Child Protection Policy
As a training provider which makes provision for young people, Progress to Excellence Ltd must ensure that:
- The welfare of young people is paramount.
- All young people, whatever their age, culture, disability, gender, language, racial origin religious beliefs and/or sexual identity have the right to protection from harm and abuse.
- All suspicions, allegations of abuse and poor practice will be taken seriously and responded to promptly and appropriately.
- All staff have a responsibility to report all concerns of abuse to the Designated Safeguarding Officer or Deputy Safeguarding Officer in their absence.
Progress to Excellence Ltd has a duty of care to safeguard all young people who work, learn and complete work experience placements both on and away from their premises.
We will respond to concerns raised by learners and staff members in incidents where they disclose information about children and young people within their family or care.
All children and young people have a right to be protected and the needs of those who may be particularly vulnerable must be taken into account.
We will ensure the safety, protection of all children and young people involved with Progress to Excellence Ltd in adherence to the child protection guidelines as detailed through Wirral Local Safeguarding Children Board.
The aim of the Child Protection Policy is to ensure children and young people are protected from abuse and exploitation by:
- Providing young people with the appropriate level of safety and protection while undertaking training, employment or work experience.
- Ensuring staff are suitable trained to identify signs and symptoms of abuse.
- Ensuring staff are fully aware of our safeguarding policies and procedures.
- Allowing all staff to make informed and confident responses to specific child protection issues.
- Ensuring Designated Safeguarding Officers are able to respond appropriately to allegations made against an adult who works with children or young people.
- Having a safer recruitment and screening process for all staff working with children and young people in adherence with relevant legislation.
As defined by The Children Act 1989, “child, children and young people” mean any individual under the age of 18. This policy applies to learners in this age group 16-18 who are registered on apprenticeship programmes, traineeship programmes and those who attend our premises to complete work experience placements.
For the purpose of this policy children undertaking learning will be referred to as young people.
The government has defined the term “safeguarding children” as:
The process of protecting children from abuse or neglect, preventing impairment of their health and development, and ensuring they are growing up in circumstances consistent with the provision of safe and effective care that enables children to have optimum life chances and enter adulthood successfully.
There are two aspects to safeguarding and promoting the welfare of young people imposed by key guidance Safeguarding Children in Education produced by Department of Education and Skills in 2004.
They are that:
- Arrangements are in place to take all reasonable measures to ensure that risks of harm to children’s welfare is minimised.
- Appropriate actions are taken to address concerns about the welfare of the child, or children, working to agreed local policies and procedures in full partnership with other local agencies.
Everyone shares responsibility for safeguarding and promoting the welfare of young people regardless of individual roles within the organisation. Therefore, we believe that all staff are responsible for implementing this policy and the reporting procedure if they receive or become aware of any of the following situations in relation to:
- Any allegation or concerns they have about an actual or suspected situation of abuse involving a young person.
- Any allegation or concern about actual or suspected staff misconduct and/or criminal activity involving the abuse of a child or young person.
- Any allegation or concerns that are raised regarding a child/ young person who are known to an employee.
However, the management team will:
- Ensure that the principles and standards referred to in this document are followed in all aspects of their employment.
- Be responsible for ensuring the procedures for complaints and whistle-blowing are clearly understood and easily accessible by learners, employers and staff members.
The Designated Safeguarding Officer (Deputy Safeguarding Officer in their absence) is responsible for:
- Ensuring policies and procedures are reviewed and adhere to our legal requirements as detailed in Working Together.
- Responding, recording and investigating any child protection issues.
- Reporting child protection issues to the Local Authority Designated Officer within 24 hours of the disclosure being made.
- Making contact with the relevant enforcement agencies, such as the police, in the event that immediate action should be required for any child protection issues.
- Keeping individuals informed about outcomes in the investigation process.
- Storing information in line with our legal requirements.
Local Authority Designated Officer (LADO)
Section 11 of the Children Act 2004 places a duty on key persons and bodies to make arrangements to ensure that, in discharging their functions, they have regard to the need to safeguard and promote the welfare of children.
Chapter 2 of Working Together 2013 provides that county level and unitary local authorities should have a Local Authority Designated Officer (LADO) to be involved in the management and oversight of individual cases. The LADO should provide advice and guidance to Progress to Excellence Ltd, liaising with the police and other agencies and monitoring the progress of cases to ensure that they are dealt with as quickly as possible, consistent with a thorough and fair process.
The LADO should be informed within one working day of all allegations that come to the attention of Progress to Excellence Ltd or that are made directly to the police.
In Wirral, the LADO is located within the Local Safeguarding Children Board and should be alerted to all cases in which it is alleged that a person who works with children has:
- Behaved in a way that has harmed, or may have harmed, a child.
- Possibly committed a criminal offence against children, or related to a child.
- Behaved towards a child or children in a way that indicates s/he may pose a risk of harm to children.
The LADO role applies to any person who works with children in a paid or unpaid capacity. This can be employees, volunteers, casual or agency staff, or anyone self-employed. The LADO is responsible for considering concerns, allegations or offences emanating from within or outside of work.
Wirral Safeguarding Children Board contact details
Local Authority Designated Officer (Allegations),
Hamilton Building, Conway Street, Birkenhead Wirral CH41 4FD.
A number of key principles underpin the requirements of our Child Protection Policy. These include:
That the best interests of any child or young person is paramount and will be the primary concern in our decision making.
Equality of opportunity: Ensure that young people have the opportunity to enjoy learning and employment safely regardless of their gender, ability, race, ethnicity, circumstances or age.
Responsibility: In order to meet our moral and legal obligations regarding our duty of care towards children and young people, we will take action where we believe that this group of individuals is at risk or is actually harmed.
Recognition: Acknowledging that an element of risk exists, and while we may never be able to totally remove this, we need to do all we can to reduce it or limit its impact.
Honesty and transparency: Keep all staff, employers and learners informed about our
Child Protection Policy and procedures to ensure they know we have the appropriate controls in place to try and protect children and young people from harm, abuse and exploitation.
Confidentiality and protection of all personal data: Information must only be shared and handled on a need-to-know basis by the appropriate person(s). Only individuals who have legitimate reasons to access this data will be able to do so.
Support and training: Provide all staff with the appropriate level of training to recognise and respond to child protection risks and incidents.
Partnership working: This includes involving the police, Wirral Local Safeguarding Board and other agencies where necessary.
Monitoring and review: The Child Protection Policy will be reviewed in accordance with legal requirements by the Designated Safeguarding Officer. All parties will be informed about any amendments made to the policy.
Understanding Child Protection Issues
When considering child protection, it is important that everyone involved has a shared understanding of what it really means. It is unlikely that we will be successful in our efforts if we do not fully understand what we are protecting children and young people from.
When we discuss “child protection”, we are referring specifically to the protection of children and young people from abuse. Abuse and neglect are forms of maltreatment of a child.
There are four types of child abuse. They are defined in the UK Government guidance Working Together to Safeguard Children 2010 (1.33 – 1.36) as follows:
- Physical abuse
- Emotional abuse
- Sexual abuse
Bullying is not defined as a form of abuse in Working Together but there is clear evidence that it is abusive and will include at least one, if not two, three or all four, of the defined categories of abuse.
Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to children 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 the child’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction.
It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children.
Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (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 (including via the internet).
Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.
Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development.
Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:
- Provide adequate food, clothing and shelter (including exclusion from home or abandonment).
- Protect a child from physical and emotional harm or danger.
- Ensure adequate supervision (including the use of inadequate care-givers).
- Ensure access to appropriate medical care or treatment.
It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
Bullying may be defined as deliberately hurtful behaviour, usually repeated over a period of time, where it is difficult for those bullied to defend themselves. It can take many forms but the three main types are physical (eg hitting, kicking, theft), verbal (eg racist or homophobic remarks, threats, name calling) and emotional (eg isolating an individual from the activities and social acceptance of their peer group).
The damage inflicted by bullying can frequently be underestimated. It can cause considerable distress to children to the extent that it affects their health and development or, at the extreme, cause them significant harm, including self-harm. All settings in which children are provided with services, or are living away from home, should have in place rigorously enforced anti-bullying strategies.
“Safe” recruitment checks that are undertaken as part of the recruitment process are our first opportunity to discourage potential offenders. We take all reasonable measures to prevent unsuitable individuals from working with children and young people.
As part of our Fair and Safe Recruitment process, we will take the following measures to ensure that only those who do not pose a risk to vulnerable groups are employed or involved in its work:
- All job advertisements must state that Progress to Excellence Ltd works to protect vulnerable groups and that those seeking work will be assessed regarding their suitability to work with this group of individuals.
- Before employing any staff working directly with vulnerable groups, background screening checks must be conducted to ensure their suitability. This includes independent references and police checks (where available).
- Where staff are to work directly with children, additional care must be taken to ensure that they are suitable. This should include checking identification, qualifications and obtaining references from previous employers.
- Staff will be asked to sign a self-declaration statement confirming that they have no convictions for any offence involving any type of harm to a child or children, and should declare anything that may affect their suitability to work with vulnerable groups.
- In exceptional circumstances, it may not be possible to obtain background checks and references. In these situations, a careful assessment should be made as to whether it is appropriate for the person to be put in the position of working alone with child/ young person.
- Where allegations are made about staff, careful consideration must take place about the appropriateness of the person continuing to work with Progress to Excellence Ltd. This may include suspension during any internal or external investigation and dismissal if the allegation is proved. The Managing Director should be consulted and involved in all processes concerning staff to ensure that employees’ rights are not violated. Peninsula Business Services have also been appointed to support Progress to Excellence Ltd with all HR-related issues.
Training, supervision and support
Once an individual has been recruited, they need to be adequately trained and supervised to ensure that any risks to young people are minimised. This aim will be achieved by:
- All staff undertaking basic child protection training.
- All staff are informed about the Child Protection Policy and given the opportunity to discuss its implications for them with both their line manager and/or designated safeguarding personnel as part of their induction.
- Not allowing staff to work alone with a young person somewhere which is isolated or where they cannot be observed. It is acceptable for staff to work alone with a young person where there are visibility panels/windows in doors.
- Supervising all learner activities. All learning activities will be completed by a qualified and eligible member of staff. They should always be trained with the necessary skills and qualifications for the work / role undertaken. All checks must be cleared before any work with young people is approved.
- Where Progress to Excellence Ltd arranges a placement for a young person, they should never be left unsupervised throughout the duration.
- No training or placement is undertaken with young people without written permission of their parents/carers.
- All staff should sign a code of conduct specific to the protection of children before working with any young person.
- Staff should be informed about all policies in relation to the use of technology (such as computers and mobile phones) and understand that they must not use this technology for the purpose of accessing, producing or distributing any information or violent or sexual images that are harmful to children. This includes adult pornography.
- When working with sub-contractors, ask for information on how the organisation works to protect young people (such as their child protection policy)
Professional code of conduct
All staff who come into contact with young people will be required to sign a code of conduct regarding the protection of children, the behaviour expected of them and their responsibilities. This includes:
- Agreement to work under the Child Protection Policy.
- Provisions regarding acceptable behaviour in the workplace – for example, not to use physical contact however acceptable or moderate it may seem, and not to use language intended to demean or humiliate young people.
- To report any concerns they may have about the protection of children and young people, in accordance with this policy.
- To observe confidentiality and not talk about any situations of actual or suspected abuse that occurs, except with those who have a legitimate aim to receive it.
- Not to pay for sexual services of any kind.
- Having no professional relationships with learners and providing them with access to your personal details.
- Not having learners as friends through social networking sites, or engaging with them outside of working hours for purposes other than teaching learning and assessment.
A person’s dress and appearance are matters of personal choice and self-expression. However, when working with young people, adults should dress in a way which is appropriate to their role and this may need to be different to how they dress outside of work.
Adults who work with young people should ensure they are dressed appropriately for the tasks and the work they undertake.
Workplace attire should therefore:
- Be appropriate for the role.
- Not to be viewed as offensive, revealing, or sexually provocative.
- Not distract, cause embarrassment or give rise to misunderstanding.
- Display any slogan or images that could be considered to be discriminatory or culturally sensitive.
There may be times where a young person develops an infatuation with an individual who works with them. All employees should deal with these situations sensitively and appropriately to uphold the dignity and safety of all involved.
However, employees must be aware that such infatuations carry a high risk of words or actions being misinterpreted and should therefore make every effort to ensure that their own behaviour is above any criticism or questioning.
Any employee, who becomes aware that a young person is developing an infatuation, should discuss this at the earliest opportunity with a member of the management team or Designated Safeguarding Officer in line with our reporting procedure so appropriate action can be taken to avoid any hurt, distress or embarrassment.
Gifts and favouritism
An employee should never accept gifts from a young person. All gestures of this nature should be sent via written or electronic form to the company’s Health and Wellbeing Officer as a compliment.
An employee should never show favouritism to a young person or give them a gift when they have met or exceed their goals. All details of recognition should be detailed on the appropriate documentation within the company.
Transporting young people
It is inappropriate for an employee to offer lifts to a young person outside their normal working duties, unless this has been brought to the attention of the line manager and has been agreed with the parents/carers.
There may be occasions where the young person requires transport in an emergency situation or where in situations were not to providing a lift may place the young person at risk. Such circumstances must always be recorded and reported to the Designated Safeguarding Officer and/or management team and parents/carers.
All occasions that involve an employee accompanying a young person in their vehicle must be fully recorded on a Young Passenger Safety Document. This will include time and dates of visit, name of individuals involved, reason for visit and a signed declaration.
Young people in distress
There may be occasions where a young person becomes distressed, for example in a pastoral support session and an employee feels they require comfort and reassurance. Employees should use their professional judgement in this situation, considering the circumstances surrounding the distress and the age and gender of the individual. An employee must always ensure they maintain clear professional boundaries in situations of this nature.
Where an employee has a particular concern about the need to provide this type of care and reassurance, or is concerned that an action may be misinterpreted, this should be reported and discussed with the Designated Safeguarding Officer, a member of the management team and parents/carers.
Employees should ensure:
- They consider the way in which they offer comfort and reassurance to a distressed young person and do it in an age-appropriate way.
- They are vigilant in offering reassurance in one-to-one situations and always record such actions.
- They follow our Child Protection Code of Conduct.
- They never touch a young person in a way which may be considered indecent.
- They record and report situations which may give rise to concern from either party.
- They never assume that all young people seek physical comfort if they are distressed.
One-to-one assessment visits
In order to safeguard our staff against allegations, and to safeguard our learners, all assessment activities involving young people will be conducted at our premises and/or the young person’s place of work. In the event that both premises are inaccessible, a meeting must be re-arranged or be held in a public place.
Progresses to Excellence Ltd has appointed numerous staff to be qualified in emergency First Aid. These individuals will be responsible for the administration of any First Aid. When administering First Aid, wherever possible employees should ensure that another employee is aware of the action being taken. Parents should always be informed when First Aid has been administered to any learner aged under 18. All accidents, however minor, will also be reported to the company’s Health and Wellbeing Officer, in line with our accident reporting procedure.
Progresses to Excellence Ltd staff are not qualified in administration of medication. In the event a young person requires medication for a personal health problem, they will be asked to self-administer medication or treatment, including ointment or use of inhalers.
Media, communication and information
This policy should be used in conjunction with our E-Safety Policy to ensure that any personal information relating to learners is:
- Kept confidential unless we have the agreement of the young person and their parent/carer. However, information that relates to a child protection incident may, where it is necessary, be passed to the Local Authority Designated Officer or law enforcement agency.
It is against our policy to:
- Use images of young people which are respectful (not degrading, or sexual images).
- Reproduce images of young people only where we have the written permission of their parents/carers.
Reporting – responding to allegations and concerns
We endeavour to ensure that this policy is properly implemented so the likelihood of an actual situation of abuse occurring from within the organisation will be reduced. Unfortunately, incidents may still arise or information be brought to our attention about the behaviour of another staff member which creates cause for concern. We may also become aware of situations of actual, or suspected, abuse from outside the organisation.
It is not the responsibility of staff to decide whether or not child abuse has taken place. All staff, however, do have a responsibility to act on any concerns by reporting them to the Designated Safeguarding Officer or Deputy Officer in their absence.
To ensure that all such situations are handled appropriately and effectively, a reporting procedure to support this policy has been implemented:
All allegations and concerns of abuse must be taken seriously, irrespective of the identity of the alleged perpetrator and victims, and severity of abuse.
All staff must report any of the following situations to the Designated Safeguarding Officer/Deputy Officer in their absence in relation to:
- Any allegation of or concern about actual or suspected situations of abuse involving young person known to Progress to Excellence Ltd.
- Any allegation of or concern about actual or suspected staff misconduct and/or criminal activity involving the abuse of a child/ children or young people whether or not they are known to Progress to Excellence Ltd in accordance with the reporting procedure.
- No staff member must agree to keep information regarding actual or suspected abuse “confidential”. However, we will seek to discuss our concern with the young person in a way that is appropriate to their age and understanding and seek their agreement, and that of their parent or carer, if making a referral to the relevant agency. However, in situations where this may place the young person in immediate danger, the Designated Safeguarding Officer may make a decision to refer to the relevant agency without informing the young person and without obtaining the consent of their parents/carer.
- All investigations must be responded to in line with the reporting procedure.
- Progress to Excellence Ltd is not an investigative authority. It is therefore essential that all referrals be made in accordance with the reporting procedure, as set by Wirral Local Safeguarding Children Board.
- Wirral Local Safeguarding Children Board and other enforcement agencies will ensure that appropriate protection and support is given to the child/young person and that any evidence is collected in accordance with the law.
- A written record of all child protection reports, including any decisions made, must be kept up to date by Designated Safeguarding Officer and Deputy Safeguarding Officer in their absence. This will be recorded on the Child Protection Referral Form and logged on the child protection within the recommended time scales as stated in the reporting procedure. This should include details of any referrals made to Wirral Local Safeguarding Board Children Board.
- All sensitive and personal data must be kept confidential (including the names of anyone who makes a report of abuse).
- Referrals must be made to the Local Authority Designated Officer when sufficient evidence exists that an allegation or concern is a serious welfare and/or criminal matter, in accordance with the reporting procedure. Apart from referrals to child welfare and law enforcement agencies, no details regarding the circumstances of children and their families will be passed to other individuals or organisations without the express permission of the young person and their parents/carers.
- Names of those who are alleged to be a risk to children will also be passed on to law enforcement agencies, where it is suspected that a crime may have been committed, for investigation in accordance with relevant legislation. This will normally be the local police.
- Where allegations are made about a staff member, the Managing Director should be consulted and involved in all processes concerning staff to ensure that employee’s rights are not violated. An allegation made about a member of staff will be taken seriously and will also be dealt with in line with our reporting procedure.