Safeguarding & PREVENT Policy

Last reviewed in July 2022 by Sarah Jones

Next review due in July 2023

Purpose & Scope

The purpose of this document is to demonstrate that, as business, Cambridge Professional Academy Ltd. and its leaders recognise the importance of the safeguarding its apprentices, learners, staff, their families and all those who have contact with the organisation in respect of suffering abuse, neglect or inappropriate pressure from others.

Our focus is on personal dignity, mental health and emotional wellbeing, control by the individual over day-to-day life, participation in work and education, the individual’s contribution to society and the awareness and ability to avoid the threat of terrorism.

This policy underlines the commitment of the directors and staff of the Professional Academy to ensuring that staff and learners are respected, protected and supported to the best of their ability.

The very young and adults at risk have a minimal representation within the usual working activities of Professional Academy, whose main purpose is to provide professional training and education to adults who have the capability to work, however leaders and staff are all aware that anyone may become at risk at any time when faced with a change of circumstances.

Cambridge Professional Academy Ltd. believes that no-one should experience abuse of any kind. We have a responsibility to promote the welfare and safety of all our apprentices, learners, staff and their families and to keep them safe. We will review this policy at least once per year reviewed by SMT and approved by Governance Board.

Legal Framework

This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children, young people and vulnerable adults:

• Keeping Children Safe in Education 2021
• Sexual Harassment between children in schools and colleges 2021
• Children Act 1989 and 2004
• Safeguarding Vulnerable Groups Act 2006
• Counter Terrorism and Security Act 2015
• Equality Act 2010

We will keep our people safe by

• We will keep our people safe by
• We will value, respect and listen to our apprentices, learners and staff.
• Train all staff. Starting at induction, and then through mandatory refresher training every year. This is tracked as part of professional development and a review of this forms is included in the performance management process.
• All concerns and allegations of abuse (physical or mental) will be taken seriously and reported appropriately (to the nominated Safeguarding Officer or Social Care Services).
• We are committed to ensuring our apprentices and learners are given the right support, training and encouragement and everyone will be treated favourably with equal learning opportunities appropriate to their particular needs.
• Any influences of extremism leading to radicalisation will be reported to the Safeguarding Officer or appropriate public authorities. With specific reference to Prevent, staff will:
  • respond to indications of ideological challenge of terrorism and the threat faced by those who promote it
  • report concerns to enable people from being draw into terrorism and get appropriate advice and support from relevant specialists
  • identify sectors and institutions where there are risks of radicalisation that need to be addressed.
  • Be aware of the Prevent Duty Guidelines in England and Wales; March 2015. (See also Appendix 1)
• We have a Code of Conduct which applies to all users of our eLearning platform. Passwords are encrypted and access to the LMS monitored.
• Staff receive appropriate training and support in monitoring our e-learning platform.
• We are aware of and implement data protection guidance.
• We do not tolerate bullying or abuse in any form within the workplace or training events.
• We foster good relationships in the workplace which creates an environment where concerns of abuse can be raised. Any of our staff would take appropriate action in the event of suspected abuse.

Our Responsibilities

Cambridge Professional Academy Ltd. acknowledges that members of staff are not specialists in recognising where abuse or radicalisation may occur or has already taken place. However, it expects everyone to adopt, support and promote this policy to the best of their ability. The policy is supported by our commitment to training staff during regular, internal meetings, accessibility of policy and support documents, and a company-wide promotion of safeguarding and Prevent awareness.
It is not the responsibility of Professional Academy to decide whether or not abuse or radicalisation has taken place. We train our staff to implement the contents of this policy in their interactions with learners and we are all aware of the responsibility to act when there is any cause for concern. Safeguarding and prevent causes for concern include but are not limited to:

• Withdrawal from family and friends, or changing circle of friends
• Hostility towards others
• Talking as if from a script
• Being unwilling to discuss their views
• Increased levels of anger
• Being secretive, particularly around what they are doing on the internet
• Using extremist terms to exclude people or incite violence
• Expressing the values of extremist or terrorist organisations (including political or religious based grievances)
• Supporting violence and terrorism towards other cultures, nationalities, or religions
• Writing or creating artwork that promotes extremist values
• Talking about being a ‘martyr’
• Possession of extremist literature or other material, or trying to access extremist websites
• Possession of any material about weapons, explosives, or military training

Delivery staff talk about safeguarding and prevent issues when meeting with apprentices for learning delivery and progress reviews. Leaders and support staff assist delivery staff by sharing details of current news stories and issues emanating from the Channel Panel forums.

If delivery staff have cause for concern they are trained to report their concerns to head office via the Safeguarding Lead. All apprentices and delivery staff are made aware of how to report a safeguarding concern at onboarding and induction, as well as, throughout their learning journey. We include details of how to report a concern in our learning resources and presentation slides.

Reporting Procedure

Apprentices, learners and staff are advised of the following contact details to report a Safeguarding or Prevent concern.

• Designated Safeguarding telephone number

07521 458256

• Designated Safeguarding Lead

Sarah Jones sarah.jones@professionalacademy.com

• Deputy Safeguarding Officer

Jacqui Lockey Jacqui.lockey@professionalacademy.com

• Prevent Officer

Sarah Jones sarah.jones@professionalacademy.com

1. Individuals should raise their concerns by contacting one of the above nominated and trained officials.
2. The details of the issue will be recorded against the relevant learner file on our learner management database in the form a case file. This will automatically be added to a central safeguarding log.
3. The details of the case will then be investigated and referred where necessary to the relevant local safeguarding or Prevent contacts.
4. Where we are unsure of the severity of the safeguarding case we would seek advice from our own local authority contact for safeguarding on the numbers available at Cambridge County Council: https://www.cambridgeshire.gov.uk/residents/adults/report-abuse-of-an-adult-at-risk
5. If the case log completed concerned a Prevent concern we would contact the relevant local FE/HE Prevent Coordinator for the geographical location of the apprentice:

• South East: Alamgir Sheriyar Alamgir.SHERIYAR@education.gov.uk
• South West: Salam Katbi Salam.KATBI@education.gov.uk (currently on seconded in DfE Covid team)
• London: Jennie Fisher Jennie.FISHER@education.gov.uk
• East Midlands: Sam Slack Salam.KATBI@education.gov.uk
• West Mids. Hifsa Haroon-Iqbal Hifsa.HAROON-IQBAL@education.gov.uk
• North East: Chris Sybenga Chris.SYBENGA@education.gov.uk
• North West: Nigel Lund Nigel.LUND@education.gov.uk

Source: David Layton Scott – Prevent Coordinator East of England) correct at the time of creating the policy

Where we are unsure of the severity of the Prevent case we would seek advice from our own Prevent Coordinator, David Layton-Scott

• Telephone contact number 07384452155
• David.LAYTON-SCOTT@education.gov.uk

Online Monitoring

Cambridge Professional Academy Ltd. Monitors student engagement with its systems. All of our apprentices and learners use their own, personal or the employer provider IT equipment to carry out the learning required of their specific qualification or standard. We are unable to access their personal computers or servers to monitor their IT usage, however, if details of their activities online were made apparent to any member of delivery or support staff, they would have been trained to know to report anything suspicious.

Monitoring and Oversight

The safeguarding team with support from SMT review and agree support/intervention required on a case by case basis, and review lessons learned. All of which is treated in the strictest confidence, and where appropriate, anonymised for the purpose of discussion. The lessons learned are shared with the wider team as part of our commitment to continuous improvement. Anonymised data and areas requiring further detailed guidance are shared with a sub group of the Governance Board for monitoring, guidance, and review of the effectiveness of the Policy. For welfare issues, the Learner Governors are not included in this process.

Successful application of this Policy depends on:

• Responsibility – everyone must play their part in safeguarding and Prevent
• Coordination and proportionality – action should be appropriate to the situation
• Empowerment – understanding the action that should be taken and how to take it
• Prevention – take action before harm occurs
• Protection – be aware of risk and reporting arrangements
• Accountability – ensure roles and lines of accountability are clear
• Procedures – accessibility and familiarity with procedures and policies
• Training – induction and regular training for all staff.

The Prevent Duty

Section 26 of the Counter-Terrorism and Security Act 2015 (‘CTSA Act’) places a duty on the Company, in the exercise of its functions, to have “due regard to the need to prevent people from being drawn into terrorism”. This is known as the Section 26 of the Counter-Terrorism and Security Act 2015 (‘CTSA Act’) places a duty on the Company, in the exercise of its functions, to have “due regard to the need to prevent people from being drawn into terrorism”. This is known as the Prevent Duty.

The term “due regard” as used in the CTSA Act means that the Company should place an appropriate amount of weight on the need to prevent people being drawn into terrorism when it considers all the other factors relevant to how it carries out its usual functions and activities.

Terrorist groups often draw on extremist ideology, developed by extremist organisations. Some people who join terrorist groups have previously been members of extremist organisations and have been radicalised by them.

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

There is no single way of identifying who is likely to be at risk of being drawn into terrorism. Factors that may have a bearing on someone becoming at risk may include:

• peer pressure - influence from other people or via the internet
• bullying
• crime against them or their involvement in crime
• anti-social behaviour
• family tensions
• race/hate crime
• lack of self-esteem or identity
• change in personal circumstances

However, there are a number of signs and indicators that an individual could be being drawn in to an extremist group: (mentioned before under “Responsibilities”)

• isolating themselves from family and friends
• talking as if from a scripted speech
• unwillingness or inability to discuss their views
• a sudden disrespectful attitude towards others
• increased levels of anger
• increased secretiveness, especially around internet use

The Prevent strategy deals with all forms of terrorism and with non-violent extremism, which can create an atmosphere conducive to terrorism and can popularise views which terrorists then exploit. It also made clear that preventing people becoming terrorists or supporting terrorism requires challenge to extremist ideas where they are used to legitimise terrorism and are shared by terrorist groups. The strategy also means intervening to stop people moving from extremist (albeit legal) groups into terrorist- related activity.

Cambridge Professional Academy Ltd. has implemented its Prevent-related responsibilities in a proportionate and risk-based way. All employees should demonstrate an awareness and understanding of the risk of radicalisation. The risk will vary greatly and can change rapidly; but no area, institution or body is risk free. The Prevent Duty is not about preventing individuals from having political and religious views and concerns, but about supporting our adults to use those concerns or act on them in a non-extremist way.

Prevent is an important element within our safeguarding policy and processes. Prevent is focused on safeguarding adults and encourages a learning environment where issues can be raised and discussed safely, whilst ensuring that apprentices and employees are resilient to extreme narratives.

The Prevent strategy is driven by:

• Ensuring all staff, including Governors Directors and Senior Managers receive awareness training on Prevent
• Wider staff awareness training for all staff
• Providing training to ensure staff understand their safeguarding responsibilities and processes and policy to outline how to make a referral
• Providing staff training and guidance on how to recognise potential signs that a colleague, apprentice or learner may be becoming involved with extremist organisations
• Creating a single point of contact for Prevent and Safeguarding related issues
• Ensuring British Values are promoted and are embedded within employability and skills programmes
• Maintaining IT policies that are robust and can deal effectively with potential online risks from extremist organisations, through appropriate use of firewalls and monitoring usage

Apprentices, learners, staff and other stakeholders may become at risk of being drawn into terrorism. In particular, all employees should be aware of the glossary in Appendix 1 and the relationship between extremism and terrorism:

The Prevent duty does not and must not involve any covert activity against people or communities. The Company may however need to share personal information to ensure, for example, that a person at risk of radicalisation is given the appropriate support. Information sharing is assessed on a case-by-case basis and is governed by legislation and the following principles:

• Necessity and Proportionality – personal information should only be shared where it is strictly necessary to the intended outcome and proportionate to it. Key to determining the necessity and proportionality of sharing information will be the professional judgment of the risks to an individual or the public;
• Consent – wherever possible the consent of the person concerned should be obtained before sharing any information about them;
• Power to share – the sharing of data by the Company requires the existence of a power to do so, in addition to satisfying the requirements of the General Data Protection Regulations 2018 and Human Rights Act 1998;
• Confidentiality – the Company should be aware of any confidentiality obligations that exist.

British Values

The Company actively promotes the fundamental British values of:

• Democracy - an understanding of how citizens can influence decision- making through the democratic process
• The rule of law - an appreciation that living under the rule of law protects individual citizens and is essential for wellbeing and safety
• Individual liberty - an understanding that the freedom to choose and hold other faiths and beliefs is protected in law
• Mutual respect - an acceptance that other people having different faiths or beliefs (or having none) should be accepted and tolerated, and should not be the cause of prejudicial or discriminatory behaviour
• Tolerance of those with different faiths and beliefs - an understanding of the importance of identifying and combatting discrimination.

Actively promoting these values means challenging opinions or behaviours that are contrary to fundamental British values. Employees should not promote or tolerate views or theories as fact which are contrary to established scientific or historical evidence and explanation. The aim is to improve safeguarding and standards of spiritual, moral, social and cultural development, and to strengthen barriers to extremism.

The British Values and Prevent duty to relate to the Equality Act 2010 as we seek to:

• Eliminate unlawful discrimination, harassment or victimisation;
• Advance equality of opportunity between people who share a protected characteristic, and those who do not;
• Foster good relations between people who share a protected characteristic, and those who do not.

Appendix 1 - Glossary

Term	Meaning
Having due regard	We should place an appropriate amount of weight on the need to prevent people being drawn into terrorism when we consider all the other factors relevant to how we carry out our functions.
Extremism	defined 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.
Interventions	are projects intended to divert people who are drawn into terrorist activity. Interventions can include mentoring, counselling, theological support, encouraging civic engagement, developing support networks (family and peer structures) or providing mainstream services (education, employment, health, finance or housing).
Non-violent extremism	is extremism, as defined above, which is not accompanied by violence
Prevention	reducing or eliminating the risk of individuals becoming involved in terrorism. Prevent includes but is not confined to the identification and referral of those at risk of being drawn into terrorism into appropriate interventions. These interventions aim to divert vulnerable people from radicalisation.
Radicalisation	the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups.
Safeguarding	the process of protecting vulnerable people, whether from crime, other forms of abuse or (in this context) from being drawn into terrorist-related activity.
Terrorism	defined by the Terrorism Act 2000, an action that endangers or causes serious violence to a person/people; causes serious damage to property; or seriously interferes or disrupts an electronic system. The use or threat must be designed to influence the government or to intimidate the public and is made for the purpose of advancing a political, religious or ideological cause.
Terrorist -related offences	those (such as murder) which are not offences in terrorist legislation, but which are judged to be committed in relation to terrorism.
Vulnerability	describes the condition of being capable of being injured; difficult to defend; open to moral or ideological attack. Within Prevent the word describes factors and characteristics associated with being susceptible to radicalisation.