Safeguarding Policy

KEY CONTACT DETAILS 

East Sussex LADO officer: Donna Tomlinson

West Sussex LADO officer: Miriam Williams

Sophie Jackson: Tribunal officer 

 

Contents: 

  1. Policy Statement and Intent 
  2. Definitions and types of abuse 
  3. Roles and Responsibilities 
  4. Concerns about a child 
  5. Child on Child abuse 
  6. Contextual Safeguarding 
  7. TutorsAllegations
  8. Management of Safeguarding 
  9. Technology
  10. Vulnerable Groups 

Appendices – definitions and details, external contacts

This policy applies to Roxstar (sole trader).

 

This policy is reviewed annually

         1.1       Policy statement 

This policy has regard to the following guidance and advice, as amended from time to time (and any supplemental guidance/advice referred to therein): 

  • Children Act 1989
  • Children Act 2004
  • Safeguarding Vulnerable Groups Act 2006
  • The Education (School Teachers’ Appraisal) (England) Regulations 2012
  • Sexual Offences Act 2003
  • Female Genital Mutilation Act 2003 (as inserted by the Serious Crime Act 2015)
  • Apprenticeships, Children and Learning Act 2009
  • Equality Act 2010
  • Counter-Terrorism and Security Act 2015
  • The UK General Data Protection Regulation (UK GDPR)
  • Data Protection Act 2018
  • The Childcare (Disqualification) and Childcare (Early Years Provision Free of Charge)

(Extended Entitlement) (Amendment) Regulations 2018

  • Voyeurism (Offences) Act 2019
  • Domestic Abuse Act 2021 Statutory guidance
  • DfE (Department for Education) (2015) ‘The Prevent duty’
  • DfE (Department for Education) (2018) ‘Working Together to Safeguard Children’
  • DfE (Department for Education) (2018) ‘Disqualification under the Childcare Act 2006’
  • DfE (Department for Education) (2023) ‘Keeping children safe in education 2023’
  • HM Government (2020) ‘Multi-agency statutory guidance on female genital mutilation’
  • HM Government (2021) ‘Channel Duty Guidance: Protecting people vulnerable to being drawn into terrorism’
  • Home Office and Foreign, Commonwealth and Development Office (2022) ‘Multiagency statutory guidance for dealing with forced marriage and Multi-agency practice guidelines: Handling cases of forced marriage’ Non-statutory guidance
  • DfE (Department for Education) (2015) ‘What to do if you’re worried a child is being abused’
  • DfE (Department for Education) (2017) ‘Child sexual exploitation’
  • DfE (Department for Education) (2018) ‘Information sharing’
  • DfE (Department for Education) (2020) ‘Sharing nudes and semi-nudes: advice for education settings working with children and young people’
  • DfE (Department for Education) (2021) ‘Teachers’ Standards’
  • DfE (Department for Education) (2022) ‘Recruit teachers from overseas’
  • Department of Health and Social Care (2022) ‘Virginity testing and hymenoplasty: multi- agency guidance’
  • KCSiE Keeping children safe in education (2023)

1.2 Intent 

Safeguarding and promoting the welfare of children is everyone’s responsibility. 

Everyone who comes into contact with children and their families has a role to play to identify concerns, share information and take prompt action. 

All practitioners must ensure their approach is child-centered. This means considering, at all times, what is in the best interests of the child. 

Roxstar (sole trader) has a holistic approach to safeguarding and child protection. 

2.1 Definitions of Safeguarding and Types and Signs of Abuse 

Safeguarding and promoting the welfare of children is defined as: 

  • protecting children from maltreatment 
  • preventing impairment of children’s health or development 
  • ensuring that children grow up in circumstances consistent with the provision of safe and effective care 
  • taking action to enable all children to have the best outcomes. 

Abuse is a form of maltreatment of a child. Somebody may abuse, exploit, 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, by their peers, or, more rarely, by others (e.g. via the internet). 

Technology is a significant component in many safeguarding and well-being issues. 

Abuse can take place wholly online, or technology may be used to facilitate offline abuse. In many cases abuse will take place concurrently via online channels and in daily life. They may be abused by an adult or adults or by another child or children. Abuse can be: 

  • physical abuse 
  • emotional abuse 
  • sexual abuse; 
  • neglect

 

If a child is subject to harassment, violence or abuse, this may breach their rights as set out in the Human Right’s Act.  

All tutors must be aware of indicators of abuse and neglect.

For types and signs of abuse and neglect, see Appendix 1 

Tutors are referred to Appendix 1 of this policy for further detail of the types of abuse and possible signs of abuse. 

Tutorsmust always be vigilant and raise any concerns with the LADO or DLADO. 

3.1 Roles and responsibilities: All tutors

All tutors have a responsibility to: 

  • Consider, at all times, what is in the best interests of the student.
  • Maintain an attitude of ‘it could happen here’ where safeguarding is concerned.
  • Provide a safe environment in which students can learn.
  • Be prepared to identify students who may benefit from early help.
  • Be aware of systems which support safeguarding, including any policies, procedures, information and training provided upon induction.
  • Be aware of the role and identity of the LADO (Designated Safeguarding Lead) and deputy LADOs (Designated Safeguarding Leads).
  • Undertake safeguarding training, including online safety training, during their induction – this will be regularly updated. 
  • Receive and understand child protection and safeguarding (including online safety) updates, e.g. via email, as required, and at least annually.
  • Be aware of the local early help process and understand their role in it.
  • Be aware of, and understand, the process for making referrals to CSCS (Children’s Social Care Services), as well as for making statutory assessments under the Children Act 1989 and their role in these assessments.
  • Make a referral to CSCS (Children’s Social Care Services) and/or the police immediately, if at any point there is a risk of immediate serious harm to a child.
  • Support social workers in making decisions about individual children, in collaboration with the LADO (Designated Safeguarding Lead)
  • Be aware of and understand the procedure to follow in the event that a child confides they are being abused, exploited or neglected.
  • Be aware that a pupil may not feel ready or know how to tell someone that they are being abused, exploited or neglected, and/or may not recognise their experiences as harmful.
  • Maintain appropriate levels of confidentiality when dealing with individual cases.
  • Reassure victims that they are being taken seriously, that they will be supported, and that they will be kept safe.
  • Speak to the LADO (Designated Safeguarding Lead) if they are unsure about how to handle safeguarding matters.
  • Be aware of safeguarding issues that can put students at risk of harm.
  • Be aware of behaviours that could potentially be a sign that a pupil may be at risk of harm.

3.2 Roxstar (sole trader) has a responsibility to: 

  • Safeguard students’ wellbeing and maintain public trust in the teaching profession as part of their professional duties, as outlined in the ‘Teachers’ Standards’.
  •  

3.3 Roxstar (sole trader) has a duty to:

  • Take strategic leadership responsibility for safeguarding arrangements.
  • Ensure that it complies with its duties under the above child protection and safeguarding legislation.
  • Guarantee that the policies, procedures and training opportunities in Roxstar (sole trader) are effective and comply with the law at all times.
  • Guarantee that Roxstar (sole trader) contributes to multi-agency working in line with the statutory guidance ‘Working Together to Safeguard Children’.
  • Confirm that Roxstar (sole trader)’s safeguarding arrangements take into account the procedures and practices of the LA as part of the inter-agency safeguarding procedures.
  • Understand the local criteria for action and the local protocol for assessment, and ensure these are reflected in Roxstar (sole trader)’s procedures.
  • Comply with its obligations under section 14B of the Children Act 2004 to supply the local safeguarding arrangements with information to fulfil its functions.
  • Ensure that tutors working directly with children read at least Part one of KCSIE.
  • Ensure that tutors who do not work directly with children read either Part One or Annex A of KCSIE. NB: Individual schools assess which guidance will be most effective for their tutorsto safeguard and promote the welfare of children.
  • Ensure that mechanisms are in place to assist tutors in understanding and discharging their role and responsibilities in regard to safeguarding children.
  • Where there is a safeguarding concern, ensure the child’s wishes and feelings are considered when determining what action to take and what services to provide.
  • Ensure systems are in place, children to confidently report abuse, knowing that their concerns will be treated seriously, and they can safely express their views and give feedback; these systems will be well-promoted, easily understood, and easily accessible.
  • Ensure that tutors have due regard to relevant data protection principles that allow them to share and withhold personal information.
  • Guarantee that there are effective and appropriate procedures in place.
  • Make sure that students are aware of safeguarding, including protection against dangers online (including when they are online at home).
  • Adhere to statutory responsibilities by conducting pre-employment checks on tutors who work with children, taking proportionate decisions on whether to ask for any checks beyond what is required.
  • Ensure that tutors are appropriately trained to support students to be themselves, e.g. if they are LGBTQ+.
  • Ensure Roxstar (sole trader) has clear systems and processes in place for identifying possible mental health problems in students, including clear routes to escalate concerns and clear referral and accountability systems.
  • Guarantee that volunteers are appropriately supervised.
  • Certify that there are procedures in place to handle allegations against staff, supply staff, volunteers and contractors.
  • Guarantee that there are procedures in place to handle students’ allegations against other students.
  • Ensure that appropriate disciplinary procedures are in place, as well as policies pertaining to the behaviour of students and staff.
  • Ensure that procedures are in place to eliminate unlawful discrimination, harassment and victimisation, including those in relation to child-on-child abuse.
  • Guarantee that there are systems in place for students to express their views and give feedback.
  • Establish an early help procedure and ensure all tutors understand the procedure and their role in it.
  • Ensure that all members of Roxstar (sole trader) have been subject to an enhanced DBS (Disclosure and Barring Service) check.
  • Be aware of their obligations under the Human Rights Act 1998, the Equality Act 2010 (including the Public Sector Equality Duty), Data Protection Act 2018, the UK GDPR and the local multi-agency safeguarding arrangements.

 

3.4 The LADO (Designated Safeguarding Lead) has a duty to:

  • Take lead responsibility for safeguarding and child protection, including online safety and filtering and monitoring.
  • Provide advice and support to other tutors on child welfare, safeguarding and child protection matters.
  • Take part in strategy discussions and inter-agency meetings, and/or support other tutors to do so.
  • Contribute to the assessment of children, and/or support other tutors to do so.
  • Refer cases: - To CSCS (Children’s Social Care Services) where abuse and neglect are suspected, and support tutors who make referrals to CSCS (Children’s Social Care Services). - To the Channel programme where radicalisation concerns arise, and support tutors who make referrals to the Channel programme. - To the DBS (Disclosure and Barring Service) where a person is dismissed or has left due to harm, or risk of harm, to a child. To the police where a crime may have been committed, in line with the National Police Chiefs’ Council (NPCC) guidance.
  • Act as a source of support, advice and expertise for all staff.
  • Act as a point of contact with the safeguarding partners.
  • Liaise with the LADO to inform them of issues, especially regarding ongoing enquiries under section 47 of the Children Act 1989 and police investigations.
  • Liaise with the case manager and the LA designated officers (LADOs) for child protection concerns in cases concerning staff.
  • Liaise with tutors on matters of safety, safeguarding and welfare, including online and digital safety.
  • Liaise with tutors when deciding whether to make a referral by liaising with relevant agencies so that children’s needs are considered holistically. 
  • Liaise with the senior mental health lead and, where available, the mental health support team, where safeguarding concerns are linked to mental health. 
  • Promote supportive engagement with parents in safeguarding and promoting the welfare of children, including where families may be facing challenging circumstances. 
  • Ensure each member of tutors has access to and understands Roxstar (sole trader)’s Child Protection and Safeguarding Policy and procedures – this will be discussed during the tutor induction process. 

Roxstar (sole trader) Child Protection and Safeguarding Policy is reviewed annually, and the procedures are updated and reviewed regularly.

 

  • Ensure Roxstar (sole trader) s’s Child Protection and Safeguarding Policy is available upon request, and parents know that Roxstar (sole trader) may make referrals for suspected cases of abuse or neglect.
  • Link with safeguarding partner arrangements to make sure that tutors are aware of the training opportunities available and the latest local policies on safeguarding. 
  • Undergo training and update this training at least every two years. 
  • Obtain access to resources and attend any relevant or refresher training courses. 
  • Encourage a culture of listening to children and taking account of their wishes and feelings; this includes understanding the difficulties students may have in approaching tutors about their circumstances and considering how to build trusted relationships that facilitate communication. 

Support and advise tutors and help them feel confident on welfare, safeguarding and child protection matters: specifically, to ensure that tutors are supported during the referral processes; and to support tutors to consider how safeguarding, welfare and educational 

 

  • Understand relevant data protection legislation and regulations, especially the Data Protection Act 2018 and the UK GDPR. 

4.1 Concerns about a child: overview 

Roxstar (sole trader) has a duty to consider at all times the pupil's best interests and take action to enable all students to achieve the best outcomes. 

Safeguarding and promoting the welfare of children is everyone’s responsibility. Everyone has a role to play in identifying concerns, sharing information and taking prompt action in accordance with this policy. 

Tutors will work with social workers and other agencies following any referral. 

All tutors will be aware that children may not feel ready or know how to tell someone that they are being abused, exploited, or neglected, and/or they may not recognise their experiences as harmful. For example, children may feel embarrassed, humiliated, or being threatened. This could be due to their vulnerability, disability and/or sexual orientation or language barriers. This will not prevent tutors from having a professional curiosity and speaking to the LADO if they have concerns about a child. 

If tutors suspect or hear an allegation or concern of abuse or neglect from a child or any third party, they must follow the relevant procedure below. 

All tutors will: 

  • listen carefully 
  • avoid asking leading questions 
  • reassure the individual that the allegation/complaint will be taken seriously 
  • not guarantee confidentiality and explain to the child that tutors will only share the information with those who need to know to help the child. 
  • explain next steps and who the information will be passed to. 

A victim must never be given the impression that they are creating a problem by reporting abuse, sexual violence or sexual harassment, nor will a victim ever be made to feel ashamed for making a report. 

All concerns, discussions and decisions (together with reasons) made under these procedures will be recorded in writing. 

Tutors will use the safeguarding LADO to record safeguarding concerns. These are then reviewed by a member of the safeguarding team and actions / decision- making recorded. Tutors are aware that their initial record will include the place of the conversation and detail of what was said and done by whom and in whose presence and signed by the person making it. 

Where a report includes online elements, tutors are reminded not to view or forward any illegal images of a child but note what has been reported. 

Where there is a safeguarding concern, Roxstar (sole trader) will ensure the pupil’s wishes and feelings are taken into account wherever possible and will work with them (and their families where appropriate) when determining what action to take and what services to provide. 

This is particularly important in the context of harmful sexual behaviours, such as sexual harassment and violence. 

Roxstar (sole trader) manages this by ensuring that the pupil’s voice is heard throughout the process. 

4.2 Concerns about a child: Information Sharing 

Information sharing is vital in identifying and tackling all forms of abuse and neglect, and in promoting children’s welfare, including their educational outcomes. Schools have clear powers to share, hold and use information for these purposes. 

Roxstar (sole trader) will ensure tutors comply with the relevant data protection principles when processing and sharing personal information, as provided for in the Data Protection Act 2018 and the UK GDPR. As part of this, Roxstar (sole trader) will ensure that members of staff: 

  • are confident of the processing conditions which allow them to process and share information for safeguarding purposes, including information which is ‘special category personal data’. 
  • understand that ‘safeguarding of children and individuals at risk’ is a processing condition that allows practitioners to share special category personal data without consent in certain circumstances. 
  • do not provide students’ personal data where the sharing does not comply with data protection law. 

Roxstar (sole trader) will comply with all data protection law and have due regard to the ‘Information sharing advice for safeguarding practitioners’ (2018), and the relevant provisions of KCSIE when sharing such data. 

Safeguarding information will often be special category personal data and Roxstar (sole trader) will have due regard to its data protection obligations when sharing such data. Personal information may be shared by Roxstar (sole trader) with a third party (such as the police or local authority) without consent if there is a lawful basis to do so such as where doing so is in order to promote a child’s welfare or where their safety may be at risk. This is because the Data Protection Act 2018 includes ‘safeguarding children and individuals at risk’ as a condition that allows information to be shared without consent in certain circumstances. Any decision to share or withhold information will be recorded including details of who the data has been shared with and reasons for sharing. 

4.3: Concerns about a child: Roxstar (sole trader) action 

If tutors have a concern about child’s welfare they will act immediately and will speak with Roxstar (sole trader) or LADO

If, in exceptional circumstances, Roxstar (sole trader) or LADO is not available, this will not delay appropriate action being taken and tutors will consider speaking to a member of the police or seek advice from local children’s social care. 

The LADO will consider the appropriate action to take in accordance with the threshold document published by the LEA

  • making an early help assessment; or 
  • making a referral for statutory services and / or 
  • making a referral to the police. 

If a child’s situation does not appear to be improving, the LADO (or the person that made the referral) will consider following local escalation procedures to ensure their concerns have been addressed and to ensure that the child’s situation improves. 

Tutors will not assume a colleague or another professional will take action and share information that might be critical in keeping children safe. 

They will be mindful that early information sharing is vital for effective identification, assessment and allocation of appropriate service provision, whether this is when problems are first emerging, or where a child is already known to local authority children’s social care (such as on a child in need or child protection plan). Tutors will challenge any inaction and follow this up with the LADO and children’s social care as appropriate. 

All concerns, discussions and decisions made and the reasons for those decisions will be recorded in writing on CPOMS. 

4.4 Concerns about a child: Early Help 

Early help means providing support as soon as a problem emerges at any point in a child's life, from the foundation years through to the teenage years. Any child may benefit from early help but all tutors will be particularly alert to the potential need for early help for a child who: 

  • has a disability or has certain health conditions and has specific additional needs; 
  • Has special educational needs (whether or not they have a statutory education, health and care plan); 
  • has a mental health need; 
  • Is a young carer; 
  • Is showing signs of being drawn in to anti-social or criminal behaviour, including gang involvement and association with organised crime groups or county lines; 
  • Is frequently missing/goes missing from care or from home; Is misusing drugs or alcohol themselves; 
  • Is at risk of modern slavery, trafficking, sexual or criminal exploitation 
  • Is at risk of being radicalised or exploited; 
  • Has a family member (carer/guardian) in prison, or is affected by parental offending; 
  • Is in a family circumstance presenting challenges for the child, such as drug and alcohol misuse, adult mental health issues or domestic abuse; 
  • Has returned home to their family from care; 
  • Is at risk of honour-based abuse such as Female Genital Mutilation or Forced Marriage; Is a privately fostered child. 

 

All tutors will be aware that behaviours linked to drug taking and/or alcohol misuse, deliberately missing education and consensual and non-consensual sharing of nudes and semi nudes images and/or videos can be signs that children are at risk from exploitation. 

In the first instance, tutors who consider that a pupil may benefit from early help will discuss this with Roxstar (sole trader) or LADO 

If early help is appropriate, the LADO will generally lead on liaising with relevant agencies and setting up inter-agency assessment as appropriate. 

Tutors may be required to support other agencies and professionals in an early help assessment, in some cases acting as the lead professional. The LADO will support tutors in liaising with external agencies and professionals in an inter- agency assessment, as appropriate. If early help is appropriate, the matter will be kept under constant review and consideration given to a referral to children's social care if the pupil's situation does not appear to be improving or is getting worse. 

4.5 Concerns about a child: urgent concerns 

If tutors believe that a child is suffering, or is likely to suffer from harm, or is in immediate danger it is important that an immediate referral to children’s social care (and/or the Police if appropriate).

If anyone other than the Roxstar (sole trader) makes a referral, they will inform the LADO as soon as possible that a referral has been made Children’s social care assessments will consider where children are being harmed in contexts outside the home, so it is important to provide as much information as possible as part of the referral process, to enable a contextual approach (see further below re Contextual Safeguarding.) 

Roxstar (sole trader) local safeguarding outreaches are East Sussex, Brighton and Hove, West Sussex County Council and The Chief Constable of Sussex Police. 

4.6 Concerns about a child: Radicalisation 

Tutors will follow Roxstar (sole trader)’s normal referral processes when there are concerns about children who may be at risk of being drawn into terrorism, as set out above. This may include a referral to Prevent and/or children’s social care depending on the level of risk. 

If tutors have concerns that there is an immediate/significant risk of a child being drawn into terrorism they must call 999 or 101 and ask for the Police Prevent team. 

Tutors may also submit a referral form to MASH or call them directly. Advice and support can also be sought from children’s social care. 

Roxstar (sole trader), in recognition that students may be at risk of being drawn into terrorism or other forms of extremism, carries out appropriate risk assessments (following consultation with local partners, such as the Police) of the potential risk in the local area. 

Risk assessments are discussed with Roxstar (sole trader) for safeguarding to ensure tutors safeguarding arrangements are sufficiently robust to help prevent and protect children from being drawn into terrorism and are regularly revised. 

See further below for more information on radicalisation. Further guidance can be found in the Revised Prevent duty guidance: for England and Wales April 2021. 

4.6 Concerns about a child: Female Genital Mutilation (FGM) 

All tutors will speak to the Roxstar (sole trader) or LADO or immediately about any concerns about FGM. 

Teaching tutors have a separate duty to report to the Police cases where they discover that an act of FGM appears to have been carried out on a girl under the age of 18. 

All tutors are referred to Appendix 1 of this policy for the procedure to be followed where they suspect or discover that a pupil may be at risk of FGM. 

4.7 Concerns about a child: Child missing from education (CME) 

Children who go missing from education, particularly persistently, can act as a vital warning sign to a range of safeguarding issues including neglect, sexual abuse and child sexual and criminal exploitation. 

Tutors will report any concerns to the relevant LADO. 

5.1 Child on Child abuse: overview 

Child-on-child abuse is any form of physical, sexual, emotional and financial abuse, and coercive control, exercised between children and within children's relationships (both intimate and non-intimate). 

All tutors working with children are advised to maintain an attitude of “it could happen here”. Tutors will recognise that even if there are no reports, it does not mean that child-on-child abuse is not happening, it may be the case that it is just not being reported. 

This is most likely to include, but may not be limited to: 

  • abuse in intimate personal relationships between peers; 
  • bullying (including cyberbullying); 
  • physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse) 
  • Sexual violence, such as rape assault by penetration and sexual assault (this may include an online element which facilitates, threatens and/or encourages sexual violence) 
  • Sexual harassment, such as sexual comments, jokes and online sexual harassment, or misogynistic messages which may be stand alone or part of a broader pattern of abuse; 
  • The non-consensual sharing of indecent images*, especially around chat groups, and the sharing of abusive images, nudes, videos and pornography to those who do not want to receive it (see further below). 
  • Causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party; 
  • Initiation/hazing type violence and rituals (this could include activities involving harassment, 
  • abuse or humiliation used as a way of initiating a person into a group and may also include an online element); 
  • 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. 

Even if there are no reported incidents in school it does not mean it is not happening, it may be the case that it is just not being reported. As such, if tutors have any concerns regarding child-on-child abuse, they will speak to their designated safeguarding lead (or deputy). 

Child-on-child abuse can be associated with factors outside Roxstar (sole trader) and can occur online and face-to-face between two or more children of any age or gender. Roxstar (sole trader) therefore takes a contextual safeguarding approach to managing child-on-child abuse. 

Child-on-child abuse is abuse and is never acceptable. 

Roxstar (sole trader) approach to sexting is guided by the advice for schools: responding to and managing sexting incidents published by SWGFL and the UK safer internet centre READ HERE.

All incidents are recorded and the response of Roxstar (sole trader) is decided based on guidance above. Outside agencies including police and social care are involved as appropriate or necessary. 

Where an issue of pupil behaviour or bullying gives ‘reasonable cause to suspect that a child is suffering, or is likely to suffer, significant harm’, tutors will refer to Roxstar (sole trader) or LADO.

5.2 Child on Child abuse: Concern Procedure 

For detailed information on what sexual violence and sexual harassment constitutes, important context to be aware of, related legal responsibilities for schools and colleges, advice on a whole school or college approach to preventing child on child sexual violence and sexual harassment and more detailed advice on responding to reports see the 

Department for Education’s statutory guidance: Keeping Children Safe in Education 

(2023), Part 5 – Child-on-child sexual violence and sexual harassment 

Key Principles 

  • It is essential that all victims are reassured that they are being taken seriously, regardless of how long it has taken them to come forward and that they will be supported and kept safe. 
  • Abuse that occurs online will not be downplayed and will be treated seriously. All tutors will be able to reassure victims that they are being taken seriously and that they will be supported and kept safe. 
  • A victim will never be given the impression that they are creating a problem by reporting abuse, sexual violence or sexual harassment. Nor will a victim ever be made to feel ashamed for making a report. 
  • It is important to explain that the law is in place to protect children and young people rather than criminalise them, and this will be explained in such a way that avoids alarming or distressing them. 

It is important to note that children may not find it easy to tell tutors about their abuse verbally. Children can show signs or act in ways that they hope adults will notice and react to. 

If tutors have any concerns about a child’s welfare, they will act on them immediately rather than wait to be told. 

Effective report management involves: 

  • not promising confidentiality at this initial stage as it is very likely a concern will have to be shared further (for example, with the designated safeguarding lead or children’s social care) to discuss next steps. Tutors will only share the report with those people who are necessary in order to progress it. It is important that the victim understands what the next steps will be and who the report will be passed to; 
  • recognising that a child is likely to disclose to someone they trust: this could be anyone. It is important that the person to whom the child discloses recognises that the child has placed them in a position of trust. They will be supportive and respectful of the child; 
  • recognising that an initial disclosure to a trusted adult may only be the first incident reported, rather than representative of a singular incident and that trauma can memory and so children may not be able to recall all details or timeline of abuse; 
  • keeping in mind that certain children may face additional barriers to telling someone because of their disability, sex, ethnicity and/or sexual orientation; 
  • listening carefully to the child, reflecting back, using the child’s language, being non- judgmental, being clear about boundaries and how the report will be progressed, not asking leading questions and only prompting the child where necessary with open questions – where, when, what, etc. It is important to note that whilst leading questions will be avoided, tutors can ask children if they have been harmed and what the nature of that harm was; 
  • considering the best way to make a record of the report. 
  • Best practice is to wait until the end of the report and immediately write up a thorough summary. This allows the tutors member to devote their full attention to the child and to listen to what they are saying. It may be appropriate to make notes during the report (especially if a second member is present). However, if making notes, tutors will be conscious of the need to remain engaged with the child and not appear distracted by the note taking. 
  • only recording the facts as the child presents them. The notes will not reflect the personal opinion of the note taker. Tutors will be aware that notes of such reports could become part of a statutory assessment by children’s social care and/or part of a criminal investigation; 
  • where the report includes an online element, being aware of searching screening and confiscation advice and UKCIS guidance on Sharing nudes and semi-nudes: advice for education settings working with children and young people. 
  • informing the Roxstar (sole trader)  or LADO as soon as practically possible.

The procedures set out below will be reviewed, at least annually, in light of an assessment of the impact and effectiveness of the policy. 

Roxstar (sole trader) treats all children involved as being at potential risk and ensures a safeguarding response is in place for both the child who has allegedly experienced the abuse, and the child who has allegedly been responsible for it. Immediate consideration will therefore be given as to how best to support and protect all children involved/impacted. 

In the event of disclosures about child-on-child abuse, all children involved will be treated as being at risk and the safeguarding procedures. This means that if a member of Roxstar (sole trader) thinks for whatever reason that a child may be at risk of or experiencing abuse by their peer(s), or that a child may be at risk of abusing or may be abusing their peer(s), they will discuss their concern with the LADO without delay so that a course of action can be agreed. 

Roxstar (sole trader) recognises that a child is likely to disclose an allegation to someone they trust: this could be any member of staff. By making such a disclosure the pupil is likely to feel that the member of staff is in a position of trust. 

All concerns/allegations of child-on-child abuse will be handled sensitively, appropriately and promptly and will be investigated including consideration of the wider context in which it may have occurred (as appropriate). 

Roxstar (sole trader) will take into account the views of the child/children affected. Unless it is considered unsafe to do so, the LADO will discuss the proposed action with the child/children and their parents following appropriate liaison with children’s social care. Roxstar (sole trader) will manage the child/children's expectations about information sharing, and keep them and their parents informed of developments, where appropriate and safe to do so. 

All children affected by child-on-child abuse will be supported by Roxstar (sole trader) and the LADO

Support from external agencies will be sought, as appropriate. 

“Victims” will be reassured that they are being taken seriously and that they will be supported and kept safe. 

Roxstar (sole trader) recognises that children with special educational needs and disabilities can be more prone to child on child group isolation than other children and will consider extra pastoral support for those children additionally through the inclusion team. 

Roxstar (sole trader) will take advice from the LCSP on the investigation of such allegations and will take all appropriate action to ensure the safety and welfare of all students involved including the alleged victim and alleged perpetrator. 

If it is necessary for a pupil to be interviewed by the Police in relation to allegations of abuse, Roxstar (sole trader) will ensure that, subject to the advice of the LCSP, parents are informed as soon as possible and that the students involved are supported during the interview by an appropriate adult and until the investigation is completed. 

Confidentiality will be an important consideration for Roxstar (sole trader) and advice will be sought as necessary from the LCSP and/ or the Police as appropriate. 

5.3 Harmful Sexual Behaviour: Reporting 

Consideration of safeguarding all those children involved in the safeguarding report will be immediate. 

Following a report of sexual violence and/or sexual harassment the LADO will therefore consider the appropriate response. This will include: 

  • The wishes of the victim in terms of how they want to proceed; 
  • The nature of the alleged incident, including whether a crime may have been committed and/or whether harmful sexual behaviour has been displayed; 
  • The ages of the children involved; 
  • The developmental stages of the children involved; 
  • Any power imbalance between the children (e.g. is/are the alleged perpetrator(s) significantly older, more mature, confident and well known social standing? Does the victim have a disability or learning difficulty); 
  • If the alleged incident is a one-off or sustained pattern of abuse (NB. sexual abuse can be accompanied by other forms of abuse and a sustained pattern may not just be of a sexual nature); 
  • That sexual violence and sexual harassment can take place within intimate personal relationships between children; 
  • Any ongoing risks to the victim, other children, adult students, or school/college staff; Importance of understanding intra familial harms and any necessary support for siblings following incidents; 
  • Other related issues and wider context, including any links to child sexual exploitation and child criminal exploitation. 

When there has been a report of sexual violence, the LADO will make an immediate risk and needs assessment in respect of each child affected by the abuse. 

Where there has been a report of sexual harassment, the need for a risk assessment will be considered on a case-by-case basis. The risk and needs assessment will consider: 

  • the victim; 
  • the alleged alleged perpetrator; and 
  • the other children (and, if appropriate, staff) at Roxstar (sole trader). 

The LADO will consider as part of Roxstar (sole trader) response, the context within which such incidents and/or behaviours occur and the importance of anonymity. 

The LADO will consider the risks posed to all students and put adequate measures in place to protect them and keep them safe. This may include consideration of the proximity of the victim and alleged alleged perpetrator and considerations regarding shared classes, sharing school premises and school transport. Any professional risk assessment will inform Roxstar (sole trader) approach. 

The police may be informed of any harmful sexual behaviours including sexual violence and sexual harassment which are potentially criminal in nature, such as grabbing bottoms, breasts and genitalia. Rape, assault by penetration and sexual assaults will be passed to the police. A report to the police will generally be made in parallel with a referral to children’s social care. 

If the LADO decides to make a referral to children’s social care and/or a report to the police against a victim’s wishes, the reasons will be explained to the pupil and appropriate specialist support offered. The LADO or will also work closely with children’s social care and other agencies are required to ensure any action taken under this policy does not jeopardise any statutory investigation and to discuss how the alleged perpetrator, staff, parents and others will be informed of the allegations and what information can be disclosed bearing in mind the need to protect those involved and their anonymity. 

The LADO will ensure that where children move to another educational institution following an incident of child-on-child abuse, the new institution is made aware of any ongoing support needs and, where appropriate, any potential risks to other children and staff. 

6.1 Contextual Safeguarding 

All tutors will be aware that safeguarding incidents and/or behaviours can be associated with factors outside Roxstar (sole trader) can occur between children outside of these environments. 

All staff will 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. 

7.1 Tutors Allegations: Whistleblowing 

Where tutors have concerns about poor or unsafe practices and potential failures in Roxstar (sole trader) safeguarding regimes, these will be raised with the LADO.

If tutors feel unable to raise an issue with Roxstar (sole trader), feel that their genuine concerns are not being (or have not been) addressed or are concerned about the way a concern is being handled, they may use other whistleblowing channels, such as the NSPCC whistleblowing helpline.. Contact details for the NSPCC helpline can be found on the Key Contacts page at the start of this policy. 

7.2 Tutors Allegations: tutors including visiting and contracted tutors

Roxstar (sole trader) procedures for managing concerns/ allegations against tutors who are currently working in Roxstar (sole trader) follows Department for Education statutory guidance and local safeguarding partners’ arrangements and applies when tutors(including supply staff, volunteers and contractors) have (or are alleged to have): 

  • Behaved in a way that has harmed a pupil or may have harmed a pupil; and/or 
  • Possibly committed a criminal offence against or related to a pupil; and/or 
  • Behaved towards a pupil in a way that indicated that they may pose a risk of harm if they were to work regularly or closely with children; and/or. 
  • behaved or may have behaved in a way that indicates they may not be suitable to work with children (including behaviour that may have happened outside school, that might make them unsuitable to work with children “transferable risk”. Advice can be sought from the LADO in assessing transferable risk). 

7.3 Tutors Allegations - Non-recent allegations 

Allegations against an adult that is no longer working/volunteering with children will be referred to the Police. Where it is known that the adult is still working/volunteering with children, all allegations (including historical/non-recent allegations of abuse) will be referred to the Police and also the LADO in the local authority that the adult is working/volunteering. 

Where an adult makes an allegation to a school that they were abused as a child, they will be advised to report the allegation to the police. Non-recent allegations made by a child, will be reported to the LADO in line with the local authority’s procedures for dealing with non-recent allegations. Abuse can be reported no matter how long ago it happened. 

If an allegation is made against anyone working with children in Roxstar (sole trader), Roxstar (sole trader)/LADO will not undertake their own investigation of allegations without prior consultation with the Local Authority ‘designated officer’ (LADO) or, in the most serious cases, the Police, so as not to jeopardise statutory investigations. In borderline cases, Roxstar (sole trader) may discuss informally with the Local Authority ‘designated officer’ on a no-names basis (if local procedures allow). 

 

All allegations will be investigated as a priority to avoid any delay. 

7.4 Tutors Allegations: when they may meet the harms threshold 

Where Laura Evenstar is absent or is the subject of the allegation or concern, reports will be made to LADO. 

Where Roxstar (sole trader) is the subject of the allegation or concern, the LADO must be informed of the allegation.

  1. Welfare of the child: Where the case manager deems that a child has been harmed, or there to be an immediate risk of harm to a child, or if the situation is an emergency, the LADO will contact Children’s Social Care and, as appropriate (e.g. if there is evidence of a possible criminal offence), the Police immediately. 
  2. Investigating and supporting the person subject to the allegation: Before contacting the LADO, Roxstar (sole trader) will conduct basic enquiries in line with local procedures to establish the facts and help determine if there is any foundation to the allegation, being careful not to jeopardise any future police investigation, such as: 
    • Was the individual in a session at the time of the allegation? 
    • Could they have come into contact with the child? 
    • Roxstar (sole trader) will establish what initial information the LADO will require, and if in doubt check with the LADO before undertaking any initial enquiries, to ensure not to prejudice the position. 
  3. The case manager will immediately discuss the allegation with the LADO and consider the nature, content and context of the allegation and agree a course of action including any involvement of the Police. The designated officer will be informed within one working day of all allegations that come to Roxstar (sole trader) attention and appear to meet the criteria or that are made directly to the Police and/or children’s social care.
  4. All discussions will be recorded in writing, and any communication with both the individual and the parents of the child(ren) agreed with the Police/LADO. The case manager will ensure that the individual who is subject of the allegation is informed as soon as possible and given an explanation of the likely course or action, unless there is an objection by children’s social care or the Police. The case manager will appoint a named representative to keep the individual informed of the progress of the case and will consider what other support is appropriate for the individual. 
  5. Suspension: The case manager will give careful consideration as to whether the circumstances of the case warrant suspension or whether alternative arrangements will be put in place until the allegation is resolved. The case manager will give due weight to the views of the LADO, their HR adviser, KCSIE (paras 361-368), as well as the police and children’s social care if relevant when making a decision about suspension. Where the individual is suspended, the case manager will ensure they know who their point of contact is in Roxstar (sole trader) and shall provide them with their contact details. 
  6. Support for the member of staff: whilst the welfare of the child is paramount, appropriate welfare support will also be made for the member of staff. Information is confidential, and will not ordinarily be shared with other staff, children or parents not directly involved. See further guidance in KCSIE. 
  7. The case manager will ensure that parents are informed as soon as possible and kept informed about progress of the case, subject to any advice from children’s social care or the Police. 
  8. Further investigation: where further investigation is required, the LADO and case manager will agree how and by whom the further investigation will be undertaken. (See further information in KCSIE). 
  9. The case manager will discuss with the designated officer whether a referral to the Disclosure and Barring Service (DBS) and/or Teaching Regulation Agency (TRA) will be made, noting the requirements of KCSIE. For instance: 
  10. If: 1) the allegation is substantiated; and 2) the person is dismissed (including by an agency) or Roxstar (sole trader) (or agency) ceases to use their services, or the person resigns or otherwise ceases to provide their services, then the employer has a legal duty to make a referral to the DBS for consideration of whether inclusion on the barred lists is required. 
  11. The LADO has a legal requirement to make a referral to the DBS where theyre move an individual from regulated activity (or would have removed an individual had they not left), and they believe the individual has: 
    • engaged in relevant conduct in relation to children and/or adults, 
    • satisfied the harm test in relation to children and/or vulnerable adults; or been cautioned or convicted of a relevant (automatic barring either with or without the right to make representations) offence. 
  12. In a case involving serious professional misconduct by a tutor, the case manager must consider whether to make a referral to the TRA. In certain cases, the TRA will consider whether to prohibiting the individual from teaching. 
  13. Where the initial discussion leads to no further action, the case manager and the LADO will record the decision and justification for it; and agree on what information will be put in writing to the individual concerned and by whom. 
  14. On conclusion of the case, the case manager will review the circumstances of the case with the designated officer to determine whether there are any improvements to be made to Roxstar (sole trader) safeguarding procedures or practices to help prevent similar events in the future. This will include issues arising from any decision to suspend the member of staff, the duration of the suspension and whether or not suspension was justified. Lessons will also be learnt from the use of suspension when the individual is subsequently reinstated. The designate officer and case manager will consider how future investigations of a similar nature could be carried out without suspending the individual. 
  15. For all other cases, where the allegation concluded to be either, unfounded, false, malicious or unsubstantiated the case manager (and if they have been involved the designated officer) will consider the facts and determine whether any lessons can be learned and if improvements can be made. 
  16. Settlement: Compromise or settlement agreements will not be used where there are allegations which indicate the person poses a risk of harm or may not be suitable to work with children and will not prevent a police and/or school investigation, or referral to the DBS or TRA where the criteria are met. Failure to do so is a criminal offence. 

Roxstar (sole trader) will continue its investigation if the person leaves, resigns or ceases to provide their services. Schools will check the relevant provisions of KCSIE. 

7.5 Tutors Allegations: Information sharing 

Tutors will be mindful of the guidance set out in KCSIE in relation to sharing information between safeguarding partners during the course of the process of managing allegations against staff. 

Roxstar (sole trader) will make every reasonable effort to maintain confidentiality and guard against unwanted publicity whilst an allegation is being investigated or considered. 

7.6 Tutors Allegations : outcomes 

Allegations found to be malicious will be removed from the individual's personnel records. In all other circumstances a written record will be made of the decision and retained on the individual's personnel file in accordance with KCSIE and a copy will only be provided to the individual concerned. 

Allegations proven to be false, unsubstantiated, unfounded or malicious will not be included in employer references. Substantiated allegations will be included in references, provided that the information is factual and does not include opinions (KCSIE). Low level concerns (see below) will not be included in references unless they relate to issues which would normally be included in a reference such as misconduct or poor performance. 

If an allegation is determined to be unsubstantiated, unfounded, false or malicious, the LADO and case manager will consider whether the child and/or person who made the allegation is in need of help or may have been abused by someone else, in which case a referral to children’s social care may be appropriate. 


 

 

If an allegation is shown to be deliberately invented or malicious, the Head will consider whether any disciplinary action is appropriate against a pupil who made it in accordance with Roxstar (sole trader) behaviour policy; or whether the Police will be asked to consider if action might be appropriate against the person responsible even if they are not a pupil. 

7.7 Tutors Allegations: contracted tutors

Where Roxstar (sole trader) has to consider an allegation against an individual not directly employed by them, where its disciplinary procedures do not fully apply, for example, tutors provided by an employment agency or business (referred to in this section as ‘the agency’), they will ensure allegations are dealt with properly. They will liaise with the local authority designated officer (LADO) and notify their employer immediately to determine a suitable outcome and discuss with the agency whether it is appropriate to suspend the supply teacher or redeploy them to another part. 

Agencies will be fully involved and cooperate with any enquiries from the LADO, police and/or children’s social care. Roxstar (sole trader) will usually take the lead because agencies do not have direct access to children or other school staff, so they will not be able to collect the facts when an allegation is made, nor do they have all the relevant information required by the LADO as part of the referral process. 

When using an agency, Roxstar (sole trader) will inform the agency of its process for managing allegations but also take account of the agency’s policies and their duty to refer to the DBS as personnel suppliers. This will include inviting the agency’s human resource manager or equivalent to meetings and keeping them up to date with information about its policies. 

7.8 Tutors Allegations: Outside organisations 

If Roxstar (sole trader) receives an allegation relating to an incident that happened when an individual or organisation was using their school premises for the purposes of running activities for children, this policy will be followed and the LADO informed.  

7.9 TutorsAllegations: concerns that do not meet the harm threshold 

As part of their whole school approach to safeguarding, Roxstar (sole trader) will ensure that they promote an open and transparent culture in which all concerns about all adults working in or on behalf of Roxstar (sole trader) are dealt with promptly and appropriately. 

The term ‘low-level’ concern does not mean that it is insignificant. A low-level concern is any concern – no matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ - that an adult working in or on behalf of Roxstar (sole trader) may have acted in a way that: 

  • is inconsistent with the teachers code of conduct, including inappropriate conduct outside of work, and relates to their conduct outside of work which, even if not linked to a particular act or omission, has caused a sense of unease about that adult’s suitability to work with children. 
  • does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the LADO. The LADO will be consulted if the school is unsure as to whether it meets harm threshold.  

 

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

  • being over friendly with children; 
  • having favourites; 
  • taking photographs of children on their mobile phone; 
  • engaging with a child on a one-to-one basis in a secluded area or behind a closed door; or, 
  • using inappropriate sexualised, intimidating or offensive language. 

It is crucial that any such concerns, including those which do not meet the allegation/harm threshold, are shared responsibly and with the right person, and recorded and dealt with appropriately. 

7.11 Tutors Allegations: Sharing/reporting a low level concern 

Low-level concerns about a member of tutors will be reported t o Roxstar (sole trader). This will be received by to the LADO. 

Where a low-level concern is raised about the designated safeguarding lead, it will be shared with Roxstar (sole trader). 

Tutors do not need to be able to determine in each case whether their concern is a low-level concern, or if it is in fact serious enough to consider a referral to the LADO or meets the threshold of an allegation. They will inform the LADO / Roxstar (sole trader) of all the low-level concerns and in a timely fashion according to the nature of each particular low-level concern. 

Roxstar (sole trader) will be the ultimate decision maker in respect of all low-level concerns, although it is recognised that depending on the nature of some low-level concerns and/or the role of the LADO in some schools/colleges, the tutor may wish to consult with the LADO and take a more collaborative decision-making approach. 

Where a low-level concern relates to a person employed by Roxstar (sole trader) that concern will be shared with the LADO and recorded in accordance with Roxstar (sole trader) low-level concern and their employer notified about the concern, so that any potential patterns of inappropriate behaviour can be identified. 

If the tutors member sharing the concern does not wished to be named Roxstar (sole trader) will respect this person’s wishes as far as possible. However, there may be circumstances where the tutors member will need to be named (for example where it is necessary in order to carry out a fair disciplinary investigation) and, for this reason, anonymity can never be promised to members of tutors who share low-level concerns. 

If schools and colleges are in any doubt as to whether the information which has been shared about a member of tutors sas a low-level concern in fact meets the harm threshold, they will consult with their LADO. 

7.12 : Self-Reporting 

Occasionally an adult may find themselves in a situation which could be misinterpreted or might appear compromising to others. Equally, an adult may, for whatever reason, have behaved in a manner which, on reflection, they consider falls below the standard set out in the teachers Code of Conduct. Self-reporting in these circumstances can be positive for a number at the earliest opportunity; it demonstrates awareness of the expected behavioural standards and self-awareness as to the individual’s own actions or how they could be perceived; and, crucially, it is an important means of maintaining a culture where everyone aspires to the highest stand 

7.13 Tutors Allegation: Low level concern response 

Roxstar (sole trader)/ LADO will: 

  • speak to the person who raised the concern (unless it has been raised anonymously), regardless of whether a written summary, or completed low-level concerns form has been provided; 
  • review the information and determine whether the behaviour (i) is entirely consistent with Roxstar (sole trader) and the law, (ii) constitutes a low- level concern, (iii) is serious enough to consider a referral to the LADO, or (iv) when considered with any other low-level concerns that have previously been raised about the same individual, will be reclassified as an allegation and referred to the LADO/other relevant external agencies; 
  • Where the LADO is in any doubt whatsoever, they will seek advice from the LADO; 
  • speak to the individual about whom the low-level concern has been raised (unless advised not to do so by the LADO/other relevant external agencies, where they have been contacted); 

Any investigation of low-level concerns will be done discreetly and, on a need-to-know basis. 

Advice will be sought from legal services (where necessary) about next steps. 

There are a number of potential outcomes including (but not limited to): 

  • If it is decided that the low-level concern in fact amounts to behaviour which is entirely consistent with the teachers’ Code of Conduct and the law it will still be important for the LADO to inform the individual in question what was shared about their behaviour, and to give them an opportunity to respond to it; In addition, the LADO will speak to the person who shared the low-level concern to provide them with feedback about how and why the behaviour is consistent with the teachers Code of Conduct and the law. 
  • Some will not give rise to any ongoing concern and, accordingly, will not require any further action; 
  • Others may be most appropriately dealt with by means of management guidance and/or training; 
  • A low-level concern may require a conversation with the individual about whom the concern has been raised. This will include being clear with the individual as to why their behaviour is concerning, problematic or inappropriate, what change is required in their behaviour, enquiring what, if any, support they might need in order to achieve and maintain that, and being clear about the consequences if they fail to reach the required standard or repeat the behaviour in question. 
  • Ongoing and transparent monitoring of the individual’s behaviour may be appropriate. An action plan or risk assessment which is agreed with the individual, and regularly reviewed with them, may also be appropriate; 
  • Some low-level concerns may also raise issues of misconduct or poor performance; 

 

  • Some concerns may trigger the organisation’s disciplinary, grievance or whistleblowing procedures, which will be followed where appropriate; 
  • A referral to the LADO as Roxstar (sole trader) believes the threshold has been met. 
  • Roxstar (sole trader) will exercise their professional judgement and, if in any doubt, seek advice from other external agencies including the LADO. 

The LADO will review the central low-level concerns file periodically to ensure that all such concerns are being dealt with promptly and appropriately, and that any potential patterns of concerning, problematic or inappropriate behaviour are identified. A record of these reviews will be made. 

7.14 Tutors Allegations: Recording concerns 

All procedures for recording and storing of records will comply with United Learning’s Data Protection Policies. 

All low-level concerns will be recorded by Roxstar (sole trader). The record will include details of the concern, the context in which the concern arose, and action taken. The name of the individual sharing their concerns will also be noted, if the individual wishes to remain anonymous then that will be respected as far as reasonably possible. 

The name of the individual sharing the low-level concern, and their role, will be stated, as will the name of the individual about whom the concern is being raised, and their role within the organisation at the time the concern is raised. If the latter individual has an opposing factual view of the incident, this will be fairly recorded alongside the concern. The record will include brief context in which the low-level concern arose, and concise details (which are chronological and as precise and accurate as possible) of any such concern and relevant incident(s). The record will be timed and dated. 

There will be appropriate records of: 

  • all internal conversations – including with the person who initially shared the low-level concern (where this has been possible), the adult about whom the concern has been shared (subject to the above), and any relevant witnesses; 
  • all external conversations – for example, with the LADO/other external agencies; the rationale for decisions; any action taken. 

Records will be reviewed so that potential patterns of concerning, problematic or inappropriate behaviour can be identified. Where a pattern of such behaviour is identified, Roxstar (sole trader) will decide on a course of action, either through its disciplinary procedures or where a pattern of behaviour moves from a concern to meeting the harms threshold, in which case it will be referred to the LADO. 

Consideration will also be given to whether there are wider cultural issues within Roxstar (sole trader) that enabled the behaviour to occur and where appropriate policies could be revised or extra training delivered to minimise the risk of it happening again. 

Adults about whom a low-level concern has been raised may have rights of access to such records, provided of course that this would not also unreasonably disclose information of children concerned. 

Roxstar (sole trader) will retain the record consistent with comply with group data protection policies. The tutors will retain all records of low-level concerns (including those which are subsequently deemed by the LADO to relate to behaviour which is entirely consistent with the teachers  Code of Conduct) 

. Any written copies of reports must be recorded securely and hard copies destroyed 

7.15 Tutors Allegations: Record Keeping 

Roxstar (sole trader) Teachers Code of Conduct can be found on the NEU. The aim of the code of conduct is to provide clear guidance about behaviour and actions and responses to low level concerns in order not to place students or tutors at risk of harm or of allegation of harm or of allegation of harm to a pupil. 

Some low-level concerns may also involve issues of misconduct or poor performance, or they may trigger the disciplinary, grievance or whistleblowing procedures. Where these issues would ordinarily require records to be made and retained on the tutors member’s personnel file, this will be done in the normal way, in addition to the records of the low-level concern(s) being retained in a low-level concerns category. 

If a low-level concern in and of itself is deemed to be serious enough to consider a referral to the LADO and, perhaps following consultation, a referral is made to them, then records relating to the low-level concern will be printed and retained on the tutors member’s personnel file. 

If a low-level concern (or group of concerns) is reclassified as an allegation, all previous records of low-level concerns relating to the same individual will be moved from the central low-level concerns file to the tutors member’s personnel file and retained in accordance with Part 4 of KCSIE. 

When a tutors member leaves and/or takes up new employment, that creates a natural point at which the content of the file may be reviewed to ensure it still has value (either as a safeguarding measure or because of its possible relevance to future claims) and is therefore necessary to keep. 

Low-level concerns will not be referred to in references unless they relate to issues which would ordinarily be included in a reference, for example, misconduct or consistent poor performance. It follows that a low-level concern which relates exclusively to safeguarding (and not to misconduct or poor performance) will not be referred to in a reference. Where a low-level concern (or group of concerns) has met the threshold for referral to LADO and found to be substantiated, it will be referred to in a reference. A history of repeated concerns or allegations which have all been found to be false, unsubstantiated or malicious will also not be included in any reference. 

Roxstar (sole trader) will refer to Part Four, Section Two of KCSIE for further advice and guidance. 

8.1 Management of Safeguarding: LADO 

Roxstar (sole trader) LADO is Donna Tomlinson who is a member of the leadership team. 

The deputy head is the DLADO and the person to whom reports will be made in the absence of the LADO. This ensures there is the required cover for the role at all times. 

The LADO and DLADO’s contact details can be found on the Key Contacts page at the start of this policy. 

The LADO’s role is to take lead responsibility for safeguarding and child protection matters in Roxstar (sole trader). 

 

The LADO’s responsibility is to maintain an overview of safeguarding within Roxstar (sole trader), to open channels of communication with local statutory agencies, to liaise closely with safeguarding partners (such as children’s social care and the police), support tutorsin carrying out their safeguarding duties children’s social care and the police), support tutors in carrying out their safeguarding duties and to monitor the effectiveness of Roxstar (sole trader) policies and procedures in practice. The LADO are most likely to have a complete safeguarding picture and be the most appropriate person to advise on a response to a safeguarding concern. 

The LADO works Roxstar (sole trader) safeguarding policy. Where a pupil leaves Roxstar (sole trader), the LADO will also ensure their child protection file is transferred to the new school/agency (separately from the main pupil file) as soon as possible. The LADO will ensure secure transit and obtain confirmation of receipt. The LADO will also consider if it would be appropriate to share any information with the new school in advance of a child leaving. For example, information that would allow the new school to continue supporting victims of abuse and have that support in place for when the child arrives. Roxstar (sole trader) will ensure that key staff, such as the SENCO, are also aware of these arrangements, as required. 

The LADO will inform the safeguarding partners of any incident which they think will be considered for a child safeguarding practice review. 

The LADO can request reviews of Roxstar (sole trader) and their own practices and concerns about welfare and safeguarding matters. This includes the personal and professional duty of all report welfare and safeguarding concerns to the LADO, or in their absence, to a member of the senior management team or directly to local children’s services. 

The LADO or Roxstar (sole trader) will always be available to discuss safeguarding concerns. During term time, the LADO and/or DLADO will always be available (during school hours) for tutors in Roxstar (sole trader) to discuss any safeguarding concerns. 

Full details of the LADO’s role can be found at Annex C of KCSIE

Ultimate lead responsibility for safeguarding and child protection remains with the LADO and this responsibility will not be delegated.

8.2 Management of safeguarding: Training 

Induction and training (including online safety) are in line with advice from local safeguarding partners. 

All new tutors will be provided with induction training that includes: 

  • safeguarding and child protection, including online safety 
  • the child protection policy, including information about the identity and role of the LADO(s)
  • the behaviour policy (which will include measures to prevent bullying, including cyberbullying, prejudice-based and discriminatory bullying) 
  • the safeguarding response to children who go missing from education 
  • a copy of Part 1 of KCSIE 2023 
  • School leaders and tutorswho work directly with children will also be required to read Annex B of KCSIE.
  • Induction training takes place on a scheduled programme termly prior to tutors starting work at Roxstar (sole trader). Copies of the above documents are provided to all ‘staff’ during induction. On appointment, all tutors will receive and sign the up-to-date versions of the Acceptable Use Declaration. The teachers code of conduct can be found in the tutors handbook. 
  • Temporary tutors are provided with Guidance/Safeguarding for tutors and volunteers are provided with the Safeguarding Children and Child Protection Policies and undertake Agency on-line Safeguarding and Child Protection training. 

As part of the whole school safeguarding approach, all tutors are also required to: 

  • Read Part One of KCSIE and confirm that they have done so via a signed form returned to the Roxstar (sole trader). Each time Part One of KCSIE is updated by the Department for Education, tutors will be updated on the changes via input at tutors briefings and the tutors bulletin. 
  • Understand key information contained in Part One of KCSIE. Roxstar (sole trader) will ensure tutors understanding by completion annually of the Hays online safeguarding training programme that incorporates all updates and changes to KCSiE. 
  • Receive training in safeguarding and child protection regularly, in line with advice from the LCSP. Training will include online safety and harmful sexual behaviours including sexual violence and sexual harassment between children. It will also include Prevent awareness training to equip tutors to raise concerns appropriately by ensuring all tutors have the knowledge and confidence to identify children at risk of being drawn into terrorism; are able to challenge extremist ideas; and know how to refer children and young people for further help. All tutors will also be made aware of the local early help process and understand their role in it. 
  • Complete training into internet safety and be familiar with the filtering and monitoring processes in place. 

LADO(s) - training and expectations includes: 

  • The LADO receives updated child protection training at least every two years to provide them with the knowledge and skills required to carry out the role. This includes local inter-agency working protocols, participation in child protection case conferences, supporting children in need, identifying children at risk of radicalisation, supporting SEND children particularly when online, overseeing online safety in school, record keeping and promoting a culture of listening to children, training in the LCSP approach to Prevent duties and harmful sexual behaviours. Further details of the required training content for the LADO are set out in Annex B of KCSIE. 
  • In addition to their formal training, the LADO’s knowledge and skills are updated at least annually to 

 

  • keep up with any developments relevant to their role. 
  • The DLADO is trained to the same level as the LADO as are all members of the core Child Protection team. 

8.5 Management of Safeguarding: Safer Recruitment

Roxstar (sole trader) is committed to safer recruitment processes and ongoing safer working practices. 

Members of the teaching Roxstar (sole trader) are subject to the necessary statutory child protection checks before starting work, for example, right to work checks, additional overseas checks (if necessary), verifying identity, taking up references, checking work history and confirming medical fitness for the role. 

For most appointments, an enhanced DBS check with 'barred list' information will be appropriate. 

Under no circumstances will an individual commence work unsupervised in sole charge of, or in unaccompanied contact with, children without a cleared DBS check. In this case, the individual will have a separate Barred List check and Roxstar (sole trader) will undertake a written Risk Assessment exercise in relation to the proposed work. All other safeguarding checks will be completed and the individual will be appropriately supervised. Please refer to Section C and Appendix 5 of the ‘Safeguarding Children – HR Procedural Guidance’ available on the United Learning Hub for further guidance. 

 

10.1 Vulnerable Groups: Special needs, disability and health issues 

Tutors will be fully aware of their difficulties and ensure that supportive measures are in place to support communication. 

Each child will have a key-adult who has oversight for the child’s needs and difficulties. The key adult should be involved (when appropriate) to support the child, LADO or other professionals in supporting the child where there are safeguarding concerns. 

Students with SEND or certain health conditions can face additional safeguarding challenges. They may not outwardly show signs of abuse and/or may have difficulties in communication about abuse or neglect. Students with SEND are more likely to be abused by their peers. The barriers to recognising abuse and neglect of this group of children can include: 

  • assumptions that indicators of possible abuse such as behaviour, mood and injury relate to
  • the child’s disability or health condition without further exploration;
  • being more prone to peer group isolation than other children
  • the potential for children with SEN and disabilities being disproportionally impacted by behaviours such as bullying, including prejudice-based bullying, without outwardly showing any signs; and
  • communication barriers and difficulties in managing or reporting these challenges.

Further guidance can be found in the DfE guidance Supporting students at school with medical conditions, and where applicable in the SEND Code of Practice. 

Tutors will support such students in expressing any concerns they may have and will be particularly vigilant to any signs or indicators of abuse, discussing this with the LADO as appropriate. 

10.2 Vulnerable Groups: Looked after children (and previously looked after children) 

Looked after children (and previously looked after children) are a particularly vulnerable group. 

Roxstar (sole trader) will ensure that prompt action is taken when necessary to safeguard these children and the local governing body ensures that tutors have the skills, knowledge and understanding necessary to keep safe any children on roll who are looked after (and previously looked after) by a local authority. 

Roxstar (sole trader) ensures that the designated member of tutorsr eceives appropriate training in order to carry out their role and has the information they need in relation to any child’s looked after status, their care arrangements (including contact arrangements with birth parents and those with parental responsibility) and details of the child’s social worker and virtual school head. 

Roxstar (sole trader) will also have responsibility for promoting the educational achievement of children who have left care through adoption, special guardianship or child arrangement orders or who were adopted from state care and will work closely with virtual school heads to promote their educational achievement. The LADO will ensure they have details of the local authority Personal Advisor appointed to guide and support any care leavers and will liaise with them as necessary regarding any issues of concern affecting them. 

10.4 Vulnerable Groups: Children who need a social worker, Child in Need, Child Protection 

Children may need a social worker due to safeguarding or welfare needs. Children may need this help due to abuse, neglect and complex family circumstances. A child’s experiences of adversity and trauma can leave them vulnerable to further harm, as well as educationally disadvantaged in facing barriers to attendance, learning, behaviour and mental health. 

Where the local authority has made Roxstar (sole trader) aware a child has a social worker, the designated safeguarding lead will hold and use this information so that decisions can be made in the best interests of the child’s safety, welfare and educational outcomes. 

This information will inform decisions about safeguarding (for example, responding to unauthorized absence or missing education where there are known safeguarding risks) and about promoting welfare (for example, considering the provision of pastoral and/or academic support, alongside action by statutory services). 

APPENDIX 1 – Details and definitions 

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. 

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 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. Tutorsare referred to DfE guidance Sexual Violence and Sexual Harassment for further information. 

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 (also known as child on 


 

child abuse) is a specific safeguarding issue in education and all tutorswill be aware of it and of their school’s policy and procedures for dealing with it.  

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 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. 

Specific safeguarding issues: behaviours linked to drug taking, alcohol abuse, truanting and sexting put children in danger. Safeguarding issues can also manifest themselves via child-on-child abuse, such as bullying (including cyberbullying), gender- based violence/sexual assaults and sexting. Safeguarding issues can also be linked to, for example, children missing education; child sexual exploitation; domestic violence; fabricated or induced illness; faith abuse; female genital mutilation; forced marriage; gangs and youth violence; gender-based violence / violence against women and girls; hate; mental health; preventing radicalisation; relationship abuse; sexting; and trafficking. 

Child Criminal Exploitation (CCE) and Child Sexual Exploitations 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. CSE and CCE can affect children, both male and female, and can include children who have been moved (commonly referred to as trafficking) for the purpose of exploitation. 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 will be noted exploitation as well as being physical can be facilitated and/or take place online. 

Child Criminal Exploitation (CCE) Some specific forms of CCE can include children being forced or manipulated into transporting drugs or money through county lines, working in cannabis factories, shoplifting or pickpocketing. They can also be forced or manipulated into committing vehicle crime or threatening/committing serious violence to others. 

Children can become trapped by this type of exploitation as perpetrators can threaten victims (and their families) with violence or entrap and coerce them into debt. They may be coerced into carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from others. As children involved in criminal exploitation often commit crimes themselves, their vulnerability as victims is not always recognised by adults and professionals, (particularly older children), and they are not treated as victims despite the harm they have experienced. They may still have been criminally exploited even if the 

36 activity appears to be something they have agreed or consented to. 

It is important to note that the experience of girls who are criminally exploited can be very different to that of boys. The indicators may not be the same, however professionals will be aware that girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being criminally exploited may be at higher risk of sexual exploitation. 

Child Sexual Exploitation (CSE): CSE is a form of sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. CSE does not always involve physical contact: it can also occur through the use of technology. 

Potential indications of CSE include (but are not limited to): 

  • Children who appear with unexplained gifts or new possessions; 
  • Children who associate with other young people involved in exploitation; Children who have older boyfriends or girlfriends; 
  • Children who suffer from sexually transmitted infections or become pregnant; 
  • Children who suffer from changes in emotional well-being; 
  • Children who misuse drugs and alcohol; 
  • Children who go missing for periods of time or regularly come home late; 
  • and Children who regularly miss school or education or do not take part in education. 

CSE can affect any child or young person (male or female) under the age of 18 years, including 16 and 17 year olds who can legally consent to have sex; can still be abuse even if the sexual activity appears consensual; can include both contact (penetrative e.g. rape and oral sex and non-penetrative acts such as masturbation, kissing, rubbing, and touching outside clothing) and non-contact sexual activity (such as involving children in the production of sexual images, forcing children to look at sexual images or watch sexual activities, encouraging children to behave in sexually inappropriate ways or grooming a child in preparation for abuse including via the internet. It can take place in person or via technology, or a combination of both; can involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence; may occur without the child or young person’s immediate knowledge (e.g. through others copying videos or images they have created and posted on social media); 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; and is typified by some form of power imbalance in favour of those perpetrating the abuse. 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. Some of the following signs may be indicators of sexual exploitation: 

CSE is a geographically widespread form of harm that is a typical feature of county lines criminal activity: drug networks or gangs groom and exploit children and young people to carry drugs and money from urban areas to suburban and rural areas, market and seaside towns. Key to identifying potential involvement in county lines are missing episodes when the victim may have been trafficked for the purpose of drugs trafficking. The LADO or DLADO will consider a referral to the National Referral Mechanism as soon as possible if there are county line concerns, such as a child being a potential victim of modern slavery or human trafficking. 

All tutorswill 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 and may be at risk of criminal exploitation. 

All tutorswill be aware of the range of risk factors which increase the likelihood of involvement in serious violence, such as being male, having been frequently absent or permanently excluded from school, having experienced child maltreatment and having been involved in offending, such as theft or robbery. 

County lines 

County lines is a term used to describe gangs and organised criminal networks involved in exporting illegal drugs (primarily crack cocaine and heroin) into one or more importing areas [within the UK], using dedicated mobile phone lines or other form of “deal line”. 

Exploitation is an integral part of the county lines offending model with children and vulnerable adults exploited to move [and store] drugs and money. Offenders will often use coercion, intimidation, violence (including sexual violence) and weapons to ensure compliance of victims. Children can be targeted and recruited into county lines in a number of locations including schools (mainstream and special), further and higher educational institutions, pupil referral units, children’s homes and care homes. Children are often recruited to move drugs and money between locations and are known to be exposed to techniques such as ‘plugging’, where drugs are concealed internally to avoid detection. Children can easily become trapped by this type of exploitation as county lines gangs create drug debts and can threaten serious violence and kidnap towards victims (and their families) if they attempt to leave the county lines network. 

One of the ways of identifying potential involvement in county lines are missing episodes (both from home and school), when the victim may have been trafficked for the purpose of transporting drugs and a referral to the National Referral Mechanism will be considered. If a child is suspected to be at risk of or involved in county lines, a safeguarding referral will be considered alongside consideration of availability of local services/third sector providers who offer support to victims of county lines exploitation. 

Please see below for more information: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/863323/HOCountyLinesGuidance_-_Sept2018.pdf

So Called ‘Honour Based’ Abuse: encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation (FGM), forced marriage, and practices such as breast ironing. It can include multiple perpetrators. 

FGM comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. Guidance on the warning signs that FGM may be about to take place, or may have already taken place, can also be found on pages 38-41 of the Multi-agency statutory g uidance on FGM. 

If tutorshave a concern that a pupil may be at risk of HBA or has suffered HBA, they will speak to the LADO (or DLADO). 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. 

There is a statutory duty on teachers to personally 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. Unless the teacher has a good reason not to, they will still consider and discuss any such case with the LADO and involve children’s social care as appropriate. If the teacher is unsure whether this reporting duty applies, they will discuss their concerns with the LADO in accordance with this policy. Where a teacher suspects that a pupil is at risk (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 it involves a pupil over 18, teachers will follow Roxstar (sole trader) local safeguarding procedures. 

Forced Marriage: Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or emotional and psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some communities use religion and culture as a way to coerce a person into marriage. Schools can play an important role in safeguarding children from forced marriage. 

Multi-agency practice guidelines: handling cases of forced marriage (pages 75-80 of which focus on the role of schools and colleges) and, Multi-agency statutory    guidance for dealing with forced marriage, which can both be found at: 

https://www.gov.uk/government/publications/the-right-to-choose-government- guidance-on- forced-marriage 

School and college tutorscan contact the Forced Marriage Unit if they need advice or information: Contact: 020 7008 0151 or email fmu@fcdo.gov.uk.

Preventing Radicalisation: Children are vulnerable to extremist ideology and radicalisation. Similar to protecting children from other forms of harms and abuse, protecting children from this risk will be a part of a schools’ 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. 

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 

 

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, tutorswill be alert to changes in children’s behaviour, which could indicate that they may be in need of help or protection. Tutorswill 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 Prevent referral.

Roxstar (sole trader) will be aware of local procedures for making a Prevent referral. 

Lesbian, Gay, Bi or Trans (LGBT): The fact that a child or a young person may be LGBT is not in itself an inherent risk factor for harm. However, children who are LGBT can be targeted by other children. In some cases, a child who is perceived by other children to be LGBT (whether they are or not) can be just as vulnerable as children who identify as LGBT. 

Risks can be compounded where children who are LGBT lack a trusted adult with whom they can be open. To address this: 

• Roxstar (sole trader) provides a safe space for all students, but has identified and trained tutors allies, to provide bespoke support for LGBTQ+ students. These tutors are easily identifiable with rainbow lanyards and known to students. 

Wellbeing for all students is a whole school priority, and students who identify as LGBTQ+ participate in all areas of school life, providing positive role models for younger students. 

Children and the court system: Children are sometime required to give evidence in criminal courts, either for crimes committed against them or for crimes they have witnessed, and this will be stressful for them. Making child arrangements following separation can also be stressful and entrench conflict in families. Tutorswill be alert to the needs of such students and report any concerns to the LADO or DLADO in accordance with this policy. 

Children with family members in prison: Children who have a parent in prison are at risk of poor outcomes including poverty, stigma, isolation and poor mental health. Tutorswill be alert to the needs of such students and report any concerns to the LADO or DLADO in accordance with this policy. Support from relevant charities, professional bodies and social services will be used wherever appropriate and possible. 

Child abduction and community safety incidents: Child abduction is the unauthorised removal or retention of a minor from a parent or anyone with legal responsibility for the child. Child abduction can be committed by parents or other family members; by people known but not related to the victim (such as neighbours, friends and acquaintances); and by strangers. 

Other community safety incidents in the vicinity of a school can raise concerns amongst children and parents, for example, people loitering nearby or unknown adults engaging children in conversation. 

As children get older and are granted more independence (for example, as they start walking to school on their own) it is important they are given practical advice on how to keep themselves safe. Many schools provide outdoor-safety lessons run by teachers or by local police staff. 

It is important that lessons focus on building children’s confidence and abilities rather than simply warning them about all strangers. Further information is available at: www.actionagainstabduction.org and www.clevernevergoes.org.

Children in need: defined under the Children Act 1989 as a child who is unlikely to achieve or maintain a reasonable level of health or development, or whose health or development is likely to be significantly or further impaired, without the provision of services; or a child with a disability. Local authorities are required to provide services to safeguard or promote the welfare of children in need, and they may be assessed under s17 Children Act 1989. 

Domestic abuse: Domestic abuse can encompass a wide range of behaviours and 

may be a single incident or a pattern of incidents. That abuse can be, but is not limited to, psychological, physical, sexual, financial or emotional. Children can be victims of domestic abuse. They may see, hear, or experience the effects of abuse at home and/or suffer domestic abuse in their own intimate relationships (teenage relationship abuse). All of which can have a detrimental and long-term impact on their health, well-being, development, and ability to learn. 

Homelessness: 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. The LADO or DLADO will raise/progress any concerns about homelessness with the Local Housing Authority although this does not replace a referral into children’s social care where a child has been harmed or is at risk of harm. 

Child on child abuse / child on child abuse: 

Children can abuse other children. This is generally referred to as child on child abuse and can take many forms. This can include (but is not limited to): 

 

Sexual violence 

It is important that school tutorsare 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 as described below: 

Rape: A person (A) commits an offence of rape if: he intentionally penetrates the vagina, anus or mouth of another person (B) with his penis, B does not consent to the penetration and A does not reasonably believe that B consents. 

Assault by Penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual, B does not consent to the penetration and A does not reasonably believe that B consents. 

Sexual Assault: A person (A) commits an offence of sexual assault if: s/he intentionally touches another person (B), the touching is sexual, B does not consent to the touching and A does not reasonably believe that B consents. 

Causing someone to engage in sexual activity without consent: A person (A) commits an offence if: s/he intentionally causes another person (B) to engage in an activity, the activity is sexual, B does not consent to engaging in the activity, and A does not reasonably believe that B consents. This could be forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party. 

What is consent? Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given to one sort of sexual activity but not another, e.g.to vaginal but not anal sex or penetration with conditions, such as wearing a condom. Consent can be withdrawn at any time during sexual activity and each time activity occurs. Someone consents to vaginal, anal or oral penetration only if s/he agrees by choice to that penetration and has the freedom and capacity to make that choice. 

  • a child under the age of 13 can never consent to any sexual activity; 
  • the age of consent is 16; 
  • sexual intercourse without consent is rape. 

Sexual harassment 

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 will 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 nudes and semi-nudes images and videos; 
  • sexualised online bullying; 
  • unwanted sexual comments and messages, including, on social media; sexual exploitation; coercion and threats; and upskirting. 

Upskirting 

The Voyeurism (Offences) Act 2019, 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 sex, can be a victim. 

Mental Health: All tutorswill 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 will attempt to make a diagnosis of a mental health problem. Tutorsare 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 tutorsare aware of how these children’s experiences, can impact on their mental health, behaviour and education. 

If tutorshave a mental health concern about a child that is also a safeguarding concern, immediate action will be taken, following their child protection policy and speaking to the designated safeguarding lead or a deputy. 

Reference will be made to: 

Mental Health and Behaviour in schools DfE guidance (November 2018); 

DfE guidance ‘promoting and supporting mental health and wellbeing in schools, which details numerous resources available to schools; and 

Public Health England: Promoting children and young people’s emotional health and wellbeing a whole school and college approach 

Paragraphs 183-185 of ‘Keeping Children Safe in Education’ (DfE, 2023) 

Modern Slavery and the National Referral Mechanism 

Modern slavery encompasses human trafficking and slavery, servitude and forced or compulsory labour. Exploitation can take many forms, including: sexual exploitation, forced labour, slavery, servitude, forced criminality and the removal of organs. 

Further information on the signs that someone may be a victim of modern slavery, the support available to victims and how to refer them to the NRM is available in the Modern Slavery Statutory Guidance. Modern slavery: how to identify and support victims - GOV.UK (www.gov.uk)

 

Cybercrime

Cybercrime is criminal activity committed using computers and/or the internet. It is broadly categorised as either ‘cyber-enabled’ (crimes that can happen off-line but are enabled at scale and at speed on-line) or ‘cyber dependent’ (crimes that can be committed only by using a computer). Cyber- dependent crimes include; 

  • unauthorised access to computers (illegal ‘hacking’), for example accessing a school’s 
  • computer network to look for test paper answers or change grades awarded; 
  • denial of Service (Dos or DDoS) attacks or ‘booting’. These are attempts to make a computer, network or website unavailable by overwhelming it with internet traffic from multiple sources; and, 
  • making, supplying or obtaining malware (malicious software) such as viruses, spyware, ransomware, botnets and Remote Access Trojans with the intent to commit further offence, including those above. 

Children with particular skills and interests in computing and technology may inadvertently or deliberately stray into cyber-dependent crime. 

If there are concerns about a child in this area, the designated safeguarding lead (or a deputy), will consider referring to the Cyber Choices programme. This is a nationwide police programme supported by the Home Office and led by the National Crime Agency, working with regional and local policing. It aims to intervene where young people are at risk of committing, or being drawn into, low-level cyber-dependent offences and divert them to a more positive use of their skills and interests. 

Note that Cyber Choices does not currently cover ‘cyber-enabled’ crimes such as fraud, purchasing of illegal drugs online and child sexual abuse and exploitation, nor other areas of concern such as online bullying or general online safety. 

Additional advice can be found at: Cyber Choices, ‘NPCC- When to call the Police and 

National Cyber Security Centre - NCSC.GOV.UK 

A Whole School Culture of Safeguarding 

The Public Sector Equality Duty helps schools and colleges (which are subject to it) to focus on key issues of concern and how to improve pupil and pupil outcomes. Some students or students may be more at risk of harm from specific issues such as sexual violence, homophobic, biphobic or transphobic bullying or racial discrimination. Such concerns will differ between education settings, but it is important that schools and colleges are conscious of disproportionate vulnerabilities and integrate this into their safeguarding policies and procedures. 

ADDENDUM 1 - Intra-Familial harms 

APPENDIX 2 – MEET THE SAFEGUARDING TEAM 

If you have any concerns please contact Roxstar (sole trader) on 07584208696  

The Designated Safeguarding Lead is: Donna tomlinson 

 

Appendix 3: External Contacts 

External Contact details 

Local Authority Designated Officer: Mirian Williams and Donna Tomlinson 

TEL: 0330 222 6450 

EMAIL: LADO@westsussex.gov.uk

Local Authority Children’s Social Services 

TEL: 01403 229 900 

EMAIL: WSChildrenServices@westsussex.gov.uk OUT OF HOURS EMERGENCY 

DUTY TEAM TEL: 0330 222 6664 

Integrated Front Door (MASH) 

TEL: 01403 229 900 

EMAIL: WSChildrenServices@westsussex.gov.uk

Police 

EMERGENCY: 999 

NON EMERGENCY NUMBER: 101 and ask for the prevent team 

EMAIL: prevent@sussex.pnn.police.uk

Local Authority Prevent Lead 

Beverly.knight@westsussex.gov.uk

TEL: 0330 222 4223 | Mobile 0789 458 9071 

EMAIL: beverly.knight@westsussex.gov.uk

Department for Education 

NON EMERGENCY NUMBER: 020 7340 7264 

EMAIL: counter.extremism@education.gsi.gov.uk

NSPCC 

TEL: 0808 800 5000 

EMAIL: help@nspcc.org.uk

 

Disclosure and Barring Service 

ADDRESS: DBS customer services, PO Box 3961, Royal Wootton Bassett, SN4 4HF, United Kingdom 

TEL: 03000 200 190 

EMAIL: customerservices@dbs.gov.uk

Teaching Regulation Agency 

TEL: 0207 593 5393 

EMAIL: misconduct.teacher@education.gov.uk

OFSTED (Concerns) 

TEL: 0300 123 4666 

EMAIL: CIE@ofsted.gov.uk

Appendix 4 : Relationship guidelines 

Roxstar (sole trader) NOTES OF GUIDANCE FOR 

Tutor-PUPIL RELATIONSHIPS 2023 

The relationship between tutors and pupil is a professional, caring relationship. 

There is a power imbalance in the relationship that teachers must be always aware of and behave accordingly, as the powerful person in the relationship. 

A personal relationship between tutorsand pupil is not appropriate under any circumstances, except where there is an existing relationship prior to the tutors/ student joining Roxstar (sole trader). This may include knowing a child through your own children or a friend’s child being accepted to Roxstar (sole trader). 

Physical contact can be therapeutic and necessary when used with care. Physical contact should be used within the context of a student’s therapeutic or support plan. Physical contact may be used during demonstrations, falls or to support a student who is distressed. This must be done with care and caution. 

All tutorswill be trained in Team Teach. The use of physical touch and restrained as guided in this training must be adhered to at all time.

ADDENDUM 1 

Intra-Familial harms: Intra-familial child sexual abuse refers to child sexual abuse (CSA) that occurs within a family environment. Perpetrators may or may not be related to the child. The key consideration is whether the abuser feels like family from the child’s point of view. Where research has recorded the gender of perpetrators of intra-familial CSA, the vast majority have been found to be male, although abuse by women does occur. In around a quarter of cases, the perpetrator is under 18.CSA in the family is rarely an isolated occurrence and may go on for many years. Much abuse in the family remains undisclosed. Children may fear their abuser, not want their abuser to get into trouble, feel that the abuse was ‘their fault’, and feel responsible for what will happen to their family if they tell. Disabled children and some black, Asian, and minority ethnic children face additional barriers. Abuse by a family member may be particularly traumatic because it involves high levels of betrayal, stigma and secrecy. CSA in the family is linked to a range of negative outcomes over the whole of the life course, including poorer physical and mental health, lower income, relationship difficulties, and further violence and abuse. It is important to provide support to the whole family, and particularly to non-abusing parents, following abuse. 

V1 reviewed Sept 23

 

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