Safeguarding Policy
Statement
Newham London Tuition Centre fully recognises its responsibilities for safeguarding. Our policy applies to all Staff, Management team, external agencies and volunteers working for Newham London Tuition Centre.
At no point whist in the care of Newham London Tuition Centre, should any student under the age of 16 be left unsupervised at any Newham London Tuition Centre. Please refer to the Failure to Collect policy for information relating to the safeguarding of children before and after a Newham London Tuition Centre session.
There are six main elements to our policy:
● Ensuring we practice safer recruitment in checking the suitability of staff and volunteers to work with children
● Parent collection
● Raising awareness of child protection issues and equipping children with the skills needed to keep them safe
● Developing and then implementing procedures for identifying and reporting cases, or suspected cases, of abuse
● Supporting pupils who have been abused in accordance with his/her agreed child protection plan
● Establishing a safe environment in which children can learn and develop
We recognise that because of the day-to-day contact with children, Newham London Tuition Centre staff have all received ‘Level 2 Safeguarding’ and the Prevent Duty training. Therefore, they have the knowledge and skills to observe the outward signs of ‘need’. The Newham London Tuition Centre will therefore:
● Establish and maintain an environment where children feel secure, are encouraged to talk, and are listened to
● Ensure children know that there are adults at Newham London Tuition Centre whom they can approach if they are worried
Newham London Tuition Centre Designated Safeguarding Leads
Atif Hussain – a.hussain@newhamtuition.com
Deputy: Nayeer Afzal – Nayeer.afzal@ntlworld.co.uk
Safeguarding Definition
The definition of the term ‘safeguarding’ as derived in this policy is taken from statutory guidance. Keeping children safe in education - GOV.UK (www.gov.uk)
Safeguarding children is defined as:
● protecting children from maltreatment
● preventing the impairment of children’s mental and physical health or development
● ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and
● taking action to enable all children to have the best outcomes
Procedures
We will follow the procedures set out by the Local Safeguarding Children Board and take account of guidance issued by the Department for Education ‘Keeping Children Safe in Education’ to:
● Ensure we have a nominated Safeguard Lead (SL)
● Ensure all Newham London Tuition Centre staff on the premises know who the Nominated safeguarding lead is.
● Ensure all Newham London Tuition Centre staff understand their responsibilities when they are alerted to the signs of need/neglect/abuse and understand their responsibility/procedures for referring any concerns to the SL.
● Ensure that Newham London Tuition Centre staff have up to date safeguarding training, so that their knowledge and awareness of child protection policies and procedures are up to date
● Follow procedures where an allegation is made against a member of staff or volunteer (Whistle Blowing policy)
● Ensure safer recruitment practices are strictly adhered to line with Safer Recruitment policy.
We recognise that children who are abused or witness violence may find it difficult to develop a sense of self-worth. They may feel helplessness, humiliation and some sense of blame. Newham London Tuition Centre may be the only stable, secure and predictable element in the lives of children at risk. When at Newham London Tuition Centre their behaviour may be challenging and defiant or they may be withdrawn. Newham London Tuition Centre will endeavour to support such student through:
● The content of the curriculum
● Newham London Tuition Centre’s ethos which promotes a positive, supportive and secure environment and gives pupils a sense of being valued
● Newham London Tuition Centre’s Teaching and Learning policy, which is aimed at supporting pupils at Newham London Tuition Centre
● Newham London Tuition Centre will ensure that all students know that some behaviour is unacceptable, but they are valued and not to be blamed for any abuse which has occurred
● Liaison with the school to support vulnerable students such as Local Authority Children’s Social Care, Child and Adult Mental Health Service, education welfare service and educational psychology service
Types of Abuse
Dealing with Child Abuse is a complex, multi-agency procedure which is defined within a legal framework. Newham London Tuition Centre will follow the recommended procedures as set out by the authorities. Because of the length and close proximity of contact with children, tutors are often best placed to identify the symptoms of need/neglect/abuse.
The role of tutors is basically defined as:
(a) Assisting in the identification of need/neglect/abuse
(b) Providing support to such who have a need/neglect/abuse
Newham London Tuition Centre is not an investigation or an intervention agency for child protection, but it has an important role to play in the recognition of need/neglect/abuse.
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.
A child may be at risk from any combination of the first four categories, however there are also at least seven other forms of abuse that you should be aware of. More detailed information on these types of abuses can be found in Appendix 1, which is essential reading.
1. Physical Abuse
This involves physical injury to the child, including deliberate poisoning and forcing a child to consume drugs such as tobacco and alcohol. It may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical abuse may also be caused when a parent or carer feigns the symptoms of, or deliberately causes, ill health to a child whom they are looking after (sometimes described as fabricated or induced illness by carers).
Symptoms may include:-
(a) Bruising - especially about the face and head.
(b) Slap marks.
(c) Cuts and abrasions.
(d) Signs of self-harm or a significant change in wellbeing
2. Sexual Abuse
This is illegal sexual activity involving a child or young person or, in the case of young people over the age of 16, sexual activity carried out without the person's consent, including coercion, threat and intimidation. Sexual abuse is forcing or enticing a child or young person to take part in sexual activities, whether or not the child is aware of what is happening. They may include non-contact activities, such as involving children in looking at, or producing pornographic material, watching sexual activities or encouraging children to behave in sexually inappropriate ways. Pupils with special education needs and/or with behavioural and emotional problems are particularly vulnerable to such abuse.
Symptoms are more difficult to define but may include:
(a) Precocious and/or promiscuous behaviour
(b) Sexual references in interactions with others
(c) Sudden changes in behaviour - withdrawal, avoidance of social contact,
truancy, aggression
(d) Abnormal response to particular teaching situations e.g. lessons/discussions on sex and health education and inter-personal relationships
(e) Sudden deterioration of performance
(f) Anxiety and/or low self-esteem
(g) Knowledge of sexual matters beyond what would be expected
(h) Strong need for affection, sometimes expressed in physical terms
(i) Difficulty in trusting or defiance of teacher
(j) Fear of Newham London Tuition Centre medical examinations
(k) Vague pains or aches, possibly arising from psychosomatic illness. (l) Threat of, or actual self-harm
3. Emotional Abuse
This is persistent emotional ill-treatment of a child which causes severe and long lasting 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 feature age or developmentally inappropriate expectations being imposed on children or cause children to feel frightened or in danger. Some level of emotional abuse is involved in all types of ill-treatment of a child.
Symptoms may include:
(a) Withdrawal, fear of people or situations, a reluctance to participate in lessons
(b) Inappropriate responses to situations e.g. excessive aggression to a mild
reprimand, no or little response to shocking news
(c) Expressions of low self-worth and low self-esteem
(d) Lack of self-confidence, nervousness in group situations
(e) Distorted views of other people (the English teacher hates me)
(f) Negative attitudes and views of significant others (my father is a pig, my family
is no good, etc)
(g) Failure to make lasting, secure relationships
4. Neglect
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. It may involve a parent or carer failing to protect a child from physical harm or danger, or the failure to ensure access to appropriate medical care. It may also include neglect of, or unresponsiveness to, a child's basic emotional needs.
Some symptoms are:
(a) Small physical size, poor growth
(b) Dirty, unkempt appearance
(c) Poor awareness of personal hygiene
(d) Symptoms of physical illness in Newham London Tuition Centre
(e) Evidence of poor care outside Newham London Tuition Centre e.g. the child is seen wandering the streets late at night, or is in the company of older children/young people
(f) Poor eating habits, an unbalanced diet, constantly asking for food or money to buy food from others, stealing food or money to buy food time.
Other Forms of Abuse (Appendix 1):
● Child on Child abuse
● Domestic violence or abuse
● Female Genital Mutilation
● Honour Based abuse and Forced Marriage
● Child Sexual Exploitation and Child Criminal Exploitation
● Serious Violence
● Mental/Physical Health
● Modern Slavery
● Self-neglect
● Organisational or institutional abuse
● Discriminatory abuse
Signs of Abuse
The signs of child abuse aren't always obvious, and a child might not feel able to tell anyone what's happening to them. Sometimes, children don't even realise that what's happening to them is abuse.
Some common signs that there may be something concerning happening in a child’s life include:
● unexplained changes in behaviour or personality
● becoming withdrawn
● seeming anxious
● becoming uncharacteristically aggressive
● physical marks/injuries (burns, scars, fractures)
● lacks social skills and has few friends, if any
● poor bond or relationship with a parent
● knowledge of adult issues inappropriate for their age
● running away or going missing
● always choosing to wear clothes which cover their body
These signs don’t necessarily mean that a child is being abused; there could be other things happening in their life which are affecting their behaviour. There may also be some concerning behaviour from adults who have children in their care, which raises concerns for the child/children’s safety and wellbeing.
Online Delivery
In the event of a centre closure or disruption resulting in the requirement to deliver tuition by online methods. To safeguard pupils in an online delivery setting, Newham London Tuition Centre must ensure the following:
● Parental consent - confirmation must be obtained that the families have agreed
to tuition prior to tuition commencing
● An appropriate parent or guardian must be present for the duration of the online session
● Clear guidance must be provided to the parent or guardian of the expectation of them, their child, and the tutor
● Contact details for the Tuition Partner must be provided to the parent or guardian, including contact details for the Tuition Partner Designated Safeguarding Lead,
to support the reporting of any safeguarding concerns at any point during the provision of online support
● All online sessions must be recorded on an appropriate platform. All sessions must be conducted on an appropriate system, and saved securely by the Tuition Partner.
● A safeguarding spot check audit must be undertaken on a minimum of 1 session per Tutor per term by the tuition partner. A record of this spot check must be kept detailing any safeguarding concerns raised, and how these have been actioned in line with the Safeguarding reporting process as appropriate.
● Where a school wishes to use their own platform, schools may conduct the recordings instead. There should be clear guidance from the Tuition Partner on the expectations of a school to record and securely store these recordings. The recordings must
be made available to the Tuition Partner if there is a safeguarding incident
or suspected incident and the Tuition Partner will need to agree a retention period
for access in case of an incident, in line with the Tuition Partner’s own retention
period for recordings. In cases where the school owns the recordings, the TP is not able to monitor the recordings. Instead, they should conduct live monitoring
by dropping into sessions, with monitored sessions selected at random and without prior warning.
● Where the individual circumstances of a child participating in the session mean that the session cannot be recorded, in individual cases other measures will need to be in place to ensure sessions are monitored. This could be through Tuition Partner drop-ins or having a teacher or teaching assistant supervise the session by also joining the session online. The parent or guardian should also be informed of the need for extra vigilance as the session is not being recorded.
The Role of the Designated Safeguarding Lead (DSL)
Newham London Tuition Centre ensures an appropriate senior member of staff is appointed to the role of designated safeguarding lead. The designated safeguarding lead should take lead responsibility for safeguarding and child protection (including online safety). This should be explicit in the role holder’s job description.
The designated safeguarding lead should have the appropriate status and authority within the organisation to carry out the duties of the post. The role of the designated safeguarding lead carries a significant level of responsibility, and they should be given the additional time, funding, training, resources and support they need to carry out the role effectively. Their additional responsibilities include providing advice and support to other staff on child welfare, safeguarding and child protection matters, taking part in strategy discussions and inter-agency meetings, and/or supporting other staff to do so, and to contributing to the assessment of children. They are also responsible for referring personnel to the Disclosure and Barring Service (DBS) and Teaching Regulation Agency (TRA), if they have caused harm, or pose a risk of harm to vulnerable groups including children.
The DSL should:
- Attend Level 3 Safeguarding Training and be familiar with Child protection policies, reviewed biannually in March and September. DSL training will be updated every two years.
- Based on (1) above, keep Newham London Tuition Centre's policy and procedures up to date.
- Provide guidance and training to tutors.
- Keep all reports and records in a safe, secure place and ensure their information.
- Liaise with the school and other agencies if needed, including receiving and preparing reports.
- Give tutors the information necessary for them to respond in the most appropriate way to students at risk bearing in mind, at all times, the need for maximum confidentiality. Information will be given only on a 'need to know' basis.
- Record the details of records on the safeguarding reporting log which include referrals made, actions taken and outcomes.
- Demonstrate the actions taken by the designated safeguarding lead where concerns are raised and how these were addressed.
- Evidence regular reporting as part of the engagement with the quality assurance process aligned with the monitoring and review of safeguarding cases.
Reporting personnel to the DBS and TRA
Referrals are made to the Disclosure and Barring Service (DBS) and Teaching Regulation Agency (TRA) when Newham London Tuition Centre, has concerns that a person has caused harm, or poses a future risk of harm to vulnerable groups, including children. In these circumstances the employer must make a referral to the DBS and consider a referral to the TRA.
Lessons Learnt
After any cases where the allegations are substantiated, the Tuition Partner will review the circumstances of the case with the Local Authority Designated Officer (LADO) and HR within the organisation.
Newham London Tuition Centre will engage with Tribal to determine whether there are any improvements that can be made to the procedures or practice to help prevent similar events in the future.
For all other cases, where the allegation is concluded to be either unfounded, false, malicious or unsubstantiated, the DSL (and if they have been involved, the LADO) will consider the facts and determine whether any lessons can be learned and if improvements can be made.
The Role of the Deputy Designated Safeguarding Lead
Newham London Tuition Centre ensures deputies are trained to the same standard as the designated safeguarding lead and the role should be explicit in their job description. Whilst the activities of the designated safeguarding lead can be delegated to appropriately trained deputies, the ultimate lead responsibility for child protection, as set out above, remains with the designated safeguarding lead, this lead responsibility should not be delegated.
Protection of Student Identity:
At Newham London Tuition Centre, we work hard to protect children. This includes identity protection.
In this respect, we issue parents with a letter seeking their approval for taking and using images of children.
If the collection of a student is changed at short notice and there’s a cause for concern, Newham London Tuition Centre will contact the parent to verify using the contact details provided on enrolment.
Reporting a Safeguarding Concern:
Recognising when to report a safeguarding concern:
- Be aware of pupils' physical condition and behaviour in terms of the different types of abuse.
- Report any concerns immediately to the DSL or deputy safeguarding lead. Make a dated note of your concerns and observations
- Do not engage the child in a discussion on a suspected problem - this may exacerbate the situation. Direct intervention with a child requires great skill and tact.
- You may ask a child to explain an obvious physical injury e.g. a bruise or black-eye as this may have a simple and innocent cause. However, it is crucial that a physical injury is reported if:-
(a) It has a number of similar antecedents
(b) The explanation given does not match the nature of the injury
- Report the following immediately to the DSL:
(a) Statements made directly to you by a child which allege or suggest abuse
(b) Statements made to you by others, including children, siblings, even members of the public
(c) Comments overheard by you made by suspected victims or others
(d) Unusual statements made in pupils' written work e.g. references to close relationships with particular individuals or descriptions of unusual situations
- It is possible that (5) above may relate to a member of staff or another person known to you. Under no circumstance should your own relationship influence your response. You are obliged by law to refer any allegation or information on possible abuse to the nominated staff.
Procedures to Log a Safeguarding Concern
If you have reason to suspect that a child or young person is suffering, or likely to suffer, some form of significant harm, or when an allegation of abuse has been made:
- You must inform the DSL immediately. The DSL must inform the Newham London Tuition Centre Director immediately.
- If at any time a student gives you information about being harmed, or the prospect of being harmed, you must tell them that the information he or she has given to you will have to be shared with the DSL and cannot be kept confidential.
- Record immediately what the student has said and in their own words. If possible, this should be with another suitable adult present, but NOT the person against whom an allegation has been made. Do not probe or ask leading questions.
- Provide a copy of your written report to the Newham London Tuition Centre Director at the earliest opportunity and within 24 hours.
- If at any time you have concerns about a student, if you suspect that they are suffering, or likely to suffer, some form of significant harm, you must tell the DSL and record your concerns clearly and in writing. The threshold for raising a concern should not be regarded as high. Even the slightest concern by staff should be reported and recorded because it may form part of a picture which the DSL is aware of.
- It is important to explain that the law is in place to protect children rather than criminalise them, and this should be explained in such a way that avoids alarming or distressing them.
- It is important that if a child reports any form of abuse, that it is believed in the first instance. The NSPCC report that children rarely retract their original disclosures and when they do, it is more likely to be because of pressures upon them. This also applies to reports made by friends.
- In any interaction with a child, you should never ask leading questions as this can later be interpreted as putting ideas into the child's mind.
- Treat any information given by the DSL in the strictest confidence - never discuss it with anyone else, including colleagues.
Definition of low-level concerns
The term ‘low-level’ concern is any concern – no matter how small – that an adult working may have acted in a way that:
● Is inconsistent with behaviour expected, including inappropriate conduct outside of work, and
● Does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the designated officer at the local authority
Any concern that causes a sense of unease or a ’nagging doubt’ and staff should report it to the DSL or deputy safeguarding lead. If such an allegation involves a member of staff, additionally Atif Hussain/Nayeer Afzal (Newham London Tuition Centre Directors) must be told and action taken in relation to the Newham London Tuition Centre’s Staff Discipline Policy.
Examples of such behaviour could include, but are not limited to:
● being over friendly with pupils
● humiliating pupils
● having favourites
● taking photographs of children on their mobile phone; without prior arrangement
● engaging with a child on a one-to-one basis in a secluded area or behind a closed door
● using inappropriate sexualised, intimidating or offensive language.
The DSL will record all concerns on the Low-Level Concerns Log, which includes all relevant details, and take appropriate action. Each time a new concern is recorded, the DSL will review all records so that potential patterns of concerning, problematic or inappropriate behaviour is identified. In the case of any patterns being identified, action will be taken through disciplinary procedures or, where a pattern of behaviour moves from a concern to meeting the harms threshold, it will be referred to the LADO.
For all other cases, where the allegation concluded to be either, unfounded, false, malicious or unsubstantiated, the Case Manager (and if they have been involved the LADO) should consider the facts and determine whether any lessons can be learned and if improvements can be made.
When concerns are made by third parties, the Head Teacher will record the concern on the Low-Level Concern Log and take appropriate action and review the records as outlined above.
Appendix 2 sets out a safeguarding summary which should be kept with you at all times when teaching children at a Newham London Tuition Centre provision.
Relevant Legislation and Guidance
● Keeping children safe in education 2022
● Working together to safeguard children 2018
● The Children Act 1989 & 2004
● The Children and Social Work Act 2017
● The Mental Capacity Act 2005
*This policy links with the following other policies: GDPR policy, Code of Conduct, Behaviour and Anti-Bullying policy, Safer-recruitment policy, Teaching and Learning policy, Whistleblowing policy, Health and Safety, Diversity and Inclusion, Failure to Collect policy, Online learning policy and associated facts and logistics of joining online learning, and Staff Handbook.
