Safeguarding and Child Protection Policy

Introduction

Everyone who comes into contact with children has a role to play in safeguarding children. All professionals should ensure that their approach is child centred: this means always considering what is in the best interests of the child.

This Safeguarding and Child Protection Policy applies to the entire College and at all times, including where students or staff are away from the College, whether they are on College – arranged activities or otherwise, and whether or not the College is open.

Safeguarding and promoting the welfare of children is defined as:

• Providing help and support to meet the needs of children as soon as problems emerge;
• Protecting children from maltreatment, whether this is within or outside the home, including online;
• Preventing impairment of children's mental and physical health or development;
• Ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and
• Taking action to enable all children to have the best outcomes in line with the outcomes.

All staff should understand the indicators of abuse, neglect, exploitation and specific safeguarding risks so that they can identify them and report any concerns about children. The indicators and key safeguarding risks for the College community are set out in Appendix 1 of this policy.

At Kennedy College Oxford we are committed to safeguarding children and we expect everyone who works with the College to share this commitment. Adults working with us take all welfare concerns seriously and encourage children and young people to talk to us about anything that worries them. We will always act in the best interest of the child.

References to staff includes all those who work for or on behalf of the College, regardless of their employment status, including contractors, supply staff, volunteers and governors.

KCO believes that it should provide a caring, positive, safe and stimulating environment in which students can learn and which promotes the social, physical, mental health and emotional wellbeing of each individual student, and which takes a child-centred approach.

KCO recognises its responsibilities and duties to report child protection (CP) concerns to the social work service within Children’s Services and to assist Children's Services in child protection enquiries and in supporting children in need.

This policy has been prepared to meet the College's responsibilities under the following legislation: the Children Act 1989, the Education and Skills Act 2008, the Children Act 2004, the Education (Independent School Standards (England) Regulations 2014, the Equality Act 2010, the Protection of Freedoms Act 2012, the Children and Social Work Act 2017, the Safeguarding Vulnerable Groups Act 2006, the Human Rights Act 1998, the Charities Act 2011, the Data Protection Act 2018 and UK General Data Protection Regulation.

The policy has regard to the following guidance and advice:

• Keeping Children Safe in Education (KCSIE) (September 2024);
• Working Together to Safeguard Children 2023 (updated February 2024);
• Prevent Duty Guidance for England and Wales (2023);
• Multi-Agency Statutory Guidance on Female Genital Mutilation (July 2020), Children Missing Education (August 2024); and
• Relationships Education, Relationships and Sex Education (RSE) and Health Education Guidance (September 2021).

Contact details for Kennedy College staff with safeguarding responsibilities

Peter Thompson
Designated Safeguarding Lead (DSL)

Julia Yang
Deputy Designated Safeguarding Lead (DDSL)

Robin Fry
Safeguarding Governor

Dr Suzanne Yang
Proprietor

External agencies and multi-agency working

KCO will develop and promote effective working relationships with other agencies including the police and Children's Social Care.

We will participate in safeguarding practice and safeguarding management reviews as necessary.

If you think a child is in immediate danger, call the police on 999.

Agency/contact person	Contact details
Oxfordshire Safeguarding Children Board (OSCB)	www.oscb.org.uk
LADO (Local Authority Designated Officer)	This email address is being protected from spambots. You need JavaScript enabled to view it. 01865 810603
MASH (Multi-Agency Safeguarding Hub)	This email address is being protected from spambots. You need JavaScript enabled to view it. 0345 050 7666 0800 833 408 (out of hours emergency)
Thames Valley Police Prevent Officer (for issues relating to radicalisation and extremism)	This email address is being protected from spambots. You need JavaScript enabled to view it.
DfE helpline for non – emergency advice relating to extremism	This email address is being protected from spambots. You need JavaScript enabled to view it. 020 7340 7264
NSPCC Report Abuse in Education Advice Helpline	This email address is being protected from spambots. You need JavaScript enabled to view it. 0800 136 663
NSPCC FGM free phone helpline	0800 028 3550
NSPCC Whistleblowing helpline	This email address is being protected from spambots. You need JavaScript enabled to view it. 0800 028 0285 (8am-8pm Mon-Fri)
Disclosure & Barring Service (DBS)	This email address is being protected from spambots. You need JavaScript enabled to view it. 03000 200 190

Aims

• To actively promote and safeguard the welfare of students, staff and others taking part in KCO courses;
• To raise awareness of all adults working with children of the need to safeguard all children and of their roles and responsibilities in respect of identifying and reporting possible cases of abuse;
• To ensure all staff receive appropriate training;
• To emphasise the need for good communication between all members of staff on matters relating to safeguarding and child protection;
• To promote safe practice and challenge poor and unsafe practice;
• To ensure appropriate action is taken in the event of incidents, concerns of abuse and support is provided to the individual(s) who raise or disclose the concern;
• To ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored;
• To ensure that all adults working at KCO have been checked as to their suitability to work with children, in line with current guidance;
• To integrate opportunities in the curriculum for children to develop the skills they need to recognize and stay safe from abuse; and
• To take account of policy in related areas such as anti-bullying, health and safety, FGM, anti-radicalisation, child sexual exploitation, sexual violence and harassment between children, procedures for dealing with allegations against staff and recruitment practice.

Principles

• KCO believes that all children have a right to be protected from harm and/or abuse, neglect or exploitation;
• The College will take reasonable steps to ensure that its students and others who come into contact with KCO do not, as a result, come to harm or are exposed to abuse;
• KCO recognises that abuse, exploitation and neglect are complex issues and rarely stand-alone events and therefore require a culture of vigilance, professional curiosity and respectful challenge and effective recording and monitoring systems;
• KCO recognises that abuse occurs in all cultures, religions and social classes and that staff need to be sensitive to the many differing factors which need to be considered depending on the child’s cultural and social background when dealing with CP issues. However, KCO also recognises that the needs of the child are paramount and any concerns will be referred on appropriately whatever the family background of the child concerned;
• KCO recognises that a child who is abused or witnesses abuse or violence may find it difficult to develop and maintain a sense of self-worth, they may feel helpless and humiliated and may feel self-blame;
• KCO accepts that research shows that the behaviour of a child in these circumstances may range from that which is perceived as normal to that which is overtly aggressive, disturbed or withdrawn;
• KCO knows that it is important that children feel secure, are encouraged to talk and are sensitively listened to, and that children know that there are adults working on at the College who they can approach if they are worried or unhappy;
• KCO acknowledges that (although all designated/key staff have been appointed to respond to a variety of situations and issues) there may be occasions where it will be appropriate to consider whether specific or additional arrangements need to be put in place where an issue is particularly sensitive due to gender issues or cultural or faith issues. This ensures that in cases of sexual abuse in particular, a student can be spoken to by a same sex member of staff (who has received enhanced training) if this is felt to be appropriate;
• KCO adheres to the principles of working in partnership with those who hold parental responsibility for each child;
• The prime concern at all times must be the welfare and safety of the child. Where there is a conflict between the needs of the child and the parent/carer, the interests of the child must be paramount;
• The ethos of KCO supports open practice, good communication and a safe culture in which children can thrive and learn;
• All staff should feel able to raise concerns about poor or unsafe practice or potential failures in KCO's safeguarding practice and know that these concerns will be taken seriously by the leadership team and dealt with sensitively and appropriately; and
• All staff should only involve those who need to be involved when a child tells them he/she/they is/are being abused, neglected or exploited.

Contextual Safeguarding

Safeguarding incidents and/or behaviours can be associated with factors outside the College and/or can occur between children outside the College, inside and outside of home and online.

All staff, including the DSL, should consider the context within which such incidents and/or behaviours occur, for example where wider environmental factors are present in a child's life that may be a threat to their safety and/or welfare, and should record these appropriately.

Extra-familial harm: all staff, but especially the DSL (and deputies) should consider whether children are at risk of abuse or exploitation in situations outside their families. Extra-familial harms take a variety of different forms and children can be vulnerable to multiple harms including (but not limited to) sexual abuse (including harassment and exploitation), domestic abuse in their own intimate relationships (teenage relationship abuse), criminal exploitation, serious youth violence, county lines and radicalisation.

Leadership of safeguarding

Governing body responsibilities

• Legal responsibility to ensure that arrangements are made to safeguard and promote the welfare of students at the College, having regard to relevant guidance issued by the Secretary of State;
• Strategic leadership responsibility for the College's safeguarding arrangements; and
• Specific responsibilities to facilitate a whole College approach to safeguarding, set out in more detail in Part 2 of KCSIE.

The governing body will:

• Appoint a board level lead on safeguarding matters;
• Ensure that it complies with its duties under legislation, including under the Human Rights Act 1998 and the Equality Act 2010;
• Ensure that the policies, procedures and training in the College are effective and comply with the law and obligations;
• Ensure that the College contributes to multi-agency working in line with the statutory guidance Working Together to Safeguard Children;
• Ensure that children are taught about how to keep themselves and others safe, including online and that effective education will be tailored to the specific needs and vulnerabilities of individual children;
• Ensure that appropriate arrangements are in place for the whole governing body to discharge their function, including appropriate consideration of safeguarding matters at Board meetings and a holistic annual review of safeguarding; and
• Establish appropriate delegation arrangements at College level, led by the Principal and DSL, to enable the College to discharge its safeguarding duties effectively.

Staff responsibilities

All staff have a duty to:

• Read this policy carefully and be fully aware of the procedures described herein;
• Report any concerns they may have about the safety and/or wellbeing of students;
• Report any concerns they may have about the safety and/or wellbeing of other persons associated with KCO;
• Report any safeguarding concerns about staff or anyone else associated with KCO;
• Maintain an attitude of ‘it could happen here’;
• Always act in the best interests of the child where safeguarding is concerned;
• Speak to a designated safeguarding lead if they are unsure about any safeguarding concern;
• Be aware of the indicators of abuse and neglect. See Appendix 1;
• Follow the reporting and referral processes below; and
• Raise any concerns about poor or unsafe practices or potential failures in the organisation's safeguarding processes.Such concerns will be taken seriously and dealt with sensitively and appropriately. Staff may follow KCO's Whistleblowing Policy or alternatively contact the NSPCC whistleblowing helpline. Contact details are provided above.

The Principal

The Principal is responsible for the overall management of the College and for the management of concerns and allegations about staff.

The Principal ensures that KCO's policies and procedures, adopted by the governing body and proprietor (particularly those concerning referrals of cases of suspected abuse, neglect and exploitation) are understood and followed by all staff.

Designated Safeguarding Lead (DSL)

Kennedy College Oxford has appointed a DSL with the appropriate qualifications and experience to carry out the duties of the role. Responsibilities of the DSL include:

Managing referrals

• Referring cases of suspected abuse to the local authority as required;
• Support staff who make referrals;
• Refer cases where a person is dismissed or left due to risk/harm to a child to the Disclosure and Barring Service as required; and
• Refer cases where a crime may have been committed to the police as required.

Working with others

• Act as a source of support, advice and expertise for staff;
• Act as a point of contact with safeguarding partners; and
• Liaise with staff on matters of safety and safeguarding and when deciding whether to make a referral by liaising with the relevant agencies.

Raising awareness

• Ensure the organisation's child protection policy is known and understood; and
• Ensure the organisation's child protection policy and procedures are reviewed at least annually.

Training

The DSL and deputies attend the necessary enhanced training courses to enable them to carry out their role effectively. This training should be updated at least every 2 years.

Recordkeeping

All concerns, discussions and decisions made and the reasons for those decisions should be recorded in writing. The records created may contain personal data. Such records will be kept secure such that only the DSL and deputies may have access to. All records created will be managed in accordance with KCO’s data privacy policies.

Deputy Designated Safeguarding Lead (DDSL)

• Deputise for the DSL in their absence;
• Support the DSL in responding to and managing safeguarding concerns as necessary;
• Conduct investigations into safeguarding concerns; and
• Liaise with partner institutions and external agencies as necessary.

Teaching students how to stay safe

KCO ensures that students are taught about how to keep themselves and others safe, including online. The College recognises that effective education should be tailored to the specific needs and vulnerabilities of individual children.

The College teaches students about safeguarding through the curriculum. This includes guidance on adjusting behaviour to reduce risks, particularly online, building resilience to protect themselves and their peers, fostering healthy and respectful relationships with others and providing information about who they should turn to for help.

KCO recognises that a one size fits all approach may not be appropriate for students, and a more personalised or contextualised approach for more vulnerable children, victims of abuse and some SEND children might be needed.

Students are taught about harmful sexual behaviours, including sexual violence and sexual harassment through a ‘Life Education’ programme, which is fully inclusive and appropriate to their age and stage of development. Sessions on relationships and sex education include amongst other topics:

• Healthy and respectful relationships;
• Boundaries and consent;
• Stereotyping, prejudice and equality;
• Body confidence and self-esteem;
• How to recognise an abusive relationship, including coercive and controlling behaviour;
• The concepts of, and laws relating to sexual consent, sexual exploitation, abuse, grooming, coercion, harassment, rape, domestic abuse, so called honour-based violence such as forced marriage and Female Genital Mutilation (FGM), and how to access support;
• What constitutes sexual harassment and sexual violence and why these are always unacceptable;
• Sharing nudes and semi-nudes;
• Porn; and
• Sexual bullying as well as sessions on online safety, where children are taught to keep themselves safe online and the risks posed by adults/young people, who use the internet and social media to bully, groom, abuse or radicalise.

Students are given the opportunity to talk about safeguarding issues within the classroom environment and are made aware of the processes by which any concerns they have can be raised, including the processes for reporting a concern about a friend or peer, and how any report will be handled.

The safe use of technology and the internet is a focus in all areas of the curriculum and key ICT safety messages are reinforced as part tutorial and pastoral activities.

Communication with parents/carers/guardians

Parents will normally be kept informed, as appropriate, of any action to be taken under these procedures. However, there may be circumstances when the DSL will need to consult the Principal, the Local Authority Designated Officer(s), children's social care, the police and/or the student before discussing details with parents.

In all cases, the DSL will be guided by the Oxfordshire Child Safeguarding Board (OSCB) referral threshold document.

Confidentiality

We recognise that all matters relating to child protection are confidential. The DSL will disclose personal information about a child or young person to other members of staff on a need-to-know basis only. However, all staff must be aware that they and KCO have a professional responsibility to share information with other agencies to safeguard children.

We will undertake no names consultations with OSCB to discuss concerns we may have, but we understand that if OSCB or another statutory agency then asks for a name we will disclose those details and it will become a referral.

Children with special educational needs or disabilities (SEND) or health issues

Kennedy College Oxford will do all that is reasonable to ensure that its curriculum, ethos, culture, policies, procedures and premises are made accessible to students with special educational needs and disabilities (SEND).

The College recognises that children with SEN and disabilities or certain medical or physical health conditions can face additional safeguarding challenges, both online and offline. The College understands that additional barriers can exist when recognising abuse, neglect and exploitation in this group of children and that that these barriers can create additional safeguarding challenges for those involved in safeguarding and promoting their welfare.

Staff will support such pupils in expressing any concerns they may have and will be particularly vigilant to any signs or indicators of abuse, discussing this with the DSL/DDSL as appropriate.

KCO will consider extra pastoral support and attention for these children, along with ensuring any appropriate support for communication is in place.

Children who are lesbian, gay, bisexual or gender-questioning

A student or young person being lesbian, gay or bisexual is not in itself an inherent risk factor for harm. However, they can sometimes be targeted by other students. In some cases, a child who is perceived by other children to be lesbian, gay or bisexual (whether they are or not) can be just as vulnerable as children who are.

Staff are aware of these vulnerabilities and KCO endeavours to create a culture where they can speak out or share their concerns with trusted members of staff.

The College will take a cautious approach when supporting a gender questioning child and consider the broad range of their individual needs, in partnership with the student’s parents (other than in the exceptionally rare circumstances where involving parents would constitute a significant harm to the child), including any clinical advice that is available and how to address wider vulnerabilities such as the risk of bullying.

KCO will refer to the DfE guidance in relation to Gender Questioning Children, when deciding how to proceed. When families/carers are making decisions about support for gender questioning children, they will be encouraged to seek clinical help and advice.

Wellbeing and mental health

In order to help students succeed, KCO recognises that it plays an important role in supporting them to be resilient and mentally healthy.

Some children are more at risk of developing mental health problems than others and these risks can relate to the child, their family or to community and life events. Risk factors are cumulative, and children exposed to multiple risks are more likely to develop behavioural or mental health problems. All staff should also be aware that mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation.

Only appropriately trained professionals should attempt to make a diagnosis of a mental health problem. Staff, however, are well placed to observe children day-to-day and identify those whose behaviour suggests that they may be experiencing a mental health problem or be at risk of developing one. Where staff have a mental health concern about a child that may also be a safeguarding concern, they should raise the issue by informing the DSL or deputy immediately.

Online safety

All staff should be aware that technology is a significant component in many safeguarding and wellbeing issues. Children are at risk of abuse online as well as face to face. In many cases abuse will take place concurrently via online channels and in daily life.

Categories of risk

The breadth of issues classified within online safety is considerable, but can be categorised into four areas of risk:

Content: being exposed to illegal, inappropriate or harmful content, for example: pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalisation and extremism.

Contact: being subjected to harmful online interaction with other users; for example: peer to peer pressure, commercial advertising and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial or other purposes.

Conduct: personal online behaviour that increases the likelihood of, or causes, harm; for example, making, sending and receiving explicit images (e.g. consensual and non-consensual sharing of nudes and semi-nudes and/or pornography, sharing other explicit images and online bullying; and

Commerce: risks such as online gambling, inappropriate advertising, phishing and or financial scams. If students or staff are at risk, it should be reported to the Anti-Phishing Working Group.

Filtering and monitoring

In order to meet the requirements of KCSIE, KCO will have in place filtering and monitoring systems to protect students from illegal, inappropriate and harmful materials online (content risk), the risk of children being subjected to harmful online interaction with other users (contact risk), risks such as online gambling, phishing or financial scams (commerce risk) and to help manage online behaviour that can increase the likelihood of, or causes, harm (conduct risk).

KCO recognises however that students have unlimited and unrestricted access to the internet via their mobile phone networks which means that they may consensually and/or non-consensually share indecent images, sexually harass, bully and control their peers via mobile and smart technology, and view and share pornography and other harmful content.

Monitoring and review

The DSL will ensure that the procedures set out in this policy and the implementation for these procedures are updated and reviewed regularly. Minimally, this will be annually.

Any safeguarding incidents will be followed by a review of these procedures by the DSL and, if appropriate, with the support of an external agency.

Where an incident involves a member of the staff, the LADO will be asked to assist in the review.

Any deficiencies or weaknesses in regard to safeguarding arrangements at any time will be remedied without delay.

Procedures

What to do if you have a concern about a child or young person

All staff members have a responsibility to safeguard and promote the welfare of children studying at Kennedy College Oxford.

If a staff member has a concern about student or receives information that leads them to be concerned that a student has been harmed or is at risk of harm or their welfare is being compromised, they are required to act appropriately and immediately to ensure action can be taken to protect the student.

It is important to understand that students may not find it easy to tell staff about abuse verbally. Students can show signs or act in ways that they hope adults will notice and react to. If staff have any concerns about a child's welfare, they should act on them immediately rather than wait to be told. Staff should never assume that somebody else will take action and share information that might be critical in keeping children safe; they should always maintain an “it could happen here” attitude and always act in the best interests of the child when concerned about their welfare. The member of staff must report the concern to the DSL or deputy.

If the concern involves an allegation against staff, a supplier or contractor, this must be reported in accordance with the procedures set out below.

Staff must report known cases of female genital mutilation (FGM) to the police. Further information about FGM and the reporting duty can be found in Appendix 1.

Guidance on receiving a disclosure

The concern may be as a result of a disclosure from a student, a parent, or a third party or may arise due to behavior that has caused the staff member to become concerned.

When listening to a child, staff must:

• Listen carefully to what the student is telling them without interrupting;
• Ideally listen to the child first and then make notes;
• Not promise confidentiality;
• Remain non-judgmental and keep an open mind;
• Not ask leading questions or more questions than needed;
• Be honest with the child and explain what will happen next; and
• Keep a sufficient written record of the conversation. All other evidence, for example, scribbled notes, mobile phones containing text messages, clothing, computers, must be kept securely with the written record.

Records should be factual and signed and dated, with the name of the signatory clearly printed in writing. Records should include:

• The student's details: name; date of birth; address and family details;
• Date and time of the event/concern/conversation;
• A clear and comprehensive summary of the event/concern/conversation;
• Details of how the concern was followed up and resolved;
• A note of any action taken and by whom, decisions reached and the outcome; and
• The name and position of the person making the record.

When reporting a concern staff must:

• Record the information fully using the Cause for Concern Record Form. See Appendix 3;
• If the form is not accessible, staff must not delay in informing the DSL or deputy;
• Note the facts in the child’s own words; and
• Pass the form by hand personally or via email (marked Confidential) to the DSL or deputies immediately.

The DSL should be informed as soon as practically possible if the DSL is not involved in the initial report.

Staff should be able to reassure the victim(s) that they are being taken seriously and that they will be supported and kept safe. A victim should never be given the impression that they are creating a problem by reporting abuse, sexual violence or sexual harassment. Nor should a victim ever be made to feel ashamed for making a report. It is important to explain that the law is in place to protect children and young people rather than criminalise them, and this should be explained in a way that avoids alarming or distressing them.

Abuse that occurs online or outside of a centre should not be downplayed and should be treated equally seriously.

Parents/Carers of the student will always be informed of allegations of abuse made by a child unless this puts the child or the subsequent investigation at risk (e.g. if they are the subject of the allegation).

Asking for advice

Staff should remember the DSL is available to offer help, advice and guidance to staff and children. If staff have a concern or problem and are unclear how to proceed, they should ask for advice.

The DSL will seek advice from external agencies if they are unsure how to proceed with a child protection situation.

Action by the DSL

On receipt of a concern, the DSL will consider the appropriate course of action. Such action may include:

• Managing any support internally using the College’s own resources or the resources of a partner institution, seeking advice from children’s social care where required;
• A multi-agency referral; and/or
• A referral to statutory services.

The views of the child will be considered when considering the appropriate course of action but will not be determinative.

Where the concern relates to the welfare of a student who is aged 18 or over, the DSL will consider whether it is necessary to refer such concerns to the Safeguarding Adults Board.

If it is decided that a referral is not required, the DSL will keep the matter under review and give ongoing consideration to a referral.

Making a referral

Where a child is suffering or is likely to suffer from harm, a referral to children’s social care (and if appropriate the police) should be made immediately.

Children in need: A child in need is a child who is unlikely to achieve or maintain a reasonable level of health or development, or whose health and development is likely to be significantly or further impaired, without the provision of services; or a child who is disabled. Children in need may be assessed under section 17 of the Children Act 1989.

Children suffering or likely to suffer significant harm: Local authorities have a duty to make enquiries under section 47 of the Children Act 1989 if they have reasonable cause to suspect that a child is suffering, or is likely to suffer significant harm.

If a referral is made by phone, this should be followed up in writing. If the referral is made by someone other than the DSL, the DSL should be informed of the referral as soon as possible.

Once a referral is made, if a response is not received within one working day, the DSL or person making the referral will contact the appropriate agency to follow up.

Allegations against staff (including contractors, volunteers and governors)

All staff should take care not to place themselves in a vulnerable position with a child and should take note of the additional factors which arise from one-to-one tutorial teaching.

The College understands that a child or young person may make an allegation against a member of staff.

Concerns and allegations that may meet the harms test will be addressed as set out in Section two of Part four of KCSIE. 'Lower level' concerns and allegations that do not meet the harms test will be addressed as set out in Section two of Part four of KCSIE.

In any event, if such an allegation is made, the member of staff receiving the allegation will immediately inform the Principal, who will, on all such occasions, discuss the content of the allegation with the LADO (Local Authority Designated Officer) or Safeguarding Team before taking any action.

All such allegations must be dealt with as a priority without delay.

Allegations that meet the harm threshold

The term allegation refers to concerns reported or raised that might indicate a person has caused harm to a child, acted in a way that created potential serious risk to a child or would pose a risk of harm if they continue to work in regular or close contact with children in their present position, or in any capacity. This means it has been alleged that anyone working (including supply staff, volunteers and contractors) in a school or college 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; and/or
• Possibly committed a criminal offence against or related to a child; and/or
• Behaved towards a child or children in a way that indicates he or she would pose a risk of harm to children; and/or
• Behaved or may have behaved in a way that indicates they may not be suitable to work with children.

Such allegations and concerns may be said to have reached the harm threshold as set out in KCSIE 2024. Clearly, such concerns must be raised immediately with the Principal or DSL.

Low level concerns

There may be situations where staff have concerns that do not meet the harm threshold: ‘low level concerns’. Nonetheless, staff are required to report these using the Cause for Concern form at Appendix 3.

The term 'low level' concern does not mean that it is insignificant. A 'low level' concern is any concern - no matter how small, and even if no more than causing a sense of unease or ‘nagging doubt’ - that an adult working with KCO may have acted in a way that is inconsistent its expected standards of conduct, including inappropriate conduct outside of work. Example behaviours include, but are not limited to:

• Being over friendly with children
• Having favourites
• Taking photographs of children on their mobile phone
• Engaging with a child on a one-to-one basis in a secluded area or behind a closed door
• Using inappropriate sexualised, intimidating or offensive language
• Humiliating a student or students
• Any use by an adult of sexually inappropriate language, references or jokes to a student

Staff should be encouraged and feel confident to self-refer, where, for example, they have found themselves in a situation which could be misinterpreted, might appear compromising to others, and/or on reflection they believe they have behaved in such a way that they consider falls below the expected professional standards.

Staff must record all low-level concerns in writing (this may be done over e-mail). The DSL will securely retain confidential files on low-level concerns. The record should include details of the concern, the context in which the concern arose and the action taken. The name of the individual sharing their concerns should also be noted, though if the individual wishes to remain anonymous then that will be respected as far as reasonably possible. The Principal should ultimately be informed of all low-level concerns and make the final decision on how to respond. Where appropriate this can be done in consultation with the DSL.

Appendix 1: Types and signs of abuse

1. Abuse, neglect and exploitation

   Abuse is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Harm can include ill treatment that is not physical as well as the impact of witnessing ill treatment of others. This can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse, including where they see, hear or experience its effects. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. They may be abused by an adult or adults or by another child or children.

   Physical abuse: 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 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 from participating in normal social interaction. It may involve seeing or hearing the ill treatment of another. It may involve serious bullying (including cyberbullying and prejudiced-based or discriminatory 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, although 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 (for example 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. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children. The sexual abuse of children by other children is a specific safeguarding issue (also known as peer on peer abuse) in education and all staff should be aware of it.

   Neglect: 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, for example, through 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 care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child's basic emotional needs.

2. Specific forms of abuse and safeguarding issues

   Statutory guidance acknowledges several specific safeguarding issues. Additional information on these safeguarding issues and information on other safeguarding issues can be found in Annex B of KCSIE. Staff should be particularly aware of these safeguarding issues, including those set out below.

   • Bullying including cyber bullying
   • Children missing education
   • Child missing from home or care
   • Child sexual exploitation (CSE)
   • Child on child abuse
   • Cybercrime
   • Domestic violence
   • Fabricated or induced illness
   • Faith abuse
   • Female genital mutilation (FGM)
   • Forced marriage and honour-based violence
   • Gangs and youth violence
   • Gender-based violence/violence against women and girls (VAWG)
   • Homophobic, biphobic and transphobic bullying
   • Mental health
   • Preventing radicalisation
   • Substance misuse

   Child sexual exploitation

   (CSE) involves exploitative situations, contexts and relationships where young people receive something (for example food, accommodation, drugs, alcohol, gifts, money or in some cases simply affection) as a result of engaging in sexual activities. Sexual exploitation can take many forms ranging from the seemingly ‘consensual’ relationship where sex is exchanged for affection or gifts, to serious organised crime by gangs and groups. What marks out exploitation is an imbalance of power in the relationship. The perpetrator always holds some kind of power over the victim which increases as the exploitative relationship develops. Sexual exploitation involves varying degrees of coercion, intimidation or enticement, including unwanted pressure from peers to have sex, sexual bullying including cyberbullying and grooming. However, it is also important to recognise that some young people who are being sexually exploited do not exhibit any external signs of this abuse.

   The victim may have been sexually exploited even if the sexual activity appears consensual. CSE does not always involve physical contact; it can also occur through the use of technology. CSE can affect any child under the age of 18 years (including 16 and 17 year olds who can legally consent to have sex) who has been coerced into engaging in sexual activities. It can include both contact (penetrative and non-penetrative acts) and non-contact sexual activity and may occur without the child’s immediate knowledge (e.g., through others copying videos or images they have created and posted on social media). Some children may not realise they are being exploited e.g. they believe they are in a genuine romantic relationship. CSE can be a one-off occurrence or a series of incidents over time and range from opportunistic to complex organised abuse. It may occur alone, or may overlap with CCE, and/or county lines, as well as other forms of abuse.

   Indicators of child sexual exploitation may include:

   • Acquisition of money, clothes, mobile phones, etc. without plausible explanation;
   • Gang-association and/or isolation from peers/social network;
   • Exclusion or unexplained absences from college, school or work;
   • Leaving home/care without explanation and persistently going missing or returning late;
   • Excessive receipt of texts/phone calls;
   • Returning home under the influence of drugs/alcohol;
   • Inappropriate sexualised behaviour for age/sexually transmitted infection;
   • Evidence of/suspicions of physical or sexual assault;
   • Relationships with controlling or significantly older individuals or groups;
   • Multiple callers (unknown adults or peers);
   • Frequenting areas known for sex work;
   • Concerning use of internet or other social media;
   • Increasing secretiveness around behaviours; and
   • Self-harm or significant changes in emotional well-being.

   If you suspect a child is at risk of CSE or that this has already taken place, this should be reported to the DSL or Deputy as soon as possible.

   Child on Child Abuse

   Staff and other adults should recognise that children and young people are capable of abusing their peers. KCO takes any concerns of this nature very seriously and concerns should be raised in the same way as other concerns, directly to the Designated Safeguarding Lead or a deputy. Child on child abuse can take the form of bullying (including cyber bullying), sexting and any other form of sexual or physical abuse. See Appendix 2.

   Female genital mutilation (FGM)

   Female genital mutilation includes procedures that intentionally alter or injure the female genital organs for non-medical reasons. It is a surprisingly common form of abuse in the UK – over 1700 victims were referred to specialist clinics in the UK during the last 2 years. Many more cases are believed to go unreported.

   A girl or woman who has undergone FGM may:

   • Have difficulty walking, sitting or standing
   • Spend longer than normal in the bathroom or toilet
   • Have unusual behaviour after an absence from her studies
   • Be particularly reluctant to undergo normal medical examinations
   • Ask for help, but may not be explicit about the problem due to embarrassment or fear

   Any indication that FGM is a risk, is imminent, or has already taken place must be reported to the DSL or Deputy and a referral to the police made.

   Child drug exploitation

   Gangs pose a significant threat to vulnerable adults and children who they rely on to conduct and/or facilitate this criminality. Exposure to gang exploitation has the potential to generate emotional and physical harm. A more recent trend identified is the targeting of adults with mental health problems. The use of mobile phones to maintain ‘deal lines’ between customers and gang members is a key feature. Although CSE is not the driving factor, there are clear links between drug exploitation and CSE. Girls who are being exploited to hold and deal drugs are vulnerable to becoming more accessible to gang members wishing to sexually exploit them. Any concerns should be directed to the DSL or Deputy.

   Honour-based violence (HBV)

   A marriage where one or both of the parties is married without their consent or against their will. It is illegal in the UK and is recognised as a form of violence against women and men, girls and boys and a serious abuse of human rights. The pressure put on people to marry against their will can be physical (including threats and actual physical or sexual violence) or emotional and psychological. Financial abuse (taking or not giving money) can be a factor. The Forced Marriage Unit has been set up by the FCO and Home Office to help stop forced marriages or to help people leave a marriage they have been forced into.
   Forced Marriage Unit
   This email address is being protected from spambots. You need JavaScript enabled to view it.
   02070080151
   Any concerns should be passed immediately to the DSL or Deputy.

   Modern slavery

   It is estimated there are many thousands of people in modern slavery in the UK today. Most commonly people are trafficked into forced labour in industries such as agriculture, construction, hospitality, manufacturing and car washes. Many women and girls are trafficked for sexual exploitation or end up in domestic slavery. The Modern Slavery Act 2015 is designed to tackle slavery in the UK. Any concerns about students should be passed to the DSL.

   Extremism & Radicalisation

   The Counter-Terrorism and Security Act places a duty on service providers to have due regard to the need to prevent people from being drawn into terrorism ("the Prevent duty").

   Radicalisation is a form of abuse and is addressed within our safeguarding procedures. KCO values:

   • Democracy
   • The rule of law
   • Individual liberty
   • Mutual respect and tolerance of different faiths and beliefs

   All KCO staff receive training to both support their awareness of the Prevent Strategy and their ability to identify and support individuals who are vulnerable to being drawn into terrorism.

   Bullying

   Teachers should ensure that all students have an opportunity, during tutorial time, to discuss bullying, its causes and student strategies to deal with it. Staff should be aware that, increasingly, bullying takes place online (cyber-bullying).

   If you become aware of a case of bullying, inform the DSL or Deputy immediately.

3. Potential signs of abuse

   Possible signs of abuse include, but are not limited to:

   • The student says he/she has been abused or asks a question or makes a comment which gives rise to that inference;
   • There is no reasonable or consistent explanation for a student's injury, the injury is unusual in kind or location or there have been a number of injuries and there is a pattern to the injuries;
   • The student's behaviour stands out from the group as either being extreme model behaviour or extremely challenging behaviour, or there is a sudden or significant change in the student’s behaviour;
   • The student asks to drop subjects with a particular teacher and seems reluctant to discuss the reasons;
   • The student's development is delayed, the student loses or gains weight or there is deterioration in the student general well-being;
   • The student appears neglected, e.g. dirty, hungry, inadequately clothed;
   • The student is reluctant to go home, or has been openly rejected by his/her parents or carers; and
   • Inappropriate behaviour displayed by other members of staff or any other person working with children, for example inappropriate sexual comments; excessive one-to-one attention beyond the requirements of their usual role or responsibilities; or inappropriate sharing of images.

Appendix 2: Child on child abuse

1. Background

   The College recognises that children of any age can abuse other children and that this can happen inside and/or outside of the College (including online) and works to minimise the risk of child-on-child abuse and will deal with any allegations robustly. KCO will adopt a zero-tolerance approach to child on child abuse.

   Child on child abuse can take many forms and may include but are not limited to:

   • Bullying (including cyberbullying, prejudice-based and discriminatory bullying);
   • Abuse in intimate personal relationships between peers;
   • Physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse);
   • Sexual violence, such as rape, assault by penetration and sexual assault (this may include an online element which facilitates, threatens and/or encourages sexual violence);
   • Sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of abuse;
   • Causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party;
   • Consensual and non-consensual sharing of nudes and semi nudes images and or videos (also known as sexting or youth produced sexual imagery);
   • Upskirting, which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification, or cause the victim humiliation, distress or alarm; and
   • Initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an online element).

2. Procedural guidelines for responding to allegations of child on child abuse

   When an instance of child-on-child abuse comes to light, is disclosed or where there is evidence to indicate it has occurred, staff should contact the DSL or Deputy. The DSL (or deputy) will make a referral to children’s social care, MASH and police as appropriate in respect of both children concerned. The interests of the identified victim must always be the paramount consideration.

   Where the allegation relates to an incident that took place within the College, it will take all appropriate action to ensure the safety and welfare and continued education of all students including the alleged perpetrator.

   The following are examples of action the College may take:

   • Take advice from children's social care and/or the police, as appropriate, on when and how to inform the student and his/her parents about the allegations and how investigation of such allegations will be conducted;
   • Keep the involved students separate during the College day while the investigation is taking place to avoid collusion or intimidation. A student against whom an allegation of abuse has been made may be suspended from the College as a neutral measure during the investigation;
   • Having established what is alleged to have taken place, avoid talking to the children any further about the incident(s);
   • Keep a detailed log of actions, discussions and decisions;
   • Assess the risk and implement a student safety plan as necessary – ensure that non-teaching times are considered, especially times when pupils are moving around the College as the student who has been harmed may feel very vulnerable at such times; and
   • Be aware that whether the incident(s) happened in college or elsewhere, other students may know what has happened (or is alleged to have happened). Other students may have been involved, either directly or indirectly. Other students may be judgemental or make unkind, or even threatening comments.

   It may be helpful to consider the following factors:

   • The relative chronological and developmental age of the students;
   • Whether the alleged abuser is supported or joined by other students;
   • Any differential in power or authority (e.g. related to race, gender, physical, emotional or intellectual vulnerability of victim);
   • The actual behaviour (consider all factors);
   • Whether the behaviour could be described as age appropriate or involves inappropriate sexual knowledge or motivation;
   • The degree of coercion, physical aggression, intimidation or bribery;
   • The victim’s experience of the behaviour and the impact it is having on them;
   • Attempts to ensure secrecy; and
   • Duration and frequency of behaviour.

   The College will take advice from children's social care and/or the police, as appropriate, on how the investigation of such allegations will be conducted. Appropriate support will be provided to all pupils involved by the College's pastoral team, and pupils may be referred to the College’ counselling services. Support from external services will be requested as necessary.

Appendix 3: Cause for Concern Form

The Cause for Concern Form can be downloaded as PDF.