Safeguarding & Prevent Policy

Introduction

This policy sets out CTS Training’s approach to Safeguarding and promoting the welfare of all its learners, staff, volunteers and visitors. The CEO, Management Team and staff recognise that a safe environment combined with clear lines of communication and decisive action ensures the best outcomes for all learners.

CTS is committed to ensuring that it:

• Provides a safe environment for learners to study in.
• Takes appropriate steps to ensure work placements are adequately equipped to support the learner in their training and safeguard the learner’s welfare, where appropriate.
• Has a robust system of reporting that engages with appropriate agencies who are able to fully support the learners’ wellbeing and safety.
• Actively promotes safe practices and encourages learner to identify potential risks.
• Learners who attend sub-contracted provision are safe and that internal safeguarding policies and procedures are in place and are being followed.

In pursuit of these aims, the Management Team and Safeguarding Committee will:

• Raise awareness of issues relating to the welfare of learners and ensure they know how to protect themselves from all forms of risk, including but not limited to, grooming, sexual harassment (either face to face or via social media), radicalisation, bullying, extremism, forms of abuse and cyber-crime.
• Identify more vulnerable learners and those at risk of potential harm.
• Adhere to the safe recruitment of staff and safe use of contractors.
• Promote culture of openness where reporting lines are clear.
• Promote culture that values the opinions of learners.
• Review policies and procedures and ensure they are communicated.
• Engage effectively with external agencies/partners.
• Establish clear reporting lines and accountability through the Safeguarding Committee.

Definition of Safeguarding

CTS uses definitions of the term ‘safeguarding’ from statutory guidance.

Safeguarding children is defined in Working together to safeguard children as:

protecting children from maltreatment;
preventing impairment of children’s health or development;
ensuring that children are growing up in circumstances consistent with the provision of safe and effective care;
taking action to enable all children to have the best outcomes.

Safeguarding vulnerable adults is defined in the Care and support statutory guidance issued under the Care Act 2014 as:

protecting the rights of adults to live in safety, free from abuse and neglect;
people and organisations working together to prevent and stop both the risks and experience of abuse or neglect;
people and organisations making sure that the adult’s wellbeing is promoted including, where appropriate, taking fully into account their views, wishes, feelings and beliefs in deciding on any action;
recognising that adults sometimes have complex interpersonal relationships and may be ambivalent, unclear or unrealistic about their personal circumstances and therefore potential risks to their safety or well-being.

Definition of Young People and Vulnerable Adults

• A child is defined as under the age of 18 years; for the purpose of this policy, in the context of a post-16 environment, children are referred to as young people.

• Vulnerable Adult is defined as someone 18 years of age or over who is or may be unable to protect him or herself against significant harm or exploitation.

Radicalisation and Acts of Terrorism

The Counterterrorism and Security Act 2015 imposes a duty on Post 16 Providers to have due regard to the need to prevent people from being drawn into terrorism. This is known as the Prevent Duty. To comply with the duty Post 16 Providers are expected to:

• work in close partnership with agencies such as the police and local authority.
• have procedures in place regarding external speakers.
• take a risk-assessed approach to Prevent with action plans in place to manage risk.
• have procedures in place regarding the use of IT facilities and access to the web.
• and provide staff training and development to enable tutors and those supporting the curriculum to utilise learning opportunities to educate and challenge extremism and for all staff to exemplify British values.

In addition to statutory duties, CTS will endeavour to adopt best practices wherever possible by adhering to Government guidance (issued at the national or local level) and the requirements of any enforcement or regulatory authority that has a vested interest in the safeguarding of Vulnerable Individuals.

Terror Threat Level Monitoring

CTS Safeguarding Lead monitors the current level and ensures all staff and learners are made aware of any changes and how this would affect the area where they may live or are visiting.

The threat level for the UK from international terrorism is set by the Joint Terrorism Analysis Centre (JTAC).

There are 5 levels of threat:

• low - an attack is highly unlikely.
• moderate - an attack is possible but not likely.
• substantial - an attack is likely.
• severe - an attack is highly likely.
• critical - an attack is highly likely soon.

MI5 is responsible for setting the threat levels from Irish and other domestic terrorism both in Northern Ireland and in Great Britain.

The DSL receives regular updates on threat levels and counter-terrorism from the G7-Prevent Regional HE/FE Co-ordinator Northeast region and checking the Security Service website https://www.mi5.gov.uk/threat-levels.

Whistleblowing

Where there are concerns of extremism or radicalisation young people, vulnerable adults and Staff will be encouraged to make use of our internal systems to whistleblow or raise any issue in confidence.

Please refer to the separate Whistleblowing Policy.

Channel

Channel is part of the Government’s Prevent Strategy and focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism.

Factors that may have a bearing on someone becoming vulnerable include:

• peer pressure
• influence from other people or via the internet
• bullying
• crime against them or their involvement in crime
• anti-social behaviour
• family tensions
• race/hate crime
• lack of self-esteem or identity
• personal or political grievances

The programme uses a multi-agency approach to protect vulnerable people by:

• identifying individuals at risk
• assessing the nature and extent of that risk
• developing the most appropriate support plan for the individual concerned

The multi-agency panel is a collaboration of local authorities, the police, statuary partners, and the local community.

Channel is a voluntary programme that aims to safeguard vulnerable individuals through targeted intervention to prevent them from committing criminal acts.

The Channel Procedure

1. If a member of staff is concerned that an individual may be vulnerable to being drawn into terrorism, then they should discuss those concerns with their line manager.
2. If appropriate the line manager will report these concerns to the Prevent Lead.
3. If necessary, the Prevent Lead will refer to the South Yorkshire Police Prevent Officer contact.
4. This officer will then liaise with the Channel Police Practitioner (CPP), team members, and agency staff.
5. The officer will then follow the stages detailed in the 2012 Government publication ‘Channel – Protecting vulnerable people from being drawn into terrorism.’

The Channel Stages

1. When the initial referral is received, the CPP will assess if the case is appropriate for Channel.
2. An initial vulnerability assessment will determine: if the individual is vulnerable to being drawn into terrorism and is suitable for Channel; should be referred to other support services; exits the process.
3. If suitable for Channel, then the referral passes to the multi-agency panel which will review the vulnerability assessment and risk; assess the support needs; produce a support plan; develop an appropriate support package; review progress.
4. The Channel Panel Chair will ensure that individuals and organisations on the panel carry out their parts of the support plan so that an effective support package is delivered.

Scope of the Policy

This policy applies to:

• All learners.
• All staff, volunteers, and partners carrying out activities on behalf of CTS Training.
• All CTS activity.

Aim of the Policy

The aim of the policy is to ensure that CTS Training safeguards all learners by:

Prevention and Promotion

• Robust staff recruitment.
• Policies and procedures that support safeguarding and the promotion of British Values.
• Close working relationships with partners who share a common purpose regarding safeguarding; Social Care; Police; Local Authority Safeguarding teams; schools; health services; referral agencies.
• Staff awareness – how to promote welfare and safety of young people and vulnerable adults.
• Implementation of the Appropriate Use ICT Policy and e-Safety and social media Policy.
• Implementation and monitoring of CTS’s Prevent Risk Register.
• Raising the awareness of safeguarding amongst learners through induction, learner information, promotional materials and our curriculum offer which includes, but is not limited to, enrichment sessions.

Protection and Support

• CTS will identify young people and adults who are suffering or likely to suffer significant harm, including those at risk of radicalisation.
• CTS will ensure all staff understand their role in identifying those at risk. The definition of abuse and signs of abuse can be found on DFE. https://www.gov.uk/government/publications/what-to-do-if-youre-worried-a-child-is-being-abused--2
• CTS carries out risk assessments of students who declare a prior criminal conviction.
• Where a young person or vulnerable adult is suffering significant harm, immediate action will be taken in accordance with the Children Act 1989.
• Action will also be taken to protect the welfare of learners where it is recognised that additional support is needed, even if the learner is not at immediate risk of harm.
• The development of skills to enable learners to keep themselves safe, through teaching and learning opportunities as part of the broad curriculum, enrichment studies, and tutorials.

Allegations of abuse against members of staff

• CTS will act in accordance with the DfE guidelines ‘Dealing with allegations of abuse against Teachers and other Staff, 2011, published March 2012.

Responsibility for Safeguarding

The Chief Executive Officer (CEO) has ultimate responsibility for the safeguarding of young people and vulnerable individuals whilst they are on programme as the Designated Safeguarding Lead. The CEO ensures the Safeguarding and Prevent Policy, and processes are adhered to by all staff. This policy applies to all CTS employees as the organisation recognises that safeguarding is everyone’s responsibility.

CTS’s Management Team ensures that CTS works closely with the local Safeguarding Children Boards and other agencies in line with statutory guidance ‘Keeping Children Safe in Education’.

CTS’s leadership, management, and staff determine how to promote the welfare of learners, so they understand and respond to risk effectively, including knowing where to get support. All staff and volunteers actively promote a culture of mutual respect and tolerance and are vigilant for signs of abuse.

The Designated Safeguarding and Prevent Lead (CEO), broad areas of responsibility are:

• Implementation of the Prevent duty;
• The Safeguarding and Prevent Policy and Procedures;
• Ensure the CTS’s policies are disseminated and implemented consistently;
• Monitoring effectiveness of the policies and actions taken;
• Oversee the referrals of cases of abuse to SCSB, RCSB, BCSB and DSCB;
• Support designated Safeguarding Representatives;
• Inter-agency working with Sheffield Safeguarding Children Board (SSCB), Rotherham Safeguarding Children Board (RSCB), Barnsley Safeguarding Children Board, Doncaster Safeguarding Children Board (DSCB), Social Care, police; schools and referral agencies;
• Referral to and working with Local Authority Designated Officer (LADO) where allegations against staff have been made;
• Referral to South Yorkshire Police where a crime has been committed;
• Ensure training and development for safeguarding complies with the statutory guidance; guidance ‘Keeping Children safe in Education’.
• Ensure the publication of the Safeguarding and Prevent Policy is on CTS website;
• Ensure the Recruitment Policy is effective in protecting young people;
• Inform the Board of Directors of key issues/police involvement;
• Act as a source of support, advice and expertise to staff on matters of safeguarding;
• Provide face to face training to staff or delegate to other staff/external partners where appropriate.

The Safeguarding and Prevent Officers, broad areas of responsibility are:

• To deputise for the Designated Safeguarding and Prevent Lead, as above, except where there are allegations against members of staff, in which case these will be referred to the HR support team.
• Receive referrals and take appropriate actions, using the local Safeguarding Children Boards ‘Thresholds of need guidance’ - Identifying needs and analysing risk when working to support children and families in Sheffield.
• Inform staff working with individual learners of known potential risk to the individual, other learners or staff (the consent of the individual learner will be sort in all cases, although there may be occasion where information may be shared without the consent of the individual, in which case the learner will be told what information is to be shared).
• Act as a point of referral for Prevent issues; reporting to the Prevent Lead.
• Risk assess the disclosure of learner criminal convictions.
• Support the Designated Safeguarding Lead on the review of policies and procedures.
• Advise the Management team of key safeguarding issues.
• Produce a monthly report of open Safeguarding cases to the Designated Safeguarding Lead.
• Act as a source of support, advice and expertise to staff on matters of safeguarding.
• Raise awareness of staff and learners locally.
• Liaise with police, Social Care, SSCB, RSCB, BSCB and DSCB regarding individual case investigations.
• Liaise with schools/colleges/referral agencies to receive information about individual learners and ensure appropriate arrangements are in place to safeguard those learners.
• Maintain appropriate, confidential, and accurate records of safeguarding referrals, actions and concerns and CTS’s confidential safeguarding electronic and paper records.
• To act as first point of call for learners or parents/carers; for bullying and other issues related to safeguarding, for example mental health.
• To receive regular training on safeguarding and maintain strong links with external and internal supportive organisations.
• To refer to Designated Safeguarding Officers for all cases where significant harm has been disclosed and/or where the potential for significant harm is likely to escalate.

All CTS Training staff

Safeguarding is ‘Everyone’s Responsibility’ - All staff receive an induction and regular updates. A safeguarding organisation chart is provided in Appendix A.

Safeguarding Committee

CTS has a Safeguarding Committee which all staff with safeguarding responsibilities are part of.

Safeguarding Committee Responsibilities

• To demonstrate a practice attitude in assessing safeguarding risks and swiftly, taking actions to prevent them.
• To raise awareness among staff of safeguarding issues and increasing vigilance and acting on learners’ concerns.
• To ensure that clear and robust reporting procedures remain in place for the safeguarding of learners’ welfare and well-being.
• It will be the responsibility of the Designated Safeguarding Lead to collate internal disclosures, potential concerns, or risk indicators, update the committee on any referrals to external parties i.e., Safeguarding Children Boards, and produce a report on learners with Safeguarding concerns and the actions that have been taken.
• Safeguarding representatives will provide support to peers, advice to learners and colleagues on signposting to appropriate support agencies, and will contribute to the evaluation and review of policies and procedures.

Main Areas of Focus

• Promoting all forms of equality, ensuring learners and staff are protected from harassment, bullying, and discrimination.
• Promoting British Values.
• Regularly evaluating the effectiveness of safeguarding practice, including the prevention of radicalisation of learners and compliance with the Prevent Duty.
• Supporting delivery staff to promote equality, raise awareness of diversity, and tackle discrimination, victimisation, harassment, stereotyping, radicalisation, and bullying in their training sessions.
• Providing strategies and guidance on how to educate learners on how to protect themselves from the risks associated with radicalisation, extremism, forms of abuse, grooming, and bullying, including using the internet, and how well they understand the risks posed by adults or young people who use the internet to bully, groom or abuse other people, especially children, young people, and vulnerable adults.
• Providing guidance to delivery staff on how to educate learners on how to keep themselves fit and healthy, both physically and emotionally.

Committee Meetings

• The committee will aim to meet face-to-face, once a quarter to discuss emerging issues, and common risk indicators which can be used to inform the curriculum and delivery and to provide support to each other in making external referrals.

• The actions of the committee will also be driven by the Prevent Risk Register and the associated actions.

These actions will be met through the following:

• Training and awareness sessions.
• Effective marketing and thorough evaluation of all communication materials.
• Development of teaching and support resources.
• Regular evaluation of reporting processes.
• Regular review of policies and procedures.
• Peer support.

Information Sharing and Record Keeping

• Information Sharing is vital to safeguard young people and vulnerable adults. There can be significant and occasionally life-threatening consequences to not sharing information. Therefore, where there has been significant harm or there is potential for significant harm staff are required to share information.
• Safeguarding staff use professional judgment regarding the potential for significant harm, keeping the needs of the individual young person paramount. Consent to share information will be sought, however, there are occasions where information is shared without consent. Guidance for information sharing for safeguarding purposes is found in Appendix B.
• Safeguarding records (paper and electronic) are kept securely by the Safeguarding Committee.
• CTS Safeguarding staff use a secure section of the shared drive to store all electronic and paper safeguarding information.

Safer Recruiter

• CTS Training adopts recruitment, selection, and pre-employment vetting procedures in line with legislation and best practice available. Most CTS’s activity is ‘regulated activity’ as set out in https://www.gov.uk/government/publications/dbs-workforce-guidance.
• CTS has a robust process of risk assessment for positive DBSs or where staff should need to commence employment prior to their DBS being received back. CTS is committed to rechecking individual DBSs every 3 years.
• CTS holds a single central register for all staff and volunteers, which lists the checks that have been carried out and the date they were completed.

Volunteers

Whilst not a legal duty, CTS does require supervised volunteers that are undertaking frequent supervised activity at CTS to provide an enhanced DBS certificate. CTS will not require a barred list check.

Work Placement Providers and Employers

The majority of 16–19-year-olds at CTS are expected to experience the world of work as part of their study programme. Work placement providers and employers are risk assessed on an individual basis to ensure students are safe. CTS ensures that employers are aware of CTS safeguarding procedures. CTS does not require DBS checks from work placement supervisors, nor are they required from employers in non-regulated activity.

Learner Recruitment

Safer recruitment extends to learners as well. CTS requests all prospective learners to disclose whether they have a criminal conviction. Following disclosure, the Designated Safeguarding Lead/and or Safeguarding Officers assess the risk to others and identify any support for the individual. Some placements, such as those that involve working with children, also require a DBS check.

Health & Safety

• CTS recognises that learners and staff want to feel safe in their learning and working environment.
• Our site has intercom access, and the external doors will be always shut with access only being gained when reception staff have confirmed the identity and allowed it.
• Thorough risk assessments are carried out on all premises. Further details are available in CTS’s Health & Safety Policies and Procedures.
• CTS requires all learners and staff to wear an identity card when they are at CTS. Learners and staff who have forgotten their cards are given temporary or replacement passes once they have been identified on our system.

Online Safety

The digital revolution has transformed the way that people now can learn using the internet and mobile technologies. CTS Training is committed to the availability of digital technology to enhance the learning experience. However, with these new technologies (particularly internet-based) comes risks associated with invasion of privacy, cybercrime, and safeguarding/prevent issues. It is imperative that a dynamic approach is used to adapt to the rapidly changing digital landscape, and that a balance is struck between guaranteeing learner safety whilst still ensuring the availability of quality digital provision. Full details of how CTS safeguards learners online can be found in the CTS e-safety and Social Media Policy.

Staff Training

• All staff must familiarise themselves with Keeping Children Safe in Education, Part 1.
• All new employees are required, as part of their induction, to complete an online safeguarding course, an online Prevent awareness course, and an online Equality and Diversity course; the exception being if alternative face-to-face training is provided.
• Established staff receive regular updating; through online refresher courses or in-house training; by designated Safeguarding staff; regular emails; and external training.
• They are also required to update their issues-led knowledge, i.e., Child Sexual Exploitation. Designated staff are expected to organise and/or deliver sessions to raise awareness of emergent issues.

Developing Learner's Skills and Awareness

• CTS has a duty to develop learner’s abilities to keep themselves safe and to recognise when others are at risk, as well as to know how to report concerns and access support.
• All learners must agree to the Behaviour and Positive Engagement Policy, which clearly identifies the expected levels of behaviour from our learners.
• CTS raises the learners’ awareness of safeguarding at induction, through information given to them and using promotional materials and campaigns.
• Safeguarding is an important aspect in the delivery of the curriculum and there are further opportunities to advance skills through the tutorial programme.
• CTS uses a wide range of resources to deliver safeguarding, approved by the designated leads, and teaching staff are expected to use opportunities as they arise to develop the learner's understanding.
• CTS also uses external providers to deliver some aspects of safeguarding development for students, such as South Yorkshire Police/Barnardos.

Monitoring and Evaluation

Safeguarding incidents, actions taken, and staff training are monitored regularly through:

• Reporting to the designated safeguarding lead (CEO) and Senior Management team
• Quarterly Safeguarding Committee meetings

The effectiveness of the policy is evaluated through:

• CTS Safeguarding Committee
• Learner Feedback
• Regular Safeguarding Committee Meetings
• Review of the Safeguarding Policy and Processes
• Quality Improvement Plan
• Ofsted Inspection

Appendix A

Safeguarding Organisation Chart and Safeguarding Committee Members

Designated Safeguarding and Prevent Lead & Committee Chair

Susannah Robb

Chief Executive Officer

0114 263 6570

susannah.robb@ctstraining.co.uk

Safeguarding & Prevent Officers

Alix Sorsby

Learner Engagement Manager

0114 263 6570

alix.sorsby@ctstraining.co.uk

Kim Hodgson

Quality & Curriculum Lead

0114 263 6570

kim.hodgson@ctstraining.co.uk

Appendix B

Definitions of Abuse

(Extracted from the NSPCC ‘First Check’ Publication

Physical Abuse

Physical abuse 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. Physical abuse as well as being a result of an act of commission can also be caused through omission or the failure to act to protect.

Emotional Abuse

Emotional abuse is the persistent emotional ill treatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to children that they are worthless or unloved, inadequate or valued only so far as they meet the needs of another person. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond the child’s developmental capability, as well as over protection 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 causing children to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all other types of ill treatment or abuse, though it may occur alone.

Sexual Abuse

Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, including prostitution, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative or non-penetrative acts. They may include non-contact activities, such as involving children in looking at, or in the production of, pornographic material or watching sexual activities, or encouraging children to behave in sexually inappropriate ways.

Neglect

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in 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 and clothing, shelter, including exclusion from home or danger, failure to ensure adequate supervision including the use of adequate caretakers, or the failure to ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

It is accepted that in all forms of abuse there are elements of emotional abuse, and that some children are subjected to more than one form or abuse at any one time. These four definitions do not minimise other forms of harm. Chapter 11 of Working Together to Safeguard Children and other inter-agency guidance draws attention to other sources of stress or harm for children and families.

These sources could include social exclusion, domestic violence, the untreated mental illness of a parent or carer, or drug or alcohol misuse.

All these areas may have a negative impact on a young person’s health and development and may be noticed by someone caring for a young person. If it is felt that a young person’s well-being is adversely affected by any of these circumstances, the same procedure for reporting concerns should be followed.

Recognising abuse is not easy and it is not your responsibility to decide whether or not child abuse has taken place or if a child is at significant risk. You do, however, have a responsibility to act if you have a concern about a young person’s welfare or safety.

Appendix C

Information Sharing for Safeguarding Purposes Guidance

All staff are provided with training at induction and receive regular updates. All staff should be familiar with the signs of abuse.

Safeguarding is the responsibility of everybody. If staff have any concerns that a young person or vulnerable adult is at risk of, or is being abused, they MUST report this.

This also applies if staff have concerns that somebody is being bullied or is a Safeguarding risk due to other factors i.e., homelessness, exploitation, financial crisis, mental or physical health etc

All Safeguarding concerns must be reported to a member of the Safeguarding team either face to face or by completing a Safeguarding Cause for Concern form.

If a learner tells you about possible or actual abuse

You must:

Stay calm and reassuring
Listen, let the learner speak unprompted and take what the learner is saying very seriously
Explain that you must involve other people and why
Make a written record and then complete the SG Cause for Concern Form or SG Incident Form
Inform any designated member of Safeguarding Staff as soon as possible, or if in an emergency or there is a risk of serious or immediate harm, anyone can make a referral to Social Services or the police
Speak to Safeguarding staff if you require support yourself