Safeguarding and Prevent Policy and Guidance (revised June 2017)

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Approved at Management Team on 12/7/17
Date of next review June 2018

Background to Safeguarding and Prevent
There have been a large number of serious and preventable cases that have influenced the
current legislation and guidance relating to safeguarding.


Major safeguarding incidentsKey messages
Victoria Climbie 2003Safeguarding and equality and diversity policies working together
Soham murders 2004Safer recruitment
Vanessa George 2009Whistleblowing
Ashleigh HallKeeping safe on line – not agreeing
to meet
Jimmy SavillePeople in authority or celebrities can
be abusers
Daniel PelkaTake action if you are not happy
RotherhamTake action, whistleblowing, authorities, must work together
RochdaleTake action, whistleblowing, authorities, must work together
Brighton College teenage British jihadi killed in US airstrikesDifficulty of identifying and preventing radicalisation


These cases lead to the following reports, recommendations and legislation.

Reports and recommendations
Lord Lamming Inquiry
Bichard Inquiry
Sunita Mason Report
‘Giving Victims a Voice’ MPS and NSPCC report into allegations of sexual abuse made against
Jimmy Saville
A Serious Case Review into the murder of Daniel Pelka
Reviews of Rotherham and Rochdale child sexual exploitation

Key legislation, guidance and strategies to underpin Safeguarding and Prevent
The Children Act 1989 and amended 2004
The Equality Act 2010
Safeguarding and vulnerable groups act 2006, amended 2012
Keeping Children Safe in Education, update 2016
The Counter-Terrorism and Security Act 2015 – the Prevent Duty
Revised Prevent Duty Guidance, July 2015


What is Safeguarding?

‘Safeguarding’ is the process of protecting vulnerable people, whether from crime, other forms of
abuse or from being drawn into terrorist related activity. Skills and Learning aims to keep
everyone, including children, young people, adults and staff, including volunteers safe from a
broad range of potential harm.

Safeguarding is most effective within a culture of vigilance, where all take responsibility for looking
out for each other and ourselves

It could happen here
It has happened here


Key elements

The aims of this policy


  • protect learners and staff from preventable harm
  • support learners and staff to acquire knowledge and skills to keep themselves and their
    families safe
  • respond to concerns and disclosures in an appropriate way
  • provide information about support agencies
  • meet our legal and statutory obligations


How we will achieve our aims


  • Professional, ethical and moral leadership and management of the Service
  • Ensuring compliance with all relevant legislation, policies and procedures, including of the
    Borough of Poole
  • A team of trained Safeguarding Officers (Designated Persons)
  • Wide promotion of alerting procedures
  • Ensuring Borough of Poole staff recruitment processes are followed
  • Disclosure and barring service checks for staff in specific roles, following assessment
  • Induction of staff so that they know and understand their responsibilities, including how to raise
  • Induction of learners so that they understand their responsibilities and how to raise concerns
  • Continuing professional development opportunities
  • Maintaining a culture of support and vigilance
  • Working with external agencies and partners to understand when and how to refer,
    communication protocols and share best practice
  • Working with subcontractors and employers so they understand their responsibilities and
    alerting procedures
  • Providing information and resources about abuse and neglect
  • Risk assessing learners with unspent criminal convictions, referred by the probation service, or
    identified by JCP prior to acceptance
  • Reviewing our safeguarding arrangements to support continual improvement


Types of abuse and neglect

Both abuse and neglect are types of maltreatment. A person may abuse or neglect another by
inflicting harm, or by failing to act to prevent harm.
People may be abused in a family, in an institution or community setting, via the internet or phone;
by those known to them or, more rarely, by a stranger. Abuse can be physical, emotional, sexual,
financial or neglect. It can be a criminal act when it is an offence against another person. It can
happen once or repeatedly. It may be deliberate or caused by ignorance.

‘Harm should be taken to include not only ill treatment but also the impairment or avoidable
deterioration in physical or mental health and the impairment of physical, behavioural, social or
emotional development’ (Law Commission)

See Appendix 1 for definitions and categories of abuse and neglect.


Specific abuse and neglect issues include:

  • Exploitation, including sexual exploitation
  • Bullying and harassment, including cyberbullying/text/e-bullying
  • Domestic abuse
  • Legal and illegal substance abuse/drugs
  • Fabricated or induced illness
  • Faith abuse
  • Forced marriage
  • Gangs and youth violence
  • Private fostering
  • Female genital mutilation
  • Gender based violence/violence against women and girls
  • Radicalisation
  • Sexting
  • Teenage relationship abuse
  • Trafficking
  • Mental health
  • Modern Slavery

See Appendix 2 for more information on these specific types of abuse, including hyperlinks to
further information.


Who is at risk?

Learners, particularly:

  • Children (up to 18 years of age)
  • Young people
  • Those with a physical disability and/or learning difficulty
  • Those who engage in on-line activities that may put them at risk, eg chatrooms to establish
  • Those with a mental health issue
  • Those engaging in risky, anti-social or criminal behaviour
  • Those with family or work challenges
  • Homeless
  • Those in informal care arrangements

Staff, including volunteers


When are Disclosure and Barring Service checks needed?

Disclosure and Barring Service checks are required for people who undertake a ‘regulated activity’
as a part of their job role. The Protection of Freedoms Act 2012 amended the definition of
regulated activity relating to adults and to children and removed the category ‘controlled’ activities.
DBS checks are repeated for staff who are still engaged in a regulated activity every 5 years.


Regulated activity relating to children
Regulated activities include:

  • teaching or training provided this takes place on four or more days in a 30 day period (ie
    meets the frequency criteria)
  • work which meets the frequency criteria taking place in a specified place (school, children’s

Staff who meet the above criteria, and their line managers are eligible for enhanced DBS check
including the barred list. Those who meet the old definition of regulated activity, and their
managers are eligible for the enhanced DBS check.


Regulated activity relating to adults

Tutors of adult groups targeted at those with disabilities or learning difficulties do not fall in the
new definition of ‘regulated activity’, however, because they were included in the Vulnerable
Groups Act, 2006, staff engaged in these activities, and their managers, are eligible for the
enhanced DBS check, without the barred list. Support staff, including volunteers are also eligible if
they are not supervised at all times.

Adult Social Care Assessors who frequently visit care or nursing homes are eligible for the
enhanced DBS check but not including the barred list.

DBS checks are repeated for staff who are still engaged in a regulated activity every 5 years.

Refer to Appendix 3 (Regulated Activity Decision Making Flowchart) and 4 (S&L staff roles and
eligibility for DBS) for further guidance.


How staff should respond to safeguarding concerns and disclosures of abuse

All staff should follow the Code of Good Practice and the Alerting Guide.
When responding to concerns staff should follow The Five Rs.


Recognise signs, symptoms and behaviours that could indicate a person is a victim of abuse or
harm. It does not matter where the abuse has taken place.

  • Disclosure – ie telling you they have been/are being abused
  • Bruising or cuts
  • Dramatic change in behaviour – aggressive or withdrawn
  • Dramatic change in appearance, attention to personal wellbeing
  • Arriving early/leaving late
  • Reluctance to make eye contact
  • Mood swings
  • Clothing that covers the body – even in hot weather
  • Inappropriate behaviour

Many of these signs will have innocent causes but they could indicate abuse.



Appropriate response is very important.

If you have concerns, try to find out if the person is OK/about any injuries/mood change etc.

If a person discloses that they have been abused, are being abused, or that they know someone
else is being abused:

  • Remember this may have been very difficult and courageous for them to do
  • Remain calm, concerned, reassuring and interested
  • Assure them that their disclosure will be taken seriously
  • Tell them that you will have to share the disclosure with one of the Safeguarding Officers.
    Do not promise to keep the information to yourself.
  • Try to find out if the disclosure relates to themselves or to another person
  • Try to find out the name of the perpetrator
  • Try to find out exactly what has happened
  • Do not prompt them or make suggestions about what has happened.


Record and Report

Record your concerns with information about the signs, symptoms or behaviours you have
observed and report these to one of the Safeguarding Officers, unless you think the person is at
risk of immediate harm. The Alerting Guide shows the contact numbers.

Record what they have told you, in their own words and what you have observed – eg about their
emotional state, any injuries, how they spoke, words they had difficulty in saying.

Report the disclosure including your notes to one of the Safeguarding Officers.

Do not speak with anyone else about the disclosure, do not investigate and do not approach an
alleged perpetrator.


The Safeguarding Officers will seek advice and will follow the correct course of action, referring to
either the police or social services if appropriate.

Only refer a concern or disclosure directly to the police or social services if you are unable to
contact one of the safeguarding officers and the person is at risk of harm if you do not do this. The
Alerting Guide includes contact numbers.

Remember – the signs and symptoms you have observed or your concerns may be important
information. Failure to share information is a common theme on almost all of the serious cases.


The Roles and Responsibilities of the Safeguarding Officers (Designated Persons)

The roles and responsibilities of the Safeguarding Officers officers fall into 3 areas.


  • Refer cases of suspected abuse or allegations to relevant statutory agencies
  • Act as a source of support, advice and expertise to staff when deciding whether and when
    to make a referral
  • Act as a source of support, advice and expertise to all learners and staff affected by a
    safeguarding incident
  • Ideally seek advice from and share information with relevant statutory agencies after
    seeking consent or informing parents or carers of a referral, unless to do so would place the
    person at increased risk of harm


  • Recognise how to identify the signs of abuse and neglect and when it is appropriate to
    make a referral to other agencies
  • Ensure each member of staff has access to and understands the safeguarding policy and
    procedures, especially new or part-time staff who may work at different establishments and
    or locations
  • Ensure all learners have access to and understand the organisations safeguarding policy
    and procedures.
  • Ensure all learners and staff have induction training covering safeguarding and are able to
    recognise and report any concerns about safety and welfare immediately they arise
  • Be able to keep detailed, accurate, secure written records of referrals and or concerns
  • Obtain access to resources and attend any relevant or refresher training courses

Raising awareness

  • Ensure the safeguarding policy and procedures are updated and reviewed annually and
    work with the management team regarding this
  • Ensure learners know that disclosures or concerns about suspected abuse or neglect may
    be referred to the police or social services

The 2016-17 safeguarding officers are Cheryl Bascombe, Janet Miles, Dan Parker and Lyn

Supporting policies, guidance and information
Borough of Poole procedures relating to the Disclosure and Barring Service checks
Skills & learning Code of Good Practice
Skills & learning Safeguarding Alerting Guide for staff and volunteers
Borough of Poole Recruitment and Selection Policy
Borough of Poole Whistleblowing policy
Borough of Poole Fairness for All
Skills & Learning Health and Safety policy
Skills & Learning internet safety and safe use of computers
Skills & Learning Risk Assessment procedures
Skills & Learning Responsible Behaviour Learner Behaviour policy
Borough of Poole Dignity at work policy
Borough of Poole Prevention of Bullying and Harassment policy
NIACE Safer Practice, Safer Learning guidelines (2007)
Borough of Poole Internet and e-mail policy
Keeping children safe in education, 2015


Appendix 1 – Definitions

The Children Act 1989 defines a child as a person under 18 years for most purposes.

Adult at risk
Department of Health guidance issued in 2000 defines an adult at risk as a person aged 18 years
and over ‘who is or may be in need of community care services by reason of mental or other
disability, age or illness; and who is or may be unable to take care of him or herself, or unable to
protect him or herself against significant harm or exploitation’. (Who Decides Lord Chancellor’s
Office 1997 and No Secrets, 2000)

Categories of abuse and neglect
See also specific types of abuse in Appendix 2

Physical abuse:

  • Hitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating, restraining or
    other type of physical harm.
  • Also includes the fabrication of symptoms of, or deliberately inducing an illness in another
  • Withholding medication or over applying medication.

Emotional abuse

  • persistent emotional maltreatment such as to cause severe and adverse effects on the
    emotional development
  • telling a person they are worthless, unloved, inadequate, or valued only if they meet the
    needs of the other person
  • not allowing the person to express a view, silencing them, making fun of what they say or
    how they communicate
  • imposing age or developmentally inappropriate expectations – interactions that are beyond
    the person’s developmental capability or over protection and limitation of exploration and
    learning, preventing the person from participating in normal social interaction
  • witnessing or hearing about the maltreatment of another person
  • feeling frightened or in danger as a result of bullying, including cyberbullying, or the
    exploitation or corruption of a person


Sexual Abuse

Forcing or enticing a person to take part in sexual activities, not necessarily involving a high level
of violence, whether or not the person understands what is happening


  • penetrative acts – rape or oral sex
  • non-penetrative acts – masturbation, kissing, rubbing, touching outside of the clothing
  • involving at risk people in looking at or in the production of sexual images, watching sexual
    activities, encouraging sexually inappropriate behaviour
  • grooming in preparation for abuse, including via the Internet

Perpetrators can be male, female, adult or children

Financial/material abuse

  • Taking/controlling a person’s money
  • Forcing someone to buy the perpetrator things
  • Forcing someone to work or not to work
  • The theft or misuse of money, property or personal possessions
  • Pressure in connection with wills, property or inheritance

Persistent failure to meet the person’s basic physical and or psychological needs, likely to lead to
the serious impairment of the person’s health or development


  • Maternal substance abuse during pregnancy
  • Failing to provide adequate food, clothing, shelter
  • Failing to protect from physical and emotional harm or danger
  • Failing to provide adequate supervision, including inadequate choice of care givers
  • Failing to ensure access to appropriate medical care or treatment
  • Unresponsive to emotional needs
  • Self neglect


Appendix 2 – Specific types of abuse

From Safe and Equal Learning Partnership Designated Person’s Training, 2015 and 2017

Definitions and resources relating to the areas of abuse, taken from Keeping children safe in education; Statutory guidance for schools and colleges, update 2016

Definitions and guidance

1. Bullying including cyberbullying

Bullying is behaviour by an individual or group, repeated over time, that intentionally hurts another individual or group either physically or emotionally. Bullying can take many forms (eg cyber-bullying via text messages or the internet), and is often motivated by prejudice against particular groups. Many experts say that bullying involves an imbalance of power between the perpetrator and the victim. The imbalance of power can be physical, psychological (knowing what upsets someone), derive from an intellectual imbalance, or by having access to the support of a group, or the capacity to socially isolate. It can result in the intimidation of a person or persons through the threat of violence or by isolating
them either physically or online.
Technology has provided a new medium for ‘virtual’ bullying. Cyber-bullying can happen at all times of the day, with a potentially bigger audience, and more accessories as people forward on content at a click.

2. Child sexual exploitation(CSE)

Exploitative situations, contexts and relationships where young people receive something (for example food, as a result of engaging in sexual activities. Sexual exploitation can take many forms ranging from the seemingly ‘consensual’ relationship where sex is exchanged for affection or gifts, to serious organised crime by gangs and groups. (from Keeping children safe in education; Statutory guidance for schools and colleges; April 2014)

3. Domestic abuse

The cross-government definition of domestic violence and abuse is:

any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. The abuse can encompass, but is not limited to:

  • psychological
  • physical
  • sexual
  • financial
  • emotional

4. Drugs

In this guidance document, where the document refers to drugs, this includes alcohol, tobacco, illegal drugs, medicines, new psychoactive substances (“legal highs”) and volatile substances, unless otherwise specified.

5. Fabricated for induced illness

There are three main ways of the carer fabricating or inducing an illness in a child. These are not mutually exclusive and include:

  • fabrication of signs and symptoms. This may include fabrication of past medical history;
  • fabrication of signs and symptoms and falsification of hospital charts and records, and specimens of bodily fluids. This may also include falsification of letters and documents;
  • induction of illness by a variety of means.

6. Faith abuse

This includes:
belief in concepts of witchcraft and spirit possession, demons or the devil acting through children or leading them astray (traditionally seen in some Christian beliefs)
the evil eye or djinns (traditionally known in some Islamic faiths contexts) or dakini (in the Hindu) context)
ritual or muti murders where the killing of children is believed to bring supernatural benefits or the use of their body parts is believed to produce potent magical remedies
use of belief in magic or witchcraft to create fear in children to make them more compliant when they are being trafficked for domestic slavery or sexual exploitation

7. Female genital mutilation (FGM)

Female genital mutilation includes any procedure involving injury to the female genital organs for non-medical reasons including the partial or total removal of the female external genitalia.
There are four types of FGM, ranging from a symbolic prick to the vagina to the fairly extensive removal and narrowing of the vagina opening.
FGM is also sometimes known as ‘female genital cutting’ or ‘female circumcision’. However, circumcision is not an appropriate term.
Communities tend to use local names for referring to this practice including ‘sunna’.

All forms are illegal in this country? and arranging for FGM to be carried out abroad is also illegal.

8. Forced marriage

A marriage in which one or both spouses do not (or, in the case of some adults with learning or physical disabilities, cannot) consent to the marriage and duress is involved. Duress can include physical, psychological, financial, sexual and emotional pressure.

9. Gangs and youth violence

‘Street gangs’ for whom crime and violence are a core part of their identity, although ‘delinquent peer groups’ can also lead to increased antisocial behaviour and youth offending. Although some group gatherings can lead to increased antisocial behaviour and youth offending.
These activities should not be confused with the serious violence of a gang.

10.Gender-based violence/violence against women and girls (VAWG)

Refers to violence, physical, sexual or otherwise, stalking and harassment and female genital mutilation.

Recognising and preventing FGM e-learning –

11.Mental health

Good or positive mental health is more than the absence or management of mental health issues; it is the foundation for wellbeing and effective functioning both for individuals and for their communities.–2

12.Modern Slavery

Spot the signs: physical appearance, isolation, poor living conditions, few or no personal possessions, restricted
freedom of movement, unusual travel times, reluctant to seek help. Not just domestic also nail bars, car washes etc

13.Private fostering

A private fostering arrangement is essentially one that is made privately (that is to say without the involvement of a local authority) for the care of a child under the age of 16 (under 18, if disabled) by someone other than a parent or close relative with the intention that it should last for 28 days of more.


‘Radicalisation’ is the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.
The current UK definition of ‘terrorism’ is given in the Terrorism Act 2000 (TACT 2000). In summary this defines terrorism as 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.

‘Extremism’ is the vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.’ It also includes calls for the death of members of our armed forces, whether in this country or overseas (2011 Prevent strategy)


‘Sexting’ is the exchange of self-generated sexually explicit images, through mobile picture messages or webcams over the internet.
Young people may also call it:

  • Cybersex
  • Sending a nudie, picture or selfie.


16.Teenage relationship abuse

Relationship abuse can include emotional, physical, sexual or financial abuse. See Appendix 1 for examples of each.:


Human trafficking is recruiting, transporting, harbouring or receiving people for the purpose of exploitation. Threats, force, coercion, abduction, fraud, deception, abuse of power or vulnerability or the giving or receiving of payments or benefits will have been used to achieve the consent of the person,. Exploitation includes prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs.

(from Palermo Protocol To Prevent, Suppress And Punish Trafficking in Persons, Especially Women And Children, Supplementing the United Nations Convention Against Transnational Organised Crime to the UN Convention (2000))


Appendix 3 – Regulated Activity Decision Making Flowchart

Appendix 4 – Skills and Learning staff roles and eligibility for DBS (including subcontractor and partner)

For all positions the following actions should be in place:

  • Safeguarding questions at selection
  • References
  • Risk assessment
  • Vigilance
  • Posters/Learner handbook
  • Alerting guide
  • Code of conduct


RoleDescriptionEvidenceActionDBS application category
1.Tutor or Assessor of
adults at risk or in care
1. Adult Care Assessor with
frequent access to nursing and care homes
2. Tutor of programme
targeted at adults formally
considered ‘vulnerable’
because of age, disability,
learning difficulty
Former definition of
regulated activity. DBS
answer to query
Qualifies under Rehabilitation of
offenders act1974
(exceptions), point 04
Enhanced DBS, not including barred listTutor Assessor (unreg)
2. Tutor or Assessor with regular or frequent
access to children
1. Tutor – teaching 4 sessions or more in any 30 day period, including under 18 year old in any setting
2. Assessor employed to assess 16-18 year olds
3. Tutor or assessor teaching or assessing adults in children’s centre or school during normal
Regulated activity,
Specified Place Teaching, training, supervising, meets frequency criteria
Enhanced DBS for
children, including
barred list
Tutor Assessor (reg children)
3. Manager (unreg)Managers of tutors or assessors teaching groups targeted at adults at risk, or teaching/assessing in care settingse-mail BoP HR 24/7/14
‘management has the power to influence/hide
or collude in behaviours’
Enhanced DBSManager (unreg)
4. Manage (reg children)Manager of tutor or assessor eligible for enhanced DBS for children including barred liste-mail BoP HR 24/7/14
‘management has the power to influence/hide
or collude in behaviours’
Enhanced DBS for children, including barred listManager (reg children)
5. Volunteers and support staffunsupervised new
volunteers and support staff in any setting or class targeted or not targeted at vulnerable adults
Staff not always
supervised. Qualifies under Rehabilitation of offenders act1974 (exceptions), points 03 and 04
Enhanced DBS excluding barred listLearning support
(unpaid) And Learning
support (paid)
6. Other rolesTutors, assessors and managers not included above, administration, customer service, models, mentors, observers etcNot regulated activity,
specified place, not
previously in scope in
Vulnerable Groups Act
Not eligible for DBS


Appendix 5 Safeguarding Alerting Guide for staff and volunteers

What to do if you see, are told about or suspect harm, abuse, radicalisation or have a welfare concern