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:
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:
Peter Thompson
Designated Safeguarding Lead (DSL)
Julia Yang
Deputy Designated Safeguarding Lead (DDSL)
Robin Fry
Safeguarding Governor
Dr Suzanne Yang
Proprietor
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) |
01865 810603 |
| MASH (Multi-Agency Safeguarding Hub) |
0345 050 7666 0800 833 408 (out of hours emergency) |
| Thames Valley Police Prevent Officer (for issues relating to radicalisation and extremism) | |
| DfE helpline for non – emergency advice relating to extremism |
020 7340 7264 |
| NSPCC Report Abuse in Education Advice Helpline |
0800 136 663 |
| NSPCC FGM free phone helpline | 0800 028 3550 |
| NSPCC Whistleblowing helpline |
0800 028 0285 (8am-8pm Mon-Fri) |
| Disclosure & Barring Service (DBS) |
03000 200 190 |
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.
The governing body will:
All staff have a duty to:
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.
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:
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.
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.
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:
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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:
Records should be factual and signed and dated, with the name of the signatory clearly printed in writing. Records should include:
When reporting a concern staff must:
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).
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.
On receipt of a concern, the DSL will consider the appropriate course of action. Such action may include:
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.
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.
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.
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:
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.
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:
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.
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.
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.
(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:
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.
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 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:
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.
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.
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
02070080151
Any concerns should be passed immediately to the DSL or Deputy.
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.
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:
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.
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.
Possible signs of abuse include, but are not limited to:
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:
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:
It may be helpful to consider the following factors:
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.
The Cause for Concern Form can be downloaded as PDF.
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