SafeGuarding & Child Protection
Policy
2024-2025
Date:
August/September 2024
Date of next review:
September 2025
CONTENTS
1. Introduction
Providing a Safe and Supportive Environment
2.1 Safer Recruitment and Selection
2.2 Safe Practice
2.3 Sharing Safeguarding Information with Students
2.4 Partnership with parents/carers
2.5 Partnership with others
2.6 Staff training and Induction
2.7 Support, Advice and Guidance for Staff
2.8 On-line Safety
2.9 Related Academy Policies
2.10 Student Information
2.11 Roles and Responsibilities:
● Action2Change
● Management
● Designated Safeguarding Lead
Section 3 – Identifying Children and Young People who may be suffering or are likely to suffer significant harm
3.1 Definitions
Section 4 – Taking Action to Ensure that Children and Young People are Safe at Action2Change and at Home
4.1 Staff will immediately report
4.2 Responding to Disclosure
4.3 Action by Designated Safeguarding Lead
4.4 Action following Child Protection referral
4.5 Recording and Monitoring
4.6 Allegations Regarding Person(s) Working in or on Behalf of the Academy, including low level concerns
4.7 Children Potentially at Greater Risk of Harm
4.8 Child on Child Abuse
4.9 Physical Intervention and Use of Reasonable Force
4.10 Domestic Abuse
4.11 Children and the Court System
Appendices
Prevent Duty and Radicalisation.
Child Sexual Exploitation.
So-Called ‘Honour’ Based Abuse.
Children Absent form Education.
Sexting.
Online safety.
NAMED PERSONS WITH RESPONSIBILITY FOR CHILD PROTECTION: Designated Safeguarding Lead: David Downs - Business owner/Director
Safeguarding Officers: Robert (Philip) Wilson
Kirsty Asquith
1. INTRODUCTION
This policy is in response to:
1) The Children Act 1988 and 2004
Provides the overarching framework for care and protection of children.
2)Education Act 2002
Section 175 of the Education Act 2002 requires local education authorities and the governors of maintained schools and further education (FE) colleges to ensure that their functions are carried out with a view to safeguarding and promoting the welfare of children.
Education (Independent Schools Standards) Regulations 2014 require independent schools to have arrangements to safeguard and promote the welfare of children who are pupils at the school.
3)Working Together To Safeguard Children 2023 - Working together to safeguard children - GOV.UK (www.gov.uk) The legislative requirements and expectations on all services working with children to safeguard and promote the welfare of Children. The three safeguarding Partners of Health, Police and Local Authority will make arrangements for education to be fully engaged in their local area arrangements.
4) Keeping Children Safe in Education 2024 - Keeping children safe in education - GOV.UK (www.gov.uk) Schools and colleges must have regard to this guidance when carrying out their duties to safeguard and promote the welfare of children. This publication includes the guidance on Sexual Violence and Sexual Harassment between children in schools and colleges.
5)Prevent Duty Guidance - prevent duty guidance - GOV.UK (www.gov.uk) England and Wales Covers the duty of schools and other providers in section 29 Counter Terrorism and Security Act 2015, to have due regard to the need to prevent people being drawn into terrorism.
6)Counter Terrorism and Security Act 2015 - Section 26 Applies to schools and other providers.
7) Serious Crime Act 2015 - Includes the mandatory reporting of FGM.
8)Information Sharing Guidance 2024 - Information sharing advice - GOV.UK (www.gov.uk)
9)Sharing Nudes and Semi Nudes 2024 - Sharing nudes and Semi-Nudes: advice for education settings with children and young people - GOV.UK (www.gov.uk)
10) Equality Act 2010 - Equality act 2010:advice for schools - GOV.UK (www.gov.uk) Schools/Colleges must not unlawfully discriminate against pupils because of their sex, race, disability, religion or belief, gender reassignment, pregnancy and maternity or sexual orientation (protected characteristics).
This policy applies to all adults, working in or on behalf of the Action2Change.
It is in line with the relevant Safeguarding Partnership’s Child Protection Procedures and DfE guidance. ‘Children’ includes everyone under the age of 18.
Everyone in the education service shares an objective to help keep children and young people safe by contributing to:
● Providing a safe environment for children and young people to learn in education settings; and
● Identifying children and young people who are suffering or likely to suffer significant harm, and taking appropriate action with the aim of making sure they are kept safe both at home and in the education setting.
● Safeguarding and promoting the welfare of children is everyone’s responsibility. Everyone who comes into contact with children and their families and carers has a role to play in safeguarding children. In order to fulfill this responsibility effectively, all professionals should make sure their approach is child-centered. This means that they should consider, at all times, what is in the best interests of the child.
Action2Change commitment
Action2Change is committed to safeguarding and promoting the welfare of all its students. Each student’s welfare is of importance. We recognise that some children may be especially vulnerable to abuse e.g. those with Special Educational Needs, those living in adverse circumstances. We recognise that children who are abused or neglected may find it difficult to develop a sense of self worth and to view the world in a positive way. We recognised that children who have been abused may not always be ready to share this information, and will provide a trusted and safe space when they are ready. Whilst at Action2Change, their behaviour may be challenging. We recognise that some children who have experienced abuse may harm others. We will always take a considered and sensitive approach in order that we can support all our students.
2. PROVIDING A SAFE AND SUPPORTIVE ENVIRONMENT 2.1Safer Recruitment and Selection
Action2Change pays full regard to DfE guidance ‘Keeping Children Safe in Education’ 2024. We ensure that all appropriate measures are applied in relation to everyone who works at Action2Change who is likely to be perceived by the students as a safe and trustworthy adult, including volunteers and staff employed by contractors. Safer recruitment practice has been fully encompassed in the Policy and procedures. Safer recruitment practice includes, verifying identity and qualifications, obtaining professional and character references, checking previous employment history and ensuring that a candidate has the health and physical capacity for the job. It also includes undertaking a selection of procedures and Disclosure and Barring Service (DBS) and other checks.
Recruitment practices in place are:
● An Enhanced DBS Certificate with Barred list check is obtained for all new staff to Action2Change;
● A CV will not be accepted, unless accompanied by a fully completed application form;
● Teacher Services checks are undertaken for all relevant staff, including QTS verification; ● ID and right to work in the UK is verified prior to appointment;
● Two references are required,
● An Enhanced DBS is obtained for volunteers;
● Action2Change staff are DBS checked where appropriate;
● All new staff to Action2Change are subject to identity, criminal conviction disclosure, health
and rights to work in the UK checks prior to commencing their employment.
2.2 Safe Practice
Staff at Action2Change have undertaken Child Safeguarding training and update this training at least every 3 years to ensure that staff are safe and aware of behaviours which should be avoided. In addition Action2Changes Code of Conduct which outlines acceptable and unacceptable behaviour towards children and young people.
Safe working practice ensures that students are safe and that all staff:
● Are responsible for their own action and behaviours and know how to avoid any conduct which could lead any reasonable person to question their motivation or intentions;
● Work in an open and transparent way;
● Discuss and/or take advice from management over any incident which may give rise to
concern;
● Record any incidents or decisions made in relation to a child or young person;
● Apply the same professional standards regardless of gender or sexuality;
● Are aware that breaches of the law and other professional guidelines could result in criminal or disciplinary action being taken against them.
2.3 Sharing Safeguarding Information with Students
Action2Change are committed to ensuring that students are aware of behaviour towards them that is not acceptable and how they can keep themselves safe. All students know that we have a senior member of staff with responsibility for child protection and know who this is. We inform students of whom they might talk to, both in and out of Action2Change, their right to be listened to and heard and what steps can be taken to protect them from harm. Life lesson materials are used to help students learn how to keep safe.
2.4 Partnership with Parents / carers
The Trust shares a purpose with parents/carers to keep children safe from harm and to have their welfare promoted.
Action2Change takes child protection and safeguarding very seriously. If a child informs staff members of any issues which cause us concern, we may request the help of outside agencies. Depending on the nature of the concern and the severity of the issue, we may or may not contact parents/carers regarding the disclosure the child has made. We would in this instance contact the relevant professional body and seek their advice. Please be aware that our aim is always to act professionally with the child’s safety and best interest at the forefront.
We are committed to working positively, open and honestly with parents/carers. We ensure that all parents/carers are treated with respect, dignity and courtesy. We respect parents/carers’ rights to privacy and confidentiality and will not share sensitive information unless we have permission or it is necessary to do so to protect a child. Action2Change staff will share with parents/carers any concerns we may have about their child unless doing so may place the child at risk of harm.
Action2Change will discuss all concerns with parents/carers about their child/ren. However, there may be exceptional circumstances when we will discuss concerns with Social Care and/or the Police without parental knowledge (in accordance with Safeguarding Partnership’s Child Protection Procedures). Action2Change will, of course, always aim to maintain a positive relationship with all parents/carers. Our Child Safeguarding Policy is available to all parents/carers upon request.
2.5 Partnerships with Others
No single professional can have a full picture of a child’s needs and circumstances. If children and families are to receive the right help at the right time, everyone who comes into contact with them has a role to play in identifying concerns, sharing information and taking prompt action. Although inter agency working and information sharing are vital in identifying and tackling all forms
of abuse, it is clear they are especially important to identify and prevent child sexual and/or criminal exploitation.
Action2Change recognises that it is essential to establish positive and effective working relationships with other agencies. These include the Local Authority, Social Care, Barnardo’s, Police, Health, Childline, NSPCC, Surestart etc.
The Data Protection Act 2018 and UK GDPR do not prevent the sharing of information for the purposes of keeping children safe. Fears about sharing information must not be allowed to stand in the way of the need to safeguard and promote the welfare and protect the safety of children.
Records of information sharing 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.
2.6 Staff Training and Induction
The Designated Safeguarding Lead and Deputy Designated Safeguarding Lead(s) with Responsibility for Child Protection undertake advanced child protection and safeguarding training on a 2 yearly basis.
All staff, undertake appropriate induction training to equip them to carry out their responsibilities for child protection effectively. Staff are required to complete online child safeguarding training which reflects the updated KCSIE and includes elements on online safety.
All staff (including temporary staff and volunteers) are made aware, prior to appointment of the responsibilities with regards to safeguarding and as part of onboarding are asked to read and sign KCSIE part 1.
All staff will be made aware that safeguarding issues can manifest themselves via child on child abuse. This is most likely to include, but not limited to: bullying (including cyber bullying), gender based violence/sexual assaults and sexting.
Staff will receive an appropriate level of training to provide them with the necessary knowledge to ensure safeguarding policies and procedures are effective. This may be delivered face to face or online.
2.7 Support, Advice and Guidance for Staff
Staff will be supported by the Designated Safeguarding Lead and Deputy Designated Safeguarding Lead, who will provide guidance and training where appropriate. They will be supported by management.
Advice and support is always available from the Local Authority’s Social Work Team and further advice is available from the Police.
2.8 Online Safety
It is essential that children are safeguarded from potentially harmful and inappropriate online material. Action2Change is compliant with the Filtering and Monitoring Standards for schools and colleges. Action2Change has a strict no-mobile phone policy to support the safeguarding of children.
As part of a broad and balanced curriculum, Action2Change offers a curriculum which covers the need for safeguarding, including online. The curriculum offers Relationships and Sex Education (RSE).
2.9 Related Trust Policies
Safeguarding covers more than the contribution made to child protection in relation to individual children. It also encompasses issues such as student health and safety and bullying and a range of other issues, for example, arrangements for meeting the medical needs of children, providing first aid, school security, drugs and substance misuse etc. There may also be other safeguarding issues that are specific to the local area of population.
Other related Trust Policies and Protocols that should be referred to include:
Health and Safety Policy
Anti-Bullying Policy
E-Safety Policy
Recruitment Procedure
Staff Code of Conduct
Whistleblowing Procedure
Alcohol Tobacco and Drug Policy
Equal Opportunities Policy
2.10 Student Information
In order to keep children safe and provide appropriate care for them Action2Change requires accurate and up to date information regarding:
● Names, address and date of birth of child;
● Names and contact details of persons with whom the child normally lives;
● Names and contact details of all persons with parental responsibility (if different from above);
● Whether the child is Looked After;
● Emergency contact details;
● If the child is or has a Child Protection Plan (formerly known as being on the Child Protection Register);
● Name and contact details of any key persons from other agencies;
● Any other factors which may impact on the safety and welfare of the child.
2.11 Roles and Responsibilities
Action2Change will ensure that:
● Child Safeguarding policy and procedures in place that are in accordance with the Safeguarding Partnership guidance and locally agreed interagency procedures, and the policy is available to parents/carers upon request;
● Safer recruitment procedures and makes sure that all appropriate checks are carried out on staff and volunteers who work with children;
● Action2Change has procedures for dealing with allegations of abuse against staff and volunteers that comply with guidance from the Local Authority and locally agreed inter-agency procedures;
● A senior member of Action2Change is designated to take lead responsibility for Child Protection (and a deputy);
● Staff undertake appropriate safeguarding and child protection training (including online safety which, amongst other things, includes an understanding of the expectations, applicable roles and responsibilities in relation to filtering and monitoring) as well as including at least annual updates;
● They remedy, without delay, any deficiencies or weaknesses regarding child protection arrangements;
● Ensure the Child Safeguarding Policy is updated and reviewed annually;
● They review their policies and procedures annually and provide information to the;
● Appropriate online filtering and monitoring is in place and is kept up to date, whilst not preventing access to online learning opportunities(if applicable);
Management will ensure that:
● The policies and procedures adopted by Action2Change are fully implemented, and followed by all staff;
● Sufficient resources and time are allocated to enable the designated Safeguarding lead and other staff to discharge their responsibilities;
● appropriate levels of qualified staff work at Action2Change to ensure adequate levels of safeguarding practitioners at all times; and
● All staff and volunteers feel able to raise concerns about poor or unsafe practice in regard to children, and such concerns are addressed sensitively and effectively in a timely manner in accordance with the agreed Whistleblowing Policy.
Each Designated Lead with Responsibility for Child Protection will:
● Take the lead responsibility for safeguarding and child protection (including online safety and understanding the filtering and monitoring systems and processes in place);
● Be given the time, funding, training, resources and support to carry out the role effectively.
Referrals
● Refer cases of suspected or alleged abuse to the relevant investigating agencies;
● Act as a source of support, advice and expertise within the setting;
● Liaise with the Director to inform of any issues and ongoing investigations and ensure there is always cover for this role.
Training
● To recognise how to identify signs of abuse and when it is appropriate to make a referral;
● Ensure that all staff have access to and understand the Child Safeguarding Policy;
● Ensure that all staff have induction training;
● Circulate relevant information and guidance to staff on a regular basis;
● Keep detailed and accurate secure written records and/or concerns;
● Are able to understand the unique risks associated with online safety which, amongst other things, includes an understanding of the expectations, applicable roles and responsibilities in relation to filtering and monitoring, and be confident that they have the relevant knowledge and up to date capability required to keep children safe whilst they are online.
● Can recognise the additional risks that children with SEN and disabilities (SEND) face online, for example, from online bullying, grooming and radicalisation and are confident they have the capability to support SEND children to stay safe online.
● Obtain access to resources and attend any relevant or refresher training courses at least every two years.
Raising Awareness
● Ensure parents/carers are made aware of the Child Safeguarding Policy which alerts them to the fact that referrals may be made.
● Ensure that appropriate staff have the information they need in relation to a child’s looked after legal status (whether they are looked after under voluntary arrangements with consent of parents or on an interim or full care order) and contact arrangements with birth parents or those with parental responsibility. They will also have information about the child’s care arrangements and the levels of authority delegated to the carer by the authority looking after him/her. The designated safeguarding lead will have details of the child’s social worker and the name of the virtual school head in the authority that looks after the child;
● Help promote education outcomes, sharing the information about the welfare, safeguarding and child protection issues that children, including children with a social worker, are experiencing, or have experienced, with teachers and school leadership staff;
All staff will:
● Fully comply with the policies and procedures;
● Attend appropriate training;
● Inform the Designated Safeguarding Lead of any concerns;
● Understand the process for making referrals to children’s social care and for statutory assessment under the Children Act;
● Record any potential safeguarding incidents appropriately.
3. IDENTIFYING CHILDREN AND YOUNG PEOPLE WHO MAY BE SUFFERING SIGNIFICANT HARM
Staff at Action2Change are well placed to observe any physical, emotional or behavioural signs which indicate that a child may be suffering significant harm. The relationships
between staff, students, parents and the public which foster respect, confidence and trust can lead to disclosures of abuse, and/or staff being alerted to concerns.
Safeguarding children is defined as:
● The actions we take to promote the welfare of children and protect them from harm is everyone’s responsibility. Everyone who comes into contact with children and families has a role to play.
Safeguarding and promoting the welfare of children is defined as:
● Protecting children from maltreatment.
● Preventing impairment of children’s mental or 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
Working Together to Safeguard Children 2018 (page 6).
Safeguarding is not just about protecting children from deliberate harm. It also includes:
● Pupils’ health and safety.
● The use of reasonable force.
● Meeting the needs of children with medical conditions.
● Providing first aid.
● Intimate care.
● Internet or e-safety.
Safeguarding can involve a range of potential issues such as:
● Bullying, including cyber bullying (by text message, on social networking sites, etc) and prejudice based bullying
● Child on child abuse
● Racist, homophobic or transphobic abuse
● Extremist behaviour i.e. radicalisation
● Child sexual exploitation
● Child criminal exploitation
● Sharing of nude and semi-nude images (sexting)
● Substance misuse.
● Upskirting (typically involves taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm).
● Issues which may be specific to a local area or population, for example gang activity and serious youth violence. Staff will need to recognise possible signs of a child being at risk of or involved in youth violence, such as lack of guilt and empathy, physical violence/aggression, positive attitude towards delinquency, previous criminal activity, unexplained money or new expensive possessions, unexplained physical injuries and regular truancy.
● Particular issues affecting children include domestic violence and abuse, female genital mutilations, honour based abuse, breast ironing and forced marriage.
4.1 Abuse, Neglect and Exploitation - Definitions
As in the Childrens’ Acts 1989 and 2004, a child is defined as anyone under the age of 18 years.
Harm means ill treatment or impairment of health and development, including, for example, impairment suffered from seeing or hearing the ill-treatment of another; development means physical, intellectual, emotional, social or behavioural development; health includes physical and mental health; ill-treatment includes sexual abuse and other forms of ill-treatment which are not physical.
Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Harm can include ill treatment that is not physical as well as the impact of witnessing 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. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults or by another child or children.
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.
Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, including prostitution, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (e.g. rape, buggery or oral sex) or non-penetrative acts. They may include non-contact activities, such as involving children in looking at or in the production of pornographic material or watching sexual activities or encouraging children to behave in sexually inappropriate ways.
Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to children that they are worthless or unloved, inadequate or valued only insofar as they meet the needs of another person. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond the child’s developmental capability, as well as overprotection and limitation of exploration and learning or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying, causing children frequently to feel frightened or in danger or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
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.
Whilst the above are the legal definitions, staff must also be aware of other forms of harm including forced marriage, radicalisation, honour based abuse and female genital mutilation. Early help means providing support as soon as a problem emerges at any point in a child’s life, from the foundation years through to the teenage years. In the first instance staff should discuss early help requirements with the designated safeguarding lead. Staff may be required to support other agencies and professionals in an early help assessment. Staff should be particularly alert to the potential need for early help for a child who:
● is disabled or has certain health conditions and has specific additional needs;
● have special educational needs (whether or not they have a statutory Education, Health and Care plan);
● has a mental health need;
● is a young carer;
● is showing signs of being drawn in to antisocial or criminal behaviour, including gang involvement and association with organised crime groups or county lines;
● is frequently missing/goes missing from care or home;
● is at risk of modern slavery, trafficking, sexual or criminal exploitation;
● is at risk of being radicalised or exploited;
● has a family member in prison, or is affected by parental offending;
● is in a family circumstance presenting challenges for the child, such as drug and alcohol misuse, adult mental health problems or domestic abuse;
● is misusing drugs or alcohol themselves;
● has returned home to their family from care;
● is at risk of so-called ‘honour’ based abuse such as Female Genital Mutilation or Forced Marriage;
● is a privately fostered child, or;
● is persistently absent from education including persistent absences for part of the school day.
A Child in Need is defined under the Children Act 1989 as a child who is unlikely to achieve or maintain a reasonable level of health or development, or whose health and development is likely to be significantly or further impaired, without the provision of services; or a child who is disabled. Local authorities are required to provide services for children in need for the purposes of safeguarding and promoting their welfare. Children in need may be assessed under Section 17 of the Children Act 1989.
Mental Health
All staff should also be aware that 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 observe children day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one.
Where children have suffered abuse and neglect, or other potentially traumatic adverse childhood experiences, this can have a lasting impact throughout childhood, adolescence and into adulthood. It is key that staff are aware of how these children’s experiences can impact on their mental health, behaviour and education.
If staff have a mental health concern about a child that is also a safeguarding concern, immediate action should be taken, following this policy and speaking to the designated safeguarding lead or a deputy.
4. TAKING ACTION TO ENSURE THAT CHILDREN ARE SAFE AT ACTION2CHANGE AND AT HOME
All staff, however, have a duty to recognise concerns and maintain an open mind. Accordingly all concerns regarding the welfare of students will be recorded and discussed with the designated safeguarding lead with responsibility for child protection (or another senior member of staff in the absence of the designated safeguarding lead) prior to any discussion with the mothering educational setting/parents/carers.
4.1 Staff will Immediately Report
● Any suspicion that a child is injured, marked or bruised in a way which is not readily attributable to the normal knocks or scrapes received in play.
● Any explanation given which appears inconsistent or suspicious.
● Any behaviours which give rise to suspicions that a child may have suffered harm (e.g. worrying drawings, writing or acts).
● Any concerns that a child may be suffering from inadequate care, ill treatment or emotional maltreatment.
● Any concerns that a child is presenting signs or symptoms of abuse of neglect. ● Any significant changes in a child’s presentation, including non-attendance.
● Any hint or disclosure of abuse from any person.
● Any concerns regarding person(s) who may pose a risk to children (e.g. living in a household with children present).
● Staff should be aware that children with SEND may face additional safeguarding challenges and should ensure that any potential barriers to them reporting concerns are removed.
● Staff in the course of their work in the profession, discovers that an act of Female
Genital Mutilation appears to have been carried out on a girl under the age of 18 they must report this personally to the Police, as well as informing their DSL;
● Any concerns that a child is at risk of, or involved in, serious violent crime.
● Concerns will be recorded on CPOMS.
4.2 Responding to Disclosure
Disclosures or information may be received from students, parents/carers, mothering educational providers or other members of the public. Action2Change recognises that those who disclose such information may do so with difficulty, having chosen carefully to whom they will speak. Accordingly, staff will handle disclosures with sensitivity.
Such information cannot remain confidential and staff will immediately communicate what they have been told to the designated safeguarding lead and make a record.
Principles
Staff will not investigate but will, wherever possible, elicit enough information to pass on to the designated safeguarding lead in order that they can make an informed decision of what to do next.
Staff will:
● Listen to and take seriously any disclosure or information that a child may be at risk of harm.
● Try to ensure that the person disclosing does not have to speak to another member of staff.
● Try to keep questions to a minimum and of an ‘open’ nature e.g. ‘can you tell me what happened?’
● Try not to show signs of shock, horror or surprise.
● Not express feelings or judgements regarding any person alleged to have harmed the child.
● Explain sensitively to the child that they have a responsibility to refer the information to the designated safeguarding lead.
● Reassure and support the child as far as possible.
● Explain that only those who ‘need to know’ will be told.
● Explain what will happen next and that the child will be involved as appropriate.
4.3 Action by the Designated Safeguarding Lead (or other senior person in their absence)
Following any information raising concern, the designated safeguarding lead will consider:
● Any urgent medical needs of the child.
● Discuss the matter with Mothering Educational setting.
● Discussing the matter with other agencies involved with the family.
● Consulting with appropriate persons e.g. Police, Children’s Social Care etc. ● The child’s wishes.
● Any suspicion of female genital mutilation of a girl under 18 years of age will be reported to the Police and Children’s Social Care.
Then decide:
● Wherever possible, to talk to parents/carers, unless to do so may place a child at risk of significant harm, impede any Police investigation and/or place the member of staff or others at risk.
● Whether to make a child protection referral to Children’s Social Care or the Police because a child is suffering or is likely to suffer significant harm and if this needs to be undertaken immediately.
OR
● Not to make a referral at this stage.
● If further monitoring is necessary.
● If early help is appropriate the designated safeguarding lead should support the staff member in liaising with other agencies and setting up an inter-agency assessment as appropriate and then ensure the case is kept under constant review and consideration given to a referral to children’s social care if the child’s situation doesn’t appear to be improving or is getting worse.
● If it would be appropriate to undertake a Common Assessment and/or make a referral for other services.
Referrals should ideally be made by a designated safeguarding lead, however in their absence, anyone can make a referral, and their absence must not delay the appropriate action being taken. Where referrals are not made by the designated safeguarding lead the designated safeguarding lead should be informed, as soon as possible, that a referral has been made.
All information and actions taken, including the reasons for any decisions made, will be fully documented.
4.4 Action following a child protection referral
The designated safeguarding lead or other appropriate member of staff will:
● Make regular contact with Children’s Social Services
● Contribute to the Strategy Discussion and Initial Assessment
● Share all reports with mothering educational setting prior to the meetings
● Where in disagreement with a decision made e.g. not to apply Child Protection Procedures or not to convene a child Protection Conference, discuss this with the Education Safeguarding Manager.
4.5 Recording and Monitoring
● Information about the child: name, address, D.O.B, those with parental responsibility, primary carers, emergency contacts, if a child has been subject to a Child Protection Plan
● Any disclosures/accounts from child or others, including parents/carers (and keep original notes)
● All concerns, discussions, decisions, actions taken (dated, timed and signed) and arrangements for monitoring/reviewing
All records should be objective and include:
● Statements, facts and observable things (what was seen/heard)
● Diagram indicating position, size, colour of any injuries (photographs if appropriate) ● Words child uses (not translated into ‘proper’ words)
● Non-verbal behaviours
Action2Change will monitor:
● Injuries/marks
● Attendance
● Changes e.g. mood/academic functioning
● Relationships
● Language
● Behaviour
● Demeanour and appearance
● Statements and comments
● Medicals
● Stories, ‘news’, drawings
● Response to PE/sport
● Family circumstances
● Parental behaviours/care of child
4.6 Allegations regarding Person(s) working at Action2Change (including volunteers)
Where an allegation is made against any person working at Action2Change, including volunteers, that he or she has:
● Behaved in a way that has harmed a child a may have harmed a child;
● Possibly committed a criminal offence against or related to a child;
● Has behaved, or may have behaved, towards a child or children in a way that indicated s/he is unsuitable to work with children; or
● Has behaved, or may have behaved, in a way that indicates they may not be suitable to work with children. This may include an incident outside of school which did not involve children but could have an impact on their suitability to work with children e.g. an incident of domestic abuse.
Action2Change will follow the correct procedure for Dealing with Allegations against a Person who works with Children.
Detailed records will be made to include decisions, action taken and the reasons for these. All records will be retained securely as mentioned above.
Whilst we acknowledge that such allegations (as all others) may be false, malicious or misplaced, we also acknowledge that they may be founded. It is, therefore, essential that all allegations are investigated properly and in line with agreed procedures.
Initial Action
● The person who has received the allegation or witnesses an event will immediately inform the LSO or Deputy and make a record
● Steps will be made where necessary, to secure the immediate safety of children and any urgent medical needs
● The member of staff will not be approached at this stage unless it is necessary to address the immediate safety of children
● The LSO may need to clarify any information regarding the allegation, however, no person will be interviewed at this stage
● Local Authority Designated Officer (LADO) will be contacted in order to determine if it is appropriate for the allegation to be dealt with by Action2Change or if there needs to be a referral to Social services and/or Police for investigation
● Consideration will be given throughout to the support and information needs of students, parents and staff of Action2Change and mothering setting.
Where a staff member feels unable to raise an issue with their designated safeguarding lead or other senior colleague, or feels that their genuine concerns are not being addressed, they should refer to the Whistleblowing Procedure in Child protection policy.
Required further investigations, including suspensions, and any relevant referrals will be managed within the Staff Disciplinary Procedure.
‘Low Level’ Concerns
The term ‘low-level’ concern does not mean that it is insignificant, it means that the behaviour towards a child does not meet the threshold set out in the bullet points above. A low-level concern is any concern, no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’, that an adult working in or on behalf of the school 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 LADO (the LADO should be consulted if you are unsure whether the concerns have met the threshold for referral)
Examples of such behaviour could include, but are not limited to:
● being over 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; or, ● using inappropriate sexualised, intimidating or offensive language
As with concerns that meet the ‘harm’ threshold’ low level concerns must be reported as follows:
● to the LSO;
● to the director or where allegations involve LSO/Director report to DLSO or LADO
As with all allegations, lessons should still be learned by the school as a result of a low level concern.
4.7 Children Potentially at Greater Risk of Harm
Looked After Children and Previously Looked After Children
https://www.gov.uk/government/publications/promoting-the-education-of-looked-after-children https://www.gov.uk/government/publications/designated-teacher-for-looked-after-children
Children who Need a Social Worker (Child in Need and Child Protection Plans)
Children Requiring Mental Health Support
Care leavers
Children with special educational needs and disabilities.
4.8 Child on Child Abuse
Child on child abuse can take many forms, such as:
● bullying (including cyberbullying, prejudice based and discriminatory bullying); ● abuse in intimate personal relationships between children (sometimes known as ‘teenage relationship abuse;);
● physical abuse which can include 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 - includes rape, assault by penetration or sexual assault (this may include an online element which facilitates, threatens and/or encourages sexual violence);
● sexual harassment - this can be defined as ‘unwanted conduct of a sexual nature’ that can occur online or offline. Child on child sexual harassment is likely to; violate a child’s dignity, and/or make them feel intimidated, degraded or humiliated and/or create a hostile, offensive or sexualised environment.
● upskirting, which typically involves taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm;
● sexting (also known as youth produced sexual imagery) - is when someone shares sexual, naked or semi-naked images or videos of themselves or other or sends sexually explicit messages via mobiles, tables, smartphones or any device that allows you to share media and messages.
● initiation/hazing type violence and rituals.
● harmful sexual behaviour (HSB) - is an umbrella term for behaviour that is inappropriate, problematic, abusive and violent which is developmentally inappropriate and may cause developmental damage. It can occur online and/or offline.
Whilst we recognise the gendered nature of child on child abuse (i.e. that it is more likely that girls will be victims and boys perpetrators), all child on child abuse or harm will always be taken seriously and acted upon, under the appropriate policy e.g. safeguarding, behaviour, and not dismissed as ‘banter’ or ‘part of growing up’. These issues will be part of PSHE lessons and discussions.
We will;
● Deal with any reports or disclosures in line with this policy and refer to the DSL (or Deputy).
● Educate children about positive, responsible and safe relationships and the unequivocal facts about consent, via PSHE, RSHE and the wider curriculum.
● Educate children about the positive, responsible and safe use of mobile technology and social media, including a ban on the use of mobile phones on school grounds to ensure that we offer a safe and secure environment.
● Ensure that children know how to report if they witness or experience such abuse and understand that any form of child -on-child abuse is unacceptable;
● Conduct a risk assessment to determine the specific risks to which the children at the school are, or may be, exposed, assessing, addressing and monitoring those risks;
● never tolerate or normalise this behaviour and are very clear is not an inevitable part of growing up;
● not tolerate or dismiss sexual violence or sexual harassment as “banter”, “part of growing up”, “just having a laugh” or “boys being boys”;
● challenge behaviour (potentially criminal in nature), such as grabbing bottoms, breasts and genitalia and flicking bras and lifting up skirts.
● understand that all of the above can be driven by wider societal factors beyond the academy, such as everyday sexist stereotypes and everyday sexist language. This is why a whole academy approach is important.
We recognise children with Special Educational Needs and Disabilities (SEND) are three times more likely to be abused than their peers. Additional barriers can sometimes exist when recognising abuse in SEND children. These can include:
● assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the child’s disability without further exploration;
● the potential for children with SEND being disproportionately impacted by behaviours such as bullying and harassment, without outwardly showing any signs; and
● communication barriers and difficulties overcoming these barriers.
● Therefore any reports of abuse involving children with SEND will involve liaison with the Designated Safeguarding Lead (or deputy) and the SENCO
Children who are lesbian, gay, bisexual, transexual or gender questioning (LGBTQ) can be targeted by their peers. In some cases, a child who is perceived by their peers to be LGBTQ (whether they are or not) can be just as vulnerable as children who identify as LGBTQ. Our schools will be a safe space for children to speak to, or share concerns, with staff.
Appropriate Management
Any response should:
● include a thorough investigation of the concern(s) or allegation(s), and the wider context in which it/they may have occurred: depending on the nature and seriousness of the alleged incident(s), it may be appropriate for the police and/or children’s social care to carry out this investigation
● treat all children involved as being at potential risk; while the alleged perpetrator may pose a significant risk of harm to other children, s/he may also have considerable unmet needs and be at risk of harm themselves.
Action2Change will ensure that a safeguarding response is in place for victims and the alleged perpetrator, and additional sanctioning work may be required for the latter. Action2Change should consider:
● that the abuse may indicate wider safeguarding concerns for any of the children involved, and consider and address the effect of wider sociocultural contexts – such as the child’s/ children’s peer group,; family; the educational environment; their experience of crime and victimisation in the local community; and the child/children’s online presence. Consider what changes may need to be made to these contexts to address the child/ children’s needs and to mitigate risk;
● the potential complexity of child-on-child abuse and of children ́s experiences, and consider the interplay between power, choice and consent. While children may appear to be making choices, if those choices are limited they are not consenting;
● the views of the child/children affected. Unless it is considered unsafe to do so (for example, where a referral needs to be made immediately), the DSL should discuss the proposed action with the child/ children and their parents, and obtain consent to any referral before it is made.
Child-on-child abuse that involves sexual assault and sexual violence must always result in a multi-agency response. As well as supporting and protecting the victim, professionals need to consider whether the alleged perpetrator could be a victim of abuse too. Children who develop harmful sexual behaviour have often experienced abuse and neglect themselves. Children affected by sexual assault and sexual violence must receive the help they need. A typical response will involve:
● Children’s social care
● The police
● Specialist services that support children who demonstrate harmful sexual behaviour ● The family
● Any other professionals who know or who have had contact with the child.
Mother educational setting
If the children are in the same class, Action2Change should separate them while the concerns are being investigated and discuss placement with the Mothering educational setting. In situations of alleged rape and assault by penetration, the alleged perpetrator must always be removed from classes they share with the victim.
Action2Change will always carry out a safety plan in respect of:
● any child who is alleged to have behaved in a way that is considered to be abusive or violent;
● any child who has reportedly been abused or affected by the alleged abusive or violent behaviour by another child, or any child who may be at risk due to the alleged abusive or violent behaviour by another child as deemed appropriate by the DSL;
Where it is alleged that a child has behaved in a way that is considered to be inappropriate or problematic (as opposed to abusive or violent), the DSL will use their professional judgement – based on the particular concern and/or allegation raised, and the needs and circumstances of the individual child/children in question – to determine whether it would be appropriate to contact children’s social care, and to carry out a safety plan.
Where other children have been identified as witnesses to alleged abuse or violence, consideration should also be given by the DSL to whether there might be any risks to those children, and whether a safety plan would be appropriate in relation to any risks presenting to them.
Where a matter is not of interest to the police and/or children’s social care, the Action2Change and mothering educational setting may still need to consider what is the most appropriate action to take to ensure positive behaviour management. Disciplinary action may sometimes be appropriate, including to:
● ensure that the child/children take(s) responsibility for and realise(s) the seriousness of their behaviour;
● demonstrate to the child/children and others that child-on-child abuse can never be tolerated; and
● ensure the safety and wellbeing of other children.
Preventing bullying - GOV.UK (www.gov.uk)
Sexual and sexist bullying (anti-bullyingalliance.org.uk)
Cyberbullying Guidance | Childnet
4.9 Physical Intervention and Use of Reasonable Force
All staff are encouraged to use de-escalation techniques and creative alternative strategies that are specific to the child. Restraint will only be used as a last resort and all incidents of this are reviewed, recorded and monitored. Reasonable force will be used in accordance with our Restraints Policy. Safeguarding and welfare concerns will be taken into account when restraint is used on SEND students.
4.10 Domestic Abuse
The definition of domestic violence and abuse is: any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. The abuse can encompass, but is not limited to: psychological; physical; sexual; financial; and emotional.
All children can witness and be adversely affected by domestic abuse in the context of their home life where domestic abuse occurs between family members. Exposure to domestic abuse and/or violence can have a serious, long lasting emotional and psychological impact on children. In some cases, a child may blame themselves for the abuse or may have had to leave the family home as a result.
4.11 Children and the Court System
Children are sometimes required to give evidence in criminal courts, either for crimes committed against them or for crimes they have witnessed. There are two age appropriate guides to support children 5-11-year olds and 12-17 year olds and support will be offered in line with these.
SAFEGUARDING INCIDENT RECORDING SHEET
Full name of Young Person
Date of Birth and Address
Year
Date of Incident
Time of Incident
Location
Observed by (full name and position)
Detailed Observation
Concerns
Have you spoken to the
young person?
What was said? (Please
record in the young person’s own words)
Have you spoken to the the mothering educational setting/
parents/carers?
What was said? (include full name of parent/carer spoken to)
Referred to
Your Name
Your Position
Signed
Date and Time of Record
NOTIFICATION OF SUSPECTED/ADMITTED/KNOWN ABUSE OF CHILD(REN) TO SOCIAL SERVICES
This form should be completed by the designated safeguarding lead with responsibility for child protection on the basis of information readily available and should not be delayed on the basis of incomplete information.
Information about the Child
Child(ren)’s surname
Child(ren)’s forename(s)
Child(ren)’s date of birth
Other name(s) by which the child(ren) may be known
Present location
Home address of child
Information about Parent/Guardian
Parent/Guardian’s surname
Parent/Guardian’s forenames
Address
Tel No
Does this person have parental responsibility
If not, insert the names and addresses of those with parental responsibility
Surname/forenames, date of birth or age of any siblings/co-resident children
Professional agencies known to be involved with the family:
(contact name, address and tel no)
Reason for Referral
Reason for referral:
Action already taken
Referred in writing/by telephone to:
On what date:
Parents advised of referral?
Child/young person advised of
referral?
Name of Designated Person
Signature
Date
Appendices
1.Prevent Duty and Radicalisation
Children are vulnerable to extremist ideology and radicalisation. Similar to protecting children from other forms of harms and abuse, protecting children from this risk is part of a schools’ safeguarding responsibility.
● Extremism is the vocal or active opposition to our fundamental values, including democracy, the rule of law, individual liberty and the mutual respect and tolerance of different faiths and beliefs. This also includes calling for the death of members of the armed forces.
● Radicalisation refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.
● 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 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.
There are now duties imposed on schools and other agencies in relation to the DfE guidance The Prevent Duty . The prevent duty is now incorporated into our existing policies.
Further advice in relation to this is within Keeping Children Safe In Education in relation to:
● Risk assessment.
● Working in partnership.
● Staff training.
● It policies.
● Building children’s resilience to radicalisation.
Where we are concerned about individual children we will follow the referral pathway defined.
The essence of our policy, however, is that we seek to protect children and young people from being drawn into, and against, the messages of all violent extremism. This includes and is not restricted to ISIL, AQ, Far Right, Neo Nazi, White Supremacist ideology, Irish Nationalist and Loyalist paramilitary groups, and extremist Animal Rights movements.
The use of social media and the internet as tools to radicalise young people cannot be underestimated. We recognise that those that seek to recruit young people to follow extremist ideology often target those who are already vulnerable in some way and that exposure to extreme views can make young people vulnerable to further manipulation and exploitation.
At Action2Change we are clear that we have a duty to safeguard young people from such dangers and we will actively promote resilience to such risks through our Relationships Education (primary) and
Relationships and Sex Education (secondary) curriculum and anti-bullying policy.
Child Criminal and/or Sexual Exploitation (CSE) Policy
The sexual exploitation of children is defined by the DfE as:
‘Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.’
We recognise that child criminal and/or sexual exploitation is a high profile issue both nationally and locally. It is important to note that the experience of girls who are criminally exploited can be very different to that of boys. The indicators may not be the same, however professionals should be aware that girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation.
Child Criminal Exploitation
Child Criminal Exploitation (CCE) CCE is where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child into any criminal activity:
(a) in exchange for something the victim needs or wants, and/or
(b) for the financial or other advantage of the perpetrator or facilitator and/or (c) through violence or the threat of violence.
The victim may have been criminally exploited even if the activity appears consensual. CCE does not always involve physical contact; it can also occur through the use of technology.
CCE can include children being forced to work in cannabis factories, being coerced into moving drugs or money across the country (county lines), forced to shoplift or pickpocket, or to threaten other young people.
Some of the following can be indicators of CCE:
● children who appear with unexplained gifts or new possessions;
● children who associate with other young people involved in exploitation;
● children who suffer from changes in emotional well-being;
● children who misuse drugs and alcohol;
● children who go missing for periods of time or regularly come home late; and
● children who regularly miss school or education or do not take part in education.
2.Child Sexual Exploitation
Child sexual exploitation can happen in a number of ways to both boys and girls, for example it can happen in the virtual world through various social media and this can still cause significant harm. It can happen though inappropriate relationships such as older boy/girlfriends or through parties, gangs or organised abuse. Some children will be particularly vulnerable to being exploited, for example if they have had a chaotic upbringing or if they are in care or go missing, involved in gangs or being bullied. We recognise however that any child can become a target for exploitation, particularly where the internet and social media are involved. This is because the normal life events that go with being a child or teenager in today’s age can be a challenge and make them susceptible to being groomed and exploited.
Some of the following signs may be indicators of CSE:
o Children who appear with unexplained gifts or new possessions;
o Children who associate with other young people involved in exploitation;
o Children who have older boyfriends or girlfriends;
o Children who suffer from sexually transmitted infections or become pregnant;
o Children who suffer from changes in emotional well-being;
o Children who misuse drugs and alcohol;
o Children who go missing for periods of time or regularly come home late; and
o Children who regularly miss school or education or do not take part in education.
At Action2Change we recognise that prevention is the best position with regard to CCE/CSE. We seek to support children to develop confidence and build resilience. We will endeavour to support their age appropriate knowledge and raise awareness and understanding of what CCE/CSE is, to understand the risks of CCE/CSE and to spot the warning signs for themselves and also their friends and peers and by doing so, keep safe.
What marks out exploitation is an imbalance of power within the relationship. The perpetrator always holds some kind of power over the victim, increasing the dependence of the victim to an exploitative relationship.
Technology can play a part in exploitation, for example, through its use to record abuse and share it with other like-minded individuals or as a medium to access children and young people in order to groom them. A common factor in all cases is the lack of free economic or moral choice.
Sexual exploitation has strong links with other forms of ‘crime’, for example, domestic violence, online and offline grooming, the distribution of abusive images of children and child trafficking.
Many adults involved in prostitution describe difficult childhood experiences that include domestic violence, neglect, emotional abuse, disrupted schooling and low educational attainment.
The perpetrators of sexual exploitation are often well organised and use sophisticated tactics. They are known to target areas where children and young people gather without much adult supervision, e.g. parks or shopping centres or sites on the internet.
Preventing sexual and criminal exploitation
The effects of sexual exploitation are harmful and far reaching. Prevention means that the risk that children and young people will become victims of sexual exploitation is reduced by:
● Reducing their vulnerability by educating young people, whilst acknowledging that all young people are vulnerable;
● Improving their resilience and enabling the confidence to report concerns; ● Disrupting and preventing the activities of perpetrators;
● Reducing tolerance of exploitative behaviour.
If prevention is not possible we aim to identify children who are at risk of, or being exploited very early. Early intervention is key to effectively working with the child to prevent or reduce the level of risk. Once they have been groomed some children will find it difficult to withdraw from their abusers and we need to contribute to helping to protect them. Some children feel that they are in a relationship with these people. We commit to working with our inter-agency partners to safeguard and protect children.
Much of this work will be through our programmes of personal, social and health education (PSHE) or through our Relationships and Sex Education (RSE) work.
An important part of educating our children is focussing on what is a healthy relationship and issues of consent. This will also target potential abusers at an early age with the intention of helping to shape their attitudes to others.
We want to have a culture where the welfare of children is actively promoted and staff and students are vigilant. As part of this children will feel listened to and safe.
Social Media
The use of media and technology is now a common feature of the social activity of most young people. Smart-phones, laptops and tablets can all be used to exchange information verbally, by text, e-mail and most commonly through mechanisms such as messengers, Facebook, Instagram, WhatsApp etc. The use of electronic media presents considerable opportunities to abusers and provides powerful tools with which to groom and control victims. Grooming is defined as developing the trust of a young person or his or her family in order to engage in illegal sexual conduct.
It may include:
● Causing a child to watch a sexual act, e.g. sending sexually themed adult content or images and videos featuring child sexual abuse to a young person. This could be via text messaging; ● Inciting a child to perform a sexual act, e.g. by threatening to show sexual images of a child to their peers or parents/carers (e.g. self-produced material or even a pseudo-image of the child);
● Suspicious online contact with a child, e.g. asking a young user sexual questions; ● Asking a child to meet in person; befriending a child and gaining their trust, etc. ● It is also known that abusers and exploiters will sometimes pose as teenagers to obtain
sexually explicit images via webcams or making arrangements to meet the victim. Often these individuals live some considerable distance from the victim and initially make contact through legitimate sites used by young people.
Working with the victim or perpetrator
When you are working with an incident or with a student that has been the victim or perpetrator of CSE you should consider the following areas:
● A child-centred approach. Action should be focussed on the child’s needs, including consideration of children with particular needs or sensitivities, and the fact that children do not always acknowledge what may be an exploitative or abusive situation;
● A proactive approach. This should be focussed on prevention, early identification and intervention as well as disrupting activity and prosecuting perpetrators;
● Parenting, family life, and services. Taking account of family circumstances in deciding how best to safeguard and promote the welfare of children and young people, this should be done in coordination with local authority support;
● The rights of children and young people. Children and young people are entitled to be safeguarded from sexual exploitation just as schools and agencies have duties in respect of safeguarding and promoting welfare;
● Responsibility for criminal acts. Sexual exploitation of children and young people should not be regarded as criminal behaviour on the part of the child or young person, but as child sexual abuse. The responsibility for the sexual exploitation of children lies with the abuser and the focus of police investigations should be on those who coerce, exploit and abuse children and young people. If there is a criminal investigation the academy will encourage the victim to seek support from nominated people in school. Students either involved or who have knowledge of an investigation should not discuss this in the academy as it is an ongoing investigation;
● An integrated approach. The working together to safeguard children document sets out a tiered approach to safeguarding: universal, targeted and responsive. Within this, sexual exploitation requires a three-pronged approach tackling prevention, protection and prosecution. The academy will be involved in the first two elements and will support the student(s) involved and work with agencies to meet the three-pronged approach.
County lines
County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs (primarily crack cocaine and heroin) into one or more areas within the UK, using dedicated mobile phone lines or other form of “deal line”.
Exploitation is an integral part of the county lines offending model with children and vulnerable adults exploited to move and store drugs and money. Offenders will often use coercion, intimidation, violence (including sexual violence) and weapons to ensure compliance of victims. Children can be targeted and recruited into county lines in a number of locations including schools, further and higher educational institutions, pupil referral units, special educational needs schools, children’s homes and care homes. Children are often recruited to move drugs and money between locations and are known to be exposed to techniques such as ‘plugging’, where drugs are concealed internally to avoid detection. Children can easily become trapped by this type of exploitation as county lines gangs create drug debts and can threaten serious violence and kidnap towards victims (and their families) if they attempt to leave the county lines network.
One of the ways of identifying potential involvement in county lines are missing episodes (both from home and school), when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism will be considered. If a child is suspected to be at risk of or involved in county lines, a safeguarding referral will be undertaken by the DSL/DDSL alongside consideration of availability of local services/third sector providers who offer support to victims of county lines exploitation.
3.So-called ‘Honour’ Based Abuse
So-called ‘honour-based’ abuse (HBA) encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation (FGM), forced marriage, and practices such as breast ironing. All forms of so-called HBV are abuse (regardless of the motivation) and should be handled and escalated as such. If in any doubts you should speak to the designated safeguarding lead.
If staff have a concern regarding a child that might be at risk of HBV they should follow the normal reporting procedures protocols for multi-agency liaison with police and children’s social care.
Female Genital Mutilation (FGM)
FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long-lasting harmful consequences. Where FGM has taken place there is now a mandatory reporting duty placed on staff.
Section 5B of the Female Genital Mutilation Act 2003 (as inserted by section 74 of the Serious Crime Act 2015) places a statutory duty upon staff along with regulated health and social care professionals in England and Wales, to report to the police where they discover (either through disclosure by the victim or visual evidence) that FGM appears to have been carried out on a girl under 18. Those failing to report such cases will face disciplinary sanctions. It will be rare for teachers to see visual evidence, and they should not be examining students, but the same definition of what is meant by “to discover that an act of FGM appears to have been carried out” is used for all professionals to whom this mandatory reporting duty applies.
Staff MUST personally report to the police cases where they discover that an act of FGM appears to have been carried out. Unless the teacher has a good reason not to, they should also still discuss any such case with the academy’s designated safeguarding lead and involve children’s social care as appropriate. The duty does not apply in relation to at risk or suspected cases (i.e. where the teacher does not discover that an act of FGM appears to have been carried out, either through disclosure by the victim or visual evidence) or in cases where the woman is 18 or over. In these cases, staff should follow local safeguarding procedures.
Forced Marriage
Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one 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. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example).
Nevertheless, some communities use religion and culture as a way to coerce a person into marriage.
Breast-ironing
Breast Ironing is practised in some African countries, notably Cameroon. Girls aged between 9 and 15 have hot pestles, stones or other implements rubbed on their developing breast to stop them growing further. In the vast majority of cases breast ironing is carried out by mothers or grandmothers and the men in the family are unaware.The Crown Prosecution Service (CPS) has updated the So-Called Honour-Based Abuse and Forced Marriage guidance to recognise breast-ironing as child abuse. CPS legal guidance makes clear to police and prosecutors that breast-ironing is a crime even if it is said that the victim has consented.
Further information is available in the following documents: Multi-Agency Statutory Guidance on Female Genital Mutilation and Multi-Agency Statutory Guidance: Handling cases of forced marriage.
4.Children Absent from Education
All children, regardless of their circumstances, are entitled to a full time education which is suitable to their age, ability, aptitude and any special educational needs they may have. Local authorities have a duty to establish, as far as it is possible to do so, the identity of children of compulsory school age who are unexplainable and/or persistent absent from education in their area.
The attendance manager must inform the mothering educational setting of students attendance and any patterns in absences from provision.
5.Sexting Policy
Definition of ‘sexting’
There are a number of definitions of sexting but for the purpose of this advice sexting is simply defined as images or videos generated:
by children under the age of 18, or
of children under the age of 18 that are of a sexual nature or are indecent.
These images are shared between young people and/or adults via a mobile phone, handheld device or website with people they may not even know. There are many different types of sexting and it is likely that no two cases will be the same. It is necessary to carefully consider each case on its own merit. It is important to apply a consistent approach when dealing with an incident to help protect yourself, the school and the child. The range of contributory factors in each case also needs to be considered in order to determine an appropriate and proportionate response. All staff should be familiar with this policy.
Dealing with Incidents of Sexting
STEP 1: Disclosure by a child
Sexting disclosures should follow normal safeguarding practices. A child is likely to be very distressed, especially if the image has been circulated widely and if they don’t know who has shared it, seen it or where it has ended up. They will need support during the disclosure and after the event. They may even need immediate protection or a referral to Social Care.
The following questions will help decide upon the best course of action:
● Is the child disclosing about themselves receiving an image, sending an image or sharing an image?
● What sort of image is it?
● Is it potentially illegal or is it inappropriate?
● Are the Safeguarding Policy and practices being followed? For example, is the Designated Safeguarding Lead (DSL) on hand and is their advice and support available?
● How widely has the image been shared and is the device in their possession? ● Is it an academy device or a personal device?
● Does the child need immediate support and/or protection?
● Are there other children and/or young people involved?
● Do they know where the image has ended up?
The situation will need to be handled very sensitively to ensure the school Safeguarding and On-line Safety policies and practices are adhered to.
STEP 2: Searching a device
It is highly likely that the image will have been created and potentially shared through mobile devices. It may be that the image is not on one single device: it may be on a website or on a multitude of devices; it may be on either a school-owned or personal device. It is important to establish the location of the image but be aware that this may be distressing for the young person involved, so be conscious of the support they may need.
The revised Education Act 2011 brought to bear significant new powers and freedoms for teachers and schools. Essentially, the Act gives schools and/or teachers the power to seize and search an electronic device if they think there is good reason for doing so. A device can be examined, confiscated and securely stored if there is reason to believe it contains indecent images or extreme pornography.
● When searching a mobile device, the following conditions should apply:
● The search is conducted by the Management or a person authorised by them
● The DSL or a deputy is present
● The search is conducted by a member of the same sex
● If any illegal images of a child are found, you should consider whether to inform the police. Any conduct involving, or possibly involving, the knowledge or participation of adults should always be referred to the police. If an “experimental” incident is not referred to the police, the reasons for this should be recorded in writing. Always put the child first.
● Do not search the device if this will cause additional stress to the child/person whose image has been distributed.
Never:
● Search a mobile device even in response to an allegation or disclosure if this is likely to cause additional stress to the child UNLESS there is clear evidence to suggest that there is an immediate problem
● Print out any material for evidence
● Move any material from one storage device to another
● View the image unless there is a clear reason to do so (see above) Send, share, copy or save the image anywhere
● Allow children to do any of the above
Always:
● Inform the Designated Safeguarding Lead
● Record the incident
● Act in accordance with the Safeguarding Policy and procedures
● Inform relevant colleagues/senior management team about the alleged incident before searching a device
● Confiscate and secure the device
When to refer to the Police
● At any point in the process if there is a concern a young person has been harmed or is at risk of harm a referral should be made to children’s social care and/or the police immediately.
● If there is an indecent image of a child on a website or a social networking site, then you should report the image to the Police and the site hosting it.
● The sharing of sexual imagery of people under 18 by adults as this constitutes child sexual abuse and should always be reported to the police.
● Any incidents with aggravating factors, for example, a young person sharing someone else’s imagery without consent and with malicious intent, should generally be referred to police and/or children’s social care.
● Young people under the age of 18 sharing adult pornography or exchanging sexual texts which don’t contain imagery.
6.Online safety
The use of technology has become a significant component of many safeguarding issues. Child sexual exploitation; radicalisation; sexual predation: technology often provides the platform that facilitates harm.
Action2Change has in place an E Safety Policy that allows the academies to protect and educate the whole school community in their use of technology and establishes mechanisms to identify, intervene in, and escalate any incident where appropriate. There is also a strict no mobile phone policy in place.
The breadth of issues classified within online safety is considerable, but can be categorised into three areas of risk:
content: being exposed to illegal, inappropriate or harmful material; for example pornography, fake news, racist or radical and extremist views;
contact: being subjected to harmful online interaction with other users; for example commercial advertising as well as adults posing as children or young adults; and
conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example making, sending and receiving explicit images, or online bullying.