Safeguarding Policy Wales
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 Policy
- Our Commitment to Safeguarding
- Relevant Legislation and Guidance
- The Role of the Designated Safeguarding Person (DSP) 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:
- Keeping Learners Safe 2022 (Welsh Government)
- The Social Services and Well-being (Wales) Act 2014 - “Working Together to Safeguard People” The Children Act 1989
- The Education Act 2002
- The Well-being of Future Generations (Wales) Act 2015
- Working Together to Safeguard children – 2018 (HM Government)
- Safeguarding children in education: handling allegations of abuse against teachers and other staff - 2014 (Welsh Government)
- Welsh Government’s Procedures for Whistleblowing in Schools and Model Policy - 2007 All Wales Area Child Protection Committees
- The Children Act 2004
- Guidance for Safer Working Practice for Adults Who Work with Children and Young People -2019 (Safer Recruitment Consortium)
- Information Sharing: Guidance for practitioners and managers – 2018 (HM Government) Rehabilitation of Offenders Act 1974
- Disqualification under the Childcare Act 2006
- 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 Social Services and Well-being (Wales) act 2014
This policy should be read in conjunction with our other relevant safeguarding policies, such as:
- Allegations Policy
- Complaints Policy
- Safer Recruitment
- Whistleblowing Expectations
The role of the Designated Safeguarding Person (DSP)
The role of the DSP includes:
- Receiving and responding appropriately to all reports of safeguarding concerns, issues or abuse which are raised by staff members, partner agencies or candidates.
- Referring any safeguarding concerns where necessary to the Local Authority and managing immediate actions required to ensure the individual at risk is safe from abuse.
- Recognising and identifying the signs of abuse, neglect and other types of harm, irrespective of whether it is online or offline, and know when it is appropriate to make a report to the local authority.
- Being supported with the emotional impact of their role and provide an opportunity for reflection on their practice. This could be done on an individual or group basis but the DSP should be provided with an opportunity for individual support where necessary.
- Providing advice and support to other staff, record-keeping, working with family members or carers, making referrals to children’s services and attending statutory meetings, as well as liaising with the SCB and working with other agencies as necessary.
- Keeping senior management appraised of any safeguarding incidents and their outcome. Considering how safeguarding more widely can be addressed and ensure preventative measures are adopted in the education setting. This part of the role will include building relationships with other agencies, as well as ensuring staff and learners are informed about risks and how to access support. Policy development (or overseeing this, including ensuring that all policies are updated as and when needed, but in any event on an annual basis.
- Liaising with Designated Safeguarding Leads/Officers in partner organisations.
- 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. The DSP must keep a record of all staff training, including the dates, details of the provider and a record of staff attendance.
- 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. 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.
- The DSP should ensure that everyone working in the education setting is aware of the Wales Safeguarding Procedures and knows how to access a copy of the procedures.
According to the Education Act 2002 and Section 3 of the Social Services and Well-being (Wales) Act 2014 a ‘child’ is anyone who has not yet reached their 18th birthday.
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.
Abuse and neglect are forms of maltreatment. Somebody may abuse or neglect a child 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’s school, community, family, those in a position of trust or another child.
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.
Child abuse can be one of four different categories as set put in All Wales Child Protection Procedures (2008)
: 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.
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 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 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.
It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
For detailed guidance on the signs which may indicate abuse and neglect see All Wales Practice Guide - Safeguarding children from neglect (2021).
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 Working Together (2018) and Keeping Learners Safe (2022), where an organisation has received an allegation that a volunteer, supply staff or member of staff who works with children has:
- behaved in a way that has harmed a child, or may have harmed a child;
- possibly committed a criminal offence against or related to a child;
- behaved towards a child or children in a way that indicates he or she may pose a risk of harm if they work regularly or closely with children.
A referral should be sent to the LADO within one working day, giving as much detail as possible.
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.
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.