Child Protection & Safeguarding Policy

IMPORTANT CONTACTS –

ROLE	NAME	CONTACT DETAILS
Main Designated Safeguarding Lead (DSL) for the Project	Sarah Robbins- CEO Designated Safeguarding Leads – Sarah Mullis and Sayma Bibi	0121 777 2722
DSLs	Sarah Mullis – Nursery Manager for Park Rd Tahmin Akhtar- Deputy Nursery Manager for Park Rd Kouser Iqbal- Nursery Practitioner for Park Road Claire Freeman- Nursery Manager for Mini Springers and Seedlings Shazia Malik- Deputy Manager for Mini Springers Helen Cremins – Inclusion lead Rachel Vargas – Community Services Sayma Bibi – Children Centre and Family Hub Manager Fuazia Azad – Children Centre – Early Years Manager Harein Qousar – Children Centre – Family Support Manager Fatima Khanom – Children Centre- Senior Family Support Worker	0121 725 4990 0121 725 4990 0121 725 4990 0121 777 2722 0121 777 2722 0121 777 2722 0121 777 2722 07958 206064 07958 206326 07701 303927 07508 706671
Adult Safeguarding Lead	Rosalyn Clare – Project Development Manager	07935 006891
Chair of Project	Tim Boyes	0121 777 7222
Designated Safeguarding Trustee	Fiona Cross – Sudworth	0121 777 7222

1	Policy Aim
2 2.1	Scope of the Policy Legislation and Statutory Guidance
3 3.1 3.2 3.3	Policy detail Equality statement Roles and responsibilities Confidentiality
4 4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 4.12 4.13 4.14	Procedures Recognising abuse & taking action If a child is suffering or likely to suffer harm, or in immediate danger Concerns about a member of staff, Trustee, volunteer or contractor (Persons in Position of Trust) Allegations of abuse made against other children Online safety and the use of mobile technology Partnership and Joint working Looked-after and previously looked-after children Pupils who are lesbian, gay, bisexual or gender questioning Complaints and concerns Record Keeping Training Recruitment – interview panels Staff who have contact with children, young people and families Monitoring arrangements
5	Related Policies
Appendix 1	Types of Abuse
Appendix 2	Allegations against staff (including low-level concerns) policy
Appendix 3	Specific Safeguarding Issues Including: Assessing adult-involved nude and semi-nude sharing incidents Sexually motivated incidents Financially motivated incidents Children who are absent from education Child criminal exploitation Child sexual exploitation Child-on-child abuse Domestic abuse Homelessness So-called ‘honour-based’ abuse (including FGM and forced marriage) Female Genital Mutilation (FGM) Forced marriage Preventing radicalisation Sexual violence and sexual harassment between children in Project activities Serious violence Checking the identity and suitability of visitors Non-collection of children Missing Child

1. Policy Aim

The Project policy ensures that all staff, students and volunteers have a responsibility to safeguard children and young people and to protect them from harm. It aims to raise awareness of how to safeguard and promote the welfare of children and provides procedures should a child protection issue arise.

This policy applies to all children up to the age of 18 years whether living with their families, in state care, or living independently (Working together to safeguard children).

Safeguarding and child protection is everyone’s responsibility. We have a duty to act quickly and responsibly in any instance that may come to our attention. If in any doubt about what constitutes a safeguarding concern, refer to the Designated Safeguarding Lead (DSL). If there is a concern, never do nothing (Laming, 2009), always do something, including sharing information with any relevant agencies. Safeguarding is everybody’s responsibility.

The Project aims to ensure that:

Appropriate action is taken in a timely manner to safeguard and promote children’s welfare All staff are aware of their statutory responsibilities with respect to safeguarding Staff are properly trained in recognising and reporting safeguarding issues

2. Scope of the Policy

Safeguarding and promoting the welfare of children is defined as:

Providing help and support to meet the needs of children as soon as problems emerge

Protecting children from maltreatment whether that is within or outside the home, including online

Preventing impairment of children’s mental and physical health or development

Ensuring that children grow up in circumstances consistent with the provision of safe and effective care

Taking action to enable all children to have the best outcomes

To safeguard children and promote children’s welfare we will:

Develop a safe culture where staff are confident to raise concerns about professional conduct Ensure all staff are able to identify the signs and indicators of abuse, including the softer signs of abuse, and know what action to take

Understand and be sensitive to factors, including economic and social circumstances and ethnicity, which can impact children and families’ lives

Share information with other agencies as appropriate.

We promote:

Always listening to children and keep them at the center of any decisions made Children developing independence and autonomy as appropriate for their age and stage of development, Safe and secure environments for children, Tolerance and acceptance of different beliefs, cultures and communities, British values and providing intervention and help for children and families in need.

Child protection refers to activities undertaken to protect specific children who are suspected to be suffering, or likely to suffer significant harm. This includes harm that occurs inside or outside the home, including online.

Abuse is a form of maltreatment of a child, and may involve inflicting harm or failing to act to prevent harm. Appendix 1 explains the different types of abuse.

Neglect is a form of abuse and is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Appendix 1 of the procedure defines neglect in more detail.

The following 3 safeguarding partners are identified in Keeping Children Safe in Education (and defined in the Children Act 2004, as amended by chapter 2 of the Children and Social Work Act 2017). They will make arrangements to work together to safeguard and promote the welfare of local children, including identifying and responding to their needs:

Birmingham City Council & Birmingham Children’s Trust

NHS Birmingham & Solihull Integrated Care Boards

West Midlands Police

Victim is a widely understood and recognised term, but we understand that not everyone who has been subjected to abuse considers themselves a victim or would want to be described that way. When managing an incident, we will be prepared to use any term that the child involved feels most comfortable with.

Alleged perpetrator(s) and perpetrator(s) are widely used and recognised terms. However, we will think carefully about what terminology we use (especially in front of children) as, in some cases, abusive behaviour can be harmful to the perpetrator too. We will decide what’s appropriate and which terms to use on a case-by-case basis.

2.1 Legislation & Statutory Guidance

This policy is based on the Department for Education’s (DfE’s) statutory guidance Keeping Children Safe in Education (2024) and Working Together to Safeguard Children (2023). We comply with this guidance and the arrangements agreed and published by our 3 local safeguarding partners.

This policy is also based on the following legislation:

The Children Act 1989 (and 2004 amendment), which provides a framework for the care and protection of children

Section 5B(11) of the Female Genital Mutilation Act 2003, as inserted by section 74 of the Serious Crime Act 2015, which places a statutory duty on teachers to report to the police where they discover that female genital mutilation (FGM) appears to have been carried out on a girl under 18

Statutory guidance on FGM, which sets out responsibilities with regards to safeguarding and supporting girls affected by FGM

The Rehabilitation of Offenders Act 1974, which outlines when people with criminal convictions can work with children

Schedule 4 of the Safeguarding Vulnerable Groups Act 2006, which defines what ‘regulated activity’ is in relation to children

Statutory guidance on the Prevent duty, which explains schools’ duties under the Counter Terrorism and Security Act 2015 with respect to protecting people from the risk of radicalisation and extremism

The Human Rights Act 1998, which explains that being subjected to harassment, violence and/or abuse, including that of a sexual nature, may breach any or all of the rights which apply to individuals under the European Convention on Human Rights (ECHR)

The Equality Act 2010, which makes it unlawful to discriminate against people regarding particular protected characteristics (including disability, sex, sexual orientation, gender reassignment and race). This means our Trustees and CEO should carefully consider how they are supporting their children within all the Project departments with regard to these characteristics. The Act allows our project to take positive action to deal with particular disadvantages affecting children (where we can show it’s proportionate). This includes making reasonable adjustments for disabled children. For example, it could include taking positive action to support girls where there’s evidence that they’re being disproportionately subjected to sexual violence or harassment.

The Childcare (Disqualification) and Childcare (Early Years Provision Free of Charge) (Extended Entitlement) (Amendment) Regulations 2018 (referred to in this policy as the “2018 Childcare Disqualification Regulations”) and Childcare Act 2006, which set out who is disqualified from working with children

This policy also meets requirements relating to safeguarding and welfare in the statutory framework for the Early Years Foundation Stage

3. Policy Detail

3.1 Equality Statement

Some children have an increased risk of abuse, both online and offline, and additional barriers can exist for some children with respect to recognising or disclosing it. We are committed to anti-discriminatory practice and recognise children’s diverse circumstances. We ensure that all children have the same protection, regardless of any barriers they may face.

We give special consideration to children who:

Have special educational needs and/or disabilities (SEND) or health conditions (see section 10) Are young carers

May experience discrimination due to their race, ethnicity, religion, gender identification or sexuality

Have English as an additional language (EAL)

Are known to be living in difficult situations – for example, temporary accommodation or where there are issues such as substance abuse or domestic violence

Are at risk of female genital mutilation (FGM), sexual exploitation, forced marriage, or radicalisation Are asylum seekers

Are at risk due to either their own or a family member’s mental health needs Are looked after or previously looked after

Are missing or absent from education for prolonged periods and/or repeat occasions Whose parent/carer has expressed an intention to remove them from school to be home educated

3.2 Roles & Responsibilities

This policy applies to all staff, volunteers and Trustees in the organisation and is consistent with the procedures of the 3 safeguarding partners.

Our services play a crucial role in preventative education. This is in the context of a ‘whole-project’ approach to preparing children for life in modern Britain, and a culture of zero tolerance of sexism, misogyny/misandry, homophobia, biphobia, transphobia and sexual violence/harassment.

All staff will:

Read and understand Part 1 and Annex B of the Department for Education’s statutory safeguarding guidance, Keeping Children Safe in Education, and review this guidance at least annually. Staff who do not work directly with children can read Annex A of KCSIE (a condensed version of Annex B)

Sign a declaration at the beginning of each academic year to say that they have reviewed the guidance

Reinforce the importance of online safety when communicating with parents and carers. This includes making parents and carers aware of what we ask children to do online (e.g. sites they need to visit or who they’ll be interacting with online)

Provide a safe space for children who are LGBTQ+ to speak out and share their concerns All staff will be aware of:

Our systems that support safeguarding, including this child protection and safeguarding policy, the staff code of conduct, the role and identity of the designated safeguarding lead (DSL) and deputy/deputies, the setting-specific behaviour policies, and the safeguarding framework document

The early help assessment process and their role in it, including identifying emerging problems, liaising with the DSL, and sharing information with other professionals to support early identification and assessment

The process for making referrals to local authority children’s social Care (Birmingham Children’s Trust) and for statutory assessments that may follow a referral, including the role they might be expected to play

What to do if they identify a safeguarding issue or a child tells them they are being abused or neglected, including specific issues such as FGM, and how to maintain an appropriate level of confidentiality while liaising with relevant professionals

The signs of different types of abuse, neglect and exploitation, including domestic and sexual abuse (including controlling and coercive behaviour, as well as parental conflict that is frequent, intense, and unresolved), as well as specific safeguarding issues, such as child-on-child abuse, grooming, child sexual exploitation (CSE), child criminal exploitation (CCE), indicators of being at risk from or involved with serious violent crime, FGM, radicalisation and serious violence (including that linked to county lines)

New and emerging threats, including online harm, grooming, sexual exploitation, criminal exploitation, radicalisation, and the role of technology and social media in presenting harm

The importance of reassuring victims that they are being taken seriously and that they will be supported and kept safe

The fact that children can be at risk of harm inside and outside of their home, at school and online

The fact that children who are (or who are perceived to be) lesbian, gay, bisexual or gender questioning (LGBTQ+) or who are the child of lgbtq+ parents can be targeted by other children

That a child and their family may be experiencing multiple needs at the same time What to look for to identify children who need help or protection

The designated safeguarding lead (DSL)

Our CEO maintains overall responsibility over Safeguarding. The Safeguarding leads take lead responsibility for child protection and wider safeguarding across the project. DSLS take responsibility for Safeguarding within their departments.

When a DSL is absent, then other DSLs from each department will act as cover. If DSLs are not on site, then they will be contactable via phone.

The DSL will be given the time, funding, training, resources and support to:

Provide advice and support to other staff on child welfare 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

Refer suspected cases, as appropriate, to the relevant body (Birmingham Children’s Trust, Channel programme, Disclosure and Barring Service, and/or police), and support staff who make such referrals directly

Have a good understanding of harmful sexual behaviour

Have a good understanding of the filtering and monitoring systems and processes in place Act as PREVENT leads for their departments.

The DSLs will also:

Keep the CEO informed of any significant issues

Liaise with local authority case managers and designated officers for child protection concerns as appropriate

Discuss the local response to sexual violence and sexual harassment with police and Birmingham Children’s Trust colleagues

Be confident that they know what local specialist support is available to support all children involved (including victims and alleged perpetrators) in sexual violence and sexual harassment, and be confident as to how to access this support

Be aware that children must have an ‘appropriate adult’ to support and help them in the case of a police investigation or search.

Provide quarterly Safeguarding Data reports to the CEO and the Safeguarding Trustee.

The Role of the Trustees

Facilitate a whole-project approach to safeguarding, ensuring that safeguarding and child protection are at the forefront of, and underpin, all relevant aspects of process and policy development

Evaluate and approve this policy at each review, ensuring it complies with the law, and hold the CEO to account for its implementation

Be aware of its obligations under the Human Rights Act 1998, the Equality Act 2010, and our local authority’s multi-agency safeguarding arrangements

To ensure there is a Trustee with safeguarding responsibility to monitor the effectiveness of this policy in conjunction with the board of Trustees. This is always a different person from the DSL.

Ensure all staff undergo safeguarding and child protection training, including online safety, and that such training is regularly updated and is in line with advice from the safeguarding partners

Ensure that the Project has appropriate filtering and monitoring systems in place, and review their effectiveness. This includes:

· Making sure that the leadership team and staff are aware of the provisions in place, and that they understand their expectations, roles and responsibilities around filtering and monitoring as part of safeguarding training

· The DSLs have the appropriate status and authority to carry out their job, including additional time, funding, training, resources and support

· Online safety is a running and interrelated theme within the whole-project approach to safeguarding and related policies

The Project has procedures to manage any safeguarding concerns (no matter how small) or allegations that do not meet the harm threshold (low-level concerns) about staff members (including supply staff, volunteers and contractors). Appendix 2 of the procedure

That this policy reflects that children with SEND, or certain medical or physical health conditions, can face additional barriers to any abuse or neglect being recognised

Where another body is providing services or activities (regardless of whether or not the children who attend these services/activities are children who are known to Springfield Project):

· Seek assurance that the other body has appropriate safeguarding and child protection policies/procedures in place, and inspect them if needed

· Make sure there are arrangements for the body to liaise with the Project about safeguarding arrangements, where appropriate

· Make sure that safeguarding requirements are a condition of using the Project premises, and that any agreement to use the premises would be terminated if the other body fails to comply

The Chair of Trustees will act as the ‘case manager’ in the event that an allegation of abuse is made against the CEO, where appropriate (see appendix 2)

All Trustees will read Keeping Children Safe in Education in its entirety.

3.3 Confidentiality).

Timely information sharing is essential to effective safeguarding

Fears about sharing information must not be allowed to stand in the way of the need to promote the welfare, and protect the safety, of children

The Data Protection Act (DPA) 2018 and the UK GDPR do not prevent, or limit, the sharing of information for the purposes of keeping children safe

If staff need to share ‘special category personal data’, the DPA 2018 contains ‘safeguarding of children and individuals at risk’ as a processing condition that allows practitioners to share information without consent if: it is not possible to gain consent; it cannot be reasonably expected that a practitioner gains consent; or if to gain consent would place a child at risk

Staff should never promise a child that they will not tell anyone about a report of abuse, as this may not be in the child’s best interests

If a victim asks the DSL not to tell anyone about the sexual violence or sexual harassment:

· There’s no definitive answer, because even if a victim doesn’t consent to sharing information, staff may still lawfully share it if there’s another legal basis under the UK GDPR that applies

· The DSL will have to balance the victim’s wishes against their duty to protect the victim and other children

· The DSL should consider that:

· Parents or carers should normally be informed (unless this would put the victim at greater risk)

· The basic safeguarding principle is: if a child is at risk of harm, is in immediate danger, or has been harmed, a referral should be made to Birmingham Children’s Trust.

Regarding anonymity, all staff will:

· Be aware of anonymity, witness support and the criminal process in general where an allegation of sexual violence or sexual harassment is progressing through the criminal justice system

· Do all they reasonably can to protect the anonymity of any children involved in any report of sexual violence or sexual harassment – for example, carefully considering which staff should know about the report, and any support for children involved

· Consider the potential impact of social media in facilitating the spreading of rumours and exposing victims’ identities

The government’s information sharing advice for safeguarding practitioners includes 7 ‘golden rules’ for sharing information, and will support staff who have to make decisions about sharing information

If staff are in any doubt about sharing information, they should speak to the DSL.

Confidentiality is also addressed in this policy with respect to record-keeping, and allegations of abuse against staff in appendix 2

4. Procedures

4.1 Recognising abuse & taking action

All staff are expected to be able to identify and recognise all forms of abuse, neglect and exploitation and shall be alert to the potential need for early help for a child who:

Is disabled

Has special educational needs (whether or not they have a statutory education health and care (EHC) plan)

Is a young carer

Is bereaved

Is showing signs of being drawn into anti-social or criminal behaviour, including being affected by gangs and county lines and organised crime groups and/or serious violence, including knife crime

Is frequently missing/goes missing from education, care or home

Is at risk of modern slavery, trafficking, sexual and/or criminal exploitation

Is at risk of being radicalised or exploited

Is viewing problematic and/or inappropriate online content (for example, linked to violence), or developing inappropriate relationships online

Is in a family circumstance presenting challenges for the child, such as drug and alcohol misuse, adult mental health issues and domestic abuse

Is misusing drugs or alcohol

Is suffering from mental ill health

Has returned home to their family from care

Is at risk of so-called ‘honour’-based abuse such as female genital mutilation (FGM) or forced marriage

Is a privately fostered child

Has a parent or carer in custody or is affected by parental offending

Is missing education, or persistently absent from school, or not in receipt of full-time education Has experienced multiple suspensions and is at risk of, or has been permanently excluded

Staff, volunteers and Trustees must follow the procedures set out below in the event of a safeguarding issue.

4.2 If a child is suffering or likely to suffer harm, or in immediate danger

Where staff are concerned that a child is suffering or likely to suffer harm they should talk to a DSL immediately. The DSL will make the decision whether to make a referral and who will make the referral.

The DSL or agreed staff membet will a referral to the Multi-Agency Safeguarding Hub (MASH) by Children’s Advice & Support Services (CASS) on 0121 303 1888 and/or the police immediately if you believe a child is suffering or likely to suffer from harm, or is in immediate danger. Anyone can make a

referral. Telephone referrals must be followed up in writing using the Request for Support form. Further information and the Request for Support form is available online: Safeguarding Concerns – Birmingham Safeguarding Children Partnership (lscpbirmingham.org.uk)

If a child makes a disclosure to you

If a child discloses a safeguarding issue to you, you should:

Listen to and believe them. Allow them time to talk freely and do not ask leading questions Stay calm and do not show that you are shocked or upset

Tell the child they have done the right thing in telling you. Do not tell them they should have told you sooner

Explain what will happen next and that you will have to pass this information on. Do not promise to keep it a secret

Write up your conversation as soon as possible in the child’s own words. Stick to the facts, and do not put your own judgement on it

Sign and date the write-up and pass it on to the DSL. Alternatively, if appropriate, make a referral to CASS and/or the police directly, and tell the DSL as soon as possible that you have done so. Aside from these people, do not disclose the information to anyone else unless told to do so by a relevant authority involved in the safeguarding process

Bear in mind that some children may:

Not feel ready, or know how to tell someone that they are being abused, exploited or neglected Not recognise their experiences as harmful

Feel embarrassed, humiliated or threatened. This could be due to their vulnerability, disability, sexual orientation and/or language barriers

None of this should stop you from having a ‘professional curiosity’ and speaking to the DSL if you have concerns about a child.

If you discover that FGM has taken place or a child is at risk of FGM

Keeping Children Safe in Education explains that FGM comprises “all procedures involving 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. It is also known as ‘female genital cutting’, ‘circumcision’ or ‘initiation’.

Possible indicators that a child has already been subjected to FGM, and factors that suggest a child may be at risk, are set out in Appendix 3 of this policy.

Any staff member who either:

· Is informed by a girl under 18 or other party that an act of FGM has been carried out on her; or

· Observes physical signs which appear to show that an act of FGM has been carried out on a girl under 18 and they have no reason to believe that the act was necessary for the girl’s physical or mental health or for purposes connected with labour or birth

This must be reported to the Police immediately after a discussion has taken place with a DSL and involve Birmingham Children’s Trust as appropriate. Staff should not examine a child or young person .Any member of staff who suspects a child is at risk of FGM or suspects that FGM has been carried out or discovers that a child aged 18 or over appears to have been a victim of FGM should speak to the DSL and follow our local safeguarding procedures.

Early help assessment

Refer to the ‘Right Help Right Time’ document to decide what level of need or if an early help assessment is appropriate, the DSL will generally lead on liaising with other agencies and setting up an inter-agency assessment as appropriate. Staff may be required to support other agencies and professionals in an early help assessment, in some cases acting as the lead practitioner.

We will discuss and agree, with statutory safeguarding partners, levels for the different types of assessment, as part of local arrangements.

The DSL will keep the case under constant review and the setting will consider a referral to local authority children’s social care if the situation does not seem to be improving. Timelines of interventions will be monitored and reviewed.

Referrals

If it is appropriate to refer the case to the Multi Agency Safeguarding Hub (MASH) or the police, the DSL will make the referral or support a member of staff to do so.

If, in exceptional circumstances, the DSL is not available, this should not delay appropriate action being taken. Staff members should speak to a member of the senior leadership team and/or seek advice from CASS, makingake a referral to MASH directly, if appropriate. The DSL must be informed as soon as is practically possible.

The local authority will make a decision within 1 working day of a referral about what course of action to take and will let the person who made the referral know the outcome. The DSL or person who made the referral must follow up with the local authority if this information is not made available, and ensure outcomes are properly recorded.

If the child’s situation does not seem to be improving after the referral, the DSL or person who made the referral must follow local escalation procedures to ensure their concerns have been addressed and that the child’s situation improves.

If you have concerns about extremism

If a child is not suffering or likely to suffer from harm, or in immediate danger, where possible speak to the DSL first to agree a course of action.

Where there is a concern, the DSL will consider the level of risk and decide which agency to make a referral to. This could include the police or Channel, the government’s programme for identifying and supporting individuals at risk of becoming involved with or supporting terrorism, or the local authority children’s social care team.

You can also email [email protected]. Note that this is not for use in emergency situations.

In an emergency, call 999 or the confidential anti-terrorist hotline on 0800 789 321 if you: Think someone is in immediate danger

Think someone may be planning to travel to join an extremist group

See or hear something that may be terrorist-related

If you have concerns about a child’s mental health

Mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.

Staff will be alert to behavioural signs that suggest a child may be experiencing a mental health problem or be at risk of developing one.

If you have a mental health concern about a child that is also a safeguarding concern, take immediate action by following the above steps, and making a referral.

If you have a mental health concern that is not also a safeguarding concern, speak to the DSL to agree a course of action.

4.3 Concerns about a member of staff, Trustee, volunteer or contractor (Persons of Position of Trust)

If you have concerns about a member of staff, or an allegation is made about a member of staff (including a Trustee, volunteer or contractor) posing a risk of harm to children, speak to the Designated Safeguarding Lead and the CEO as soon as possible. If the concerns/allegations are about the CEO, speak to the Chair.

The CEO/chair of Trustees will then follow the procedures set out in Appendix 2, if appropriate.

Where you believe there is a conflict of interest in reporting a concern or allegation about a member of staff (including a Trustee, volunteer or contractor) report it directly to the local authority designated officer (LADO).

If you receive an allegation relating to an incident where an individual or organisation was using the Project’s premises for running an activity for children, follow our safeguarding policies and procedures, informing the LADO, as you would with any safeguarding allegation.

Where appropriate, the relevant departmental manager will inform Ofsted of the allegation and actions taken, within the necessary timescale (see appendix 2 for more detail).

4.4 Allegations of abuse made against other children

We recognise that children are capable of abusing their peers. Abuse will never be tolerated or passed off as “banter”, “just having a laugh” or “part of growing up”, as this can lead to a culture of unacceptable behaviours and an unsafe environment for children and young people

We also recognise the gendered nature of child-on-child abuse. However, all child-on-child abuse is unacceptable and will be taken seriously.

Most cases of children and young people hurting other children or young people will be dealt with under the relevant setting-specificbehaviour policy, but this child protection and safeguarding policy will apply to any allegations that raise safeguarding concerns.

This might include where the alleged behaviour:

Is serious, and potentially a criminal offence

Could put Children or Young People at risk

Is Violent

Involves Children or Young People being forced to use drugs or alcohol

Involves sexual exploitation, sexual abuse or sexual harassment, such as indecent exposure, sexual assault, upskirting or sexually inappropriate pictures or videos (including the sharing of nudes and semi-nudes)

See appendix 3 for more information about child-on-child abuse.

Procedures for dealing with allegations of child-on-child abuse

If a Children or Young People makes an allegation of abuse against another pupil: You must record the allegation and tell the DSL, but do not investigate it

The DSL will contact Birmingham Children’s Trust and follow the advice given, as well as the police if the allegation involves a potential criminal offence

The DSL will put a risk assessment and support plan into place for all children involved (including the victim(s), the child(ren) against whom the allegation has been made and any others affected) with a named person they can talk to if needed.

The DSL will contact the children and adolescent mental health services (CAMHS), if appropriate

If the incident is a criminal offence and there are delays in the criminal process, the DSL will work closely with the police (and other agencies as required) while protecting children and/or taking any actions against the alleged perpetrator. We will ask the police if we have any questions about the investigation.

Creating a supportive environment and minimising the risk of child-on-child abuse

We recognise the importance of taking proactive action to minimise the risk of child-on-child abuse, and of creating a supportive environment where victims feel confident in reporting incidents.

To achieve this, we will:

Challenge any form of derogatory or sexualised language or inappropriate behaviour between peers, including requesting or sending sexual images

Be vigilant to issues that particularly affect different genders – for example, sexualised or aggressive touching or grabbing towards female children, and initiation or hazing type violence with respect to boys

Ensure children and young people are able to easily and confidently report abuse using our reporting systems

Ensure staff reassure victims that they are being taken seriously

Be alert to reports of sexual violence and/or harassment that may point to environmental or systemic problems that could be addressed by updating policies, and processes, or could reflect wider issues in the local area that should be shared with safeguarding partners.

Support children who have witnessed sexual violence, especially rape or assault by penetration. We will do all we can to make sure the victim, alleged perpetrator(s) and any witnesses are not bullied or harassed

Consider intra-familial harms and any necessary support for siblings following a report of sexual violence and/or harassment

Ensure staff are trained to understand:

· How to recognise the indicators and signs of child-on-child abuse, and know how to identify it and respond to reports

· That even if there are no reports of child-on-child abuse in school, it does not mean it is not happening – staff should maintain an attitude of “it could happen here”

· That if they have any concerns about a child’s welfare, they should act on them immediately rather than wait to be told, and that victims may not always make a direct report

· The important role they have to play in preventing child-on-child abuse and responding where they believe a child may be at risk from it and they should speak to the DSL if they have any concerns

The DSL will take the lead role on any action required in relation to the alleged perpetrator(s). We will provide support at the same time as taking any formal action. Action can be taken while other investigations are going on, e.g. by the police. The fact that another body is investigating or has investigated an incident does not, in itself, prevent our Project from reaching its own conclusion about what happened and making a decision.

Sharing of nudes and semi-nudes (‘Sexting’)

Your responsibilities when responding to an incident

If you are made aware of an incident involving the consensual or non-consensual sharing of nude or semi-nude images/videos, including pseudo-images, which are computer-generated images that

otherwise appear to be a photograph or video (also known as ‘sexting’ or ‘youth produced sexual imagery’), you must report it to the DSL immediately.

You must not:

View, copy, print, share, store or save the imagery yourself, or ask a child or young person to share or download it (if you have already viewed the imagery by accident, you must report this to the DSL)

Delete the imagery or ask the child or young person to delete it

Ask the child(s) or young person who are involved in the incident to disclose information regarding the imagery (this is the DSL’s responsibility)

Share information about the incident with other members of staff, the child(s) or young person it involves or their, or other, parents and/or carers

Say or do anything to blame or shame any young people involved

You should explain that you need to report the incident and reassure the child or young person that they will receive support and help from the DSL.

Informing parents/carers

The DSL will inform parents/carers at an early stage and keep them involved in the process unless there is a good reason to believe that involving them would put the pupil at risk of harm.

Recording incidents

All incidents of sharing of nudes and semi-nudes, and the decisions made in responding to them, will be recorded. The record-keeping arrangements set out in of this policy also apply to recording these incidents.

Reporting systems for children and young people using Springfield Project services

Where there is a safeguarding concern, we will take the child’s wishes and feelings into account when determining what action to take and what services to provide.

We recognise the importance of ensuring children and young people feel safe and comfortable to come forward and report any concerns and/or allegations.

To achieve this, we will:

Put systems in place for children and young people to confidently report abuse

Ensure our reporting systems are well promoted, easily understood and easily accessible for children and young people

Make it clear to children and young people that their concerns will be taken seriously, and that they can safely express their views and give feedback

4.5 Online safety and the use of mobile technology

We understand the need to protect children from harmful online content. Technology is a key factor in safeguarding and wellbeing. The Project aims to:

Have robust processes (including filtering and monitoring systems) in place to ensure the online safety of children, young people, staff, volunteers and trustees.

Protect and educate the whole Project to ensure safe and responsible use of technology, including mobile and smart technology (which we refer to as ‘mobile phones’)

Set clear guidelines for the use of mobile phones

Establish clear mechanisms to identify, intervene in and escalate any incidents or concerns, where appropriate

The 4 key categories of risk

Our approach to online safety is based on addressing the following categories of risk:

Content – being exposed to illegal, inappropriate or harmful content, such as pornography, fake news, racism, misogyny, self-harm, suicide, antisemitism, radicalisation and extremism

Contact – being subjected to harmful online interaction with other users, such as peer-to-peer pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes

Conduct – personal online behaviour that increases the likelihood of, or causes, harm, such as making, sending and receiving explicit images (e.g. consensual and non-consensual sharing of nudes and semi-nudes and/or pornography), sharing other explicit images and online bullying; and

Commerce – risks such as online gambling, inappropriate advertising, phishing and/or financial scams

To meet our aims and address the risks above:

We will train relevant staff, as part of their induction, on safe internet use and online safeguarding issues.

Ensure staff are aware of any restrictions placed on them with regards to the use of their mobile phone and cameras, for example, that:

• Staff are allowed to bring their personal phones to work for their own use, but will limit such use to non-contact time when children are not present

• Staff will not take pictures or recordings of pupils on their personal phones or cameras

4.6 Partnership and Joint working

Where children and young people are subject to Multi-agency plans, project staff will ensure good communication and joint working with all partners. The Project aims to attend all multi-agency meetings for all children and young people.

4.7 Looked-after and previously looked-after children

We will ensure that staff have the skills, knowledge and understanding to keep looked-after children and previously looked-after children safe.

4.8 Pupils who are lesbian, gay, bisexual or gender questioning

The section of KCSIE 2024 on gender questioning children remains under review, pending the outcome of the gender questioning children guidance consultation, and final gender questioning guidance documents being published.

Children who identify or may identify as lesbian, gay or bisexual need to receive a positive and supportive response from staff and volunteers.

Staff and volunteers should listen to children and Young people without judgement and signpost to further support if required.

Staff and volunteers should not share any confidential information with parents and carers, however, may provide support to children and young people who are considering whether and how to tell parents.

We recognise that children who are (or who are perceived to be) lesbian, gay, bisexual or gender questioning (LGBTQ+) can be targeted by other children.

We also recognise that LGBTQ+ children are more likely to experience poor mental health. Any concerns should be reported to the DSL.

When families/carers are making decisions about support for gender questioning children, they should be encouraged to seek clinical help and advice. This should be done as early as possible when supporting pre-pubertal children.

Staff will receive relevant training to support Children and Young people around LGBTQ + issues.

4.9 Complaints and concerns

Complaints against staff

Complaints against staff that are likely to require a child protection investigation will be handled in accordance with our procedures for dealing with allegations of abuse made against staff as persons in a position of trust(see appendix 2).

Other complaints

Parents & service users who want to make a complaint are expected to follow our complaints policy. Any issues that relate to our safeguarding practice will be recorded as such and dealt with accordingly

Whistle Blowing

The Project has a separate whistle blowing policy that staff can use should they have any concerns relating to safeguarding practice and concerns about staff conduct.

4.10 Record Keeping

We will hold records in line with our records retention schedule.

All safeguarding concerns, discussions, decisions made and the rationale for those decisions, must be recorded in writing. This should include instances where referrals were or were not made to another agency such as local authority Birmingham Children Trust or the Prevent programme, etc. If you are in any doubt about whether to record something, discuss it with the DSL.

Records will include:

A clear and comprehensive summary of the concern

Details of how the concern was followed up and resolved

A note of any action taken, decisions reached and the outcome

Concerns and referrals will be kept in a separate child protection file for each child.

Any non-confidential records will be readily accessible and available. Confidential information and records will be held securely and only available to those who have a right or professional need to see them. Managers are responsible for the secure storage of records within their area of work. Safeguarding records are stored:

Children’s Centre	Within the RIO electronic storage system
Mini-Springers Nursery	In a locked filing cabinet in the Nursery Manager’s office
Park Road Nursery	In a locked filing cabinet in the Nursery Manager’s office
Seedlings	In a locked filing cabinet in the Mini-Springers Nursery Manager’s
Community Services	In electronic folder

In addition:

Our Safer Recruitment policy sets out our policy on record-keeping specifically with respect to recruitment and pre-appointment checks

Appendix 2 sets out our policy on record-keeping with respect to allegations of abuse made against staff

4.11 Training

All staff

All staff members will undertake safeguarding and child protection training at induction, including on whistle-blowing procedures and online safety, to ensure they understand the Project’s safeguarding systems and their responsibilities, and can identify signs of possible abuse, exploitation or neglect.

This training will be regularly updated and will:

Be integrated, aligned and considered as part of the whole-project safeguarding approach and wider staff training.

Be in line with advice from the 3 safeguarding partners

Include online safety, including an understanding of the expectations, roles and responsibilities for staff around filtering and monitoring

All relevant Staff to receive Graded Care Profile 2 training to help identify Neglect

All staff will have training on the government’s anti-radicalisation strategy, Prevent, to enable them to identify children at risk of becoming involved with or supporting terrorism, and to challenge extremist ideas.

The DSLs and Deputy DSLs

All DSLs will undertake child protection and safeguarding training at least every 2 years.

In addition, they will update their knowledge and skills at regular intervals and at least annually (for example, through e-bulletins, meeting other DSLs, or taking time to read and digest safeguarding developments).

Trustees

All Trustees receive training about safeguarding and child protection (including online safety), which is regularly updated.

This is to make sure that they:

Have the knowledge and information needed to perform their functions and understand their responsibilities, such as providing strategic challenge

Can be assured that safeguarding policies and procedures are effective and support the Project to deliver a robust whole-project approach to safeguarding

4.12 Recruitment – interview panels

At least 1 person conducting any interview for any post at the Project will have undertaken safer recruitment training. This will cover, as a minimum, the contents of Keeping Children Safe in Education, and will be in line with local safeguarding procedures.

See our Staff Recruitment Policy for more information about our recruitment procedures and our Volunteer Policy for information about the recruitment of volunteers.

4.13 Staff who have contact with children, young people and families

All staff who have contact with children and families will have supervisions which will provide them with support, coaching and training, promote the interests of children and allow for confidential discussions of sensitive issues.

4.14 Monitoring arrangements

This policy will be reviewed annually by Sarah Mullis, and Sayma Bibi (Safeguarding Leads for the Project). At every review, it will be approved by the Board of Trustees

The DSLs meet termly for review, reflection and quality monitoring of safeguarding practices and procedure.

Trustees receive quarterly safeguarding reports for compliance and monitoring. 5. Related Policies:

This policy links to the following policies and procedures:

Positive Behaviour Management

Over 5s Behaviour

Missing Child Policy

Lost Child Policy

Anti-bullying

Whistleblowing

Staff Code of Conduct

Induction

Complaints

Health and safety

Online safety

Mobile phone use

Equality & Diversity

Volunteers

Safer Recruitment

Disciplinary

These appendices are based on the Department for Education’s statutory guidance, Keeping Children Safe in Education.

Appendix 1: types of abuse

Abuse, including neglect, and safeguarding issues are rarely standalone events that can be covered by 1 definition or label. In most cases, multiple issues will overlap.

Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Emotional abuse may involve:

Conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person

Not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate

Age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction

Seeing or hearing the ill-treatment of another

Serious bullying (including cyber-bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children

Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve:

Physical contact, including assault by penetration (for example, rape or oral sex) or non penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing

Non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet)

Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse.

Once a child is born, neglect may involve a parent or carer failing to:

Provide adequate food, clothing and shelter (including exclusion from home or abandonment) Protect a child from physical and emotional harm or danger

Ensure adequate supervision (including the use of inadequate care-givers)

Ensure access to appropriate medical care or treatment

It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Appendix 2

Allegations against staff (including low-level concerns) policy

Section 1: allegations that may meet the harm threshold

This section applies to all cases in which it is alleged that a current member of staff, including agency staff,volunteers or contractors, has:

Behaved in a way that has harmed a child, or may have harmed a child, and/or Possibly committed a criminal offence against or related to a child, and/or

Behaved towards a child or children in a way that indicates they may pose a risk of harm to children, and/or

Behaved or may have behaved in a way that indicates they may not be suitable to work with children – this includes behaviour taking place both inside and outside of school

If we’re in any doubt as to whether a concern meets the harm threshold, we will consult out local authority designated officer (LADO).

We will deal with any allegation of abuse quickly, in a fair and consistent way that provides effective child protection while also supporting the individual who is the subject of the allegation.

A ‘case manager’ will lead any investigation. This will be the CEO or a senior member of staff that the CEO has delegated responsibility to, or the chair of governors where the CEO is the subject of the allegation. The case manager will be identified at the earliest opportunity.

Our procedures for dealing with allegations will be applied with common sense and judgement.

If we receive an allegation of an incident happening while an individual or organisation was using the Project’s premises to run activities for children, we will follow our safeguarding policies and procedures and inform the LADO.

Suspension of the accused until the case is resolved

Suspension of the accused will not be the default position, and will only be considered in cases where there is reason to suspect that a child or other children is/are at risk of harm, or the case is so serious that there might be grounds for dismissal. In such cases, we will only suspend an individual if we have considered all other options available and there is no reasonable alternative.

Based on an assessment of risk, we will consider alternatives such as:

Redeployment within the Project so that the individual does not have direct contact with the child or children concerned

Providing an assistant to be present when the individual has contact with children

Redeploying the individual to alternative work in the Project so that they do not have unsupervised access to children

If in doubt, the case manager will seek views from HR and the designated officer at the local authority, as well as the police and local authority children’s social care where they have been involved.

Definitions for outcomes of allegation investigations

Substantiated: there is sufficient evidence to prove the allegation

Malicious: there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive, or to cause harm to the subject of the allegation

False: there is sufficient evidence to disprove the allegation

Unsubstantiated: there is insufficient evidence to either prove or disprove the allegation (this does not imply guilt or innocence)

Unfounded: to reflect cases where there is no evidence or proper basis which supports the allegation being made

Procedure for dealing with allegations

In the event of an allegation that meets the criteria above, the case manager will take the following steps:

Conduct basic enquiries in line with local procedures to establish the facts to help determine whether there is any foundation to the allegation before carrying on with the steps below

Discuss the allegation with the designated officer at the local authority. This is to consider the nature, content and context of the allegation and agree a course of action, including whether further enquiries are necessary to enable a decision on how to proceed, and whether it is necessary to involve the police and/or local authority children’s social care services. (The case manager may, on occasion, consider it necessary to involve the police before consulting the designated officer – for example, if the accused individual is deemed to be an immediate risk to children or there is evidence of a possible criminal offence. In such cases, the case manager will notify the designated officer as soon as practicably possible after contacting the police)

Inform the accused individual of the concerns or allegations and likely course of action as soon as possible after speaking to the designated officer (and the police or local authority children’s social care services, where necessary). Where the police and/or local authority children’s social care services are involved, the case manager will only share such information with the individual as has been agreed with those agencies

Where appropriate (in the circumstances described above), carefully consider whether suspension of the individual from contact with children at the setting is justified or whether alternative arrangements such as those outlined above can be put in place. Advice will be sought from the designated officer, police and/or local authority children’s social care services, as appropriate

Where the case manager is concerned about the welfare of other children in the community or the individual’s family, they will discuss these concerns with the DSL and make a risk assessment of the situation. If necessary, the DSL may make a referral to local authority children’s social care

If immediate suspension is considered necessary, agree and record the rationale for this with the designated officer. The record will include information about the alternatives to suspension that have been considered, and why they were rejected. Written confirmation of the suspension will

be provided to the individual facing the allegation or concern within 1 working day, and the individual will be given a named contact at the school and their contact details

If it is decided that no further action is to be taken in regard to the subject of the allegation or concern, record this decision and the justification for it and agree with the designated officer what information should be put in writing to the individual and by whom, as well as what action should follow both in respect of the individual and those who made the initial allegation

If it is decided that further action is needed, take steps as agreed with the designated officer to initiate the appropriate action and/or liaise with the police and/or local authority children’s social care services as appropriate

Provide effective support for the individual facing the allegation or concern, including appointing a named representative to keep them informed of the progress of the case and considering what other support is appropriate.

Inform the parents or carers of the child/children involved about the allegation as soon as possible if they do not already know (following agreement with local authority children’s social care services and/or the police, if applicable). The case manager will also inform the parents or carers of the requirement to maintain confidentiality about any allegations made against teachers (where this applies) while investigations are ongoing. Any parent or carer who wishes to have the confidentiality restrictions removed in respect of a staff member will be advised to seek legal advice

Keep the parents or carers of the child/children involved informed of the progress of the case (only in relation to their child – no information will be shared regarding the staff member)

Make a referral to the DBS where it is thought that the individual facing the allegation or concern has engaged in conduct that harmed or is likely to harm a child, or if the individual otherwise poses a risk of harm to a child

For our Early Years settings:

We will inform Ofsted of any allegations of serious harm or abuse by any person living, working, or looking after children at the premises (whether the allegations relate to harm or abuse committed on the premises or elsewhere), and any action taken in respect of the allegations. This notification will be made as soon as reasonably possible and always within 14 days of the allegations being made.

Where the police are involved, wherever possible the Project will ask the police at the start of the investigation to obtain consent from the individuals involved to share their statements and evidence for use in the Projects’ disciplinary process, should this be required at a later point.

Additional considerations for contracted staff

If there are concerns or an allegation is made against someone not directly employed by the Project, such as contracted staff member provided by an agency, we will take the actions below in addition to our standard procedures.

We will not decide to stop using an individual due to safeguarding concerns without finding out the facts and liaising with our LADO to determine a suitable outcome

The CEO will discuss with the agency whether it is appropriate to suspend the individual.

We will involve the agency fully, but the Project will take the lead in collecting the necessary information and providing it to the LADO as required

We will address issues such as information sharing, to ensure any previous concerns or allegations known to the agency are taken into account (we will do this, for example, as part of the allegations management meeting or by liaising directly with the agency where necessary)

When using an agency, we will inform them of our process for managing allegations, and keep them updated about our policies as necessary, and will invite the agency’s HR manager or equivalent to meetings as appropriate.

Specific actions:

Action following a criminal investigation or prosecution

The case manager will discuss with the local authority’s designated officer whether any further action, including disciplinary action, is appropriate and, if so, how to proceed, taking into account information provided by the police and/or local authority children’s social care services.

Conclusion of a case where the allegation is substantiated

If the allegation is substantiated and the individual is dismissed or the Project ceases to use their services, or the individual resigns or otherwise ceases to provide their services, the Project will make a referral to the DBS for consideration of whether inclusion on the barred lists is required.

Individuals returning to work after suspension

If it is decided on the conclusion of a case that an individual who has been suspended can return to work, the case manager will consider how best to facilitate this.

The case manager will also consider how best to manage the individual’s contact with the child or children who made the allegation, if they are still attending the setting.

Unsubstantiated, unfounded, false or malicious reports

If a report is:

Determined to be unsubstantiated, unfounded, false or malicious, the CEO/Lead DSL will consider the appropriate next steps. If they consider that the child and/or person who made the allegation is in need of help, or the allegation may have been a cry for help, a referral to local authority children’s social care may be appropriate

Shown to be deliberately invented, or malicious, the Project will consider whether any disciplinary action is appropriate against the individual(s) who made it

Unsubstantiated, unfounded, false or malicious allegations

If an allegation is:

Determined to be unsubstantiated, unfounded, false or malicious, the LADO and case manager will consider the appropriate next steps. If they consider that the child and/or person who made the allegation is in need of help, or the allegation may have been a cry for help, a referral to local authority children’s social care may be appropriate

Shown to be deliberately invented, or malicious, the Project will consider whether any disciplinary action is appropriate against the individual(s) who made it

Confidentiality and information sharing

The Project will make every effort to maintain confidentiality and guard against unwanted publicity while an allegation is being investigated or considered.

The case manager will take advice from the LADO, police and local authority children’s social care services, as appropriate, to agree:

· Who needs to know about the allegation and what information can be shared

· How to manage speculation, leaks and gossip, including how to make parents or carers of a child/children involved aware of their obligations with respect to confidentiality

· What, if any, information can be reasonably given to the wider community to reduce speculation · How to manage press interest if, and when, it arises

Record-keeping

The case manager will maintain clear records about any case where the allegation or concern meets the criteria above and store them on the individual’s confidential personnel file for the duration of the case.

The records of any allegation that, following an investigation, is found to be malicious or false will be deleted from the individual’s personnel file (unless the individual consents for the records to be retained on the file).

For all other allegations (which are not found to be malicious or false), the following information will be kept on the file of the individual concerned:

· A clear and comprehensive summary of the allegation

· Details of how the allegation was followed up and resolved

· Notes of any action taken, decisions reached and the outcome

· A declaration on whether the information will be referred to in any future reference

In these cases, the Project will provide a copy to the individual, in agreement with local authority children’s social care or the police as appropriate.

We will retain all records at least until the accused individual has reached normal pension age, or for 10 years from the date of the allegation if that is longer.

References

When providing employer references, we will:

Not refer to any allegation that has been found to be false, unfounded, unsubstantiated or malicious, or any repeated allegations which have all been found to be false, unfounded, unsubstantiated or malicious

Include substantiated allegations, provided that the information is factual and does not include opinions

Learning lessons

After any cases where the allegations are substantiated, the case manager will review the circumstances of the case with the local authority’s designated officer to determine whether there are any improvements that we can make to the Project’s procedures or practice to help prevent similar events in the future.

This will include consideration of (as applicable):

· Issues arising from the decision to suspend the member of staff

· The duration of the suspension

· Whether or not the suspension was justified

· The use of suspension when the individual is subsequently reinstated. We will consider how future investigations of a similar nature could be carried out without suspending the individual

For all other cases, the case manager will consider the facts and determine whether any improvements can be made.

Non-recent allegations

Abuse can be reported, no matter how long ago it happened.

We will report any non-recent allegations made by a child to the LADO in line with our local authority’s procedures for dealing with non-recent allegations.

Where an adult makes an allegation to the Project that they were abused as a child, we will advise the individual to report the allegation to the police.

Section 2: concerns that do not meet the harm threshold

The section is based on ‘Section 2: Concerns that do not meet the harm threshold’ in part 4 of Keeping Children Safe in Education.

This section applies to all concerns (including allegations) about members of staff, including supply Trustees, volunteers and contractors, which do not meet the harm threshold set out in section 1 above.

Concerns may arise through, for example:

Suspicion

Complaint

Safeguarding concern or allegation from another member of staff

Disclosure made by a child, parent or other adult within or outside the setting Pre-employment vetting checks

We recognise the importance of responding to and dealing with any concerns in a timely manner to safeguard the welfare of children.

Definition of low-level concerns

The term ‘low-level’ concern is any concern – no matter how small – that an adult working in or on behalf of the setting may have acted in a way that:

Is inconsistent with the staff code of conduct, including inappropriate conduct outside of work, and

Does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the designated officer at the local authority

Examples of such behaviour could include, but are not limited to:

Being overly friendly with children

Having favourites

Taking photographs of children on their mobile phone

Engaging with a child on a one-to-one basis in a secluded area or behind a closed door Humiliating pupils

Sharing low-level concerns

We recognise the importance of creating a culture of openness, Project and transparency to encourage all staff to confidentially share low-level concerns so that they can be addressed appropriately.

We will create this culture by:

Ensuring staff are clear about what appropriate behaviour is, and are confident in distinguishing expected and appropriate behaviour from concerning, problematic or inappropriate behaviour, in themselves and others

Empowering staff to share any low-level concerns

Empowering staff to self-refer

Addressing unprofessional behaviour and supporting the individual to correct it at an early stage

Providing a responsive, sensitive and proportionate handling of such concerns when they are raised

Helping to identify any weakness in the Project’s safeguarding system

Responding to low-level concerns

If the concern is raised via a third party, the Designated Safeguarding Lead will collect evidence where necessary by speaking:

Directly to the person who raised the concern, unless it has been raised anonymously To the individual involved and any witnesses

The Designated Safeguarding Lead/CEO will use the information collected to categorise the type of behaviour and determine any further action, in line with the Project’s staff code of conduct. The Designated Safeguarding Lead/CEO will be the ultimate decision-maker in respect of all low-level concerns, though they may wish to collaborate with the DSL.

Record keeping

All low-level concerns will be recorded in writing. In addition to details of the concern raised, records will include the context in which the concern arose, any action taken and the rationale for decisions and action taken.

Records will be:

Kept confidential, held securely and comply with the DPA 2018 and UK GDPR

Reviewed so that potential patterns of concerning, problematic or inappropriate behaviour can be identified. Where a pattern of such behaviour is identified, we will decide on a course of action, either through our disciplinary procedures or, where a pattern of behaviour moves from a concern to meeting the harm threshold as described in section 1 of this appendix, we will refer it to the designated officer at the local authority

Retained at least until the individual leaves employment at the Project

Where a low-level concern relates to an agency staff or contractor, we will notify the individual’s employer, so any potential patterns of inappropriate behaviour can be identified.

References

We will not include low-level concerns in references unless:

The concern (or group of concerns) has met the threshold for referral to the designated officer at the local authority and is found to be substantiated; and/or

The concern (or group of concerns) relates to issues which would ordinarily be included in a reference, such as misconduct or poor performance

Appendix 3: specific safeguarding issues

This appendix is mostly based on the advice in Keeping Children Safe in Education, in particular, annex B

Annex B also includes information on further issues to be aware of, including child abduction and community safety incidents, children’s involvement in the court system, children with family members in prison, county lines, modern slavery and cybercrime

Assessing adult-involved nude and semi-nude sharing incidents

This section is based on annex A of the UK Council of Internet Safety’s advice for education settings.

All adult-involved nude and semi-nude image sharing incidents are child sexual abuse offences and must immediately be referred to police/social care. However, as adult-involved incidents can present as child-on-child nude/semi-nude sharing, it may be difficult to initially assess adult involvement.

There are two types of common adult-involved incidents: sexually motivated incidents and financially motivated incidents.

Sexually motivated incidents

In this type of incident, an adult offender obtains nude and semi-nudes directly from a child or young person using online platforms.

To make initial contact, the offender may present as themselves or use a false identity on the platform, sometimes posing as a child or young person to encourage a response and build trust. The offender often grooms the child or young person on social media, in chatrooms or on gaming platforms, and may then move the conversation to a private messaging app or an end-to-end encrypted (E2EE) environment where a request for a nude or semi-nude is made. To encourage the child or young person to create and share nude or semi-nude, the offender may share pornography or child sexual abuse material (images of other young people), including AI-generated material.

Once a child or young person shares a nude or semi-nude, an offender may blackmail the child or young person into sending more images by threatening to release them online and/or send them to friends and family.

Potential signs of adult-involved grooming and coercion can include the child or young person being:

Contacted by an online account that they do not know but appears to be another child or young person

Quickly engaged in sexually explicit communications, which may include the offender sharing unsolicited images

Moved from a public to a private/E2EE platform

Coerced/pressured into doing sexual things, including creating nudes and semi-nudes Offered something of value such as money or gaming credits

Threatened or blackmailed into carrying out further sexual activity. This may follow the child or young person initially sharing the image or the offender sharing a digitally manipulated image of the child or young person to extort ‘real’ images

Financially motivated incidents

Financially motivated sexual extortion (often known as ‘sextortion’) is an adult-involved incident in which an adult offender (or offenders) threatens to release nudes or semi-nudes of a child or young person unless they pay money or do something else to benefit them.

Unlike other adult-involved incidents, financially motivated sexual extortion is usually carried out by offenders working in sophisticated organised crime groups (OCGs) overseas and are only motivated by profit. Adults are usually targeted by these groups too.

Offenders will often use a false identity, sometimes posing as a child or young person, or hack another young person’s account to make initial contact. To financially blackmail the child or young person, they may:

Groom or coerce the child or young person into sending nudes or semi-nudes and financially blackmail them

Use images that have been stolen from the child or young person taken through hacking their account

Use digitally manipulated images, including AI-generated images, of the child or young person

The offender may demand payment or the use of the victim’s bank account for the purposes of money laundering.

Potential signs of adult-involved financially motivated sexual extortion can include the child or young person being:

Contacted by an online account that they do not know but appears to be another child or young person. They may be contacted by a hacked account of a child or young person

Quickly engaged in sexually explicit communications which may include the offender sharing an image first

Moved from a public to a private/E2EE platform

Pressured into taking nudes or semi-nudes

Told they have been hacked and they have access to their images, personal information and contacts

Blackmailed into sending money or sharing bank account details after sharing an image or the offender sharing hacked or digitally manipulated images of the child or young person

Children who are absent from education

A child being absent from education, particularly repeatedly, can be a warning sign of a range of safeguarding issues. This might include abuse or neglect, such as sexual abuse or exploitation or child criminal exploitation, or issues such as mental health problems, substance abuse, radicalisation, FGM or forced marriage.

There are many circumstances where a child may be absent or become missing from education, but some children are particularly at risk. These include children who:

Are at risk of harm or neglect

Are at risk of forced marriage or FGM

Come from Gypsy, Roma, or Traveller families

Come from the families of service personnel

Go missing or run away from home or care

Are supervised by the youth justice system

Cease to attend a school

Come from new migrant families

We will follow our procedures for absence and for dealing with children who are absent, particularly on repeat occasions, to help identify the risk of abuse, exploitation and neglect, including sexual exploitation, and to help prevent the risks of going missing in future. This includes informing the local authority if a child leaves a setting without a new setting being named, and adhering to requirements with respect to sharing information with the local authority, when applicable, when removing a child’s name from the admission register at non-standard transition points.

Staff will be trained in signs to look out for and the individual triggers to be aware of when considering the risks of potential safeguarding concerns which may be related to being absent, such as travelling to conflict zones, FGM and forced marriage.

If a staff member suspects that a child is suffering from harm or neglect, we will follow local child protection procedures, including with respect to making reasonable enquiries. We will make an immediate referral to the local authority children’s social care team, and the police, if the child is suffering or likely to suffer from harm, or in immediate danger.

Child criminal exploitation

Child criminal exploitation (CCE) is a form of abuse where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into criminal activity. It may involve an exchange for something the victim needs or wants, and/or for the financial or other advantage of the perpetrator or facilitator, and/or through violence or the threat of violence.

The abuse can be perpetrated by males or females, and children or adults. It can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse.

The victim can be exploited even when the activity appears to be consensual. It does not always involve physical contact and can happen online. For example, young people may be forced to work in cannabis factories, coerced into moving drugs or money across the country (county lines), forced to shoplift or pickpocket, or to threaten other young people.

Indicators of CCE can include a child:

Appearing with unexplained gifts or new possessions

Associating with other young people involved in exploitation

Suffering from changes in emotional wellbeing

Misusing drugs and alcohol

Going missing for periods of time or regularly coming home late

Regularly missing school or education

Not taking part in education

If a member of staff suspects CCE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate.

Child sexual exploitation

Child sexual exploitation (CSE) is a form of child sexual abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity. It may involve an exchange for something the victim needs or wants and/or for the financial advantage or increased status of the perpetrator or facilitator. It may, or may not, be accompanied by violence or threats of violence.

The abuse can be perpetrated by males or females, and children or adults. It can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse.

The victim can be exploited even when the activity appears to be consensual. Children or young people who are being sexually exploited may not understand that they are being abused. They often protect their abuser and may be tricked into believing they are in a loving, consensual relationship.

CSE can include both physical contact (penetrative and non-penetrative acts) and non-contact sexual activity. It can also happen online. For example, young people may be persuaded or forced to share sexually explicit images of themselves, have sexual conversations by text, or take part in sexual activities using a webcam. CSE may also occur without the victim’s immediate knowledge, for example through others copying videos or images.

In addition to the CCE indicators above, indicators of CSE can include a child:

Having an older boyfriend or girlfriend

Suffering from sexually transmitted infections or becoming pregnant

If a member of staff suspects CSE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate.

Child-on-child abuse

Child-on-child abuse is when children abuse other children. This type of abuse can take place inside and outside of school. It can also take place both face-to-face and online, and can occur simultaneously between the 2.

Our school has a zero-tolerance approach to sexual violence and sexual harassment. We recognise that even if there are there no reports, that doesn’t mean that this kind of abuse isn’t happening.

Child-on-child abuse is most likely to include, but may not be limited to:

Bullying (including cyber-bullying, prejudice-based and discriminatory bullying)

Abuse in intimate personal relationships between children (this is sometimes known as ‘teenage relationship abuse’)

Physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse)

Sexual violence, such as rape, assault by penetration and sexual assault (this may include an online element which facilitates, threatens and/or encourages sexual violence)

Sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of abuse

Causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party

Consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth produced sexual imagery)

Upskirting, which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm

Initiation/hazing type violence and rituals (this could 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)

Where children abuse their peers online, this can take the form of, for example, abusive, harassing, and misogynistic messages; the non-consensual sharing of indecent images, especially around chat groups; and the sharing of abusive images and pornography, to those who don’t want to receive such content.

If staff have any concerns about child-on-child abuse, or a child makes a report to them, they will follow the procedures set out in our main policy.

When considering instances of harmful sexual behaviour between children, we will consider their ages and stages of development. We recognise that children displaying harmful sexual behaviour have often experienced their own abuse and trauma, and will offer them appropriate support.

Domestic abuse

Children can witness and be adversely affected by domestic abuse and/or violence at home where it occurs between family members. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.

Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse (abuse in intimate personal relationships between children) and child/adolescent to parent violence and abuse. It can be physical, sexual, financial, psychological or emotional. It can also include ill treatment that isn’t physical, as well as 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, including where they see, hear or experience its effects.

Anyone can be a victim of domestic abuse, regardless of gender, age, ethnicity, socioeconomic status, sexuality or background, and domestic abuse can take place inside or outside of the home. Children who witness domestic abuse are also victims.

Older children may also experience and/or be the perpetrators of domestic abuse and/or violence in their own personal relationships. This can include sexual harassment.

Exposure to domestic abuse and/or violence can have a serious, long-lasting emotional and psychological impact on children and affect their health, wellbeing, development and ability to learn.

If police are called to an incident of domestic abuse and any children in the household have experienced the incident, the police will inform the key adult in school (usually the designated safeguarding lead) before the child or children arrive at school the following day. This is the procedure where police forces are part of Operation Encompass..

The DSL will provide support according to the child’s needs and update records about their circumstances.

Homelessness

Being homeless or being at risk of becoming homeless presents a real risk to a child’s welfare.

The DSL and deputy/deputies will be aware of contact details and referral routes in to the local housing authority so they can raise/progress concerns at the earliest opportunity (where appropriate and in accordance with local procedures).

Where a child has been harmed or is at risk of harm, the DSL will also make a referral to local authority children’s social care.

So-called ‘honour-based’ abuse (including FGM and forced marriage)

So-called ‘honour-based’ abuse (HBA) encompasses incidents or crimes committed to protect or defend the honour of the family and/or community, including FGM, forced marriage, and practices such as breast ironing.

Abuse committed in this context often involves a wider network of family or community pressure and can include multiple perpetrators.

All forms of HBA are abuse and will be handled and escalated as such. All staff will be alert to the possibility of a child being at risk of HBA or already having suffered it. If staff have a concern, they will speak to the DSL, who will activate local safeguarding procedures.

Female Genital Mutilation (FGM)

The DSL will make sure that staff have access to appropriate training to equip them to be alert to children affected by FGM or at risk of FGM.

Indicators that FGM has already occurred include:

A pupil confiding in a professional that FGM has taken place

A mother/family member disclosing that FGM has been carried out

A family/pupil already being known to social services in relation to other safeguarding issues A girl:

· Having difficulty walking, sitting or standing, or looking uncomfortable

· Finding it hard to sit still for long periods of time (where this was not a problem previously)

· Spending longer than normal in the bathroom or toilet due to difficulties urinating · Having frequent urinary, menstrual or stomach problems

· Avoiding physical exercise or missing PE

· Being repeatedly absent from school, or absent for a prolonged period

· Demonstrating increased emotional and psychological needs – for example, withdrawal or depression, or significant change in behaviour

· Being reluctant to undergo any medical examinations

· Asking for help, but not being explicit about the problem

· Talking about pain or discomfort between her legs

Potential signs that a pupil may be at risk of FGM include:

The girl’s family having a history of practising FGM (this is the biggest risk factor to consider) FGM being known to be practised in the girl’s community or country of origin A parent or family member expressing concern that FGM may be carried out

A family not engaging with professionals (health, education or other) or already being known to social care in relation to other safeguarding issues

A girl:

· Having a mother, older sibling or cousin who has undergone FGM

· Having limited level of integration within UK society

· Confiding to a professional that she is to have a “special procedure” or to attend a special occasion to “become a woman”

· Talking about a long holiday to her country of origin or another country where the practice is prevalent, or parents/carers stating that they or a relative will take the girl out of the country for a prolonged period

· Requesting help from a teacher or another adult because she is aware or suspects that she is at immediate risk of FGM

· Talking about FGM in conversation – for example, a girl may tell other children about it (although it is important to take into account the context of the discussion)

· Being unexpectedly absent from school

· Having sections missing from her ‘red book’ (child health record) and/or attending a travel clinic or equivalent for vaccinations/anti-malarial medication

The above indicators and risk factors are not intended to be exhaustive.

Forced marriage

Forcing a person into marriage is a crime. A forced marriage is one entered into without the full and free consent of 1 or both parties and where violence, threats, or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological.

It is also illegal to cause a child under the age of 18 to marry, even if violence, threats or coercion are not involved.

Staff will receive training around forced marriage and the presenting symptoms. We are aware of the ‘1 chance’ rule, i.e. we may only have 1 chance to speak to the potential victim and only 1 chance to save them.

If a member of staff suspects that a pupil is being forced into marriage, they will speak to the pupil about their concerns in a secure and private place. They will then report this to the DSL.

The DSL will:

Speak to the pupil about the concerns in a secure and private place

Activate the local safeguarding procedures and refer the case to the local authority’s designated officer

Seek advice from the Forced Marriage Unit on 020 7008 0151 or [email protected]

Refer the pupil to an education welfare officer, pastoral tutor, learning mentor, or school counsellor, as appropriate

Preventing radicalisation

Radicalisation refers to the process of a person legitimising support for, or use of, terrorist violence

Extremism is the promotion or advancement of an ideology based on violence, hatred or intolerance, that aims to:

· Negate or destroy the fundamental rights and freedoms of others; or

· Undermine, overturn or replace the UK’s system of liberal parliamentary democracy and democratic rights; or

· Intentionally create a permissive environment for others to achieve the results outlined in either of the above points

Terrorism is an action that:

· Endangers or causes serious violence to a person/people;

· Causes serious damage to property; or

· Seriously interferes or disrupts an electronic system

The use or threat of terrorism must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious or ideological cause. Schools have a duty to prevent children from becoming involved with or supporting terrorism. The DSL, or designated Prevent lead, will undertake in-depth Prevent awareness training, including on extremist and terrorist ideologies. They’ll make sure that staff have access to appropriate training to equip them to identify children at risk.

We will assess the risk of children in our school from becoming involved with or supporting terrorism. This assessment will be based on an understanding of the potential risk in our local area, in collaboration with our local safeguarding partners and local police force.

We will ensure that suitable internet filtering is in place, and equip our pupils to stay safe online at school and at home.

There is no single way of identifying an individual who is likely to be susceptible to radicalisation into terrorism. Radicalisation can occur quickly or over a long period.

Staff will be alert to changes in pupils’ behaviour.

The government website Educate Against Hate and charity NSPCC say that signs that a pupil is being radicalised can include:

Refusal to engage with, or becoming abusive to, peers who are different from themselves Becoming susceptible to conspiracy theories and feelings of persecution

Changes in friendship groups and appearance

Rejecting activities they used to enjoy

Converting to a new religion

Isolating themselves from family and friends

Talking as if from a scripted speech

An unwillingness or inability to discuss their views

A sudden disrespectful attitude towards others

Increased levels of anger

Increased secretiveness, especially around internet use

Expressions of sympathy for extremist ideologies and groups, or justification of their actions Accessing extremist material online, including on Facebook or Twitter

Possessing extremist literature

Being in contact with extremist recruiters and joining, or seeking to join, extremist organisations

Children who are at risk of radicalisation may have low self-esteem, or be victims of bullying or discrimination. It is important to note that these signs can also be part of normal teenage behaviour – staff should have confidence in their instincts and seek advice if something feels wrong.

If staff are concerned about a child, they will follow our safeguarding procedures, including discussing their concerns with the DSL.

Staff should always take action if they are worried.

Sexual violence and sexual harassment between children in Project activities Sexual violence and sexual harassment can occur:

Between 2 children of any age and sex

Through a group of children sexually assaulting or sexually harassing a single child or group of children

Online and face to face (both physically and verbally)

Sexual violence and sexual harassment exist on a continuum and may overlap.

Children who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment and will be exacerbated if the alleged perpetrator(s) attends the same school.

If a victim reports an incident, it is essential that staff make sure they are reassured that they are being taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting any form of abuse or neglect. Nor should a victim ever be made to feel ashamed for making a report.

When supporting victims, staff will:

Reassure victims that the law on child-on-child abuse is there to protect them, not criminalise them

Regularly review decisions and actions, and update policies with lessons learnt

Look out for potential patterns of concerning, problematic or inappropriate behaviour, and decide on a course of action where we identify any patterns

Consider if there are wider cultural issues within the school that enabled inappropriate behaviour to occur and whether revising policies and/or providing extra staff training could minimise the risk of it happening again

Remain alert to the possible challenges of detecting signs that a child has experienced sexual violence, and show sensitivity to their needs

Some groups are potentially more at risk. Evidence shows that girls, children with SEN and/or disabilities, and lesbian, gay, bisexual and transgender (LGBT) children are at greater risk.

Staff should be aware of the importance of:

Challenging inappropriate behaviours

Making clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up

Challenging physical behaviours (potentially criminal in nature), such as grabbing bottoms, breasts and genitalia, pulling down trousers, flicking bras and lifting up skirts. Dismissing or tolerating such behaviours risks normalising them

If staff have any concerns about sexual violence or sexual harassment, or a child makes a report to them, they will follow the Project’s safeguarding procedures set out in this policy.

Serious violence

Indicators which may signal that a child is at risk from, or involved with, serious violent crime may include:

Increased absence from school

Change in friendships or relationships with older individuals or groups

Significant decline in performance

Signs of self-harm or a significant change in wellbeing

Signs of assault or unexplained injuries

Unexplained gifts or new possessions (this could indicate that the child has been approached by, or is involved with, individuals associated with criminal networks or gangs and may be at risk of criminal exploitation (see above))

Risk factors which increase the likelihood of involvement in serious violence include: Being male

Having been frequently absent or permanently excluded from school

Having experienced child maltreatment

Having been involved in offending, such as theft or robbery

Staff will be aware of these indicators and risk factors. If a member of staff has a concern about a pupil being involved in, or at risk of, serious violence, they will report this to the DSL.

Checking the identity and suitability of visitors

All visitors will be required to verify their identity to the satisfaction of staff. Visitors entering one of our early years services will be required to leave their belongings, including their mobile phone(s), in a safe place during their visit.

If the visitor is unknown to the setting, we will check their credentials and reason for visiting before allowing them to enter the setting. Visitors should be ready to produce identification.

Visitors are expected to sign the visitors book and wear a visitor’s badge.

Visitors to one of our childrens services who are visiting for a professional purpose will be asked to show a photo ID and:

Will be asked to show their DBS certificate, which will be checked alongside their photo ID

Non-collection of children

If a child is not collected at the end of the session/day, please refer to the settings-specific policy.

Missing Child

Please refer to the setting-specific policy.

	Child Protection & Safeguarding Policy
Date: September 2024	Owner: Sarah Mullis and Sayma Bibi
Date Approved:	23^rdSeptember 2024
Review date: September 2025	Version: 1

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