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Safeguarding and Prevent Policy

Introduction

Goddard Veterinary Nursing College (GVNC) has a duty of care to safeguard young people employed or enrolled on its training programmes (apprentices or apprentices) from harm. The Children Act, 2004 places a statutory duty on key people and bodies to make arrangements to safeguard and promote the welfare of young people. The Every Child Matters: Change for Children programme, identifies 5 key outcomes for every child and young person, whatever their background or circumstance. These are to: be healthy; stay safe; enjoy and achieve; make a positive contribution; achieve economic well-being.

GVNC believes that all young people have a right to protection, and the needs of disabled children and others who may be particularly vulnerable must be taken into account. GVNC will ensure the safety and protection of all in its employ or enrolled on its training programmes through adherence to the safeguarding guidelines adopted by the organisation. In this policy statement any references to children or young people who should be considered to include vulnerable adults within its scope.

Key Terminology:

  • A child is defined as a person under the age of 18 (The Children Act 1989).
  • A vulnerable adult has been defined in the Police Act 1997 (Enhanced Criminal Record Certificates) (Protection of Vulnerable Adults) Regulations 2000 as a person aged 18 or over who is receiving …..”any services provided in an establishment catering for a person with learning difficulties” with “a learning or physical disability”, “a physical or mental illness, chronic or otherwise, including an addiction to alcohol or drugs”, “a reduction in physical or mental capacity” and as a consequence has “an impairment in a person’s ability to protect himself/herself from assault abuse or neglect”.
  • The term “staff” will be used to describe those employed by GVNC, including those that are part time.
  • Abuse is defined as the “harming of another individual usually by someone who is in a position of power, trust or authority over that individual. The harm may be physical, psychological or emotional” (Centre for Policy on Ageing, 1996).

The main forms of abuse and neglect are generally classified under the following ten headings (this includes observations of a child to the abuse):

1) Physical abuse

The non-accidental infliction of physical force that results (or could result) in bodily injury, pain, or impairment.

2) Domestic violence

Incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse by someone who is or has been an intimate partner or family member, regardless of gender or sexuality. Domestic abuse is not just about partners, but all family relationships including forced marriage.

3) Sexual abuse

Direct or indirect involvement in sexual activity without consent. This could also be the inability to consent, pressure or inducement to consent or take part.

Please refer to the policy addendum relating to sexual harassment.

4) Psychological (emotional) abuse

Acts or behaviour which impinge on the emotional health of, or which causes distress or anguish to individuals. This may also be present in other forms of abuse.

5) Financial or material abuse

Unauthorised, fraudulent obtaining and improper use of funds, property, or any resources of an adult at risk from abuse.

6) Modern slavery

Encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive, and force individuals into a life of abuse, servitude and inhumane treatment.

7) Discriminatory abuse

Discriminatory abuse exists when values, beliefs, or culture result in a misuse of power that denies mainstream opportunities to some groups or individuals.

8) Organisational (Institutional) abuse

Institutional abuse occurs where the culture of the organisation (such as a care home) places emphasis on the running of the establishment and the needs of the staff above the needs and care of the adult, including neglect and poor care practice within an institution or specific care setting, such as a hospital or care home, for example, or in relation to care provided in one’s own home from domiciliary services.

9) Neglect and acts of omission

Ignoring or withholding physical or medical care needs which result in a situation or environment detrimental to individual(s). Ill-treatment and wilful neglect of a person who lacks capacity are now criminal offences under the Mental Capacity Act.

10) Self-neglect

Self-neglect is characterised as the behaviour of a person that threatens his/her own health or safety. Self-neglect generally manifests itself as a refusal or failure to provide himself/herself with adequate food, water, clothing, shelter, personal hygiene, medication (when indicated), and safety precautions. The definition of self-neglect excludes a situation in which a mentally competent adult, who understands the consequences of his/her decisions, makes a conscious and voluntary decision to engage in acts that threaten his/her health or safety as a matter of personal choice.

Aims of the Policy

The aim of the safeguarding policy is to outline the practice and procedures for staff to contribute to the prevention of the abuse of children through raising awareness and providing a clear framework for action when abuse is suspected. GVNC is unequivocally committed to providing children and vulnerable adults with appropriate safety and protection whilst in the care of the organisation and to allow all staff to make informed and confident responses to specific issues. The policy covers all staff and areas of work with specific guidance for those regularly in contact with children and vulnerable adults.

Promotion of this Policy

This policy will be included in all GVNC Handbooks associated with training of apprentices and apprentices – namely, the Student Handbook, Policy Handbook for Learners and Staff, and Clinical Supervisors & Mentors Training Practice Handbook.

It is promoted at induction and referred to throughout the course.

The curriculum will include training on scam email, social media, Equity, Diversity and Inclusion (EDI), sexual harassment, civility, safeguarding and wellbeing on induction and within the first month of learning then annually during the length of the course. Within the curriculum will be an ongoing culture of safeguarding, wellbeing and civility.

Within the policy, the procedure for raising a concern and the process that may follow is provided to apprentices via the above documents.

Who to report concerns to?

Personal Tutor, Cohort Lead or a trusted member of staff.

What happens when I tell a member of staff about a problem I have?

If you have any worries or concerns during your time at college, there are lots of people you can talk to including your Personal Tutor and Cohort Lead. Conversations you have with members of staff will be in a secure and safe environment and no information will be shared unless necessary. If you talk to a member of staff about an issue which means that you may be at risk of harm or harming someone else or are involved in something illegal, that member of staff will need to pass the information on to other members of staff and external agencies.

Staff involved in safeguarding issues

All staff are involved in keeping apprentices safe, but we have certain members of staff who are experts in this area, and these are the people that will deal with specific issues and pass them on to the local authority or police when necessary.

Training of Employees on this Policy

All employees who are involved in teaching and training apprentices within the college will receive this policy as part of their induction. They will be trained by the Designated Safeguarding Lead (DSL) or a Deputy Safeguarding Lead specifically on the information in this policy. GVNC will ensure that new members of staff undertake safeguarding training, and ensure they read and fully understand the safeguarding policy, signing a statement to this effect. Regular training sessions are held for all staff to keep policies and procedures fresh in everyone’s minds. This also provides an opportunity to update staff on any changes to the policy or legislative developments. Email updates regarding safeguarding are shared among the team and embedded into lessons where appropriate.

Designated Safeguarding Lead (DSL)

A Designated Safeguarding Lead, who has a minimum level 3 qualification in safeguarding shall be appointed. This is currently the Training Manager, Emma Eve-Raw. The DSL is required to maintain their qualification status and to attend suitable safeguarding continuing professional development

(CPD) at least every other year. The DSL role is included in the job description of the Training Manager.

A Deputy Safeguarding Lead will also be appointed and fully trained. This is currently Claire Digby- Maloney. They are also required to attend suitable CPD every other year and this role is included in their job description.

All issues or incidents are to be reported to the DSL (or a deputy DSL in the case that the DSL is absent) immediately staff become aware of them. The DSL (or her deputy) will thoroughly document any issues or incidents reported to them and will decide how to proceed. This decision will also be documented, and all records will be shared with external agencies where it is necessary for them to be involved.

If a concern is raised about a member of the team this must be directed to the Head of Centre. If the concern is regarding the Head of Centre then to the principal and subsequently the Governance board for review of the concern / allegation.

Rights and Responsibilities

Responsibilities of the Senior Management Team:

  • To ensure staff are aware of the safeguarding on policy and understand their responsibilities.
  • To ensure there is a Designated Safeguarding Lead within the organisation and ensure they have had appropriate training and support for this role. This person is the Head of Centre, Emma Eve-Raw (contact details: email; eeveraw@gvgtraining.education, phone number; 0204 558 8826).
  • To ensure that there are Deputy Designated Safeguarding Leads, who are suitably qualified. This is Claire Digby-Maloney (contact details: e-mail cdigbymaloney@gvgtraining.education, phone number 020 4558 0584). Claire can be contacted in Emma’s absence.
  • The Local Authority Designated Officer (LADO) is Helen Curtis (contact details: email; helen.curtis@redbridge.gov.uk, telephone; 0208 708 5350). The Local Authority Designated Officer (LADO) works within Children’s Services and should be alerted to all cases in which it is alleged that a person who works with children has:
    • Behaved in a way that has harmed, or may have harmed, a child
    • Possibly committed a criminal offence against children, or related to a child
    • Behaved towards a child or children in a way that indicates s/he is unsuitable to work with children.

The LADO role applies to paid, unpaid, volunteer, casual, agency and self-employed workers. They capture concerns, allegations or offences emanating from outside of work.
The LADO is involved from the initial phase of the allegation through to the conclusion of the case.

They will provide advice, guidance and help to determine whether the allegation sits within the scope of the procedures.

The LADO helps co-ordinate information-sharing with the right people and will also monitor and track any investigation, with the aim to resolve it as quickly as possible.

  • To identify a designated person responsible for Child Protection within the organisation and ensure they have had appropriate training and support for this role. This person is Emma Eve-Raw.
  • To identify deputies responsible for Child Protection when the designated person is not at work and ensure they have had appropriate training and support for this role. The designated Deputy is Claire Digby-Maloney.
  • Ensure every member of staff knows the name of the person responsible for safeguarding and their role and the designated deputy and their role.
  • To notify the appropriate agencies if abuse is identified or suspected.
  • To support and where possible secure the safety of individuals and ensure that all referrals to services have full information in relation to identified risk and vulnerability.
  • To adopt recruitment and selection procedures and other management processes that help to deter, reject, or identify people who might abuse children or vulnerable adults, or are otherwise unsuited to work with them. This will include advising all applicants who will be working with children/vulnerable adults that an enhanced Disclosure and Barring Service (DBS) check will be carried out on them, that full identifying details will be required and that any subsequent offer of employment will be subject to the DBS check and obtaining two satisfactory references, one of which must be from their current or most recent employer (and not from relatives or people writing purely in the capacity of friend). Applicants will also be advised that GVNC reserve the right to request a DBS check at any time during their employment and that refusal to provide permission for a DBS check will constitute an act of grass misconduct.
  • To DBS check all staff that have access to or work with children and vulnerable adults and ensure that accurate records of all checks carried out on staff are maintained.
  • To put in place procedures for ensuring that those who report abuse are supported.
  • Follow the procedures set out by the Local Safeguarding Children Board’s (LSCB’s), which are known as the SET procedures.
  • Liaise with the relevant responsible nominee (e.g., social worker) where an individual is the subject of a child/adult protection plan and ensure that the child is supported in line with this.
  • Ensure all records regarding child protection/protection of vulnerable adults are kept
  • securely, in locked locations, with only the DSL and the designated person/deputy responsible for child protection having access.
  • To develop a range of associated policies which impact on the safeguarding of children and vulnerable adults, including health and safety, equality and diversity, confidentiality, and e- safety,
  • Ensure this policy document is reviewed annually and updated.

Responsibilities of Staff

  • To be familiar with the safeguarding policy and procedures, as well as any associated policies.
  • To take appropriate action in line with the policies of GVNC, including reporting any concerns to the designated person/deputy responsible for child protection.
  • Provide support or specific services as required by the child/adult protection plan as instructed by the designated responsible person/designated deputy.
  • To refer any learner of concern under early detection relating to mental health or wellbeing by completing the GVNC Mental Health and Wellbeing Early Detection Form. Anyone deemed to be at risk will be added to our list of learners that we keep for early detection purposes. The DSL and Deputy plus the Deputy Head of centre will be made aware of concerns and cohorts leads / personal tutors advised at monthly meetings that a learner has been flagged to monitor though will not be advised of the details. Early detection forms must be submitted via the safeguarding email address as well as any safeguarding referrals.
  • Staff are advised to report / discuss concerns with the DSL or Deputy DSL prior to reporting via the submission forms to risk assess the situation.
  • To declare any relevant existing or subsequent convictions. Failure to do so will be regarded as gross misconduct, possibly resulting in dismissal.
  • All new employees must provide at least two written references from their previous last two employers. The applicant will need to confirm there is no reason why they are unable to work with children and/or adults and that they have no criminal convictions. They must state the reason they left their last employer, and a DBS check will be conducted within the first 3 months of employment and prior to being left alone with learners.
  • To support those who report abuse.
  • To follow Company policy regarding the confidentiality of information, including that information relating to child protection/protection of vulnerable adults.
  • A ‘looked after child’ – therefore by definition is a vulnerable child and will be monitored and GVNC will work with the allocated social worker, local authority and foster parents to ensure regular meetings are held and the welfare of the child paramount with a lower reporting threshold. Children and young adults within an abusive household not subject to abuse – we will consider this abuse by observation and the risk of any apprentice/ learner in this situation supported accordingly including low threshold reporting and inclusion of authorities as necessarily1.
  • The Governance board will take an annual safeguarding quiz and all sign to say they have read the updated KCSIE in the September quarterly board meeting. SG / PREVENT policies reviewed, and any updates discussed.

Rights of Children and Vulnerable Adults

  • To be made aware of this policy
  • To have alleged incidents recognised and taken seriously
  • To receive fair and respectful treatment throughout
  • To be involved in any process as appropriate
  • To receive information about the process and outcomes
  • To have their comments treated confidentially (but their concerns may be shared if they or others are at significant risk)

Awareness of Actual or Likely Occurrences of Abuse

There are a number of ways in which abuse becomes apparent:

  • A child/vulnerable adult discloses abuse.
  • Someone else discloses that a child/vulnerable adult has told him/her or that he/she strongly believes a child/vulnerable adult has been or is being abused.
  • A child/vulnerable adult may show signs of abuse (see below).
  • Someone else’s behaviour or the way in which he/she relates to a child/vulnerable adult causes concern.

There are other types of abuse which always involve aspects of the five definitions of abuse from Working Together however are wider themes.

These are:

Female Genital Mutilation (FGM) is defined in multi-agency statutory guidance on female genital mutilation April 2016 as: “FGM is a procedure where the female genital organs are injured or changed and there is no medical reason for this. It is frequently a very traumatic and violent act for the victim and can cause harm in many ways. The practice can cause severe pain and there may be immediate and/or long-term health consequences, including mental health problems, difficulties in childbirth, causing danger to the child and mother; and/or death.”

Honour Based Violence is defined by the NSPCC as “Abuse committed in the context of preserving “honour” often involves a wider network of family or community pressure and can include multiple perpetrators. It is important to be aware of this dynamic and additional risk factors when deciding what form of safeguarding action to take.” If staff have a concern regarding a child that might be at risk of HBV or who has suffered from HBV, they should speak to the Safeguarding Officer. As appropriate, they will activate local safeguarding procedures, using existing national and local protocols for multiagency liaison with police and children’s social care.

Forced Marriage (FM) is defined in ‘The Right to Choose: Multi-agency statutory guidance for dealing with Forced Marriage June 2014 as: “a marriage in which one or both spouses do not consent to the marriage but are coerced into it. Duress can be physical, psychological, financial, sexual and emotional pressure. In the cases of some vulnerable adults who lack the capacity to consent coercion in not required for a marriage to be forced.”

Forced marriage is therefore very different to an arranged marriage. Further risks around forced marriage may involve the victim being forced or tricked to travel over sees to marry however this does not occur in all cases.

Child Sexual Exploitation (CSE) is a form of sexual abuse which is defined above from ‘Working together to safeguard Children 2018’. ‘Child sexual exploitation:

Definition and a guide for practitioners ….2017’ further defines Child Sexual Exploitation as: Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.

Radicalisation is defined as “The process by which a person comes to support terrorism and forms of extremism leading to terrorism.” This can involve right-wing extremism such as Neo-Nazism, left- wing extremism such as animal rights, as well as extreme Islamism. Under Section 26 of the Counterterrorism and Security Act 2015, Colleges have a duty in the exercise of its functions to have: “Due regard to the need to prevent people from being drawn into terrorism.”

This is known as the Prevent Duty. Exploiting an apprentice’s vulnerability to being radicalised is another form of abuse. Therefore, a staff member’s response should be that of responding to a safeguarding matter using the processes detailed within this document. It is important that Staff members report any concern about an individual and do not take a ‘wait and see’ attitude, so the Safeguarding Team can build up a picture of the apprentice’s vulnerability and act if necessary.

GVNC has a role to play in ensuring that apprentices and employees are resilient to extreme narratives and as part of this process, employees are kept up to date on the latest concerns around radicalisation which are discussed during monthly tutor team meetings. There is an ongoing input surrounding radicalisation and risk factors relating to Prevent throughout the apprentices’ training. This is carefully designed by staff and considers risks and narratives which apprentices may be exposed to in their personal lives as well as whilst training in their apprenticeship, with the objective of giving them the skills to identify risks and deal with them appropriately.

Background

PREVENT is part of the Home Office and the Police counter-terrorism strategy and aims to stop people from becoming terrorists or supporting terrorism by working with individuals and communities to address issues before they become a criminal matter to stop people moving from extremism into terrorist-related activity. GVNC has a legal responsibility to fulfil the Prevent duty statement to protect apprentices, which is recognised and actioned.

Context

Young people in the UK are potentially vulnerable to engagement with extremist ideologies or to targeting by extremist organisations. Colleges, and other organisations that interact with young people, should be aware of these risks and be familiar with the support networks and processes in place to protect vulnerable individuals from becoming radicalised or drawn into terrorism.

Prevent Lead

The Designated Safeguarding Lead has overall responsibility for Prevent within Goddard Veterinary Group and any concerns or questions relating to Prevent should be directed to them. This is currently the Training Manager Emma Eve-Raw. If Emma-Eve Raw is not available, any concerns should be reported to the Deputy Safeguarding Lead, Claire Digby-Maloney. All contact details are above.

Definition of Radicalisation

The Institute of Strategic Dialogue defines radicalisation as “the process through which an individual changes from passiveness or activism to become more revolutionary, militant or extremist, especially where there is intent towards, or support for, violence.”

Driving factors behind radicalisation can include:

  • Lack of integration and/or polarisation
  • Identity crises and/or isolation
  • Political and/or democratic disenfranchisement
  • Discrimination
  • Foreign policy and/or international crises or disputes
  • Political movements
  • Ideologies and/or faiths

Who are we safeguarding?

There is no stereotype for people who hold extremist views. Vulnerability, isolation, and personal grievances added to strong political, religious or social views, can result in a person searching for a cause.

People can become vulnerable for many reasons including:

  • Low self-esteem
  • Guilt
  • Loss
  • Isolation
  • Family breakdown
  • Fear
  • Lack of purpose
  • Anger
  • Peer pressure

Early detection is important, all early detection referral will be firstly directed to Claire Digby-Maloney for discussion with DSL and to go on the watch list.

We are by no means suggesting that one or all these characteristics or circumstances will drive someone to terrorism. But they often lead to a sense of injustice – be that on a personal or more far- reaching scale. Their vulnerabilities or susceptibilities are then exploited towards crime or terrorism by people who have their own agenda.

As a result of such vulnerabilities, individuals may become involved in a new friendship group, they may be looking for answers to questions about their identity, faith, and belonging. They may possess extremist literature, change their behaviours and language, and seek to promote their new ideals to others.

It is important to understand that changes such as these may be attributed to other factors such as alcohol or drug abuse, family breakdown, domestic abuse, bullying etc. In these cases, the training and professional judgments within Prevent is crucial in recognising vulnerability and increasing support to promote safe choices.

Other critical factors to consider are:

  • Is the person in contact with extremist recruiters?
  • Do they speak about extremist causes or leaders?
  • Are they accessing extremist websites and/or social media?
  • Do they possess extremist literature?
  • Do they use extremist narrative to try and explain their own disadvantages?
  • Do they try and justify the use of violence to solve social issues?
  • Have they joined extremist organisations?
  • Have there been significant behavioural or appearance changes?

Interventions

Staff are made aware of the purpose of Prevent and their duties under the legislation through completion of the Channel general awareness module.

All staff members who identify a concern through conversations, behaviour, appearance, or actions and will report these concerns to the Designated Safeguarding Lead, or a Deputy in the absence of the Lead.

There is no typical gender, age, religion, or background that extremists will target but they use a sense of “Duty” (belonging to a specific group), “Status” (need for reputation) and “Spiritual Rewards” (test of faith) as a way of drawing them in.

This raises the question of what those signs of radicalisation will look like:

They will look a lot like troubling behaviour:

Emotional – angry, mood swings, newfound arrogance

Verbal – expressing opinions that are at odds with generally shared values

Physical – appearance (tattoos), change in routine

What to do if you believe someone to be at risk of radicalisation

The College will adopt the ethos of “Notice, Check, Share” where there are concerns that an individual may be vulnerable.

Notice – Recognition of any changes in behaviour or appearance similar to those outlined above

Check – Speak with someone you trust like a tutor and see what they recommend but trust your instinct if you are still concerned

Share – Speak to one of the named contacts to report your concerns. Remember trust your instinct

If you are concerned about another apprentice or staff member, please “Check” and “Share” with the tutor your concerns in the first instance.

Protecting Apprentices from Radicalising Influences

All front-line staff will promote British Values to the apprentices through topical discussion in lessons. This could for instance be a class discussion which reflects on apprentices’ experiences both in the workplace and home life. The apprentices understanding of fundamental British values is further promoted and evaluated through progress review.

The promotion of British Values is one way in which GVNC can ensure that apprentices are protected from radicalising influences. British values are embedded into all lessons and in to the ethos of the college (see British Values section in all Handbooks).

Apprentices should be empowered to make their own choices through promotion and celebration of individuality throughout their training experience.

Staff should maintain approachability with apprentices so that they feel that they could confide in a member of staff if they identified themselves as being at risk of radicalisation.

Responsibility for Contacting Prevent

Managers supporting learners internally or externally are responsible for making decisions to contact the Counter-Terrorism Team at Essex Police if serious concerns are raised about an individual.

Procedure for Implementing the Prevent Protocol

The following flow chart represents the procedure for implementing the Prevent Protocol. The Prevent Lead is responsible for managing and overseeing this process.

The local Prevent coordinator is Jenny Fisher, contact details:

Email: jennie.fisher@education.gov.uk. Telephone: 07880 469 588.

Regional further and higher education Prevent co-ordinators play a key role in the delivery of Prevent, providing further education (FE) and higher education (HE) providers with support to build resilience against the dangers of radicalisation.

They do this through strategic engagement with senior leaders and through the provision of advice, support and training (including WRAP – workshops to raise awareness of Prevent) to staff in:

  • universities
  • colleges
  • independent HE providers
  • apprenticeship providers
  • employer based learning providers
  • other forms of FE and HE

They help co-ordinate stakeholders involved in the delivery of Prevent in FE, HE and wider Prevent partners. This ensures there is a full and robust understanding of any regional threat and risk relating to FE and HE.

Incivility such as offensive language, harassment or noted bullying will be investigated and the student noted as a ‘low level concern.’ The situation will be addressed by the following process:

  1. Reporting to Cohort Lead
  2. Reporting to Deputy Head of Centre
  3. Head of Centre

The Head of Centre will contact the student’s manager if appropriate, an initial meeting will be held by the cohort lead and any subsequent behaviour if not addressed will be dealt with by a meeting with the HOC, DHOC and manager is appropriate.

Child Criminal Exploitation: County Lines is defined in Working together to safeguard Children 2018 (updated December 2020) as “Criminal exploitation of children is a geographically widespread form of harm that is a typical feature of county lines criminal activity: drug networks or gangs groom and exploit children and young people to carry drugs and money from urban areas to suburban and rural areas, market and seaside towns. Key to identifying potential involvement in county lines are missing episodes, when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral should be considered. Like other forms of abuse and exploitation, county lines exploitation:

  • can affect any child or young person (male or female) under the age of 18 years;
  • can affect any vulnerable adult over the age of 18 years;
  • can still be exploitation even if the activity appears consensual;
  • can involve force and/or enticement-based methods of compliance and is often accompanied by violence or threats of violence;
  • can be perpetrated by individuals or groups, males or females, and young people or adults; and
  • is typified by some form of power imbalance in favour of those perpetrating the exploitation. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, cognitive ability, physical strength, status, and access to economic or other resources.

Further information can be found via:

https://www.gov.uk/government/collections/county-lines-criminal-exploitation-of-children-and- vulnerable-adults

Apprentices returning to site post-lockdown

As we start to see some young people potentially accessing College sites over the coming weeks it is important to stay vigilant in identifying signs and indicators of potential concerns, particularly when we think about what we know with neglect and self-harm and how these could be more easily concealed or harder to identify without regular face to face contact with an individual.

Good Practice Guidance

All staff should be encouraged to demonstrate exemplary behaviour in order to protect themselves from false allegations. The following are common sense examples of how to create a positive culture and climate.

Good Practice for Staff Means

  • Treating all people equally with respect and dignity.
  • Always putting the welfare of each young person/vulnerable adult first.
  • Maintaining a safe and appropriate distance from other people at work, avoiding physical contact.
  • Wherever possible, avoiding lone working with a child or vulnerable adult. If unavoidable, one to one contact should take place in an environment where other staff are present, within sight or hearing.
  • Building balanced relationships based on mutual trust and empowering children and vulnerable adults to share in decision making.
  • Maintaining confidentiality at all times in accordance with company policy
  • Giving enthusiastic and constructive feedback rather than negative criticism.
  • Recognising the developmental needs and capacity of young people and disabled adults
  • Being aware of the possible forms and signs of abuse, including:
    • Physical, e.g. a history of injuries, bruising, finger marks, burns of unusual location or type, injuries found in different states of healing, injury shape similar to an object, injuries to head/face/scalp, accounts which vary with time or are inconsistent with physical evidence, weight loss due to malnutrition or rapid weight gain.
    • Sexual, e.g. disclosure or partial disclosure (use of phrases such as “it’s a secret”, medical problems (such as genital infections, pregnancy, difficulty walking or sitting), disturbed behaviour (such as depression, withdrawal from activities, loss of previous skills, self-injury, showing fear or aggression, inappropriately seductive behaviour, loss or appetite.
    • Psychological/emotional signs, e.g. isolation, unkempt/ unwashed, over meticulous, inappropriately dressed, withdrawn, agitated, anxious, change in appetite, tearfulness, unexplained paranoia or excessive fears, low self-esteem, confusion.
    • Neglect signs, e.g. poor physical condition, clothing in poor condition, untreated injuries or medical problems, poor personal hygiene.
    • Cyber Bullying, e.g. isolation, withdrawn, aggressive behaviour, low self-esteem, agitated, anxious, mood swings.
    • Female Genital Mutilation (FGM), e.g. discussing that they are going on a long holiday to a country where FGM is prevalent, or talking about a procedure or ceremony to ‘become a woman’, difficulty walking, difficulty in passing urine or the need to pass urine more frequently, looking uncomfortable when sitting down, becoming withdrawn.
    • Forced Marriage, e.g. withdrawn, spending significantly less time with friends, physical abuse signs, anxious, tearfulness, withdrawal from activities.
    • Self-harm,e.g. depression, withdrawn, tearfulness, low self-esteem, change in eating habits leading to weight loss or gain, drinking or taking drugs, visible self-harm marks (e.g. cuts/ burns/ bald patches from hair being pulled out), anxiety.
    • Child exploitation, e.g. withdrawn, quiet or disruptive in the classroom, regularly being out late at night or not going home, signs of physical abuse, tiredness, signs of having a sexually transmitted disease, having gifts or possessions which can’t be accounted for, displaying inappropriate sexual behaviour.

Use of Information Computer Technology (ICT)

Where students are required to use ICT as part of a learning activity, the tutor should ensure that they are able to see the screen of the device and should check that all apprentices are only accessing appropriate internet sites. The internet is set up to ensure that over 18 content and other inappropriate content, such as adverts are blocked.

GVNC recognise that internet safety is an organisation wide responsibility, including that of staff, apprentices, and employers. IT usage is monitored, examples include tutors can see screens at all times in the classroom. Online lessons have a waiting room, and tutors only accept apprentices and staff during these sessions. An internet safety policy and online learning policy form part of the course handbook are presented in induction and embedded throughout the course.

All students will be expected to be on camera for their online learning, unless the tutor has advised otherwise, or an extenuating circumstances (EC) form has been completed and

authorisation given for a valid reason by the Head of Centre. Cameras on are not only for engagement, monitoring attendance but also to ensure there are no safeguarding concerns.

Those who do not have their cameras on may be removed from the lesson and marked as unauthorised and any potential safeguarding concerns investigated further. If students have children at home during a lesson, then they must not be in view of the camera and if they were to be then must be fully dressed.

Children and vulnerable adults may expose themselves to danger, whether knowingly or unknowingly, when using the internet and other technologies. Additionally, some children and vulnerable adults may find themselves in activities which are inappropriate or possibly illegal.

We therefore recognise our responsibility to educate our students teaching them the appropriate behaviours and critical thinking skills to enable them to remain both safe and legal when using the internet and related technologies. These are also embedded in lessons where appropriate.

Inappropriate Practices for Staff which are prohibited

  • Spending excessive amounts of time alone with any apprentice.
  • Arranging to meet an apprentice outside of working time.
  • Engaging in rough physical or sexually provocative games, including horseplay.Allowing or engaging in any form of inappropriate touching.Engaging in sexually suggestive comments to an apprentice, even in fun, or allowing others to make them unchallenged.
  • Allow allegations made by a child or vulnerable adult to go unchallenged, unrecorded, or not acted upon.

Where there is a complaint made against a member of staff on the grounds of inappropriate practice, one or more of the following types of investigation will be initiated:

  • A criminal investigation
  • A child protection investigation
  • A disciplinary or gross misconduct investigation, which could result in dismissal

If the designated member of staff responsible for child protection is the subject of a complaint, then the matter must be reported to the Manager responsible for child protection.

Responding to Allegations or Suspicions

Basic principles for staff in reacting to suspicions, allegations and/or disclosures:

  • Stay calm. Listen carefully and give time to the person to say what they want. Don’t make assumptions, don’t paraphrase, and don’t offer alternative explanations. Remember that an allegation of abuse or neglect may lead to criminal prosecution, so don’t do anything to jeopardise a police investigation such as asking leading questions or attempting to investigate the allegations yourself. Never promise confidentiality (legally you cannot do so).
  • Reassure and explain that they have done the right thing in telling. Explain that only those professionals who need to know will be informed. Don’t make negative comments about the alleged abuser.
  • Record in writing as near as verbatim as possible what was said and do this as soon as possibleDon’t try to deal with it yourself – report to the designated member of staff with responsibility for child protection/protection of vulnerable adults
  • Record your report including: the date and time of disclosure, suspicion, allegation, or actual abuse incident; details given to you, e.g., date and time of when things occurred; an indication of the parties involved; details of what action you have taken; details of reporting (who to and when). Records should be kept completely confidential and secure and only shared with those who need to know about the suspicion, allegation, or actual incident of abuse.

It is the duty of anyone who works with children or vulnerable adults to report disclosure of abuse. All suspicions or allegations must be taken seriously and dealt with according to this procedure. It is not for staff to decide whether or not a suspicion or allegation is true. It is the primary responsibility of the person who first suspects or who is told of abuse to report it immediately to the designated member of staff responsible for child protection.

For GVNC, this is Emma Eve-Raw. In the event of Emma’s absence, this should be reported to the deputy person – Claire Digby-Maloney. Emma Eve-Raw holds a list of first contacts for referral of any issues regarding safeguarding of children and vulnerable adults, which is up-dated periodically.

Records, Confidentiality and Information Sharing

  • Any information recorded will be kept in a separate named file or secure on-line system, or in a secure cabinet and not with the apprentice’s academic file. These files will be the responsibility of the DSL. Individual’s information will only be shared within institutions based on ‘need to know in the individual’s interests’ and on the understanding that it remains strictly confidential.
  • Individual’s information will only be kept in the file and this file will be kept up to date. Record of contact with professionals and concerns that are raised while the apprentice is at college and reports will be stored here.
  • When an apprentice under the age of 18 or vulnerable adult leaves our college and enrolls with a new educational institution, the DSL will ensure that the child protection file is forwarded to the receiving institution in an appropriately agreed manner, upon receipt of a formal request from the new institution.
  • Safeguarding files will be reviewed for deletion and / or destruction seven years after the most recent safeguarding file for that Apprentice has been closed.
  • Guidance states that where reasonably possible, we should have more than one emergency contact number for our apprentices.

Procedure

Staff at the College will be guided by the following process if an apprentice tells them about possible abuse:

  • Listen carefully and stay calm
  • Do not interview the apprentice, but question normally and without pressure, in order to be sure that you understand what the apprentice is telling you
  • Do not put words into the apprentice’s mouth
  • Reassure the apprentice that by telling you, they have done the right thing
  • Inform the apprentice that you must pass the information on, but that only those that need to know about it will be told. Inform them of whom you will report the matter to
  • Note the main points carefully
  • Make a detailed note of the date, time, place, what the apprentice said, did and your questions etc.
  • Do not investigate concerns or allegations yourself but report them immediately to the Safeguarding Officer.

Records should be signed and dated and kept in chronological order. Group actions minuted in child conferences/strategy meetings must be implemented. Recording is a tool of professional accountability and is central to safeguarding and protecting apprentices. It is not always possible to know whether a small or vague concern held today may increase as the days or weeks pass and later form the substance of a vulnerable adult protection referral. For this reason, it is vital that concerns are recorded accurately so that they can be monitored, and emerging patterns noticed. Staff at the College will report any safeguarding concerns they may have about a apprentice to the Safeguarding Officer for advice and guidance.

Where a member of staff is reporting a concern or disclosure about FGM (female genital mutilation) of a young person under the age 18, the member of staff must personally report to the police, and our safeguarding team will support that member of staff to make the report. This is in line with new guidance on mandatory reporting outlined in Keeping Children Safe in Education 2020.

For all referrals to safeguarding, staff will need to complete the Safeguarding referral process form. For matters which need immediate consultation with a Safeguarding Officer the Safeguarding mobile should be called, during normal working hours (Monday to Friday, 9am-5pm).

Out of hours emergency safeguarding contacts

It is deemed good practice to share these contact numbers with apprentices:

If there is a life-threatening situation, please ring for an ambulance and/or contact the police on 999 or 101 non-emergency.

If you think a child, young person or vulnerable adult is being abused or mistreated or you have concerns about a child young person or vulnerable adult’s well-being you should call the Duty Team at the relevant local authority. The emergency contact details are available on the Local Authorities website.

Service: Childline

Website: www.childline.org.uk Telephone: 0800 1111

Service: Samaritans

Website: www.samaritans.org Telephone: 1116123

Email: jo@samaritans.org

Service: MIND Service:

Website: www.mind.org.uk Telephone: 0300123 3393 Email: info@mind.org.uk

Service: NSPCC Helpline Children (Under 18)

Website: https://www.nspcc.org.uk/

Telephone: 0808 800 5000 or Text 88858 (free service) Email: help@nspcc.org.uk

Service: Young Minds

Website : https://youngminds.org.uk Telephone : 0808 802 5544

Service: The Mix

Website: https://www.themix.org.uk Telephone: 0808 808 4994

Service: Women’s Aid

Website: https://www.womensaid.org.uk Email: info@womensaid.org.uk

Service: Stonewall

Website: https://www.stonewall.org.uk/help-and-advice Email: info@stonewall.org.uk

Service: IKWRO – Domestic Violence

Website: http://ikwro.org.uk Telephone: 0207 920 6460

Service: Women’s and Girls Network – Domestic Violence

Website: http://www.wgn.org.uk Telephone: 0808 801 0660 Email: advice@wgn.org.uk

Service: CEOP

Website: https://www.ceop.police.uk/safety-centre/

Service: NSPCC

Website: https://www.nspcc.org.uk/keeping-children-safe/online-safety/ Telephone: 0800 1111 (Under 18’s) Telephone: 0808 800 5000 (Over 18’s) Email: help@nspcc.org.uk

Service: Vetlife

Website: https://www.vetlife.org.uk Telephone: 0303 040 2551

How to Report a Concern

This action has been designated the responsibility of the safeguarding lead.

Depending on the nature and urgency of the concern, following guidance found here: https://www.londoncp.co.uk/files/revised_guidance_thresholds.pdf

Local social services can be contacted, or telephone 999 if the concern is deemed urgent.

Commitment to this Policy

To ensure that this policy remains at the forefront of the college environment, all teaching and management meetings will include safeguarding in the agenda as a discussion point. Safeguarding is also included on apprentice trackers. Ensuring all staff remain up to date is ensured by providing minutes of the meetings, which all staff confirm they have read and understood, ensuring safeguarding CPD is updated and tracked for all staff, and annual updates completed.

1 Part 2 of the ‘Keeping children safe in education’ will be reviewed annually and any updated incorporated into Governance Board meetings, staff and CS/Mentor training, manager training and protocols. All staff received annual SG / PREVENT training.