be aware that the risks to these students can be compounded when they do not have a trusted adult with whom they can speak openly with. Staff will endeavour to reduce the additional barriers faced by these students and provide a safe space for them to speak out and share any concerns they have.

Students requiring mental health support.

All staff will be made aware that mental health problems can, in some cases, be an indicator that a student has suffered, or is at risk of suffering, abuse, neglect or exploitation. Use of the school premises for non-school activities

Where the organisation hires or rents out school facilities or the school premises to organisations or individuals, e.g., for providers to run community or extracurricular activities, it will ensure that appropriate arrangements are in place to keep students safe.

Where the organisation provides the activities under the direct supervision or management of school staff, child protection arrangements will apply. Where activities are provided separately by another body, this may not be the case; therefore, the organisation will seek assurance that the body concerned has appropriate safeguarding and

child protection policies and procedures in place, including inspecting these as needed. The organisation will also ensure that there are arrangements in place to liaise with the school on these matters where appropriate. The organisation will ensure safeguarding requirements are included in any transfer of control agreement, i.e., a lease or hire agreement, as a condition of use and occupation of the premises and specify that failure to comply with this would lead to termination of the agreement.

Extracurricular activities and clubs

External bodies that host extracurricular activities and clubs at the school, e.g., charities or companies, will work in collaboration with the school to effectively safeguard students and adhere to local safeguarding arrangements.

Staff and volunteers running extracurricular activities and clubs are aware of their safeguarding responsibilities and promote the welfare of students. Paid and volunteer staff understand how they should respond to child protection concerns and how to make a referral to CSCS or the police, if necessary.

All national advisory bodies of sport that receive funding from either Sport England or UK Sport must aim to meet the Standards for Safeguarding and Protecting Children in Sport.

12. Alternative provision

The school will remain responsible for a student’s welfare during their time at an alternative provider. When placing a student with an alternative provider, the school will obtain written confirmation that the provider has conducted all relevant safeguarding checks on staff.

13. Work experience

When a student is sent on work experience, the school will ensure that the provider has appropriate safeguarding policies and procedures in place. Where the school has students conduct work experience at the school, an enhanced DBS check will be obtained if the student is over the age of 16.

14. Concerns about students

If a member of staff has any concern about a student’s welfare, or a student has reported a safeguarding concern in relation to themselves or a peer, they will act on them immediately by speaking to the DSL or deputy DSLs.

Staff will be aware that students 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. Staff will be aware that this must not prevent them from having professional curiosity and speaking to the DSL, or deputy DSL, if they have a concern about a student.

All staff members are aware of the procedure for reporting concerns and understand their responsibilities in relation to confidentiality and information sharing, as outlined in the communication and confidentiality section of this policy.

Where the DSL is not available to discuss the concern with, staff members will contact the deputy DSLs with the matter. If a referral is made about a student by anyone other than the DSL, the DSL will be informed as soon as possible.

The LA will make a decision regarding what action is required within one working day of the referral being made and will notify the referrer. Staff are required to monitor a referral if they do not receive information from the LA regarding what action is necessary for the student. If the situation does not improve after a referral, the DSL will ask for reconsideration to ensure that their concerns have been addressed and that the situation improves for the student.

If early help is appropriate, the case will be kept under constant review. If the student’s situation does not improve, a referral will be considered. All concerns, discussions and decisions made, as well as the reasons for making those decisions, will be recorded in writing by the DSL and kept securely on CPOMS

If a student is in immediate danger, a referral will be made to CSCS and/or the police immediately. If a student has committed a crime, such as sexual violence, the police will be notified without delay.

Where there are safeguarding concerns, the school will ensure that the student’s wishes are always considered, and that there are systems available for students to provide feedback and express their views. When responding to safeguarding concerns, staff members will act calmly and supportively, ensuring that the student feels like they are being listened to and believed.

An inter-agency assessment will be undertaken where a child and their family could benefit from coordinated support from more than one agency. These assessments will identify what help the child and family require in preventing needs escalating to a point where intervention would be needed.

15. Managing referrals

The reporting and referral process outlined in the Reporting Safeguarding Concerns Process Flowchart will be followed accordingly.

All staff members, in particular the DSL, will be aware of the LA’s arrangements in place for managing referrals. The DSL will provide staff members with clarity and support where needed. When making a referral to CSCS or other external agencies, information will be shared in line with confidentiality requirements and will only be shared where necessary to do so.

The DSL will work alongside external agencies, maintaining continuous liaison, including multi-agency liaison where appropriate, in order to ensure the wellbeing of the students involved. The DSL will work closely with the police to ensure the school does not jeopardise any criminal proceedings, and to obtain help and support, as necessary.

Where a student has been harmed or is in immediate danger or at risk of harm, the referrer will be notified of the action that will be taken within one working day of a referral being made. Where this information is not forthcoming, the referrer will contact the assigned social worker for more information.

The school will not wait for the start or outcome of an investigation before protecting the victim and other students: this applies to criminal investigations as well as those made by CSCS. Where CSCS decide that a statutory investigation is not appropriate, the school will consider referring the incident again if it is believed that the student is at risk of harm. Where CSCS decide that a statutory investigation is not appropriate and the school agrees with this decision, the school will consider the use of other support mechanisms, such as early help and pastoral support.

At all stages of the reporting and referral process, the student will be informed of the decisions made, actions taken and reasons for doing so. Discussions of concerns with parents will only take place where this would not put the student or others at potential risk of harm. The school will work closely with parents to ensure that the student, as well as their family, understands the arrangements in place, such as in-school interventions, is effectively supported, and knows where they can access additional support.

16. Concerns about school safeguarding practices

Any concerns regarding the safeguarding practices at the school will be raised with the SLT, and the necessary whistleblowing procedures will be followed, as outlined in the Whistleblowing Policy. If a staff member feels unable to raise an issue with the SLT, they should access other whistleblowing channels such as the NSPCC whistleblowing helpline (0800 028 0285).

17. Safeguarding concerns and allegations of abuse against staff

All allegations against staff, supply staff, volunteers and contractors will be managed in line with the school’s Allegations of Abuse Against Staff Policy, a copy of which will be provided to, and understood by, all staff. The school will ensure all allegations against staff, including those who are not employees of the school, are dealt with appropriately and that the school liaises with the relevant parties.

When managing allegations against staff, the school will recognise the distinction between allegations that meet the harms threshold and allegations that do not, also known as “low-level concerns,” as defined in the Allegations of Abuse Against Staff Policy. Allegations that meet the harms threshold include instances where staff have:

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

Low-level concerns will be handled in line with the schools’ Low-level Safeguarding Concerns Policy.

18.  Communication and confidentiality

All child protection and safeguarding concerns will be treated in the strictest of confidence in accordance with school data protection policies.

Where there is an allegation or incident of sexual abuse or sexual violence, the victim is entitled to anonymity by law; therefore, the school will consult its policy and agree on what information will be disclosed to staff and others, in particular the alleged perpetrator and their parents. Where a report of sexual violence or sexual harassment is progressing through the criminal justice system, the school will do all it can to protect the anonymity of the students involved in the case.

Concerns will only be reported to those necessary for its progression and reports will only be shared amongst staff members and with external agencies on a need-to-know basis. During the disclosure of a concern by a student, staff members will not promise the student confidentiality and will ensure that they are aware of what information will be shared, with whom and why.

Where it is in the public interest, and protects students from harm, information can be lawfully shared without the victim’s consent, e.g., if doing so would assist the prevention, detection, or prosecution of a serious crime. Before doing so, the DSL will weigh the victim’s wishes against their duty to protect the victim and others. Where a referral is made against the victim’s wishes, it is done so carefully with the reasons for the referral explained to the victim and specialist support offered.

Depending on the nature of a concern, the DSL will discuss the concern with the parents of the students involved. Discussions with parents will not take place where they could potentially put a student at risk of harm. Discussion with the victim’s parents will relate to the arrangements being put in place to safeguard the victim, with the aim of understanding their wishes in terms of support arrangements and the progression of the report. Discussion with the alleged perpetrator’s parents will have regards to the arrangements that will impact their child, such as moving classes, with the reasons behind decisions being explained and the available support discussed. External agencies will be invited to these discussions where necessary.

Where confidentiality or anonymity has been breached, the school will implement the appropriate disciplinary procedures as necessary and will analyse how damage can be minimised and future breaches be prevented.

Where a student is leaving the school, the DSL will consider whether it is appropriate to share any information with the student’s new provider, in addition to the child protection file, that will allow the new provider to support the student and arrange appropriate support for their arrival.

19. Safer recruitment

The school’s full policy and procedures for safer recruitment are outlined in the Safer Recruitment Policy.

An enhanced DBS check with barred list information will be undertaken for all staff members engaged in regulated activity. A person will be in ‘regulated activity’ if, because of their work, they:

• Are responsible daily for the care or supervision of children.
• Regularly work in the school at times when children are on the premises.
• Regularly meet children under 18 years of age.

The DfE’s DBS Workforce Guides will be consulted when determining whether a position fits the child workforce criteria.

The Executive Director will conduct the appropriate pre-employment checks for al prospective employees, including internal candidates and candidates who have lived or worked outside the UK.

The appropriate DBS and suitability checks will be carried out for all Executive Director, volunteers, and contractors.

Staff suitability

All centres providing care for students under the age of eight must ensure that staff and volunteers working in these settings are not disqualified from doing so under the Childcare (Disqualification) and Childcare (Early Years Provision Free of Charge) (Extended Entitlement) (Amendment) Regulations 2018. A person may be disqualified if they:

• Have certain orders or other restrictions placed upon them.
• Have committed certain offences.

All staff members are required to sign the Staff Disqualification Declaration Form confirming that they are not disqualified from working in a schooling environment. A disqualified person will not be permitted to continue working at the school unless they apply for and are granted a waiver from Ofsted. The school will provide support with this process.

Ongoing suitability

Following appointment, consideration will be given to staff and volunteers’ ongoing suitability – to prevent the opportunity for harm to children or placing children at risk.

Referral to the DBS

The school will refer to the DBS anyone who has harmed a child or poses a risk of harm to a child, or if there is reason to believe the member of staff has committed an offence and has been removed from working in regulated activity. The duty will also apply in circumstances where an individual is deployed to another area of work that is not in regulated activity or they are suspended.

20. Single central record (SCR)

The school keeps an SCR which records all staff, including agency and third-party supply staff, and teacher trainees on salaried routes, who work at the school.

All members of the proprietor body are also recorded on the SCR.

The following information is recorded on the SCR:

• An identity checks.
• A barred list checks.
• An enhanced DBS checks.
• A prohibition from teaching check
• A check of professional qualifications, where required.
• A check to determine the individual’s right to work in the UK
• Additional checks for those who have lived or worked outside of the UK
• A section 128 check for those in management positions

For agency and third-party supply staff, the school will also record whether written confirmation from the employment business supplying the member of staff has been received which indicates that all the necessary checks have been conducted and the date that confirmation was received.

If any checks have been conducted for volunteers, this will also be recorded on the SCR. If risk assessments are conducted to assess whether a volunteer should be subject to an enhanced DBS check, the risk assessment will be recorded.

Written confirmation that supplies agencies have completed all relevant checks will also be included.

The school is free to record any other information it deems relevant.

The details of an individual will be removed from the SCR once they no longer work at the school.

21. Training

Staff members will undergo safeguarding and child protection training at induction, which will be updated on a termly basis and/or whenever there is a change in legislation.

The induction training will cover:

• The Child Protection and Safeguarding Policy.
• The Child-on-child Abuse Policy and procedures.
• The Staff Code of Conduct.
• Part one of ‘Keeping children safe in education’ (KCSIE) (or Annex A, if appropriate).
• The Behaviour Policy.
• The Children Missing Education Policy, including the safeguarding response to children who go missing from education.
• Appropriate child protection and safeguarding training, including online safety training.
• Information about the role and identity of the DSL and deputy DSLs.

All staff members will also receive regular safeguarding and child protection updates as required, but at least annually. Training will cover, at a minimum:

• The issues surrounding sexual violence and sexual harassment.
• Contextual safeguarding.
• How to keep CLA safe.
• CCE and the need to refer cases to the National Referral Mechanism.
• Updated online safety training.

Staff will receive opportunities to contribute towards and inform the safeguarding arrangements in the school.

The DSL and deputy DSLs will undergo child protection and safeguarding training and update this training at least every two years. The DSL and deputy DSLs will also obtain access to resources and attend any relevant or refresher training courses, ensuring they keep up to date with any developments relevant to their role. This will include training to understand:

• The assessment process for providing early help and statutory intervention, including local criteria for action and CSCS referral arrangements.
• How LAs (Local Authority) conduct child protection case conferences and a child protection review conference, to enable the DSL to attend and contribute to these effectively when required.
• The importance of providing information and support to CSCS.
• The lasting impact that adversity and trauma can have.
• How to be alert to the specific needs of children in need, students with SEND and/or relevant health conditions, and young carers.
• The importance of internal and external information sharing.
• The Prevent duty.
• The risks associated with online safety, including the additional risks faced online by students with SEND.

22.        Monitoring and review

This policy is reviewed at least annually by the DSL and the Headteacher. This policy will be updated as needed to ensure it is up to date with safeguarding issues as they emerge and evolve, including any lessons learnt.

Any changes made to this policy will be communicated to all members of staff. All members of staff are required to familiarise themselves with all processes and procedures outlined in this policy as part of their induction programme. The next scheduled review date for this policy is 1^st September 2024

Specific safeguarding issues

This appendix sets out details about specific safeguarding issues that students may experience and outlines specific actions that would be taken in relation to individual issues.

Here are the issues covered:

1. Domestic abuse
2. Homelessness
3. Children missing from education
4. Child abduction and community safety incidents
5. Child criminal exploitation (CCE)
6. Cyber-crime
7. Child sexual exploitation (CSE)
8. Modern slavery
9. FGM
10. Forced marriage
11. Radicalisation
12. Students with family members in prison
13. Students required to give evidence in court
14. Mental health
15. Serious violence

Domestic abuse

For the purposes of this policy, and in line with the Domestic Abuse Act 2021, “domestic abuse” is defined as abusive behaviour of a person towards another person (including conduct directed at someone else, e.g., the person’s child) where both are aged 16 or over and are personally connected. “Abusive behaviour” includes physical or sexual abuse, violent or threatening behaviour, controlling or coercive behaviour, economic abuse, psychological or emotional abuse, or another form of abuse. “Personally connected” includes people who:

• Are, have been, or have agreed to be married to each other.
• Are, have been, or have agreed to be in a civil partnership with each other.
• Are, or have been, in an intimate personal relationship with each other.
• Each have, or had, a parental relationship towards the same child.
• Are relatives.

The school will recognise the impact of domestic abuse on children, as victims, if they see, hear, or experience the effects of domestic abuse. All staff will be aware of the signs of domestic abuse and follow the appropriate safeguarding procedures where concerns arise.

Homelessness

The DSL and deputy DSLs will be aware of the contact details and referral routes into the Local Housing Authority so that concerns over homelessness can be raised as early as possible.

Indicators that a family may be at risk of homelessness include:

• Household debt.
• Rent arrears.
• Domestic abuse.
• Anti-social behaviour.
• Any mention of a family moving home because “they have to.”

Referrals to the Local Housing Authority do not replace referrals to CSCS where a child is being harmed or at risk of harm. For 16- and 17-year-olds, homelessness may not be family-based and referrals to CSCS will be made as necessary where concerns are raised.

Children missing from education.

A child going missing from school is a potential indicator of abuse or neglect and, as such, these children are increasingly at risk of being victims of harm, exploitation, or radicalisation. Staff will monitor students that go missing from the school, particularly on repeat occasions, and report them to the DSL following normal safeguarding procedures, in accordance with the Children Missing Education Policy. The school will inform the LA of any student who fails to attend regularly or has been absent without the school’s permission for a continuous period of 10 school days or more.

Admissions register.

Students are placed on the admissions register at the beginning of the first day that is agreed by the school, or when the school has been notified that the student will first be attending. The school will notify the LA within 5 days of when a student’s name is added to the admissions register.

The school will ensure that the admissions register is kept up-to-date and accurate at all times and will inform parents when any changes occur. Two emergency contacts will be held for each student where possible. Staff will monitor students who do not attend the school on the agreed date and will notify the LA at the earliest opportunity.

If a parent notifies the school that their child will live at a different address, the school will record the following information on the admissions register:

• The full name of the parent with whom the student will live.
• The new address
• The date from when the student will live at that address.

If a parent notifies the school that their child will be attending a different school, or is already registered at a different school, the following information will be recorded on the admissions register:

• The name of the new school
• The date on which the student first attended, or is due to attend, that school

Where a student moves to a new school, the school will use a secure internet system to securely transfer students’ data.

To ensure accurate data is collected to allow effective safeguarding, the school will inform the LA of any student who is going to be deleted from the admission register, in accordance with the Education (Student Registration) (England) Regulations 2006 (as amended), where they:

• Have been taken out of the school by their parents, and are being educated outside the national education system, e.g., home education.
• Have ceased to attend the school, and no longer live within a reasonable distance of the premises.
• Have been certified by the school’s medical officer as unlikely to be in a fit state of health to attend, before ceasing to be of compulsory school age, and their parent has not indicated the intention to the student continuing to attend school after ceasing to be of compulsory school age.
• Have been in custody for a period of more than four months due to a final court order and the school does not believe they will be returning to the school at the end of that period.
• Have been permanently excluded.

The school will also remove a student from the admissions register where the school and LA has been unable to establish the student’s whereabouts after making reasonable enquiries into their attendance.

If a student is to be removed from the admissions register, the school will provide the LA with the following information:

• The full name of the student
• The full name and address of any parent with whom the student lives
• At least one telephone number of the parent with whom the student lives
• The full name and address of the parent with whom the student is going to live, and the date that the student will start living there, if applicable
• The name of the student’s new school and the student’s expected start date there, if applicable
• The grounds for removal from the admissions register under regulation 8 of the Education (Student Registration) (England) Regulations 2006 (as amended)

The school will work with the LA to establish methods of making returns for students back into the school. The school will highlight to the LA where they have been unable to obtain necessary information from parents, e.g., where an address is unknown. The school will also highlight any other necessary contextual information, including safeguarding concerns.

Child abduction and community safety incidents

For the purposes of this policy, “child abduction” is defined as the unauthorised removal or retention of a child from a parent or anyone with legal responsibility for the child. Child abduction can be committed by parents and other relatives, other people known to the victim, and strangers.

All staff will be alert to community safety incidents taking place in the vicinity of the school that

may raise concerns regarding child abduction, e.g., people loitering nearby or unknown adults conversing with students.

Students will be provided with practical advice and lessons to ensure they can keep themselves safe outdoors.

Child criminal exploitation (CCE)

For the purposes of this policy, “child criminal exploitation” is defined as a form of abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into taking part in criminal activity, for any of the following reasons:

• In exchange for something the victim needs or wants
• For the financial advantage or other advantage of the perpetrator or facilitator
• Through violence or the threat of violence

Specific forms of CCE can include:

• Being forced or manipulated into transporting drugs or money through county lines.
• Working in cannabis factories.
• Shoplifting or pickpocketing.
• Committing vehicle crime.
• Committing, or threatening to commit, serious violence to others.

The school will recognise that students involved in CCE are victims themselves, regardless of whether they have committed crimes, and even if the criminal activity appears consensual. The school will also recognise that students of any gender are at risk of CCE.

School staff will be aware of the indicators that a student is the victim of CCE, including:

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

County lines

For the purposes of this policy, “county lines” refers to gangs and organised criminal networks exploiting children to move, store or sell drugs and money into one or more areas, locally and/or across the UK.

As well as the general indicators for CCE, school staff will be aware of the specific indicators that a student may be involved in county lines, including:

• Going missing and subsequently being found in areas away from their home.
• Having been the victim or perpetrator of serious violence, e.g., knife crime.
• Receiving requests for drugs via a phone line.
• Moving drugs.
• Handing over and collecting money for drugs.
• Being exposed to techniques such as ‘plugging,’ where drugs are concealed internally to avoid detection.
• Being found in accommodation they have no connection with or a hotel room where there is drug activity.
• Owing a ‘debt bond’ to their exploiters.
• Having their bank account used to facilitate drug dealing.

Staff will be made aware of students with missing episodes who may have been trafficked for the purpose of transporting drugs. Staff members who suspect a student may be vulnerable to, or involved in, county lines activity will immediately report all concerns to the DSL.

The DSL will consider referral to the National Referral Mechanism on a case-by-case basis and consider involving local services and providers who offer support to victims of county lines exploitation.

Cyber-crime

For the purposes of this policy, “cyber-crime” is defined as criminal activity committed using computers and/or the internet. This includes ‘cyber-enabled’ crimes, i.e., crimes that can happen offline but are enabled at scale and at speed online, and ‘cyber-dependent’ crimes, i.e., crimes that can be committed only by using a computer. Crimes include:

• Unauthorised access to computers, known as ‘hacking.’
• Denial of Service attacks, known as ‘booting.’
• Making, supplying, or obtaining malicious software, or ‘malware,’ e.g., viruses, spyware, ransomware, botnets, and Remote Access Trojans with the intent to commit further offence.

All staff will be aware of the signs of cyber-crime and follow the appropriate safeguarding procedures where concerns arise. This may include the DSL referring students to the National Crime Agency’s Cyber Choices programme.

Child sexual exploitation (CSE)

For the purposes of this policy, “child sexual exploitation” is defined as a form of sexual abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity, for any of the following reasons:

• In exchange for something the victim needs or wants
• For the financial advantage, increased status or other advantage of the perpetrator or facilitator
• Through violence or the threat of violence

The school will recognise that CSE can occur over time or be a one-off occurrence, and may happen without the student’s immediate knowledge, e.g., through others sharing videos or images of them on social media. The school will recognise that CSE can affect any student who has been coerced into engaging in sexual activities, even if the activity appears consensual; this includes students aged 16 and above who can legally consent to sexual activity. The school will also recognise that students may not realise they are being exploited, e.g., they believe they are in a genuine romantic relationship.

School staff will be aware of the key indicators that a student is the victim of CSE, including:

• Appearing with unexplained gifts, money, or new possessions.
• Associating with other children involved in exploitation.
• Suffering from changes in emotional wellbeing.
• Misusing drugs or alcohol.
• Going missing for periods of time or regularly coming home late.
• Regularly missing school or education or not taking part.
• Having older partners.
• Suffering from sexually transmitted infections.
• Displaying sexual behaviours beyond expected sexual development.
• Becoming pregnant.

All concerns related to CSE will be managed in line with the school’s Child Sexual Exploitation (CSE) Policy.

Where CSE, or the risk of it, is suspected, staff will discuss the case with the DSL. If after discussion a concern remains, local safeguarding procedures will be triggered, including referral to the LA. The LA and all other necessary authorities will then handle the matter to conclusion. The school will cooperate as needed.

Modern slavery

For the purposes of this policy, “modern slavery” encompasses human trafficking and slavery, servitude, and forced or compulsory labour. This can include CCE, CSE, and other forms of exploitation.

All staff will be aware of and alert to the signs that a student may be the victim of modern slavery. Staff will also be aware of the support available to victims of modern slavery and how to refer them to the National Referral Mechanism.

FGM

For the purposes of this policy, “FGM” is defined as all procedures involving the partial or total removal of the external female genitalia or other injury to the female genital organs. FGM is illegal in the UK and a form of child abuse with long-lasting harmful consequences.

All staff will be alert to the possibility of a student being at risk of FGM, or already having suffered FGM. If staff are worried about someone who is at risk of FGM or who has been a victim of FGM, they are required to share this information with CSCS and/or the police. The school’s procedures relating to managing cases of FGM and protecting students will reflect multi-agency working arrangements.

As outlined in Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime Act 2015), teachers are legally required to report to the police any discovery, whether through disclosure by the victim or visual evidence, of FGM on a student

under the age of 18. Teachers failing to report such cases may face disciplinary action. Teachers will not examine students, and so it is rare that they will see any visual evidence, but they must personally report to the police where an act of FGM appears to have been carried out. Unless the teacher has a good reason not to, they should also consider and discuss any such case with the DSL and involve CSCS as appropriate. NB: This does not apply to any suspected or at-risk cases, nor if the individual is over the age of 18. In such cases, local safeguarding procedures will be followed.

All staff will be aware of the indicators that students may be at risk of FGM. While some individual indicators they may not indicate risk, the presence of two or more indicators could signal a risk to the student. It is important to note that the student may not yet be aware of the practice or that it may be conducted on them, so staff will be sensitive when broaching the subject.

Indicators that a student may be at heightened risk of undergoing FGM include:

• The socio-economic position of the family and their level of integration into UK society.
• The student coming from a community known to adopt FGM.
• Any girl with a mother or sister who has been subjected to FGM.
• Any girl withdrawn from PSHE.

Indicators that FGM may take place soon include:

• When a female family elder is visiting from a country of origin.
• A girl confiding that she is to have a ‘special procedure’ or a ceremony to ‘become a woman.’
• A girl requesting help from a teacher if she is aware or suspects that she is at immediate risk.
• A girl, or her family member, talking about a long holiday to her country of origin or another country where FGM is prevalent.

All staff will be vigilant to the signs that FGM has already taken place so that help can be offered, enquiries can be made to protect others, and criminal investigations can begin. Indicators that FGM may have already taken place include the student:

• Having difficulty walking, sitting, or standing.
• Spending longer than normal in the bathroom or toilet.
• Spending prolonged periods of time away from a classroom during the day with bladder or menstrual problems.
• Having prolonged or repeated absences from school, followed by withdrawal or depression.
• Being reluctant to undergo normal medical examinations.
• Asking for help, but not being explicit about the problem due to embarrassment or fear.

FGM is included in the definition of “‘honour-based’ abuse (HBA),” which involves crimes that have been committed to defend the honour of the family and/or community. All forms of HBA are forms of abuse and will be treated and escalated as such. Staff will be alert to the signs of HBA, including concerns that a child is at risk of HBA, or has already suffered from HBA, and will consult with the DSL who will activate local safeguarding procedures if concerns arise.

Forced marriage

Forced marriage is a crime. It is a form of abuse directed towards a child or vulnerable adult, including adults who are forced into marriage against their free will.

Forced marriage is a marriage where one or both spouses do not consent to the marriage but are coerced into it. Force can be physical, psychological, financial, sexual, and emotional pressure. A lack of full and free consent can be where a person does not consent or where they cannot consent, e.g., due to some forms of SEND. Where an individual lacks the capacity to consent to marriage, coercion is not required for a marriage to be forced.

Under the Anti-social Behaviour, Crime and Policing Act 2014 a person commits an offence if he or she uses violence, threats or any other form of coercion for the purpose of causing another person to enter into a marriage and believes, or ought reasonably to believe, that the conduct may cause the other person to enter into the marriage without free and full consent.

It is an offence to do anything intended to cause a child to marry before the child’s eighteenth birthday, whether or not the conduct amounts to violence, threats, or any other form of coercion or deception

All staff will be alert to the indicators that a student is at risk of, or has undergone, forced marriage, including, but not limited to, the student:

• Being absent from school – particularly where this is persistent.
• Requesting for extended leave of absence and failure to return from visits to country of origin.
• Being fearful about forthcoming school holidays.
• Being subjected to surveillance by siblings or cousins at school.
• Demonstrating a decline in behaviour, engagement, performance, exam results or punctuality.
• Being withdrawn from school by their parents.
• Being removed from a day centre when they have a physical or learning disability.
• Not being allowed to attend extracurricular activities.
• Suddenly announcing that they are engaged to a stranger, e.g., to friends or on social media.
• Having a family history of forced marriage, e.g., their older siblings have been forced to marry.
• Being prevented from going on to further or higher education.
• Showing signs of mental health disorders and behaviours, e.g., depression, self-harm, anorexia.
• Displaying a sudden decline in their educational performance, aspirations, or motivation.

Staff who have any concerns regarding a student who may have undergone, is currently undergoing, or is at risk of forced marriage will speak to the DSL or Headteacher and local safeguarding procedures will be followed – this could include referral to CSCS, the police or the Forced Marriage Unit. The DSL or Headteacher will ensure the student is spoken to privately about these concerns and further action taken as appropriate. Students will always be listened to, and their comments taken seriously.

It will be made clear to staff members that they should not approach the student’s family or those with influence in the community, without the express consent of the student, as this will alert them to the concerns and may place the student in further danger.

Advice will be sought from the Forced Marriage Unit following any suspicion of forced marriage among students.

If a student is being forced to marry, or is fearful of being forced to, the school will be especially vigilant for signs of mental health disorders and self-harm. The student will be supported by the DSL and senior mental health lead and referrals will be made on a case-by-case basis.

Staff members will make themselves aware of how they can support victims of forced marriage in order to respond to the victims needs at an early stage and be aware of the practical help they can offer, e.g., referral to social services and local and national support groups.

Local child safeguarding procedures will be activated following concerns regarding forced marriage – the school will use existing national and local protocols for multi-agency liaison with police and children’s social care.

The school will support any victims to seek help by:

• Making them aware of their rights and choices to seek legal advice and representation.
• Recording injuries and making referrals for medical examination where necessary.
• Providing personal safety advice.
• Developing a safety plan in case they are seen, e.g., by preparing another reason for why the victim is seeking help.

The school will establish where possible whether students at risk of forced marriage have a dual nationality or two passports.

The school will aim to create an open environment where students feel comfortable and safe to discuss the problems they are facing – this means creating an environment where forced marriage is discussed openly within the curriculum and support and counselling are provided routinely.

The school will take a whole school approach towards educating on forced marriage in the school curriculum and environment – in particular, the school’s RSHE curriculum will incorporate teaching about the signs of forced marriage and how to obtain help. Appropriate materials and sources of further support will be signposted to students. Students will be encouraged to access appropriate advice, information, and support.

Teachers and other staff members will be educated through CPD (Continuing Professional Development) about the issues surrounding forced marriage and the signs to look out for.

Radicalisation

For the purposes of this policy, “radicalisation” refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.

For the purposes of this policy, “extremism” refers to the vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty, and the mutual respect and tolerance of different faiths and beliefs. Extremism also includes calling for the death of members of the armed forces.

For the purposes of this policy, “terrorism” refers to an action that endangers or causes serious violence to a person or people, serious damage to property, or seriously interferes with or disrupts an electronic system. The use or threat of these actions must be designed to influence the government or intimidate the public and be made for the purpose of advancing a political, religious, or ideological cause.

Protecting students from the risk of radicalisation is part of the school’s wider safeguarding duties. The school will actively assess the risk of students being radicalised and drawn into extremism and/or terrorism. Staff will be alert to changes in students’ behaviour which could indicate that they may need help or protection. Staff will use their professional judgement to identify students who may be at risk of radicalisation and act appropriately, which may include contacting the DSL or making a Prevent referral. The school will work with local safeguarding arrangements as appropriate.

The school will ensure that they engage with parents and families, as they are in a key position to spot signs of radicalisation. In doing so, the school will assist and advise family members who raise concerns and provide information for support mechanisms. Any concerns over radicalisation will be discussed with the student’s parents, unless the school has reason to believe that the child would be placed at risk as a result.

The DSL will undertake Prevent awareness training to be able to provide advice and support to other staff on how to protect students against the risk of radicalisation. The DSL will hold formal training sessions with all members of staff to ensure they are aware of the risk indicators and their duties regarding preventing radicalisation.

The Prevent duty.

Under section 26 of the Counterterrorism and Security Act 2015, all schools are subject to a duty to have “due regard to the need to prevent people from being drawn into terrorism”, known as “the Prevent duty”. The Prevent duty will form part of the school’s wider safeguarding obligations.

The school’s procedures for carrying out the Prevent duty, including how it will engage and implement the Channel programme, are outline in the Prevent Duty Policy.

Students with family members in prison

Students with a family member in prison will be offered pastoral support, as necessary. They will receive a copy of ‘Are you a young person with a family member in prison?’ From Action for Prisoners’ Families where appropriate and allowed the opportunity to discuss questions and concerns.

Students required to give evidence in court

Students required to give evidence in criminal courts, either for crimes committed against them or crimes they have witnessed, will be offered appropriate pastoral support.

Students will be provided with the booklet ‘Going to Court’ From HMCTS where appropriate and allowed the opportunity to discuss questions and concerns.

Students will be provided with the booklet ‘Going to Court and being a witness’ From HMCTS where appropriate and allowed the opportunity to discuss questions and concerns.

Mental health

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

Staff will not attempt to make a diagnosis of mental health problems – the school will ensure this is done by a trained mental health professional. Staff will, however, be encouraged to identify students whose behaviour suggests they may be experiencing a mental health problem or may be at risk of developing one. Staff will also be aware of how students’ experiences can impact on their mental health, behaviour, and education.

Staff who have a mental health concern about a student that is also a safeguarding concern will act in line with this policy and speak to the DSL or deputy DSLs.

The school will access a range of advice to help them identify students in need of additional mental health support, including working with external agencies.

In all cases of mental health difficulties, the school’s Social, Emotional and Mental Health (SEMH) Policy will be always consulted and adhered to.

Serious violence

Through training, all staff will be made aware of the indicators which may signal a student is at risk from, or is involved with, serious violent crime. These indicators include, but are not limited to:

• Increased absence from school.
• A change in friendships.
• Relationships with older individuals or groups.
• A significant decline in academic performance.
• Signs of self-harm.
• A notable change in wellbeing.
• Signs of assault.
• Unexplained injuries.
• Unexplained gifts or new possessions.

Staff will be made aware of some of the most significant risk factors that could increase a student’s vulnerability to becoming involved in serious violence. These risk factors include, but are not limited to:

• Being male.
• Having been frequently absent from school.
• Having been permanently excluded from school.
• Having experienced child maltreatment.
• Having been involved in offending, such as theft or robbery.

Staff members who suspect a student may be vulnerable to, or involved in, serious violent crime will immediately report their concerns to the DSL.