Safeguarding and Prevent Duty Policy

Safeguarding and Prevent Duty Policy

This policy has been reviewed following the publication of Keeping Children Safe in Education 2016 and the Ofsted guidance for inspectors of August 2016 and ensures staff are aware of the mandatory requirement to report known cases of FGM and the risks of peer on peer abuse. It has also been reviewed following the DfE consultation into changes to statutory guidance: working together to safeguard children and new regulations, to ensure we remain aware of any planned changes to the statutory guidance keeping children safe in education: For Schools and Colleges.

Safeguarding Policy

Policy Statement

The Source is strongly committed to practices that protect children, young people and vulnerable adults from abuse, neglect or significant harm. Staff recognise, and accept their responsibility to develop the awareness of the risks and issues involved in safeguarding. The company is committed to working with existing local safeguarding or adult safeguarding boards and other health and social care partnerships to ensure the safeguarding of its learners. Definition For the purpose of this policy and procedure, children are defined in the children Act of 1989 as a person under the age of 18 years. The Safeguarding Vulnerable Groups Act 2006 defines a ‘vulnerable adult’ as a person aged 18 and over, and:

  • Receiving a social care service
  • Receiving a health service
  • Living in sheltered accommodation
  • Detained in custody or under a probation order
  • Requiring assistance in the conduct of his/her affairs
  • Receiving a service or participating in an activity targeted at older people, people with disabilities or with physical or mental health conditions

Accountability and Responsibility

The Source has trained Safeguarding Officers; Andy Womble, Work Based Learning Manager and Helen Lee from Schools & Community, both ultimately responsible to the Chief Executive and Board of Directors. Incidents or concerns are reported at local level to managers and escalated to the safeguarding staff. The Safeguarding Team are responsible for monitoring and managing incidents or concerns and liaising with safeguarding agencies. The Source Board is responsible for responding to an annual report on safeguarding within the company. The working arrangements are that at least one of the two designated safeguarding officers is available at all times. Staff are able to raise concerns at any time.


The company has a duty to promote safeguarding issues and measures to staff and ensure they:

  • Analyse their own practice against established good practice, and assess risks to ensure their practice is likely to protect them from false allegations. Recognise their responsibilities and report any concerns about suspected poor practice or possible abuse (Code of Conduct)
  • Follow the guideline for staff (Quick Guide included in this booklet)
  • Undertake annual training on safeguarding to raise awareness of current issues and legislation:-

For Managers and staff involved in the direct delivery of training (Work Based Learning, Schools & Community and Training department) annual refresher training is completed.

For Managers and staff from all other departments a mandatory ‘Safeguarding’ briefing session delivered by the senior nominated safeguarding officer.

Members of the Board of Trustees also complete refresher training annually.

In line with revised guidance in 2016, designated members of staff responsible for safeguarding have safeguarding training every 2 years.

Disclosure & Barring Service (DBS)

The Company has a responsibility to ensure safe recruitment and employment practices. New and existing staff who frequently or intensively work with children, young people and vulnerable adults in training supervision, care, advice, treatment and transport have to be checked through the DBS. This information will then be kept securely and handled in line with the Company DBS policy. Relevant details will be kept on a Single Central Record that will be subject to annual checks and audits.

Statutory Framework

The Source aims to meet legislative requirements and good practice in safeguarding. The statutory framework under which we operate includes the Children Act 1989. This provides the legal framework for the protection of children and young people in the UK. The Protection of Children Act 1999 requires employers to carry out Criminal Record Checks before employees are allowed to come into contact with children. The Safeguarding Vulnerable Groups Act 2006 sets out the type of activity in relation to children and vulnerable adults for which employers and individuals will be subject. From 2008 Ofsted inspectors make a judgement on procedures for safeguarding learners meeting current government requirements. They comment on policy, procedures, vetting and training as impact on learners dictates.


The Source’s Safeguarding Policy is reviewed annually and its provisions monitored by the Senior Management team. The review process includes analysis of monitoring data, consultation with and feedback from learners, clients, staff and other stakeholders to determine the impact of the policy and any action required.

Very useful reference guides for staff can be found from the following

  • Learning and Work Institute
  • MindEd

Based on a report issued by the Department for Education (April 2014) Keeping Children Safe in Education the Staying Safe Handbook issued to all staff includes information on specific safeguarding measures and these are as follows:

  • Child sexual exploitation
  • Bullying including cyber bullying
  • Domestic violence
  • Drugs
  • Fabricated or induced illness
  • Faith abuse
  • Female genital mutilation (FGM) and recognition of the mandatory duty to report known cases (2016)
  • Forced marriage
  • Gangs and youth violence
  • Gender based violence
  • Mental health
  • Private fostering
  • Radicalisation
  • Sexting
  • Teenage relationship abuse
  • Trafficking

Relevant Documents

This policy should be read in conjunction with:

  • Staying Safe Handbook
  • The Company DBS policy
  • Keeping Children Safe in Education (2016) Section 1 Keeping Children Safe in Education issued to staff in December 2016
  • DfE Guidance on the scope of regulated activity (2016)

Prevent Duty – Policy Statement

The Prevent Duty

The duty to actively promote ‘Fundamental British Values has been live from 1st July 2015. This was first set out by the government in the ‘Prevent’ Strategy in 2011.

The Counter Terrorism and Security Act 2015 has introduced the Prevent Duty for various bodies including all FE colleges, adult education providers and independent learning providers with SFA funding or with over 250 students enrolled.

The Prevent Duty has “due regard to the need to prevent people from being drawn into terrorism” Anti-Terrorism and Security Act 2015: Schedule 3, Section 21.

What is our Responsibility?

  • To assess the risks of people being drawn into terrorism, including support for extremist ideas that are part of terrorist ideology.
  • All staff to actively promote British values.
  • To raise awareness of the Prevent duty and British values to all staff and learners.
  • To establish a reporting procedure for all concerns relating to people being drawn into terrorism.

What is Extremism?

Extremism is defined 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. We also include in our definition of extremism calls for the death of members of our armed forces, whether in this country or overseas (HM Government Prevent Strategy, 2011).

What is Radicalisation?

Radicalisation is defined as the process by which people come to support terrorism and extremism and, in some cases, to then participate in terrorist groups.

What are British Values?

British Values are defined as “democracy, the rule of law, individual liberty and mutual respect and tolerance for those with different faiths and beliefs”; institutions are expected to encourage students to respect other people with particular regard to the protected characteristics set out in the The Equality Act 2010.

Vulnerability / Risk Indicators

The following lists are not exhaustive and all or none may be present in individual cases of concern. Nor does it mean that vulnerable people / young people experiencing these factors are automatically at risk of exploitation for the purposes of extremism. The accepted view is that a complex relationship between the various aspects of an individual’s identity determines their vulnerability to extremism.

The following factors may increase an individual’s vulnerability:

  • Identity crisis – Being distanced from cultural and or religious heritage and uncomfortable with their place in the society around them.
  • Personal crisis – Family tensions; sense of isolation; adolescence; low selfesteem; disassociating from existing friendship group and becoming involved with a new and different group of friends; searching for answers to questions about identity, faith and belonging.
  • Personal circumstances – Migration; local community tensions; events affecting country or region of origin; alienation from UK values; having a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy.
  • Unmet aspirations – Perceptions of injustice; feelings of failure; rejection of civic life.
  • Criminality – Experiences of imprisonment; poor resettlement / reintegration, previous involvement with criminal groups.

Relevant Documents

This policy should be read in conjunction with:

  • Prevent Duty Guidance 5977/3799_Revised_Prevent_Duty_Guidance__England_Wales_V2- Interactive.pdf
  • The Source Academy British Values Toolkit
  • The Source Academy Prevent Risk Assessment

Staff Responsibilities

  • All staff at The Source have undertaken training in the Prevent Duty as identified by their leaders and managers
  • All staff at The Source are aware of when it is appropriate to refer concerns about students, learners or colleagues to the Designated Safeguarding Officer.
  • All staff at The Source exemplifies British values of “democracy, the rule of law, individual liberty and mutual respect and tolerance for those with different faiths and beliefs” into their practice.

Risk Assessment

The statutory guidance makes clear that FE colleges, adult education providers and independent learning providers are expected to assess the risk of people being drawn into terrorism, including support for extremist ideas that are part of terrorist ideology. As with managing other safeguarding risks, there is no single way of identifying an individual who is likely to be susceptible to a terrorist ideology, however it is important that all providers understand the risk so that they can respond in an appropriate and proportionate way.

Online Safety

The Source Academy has an active web marshalling and monitoring system through its parent company which includes filtering and monitoring of internet usage and in respect of the Prevent Duty, the system ensures users are protected from accessing or viewing material or websites that may encourage radicalisation or promote extremist views. Learner IT suites have strictly controlled access to external websites that prevent the viewing or downloading of:

  • Defamatory material
  • Offensive, vulgar or obscene material
  • Any racist or sexist material
  • Any material that could constitute bullying or harassment (such as on the grounds of sex, including sexual orientation, race of disability or any protected characteristic)
  • Any material that could be otherwise considered illegal, or perceived as falling into one of the above categories
  • Sites or material that may promote or encourage radicalisation and extremist views

Safeguarding Reporting Procedure

This procedure is to be followed when dealing with concerns, suspicions or disclosures of harm or abuse.

  1. Member of staff is concerned about learners/customers welfare, receives a disclosure or suspects a case of harm or abuse.
  2. Member of staff accesses the ‘Quick guide for staff’ policy located in the ‘Staying safe handbook’ which is kept in the electronic safeguarding file for the full procedure.
  3. Member of staff then contacts a Safeguarding Officer for information and guidance in confidence.
  4. Member of staff completes a Safeguarding Incident Form and returns to the Safeguarding Officer in a confidential manner.
  5. Safeguarding Officer is to discuss the concern with the necessary people, and provide advice and support to the staff member, and help to ensure that the student is supported.

It is important that children, young people and vulnerable adults are protected from abuse, neglect or significant harm. It is the responsibility of all employees of The Source to safeguard and promote the welfare of children, young people and vulnerable adults participating in training programmes and activities held by The Source. Employees should report any allegations or concerns regarding the welfare of these groups using the following guidelines. The Safeguarding poster which accompanies these guidelines conveys in words and pictures what constitutes abuse.

What is abuse and when is a person at risk………….

For children and young people this includes:

  • Physical abuse which may involve shaking, throwing, poisoning, burning, scalding, drowning, suffocating or otherwise causing physical harm.
  • Emotional abuse which is the persistent emotional maltreatment so as to cause severe and persistent adverse effects on their emotional development.
  • Sexual abuse which involves forcing or enticing a child or young person to take part in sexual activities, including prostitution, whether or not the child/young person is aware of what is happening.
  • Neglect consisting of the persistent failure to meet a child’s or young person’s basic physical and/or psychological needs, which is likely to result in the serious impairment of their health or development.

For vulnerable adults abuse can mean:

  • Physical abuse including hitting, slapping, punching, kicking, misuse of medication, restraint or inappropriate sanctions.
  • Sexual abuse including rape, sexual assault, or sexual acts to which the victim has not consented, could not consent to or was pressurised into consenting to.
  • Psychological abuse including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, verbal abuse, isolation or withdrawal of services or supportive networks.
  • Discriminatory abuse including racist, sexist, religious abuse or abuse that is based on a person’s disability.
  • Financial abuse including fraud, exploitation, pressure in connection with wills, property, inheritance or financial transactions or the misuse or misappropriation of property, possessions or benefits.
  • Neglect including ignoring physical or medical care needs, failure to provide access to appropriate services or the withholding of necessities of life.

What to do if…………

A young person or vulnerable adult discloses abuse to you

Take the disclosure seriously and never dismiss the allegation of abuse. Provide a quiet and supportive environment to help the person feel at ease. Remember that an allegation of abuse of neglect may lead to have a criminal investigation and asking leading questions or attempting to investigate the allegation yourself may cause problems for any subsequent court proceedings.

Do not make promises regarding confidentiality. Explain to the person at the outset that you will need to report the disclosure and share the information with The Source Safeguarding Officer. The Safeguarding Officer will, where possible respect the wishes of the individual; however, information will be shared with external agencies where it is judged that a person is at risk of suffering significant harm.

Report the disclosure to a Safeguarding Officer immediately. Complete the Incident Form and forward to the Safeguarding Officer within 24 hours. The Safeguarding Officer or Senior Manager will identify the appropriate next steps and keep in contact with you to ensure that our Duty of Care is fulfilled.

What to do if……………

You are concerned a young person or vulnerable adult may be at risk

  • Contact the Safeguarding Officers or your manager for advice and guidance
  • Make and keep a record of your concerns and forward to the Safeguarding Officer within 24 hours
  • Discuss your concerns with the young person if appropriate

What to do if……………

A young person or vulnerable adult accuses you or another member of staff of abuse

  • Contact your manager and the Safeguarding Officer for advice and guidance
  • Make and keep a record of the accusation and actions taken and forward to the Safeguarding Officer within 24 hours

Peer on Peer Abuse

Peer abuse is behaviour by an individual or group, intending to physically, sexually or emotionally hurt others. Staff and managers at The Source Academy are aware of the potential for young people to abuse their peers and raise young people’s awareness of the dangers associated with on line activity, including, for example, use of social media, grooming, bullying and cyberbullying, gender based violence sexting and sexual assault and honour based and gang violence.

Peer on peer abuse can:

  • Be motivated by perceived differences e.g. on grounds of race, religion, gender, sexual orientation, disability or other differences.
  • Result in significant, long lasting and traumatic isolation, intimidation or violence to the victim.

Children or young people who harm others may have additional or complex needs and may be experiencing:

  • Significant disruption in their own lives
  • Exposure to domestic abuse or witnessing or suffering abuse
  • Educational under-achievement
  • Involvement in crime

Instances of peer on peer abuse will be reported upon following the Safeguarding reporting procedure and include:

  • An assessment of an incident between peers should be completed and consider:
  • The ages of everyone involved
  • Differences in power or authority in relation to age, race, gender, physical, emotional or intellectual vulnerability
  • All alleged physical and verbal aspects of the behaviour and incident
  • Whether the behaviour involved inappropriate sexual knowledge or motivation
  • What was the degree of physical aggression, intimidation, threatening behaviour or bribery
  • The effect on the victim
  • Any attempts to ensure the behaviour and incident is kept a secret
  • The child or young person’s motivation or reason for the behaviour, if they admit that it occurred
  • Whether this was a one-off incident, or longer in duration

Useful guidance is available from:

  • New Choices Inc.
  • This is abuse campaign 0010/2015-03-08_This_is_Abuse_campaign_summary_report__2_.pdf
  • bullying/definition/index.html#types
  • EACH resources for LGBT
  • Child Online Protection and Exploitation Service

Useful contact numbers:

Safeguarding Sheffield Children Advisory Service 0114 2053535

Adult Access Sheffield Safeguarding Team 0114 273 4908

Rotherham Safeguarding Children Team 01790 823 987

Child Line 0800 1111

Barnardos 0113 393 3200

NSPCC Child Protection Helpline 0808 800 5000

South Yorkshire Police 0114 220 2020

Staff Behaviour Policy

Code of Behaviour For All Staff

You must not:

  • Staff should not spend excessive amounts of time alone with children and vulnerable adults, away from others. Meetings with individual children and vulnerable adults should be avoided or take place within sight of others. If privacy is needed, the door should remain open and other staff or should be aware of the meeting.
  • Staff are advised not to make unnecessary physical contact with children and vulnerable adults. However, there may be occasions when physical contact is unavoidable, e.g. providing comfort at times of distress. In all such cases contact should only take place with the consent of the child.
  • It is not good practice to take children and vulnerable adults alone in a car, however short the journey. Where this is unavoidable, it should be with the full knowledge and consent of the parents (or guardians).
  • Staff should not meet children and vulnerable adults outside of the work environment.
  • Staff should not start an investigation or question anyone after an allegation or concern has been raised. This is the job of the authorities. You should record the facts and report these to the Safeguarding Officer.

Staff should never:

  • Initiate or engage in sexually provocative conversations or activity.
  • Allow the use of inappropriate language to go unchallenged.
  • Do things of a personal nature for children and vulnerable adults that they can do themselves.
  • Allow any allegations made by a child or vulnerable adult go without being reported and addressed.
  • Trivialise or exaggerate child or vulnerable adult abuse issues.
  • Make promises to keep any disclosure confidential from relevant authorities.
  • Staff should not show favouritism to any one child or vulnerable adult, nor should they issue or threaten any form of physical punishment.

You must:

  • Staff must respect children and vulnerable adults’ rights to privacy and encourage children and vulnerable adults to feel comfortable enough to report attitudes or behaviour they do not like.
  • Staff will be expected to act with discretion with regard to their personal relationships. They should ensure their personal relationships do not affect their leadership role within the organisation. All pre-existing relationships between staff and children and vulnerable adults must be declared.
  • All staff should be aware of the procedure for reporting concerns or incidents, and should familiarise themselves with the contact details of the Safeguarding Officer.
  • If a member of staff finds himself or herself the subject of inappropriate affection or attention from a child or vulnerable adult they should make others aware of this.
  • If a member of staff has any concerns relating to the welfare of a child or vulnerable adult in their care, be it concerns about actions/behaviours of another staff member or concerns based on any conversation with the child or vulnerable adult; particularly where the child or vulnerable adult makes an allegation, they should report this to a Safeguarding Officer.

Procedure for Responding to an Allegation of Child Abuse

This procedure must be followed whenever an allegation is made that a child or vulnerable adult has been abused or when there is a suspicion that a child or vulnerable has been abused.

Do not make promises regarding confidentiality. Explain to the person at the outset that you will need to report the disclosure and share the information with The Source Safeguarding Officer. The Safeguarding Officer will, where possible respect the wishes of the individual; however, information will be shared with external agencies where it is judged that a person is at risk of suffering significant harm.

The member of staff or learner who has concerns about possible abuse or neglect contacts their line manager and Safeguarding Officer as soon as possible for advice and support. A record of the incident or concern should be made on the Incident Record. If the complainant is the child or vulnerable adult him/herself, questions should be kept to the minimum necessary to understand what is being alleged and leading questions should be avoided. The use of leading questions can cause problems for the subsequent investigation and court proceedings.

The Safeguarding Officer must report the matter to the local Social Services Department as a matter of urgency whether or not they feel this action is justified in the particular circumstances of the case. The matter will be reported over the telephone to the duty social worker (or such other person as required by the local Area Child Protection Committee (ACPC) procedure). In the unlikely event that social services cannot be reached contact the relevant police child protection team for the area.

A written record of the report will be retained by the Safeguarding Officer. The written record will note the date and time of the report and must include the name and position of the person to whom the matter is reported. The Safeguarding Officer should discuss with the Social Services Department what action will be taken to inform the parents/guardian of the child or vulnerable adult and a note of that conversation should be made.

Allegations Against a Member of Staff

In the event there is any suspicion, allegation or apparent abuse of a child or vulnerable adult by a member of staff the matter should be reported to the Safeguarding Officers as soon as possible or to a Senior Manager, Chief Executive or the Human Resources Team.

On being notified of any such matter the Safeguarding Officer and senior manager shall:

  • Take such steps as they consider necessary to ensure the safety of the child or vulnerable adult in question.
  • Liaise with the person who reported the original concern and ensure that a report of the matter is completed.
  • Report the matter to the local social service department in accordance with the procedure set out above if not already done so.
  • Notify The Source Chief Executive.

If the Safeguarding Officer is the subject of the allegation or complaint the matter must be reported direct to The Source Chief Executive. If a complaint has been made against The Source Chief Executive the matter must be reported to the Chair of The Board of Directors.

All staff should be aware of the fact that allegations may be made against them, and that the allegation may have grounds for substantiation or not. Any such notification may result in immediate suspension of the member of staff, and may result in the application of the company’s disciplinary procedure where it is considered appropriate.

Whistle Blowing and Freedom to Speak Up

The Source Academy has an established whistleblowing policy contained within the staff handbook. We have reviewed Sir Robert Francis’s Freedom to Speak Up report and in context of its own organisation The Source Academy is committed to the principles of Freedom to Speak Up by creating a culture of safety where staff can raise concerns that are free from the risks of bullying or other intimidation, where managers encourage the raising of concerns and the organisation is able to reflect on its practices.

The policy provides a procedure for raising, investigating and resolving concerns and supporting staff through the process.

The NSPCC has launched guidance and a whistleblowing helpline if you have any concerns. The Whistleblowing Advice Line offers free advice and support to professionals with concerns about how child protection issues are being handled in their own or another organisation. If you think an organisation is putting children at risk, even if you're not certain, you can call them to talk through your concerns.

Non Attendance

Policy for Reporting Non-Attendance on Training Programmes

Our contact details are given to learners on all programmes and they are asked to contact us to report non-attendance. Details of learners’ responsibilities with regards to non-attendance are highlighted in the Student Handbook.

Traineeships / Adult Programmes

If learners don’t attend and don’t ring in, we contact them by telephone, using the mobile and / or landline numbers. We will endeavour to speak to the learner to establish the reason for the non-attendance; if this isn’t possible then messages are left for the learner to ask them to contact us. We will also email learners where no contact has been made.

For Trainees under the age of 18, if we are not able to speak to the learner then contact is made with the parent or guardian.

Work Placement

Learners are made aware of the reporting procedures for non-attendance during work placement, they are provided with contact details for The Source and the work place. We make contact with the work place at intervals during the placement to check for attendance (and performance). The employer also has our contact details and is asked to contact us should the learner not attend. Non-attendance is followed up once the learner is back in class.

Schools (Year 10 and 11)

The attendance register is completed by the tutor and collected by the Admin team by 9.30 and again by 13.30 (after the lunch break). Admin then contact School by telephone to report any non-attendance.

Child Protection / Safeguarding

We follow-up on non-attendance once the learner is back in class and establish the reasons for the absence. The Safeguarding procedures are then followed if appropriate.

Specific Safeguarding Issues

Expert and professional organisations are best placed to provide up-to-date guidance and practical support on specific safeguarding issues. For example NSPCC offers information for schools and colleges on the TES website and also on its own website Schools and colleges can also access broad government guidance on the issues listed below via the GOV.UK website:

  • Child sexual exploitation (CSE)
  • Bullying including cyber bullying
  • Domestic Violence
  • Drugs
  • Fabricated or induced illness
  • Faith abuse
  • Female genital mutilation
  • Forced marriage
  • Gangs and youth violence 6293/Advice_to_Schools_and_Colleges_on_Gangs.pdf
  • Gender based violence
  • Mental health
  • Private fostering private-fostering
  • Radicalisation
  • Sexting
  • Teenage relationship abuse
  • Trafficking


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