Date of Policy: 01 /01/2023
This policy will be reviewed every 12 months. Review date: 01/01/2024
Designated Safeguarding Officer: Lucy Reed
Designated Safeguarding Officer Contact details: [email protected]
or +44 (0)117 457 3257
Deputy Designated Safeguarding Officer: Ben Goldsmith
Deputy Designated Safeguarding Officer Contact Details: [email protected]
or +44 (0)208 787 4553
Table of Contents
Safeguarding Children and Adults at Risk Policy
- Our Commitment to Safeguarding
- Relevant Legislation and Guidance
- The Role of the Designated Safeguarding Officer (DSO) 6. Definitions
- Recruitment and Selection Process
- Responding to Safeguarding Concerns
- Dealing with Allegations of abuse made against candidates
- Duty to make a referral to the DBS
- Whistle Blowing
Safeguarding is everyone’s responsibility. anzuk Education acknowledges the duty to safeguard and promote the welfare of children and adults at risk; and is committed to ensuring safeguarding practice that reflects statutory responsibilities, government guidance and complies with best practice requirements. All children and adults, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have the right to equal protection from all types of harm or abuse.
This policy applies to all internal staff and candidates and will be widely promoted and be mandatory for everyone involved in anzuk Education. Failure to comply with this policy and the company’s safeguarding procedures may result in disciplinary action being taken, including termination of employment and/or contract.
All candidates placed by anzuk Education are expected to familiarise themselves with arrangements for safeguarding children and adults at risk in the organisation where they are placed and to have a clear understanding regarding abuse and neglect in all forms; including how to identify, respond and report.
Here at anzuk Education we expect all staff, and candidates to follow and promote good practice in safeguarding. In order to do so, they should:
- Read, understand, accept and act in accordance with this policy.
- Be vigilant and follow professional codes of conduct to maintain professional boundaries and safe working practices.
- Report any concerns or disclosures related to the protection and safety of children and adults at risk. Undertake mandatory safeguarding training and awareness sessions where provided
- Help educate learners/service users in placements regarding matters of keeping safe, including acting as a good role model.
In response to the COVID-19 pandemic and the government-instructed lockdown on 23 March 2020, a number of the Best Practice Requirements in the APSCo Compliance+ Standards were not compatible with the increased level of remote working.
We have worked closely with APSCo across this period and implemented all best practice recommendations as per APSCo Compliance+ standards. Full details of these changes can be found as follows: Compliance+ COVID standards
- We will ensure that all educators who have been unable to work since 23 March 2020 (and have not been furloughed by ourselves), are re referenced and all checks re run. In the unlikely event we have been unable to obtain a reference prior to the start of an assignment we will refer to the client school for consent for the educator to attend. We will endeavour to obtain any missing references within 4 weeks of the assignment starting.
- All anzuk internal staff as well as temporary workers, candidates and contractors are advised to adhere to government guidelines with regards to protecting themselves and others against Coronavirus.
- Please refer to our COVID-19 Support page for more information COVID 19 Resources
Our commitment to Safeguarding
This policy is designed to meet the above principles by ensuring that:
- anzuk Education has robust safer recruitment processes that ensures that those who are known to be a risk to children or adults do not gain access to them; those whose actions suggest that they are a risk to children/adults are detected at the earliest stage and prevented from continuing to work with children/adults; and that those who intend to do harm are prevented at every possible stage from entering the workforce.
- Staff and candidates understand their roles and responsibilities in respect of safeguarding and are provided with appropriate learning opportunities to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children and adults at risk.
- There is an open and transparent culture which enables staff and candidates to raise concerns around children/adults at risk, those that work with children/adults at risk, and processes within anzuk Education.
- It is as simple as possible for an individual to report concerns about harm or risk and clear procedures are implemented where safeguarding and child/adult protection issues arise. Where concerns are reported anzuk Education will ensure that individuals are supported.
- anzuk Education has robust policies and procedures in place, which are reviewed and updated at least every 12 months.
- anzuk Education stays up to date with developments on safeguarding best practice, reporting and auditing safeguarding activities annually and addressing any areas for improvement.
- anzuk Education will report any concerns regarding any individual, or any potential safeguarding situation that it becomes aware of as soon as practicable to the appropriate authority and will co- operate in any ongoing investigations or assessments.
- anzuk Education will work in partnership with other services (including local authority children’s and adult social care) to ensure that those who are identified as being at risk of abuse are protected.
- Confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored.
Relevant Legislation and Guidance
The principal pieces of legislation governing this policy are:
- Working Together to Safeguard Children 2018 (HM Government)
- Keeping Children Safe in Education 2022 (Department for Education) The Children Act 1989
- The Children Act 2004 The Care Act 2014
- Care and Support Statutory Guidance 2022 (Department of Health and Social Care) Information Sharing: Guidance for practitioners and managers 2018 (HM Government) Rehabilitation of Offenders Act 1974
- Disqualification under the Childcare Act 2006 - Update 2018 (Department for Education) Counter Terrorism and Security Act 2015 (including the 'Prevent Duty')
- The Prevent Duty, Departmental, Advice for Schools and Child Care Providers 2015 (Department for Education)
- Modern Slavery Act 2015 Human Rights Act 1998
- Local Safeguarding Partners/Arrangements/Local Safeguarding Adult Board
- Guidance for safer working practice for those working with Children and Young people in Education settings 2022 (Safer Recruitment Consortium)
This policy should be read in conjunction with our other relevant safeguarding policies, such as:
- Allegations Policy
- Complaints Policy
- Safer Recruitment
The role of the Designated Safeguarding Officer (DSO)
The role of the DSO includes:
- Ensuring that all relevant staff and candidates have received safeguarding training appropriate to their role and continue receiving training to enable the development of skills and good practice when working with children/adults at risk.
- Receiving and responding appropriately to all reports of safeguarding issues or abuse which are raised by staff members, partner agencies or candidates.
- Ensuring that confidential, detailed and accurate records are kept of any concerns, reports or referrals related to candidates or children/adults at risk that they work with.
- Liaising with Designated Safeguarding Leads/Officers in partner organisations.
- Acting as a source of support, advice and expertise for staff and candidates with concerns and liaising with other agencies and professionals.
- Supporting staff and candidates involved in safeguarding incidents and assisting them in challenging or reporting poor or unsafe practice.
- Referring any allegations of abuse or safeguarding concerns to the relevant children or adult social care and if relevant, the police and/or the Local Authority’s Designated Officer (LADO). In order to do this, the DSO will need to consult the Local Safeguarding Partnership Arrangements/Local Safeguarding Adult Board for the area in which the organisation is located. Further details on referral routes are located in
- Working Together to Safeguard Children (2018), Care and Support Statutory Guidance 2022, and in Keeping Children Safe in Education (2022).
- Reporting concerns to the Disclosure and Barring Service (DBS), this may be where a staff member or candidate has been dismissed or left, where serious concerns have been raised about their conduct or behaviour, and the company believes they pose a risk to children/vulnerable adults. The DSO will complete the necessary referral documents to the DBS and liaise with them thereafter if they have any further questions regarding the staff member or candidate.
- Keeping senior management appraised of any safeguarding incidents and their outcome.
- Liaising with the Company’s Compliance Officer and senior management regarding training and skill development programmes available to staff and candidates.
- Policy development (or overseeing this, including ensuring that all policies are updated as and when needed, but in any event on an annual basis.
According to the Children Act 1989, a ‘child’ is anyone who has not yet reached their 18th birthday. The fact that a child has reached 16 years of age, is living independently or is in further education, is a member of the armed forces, is in hospital or in custody in the secure estate for children and young people, does not change his or her status or entitlement to services or protection under current legislation.
In this policy, the terms ‘child’ and ‘young person’, or children’ and ‘young people’, are used interchangeably to refer to any individual under the age of 18.
The Care Act 2014 defines an ‘adult at risk’ as an adult who:
- has needs for care and support (whether or not the local authority is meeting any of those needs) and,
- is experiencing, or at risk of, abuse or neglect; and,
- as a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect.
Abuse and neglect are forms of maltreatment. Somebody may abuse or neglect a child/vulnerable adult by inflicting harm, or by failing to act to prevent harm.
The Children Act 1989 defines ‘harm’ as “ill-treatment or the impairment of health or development”. ‘Development’ means physical, intellectual, emotional, social or behavioural development; ‘health’ means physical or mental health; and ‘ill-treatment’ includes sexual abuse and forms of ill-treatment which are not physical. As a result of the Adoption and Children Act 2002, the definition of harm also includes “impairment suffered by hearing or seeing the ill-treatment of another”
Abuse may be perpetrated by an individual from the child or adult’s school, college, day centre, community, family, those in a position of trust or another child/vulnerable adult.
All staff should be aware that children can abuse other children (often referred to as peer on peer abuse).
This is most likely to include but may not be limited to: bullying (including cyberbullying), physical abuse, sexual violence, sexual harassment, up-skirting, sexting (also known as youth produced sexual imagery); and initiation/hazing type violence and rituals.
Categories of abuse - Children
Child abuse can be one of four different categories as set put in Working Together to Safeguard Children (2018):
Physical Abuse: Physical abuse is a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
Emotional Abuse: The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to a child that
they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill- treatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
Sexual Abuse: Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (e.g. rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children
Neglect: Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:
- provide adequate food, clothing and shelter (including exclusion from home or abandonment);
- protect a child from physical and emotional harm or danger;
- ensure adequate supervision (including the use of inadequate caregivers);
- or ensure access to appropriate medical care or treatment.
Categories of abuse - Adults at risk
The categories of adult abuse are set out in the Care Act 2014 and are as follows:
: including assault, hitting, slapping, pushing, misuse of medication, restraint, inappropriate physical sanctions.
: including psychological, physical, sexual, financial, emotional abuse; so-called ‘honour’ based violence.
: including rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, indecent exposure and sexual assault or sexual acts to which the adult has not consented or was pressured into consenting.
: including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyber bullying, isolation or unreasonable and unjustified withdrawal of services or supportive networks.
Financial or Material Abuse
: including theft, fraud, internet scamming, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.
encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.
: including forms of harassment, slurs or similar treatment; because of race, gender and gender identity, age, disability, sexual orientation or religion.
: including neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example, or in relation to care provided in one’s own home. This may range from one off incidents to on-going ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes and practices within an organisation.
glect and Acts of Omission
: including ignoring medical, emotional or physical care needs, failure to provide access to appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.
: this covers a wide range of behaviour neglecting to care for one’s personal hygiene, health or surroundings and includes behaviour such as hoarding.
Further information can be found at https://www.gov.uk/government/publications/adult-safeguarding- statement-of-government-policy
Recruitment and Selection Process
anzuk Education is also committed to protecting children and adults at risk through a careful recruitment and selection process (Safer Recruitment), a Whistleblowing Policy and guidance on appropriate behaviour (Code of Conduct). These policies
should be read alongside this policy.
anzuk Education’s rigorous procedures, following ASPCo’s Compliance+ process ensures that any candidate found to have a history of unacceptable conduct or practice, will not be placed.
Responding to Safeguarding Concerns
have a responsibility to protect children/adults at risk. This includes:
- Observing anzuk Education policies and processes including any Code of Conduct
- Attending the recommended training and keeping their skills and knowledge concerning safeguarding and safer recruitment up to date
- Reporting any concerns arising from meeting candidates or carrying out pre-placement checks to the DSO without delay and making a clear written record of all relevant information to be passed to the DSO
- Reporting any concerns arising from organisation visits / placements to the Designated Safeguarding Lead/Officer at the relevant organisation and confirming that this has been done to anzuk Education DSO
- Taking action, such as following the process detailed in the Whistleblowing Policy where there are concerns about practice.
All candidates working through anzuk Education are expected to keep children and vulnerable adults safe by:
- Following the anzuk Education policies including the Code of Conduct
- Following the Safeguarding Policy of each placement, including any Code of Conduct
- Making the Designated Safeguarding Lead/Officer at the placement aware of any concerns regarding any children/vulnerable adults; or any adults caring for or working with those persons
- Seeking advice and support from anzuk Education’s DSO when they have reason to believe that their concerns have not been responded to appropriately or they have concerns about practice in the placement.
Dealing with allegations of abuse made against candidates
All candidates placed on assignment are responsible for supporting safe behaviour and have responsibility to follow the guidance laid out in this policy and related policies, such as the Code of Conduct.
In accordance with the Care Act (2014), Working Together (2018) and Keeping Children Safe in Education (2022), where an organisation has received an allegation that a volunteer, supply staff or member of staff who works with children/vulnerable adults has:
- behaved in a way that has harmed a child/adult, or may have harmed a child/adult;
- possibly committed a criminal offence against or related to a child/adult;
- behaved towards a child/adult in a way that indicates he or she may pose a risk of harm to children/vulnerable adults; or
- or behaved or may have behaved in a way that indicates they may not be suitable to work with children/vulnerable adults,
a referral should be sent to the LADO within one working day, giving as much detail as possible.
Details regarding allegations that meet the harms threshold and concerns that do not meet the allegations threshold (referred to as ‘low level concerns’), including who will take responsibility for this once a candidate is placed, are set out in anzuk Education’s Allegation Policy which should be read alongside this policy.
10. Duty to make a referral to the DBS
Where there is evidence that anyone has harmed, or poses a risk of harm, to a child or adult at risk, there is a legal duty on anzuk Education to report that person to the Disclosure and Barring Service using their guidance available here.
The DBS has statutory authority to bar a person from working in regulated activity with children and/or adults at risk in the UK.
A referral to the DBS will also be made if the person resigns prior to an investigation being carried out or reaching its conclusion. If the accused person resigns, or ceases to provide their services, this should not prevent an allegation being followed up in accordance with this guidance.
anzuk Education will not make any compromise/settlement agreement in the case of a person deemed unsuitable to work with children/vulnerable adults. Any such agreement which contained a condition of not referring the case to the DBS would constitute a criminal offence.
Anyone who is concerned about a child’s or adult at risk’s welfare or who believe that a child or adult at risk may be at risk of abuse should pass any information to the DBS or other appropriate authority as soon
as possible and no longer than 24 hours after the initial concern.
11. Whistle Blowing
Candidates may find it difficult to raise concerns about colleagues, managers, people in placement or concerning how safeguarding concerns are responded to within a setting. anzuk Education has a specific Whistleblowing Policy which encourages candidates to raise concerns and also provides details of outside organisations that candidates can approach for support and advice. anzuk Education aims to have an open and honest culture where safeguarding is responded to effectively, and both staff and candidates feel safe, supported and able to voice any concerns that they have in the knowledge that they will be responded to.
anzuk Education safeguarding policy is available on clients and candidates request or via our website
All staff, temporary workers, candidates and contractors must be aware that they have a professional duty to share information with other recruitment firms in order to safeguard children/adults at risk. The public interest in safeguarding children/adults at risk may override confidentiality interests. However, information will be shared on a need to know basis only, as judged by anzuk Education.