Safeguarding / Prevent and Child Protection Policy 2024/25

These appendices are based on the Department for Education’s statutory guidance,

Keeping Children Safe in Education.

Appendix 1 - types of abuse

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

Physical abuse may involve hitting, shaking, throwing, poisoning, burning, or scalding, drowning, suffocating. or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.

Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Emotional abuse may involve

• Conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person
• Not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate
• Age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction
• Seeing or hearing the ill-treatment of another
• Serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children

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

• Physical contact, including assault by penetration (for example rape or oral sex) or non- penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing.
• Non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, forcing someone to strip or grooming a child in preparation for abuse (including via the internet)

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

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

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

• Provide adequate food, clothing, and shelter (including exclusion from home or abandonment)
• Protect a child from physical and emotional harm or danger
• Ensure adequate supervision (including the use of inadequate caregivers
• Ensure access to appropriate medical care or treatment

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

Appendix 2: safer recruitment and DBS checks - policy and procedures

We will record all information on the checks carried out in HTAE’s single central record (SCR). Copies of these checks, where appropriate, will be held in individuals’ personnel files. We follow requirements and best practice in retaining copies of these checks, as set out below.

New staff

When appointing new staff, we will -

• Verify their identity
• Obtain (via the applicant) an enhanced Disclosure and Barring Service (DBS) certificate, including barred list information for those who will be engaging in regulated activity (see definition below). We will not keep a copy of the DBS certificate but will record the certificate number and the name of the staff member who checked the certificate. For this we use Hull City Council online DBS checking system
• Obtain a separate barred list check if they will start work in regulated activity before the DBS certificate is available. Head of service and HR must approve any member of staff who works in regulated activity before the DBS certificate is available. Strict guidance and procedures would be sought and acted on before any member of staff is approved to start in regulated activity before the DBS is available. The start date would also be in line with approved Hull City Council policy and procedures for vetting new staff
• Verify their mental and physical fitness to carry out their work responsibilities
• Verify their right to work in the UK. We will keep a copy of this verification for the duration of the member of staff’s employment and for 2 years afterwards
• Verify their professional qualifications, as appropriate
• Ensure they are not subject to a prohibition order if they are employed to be a tutor
• Carry out further additional checks, as appropriate, on candidates who have lived or worked outside of the UK, including (where relevant) any tutor sanctions or restrictions imposed by a European Economic Area professional regulating authority, and criminal records checks or their equivalent
• Check that candidates taking up a management position are not subject to a prohibition from management (section 128) direction made by the secretary of state

We will ask for written information about previous employment history and check that information is not contradictory or incomplete.

We will seek references on all short-listed candidates, including internal candidates, before interview. We will scrutinise these and resolve any concerns before confirming appointments. The references requested will ask specific questions about the suitability of the applicant to work with children.

Regulated activity means a person who will be -

• Responsible, on a regular basis in a HTAE or college, for teaching, training, instructing, caring for or supervising children
• Carrying out paid, or unsupervised unpaid, work regularly in a HTAE or college where that work provides an opportunity for contact with children
• Engaging in intimate or personal care or overnight activity, even if this happens only once and regardless of whether they are supervised or not

Existing staff

If we have concerns about an existing member of staff’s suitability to work with children, we will carry out all the relevant checks as if the individual was a new member of staff. We will also do this if an individual moves from a post that is not regulated activity to one that is.

We will refer to the DBS anyone who has harmed, or poses a risk of harm, to a child or vulnerable adult. HTAE policy is to renew all staff DBS every 3 years in line with Hull City Council Policy and procedures, where -

• We believe the individual has engaged in relevant conduct
• The individual has received a caution or conviction for a relevant offence, or there is reason to believe the individual has committed a listed relevant offence, under the Safeguarding Vulnerable Groups Act 2006 (Prescribed Criteria and Miscellaneous Provisions) Regulations 2009
• The ‘harm test’ is satisfied in respect of the individual (i.e., they may harm a child or vulnerable adult or put them at risk of harm)
• The individual has been removed from working in regulated activity (paid or unpaid) or would have been removed if they had not left

Agency and third-party staff

We will obtain written notification from any agency or third-party organisation that it has carried out the necessary safer recruitment checks that we would otherwise perform. We will also check that the person presenting themselves for work is the same person on whom the checks have been made.

Contractors

We will ensure that any contractor, or any employee of the contractor, who is to work at HTAE has had the appropriate level of DBS check. This will be -

• An enhanced DBS check with barred list information for contractors engaging in regulated activity
• An enhanced DBS check, not including barred list information, for all other contractors who are not in regulated activity but whose work provides them with an opportunity for regular contact with children

We will obtain the DBS check for self-employed contractors. We will not keep a copy of the DBS certificate but will record the certificate number and the name of the staff member who checked the certificate.
Contractors who have not had any checks will not be allowed to work unsupervised or engage in regulated activity under any circumstances.

We will check the identity of all contractors and their staff on arrival at HTAE.

Trainee/learner tutors

Where applicants for initial tutor training are salaried by us, we will ensure that all necessary checks are carried out.

Where trainee tutors are fee-funded, we will obtain written confirmation from the training provider that necessary checks have been carried out and that the trainee has been judged by the provider to be suitable to work with children.

Volunteers

We will -

• never leave an unchecked volunteer unsupervised or allow them to work in regulated activity
• obtain an enhanced DBS check with barred list information for all volunteers who are new to working in regulated activity
• carry out a risk assessment when deciding whether to seek an enhanced DBS check without barred list information for any volunteers not engaging in regulated activity

Governors

All governors and members will have an enhanced DBS check without barred list information.

They will have an enhanced DBS check with barred list information if working in regulated activity.

All governors and members will also have the following checks -

• Identity
• Right to work in the UK
• Other checks deemed necessary if they have lived or worked outside the UK All members will also have the following checks:
• A section 128 check (to check prohibition on participation in management under section 128 of the Education and Skills Act 2008)

Staff working in alternative provision settings.

Where we place a learner with an alternative provision provider, we obtain written confirmation from the provider that they have carried out the appropriate safeguarding checks on individuals working there that we would otherwise perform.

Adults who supervise learners on work experience

When organising work experience, we will ensure that policies and procedures are in place to protect children from harm.

No learner under the age of 16 will have work experience placements.

Appendix 3: allegations of abuse made against staff (incl. Supply staff and volunteers)

This section of this policy applies to all cases in which it is alleged that a current member of staff, supply staff for volunteer has or may have -

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

It applies regardless of whether the alleged abuse took place in the HTAE. Allegations against a tutor who is no longer teaching and historical allegations of abuse will be referred to the police.

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

Suspension

Suspension will not be the default position and will only be considered in cases where there is reason to suspect that a child or other children is/are at risk of harm, or the case is so serious that it might be grounds for dismissal.

Definitions for outcomes of allegation investigations -

• Substantiated - there is sufficient evidence to prove the allegation
• Malicious - there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive
• False - there is sufficient evidence to disprove the allegation
• Unsubstantiated - there is insufficient evidence to either prove or disprove the allegation (this does not imply guilt or innocence)
• Unfounded - to reflect cases where there is no evidence or proper basis which supports the allegation being made

Procedure for dealing with allegations

In the event of an allegation that meets the criteria above, the Head of Service (or Chair of Governors where the Head of Service is the subject of the allegation) will be the ‘case manager’ and will take the following steps -

• Immediately discuss the allegation with the designated officer at the local authority. This is to consider the nature, content and context of the allegation and agree a course of action, including whether further enquiries are necessary to enable a decision on how to proceed, and whether it is necessary to involve the police and/or children’s social care services. (The case manager may, on occasion, consider it necessary to involve the police before consulting the designated officer - for example, if the accused individual is deemed to be an immediate risk to children or there is evidence of a possible criminal offence. In such cases, the case manager will notify the designated officer as soon as practicably possible after contacting the police)
• Inform the accused individual of the concerns or allegations and likely course of action as soon as possible after speaking to the designated officer (and the police or children’s social care services, where necessary). Where the police and/or children’s social care services are involved, the case manager will only share such information with the individual as has been agreed with those agencies
• Where appropriate (in the circumstances described above), carefully consider whether suspension of the individual from contact with children at the HTAE is justified or whether alternative arrangements can be put in place. Advice will be sought from the designated officer, police and/or children’s social care services, as appropriate
• If immediate suspension is considered necessary, agree, and record the rationale for this with the designated officer. The record will include information about the alternatives to suspension that have been considered, and why they were rejected. Written confirmation of the suspension will be provided to the individual facing the allegation or concern within 1 working day, and the individual will be given a named contact at HTAE and their contact details.
• If it is decided that no further action is to be taken in regard to the subject of the allegation or concern, record this decision and the justification for it and agree with the designated officer what information should be put in writing to the individual and by whom, as well as what action should follow both in respect of the individual and those who made the initial allegation
• If it is decided that further action is needed, take steps as agreed with the designated officer to initiate the appropriate action in HTAE and/or liaise with the police and/or children’s social care services as appropriate
• Provide effective support for the individual facing the allegation or concern, including appointing a named representative to keep them informed of the progress of the case and considering what other support is appropriate
• Inform the parents or carers of the child/children involved about the allegation as soon as possible if they do not already know (following agreement with children’s social care services and/or the police, if applicable). The case manager will also inform the parents or carers of the requirement to maintain confidentiality about any allegations made against tutors (where this applies) while investigations are ongoing. Any parent or carer who wishes to have the confidentiality restrictions removed in respect of a tutor will be advised to seek legal advice
• Keep the parents or carers of the child/children involved informed of the progress of the case and the outcome, where there is not a criminal prosecution, including the outcome of any disciplinary process (in confidence)
• Make a referral to the DBS where it is thought that the individual facing the allegation or concern has engaged in conduct that harmed or is likely to harm a child, or if the individual otherwise poses a risk of harm to a child

If HTAE is made aware that the secretary of state has made an interim prohibition order in respect of an individual, we will immediately suspend that individual from teaching, pending the findings of the investigation by the Teaching Regulation Agency.

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

Timescales

• Any cases where it is clear immediately that the allegation is unsubstantiated or malicious will be resolved within 1 week
• If the nature of an allegation does not require formal disciplinary action, we will institute appropriate action within 3 working days
• If a disciplinary hearing is required and can be held without further investigation, we will hold this within 15 working days

Hull City Council disciplinary policy and procedures will be followed in line with the advisory guidelines in this policy

Specific actions

Action following a criminal investigation or prosecution.

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

Conclusion of a case where the allegation is substantiated.

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

If the individual concerned is a member of teaching staff, the case manager and personnel adviser will discuss with the designated officer whether to refer the matter to the Teaching Regulation Agency to consider prohibiting the individual from teaching.

Individuals returning to work after suspension.

If it is decided on the conclusion of a case that an individual who has been suspended can return to work, the case manager will consider how best to facilitate this.
The case manager will also consider how best to manage the individual’s contact with the child or children who made the allegation if they are still attending HTAE.

Unsubstantiated or malicious allegations

If an allegation is shown to be deliberately invented, or malicious, the Head of Service, or Chair of Governors in the case of an allegation against the Head of Service, will consider whether any disciplinary action is appropriate against the learner(s) who made it, or whether the police should be asked to consider whether action against those who made the allegation might be appropriate, even if they are not a learner.

Confidentiality

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

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

• Who needs to know about the allegation and what information can be shared
• How to manage speculation, leaks, and gossip, including how to make parents or carers of a child/children involved aware of their obligations with respect to confidentiality
• What, if any, information can be reasonably given to the wider community to reduce speculation
• How to manage press interest if, and when, it arises

Record-keeping

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

• A clear and comprehensive summary of the allegation
• Details of how the allegation was followed up and resolved
• Notes of any action taken and decisions reached (and justification for these, as stated above)

If an allegation or concern is not found to have been malicious, the HTAE will retain the records of the case on the individual’s confidential personnel file and provide a copy to the individual.

Where records contain information about allegations of sexual abuse, we will preserve these for the Independent Inquiry into Child Sexual Abuse (IICSA), for the term of the inquiry. We will retain all other records at least until the individual has reached normal pension age, or for 10 years from the date of the allegation if that is longer. Seek advice from HR.

The records of any allegation that is found to be malicious will be deleted from the individual’s personnel file.

References

When providing employer references, we will not refer to any allegation that has been proven to be false, unsubstantiated, or malicious, or any history of allegations where all such allegations have been proven to be false, unsubstantiated, or malicious.

Learning lessons

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

This will include consideration of (as applicable) -

• Issues arising from the decision to suspend the member of staff
• The duration of the suspension
• Whether or not the suspension was justified
• The use of suspension when the individual is subsequently reinstated. We will consider how future investigations of a similar nature could be carried out without suspending the individual

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 harm threshold for an allegation.

‘Keeping Children Safe in Education’ defines a low-level concern as “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 HTAE or college 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”

Avoiding low-level concerning behaviour

Behaviour defined as a ‘low-level concern’ can exist on a spectrum, from the inadvertent or thoughtless, or behaviour that may look to be inappropriate but is not in specific circumstances, through to that which is ultimately intended to enable abuse.

Staff education and reinforcement on avoiding circumstances which may put them in a difficult situation is key to avoiding the need for dealing with these types of concerns.

HTAE ensures that staff are clear about what appropriate behaviour is through their induction and regularly reinforcement of documents such as -

• Staff Code of Conduct
• ‘Avoiding Allegations’ guidance
• Safeguarding and Child Protection policies and regular training
• Tutors’ Standards (for teaching staff)

Reporting a low-level concern

Low-level concerns about a member of staff should be reported to the Head of service as per HTAE’s Child Protection procedures. If the concern is about the Head of service this should be reported to the Chair of Governors.

Low-level concerns about supply staff, contractors and local authority visiting staff will also be reported to their employers.

Dealing with a low-level concern

Where a concern is raised about the practice or behaviour of a member of staff, this information must be recorded and passed to the Head of service.

The Head of service must then make an assessment to determine if the matter is a ‘low-level concern’ or an ‘allegation’ and follow one of the following routes -

• Allegations that meet the harm threshold will be referred to the LADO for advice
• Low-level concerns that HTAE feel may need further guidance on will be referred to the LADO for advice
• Low-level concerns that HTAE feel they can deal with internally will be dealt with via HTAE usual child protection investigation process

HTAE will engage with its HR provider where it is necessary to undertake further investigation and/or deal with the concern under relevant processes.

Recording a low-level concern

All low-level concerns should be formally recorded by a member of staff when they are made aware of them.

This record should then be passed to the Head of service (or Chair of Governors if the concern is about the Head of service).

• Details of the concern
• The context in which the concern arose
• The outcome of the investigation and any action taken, and
• The name of the individual sharing their concerns (if known) (unless the individual wishes to remain anonymous which must be respected as far as possible)

Relevant records will be retained confidentially on the personnel file. A separate record will also be kept of low-level concerns to more easily identify patterns that may involve more than one member of staff. All records must be kept in line with data protection principles.

Reviewing a low-level concern

Records will be reviewed so that potential patterns of concerning, problematic or inappropriate behaviour can be identified.

Where a pattern of such behaviour is identified, the Head of service will decide on a course of action, which may include -

• Disciplinary investigation and/or proceedings
• Management Advice, including recommendations for training
• Referral to the LADO (where a pattern of behaviour moves from a concern to meeting the harm threshold). HTAE will take advice, where appropriate, from their HR provider in respect of low-level concerns.

HTAE will also review appropriate policies and training, or other wider cultural issues in the service, to see whether anything needs to be done to minimise the risk of similar behaviour happening again.
Relevant records will be retained confidentially on the personnel file. A separate record will also be kept of low-level concerns to more easily identify patterns that may involve more than one member of staff. All records must be kept in line with data protection principles.

Low-level concerns should not be included in references unless they relate to issues which would normally be included in a reference, for example, misconduct or poor performance. It follows that a low-level concern which relates exclusively to safeguarding (and not to misconduct or poor performance) should not be referred to in a reference. However, where a low-level concern (or group of concerns) has met the threshold for referral to the LADO and found to be substantiated, it should be referred to in a reference.

Appendix 4 - specific safeguarding issues Children missing from education

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

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

• are at risk of harm or neglect
• are at risk of forced marriage or FGM
• come from Gypsy, Roma, or Traveller families
• come from the families of service personnel
• go missing or run away from home or care
• are supervised by the youth justice system
• Cease to attend HTAE
• Come from new migrant families

We will follow our procedures for unauthorised absence and for dealing with children who go missing from education, particularly on repeat occasions, to help identify the risk of abuse and neglect, including sexual exploitation, and to help prevent the risks of going missing in future. This includes informing the local authority if a child leaves HTAE without a new training provider being named and adhering to requirements with respect to sharing information with the local authority, when applicable, when removing a child’s name from the admission register at non-standard transition points. The HTAE data team inform connexions of any leavers under the age of 18.

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

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

Child Criminal Exploitation (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, see below for more information), 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 substances and alcohol; • children who go missing for periods of time or regularly come home late; and
• children who regularly miss HTAE or education or do not take part in education.

Child sexual exploitation

Child sexual exploitation (CSE) is a form of child sexual abuse that occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity in exchange for something the victim needs or wants, and/or for the financial advantage or increased status of the perpetrator or facilitator.

This can involve violent, humiliating and degrading sexual assaults, but does not always involve physical contact; it can also occur through the use of technology. CSE can affect any child or young person (male or female) under the age of 18 years, including 16- and 17-year- olds who can legally consent to have sex. It can include both contact (penetrative and non- penetrative acts) and non-contact sexual activity and may occur without the child or young person’s immediate knowledge (e.g., through others copying videos or images they have created and posted on social media). For example, young people may be persuaded or forced to share sexually explicit images of themselves, have sexual conversations by text, or take part in sexual activities using a webcam.

Children or young people who are being sexually exploited may not understand that they are being abused. They often trust their abuser and may be tricked into believing they are in a loving, consensual relationship. If a member of staff suspects CSE, they will discuss this with the DSL. The DSL will trigger the local safeguarding procedures, including a referral to the local authority’s children’s social care team and the police, if appropriate.

Indicators of sexual exploitation can include the CCE indicators listed above and -

• children who have older boyfriends or girlfriends
• children who suffer from sexually transmitted infections or become pregnant

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.

Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem.

Staff, however, are well placed to 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 their child protection policy and speaking to the designated safeguarding lead or a member of the pastoral team.

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 importing 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 HTAEs, further and higher educational institutions, pupil referral units, special educational needs, 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 HTAE), when the victim may have been trafficked for the purpose of transporting drugs.

If a child is suspected to be at risk of or involved in county lines, then refer this to the DSL, DDSL or other senior member of staff using CPOMS.

Homelessness

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

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

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

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

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

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

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

FGM

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

Section 7.3 of this policy sets out the procedures to be followed if a staff member discovers that an act of FGM appears to have been carried out or suspects that a learner is at risk of FGM.

Indicators that FGM has already occurred include -

• a learner confiding in a professional that FGM has taken place
• a mother/family member disclosing that FGM has been carried out
• a family/learner already being known to social services in relation to other safeguarding issues
• a girl -
  • having difficulty walking, sitting, or standing, or looking uncomfortable
  • finding it hard to sit still for long periods of time (where this was not a problem previously)
  • spending longer than normal in the bathroom or toilet due to difficulties urinating
  • having frequent urinary, menstrual or stomach problems
  • avoiding physical exercise
  • being repeatedly absent from HTAE, or absent for a prolonged period
  • demonstrating increased emotional and psychological needs - for example, withdrawal or depression, or significant change in behaviour
  • being reluctant to undergo any medical examinations
  • asking for help, but not being explicit about the problem
  • talking about pain or discomfort between her legs

Potential signs that a learner may be at risk of FGM include -

• the girl’s family having a history of practising FGM (this is the biggest risk factor to consider)
• FGM being known to be practiced in the girl’s community or country of origin
• a parent or family member expressing concern that FGM may be carried out
• a family not engaging with professionals (health, education or other) or already being known to social care in relation to other safeguarding issues
• a girl -
  • having a mother, older sibling or cousin who has undergone FGM
  • having limited level of integration within UK society
  • confiding to a professional that she is to have a “special procedure” or to attend a special occasion to “become a woman”
  • talking about a long holiday to her country of origin or another country where the practice is prevalent, or parents stating that they or a relative will take the girl out of the country for a prolonged period
  • requesting help from a tutor or another adult because she is aware or suspects that she is at immediate risk of FGM
  • talking about FGM in conversation - for example, a girl may tell other children about it (although it is important to take into account the context of the discussion)
  • being unexpectedly absent from HTAE
  • having sections missing from her ‘red book’ (child health record) and/or attending a travel clinic or equivalent for vaccinations/anti-malarial medication

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

Forced marriage

Forcing a person into marriage is a crime. A forced marriage is one entered in to 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.

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

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

The DSL will -

• speak to the learner about the concerns in a secure and private place
• activate the local safeguarding procedures and refer the case to the local authority’s designated officer
• seek advice from the Forced Marriage Unit on 020 7008 0151 or fmu@fco.gov.uk. Seek advice from the Police on 101 Preventing radicalisation
• 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

HTAE have a duty to prevent children from being drawn into radicalisation. All staff and the safeguarding Governor will undertake Prevent awareness training to equip them to identify children at risk. We will assess the risk of children in our HTAE centres being drawn into radicalisation. This assessment will be based on an understanding of the potential risk in our local area, in collaboration with our local safeguarding partners and local police force.

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

There is no single way of identifying an individual who is likely to be susceptible to an extremist ideology. Radicalisation can occur quickly or over a long period. Staff will be alert to changes in learners’ behaviour.

The government website Educate Against Hate and charity NSPCC says that signs that a learner is being radicalised can include -

• Refusal to engage with, or becoming abusive to, peers who are different from themselves
• Becoming susceptible to conspiracy theories and feelings of persecution
• Changes in friendship groups and appearance
• Rejecting activities, they used to enjoy
• Converting to a new religion
• Isolating themselves from family and friends
• Talking as if from a scripted speech
• An unwillingness or inability to discuss their views
• A sudden disrespectful attitude towards others
• Increased levels of anger
• Increased secretiveness, especially around internet use
• Expressions of sympathy for extremist ideologies and groups, or justification of their actions
• Accessing extremist material online, including on Facebook or Twitter
• Possessing extremist literature
• Being in contact with extremist recruiters and joining, or seeking to join, extremist organisations

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

If staff are concerned about a learner, they will follow our procedures set out in section 7.5 of this policy, including discussing their concerns with the DSL who may make a Prevent referral. Staff should always take action if they are worried.

Checking the identity and suitability of visitors

All visitors will be required to verify their identity to the satisfaction of staff.

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

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

Visitors to HTAE who are visiting for a professional purpose, such as educational psychologists, external professionals supporting HTAE learners, including external staff carrying out SEND assessments will be asked to show photo ID and -

• will be asked to show their DBS certificate, which will be checked alongside their photo ID
• the organisation sending the professional, such as the LA or educational psychology service, will provide prior written confirmation that an enhanced DBS check with barred list information has been carried out

All other visitors, including visiting speakers, will be always accompanied by a member of staff. We will not invite into HTAE any speaker who is known to disseminate extremist views and will carry out appropriate checks to ensure that any individual or organisation using HTAE facilities is not seeking to disseminate extremist views or radicalise learners or staff.

Missing learners

Our procedures are designed to ensure that a missing learner is found and returned to effective supervision as soon as possible. If a learner goes missing, we will -

• notify parents/carers as soon as possible
• contact the police if we suspect the learner is at risk of harm or are unable to contact parents/carers
• attempt to contact the learner to establish his/her whereabouts via his/her mobile or with the help of friends via mobiles/social media after taking advice from external authorities

Modern slavery

Modern slavery can include -

• domestic servitude
• sexual exploitation
• forced marriage
• child exploitation
• criminal exploitation
• debt bondage
• forced labour
• organ harvesting.

This list is not exhaustive - the image is taken from a government publication and shows common areas where labour exploitation takes place.

What to look for -

• situations where you do not know who holds parental responsibility (see also private fostering)
• children missing from education and/or home
• unbelievable or surprising accounts of how they are in the country
• intimidation of people at risk
• parents working without pay
• children being involved in inappropriate work
• injuries
• tattoos or other marks indicating ‘ownership’
• distrust of authority
• indicators of child exploitation
• Information icon
• Barriers

Potential victims may -

• be reluctant to come forward with information
• not recognise themselves as having been trafficked, exploited or enslaved
• tell their stories with obvious errors

It’s not uncommon for perpetrators to provide stories for victims to tell if approached by the authorities. Errors or unrealistic stories may be because they have had to memorise false histories that have been composed by others.

Other indicators may include those relating to physical health, sexual health and emotional health, with these being broadly similar to those relating to general safeguarding concerns where a person is being exploited (child or adult).

What to do

Modern slavery of children is child abuse, therefore normal child protection procedures apply -

• Refer to children’s services or the police as a ‘first responder’
• Ensure they follow the National Referral Mechanism to assess next steps
• Follow your safeguarding procedures in relation to any other risks

Resources

• GOV.UK Modern Slavery

Including information on -

• Modern slavery strategy
• Modern slavery training: resource page
• Modern slavery: duty to notify
• Modern Slavery Act 2015
• Modern slavery victims: referral

Knife crime

Knife crime is on the rise nationally and this includes our locality. Our procedures help to ensure that we work together to identify and support learners who may be at risk of knife crime, making reference to the relevant recommendations in Safeguarding Children and Young People in Education from Knife Crime, March 2019.

Upskirting

KCSiE 2023 describes this as: “‘Upskirting’ typically involves taking a picture under a person’s clothing without them knowing, with the intention of viewing their genitals or buttocks to gain sexual gratification, or cause the victim humiliation, distress, or alarm. It is now a criminal offence. Anyone of any gender, can be a victim.” As such, HTAE will treat any actions of this nature as a serious incident and will follow the advice of the police and EHASH.

Domestic Abuse and IPV (Intimate Partner Violence)

The Domestic Abuse Act 2021 received Royal Assent on 29 April 2021. The Act introduces the first ever statutory definition of domestic abuse and recognises the impact of domestic abuse on children, as victims in their own right, if they see, hear or experience the effects of abuse. The statutory definition of domestic abuse, based on the previous cross-government definition, ensures that different types of relationships are captured, including ex-partners and family members. The definition captures a range of different abusive behaviours, including physical, emotional and economic abuse and coercive and controlling behaviour.

Under the statutory definition, both the person who is carrying out the behaviour and the person to whom the behaviour is directed towards must be aged 16 or over and they must be “personally connected” (as defined in section 2 of the 2021 Act). Types of domestic abuse include intimate partner violence, abuse by family members, teenage relationship abuse and child to parent abuse. Anyone can be a victim of domestic abuse, regardless of sexual identity, age, ethnicity, socio-economic status, sexuality or background and domestic abuse can take place inside or outside of the home. 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.

Experiencing domestic abuse 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. Young people can also experience domestic abuse within their own intimate relationships.

This form of child-on-child abuse is sometimes referred to as ‘teenage relationship abuse’. Depending on the age of the young people, this may not be recognised in law under the statutory definition of ‘domestic abuse’ (if one or both parties are under 16). However, as with any child under 18, where there are concerns about safety or welfare, child safeguarding procedures will be followed and both young victims and young perpetrators will be offered support.

Where HTAE has been made aware that a learner has been affected by domestic abuse, they will be monitored and supported where appropriate. This will always be done sensitively and confidentially.