SAFEGUARDING POLICY AND PROCEDURE

Posted by UCAN / In Public Policies / October 26th, 2023

PROMOTION OF THE POLICY

The policy is promoted through staff induction, the staff handbook, apprentice induction, e-portfolio work, newsletters to apprentices and employers, training sessions, and the apprentice handbook.

1. STAFF TRAINING

Safeguarding awareness and training are mandatory for all staff at induction.  Information is provided to all apprentices at enrolment in order to raise awareness of Safeguarding and the contents of this policy. Regular CPD keeps all staff updated about any relevant Safeguarding developments and National Policy changes.

2. INTRODUCTION

This Policy describes the support and protection procedures UCAN provides for all our apprentices and employees, including those of specified groups who may be particularly “at risk”, notably:

• Children - a “Child” is defined as all young people under the age of 18, or in the case of those with learning difficulties under 25 years, in accordance with the 1989 Children Act and the Children Act 2004.

• Keeping Children Safe In Education applies to providers of post-16 education as set out in the Education and Training (Welfare of Children) Act 2021. This has been reviewed and the updated legislation came into effect in September 2022.

• Adults at Risk – an “Adult at Risk” is defined as, “a person who is, or maybe in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation”.

• We hold as one of our highest priorities the health, safety and welfare of all those involved in courses or activities we deliver, and accountability rests with our Governance Board. We fully deliver on our obligations under relevant legislation, regulations and guidance particularly as stated in the Education Act 2002.

• We recognise our obligations to safeguard all apprentices, staff, volunteers and contractors. The Board has a duty to ensure that all employees fulfil their responsibilities, not to judge or assume but to immediately report any concerns discovered or suspected no matter how trivial they may seem.

• Our Safer Recruitment Policy and Procedures make specific reference to the role and responsibilities of all employees in upholding the principles and practice of effective safeguarding. All recruitment is subject to appropriate and satisfactory DBS checks.

3. HOW DO WE PREVENT THE ABUSE OF APPRENTICES?

Through our apprentice induction process, we advise all apprentices about the standards of behaviour and conduct they can expect from employees and volunteers and what to do if they experience or suspect abuse or sexual harassment or violence. We advise all parents/guardians/carers of apprentices, children, and adults at risk of the existence of our Safeguarding Procedures; these procedures include the potential for concerns to be referred to the relevant support or investigative agencies in the interests of the child or adult at risk.

Our organisational structure incorporates fully trained safeguarding officers (DSOs) and fully trained mental health officers (MHO)  allocated to each of the regions in which we are represented, and they work as a team. Mental health refers to emotional, psychological and social wellbeing. Whilst not all mental health issues are safeguarding risks, it is important to raise any concerns about a young person’s mental health so that appropriate intervention can be put in place.

The team is led by  Designated Safeguarding Lead. All staff have an awareness of Adverse childhood experiences (also known as ACEs) and where appropriate use ‘trauma-informed practice’ which allows staff to explore how adverse life experiences affect behaviour and the impact this can have on classroom behaviour and educational settings as a whole.

Case reviews are held weekly/fortnightly/monthly as required, to review all live Safeguarding and Pastoral reports, where all actions are discussed across all the DSOs and our MHO and actions agreed upon.

Our Safeguarding Team works with appropriate local agencies, and in particular, the Local Authority Designated Officer (LADO) and Local Safeguarding Children’s Boards (LSCBs), to ensure that children and adults are at risk, and other apprentices and employees, are safeguarded through the effective operation of our procedures.

Our Safeguarding Team:

• Implements regular training/CPD for all staff in Safeguarding, Prevent and Mental Health.

• Develops resources, assignments and events within our training programmes to develop apprentice awareness of these issues.

• Monitors implementation and supervises all cases.

• Maintains and frequently reviews the policy procedures for approval by the Governance Board.

• Maintains alignment of this policy with other related policies such as Bullying and Sexual Harassment.

• Ensures that any subcontractor or partner for the delivery of services to apprentices has appropriate Safeguarding, Prevent, Mental Health, and Health and Safety policies in place.

• Undertakes any improvements related to our processes identified in our QIP.

• Provides an annual report for the Governance Board.

Each regional DSO:

• Deals with issues raised locally in their area.

• Ensures that all Prevent procedures are followed.

• Maintains confidentiality of records.

• Works with our MHO to provide appropriate support to apprentices with difficulties and signpost them to relevant support agencies.

• Works with other agencies within the framework of LA prevent coordinators.

• Maintain the currency of their training.

• Contributes to staff Prevent training in their region.

SPECIFIC RESPONSIBILITIES

We aim to ensure that staff roles and responsibilities in relation to Safeguarding duties are clear and transparent.

THE BOARD has responsibility for the safeguarding policy and framework, facilitating regular meetings of the Designated Safeguarding Officers (DSOs). In cases where an incident involves a member of staff, the Board will involve the HR team in the investigative process. The Board will commission and collate a range of risk assessments in relation to Safeguarding.

THE QUALITY, ASSESSMENT and HR teams are involved in the application and critical discussion of Safeguarding and mental health issues in the classroom for apprentices, and in training for staff.

Below are the standards of behaviour required of EMPLOYEES in order to fulfil their roles and duty of care within the organisation. These guidelines also apply to VOLUNTEERS who work in an unpaid capacity on UCAN premises.

Staff must:

• Implement the Safeguarding Policy and Procedures at all times.

• Always use our ‘Raise a Concern’ online reporting system.

• Treat all apprentices and staff with respect.

• Be an example of the good conduct you wish others to follow.

• Ensure that there is more than one adult present during activities with children and young people or at least that you are within sight or hearing of others. Where this is not possible, a risk assessment should be agreed upon and signed by a DSO.

• Respect a young person’s right to personal privacy and encourage young people and vulnerable adults to feel comfortable and caring enough to point out attitudes or behaviour they do not like.

• Remember that someone else might misinterpret your actions, no matter how well-intentioned you are.

• Be aware that any physical contact with a child, young person or vulnerable adult may be misinterpreted.

• Recognise that special caution is required when you are discussing sensitive issues with children and young people.

• Operate within the organisation’s principles and guidance and any specific procedures.

• Challenge unacceptable behaviour and report all allegations or suspicions of abuse.

 Staff must not:

• Have inappropriate physical or verbal contact with children, young people or adults.

• Allow yourself to be drawn into inappropriate attention–seeking behaviour or make suggestive or derogatory remarks or gestures in front of children, young people or vulnerable adults.

• Jump to conclusions about others without checking facts.

• Show favouritism to any individual.

• Rely on your good name or that of the organisation to protect you.

• Believe ‘it could never happen to me.

• Take a chance when common sense, policy or practice suggests not.

• Investigate a concern yourself.

4. HOW DO WE RAISE, RECORD AND INVESTIGATE CONCERNS?

If any person, including a child, young person or vulnerable adult confides to someone that they are being or have been abused, or are experiencing mental health problems, they have placed that person in a position of trust.

An incident of concern should be recorded by pressing the Raise a Concern button on the employer, employee or apprentice portal. In the event that you do not have internet access, in the first instance telephone a member of the DSO Team.

The detailed instructions contained in Raise a Concern should be followed:

• Be clear that they cannot keep secrets and that they have to pass on information if they think a child or young person has been or is being harmed in some way.

• React calmly. Panic may frighten or silence the person.

• Reassure the person they were right to tell or share.

• Make it clear the child, young person or adult is not to blame and is not alone in how they feel.

• Take what is said seriously, recognising that there may be difficulties in interpreting what is said especially by a child.

• Keep questions to the point to ensure a clear and accurate understanding of what is being said – do not judge. Only ask questions in order to clarify what is being said. For Safeguarding issues, it is up to Children's Social Care and the police to investigate the matter fully.

• Make a full record of what is being said using UCAN Reports online, using the person's own words where possible.

• Do not delay in generating the report.

5. HOW DO WE PROVIDE SUPPORT AND GUIDANCE?

Confidentiality and trust should be maintained as far as possible, but employees must act on the basis that the safety of the child or adult is the overriding concern. The degree of confidentiality will be governed by the need to protect the child or adult. The child or adult should be informed at the earliest possible stage of their disclosure that this will then be escalated to the appropriate agencies if appropriate.

All conversations should always be held in private. UCAN complies with the requirements of the Data Protection Act 2018, which allows for disclosure of personal data where this is necessary to protect the vital interests of a child or adult.

Whatever happens, you should always be open and honest with the child or adult if you intend to take the case further.

Employees must not discuss the case with anyone other than those involved in the case. If employees have any concerns about the progress of the case or have any other concerns, these must be discussed with the DSO or MHO.

6. WHAT HAPPENS NEXT?

Taking into account all the information available, the case review team will decide on the next steps, which may include taking no further action. In most cases, the DSO/MHO will decide whether the issue is pastoral or a mental health issue and this will be dealt with by the person reporting supported by the DSO Team. For Safeguarding and Prevent we will seek advice from the Local Authority Designated Officer (LADO) and agree on what further action is necessary, which may include:

• Seeking further advice from the LSCB

• Undertaking further investigation under the direction of the LADO or support an investigation by the LSCB

• Making a referral to the appropriate agency.

• Reporting the incident to a designated Social Worker.

• Reporting the matter to the police if a crime is suspected.

If a referral is made, this must be confirmed in writing to the appropriate agency within 24 hours.

The DSO may consider that those involved may require counselling. Where it is felt there is a need for counselling (which could be for the children, adults at risk, other apprentices, employees, parents or carers involved) the DSO will make the necessary arrangements.

7. ALLEGATIONS AGAINST EMPLOYEES

The primary concern of the organisation is to ensure the safety of the child or adult. It is essential in all cases of suspected abuse by an employee that action is taken quickly and professionally whatever the validity. There are occasions when a child or adult will accuse an employee of physically or sexually harassing or abusing them. In some cases, this may be false or unfounded. However, in some cases, the allegations may be true.

Any instance of a child or adult being abused by an employee is particularly serious. On the other hand, for an innocent person to be accused of such an act is a serious ordeal which can result in long-term damage to their health and career. In the event that any employee suspects any other employee of abusing an apprentice, it is their responsibility to bring these concerns to the DSO Team.

On being notified of any such matter the DSO shall:

• Report to the LADO – Anthony Goble (0300 123 22 44) and take such steps as he/she considers necessary to ensure the safety of the child or adult in question and any other child or adult who might be at risk.

• Ensure that a report of the matter is completed by the person who reported the original concern.

• Put in place the steps necessary to follow the advice of the LADO.

If the allegation concerns a DSO, the matter should be discussed with the DSO’s line manager in addition to following the normal safeguarding procedures outlined in this document.

8. HOW WE MONITOR APPRENTICES’ USE OF IT

In furtherance of our duty to safeguard apprentices and the ‘Every Child Matters’ agenda we do all that we can to make our apprentices and staff stay e-safe and to satisfy our wider duty of care. Our approach is to implement firewall safeguards within the Company and to support staff and apprentices to identify and manage risks independently. We believe this can be achieved through a combination of security measures, training and guidance.

All apprentices are informed what to do if they have e-safety concerns and who to talk to. In most cases, this will be the Prevent/Safeguarding Designated Senior Person or their deputy. Where the Senior Management Team (SMT) considers it appropriate the Prevent/Safeguarding Designated Senior Person may be asked to intervene with appropriate additional support from external agencies.

9. PROTECTING LEARNERS WHEN DELIVERING EDUCATION REMOTELY

It is important that all staff ensure that they protect learners when they are delivering education remotely and that all staff are aware of what to do if they have a concern. If staff are delivering a session, they should agree on the terms beforehand, for example, do learners understand the code of conduct for the session (videos on or off, will they be muted on arrival and what can they do if they have a concern or question)

UCAN uses a variety of platforms to facilitate online learning and it is important that the risks and issues are understood and that all staff know what to look out for and how to respond.

If you do have any specific safeguarding concerns, you should record them in the same way as you do any offline concerns. If there are specific cases where illegal imagery has been shared, for example, child sexual abuse imagery, this should be reported to the police and the Internet Watch Foundation.

10. SECURITY

UCAN does what it can to make sure the Company's network is safe and secure. Security software is kept up to date. Appropriate security measures include the use of enhanced filtering and protection of firewalls, servers, routers, work stations etc. to prevent accidental or malicious access of systems and information. Digital communications, including e-mail and internet postings over the UCAN network, are monitored in line with the Network Usage Policy.

Ensure that the platform used to deliver remote learning is secure and password protected if possible. All staff are aware of online safety measures such as enabling waiting rooms when delivering online sessions to ensure all attendees are authorised, attendees.

11. BEHAVIOUR

UCAN will not tolerate any abuse of IT systems. Offline or online communications by staff and apprentices should be courteous and respectful at all times. Any reported incident of bullying or harassment or other unacceptable conduct will be treated seriously and in line with the staff and apprentice disciplinary policies and procedures.

Where conduct is found to be unacceptable UCAN will deal with the matter internally. Where conduct is considered illegal UCAN will report the matter to the police.

PERSONS RESPONSIBLE, WITH CONTACT DETAILS

DESIGNATED SAFEGUARDING LEAD:

Julie Cavalli::         *Removed*

DESIGNATED SAFEGUARDING OFFICERS: 

Jayshree Karsan:         *Removed*  

Della King:                 *Removed*  

Dedicated number:  01278 557367

DESIGNATED MENTAL HEALTH OFFICER:

Della King:                 *Removed*  

AUTHORISED BY:

UCAN Governance Board