Richer Education Safeguarding (Child Protection Policy)
Richer Education takes seriously all complaints that might arise against members of its staff. Procedures are in place for children, parents and staff to share any concern that they may have about the actions of any member staff or volunteer. All such complaints will be brought immediately to the attention of the Directors or one of the Designated Safeguarding Leads if the Directors are not available and nothing should be said to the colleague involved. These procedures are used in respect of all cases in which it is alleged that a tutor or any other member of staff (including volunteers) during a Richer Education session, workshop and or private tuition that provides education for children under 18 years of age 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; or
- Behaved towards a child or children in a way that indicates he or she would pose a risk of harm if they work regularly or closely with children.
The Local Authority Designated Officer (LADO) should be informed of all allegations that come to Richer Education’s attention and appear to meet the criteria. Contact can also be made with the LSCB who will liaise with the LADO. Many cases may well either not meet the criteria set out above, or may do so without warranting consideration of either a police investigation or enquiries by local authority children’s social care services. In these cases, local arrangements will be followed to resolve cases without delay.
Some rare allegations will be so serious they will require immediate intervention by children’s social care services and/or police. In such cases, referral to the LADO will lead to a Strategy Meeting or Discussion being held in accordance with the DfE guidance and London SCB procedures. This process will agree upon the appropriate course of action and the time-scale for investigations.
Richer Education has a legal duty to refer to the Disclosure Barring Service (DBS) office anyone who has harmed, or poses a risk of harm, to a child and who has been removed from working (paid or unpaid) in any of its regular activities. The DBS will consider whether to ban the person. Referrals will be made as soon as possible after the resignation or removal of the individual.
The full procedures for dealing with allegations of abuse made against tutors and/or other staff can be found in Part four of the DfE guidance “Keeping children safe in education”.
The Directors are: Mr Rafael Hernandez (+44 20 7871 0481 (option 3) / WhatsApp +44 75 3522 5432)
Ms Sian Chalkley (+44 20 7871 0481 (option 3) / WhatsApp +44 75 3522 5432)
Richer Education is committed to providing a safe and secure environment for children, staff and visitors and promoting a climate where children and adults will feel confident about sharing any concerns that they may have about their own safety or the well being of others.
The Richer Education’s Child Protection (CP) policy draws upon duties conferred by the Children Acts 1989 and 2004, S175/157 of the 2002 Education Act, the Education & Inspections Act 2006 and the guidance contained in “Working Together to Safeguard Children”, the DfE’s statutory guidance “Keeping children safe in education”, Office for Standards in Education (OFSTED) Guidance and procedures produced by the London Safeguarding Children Board (LSCB) The policy is applicable to all on and off-site activities undertaken by children whilst they are the responsibility of Richer Education.
The purpose of this policy is to:
- Identify the names of responsible persons in Richer Education and explain the purpose of their role
- Describe what should be done if anyone in Richer Education has a concern about the safety and welfare of a child or teenager who attends Richer Education
- Identify the particular attention that should be paid to those children who fall into a category that might be deemed ‘vulnerable’
- Set out expectations in respect of training
- Ensure that those responsible for recruitment are aware of how to apply safeguarding principles in employing staff
- Set out expectations of how to ensure children are safeguarded when there is potential to come into contact with non-Richer Education staff, e.g. volunteers and contractors
- Outline how complaints against staff will be handled
- Set out expectations regarding record keeping
- Clarify how children will be kept safe through the everyday life of Richer Education
- Outline how the implementation of this policy will be monitored
This policy is consistent with all other policies adopted by the Directors and should, in particular, be read in conjunction with the following policies relevant to the safety and welfare of children:
- The Anti-Bullying Policy
- Whistleblowing Policy
Responsibilities and Immediate Action
Safeguarding children in Richer Education is the responsibility of the whole Richer Education staff. All adults working in Richer Education (including visiting staff, volunteers and students on placement) are required to report instances of actual or suspected child abuse or neglect to the Designated Safeguarding Lead who is a member of Richer Education’s leadership team.
The Designated Safeguarding Lead is: Sian Chalkley
The Deputy Designated Safeguarding Lead(s) is: Rafael Hernandez
The Designated Safeguarding Lead is also the first point of contact for external agencies that are pursuing Child Protection investigations and co-ordinates Richer Education’s representation at CP conferences and Core Group meetings (including the submission of written reports for conferences). When an individual concern/incident is brought to the notice of the Designated Safeguarding Lead, they will be responsible for deciding upon whether or not this should be reported as a safeguarding issue. Where there is any doubt as to the seriousness of this concern, or disagreement between the Designated Safeguarding Lead and the member of staff reporting the concern, advice will be sought from the Deputy Designated Safeguarding Lead, the LA’s Strategic Lead Officer for safeguarding in education services or the Early Help Service (EHS) Duty Manager.
Referrals should be made to Local Safeguarding Children Board (LSCB) via a Common Assessment Framework (CAF) form and copied to the LA’s Safeguarding Coordinator via the following email address: firstname.lastname@example.org . Prior to any written CAF being sent as a referral to social care, there should be a verbal consultation with the LSCB social worker or manager, by calling the duty desk on 020 7361 3013, to ensure that making a referral is an appropriate action.
The parent/carer will normally be contacted to obtain their consent before a referral is made. However, if the concern involves, for example, alleged or suspected child sexual abuse, honour-based violence, fabricated or induced illness or the Designated Safeguarding Lead has reason to believe that informing the parent at this stage might compromise the safety of the child or a staff member, nothing should be said to the parent/carer ahead of the referral, but a rationale for the decision to progress without consent should be provided with the referral.
In circumstances where a child has an unexplained or suspicious injury that requires urgent medical attention, the Child Protection referral process should not delay the administration of first aid or emergency medical assistance. If a child is thought to be at immediate risk because of parental violence, intoxication, substance abuse, mental illness or threats to remove the child during session/workshop, for example, urgent Police intervention will be requested.
Where a child sustains a physical injury or is distressed as a result of reported chastisement, or alleges that they have been chastised by the use of an implement or substance, this will immediately be reported for investigation.
All parents applying for places at Richer Education will be informed of our safeguarding responsibilities and the existence of this policy. In situations where children sustain injury or are otherwise affected by an accident or incident whilst they are the responsibility of Richer Education, parents will be notified of this as soon as possible.
Richer Education recognises the need to be alert to the risks posed by strangers or others (including the parents or carers of other children) who may wish to harm children in Richer Education or children travelling to and from Richer Education sessions, workshops and/or courses and will take all reasonable steps to lessen such risks.
Particular vigilance will be exercised in respect of children who are subject to Child Protection Plan and any incidents or concerns involving these children will be reported immediately to the allocated Social Worker (and confirmed in writing; copied to the LA’s Safeguarding Coordinator). If the child in question is a Looked-After child (LAC), this will also be brought to the notice of the Designated Person with responsibility for children in public care.
If a child discloses that they have witnessed domestic abuse or it is suspected that they may be living in a household that is affected by family violence, this will be referred to the Designated Safeguarding Lead as a safeguarding issue.
We will always ascertain the views and feelings of all children. Richer Education acknowledges the additional need for support and protection of children who are vulnerable by virtue of disability, homelessness, refugee/asylum seeker status, the effects of substance abuse within the family, those who are young carers, mid-year admissions, children who are excluded from mainstream education and children where English is an additional language, particularly for very young children, using the translation service if necessary.
We acknowledge that children who are affected by abuse or neglect may demonstrate their needs and distress through their words, actions, behaviour, demeanour, work or other children. Richer Education has a strong commitment to an anti-bullying policy and will consider all coercive acts and inappropriate child-on-child behaviour and sexual activity within a Child Protection context.
Where it comes to our notice that a child under the age of 13 is, or may be, sexually active, whether or not they are a child enrolled at Richer Education, this will result in an immediate referral to Children’s Services. In the case of a young person between the ages of 13 and 16, an individual risk assessment will be conducted in accordance with the London Child Protection Procedures. This will determine how and when information will be shared with parents and the investigating agencies.
The law requires that Children’s Services are notified of private fostering arrangements. Any privately fostered children, i.e. children under the age of 16 (under 18 if disabled) who are cared for 28 days or more by someone who is not their parent or a close relative, that come to our attention will be referred to Children’s Services. Close relatives are defined as step-parents, grandparents, brothers, sisters, uncles or aunts (whether of full blood, half blood or by marriage).
Whole Richer Education in-service training on safeguarding issues will be organised on at least a yearly basis. The last Safeguarding and Child Protection training for all members of the staff was held on 26 September 2021. The next Safeguarding and Child Protection training session for all staff will take place on or around 24 September 2022. All newly recruited staff (teaching and non-teaching) and Directors of the company will be appraised of this policy and will be required to attend relevant LA or Safeguarding Board training. In addition, all new staff and temporary staff will be required to attend an induction session with the Designated Safeguarding Lead or their deputy on their first day in Richer Education. The Designated Safeguarding Lead (and their Deputies) will attend the LA’s dedicated induction course and then refresher training at least every two years. Designated staff will be encouraged to attend appropriate network meetings and to participate in the multi-agency training programme organised by the LSCB.
Richer Education is committed to the process of creating a culture of safe recruitment and, as part of that, adopts recruitment procedures that help deter, reject or identify people who might abuse children. Safe recruitment processes are followed and all staff recruited to Richer Education will be subject to appropriate identity, qualification and health checks. References will be verified and appropriate criminal record checks DBS checks; barred list checks and prohibition checks will be undertaken. The level of DBS check required, and whether a prohibition check is required, will depend on the role and duties of an applicant to work in Richer Education, as outlined in Part three of the DfE guidance “Keeping children safe in education”.
Relevant members of Richer Education who are involved in recruitment will undertake the safer recruitment training. Richer Education will ensure that at least one person on any appointment panel has undertaken safer recruitment training in line with staffing regulations.
Staff joining Richer Education on a permanent or temporary basis will be given a copy of this policy. Additionally, the Staff Handbook confirms Child Protection procedures.
Any parent or other person/organisation engaged by Richer Education to work in a voluntary capacity with children will be subjected to all reasonable vetting procedures and Criminal Records Checks. There is no legal requirement to obtain DBS certificate for volunteers who are not in regulated activity and who are supervised regularly and on ongoing day to day basis by a person who is in regulated activity, but an enhanced DBS check without a barred list check may be requested following a risk assessment. Volunteers will be subject to the same code of conduct as paid employees of Richer Education.
Voluntary sector groups that operate within this Richer Education or provide off-site services for our children or use Richer Education facilities will be expected to adhere to this policy or operate a policy, which is compliant with the procedures adopted by the LSCB.
STAFF CODE OF CONDUCT
All staff (paid and voluntary) are expected to adhere to a code of conduct in respect of their contact with children and their families. Children will be treated with respect and dignity and no punishment, detention, restraint, sanctions or rewards are allowed outside of those detailed in Richer Education’s Behaviour Management Policy. Whilst it would be unrealistic and undesirable to preclude all physical contact between adults and children, staff are expected to exercise caution and avoid placing themselves in a position where their actions might be open to criticism or misinterpretation. Where incidents occur which might otherwise be misconstrued, or in the exceptional circumstances where it becomes necessary to physically restrain a child for their own protection or others’ safety, this will be appropriately recorded and reported to the Directors and parents. Any physical restraint used will comply with DfE and LA guidance.
Except in cases of emergency, qualified First Aiders will only administer first aid. If it is necessary for the child to remove clothing for first aid treatment, there will, wherever possible, be another adult present. If a child needs help with toileting, nappy changing or washing after soiling themselves, another adult should be present or within earshot. All first aid treatment and non-routine changing or personal care will be recorded and shared with parents/carers at the earliest opportunity.
Children requiring regular medication or therapies for long-term medical conditions will be made the subject of a Medical Plan that has been agreed with the parents and the health authority.
For their own safety and protection, staff should exercise caution in situations where they are alone with children. Other than in formal teaching situations; private tuition, for example, the door to the room in which the 1:1 coaching, counselling or meeting is taking place should be left open. Where this is not practicable because of the need for confidentiality, another member of staff will be asked to maintain a presence nearby and a record will be kept of the circumstances of the meeting. All rooms that are used for the teaching or counselling of children will have clear and unobstructed glass panels in the doors.
Richer Education staff should also be alert to the possible risks that might arise from social contact with children outside Richer Education. Home visits to children or private tuition of children should only take place with the knowledge and approval of the Directors. Visits/telephone calls by children to the homes of staff members should only occur in exceptional circumstances and with the prior knowledge and approval of the Directors. Any unplanned contact of this nature or suspected infatuations or ‘crushes’ will be reported to the Directors of Richer Education. Staff supervising off-site activities or Richer Education journeys will be provided with a Richer Education mobile telephone as a point of contact for parents and carers.
Staff will only use Richer Education’s digital technology resources and systems for Professional purposes or for uses deemed ‘reasonable’ by the Directors. Staff will only use the approved Richer Education email, Richer Education Learning Platform or other Richer Education approved communication systems with children or parents/carers, and only communicate with them on appropriate Richer Education business and will not disclose their personal telephone numbers and email addresses to children or parents/carers. Staff will not use personal cameras (digital or otherwise) or camera phones for taking and transferring images of children or staff without permission and will not store images at home.
Staff should be aware of Richer Education’s whistleblowing procedures and share immediately any disclosure or concern that relates to a member of staff with the Directors or one of the Designated Safeguarding Leads if the Directors are not available and nothing should be said to the colleague involved. It should be shared with the Management Board if it relates to the Directors.
Contractors who are engaged by or on behalf of Richer Education to undertake works will be made aware of this policy and the reasons for this. Long-term contractors who work regularly with Richer Education during term time and school holidays will be asked to provide their consent for DBS checks to be undertaken. These checks will be undertaken when individual risk assessments by the Directors deem this to be appropriate. All contractors and sub-contractors will be issued with copies of Richer Education’s code of conduct for staff.
Individuals and organisations that are contracted by Richer Education to work with or provide services to children will be expected to adhere to this policy and their compliance will be monitored. Any such contractors will be subject to the appropriate level of DBS check, if any such check is required (for example because the contractor is carrying out teaching or providing some type of care for or supervision of children regularly). Contractors for whom an appropriate DBS check has not been undertaken will be supervised if they will have contact with children. We will always check the identity of contractors and their staff on arrival at Richer Education.
COMPLAINTS/ALLEGATIONS MADE AGAINST STAFF
Brief and accurate written notes will be kept of all incidents and child protection or child in need concerns relating to individual children. This information may be shared directly with other agencies as appropriate. All contact with parents and external agencies will be logged and these will be kept as CP records. Richer Education will take into account the views and wishes of the child who is the subject of the concern but staff will be alert to the dangers of colluding with dangerous “secrets”.
Child protection records are not open to children or parents. All CP records are kept securely by the Designated Safeguarding Lead and separately from educational records. The Designated Safeguarding Lead and Directors of Richer Education may only access them.
The content of Child Protection Conference or Review reports prepared by Richer Education will follow the headings recommended by Children’s Services and will, wherever possible, be shared with the parents/carer in advance of the meeting.
Richer Education will require documentary proof as to the identity of children presented for enrolment. If there is any doubt as to the identity of a child, advice will be sought from the local authority and other statutory agencies, as appropriate. We will maintain accurate and up to date records of those with Parental Responsibility and emergency contacts. Pupils will only be released to the care of those with Parental Responsibility or someone acting with their written consent.
SAFETY WITH RICHER EDUCATION
No internal doors to classrooms, seminar rooms, lecture theatres, and laboratories will be locked whilst children are present in these areas.
Weekly registration and dismissal will be controlled by doors that are secured physically or by constant staff supervision or video surveillance. Authorised visitors to Richer Education will be logged into and out of the premises, through the Richer Education registration and dismissal system, and will be asked to wear their identity badges or be issued with Richer Education ‘Visitor’ badges and Richer Education lanyards. Unidentified visitors will be challenged by staff or reported to the Directors or Richer Education office. Carelessness in closing any controlled entrance will be challenged.
The presence of intruders and suspicious strangers seen loitering near Richer Education’s workshops, classes, courses and/or sessions or approaching children, will be reported to the Police and the LA with a view to alerting other local Richer Educations through appropriate systems.
Parents, carers or relatives may only take still or video photographic images of children in Richer Education or on Richer Education-organised activities with the prior consent of Richer Education and then only in designated areas. Images taken must be for private use only. Recording and/or photographing other than for private use would require the consent of the other parents whose children may be captured on film. Without this consent, the Data Protection legislation would be breached. If parents do not wish their children to be photographed or filmed and express this view in writing, their rights will be respected.
WORKING IN PARTNERSHIP WITH PARENTS
It is our policy to work in partnership with parents or carers to secure the best outcomes for our children. We will therefore communicate as clearly as possible about the aims of this Richer Education.
- We will use clear statements in our brochures and correspondence.
- We will involve parents and children in the review of this policy and in the development of Codes of Conduct and Equalities and Behaviour Management policies.
- We will be alert to the needs of parents/carers who do not have English as their first language and will utilise the translation services as necessary.
- We will keep parents informed as and when appropriate.
- This policy will be reviewed on an annual basis and we be kept up to date in line with model procedures from the Royal Borough of Kensington and Chelsea.
- Secure and Confidential Records are kept of all incidents that fall within the scope of the policy. The deputy designated person provides a written report for all case conferences following local authority guidelines.
- Annual audits of safeguarding procedures are arranged with the local authority to ensure that all procedures are up to date and correct.
All complaints arising from the operation of this policy will be considered under Richer Education’s complaint procedure, with reference to the LA’s Strategic Lead Officer for safeguarding in education services as necessary.