The D Foundation is committed to ensuring the welfare and safety of all learners, staff and visitors, in particular those who are young people, children (under 18 years of age) and vulnerable adults (hereafter referred to as vulnerable persons). Our Safeguarding Policy covers the way in which we promote this and manage it within the company. Our Policy also links to QAA Quality Code and National Legislation. This document is designed to underpin the culture of the safeguarding requirements to ensure learner and staff welfare.
This commitment entails that all individuals who undertake work on behalf of The D Foundation, who have direct contact with these learners, are suitable for employment within a position of trust.
All members of the management team are fully committed to this policy. The operation and effectiveness of this policy will be kept under regular review.
Within this document and any referenced documents, where the term Designated Safeguarding Officer SO) is referenced it is implied that in their absence the Deputy SO will assume the role.
This policy and related procedures are based on the following principles:
The welfare of vulnerable persons is of primary concern.
All vulnerable persons and those with protected characteristics, whatever their age, gender, gender identity, culture, disability, ability, language, racial origin, socio-economic status, religious belief and / or sexual identity, have the right to safeguarding from abuse.
It is everyone’s responsibility to report any concerns about abuse to the SO who will act upon the report and inform, as appropriate, the relevant Local Authority Safeguarding Board and / or Disclosure and Barring Service (DBS). Where appropriate, the conduct of a joint investigation is the responsibility of the Local Safeguarding Children Board (LSCB) / Local Safeguarding Adults Board (LSAB) and the Police with which full cooperation will be given.
All incidents of alleged poor practice, misconduct and abuse will be taken seriously and responded swiftly to and appropriately.
All personal data will be processed in accordance with the requirements of the Data Protection Act 2018 and GDPR.
Promoting the Safeguarding Policy
This Policy and need for Safeguarding compliance is promoted in the following ways.
Employees: All employees receive Safeguarding training during induction and at regular intervals with an annual re-training schedule. Safeguarding is on the Agenda for all Senior Management Team meetings and Standardisation meetings to ensure the policy is rigorously enforced an any learners that of concern are identified and discussed between the relevant team members.
Employers: All employers of learners or apprentices are issued with our Safeguarding Policy and this is discussed with their relevant contact with The D Foundation, together with the procedures should a Safeguarding event be identified. We will also offer training and guidance where required.
Learners and Apprentices: Safeguarding is discussed, and the Policy explained at the Information Advice and Guidance session. It is further discussed at all reviews with questions to ensure the learner/apprentice can provide evidence of their knowledge and understanding. Safeguarding is also included within the learner handbook issued on induction.
All staff and learners/apprentices are requested to sign a confirmation statement that they have been issued with, received training on, and understand the Safeguarding Policy.
To further promote and endorse this policy and the process, posters are displayed within training rooms, toilets and other prominent locations regarding who and how to contact in the event of a Safeguarding concern.
Since the pandemic more learners receive online training and as such this e-Safety element has been incorporated into the Safeguarding Policy. An eSafety incident is one where the misuse of technology has had a negative impact on the safety, security or wellbeing of young learners or staff members.
This can be completed on a computer by taking a “screenshot”. Alternatively press the “print Screen” button on the computer where the offending material is visible on the monitor. Open a second program (e.g. Word or PowerPoint) and “paste” the image. In most programs this can be done by right-clicking anywhere on the page, then click “paste”. Type the computer number, the username and the name of the person taking the screenshot under the image before saving this file in a safe location (e.g. a password protected mobile device).
Laws that may be contravened include The Computer Misuse Act 1990. The Protection from Harassment Act 1997, The Malicious Communications Act 1988 and Section 127 of the Communications Act 2003.
Phone telephone number 999 and ask for the Police if urgent, otherwise speak to the Safer Neighbourhood Team, and inform of the evidence/materials you have found.
Internet Watch Foundation – www.IWF.org.uk, and click “report criminal content”.
Child Exploitation and Online Protection www.ceop.gov.uk/reportabuse/, and click “report” on the home page.
Use the “screenshot” method listed above but in the presence of a witness to demonstrate you have not tampered with the evidence. Sign a print out of the evidence file and have the witness countersign it. Then remove the computers involved from the network and store them securely.
If the evidence is on a mobile device (e.g. mobile phone) ask the young person not to use the device until the Police have confirmed whether they would like to see it. If the young person needs to continue using it ask to take photos of the screen with a witness present and ask the learner to not delete any evidence. The phone may be confiscated if necessary.
The person who published the offending information is most able to remove it.
What is abuse?
Abuse is any behaviour towards a person that deliberately or unknowingly causes them harm, concern, endangers life or violates their rights.
Abuse may be:
• Psychological – repeatedly being made to feel unhappy, humiliated, afraid or devalued by others
• Financial or Material – stealing or denying access to money or possessions
• Discriminatory – abuse motivated by discriminatory attitudes towards race, religion, gender, gender identity, disability, ability, cultural background, or sexual identity
All staff and trainees are required to take shared responsibility for the safeguarding and safety of any vulnerable persons whilst on learning programmes delivered by us or any of our agents irrespective of location.
All The D Foundation staff are in a position of trust, in particular those staff who teach, support, and guide or in any way interact with students and vulnerable persons visiting the Technology Centre and any other location being used during training.
The Directors of The D Foundation has responsibility for the oversight of the Safeguarding and Vulnerable Adults Policy with delegated responsibility to relevant members of the Management Team.
We have Staff Recruitment and Training Procedures in place to check the suitability of staff working directly with vulnerable persons. These procedures draw on the guidance provided by “Safeguarding Children and Safer Recruitment in Education” published by DCSF and include reference to a Policy Statement on the Recruitment of Ex-Offenders.
We already have processes in place to check the suitability of some staff working directly with vulnerable persons within Regulated and Controlled Activities as defined by the Disclosure and Barring Service (DBS). Staff who have regular access or significant occasional contact with vulnerable persons in the course of their teaching, assessing or other work activities, will need to have satisfactory and up-to-date Disclosure and Barring Service (DBS).
The D Foundation will raise awareness of safeguarding issues with staff and employers and to share examples of good practice.
We will inform learners of their rights and responsibilities and to raise awareness of safeguarding issues.
We will additionally ensure that all student helpers, mentors, trainee tutors / instructors / assessors etc. who are in regular or significant occasional contact with vulnerable persons must have had a satisfactory enhanced DBS check undertaken by The D Foundation before allowing them to work with vulnerable persons.
A ‘satisfactory’ check is defined as having no criminal convictions (including cautions, reprimands and final warnings) relevant to the post and the protection of vulnerable persons.
All staff must report any subsequent criminal convictions immediately. Failure to do so will result in disciplinary action being taken and, if appropriate, The D Foundation will notify the Local Authority Safeguarding Board and / or the DBS.
Establishing a caring environment
All staff are responsible for making our facilities a safe and caring environment for all, including vulnerable persons.
A caring environment is one:
• in which the health, safety and welfare of vulnerable persons has been assessed and catered for
• in which staff are aware to the possibility of abuse and take measures to prevent that possibility
• where there is a sound and known reporting system for any incident
• where staff take reasonable and practical precautions to avoid any suspicions of abuse being brought against them
• where staff feel safeguarded and work within a supportive environment
The D Foundation is safeguarding against abuse by:
a) Establishing a safe learning environment in which all learners and apprentices can learn and develop.
b) Developing and using safe recruitment procedures and to ensure that any Institute member who has substantial contact with vulnerable adults will be checked for relevant criminal convictions whenever appropriate and possible within the constraints of legislation. An enhanced disclosure (DBS) check will be required.
c) Ensuring that all applicants are required to complete and sign an application form.
d) Seeking references from all applicants.
e) Helping to equip employers, staff, learners and apprentices with information and awareness to keep themselves safe.
f) Maintaining clear procedures to identify and report suspected cases of abuse.
g) Ensuring all staff are aware of these procedures and trained in their use as appropriate.
h) Providing appropriate support to learners who have been abused.
Where under-18s are concerned there are statutory responsibilities for any organisation to follow regarding the safety of young people. The controls in place to meet these statutory responsibilities are considered good practice and are used for all vulnerable persons.
All staff MUST contact the SO if they have cause to believe a student or vulnerable persons involved in any activity, covered by this policy is in any way at risk. The relevant procedures will then be followed.
Records will be kept of all such incidents and their outcomes and held securely within the office of the Manager, Apprentices and Skills in accordance with the Data Protection Act 2018 and GDPR.
All staff should be aware that in accordance with statutory requirements where vulnerable persons safeguarding issues are involved, it is not possible to offer confidentiality to a person under 18 as any disclosures must be reported.
Where possible, The D Foundation will identify vulnerable persons and ensure that there are appropriate support measures are in place. This is most likely to be identified during the recruitment process, where a referral can be made, that clearly identifies the learner as having mental health difficulties or a disability that puts them into the legal definition of ‘vulnerable’.
Any member of staff with concerns regarding any learner whom they believe or know to be vulnerable must raise their concerns immediately with the SO.
Any person on an a programme with concerns regarding any learner whom they believe or know to be vulnerable may also raise their concerns immediately with the SO.
Recording and monitoring
All members of staff working closely with vulnerable persons have to be alert to possibilities of abuse and any concerns about the behaviour of any adult with respect to that vulnerable person should be reported to a senior member of staff who will decide what further action to take.
It is the duty of staff to inform only not to investigate – this is the role of the Police and Local Authority.
If staff, in the course of their work, have a safeguarding issue brought to their notice, this must be treated as priority over all other work.
Guidance with regard to a specific incident may be obtained from the SO.
An oral, then written report should be provided to the SO who will keep a confidential record of any such incidents held securely within the office of the Directors.
Allegations of abuse or inappropriate behaviour involving staff
Allegations involving a member of staff and vulnerable persons should be reported to a senior member of staff.
Consideration will be given as to whether the situation falls within the definition of abuse (See “What is abuse?”).
The D Foundation management team will ensure that staff who are likely to be in regular contact with vulnerable persons receive appropriate Level 1 and 2 Safeguarding Training is held for key personnel to ensure that they have the necessary awareness to safeguard the learners in their care. These key personnel include all staff who come in contact with a learner.
We will provide information to raise awareness to ensure that all staff understands what to do if a student or visitor covered by this policy discloses abuse or any other safeguarding issue.
Relationships with young people aged 16-18
It should be noted that whilst a young person can consent to sexual activity once they reach the age of 16, the Sexual Offences (amendment) Act 2000 makes it a criminal offence for a person to engage in any kind of sexual activity with a person under 18 where the adult is in a position of trust.
For any activity involving young people, parent or guardians must be given the opportunity to refuse permission for photographs, videos or other images to be made of their children and for the children interviewed by press, broadcasters or other media.
Code of Good Practice
The following guidelines are intended to be a common-sense approach that both reduce the opportunities for the abuse of vulnerable persons and help to protect staff and students from any false allegation.
• Treat all vulnerable persons with respect and respect their right to personal privacy.
• Ensure that, whenever possible, there is more than one adult present during activities or that you are within sight or hearing of others. (try to avoid one-to-one situations)
• Report any signs of Radicalisation to the SO such as changes in dress sense, written work showing interests or positive views on extremism, possession of materials or symbols etc.
• Exercise caution when discussing sensitive issues with vulnerable persons.
• Exercise caution in initiating any physical contact with a vulnerable person.
• Operate within the guidance offered by this Code of Good Practice.
• Challenge all unacceptable behaviour and report all allegations or suspicions of abuse.
• Keep parents fully informed of all anticipated activities.
You SHOULD NOT:
• Spend excessive time alone with vulnerable persons away from others.
• Take vulnerable persons alone in a car journey, however short.
• Take vulnerable persons to your home.
• Engage in physical or sexually provocative games including horseplay.
• Allow or engage in inappropriate touching of any form.
• Make over-familiar or sexually suggestive comments or approaches to a vulnerable person as a ‘joke’.
• Let allegations, over familiar or sexually suggestive comments or approaches made by vulnerable persons go unchallenged or unrecorded.
• Do things of a personal nature that vulnerable persons can do for themselves.
• Take photographs, videos or other images of a young person without the express permission of their parents.
• All staff should avoid connecting with students through social media channels such as Twitter, Facebook, Instagram and Snapchat etc.
This document will be reviewed annually or whenever there is a change in statutory law or best practice.