Safeguarding and PREVENT Policy

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Safeguarding and Prevent Policy

Through developing practice, collaboration, research and dissemination, Cambridge Professional Academy Ltd. seeks to ensure that everyone in our care receives support and protection to meet their individual needs. Cambridge Professional Academy’s Governance Board fully endorses this Policy and Guidance.

This Policy has been developed to bring together the key principles of Safeguarding, The Prevent Duty, Equality and Diversity and Health and Safety. It applies to all staff, including senior managers, the Board, volunteers and seasonal workers, agency staff, learners or anyone working for and on behalf of Cambridge Professional Academy Ltd.  Full details of our PREVENT procedure can be found in Appendix A of this document.

The term ‘learner’ used in this policy refers to learners of Cambridge Professional Academy Ltd. (internal or subcontractors’) who attend interviews, online learning, study in centres or in their place of work.

Through developing practice, collaboration, research and dissemination, Cambridge Professional Academy Ltd. seeks to ensure that everyone in our care receives support and protection to meet their individual needs. Cambridge Professional Academy’s Governance Board fully endorses this Policy and Guidance.

This Policy has been developed to bring together the key principles of Safeguarding, The Prevent Duty, Equality and Diversity and Health and Safety. It applies to all staff, including senior managers, the Board, volunteers and seasonal workers, agency staff, learners or anyone working for and on behalf of Cambridge Professional Academy Ltd.  Full details of our PREVENT procedure can be found in Appendix A of this document.

The term ‘learner’ used in this policy refers to learners of Cambridge Professional Academy Ltd. (internal or subcontractors’) who attend interviews, online learning, study in centres or in their place of work.

Our commitment

  • We promote the welfare of every learner and to keep them safe
  • We are committed to practise in a way that protects every learner.
  • We believe that learners should never experience any form of abuse, discrimination, harassment or victimisation.
  • We protect learners who receive our services. This includes the children of learners who use our services and any siblings of learners.
  • We will protect learners from radicalisation and extremism, by responding swiftly where learners are vulnerable to these issues.
  • We will provide staff and volunteers with regular updates and annual training on Safeguarding and Prevent using the resources provided by the Education and Training Foundation and other accredited sources.
  • We will record and check the details of all visitors to all our premises.
  • We recognise that ignoring abuse is not an option and all staff must report any concerns for the wellbeing of learners in accordance with this policy
  • We also commit to keeping a Safeguarding and Prevent Action plan/risk register

Aims

Our aims are to:

  • Promote fundamental British values, including freedom of speech, rights to be safe and listened to, by creating an environment that encourages every learner to raise any concerns.
  • Encourage learners to develop a sense of autonomy and independence in their learning and development.
  • Enable all learners to have the self-confidence and the vocabulary to resist inappropriate approaches.
  • Work with employers to build their understanding of and commitment to the principles of safeguarding and Prevent duty.
  • Liaise with other statutory agencies to ensure legislative procedures are current.
  • Liaise with external agencies to support staff and learners where required

The Statutory Framework

The Children Act 1989 placed a duty on local authorities to investigate situations where a child is at risk of significant harm. Schools, Colleges and Providers had a legal obligation to work with investigating agencies acting on behalf of children in need Guidance was published in ‘Safeguarding Children in Education’ (2004). It set out the requirements to provide a safe learning environment, identify young people suffering, or likely to suffer, significant harm and take appropriate action in full partnership with other local agencies. It encompassed wider issues such as health, safety, drug/substance abuse and bullying as well as the contribution made to safeguarding in relation to individual children and underpinned our common law duty of care.

This was replaced and extended in January 2007 by ‘Safeguarding Children and Safer Recruitment in Education’, which includes more specific guidance (including some statutory requirements) relating to the recruitment and vetting of staff. The responsibility for making sure appropriate arrangements are in place lies with Cambridge Professional Academy Ltd. Staff members are responsible for carrying out their duties in compliance with the arrangements set out by Cambridge Professional Academy Ltd., we are not the investigating agency. This function is carried out by local authority Children’s Services, or other agencies with statutory powers. The Children Act 1989, and subsequent legislation and guidance, are concerned with the emotional, physical or sexual abuse or neglect of children, defined as under the age of 18. However, it is recognised that children acquire degrees of legal capacity (for example, the ability to give informed consent) and maturity prior to their 18th birthday, and that there are learners over 18 who continue to be vulnerable due to a learning difficulty and/or disability.

Children are defined in the Children Act 1989 and 2004, as a person under the age of 18 years. The Safeguarding Vulnerable Groups Act 2006 defines a vulnerable learner as a person aged 18 or over and:

  • Teenagers
  • Children and young people missing from education
  • Those at risk of FGM (Female Genital Mutilation)
  • Those at risk of Forced Marriage
  • Those at risk of Honour Based Violence
  • Trafficked children and young people
  • Those in the ‘looked after’ system
  • Children and young people living away from home
  • Children from some minority ethnic groups
  • Those with abuse & trauma in their past
  • Those living in sheltered accommodation
  • detained in custody or under probation order
  • Those living with domestic violence, parental substance misuse and/or parental mental ill health, receiving a service or participating in an activity targeted at older people, people with disabilities or with physical or mental health conditions

This policy and related procedures are driven by the following legislation and guidance:

  • The Children Act 1989
  • The Children Act 2004
  • Working Together to Safeguard Children 2018
  • What to do if you are worried a child is being abused 2015
  • Keeping Children Safe in Education (KCSIE) 2018
  • Protection of Freedoms Act 2012
  • Care Act 2014
  • Keeping Learners Safe 2015
  • Safeguarding Children: Working Together Under the Children Act 2004 a Disqualification under the Childcare Act 2006 (2018)
  • Counter Terrorism and Security Act 2015
  • Prevent Duty Guidance for England and Wales (2015)
  • Channel Duty Guidance: Protecting vulnerable people from being drawn into terrorism 2015
  • Multi-agency guidance on FGM (2016)
  • Modern Slavery Act (2015)
  • Information sharing: advice for practitioners providing safeguarding services (2018);
  • Children missing in Education (2016)
  • Child sexual exploitation: definition and a guide for practitioners, local leaders and decision makers working to protect children from child sexual exploitation (2017)
  • Sexting in schools and colleges: responding to incidents and safeguarding young people (UK Council for Child Internet Safety (UKCCIS), 2016);
  • Sexual violence and sexual harassment between children in schools and colleges (2018)
  • General Data Protection Act (2018)
  • Specific roles and responsibilities concerning Safeguarding

The Designated Safeguarding Lead will:

  • Report recommendations for changes to the Company Safeguarding and Prevent Policy and Procedures taking into account legislative changes to the Board of Directors
  • Undertake regular and appropriate training for this role
  • Make the decision to investigate any allegations or concerns about abuse
  • Address any immediate protection issues
  • Make the decision and support staff to refer to an appropriate statutory agency (Police, Local Authority, Social Services and / or Channel)
  • Liaise with Local Safeguarding Board
  • Ensure employees are trained on Company Safeguarding procedures
  • Source appropriate external training for Safeguarding

Working with others

  • Liaise with SMT / Senior Executive Board to inform of issues / ongoing enquires related to section 47 of the Children's Act 1989.
  • As required liaise with “case manager” and the Designated Safeguarding Lead at the Local Authority for child protection concerns on all cases which concern a Staff Member.
  • Liaise with staff on matters of safety and safeguarding when deciding whether to make a referral by liaising with relevant external agencies.
  • Act as a source of support, advice and expertise for staff.
  • Link with Local Children's and Learners Safeguarding Boards
  • Work with trainers and tutors to ensure Child /Vulnerable Learner Protection File are transferred to new College, Training Provider or other support services
  • Availability; telephone, or in person where possible to deal with any incidents.

Ongoing Development & Raising Awareness

  • Understand the assessment process for providing early help and intervention, through locally agreed common and shared assessment process (local safeguarding boards).
  • Have working knowledge of each local safeguarding board children’s & learners.
  • Develop staff awareness of policies and processes.
  • Alert to specific children in need, SEN, Young Carers and “Looked after.”
  • Keep detailed, accurate, secure written records of concerns and referrals.
  • Ensure open and listening culture.
  • Understand Prevent Duty, providing advice and support to staff.
  • Ensure Policies & Procedures are known.

Deputy Safeguarding Officer will:

  • Report on best practice and recommendations for improvements to the Company Safeguarding Policy and Procedures to the Safeguarding Lead
  • Make the decision to investigate any allegations or concerns about abuse
  • Address any immediate protection issues
  • Carry out any internal investigations regarding Safeguarding
  • Make the decision to refer to an appropriate statutory agency (Police, Social Services, Local Authority and /or Channel)
  • Liaise with Local Safeguarding Board
  • Work closely with tutors to respond to any immediate welfare and or safeguarding concerns
  • Work closely with the Safeguarding Lead to escalate immediate protection issues
  • Work with tutors and support teams to develop the confidence of all when speaking with learners regarding welfare and safeguarding, PREVENT discussions.
  • Undertake regular and appropriate training for this role
  • Keep up to date with safeguarding and PREVENT policy changes
  • Work to promote safeguarding and PREVENT best practice
  • Complete their Designated Safeguarding training by an approved training provider and refresher training as appropriate (but as a minimum every 2 years) to cover as a minimum

Managers will:

  • Ensure that this Policy is brought to the attention of all their employees;
  • Ensure that the Policy and associated procedures are implemented effectively;
  • Ensure that risks are assessed and that appropriate risk reduction measures are developed tor all work tasks and activities;
  • Ensure their employees have appropriate instruction, training and development to enable them to fulfil their Safeguarding and Prevent responsibilities and to work safely
  • Monitor the performance of their own employees to ensure Policy requirements and Company standards are being met;
  • Ensure that all incidents of suspected or alleged abuse are reported;
  • Set a good example and promote responsible attitudes among employees and learners.

All staff, contractors and volunteers will;

  • Be alert to signs of abuse and extremism and take responsibility for referring concerns to Cambridge Professional Academy’s Safeguarding team
  • Be prepared to listen to and take seriously the concerns of learners and carers
  • Abide by the codes of conduct for Cambridge Professional Academy Ltd. employees and volunteers
  • Promote the health, safety and welfare of learners
  • Maintain records as necessary
  • Set a good example to learners by their own behaviour

We ensure that any relevant history of the learner, particularly in relation to potential indicators of abuse or neglect is recorded confidentially within their records.

This includes learners that are participating in Work experience and off-site activities. We work closely and collaboratively with all sub-contractors and employers to ensure that they have appropriate and effective safeguarding and prevent policies and procedures in place, and these are audited on a regular basis by Senior Managers, Quality and Service Standards Service Excellence, Safe and Sound, and the Subcontractor Manager.

Safeguarding definitions and guidance

Safeguarding is defined as:

  • Protecting children and vulnerable learners from maltreatment.
  • Preventing impairment of children's and vulnerable learners’ health or development.
  • Ensuring that children and vulnerable learners are growing up in circumstances consistent with the provision of safe and effective care.
  • Acting to enable all children and vulnerable learners to have the best life-chances.

Significant Harm:

  • Harm means ill treatment or the impairment of health or development, including impairment suffered from seeing or hearing the ill treatment of another.
  • Development means physical, intellectual, emotional, social or behavioural development.
  • Health means physical or mental health.
  • Ill treatment includes physical & sexual abuse and forms of ill treatment which are not physical. (s.31 (9) Children Act 1989 as amended by the Adoption and Children Act 2002)

Welfare - Welfare is defined as a child or vulnerable learner in need of universal help from those already involved or from a single or multiple agency response.

Missing from Education - Children and young people and vulnerable learners who go missing from education will fail to achieve their full potential academically, and fail to achieve economic wellbeing in later life. They are also at a greater risk of physical harm, self- inflicted or inflicted by others, being sexually exploited and becoming involved in crime and anti-social behaviour, being employed illegally or abusing drugs and alcohol. In line with the duty under section 10 of the Children Act 2004, Cambridge Professional Academy Ltd. must take reasonable steps to monitor learners’ attendance through a daily register. This is also completed for vulnerable learners. Attendance should be monitored closely and poor or irregular attendance should be addressed. Please see Missing from Education Policy or more information.

Recognition of Abuse, including Neglect, Bullying and Cyber Bullying

Recognising abuse is not easy, and it is not the responsibility of staff, volunteers or learners to decide whether abuse has taken place or if there is significant risk. We do however have a responsibility to act if we think it may be happening.

Abuse, including neglect, includes forms of maltreatment of a child or vulnerable learner. Somebody may abuse a child or vulnerable learner by inflicting harm, by failing to act to prevent harm. Children and vulnerable learners may be abused in a family or in an institutional or community setting; by those known to them or, more rarely, by a stranger for example via the internet. They may also be abused by a learner or learners, or by another child or children.

Contextual Safeguarding

Children’s, young people and vulnerable learners’ experiences of abuse and violence are rarely isolated events, and they can often be linked to other things that are happening in their lives and spaces in which they spend their time. Any response to peer on peer abuse therefore needs to consider the range of possible types of peer on peer abuse set out above and capture the full context of children’s, young people and vulnerable learner’s experiences. This can be done by adopting a ‘contextual safeguarding’ approach and by ensuring that our response to incidents of peer on peer abuse takes into account any potential complexity.

Types and Signs of Abuse

Child or Vulnerable Learner abuse - may be physical, sexual or emotional abuse, or neglect.

Significant harm - ill treatment or the impairment of health or development (compared with the health or development which might be expected of a similar child/ learner)

Physical abuse - actual or likely physical injury to a child or vulnerable learner, or failure to prevent injury. This may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm. Physical harm may also be caused when a parent or carer feigns symptoms of, or deliberately causes, ill health to a child or vulnerable learner they are looking after. This form of physical harm is recognised as Fabricated or Induced Illness.

Sexual abuse - actual or likely sexual exploitation of a child or vulnerable learner, including prostitution. Involving forcing or enticing a child or vulnerable learner to take part in sexual activities without their consent or understanding. The activities may involve physical contact including penetration or non- penetrative acts. For example, it may also include involving the child looking at or being involved in the production of, pornographic material or watching sexual activities, or encouraging the victim to behave in sexually inappropriate ways. Can include grooming a child or vulnerable learner in preparation for abuse.

Emotional abuse - emotional abuse is the persistent emotional ill treatment of a child or vulnerable learner with the intent to cause severe and persistent adverse effects on the victim’s emotional development. It may involve conveying to the victim that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. Age or developmentally inappropriate expectations being imposed on children, causing children frequently to feel frightened, or the exploitation or corruption of children or vulnerable learners will also constitute emotional abuse. This may also include overprotection and limitation of exploration and learning or participating in normal social interaction. It can include seeing or hearing ill treatment of another person. It may include serious bullying, including cyber-bullying. It may include not giving the child or vulnerable learner opportunities to express their views, deliberately silencing them, or making fun of what they say or how they communicate.

Neglect - neglect is the persistent failure to meet a child or vulnerable learner’s basic physical and/or psychological needs, likely to result in the serious impairment of their health or development such as failing to provide adequate food, shelter and clothing, medical care or treatment or neglect of, or unresponsiveness to, their basic emotional/physical needs. It can include not protecting a child or vulnerable learner from emotional harm or danger.

Peer on peer abuse - Peer on peer abuse is behaviour by an individual or group of individuals which can be a one-off incident or repeated over time. Peer on peer abuse is behaviour that intentionally hurts another individual or group either physically or emotionally. It is more likely that girls will be victims and boys’ perpetrators, but all peer on peer abuse is unacceptable and will be taken seriously. Peer on peer abuse can take many forms including serious bullying (including cyberbullying), relationship abuse, domestic violence, child sexual exploitation, youth and serious youth violence, financial abuse, harmful sexual behaviour and/or gender-based violence and is often motivated by prejudice against particular groups steered by a dislike for a person’s:

  • race;
  • religion;
  • gender;
  • special educational needs or disabilities; or where a child:
  • is adopted or in care;
  • has caring responsibilities;
  • is suffering from a health problem;
  • is frequently on the move (e.g. those from military families or the travelling community)
  • is experiencing a personal or family crisis
  • has actual or perceived differences, (e.g. physical or cultural differences)

These types of abuse rarely take place in isolation and often indicate wider safeguarding concerns. Abusive behaviour can happen to pupils in schools and settings and it is necessary to consider what abuse is and looks like, how it can be managed and what support and intervention can be put in place to meet the needs of the individual and what preventative strategies may be put in place to reduce further risk of harm.

There may be reports where the alleged incident is between two pupils from the same or different educational establishments but is alleged to have taken place away from the premises. The safeguarding principles, and our duty to safeguard and promote the welfare of the learner remain the same regardless of where the incident took place and regardless of whether the incident was online or offline.

Abuse is abuse and will never be tolerated or passed off as ‘banter’, ‘just having a laugh’, ‘part of growing up’ or ‘boys being boys’. Equally, abuse issues can sometimes be gender specific e.g. girls being sexually touched/assaulted and boys being subject to initiation/hazing type violence. We will not dismiss abusive behaviour between children, young people and vulnerable learners as ‘normal’ and our thresholds for investigating claims and allegations are the same as for any other type of abuse.

Preventing violence and ensuring immediate physical safety is Cambridge Professional Academy’s first priority but we also acknowledge that emotional abuse can be just as damaging if not more so than physical violence. We recognise that abuse often involves an imbalance of power between the perpetrator and the victim. This could involve perpetrators of abuse having control over the relationship which makes it difficult for the victim to defend themselves. The imbalance of power can manifest itself in several ways, it may be physical, psychological (knowing what upsets someone), derive from an intellectual imbalance, or by having access to the support of a group, or the capacity to socially isolate. It can result in the intimidation of a person or persons through the threat of violence or by isolating them either physically or online.

We also acknowledge that low level disruption and the use of offensive language can have a significant impact on its target. If left unchallenged or dismissed as ‘banter’ or ‘horseplay’, it can also lead to reluctance to report other behaviour.

Bullying and Harassment - Bullying can include a variety of behaviours from one individual/ group to another individual/ group such as name calling, offensive language, coercion, hitting, pushing, theft or damage to belongings, cyber, spreading harmful messages, hate crime or mate crime which is befriending someone with the intent to exploit them in some way. Please refer to Cambridge Professional Academy’s Anti- Bullying Policy for further detail.

Cyber Bullying and E-Safety - The safe and responsible use of technology, is sometimes presented as primarily a child or vulnerable learner protection issue. While children, young people and vulnerable learners do need support to keep themselves safe online the risks associated with the use of technology (e.g. internet, text or video messaging, email, chatrooms, social media networking sites) to embarrass, humiliate, threaten, intimidate or bully an individual in an attempt to gain power and control over them. There is also the mismanagement of personal data, risks of financial scams, identity theft, grooming, and radicalisation.

Learning Difficulty and/or Disability - Children or learners with a learning difficulty and/or disability may be especially vulnerable to abuse or bullying any may have difficulties in communicating this to staff. At Cambridge Professional Academy, staff are skilled, experienced and they work closely with learners and their colleagues so they can identify signs at an early stage. Any reports of a learner with a learning difficulty and/or disability being abused or bullied will involve the Learner Welfare and Safeguarding Manager at the very earliest opportunity.

Risk to self and/or others - This may include but is not exclusive to self- harm, suicidal tendencies or potential risk of harming others, which may or may not include children. This may be because of an individual experiencing a significant level of personal, emotional trauma and/or stress.

Domestic Violence - can be physical, emotional, sexual, neglect. This category also covers Forced Marriages and honour-based violence. Some learners may experience issues with drugs or alcohol to self-medicate or via dependence.

Female Genital Mutilation (FGM) - Victims of FGM are likely to come from a community that is known to practice FGM. Professionals should note that girls at risk of FGM may not yet be aware of the practice or that it may be conducted on them, so sensitivity should always be shown when approaching the subject.

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 staff to report where, during their professional duties, they either are informed by a girl under 18 that an act of FGM has been carried out on her, observe physical signs which appear to show that an act of FGM has been carried out on a girl under 18 and they have no reason to believe that the act was necessary for the girl’s physical or mental health or for purpose with labour or birth. For the purposes of the duty, the relevant age is the girl’s age at the time of disclosure/identification of FGM (i.e. it does not apply where a woman aged 18 or over discloses she had FGM when she was under 18).

Forced Marriage - One or both spouses do not consent to the marriage or consent is extracted under duress. Duress includes both physical and emotional pressure. A clear distinction must be made between a forced marriage and an arranged marriage. In arranged marriages, the families of both spouses take a leading role in choosing the marriage partner but the choice whether to accept the arrangement remains with the young people.

Modern slavery - Encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.

Risks/ abuse related to family/cultural belief/ faith - It is important to remember that many children and vulnerable learners are a part of a familv. Some families have certain values and beliefs that can cause harm to a child or vulnerable learner. An example of this can include strong beliefs or a sense of honour or shame that can prevent people from seeking or accepting the help they need. A strong cultural or religious belief in the sanctity of marriage may dissuade people from leaving their partners, even if they are violent. In addition, many religions and cultures have strong beliefs around sex outside marriage, making it very hard for young, unmarried, pregnant women to get the help they need. Differences in culture or religion between partners, or between parents and children, may also make it more difficult for individuals to understand and support each other. Where one partner perceives their faith and heritage to be superior to, or more important than, their partner's it can lead to a power imbalance and an erosion of the other partner's self-esteem. In extreme cases children who are perceived as “disobedient” or “different” are believed to be possessed by a spirit controlling their behaviour. The children can be physically and emotionally abused to exorcise the spirit.

Sexting - This is when someone sends or receives a sexually explicit text, image or video. This includes sending ‘nude pics’ or ‘rude pics’ or ‘nude selfies’. Pressuring someone into sending a nude picture can happen in any relationship and to anyone, whatever their age, gender or sexual preference. Once the image is taken and sent, the sender has lost control of the image and the image could end up anywhere. By having in their possession or distributing to others indecent images of a person under 18, many young people are not aware that they could be committing a criminal offence under the Sexual Offences Act 2003.

Any direct disclosure by a learner (male or female) will be taken very seriously. A child or young person who discloses they are the subject of sexual imagery is likely to be embarrassed and worried about the consequences. It is likely that disclosure is a last resort and they may have already tried to resolve the issue themselves. When an incident involving sexting comes to our attention, we will follow the guidance as set out in the UKCCIS publication Sexting in Schools and Colleges: Responding to incidents and safeguarding young people.

Initiation/Hazing - Hazing is a form of initiation ceremony which is used to induct newcomers into an organisation such as a school or sports team etc. Hazing can also be used as initiation into a street or other ‘gang’. There are several different forms, from relatively mild rituals to severe and sometimes violent ceremonies. The idea behind this practice is that it welcomes newcomers by subjecting them to a series of trials which promote a bond between them. After the hazing is over, the newcomers also have something in common with older or established members of the organisation or ‘gang’, because they have all experienced this as part of a ‘rite of passage’. Many rituals involve humiliation, embarrassment, abuse and harassment.

Parental Impacts - The issues of parents and carers can have a significant impact upon a child or vulnerable learner’s wellbeing. Some issues can include Substance Misuse, Mental Health and Domestic Abuse. It is also important to note that some children and vulnerable learners also misuse drugs or alcohol when experiencing trauma in their own lives and they may require support around both factors. It is fundamental that wherever a concern is held for a child or vulnerable learner that confidentiality is respected however if the concern must involve the parent or carer for safeguarding reasons then it is good practice to work together and inform parents or carers of any referrals that may have to be made to support services.

The Prevent Duty

In 2011, the Government published the Prevent Strategy which raised awareness of the specific need to safeguard children, young people and families from extremism and radicalization. Please refer to our Prevent Duty Procedure.

Extremist groups have attempted to radicalise vulnerable children and young people to hold extreme views including views justifying political, religious, sexist or racist violence, or to steer them into a rigid and narrow ideology that is intolerant of diversity and leaves them vulnerable to future radicalisation.

Prevent is about safeguarding our learners to keep them both safe and within the law. The Prevent Duty is not about preventing learners from having political and religious views and concerns but about supporting them to use those concerns or act on them in non-extremist ways.

Radicalisation & Extremism - The holding of extreme political or religious views e.g. animal welfare rights, environmentalists, EDL / white supremacy groups, anti-gay groups, Islam / Christian ideology. The Counter Terrorism and Security Act, places a duty on specified authorities, including local authorities and childcare, education and other children’s services providers, in the exercise of their functions, to have due regard to the need to prevent people from being drawn into terrorism. (“The Prevent duty”)

The current threat from terrorism in the United Kingdom may include the exploitation of vulnerable people, to involve them in terrorism or in activity in support of terrorism. The normalisation of extreme views may also make children and young people vulnerable to future manipulation and exploitation.

Cambridge Professional Academy Ltd. is clear that this exploitation and radicalisation should be viewed as a safeguarding concern and that protecting children from the risk of radicalisation is part of the companies safeguarding duty.

Radicalisation refers to the process by which a person comes to support terrorism and forms of extremism leading to terrorism. Learners may become susceptible to radicalisation through a range of social, personal and environmental factors - it is known that violent extremists exploit vulnerabilities in individuals to drive a wedge between them and their families and communities. It is vital that school staff can recognize those vulnerabilities.

Extremism is defined by the Government in the Prevent Strategy 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.

Responding to suspicions of radicalisation and extremism

We are alert to changes in a learner’s behaviour or attitude which could indicate that they need help or protection.

  • When any member of staff has concerns that a learner may be at risk of radicalisation or involvement in terrorism, they should speak with the On-Duty Designated Safeguarding Officer for investigation and action.
  • Disclosure records are held by the Safe and Sound team and stored on a secure server.
  • Staff take care not to influence the outcome either through the way they speak to or question children/vulnerable learners.
  • We will continue to welcome the learner whilst investigations are being made. The learner may choose to withdraw from learning activities whilst investigations take place. os) We follow the procedures as set by the Local Safeguarding Board in relation to the delivery of services’ and designated roles and tasks in supporting the learner, family, and employer subsequent to any investigation.
  • All suspicions and investigations are kept confidential and shared only with those who need to know.
  • Any information is shared under the guidance of the Regional Prevent Coordinator HE/FE.

Numerous factors can contribute to and influence the range of behaviours that are defined as violent extremism, but most young people do not become involved in extremist action. For this reason, the appropriate interventions in any case may not have any specific connection to the threat of radicalisation, for example they may address mental health, relationship or drug/alcohol issues.

Channel

Channel is a multi-agency approach to provide support to individuals who are at risk of being drawn into terrorist related activity. It is led by the regional Police Counter-Terrorism Unit, and it aims to:

  • Establish an effective multi-agency referral and intervention process to identify vulnerable individuals.
  • Safeguard individuals who might be vulnerable to being radicalised, so that they are not at risk of being drawn into terrorist-related activity.
  • Provide early intervention to protect and divert people away from the risks they face and reduce vulnerability.

The Channel programme focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. It provides a mechanism for schools to make referrals if they are concerned that an individual might be vulnerable to radicalisation. An individual’s participation in the programme is entirely voluntary at all stages.

Training Providers have a duty to cooperate with the Channel programme in the carrying out of its functions, and with the Police in providing information about an individual who is referred to Channel (Section 38, Counter Terrorism and Security Act 2015).Further guidance about duties relating to the risk of radicalisation is available in the Prevent Duty Guidance for FE. Please also refer to our Prevent Policy

Recognition of vulnerability factors can include:

  • Identity Crisis — the learner is distanced from their cultural / religious heritage and experiences discomfort about their place in society.
  • Personal Crisis — the learner may be experiencing family tensions; a sense of isolation; and low self- esteem; they may have dissociated from their existing friendship group and become involved with a new and different group of friends; they may be searching for answers to questions about identity, faith and belonging.
  • Personal Circumstances — migration; local community tensions; and events affecting the learner’s country or region of origin may contribute to a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy.
  • Unmet Aspirations — the learner may have perceptions of injustice; a feeling of failure.
  • Rejection of civic life.
  • Experiences of Criminality — which may include involvement with criminal groups, imprisonment, and poor resettlement / reintegration.
  • Special Educational Need — learners may experience difficulties with social interaction, empathy with others, understanding the consequences of their actions and awareness of the motivations of others.

However, this list is not exhaustive, nor does it mean that all young people experiencing the above are at risk of radicalisation for the purposes of violent extremism.

More critical risk factors could include:

  • Being in contact with extremist recruiters.
  • Accessing violent extremist websites, especially those with a social networking element. “Possessing or accessing violent extremist literature.
  • Using extremist narratives and a global ideology to explain personal disadvantage.
  • Justifying the use of violence to solve societal issues.
  • Joining or seeking to join extremist organisations.
  • Significant changes to appearance and / or behaviour.
  • Experiencing a high level of social isolation resulting in issues of identity crisis and / or personal crisis.

Allegations against staff

Cambridge Professional Academy Ltd. recognises that whilst most staff and volunteers who work with children and vulnerable learners are committed to their wellbeing and care there exists a range of abuse perpetrated by workers that despite the best efforts and interventions can still take place.

An allegation may relate to a member of staff including a volunteer who works with children who has behaved in way that has harmed a child, or may have harmed a child, possibly committed a criminal offence against or related to a child or behaved towards a child or children in way that indicates they may pose a risk of harm to children.

  • We ensure that all learners and employers know how to complain about staff, which may include an allegation of abuse or neglect of statutory duties.
  • We follow the guidance of the Local Safeguarding Board when responding to any complaint that a member of staff or volunteer has abused a learner.
  • Each Manager knows that the HR Designated Safeguarding Officer is to be made aware immediately of any allegation or complaint against a member or staff or volunteer.
  • We respond to any disclosure by learners or employers that abuse by a member of staff may have taken, or is taking place, by first recording the details of any such alleged incident on an
  • We refer any such complaint immediately to the Local Authority's Designated Officer (LADO) to investigate.
  • We co-operate entirely with any investigation carried out by the local authority and police.
  • Disclosure and Barring Service liaison (DBS).

Responding to suspicions

Cambridge Professional Academy Ltd. is committed to responding promptly and appropriately to all incidents or concerns that may occur and to work with statutory agencies in accordance with the procedures that are set down in 'What to do if you are worried a child is being abused.' (DfE 2014)

We acknowledge that abuse or neglect of basic safety and welfare procedures for learners can take place and that this can take different forms - physical, emotional, and sexual as well as employer's neglect of legal responsibilities and neglect of parental or statutory responsibilities (including where young people are in care of social services).

We also acknowledge that this can take the form of 'virtual' or internet-based abuse or neglect.

We recognise that when young people or vulnerable learners are suffering from physical, sexual or emotional abuse, or may be experiencing neglect, this may be demonstrated through the things they say (direct or indirect disclosure) or through changes in their appearance, their behaviour, or their play.

Where any member of staff who has knowledge of, or a suspicion that, a child, young or vulnerable person is or has been suffering significant harm must refer their concern to the On-Duty Designated Safeguarding Officer/Lead as soon as possible but within 24 hours at the latest. The member of staff must make a dated record of the details of the concern on the Safeguarding Concern Form and email to Jill Towner at jill.towner@professionalacademy.com or Neil Donoghue at neil.donoghue@professionalacademy.com for investigation and action, the person raising the concern must not retain any written information. Please see the Safeguarding Staff user guide for further information.

All allegations or suspicions must be taken seriously. The learner or staff member must be advised that this information cannot be kept confidential and will be passed on to the Designated Safeguarding Officer/Lead in Cambridge Professional Academy Ltd. in the first instance.

Support for Staff

Where a member of staff finds a disclosure particularly distressing, they may wish to access the additional services within Westfield Health Scheme or contact HR Department for support. Cambridge Professional Academy Ltd. have an open-door policy for any staff who wish to discuss their concerns, staff will need to be mindful that Cambridge Professional Academy Ltd. cannot as with learners to give absolute confidentiality to any disclosures All learners receive programme inductions which includes raising awareness of commitment towards Safeguarding, details of the support services that can be offered and contact details for the Safeguarding team. The understanding of all aspects of Safeguarding and safe working practices is checked at each review and the opportunity to discuss any issues is given. Assessments are made to ensure that the learners wellbeing is safeguarded by the work placement and their teams to ensure arrangements are in place to, prior to work related activity commencing:

  • Pre-placement Health and Safety checks of employer’s premises and health and safety management arrangements are complete, including insurance details, young person risk assessments, lone working policies etc.
  • Employers are made aware of relevant Cambridge Professional Academy Ltd. Policies
  • The requirements for DBS checks are assessed and the relevant processes undertaken where required.

Confidentiality

A good working relationship between staff and learners depends to a large extent on the establishment of trust. However, guarantees of absolute confidentiality should not be given. If a learner / staff member discloses to a member of staff, it is important that the boundaries of confidentiality and the need to pass on that information are explained. It is often easier to explain to that you have a responsibility to pass on information on certain matters than to get into a situation where you break a confidence.

Disciplinary action

It is a criminal offence for a person over 18 in a position of trust to enter a sexual relationship with any learner under 18 years old, even if the relationship is consensual. If allegations are made against staff the same procedures as outlined above must be followed. If a member of staff suspects abuse, whether sexual or otherwise, from another member of staff, the Designated Safeguarding Lead must be informed. Depending on the severity of the allegations outside agencies may be informed and/or the staff disciplinary procedure may be invoked.

Where a member of staff or a volunteer is dismissed from the delivery of services or internally disciplined because of misconduct relating to a learner, we notify the Disclosure and Barring Service (DBS) so that appropriate action is taken.

Safer Recruitment Processes

We provide adequate and appropriate staffing resources and training to meet the needs of learners.

All staff, volunteers and learners are informed that their job falls under the DBS requirements for an enhanced check under section 128 of the Education Skills Act 2008.

We will provide the applicant with more information about the level of check required

There are 3 types of check:

  • Standard (This checks for spent and unspent convictions, cautions, reprimands and final warnings.)
  • Enhanced (This includes the same as the standard check plus any additional information held by local police that's reasonably considered relevant to the workforce being applied for (learner, child or other workforce.)
  • Enhanced with list checks (This is like the enhanced check but includes a check of the DBS barred lists.)

Checks will be made using an appointed third-party provider or using the update service.

Information Sharing & Record Keeping

There may be some circumstances where the welfare or safety of an individual may take precedence over confidentiality. When sharing information there are Seven Golden Rules that Cambridge Professional Academy Ltd. will adhere to:

  • The Data Protection Act is not a barrier to sharing information.
  • Be open and honest.
  • Seek advice.
  • Share with consent where appropriate. (There may be some circumstances where seeking consent including parental consent is not required)
  • Consider safety and well-being.
  • Ensure that information sharing is appropriate and secure.
  • Keep a record.

The Staff member who receives the allegation or disclosure should make an immediate written record of the conversation, including the following information:

  • Date and time of report.
  • Name of Individual.
  • DOB of alleged.
  • Nature of allegation.
  • Any other information given, including siblings if relevant. (their full names and DOB if possible)
  • Confirmation that the Learner / staff member has been advised of the next steps.

Disclosure records are held by the Designated Safeguarding Lead and stored on a secure server. Staff must take care not to influence the outcome either through the way they speak to or question learners.

Cambridge Professional Academy Ltd. continues to welcome the learner whilst investigations are being made in relation to any alleged abuse. The learner may choose to withdraw from learning activities whilst investigations take place.

We follow the procedures as set by the Local Safeguarding Board in relation to the delivery of services' and designated roles and tasks in supporting the learner, family, and employer subsequent to any investigation.

All suspicions and investigations are kept confidential and shared only with those who need to know. Any information is shared under the guidance of the Local Safeguarding Board and Local Authority Designated Officer.

Recording – When recording an incident, a Safeguarding Report Form must be completed. Whilst you can record observations, do not interpret or give opinion as this may bias the information provided and jeopardise any future investigation into the allegation. The Safeguarding Report Form should be kept securely.

Report - Any issues or concerns, allegations or suspicions relating to Safeguarding must be taken seriously and reported to the Designated Safeguarding Lead or Deputy in their absence.

Designated Safeguarding Lead: Jill Towner 01223 783605 or jill.towner@professionalacademy.com
Deputy: Neil Donoghue 01223 783856 or neil.donoghue@professionalacademy.com   

Literature outlining the reporting processes including posters or pop-up banners as appropriate will be on display in learning environments to inform Apprentices of how to raise a concern.

Refer - Where required, the Safeguarding Representative will refer or support you with guidance on next steps and / or signposting the relevant external agency.

We abide by the DBS regulatory requirements in respect of requesting references and DBS checks for staff and volunteers.

New staff and volunteers are not given unsupervised access to young people or vulnerable learners pending return of a satisfactory DBS check.

We will meet the DBS reporting requirements in respect of any person who is dismissed from our employment or resigns in circumstances that would otherwise have led to dismissal for reasons of learner protection concern.

Disclosure

Cambridge Professional Academy Ltd. strongly supports the principle of working in partnership with children, parents/ carers and learners. This means seeking clear, explicit and informed consent from the individual(s) concerned for information about them to be shared with specified other individuals or agencies where consistent with the individual(s) best interests.

It is possible, however, to identify some circumstances in which sharing confidential information without consent will normally be justified in the public interest. These are:

  • When there is evidence that the child is suffering or is at risk of suffering significant harm.
  • Where there is reasonable cause to believe that a child may be suffering or at risk of significant harm.
  • To prevent significant harm arising to children and young people or serious harm to learners, including through the prevention, detection and prosecution of serious crime.
  • For this purpose, serious crime means any crime which causes or is likely to cause significant harm to a child or young person or serious harm to and learner.

Cambridge Professional Academy’s Safeguarding and Prevent Policy should be read in conjunction with the following policies which are located on Sharepoint:

  • Health & Safety Policy
  • Equality and Diversity Policy
  • Whistle Blowing Policy
  • Code of Conduct
  • Grievance Procedure
  • Disciplinary Procedure
  • Confidentiality Procedure
  • Internet, email and
  • Data security

APPENDIX A – PREVENT Procedure

Prevent Duty Procedure: Detecting and Preventing Radicalisation and Extremism

This procedure forms part of Cambridge Professional Academy’s Safeguarding and Prevent Policy. The Prevent Procedure is communicated to all our staff, employers, sub-contractors and learners, to support them to identify anyone who they think may be at risk of radicalisation and extremism, and to help them to take the appropriate action.

Background

PREVENT is part of the Home Office and the Police counter-terrorism strategy CONTEST and aims to stop people from becoming terrorists or supporting terrorism by working with individuals and communities to address issues before they become a criminal matter to stop people moving from extremism into terrorist-related activity.

Context

People of any age, but in particular young people in the UK, are potentially vulnerable to engagement with extremist ideologies or to targeting by extremist organisations. Learning providers and others who engage with young people, should be aware of these risks and be familiar with the support networks and processes in place to protect vulnerable individuals from becoming radicalised or drawn into terrorism. Cambridge Professional Academy Ltd. works nationally across a variety of dispersed locations, in which the Home Office-defined risks of radicalisation vary considerably.  We therefore need a support network in place for staff and learners that includes a central point of access. This is provided by effective communication with the Regional Prevent Coordinator HE/FE, and ongoing links with other regional leads.

Procedure

We have developed internal support mechanisms for both staff, employers, sub-contractors and learners for safeguarding, and these will also apply for the PREVENT procedure. We outline below who staff, employers, sub-contractors and learners should contact with any concerns.  Cambridge Professional Academy Ltd. has developed links with external agencies who can provide support in this area.  If, once internal processes are completed, we consider that additional external support or referral is required then this may be arranged by the Safeguarding Team. External support will normally involve an individual being asked to voluntarily receive tailored support from relevant external individuals or organisations.

Definition of Radicalisation

The Institute of Strategic Dialogue defines radicalisation as ‘the process through which an individual change from passivity or activism, to become more revolutionary, militant or extremist, especially where there is intent towards, or support for, violence’.  Driving factors behind radicalisation can include:

  • Lack of integration and/or polarisation
  • Identity crisis and/or isolation
  • Political and/or democratic disenfranchisement
  • Discrimination
  • Foreign policy and/or international crises or disputes
  • Political movements
  • Ideologies or faiths

Who are we safeguarding?

There is no stereotype for people who hold extremist views. Vulnerability, isolation and personal grievances added to strong political, religious of social views, can result in a person searching for a cause.  People can become vulnerable for many reasons including:

  • Low self-esteem
  • Guilt
  • Loss
  • Isolation
  • Family breakdown
  • Fears
  • Lack of purpose
  • Anger
  • Peer pressure

We are by no means suggesting that one or all of these characteristics or circumstances will drive someone to terrorism. But they often lead to a sense of injustice – be that on a personal or more far-reaching scale. Their vulnerabilities or susceptibilities are then exploited towards crime or terrorism by people who have their own agenda.

There is no typical gender, age, religion or background that extremists will target, but they use a sense of ‘duty’ (belonging to a specific group), ‘status’ (need for reputation), and ‘spiritual rewards’ (test of faith), as a way of drawing them in. 

This raises the question of what those signs of radicalisation will look like: they will look a lot like other troubling behaviour:

  • Emotional: anger, mood swings, a new-found arrogance
  • Verbal: expression of opinions that are at odds with generally shared values
  • Physical: changes in appearance or routine.

What to do if you believe someone to be at risk of radicalisation

Cambridge Professional Academy Ltd. has adopted the approach of ‘Notice, Check, Share’ where there are concerns that an individual may be vulnerable:

Notice: recognise any changes in behaviour or appearance similar to those outlined above.

Check: speak with someone you trust like a tutor/manager or Safeguarding Team and see what they recommend but trust your instinct if you are still concerned. It might on occasions be useful to speak to the person concerned who may be willing to provide useful context and detail to assist understanding.

Share: speak to one of the named Designated Safeguarding Officers to report your concerns. 

‘Remember to trust your instinct’

Guidance:

  • If you are a learner and you are concerned about another learner, please Check with your tutor in the first instance and together Share with the Designated Safeguarding Officer.
  • If you are a learner and you are concerned about a member of staff, or a person representing Cambridge Professional Academy Ltd., please first Check with the Designated Safeguarding Officer and together Share with the Group Safe and Sound Manager.
  • If you are a member of staff and concerned about a learner, please Check and Share with the Designated Safeguarding Officer.
  • If you are a member of staff and you are concerned about another member of staff, please Check with your line manager and Share with the HR Designated Safeguarding Officer (where the concern is your line manager then Check and Share with the HR Designated Safeguarding Officer)
  • If you are a member of staff and you are concerned about a person external to Cambridge Professional Academy Ltd., please Check and Share with a Manager.

Responsibility for contacting PREVENT support:

The following people are responsible for making the decision to contact the police Prevent Team or the Regional Prevent Coordinator HE/FE if serious concerns are raised about a learner, employer, a member of staff or a person external to Cambridge Professional Academy Ltd.:

Designated Safeguarding Lead: Jill Towner 01223 783605 or jill.towner@professionalacademy.com

Deputy: Neil Donoghue: 01223 783856 or neil.donoghue@professionalacademy.com  

No one person will usually make this decision.  The Safeguarding Lead(or Deputy in their absence) must make any decision for referral.  This would be in the first instance through our Designated Safeguarding Lead Jill Towner through whom we have access to a national network of support. Contact details are telephone 01223 783605 or email jill.towner@professionalacademy.com.  Advice would be sought and appropriate action would follow.

PREVENT is designed to make reporting easier and more straightforward.  Cambridge Professional Academy Ltd. will do everything it can to ensure that support and guidance are available to staff, employers, learners and all connected with the company.  If you have any proposals for additional support or advice that you think may help, please share these with a Senior Manager/ Group Safe and Sound Manager.

Please note: as outlined in Keeping Children Safe in Education (April 2014), any individual has the right to refer to their local Safeguarding Children Board if they have concerns about an individual.  Similarly, any individual may report any behaviour that raises a concern that they are at risk of radicalisation, to the police.  However, anyone wishing to report a matter related to a learner, member of staff or other person connected with Cambridge Professional Academy Ltd., should please inform a Senior Manager and the Safeguarding Lead and seek their support before taking any action.