Safeguarding and child protection policy
|Headteacher/principal||Simon Trevor-Roberts||020 7586 1444|
|Designated safeguarding lead||Wendy Burton||020 7586 1444 x 1|
|Deputy designated safeguarding lead||Gemma Fernandes||020 7586 1444|
|Online safety officer||Alexa Aston||020 7586 1444|
|Child protection lead officer and Local Authority Designated Officer (LADO) at London Borough of Camden||Sophie Kershaw|
Deputy LADO John Lawrence-Jones
|020 7974 4556|
|Safeguarding lead officers at London Borough of Camden||Michelle O’Regan (Head of Service – Children in Need)||020 7974 1905|
|Tracey Murphy (Service manager)||020 7974 4103|
|Patricia Williams (Service manager)||020 7974 1558|
|Children’s Contact Service/MASH team at London Borough of Camden||Jade Green||020 7974 1553/3317
Fax: 020 7974 3310
|Camden’s Online safety contact officer||Jenni Spencer||020 7974 2866|
|Camden’s Prevent Education Officer||Jane Murphy||020 7974 1008|
Core operational policies and procedures
1 Purpose of policy
This policy sets out how the school will meet its statutory duty under the Schedule to the Education (Independent School Standards) Regulations 2014 to safeguard and promote the welfare of children and help them to achieve good outcomes. The school will achieve this by providing a safe learning environment and ensuring school staff have the skills and knowledge to take action where children need extra support from early help services or require a social work service because they are in need or need to be protected from harm.
This policy is an adapted version of Camden’s Model Safeguarding and Child Protection Policy for schools and colleges in Camden (September 2019 edition), adapted for the use of Trevor-Roberts School.
Trevor-Roberts School attaches great importance to the welfare and safety of all its pupils and aims to create an ethos in which the children develop their confidence and feel secure, valued, listened to and are taken seriously.
Where a child is suffering significant harm, or is likely to do so, action should be taken to protect that child. Action should also be taken to promote the welfare of a child in need of educational support, even if they are not suffering harm or are at immediate risk.
Staff should operate in an environment where they feel able to raise concerns and are supported in their safeguarding role.
This policy remains in force throughout the response to coronavirus (Covid-19).
2 Roles and responsibilities
2.1 Camden Supporting People Directorate
The Directorate includes Children’s Safeguarding and Social Work (CSSW), Early Intervention and Prevention and Education divisions and these services will support the school to safeguard and promote the welfare of pupils by:
- co-ordinating the delivery of integrated children’s services within the borough, including an early help service
- providing statutory social work services under the Children Act 1989
- providing the school with advice, support and guidance, model policies and procedures, training and dedicated lead officers with responsibility for child protection, safeguarding and online safety
- dealing with allegations against members of staff and volunteers through the Local Authority Designated Officer (LADO)
- taking responsibility for those children who are missing from or not in education, including children who are known to be home educated.
2.2 The proprietors
The proprietors will ensure that :
- the school always acts in the best interests of the children
- the school meets its statutory duties with regard to safeguarding and protecting pupils and that the following are in place and are regularly monitored, reviewed and updated where necessary;
- safeguarding policies and procedures covering early help and child protection that are consistent with Camden Safeguarding Children Partnership procedures and Camden’s internal policies
- a staff code of conduct policy including policies covering staff/pupil relationships and communications and staff use of social media
- a procedure for responding to incidents where children go missing from education, particularly where there are repeated incidents that suggest potential safeguarding risks may be present.
- The school is able to work jointly with other agencies in order to ensure pupils can access help and support from early help services and statutory social work services and that children’s plans are implemented and monitored
- There is a nominated person with responsibility for liaising with the MASH team at Camden on safeguarding and child protection matters and who links with the LADO in the event of an allegation against the head teacher (at Trevor-Roberts this is the DSL, Wendy Burton)
- A senior member of staff is appointed as the designated safeguarding lead (DSL) (Wendy Burton) who is responsible for carrying out the statutory duties as set out in this policy and that Wendy Burton is given sufficient time and resources to carry out her responsibilities and that another member of staff is appointed to deputise in her absence
- Staff receive a thorough induction on joining and are given copies of all relevant safeguarding and child protection polices and the staff code of conduct policy
- Staff are confident that they can raise issues with leaders where there are concerns about safeguarding practice at the school and there are robust whistleblowing procedures in place
- Steps are taken to ensure parents and pupils are aware of the school’s safeguarding and child protection policies and procedures
- The Director of Curriculum (Alexa Aston) will take steps to ensure children are given opportunities within the curriculum to learn how to keep themselves safe, including online, in accordance with the school’s curriculum and PSHE policies
- The school has appropriate written procedures in place to ensure safer recruitment practices and reasonable checks on visitors to the school, to deal with allegations against staff or volunteers and to report matters to the Disclosure and Barring Service as required, and that these policies are consistent with statutory guidance and reviewed on an annual basis
- At least one member of staff has undertaken accredited safer recruitment training – at Trevor-Roberts School this is James Grey, Wendy Burton and Amanda Trevor-Roberts
- All staff receive safeguarding and child protection training at least every 2 years and receive regular updates from the designated safeguarding lead to ensure they remain up to date with new legislation
- The school has procedures in place to deal with allegations made against other pupils
- Children’s wishes and feelings are taken into account when deciding on what action to take or services to provide to protect individual children
2.3 Head teacher
The head teacher will ensure that the school meets its statutory safeguarding duty by ensuring the following:
- Staff are inducted thoroughly and have read all the school’s safeguarding and child protection policies, behaviour policies and Camden’s children missing from education policy so that they are fully aware of their role in safeguarding children and are able to fully implement policies
- All staff are able to identify those children who may need extra help and can make appropriate referrals to early help services
- All staff are vigilant to harm and abuse, are able to identify those children for whom there are child protection concerns and can make appropriate referrals to the DSL and/or Camden
- Staff are able to work in partnership with other agencies to safeguard children, including providing early help support, contributing to assessments and the implementation of any child’s plan, attending network meetings and case conferences, monitoring children’s progress and liaising with social workers
- Safer recruitment practice is followed when recruiting to posts and appropriate action is taken whenever an allegation is made against a member of staff
- The school offers a safe environment for staff and pupils to learn
- Safeguarding issues are brought to the attention of the DSL
- The school encourages a culture of listening to children and taking account of their wishes and feelings
- The school’s safeguarding policy and the implementation of the same is overseen and audited annually by a policy expert independent of the school and that any recommendations made by that expert are put into effect.
2.4 Role of the designated safeguarding lead
The role of the designated safeguarding lead and their deputy is to take lead responsibility for safeguarding and child protection within the school and to always be available during school hours for staff to discuss safeguarding concerns.
The DSL at Trevor-Roberts for the whole school including EYFS is Wendy Burton. Wendy Burton has the appropriate status and authority within the school to act as DSL, being a member of the school Senior Management Team. The deputy DSL is Gemma Fernandes.
The designated safeguarding lead (and her deputy) will:
- refer cases of suspected abuse to Camden;
- liaise with and manage referrals to relevant agencies such as the MASH team at Camden, the LADO, the Channel Panel, the Police and the Disclosure and Barring Service (DBS);
- keep the head teacher informed of on-going safeguarding and child protection issues (including online safety) and enquiries;
- provide advice and guidance for staff on safeguarding and child protection issues and making referrals;
- understand the early help assessment process and intervention (EHAT);
- ensure the school’s safeguarding and child protection policies are up to date and consistent with Camden’s Safeguarding Children Partnership policies and that policies are reviewed annually;
- ensure all staff, including temporary staff, are aware of and understand the school’s child protection policy and procedures and are able to implement them;
- attend training, including Prevent awareness training, every two years with regular upates at least annually, and the designated teachers meetings hosted by Camden in order to keep up to date with new policy, emerging issues and local early help, safeguarding and child protection procedures and working practices;
- provide regular updates received from Camden to all staff members and governors on any changes in safeguarding or child protection legislation
- have an awareness of those children who may be in need, young carers and children who have special educational needs and liaise with the SENCO when considering any safeguarding action for a child with special needs;
- oversee the operation and implementation of the school’s online safety policy;
- ensure the school’s child protection policy is reviewed annually;
- support staff who make referrals to Camden or the Channel programme;
- oversee child protection systems within the school, including the keeping and management of records, standards of recording concerns and referral processes and to monitor the effectiveness of policies and procedures in practice;
- provide a link between the school and other agencies, particularly CSSW and the Camden Safeguarding Children Partnership;
- ensure staff, including temporary staff, receive appropriate safeguarding and child protection training (including online safety) every 2 years;
- ensure parents are fully aware of the school policies and procedures and that they are kept informed and involved;
- refer cases where a person is dismissed or left due to risk of or harm to a child to the DBS or TRA as appropriate;
- ensure relevant and detailed records are kept and passed on appropriately when children transfer to other schools and where appropriate, share relevant information with schools or colleges to enable continued support the child on transfer.
2.5 Working with parents and carers
The school recognises the importance of working in partnership with parents and carers to ensure the welfare and safety of pupils.
The school will:
- make parents aware of the school’s statutory role in safeguarding and promoting the welfare of pupils, including the duty to refer pupils on where necessary, by making all school policies available on the school web-site or on request
- provide opportunities for parents and carers to discuss any problems with class teachers and other relevant staff
- ensure a robust complaints system is in place to deal with issues raised by parents and carers
- provide advice and signpost parents and carers to other services and resources where pupils need extra support.
2.6 Multi-agency working
The school will work in partnership with relevant agencies in order to meet its obligations under section 11 of the Children Act 2004 and Working together to safeguard children 2018.
As a relevant agency under the new Camden Safeguarding Children Partnership (CSCP) safeguarding arrangements, the school recognises its vital role in safeguarding school-age children and its statutory duty to co-operate with the CSCP to ensure joint working with partner agencies in order to improve outcomes for children in Camden.
The school recognises its vital role in safeguarding school-age children and will co-operate with the Camden Safeguarding Children Partnership to ensure joint working with partner agencies in order to improve outcomes for children in Camden.
3 Safeguarding children
The school will carry out its duty to safeguard pupils which is:
- protecting children from maltreatment
- preventing impairment of children’s mental and physical health or development
- ensuring children are growing up in circumstances consistent with the provision of safe and effective care
- undertaking that role so as to enable children to have optimum life chances so they can enter adulthood successfully
- taking action to enable all children to have the best outcomes.
The school will refer to Camden’s thresholds and eligibility criteria (available at the link below) to help make decisions on the child’s level of need and the appropriate service to refer on for services. Staff will consult with the designated safeguarding lead for advice and to discuss the case prior to making any referral for services.
All referrals for a children’s social care service will be made by way of an e-CAF referral to Camden’s Child and Family Contact team. The team is Camden’s “front door” for children’s social care referrals and accepts referrals for all cases.
Parental consent for referral will be sought but a referral will be made regardless of consent being given in cases where there are safeguarding concerns about the child and making a referral without parental consent is a proportionate response to these concerns.
Staff will also share information and work in an integrated way to ensure a co-ordinated response from agencies to support families and meet the child’s needs.
3.1 Early help cases
Staff will identify children who need extra help at an early stage and provide help and support in order to prevent concerns from escalating.
- In particular, staff will be aware of the needs of the following groups of children whose circumstances may mean they will require early help:
- children with disabilities and additional needs, including those with special educational needs
- young carers
- children showing early signs of being drawn into anti-social or criminal behaviour, including gangs and organised crime
- children who frequently go missing from home, school or care;
- children who are misusing drugs or alcohol;
- children at risk of exploitation through modern slavery and trafficking;
- children whose home circumstances are negatively affected by adult substance misuse or mental ill health or domestic abuse;
- children who have returned home from care;
- children who show early signs of abuse or neglect;
- children at risk of radicalisation;
- privately fostered children.
- Where the child’s extra needs require services, consideration will be given to what early help support can be offered a child by the school
- If the child requires an early help service from another agency, the school will make a referral to the Early Help service (via the Child and Family Contact team) for appropriate help and support. Staff will consult with parents prior to making any referral to discuss the matter and gain consent to refer the child
- Where the child is receiving an Early Help service, the school will work as part of the Team around the Family and take up the role of lead professional where this is appropriate
- Early help provision should be monitored and reviewed to ensure outcomes for the child are improving. If the school believes that this is not the case, consideration should be given to making a referral for a statutory social work service.
3.2 Referral for a statutory social work service
Where there are concerns about a child’s welfare, staff will act immediately by seeking the advice of the designated safeguarding lead or their deputy who are most likely to have the most complete safeguarding overview. Following consultation, the designated safeguarding lead should decide on whether to make a referral to Camden via the Contact Service (contact details are set out at the beginning of this policy).
Where the referral raises concerns that the child is at risk of significant harm, the case will be passed on to Camden’s MASH team to gather relevant information from other agencies.
The Contact Service will inform the school within 1 working day of the outcome of any referral and what action Camden will be taking. This may include any of the following:
- Carrying out a child and family assessment to identify the child’s needs and establish if the child is a child in need under section 17 of the Children Act 1989. These are children (including disabled children) who are unlikely to meet a reasonable standard of health and development unless provided with services
- Convening a strategy meeting under child protection procedures as set out in section 4 for any child where there are concerns about significant harm and/or taking any immediate action in order to protect the child
- Providing services for the child and their family in the meantime whilst work is on-going (including details of services).
4 Child protection procedures
4.1 Role of school
The school will work to the following policy documents in order to support the protection of pupils who are at risk of significant harm.
- Working together to safeguard children (DfE 2018)
- What to do if you’re worried a child is being abused (DfE2015) – see here
- The London Safeguarding Children Board child protection procedures – see here
- Keeping children safe in education (DFE 2019)
In line with these policies and procedures, the school will:
- identify those pupils where there are child protection concerns and make a referral to Camden
- attend child protection case conferences in order to effectively share information about risk and harm
- contribute to the development and monitoring of child protection plans as a member of the core group
- carry out the school’s role in implementing the child protection plan and continually monitoring the child’s wellbeing, and liaising with the allocated social worker as required.
Staff have a responsibility to identify those children who are suffering from abuse or neglect and to ensure that any concerns about the welfare of a pupil are reported to the designated safeguarding lead. Knowing what to look for is vital to the early identification of abuse and neglect. All staff should be aware of indicators of abuse and neglect so that they are able to identify cases of children who may be in need of help or protection.
Staff should refer to Appendix 1 for a full definition of significant harm and the specific indicators that may suggest a pupil may be at risk of suffering significant harm.
Any concerns held by staff should be discussed in the first instance with the designated safeguarding lead or their deputy and advice sought on what action should be taken. Where required, advice on thresholds and indicators of harm can be obtained from the MASH social worker on a no-names basis.
Concerns may be monitored over time and recorded on the monitoring/incident form shown at Appendix 2. Details of any concerning incidents should also be recorded on this form.
All staff should be aware that safeguarding incidents and/or behaviours can associated with factors outside the school and/or can occur between children outside of these environments. All staff, but especially the DSL should consider whether children are at risk of abuse or exploitation in situations outside their families. Extra-familial harms take a variety of different forms and children can be vulnerable to multiple harms including (but not limited to) sexual exploitation, criminal exploitation, and serious youth violence.
Indicators of abuse and neglect
A. Abuse: 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. 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 wholly 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.
B. Physical abuse: a form of abuse which 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.
C. Emotional abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It 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. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature 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 from participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), 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, although it may occur alone.
D. 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. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of children by other children is a specific safeguarding issue in education (see paragraph 27).
E. Neglect: 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, for example, 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); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
All staff should have an awareness of safeguarding issues that can put children at risk of harm. Behaviours linked to issues such as drug taking, alcohol abuse, deliberately missing education and sexting (also known as youth produced sexual imagery) put children in danger.
Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)
Both CSE and CCE are forms of abuse and both occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into sexual or criminal activity. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources.
In some cases, the abuse will be in exchange for something the victim needs or wants and/or will be to the financial benefit or other advantage (such as increased status) of the perpetrator or facilitator. The abuse can be perpetrated by individuals or groups, males or females, and children or adults. The abuse can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse. It can involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence.
Victims can be exploited even when activity appears consensual and it should be noted exploitation as well as being physical can be facilitated and/or take place online. More information including definitions and indicators are included in Appendix 1.
Peer on peer abuse
All staff should be aware that children can abuse other children (often referred to as peer on peer abuse). This is most likely to include, but may not be limited to:
- bullying (including cyberbullying);
- physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm;
- sexual violence, such as rape, assault by penetration and sexual assault;
- sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be stand-alone or part of a broader pattern of abuse;
- 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); and
- initiation/hazing type violence and rituals.
All staff should be clear as to the school’s or college’s policy and procedures with regards to peer on peer abuse.
All staff should be aware of indicators, which may signal that children are at risk from, or are involved with serious violent crime. These may include increased absence from school, a change in friendships or relationships with older individuals or groups, a significant decline in performance, signs of self-harm or a significant change in wellbeing, or signs of assault or unexplained injuries. Unexplained gifts or new possessions could also indicate that children have been approached by, or are involved with, individuals associated with criminal networks or gangs.
All staff should be aware of the associated risks and understand the measures in place to manage these. Advice for schools and colleges is provided in the Home Office’s Preventing youth violence and gang involvement and its Criminal exploitation of children and vulnerable adults: county lines guidance.
Female Genital Mutilation
Whilst all staff should speak to the designated safeguarding lead (or deputy) with regard to any concerns about female genital mutilation (FGM), there is a specific legal duty on teachers. If a teacher, in the course of their work in the profession, discovers that an act of FGM appears to have been carried out on a girl under the age of 18, the teacher must report this to the police. See Appendix 1 for further details.
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 this child protection policy and speaking to the DSL or deputy.
The Department of Education has published advice and guidance on Preventing and Tackling Bullying and Mental Health and Behaviour in Schools.
Safeguarding incidents and/or behaviours can be associated with factors outside the school or college and/or can occur between children outside the school or college. All staff, but especially the designated safeguarding lead (and deputies) should be considering the context within which such incidents and/or behaviours occur. This is known as contextual safeguarding, which simply means assessments of children should consider whether wider environmental factors are present in a child’s life that are a threat to their safety and/or welfare.
Children’s social care assessments should consider such factors so it is important that schools and colleges provide as much information as possible as part of the referral process. This will allow any assessment to consider all the available evidence and the full context of any abuse. Additional information regarding contextual safeguarding is available here: Contextual Safeguarding.
Additional information and support
Departmental advice What to Do if You Are Worried a Child is Being Abused – Advice for Practitioners provides more information on understanding and identifying abuse and neglect. Examples of potential indicators of abuse and neglect are highlighted throughout the advice and will be particularly helpful for school and college staff. The NSPCC website also provides useful additional information on abuse and neglect and what to look out for.
Appendix 1 contains important additional information about specific forms of abuse and safeguarding issues.
- All school staff should be aware that abuse, neglect and safeguarding issues are rarely stand-alone events that can be covered by one definition or label. In most cases, multiple issues will overlap with one another.
- Any concerns held by staff should be discussed in the first instance with the designated safeguarding lead or their deputy and advice sought on what action should be taken. Where required, advice on thresholds and indicators of harm can be obtained from the MASH social worker on a no-names basis (contact details are set out at the top of this page).
- Concerns may be monitored over time and recorded on the monitoring/incident form shown at Appendix 2. Details of any concerning incidents should be recorded on this form.
4.3 Dealing with disclosures
If a pupil discloses to a member of staff that they are being abused, the member of staff should:
- listen to what is said without displaying shock or disbelief and accept what the child is saying;
- allow the child to talk freely;
- reassure the child but not make promises that it may not be possible to keep, or promise confidentiality, as a referral may have to be made to Camden;
- reassure the child that what has happened is not their fault and that they were right to tell someone;
- not ask direct questions but allow the child to tell their story;
- not criticise the alleged perpetrator;
- explain what will happen next and who has to be told;
- make a formal record and pass this on to the designated safeguarding lead;
- staff must not view or forward any illegal images of a child.
- Where possible, a decision on whether or not to refer a pupil to Camden should be made by the designated safeguarding lead or their deputy following a discussion with the member of staff who has raised concerns. However this should not delay any referral and any member of staff may make a referral if this is necessary but staff should discuss the matter with a member of the senior management team and take advice from the Child and Family Contact team social worker. The designated safeguarding lead should be informed as soon as possible.
- Referrals should be in writing using an e-CAF referral completed either by the teacher raising concerns or by the designated safeguarding lead. Urgent child protection referrals will be accepted by telephone but must be confirmed in writing via the e-CAF referral within 48 hours.
- Where there is any doubt about whether the concerns raised meet the thresholds for a child protection referral, the designated safeguarding lead may discuss the case on a “no names” basis with the Child and Family Contact team social worker to obtain advice on how to proceed.
- Parental consent should be sought prior to the referral being made but a referral can be made if parents refuse consent where there are safeguarding concerns about the child and referral without consent is a proportionate response to those concerns. Consent should not be sought if this would place the child at risk of further harm, interfere with a criminal investigation or cause undue delay.
- If the child already has an allocated social worker, the referral should be made directly to them. If the child is not already known to Camden, referrals should be made to the Child and Family Contact team.
- All referrals will be acknowledged by the Child and Family Contact team manager within 24 hours and the referrer informed of what action will be taken.
- If the school does not think the child’s situation is improving within a reasonable timescale following referral, this should be taken up with Camden/Early help services via the designated safeguarding lead.
- If the child lives outside Camden, a referral should be made to their home local authority.
- If Wendy Burton decides that a referral to children’s social care is not needed, she will continue to monitor the situation by recording relevant incidents on the monitoring form attached to this policy at Appendix 2 as appropriate.
4.5 Attendance at case conferences and core groups
- The designated safeguarding lead will liaise with Camden to ensure that all relevant information held by the school is provided to Camden during the course of any child protection investigation.
- The designated safeguarding lead will ensure that the school is represented at child protection case conferences and core group meetings:
- where possible, a member of staff who knows the child best, such as a class teacher of head of year will be nominated to attend
- failing that, the designated safeguarding lead or their deputy will attend
- if no-one from the school can attend, the designated safeguarding lead will ensure that a report is made available to the conference or meeting.
Where a pupil is the subject of a child protection plan and the school has been asked to monitor their attendance and welfare as part of this plan;
- monitoring will be carried out by the relevant staff member in conjunction with the designated safeguarding lead;
- all information will be recorded on the child protection monitoring/incident form shown at appendix 2 prior to each conference and core group meeting;
- the completed monitoring form will be kept on the pupil’s separate chid protection file (that should be separate from the school record) and copies made available to all conferences and core group meetings;
- the designated safeguarding lead will notify the allocated social worker if the child is removed from the school roll, excluded for any period of time or goes missing.
- Child protection records relating to pupils are highly confidential and will be kept in a designated welfare file separate to the pupil’s education records. These records will be securely held within the school.
- The designated safeguarding lead is responsible for ensuring that records are accurate, up to date and that recording is of a high standard.
- All information should be accurately recorded if appropriate on the safeguarding monitoring/incident form (see appendix 2) and all records should be signed and dated.
- Records should show:
- what the concerns were;
- what action was taken to refer on concerns or manage risk within the school;
- whether any follow-up action was taken;
- how and why decisions were made.
- Any incidents, disclosures or signs of neglect or abuse should be fully recorded with dates, times and locations. Records should also include a note of what action was taken.
- The monitoring/incident form must be completed;
- whenever concerns arise or there is a serious incident or
- where a child is being monitored
- Where a child who is subject to a child protection plan transfers to another school, the designated safeguarding lead is responsible for ensuring that copies of all relevant records are passed to the designated safeguarding lead at the new school.
- Child protection records will only be kept until the pupil leaves the school and should be disposed of as confidential waste or passed to the school the pupil transfers to whichever is appropriate in the opinion of the DSL and in accordance with the principles set out in the Data Protection Act 1998. The child protection records should be transferred separately from the main pupil file, ensuring secure transit and confirmation of receipt should be obtained.
- The DSL will consider if it would be appropriate to share information with the new school prior to the child arriving.
- If the school receives child protection records relating to a new pupil the school will ensure that key staff are aware of what the records say.
4.8 Confidentiality and information sharing
- All information obtained by school staff about a pupil will be kept confidential and will only be shared with other professionals and agencies with the family’s consent unless there are safeguarding concerns that need to be shared with Camden and parents refuse consent or seeking consent would place the child at further risk.
- If the child is under 12, consent to share information about them must be obtained from their parents or carers. Young people aged 12 to 15 may give their own consent to information sharing if they have sufficient understanding of the issues.
- Where a child is at risk of suffering significant harm, schools and colleges have a legal duty to share this information with Camden and make appropriate referrals. Equally, where a child is subject to a child protection investigation, schools and colleges must share any information about the child requested by Camden.
- Parental consent to making a child protection referral should be sought but if withheld, the referral must still be made and parents made aware of this. Before taking this step, schools and colleges should consider the proportionality of disclosure against non-disclosure; is the duty of confidentiality overridden by the need to safeguard the child?
- Parental consent to referral can be dispensed with if seeking consent is likely to cause further harm to the child, interfere with a criminal investigation or cause undue delay in taking action to protect the child. However, schools should discuss this with the Child and Family Contact team social worker on a “no names” basis to gain advice on whether this course of action should be taken.
- Do not delay referral where it is not possible to contact the parents/carers
- Only relevant information should be disclosed, and only to other staff and professionals who need to know. Staff should consider the purpose of the disclosure, and remind recipients that the information is confidential and only to be used for the stated purpose.
- In the event that a child makes a disclosure of neglect or abuse, staff cannot guarantee them confidentiality, but must explain why they have to pass the information on, to whom and what will happen as a result. Parents should also be made aware of the school’s duty to share information.
- Staff should discuss any concerns or difficulties around confidentiality or information sharing with the designated safeguarding lead or seek advice from the Child and Family Contact team social worker.
- The Data Protection Act 2018 and GDPR and human rights law are not barriers to justified information sharing. There is a duty to share information if to do so is in the public interest and/or is for the purpose of keeping children safe. The information sharing should be necessary, proportionate, relevant, accurate, timely and secure. Always record your decision and what you share and the justification.
5 Policy availability and updating
This document and KCSIE Part 1 is given to all staff upon registration, is placed in the policy file and on the school intranet and noticeboard for reference, is updated annually and is available to view at any time. It is also available to parents and the public on the website and upon request.
If there has been a substantiated allegation against a member of staff the school will work with the LADO to review the school’s procedures in order to determine whether there are any improvements to the school’s procedures or practice that could be made in order to help prevent similar future events.
The proprietors and the DSL will conduct an annual review of this policy and update it annually with the guidance of an independent visitor who will carry out an annual audit of the school’s safeguarding policy and the implementation of the same. This visitor will provide an annual report following the audit and the school will follow and implement its findings and recommendations.
6 Recruitment Policy
See also Trevor-Roberts Recruitment Protocol
6.1 General principles
The school recognises safer recruitment practices are an essential part of creating a safe environment for children and will ensure that staff working in the school are suitable do to so and do not pose any kind of risk to children.
The school will follow the Keeping children safe in education guidance (DfE 2019).
- The school will carry out extensive checks and enquiries on applicants for all positions, including voluntary and support roles in accordance with statutory requirements.
- No staff member, volunteer, or anyone involved in the management of the school will be allowed to take up posts until all checks and enquiries required for that position have been satisfactorily completed.
- Checks with the Disclosure and Barring Service will be carried out at the level appropriate to the candidate’s role in the school (see section 6.4 and Trevor-Roberts DBS Policy).
- All job advertisements and application forms will clearly state that the role is a safeguarding role and that applicants will be expected to agree to undergo DBS and other checks as part of safer recruitment practices.
- Staff who normally sit on interview panels will be trained in safeguarding interviewing techniques and no interview should go ahead unless at least one member of the panel has undergone safer recruitment training.
- School staff with responsibility for carrying out recruitment checks should ensure they have a copy of any relevant documents or take relevant issue numbers from documents as proof that the document has been seen.
- Checks will be taken out on existing staff where concerns arise regarding their suitability to work with children or a person moves into a post that is a regulated activity.
- James Grey will be responsible for keeping a single central record of all staff and volunteers who work at the school.
- The single central records should include details of all checks carried out and the outcome of these checks or any certificates obtained in the format shown at appendix 4.
- Where the school has salaried trainee teachers, the school will ensure that all necessary checks are carried out on the trainees, including DBS checks, and that the outcome of these checks is recorded on the single central record.
- For trainee teachers, the school will obtain written confirmation from the training provider that the necessary checks have been carried out and that the trainee has been judged to be suitable to work with children.
- Where staff are recruited via third parties such as employment agencies, the head teacher will:
- Seek written confirmation from the agency that the agency has carried out all necessary checks on the individual
- Request written confirmation of the outcome of all check
- Request written confirmation that an enhanced DBS certificate has been received by the agency
- Check the identity of agency staff when they first present for work to ensure that they are the person against whom the checks were taken out.
6.2 Checks to be taken out (pre-appointment checks)
The school will verify the following information for all new staff:
- The applicant’s identity must be verified from their passport or other photographic ID and proof of address must be provided.
- The applicant’s right to work in the UK must be evidenced through documentation. Only original documentation should be accepted and its validity checked in the presence of the applicant.
- Where the applicant will be involved in regulated activity, an enhanced DBS check will be taken out, including information from the barred list. If the applicant will begin work before an enhanced DBS check can be completed, a barred list check will be obtained. Where an enhanced DBS certificate is required, it must be obtained from the candidate before, or as soon as practicable after, the person’s appointment.
- In the case of teaching staff, checks will be made on the applicant’s academic and vocational qualifications and further checks made on the TRA Teacher Services system to ensure they are not prohibited from teaching under a teacher prohibition order.
- Checks will be made to ensure any member of staff is not barred from teaching or management under a section 128 direction.
- The applicant will need to supply a complete employment history by way of a CV. Any chronological gaps will require explanation and, if necessary, evidence.
- Where the applicant has been living abroad, similar enquiries will be made in the country of origin relating to the applicant’s qualifications and suitability to teach via the TRA Teacher Services system.
- Enquiries will be made regarding the applicant’s state of physical and mental health to the extent that it may affect their capacity to carry out their role.
- The school will keep copies of the following documents on staff personnel files:
- documents used as proof of identity such as passports or driving licences;
- a summary of the DBS certificate (but all other documents relating to the DBS check must be destroyed);
- documents that prove the staff member’s right to work in the UK(failure to do so can result in a fine for employing illegal workers).
- Applicants will be asked to provide a full employment history and details of at least 2 referees, including previous and recent employers, and who should be a senior member of staff with the authority toprovide references. References from colleagues will not be acceptable.
- All references will be taken up and will be requested directly from the referee. Referees will be contacted to resolve any issues that emerge from the references provided.
6.4 DBS checks
See also Trevor-Roberts DBS Policy
In order to ensure that people who work in the school are suitable to do so and are not barred from working with children, the school will apply to the Disclosure and Barring Service (DBS) for police checks and other barred list information as part of the recruitment process.
Full DBS checks which include barred list checks will only be taken out on individuals who are involved in regulated activity. This is defined as close, unsupervised contact on a regular basis involving activities such as:
- guidance and advice
- driving a vehicle
- personal or intimate care.
The activity must be carried out regularly as part of the staff member’s day to day responsibilities and the checks will be reasonable in order to safeguard children.
Full DBS checks with barred list checks will also be carried out on permanent staff members working at the school or unpaid volunteers who regularly work unsupervised at the school and whose work means they have an opportunity for regular contact with children.
Other staff, contractors and supervised volunteers who have opportunities for regular contact with children but do not carry out a regulated activity will be subject to an enhanced DBS check but not barred list checks.
Decisions on whether a person is carrying out a regulated activity or whether their role provides opportunities for regular contact with children requiring a DBS check will be made by James Grey and the following will be taken into consideration when deciding on this:
- the age of the children;
- their level of vulnerability;
- the numbers of children in the group;
- the nature of the role;
- opportunities for contact with the children.
The school has robust procedures for day to day staff management and supervision and clear procedures for reporting and acting on concerns. Staff carrying out roles involving regulated activity will be suitably supervised on a regular basis by senior staff carrying out a similar role.
The school will ensure that all DBS checks carried out on staff are renewed after 3 years of the original DBS disclosure.
James Grey will ensure that the following are carried out in relation to unpaid volunteers such as parents who accompany pupils on school outings or provide help in the classroom:
- All volunteers will be required to undergo a recruitment process, such as references, DBS and other checks and interviews that is appropriate and proportional to the duties assigned to them.
- Volunteers who are carrying out a regulated activity, for example being left unsupervised with children or providing personal care to children should be subject to an enhanced DBS check, including barred list information.
- New volunteers who are not carrying out regulated activity but who have an opportunity for regular contact with children will be subject to an enhanced DBS check but this may not include a barred list check.
- For other volunteers who are not carrying out regulated activity and do not have regular contact with children, the head teacher/principal will carry out a risk assessment to decide whether an enhanced DBS check should be carried out depending on:
- the nature of the role
- what information is already known about the volunteer
- what references from work or volunteering activity the volunteer has provided regarding suitability
- Whether the role is eligible for an enhanced DBS check
- The school will ensure that all volunteers are competent to carry out the duties assigned to them and are only assigned duties that are suitable to their qualification and experience.
- Volunteers carrying out regulated activity but for whom a DBS check has not been carried out will be suitably supervised by teaching staff at all times at a level that ensures the safety of pupils.
- All volunteers will be fully inducted in relation to all school policies and procedures.
6.6 Alternative education provision
Whenever the school places a pupil with an alternative education provider, the school will obtain written confirmation of the provider’s safeguarding and child protection policies and ensure that appropriate safeguarding checks on individuals working at the establishment have been carried out.
7 Staff practice and conduct
7.1 Induction and training
See also Trevor-Roberts School Induction Programme for newly appointed staff
- James Grey will ensure that all staff are fully inducted, are made aware of the following policies of the school and that staff are fully aware of their role in implementing these
- Safeguarding and child protection policy and procedures including online safety and the role and identity of the DSL and deputy DSL
- The Pupil Behaviour policies including the Pupil Reward and Sanction Policy, the Discipline and Exclusion Policy and the Anti-Bullying Policy
- The Trevor Roberts School Staff code of conduct including the Trevor-Roberts School Mobile Phone Policy and ICT Policy
- Children missing from education policy.
- Staff will be asked to confirm in writing that they have received and read all relevant staff policies and Part 1 of KCSIE and Annex A.
- The designated safeguarding lead will ensure that all staff are fully inducted with regard to the school child protection procedures and that they receive safeguarding and child protection training on a two-yearly basis.
- James Grey will keep a central record of all statutory and other training undertaken by staff members, governors and volunteers.
- School staff will receive multi-agency safeguarding training provided by Camden Safeguarding Children Partnership at the relevant level.
- As well as basic safeguarding training, the designated safeguarding lead and their deputy will receive specific training on their role and other relevant multi-agency training courses provided by Camden.
- School staff will also receive training on the use of the Common Assessment Framework assessment and referral process as part of their safeguarding training.
- School staff will receive regular and timely updates on child protection and safeguarding issues via the designated safeguarding lead in order to ensure they remain up to date with new legislation.
7.2 Conduct and safe teaching practice
- The school expects staff and volunteers to set a good example to pupils through their own conduct and behaviour and aims to protect them from the risk of allegations being made against them by ensuring they maintain high standards of professionalism and appropriate boundaries – see Trevor Roberts School Staff Code of Conduct
- James Grey will ensure that there is a written code of conduct in place and that each member of staff, including volunteers, signs a code of conduct agreement on appointment that sets out the school expectations with regards to standards of professional behaviour and that all staff receive copies of relevant policies.
- Staff and volunteers should be aware of current guidance on safe teaching practice contained in the DCSF “Guidance for safer working practice for those working with children & young people in education settings” (May 2019).
7.3 Providing intimate or personal care to pupils
Staff may need to provide intimate or personal care to younger pupils, for example helping a child who has soiled themselves or supervising pupils who are changing for P.E.
Children should be encouraged to carry out self-care tasks for themselves where appropriate, but where adult intervention is needed, the following should be observed:
- When taking pupils to the toilet, staff should make colleagues aware of the task to be undertaken and explain to the child what will happen.
- Parents should always be notified if intimate care has been provided.
- When providing intimate care, staff should carefully and sensitively observe the child’s emotional response and report any concerns to the designated safeguarding lead
- When children are changing, levels of supervision should be appropriate to the pupil’s age.
- Staff should avoid any physical contact unless a child needs help.
- Staff should ensure that changing areas are private and that others are not able to enter whilst children are changing.
7.4 Pupil behaviour management, physical intervention and restraint
There are circumstances when it is appropriate for staff in schools and colleges to use reasonable force to safeguard children. The term “reasonable force” covers the broad range of actions used by staff that involve a degree of physical contact to control or restrain children. This can range from guiding a child to safety by the arm, to more extreme circumstances such as breaking up a fight or where a young person needs to be restrained to prevent violence or injury. “Reasonable” in these circumstances means “using no more force than is needed.” The use of force may involve either passive physical contact, such as standing between pupils or blocking a pupil’s path, or active physical contact such as leading a pupil by the arm out of the classroom.
The Department of Education believes that the adoption of a “no contact” policy at a school can leave staff unable to fully support and protect their pupils. The Department encourages school to adopt sensible policies which allow and support their staff to make appropriate physical contact. The decision on whether or not to use reasonable force to control or restrain a child is down to the professional judgment of the staff concerned and should always depend on individual circumstances.
Camden’s policy on physical intervention and restraint
Physical intervention and restraint on pupils should only be used as a last resort, normally when de-escalation strategies have failed, and when there is a clear risk of serious harm to the pupil or others or serious damage to property.
Decisions on when to use physical intervention is a matter of professional judgement, and any intervention or restraint should be proportionate, reasonable and necessary to the perceived risk and should continue only for as long as the risk remains. Should such an intervention be required the school should record the details, including any injury, and contact the parent/carer on the same day to explain the circumstances involved.
Use of physical intervention and restraint for vulnerable pupils with learning and other disabilities, autism and mental health difficulties should be carefully monitored as these pupils are more susceptible to experience physical intervention and restraint due to their circumstances.
7.5 Music tuition
It is recognised that music tutors are vulnerable to allegations being made against them because they often work with children alone and the activity can involve some physical contact with a child.
Music tutors need to be aware of the possibility of their conduct and behaviour, including physical contact, being misinterpreted by a child or taken out of context by other adults and:
- ensure they behave in an appropriate manner and maintain professional boundaries at all times
- only use physical contact as necessary within the context of the activity, for example as a means of demonstrating technique, and only for a long as needed
- make sure any physical contact cannot be misinterpreted by a child by explaining in advance what contact will be involved and why
- ask the child’s permission first and respect their wishes
- report any incidents or issues that arise to the appropriate member of staff and make sure a record is taken
- never travel alone with children in a car
- seek permission from parents before contacting children by mobile phone, for instance to rearrange a lesson or rehearsal, and use home telephone contacts wherever practicable.
The school will:
- carry out a risk assessment around providing music tuition. This should include:
- providing rooms/spaces that are adequately safe and open locations where the teacher can be easily observed by others, for example a door with glass in it
- passing on any relevant information about children that may have a bearing on how they could react to physical contact so the tutor can adapt their practice accordingly
- letting parents known when they arrange tuition what level of physical contact may take place as part of the activity
- recording any reported incidents or issues and dealing with these within the framework of the school’s own policies
- making sure music tutors are aware of the school’s safeguarding and staff conduct policies prior to starting.
7.6 What school staff should do if they have safeguarding concerns about another staff member who may pose a risk of harm to children or if an allegation is made against a member of staff
If staff have safeguarding concerns about another staff member or an allegation is made about another member of staff (including supply staff and volunteers) posing a risk of harm to children, then :
- this should be referred to the headteacher Simon Trevor-Roberts
- where there are concerns/allegations about the headteacher, this should be referred directly to the LADO
Further details can be found at Appendix 3.
The head teacher, Simon Trevor-Roberts, will be the school representative for the purposes of the allegations procedures and will be the link with the Local Authority Designated Officer for all allegations raised. The DSL, Wendy Burton, will be the deputy to act in their absence.
The school fosters a culture of openness in line with the “Freedom to speak up” review and will encourage a culture whereby staff feel enabled to raise concerns relating to the safeguarding of children or poor practice within the school that may cause a risk to children.
The school recognises that there may be circumstances where staff and pupils feel unable to raise concerns or incidents of malpractice within the school environment if there is reasonable doubt that these would be dealt with adequately.
All staff and volunteers have a legal duty to raise concerns where they feel individuals or schools are failing to safeguard and promote the welfare of children. Where it is not possible to raise concerns within the school, staff and volunteers may report concerns to the following:
- Camden’s lead officers for child protection or safeguarding where there are issues regarding the welfare of a pupil (contact details here)
- The following numbers can be used where there are issues regarding the school’s overall procedures around safeguarding
- Camden Council’s confidential and independent help-line for protected disclosure on 0800 734199
- the Ofsted whistle-blowing line on 0300 123 3155
- the NSPCC whistleblowing helpline on 0800 028 0285 – line is available from 8 am to 8 pm Monday to Friday and by email: firstname.lastname@example.org
- The head teacher is responsible for ensuring that these numbers are advertised on the school premises and made available to staff and pupils.
8 Health and safety and risk assessments
8.1 Responsibility for health and safety
The head teacher will ensure that there is a robust health and safety policy in place in order to meet the statutory responsibility for the safety of pupils and staff within the school environment.
Any health and safety policy adapted by the school will be based on the government guidance (download here) and will seek to balance risk avoidance against providing pupils with opportunities to take part in activities that help them learn to manage risk themselves.
Day-to-day responsibility for health and safety issues in the school will be delegated to James Grey who is competent to carry out these duties and who has received the appropriate training.
8.2 Risk assessments
The school will seek to identify and manage risk through the use of risk assessments. These will be carried out:
- on an annual basis for the school environment as a whole;
- for all school trips;
- for pupils travelling between locations during the school day;
- for all work-based learning or work experience placements;
- when a pupil who has been excluded for risky or violent behaviour is returning to the school which might include welfare risk assessments;
- whenever there are any changes to the school environment or school practices;
- following any serious incident which might include welfare risk assessments.
8.3 Working with aggressive and violent parents
Where schools are working with families who are known to Camden and there are concerns about the behaviour of parents towards members of school staff, this must be discussed with the head teacher and the designated safeguarding lead and the information shared with Camden.
If there are high levels of risk involved in contact with parents, Camden may convene a risk assessment meeting with the network in order to discuss strategies to reduce risk, and it is vital that schools and colleges are part of this process.
8.4 Site security and visitors
- The head teacher is responsible for the security of the school premises and will take steps to ensure it is a safe environment and securely protected against trespass and/or criminal damage.
- James Grey will decide whether or not contractors should be subject to DBS checks before being allowed access to the building, depending on the level of access they are likely to have to pupils.
- Where the visitor is employed by an organisation where DBS checks are normally required, for example NHS staff, James Grey will request written confirmation that relevant checks have been carried out for that individual.
- All visitors and contractors will be:
- informed to report to the school office on arrival
- expected to provide proof of identity
- expected to carry some form of identification at all times when on the school premises;
- suitably supervised by school staff at all times;
- made aware of school health and safety procedures.
- James Grey will ensure that any contract entered into with contractors sets out clearly the expectations for worker’s behaviour and the responsibility of contractors to monitor and ensure compliance with school policies.
- Contracted workers will not be allowed to approach or speak to pupils in any circumstances and must ensure that all equipment and working practices are in line with health and safety standards.
- Visiting organisations such as theatre groups who will be performing for or working directly with pupils will be expected to have adequate child protection procedures in place and must agree with class teachers in advance what level of supervision or contact they will have regarding pupils.
- Prevent requires schools to endeavour to ensure that any visiting speakers are suitable and properly supervised
8.6 Monitoring and review
To enable the school to monitor the safety of the premises and the school environment, as well as the implementation of policies, the head teacher will ensure that:
- all school policies are regularly monitored by the designated safeguarding lead and annually reviewed by the head teacher;
- the school keeps a central record of all accidents and incidents including what action was taken and by whom;
- staff are aware of their responsibility to record accidents and incidents;
- the head teacher has an overview all accidents/incidents;
- serious accidents and incidents are reported to the HSE
- the designated safeguarding lead ensures a high standard of recording of all concerns held about children;
- all accidents and incidents are scrutinised on a regular basis by James Grey to identify any problems or weaknesses around school safeguarding policies and procedures or any emerging patterns, and agreeing to any course of action.
9 Non-collection of children from school
The school has a policy regarding handing over children to adults wo are not their parent or known carer at the end of the school day. Parents will be asked to provide the details of the person who will normally collect the child and will be informed of the need to notify the school in advance if this changes, giving details of the person authorised to collect the child. The school will also ensure that the details of at least two people who can be contacted in an emergency in the event that the child is uncollected are given to the school.
Parents are asked to inform the school where children are subject to court orders that limit contact with a named individual or when information about the child should not be divulged because it may pose a risk to the child.
In the event that anyone who is not authorised to do so attempts to collect the child, the school will not allow the child to leave but contact the parent immediately.
If a child is uncollected at the end of the school day, the school will follow the procedure agreed with Camden:
- The schools will check with the child to see if there are any changes to arrangements for collection and try to make contact with the parent or other family members, and wait with the child until someone comes to collect them.
- Children will not be released into the care of another parent even where they offer to take the child home.
- The school will contact the Children and Families Contact Service to put Camden on notice at 4.00 pm if there are difficulties in contacting parents or other family members.
- If no contact can be made with the parent by 4.30pm, the school will contact the Children and Families Contact Service who will arrange for a social worker to collect the child or make arrangements for the child to be transported to the Camden Safeguarding and Social Work office.
- The school will regularly ask parents to confirm and update contact details and to nominate a family member or friend who can collect the child in the event that they are unable to do so.
- Where children are regularly uncollected or collected late, this should be discussed with the designated safeguarding lead and reported to the Pupil Attendance Service. If there are also child protection concerns, a referral should be made to Camden.
10 Children who are missing from education or home educated
The school maintains an admissions register and a daily attendance register for each form. All pupils are placed on both registers.
The school will inform the local authority of any pupil who is going to be removed from the admissions register where the pupil:
- Has been taken out of school by their parents and the school has received written notification from the parent that they are being educated outside the school system e.g.home education (see below)
- Has ceased to attend school and no longer lives within reasonable distance of the school at which they are registered
- Has been certified by the school medical officer as unlikely to be in a fit state of health to attend school
- Has been in custody for a period of more than four months due to a final court order and the head does not reasonably believe they will be returning to the school at the end of that period
- Has been permanently excluded
The local authority must be informed as soon as any of these grounds for removal from the register are met, and in any event no later than removing the pupil’s name from the register.
The school must also inform the local authority of any pupil who fails to attend school regularly, or who has been absent without the school’s permission for a continuous period of 10 school days or more.
The school must also notify Camden when a child joins or leaves the school at a “non-standard transition point” (within 5 working days).
All staff should be aware of the school’s safeguarding response to children who go missing from education.
When a pupil leaves the school, Gemma Fernandes will ascertain from the new school that the the pupil has started at that school.
The school will be aware of those children who are persistently absent or missing from school as this may be an indicator of welfare concerns.
Schools should refer to Camden’s “Children missing from education” policy and the CSCB missing children protocol for further details available here.
Where a parent notifies the school that they are removing the child so they can be educated at home, the following notifications should be made:
- The Pupil Attendance Service must be notified of all decisions.
- If the child is already known to Camden, their allocated social worker should be notified immediately.
- If the child is not known to Camden, but the school has concerns about their welfare, the designated safeguarding lead should make a referral to Camden.
11 Online safety
See also Trevor-Roberts School ICT Policy/Online Safety Policy
As part of its duty to provide a safe learning environment and ensure pupils are taught how to remain safe online, the school will implement the recommendations of Camden’s model schools online policy (as adapted by the school).
The DSL retains overall responsibility for online safety within the school but the day to day operation and implementation of the school’s online safety policy is delegated to the school’s online safety officer Alexa Aston.
It is essential that children are safeguarded from potentially harmful and inappropriate online material. As such the school will ensure that filters and appropriate monitoring systems are in place. However the school will try and ensure that “over blocking” does not lead to unreasonable restrictions as to what children can be taught with regard to online teaching and safeguarding.
12 Looked after and previously looked after children and care leavers
The school recognises that looked after and previously looked after children and care leavers are particularly vulnerable due to their status and their pre-care experiences.
A child who is being looked after by the local authority is known as a child in care. They might be living with foster parents, at home with their parents under the supervision of social care or in residential homes.
13 Children with special education needs or disabilities (SEND)
The school is aware that children with special education needs or disabilities may be more vulnerable to harm and abuse and may be more likely to experience bullying. They may also have difficulty in reporting harm and abuse due to communications difficulties and professionals may miss vital indicators.
14 Safeguarding vulnerable groups
The school is aware that some pupils may be living in circumstances that may make them more vulnerable to abuse, neglect or poor outcomes and who may need help or intervention from Early Help Services, Camden or other agencies in order to overcome problems or keep them safe.
15 Privately fostered children
Private fostering occurs when a child under the age of 16 is provided with care and accommodation by a person who is not a parent, person with parental responsibility for them or a close relative in their own home. A child is not privately fostered if the person caring for and accommodating them has done so for less than 28 days and does not intend to do so for longer.
The school should notify the local authority of any private fostering arrangement to allow the local authority to check the arrangement is suitable and safe for the child.
Schools have a legal duty to notify Camden of any pupil they know to be privately fostered. The DSL should contact the Fostering team on 020 7974 6783 to notify Camden of any private fostering arrangements that come to the school’s notice.
16 Young carers
If schools have concerns about a pupil they believe to be a young carer, they can contact Family Action on 020 7272 6933 for advice and can refer the pupil on for services and support. Further details can be found on the website. www.family-action.org.uk
17 Contextual safeguarding for young people and extra-familial harm
The school is aware that as young people grow more independent and spend more time away from home, they may face more risk from safeguarding threats outside of the home. These threats may be from within the community, from other pupils at school or from their own peer group rather than from within the family (extra-familial harm).
Whenever staff are made aware of any safeguarding incident or concerning behaviour that has taken place out of the home and that has put a young person at risk, staff will consider this in the context of the young person’s peer relationships and the wider environment when assessing the level and nature of the risk and making decisions on referrals.
The school will adhere to the following policies whenever there are concerns that young people are at risk from extra-familial harm:
- Young people can be at risk from extra-familial harm such as threats to their safety or welfare arising from behaviours and circumstances occurring outside of the home such as substance misuse, involvement in gangs, serious violence, criminal and sexual exploitation. Even though there might not be concerns about parenting, these threats may still raise safeguarding concerns that need to be addressed.
- Schools should be aware of the indicators that a young person may be involved in violent crime or may be being criminally exploited and as such at risk from becoming a victim of violence. Indicators include absenteeism, changes in friendship groups, declining academic performance, changes in emotional welfare and signs of physical assault.
- Those children who are involved in county lines exploitation (where the child is coerced into selling drugs) may also be in possession of goods and money and may own several mobile phones.
18 Young people at risk from gang activity or serious youth violence
Camden has a comprehensive strategy for reducing the risks posed by gang activity, and schools can refer young people to the Young Person’s Advocate based in the Youth Offending Service on 020 7974 6174 for advice.
19 Modern slavery and trafficked children
The CSCP protocol provides guidance for agencies where it is thought children have been trafficked into or within the UK or where they are vulnerable to modern slavery/forced labour. This includes young people who are criminally exploited under the county lines model.
20 Children who run away/go missing
The school is aware that many of these forms of exploitation are linked and that going missing from home or from education can be an indicator that young people are involved in child sexual exploitation, gang activity, modern slavery, criminal exploitation and trafficking.
21 Children and young people experiencing mental health issues
The school recognises that some pupils may experience mental health issues that can negatively affect their behaviour and their ability to participate fully in education.
The school will ensure that staff have an understanding of trauma informed practice and its link with mental health and are able to recognise pupils who are experiencing mental health issues and help them to access the most appropriate help. Where there are safeguarding concerns arising from a pupil’s mental health issues, staff will discuss concerns with the DSL to agree any actions to be taken.
The school will ensure that staff are teaching about mental wellbeing (as part of the statutory Health Education) to help reduce the stigma attached to mental and emotional problems. The school will also ensure early identification of pupils who have mental health needs and put in place appropriate support and interventions, including specialist services, where needed.
The school will take account of the government guidance Mental health and behaviour in schools.
Appendix 1 (which is adapted from Annex A of Keeping Children Safe in Education 2020 Edition) contains important additional information about specific forms of abuse and safeguarding issues.
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.
The guides explain each step of the process, support and special measures that are available. There are diagrams illustrating the courtroom structure and the use of video links is explained.
Making child arrangements via the family courts following separation can be stressful and entrench conflict in families. This can be stressful for children. The Ministry of Justice has launched an online child arrangements information tool with clear and concise information on the dispute resolution service. This may be useful for some parents and carers.
Children missing from education
All staff should be aware that children going missing, particularly repeatedly, can act as a vital warning sign of a range of safeguarding possibilities. This may include abuse and neglect, which may include sexual abuse or exploitation and child criminal exploitation. It may indicate mental health problems, risk of substance abuse, risk of travelling to conflict zones, risk of female genital mutilation or risk of forced marriage. Early intervention is necessary to identify the existence of any underlying safeguarding risk and to help prevent the risks of a child going missing in future. Staff should be aware of their school’s or college’s unauthorised absence and children missing from education procedures.
Children with family members in prison
Approximately 200,000 children in England and Wales have a parent sent to prison each year. These children are at risk of poor outcomes including poverty, stigma, isolation and poor mental health. NICCO provides information designed to support professionals working with offenders and their children, to help mitigate negative consequences for those children.
Child Criminal Exploitation (CCE)
CCE is where an individual or group takes advantage of an imbalance of power to coerce, 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 advantage or other advantage of the perpetrator or facilitator and/or through violence or the threat of violence.
The victim may have been criminally exploited even if the activity appears consensual. Child criminal exploitation 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 (see County Lines below), 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 wellbeing
- 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.
Child Sexual Exploitation (CSE)
CSE occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child 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.
CSE does not always involve physical contact; it can also occur through the use of technology. CSE can affect any child (male or female). It can include both contact (penetrative and non-penetrative acts) and non-contact sexual activity may occur without the child’s immediate knowledge (e.g.through others copying videos or images they have created and posted on social media).
The above CCE indicators can also be indicators of CSE, as can :
- children who have older boyfriends or girlfriends ; and
- children who suffer from sexually transmitted infections or become pregnant.
The department provides: Child sexual exploitation: guide for practitioners
County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs into one or more importing areas within the UK, using dedicated mobile phone lines or other forms of “deal line”.
County lines is the most common form of criminal exploitation in Camden and describes when gangs and organised crime groups exploit young people to transport and sell drugs, sometimes across county boundaries but also locally and within the borough. The young people have dedicated mobile phone “lines” for taking orders for drugs and are used as they are less likely to be stopped by police, allowing adult dealers to avoid the risk of arrest. Indicators include unexplained money, having several mobile phones, frequent calls, being in trouble with the police for possession of drugs or being found in an area to which they have no connection.
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 should be considered. If a child is suspected to be at risk of or involved in county lines, a safeguarding referral should be considered alongside consideration of availability of local services/third sector providers who offer support to victims of county lines exploitation.
Further information on the signs of a child’s involvement in county lines is available in guidance published by the Home Office.
The cross-government 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:
- financial; and
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. Domestic abuse affecting young people can also occur within their personal relationships, as well as in the context of their home life.
Advice on identifying children who are affected by domestic abuse and how they can be helped is available here.
- NSPCC- UK domestic-abuse Signs Symptoms Effects
- Refuge what is domestic violence/effects of domestic violence on children
- Safelives: young people and domestic abuse.
Schools can refer young people affected by domestic or sexual violence to the specialist worker based in the Camden Safety Net on 0207 974 1864 for advice and support.
Operation Encompass operates in Camden. It helps police and schools work together to provide emotional and practical help to children. The system ensures that when police are called to an incident of domestic abuse, where there are children in the household who have experienced the domestic incident, the police will inform the key adult (usually the DSL) in school before the child or children arrive at school the following day. This ensures that the school has up to date relevant information about the child’s circumstances and can enable support to be given to the child according to their needs.
The school will ensure that the school receives all police notifications of children who have been involved in domestic abuse incidents via Operation Encompass.
The DSL will inform relevant staff of any notification and agree what support (if any) the pupil should receive from the school.
Schools should share details of the notification with as few staff members as possible in order to keep the information confidential, and the school will decide on the most appropriate staff to be informed.
Camden Operation Encompass contact details :
Please note that there is no need for schools to make a referral to CSSW following a notification as the police will have already referred the case to the MASH.
National Domestic Abuse Helpline
Refuge runs the National Domestic Abuse Helpline which can be called free of charge and in confidence 24 hours a day on 0808 200 0247. Its website provides guidance and support for potential victims, as well as those who are worried about friends and loved ones. It also has a form through which a safe time from the team for a call can be booked.
Additional advice on identifying children who are affected by domestic abuse and how they can be helped is available at :
● NSPCC – UK domestic abuse Signs Symptoms Effects
● Refuge what is domestic violence/effects of domestic violence on children
● SafeLives : young people and domestic abuse
Being homeless or being at risk of becoming homeless presents a real risk to a child’s welfare. The designated safeguarding lead (and any deputies) should be aware of contact details and referral routes in to the Local Housing Authority so they can raise/progress concerns at the earliest opportunity. Indicators that a family may be at risk of homelessness include household debt, rent arrears, domestic abuse and anti-social behaviour, as well as the family being asked to leave a property. Whilst referrals and/or discussion with the Local Housing Authority should be progressed as appropriate, and in accordance with local procedures, this does not, and should not, replace a referral into children’s social care where a child has been harmed or is at risk of harm.
The Homelessness Reduction Act 2017 places a new legal duty on English councils so that everyone who is homeless or at risk of homelessness will have access to meaningful help including an assessment of their needs and circumstances, the development of a personalised housing plan, and work to help them retain their accommodation or find a new place to live.
So-called ‘honour-based’ abuse (including Female Genital Mutilation and Forced Marriage)
So-called ‘honour-based’ abuse (HBA) encompasses incidents or 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. Abuse committed in the context of preserving “honour” often involves a wider network of family or community pressure and can include multiple perpetrators. It is important to be aware of this dynamic and additional risk factors when deciding what form of safeguarding action to take. All forms of HBV are abuse (regardless of the motivation) and should be handled and escalated as such. Professionals in all agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a child being at risk of HBA, or already having suffered HBA.
If staff have a concern regarding a child that might be at risk of HBA or who has suffered from HBA, they should speak to the designated safeguarding lead (or deputy). As appropriate, they will activate local safeguarding procedures, using existing national and local protocols for multi-agency liaison with police and children’s social care. Where FGM has taken place, since 31 October 2015 there has been a mandatory reporting duty placed on teachers103 that requires a different approach (see following section).
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.
FGM mandatory reporting duty for teachers
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 teachers 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 pupils or 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.
Information on when and how to make a report can be found here.
Teachers 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 good reason not to, they should still consider and discuss any such case with the school’s or college’s designated safeguarding lead (or deputy) 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, teachers should follow local safeguarding procedures.
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. Schools and colleges can play an important role in safeguarding children from forced marriage.
The Forced Marriage Unit has published statutory guidance and Multi-agency guidelines, pages 35-36 of which focus on the role of schools and colleges. School and college staff can contact the Forced Marriage Unit if they need advice or information: Contact: 020 7008 0151 or email email@example.com.
Children are vulnerable to extremist ideology and radicalisation. Similar to protecting children from other forms of harms and abuse, protecting children from this risk should be a part of a schools’ or colleges’ safeguarding approach.
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.
There is no single way of identifying whether a child is likely to be susceptible to an extremist ideology. Background factors combined with specific influences such as family and friends may contribute to a child’s vulnerability. Similarly, radicalisation can occur through many different methods (such as social media) and settings (such as the internet).
However, it is possible to protect vulnerable people from extremist ideology and intervene to prevent those at risk of radicalisation being radicalised. As with other safeguarding risks, staff should be alert to changes in children’s behaviour, which could indicate that they may be in need of help or protection. Staff should use their judgement in identifying children who might be at risk of radicalisation and act proportionately which may include the designated safeguarding lead (or deputy) making a referral to the Channel programme.
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 is no single way of identifying whether a child is likely to be susceptible to an extremist ideology. Background factors combined with specific influences such as family and friends may contribute to a child’s vulnerability. Similarly, radicalisation can occur through many different methods (such as social media or the internet) and settings (such as within the home).
However it is possible to protect vulnerable people from extremist ideology and intervene to prevent those at risk of radicalisation being radicalised. As with other safeguarding risks, staff should be alert to changes in children’s behaviour, which could indicate that they may be in need of protection. Staff should use their judgment in identifying children who might be at risk of radicalisation and act proportionately which may include the DSL or deputy making a Prevent referral.
The Prevent duty
The school’s safeguarding duty includes the duty to promote British values in order to counter the extremist narrative and prevent young people from being radicalised and drawn into terrorism.
Under the Counter-Terrorism and Security Act 2015, the school also has a duty to refer young people on to Camden’s Channel Pannel under the Prevent strategy where there are concerns that they are being radicalised.
The school will follow the guidance set out in the CSCP guidance “Safeguarding children and young people from radicalisation and extremism” where:
- a school has concerns that a young person might be considering extremist ideologies and/or may be radicalised and would benefit from specialist support to challenge extremist ideologies, or
- that a younger pupil may be at risk due to their parent’s radicalisation.
Schools should always be a safe place for young people to explore new ideas and perspectives and develop their critical thinking skills. Where there are concerns about radicalisation and a referral under the Prevent duty to Channel Panel is being considered the school should discuss these concerns internally and also consider external advice and guidance where necessary and appropriate .
The designated safeguarding lead will be consulted for internal advice on making a referral. Prior to making a referral the school may also speak to and get advice from their police schools officer, the Police Prevent Engagement Officer (Mark Fowler, Mark.P.Fowler@met.pnn.police.uk or call 0208 733 6014) and Camden’s Prevent co-ordinator (Albert Simango firstname.lastname@example.org or call 020 7974 2010) or the Prevent Education Officer (Jane Murphy, email@example.com or call 020 7974 1008) or the DFE dedicated telephone helpline 0207 340 7264.
The department has published advice for schools on the Prevent duty. The advice is intended to complement the Prevent guidance and signposts other sources of advice and support.
There is additional guidance here.
Educate Against Hate, a website launched by the Her Majesty’s Government has been developed to support and equip school and college leaders, teachers, and parents with information, tools and resources (including on the promotion of fundamental British values) to help recognise and address extremism and radicalisation in young people. The platform provides information on and access to training resources for teachers, staff and school and college leaders, some of which are free such as Prevent e-learning, via the Prevent Training catalogue.
Channel is a voluntary, confidential support programme which focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. Prevent referrals may be passed to a multi-agency Channel panel, which will discuss the individual referred to determine whether they are vulnerable to being drawn into terrorism and consider the appropriate support required. A representative from the school may be asked to attend the Channel panel to help with this assessment. An individual’s engagement with the programme is entirely voluntary at all stages.
Guidance on Channel is available at Channel guidance.
Peer on peer/child on child abuse
Children can abuse other children. This is generally referred to as peer on peer abuse and can take many forms. This can include (but is not limited to): bullying (including cyberbullying); sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; sexting and initiation/hazing type violence and rituals.
Where appropriate the school will refer the perpetrator and the victim to the Child and Family Contact team under the Peer on peer abuse protocol available here.
Sexual violence and sexual harassment between children in schools and colleges
Context: Sexual violence and sexual harassment can occur between two children of any age and sex. It can also occur through a group of children sexually assaulting or sexually harassing a single child or group of children.
Children who are victims of sexual violence and sexual harassment will likely find the experience stressful and distressing. This will, in all likelihood, adversely affect their educational attainment. Sexual violence and sexual harassment exist on a continuum and may overlap, they can occur online and offline (both physical and verbal) and are never acceptable. It is important that all victims are taken seriously and offered appropriate support. Staff should be aware that some groups are potentially more at risk. Evidence shows girls, children with SEND and LGBT children are at greater risk. Staff should be aware of the importance of:
- making clear that sexual violence and sexual harassment is not acceptable, will never be tolerated and is not an inevitable part of growing up;
- not tolerating or dismissing sexual violence or sexual harassment as “banter”, “part of growing up”, “just having a laugh” or “boys being boys”; and
- challenging behaviours (potentially criminal in nature), such as grabbing bottoms, breasts and genitalia, flicking bras and lifting up skirts. Dismissing or tolerating such behaviours risks normalising them.
What is sexual violence and sexual harassment?
It is important that school and college staff are aware of sexual violence and the fact children can, and sometimes do, abuse their peers in this way. When referring to sexual violence we are referring to sexual violence offences under the Sexual Offences Act 2003 which includes rape and/or any type of sexual assault
When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur online and offline. When we reference sexual harassment, we do so in the context of child on child sexual harassment. 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. Whilst not intended to be an exhaustive list, sexual harassment can include:
- sexual comments, such as: telling sexual stories, making lewd comments, making sexual remarks about clothes and appearance and calling someone sexualised names;
- sexual “jokes” or taunting;
- physical behaviour, such as: deliberately brushing against someone, interfering with someone’s clothes (schools and colleges should be considering when any of this crosses a line into sexual violence – it is important to talk to and consider the experience of the victim) and displaying pictures, photos or drawings of a sexual nature; and
- online sexual harassment. This may be standalone, or part of a wider pattern of sexual harassment and/or sexual violence. It may include:
- non-consensual sharing of sexual images and videos;
- sexualised online bullying;
- unwanted sexual comments and messages, including, on social media;
- sexual exploitation; coercion and threats; and
The Voyeurism (Offences) Act, which is commonly known as the Upskirting Act, came into force on 12 April 2019. ‘Upskirting’ is where someone takes a picture under a person’s clothing (not necessarily a skirt) without their permission and/or knowledge, with the intention of viewing their genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim humiliation, distress or alarm. It is a criminal offence. Anyone of any gender can be a victim.
The response to a report of sexual violence or sexual harassment
The initial response to a report from a child is important. It is essential that all victims are reassured that they are being taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting sexual violence or sexual harassment. Nor should a victim ever be made to feel ashamed for making a report
Additional advice and support
There are many links for additional advice and support set out at the end of Annex A of Keeping Children Safe in Education September 2020 edition and at B13 in Camden’s Model Safeguarding Policy.
Appendix 2: Safeguarding children monitoring/incident form
Appendix 3: Supporting people directorate
Guidance for schools on dealing with allegations against staff members
1 Purpose and scope of policy
Schools have a duty to safeguard pupils and create a safe learning environment so it is crucial that there is a robust process in place for dealing with any allegations of harm or abuse by a staff member or volunteer against a pupil.
This policy sets out the procedures to be followed by head teachers when dealing with allegations that a member of staff or volunteer has:
- 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, or
- behaved towards a child or children in a way that indicates he or she may pose a risk of harm to children
- behaved or may have behaved in a way that indicates they may not be suitable to work with children
As well as covering the four categories of harm and abuse, allegations involving inappropriate relationships with pupils, grooming behaviour on-line, possession of indecent photographs or images of children and other offences under the Sexual Offences Act 2003 should also be dealt with under this policy.
The policy applies to all head teachers and staff members within the school, including permanent and temporary staff, supply teachers and volunteers who are currently working at the school even if the allegation involves an incident that happened at another school. Allegations against staff that have since left the school are not dealt with under this policy and should be referred to the police.
If allegations about a staff member’s treatment of their own child are raised, the police or local children’s social care department where the staff member lives should notify the Camden LADO who will contact the school and theCAIT to explore whether the information raises questions about the person’s suitability to work with children.
2 Legal framework
All schools must have procedures in place to deal adequately with any allegations made against staff and the procedures must comply with the guidance set out in Working together to safeguard children and the statutory guidance “Keeping children safe in education”.
Camden follows the London Safeguarding Children Partnership child protection procedures for dealing with allegations against staff (section 7) and schools should be aware of their role under these procedures.
As employers, schools must also ensure that members of staff against whom an allegation has been made are treated fairly, that they are kept informed of the progress of any investigation or disciplinary process and that they receive support. Allegations should be dealt with in a timely manner and if the member of staff has been suspended pending investigation, there should be a named member of staff responsible for keeping them informed of developments.
- The welfare of pupils is paramount; all staff members and volunteers have a duty to take any necessary action to safeguard and promote the pupil’s welfare.
- The pupil’s welfare must be taken into account throughout the duration of any investigation and appropriate services provided where needed.
- Allegations should be dealt with fairly and quickly and generally resolved within 1-3 months. Only in exceptional circumstances, for example where criminal proceedings are taking place, should allegations take more than 12 months to resolve.
- Allegations should be dealt with by the most efficient method and at an appropriate level, involving agencies such as the police and CSSW only where there is a clear need.
- Parents, pupils and staff should be made aware of this policy so that everyone is clear about how concerns can be raised and what actions are likely to happen when an allegation is made. Pupils should be taught how to protect themselves and who they should approach for help.
- Information should be shared in a timely way but only for the purposes of safeguarding and promoting the welfare of children.
- Those staff members wishing to raise concerns anonymously will be supported through Camden’s whistle-blowing procedures.
- All responses should be fair, transparent and balanced and should ensure the safety of children whilst supporting those adults who are the subject of allegations.
Every school must have a named person who is responsible for the management of allegations against staff and to whom allegations and concerns should be reported in the first instance. At Trevor-Roberts, this will be the headmaster, Simon Trevor-Roberts.
Schools should also appoint a deputy to deal with allegations in the named person’s absence. The deputy at Trevor-Roberts, for this purpose, is Wendy Burton the DSL. Any allegation against the head teacher should be referred directly to the LADO (contact details below and at the start of the safeguarding policy).
Camden has a named Local Authority Designated Officer (LADO) whose role is to oversee the management of all cases involving allegations against staff. However, the day to day management of cases is covered on a rota basis by Independent Reviewing Officers (IROs) based in the Quality Assurance Unit so that there is always a senior social work professional available to provide advice and take any necessary action. Throughout this policy, references to the LADO will mean either the LADO or the IRO who has been allocated the case via the rota.
The LADO will provide advice to schools on individual cases, liaise with Children’s Safeguarding and Social Work (CSSW) and the Police Child Abuse Investigation Team (CAIT) where required and monitor and review the progress of cases.
Camden’s LADO is:
Sophie Kershaw-Jones (deputy John Lawrence-Jones)
LADO and QA support officer
Children’s Quality Assurance Unit
Children’s Safeguarding and Social Work
5 Pancras Square
London N1 4AG
Tel: 020 7974 4556
Fax: 020 7974 6702
Referral form and guidance: www.cscp.org.uk
Camden Borough Police CAIT will appoint a responsible officer to oversee police responses for managing allegations, liaising with the LADO on individual cases and ensuring police attendance at meetings and monitoring and reviewing the progress of cases.
Camden Borough Police senior officer is:
DCI Ralph Coates
Police Child Abuse Investigation Team (CAIT)
Holborn Police Station
10 Lambs Conduit Street
London WC1N 3NR
Tel:0208 345 0124 mobile 07920 710321
Allegations may arise following a complaint from a parent or pupil or through concerns raised by other staff members. All allegations must be reported to Simon Trevor-Roberts immediately.
A written note of the details of the allegation, including times, dates, locations and the nature of the concern must be agreed with Simon Trevor-Roberts. Staff should be aware of the general rule that allegations must not be investigated and pupils should not be promised confidentiality.
Simon Trevor-Roberts will notify the Camden LADO within 1 working day of all allegations made against members of staff. The responsible officer should complete the LADO Agency reporting form and email this to the LADO mailbox LADO@camden.gov.uk.
The referral form is available here. The LADO will contact the referrer as soon as possible to discuss the case and decide what action to take.
However, it is recognised that in some emergency situations, schools may have to take immediate action to protect pupils, and may contact the LADO by telephone to discuss the matter to agree urgent action.
5.2 Initial action
Following notification, initial discussions between the school representative and the LADO should look at all the available information about the incident or allegation, the staff member and the child involved (including details of any previous allegations made by the child and their family) and decide if the allegation is serious enough to be dealt with under this policy.
The school representative and the LADO should agree what action to take, which may be:
- referral to the police for a criminal investigation
- referral to CSSW for assessment and possible child protection investigation
- initiation of disciplinary proceedings against the member of staff
- no further action to be taken.
Some cases may not involve harm to pupils and will not require an immediate response from the police or CSSW; in these cases, agreement will be made for the school to deal with the matter under local school policy as aprofessional standards matter. If following the school’s own investigationsthere are concerns, the school should refer the matter back to the LADO for action to be taken under this policy.
If the case raises serious concerns immediate action will be taken under this policy.
Where action will be taken, the LADO will liaise with the police and CSSW to ensure appropriate referrals are made and that all relevant information is passed on. The LADO and responsible person should also consider:
- if any further information is needed to assist the investigation
- whether any immediate action needs to be taken to protect pupils
- whether parents should be notified of the allegations (although in some cases this will be unavoidable, for example if the child requires medical treatment)
- how the child and their parents will be supported during the process
- whether any regulatory body such as Ofsted needs to be informed of the allegation.
Consideration should also be given to whether the seriousness of the allegations warrants the member of staff being suspended or whether they should continue to have contact with the child involved or any other pupil. See section 6.2 for further guidance on this.
The member of staff should be informed of the allegation and given as much information as possible, unless there are good reasons for not doing so. In cases where a criminal or child protection investigation is possible, the LADO should seek the advice of the police and CSSW regarding what information can be shared.
The school and the LADO should both make a written note of discussions and decisions should be agreed and the reasons for taking any particular course of action noted. This is particularly important in cases where no further action will be taken.
5.3 Initial strategy meeting
If the LADO believes that the pupil has suffered or is at risk of suffering significant harm, a referral will be made to CSSW and a strategy meeting convened to share information and agree on further action.
The meeting will be chaired by the LADO and should be attended by the responsible person from the school, a representative from the police CAIT and any other relevant person or agency, for example a representative from the employment agency supplying a temporary staff member.
The strategy meeting will:
- decide whether or not the pupil has or is likely to suffer significant harm and whether to instigate a child protection and/or criminal investigation which may be jointly conducted between the police and CSSW;
- look at what disciplinary processes should be put in place;
- consider the allegation in the light of any previous allegations or concerns and whether the staff member was acting reasonably in linewith the school’s behaviour policy (see section 6.1);
- make a decision about suspending the staff member where this is a proportionate response (see section 6.2);
- consider what action should be taken to ensure the safety of the pupil involved and all other pupils;
- agree the plan for investigating the allegation and providing support to the staff member and the child whilst the investigation is on-going;
- agree what information should be shared between agencies and how issues relating to media reporting or containing speculation will be dealt with.
The strategy meeting may consider suspending the member of staff but other alternative arrangements to ensure the member of staff has no contact with the child involved should be considered in the first instance before suspending the staff member.
It is a school decision as to whether or not to suspend the staff member and this should be based on a clear risk assessment and be in accordance withthe school’s own policies on staff conduct.
However, in cases where there are serious allegations and clear evidence of abuse, the police and CSSW may take alternative action if schools do not follow a recommendation to suspend a staff member.
5.4 Review strategy meeting
A review strategy meeting should be held within a reasonable timescale in order to review the actions agreed at the initial strategy meeting and agree what further action should be taken.
The review should consider the outcome of any investigations carried out by the police and CSSW and whether there is enough evidence to pursue the allegation further or take action under child protection procedures.
If no further action will be taken by CSSW or the police, the meeting should agree what further steps the school should take to ensure the safety of pupils, for example what further investigation should be carried out by the school or what action to take with regard to the member of staff involved.
5.5 Final outcome of investigations
Following the review strategy meeting once investigations are completed and final actions decided the possible outcomes are:
- The allegation is substantiated as there is sufficient evidence to pursue the allegation.
- The allegation is malicious: there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive.
- The allegation is false: there is sufficient evidence to disprove the allegation.
- The allegation is unsubstantiated: there is insufficient evidence toeither prove or disprove the allegation.
- The allegation is unfounded: these will be cases where there is no evidence or proper basis which supports the allegation being made.
5.6 Police action and criminal proceedings
The police CAIT should keep the school and the LADO informed of all progress in investigations and proceedings, including any decision to charge or the outcome of trials. These should be discussed with the LADO to decide on any action needed by the school in relation to disciplinary proceedings or decisions on continued employment.
5.7 Disciplinary proceedings
Decisions to follow disciplinary proceedings lies with the school but must be considered in all cases where a criminal or child protection investigation has not been considered necessary or on completion of any criminal proceedings. The school representative should discuss any disciplinary proceedings with the LADO and look at what options are available to deal with the matter.
If a further investigation is required, CSSW and Camden Learning will be able to advise schools on how to undertake the investigation and may be able to provide a suitable council officer to carry out the task if necessary.
The school representative should discuss any disciplinary proceedings with the LADO taking into account any information raised by child protection enquiries, criminal proceedings or the outcome of any trial. This discussion should also look at whether a referral should be made to the Disclosure and Barring Service.
If the staff member concerned is an agency worker or volunteer where disciplinary proceedings are not possible, the school and the LADO should work jointly with the employer or individual to resolve the matter.
If formal disciplinary action will not be required, the head teacher should take any appropriate action within 3 working days. Full disciplinary hearings should be held within 15 working days if no further investigation is needed.
If a disciplinary investigation uncovers evidence of significant harm to a child, a referral must be made to CSSW and the disciplinary proceedings suspended until the outcome of any child protection investigation.
5.8 Referral to the Disclosure and Barring Service (DBS) and the Teaching Regulation Agency (TRA)
There is a legal duty on employers to refer any individual to the DBS if it is thought that they pose a risk to children or have harmed a child. The DBS will then make a decision as to whether or not to bar the person from working with children in a regulated activity such as teaching.
“Compromise agreements” cannot be used to prevent a referral being madeto the DBS when it is legally required.
As cases move towards conclusion and all information is available, the school and the LADO should discuss whether a referral needs to be made to the DBS. A referral must be made if the allegation is proved and the person has been removed from their post or has resigned prior to being removed.
Where the member of staff is a teacher, the strategy discussion should consider whether a referral should be made to the TRA in order to consider a prohibition from teaching. However the final decision on whether or not to make the referral rests with the school. Further guidance is available on the Teaching Regulation Agency website.
5.9 Monitoring and oversight of cases
The LADO will review all cases involving allegations against staff members on a fortnightly basis where the case is complex or on a monthly basis for more straightforward cases. This is to ensure that cases are dealt with efficiently and within prescribed timescales. The responsible police officer in CAIT will review all cases in criminal proceedings that involve allegations against staff members and will pass on information to the school and the LADO regarding progress of investigations and prosecutions. Cases must be reviewed within 4 weeks of any decision to refer the matter to the police and then at fortnightly intervals.
Once cases have been resolved, the responsible person should review the events in order to identify any issues and decide whether school procedures or practices need to be updated or improved so that similar incidents can be prevented or responses improved in the future.
6 Practice issues
6.1 Allegations involving physical contact
For some teachers, for example music and PE teachers, physical contact with a pupil is unavoidable and necessary in order to teach the subject. Guidance on this is available in the schools safeguarding and child protection policy.
Further, teachers can use reasonable force in order to control or restrain a pupil in specific circumstances. Schools should refer to Camden’s guidance on the use of physical restraint and intervention.
These factors must be taken into account at all stages of the process, from initial consideration and strategy discussion. In particular, it must be demonstrated that any contact that has taken place is within the boundaries set out by local safe working practices and agreed procedures for the use of physical restraint.
It is important that staff are provided with and follow school guidance on acceptable behaviour and safe working practice in order to protect them from misplaced or malicious allegations.
Suspension should not be an automatic outcome of any allegation but used only where there is no alternative following a risk assessment and having considered other alternative ways of reducing harm.
Schools should consider the effect of suspension on the member of staff and be mindful that suspension will normally only be justified where there is a risk of significant harm to pupils, a police investigation is likely to be carried out or the allegation is so serious it would normally warrant immediate dismissal if proved true.
Even in these cases, schools should first consider other ways of managing risk, such as arranging for the member of staff to have limited contact with pupils or ensuring they are constantly supervised.
Decisions on suspension should be based on a robust risk assessment and discussed with the LADO in the first instance. CSSW and the police will be able to advise schools on possible courses of action to safeguard pupils and may make a recommendation on suspension but the final decision will rest with the school. All decisions on suspension should continue to be reviewed as new information becomes available during investigation.
If suspension is to be used, the member of staff must be given written confirmation of the decision within 1 working day detailing the reasons and giving the name of the person at the school whom the member of staff can contact for support and information.
Any decision to suspend a member of staff should be recorded by the school and the LADO with reasons given and details of what alternative ways of managing risk other than suspension were considered and why they were rejected.
Full investigations into allegations must proceed even if the person involved resigns as it is important that the matter is properly dealt with and that a resolution or conclusion is reached and appropriate action taken. It is important to decide whether allegations are substantiated and what further action may have to be taken to safeguard children through referral to the Disclosure and Barring Service and the Teaching Regulations Agency even if the staff member involved has left the school.
Schools should not use compromise or settlement agreements that allow a person to resign with a reference in return for not initiating disciplinary proceedings in cases where allegations of abuse of children are involved. As stated above, it is crucial that all allegations are fully investigated and failure to refer to the DBS or TRA when the criteria for doing so are met would be a criminal offence on the part of the school.
6.4 Unfounded or malicious allegations
If an allegation is proved to be unfounded or malicious, the LADO may decide to refer the child to CSSW for assessment as a child in need. Maliciousallegations made by pupils may also be dealt with under the school’sbehaviour policies if this is more appropriate.
6.5 Records and references
All allegations made must be recorded on the individual’s personnel file,giving details of the nature of the allegation, actions taken and decisions reached. This is the case even where the allegation is unfounded. However, the exception to this is any allegation that is proved to be malicious; all references to these allegations should be removed from the personnel record.
It is important that records show clearly how a resolution to the allegation was reached and that this information is available when references are being written or information sought from future employers. Information should be kept on the personnel file until the person reaches retirement age or for 10 years from the date of the allegation if that is longer.
Allegations that have been found to be false, unsubstantiated, or malicious should not be included in a reference, including any repeated concerns that have been found to be false, unsubstantiated or malicious.
Schools can get further advice from the Information Commissioner guidance available at: Employment | ICO
6.6 Confidentiality and information sharing
It is essential that confidentiality is maintained whilst any investigation is on- going and the Police will not make public any details of criminal investigations unless and until the person involved is charged. All those involved, including parents and pupils, must be made aware of the statutory reporting restrictions in place to ensure the identity of the staff member and the victim is not made public. This includes posting information about the allegation on social networking sites.
At the initial discussion, the school representative and the LADO may wish to discuss what information will be shared with whom and what action will be taken to manage any possible breaches of confidentiality or press interest.
In general, information may be shared at the initial discussion and strategy meetings in order to gather as much information as possible to make an informed judgement on what action to take.
Consent must be obtained to share information with third parties, for example police statements or child protection investigations being passed on to schools for the purposes of disciplinary proceedings.
7 Support for those involved
Schools have a duty to support staff members who are being investigated following an allegation in order to minimise stress. Staff should be informed as soon as possible about any allegation made and given all information available, subject to advice from the police and CSSW.
Staff should have a named person available to provide support and information, particularly if they have been suspended, and should be given advice on obtaining legal representation and counselling if needed. They should also be told about the process of any investigation and kept informed of the outcomes and progress of these.
A copy of the CSCB information leaflet “Allegations against staff – what happens next?” should be provided to the member of staff. The leaflet is available here.
Schools should not insist that suspended staff members of staff have no contact with other staff unless there is good reason to believe such contact may interfere with investigations. This is a matter that schools may wish to discuss with the LADO and the Police CAIT.
Schools should also consider the support needs of any member of staff returning to work following suspension once the investigation has been completed.
7.2 Children and parents
The parents of the child should be notified of allegations and given all information available as soon as possible subject to advice from the police and CSSW if there will be an on-going investigation or further action. They should also be kept informed of progress and outcomes of investigations.
Consideration should be given to the impact of the allegation on the child and support put in place. If the child has suffered significant harm or is in need, a referral will be made to CSSW who will assess the child and provide appropriate services and support.
Parents should be informed of any referral to CSSW and their consent sought and should be reminded of the need to maintain confidentiality about the allegation while the matter is under investigation.
7.3 Supply teachers
Schools should be aware that supply teachers and others who are not directly employed by the school will still be subject to these procedures and any allegations made against these staff must be investigated in the same way, even if the school decides to end the staff member’s contract of employment.
The school should take the lead in referring the matter and investigating the allegation in partnership with the LADO under these procedures but employment agencies and others are expected to co-operate and should be invited to the strategy discussion to ensure their role is clarified.
Schools should ensure that supply teachers and others are aware of their right to support from a trade union or colleague during the investigation process.
Appendix 4: School central record
This record should indicate what checks have been taken out for the following:
- For schools, all staff, including supply staff and teacher trainees on salaried routes, who work in school and others who work in regular contact children in school, including volunteers
- For independent schools, including academies and free schools as above plus all members of the proprietorial body and involved in the management of the school
- For colleges, all staff providing education and/or whose positions involve a relevant activity
Please give details of confirmation of checks that have been carried out by the supplying agency.
- Unsupervised volunteers should not be left alone or allowed to work in regulated activity.
- For new volunteers in regulated activity who regularly teach children unsupervised an enhanced DBS is needed with a barred list check.
- For new volunteers not in regulated activity, schools should obtain an enhanced DBS certificate.
- Existing volunteers who provide personal care, the school should consider obtaining an enhanced DBS.
- Existing volunteers who are unsupervised do not need to have a DBS check with a barred list check because the volunteer should have been checked originally.
- For existing volunteers not in regulated activity there is no requirement for an enhanced DBS check (a school can request one but may not request a check of the barred list).
- For a volunteer not engaging in regulated activity a risk assessment should be made and a professional judgement made about the need for an enhanced DBS check.
- Supervision of volunteers – there must be supervision by a person in regulated activity, where supervision occurs, this must be regular and day to day and the supervision must be reasonable in all the circumstances to ensure the protection of children.
Regulated activity (see p20 for definition) – the period condition is at any time on more than three days in any period of 30 days. ‘Frequently’ is doing something once a week or more. Work of the nature defined is considered regulated activity if done regularly; where this is the case an enhanced DBS check is needed with a barred list check.
Contractors or employees of contractors working at the school should have the appropriate level of DBS check if a check is required, eg if the contractor is carrying out teaching or providing a level of care or supervision of children regularly.
Documents and certificates
Please give details of any documentary evidence obtained as part of each check. Please note that there is no requirement to list DBS numbers. Also, to comply with the Data Protection, DBS certificates should not be retailed any longer than six months. Other documents to verify identity, right to work in the UK etc, should be kept in personnel files.
Record of checks taken out and/or certificates obtained
Date of service
Position held/regulated activity?
Evidence of identity: (name of person carrying out check and date of check)
Barred list check (date and name of person carrying out check)
Enhanced DBS check (date and name of person carrying out check)
Prohibition from teaching check (date and name of person carrying out check)
Prohibition from management of schools under section 128 check (independent and free schools and academies only)
Checks on persons from overseas (date and name of person carrying out check)
Checks on professional qualifications/Certificates obtained (date and name of person carrying out check)
Checks on right to work in the UK/documents obtained (date and name of person carrying out check)
For supply staff, evidence from the employment agency that relevant checks have been carried out (date of confirmation and name of school staff checking)