Safeguarding and Prevent Policy and Procedures

1. Our commitment

All our employees who work with learners have a crucial role to play in shaping their lives by bringing a unique opportunity to interact in ways that are inspiring. This policy has been produced to help establish safe and responsive environments which safeguard all and reduce the risk of our staff being unjustly accused of improper or unprofessional conduct. We all have a duty of care to safeguard and promote welfare, and to enhance awareness of the broader welfare spectrum, specifically the issues facing young people and adults in society.

2. Purpose

The aim of the policy is to ensure our staff are aware of and understand their responsibilities, that of others, signs there might be a safeguarding concern, along with the reporting procedures for all safeguarding issues.

3. Scope

This policy covers safeguarding of our learners, both Children and Adults at Risk, within our main provision and our sub contracted provision. It is inclusive of specific highlighted safeguarding agenda areas – as defined by law, and in the wider context all our students and learners. This policy also aligns our compliance with the Government Prevent strategy.

4. Swatpro Key Contacts - See Appendix L

Swatpro Lead Designated Officer

Name: Kathleen Harrison-Ford

Qualification: NSPCC Level 3 Designated Safeguarding Lead

Date achieved: 03.10.2019 Email: supportme@swatpro.org.uk

Tel no: 01392 437659

Swatpro Deputy Designated Officer

Name: Jenny Scott

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11.12.2019

Email: supportme@swatpro.org.uk

Tel no: 01392 437659

Swatpro Nominated Director

Name: Rod Davis

Tel no: 01392 437659

Swatpro Out-of-hours Contact Number

07860 804249

4.1 Key Contacts Swatpro Partners

Absolute Training

Designated Safeguarding Lead

Name: Nyc Whitworth

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11th Dec 2019

Tel no: 07738 242186

Deputy Safeguarding Lead

Name: Gavin Whitworth

Qualification:

Date achieved:

Tel no:

Nominated Director/Owner

Name: Nyc Whitworth

Tel no: 07738 242186

BEMA

Designated Safeguarding Lead

Name: Dave Alma

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11th Dec 2019

Tel no: 03330 235347

Deputy Safeguarding Lead

Name: Martin Wear

Qualification: Level 3 Safe & Equal Learning Partnership (Safeguarding update and refresher)

Date achieved: 18.12.2018

Tel no: 03330 231356

Nominated Director/Owner

Name: Dave Alma

Tel no: 03330 235347

Channel Training

Designated Safeguarding Lead

Name: Darren Sherwood

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11th Dec 2019

Tel no: 01643 708715

Deputy Safeguarding Lead

Name: Karen Garwood

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11th Dec 2019

Tel no: 01643 708715

Nominated Director/Owner

Name: Darren Sherwood

Tel no: 01643 708715

F-TEC

Designated Safeguarding Lead

Name: Vicki Cartner

Qualification: CPD – Child Protection – Designated Professional

Date achieved: 03.01.19

Tel no: 01793 686182

Deputy Safeguarding Lead

Name: Geoff Wall

Qualification: Training booked 4th February 2020

Date achieved: Training booked 4th February 2020

Tel no: 01793 686182

Nominated Director/Owner

Name Karl Baum

Tel no: 01793 686182

Hudson Training

Designated Safeguarding Lead

Name: Natalie Vickery

Qualification - On programme currently "Designated safeguarding officer Training" (level 3)

NCFE level 2 Safeguarding and prevent 06/03/19

EAT foundation Prevent training 4 x modules 09/11/19

Tel no 01823 368020

Deputy Safeguarding Lead

Name: Neil Young

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11th Dec 2019

Tel no: 01823 368020

Nominated Director/Owner

Name: Neil Young

Tel no: 01823 368020

NBT

Designated Safeguarding Lead

Name: Rebecca Elliott

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11th Dec 2019

Tel no: 07543 609119

Deputy Safeguarding Lead

Name:

Qualification:

Date achieved:

Tel no:

Nominated Director/Owner

Name: Jonathan Hall

Tel no: 0117 414 9259

Paignton SEC

Designated Safeguarding Lead

Name: Pippa Garrigan

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11th Dec 2019

Tel no: 01803 559816

Deputy Safeguarding Lead

Name: Sarah Abbott

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11th Dec 2019

Tel no: 01803 559816

Nominated Director/Owner

Name: Pippa Garrigan

Tel no: 01803 559816

Puffins

Designated Safeguarding Lead

Name: Sue Holding

Qualification: L3 Advanced Safeguarding – Delivered by Devon County Council

Date achieved: Oct 2016, updated Nov 2019

Tel no: 01392 496017

Deputy Safeguarding Lead

Name: Gemma Rolstone

Qualification: Safeguarding forum for safeguarding lead professionals, with Badcott

Date achieved: 26/09/2019

Tel no: 01392 496017

Nominated Director/Owner

Name: Gillian Fawcett

Tel no: 01392 496017

RD&E

Designated Safeguarding Lead

Name: Karoline Callard

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11th Dec 2019

Tel no: 01392 408132

Deputy Safeguarding Lead

Name: Mandy Cheyne

Qualification:

Date achieved:

Tel no: 01392 408132

Nominated Director/Owner

Name: Claudia Trick

Tel no: 01392 408132

Train4All

Designated Safeguarding Lead

Name: Victoria Smith

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11.12.2019

Tel no: 01747 854917

Deputy Safeguarding Lead

Name: Liz Wilson

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11.12.2019

Tel no: 01458 274043

Nominated Director/Owner

Name: Jon Allen

Tel no: 01458 274043

Varsity Training

Designated Safeguarding Lead

Name: Stacey Stone

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11.12.2019

Tel no: 01934 808591

Deputy Safeguarding Lead

Name: Angela Elliott

Qualification: Safeguarding Essential including prevent

Date achieved: Jan 19 valid for 3 years

Tel no: 01934 808591/07868016809

Nominated Director/Owner

Name: Del Wraight

Tel no: 01934 808591

Wessex Training

Designated Safeguarding Lead

Name: Lynn Croucher

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11.12.2019

Tel no: 01305 770007

Deputy Safeguarding Lead

Name: Andrea Serlin

Qualification: Prevent and Safeguarding

Date achieved: 2016

Tel no: 01305 770007

Nominated Director/Owner

Name: Lynn Croucher CEO

Tel no: 01305 770007

White Horse Training

Designated Safeguarding Lead

Name: Yvonne Greenwood

Qualification: Safeguarding Associates for Excellence Level 3 Designated Safeguarding Lead

Date achieved: 11.12.2019

Tel no: 01225 460167

Deputy Safeguarding Lead

Name:

Qualification:

Date achieved:

Tel no:

Nominated Director/Owner

Name: Nicola Bevan

Tel no: 01225 460167

Working Knowledge

Designated Safeguarding Lead

Name: Joanna Trendall

Qualification: Enhanced DBS, DSL and PREVENT one day training delivered by Ofsted

Date achieved: 8th Nov 2018

Tel no: 07867 555713

Deputy Safeguarding Lead

Name: James Lott

Qualification:

Date achieved:

Tel no: 07980 589427

Nominated Director/Owner

Name: James Lott

Tel no: 07980 589427

5. Definitions

Safeguarding is the protection of children and adults at risk from abuse and neglect, promoting health and development, ensuring safety and care, and ensuring optimum life chances. The Safeguarding Agenda includes a wide range of potential risks (see appendix F for full definitions and indicators of a Safeguarding concern).

  • Abuse
    • Physical,
    • Domestic Violence,
    • Sexual,
    • Psychological,
    • Financial or material,
    • Modern Slavery
    • Discriminatory
    • Organisational
    • Neglect of act of omission
    • Self-neglect
  • Child sexual exploitation
  • Bullying AND cyberbullying
  • Substance misuse
  • Fabricated and induced illness
  • Faith abuse
  • Forced marriage
  • Gang and youth violence, including County Lines
  • Private fostering
  • Female genital mutilation (FGM)
  • Gender based violence
  • Radicalisation
  • Sexting
  • Teenage relationship abuse
  • Trafficking and modern slavery
  • Breast ironing
  • Mental health concerns
  • Children missing in Education
  • Upskirting

A Child is defined as anyone under the age of 18. An adult at risk (previously vulnerable adult) is defined as any person over the age of 18 and at risk of abuse or neglect because of their need for support or personal circumstance. Alongside the Safeguarding Agenda above this could be due to, and not limited to any of the following:

  • Living in sheltered housing
  • Receiving any form of health care
  • Receiving a welfare service in order to support their need to live independently
  • Receiving a service due to their age or disability
  • Living in residential accommodation such as a care home
  • Receiving domiciliary care in their own home
  • Expectant or nursing mother living in residential care
  • Person under supervision of probation service
  • Mental health

While the definitions of a child and adult at risk give the rationale for legislative intervention, it is important to note that a person may be deemed at higher risk of a safeguarding issue affecting them due to other factors, examples:

  • Poor numeracy and literacy skill, or specific learning need
  • Unsupportive home environment
  • English not a first language
  • Unsupportive employer
  • Under represented group
  • Acting as a carer for another family member
  • Background in offending
  • Disability or social need

6. Our responsibility

We all have a responsibility to ensure that children, young people and adults at risk are protected from harm, informed about potential risks to their welfare, and understand how to seek help. We ensure all concerns are dealt with timely and appropriately.

We also have a responsibility to minimise the risk of allegations against our staff.

All staff are expected to comply with any DBS check request and to have a good understanding of what constitutes a safeguarding or welfare concern and how to provide support, guidance in such instances and the channels for escalating a concern. To assist in this, we provide on-going training and awareness, as well as continuous information, advice and guidance which will help our staff to feel confident in proactively promoting safeguarding and understanding their individual responsibilities.

The responsibilities of particular individuals are detailed below:

  • Our CEO - to ensure we have effective policies, and these are implemented and followed, and sufficient time and resources are allocated to employees to carry out their responsibilities.
  • Designated Safeguarding Lead – to maintain links with Local Safeguarding Children’s Boards, Local Safeguarding Adult’s Boards and Prevent Channel team, inform and advise all parties on legislation changes and current safeguarding themes, plan and implement training for all employees including CPD, quality assurance and standardisation for the designated safeguarding officer team. Carry out investigations where appropriate into welfare concerns reported and liaise with external bodies such as safeguarding board where appropriate. Support and coordinate escalation process. Overall management of safeguarding issues and report to Swatpro Management Team of issues that arise. Review procedures and policies on a timely basis. Maintain own CPD to ensure their role can be fulfilled competently. To ensure Swatpro Partners have a DSL, deputy and that the owner/Director has a Strategic view of Safeguarding and Prevent to ensure the safety of our learners. To audit partners safeguarding and prevent practice.
  • Designated Safeguarding Officers – to deal with employee concerns over learner’s welfare, signpost and offer guidance. Carry out investigations where appropriate into welfare concerns reported and liaise with external bodies such as safeguarding board where appropriate. Maintain own CPD to ensure their role can be fulfilled competently and seek guidance where appropriate. Act as DSL in DSL absence.
  • Our Trainers/Tutors - to check safety and welfare with all learners at each visit/communication, ensuring learners complete all safety related learning activities within their programme. You must be aware of indicators and that there may be a safeguarding issue Appendix E, and if required to follow the 5 R’s procedure - our flow chart for reporting issues that concern them or are reported to them (see Appendix D). To provide support and referral to external agencies as they see fit, if comfortable to do so, and then inform safeguarding team of their actions. To carry out training as directed by the safeguarding team in a timely manner.
  • Support Teams - You must be mindful of indicators that there may be a safeguarding issue should you come into contact with a learner or potential learner – see Appendix E, and if required to follow the 5 R’s procedure - our flow chart for reporting issues that concern them or are reported to them (see Appendix D). To carry out training as directed by the safeguarding team in a timely manner.
  • Our Swatpro Partners – Must have a Safeguarding and Prevent designated lead, a Safeguarding and Prevent deputy, out of hours cover and a Director or Owner who oversee the strategic direction, the self-assessment and ensures the DSL has capacity and undertakes their role. This should be detailed in their Job Description. Partners are responsible and accountable for responding to a concern or disclosure and must keep their own records. Partners must ensure that all their staff know the signs of abuse and radicalisation and know how to act. Every Safeguarding or Prevent concern must the notified to the Swatpro DSL. Partners must comply with Swatpro DSL for audits.

6.1 Review of Safeguarding Policy and Procedures

These procedures are reviewed annually aligned with other policy reviews and the Self-Assessment Review (SAR) and also when new law and/or government guidance is issued.The review of the policy and procedures sits with the Designated Safeguarding Lead.

See Appendix K for reviews.

7.0 Safer Recruitment

Swatpro carries out a safe recruitment process and ensures that all appropriate checks are carried out on new staff, including volunteers that will work or come into contact with children, young people and adults at risk in line with the Disclosure and Barring Service requirements. Swatpro holds a Single Central Record which is updated annually and as new staff are recruited.

Swatpro has systems for the early identification, recording and flagging as appropriate of welfare, learning and potential safeguarding needs of learners at time of recruitment.

All 16 to 18-year olds, from moment of recruitment and throughout the learner journey are considered to be a specific cohort at greater risk due the vulnerabilities associated with their age. Additional safeguarding considerations are given to this group in every aspect of their training and working life to counter these risks.

Employers themselves are not subject to the Duty or to statutory requirements in respect of safeguarding in the same way that providers are (unless the employer themselves are a “specified authority”). Therefore, Swatpro ensures that employers are sufficiently well informed to understand their vital role as cooperative partners with providers when undertaking to take learners on training programmes.

7.1 Disclosure and Barring Service Checks

The Disclosure and Barring Service (DBS) is an executive agency of the Home Office and its primary purpose is to help employers make safer recruitment decisions and appointments. By conducting checks and providing details of criminal records and other relevant information, DBS helps to identify applicants who may be unsuitable for certain work and positions, especially those involving contact with children (those less than 18 years old) or adults at risk.

Depending on the type and regularity of contact with children or adults at risk involved in a particular role, employers are entitled to make appropriate types of enquiry about the applicant’s criminal record and seek a disclosure through a DBS check. Swatpro can undertake five types of criminal records checks depending on the role applied for:

1.Standard DBS check

This will be for positions that are included in the Rehabilitation of Offenders Act (ROA) 1974 (Exceptions) Order 1975. This type of check contains details of individual’s convictions, cautions, reprimands or warnings recorded on police central records and includes both ‘spent’ and ‘unspent’ convictions that will be shown on a criminal records check.

2. Enhanced DBS check

This will be for positions included in both the ROA 1974 Exceptions Order and in the Police Act 1997 regulations. This type of check contains the same details as the standard check plus any information held locally by police forces that it is reasonably considered to be relevant to the post applied for.

3. Enhanced DBS & barred list check (child)

An enhanced check with information from the DBS’s children’s barred list is only available for those individuals engaged in regulated activity with children and a small number of posts as listed in the Police Act 1997 regulations.

4. Enhanced DBS & barred list check (adult)

An enhanced check with information from the DBS’s adults barred list is only available for those individuals engaged in regulated activity with adults and a small number of posts as listed in the Police Act 1997 regulations.

5. Enhanced DBS & barred list check (child and adult)

An enhanced check with information from the DBS’s children and adults barred list is only available for those individuals engaged in regulated activity with both vulnerable groups including children and a small number of posts as listed in the Police Act regulations.

7.2 When and What Type of DBS Check is Appropriate

Swatpro's CEO (in consultation with HR partner) and Designated Safeguarding Lead are responsible for deciding which level of check is appropriate for a particular role and whether barred list checks are necessary. Even where a post has some contact with children or adults at risk, the definition of regulated activity may not be fully satisfied, but in order to safeguard our learners any unsupervised contact with learners will result in an enhanced DBS check with child barred list. The Safeguarding Vulnerable Groups Act 2006 (amended by the Protection of Freedoms Act 2012) defines what types of activities involving children and adults at risk are regulated and therefore require barring list checks. Appendix A specifies current posts at Swatpro that require DBS and/or barring list checks.

Regulated Activity – is a term that defines activities that an individual engages in. The criteria for regulated activity differ for adult and children as shown overleaf:

Children

  • Regular activity (once per week or 4 times over the course of 1 month)
  • Unsupervised activity
  • Teaching, training, assessing, mentoring based activities in relation to non-work-related activities - working intensively and closely with a child within a specified setting

Adult

  • Health care professionals - giving first aid or receiving first aid
  • Receiving or giving personal assistance to those due to age, illness or disability (going to the toilet/ washing/ nutritional advice)
  • Providing social care - being subject to or assessing the need for health/ social care
  • Providing assistance in someone’s personal affairs or allowing someone else to do so
  • Provide assistance with cash, bills and shopping (allowing someone else to or shopping on someone’s behalf)
  • Person who transports or is transported because of their illness

Individuals must not engage in regulated activity with either children or adults at risk if they have been barred from doing so by the Disclosure and Barring Service (DBS). How we meet our responsibility towards this is explained below.

Where Swatpro is recruiting for a role that qualifies for a DBS disclosure, the advert and further information will confirm the type of DBS disclosure required. When the most suitable candidate for the position has been identified, the offer of appointment will be made subject to a satisfactory DBS, right to work, references and qualification checks. In the instance that the outcome of a DBS check has not been received from the appropriate authority prior to learner visits being carried out, all visits with learners aged below 18 will be supervised by a person whose DBS outcome has been received and approved. The team manager will be responsible for arranging this supervision. Quality assurance of this process will take place on a weekly basis.

As a DBS check forms part of our recruitment process, we encourage all candidates to declare anything relevant to the type of disclosure required for the role they applied for. Once an offer has been made, candidates should tell us of any further details of convictions, including those that normally would be considered as spent, cautions or reprimands.

As part of our safeguarding obligations, we will re-apply for the appropriate types of DBS checks on a 3-year basis during employment with Swatpro.

7.3 Confidentiality

Information provided in a DBS disclosure report must be kept confidential and only on a need-to-know basis. Such information will be handled in accordance with Swatpro’s ‘Statement on the Secure Storage, Handling, Use, Retention and Disposal of Disclosures and Disclosure Information’, Appendix B. Any other information regarding offences must be kept securely and in accordance with Swatpro’s Data Protection Policy.

We recognise that job applicants and our employees need to feel confident that information about their convictions will not be disclosed to colleagues unless there is a specific reason for doing so. Those involved in recruitment decisions should ensure that when appointing an individual with a conviction, they are advised as to whom within Swatpro knows of their conviction and the reasons why the information has been disclosed.

For further information on our disclosure process see Appendix C.

7.4 Failure to Disclose Information Relevant to the Type of DBS Check Appropriate to Your Role

Having a criminal record does not necessarily preclude an individual from working at Swatpro. The decision as to whether a person with a criminal record should be appointed, or an offer of employment withdrawn, or employment terminated will be taken only after careful and thorough consideration of the outcome of any DBS check as well as job and offence related factors as explained in 8.6.

Nonetheless we request all employees to tell us about any information relevant to the type of DBS check appropriate for their role. This could mean, for example, that if the role requires satisfactory Enhanced DBS and barring check, there is a need to tell us about any convictions, cautions or reprimands or being barred from working with children as soon as any of these have been issued. Failure to disclose information relevant to the type of DBS check appropriate to the role may be seen by Swatpro as a breach of trust and confidence. Such acts are considered as gross misconduct and the individual would be invited to a disciplinary hearing with a potential outcome of instant dismissal.

7.5 Exploring the Relevance of Information Provided in the Disclosure Report

As we explained in the previous section having a criminal record does not necessarily preclude an individual from working at Swatpro. The decision as to whether a candidate with a criminal record should be appointed, or an offer of employment withdrawn, will be taken only after careful and thorough consideration of the outcome of any DBS check as well as the job and offence related factors as explained in section 8.6.

Similar to the recruitment process, a disclosure of a criminal record will not necessarily lead to termination of your employment with us and the decision will be taken only after careful and thorough consideration of the job and offence related factors. Any decision to terminate employment would follow our Disciplinary Policy (or Probationary Policy if you have not yet passed your probation).

The responsible manager with guidance from an HR Specialist, if required, alongside the Designated Safeguarding Lead, will make an initial assessment of the content of the disclosure report. If the report provides no evidence of convictions or any other related information, no further action will be taken.

If the report confirms a conviction or any other related information, the responsible manager with guidance from an HR Specialist alongside the Designated Safeguarding Lead will make an initial assessment of whether the information provided has any potential relevance to the post. If there is clearly no potential relevance, no further action will be taken.

If the report confirms a potentially relevant conviction or any other potentially relevant information further exploration will be required following the process outlined below.

7.6 Exploring a Conviction and its Relevance

All discussions relating to convictions must take place after the selection process has been completed and will involve the line manager, Senior Management Team and Designated Safeguarding Lead. As part of the decision-making process they will normally meet with the individual to gain more information from the person about the nature and circumstances of any conviction.

The suitability for employment of a person with a criminal record will clearly vary, depending upon the nature of the job and the details and circumstances of any convictions. The decision will be made on the basis of a risk assessment to enable the applicant's criminal record and circumstances to be assessed in relation to the tasks he or she will be required to perform and the circumstances in which the work is to be carried out. The following job-related factors should be taken into account:

  • Does the post involve direct contact with learners or the public?
  • What level of supervision will the post-holder receive?
  • What level of trust is involved? Will the nature of the job present any opportunities for the post-holder to reoffend in the place of work?
  • Does the post involve any direct responsibility for finance or items of value?
  • Does the post involve any contact with children or other vulnerable groups of learners or employees?

The assessment is also likely to include consideration of the following factors relating to the individual’s offence(s):

  • The seriousness of the offence(s) and relevance to the safety of other employees, students, research subjects, the public etc.
  • The length of time since the offence(s) occurred.
  • Relevant information offered by the person about the circumstances that led to the offence(s) being committed, for example the influence of domestic or financial difficulties.
  • The degree of remorse, or otherwise, expressed by the person and their motivation to change.
  • Whether the offence was a one-off, or part of a history of offending.
  • Whether person’s circumstances have changed since the offence(s) was committed, making re-offending less likely.
  • Whether the offence has since been decriminalised.

Following careful and thorough consideration of all these matters and consultation with the Senior Management Team, HE Specialist and Designated Safeguarding Lead, a decision will be made as to whether the individual should be appointed. If appropriate we may seek further information from relevant bodies when reaching this decision. If the decision is not to appoint, a letter will be sent to the individual confirming the reasons for this decision.

The above process will also be followed in the event of a criminal conviction coming to light after the formal offer of employment has been made or during employment. In such cases Swatpro would reserve the right to withdraw the offer of appointment where appropriate or terminate employment in line with the Swatpro’s Disciplinary Policy (or Probationary Policy if in probationary period).

8. Reporting a Concern - see Appendices D for Process Charts

All notes which are taken (in the form they are taken) MUST be retained. These should be attached to the concern or disclosure paperwork and scanned with the electronic versions of the concern or disclosure and stored as per Swatpro storage guidance.

a) If a learner raises a concern/allegation with you: If the learner has a concern over their own personal welfare and wellbeing, you are to listen to and record all information given as soon as possible, without passing any opinion or making any judgement or assumptions. Take any actions required to secure the immediate safety of the child, young person or adult at risk if deemed appropriate, this may involve staying with them until a responsible adult can be located. If the person is at risk of significant harm or is being harmed call the police. All concerns must be reported to the Designated Safeguarding Lead. The designated lead will then decide the appropriate course of action, and if a referral outside the organisation is appropriate. (Appendix D1)

b) If a tutor/assessor has concerns over a learner: This might be through observation, alleged by others or discussion. To follow procedure set out as point (a). (Appendix D1)

c) If a learner/ parent has a concern/ allegation about an member of Swatpro staff : All learners are to be informed that if they have a concern over their own personal welfare and wellbeing and they do not feel comfortable talking to their tutor/assessor about their concerns, they are to contact Swatpro’s Designated Officer. Contact details for the designated person are available in this policy. The safeguarding policy is also available on Swatpro’s external website. (Appendix D2)

d) If a parent contacts you to report a concern about their child. Ensure you listen and record the details as per a learner reporting a concern to you. Ensure you have contact details for the parent. You must report the issue to the designated officer. The designated officer will then decide the appropriate course of action, and if a referral outside the organisation is appropriate, liaise with the parent as appropriate. (Appendix D2)

e) If you observe a safeguarding issue taking place within the working practices of an employer’s setting - example would be a practitioner hitting a child or observing inappropriate restraint techniques. Take action to stop the activity immediately, and inform the individual of your concerns, ask them to remove themselves from the area and advise them you will inform their senior manager. Take any actions to secure the safety of the child or adult at risk, this may involve staying with them until a responsible adult can be located. Inform your designated safeguarding officer. Be mindful of differences between poor practice and a safeguarding issue and apply your action appropriately. (Appendix D3)

f) If a learner reports unsafe practices or safeguarding issues to you within their working environment - Advise the learner to follow in house reporting or whistle blowing procedures. You may support the learner in speaking to the appropriate senior team members. Report the incident to your designated safeguarding officer who will offer additional guidance and signposting for the learner and will monitor. (Appendix D3)

  • If you require an immediate response call your sector designated safeguarding officer immediately, it is noted that the designated officer may not be available out of normal working hours, so in circumstances where the individual is in immediate danger report the incident to the police on 999.
  • The designated officer will endeavour to make initial contact with regards the concerns within 48 hours.
  • The designated officer will assess if the individual is at risk of significant harm and decide upon the next course of action, this can range from offering signposting to support agencies to referral to the police and local safeguarding authorities. This may also involve passing information to the DBS.
  • Also be mindful of any subcontract arrangements in place for the learner. In some instances, safeguarding officers at other companies might need to be informed. Ensure you pass to the safeguarding officer the name of the sub-contractor. For employer providers we partner with, their safeguarding officer must be informed, and they take the lead in dealing with the concern. We will support where required.

g) If anyone has a concern about the Designated Safeguarding Lead – this should be referred to the Deputy Designated Safeguarding Lead who will advise the CEO immediately or the HR support specialist.

Important Information

If you feel the safeguarding concern you have reported is not being dealt with effectively by the safeguarding officer, please refer to the Designated Safeguarding Lead or follow the whistleblowing policy.

If you disagree with the result of a safeguarding referral outcome, please refer to the Safeguarding lead for guidance or you may also follow the local safeguarding board escalation procedure – found on their local authority website.

(See Appendices D and E for process of reporting)

9. Training and Educating Employees

Each member of the safeguarding team has a formal L3 safeguarding qualification and undertake CPD events and standardisation meetings in order to keep updated with legislation and refresh their knowledge.

All employees undertake a Safeguarding Induction and/or completion of a L2 online course specifically for Safeguarding our people. The training received is continually reviewed to ensure most appropriate and up to date training is given. Aligning with the mandatory duty surrounding the Governments Counter Terrorism and Security Act 2015 all staff undertake Prevent training aligning with their role within Swatpro

Periodic updates surrounding key safeguarding concepts are communicated monthly via the internal communication channels. Monthly focus topics are also distributed via these internal communication channels to raise awareness and promote discussion in all areas under the wider safeguarding agenda including areas such as radicalisation, mental health issues, positive relationships, and staying safe on the internet, which will educate employees alongside giving greater knowledge to be passed onto learners.

There is reference to safeguarding in all team meetings utilising the information in the monthly safeguarding and equality to stem discussions. There is also an annual CPD update for formal procedures

Our Designated Safeguarding Lead hosts an online meeting with our partners to discuss the safeguarding agenda, support CDP and keeping current of ‘on the ground’ issues.

10. Keeping Yourself Safe

To maintain yours and the learner’s safety, the following are strictly prohibited:

  • Befriending learners on personal social media sites
  • Distributing personal telephone numbers
  • Visiting learners at home or transporting learners to and from locations (this includes travelling in the car with a learner driving)
  • Using sarcasm, insults or belittling comments towards learners
  • Receiving or giving gifts (detailed in contract of employment)
  • Personal relationships with learners (Position of Trust Offence)

It also important to be mindful of the following when conducting yourself:

  • Locations of a one to one meeting with colleagues. These should take place at a neutral location
  • You will naturally build a rapport with learners through the apprenticeship contact, and the learners may see you as a confidante and support but be sure to maintain professional boundaries whenever carrying out work on Swatpro’s behalf.
  • Be respectful of all young and vulnerable people, and appreciate you are in a position of trust. We have the opportunity to listen to their concerns and support them.
  • Uphold confidentiality within certain remits when required by the situation but be careful not to promise to keep secrets or ask others to do so.
  • Avoid spending time alone with learners in a closed environment. If this is unavoidable for example during a formal assessment/ examination, ensure a member of the site staff is aware where you are and monitors this.
  • Be careful when giving learner advice – as this is based on your opinion, focus support around information (facts) and guidance (signposting).
  • Be mindful of any learners you acquire that by default creates a conflict of interest i.e. a partner or friend becomes a learner. Discuss appropriateness/ alternative assessor arrangements with your line manager.
  • If a learner offers you gifts of any sort as a result of the support through their programme, this is prohibited under your contract of employment.
  • If at any point you feel unsafe in a learner’s company inform the employer, your line manager, the designated safeguarding officer and leave the premises.
  • If at any point you feel unsafe in the employer’s company leave the premises, inform your line manager and the designated safeguarding officer.

11. Keeping Learners Safe

Swatpro provides an employer trifold Safeguarding and Prevent card that is available to employers to help them understand Swatpro and their own responsibilities under Safeguarding and the Prevent Agenda

Swatpro details within the employer contract the responsibilities expected of an employer who has a Swatpro learner.

It is the responsibility of Swatpro and its partners to ensure that employers understand the requirements of The Prevent Duty (and Safeguarding generally) to the sort of issues that may be indicators of concern in this regard. We achieve this by issuing an Employer contract setting out minimum requirements regarding safeguarding. We keep our employers updated on Safeguarding and Prevent and provide training for key employer staff.

We ensure the employer single point of contact (SPOC) is well versed in Safeguarding/Prevent and the specific requirements of the provider with regards to safeguarding and reporting. We provide important updates and the fact that the employer (often through the SPOC) accepts the responsibilities and requirements placed upon them by the provider.

Health and safety vetting and monitoring is carried out during learner induction, this involves a discussion between the tutor, employer and learner and allows for the tutor to be confident in the employers ability to keep the learner safe during their employment and also to help educate the learner in looking after their own welfare and that of others while at work.

Learners are made aware of all of Swatpro’s relevant policies, who the designated persons are and how to report a concern during their induction to the programme. There is also a a direct email address to allow the learners to access support from the designated safeguarding officer confidentially.

Learners are issued with a learner trifold Safeguarding and Prevent card detailing both internal and external support services. This contains contact details for police, Swatpro direct link to the safeguarding team. It also provides details of external learner welfare assistance 24-hour confidential helplines signposting to relevant support experts should they require it.

Monthly topics in relation to British Values, equality and diversity, safeguarding and prevention from being drawn into terrorism are discussed during apprenticeship visits with the learner and employer. Swatpro Savvy Learning Centre Courses surrounding these activities are discussed and documented at each visit, along with pastoral checks. These discussions and documented.

Before the end of a learner’s programme, whether successful or incomplete, tutors inform the DSL of any identified and open safeguarding/Prevent matters. This allows the DSL to make informed decisions on where and how the learner might need and be able to access ongoing support or for families, other agencies or follow on organisations (other providers or employers where known) to be involved. In the case of adult learners this will of course necessitate discussion with the learner and in most cases their consent.

11.1 Alert signs

Unexplained and lengthy absence from the workplace, study sessions or prearranged meetings with assessors could be an indication of safeguarding/Prevent issues and need to be investigated at an early stage.

We ensure our employers have clear guidelines on absence reporting involving learners and the measures that should be undertaken with clarity around timeframes. The existence of implementation of such robust procedures provides consistency, protects staff and helps to identify serious concerns at an early stage. We ensure employers understand that we class learners that are absent or avoiding interaction as vulnerable until the circumstances are clarified and all absence involving 16 to 18-year-old young people should involve early intervention and reporting.

11.2 Peer on Peer Abuse in young people

Helping our learners understand how to keep themselves safe whilst moving into adulthood is part of every contact we have with our learners. As both involved are young people understanding the difference between young people learning and being deliberately abusive is something that needs to be measured. Keeping a chronological record can help to see a pattern of abuse building up. Support should be given to both young people as a bully may be abused in the wider context. If, however, the abuse presents ‘significant risk or harm or actual harm’ then the priority is to keep that young person safe. In every case the Safeguarding Officer must be contacted and if necessary, the police called. Refer to para 8b and Appendix D1.

11.3 Preventing Radicalisation to Extremism

Section 26(1) of the Counter-Terrorism Security Act (CTSA) 2015 imposes a statutory duty on “specified authorities”, when exercising their functions, “to have due regard to the need to prevent people from being drawn into terrorism”.

In broad terms, Specified Authorities are defined within the sector Statutory Guidance3 as “further education institutions on the Skills Funding Agency (SFA) register of training organisations (ROTO), including subcontractors which receive more than £100,000 of SFA funding via lead providers”.

The CTSA goes on to say “There is an important role for further education institutions, including sixth form colleges and independent training providers, in helping prevent people being drawn into terrorism, which includes not just violent extremism but also nonviolent extremism, which can create an atmosphere conducive to terrorism and can popularise views which terrorists exploit. It is a condition of funding that all further education and independent training providers must comply with relevant legislation and any statutory responsibilities associated with the delivery of education and safeguarding of learners”.

The term Prevent Statutory Duty or the Prevent Duty (The Duty) are the most commonly referred to titles by which this requirement is known to most practitioners across the sector.

It is worth remembering at this point that the fundamental aims of Prevent, as part of the revised 2018 Contest Strategy2 are, “to safeguard vulnerable people to stop them becoming terrorists or supporting terrorism”.

Swatpro ensures that awareness and discussion about radicalisation is a regular occurrence with both the learner and employer, through the recruitment process, induction and at each review (both learner and tri-partite). Standardisations meetings are held between tutors. The DSL ensures that Swatpro Academy tutors are kept aware of both safeguarding and Prevent news and also audits partners to ensure internal procedures are robust.

Channel Programme

Channel is the name for the process of identifying and referring a person at risk of radicalisation for early intervention and support. It is a multi-agency approach to protect vulnerable people using collaboration between local authorities, statutory partners (such as education and health organisations, social services, children’s and youth services and offender management services), the police and the local community. Channel operates to:

• Identify people at risk of being drawn into terrorism.

• Assess the nature and extent of that risk.

• Develop the most appropriate support plan for the individuals concerned.

Channel may be appropriate for anyone who is vulnerable to being drawn into any form of terrorism. Channel aims to safeguard children and adults of any faith, ethnicity or background before their vulnerabilities are exploited by those that would want them to embrace terrorism. The emphasis is on early intervention to protect and divert people away from the risk they face before being drawn into committing terrorist-related activity.

Appendix H details the Channel process and contacts

11.4 Online Safety

The internet plays an increasingly dominant role in the process of grooming, whether sexual based or for organised crime and radicalisation.It is used extensively by pedophiles, extremist and terrorist groups. Our IT policy reflects the requirements of the Prevent Duty to highlight early indicators of risks through internet activity and our tutors equip learners with an understanding of how to use the internet safely, its inherent dangers and how to protect themselves. This is supported through course from our Swatpro Savvy Virtual Learning Centre.

12. Leadership and Management

Senior Management meet quarterly providing a greater focus on safeguarding and safety of learners.

The effectiveness of all welfare support and educational material is analysed periodically by learner voice .

The Safeguarding team are also subject to Quality Assurance checks carried out by the Safeguarding Lead

Swatpro Designated Safeguarding Lead (DSL) holds quarterly online meetings with all partner DSLs to support CPD and ‘on the ground’ awareness.

Swatpro Designated Safeguarding Lead undertakes audit checks with partners to ensure their internal processes are robust and are in compliance with the needs of Swatpro as main provider.

Safeguarding is also a standing item on Board Agendas

13. Associated Policies

  • Equality and Diversity Policy
  • Health & Safety Policy
  • Grievance Policy
  • Disciplinary Policy
  • IT Policy
  • Whistleblowing Policy
  • Data Protection and GDPR Policy
  • Appendix A

    List of posts that require appropriate type of DBS and barring list check

    Posts

    Basic check

    Enhanced check

    Enhanced with barred

    Admin

    Tutors

    Quality Improvement Manager

    Management Information and Compliance Manager

    Business Support and Development Manager (DSL)

    CEO & Chair

    Appendix B

    Statement on the secure storage, handling, use, retention and disposal of disclosures and disclosure information

    B1 – Safer Recruitment

    General Principles

    As an organisation using the Disclosure and Barring Service (DBS) to help assess the suitability of applicants for positions of trust, Swatpro complies fully with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of disclosures and disclosure information. It also complies fully with its obligations under the Data Protection Act and other relevant legislation pertaining with the safe handling, use, storage, retention and disposal of DBS disclosure information.

    Storage and Access

    Disclosure information is never kept on an applicant’s personnel file and is always kept separately and securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to see it as part of their duties.

    Handling

    In accordance with section 124 of the Police Act 1997, disclosure information is only passed to those who are authorised to receive it in the course of their duties. The DSL will be responsible for maintaining a record of all those to whom disclosures or disclosure information has been revealed. It is recognised that it is a criminal offence to pass this information to anyone who is not entitled to receive it.

    Usage

    Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.

    Retention

    Once a recruitment (or other relevant) decision has been made, Swatpro does not keep disclosure information for any longer than is absolutely necessary. This is generally for a period of up to six months, to allow for the consideration and resolution of any disputes or complaints. If, in very exceptional circumstances, it is considered necessary to keep disclosure information for longer than six months, Swatpro will consult the DBS about this before doing so. Throughout this time, the usual conditions regarding safe storage and strictly controlled access will prevail.

    Disposal

    Once the retention period has elapsed, Swatpro will ensure that any disclosure information is immediately destroyed by secure means, i.e. by shredding or confidential waste disposal. While awaiting destruction, disclosure information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack). Swatpro will not keep any photocopy or other image of the disclosure or any copy or representation of the contents of a disclosure. However, Swatpro will keep a record of the date of issue of a disclosure, the name of the subject, the type of disclosure requested, the position for which the disclosure was requested, the unique reference number of the disclosure and the details of the recruitment decision taken.

    B2 – Learner Disclosure and Concerns Records

    Guiding principles of record management

    According to Data Protection principles, records containing personal information should be adequate, relevant and not excessive for the purpose (s) for which they are held, accurate and up to date and only kept for as long as is necessary. The introduction of the General Data Protection Regulations (GDPR) in 2018 does not change the way child protection records should be stored and retained.

    Storage and Access

    Disclosure and concern records are not kept on the learners main file and are always kept separately and securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to see it as part of their duties.

    Handling

    Files containing sensitive or confidential data are kept secure and allow access on a ‘need to know’ basis and with a recording log to see who has accessed these files.

    Usage

    The information held within chronological records is used to escalate early help, child in need and child protection intervention.

    Retention

    Records will be kept in line with Swatpro document retention policy

    Disposal

    Once the retention period has elapsed, Swatpro will ensure that any disclosure information is immediately destroyed by secure means, i.e. by shredding or confidential waste disposal. While awaiting destruction, disclosure information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack).

    Appendix C

    DBS Disclosure Process

    Swatpro uses Personnel Checks (www.personnelchecks.co.uk) who is a registered body responsible for authorising and processing applications for DBS checks.

    Successful candidates will be sent an electronic DBS disclosure application and guidance with the written offer of employment. The completed electronic disclosure and associated ID documentation must be verified in person and the online verification completed. This must be done by bringing the documents to their ID verifier, who will authenticate and scan the documents. The ID verifier is responsible for completing their online ID process for each DBS request with Personnel Checks.

    Personnel Checks will then process the application and return a disclosure report to the ID Verifier, with a copy also sent to the individual. The published DBS turnaround time is for 95% of disclosures to be sent out within 4 weeks.

    Wherever possible the DBS disclosure should be obtained prior to the individual commencing employment, but sometimes this may not be possible. In such cases the individual can commence employment but only on a supervised basis for those aspects of the job involving contact with children or adults at risk until such time as a satisfactory disclosure report is received.

    Disclosure reports for applicants with a substantial record of overseas residence, including current UK residents and British nationals, may not include information on convictions from outside the UK. In most circumstances however, a disclosure report should still be sought. The DBS can also offer guidance on the availability of criminal record checks in a variety of foreign countries and the applicant can be requested to obtain the equivalent checks from the country in question, where available.

    Appendix D – Process Charts

    D1 - Learner Safeguarding Concerns

    View process

    D2 - Parent, Employer, or Learner raises a concern over a Swatpro Team Member

    View process

    D3 - Safeguarding concern witnessed or reported relating to activity in learner setting

    View process

    Appendix E- Detailed Procedure for dealing with Safeguarding Concerns

    View process

    Appendix F - Indicators of Abuse

    View table

    Appendix G

    Ga - Concern Form

    Open form

    Gb - Disclosure Recording Form

    Open form

    Appendix H – Prevent Channel Process

    Prevent Channel Process

    Appendix I - Useful Contact Details

    View details

    Appendix J - Laws and guidance

    View details

    Appendix K -Record of Review of Policy and Procedure

    Date

    Whom

    Record of change

    Next review date

    2011

    Rod Davis

    Nov 2012

    2012

    Rod Davis

    Nov 2013

    2013

    Rod Davis

    Nov 2014

    2014

    Rod Davis

    Nov 2015

    2015

    Rod Davis

    Nov 2016

    2016

    Rod Davis

    Nov 2017

    2017

    Rod Davis

    Nov 2018

    2018

    Rod Davis

    Nov 2019

    28.11.2019

    Kathleen Harrison-Ford

    Refreshed to include procedures within the policy and update all to reflect new government guidance

    Nov 2020

    Appendix L – Swatpro Safeguarding Structure

    View details