1. Policy Statement:

This policy reflects the importance of our responsibility to safeguard and promote the welfare of all our apprentices and staff, by protecting them from bullying, neglect, physical, sexual or emotional abuse.

FSTP is committed to the safety and wellbeing of all apprentices, it ensures that all staff work within this policy to help minimise any potential risk or harm. FSTP expects that all staff are committed to promoting the welfare of apprentices.

This policy complies with the Department of Education’s Keeping Children Safe in Education (KCSIE September 2021) and associated guidance Working Together to Safeguard Children (2018). FSTP also complies with the statutory guidance in relation to Sexual Violence and Sexual Harassment Between Children in Schools and Colleges (KCSIE September 2021), The Prevent Duty Act (April 2019), The Counter-Terrorism Security Act (June 2015) and Social Media for Online Radicalisation (July 2015).

FSTP have a statutory requirement, under sections 27 (children in need) and 47 (reasonable cause to suspect a child is suffering or is likely to suffer significant harm) of the Children’s Act 1989, to assist the Local Authority Social Services Department.

“Safeguarding is everyone’s responsibility whether we work directly or indirectly within the vulnerable groups.”

2. Purpose:

The main aims of this policy are to ensure that all staff are fully engaged in being vigilant about raising awareness and that they overcome any barriers to believing that such issues will not happen at FSTP.

We will also ensure that we work alongside all other agencies and professional bodies, where required, to ensure all staff and apprentices feel safe from harm.

3. Scope:

This policy covers:

4. PREVENT:

The PREVENT duty requires the education sector to have “due regard to the need to prevent people from being drawn into terrorism, supporting terrorism or being drawn into non-violent extremism” (The Counterterrorism and Security Act Sect 26).

Guidance is issued under Section 29 of the CTS Act:

The purpose of PREVENT is:

All FSTP staff and contractors have a legal responsibility under the PREVENT duty to make sure that:

5. Safeguarding:

FSTP are committed to safeguarding and promoting the welfare of all learners including young people and vulnerable adults (adults at risk).

A vulnerable adult or adult at risk is defined as a person who:

The aims of this policy are:

Safeguarding regulations have been around for a while, across a wide range of legislation, but were brought together by the Safeguarding Vulnerable Groups Act 2006. This legislation provides definitions of children and vulnerable adults and sets out the legislative framework of measures to protect them from harm, including:

The term ‘safeguarding’ embraces both child and vulnerable adult protection and preventative approaches to keep our apprentices, staff and employers safe. Safeguarding encompasses apprentices’ health and safety, welfare, and well-being.

6. PREVENT and Safeguarding Principles:

All apprentices will be provided with information, electronically, about our Safeguarding Policy once they have had their induction onto a programme. This policy will also be readily available on our website.

7. Employer Responsibilities:

As the employer of a learner, it is important that you understand your responsibilities to them and what safeguarding means to you. The following information should provide answers to some of the questions you may have. If your questions are not answered here, please get in touch with us using the contact details provided.

As the employer of an apprentice:

8. PREVENT and Safeguarding Provision:

FSTP provides the following safeguarding support, provision and monitoring to ensure that all apprentices are kept safe:

9. PREVENT and Safeguarding Disclosures:

If a learner makes a safeguarding disclosure:

10. Reporting a PREVENT or Safeguarding Concern:

If the learner has a concern over their own personal welfare and wellbeing, you must listen to and record all information given, making no judgement or assumptions.

You should take any actions required to secure the immediate safety of the child or adult at risk, if deemed appropriate, this may involve staying with them until a responsible adult can be located.

You must report the issue to the designated officer, regardless of whether the learner agrees. The designated officer will then decide the appropriate course of action, and if a referral outside the organisation is appropriate.

11. Responding to a PREVENT or Safeguarding Report:

A member of the Safeguarding Team will review every reported prevent or safeguarding risk within 2 working hours of receipt and will record this within the Report Register.

If appropriate, the team member will contact the person making the report and/or the apprentice, in order to clarify the situation and to provide welfare support.

If required, the team member will escalate the risk to the Designated Safeguarding and PREVENT Lead and discuss any further action to be taken.

If required, the Designated Safeguarding and PREVENT Lead will escalate the risk further (in line with government guidance).

All safeguarding team members will ensure that the Report Register is updated to include reports, disclosures, assessments, actions, escalations and further/future reports.

The Safeguarding Team will meet monthly to discuss new reports/risks, identify potential patterns, review processes and identify additional staff training required.

12. Confidentiality:

It is essential that confidentiality is maintained at all stages of the process when dealing with safeguarding concerns. Information relating to the concern, and subsequent case management, should be shared on a need-to-know basis only and should always be kept secure. However, whilst respecting privacy and GDPR, the right to confidentiality is not absolute and sharing information with the right people at the right time is essential to good safeguarding practice. For example, if we believe that parents, social services or the police should be informed.

If any staff member has a safeguarding issue brought to their attention, they must treat it as a matter of urgency and contact one of our Designated Safeguarding Team.

Any concern must be documented and emailed to the Designated Safeguarding Lead within 2 hours of the disclosure. Unless the child is in immediate harm, where the relevant authorities must be contacted immediately. In this situation ensure that the child is accompanied and kept safe until the relevant authorities arrive.

If you have any concerns about an apprentice, then please do not hesitate to contact one of FSTP’s designated safeguarding team.

Safeguarding our apprentices, staff and employers is an important issue to us. FSTP will provide guidance, but all staff should be particularly alert to the potential need for early help for a child who:

13. Radicalisation:

Radicalisation is defined as the act or process of making a person more radical or favouring of extreme or fundamental changes in political, economic, or social conditions, institutions, or habits of the mind.

We recognise that safeguarding against radicalisation is no different from safeguarding against any other vulnerability and should therefore be treated as equally as important.

People can be drawn into violence or they can be exposed to the messages of extremist groups by many means. The risk of radicalisation is the product of several factors and identifying this risk requires that staff exercise their professional judgement, seeking further advice as necessary. It may be combined with other vulnerabilities or may be the only risk identified.

Potential indicators include:

14. Extremism:

Extremism is defined as holding extreme political or religious views.

The Government has defined extremism as “vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs”. This also includes calls for the death of members of the British armed forces.

It also includes not discriminating against those with protected characteristics (Equality Act 2010), namely:

15. Fundamental British Values:

The expectations at FSTP are that all staff will uphold the fundamental principles of British values, including:

16. CONTEST:

CONTEST is the Government’s Counter Terrorism Strategy (published in July 2006 and refreshed in June 2018). The aim of the strategy is ‘to reduce the risk from international terrorism, so that people can go about their lives freely and with confidence.’

CONTEST has four strands, often known as the four Ps. The aims of the 4 Ps are:

17. Terrorism:

An action that endangers or causes serious violence to a person/people, causes serious damage to property or seriously interferes or disrupts an electronic system. The use of threat must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious or ideological cause.

18. Channel:

Channel is an early intervention, multi-agency process designed to safeguard vulnerable people from being drawn into violent extremist or terrorist behaviour. Channel works in a similar way to existing safeguarding partnerships aimed at protecting vulnerable people.

Channel is designed to work with individuals of any age who are at risk of being exploited by extremist or terrorist ideologues. The process is shaped around the circumstances of each person and can provide support for any form of radicalisation or personal vulnerabilities.

Each Channel Panel is chaired by a local authority and brings together a range of multi-agency partners to collectively assess the risk, and it can decide whether a support package is needed. The group may include statutory and non-statutory partners, as well as lead safeguarding professionals. If the group feels the person would be suitable for Channel, it will look to develop a package of support that is bespoke to the person. The partnership approach ensures those with specific knowledge and expertise, around the vulnerabilities of those at risk, can work together to provide the best support.

Channel interventions are delivered through local partners and specialist agencies. The support may focus on a person’s vulnerabilities around health, education, employment or housing, as well as specialist mentoring or faith guidance and broader diversionary activities such as sport. Each support package is tailored to the person and their circumstances.

A person will always be informed first if it is felt that they would benefit from Channel support. The process is voluntary and their consent would be needed before taking part. This process is managed carefully by the Channel Panel.

Anyone can make a referral. Referrals come from a wide range of partners including education, health, youth offending teams, police and social services.

Referrals are first screened for suitability through a preliminary assessment by the Channel Coordinator and the local authority. If suitable, the case is then discussed at a Channel Panel of relevant partners to decide if support is necessary. If raising a concern because you believe that someone is vulnerable to being exploited or radicalised, please use the established safeguarding or duty of care procedures within your organisation to escalate your concerns to the appropriate leads, who can raise concerns to Channel if appropriate.

19. Sexual Violence and Harassment:

FSTP recognises that sexual violence and harassment can happen, even though it is not always reported. Therefore, all staff are expected to be vigilant and to follow the safeguarding policy if they have a concern or suspicion in regard to this.

We take a zero-tolerance approach to all violence and harassment.

20. Female Genital Mutilation (FGM):

Female Genital Mutilation (FGM) is illegal in England and Wales under the FGM Act 2003. It is a form of child abuse and violence against women. FGM comprises all procedures involving partial or total removal of the external female genitalia for non-medical reasons.

The FGM mandatory reporting duty is a legal duty provided for in the FGM Act 2003 (as amended by the Serious Crime Act 2015).

The legislation requires regulated health and social care professionals and teachers in England and Wales to make a report to the police where, in the course of their professional duties, they:

For the purposes of the duty, the relevant age is the girl’s age at the time of the disclosure or identification of FGM (i.e. it does not apply where a woman aged 18 or over discloses that she had FGM when she was under 18).

Complying with the duty does not breach any confidentiality requirement or other restriction on disclosure which might otherwise apply. The duty is a personal duty which requires the individual professional, who becomes aware of the case, to make a report; the responsibility cannot be transferred. The only exception to this is if you know that another individual from your profession has already made a report; there is no requirement to make a second.

Reports under the duty should be made as soon as possible after a case is discovered, and best practice is for reports to be made by the close of the next working day, unless any of the factors described below are present. You should act with at least the same urgency as is required by your local safeguarding processes.

A longer timeframe than the next working day may be appropriate in exceptional cases where, for example, a professional has concerns that a report to the police is likely to result in an immediate safeguarding risk to the child (or another child e.g. a sibling) and considers that consultation with staff or other agencies is necessary prior to the report being made.

If you think you are dealing with such a case you are strongly advised to consult staff (including your designated safeguarding lead) as soon as practicable, and to keep a record of any decisions made. It is important to remember that the safety of the girl is the priority.

It is recommended that you make a report orally by calling 101, the single non-emergency number. You should be prepared to provide the call handler with the following information:

Throughout the process you should ensure that you keep a comprehensive record of any discussions held and subsequent decisions made, in line with standard safeguarding practice. This will include the circumstances surrounding the initial identification or disclosure of FGM, details of any safeguarding actions which were taken, and when and how you reported the case to the police (including the case reference number). You should also ensure that your organisation’s designated safeguarding lead is kept updated as appropriate.

In line with safeguarding best practice, you should contact the girl and/or her parents or guardians, as appropriate, to explain the report, why it is being made, and what it means.

Wherever possible, you should have this discussion in advance or in parallel to the report being made. However, if you believe that telling the child/parents about the report may result in a risk of serious harm to the child or anyone else, or of the family fleeing the country, you should not discuss it. FGM is child abuse, and employers and the professional regulators are expected to pay due regard to the seriousness of breaches of the duty.

21. Cyberbullying:

Cyberbullying involves the use of electronic communication devices to bully people. These include mobile phones, tablets, iPods, laptops, and/or PCs. Social media platforms such as Facebook, Instagram, Twitter, and WhatsApp are used by cyberbullies to put out their communications.

Those people most at risk are:

Definitions of cyberbullying are:

22. Grooming:

Grooming is a word to describe people befriending children and vulnerable adults to take advantage of them for sexual preferences. It is also used by extremist groups to radicalise individuals in to supporting and potentially committing terrorist attacks. You will probably associate grooming with children, and predominantly this is what you will hear and see in the media on the subject, but it does also affect vulnerable adults.

Sexual online grooming is when people form relationships with children pretending to be their friend, using social media platforms to do so. The person carrying out the online grooming will try to establish the likelihood of the child telling someone. They will also find out as much as they can about the child’s family and social networks. Online groomers will tend to use chatrooms, which are focussed on young people. There are countless teen chat rooms on the internet. Those carrying out the grooming will pretend to be a child themselves, similar in age to the person they are grooming, and will even change their gender to make it easier to befriend the person they are grooming. Grooming online is anonymous and children find it easier to trust an online ‘friend’ than someone they have met ‘face to face’.

A child might be groomed online if:

A groomer may:

Unfortunately, children or vulnerable adults may not speak out about their situation if they:

23. Safer Recruitment Process:

FSTP follows a safe recruitment process and ensures that all appropriate checks are carried out on new staff that will work with or meet children and adults at risk, in line with the Disclosure and Barring Service (DBS) requirements. See safer recruitment policy for further details.

The Disclosure and Barring Service (DBS) is an executive agency of the Home Office, and its primary purpose is to help employers make safer recruitment decisions and appointments. By conducting checks and providing details of criminal records and other relevant information, DBS helps to identify applicants who may be unsuitable for certain work and positions, especially those involving contact with children (those less than 18 years old) or adults at risk.

Depending on the type and regularity of contact with children or adults at risk involved in a particular role, employers are entitled to make appropriate types of enquiries about the applicant’s criminal record and seek a disclosure through a DBS check.

FSTP can undertake five types of criminal records checks depending on the role applied for:

Standard DBS check – this will be for positions that are included in the Rehabilitation of Offenders Act (ROA) 1974 (Exceptions) Order 1975. This type of check contains details of individual’s convictions, cautions, reprimands, or warnings recorded on police central records and includes both ‘spent’ and ‘unspent’ convictions that will be shown on a criminal records check.

Enhanced DBS check – this will be for positions included in both the ROA 1974 Exceptions Order and in the Police Act 1997 regulations. This type of check contains the same details as the standard check plus any information held locally by police forces that it is reasonably considered to be relevant to the post applied for.

Enhanced DBS and barred list check (child) – an enhanced check with information from the DBS’s children’s barred list is only available for those individuals engaged in regulated activity with children and a small number of posts as listed in the Police Act 1997 regulations.

Enhanced DBS and barred list check (adult) – an enhanced check with information from the DBS’s adults barred list is only available for those individuals engaged in regulated activity with adults and a small number of posts as listed in the Police Act 1997 regulations.

Enhanced DBS and barred list check (child and adult) – an enhanced check with information from the DBS’s children and adults barred list is only available for those individuals engaged in regulated activity with both vulnerable groups including children and a small number of posts as listed in the Police Act regulations.

24. Keeping Staff Safe:

To maintain staff and apprentice safety, the following are strictly prohibited:

It is also important to be mindful of the following when conducting yourself:

· You will naturally build a rapport with learners, and the learners may see you as a confidant and support but be sure to maintain professional boundaries whenever carrying out work on FSTP’s behalf.

25. Whistle Blowing:

It is acknowledged that there may be times when a member of staff witnesses an incident, action or event that may give them cause for concern. If any member of staff witnesses a potential safeguarding issue, they must treat it as a matter of urgency and contact one of our designated safeguarding team members. Any concern must be documented and emailed to the Designated Safeguarding Lead within 2 hours of the disclosure. Unless the child is in immediate harm, where the relevant authorities will be contacted immediately. In this situation ensure that the child is accompanied and kept safe until the relevant authorities arrive.

We are always committed to the safety and security of all learners whilst in our care, equally we are committed to the safety and security of all staff.

All staff are required to share any concerns regarding any staff practices that compromise the safety of the learners.

Failure to notify the designated safeguarding officer of any concerns regarding any incidents, events or practices by individual staff will result in referral to the safeguarding team, Ofsted, and the police for investigation.

Where external authorities are conducting their own enquiries, our own investigation will run in parallel without jeopardy to any official enquiries and the member of staff will be placed on suspension.

Any staff member who discloses a concern will be given assurance of confidentiality as far as practically possible, without jeopardy to any investigations by external authorities or our own investigation.

Any staff member expressing a concern about their safety following a disclosure will be given all necessary support to enable them to safely continue in their role.

26. Update GOV WEBSITE – 08.03.2019:

Court of Appeal judgment

The Court of Appeal ruled on 8 March 2019 that one paragraph contained within the Prevent duty guidance for higher education institutions in England and Wales (paragraph 11) was unlawful. The same, or a similar, paragraph is also contained in the Prevent duty guidance for further education institutions in England and Wales (paragraph 8), the Prevent duty guidance for higher education institutions in Scotland (paragraph 11), and the Prevent duty guidance for further education institutions in Scotland (paragraph 8).

This judgment only affects that one paragraph in each of those documents and the rest of those documents, and the other Prevent duty guidance documents, should continue to be read as before.

Higher and further education institutions affected by the Prevent duty should refer to the court’s judgment, in particular paragraphs 158 to 177. The government is considering the ruling and will announce its next steps in due course.

27. Designated Safeguarding Persons Contact Details:

Designated Safeguarding and PREVENT Lead – Philippa Grocott

Email: philippagrocott@fstp.co.uk

Telephone: 01908 395243

Deputy Designated Safeguarding and PREVENT Lead – Nicola Spennati

Email: nicolaspennati@fstp.co.uk

Telephone: 01908 395243

This policy has been approved by:

(Senior Manager/Director/CEO, with overall responsibility for apprenticeship delivery):

Name:Philippa Grocott
Job title:Head of Regulatory Sales and Apprenticeships
Date approved:19/10/2021
Signature:

Next planned policy review date: April 2022 (unless required sooner)